REGIONAL HAZE 

 STATE IMPLEMENTATION PLAN 

FOR 

THE STATE OF ARIZONA 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDICES - VOLUME III

Appendix A-12 through Appendix A-18

Air Quality Division 

Arizona Department of Environmental Quality

 
List of Appendices Arizona Regional Haze SIP 

LIST OF APPENDICES

APPENDIX VOLUME I

APPENDIX A-1. BACKGROUND 

Appendix A-1a. Definitions 

Appendix A-1b. Arizona Department of Environmental Quality – Air Quality 

Division Organization Charts 

APPENDIX A-2. DESCRIPTIONS OF ARIZONA 

Appendix A-2a. Bibliography for Chapter 2 

APPENDIX A-5. ATTRIBUTABLE IMPAIRMENT 

Appendix A-5a. Arizona’s RAVI rule 

Appendix A-5b. Notification letters to FLMS on contact person, and Public 

Comment Period 

Appendix A-5c. Supporting Documents Related To The Promulgation Of 

Arizona’s RAVI Rule 

Appendix A-5d. New source review rule-R18-2-410 

APPENDIX A-6. CLEAN AIR CORRIDOR 

Appendix A-6a. WRAP Policy on Clean Air Corridors 

Appendix A-6b. WRAP Emission Tracking System and Assessment Process for 

the Clean Air Corridor 

APPENDIX A-7. STATIONARY SOURCES 

Appendix A-7a. Arizona Draft Western Backstop SO2 Trading Program Rule 

Appendix A-7b. Proposed WRAP 309 Coordinating Committee Charter 

Appendix A-7c. WRAP Report on Assessment of NOx/PM Strategies 

APPENDIX A-8. SO2 MILESTONES/BACKSTOP 

Appendix A-8a. WRAP Market Trading Forum Non-Utility Sector Allocation 

Final Report from the Allocations Working Group (November 

2002) 

Appendix A-8b. Western Emissions Backstop (WEB) Emissions & Allowance 

Tracking Systerm (EATS) Analysis 

Appendix A-8c. Recommendations for Making Additional Determinations in the 

Context of Reasonably Attributable BART 

APPENDIX A-9. MOBILE SOURCES 

Appendix A-9a. Arizona Mobile Source Work Group Findings and 

Recommendations Related to Mobile Source Emissions 
List of Appendices Arizona Regional Haze SIP 

LIST OF APPENDICES (Cont.)

APPENDIX VOLUME II

APPENDIX A-10. FIRE PROGRAMS 

Appendix A-10a. WRAP report “Assessing Status of Incorporating Smoke Effects 

into Fire Planning and Operation” 

Appendix A-10b. EPA’s “Interim Air Quality Policy on Wildland and Prescribed 

Fires” 

Appendix A-10c. Revised Arizona R18-2-602, “Unlawful Open Burning” and 

Article 15, “Forest and Range Management Burns” 

Appendix A-10d. Supporting Documents Related to the Promulgation of Revised 

Arizona R18-2-602, “Unlawful Open Burning” and Article 15, 

“Forest and Range Management Burns” 

Appendix A-10e. WRAP “Policy on Fire Tracking Systems” 

Appendix A-10f. WRAP report “Nonburning Alternatives for Vegetation and 

Fuel Management” 

Appendix A-10g. WRAP report “Burning Management Alternatives on 

Agricultural Lands in the Western United States” 

Appendix A-10h. WRAP report “Enhanced Smoke Management Programs for 

Visibility” 

Appendix A-10i. Arizona Revised Statute 49-501 

Appendix A-10j. WRAP report “Annual Emission Goals for Fire” 
List of Appendices Arizona Regional Haze SIP 

LIST OF APPENDICES (Cont.)

APPENDIX VOLUME III

APPENDIX A-12. POLLUTION PREVENTION 

Appendix A-12a. Arizona Pollution Prevention Work Group Review of WRAP 

Policy on Renewable Energy and Energy Conservation 

Appendix A-12b. Details of Renewable Energy Generation and Capacity 

Appendix A-12c. ICF Assessment of Renewable Energy and Energy 

Conservation Programs 

APPENDIX A-13. OTHER GCVTC OPTIONS 

Appendix A-13a. Arizona’s Assessment of Other Recommendations Of The 

Grand Canyon Visibility Transport Commission 

Appendix A-13b. Summary of Discussions with Federal Land Managers on 

Emissions In-and-Near the Four Arizona GCVTC Class I 

Areas 

APPENDIX A-14. PROJECTION OF VISIBILITY 

Appendix A-14a. Arizona Technical Review Memoranda of WRAP Emission 

Inventories and Technical Support Document 

Appendix A-14b. Summary of Emission Inventories used in WRAP Modeling 

APPENDIX A-18. PUBLIC PARTICIPATION 

Appendix A-18a. Notices of Public Hearings 

Appendix A-18b. Hearing Agendas, Sign-in Sheets, Transcripts, and 

Certifications 

Appendix A-18c. Written Comments Received During Comment Period 

Appendix A-18d. Responsiveness Summary 
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

APPENDIX A-12. POLLUTION PREVENTION

This appendix contains work products and references relied upon by Arizona in the 

development of Chapter 12 of the Regional Haze SIP. 
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

Appendix A-12a. Arizona Pollution Prevention Work Group Review of 

WRAP Policy on Renewable Energy and Energy 

Conservation
November 13, 2002

Jeff Burks

Utah Energy Office

Department of Natural Resources

1594 W. North Temple

Box 146480

Salt Lake City, UT 84114

R.T. "Hap" Boyd

GE Wind Energy

444 S. Flower Street, Suite 4545

Los Angeles, CA 98071

Dear Jeff and Hap:

The Arizona Regional Haze Pollution Prevention Workgroup (P2WG) would like to 

provide the following comments on the WRAP’s Air Pollution Prevention Forum’s 

renewable energy report, "Recommendations of Air Pollution Prevention Forum to 

Increase the Generation of Electricity from Renewable Resources." Items 1 – 10, 

below, are fairly general in nature and relate to the body of the Report. We have also 

included an attachment of comments that relate specifically to the Report’s Appendix 

A for Arizona.

The P2WG was very impressed with the report. The group greatly appreciated the 

wealth of information contained in the report and the fact that the report was one of 

the few that quantifies the costs and benefits of renewable energy. This type of 

information will be very useful to agencies promoting the use of renewable energy.

We do have a few specific comments and suggestions.

1. The report should include a statement or paragraph that certain economic factors 

referenced in the report (e.g., financial impact of incorporating various 

recommendations, differential costs of renewable energy) corresponding to a 

particular state could be significantly different from the regional estimates 

identified in the report. Adding an explanation in the report to clarify that the 

numbers are based on regional averages and must be tailored to each state for 

specific use would prevent confusion and erroneous expectations.
Letter to J. Burks and R. Boyd

RE: Renewable Energy Report Comments

November 13, 2002

Page Two

2. The Executive Summary should clarify that it will be difficult to meet the 10/20 

goals. Although such a statement is included on the bottom of page ii (“The 

10/20 goals are ambitious by any standard.”), it would be helpful to have an 

expanded explanation that the Regional Haze Rule has established the 10/20 goals 

as just that – goals. What is expected is a full and reasonable attempt to attain the 

goals and, if the goals aren’t met, an explanation of strategies used to make 

progress towards the goals. In addition, each state will be unique in its ability to 

meet or make progress towards the goals.

3. Page III-4: Arizona has adopted a Renewable Portfolio Standard, ACC R14-2-

1618.

4. Page IV-1: The Wisconsin report analysis numbers seem very generous, and the 

report does not have a reference for the cited figures. It would be helpful to add a 

citation for the Wisconsin report.

5. There appear to be inconsistencies about the cost of state agency renewable 

purchase requirement. Page III-17 of the report states a total cost of a 10% 

renewable purchase requirement at $4.2 million, based on an incremental cost of 

1.5 cents/kWh and an additional demand for 280,000 MWh. Page IV-15 makes a 

similar calculation and arrives at a cost of $37.5 million based on an incremental 

cost of 2.5 cents/kWh and an additional demand for 600,000 MWh.

6. The report states different incremental costs for renewable energy in different 

places. It would be helpful to achieve consistency whenever possible and to 

explain any remaining differences. In addition the report should provide a source, 

evaluation, or other justification for incremental costs presented and qualify that 

the costs are based on a regional average. The incremental cost for renewable 

energy for a particular state may vary significantly from the regional average.

7. The report appears to assume new natural gas or combined cycle is being 

replaced, but that may not be the case. 

8. Pages IV-11, 12: The report proposes that a state’s contribution to the regional 

goal should be based on that state’s energy consumption. This could be 

problematic for Arizona in that it could require us to rely on out-of-state 

renewable resources to meet that goal, which would dilute the state’s investment 

in its most abundant resource, solar energy. The report should clarify that there 

are other feasible approaches. 

9. Page IV-13: Principal 1 appears to be saying that the majority of State and Federal 

financial incentives should be directed at landfill gas, low-impact hydro and wind, 

and only a small percentage should be directed at solar. This could put our State 

at an economic disadvantage, as solar is our most abundant renewable resource. 

An alternative to this principle is that states should direct the majority of their 

financial incentives toward the resources that are viable and most abundant in that 
Letter to J. Burks and R. Boyd

RE: Renewable Energy Report Comments

November 13, 2002

Page Three 

state, thereby creating a greater diversity of renewable energy resources 

throughout the region.

10. Page I-14 says renewables will probably “supplant new gas fired generation.” In 

many cases, renewables may supplant the oldest and least efficient peaking power 

plants.

Thank you for the opportunity to comment on the report.

Sincerely,

Ursula Kramer

Director, PDEQ

cc: Lee Alter, Western Governors’ Association

Richard Tobin, II, Acting Director, ADEQ
Appendix Comments

Page I-14 states that renewable electricity will probably “supplant new gas-fired generation.” 

While this is generally true, during peak hours of the summer in Arizona, renewables, such as 

solar, that are operating during peak times (generally from 3 PM to 7 PM) will often supplant 

the use of the oldest and least efficient gas combustion turbines. These older peakers are 

much more polluting than the new combined cycle gas units and their delivered costs per 

kWh are extremely high, due to their inefficiency and relatively few hours of operation each 

year. It is important to recognize this fact when calculating pollution abatement and the cost 

differential between renewables and the older peakers. Some of the old peakers produce 

electricity in a cost range that can be equal to or higher than many renewable resource costs. 

The following comments relate specifically to the Arizona summary in Appendix A.

The Arizona Environmental Portfolio Standard was adopted after the date of the Draft 

Report. The following wording is suggested to replace the paragraph in the Draft Report:

Environmental Portfolio Standard

“In March 2001, the Arizona Corporation Commission approved rules implementing the 

Environmental Portfolio Standard, ACC R14-2-1618. The standard requires a minimum 

percentage of retail electricity sales to be from eligible solar electric or “environmentally 

friendly renewable electricity technologies.” The standard began with .2% in 2001 and rises 

to 1.1% in 2007. At least 50% of the portfolio standard must be solar electric in early years, 

increasing to 60% solar electric in 2004.”

Further information can be found at http://www.cc.state.az.us/utility/electric/R14-2-1618.htm

The following is an update for the various incentive programs offered in Arizona:

Arizona Public Service Projects

APS - Remote Solar Electric Services:

The Remote Solar Electric Services program was created by Arizona Public Service (APS) in 

1997. It is designed to provide solar power to off-grid residential customers (those located 

more than one-third mile from power lines). APS stand-alone systems are available for 

purchase and include photovoltaic (PV) panels, 120/240 VAC electronic power conditioning 

equipment, a battery bank that stores electricity for use at night, and a backup propane 

generator for extra power when needed. APS service and maintenance can be purchased for 

an additional annual fee. 

APS - Solar Partners Plus - EPS Credit Purchase Program

Arizona Public Service (APS) offers customers who install photovoltaic systems the 

opportunity to sell the credits associated with the energy generated by these systems to APS. 

These energy credits will be used to meet APS Environmental Portfolio Standards (EPS) 
requirements. Through the EPS Credit Purchase Program, participating customers receive a 

one-time EPS Energy Purchase Credit of $2.00 per watt of DC electricity (based on the 

manufacturer’s rating) for purchasing and installing a photovoltaic system capable of 

producing 5 kilowatts or less. 

For grid-tied systems rated at 5 kW or less: 

?? Customers must purchase a new photovoltaic solar system rated at 5 kW or less.

?? Installations must meet APS interconnection requirements. 

?? Customers must sign an interconnection agreement with APS.

?? The system must use UL-rated components and meet IEEE 929 specifications.

?? A licensed contractor must install the system.

?? The system generation must be metered separately and the kWh credits may, at APS' 

option, be recorded annually.

?? The meter (not provided by APS) must be placed adjacent to the existing meter and 

marked "solar meter". 

For remote systems rated at 5 kW or less:

?? The system must use UL components and meet IEEE 929 specifications.

?? A licensed contractor must install the system.

APS Solar Partner Green Power Program

In 1997, the City of Scottsdale joined the Arizona Public Service (APS) Solar Partners 

Program. At that time, the available role for the City was to provide facilities or land where 

APS, at no charge to them and no cost to the City, could install solar power generating 

systems. The solar power generated from these systems is added to the power grid where it 

became available for Scottsdale residents who subscribe to the Solar Partners Program. The 

first system installed was an 8,000 square-foot, 34-kW PV roofing system on employee 

parking lot carports at the City’s Via Linda Campus. The Civic Center Library and Mustang 

Library are each host to a 2-kW PV system. The Water Campus system is comprised of two 

150-kW single access tracking systems mounted on water storage reservoirs. The Water 

Campus system is the largest system of its type in the United States and is the first solar 

installation on a reservoir. 

APS expanded the Solar Partners Program to enable commercial enterprises and those 

partners whose facilities included APS solar power generating installations to purchase a 

portion of the solar power they generated. In June 2000, Scottsdale began an annual purchase 

of 40,500 kWh of solar energy for its Civic Center and Mustang Libraries. Other partners 

include KNXV TV (34,200 kWh annually) and ST Micro (36,000 kWh annually and who has 

hosted a 20kW installation at their Phoenix plant).

Net Metering

In 1981, the ACC adopted a net metering rule (Decision No. 52345) requiring the state’s 

regulated utilities to offer net metering for renewable and cogeneration resources with a 

capacity of 100 kilowatts or less. Excess electricity generated by the system is purchased at 
each utility’s avoided cost. 

No Arizona utility filed a net metering tariff until Arizona Public Service (APS) company 

filed in 1994 to allow net metering of all renewable energy generators under 10 kW. Net 

excess generation under the APS tariff is purchased at the utility’s avoided cost. Tucson 

Electric Power Company (TEP) filed two net metering tariffs in 1996. The first is Tariff 101 

applying to commercial customers, and Tariff 102 applies to all other customers. Under both 

tariffs, net metering is allowed for QFs 100 kW or smaller. Net excess generation is 

purchased at fixed seasonal rates. Commercial customers may receive 4.4¢/kWh May 

through October and 3.5¢/kWh for November through April. All other customers receive 

4.84¢/kWh May through October and 3.85¢/kWh November through April.

Tucson Electric Power Projects

Tucson - Solar Dividend

The City of Tucson has implemented a Solar Dividend investment policy in which the rate 

savings from restructuring are converted into a budget line item for solar energy investment 

for the municipality. Implemented in fiscal 2000, the policy will be in effect for five years.

For further information, refer to http://www.aps.com/my_community/solar_main.html.

TEP GreenWatts:

Launched in January 2000, GreenWatts is a TEP program that enables supporters to invest 

directly in the creation of “Green” power. For each GreenWatt that a customer adopts, 

Tucson Electric Power (TEP) will generate 20-kilowatt hours per month from renewable 

energy resources. The first GreenWatt is $2.00 and each additional GreenWatt is $1.50. This 

amount appears as a line item on a customer’s monthly statement. Every ten GreenWatts that 

are adopted save a ton of coal per year from being used and encourages environmental 

conservation in Southern Arizona. One hundred percent of the dollars raised go directly to 

building and maintaining renewable facilities in Arizona. The supply of GreenWatts is 

limited by the amount of “green” energy TEP produces. 

TEP SunShare:

Launched in 2002, TEP’s SunShare program is designed to encourage customers to install 

new photovoltaic equipment at their residence or business. TEP currently offers two options 

for those who are interested in investing in solar. SunShare, option #1, requires that 

customers provide their own photovoltaic equipment while SunShare Kit, option #2, requires 

that customers purchase the solar equipment from TEP. 

Under the SunShare programs, systems of 1 kW to 5kW are eligible. The customer may 

either purchase a qualifying system 1 kW or larger from a third party or may purchase a 1-

kW or 5-kW system kit from TEP. 

Under SunShare, option #1, TEP will credit the customer $2,000 per AC kW of proven, 

installed solar generating capacity. Under the SunShare Kit, option #2, TEP will credit the 

customer $2,000 for the 1 kW system and up to $10,000 for the 5 kW system. The kit 
includes panels, inverter, supports, meter, and meter socket. The retail cost for a 1 kW solar 

kit is approximately $9,000 plus installation costs. However, a kit purchased from TEP will 

cost $4000 after the $2000 credit. TEP also offers a net metering option which credits the 

customer with the energy sent into the grid on a kWh basis. 

To qualify for the buy down program, participants must: 1) be a customer of TEP; 2) have at 

least 550-sq. ft. of unobstructed space; 3) have a roof facing true south; 4) be within 100 ft of 

where tying to the grid; and 5) have a roof that can accommodate panels at a 32-degree angle. 

Installations must have been made after January 1, 1997. Annual inspections and 

maintenance labor for repairs will be provided by TEP. The PV equipment must meet TEP 

and Arizona Corporation Commission requirements for self-generation equipment.

ARIZONA REVISED STATUTES 

Solar and Wind Energy Systems Tax Credit, ACC R14-2-1618:

Provides a personal income tax credit of 25% of the cost of a solar or wind energy device. A 

credit of up to $1,000 can be claimed the year the system is installed. If the credit exceeds a 

taxpayer’s liability in that year, the unused portion of the credit may be carried forward for 

up to five years. A taxpayer may claim the credit under this section only once in a tax year 

and may not accumulate over different tax years tax credits under this section exceeding, in 

the aggregate, one thousand dollars for the same residence. Qualifying technologies include 

passive solar heating, active solar space heating, solar water heating, photovoltaics, and wind 

systems. Passive systems shall clearly be designed as a solar energy device, such as a trombe 

wall, and not merely as a part of a normal structure, such as a window.

Solar and Wind Energy Equipment Tax Exemption:

Provides a sales tax exemption to retail businesses of up to $5,000 for solar and wind energy 

equipment. Qualifying equipment includes passive solar heating, active solar space heating, 

solar water heating, photovoltaics, wind electric generators, and wind-powered water pumps. 

Passive systems shall clearly be designed as a solar energy device, such as a trombe wall, and 

not merely as a part of a normal structure, such as a window. Before deducting any amount 

under this exemption, the retailer shall register with the department as a solar energy retailer. 

By registering, the retailer acknowledges that it will make its books and records relating to 

sales of solar energy devices available to the department for examination.
The following is a fact sheet from Salt River Project’s Environmental Initiative:

Salt River Project’s 

Environmental Initiative

In February 2000, SRP initiated a four-year, $29 million program to fund a renewable energy 

program. This significant investment in the future was made without raising the standard 

electricity rates of SRP customers. SRP is taking steps to establish renewable energy 

programs that help protect the environment and provide reassurance for today’s families and 

future generations.

Assessing Clean Technologies

EarthWise Energy is the first green power program in Arizona that offers a diverse mix of 

local renewable energy sources. Participating SRP customers make a small additional 

payment on their monthly electric bill to help support our effort to build, operate and 

maintain new renewable electric generating stations. These new facilities will further 

improve the quality of the air in the Salt River Valley and reduce our dependence on nonrenewable fuels.

EarthWise Energy uses a variety of “clean” technologies to achieve the greatest cost 

effectiveness and environmental benefits for SRP and its customers.

Under this new program, we have completed a 200-kilowatt solar power plant in Glendale 

and are pursuing other opportunities for solar generation. We have also installed a 4,000-

kilowatt (four megawatt) generation facility on the Salt River Pima Maricopa Indian 

Community that uses landfill gas from the Tri-Cities Landfill. This plant will produce enough 

electricity to power 2000 homes for one year. By capturing this naturally occurring gas and 

converting it to energy, we are improving community safety and the environment (methane is 

explosive and is a suspected global warming agent).

SRP’s newest project, Arizona Falls, is a low impact hydro facility located on a canal at 56th

Street and Indian School in Phoenix. The power of the 20-foot drop in elevation in the canal 

will be used to generate 750-kilowatts of clean energy.

Implementing The Program

SRP established an operations committee to implement the renewable energy program. The 

committee is responsible for program design, implementation, budget, administration, 

management and measurement.

The program will proceed with these goals:

?? Develop a market for renewable and sustainable energy sources.

?? Demonstrate the ability of renewable technologies to improve air quality.

?? Build community and public relationships to showcase renewable energy technologies.

?? Establish SRP as a national leader in renewable energy.

?? Demonstrate fiscal stewardship.
Involving The Public

In addition to encouraging customers to participate in the program, we have formed a 

Customer Support Group to help us with program development and evaluation, and to assist 

in communicating program messages to the community.

This committee consists of 30 residential, commercial and industrial customers, educators, 

media representatives, elected officials and government officials. 

We have also formed a Technical Advisory Committee of industry experts to review and 

evaluate new and existing renewable technologies, and to provide technical expertise in our 

program development.

Through a public process, SRP will review the program during its fourth year to determine if 

the stated goals were met and the future direction of its renewable energy activities.

More than 3,000 residential customers participate in the program by paying an additional 

$3/per month for a 100-kwh block of energy. In addition, 45 small commercial customers 

participate in this program, and a new large governmental customer, Maricopa County is 

purchasing the largest amount of green energy in the state.
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

Appendix A-12b. Details of Renewable Energy Generation and Capacity
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

Appendix A-12b. Details of Renewable Energy Generation and Capacity 

Pursuant to 51 CFR 309 (d) (8) (i), The Table below summarizes all renewable energy generation capacity and 

production in use or planned as of 2002. 

Project # SYSTEM 

Year 

Installed 2002 kW 

Planned 

kW KWh in 2002 Source

 

Solar APS Installations 

 Flagstaff 82 kW 1997 80 80 168,026 1 

 Rooftop Demos 1997 4 4 7,560 1 

 RSES 1997 6 6 11,340 1 

 Ocotillo #1 1998 80 80 167,980 1 

 RSES 1998 7 7 13,230 1 

 Ocotillo #2 1999 93 93 195,447 1 

 San Luis 1999 2 2 3,780 1 

 Deer Valley School 1999 4 4 7,560 1 

 Gilbert High School 1999 2 2 3,780 1 

 NAU 1999 2 2 3,780 1 

 Scottsdale Library 1999 2 2 3,780 1 

 Tempe Recycling 1999 2 2 3,780 1 

 Scottsdale Parking 1999 34 34 0 1 

 Glendale #1 1999 78 78 156,897 1 

 STAR Parking 1999 4 4 5,058 1 

 STAR Dishes 1999 40 40 301 1 

 RSES 1999 19 19 35,910 1 

 STAR Amonix - 2, 3, 4 2000 60 60 116,905 1 

 ST Micro 2000 22 22 32,260 1 

 SOL 2000 10 10 18,900 1 

 RSES 2000 5.5 5.5 10,395 1 

 Gilbert 2001 122 122 257,760 1 

 Glendale #2 2001 100 100 178,508 1 

 Prescott 2001 194 194 445,920 1 

 STAR Tilted Trackers 2001 60 60 125,191 1 

 STAR Amonix - 1, 5, 7 2001 75 75 141,897 1 

 RSES 2001 14.6 14.6 27,518 1 

 Yucca 2002 103 103 222,640 1 

 Ocotillo East Yard 2002 125 125 129,200 1 

 Mustang Library - Scottsdale 2002 2 2 1,890 1 

 Ocotillo Parking 2002 20 20 23,276 1 

 Gray Wolf Landfill 2002 24 24 911 1 

 Scottsdale Water #1 2002 131 131 206,800 1 

 Scottsdale Water #2 2002 125 125 193,440 1 

 ADEQ Parking Canopy 2002 127 127 0 1 

 STAR Amonix - 6 2002 35 35 5,672 1 
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

 Prescott Airport 2002 734 734 30,310 1 

 RSES 2002 8.32 8.32 7,862 1 

TOTAL 2,556 2,556 2,965,465

Solar Tucson Electric Power 

 Habitat Home 1999 0.75 0.75 2,783 2 

 Reid Park Zoo 2000 0.84 0.84 3,661 2 

 Pima Air Museum 2000 0.9 0.9 2,660 2 

 Stafford Middle School 2000 4.5 4.5 17,684 2 

 U of A agricultural Station 1996 5.62 5.62 9,280 2 

 Hayden / Udall #1 2002 21.6 21.6 12,092 2 

 Hayden / Udall #2 2002 21.6 21.6 12,092 2 

 Fort Huachuca 1997 30 30 109,427 2 

 Utility TEP Trailers 1998 3.97 3.97 20,771 2 

 Gate 2 Solarex Panels 2000 2.31 2.31 11,328 2 

 OH3 2000 21.6 21.6 74,778 2 

 OH4 2000 21.6 21.6 74,822 2 

 Springerville 2000 21.6 21.6 75,715 2 

 St. John's Test 2000 1.5 1.5 3,512 2 

 DMP1 2000 108 108 345,118 2 

 DMP2 2000 108 108 337,002 2 

 SGS C1 2001 135 135 293,297 2 

 SGS C2 2001 135 135 304,365 2 

 SGS C3 2001 135 135 266,390 2 

 SGS C4 2001 135 135 256,246 2 

 SGS C5 2001 135 135 245,376 2 

 SGS C6 2001 135 135 241,712 2 

 SGS C7 2002 135 135 93,479 2 

 SGS C8 2002 135 135 101,674 2 

 SGS C9 2002 135 135 101,757 2 

 SGS C10 2002 135 135 70,069 2 

 SGS C11 2002 135 135 127,121 2 

 SGS C12 2002 135 135 103,941 2 

 SGS TF1 2001 135 135 268,258 2 

 SGSTF2 2001 135 135 180,655 2 

 SGS TF5 2001 129 129 269,654 2 

 SGS TF6 2001 129 129 289,309 2 

 SGS TF7 2001 129 129 266,225 2 

 SGSTF8 2001 129 129 265,986 2 

 OH SB/ASE Test 2002 1.1 1.1 2,158 2 

 OH Tc/ASE Test 2002 0.8 0.8 1,109 2 

 OH/TC/BP Test 2002 1.2 1.2 1,850 2 

 Tohono Chul 2002 2.8 2.8 310 2 

 Global Solar Test 2002 1.4 1.4 52 2 
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

 BP 1.4 Xtal Test 2002 1.4 1.4 55 2 

 SunShare 29 Units 2002 61.3 61.3 41,457 2 

TOTAL 2,850 2,850 4,905,230

Solar Salt River Project 

 

South Mountain Community 

College 1998 1.8 3,311 5 

 Scottsdale Community College 2000 1 1,850 5 

 Cesar Chavez High School 2000 1 1,850 5 

 Chandler Research House 1997 2.4 4,415 5 

 Palomino Residence 1998 1 1,850 5 

 Calex Homes Johnson Ranch 2001 1 1,850 5 

 Calex Homes Johnson Ranch 2001 0.85 1,564 5 

 Calex Homes Johnson Ranch 2001 1 1,850 5 

 Calex Homes Johnson Ranch 2001 0.7 1,288 5 

 Calex Homes Johnson Ranch 2001 1.4 2,575 5 

 Calex Homes Gold Canyon 2002 0.5 920 5 

 ASU East 2002 1 1,850 5 

 Agua Fria PV 2001 200 431,000 5 

 Roger Solar Park PV1 and PV2 2003 200 0 5 

 Rogers Solar Park PV3 2003 200 0 5 

 Tempe Warehouse 2003 200 0 5 

 City of Phoenix Park & Ride 2003 100 0 5 

City of Mesa Red Mountain 

Branch Library 2003 25 0 5 

TOTAL 214 725 456,173 

 

Solar LAW Fund/Native Sun 

2001 Purchases 1997 4.473 4.473 8,454 1 

 1998 6.491 6.491 12,268 1 

 1999 1.251 1.251 2,364 1 

 2000 0.384 0.384 726 1 

 2001 0.150 0.150 284 1 

2002 Purchases 1997 4.511 4.511 1 

 1998 1.354 1.354 1 

 1999 0.128 0.128 1 

 2000 0.000 0.000 1 

 2001 0.053 0.053 1 

 2002 14.270 14.270 1 

 TOTAL 17.260 17.260 24,096

 

Solar Customer Programs 

2002 Systems 2002 28.85 28.85 27,263 1 

 TOTAL 28.85 28.85 27,263 
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

Solar Yuma Proving Grounds 

 450 System 1997 450 450 897,000 1 

 SWTR Site 1998 105 105 198,450 1 

 Signs 1999 0.00 0.00 2 1 

 Lights 1999 0.20 0.20 1,752 1 

 Jog Path 2000 0.09 0.09 166 1 

TOTAL 555 555 1,097,370

Solar ORC Trough 

 1MW trough plant 2004 0 1 

TOTAL 00 0

Solar IST 

 Prison Water System 1999 1,104,167 1 

TOTAL 0 0 1,104,167

 

Methane 

TEP Landfill methane 1999 5,500 5,500 45,000,000 1 

 Butterfield Landfill Methane 2003 70 1 

 Mesa NW Water Treatment Plant 1 

Allied Waste Apache Junction 

Landfill 1 

Tri-Cities Landfill Generation 

Plant 2001 4,000 4,000 18,715,000 3 

TOTAL 9,500 9,570 63,715,000

 

Wind Army Depot (Wind) 

 Wind Turbine 1 

 TOTAL 0 0 

 

Wood Chips Environmental Forest 

 Wood chips 2003 3,000 0 1 

 TOTAL 0 3,000 0 

 

Low Impact 

Hydro Salt River Project 

 Arizona Falls Project 2003 750 3 

 Total 0 750 0 

 
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

Sub-Totals 

Existing & 

Planned

SOLAR 6,222 6,733 10,579,764

METHANE 9,500 9,570 63,715,000

WIND 0 0 0

WOOD CHIPS 0 3,000 0

LOW-IMPACT HYDRO 0 750 0

 TOTAL 15,722 20,053 74,294,764 

 

Sources 

1 Information from the Arizona Corporation Commission Environmental Portfolio Tracking March 

2002. 

2 Information from the Arizona Corporation Commission Environmental Portfolio Tracking March 

2002, Tucson Electric Power Photovoltaic Systems Installed and In Service at the End of 2002. 

3 See generally http:///www.srpnet.com/environmental/comparison.asp and linked from that page. 

4 "Overview of SRP'S Renewable Energy Program," Presentation by Herjinder Hawkins to PPWG on 

March 24, 2003. 

5 Information from Renewable Energy Program files 

 
Appendix A-12 – Pollution Prevention Arizona Regional Haze SIP

Appendix A-12c. ICF Assessment of Renewable Energy and Energy 

Conservation Programs
 

REPORT 

Economic Assessment of Implementing 

the 10/20 Goals and Energy Efficiency 

Recommendations 

Prepared for 

Western Regional Air Partnership 

Air Pollution Prevention Forum 

Prepared by 

ICF Consulting Group 

October 2002
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 i 

Executive Summary........................................................................................................... iv 

I. Introduction .................................................................................................................... 1 

II. Overview ........................................................................................................................ 2 

II.1 Background .............................................................................................................. 2 

II.2 Objective .................................................................................................................. 2 

II.3 Summary of Key Findings ....................................................................................... 3 

III. Analytical Approach ..................................................................................................... 5 

III.1 Scenarios Analyzed................................................................................................. 6 

III.2 Analytical Tool ....................................................................................................... 8 

III.3 Data and Assumptions .......................................................................................... 15 

IV. Emissions and Production Costs Impacts................................................................... 26 

IV.1 Key Elements Under the Business-As-Usual (BAU) Scenario ............................ 26 

IV.2 Electric System Capacity and Generation Impacts............................................... 28 

IV.3 Production Costs Impacts ..................................................................................... 31 

IV.4 Emissions Impacts ................................................................................................ 34 

IV.5 Impact on the Regional Backstop SO2 Trading Program ..................................... 35 

IV.6 Wholesale Electricity Price Impacts..................................................................... 36 

V. Secondary Regional Economic Impacts ..................................................................... 41 

VI. Caveats and Uncertainties.......................................................................................... 43 

VII. Conclusions .............................................................................................................. 45 

Appendix I: Regional Economic Impacts........................................................................ 47 

Appendix II: Energy Efficiency Analysis and Methodology .......................................... 50 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 ii 

Preface 

Regulatory Framework for Tribal Visibility Implementation Plans

The regional haze rule explicitly recognizes the authority of tribes to implement 

the provisions of the rule, in accordance with principles of federal Indian law, and 

as provided by the Clean Air Act §301(d) and the tribal authority rule (TAR) (40 

CFR §§49.1– .11). Those provisions create the following framework: 

1. Absent special circumstances, reservation lands are not subject to state 

jurisdiction. 

2. Federally recognized tribes may apply for and receive delegation1

 of federal 

authority to implement CAA programs, including visibility regulation, or 

"reasonably severable" elements of such programs (40 CFR §§49.3, 49.7). 

The mechanism for this delegation is a tribal implementation plan (TIP). A 

reasonably severable element is one that is not integrally related to program 

elements that are not included in the plan submittal, and is consistent with 

applicable statutory and regulatory requirements. 

3. The regional haze rule expressly provides that tribal visibility programs are 

“not dependent on the strategies selected by the state or states in which the 

tribe is located” (64. Fed. Reg. 35756), and that the authority to implement 

§309 TIPs extends to all tribes within the GCVTC region (40 CFR 

§51.309(d)(12)). 

4. The EPA has indicated that under the TAR tribes are not required to submit 

§309 TIPs by the end of 2003. Rather, they may choose to opt-in to §309 

programs at a later date (67 Fed. Reg. 30439). 

5. Where a tribe does not seek delegation through a TIP, EPA, as necessary 

and appropriate, will promulgate a federal implementation plan (FIP) within 

reasonable timeframes to protect air quality in Indian country (40 CFR 

§49.11). EPA is committed to consulting with tribes on a government-togovernment basis in developing tribe-specific or generally applicable TIPs 

where necessary (See, e.g., 63 Fed. Reg. 7263-64). 

The amount of modification, if any, needed for this report to fulfill tribal needs may vary 

considerably from tribe to tribe. The authors have striven to ensure that all references to 

tribes in the document are consistent with principles of tribal sovereignty and autonomy 

as reflected in the above framework. Any inconsistency with this framework is strictly 

inadvertent and not an attempt to impose requirements on tribes which are not present 

under existing law. 

 

1 Tribes also possess a more fundamental source of authority to regulate their environments, 

based on their inherent authority as sovereign nations, which predates the formation of the United 

States. However, in the context of air pollution regulation and visibility planning in particular, tribal 

authority will more likely be based on delegation of federal authority.
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 iii 

Tribal Participation in the WRAP

Tribes, along with states and federal agencies, are full partners in the WRAP, having 

equal representation on the WRAP Board as states. Whether Board members or not, it 

must be remembered that all tribes are governments, as distinguished from the 

“stakeholders” (private interest) which participate on Forums and Committees but are not 

eligible for the Board. 

Despite this equality of representation on the Board, tribes are very differently situated 

than states. There are over four hundred federally-recognized tribes in the WRAP 

region, including Alaska. The sheer number of tribes makes full participation impossible. 

Moreover, many tribes are faced with pressing environmental, economic, and social 

issues, and do not have the resources to participate in an effort such as the WRAP, 

however important its goals may be. These factors necessarily limit the level of tribal 

input into and endorsement of WRAP products. 

The tribal participants in the WRAP, including Board members Forum and Committee 

members and co-chairs, make their best effort to ensure that WRAP products are in the 

best interest of the tribes, the environment, and the public. One interest is to ensure that 

WRAP policies, as implemented by states and tribes, will not constrain the future options 

of tribes who are not involved in the WRAP. With these considerations and limitations in 

mind, the tribal participants have joined the state, federal, and private stakeholder 

interests in approving this report as a consensus document. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 iv 

Executive Summary 

With a view towards improving visibility and air quality in the national parks and 

wilderness areas of the Colorado plateau, the Grand Canyon Visibility Transport 

Commission (GCVTC) issued several recommendations in 1996 on strategies for air 

pollution prevention. In its recommendations, the GCVTC emphasized the need to 

integrate air pollution prevention with cost-effective pollution control strategies in order to 

prevent degradation of natural resources in the West.1

 

Two key recommendations from the GCVTC focused on the development of renewable 

energy sources and the promotion of energy conservation. Labeled the “10/20 goals”, 

the recommendation on development of renewable energy sources encouraged states 

and tribes in the Transport Region to undertake steps that would increase the use of 

renewable energy to 10 percent of the regional power needs by 2005 and 20 percent of 

the regional power needs by 2015. For energy conservation, the commission supported 

the continued development of energy efficiency standards and suggested that the 

emphasis on energy conservation be maintained within the changing electric power 

markets. In addition to the 10/20 goals and energy conservation recommendations, the 

GCVTC suggested that future modeling work be conducted to analyze the potential 

emission reductions, cost savings and secondary benefits associated with the use of 

renewable energy, energy efficiency and pollution prevention. 

The Regional Haze Rule issued by the US Environmental Protection Agency in April 

1999 included the air pollution prevention recommendations of the GCTVC. Under the 

rule, the states of the Transport Region must include in their State Implementation Plans 

(SIP) an outline of the programs and policies that each state will rely on to work towards 

meeting the air pollution prevention recommendations. Tribal governments may seek 

approval from EPA to incorporate the requirements of the regional haze regulations, 

including the GCVTC recommendations, in their Tribal Implementation Plans (TIP) under 

the provisions of the Tribal Authority Rule (TAR). 

The Air Pollution Prevention (AP2) forum of WRAP has been charged with implementing 

the air pollution prevention recommendations of the GCVTC. The AP2 forum 

commissioned ICF Consulting to analyze the potential emissions reductions, costs and 

secondary regional economic impacts of meeting the 10/20 goals and energy efficiency 

recommendations. 

This study documents the analytic and technical support to the AP2 forum’s report 

detailing its recommendations regarding renewable energy and energy efficiency to the 

WRAP Board. The AP2 forum’s report provides a discussion of the policy imperatives 

and broader implications of the GCVTC air pollution prevention recommendations, while 

this report describes the emissions reductions, costs and secondary economic impacts 

of meeting the 10/20 goals and implementing the energy efficiency recommendations, 

given the assumptions and scenarios developed by the AP2 forum. The analysis 

examines the impacts for the nine states and tribal lands of the Transport region and 

was focused around stationary sources engaged in the production of electricity and 

 

1

 “Recommendations for Improving Western Vistas,” The Grand Canyon Visibility Transport 

Commission, June 1996, page 28. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 v 

industrial steam along with and process-related SO2 sources such as refineries and 

smelters. 

Analytical Framework 

The AP2 forum developed a three-phase analytical framework to assess the potential 

emissions reduction, costs and secondary regional economic impacts of implementing 

the 10/20 goals and energy efficiency recommendations. These included: (1) 

assumptions and scenario development, (2) modeling of the electric, steam and process 

source sectors, and (3) modeling of the secondary regional economic impacts. 

The AP2 forum developed two types of scenarios in order to examine the emissions, 

costs and secondary regional economic impacts of meeting the 10/20 goals and 

implementing the energy efficiency recommendations. The first was the Business-AsUsual (BAU) scenario that characterized how the future might unfold with the proposed 

regional backstop SO2 trading program but without any policy measures designed to 

accomplish the 10/20 goals and energy efficiency recommendations. The second set of 

scenarios reflected a future with the regional backstop SO2 trading program and policy 

drivers designed to meet the 10/20 goals or energy efficiency recommendations, or both. 

Assessments of emissions, costs and secondary regional economic impacts were 

estimated by analyzing the changes in the policy scenarios relative to the BAU scenario. 

The AP2 forum selected as the business-as-usual scenario the Annex cap-and-trade 

scenario developed by the WRAP/Market Trading Forum (MTF)2

 for its economic 

analysis, with minor modifications to account for the planned additions to renewable 

energy capacity. The policy scenarios developed by the AP2 forum were focused 

around objectives of implementing the 10/20 goals and energy efficiency 

recommendations with some additional scenarios designed to analyze the sensitivity of 

the results to higher gas prices and improvements in renewable energy technology cost 

and performance. 

In designing the policy scenarios and in developing the data for those scenarios, the 

AP2 forum modified some of the assumptions on the cost and performance of renewable 

energy technologies from those used in the MTF Annex scenario. The AP2 recognized 

that the 10/20 goals had the potential to not only affect the level of renewable energy 

generation in the West, but would also had to potential to influence the underlying 

market conditions for those technologies. Under a climate where policies are in place 

designed to achieve the 10/20 renewable energy goals and energy efficiency 

recommendations, the AP2 forum believes that the wind resource development costs 

could improve over time because of the cost benefits of “learning by doing”, because of 

better alignment of incentives for improving technologies’ cost and performance and 

because of reduced barriers to entry. 

The adjustments in the assumptions for the policy scenarios were focused only around 

wind technologies because wind was likely to be the largest renewable energy and it 

was resource also where the forum anticipated most improvements in cost and 

performance would occur. However, recognizing the uncertainty inherent in such 

 

2

 “Economic Impacts of Implementing a Regional SO2 Emissions Program in the Grand Canyon 

Visibility Transport Region,” Western Regional Air Partnership/ Market Trading Forum, 

September 2000. (MTF 2000). 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 vi 

assumptions about technology improvements, the AP2 forum developed a sensitivity 

scenario to test the cost implications of implementing the 10/20 goals without the 

assumed improvements in renewable technology cost and performance. 

In Phase II of the analysis, ICF Consulting’s Integrated Planning Model (IPM®) was used 

as the analytical tool for modeling the costs and emissions impacts of the policy 

scenarios. IPM simulates productions activity in the electricity generation and industrial 

steam production markets using an integrated view of fuel, emissions, capacity and 

generation markets. Results from IPM served as inputs to modeling of the secondary 

regional economic impacts in Phase III of the analysis. The Policy Insights model 

produced by Regional Economic Models Inc. (hereafter referred to as REMI) was used 

as the analytical tool for estimating the secondary regional economic impacts. 

Emissions Reductions and Cost Impacts

The 10/20 goals require renewable energy to satisfy 10 percent of the regional energy 

needs by 2005 and 20 percent of the regional energy needs by 2015. The energy 

efficiency recommendations developed by the AP2 forum calls for electricity demand 

reductions in the Transport Region to grow to 8 percent of the electricity generation 

demand by 2018. The analysis indicates that both these policy objectives could serve 

as cost-effective air pollution prevention strategies because they provide opportunities 

for emissions reductions at modest costs or with some savings. 

Because the assessment of impacts are based on analysis of the differences between 

the policy scenarios and the BAU scenario, some notable elements of the BAU scenario 

are described below to provide a helpful context for understanding the results. One of 

the most important components of the BAU scenario driving the results is the growth of 

gas-fired generation capacity. Under the BAU scenario, the growth in electricity demand 

is met by additions of new gas-fired combined cycle capacity. As illustrated in Figure 

ES-1 below, almost 30 GW of new combined cycle capacity is projected under the BAU 

scenario by 2018. This represents 80 percent of the growth in capacity additions and 

accounts for 37 percent of all generation in the Transport Region in that year. 

Figure ES-1: Capacity Additions Under the BAU Scenario3

 

 

3

 O/G steam & Turbines refers to Oil/Gas Steam and Gas Turbines; combined cycles refer to gas-fired 

combined cycles and cogeneration refers to combined heat and power. 

-

5,000

10,000

15,000

20,000

25,000

30,000

35,000

2005 2010 2018

Capacity Additions by 2018 (MW)

Coal

O/G Steam & Turbines

Combined Cycles

Renew ables

Cogeneration
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 vii 

The mix of generation and capacity additions under the BAU scenario has important 

implications both for the growth in emissions under the BAU scenario and the potential 

for emissions reductions from the 10/20 goals and energy efficiency recommendations. 

Because generation from new gas capacity is assumed to be relatively clean, NOx

emissions under the BAU scenario remains relatively changed between 2005 and 2018, 

growing by 1 percent to 606 thousand tons in 2018. During that same period, the NOx

emissions rate for oil/gas units declines from 0.2 lbs/MWh in 2005 to 0.05 lbs/MWh, 

reflecting the projected turnover to newer efficient combined cycle generation. 

As a result of increased fossil fuel generation, CO2 emissions under the BAU scenario 

increases by 19 percent between 2005 and 2018 to 401 million metric tones. SO2

emissions under the BAU scenario is held to the regional targets specified in the Annex 

because the scenario includes the assumptions that the regional SO2 trading program 

proposed under the Annex will be in place. Because of the SO2 cap-and-trade program, 

none of the policy scenarios will result in any changes in SO2 emissions. 

Implementation of the 10/20 goals and energy efficiency recommendations will lead to 

significant growth in renewable energy capacity, totaling 20 GW by 2018. The growth 

reflects the requirements of the 10/20 goals and the assumption that the policy climate of 

the 10/20 goals may better align incentives to spur the improvements in renewable 

technology cost and performance through accelerated learning by doing and by easing 

some of the barriers to entry for renewable energy. Figure ES-2 below summarizes the 

growth in renewable energy capacity under the 10/20 goals and Figure ES-3 below 

contrasts the generation mix in 2018 between the BAU and 10/20 goals policy scenario. 

38%

3% 18%

5%

8%

17%

11%

Coal

O/G Steam & Turbines

Combined Cycles

Renewables

Cogens

Hydro

Nuclear

31%

0%

37%

4%

8%

14%

6%

Generation Mix Under BAU 

2005

543 thousand GWh 

2018

680 thousand GWh 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 viii 

Figure ES-2: Renewable Energy Capacity Additions Under the 10/20 Goals 

0

5

10

15

20

25

Wind Geothermal Landfill Gas

Capacity Additions by 2018 (GW)

Figure ES-3: Generation Mix in 2018 Under the BAU and 10/20 Goals 

As illustrated in Figures ES-2 and ES-3, wind power dominates most of the growth in 

new renewable capacity and the increased use of renewable energy displaces new gasfired generation. While these results illustrate only the impact for the 10/20 goals, similar 

impacts occurs with increased use of energy efficiency. The important results in 

capacity changes of the 10/20 goals and energy efficiency is that new renewable energy 

capacity and energy conservation compete against new conventional capacity while 

leaving the existing electricity generation stock relatively undisturbed. 

The fact that the renewable energy and energy efficiency are likely to compete against 

generation from new gas-fired capacity affects the emissions reductions projected under 

the 10/20 goals and energy efficiency recommendations. As illustrated in Figure ES-4 

below, the analysis indicates that under the 10/20 goals and energy efficiency, the 

potential savings in NOx emissions are likely to range between 8,000 tons and 14,000 

tons (or 1 percent to 2 percent relative to the BAU). In Figure ES-4 below, the bars 

labeled “10/20 goals” represents the policy scenario with the 10/20 goals, “EE” 

31%

0%

37%

4%

8%

14%

6%

29%

0%

4% 26%

7%

14%

6%

14%

Coal

O/G Steam & Turbines

Combined Cycles

Existing Renewables

Cogens

Hydro

Nuclear

New Renewables
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 ix 

represents the policy scenarios with the energy efficiency recommendations and “EE + 

10/20 goals” represents the policy scenario with both the 10/20 goals and the energy 

efficiency recommendations. 

Figure ES-4: Potential NOx Emissions Reductions Under the 10/20 Goals and 

Energy Efficiency Recommendations 

 

 

Implementation of the 10/20 goals and energy efficiency recommendations also lead to 

reductions in CO2 emissions through displaced fossil fuel generation. As illustrated in 

Figure ES-5, CO2 emissions savings in 2018 from meeting the 10/20 goals and 

implementing the energy efficiency recommendations is projected to range between 40 

million metric tones and 55 million metric tones (or 10 percent to 14 percent relative to 

the BAU). 

Figure ES-5: Potential CO2 Emissions Reductions Under the 10/20 Goals and 

Energy Efficiency Recommendations 

-

10

20

30

40

50

60

Change in CO

2005 2010 2015 2018

2 Emissions Relative to BAU 

(Million Metric Tonnes of CO2)

10/20 Goals

EE

EE + 10/20 Goals

-

2

4

6

8

10

12

14

16

Change in NO

2005 2010 2015 2018

x Emission Relative to BAU 

(Thousands Tons of NOX)

10/20 Goals

EE

EE + 10/20 Goals
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 x 

Though the emissions reduction potential for NOx and CO2 appears to be modest, it is 

important to recognize the source of those reductions and the implications for air 

pollution prevention. Because these emissions reductions come from new generating 

sources, the 10/20 goals and energy efficiency recommendations provide opportunities 

to hedge against future emissions growth. 

Implementation of the 10/20 goals and energy efficiency scenarios does not reduce SO2

emissions because of the regional SO2 trading program proposed under the Annex. 

However, because the trading program creates a monetary value for emissions 

reductions, any potential for emissions reductions is fully offset by increases in SO2

emissions from sources affected by the trading program. In other words, with the 10/20 

goals and energy efficiency, the level of SO2 emissions in 2013 and 2018 will remain 

unchanged from the emissions caps specified by the Annex. The 10/20 goals and 

energy efficiency could, however, decrease the compliance cost of the SO2 trading 

program by as much as $ 7 million (or 10 percent of projected compliance cost4

) in 2018 

and could displace 1,200 MW to 1,700 MW of new scrubber capacity by 2018. 

In addition to the potential emissions savings, implementation of the10/20 goals and 

energy efficiency recommendations could be achieved through modest production cost 

or with some savings. In particular, implementation of the energy efficiency 

recommendations leads to net annual levelized production costs5

 savings of $750 million 

to $1 billion (or 4 percent to 7 percent relative to the BAU scenario). These net savings 

reflect the cost of implementing the recommendations, the avoided investment costs of 

transmissions and distribution, and the reductions in electricity and steam production 

costs resulting from lower electricity demand. Figure ES-6 compares the production cost 

across the BAU and energy efficiency policy scenarios. 

Figure ES-6: Annual Levelized Production Cost Under the BAU and Energy 

Efficiency Policy Scenarios 

$16.4 $16.7 $17.4

$0

$5

$10

$15

$20

BAU EE EE + 10/20 Goals

Annual Levelized Production Costs (Billion 2001$)

 

4

 MTF 2000. 

5

 Annual levelized production costs reflect the capital, fuel and operation and maintenance 

expenditures associated with the production of electricity and industrial steam levelized over the 

years 2005 – 2022. These modeled production costs do not include the sunk costs (capital cost 

or carrying charges) of existing units. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 xi 

Implementation of the10/20 goals by themselves will lead to modest increases in annual 

levelized production costs. The impact on production costs could range between $300 

million and $900 million (or 2 percent to 5 percent relative to the BAU scenario). The 

range reflects the impacts under alternative assumptions about renewable technology 

cost and performance: the former includes the assumption that renewable technology 

cost and performance will improve over time, while the latter cost impacts do not allow 

for those improvements. The increase in production costs under the 10/20 goals is 

largely driven by the capital investments in new renewable energy generation capacity 

and is offset by the production cost savings from the displaced fossil fuel generation. 

Figure ES-7 compares the annual levelized production costs across the BAU and 10/20 

goals policy scenarios. 

Figure ES-7: Annual Levelized Production Costs Under the BAU and 10/20 Goals 

Policy Scenarios 

Secondary Regional Economic Impacts

The objective of the secondary regional economic analysis was to assess the impacts of 

the 10/20 goals and energy efficiency recommendations on the regional economy of the 

Transport Region. For this analysis, the results from the IPM modeling served as inputs 

to the REMI model. This assessment of regional economic impacts is focused around 

changes in employment, gross regional product and personal disposable income. 

Implementation of the 10/20 goals and energy efficiency recommendations has little or 

no impact on the regional economy. Most of the regional impacts are less than one half 

of one percent. Table ES-1 summarizes the annual average secondary region economic 

impacts under the policy scenarios for the years 2005 - 2020. 

$17.7 $18.3

$17.4

$0

$5

$10

$15

$20

BAU 10/20 Goals 10/20 Goals with No Cost &

Performance Improvements

Annual Levelized Production Costs (Billion 2001$)
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 xii 

Table ES-1: Annual Average (2005 – 2020) Changes In Key Economic Indicators 

for the Transport Region Under the Policy Scenarios 

The results of the regional economic analysis indicate that the 10/20 goals and energy 

efficiency may, on average, lead to an increase in economic activity. Over time, the 

policies lead to small increases in economic activity in the early years a small decline in 

later years. The impacts in the 2005 to 2015 time period are largely the result of 

investment in new renewable energy facilities that increase labor demand and have 

secondary impacts on output and income. Following the investment and construction 

boom, the region will see some decline in employment, gross regional product and 

personal disposable income. 

On average, the 10/20 goals will lead to small increases in employment and personal 

income along with a small decline in gross regional product. Implementation of the 

energy efficiency recommendations results in small increases in employment, personal 

disposable income and gross regional product. The economic impacts under the 10/20 

goals and energy efficiency are largely the result of increased capital investments in new 

renewable energy generating capacity. The boom in construction sparked by the 

investments appears to be the key reason for growth. 

Caveats and Uncertainties 

This analysis was conducted to help the AP2 forum understand the potential emissions 

reductions, costs and secondary regional economic impacts of the implementing the 

10/20 goals and the energy efficiency recommendations. The assumptions developed 

by the AP2 for this study are based on a variety of different sources including research 

of existing literature, data developed by the Energy Information Administration, and the 

National Renewable Energy Laboratory. Key drivers affecting the results on projections 

of renewable energy capacity, emissions savings and costs include the assumptions on 

renewable energy technology cost and performance. 

Though the modeling and analytical results provide detailed estimates of potential 

impacts, it is important to recognize that the magnitude of the results are quite small, 

particularly in estimates of the regional economic impacts. As with any analytical results, 

small perturbations are difficult to interpret precisely. In instances where the changes 

appear to be very small, analysis of broader trends, rather than specific numbers, will 

often provide a more robust and meaningful description of the impacts. 

Conclusions 

The analysis indicates that the 10/20 goals and energy efficiency recommendations 

could both serve as cost-effective air pollution prevention strategies. The 10/20 goals 

will lead to increases renewable energy capacity, while the energy efficiency 

recommendations will result in lower energy demand through conservation. Because 

both the 10/20 goals and energy efficiency displace new additions of fossil fuel capacity 

and generation, they are likely to provide a hedge against future emissions growth in 

Employment Gross Regional Product Personal Disposable Income

(Persons) (% Change) (Million 2001$) (% Change) (Million 2001$) (% Change)

10/20 Goals 627 0.00% -312 -0.01% 73 0.00%

Energy Efficiency (EE) 8,415 0.02% 450 0.02% 776 0.04%

10/20 Goals + EE 4,097 0.01% -58 0.00% 547 0.03%
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Executive Summary; October 2002 

 xiii 

NOx and CO2. The 10/20 goals can be achieved under modest cost impacts, while 

energy efficiency will result some cost savings and both the objectives have little or no 

regional economic impacts. 

 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 1 

I. Introduction 

This analysis was commissioned by the Air Pollution Prevention (AP2) forum of the 

Western Regional Air Partnership (WRAP) to help WRAP participants, western states 

and Indian tribes understand the potential emissions reductions, costs and secondary 

economic impacts from meeting the 10/20 renewable energy goals and implementing 

the energy efficiency recommendations. This study builds upon the framework, data and 

assumptions previously developed by the Market Trading Forum1

 (MTF) of WRAP and 

examines the impacts on electricity, industrial and process sources located within the 

nine states and tribal lands of Transport Region. 

This report includes seven sections discussing the analytical framework, data, 

assumptions and results. Specifically: 

Section II provides background to the study, describes the key objectives of the 

analysis and summarizes the main findings. 

Section III details the scenarios, data, assumptions and analytical framework. 

Details on renewable energy technology costs and performance assumptions 

developed by the AP2 forum are also described. The section also provides an 

overview of the modeling tools used -- ICF’s Integrated Planning Model® (IPM) 

and REMI’s Policy Insights® model-- and a discussion of the approach used to 

integrate the two models. 

Section IV discusses the emissions and production costs impacts of 

implementing the 10/20 goals and energy efficiency recommendations based on 

the IPM modeling results. 

Section V discusses the secondary regional economic impacts based on the 

results of the REMI model. The analysis focuses on impacts on employment, 

gross regional product and disposable income. 

Section VI contains a discussion of the caveats and uncertainties underlying the 

results. 

Section VII describes the conclusions of the study. 

 

1 “Economic Impacts of Implementing a Regional SO2 Emissions Program in the Grand Canyon 

Visibility Transport Region,” Western Regional Air Partnership/ Market Trading Forum, 

September 2000. (MTF 2000).
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 2 

II. Overview 

II.1 Background 

With a view towards improving visibility and air quality in the national parks and 

wilderness areas of the Colorado plateau, the Grand Canyon Visibility Transport 

Commission (GCVTC) issued several recommendations in 1996 on strategies for air 

pollution prevention in the West. In its recommendations, the GCVTC emphasized the 

need to integrate air pollution prevention with cost-effective pollution control strategies in 

order to prevent degradation of natural resources in the West.2

 

Two key GCVTC recommendations focused on the development of renewable energy 

sources and the promotion of energy conservation. The recommendation on 

development of renewable energy sources encouraged states and tribes in the 

Transport Region to undertake steps that would increase the use of renewable energy to 

10 percent of the regional power needs by 2005 and 20 percent of the regional power 

needs by 2015 (hereinafter the “10/20 goals”). For energy conservation, the commission 

supported the continued development of energy efficiency standards and suggested that 

the emphasis on energy conservation be maintained within the changing electric power 

markets. In addition to the renewable resource and energy conservation 

recommendations, the GCVTC suggested that future analysis examine the potential 

emission reductions, cost savings and secondary benefits associated with the use of 

renewable energy and energy efficiency. 

The Regional Haze Rule issued by U.S. Environmental Protection Agency in April 1999 

included the air pollution prevention recommendations of the GCTVC. Under the rule, 

the states of the Transport Region must include in their State Implementation Plans 

(SIP) an outline of the programs and policies that each state will rely on to work towards 

meeting the air pollution prevention recommendations. Tribal governments may seek 

approval from EPA to incorporate the requirements of the regional haze regulations, 

including the GCVTC recommendations, in their Tribal Implementation Plans (TIP) under 

the provisions of the Tribal Authority Rule (TAR)3

. 

The AP2 forum of WRAP has been charged with implementing the air pollution 

prevention recommendations of the GCVTC and commissioned ICF Consulting to 

examine the potential emissions reductions, costs and secondary economic impacts of 

meeting the 10/20 goals and energy efficiency recommendations. 

II.2 Objective 

This study serves as the documentation of the analytic and technical support to the AP2 

forum’s report detailing its recommendations regarding renewable energy and energy 

efficiency to the WRAP Board. While the AP2 forum’s report provides a discussion of 

the policy imperatives and broader implications of the GCVTC air pollution prevention 

 

2

 “Recommendations for Improving Western Vistas,” The Grand Canyon Visibility Transport 

Commission, June 1996, page 28. 

3

 63 Fed. Reg. 7254-7274, codified at 40 CFR Part 49. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 3 

recommendations, this report describes the potential emissions reductions, costs and 

secondary economic impacts of meeting the 10/20 goals and implementing the energy 

efficiency recommendations, given the assumptions and scenarios developed by the 

AP2 forum. The analysis examined the impacts for the nine states and tribal lands of the 

Transport region and was focused around stationary sources engaged in the production 

of electricity and industrial steam along with process sources (e.g., copper smelters and 

refineries). 

II.3 Summary of Key Findings 

The analysis indicates that the 10/20 goals and energy efficiency could both serve as 

cost-effective air pollution prevention strategies. 

The objective of the 10/20 goals is to have renewable energy providing 10 

percent of the regional energy demand by 2005 and 20 percent by 2015. The 

AP2 forum’s recommendations for energy efficiency seeks to reduce electricity 

demand in the Transport region by 8 percent by 2018 from the Business-AsUsual (BAU) conditions through energy conservation in the residential, 

commercial, industrial and manufacturing sectors. 

Wind power is expected to provide the largest source of renewable energy 

generation in meeting the 10/20 goals, accounting for much as 80 percent of the 

growth in renewable energy capacity. By 2018, the expansion in wind capacity 

under the 10/20 goals is expected to reach 18 GW. The 10/20 goals will also 

lead to some expansion of renewable energy generation from geothermal and 

landfill gas. 

Penetration of energy efficiency and renewable energy will primarily compete 

against new conventional capacity additions. In the absence of energy efficiency 

and the 10/20 goals, most of the expansion in conventional capacity will likely 

consist of gas-fired combined cycles. New additions to renewable energy 

capacity and demand reductions motivated by the 10/20 goals and the energy 

efficiency recommendations are projected to displace new gas-fired combined 

cycle capacity while leaving the existing stock relatively unaffected. 

Under the scenarios analyzed, energy efficiency and 10/20 goals provide 1 to 2 

percent reductions in NOx emissions and 10 to 14 percent reductions in CO2 

emissions. The reduction potential appears to be modest partly because the 

displaced generation consists almost entirely of relatively clean gas-fired 

combined cycle. Since the 10/20 goals and energy efficiency primarily displace 

generation from new fossil fired capacity additions, the 10/20 goals and energy 

efficiency can provide a hedge against future emissions growth. 

The 10/20 goals and energy efficiency do not provide any SO2 reductions in the 

presence of a regional SO2 emissions cap and trading program proposed in the 

Annex. However, the 10/20 goals and energy efficiency may lower the 

compliance cost of the trading program by as much as $ 10 million in 2018 (or 7 

percent) and displace the need for 1,200 MW to 1,700 MW of new scrubber 

capacity. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 4 

The increase in annual levelized production costs under the 10/20 goals will 

range between $ 300 million and $ 900 million (or 2 percent to 5 percent relative 

to the business-as-usual scenario). Under an energy efficiency scenario, the 

savings in annual levelized production cost may range between $ 700 million to $ 

1 billion (or 5 percent to 7 percent relative to the business-as-usual scenario). 

Implementation of the 10/20 goals and energy efficiency recommendations will 

have small or no impacts on the regional economy. Under the 10/20 goals 

scenario, employment and personal income is projected to increase on average 

by less than one half of one percent per year. Gross regional product is likely to 

decline by approximately the same percentage impact. Similarly, implementation 

of the energy efficiency recommendations is projected to lead to small increases 

in employment, gross regional product and personal income of less than one half 

of one percent each. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 5 

III. Analytical Approach 

This section describes the analytical approach, data, assumptions, methodology and 

modeling tools used in the analysis. There were three distinct phases to the analysis: 

(1) assumptions and scenario development, (2) modeling of the electric and steam 

sectors, and (3) modeling of the secondary regional economic impacts. Figure I 

presented below illustrates the three phases of the analysis and the overall analytical 

approach. Details on each of the phases of the analysis are described below. 

Figure I: Overview of Analytical Approach 

Phase III: 

Modeling of 

Secondary 

Economic Impact

REMITM Modeling 

Secondary regional economic 

impacts 

Employment Impacts 

Gross Regional Product 

Impacts 

Income Impacts 

WR

Economic Impacts of Implementing a 

Regional SO2 Emissions Program in the 

Grand Canyon Visibility Transport Region

Volume I

Prepared for:

Western Regional Air Partnership

Market Trading Forum

Prepared by:

ICF Consulting

September 2000

WRAP/MTF Economic Analysis 

Served as starting point for 

analysis 

AP2 selected Annex Scenario as 

Business-As-Usual scenario

Phase I: 

Assumptions and 

Scenario Development

AP2 Forum 

Reviewed and revised assumptions 

for renewable energy technology 

Developed energy efficiency cost 

and performance assumptions 

Developed scenarios for analysis of 

10/20 goals and energy efficiency 

(EE) 

Integrated

Approach

Environmental

 Markets

Fuel

 Markets

Electric

 Markets

IPM® Modeling 

Modeled 10/20 and EE Scenarios 

developed under Phase I 

Electric/Steam Sector System 

Impacts 

Emission Impacts 

Production Cost Impacts

Phase II:

Modeling of Electric 

and Steam Sector 

Demand

Employment 

Demand

by Industry, 

by Occupation

Market Shares

Local and export 

market shares

by Industry

Output

Final Demand 

by Type

Output 

by Industry

Wage Rate

Wage Rate, Prices and Profits

by Industry

Supply

Population 

by Age, 

Gender, Race

Labor Supply
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 6 

III.1 Scenarios Analyzed 

The AP2 forum developed two types of scenarios in order to examine the emissions, 

costs and secondary regional economic impacts of meeting the 10/20 goals and 

implementing the energy efficiency recommendations. The first was the Business-AsUsual (BAU) scenario that characterized how the future might unfold without any policy 

measures designed to accomplish the 10/20 goals and energy efficiency 

recommendations. The second set of scenarios reflected a future with policy drivers 

designed to meet the 10/20 goals or energy efficiency recommendations, or both. 

Assessments of emissions, costs and secondary regional economic impacts were 

estimated by analyzing the changes in the policy scenarios relative to the BAU scenario. 

This analysis examined the 10/20 goals and energy efficiency recommendations in the 

context of the regional backstop SO2 trading program proposed in the Annex. In 

September 2000 the WRAP/MTF conducted extensive analysis of the economic impacts 

of the Annex proposal.4

 The AP2 forum selected the WRAP/MTF scenario with the 

Annex as the basis for the BAU scenario. However, the existing stock of renewable 

energy plants under the WRAP/MTF Annex scenario was modified to account for firm 

projected renewable energy plants. 

 

The policy scenarios developed by the AP2 forum were focused around the policy 

objectives of the 10/20 goals and energy efficiency recommendations. Policy scenarios 

also included cases designed to test the sensitivity of the impacts to changes in 

technology improvements and higher gas prices. The results of the sensitivity scenarios 

are mentioned briefly in the report since they do not appear to add substantively to the 

insights gained from the core policy scenarios. 

In designing the policy scenarios and in developing the data for those scenarios, the 

AP2 forum modified some of the assumptions on the cost and performance of renewable 

energy technologies from those used in the BAU scenario. There were two reasons for 

this. First, the AP2 forum felt that the BAU scenario, which was adopted from the 

WRAP/MTF Annex scenario, did not contain enough details on renewable energy 

technologies since that had not been the focus of the WRAP/MTF. 

Second, and more importantly, the AP2 recognized that the 10/20 goals would not only 

affect the level of renewable energy generation in the west, but also had the potential to 

influence the underlying market conditions for those technologies. Under a climate 

where policies are in place designed to achieve the 10/20 renewable energy goals and 

energy efficiency recommendations, the AP2 forum believes that the wind resource 

development costs could improve over time because of the cost benefits of “learning by 

doing”, from better alignment of incentives for improving technologies’ cost and 

performance and from reduced barriers to entry. The adjustments in the assumptions 

for the policy scenarios were focused only around wind technologies since wind was 

likely to be the largest sources of renewable energy and it was also where the forum 

anticipated most improvements in cost and performance would occur. 

Recognizing the inherent uncertainty in assumption on technological improvements over 

time, the AP2 forum developed a sensitivity scenario that did not include the assumed 

 

4

 MTF 2000. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 7 

improvements in renewable technology cost and performance. The objective of this 

sensitivity scenario was to capture the higher end of the potential cost impacts of the 

10/20 goals. Table 1 presented below provides a summary of the scenarios developed 

by the AP2 forum. 

Table 1: Scenarios 

Scenario Assumptions Used 

Business-As- Usual Scenario 

Used WRAP/MTF Annex scenario 

Includes firm new renewable projects in 

existing generation stock 

10/20 Goals 

Updated renewable technology cost and 

performance assumptions 

Includes 10/20 goals as requirements 

that electric system has to meet 

Retained all other assumptions from 

WRAP/MTF Annex scenario 

10/20 Goals and 

Energy Efficiency 

Updated renewable technology cost and 

performance assumptions 

Includes energy efficiency 

recommendations 

Includes 10/20 goals as requirements 

that electric system has to meet 

Retained all other assumptions from 

WRAP/MTF Annex scenario 

Energy Efficiency Only 

Updated renewable technology cost and 

performance assumptions 

Includes energy efficiency 

recommendations 

Retained all other assumptions from 

WRAP/MTF Annex scenario 

Policy Scenarios 

Sensitivity Scenarios 

Impact of 10/20 goals assuming no 

improvements in renewable technology 

cost and performance over time 

Impact of higher gas prices on 10/20 

goals 

All the scenarios summarized in Table 1 above were modeled under Phase II of the 

analysis that examined the electric and steam sectors. In Phase III where the regional 

economic impacts were modeled, only selected policy scenarios were analyzed. These 

included the 10/20 goals policy scenario, the 10/20 goals and energy efficiency policy 

scenario and the energy efficiency policy scenarios. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 8 

III.2 Analytical Tool 

Integrated Planning Model (IPM®) 

ICF’s Integrated Planning Model (IPM) was used as the analytical tool for modeling the 

costs and emissions impacts of the policy scenarios under Phase II of the analysis. IPM 

is a well-established electric and industrial boiler sectors model. For the WRAP/MTF 

analysis of the SO2 program, it was enhanced to capture emissions from process 

sources. The model has been used in a wide range of analyses by government and 

industry. Within WRAP, the model was used by WRAP/MTF for the economic analyses 

and for the analysis of market issues related to the SO2 emissions trading program. The 

model is also currently being used by the National Tribal Environmental Council (NTEC) 

to analyze issues related to the tribal set-asides under the regional backstop SO2 trading 

program. 

IPM is a detailed engineering-economic capacity expansion and production-costing 

model of the power and industrial sectors supported by an extensive database of every 

boiler and generator in the nation. It is a multi-region model that provides least-cost 

capacity expansion plans, credible plant dispatch, and electric prices forecasts. IPM 

explicitly considers gas, oil, and coal markets, power plant costs and performance 

characteristics, environmental constraints and emissions markets, and other power 

market fundamentals. 

As illustrated in Figure 2 below, IPM provides an integrated analysis of electricity and 

steam markets. The model captures the interactions of real world constraints and 

simulates electric and steam markets based on economic fundamentals using a linear 

programming structure. Figure 2 illustrates the key components of IPM. 

Figure 2: The Integrated Planning Model 

IPM models the contiguous U.S. using distinct power markets represented as “model 

regions.” These regions correspond in most cases to the regions and sub-regions of the 

North American Electric Reliability Council (NERC). For this analysis, the nine western 

IPM

Environmental

Compliance

Technologies

and Costs

• Capacity Additions

• Fuel Prices

• Electric Prices

• Asset Values

• Emissions

• Retrofit Decisions

• Compliance Costs

• Steam Demand

• Electric Demand

• Gas Supply

• Coal Supply

Environmental

Regulatory

Scenario

New Electric and 

CHP Technologies
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 9 

states and tribes of the GCVTC region are contained within the model regions of 

California and Southwest Nevada (CNV), Pacific Northwest (WSCP) and interior West 

(WSCR). The models regions used in this study are illustrated in Figure 3 below. 

Figure 3: Regional Structure of IPM for AP2 Forum Analysis 

CNV

SPPN

ERCT

NENG

LILC

UPNY

FRCC

WUMS

MECS

MACS

MACE

MACW

SOU

SPPS

WSCP

WSCR

MAPP

TVA

ECAO

MANO

VACA

The modeling for this analysis covered the electricity, industrial steam and other 

industrial process sources of SO2 emissions (e.g., copper smelters and refineries). The 

electricity sector includes all existing boilers and generators. IPM forecasts new 

capacity builds to meet the growth in electricity demand. The industrial steam sector 

includes sources that sell steam to industrial, commercial and institutional facilities. 

Expansion in steam demand is met through new boilers and/or combined heat and 

power (CHP) cogeneration facilities. Process sources of SO2 such as refineries and 

smelters are also included in the modeling to capture their potential interactions in the 

regional SO2 allowance markets. The analysis does not model production activity of 

these industrial process sources. 

In IPM the 10/20 goals are modeled as electricity generation constraint on the power 

system that requires that the system must produce at a minimum the renewable 

generate targets specified by the 10/20 goals. The IPM model determines the optimal 

mix of renewable energy taking into account the target levels and their timing and 

geographic scope. In determining the optimal plan, the model also takes into account all 

existing and future air regulations included in the scenario, fuel prices and availability, 

and emission markets. The energy efficiency recommendations are modeled as 

reductions in energy requirements and peak demand levels. Reductions in demand are 

specified exogenously; the model responds to the new demand and determines the least 

cost method for satisfying that demand. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 10 

Regional Economic Assessment: REMI’s Policy Insights® Model (REMI) 

The Policy Insights® model produced by Regional Economic Models Inc. (hereinafter 

“REMI”) was used to estimate the secondary regional economic impacts of the 

implementing the 10/20 goals and the energy efficiency recommendations. REMI is a 

widely accepted tool for analyzing regional economic impacts and was previously used 

by WRAP/MTF for economic analysis of alternative emissions milestones (or caps) on 

the regional SO2 trading program. 

The REMI model is composed of five basic blocks – output, supply, demand, market 

shares and wage rate - that broadly characterize the regional economy. These blocks 

are inter-linked and the model uses a single set of simultaneous equations to estimate 

how a change from a policy might filter through the economy. Figure 4 illustrates the 

analytical framework of the REMI model. 

Figure 4: Analytical Framework in the REMI Model 

The REMI model used in this analysis consists of 10 regions, which include Arizona, 

Colorado, California, New Mexico, Nevada, Utah, Wyoming, Oregon, Idaho and the rest 

of the country. Because of the analytical difficulty in modeling tribal areas as a separate 

model region, tribal areas have been integrated in with the state in which they are 

located. 

The AP2 Forum selected three scenarios for analysis of the regional economic impacts. 

These include: 

1. 10/20 Goals; 

2. Energy Efficiency Recommendations; and 

3. 10/20 Goals and Energy Efficiency Recommendations. 

For all the three scenarios, the inputs to REMI are derived from the IPM modeling 

results. Most of the inputs to REMI require changes relative to a reference point and the 

Business-As-Usual (BAU) scenario was used as the reference case in developing the 

inputs to REMI. All REMI inputs are specified by year, state and sector. 

Demand

Employment 

Demand

by Industry, 

by Occupation

Market Shares

Local and export 

market shares

by Industry

Output

Final Demand 

by Type

Output 

by Industry

Wage Rate

Wage Rate, Prices and Profits

by Industry

Supply

Population 

by Age, 

Gender, Race

Labor Supply

Source: REMI®

Demand

Employment 

Demand

by Industry, 

by Occupation

Market Shares

Local and export 

market shares

by Industry

Output

Final Demand 

by Type

Output 

by Industry

Wage Rate

Wage Rate, Prices and Profits

by Industry

Supply

Population 

by Age, 

Gender, Race

Labor Supply

Source: REMI®
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 11 

There are three IPM outputs that form the basis for the inputs to REMI. These include 

1. Incremental Production Cost Impacts; 

2. Changes in Wholesale Electricity Price; and 

3. Revenue Changes from Allowance Allocations. 

 

The approach and methodology used in adapting the IPM outputs for use in REMI are 

discussed in detail below. 

Incremental Production Cost Impacts 

Incremental production costs in IPM are composed of the capital, fixed operating, 

variable operating and fuel costs associated with the 10/20 goals and energy efficiency 

recommendations. Under the 10/20 goals, for instance, the incremental annual levelized 

production cost was $ 300 million annually and reflects the total change in production 

costs in meeting the 10/20 targets. 

Impacts on production costs of sectors aside from power generators as a result of the 

policies are captured through REMI variables that reflect the factors of production in 

these sectors. Within REMI, these changes in production costs affect both market 

shares and final demand for each sector’s products through changes in the relative price 

of the products. Industries within these sectors that compete in regional markets (and 

thus are price setters for their product) are able to pass through cost via regional price 

increases, while sectors that compete nationally (and thus are “price takers”) experience 

a change in competitiveness relative to other regions and rest of the U.S. 

For electric generators, the production cost impacts are not modeled directly in REMI 

because the electricity price impact is already known through IPM modeling. Instead, 

the production cost impacts are combined with the electricity price change and the net 

revenue impacts are input into REMI as changes in dividends or shareholder income. 

Changes in dividends and shareholder income directly affect changes in personal 

income, which in turn affects output and employment demand. For purposes of REMI 

modeling, avoided transmission and distribution avoided costs under the EE 

recommendations are treated as changes in production cost. 

The capital investments for new electric generation capacity projected in IPM were 

modeled as construction and electric equipment demand in REMI. An increase in 

construction demand has a pronounced effect on the regional economy because it leads 

to an increase in employment, which in turn affects output, income, wages, population 

and labor supply. The increase in electrical equipment demand also affects output but 

the regional impacts are less pronounced than construction demand impacts because 

some of the expenditures flow out of the region for capital purchases made elsewhere. 

The regional purchase coefficients in REMI determines how much of the expenditures 

are spent locally versus outside of the region. 

Changes in fuel expenditures, which are a component of total production costs, have 

been modeled in REMI as mining demand impacts. The change in mining demand 

affects employment and also flows through to changes in income and output. 

 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 12 

Figure 5 below illustrates how production cost impacts from IPM have been modeled in 

REMI and also describes how those impacts relate to changes in the regional economy. 

Figure 5: Production Cost Impacts in REMI 

Changes in Wholesale Electricity Prices 

Wholesale electricity prices are outputs of IPM and have been used in REMI to describe 

how retail rates might change as a result of the policies. Wholesale electricity price 

impacts have been converted to retail rates based on the assumption that distribution 

and retailing cost do not change under the policies and that the changes in wholesale 

electricity price changes are fully realized by end use customers. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 13 

Under the 10/20 goals, the wholesale electricity price impacts modeled in REMI also 

include the premium necessary for implementing the renewable energy targets. In this 

analysis, the premium is based on a System Benefits Charge (SBC) type approach 

where every end user pays the levelized renewable energy credit price. Under the 

scenarios involving the EE recommendations, the EE implementations cost were also 

included in the electricity price impacts. EE implementation costs were provided by state 

and sector and were converted to a kWh basis using the share of electricity demand for 

that state and sector. In effect, the EE implementation costs are recovered through 

changes in electricity prices. In sum, the electricity price changes modeled in REMI 

include the following components: 

1. Wholesale electricity prices; 

2. Premium for 10/20 goals; and 

3. EE implementation costs. 

The changes in electricity prices are modeled separately for the residential, commercial 

and industrial sectors. 

For the industrial and commercial sectors the changes in electricity prices affect their 

raw material cost. The change in the price of electricity affects the relative price of their 

factors of production and affects the type of resources (labor, capital) that the sectors 

might employ in production. With lower electricity prices, these sectors might substitute 

capital for labor thereby leading to an increase in investments, which in turn affects 

demand and output. 

For the residential sector, the change in electricity price is modeled through the 

consumer price index. In this case, a reduction in electricity price implies an increase in 

income because consumers have more to spend on other goods and services, which in 

turn increases consumption, demand and output. 

Figure 6 below illustrates how the electricity price impacts have been modeled in REMI 

and its linkages in the regional economy. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 14 

Figure 6: Electricity Price Impacts in REMI 

Demand

Employment 

Demand

by Industry, 

by Occupation

Market Shares

Local and export 

market shares

by Industry

Output

Final Demand 

by Type

Output 

by Industry

Wage Rate

Wage Rate, Prices and Profits

by Industry

Supply

Population 

by Age, 

Gender, Race

Labor Supply

Demand

Employment 

Demand

by Industry, 

by Occupation

Market Shares

Local and export 

market shares

by Industry

Output

Final Demand 

by Type

Output 

by Industry

Wage Rate

Wage Rate, Prices and Profits

by Industry

Supply

Population 

by Age, 

Gender, Race

Labor Supply

Change in electricity price in the industrial

and commercial sector affects the relative

price of inputs in the factors of production. 

Change in electricity price in the residential

sector affects the consumer expenditure price

index, which in turn affects income. 

Revenue Changes from Allowance Allocation 

 

The revenue changes from allowance allocation account for changes in the allowance 

position under the SO2 trading program of the Annex. Although the cap in the trading 

program does not change under the 10/20 goals and the energy efficiency 

recommendations, the compliance strategy changes, which in turn affects the number of 

allowances that sources in a state will have to buy or sell. 

The expenditures/revenues from the sale/purchase of allowances is based on the 

allowance price of the regional SO2 trading program and the net allowance position of 

the state. A state that has allowances to sell will realize an increase in revenues, while a 

state that needs to purchase allowances will see an increase in expenditures. Because 

these revenues/expenditures accrue to the sources affected by the trading program, the 

changes in expenditures/revenues from allowance allocations have been modeled in 

REMI as dividend and shareholder income. The impact of the allowance allocation does 

not change the overall cost to the region (because expenditures and revenues cancel 

out) but merely redistributes the impacts across the region. Some of the dividend and 

shareholder incomes are assumed to flow out of the region based on the income 

distribution. Figure 7 illustrates how revenue changes from allowance allocations have 

been modeled in REMI and the related impacts on the regional economy. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 15 

Figure 7: Revenue Impacts from Allowance Allocations 

Changes in revenue/expenditures from

purchase or sale of allowances in the

regional SO2 trading program affects

dividend and shareholder income. 

Demand

Employment 

Demand

by Industry, 

by Occupation

Market Shares

Local and export 

market shares

by Industry

Output

Final Demand 

by Type

Output 

by Industry

Wage Rate

Wage Rate, Prices and Profits

by Industry

Supply

Population 

by Age, 

Gender, Race

Labor Supply

Demand

Employment 

Demand

by Industry, 

by Occupation

Market Shares

Local and export 

market shares

by Industry

Output

Final Demand 

by Type

Output 

by Industry

Wage Rate

Wage Rate, Prices and Profits

by Industry

Supply

Population 

by Age, 

Gender, Race

Labor Supply

 

III.3 Data and Assumptions 

As noted before, for this analysis the AP2 forum used much of the data and assumptions 

developed by the WRAP/MTF. These assumptions are fully documents in the economic 

analysis report produced by the WRAP/MTF in September 20005

 and have not been 

replicated in this report. The section describes only the data and assumptions that 

changed relative to the WRAP/MTF economic analysis. In addition, as noted before, the 

AP2 forum updated the renewable energy technology cost and performance 

assumptions for the policy scenarios. Because the BAU scenario did not include any 

projected additions to renewable energy capacity (outside of firm new capacity), for 

renewable energy technologies, this section describes only the assumptions used in the 

policy scenarios. 

 

5

 MTF 2000. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 16 

Environmental Regulations 

Regional and national existing environmental regulations affecting stationary sources 

that produce electricity and/or industrial steam are represented identically in both the 

BAU and policy scenarios. The regulations modeled include: 

1990 Clean Air Act Amendments Title IV NOx and SO2, 

Title IV SO2 national trading program, 

Northeast NOx SIPCALL, and 

Regional backstop SO2 trading program proposed under the Annex for the 

states and tribes of the Transport Region with the assumption that all 

states/tribes will participate in the trading program. The specific milestones 

used in modeling the Annex are summarized in Table 2 below. 

Table 2: Milestones Used for the Regional Backstop SO2 Trading Program 

Proposed In the Annex 

2013 2018 

Thousands Tons of SO2 630 507 

Natural Gas Prices 

The AP2 forum retained the natural gas price assumptions developed by the 

WRAP/MTF for this analysis. In addition, the AP2 forum developed the high natural gas 

prices for the sensitivity scenario based on the approach used in the WGA Transmission 

Report.6

 Table 3 below provides a summary of the natural gas prices assumed in the 

study. The BAU and policy scenarios both include the base price while the high prices 

were used only in the high gas price sensitivity policy scenario. 

Table 3: Assumptions on Delivered Natural Gas Price

National Average Delivered Natural Gas Price (2001 $/mmbtu) 

Year Base High Gas Price 

2005 $3.16 $4.44 

2010 $3.31 $4.99 

2020 $3.49 $5.93 

Cost and Performance for Grid Connected Utility Scale Solar Technologies 

The AP2 forum assumed that two types of grid-connected utility scale solar technologies 

-- solar photovoltaic and solar thermal -- would be available under the policy scenarios. 

Recognizing that some cost improvements in these technologies would occur over time, 

the forum allowed for some cost decline in both technologies after 2010. Table 4 

presented below provides the cost and performance assumptions for solar photovoltaic 

and solar thermal. 

 

6

 “Conceptual Plans for Electricity Transmission in the West,” Report to the Western Governors’ 

Association, August 2001. High gas prices were based on gas prices in Annual Energy Outlook 2001 plus 

50%. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 17 

Table 4: Cost and Performance Assumptions for Solar Technologies7

Overnight 

Capital Cost 

Fixed O&M 

Available Years Technology Cost Annual Average 

Capacity Factor (2001$/kW) (2001$/kW-Yr) 

Solar PV 28% 4,576 11 2000-2009 Solar Thermal 42% 3,170 50 

Solar PV 28% 2,737 11 2010-2030 Solar Thermal 42% 2,853 50 

The analysis reflects the fact that solar plants are not dispatchable by basing the 

generation estimates on generation profiles that describe the hourly generation for a 

typical day in the winter and summer. Furthermore, in order to account for the 

intermittency in generation from solar technologies, solar photovoltaic and solar thermal 

plants do not receive capacity credit on their entire nameplate capacity. Instead, the 

capacity credit is limited to their capacity factor in the peak 30 percent of hours. 

Cost and Performance for Biomass Technologies 

The AP2 forum assumed that both direct combustion and biomass gasification combined 

cycles (BGCC) would be available for commercial application to electricity generation. 

However, recognizing that BGCC is not yet a mature technology, the forum assumed 

that BGCC would be available only after 2010. Table 5 presented below summarizes 

the cost and performance assumptions for biomass technologies. 

Table 5: Cost and Performance Assumptions for Biomass Technologies8

Available 

Year Technology Heat Rate (Btu/kWh) 

Overnight 

Capital Cost

(2001$/kW) 

Fixed O&M 

(2001$/kW-Yr) 

Variable O&M 

(2001mills/kWh)

2000 Direct 

Combustion 8,219 1,420 48 5.75 

2010 

Biomass 

Gasification 

Combined 

Cycle 

13,000 1,489 66 7.74 

Biomass fuel supply is reflected in a composite supply curve containing energy crops, 

agricultural residue, forestry residue, and urban wood waste and mill residue available 

for electricity generation. For each model region and year, the supply curve denotes the 

price-quantity relationship of biomass.9

 

 

7 Annual Energy Outlook (AEO) 2001. 

8

 Data for Direct Combustion Biomass from Technology Characterization report by DOE-NREL 

1997. Data for Biomass Gasification Combined Cycle from Annual Energy Outlook 2001. 

9

 Biomass supply curve based on data from Annual Energy Outlook 2001. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 18 

Cost and Performance for Geothermal Technologies 

For geothermal generating technologies, the AP2 forum wanted to ensure that the 

effects of resource depletion were included in the cost and performance. Consequently, 

rather than a single option, the policy scenarios include a geothermal supply curve that 

characterize the relationship between available capacity and development-production 

cost. The supply curve is specified for each of the three model regions that circumscribe 

the Transport Region and is presented in Table 6 below. 

Table 6: Cost and Performance Assumptions for Geothermal Technologies10

Region 

Potential 

Capacity 

(MW) 

Overnight 

Capital Cost 

(2001$/kW) 

Fixed O&M 

(2001$/kW-Yr) 

Capacity 

Factor 

(%) 

653 2,137 75 90 

6,782 2,312 98 90 

3,806 3,311 122 90 

CNV 

[California and Southern 

Nevada) 12,836 5,979 258 90 

3,500 2,332 72 90 

2,200 3,563 130 90 WSCP 

[Pacific Northwest] 

3,075 5,156 195 90 

920 2,113 70 90 

250 2,735 96 90 

5,713 3,515 122 90 

WSCR 

[Interior West] 

5,606 6,877 238 90 

Cost and Performance for Landfill Gas Technologies 

A limited amount of potential landfill gas capacity was expected to be available in the 

Transport Region in the future and this resource was included by the AP2 in its policy 

scenarios. The potential capacity reflects landfill gas with a gas collection system 

already in place; capital costs reflect addition of generating equipment. Table 7 

presented below summarizes the cost and performance assumptions for landfill gas 

generation. 

 

10 Annual Energy Outlook 2001. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 19 

Table 7: Cost and Performance Assumptions for Landfill Gas Generation11

Region Potential 

Capacity 

(MW) 

Overnight 

Capital Cost 

(2001$/kW) 

Fixed O&M 

(2001$/kW-Yr) 

Variable O&M 

(2001 mills/kWh) 

Capacity 

Factor 

(%) 

CNV 

[California and 

Southern 

Nevada] 

528 1,291 85 11 87 

WSCP 

[Pacific 

Northwest] 

128 1,291 85 11 87 

WSCR 

[Interior West] 336 1,291 85 11 87 

Cost and Performance for Wind Technologies 

Because wind generation is the renewable energy resource most likely to penetrate in 

the future, the AP2 forum spent considerable time characterizing wind resources for the 

policy scenarios. In developing the assumptions, the forum sought to capture the issues 

of intermittency, resource availability, reliability and transmission access that are often 

associated with wind generation. 

The AP2 forum assumed that grid-connected central station wind plants could be located 

in wind classes 6 or greater, 5 and 412; lower wind classes were unlikely to support 

commercial electricity generation. Within each wind class, the total resource is divided 

into four cost categories to account for resource degradation and impact on electric 

system reliability stemming from the intermittency in wind generation. 

Cost multipliers are applied to each of the four wind classes to reflect these factors. The 

four cost categories reflect multipliers of 1, 1.2, 1.4 and 1.6 applied to base cost. The 

result is a wind resource supply curve that limits how much wind capacity is available at 

each cost point. The AP2 forum assumed that the highest cost category could not 

exceed 1.6 since at the very most (or at high levels of wind generation) a combustion 

turbine could be used to provide backup for the intermittency in wind generation to guard 

against any system reliability concerns. The available wind capacity resources were 

distributed among the four cost categories as outlined below with the best wind resource 

being assigned to the lowest cost scalar first.13 

Cost Scalar 1.0: Wind capacity equal to 10 percent of the region’s generation or 

10 percent of available capacity whichever is lower; 

 

11 “Energy Project Landfill Gas Utilization Software Manual,” Appendix A, US EPA 1997 and 

“Turning a Liability into An Asset: A Landfill Gas-to-Energy Project Development Handbook,” US 

EPA September 1996. 

12 Wind classes are based on average wind speed in the area. Class 6 or greater have the 

highest average wind speeds, while class 4 has the least average wind speed. 

13 Data provided by Walter Short, National Renewable Energy Laboratory. A similar methodology 

was also used in “Scenarios for Clean Energy Future,” Union of Concerned Scientists. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 20 

Cost Scalar 1.2: Wind capacity meeting 10 percent – 15 percent of region’s 

generation; 

Cost Scalar 1.4: Wind capacity meeting 15% - 20% of region’s generation; and 

Cost Scalar 1.6: Remaining wind capacity. 

Table 8 presented below summarizes the potential capacity by wind class and cost 

category for each model region. 

Table 8: Potential Wind Capacity by Model Region, Wind Class and Cost Class 

To characterize the cost and performance of wind technologies, the AP2 forum 

developed four technology vintages that become available for commercial application at 

different times in the planning horizon. The four vintages reflect expectations of 

declining costs and technological improvements. Table 9 provides a summary of the 

cost and performance assumptions for wind technologies. 

(in MW) Cost Scalars

Model Region Wind Class 1 1.2 1.4 1.6

CNV Class 6 1,574 4,543 

(California and South- Class 5 2,775 

West Nevada) Class 4 4,699 2,145 

CNV Total 1,574 12,017 2,145 - 

WSCP Class 6 678 

(Pacific Northwest) Class 5 6,088 

Class 4 962 3,316 17,935 

WSCP Total 678 7,050 3,316 17,935 

WSCR Class 6 6,593 3,297 3,297 55,156 

(Interior West) Class 5 32,384 

Class 4 292,468 

WSCR Total 6,593 3,297 3,297 380,008 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 21 

Table 9: Cost and Performance Assumptions for Wind Technologies14

Available 

Years 

Overnight 

Capital Costs 

(2001$/kW) 

Fixed O&M 

(2001$/kW-Yr) 

Variable O&M 

(2001 cents/kWh) 

Annual Average 

Capacity Factor 

Wind Class 6 

2000-2004 1000 4.00 0.5 40.4 

2005-2009 915 4.00 0.2 45.3 

2010-2014 800 4.00 0.18 46.4 

2015-onward 770 4.00 0.17 47.9 

Wind Class 5 

2000-2004 1000 4.00 0.5 35.3 

2005-2009 915 4.00 0.2 40.2 

2010-2014 855 4.00 0.18 41.3 

2015-onward 825 4.00 0.17 42.75 

Wind Class 4 

2000-2004 1000 4.00 0.5 30.2 

2005-2009 915 4.00 0.2 35.1 

2010-2014 910 4.00 0.18 36.2 

2015-onward 880 4.00 0.17 37.6 

Notes: 

Does not include Production Tax Credit. 

For this analysis, the generation output from wind plants is based on generation profiles 

that describe the hourly generation for a typical day in summer and winter. The annual 

average capacity factor presented in Table 9 above is therefore a summary 

characteristic of that generation profile. Furthermore, because wind plants are not 

dispatchable, the capacity credit for wind is restricted to the average generation in the 

peak 30% of the hours represented by the profile. 

 

Recognizing that wind technologies may encounter problems with transmission 

bottlenecks, particularly in the interior West where significant resources are located, the 

AP2 forum decided to include a transmission cost adder of $208 ($2001/kW)15 for wind 

resources located in the interior west. While the cost of interconnection to the grid is 

reflected in the capital costs reported in Table 9 above, the transmission cost adder for 

the interior West reflects the fact that these resources may also require some upgrades 

to the existing transmission system in order to deliver the power to the load centers. 

Connection to the grid alone does not guarantee delivery because there may not be 

sufficient capacity on the transmission lines to carry the additional power. The forum felt 

that this cost was particularly warranted for the interior west because much of the wind 

resource there is located in Wyoming. The forum felt that developing the resources in 

the interior west would, at a minimum, require some upgrades to the local transmission 

system to get the power to the demand centers. 

 

14 Data provided by Walter Short, National Renewable Energy Laboratory. 15 Based on “Conceptual Plans for Electricity Transmission in the West,” Report to the Western 

Governors’ Association, August 2001. Estimated using the incremental cost between the Gas 

transmission scenario and the Alternative Fuel Scenarios. Consistent with this report, the 

transmission cost adder is also applied to new coal capacity in the interior west. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 22 

The assumptions presented in Table 9 reflect declining technology costs and improved 

capacity factors over time. In the sensitivity policy scenario that do not allow for those 

improvements, the 2000-2004 costs and performance are held constant over all time 

periods.

Assumptions on the 10/20 Renewable Energy Goals 

The 10/20 goals were an explicit requirement in many of the policy scenarios and the 

characterization of that policy goal is based on the recommendations of the GCVTC. 

The AP2 forum assumed that the minimum renewable energy generation targets for the 

10/20 goals would be based on the electricity demand in the nine states and tribal land 

of the Transport Region. The 10/20 goals, as modeled in this analysis, requires that by 

2005 10 percent of the regional electricity demand be met by generation from renewable 

energy and by 2015 20 percent of the regional electricity demand be met by generation 

from renewable resources. Existing generation from renewable energy also counts 

towards that target. Figure 8 presented below provides a summary of the targets and 

the existing generation from renewable energy under the BAU. 

Figure 8: 10/20 Renewable Energy Generation Targets 

-

40,000

80,000

120,000

160,000

2005 2010 2015 2018

GWh

10/20 Goals Existing RE Generation Under BAU

This analysis assumes that the 10/20 renewable energy targets can be met by 

generation from wind, solar photovoltaic, solar thermal, biomass gasification combined 

cycle, biomass direct combustion, landfill gas and geothermal. The analysis did not 

include options for small hydro (due to data limitations), though small hydro is a potential 

renewable energy supply option. In addition, the renewable energy targets can be met 

by generation from renewable technologies located anywhere within the nine states and 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 23 

tribal lands of the Transport Region and also within the state of Washington and 

Montana16. 

Assumptions on Energy/Capacity Savings and Implementation Costs for Energy 

Efficiency Recommendations 

The AP2 forum commissioned the Tellus Institute to develop the energy savings and 

implementation cost assumptions for the energy efficiency recommendations. A 

description of the approach and method used for the energy efficiency analysis along 

with the detailed results are presented in Appendix II. 

The assumptions on the energy savings and implementation costs for the energy 

efficiency measures were developed outside of IPM, the power-industrial-process 

sources sectors modeling framework. The energy and peak capacity savings associated 

with energy efficiency were introduced into IPM to estimate the emissions reductions 

and cost savings resulting from lower energy demand. The potential emissions 

reductions were estimated using the change in emissions between the energy efficiency 

policy scenarios and the BAU scenario. The net production costs impacts were 

determined based on the following: 

(1) The energy efficiency implementation costs estimated outside of IPM; 

(2) The avoided investment cost savings in transmission and distribution estimated 

outside of IPM; 

(3) The cost saving from reduced generation estimated using IPM. 

 

The assumptions for the energy efficiency recommendations were specified by model 

region (CNV – California and Southwest Nevada; WSCP – Pacific Northwest; and 

WSCR – Interior West) to fit in with the modeling specification for IPM. Though the three 

model regions encompass more than the nine states and tribal lands of the Transport 

Region, the saving and cost estimates were based only the states and tribal lands of the 

Transport Region. Savings were characterized as electricity demand savings, the 

annual reduction in electricity demand inclusive of loss, and peak savings, the avoided 

generation capacity associated with the electricity demand savings. Figures 9 and 10 

presented below describe the total regional energy and capacity savings. The total 

savings reflects the sum of savings across the industrial, residential and commercial 

sectors and represents 1 percent of electricity demand in 2005 and growing to 8 percent 

by 2018 under BAU conditions. 

 

16 Renewable generation located in Washington and Montana were allowed to count towards the 10/20 

targets because, in the modeling, these states share common electricity markets with many of the 

states/tribes of the Transport Region. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 24 

Figure 9: Annual Electricity Demand Savings Under the Energy Efficiency 

Recommendations 

-

5,000

10,000

15,000

20,000

25,000

30,000

35,000

CNV (California and

Southwestern Nevada)

WCSP (Pacific Northwest) WSCR (Interior West)

Energy Savings (GWh)

2005 2010 2018

Figure 10: Generation Capacity Savings Under the Energy Efficiency 

Recommendations 

0

2

4

6

8

10

CNV (California and

Southwestern Nevada)

WCSP (Pacific Northwest) WSCR (Interior West)

Peak Demand Savings (GW)

2005 2010 2018

The costs for implementing the energy efficiency recommendations include the costs 

borne by both the customer and the sponsor and reflect the equipment purchase, fuel, 

operations, administration and marketing costs. In addition to the implementation costs, 

the AP2 forum assumed that the energy efficiency measures would lead to avoid 

investments in the transmission and distribution system at an annual average cost 

savings of 2.4 cents/kWh (2001 $). Because IPM is a wholesale electricity model that 

captures cost savings only at the wholesale generation levels, it was necessary to 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 25 

account for these avoided transmission and distribution (T&D) costs outside the model. 

Figure 11 provides a summary of the assumptions on total implementation costs and 

avoided T&D investments costs savings for the energy efficiency recommendations. In 

IPM modeling of the energy efficiency scenarios, the projected production cost savings 

from IPM are compared against the assumed implementation and avoided T&D costs to 

estimate net savings. 

Figure 11: Annual Implementation Costs and Avoided T&D Cost Savings Under 

the Energy Efficiency Recommendations 

(2,000)

(1,500)

(1,000)

(500)

-

500

1,000

1,500

2,000

2005 2010 2018

Million 2001$

Implementation Costs T&D Savings Net Annual Costs

 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 26 

IV. Emissions and Production Costs Impacts 

This section describes the emissions and costs impacts on the electricity, industrial and 

process source sectors under the policy scenarios. The impacts are described in terms 

of the changes relative to the BAU scenario, thus the first section outlines the notable 

elements under the BAU scenario. 

IV.1 Key Elements Under the Business-As-Usual (BAU) Scenario 

The BAU scenario represents a projection of the future without additional efforts to 

promote renewable energy and energy efficiency in the West. It provides a good 

reference point for analyzing the impacts of meeting the 10/20 goals and implementing 

the energy efficiency recommendations. The BAU scenario includes about 1 GW of 

additional renewable resources that are currently under construction or near the 

construction phase. However, no additional renewable resources beyond these planned 

additions are projected in the BAU. As a point of reference, over the last decade about 2 

GW of new renewable resources have been brought on line. 

Figure 12: Existing Renewable Energy Capacity17

5%

24%

4%

20%

47%

0% 4%

21%

15%

49%

49%

19%

2%

11%

19%

Geothermal

Solar/PV

Wind

Landfill Gas

Biomass/Waste

9%

48%

6%

36%

1% 

Geothermal

US 

GCVTC Region 

10 GW 15 GW 

1990 1998 

4 GW 6 GW 

 

17 1990 Data: Energy Information Administration (EIA) Form 860 and EIA Form 867. Some 1990 

capacity has been withheld for confidentiality. 1998 Data: EIA Form 860A and EIA Form 860B. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 27 

The BAU does not assume any major policy efforts to increase renewable energy or 

energy efficiency, aside from the indirect benefits afforded clean energy sources by 

existing air regulations including the Title IV SO2 program under the Clean Air Act 

Amendments and the regional SO2 backstop trading program proposed under the 

Annex. The growth in renewable capacity under the BAU is limited to the firm capacity 

additions planned and/or under construction. 

Under the BAU scenario, the growth in electricity demand is likely to be met by additions 

of new gas-fired capacity. By 2018, almost 30 GW of new combined cycle capacity, 

representing 80 percent of the total growth in new capacity is projected under the BAU. 

The new combined cycle capacity will likely consist of new combined-cycle and 

repowering of the older stock of oil/gas steam units to more efficient combined cycle 

units. As illustrated in Figure 13, by 2018 gas-fired generation from combined cycles 

represents 37 percent of all generation in the Transport Region up from 21 percent in 

2005 (oil/gas steam and combined cycle). The generation from nuclear, hydro and 

renewable energy remains unchanged between 2005 and 2018, but accounts for a 

smaller share of the total generation in 2018. 

Figure 13: Capacity Growth and Generation Mix Under the BAU 

-

5,000

10,000

15,000

20,000

25,000

30,000

35,000

2005 2010 2018

Capacity Additions by 2018 (MW)

Coal

O/G Steam & Turbines

Combined Cycles

Renew ables

Cogeneration

Generation Mix Under BAU

38%

3% 18%

5%

8%

17%

11%

Coal

O/G Steam & Turbines

Combined Cycles

Renewables

Cogens

Hydro

Nuclear

31%

0%

37%

4%

8%

14%

6%

2005

543 thousand GWh

2018

680 thousand GWh

The changes in emissions over time under the BAU scenario reflect the changing mix in 

capacity and generation. SO2 emissions under the BAU scenario remain relatively 

unchanged till 2013, after which the emissions decline as a result of the assumed SO2
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 28 

cap and regional trading program. Though NOx emissions remain relatively unchanged 

under the BAU scenario between 2005 and 2018, the NOx emissions rate declines 

significantly as a result of the repowering of existing oil/gas steam units. For CO2, the 

change in emissions between 2005 and 2018 mirrors the increase in fossil fuel usage 

and rises by 19 percent between the two years. Figure 14 presented below provides a 

summary of projected emissions under the BAU scenario.

Figure 14: Emissions Under the BAU Scenario 

-

200

400

600

800

2005 2010 2015 2018

CO2 (Million Metric Tonnes)

NOx ('000 tons)

SO2 ('000 tons)

IV.2 Electric System Capacity and Generation Impacts 

Implementation of the10/20 goals and energy efficiency recommendations lead to 

significant increases in renewable energy capacity, totaling nearly 20 GW by 2018. The 

increase in renewable energy capacity is driven by the combination of two key factors. 

First, under the policy scenarios that include the 10/20 goals there is an explicit 

requirement that by 2005 10 percent of the regional electricity demand must be met by 

renewable resources. By 2015, the requirement increases to 20 percent. Second, the 

growth in renewable energy capacity is spurred by declining renewable technology cost 

and performance improvements that the AP2 forum assumed would occur in the policy 

scenarios. 

 

Under the 10/20 goals policy scenario, as illustrated in Figure 15 below, renewable 

energy generation in the states and tribal lands of the Transport region expands to 18 

percent, up from 4 percent under the BAU scenario18. Most of this expansion comes 

from new wind capacity, which accounts for 65 percent of the renewable energy 

generation. 

 

18 Two percent of the renewable energy generation for the 10/20 goals comes from states and tribal regions 

outside the Transport Region but that share common electric market with the states/tribes in the Transport 

Region. The scenario assumes that renewable energy generation from such sources can be used towards 

the 10/20. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 29 

Figure 15: Renewable Energy Capacity and Generation Under the 10/20 Goals 

0

5

10

15

20

25

Wind Geothermal Landfill Gas

Capacity Additions by 2018 (GW)

31%

0%

37%

4%

8%

14%

6%

29%

0%

4% 26%

7%

14%

6%

14%

Coal

O/G Steam & Turbines

Combined Cycles

Existing Renewables

Cogens

Hydro

Nuclear

New Renewables

2018 Generation Mix 

BAU 10/20 Goals 

The expansion of renewable energy capacity under the 10/20 goals predominantly 

displaces new gas-fired capacity. As illustrated in Figure 16 below, by 2018 displaced 

gas fired combined cycles accounts for almost 80 percent of the 13 GW of the total 

displaced capacity. The type of displaced capacity (i.e., gas fired combined cycle) 

reflects the fact that renewable energy capacity will compete against new fossil capacity 

additions rather than affect the stock of existing units. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 30 

Figure 16: Capacity Displaced Under the 10/20 Goals 

Coal

Oil/Gas Steam & 

Gas Turbines

Gas Combined 

Cycles

Cogens

-10,000

-8,000

-6,000

-4,000

-2,000

0

2,000

Capacity Displaced by 2018 (MW)

Results of the analysis indicate that wind will remain the dominant renewable energy 

technology across a range of different sensitivities and assumptions, particularly when 

renewable energy generation accounts for 10 percent to 20 percent of regional electricity 

generation. As illustrated in Figure 16 below, across the other policy scenarios analyzed 

by the AP2 forum, new wind capacity accounts for at least 75 percent of the additions to 

renewable energy capacity. In Figure 17 presented below, “EE” refers to the energy 

efficiency policy scenario, “EE + 10/20” refers to the policy scenario that includes energy 

efficiency along with the 10/20 goals, “10/20 Goals with No Improvements in RE 

Technologies” refers to the policy scenario that includes the 10/20 goals but does not 

allow for improvements in renewable technology cost and performance and “High Gas 

Prices” refers to the policy scenario with 50% higher gas prices. 

Figure 17: Renewable Energy Capacity Additions Under Alternative Policy 

Scenarios 

0

5

10

15

20

25

30

35

40

EE EE + 10/20 Goals 10/20 Goals with No

Improvements in RE

Technologies

High Gas Price

Capacity Additions by 2018 ('000 MW)

Wind Geothermal Landfill Gas
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 31 

In summary, the changes in electric capacity and generation under the policy scenarios 

provide some interesting insights. First, the results of the analysis suggest that wind is 

likely to be the primary choice for renewable energy technology in the West. Even with 

renewable energy generation providing over 20 percent of the region’s electricity 

generation demand, as in the high gas price scenario, wind appears to be the dominant 

technology of choice. Second, the penetration of the renewable energy capacity and 

energy efficiency appears to displace mostly new additions to capacity rather than 

affecting the existing generation stock. Because most of the new capacity additions 

under the BAU are gas-fired combined cycle, the results indicate that new gas-fired 

capacity will be primarily displaced under the policy scenarios. The more important, 

broader implication is also that renewable energy and energy efficiency compete against 

new capacity in the supplying electricity.

IV.3 Production Costs Impacts 

Implementing the 10/20 renewable energy goals will lead to increased production costs, 

while the energy efficiency recommendations will result in production costs savings. 

Production costs, in this case, reflects the incremental or going forward costs 19

associated with producing electricity and industrial steam and includes incremental 

capital costs, fuel costs and operation and maintenance costs. 

As mentioned previously, the AP2 forum considered the production cost impacts of 

meeting the 10/20 goals under two alternative policy scenarios. In the first policy 

scenario, the AP2 forum assumed that the cost of developing renewable energy, 

particularly wind, would improve in the future as a result of the growth in renewable 

energy capacity. In the second scenario, the AP2 forum wanted to examine the 

production costs impacts without allowing for any improvements in renewable 

technology cost and performance. As illustrated in Figure 18 below, the annual levelized 

production cost impacts under the two policy scenarios could range between $300 

million (2001 $) and $900 million (2001 $) or 2 percent to 5 percent of the production 

costs under the BAU respectively. 

Figure 18: Production Cost Impacts in Meeting the 10/20 Renewable Energy Goals 

$17.7 $18.3

$17.4

$0

$5

$10

$15

$20

BAU 10/20 Goals 10/20 Goals with No

Improvements in RE

Technologies

Annual Levelized Production Costs (Billion 2001$)

 

19 Embedded cost associated with the capital cost of existing units are not included in modeled 

production costs. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 32 

The increase in production costs in meeting the 10/20 goals is largely driven by the 

capital expenditures required for new renewable energy projects. While the penetration 

of renewable energy leads to reductions in costs from displaced fossil fuel generation, it 

is not sufficient to fully offset the increased capital expenditures. Nonetheless, there is a 

shift in production costs away from fuel and towards capital. Under the 10/20 goals, 

operation-and-maintenance costs remain relatively unchanged. Figure 19 presented 

below highlights the composition of the change in annual levelized production costs for 

2018. 

 

Figure 19: Composition of Annual Levelized Production Cost Impacts in Meeting 

the 10/20 Goals 

$14

-$1,216

$1,485

$1,930

$299

-$1,321 -$1,500

-$1,000

-$500

$0

$500

$1,000

$1,500

$2,000

$2,500

10/20 Goals 10/20 Goals with No Improvements in RE

Technologies

Change in Production Cost Relative to BAU

(Million 2001$)

Operations & Maintenance

Fuel

Capital

Unlike the 10/20 goals, implementation of the energy efficiency recommendation with 

and without the 10/20 goals leads to annual levelized production costs savings of $730 

million to $1 billion (2001 $) respectively. These net savings reflect the cost of 

implementing the recommendations, the avoided investment costs for transmission and 

distribution infrastructure and the reduction in electricity production costs from decreased 

electricity demand. Though the requirements of the 10/20 goals somewhat lowers the 

savings from energy efficiency, the 10/20 goals and energy efficiency recommendations 

still result in annual levelized production costs savings of over $700 million. These 

savings represent 4 percent to 7 percent of the annual levelized production costs of the 

BAU scenario. Figure 20 presented below contrasts the annual levelized production 

costs under the BAU and policy scenarios with the energy efficiency recommendations. 

 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 33 

Figure 20: Annual Levelized Production Costs Under the BAU and Policy 

Scenarios with the Energy Efficiency Recommendations 

$16.4 $16.7 $17.4

$0

$5

$10

$15

$20

BAU EE EE + 10/20 Goals

Annual Levelized Production Costs (Billion 2001$)

The projected production costs savings presented in Figure 19 reflects the assumed 

improvements in renewable energy technology cost and performance. The AP2 forum 

assumed that the energy efficiency recommendations would occur under a policy regime 

that would actively promote renewable energy, though without explicit targets, thus 

leading to enhancements in technology cost and performance. 

Much like the policy scenarios with the 10/20 goals, the production cost savings under 

the policy scenarios with are driven by reductions in fuel expenditures because energy 

efficiency displaces gas generation. Figure 21 presented below illustrates that by 2018, 

energy efficiency and energy efficiency with the 10/20 goals leads to almost $ 2 billion in 

fuel expenditure savings, offset only by increased capital investments in renewable 

energy capacity. 

 

Figure 21: Composition of Production Cost Impacts Under the Energy Efficiency 

Policy Scenarios 

-$260

-$1,060

$181

$1,189

-$181

-$2,000 -$1,815

-$1,500

-$1,000

-$500

$0

$500

$1,000

$1,500

Change in Production Costs Relative to BAU 

EE EE + 10/20 Goals

(Million 2001$)

Operations & Maintenance

Fuel

Capital
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 34 

In summary, the production cost impacts of the policy scenarios yield some interesting 

insights for the 10/20 goals and energy efficiency recommendations. First, the 10/20 

goal will results in modest production cost impacts of 2 percent to 5%, while energy 

efficiency recommendations will achieve production cost savings of 5 percent to 7 

percent. Second, and perhaps the most notable feature of these policies is that because 

both the 10/20 goals and energy efficiency recommendations shift production 

expenditures away from fuel and towards capital, these policy objectives can offer some 

security against fuel price volatility and fuel supply shocks. 

IV.4 Emissions Impacts 

Under the 10/20 goals, the emissions reductions occur because conventional fossil fuel 

generation is replaced with clean or low emissions generation from renewable energy. 

With energy efficiency, demand savings displaces electricity generation, which in turn 

creates the opportunities for emissions reductions. The level of associated emissions 

reductions depends on the pollutant being examined. Fuel based emissions (CO2) 

generally follow fuel consumption, while technology/fuel dependent emissions such as 

NOx depends on the relative emission rate of displaced technologies. 

Under the policy scenarios of the 10/20 and energy efficiency, the change in NOx

emissions relative to the BAU scenario range between 1 percent and 2 percent. As 

illustrated in Figure 22 below, by 2018 the emissions reduction in NOx from 

implementing the 10/20 goals and the energy efficiency will be between 8,000 tons and 

14,000 tons annually. Most of the emissions reductions are likely to occur after 2010, 

when the penetration of renewable energy and energy efficiency is most significant. 

Figure 22: Reductions In NOx Emissions Under the Policy Scenarios 

-

2

4

6

8

10

12

14

16

Change in NO

2005 2010 2015 2018

x Emission Relative to BAU 

(Thousands Tons of NOX)

10/20 Goals

EE

EE + 10/20 Goals

The modes emissions reductions in NOx under the 10/20 goals and energy efficiency 

recommendations reflect that the fact that they largely displaced new gas-fired combined 

cycles, which are expected to have relatively low NOx emission rates. However, it is 

important to recognize that because these reductions come from new generation 

capacity, renewable energy and energy efficiency will provide a hedge against future 

NOx emissions growth. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 35 

Estimated emissions reductions in CO2, on the other hand, are driven largely by 

reductions in fossil fuel use. As highlighted in Figure 23 below, the reductions in CO2

emissions range between 10 percent and 14 percent under the various policy scenarios. 

By 2018, when the penetration of renewable energy and energy efficiency are most 

significant, the reductions are projected to between 40 million metric tonnes and 55 

million metric tones. 

Figure 23: Reductions In CO2 Emissions Under the Policy Scenarios

-

10

20

30

40

50

60

Change in CO

2005 2010 2015 2018

2 Emissions Relative to BAU 

(Million Metric Tonnes of CO2)

10/20 Goals

EE

EE + 10/20 Goals

As was true for NOx emissions, because CO2 emissions reductions derive from 

reductions in fossil fuel use in new capacity additions, the 10/20 goals and energy 

efficiency will likely provide a hedge against future CO2 emissions growth. 

Unlike NOx and CO2 emissions, the analysis projects no reductions in SO2 emissions 

reflecting the regional emissions cap and SO2 trading program as proposed in the Annex 

and modeled in all scenarios. However, because the SO2 trading program creates a 

monetary value for SO2 emissions, affected sources under the cap and trade program 

take advantage of reduced fuel use and associated lower emissions to reduce their 

overall cost of compliance with the cap. Thus, there is an economic benefit to fully 

offsetting any SO2 emissions reductions provided by the 10/20 goals and energy 

efficiency recommendations. This result is not unique to this particular situation but is 

rather a general outcome under an emissions cap and trading program. Analysis of the 

extent to which the 10/20 goals might lower the costs of compliance in the regional 

backstop SO2 trading program in the Transport Region is discussed below. 

IV.5 Impact on the Regional Backstop SO2 Trading Program 

The compliance cost of the regional trading program such as the Annex depends on the 

level of reductions required. The 10/20 goals and energy efficiency programs help to 

lower the compliance cost of the regional backstop SO2 trading program by lowering the 

amount of reductions needed to meet the milestone. The penetration of renewable 

energy under the 10/20 goals displaces fossil fuel generation, which in turn provides the 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 36 

remaining plants in the trading program with more headroom under the emissions cap. 

The implementation of the energy efficiency recommendations would have the same 

effect because it also displaces fossil fuel generation. 

The results of the analysis indicate that by implementing the 10/20 goals, the compliance 

cost of meeting the SO2 reduction requirements through a trading program as proposed 

in the Annex could decline by approximately $10 million (or 7 percent of the compliance 

cost without the 10/20 goals20) in 2018. This estimate is based on a comparison 

between two scenarios, one including the 10/20 goals without the regional trading 

program and the other including the 10/20 goals and the regional trading program (i.e., 

the 10/20 goals policy scenario). 

The fact that the 10/20 goals may make it cheaper to comply with the SO2 cap and trade 

program can be illustrated by examining projected amount of SO2 scrubbers constructed 

under the scenarios. Scrubber installations (or enhancements to existing scrubbers) are 

likely to be a key compliance strategy in meeting the SO2 reduction requirements under 

the Annex trading program. As illustrated in Figure 24 below, 1,200 MW to 1,700 MW, 

representing 13 percent to 17 percent, of fewer scrubber installations are projected 

under the policy scenarios relative to the BAU scenario. 

Figure 24: Projected Scrubber Installations Under the Annex SO2 Trading 

Program 

-

2,000

4,000

6,000

8,000

10,000

12,000

2015 2018

Installed Scrubber Capacity (MW)

BAU 10/20 Goals 10/20 Goals + EE EE

In summary, the results of the analysis suggest that implementation of the10/20 goals 

and energy efficiency recommendations will help to reduce the compliance cost of the 

regional backstop SO2 trading program by as much as $ 10 million (or 7 percent) in 2018 

and displaces 1,200 MW to 1,700 MW of new scrubber installations. 

IV.6 Wholesale Electricity Price Impacts 

This section discusses the wholesale electricity price impacts and the renewable energy 

credit price under the policy scenarios of the 10/20 goals and the energy efficiency 

recommendations. The distinction between the wholesale electricity price and the 

renewable energy credit price has been maintained for this discussion because the 

policy design of the 10/20 goals, particularly on how the compliance cost of the 10/20 

 

20 Ibid., MTF 2000. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 37 

goals might be recovered, has not been determined. 

In the IPM framework, wholesale electricity prices represent the price at which electricity 

would be sold by a generator to a retail distributor, assuming competitive generation 

markets. The model is a wholesale power market model and thus does not model retail 

markets or project electricity retail prices.21 In IPM, wholesale electricity prices are 

based on two separate components, energy price and capacity price, which together 

reflect the price of simultaneously satisfying electricity and reliability demand. 

Energy prices reflect the variable cost of operation and include fuel cost, 

variable operating costs and emissions-related costs. Emissions-related 

costs only exist if an emissions trading program is in place and the 

allowance price in the trading program is greater than zero. 

Capacity prices relate to fixed costs and include the capital and fixed 

operating costs. Some generating units, such as peaking combustion 

turbines, often come on-line to serve reliability and only operate a very 

small fraction of the hours in a year. Such plants often recover their costs 

through capacity payments. The capacity price can be zero if an 

electricity market has excess capacity. 

The wholesale electricity price is the sum of the energy price and capacity price and both 

prices reflect the cost of the marginal unit. For energy, the marginal unit is the 

generating unit that provides the last kWh to satisfy demand and the energy price is 

based on the variable cost of that marginal unit. All generators, independent of their own 

cost of generation, receive the same price for the energy sold. Marginal energy prices 

vary hourly in energy markets. In IPM, marginal energy prices vary by season and load 

segment (i.e., base, peak, etc). Similarly, the marginal unit in capacity markets is the 

last unit that has to come on-line to satisfy the peak plus reliability demand and the 

resulting capacity price is based on the capital and fixed operating costs of that marginal 

unit. 

As illustrated in Figure 24 below, the 10/20 goals and energy efficiency leads to a 

decline in wholesale electricity prices, of as much as 10 percent under the policy 

scenario with the 10/20 goals and energy efficiency. The electricity price impacts are 

differentiated by model region because each of the three regions has separate electricity 

markets. Though electricity prices often vary within a year and across years, for clarity 

Figure 25 contrasts the levelized annual average wholesale electricity price between the 

BAU and policy scenarios. 

 

21 For purposes of regional economic modeling, where changes in prices (rather than the actual 

price) serve as modeling inputs, we have included the assumption that end-use electricity 

customers realize the full benefit (or cost) of the change in wholesale electricity price. In other 

words, the distribution and/or retailing costs between the Business-As-Usual scenario and the 

10/20 goals scenario are assumed to remain constant and the changes in wholesale electricity 

prices fully flows through to retail rates.
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 38 

Figure 25: Levelized Annual Average Wholesale Electricity Price 

$0

$5

$10

$15

$20

$25

$30

$35

CNV (California, Southwest

Nevada)

WSCP (Pacific Northwest) WSCR (Interior West)

Levelized Annual Average 

Wholesale Electrcity Price (2001 $/MWhr)

BAU 10/20 Goals EE + 10/20 Goals EE

Under the 10/20 goals, the wholesale electricity price declines for two reasons: (1) 

generation from renewable energy have little or no variable cost of operation and (2) 

because the 10/20 goals essentially requires the power system to produce the level of 

generation associated with the targets, in generation markets, wholesale electricity price 

is determined by the marginal cost in meeting the incremental demand (i.e., the demand 

left after the generation required by the 10/20 goals have been accounted for). Under 

energy efficiency, the change in wholesale electricity price results from reduced demand, 

which eliminates the need for the higher cost units and thus leads to lower prices. 

Figure 25 presented above, however, does not account for the “compliance cost” of the 

10/20 goals or the implementation costs associated with energy efficiency. The issue of 

how those costs are recovered is more an issue of policy design but for purposes of this 

analysis the AP2 forum assumed that the costs of meeting the 10/20 goals and 

implementing the energy efficiency recommendations would be recovered uniformly 

through all end-users, as in a Systems Benefit Charge (SBC) type framework. 

To achieve the 10/20 goals, developers of renewable energy must earn sufficient 

revenue to cover their investment costs and earn a reasonable return. These required 

earnings are reflected in the marginal costs of satisfying the goal – or in the language of 

renewable portfolio approaches – the renewable energy credit (REC) price. The value of 

the REC represents the incremental costs over the wholesale energy price that the 

marginal renewable energy producer must earn – over the commodity energy price – to 

give him sufficient returns and incentives to construct the renewable capacity. RECs 

reflect the market price implications of achieving the 10/20 goals while production costs 

impacts only describe the total production cost implications of meeting the 10/20 targets 

without describing the price implications (opportunity cost) of the target. 

Figure 25 presented below summarizes the annual levelized REC for the policy 

scenarios with the 10/20 goals. In addition, Figure 26 also describes the value of the 

REC levelized over the electricity demand of the Transport Region. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 39 

Figure 26: Renewable Energy Credit Price for the 10/20 Goals 

$7.03

$7.96

$0.98 $1.09

$0.00

$2.00

$4.00

$6.00

$8.00

$10.00

10/20 Goals EE + 10/20 Goals

2001$/MWh

Renewable Eenergy Credit (REC) Price REC Price Levelized over Electricity Demand

Similarly implementation costs of the energy efficiency recommendations have been 

translated into price impacts by assuming that the annual levelized implementation costs 

of $ 45 million22 will be distributed evenly through all end-users, resulting in an annual 

levelized cost of $ 0.07/MWh. 

The wholesale electricity price along with the renewable energy credit price and the 

energy efficiency implementation costs provide a better description of electricity price 

impacts because it explicitly accounts for the compliance cost of the policy objectives. 

As presented in Figure 27 below, the wholesale electricity price in the Transport Region 

will increase by 1 percent to 2 percent under the 10/20 goals, decrease by as much as 5 

percent with energy efficiency and decrease by as much as 8 percent with energy 

efficiency and the 10/20 goals. This projected electricity price impact is measured at the 

wholesale level (the price at which generators will sell to utilities or distribution 

companies for end-use sales) because it does not account for the distribution and 

retailing costs. Retail price impacts would be lower in proportion to the share of retail 

prices that are wholesale price component. 

 

22 Includes implementation costs and avoided investments costs in transmission & distribution, 

see Section III.2 above for details. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 40 

Figure 27: Wholesale Electricity Price Impacts Under the Policy Scenarios 

$30.2 $32.4 $31.0 $31.8

$31.4 $31.6 $32.5

$29.6 $31.3 $32.3 $31.1 $32.0

$0

$5

$10

$15

$20

$25

$30

$35

CNV (California, Southwest

Nevada)

WSCP (Pacific Northwest) WSCR (Interior West)

Levelized Annual Average 

Wholesale Electricity Price (2001$/MWh)

BAU 10/20 Goals EE +10/20 Goals EE

In summary, the analysis indicates that the 10/20 goals can be achieved with modest 

price impacts of 1 percent to 2 percent, while energy efficiency could help to reduce the 

wholesale price by as much as 8 percent in some regions. The largest gains appear to 

be concentrated in regions that achieve the highest levels of renewable energy and 

energy efficiency penetration. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 41 

V. Secondary Regional Economic Impacts 

This section describes the secondary regional economic impacts resulting from the 

implementation of the 10/20 goals and the energy efficiency recommendations. The 

AP2 forum selected three policy scenarios for analysis of the regional economic impacts: 

(1) 10/20 goals; (2) energy efficiency; and (3) 10/20 goals and energy efficiency. Details 

of the modeling framework and assumptions on regional economic impacts are 

contained in Section III.2. 

 

Although the REMI model provides estimates on a variety of different impacts, the 

analysis has been focused around gross regional product (GRP), employment and real 

disposable personal income. These selected parameters provide a reasonably clear 

picture of the overall economic impacts of the 10/20 goals and energy efficiency. Gross 

regional product is analogous to national gross domestic product and describes the final 

demand or output of the regional economy. It consists of consumption, investment, 

government expenditures and net exports, while real personal disposable income 

describes personal income after taxes. 

The most informative aspects of the economic impacts are contained in the estimates of 

the overall regional impacts rather than the state-by-state impacts. While the state-bystate impacts provide a description of how the broader regional impacts may be 

distributed by state, the state level results may be sensitive to assumption on the 

distribution of the initial impacts. In particular, the state level results may be sensitive to 

assumption on how renewable energy investments are allocated across states. IPM 

projects renewable energy capacity only by model regions and the state level allocations 

were based on how the renewable energy resources were distribution by state. 

On average over the analysis horizon, the 10/20 goals and the EE recommendations 

have a small impact on GRP, employment and personal income, often less one half of 

one percent. Most of the impacts are closely aligned with the construction boom that 

results from capital investment in renewable energy. In addition, the decline in electricity 

prices from the 10/20 goals and energy efficiency lowers the cost of production in the 

commercial, industrial and manufacturing sector, which in turns leads to higher income 

and output. The reduction in electricity prices for the residential sector also leads to 

higher real income, increased consumption and investments. Table 10 presented below 

summarizes the change in employment, gross regional product and personal disposable 

income across the three policy scenarios. State/level details are presented in Appendix 

I. 

Table 10: Annual Average (2005 – 2020) Changes In Key Economic Indicators for 

the Transport Region Under the Policy Scenarios 

Under the 10/20 goals, the employment impacts occur mostly in the 2005 to 2015 time 

period because most of the investment in renewable energy capacity occurs at that time. 

Employment Gross Regional Product Personal Disposable Income

(Persons) (% Change) (Million 2001$) (% Change) (Million 2001$) (% Change)

10/20 Goals 627 0.00% -312 -0.01% 73 0.00%

Energy Efficiency (EE) 8,415 0.02% 450 0.02% 776 0.04%

10/20 Goals + EE 4,097 0.01% -58 0.00% 547 0.03%
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 42 

Under the scenario that includes only the EE recommendations, the increase in capital 

investments occur a little later, in the 2011-2015 time period, resulting in an increase in 

employment over that time period. 

The increase in employment also affects gross regional product (or output) through 

changes in investment and consumption. The increase in employment demand briefly 

causes wage rates to increase, as labor markets adjust, and this along with the increase 

in output leads to the increase in personal income. In short, the increase in employment 

caused by increased investments in renewable energy has the most dominant impact in 

the regional economy and also leads to related increase in gross regional product and 

personal income. 

The change in employment, though, is temporary and begins to ebb after the 2015 time 

period as investments in renewable energy decline. The decline in income, which have 

a less pronounced effect during times of high investments but continue to occur even 

after the investments have tapered off, add to the regional economic impacts after 2015. 

The decline in income reflects the drop in profits as a result of the changes in electricity 

prices and mining revenues from reduced fossil fuel consumption. These income effects 

are somewhat mitigated by the lower electricity cost faced by the residential, commercial 

and industrial sector but are not sufficient to offset the decline in income from profits. In 

addition, wages begins to decline slightly after 2010 as the construction demand begins 

to taper off and labor markets readjust. 

On average over the analysis horizon, the 10/20 goals lead to small increases in 

employment and personal income and to a minor decline in gross regional product. 

Energy efficiency leads to increases in employment, personal disposable income and 

gross regional product over the entire analysis horizon. 

In summary, the results of the regional economic analysis indicate that the 10/20 goals 

and the energy efficiency recommendations will have small or no impacts on the regional 

economy. The policies may lead to small increases in economic activity in the early 

years and a small decline in the later years. The impacts in the 2005 to 2015 time 

period are largely the result of investment in new renewable energy facilities that 

increase labor demand and have secondary impacts on output and income. Following 

the investment and construction boom, the region sees some decline in employment, 

gross regional product and personal disposable income because of the income impacts 

from lower profits in the electric and mining sector. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 43 

VI. Caveats and Uncertainties 

The objective of this analysis was to assist the AP2 forum in understanding the potential 

emissions reductions, costs and secondary regional economic impacts of implementing 

the 10/20 goals and energy efficiency recommendations. The AP2 forum intends for this 

report to serve as a technical appendix, providing the analytical support for its 

recommendation to WRAP. As with any analytical assessment, the findings presented 

in this report should be understood and applied in the context of which it was developed 

and recognizing the assumptions, analytical framework, caveats and uncertainties 

underlying the analysis. 

One of the key factors driving the results of the analysis is the assumption on renewable 

energy technology cost and performance. Existing literature on this subject provide a 

wide range of estimates, particularly in how the cost and performance might change in 

future years. The assumptions developed by the AP2 forum for the policy scenarios was 

based on a variety of different sources, including research of existing literature, data 

developed by the Energy Information Administration, data developed by the National 

Renewable Energy Laboratory and stakeholder input. The assumptions represent the 

forum’s best view of renewable energy technologies given the policy climate likely under 

the 10/20 goals and energy efficiency recommendations. 

Outside of the cost and performance assumptions for renewable energy technologies, 

this analysis was conducted using the data, assumptions and analytical framework 

developed by the WRAP/MTF in 2000 for the economic analysis of regional trading 

program in support of the Annex. Those assumptions describe the electric system 

operation, technology cost and performance including pollution control equipment, fuel 

prices and economic conditions.23 In addition, the AP2 forum adopted the WRAP/Annex 

scenario as the BAU scenario for this analysis with minor modifications to account for 

the planned additions to renewable energy capacity. 

The state level description of the secondary regional economic impacts presented in 

Appendix I should be used with some caution because the results may be sensitive to 

the assumptions on how the impacts were allocated by state. A key driver of the 

regional economic impacts was the capital investments for renewable energy projects. 

In IPM, which provided inputs for the REMI modeling, the growth in renewable energy 

capacity is described only by model region and the investments for new capacity were 

allocated by state based on distribution of renewable resource availability. 

Though the modeling and analytical results provide detailed estimates of emissions 

reductions, cost and secondary regional economic impacts, it is important to recognize 

that the magnitude of the projected changes are quite small. This is particularly 

important for analysis of secondary regional economic impacts projected through the 

REMI model because most of the impacts are less than one half of one percent. 

Similarly, many of the costs projected from the IPM model are small relative to the total 

production costs of the sectors modeled. As with any analytical results, small 

perturbations are difficult to interpret precisely. In instances where the changes appear 

 

23 MTF 2000. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 44 

to be very small, analysis of broader trends, rather than specific numbers, will often be a 

more robust and meaningful description of the impacts. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 45 

VII. Conclusions 

The objective of the analysis was to assist the AP2 forum in assessing the potential 

emissions reduction, costs and secondary regional economic impacts of meeting the 

10/20 goals and implementing the energy efficiency recommendations in the states and 

tribal lands of the Transport Region. The analysis suggests that the 10/20 goals and 

energy efficiency could both serve as cost-effective air pollution prevention strategies 

because they provide opportunities for emissions reductions with modest cost or with 

some cost savings. 

The 10/20 goals require that renewable energy resource satisfy 10 percent of the 

regional energy needs by 2005 and 20 percent of the regional energy needs by 2015. 

Most of the expansion in renewable energy is likely to come from wind power, where the 

greatest improvements in technology cost and performance are expected. Additional 

penetration of geothermal and landfill gas capacity are also projected under the 10/20 

goals. The investments required for this expansion is likely to increase annual levelized 

production costs by $300 million to $900 million, representing a production cost increase 

of 2 percent to 5 percent relative to the BAU scenario. The increase in wholesale 

electricity prices from meeting the 10/20 goals are likely to be less than 2 percent. 

The energy efficiency recommendations developed by the AP2 forum calls for electricity 

demand reductions in the Transport Region growing to 8 percent of the electricity 

demand by 2018. Implementation of the energy efficiency recommendations will lead to 

annual levelized production cost savings between $700 million and $1 billion in addition 

to some reductions in wholesale electricity prices. The savings under the energy 

efficiency policy scenarios accrue from reduced electricity and steam production cost 

and from avoided investment costs in transmissions and distribution, but are offset by 

the energy efficiency implementation costs. 

Future expansion of renewable energy capacity and increased penetration of energy 

efficiency is likely to compete against new conventional generation technologies. 

Analysis of the BAU scenario indicates that in the absence of 10/20 goals or energy 

efficiency, the growth of conventional capacity will consist mostly of gas-fired combined 

cycles. The penetration of renewable energy and energy efficiency under the policy 

scenario is likely to displace new gas-fired combined cycles, which are relatively low 

emissions technologies. 

For 2018, the analysis indicates that annual emissions savings from implementing the 

10/20 goals and energy efficiency recommendations will be between 1 percent and 2 

percent in NOx and 10 percent to 14 percent in CO2. Though the potential for emissions 

reductions may appear to be modest because renewable energy and energy efficiency 

compete against new gas fired generation sources, the 10/20 goals and energy 

efficiency will provide a hedge against future emissions growth. 

Though the 10/20 goals and energy efficiency are unlikely to reduce SO2 emissions in 

the presence of regional backstop SO2 trading program proposed in the Annex, they 

could help reduce the compliance cost of trading program. By meeting the 10/20 goals, 

the compliance cost of the trading program could decrease the compliance cost by as 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 46 

much as $ 10 million (or 7%) and may displace 1,200 MW to 1,700 MW of new scrubber 

installations. 

The 10/20 goals and energy efficiency are likely to have very small impacts on the 

regional economy. On average over the analysis horizon, energy efficiency will lead to 

small gains of less than one half of one percent in employment, gross regional product 

and personal disposable income. Similarly, on average over the analysis horizon, the 

10/20 goals will lead to small increases of less than one half of one percent in 

employment and personal income along with an equally small decline the gross regional 

product. The economic impacts under the 10/20 goals and energy efficiency are the 

result of increased capital investment in renewable technologies and lower electricity 

prices. In implementing the 10/20 goals and the energy efficiency recommendations, the 

boom in construction job sparked by the investments along with the lower production 

costs from lower electricity prices appear to be key reasons for the changes in the 

regional economy. 

 

 

 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 47 

 Appendix I: Regional Economic Impacts 

Economic Impacts by State

10/20 Goals Scenario

Annual Average Change in Employment

2005-2010 2011-2015 2016-2020

Persons Percent Persons Percent Persons Percent Annual Average

AZ 278 0.01% -768 -0.02% -1,530 -0.04% -614

CA -612 0.00% -4,123 -0.02% -6,724 -0.03% -3,619

CO 651 0.02% 450 0.01% 1,160 0.03% 747

ID 854 0.10% 1,274 0.15% 264 0.03% 801

NM 177 0.02% -522 -0.04% -1,372 -0.11% -525

NV 285 0.02% 451 0.03% 791 0.05% 495

OR -2,541 -0.11% -1,351 -0.06% -1,549 -0.06% -1,859

UT 720 0.05% 172 0.01% -391 -0.02% 201

WY 6,271 1.70% 10,380 2.71% -1,897 -0.48% 5,003

9 States 6,080 0.02% 5,961 0.02% -11,250 -0.03% 627

Economic Impacts by State

EE Only Scenario

Annual Average Change in Employment

2005-2010 2011-2015 2016-2020 Annual Average

Persons Percent Persons Percent Persons Percent

AZ 902 0.03% 3,434 0.10% 1,837 0.05% 1,986

CA -3,269 -0.01% 5,131 0.02% -11,315 -0.05% -3,158

CO 849 0.03% 4,060 0.12% 6,603 0.19% 3,651

ID 925 0.11% 680 0.08% -193 -0.02% 499

NM 270 0.02% 762 0.06% -406 -0.03% 212

NV -81 -0.01% 724 0.05% 252 0.02% 275

OR 1,084 0.05% 1,871 0.08% 997 0.04% 1,303

UT 321 0.02% 1,347 0.08% -98 -0.01% 511

WY -27 -0.01% 11,148 2.91% -1,071 -0.27% 3,139

9 States 975 0.00% 29,156 0.08% -3,397 -0.01% 8,415

Economic Impacts by State

EE + 10/20 Goals Scenario

Annual Average Change in Employment

2005-2010 2011-2015 2016-2020

Persons Percent Persons Percent Persons Percent Annual Average

AZ 859 0.03% 2,811 0.08% 3,297 0.10% 2,231

CA -4,828 -0.02% -6,640 -0.03% -10,943 -0.05% -7,305

CO 1,218 0.04% 2,930 0.09% 8,049 0.23% 3,888

ID 986 0.12% 2,573 0.29% -297 -0.03% 1,081

NM 307 0.03% 230 0.02% -274 -0.02% 101

NV 302 0.02% 481 0.03% 543 0.03% 433

OR -923 -0.04% 167 0.01% -1,131 -0.05% -647

UT 959 0.06% 1,048 0.06% 422 0.03% 819

WY 6,169 1.67% 4,843 1.27% -1,055 -0.27% 3,497

9 States 5,050 0.01% 8,441 0.02% -1,389 0.00% 4,097
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

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 48 

Economic Impacts by State

10/20 Goals Scenario

Annual Average Changes in Gross Regional Product

2005-2010 2011-2015 2016-2020

Million $ (F Percent Million $ (F Percent Million $ (F Percent

Annual 

Levelized 

(million 

2001$)

AZ 26 0.01% -46 -0.02% -129 -0.05% -29

CA -135 -0.01% -554 -0.03% -958 -0.04% -423

CO 42 0.02% 36 0.01% 90 0.03% 49

ID 31 0.06% 49 0.08% -14 -0.02% 27

NM 4 0.01% -35 -0.04% -98 -0.11% -30

NV 15 0.02% 25 0.02% 56 0.05% 27

OR -148 -0.10% -95 -0.06% -138 -0.07% -129

UT 36 0.04% 7 0.01% -35 -0.03% 12

WY 242 0.95% 392 1.39% -172 -0.54% 185

9 States 112 0.00% -221 -0.01% -1399 -0.04% -312

Economic Impacts by State

EE Only Scenario

Annual Average Changes in Gross Regional Product

2005-2010 2011-2015 2016-2020

Million $ (F Percent Million $ (F Percent Million $ (F Percent

Annual 

Levelized 

(million 

2001$)

AZ 57 0.02% 249 0.10% 141 0.05% 129

CA -200 -0.01% 293 0.01% -1108 -0.05% -233

CO 63 0.03% 318 0.13% 613 0.22% 251

ID 41 0.07% 42 0.07% -17 -0.02% 27

NM 12 0.02% 40 0.05% -21 -0.02% 13

NV -4 0.00% 53 0.05% 26 0.02% 18

OR 67 0.04% 146 0.08% 77 0.04% 91

UT 22 0.02% 100 0.09% 31 0.03% 46

WY -5 -0.02% 451 1.60% -100 -0.32% 109

9 States 52 0.00% 1,692 0.05% -359 -0.01% 450

Economic Impacts by State

EE + 10/20 Goals Scenario

Annual Average Changes in Gross Regional Product

2005-2010 2011-2015 2016-2020

Million $ (F Percent Million $ (F Percent Million $ (F Percent

Annual 

Levelized 

(million 

2001$)

AZ 61 0.03% 194 0.08% 230 0.08% 133

CA -409 -0.02% -720 -0.03% -1232 -0.05% -650

CO 85 0.04% 236 0.09% 712 0.25% 258

ID 38 0.07% 113 0.18% -36 -0.05% 43

NM 8 0.01% 1 0.00% -33 -0.04% -3

NV 16 0.02% 30 0.03% 40 0.03% 24

OR -57 -0.04% 16 0.01% -91 -0.05% -44

UT 52 0.05% 74 0.07% 51 0.04% 57

WY 235 0.92% 156 0.56% -115 -0.36% 125

9 States 30 0.00% 100 0.00% -475 -0.01% -58
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 49 

Economic Impacts by State

10/20 Goals Scenario

Annual Average Changes in Real Disposable Income

2005-2010 2011-2015 2016-2020

Million $ (F Percent Million $ (F Percent Million $ (F Percent

Annual 

Levelized 

(million 

2001$)

AZ 31 0.02% 13 0.01% -35 -0.02% 11

CA -77 -0.01% -221 -0.02% -373 -0.03% -175

CO 42 0.03% 97 0.06% 125 0.07% 75

ID 18 0.05% 36 0.08% 6 0.01% 21

NM 11 0.02% -8 -0.01% -46 -0.07% -7

NV 16 0.02% 45 0.05% 52 0.05% 33

OR -110 -0.10% -85 -0.07% -80 -0.06% -95

UT 29 0.05% 19 0.03% -8 -0.01% 18

WY 183 1.06% 379 2.01% 3 0.02% 193

9 States 143 0.01% 277 0.01% -357 -0.02% 73

Economic Impacts by State

EE Only Scenario

Annual Average Changes in Real Disposable Income

2005-2010 2011-2015 2016-2020

Million $ (F Percent Million $ (F Percent Million $ (F Percent

Annual 

Levelized 

(million 

2001$)

AZ 72 0.05% 331 0.19% 245 0.13% 182

CA -55 0.00% 217 0.02% -401 -0.03% -40

CO 67 0.04% 382 0.22% 612 0.32% 272

ID 33 0.08% 45 0.10% -3 -0.01% 28

NM 22 0.04% 88 0.14% 32 0.05% 42

NV 9 0.01% 96 0.11% 83 0.09% 50

OR 54 0.05% 110 0.09% 92 0.07% 78

UT 21 0.03% 99 0.14% 48 0.06% 49

WY 2 0.01% 371 1.97% 23 0.11% 115

9 States 224 0.01% 1,741 0.09% 731 0.03% 776

Economic Impacts by State

EE + 10/20 Goals Scenario

Annual Average Changes in Real Disposable Income

2005-2010 2011-2015 2016-2020

Million $ (F Percent Million $ (F Percent Million $ (F Percent

Annual 

Levelized 

(million 

2001$)

AZ 69 0.04% 285 0.16% 414 0.22% 204

CA -140 -0.01% -352 -0.03% -599 -0.04% -285

CO 76 0.05% 325 0.19% 747 0.39% 288

ID 31 0.08% 90 0.20% 4 0.01% 42

NM 21 0.04% 62 0.10% 70 0.10% 43

NV 24 0.03% 80 0.09% 109 0.11% 58

OR -27 -0.03% 6 0.00% 1 0.00% -12

UT 42 0.07% 83 0.11% 87 0.11% 63

WY 180 1.05% 209 1.11% 21 0.10% 146

9 States 278 0.02% 788 0.04% 854 0.04% 547
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 50 

Appendix II: Energy Efficiency Analysis and 

Methodology 

ESTIMATION OF POTENTIAL ENERGY EFFICIENCY SAVINGS FOR THE WESTERN 

REGIONAL AIR PARTNERSHIP BY THE AIR POLLUTION PREVENTION FORUM

Approach, Methods and Summary Results 

David Von Hippel and David Nichols 

Tellus Institute 

(Revised draft, June 26, 2002) 

Introduction 

Tellus Institute was asked by the Air Pollution Prevention Forum (the AP2 

Forum) to prepare estimates of electric energy efficiency savings in order to determine 

the potential impact of energy efficiency programs on air pollutant emissions from the 

electricity generation sector in the West. The Forum asked the Tellus team to estimate 

the achievable potential for electricity savings through energy efficiency programs in 

three air pollutant modeling regions: the Interior West (the "WSCR" region including 

Utah, Colorado, Arizona, New Mexico, Wyoming, Eastern Idaho, and Nevada excluding 

the Las Vegas area), part of the Pacific Northwest (the "WSCP" region, including Oregon 

and Western Idaho), and California/Las Vegas (the "CNV" region). Energy efficiency 

programs for the three areas were modeled over the period from 2002 through 2018, with 

impacts of measures installed under the programs counted through 2026. Only a limited 

set of energy efficiency measures were included in the program, so the estimates prepared 

were not, nor were they intended to be, fully comprehensive assessments of all potential 

electricity savings. The electricity savings (energy and peak) and the incremental costs of 

the programs were provided for use in ICF's IPM modeling system, and were used to 

generate air pollution scenario results as described in the Draft Final Report on Energy 

Efficiency and Renewable Energy, to which this document is a supplement. 

The sections below describe the overall approach used to estimate the potential 

impacts of energy efficiency programs, present a brief summary of the overall results of 

the estimation process, and indicate what next steps might be undertaken to elaborate the 

assessment of energy efficiency opportunities in the West. 

Overall Approach 

The key steps in the estimation of energy efficiency opportunities in the Interior 

West and Oregon/Western Idaho regions were as follows: 

Identification of energy efficiency measures, by Forum group members and the 

Tellus team 

Measure evaluation, to determine the basic cost-effectiveness of individual measure 

installations. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 51 

Program evaluation, including assembly of illustrative energy efficiency programs 

(application of measures to markets) and estimation of program impacts and costs, by 

year. 

Each of these steps is described briefly below. A different, more aggregate 

approach was used for the California/Las Vegas region. 

Identification of Measures 

The Forum group, based on their knowledge of electricity demand in the West, 

prepared a preliminary list of energy efficiency measures for the Tellus team to evaluate. 

The measures spanned all customer categories (including residential, 

commercial/institutional, industrial, and agricultural consumers), and ranged widely in 

scope and applicability. Measures designed strictly to reduce or displace load (load 

response and load management programs), but not save energy, were not included, nor 

were major uses of renewable energy in end-use settings (such as solar water heating). 

Likewise distributed generation technologies without heat production, gas energy 

efficiency measures, and transportation sector measures were also excluded from the 

study. 

The Tellus team performed an initial, qualitative screening of the suggested 

measures, eliminating (in a relatively few cases) measures from the list, and adding other 

measures that the team felt merited consideration. The final list of measures considered 

in the Interior West is presented in Table 1, below. The same list of measures was 

considered in the Oregon/Western Idaho region, except that two measures for application 

in the aluminum industry (aluminum production cell retrofit and advanced forming 

processes) were investigated in the latter region. Summary descriptions of these 

measures are provided in Attachment 1 to this document. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

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Table 1: Energy Efficiency Measures Evaluated, Interior West Region 

Residential Sector Measures Commercial Sector Measures Industrial Sector Measures 

Efficient Central Air Conditioning Lighting, Advanced Measures Motor Downsizing 

Efficient Room Air Conditioning Lighting, Efficient Fluorescent Premium Motors versus Rewinding 

Evaporative Cooling Refrigeration, High-cost Measures Premium Motors (versus standard 

new motors) 

Indirect-direct Evaporative Cooling Refrigeration, Low-cost Measures Air Compressor System Measures 

Appliance Recycling (refrigerators) Air Conditioning Improvement 

Residential-type Central AC 

Fan System Measures 

Compact Fluorescent Torchieres Air Conditioning Improvement 

Residential-type Room-type AC 

Pump System Measures 

CFL Fixtures--Indoor Air Conditioning Improvement, Small 

Heat Pumps 

CHP24, 10 MW Combustion Turbine 

(replacing gas boiler) 

CFL Fixtures--Outdoor Air Conditioning Improvement, 20-

ton Package Units 

CHP, 3000 kW diesel-type (replacing 

gas boiler) 

CFL Bulbs Air Conditioning Improvement, 350-

ton Centrifugal Units 

CHP, 40 MW Combustion Turbine 

(replacing gas boiler) 

Duct Test and Seal--Homes with 

Central AC 

Air Conditioning, IDDEC25, 20, 150, 

and 350-ton Equivalent Units 

Industrial CHP, 800 kW diesel-type 

(replacing gas boiler) 

Duct Test and Seal--Homes with 

Electric Space Heat 

Ground-source Heat Pumps, 1000 

to 3000 operating hours/yr 

High-efficiency Transformers 

Energy Star (Vertical Axis) Clothes 

Washer 

Efficient Clothes Washers 

SEHA (Horizontal Axis) Clothes 

Washer 

LED Exit Signs 

Appliance Standby Loss Reduction, 

Incentive Approach 

LED Traffic Signals 

Appliance Standby Loss Reduction--

Standards Approach 

Retrocommissioning of Buildings 

Home Weatherization Space Heat High Efficiency Gas 

Boiler 

New Home Building Envelope 

Improvement to IECC 2000 levels 

Space Heat, Standard Gas Boiler 

New Home Building Envelope 

Improvement--Enhanced levels 

Space Heat, Gas Unit Heater 

Water Heat Gas Boiler Fuel Switch 

Water Heater Fuel Switching 

Water Heating, Heat Pump Unit 

 

24 CHP = Combined Heat and Power (or Cogeneration) 

25 IDDEC = Indirect-direct Evaporative Cooling 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 53 

Table 1 (Continued): Energy Efficiency Measures Evaluated, Interior West 

Region

Additional Commercial Sector Measures 

Gas Air Conditioning (with heat recovery displacing Electric WH26) 

Gas Air Conditioning (with heat recovery displacing Gas WH) 

Gas Air Conditioning (w/o heat recovery) 

Building Envelope--Improvements to ASHRAE Standards 

Building Envelope--Improvements to Enhanced Level 

Cooling Tower VSD27 (CA Central Valley-type Climate) 

Cooling Tower VSD (CA Desert-type Climate) 

High-efficiency Transformers 

CHP, 100 kW diesel-type replacing Electric WH 

CHP, 100 kW diesel-type replacing Gas WH 

CHP, 30 kW Micro-turbine replacing Electric WH 

CHP, 30 kW Micro-turbine replacing Gas WH 

CHP, 800 kW diesel-type replacing Electric WH 

CHP, 800 kW diesel-type replacing Gas Boiler 

Measure Evaluation 

For each measure listed in Table 1, plus several other measures28, MS ExcelTM 

workbook tools were used to evaluate the measure cost-effectiveness. For each measure, 

cost-effectiveness was calculated relative to standard technologies, that is, technologies 

providing the same energy service but with efficiencies just meeting existing or planned 

standards, or technologies that correspond to standard practice for the end-use. 

Inputs to the measure cost-effectiveness calculation included: 

Measure cost information, including incremental or total measure capital cost (of 

both the energy-efficient and standard measure) per unit, and incremental or total 

non-fuel annual operating and maintenance (O&M) costs. 

Energy use impacts, including annual energy and peak power savings or usage, and 

annual gas use, if applicable, expressed on the same unit basis as the costs. 

An assumed discount rate (4.88 percent per year on a real basis). 

Real levelized avoided capacity and energy costs, in this case, estimates based on 

"proxy" gas-fired combustion turbine or combined-cycle units, using gas prices as 

defined by the Forum for use in the IPM modeling process. Note that these costs 

were used for rough screening purposed only, and are not the same as the costs used 

in the IPM modeling work to derive the impacts of energy efficiency programs on 

overall power system costs. 

Estimated electricity rates, calculated very roughly as the weighted averages of year 

2000 electricity rates in the regions being studied, by sector, escalated at 1 percent 

annually (on a real basis). 

Gas avoided costs based on the costs used in the IPM modeling work. 

The data elements above were derived from a wide variety of national and 

regional publications. Additional inputs were developed through consultation with 

experts in the energy-efficiency field. In cases where electricity usage in a measure was 

 

26 WH = Water Heating 

27 VSD = Variable Speed Drive 

28 Including fuel cell-based and other types/sizes of combined heat and power equipment, as well as several 

energy-efficiency measures that proved less than cost-effective. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 54 

likely to be weather-sensitive (space cooling, for example), adjustments to national or 

regional values were made based on conditions in the region (Interior West or Oregon/W. 

Idaho) modeled. Attachment 2 to this document provides a tabular summary of key 

measure cost and savings figures, as well as key program-related inputs to the energy 

efficiency analysis. 

The outputs of the measure cost analyses included life-cycle costs, for those 

measures where standard units were compared directly with higher-than-standardefficiency measures, and in all cases benefit-cost ratios for energy-efficiency measures 

relative to standard practice were calculated. The resulting ratios thus represent 

“incremental” measure costs and savings, relative to standard equipment. Benefit-cost 

ratios calculated from a total resource cost perspective were the primary yardstick used to 

assess whether measures should be included in programs, but in some cases participant 

cost measures were used to (roughly) inform the level of incentives that might be 

required. 

Program Evaluation 

Increasing the market penetration of energy-efficiency measures in an aggressive 

manner generally implies the provision of financial incentives to customers. As a 

consequence, the program evaluation phase of the development of energy-efficiency 

estimates for use by the AP2 Forum focused on estimating the sponsor costs of reaching a 

broader market for energy efficiency measures29. The estimation of energy-efficiency 

program costs and benefits involved the following steps: 

Grouping of measures into "programs" based, typically, on the end-uses and sectors 

addressed by the measures. 

Estimating the program market by consideration of the electricity demand in the 

sector and end-use addressed by the program, and of the nature and current market for 

the measure to be implemented. Sources for information on markets for energyefficiency measures included national end-use surveys, statistics on electricity use by 

sector, State, and utility area, and a host of specific studies on particular markets from 

the national and regional literature. 

Estimating program penetration rates based on a combination of penetration rates 

historically achieved by utilities mounting aggressive energy efficiency efforts, and 

on program targets that were felt to be "aggressive but achievable" in the markets 

studied. 

Estimating expenditures for administering energy-efficiency programs, including 

both start-up and ongoing costs, based on consideration of the types of activities and 

interactions with customers that would be required to initiate the energy efficiency 

programs considered and to carry them out on an ongoing basis. 

In a few cases, program impacts were based on the assumption that mandatory 

standards would be implemented in the future (for example, in 2008), which would raise 

 

29 The AP2 Forum wished to leave open the question of what types of agencies might organize and offer 

energy-efficiency programs of the types implied in the work described here. Accordingly, the 

organizations offering the programs are referred to as "sponsors", which could include government 

agencies, energy-efficiency program administrators retained to coordinate the use of funds collected 

through systems benefit charges, or, as in the past, distribution utilities. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 55 

effective program participation to near 100 percent (and reduce sponsor measure costs to 

zero). 

The ECO2TM DSM analysis software package, developed at Tellus Institute, was 

used to evaluate the candidate energy-efficiency programs. Key program inputs—such as 

the number of participants annually per measure, program administrative costs, and 

shares of measure costs assumed paid by the sponsor and by customers—were developed 

and documented in the same set of workbooks used to develop measure data. Program 

results from the ECO2 runs included annual energy savings, peak power savings 

(summer and winter peak), customer measure costs, sponsor measure costs, 

administration costs, customer O&M costs, net fuel (gas) and water costs (if any), 

estimated energy and capacity costs avoided by the program (from the perspectives of 

customers and society), and end-use pollutant emissions for the years 2002 through 2026. 

Net present values of program costs (and estimated benefits), as well as costs of saved 

energy, were calculated in a set of Excel workbooks that compiled ECO2 results for each 

region. Specific examples, for several of the measures and programs evaluated, of the 

overall analytical approach used to estimate energy efficiency costs and impacts for the 

WSCR and WSCP regions, are provided in Attachment 3 to this document. 

Approach Used in the CNV Modeling Region 

Savings and costs for energy efficiency in the CNV (California/Las Vegas) region 

were estimated based on a parameterization of a national (American Council for an 

Energy Efficient Economy or ACEEE) study. Based on its national analysis, ACEEE 

provided Tellus with estimated electricity reductions by sector for a number of policies. 

The Tellus team used results of some of these policies ("Appliance Standards", "Public 

Benefits Funds", and "Tax Credits") as a base for a rough estimate of potential electricity 

savings in the CNV modeling region. National electricity reductions through application 

of energy efficiency measures were allocated to the region based on the base case level of 

electricity consumption from NEMS (National Energy Modeling System) runs for each 

sector. From NEMS output, the Tellus team determined the region's electricity sales by 

sector as a fraction of national sales by sector. This fraction was applied to the national 

estimate of electricity use reductions from ACEEE to determine CNV reductions. A 

similar approach was used to estimate program costs30. 

Once estimates based on ACEEE results were obtained, these estimates were 

"trued-up" for consistency with end-use based energy efficiency costs and savings as 

estimated by the Tellus team for the Interior West and Oregon/W. Idaho regions. In the 

process, ACEEE savings estimates were reduced by nearly two-thirds31. The results of 

this "true-up" procedure should be considered only a rough approximation of the 

probable results if an end-use method were applied for the California/Las Vegas region. 

 

30 The ACEEE source document for which the original ACEEE estimates were prepared is Nadel, S. and H. 

Geller with the Tellus Institute (2001), Smart Energy Policies: Savings Money and Reducing Pollutant 

Emissions Through Greater Energy Efficiency. American Council for an Energy-Efficient Economy, 

Report No. E012, September, 2001. 

31 Note that this "true-up" also implicitly excludes savings due to free-riders, since the WSCR savings used 

to accomplish the true-up exclude savings from free-riders. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 56 

Selection of Measures and Programs for Use in IPM Emissions 

Modeling Effort 

The AP2 Forum reviewed the results of the energy-efficiency analyses described 

above in order to decide which results to carry forward for use in the IPM emission 

modeling effort. In addition to deciding to exclude the results of the combined heat and 

power analyses (see discussion below), the Forum felt that it would be prudent to remove 

the costs and savings for those measures with higher costs of saved energy from the 

packages of energy-efficiency programs modeled in each region. A threshold of 5.4 

cents (2001 dollars) per kWh saved (on a levelized basis) was set, based very roughly on 

current average avoided costs for electricity generation in the West regions, and measures 

with costs higher than the threshold level were accordingly excluded from the final 

packages of energy-efficiency programs for which energy/power savings and costs were 

included in the IPM modeling effort. The cost and savings of the resulting packages of 

energy-efficiency programs are described below. 

Summary Results 

The summary results provided below present energy and peak power savings, as 

well as costs, estimated for the energy-efficiency programs and measures included in the 

final package of programs used in the IPM modeling effort. Results are presented by 

region, and on an overall basis. 

Energy Savings 

Figures 1 through 3 show annual GWh electricity savings for the years 2002 

through 2018 in the WSCR (Interior West), WSCP (Oregon/W. Idaho), and CNV 

(California/Las Vegas) regions, respectively. Results are shown by sector, and indicate 

that commercial sector savings dominate the package of programs (though the suite of 

industrial measures examined was relatively limited), followed by residential sector 

savings. By 2018, annual electricity savings from the package of energy efficiency 

programs in the Interior West totals about 20,000 GWh, versus about 5,200 GWh in the 

Oregon/W. Idaho region, and about 28,000 in California/Las Vegas32. 

 

32 Note that these figures do not include credit for avoided transmission and distribution losses, so the net 

effect on required generation will be higher than the end-use savings indicated here. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 57 

Figure 1: 

Energy Savings from AP2 Forum Energy Efficiency 

Recommedations: Interior West

-

5,000

10,000

15,000

20,000

25,000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

Annual GWH

Industrial

Commercial/Institutional

Residential

Figure 2:

Energy Savings from AP2 Energy Efficiency Recommendations: 

WSCP Region

-

1,000

2,000

3,000

4,000

5,000

6,000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

Annual GWH

Industrial

Commercial/ Institutional

Residential
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 58 

Figure 3:

Estimated GWH Savings from Energy Efficiency 

Programs: CNV Region

-

5,000

10,000

15,000

20,000

25,000

30,000

35,000

20022003200420052006200720082009201020112012201320142015201620172018

GWh

Industrial--EE

Commercial--EE

Residential--EE

 Figure 4 indicates the magnitude of energy savings for each of the programs 

included in the energy-efficiency package for the Interior West. 

Figure 4:

Energy Savings for Illustrative Interior West DSM Programs

-

5,000

10,000

15,000

20,000

25,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Annual GWH

Resident. Evap. Cooling Res. Appliance Recycle

Res. CFL Bulb Introduct. Res. CFL Fixtures

Res. CFL Torchieres Resident. Clothes Washers

Res. Appl. Standby Redn. Resident. Weather-ization

C/I Lighting C/I Refrig.

C/I Cooling Efficiency C/I Cooling IDDEC

C/I Gas AC C/I GSHP

C/I Misc Devices C/I Retro-Commiss

C/I Gas Space Heat C/I Water Heat

C/I VSD Cooling Towers C/I and Industrial Transform

Industrial Motors Industr. Drive Systems

Peak Power Savings 

Figures 5 and 6 present annual summer peak power savings, by region and by 

sector, for the Interior West and Oregon/W. Idaho regions. By 2018, summer peak 

savings in the Interior West are over 6,000 MW, and savings in the Oregon/W. Idaho 

region are over 1,400 MW. Total summer peak power savings for the California/Las 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 59 

Vegas region from the energy-efficiency package were estimated at approximately 780 

MW in 2005, 3,500 MW in 2010, 6,600 MW in 2015, and 8,700 MW in 2018. Figure 7 

shows summer peak savings by sector for the period 2002 to 2018 in the Interior West. 

Figure 5: 

Summer Peak Savings from AP2 Energy Efficiency 

Recommedations: WSCR Region

-

1,000

2,000

3,000

4,000

5,000

6,000

7,000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

Summer Peak MW

Industrial

Commercial/ Institutional

Residential

Figure 6:

Summer Peak Savings from AP2 Energy Efficiency 

Recommendations: WSCP

-

200

400

600

800

1,000

1,200

1,400

1,600

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

Summer Peak MW

Industrial

Commercial/ Institutional

Residential
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 60 

Figure 7:

Summer Peak Savings for Illustrative Interior West DSM Programs

-

1,000

2,000

3,000

4,000

5,000

6,000

7,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

MW Savings

Resident. Evap. Cooling Res. Appliance Recycle

Res. CFL Bulb Introduct. Res. CFL Fixtures

Res. CFL Torchieres Resident. Clothes Washers

Res. Appl. Standby Redn. Resident. Weather-ization

C/I Lighting C/I Refrig.

C/I Cooling Efficiency C/I Cooling IDDEC

C/I Gas AC C/I GSHP

C/I Misc Devices C/I Retro-Commiss

C/I Water Heat C/I VSD Cooling Towers

C/I and Industrial Transform Industrial Motors

Industr. Drive Systems

Program Costs 

The total incremental costs of the packages of energy-efficiency programs for 

each region are presented in Figures 8 through 10 for the three regions modeled. These 

costs are presented as annualized costs, that is, incremental capital costs for purchase of 

measures are levelized so that a portion of those costs are ascribed to each year in which 

a given device installed under the program is in operation. By 2018, total annualized 

costs in the Interior West region reach about $550 million and costs in the Oregon/W. 

Idaho region reach $130 million, both in year 2018 dollars (or about $340 and $80 

million 2001 dollars, respectively), while total annualized costs in the California/Las 

Vegas region reach approximately $1,100 million 2001 dollars. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 61 

Figure 8:

Total Annual Costs of AP2 Forum Energy Efficiency Recommendations 

for Interior West Region (Measure Costs Annualized)

$-

$50

$100

$150

$200

$250

$300

$350

$400

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Million 2001 Dollars

Customer Gas Costs

Customer Water Costs

Customer O&M Costs

Sponsor Admin Costs

Sponsor Measure Costs

Customer Measure Costs

Figure 9:

Total Annual Costs of AP2 Forum Energy Efficiency Recommendations 

for Oregon/Western Idaho Region (Measure Costs Annualized)

$-

$10

$20

$30

$40

$50

$60

$70

$80

$90

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Million 2001 Dollars

Customer Gas Costs

Customer Water Costs

Customer O&M Costs

Sponsor Admin Costs

Sponsor Measure Costs

Customer Measure Costs
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 62 

Figure 10:

Annualized Program Costs by Sector: 

California/Las Vegas Region

$-

$200

$400

$600

$800

$1,000

$1,200

19992000200120022003200420052006200720082009201020112012201320142015201620172018

Million 2001 Dollars

Industrial

Commercial

Residential

Costs of Saved Energy 

Figure 11 show the curve of the cost of saved energy for the measures ultimately 

included in the Interior West energy efficiency package. Table 2 presents the same 

information in a tabular format that identifies the measures at each cost level. Note that 

the costs shown in Table 2 are discounted total incremental program costs for the period 

2002 to 202633. Cost curve results for the Oregon/W. Idaho region are not shown here, 

but are similar. 

Figure 11:

Cost of Saved Energy vs. Lifetime GWh Savings for Measures 

Included in Interior West Energy Efficiency Study

-$0.06

-$0.04

-$0.02

$0.00

$0.02

$0.04

$0.06

- 50,000 100,000 150,000 200,000 250,000 300,000 350,000

GWh Lifetime Savings

Real Levelized $/kWh Saved

 

33 Note that the discounting formulae used to prepare the values in Table 2 incorporate zero cost values for 

2001, so the values shown are effectively in year 2001 dollars. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 63 

Table 2: Cost Of Saved Energy Results Sorted By Cost Per kWh: 

Measure

Discounted 

TRC Cost 

($1000)

MWh Savings 

Through 2026

Real Levelized 

Cost of Saved 

Energy 

($/kWh)

Percent of 

Total 

Cummul. 

Package 

Savings

Cummulative 

MWh Savings 

through 2026

Percent of 

Total 

Cummul. 

Package 

Costs

Cummulative 

Discounted 

TRC Cost

Residential Evaporative Cooling (111,017) $ 5,007,946 (0.0489) $ 1.7% 5,007,946 -4.4% (111,017) $ 

Residential IDDEC Cooling (15,554) $ 2,305,001 (0.0151) $ 2.5% 7,312,947 -5.0% (126,571) $ 

Comml/Instit. Space Heat Std. Gas Boiler (458) $ 465,659 (0.0022) $ 2.6% 7,778,606 -5.0% (127,029) $ 

Comml/Instit. Space Heat High Eff. Gas Boiler (565) $ 962,327 (0.0013) $ 3.0% 8,740,933 -5.1% (127,594) $ 

Comml/Instit. Water Heat Gas Boiler Fuel Switch (1,145) $ 3,325,686 (0.0008) $ 4.1% 12,066,619 -5.1% (128,739) $ 

Comml/Instit. Water Heater Fuel Switching (505) $ 3,484,222 (0.0003) $ 5.3% 15,550,841 -5.1% (129,244) $ 

Comml/Instit. Space Heat Gas Unit Heater 422 $ 803,719 0.0011 $ 5.6% 16,354,560 -5.1% (128,821) $ 

Industrial Fan System Measures 7,041 $ 2,473,382 0.0062 $ 6.4% 18,827,942 -4.8% (121,780) $ 

Industrial Air Compressor System Measures 23,789 $ 8,347,664 0.0062 $ 9.2% 27,175,606 -3.9% (97,991) $ 

Residential CFL Torchiere 62,045 $ 21,232,172 0.0067 $ 16.5% 48,407,778 -1.4% (35,946) $ 

Industrial Motor Downsizing 3,416 $ 865,684 0.0086 $ 16.8% 49,273,462 -1.3% (32,531) $ 

Comml/Instit. Refrigeration, Low-cost Measures 29,224 $ 6,446,877 0.0098 $ 19.0% 55,720,339 -0.1% (3,307) $ 

Residential CFL Bulbs 49,797 $ 8,999,064 0.0099 $ 22.0% 64,719,403 1.8% 46,490 $ 

Comml/Instit. Water Heating, Heat Pump Unit 4,169 $ 833,390 0.0106 $ 22.3% 65,552,793 2.0% 50,659 $ 

Comml/Instit. LED Exit Signs 10,551 $ 2,212,350 0.0109 $ 23.1% 67,765,143 2.4% 61,210 $ 

Comml/Instit. Lighting, Efficient Fluorescent 120,842 $ 22,406,144 0.0117 $ 30.7% 90,171,287 7.2% 182,052 $ 

Residential CFL Fixtures--Indoor 24,370 $ 4,477,776 0.0124 $ 32.2% 94,649,063 8.2% 206,422 $ 

Industrial Premium Motors 32,469 $ 4,640,110 0.0137 $ 33.8% 99,289,173 9.5% 238,891 $ 

Residential Appl. Standby Loss Red.--Mandatory 186,808 $ 31,092,432 0.0138 $ 44.4% 130,381,605 16.9% 425,699 $ 

Residential Appl. Standby Loss Red.--Incentive 19,091 $ 2,018,494 0.0148 $ 45.1% 132,400,099 17.7% 444,789 $ 

Comml/Instit/Industrial Transformers (C/I) 14,260 $ 1,903,312 0.0172 $ 45.7% 134,303,411 18.2% 459,050 $ 

Industrial Pump System Measures 130,051 $ 15,459,078 0.0183 $ 51.0% 149,762,489 23.4% 589,101 $ 

Comml/Instit. Retrocommissioning 35,765 $ 4,203,554 0.0186 $ 52.4% 153,966,043 24.8% 624,866 $ 

Comml/Instit. Refrigeration, High-cost Measures 30,151 $ 3,487,028 0.0188 $ 53.6% 157,453,071 26.0% 655,018 $ 

Residential Appliance Recycling 40,598 $ 2,593,122 0.0204 $ 54.5% 160,046,193 27.6% 695,616 $ 

Comml/Instit/Industrial Transformers (Industrial) 2,150 $ 223,428 0.0220 $ 54.6% 160,269,621 27.7% 697,766 $ 

Residential CFL Fixtures--Outdoor 5,562 $ 515,112 0.0228 $ 54.7% 160,784,733 27.9% 703,328 $ 

Comml/Instit. AC Impr., 20-ton Package Units 296,085 $ 28,046,667 0.0236 $ 64.3% 188,831,400 39.7% 999,414 $ 

Comml/Instit. Ground-source HP, 3000 hrs/yr 30,955 $ 2,745,355 0.0249 $ 65.2% 191,576,755 40.9% 1,030,369 $ 

Comml/Instit. Lighting, Advanced Measures 795,012 $ 64,744,193 0.0266 $ 87.2% 256,320,948 72.4% 1,825,380 $ 

Comml/Instit. AC Impr., Residential-type CAC 57,876 $ 4,042,410 0.0307 $ 88.6% 260,363,358 74.7% 1,883,257 $ 

Comml/Instit. LED Traffic Signals 13,697 $ 931,600 0.0322 $ 88.9% 261,294,958 75.3% 1,896,954 $ 

Comml/Instit. Efficient Clothes Washers 15,511 $ 914,946 0.0335 $ 89.2% 262,209,904 75.9% 1,912,465 $ 

Comml/Instit. AC Impr., Small Heat Pump 93,753 $ 5,867,466 0.0343 $ 91.2% 268,077,370 79.6% 2,006,218 $ 

Comml/Instit. Ground-source HP, 2000 hrs/yr 30,955 $ 1,830,237 0.0373 $ 91.9% 269,907,607 80.9% 2,037,173 $ 

Comml/Instit. AC Impr., Res. Room-type AC 66,814 $ 3,738,494 0.0383 $ 93.1% 273,646,101 83.5% 2,103,987 $ 

Residential Weatherization 109,264 $ 5,824,614 0.0402 $ 95.1% 279,470,715 87.8% 2,213,251 $ 

Comml/Instit. Gas AC, w/ heat recov. (EWH) 53,763 $ 2,896,170 0.0420 $ 96.1% 282,366,885 90.0% 2,267,014 $ 

Comml/Instit. Cooling Tower VSD--Desert Climate 6,408 $ 336,718 0.0431 $ 96.2% 282,703,603 90.2% 2,273,422 $ 

Industrial Prem. Motor vs. Rewind 10,383 $ 436,716 0.0464 $ 96.4% 283,140,319 90.6% 2,283,805 $ 

Residential SEHA Clothes Washer 66,392 $ 3,052,546 0.0476 $ 97.4% 286,192,865 93.3% 2,350,197 $ 

Residential Energy Star Clothes Washer 57,518 $ 2,527,540 0.0498 $ 98.3% 288,720,405 95.6% 2,407,715 $ 

Comml/Instit. AC, IDDEC, 150-ton Equiv. Units 111,958 $ 5,072,414 0.0501 $ 100.0% 293,792,819 100.0% 2,519,673 $ 

ALL MEASURES/ALL PROGRAMS 2,519,673 $ 293,792,819 0.0186 $ 

Combined Heat and Power 

Based on the results of two national studies, the Tellus team identified a 

considerable achievable potential for the application of combined heat and power (CHP) 

in all three of the modeled regions. Implementation of CHP could result in significant 

cost savings, displacement of capacity (about 7.5 GW at the end-use level), and overall 

fuel (gas) savings relative to separate production of power and heat, and would also help, 

in many instances, to ease transmission constraints by providing distributed generation. 

Gas-fired CHP systems do, however, produce emissions of nitrogen oxides (NOx) that 

might, depending on the type of CHP used and the type and extent of emissions control 

equipment with which it is fitted, result in an increase of NOx emissions relative to 

separate heat production and power generation. This result is far from certain, as it 

depends on the average emission factors for CHP systems meeting current standards in 

major air sheds in the West. Though any increase in NOx emissions from the 

implementation of modern, regulations-compliant CHP system is likely to be modest 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 64 

relative to overall NOx emissions from power generation in the West, Forum members 

were sufficiently concerned about the potential impact of CHP systems on local and 

regional air quality, as well as about the ultimate "marketability" of CHP systems, that a 

consensus decision was made to leave savings (and costs) of CHP programs out of the 

total energy-efficiency savings figure passed on to the IPM modeling effort. 

Summary Results, All Regions 

Figures 12, 13, and 14 show, respectively the energy savings, summer peak 

savings, and annualized costs of the sum of all three regional energy efficiency packages 

modeled for the AP2 Forum. Together, the energy efficiency packages save 

approximately 54,000 GWh of electricity annually by 2018, with peak savings in that 

year of about 16,000 MW, at an annualized cost in 2018 of about $1.6 billion (2001 

dollars). The savings, both energy and peak power, from the energy efficiency packages 

in the three regions combined are shown by sector (residential, commercial/institutional, 

and industrial) in Figures 15 and 16 (peak results are not available by sector for the CNV 

region). 

Figure 12:

Estimated Total Energy Efficiency (EE) Savings 

by Region, AP2 Forum Recommendations

-

10,000

20,000

30,000

40,000

50,000

60,000

2002

2003

2004

2005

2006

2007

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2011

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2015

2016

2017

2018

Annual GWh Savings

CNV-EE

WSCP-EE

WSCR-EE

Figure 13:

Estimated Energy Efficiency (EE) Summer Peak 

Savings by Region: AP2 Forum Recommendations

-

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

2002

2003

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2017

2018

MW Summer Peak Savings

CNV-EE

WSCP-EE

WSCR-EE
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 65 

Figure 14:

Estimated Annualized Incremental Costs of 

Energy Efficiency Programs by Region

0

200

400

600

800

1000

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1400

1600

1800

2002

2003

2004

2005

2006

2007

2008

2009

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M illion 2001 Dollars

CNV

WSCP

WSCR

Figure 15:

Estimated Energy Efficiency Savings by Sector (all 

Regions): AP2 Forum Recommendations

-

10,000

20,000

30,000

40,000

50,000

60,000

2002

2003

2004

2005

2006

2007

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20142015

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2018

Annual GWh Savings

Industrial

Commercial

Residential

Figure 16:
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 66 

Estimated Energy Efficiency (EE) Summer Peak 

Savings by Sector: AP2 Forum Recommendations

-

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

MW Summer Peak Savings

California (All Sectors)

Industrial (WSCR + WSCP)

Commercial/ Institutional (WSCR + WSCP)

Residential (WSCR + WSCP)

Potential "Next Steps" in Energy Efficiency Analysis for the West 

The analysis described above has identified a number of significant energy 

efficiency opportunities in the West. As with most energy-efficiency analyses of this 

type, the reliability and accuracy of the work done for the Forum might, given time and 

resources, be broadened, deepened, and followed-up in a number of ways. Possible "next 

steps" in identifying, evaluating, and implementing energy-efficiency programs in the 

West include: 

Obtain additional expert review of the assumptions and other inputs used in the 

energy-efficiency analysis. 

Preparing a measure-by-measure estimate of energy-efficiency potential, similar to 

that done for the other two regions, for the California/Las Vegas region. 

Review the air pollutant emissions (especially NOx) impacts of potential combined 

heat and power systems, factoring in local regulations on new emissions sources and 

the types of pollution control used on new CHP systems. 

Deepen the overall analysis by evaluating additional measures, and by incorporating 

more region-, state-, tribe- and utility-area-specific information into the estimates 

wherever possible. 

Provide the energy-efficiency analysis on a State-by-State or Tribal level and/or work 

with state- or tribe-level teams (for example, from State Energy Offices or Tribal 

groups) to develop individual state- or tribal-level analyses. 

Identify and tailor approaches for implementation of energy-efficiency programs on 

regional, statewide, or tribal area bases. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 67 

ATTACHMENT 1: 

BRIEF DESCRIPTIONS OF MEASURES CONSIDERED IN THE 

WESTERN REGIONAL AIR PARTNERSHIP (WRAP) ENERGY 

EFFICIENCY ANALYSES 

Background

Several members of the Air Pollution Partnership (AP2) Forum have requested, 

on behalf of their constituents, a listing with brief definitions of the energy efficiency 

measures considered during the WRAP energy efficiency analyses carried out for the 

WSCR (Interior West) and WSCP (Northwest—Oregon and Western Idaho) regions. 

The listing below is divided into residential, commercial/institutional, industrial, and 

combined heat and power (CHP) measures. This listing is intended to supplement the 

document Estimation of Potential Energy Efficiency Savings for the Western Regional 

Air Partnership by the Air Pollution Prevention Forum: Approach, Methods and 

Summary Results, itself an annex to Final Report on Energy Efficiency and Renewable 

Energy, which reports on the overall pollution impacts modeling effort overseen by the 

AP2 Forum. 

The descriptions that follow cover all of the energy efficiency measures 

evaluated, including some measures (higher cost and CHP measures) ultimately not 

included in the package of energy efficiency measures used in pollutant emissions 

modeling. For each of the descriptions, names in italics and parentheses (for example 

"Residential Efficient CAC") correspond to the short measure names found in tables of 

"Cost of Saved Energy Results" presented in Estimation of Potential Energy Efficiency 

Savings for the Western Regional Air Partnership by the Air Pollution Prevention Forum:

Approach, Methods and Summary Results (to which these descriptions are attached) and 

used by the AP2 Forum to review the energy efficiency analyses. 

RESIDENTIAL SECTOR MEASURES

Residential Appliance Recycling: The appliance recycling program approach provides 

incentives to customers to allow their operable refrigerators or freezers to be disposed of. 

Appliance recycling has been operated successfully in several regions. A recycling 

company is contracted to collect the appliances and dispose of them in an 

environmentally responsible way. The electricity savings result from the fact that the 

average stock of refrigerators and freezers now in use consumes more than twice the 

electricity of the new units available on the market today ("Residential Appliance 

Recycling"). 

Residential Air Conditioning—High-efficiency Units: Compressor, control, fan, heatexchanger, seal, and other improvements in central and room air conditioners make the 

most efficient residential units available substantially more efficient than those just 

meeting standards ("Residential Efficient CAC", "Residential Efficient Room AC"). 

Residential Air Conditioning—Evaporative Cooling: In contrast to typical 

compressor-driven air conditioners, evaporative coolers lower indoor temperatures by 

evaporating a mist of water, which carries away heat. Evaporative or "swamp" coolers 

are effective in low-humidity areas, and use only a small fraction of the electricity used 

by compressor-driven air conditioners ("Residential Evaporative Cooling"). 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 68 

Residential Air Conditioning—IDDEC: A variant of residential evaporative cooling 

called indirect/direct evaporative cooling, or IDDEC, is under development that will 

provide reliable cooling with significantly less electricity input than typical compressordriven air conditioning, and is useful in applications where standard evaporative cooling 

might not be appropriate ("Residential IDDEC Cooling"). 

Residential Heating and Cooling—System and Duct Service and Repair: Many 

existing heating systems can be made significantly more efficient by applying a package 

of system and duct repair measures, including tune-ups for heat-pump condenser and 

evaporator units, cleaning, sealing and insulating duct work, or re-routing duct work to 

make the flow of heat from the furnace to living areas more efficient (evaluated as two 

measures: "Residential Duct Test and Seal--CAC", and "Residential Duct Test and Seal--

ESH"). 

Residential Heating and Cooling—Weatherization Retrofits: The thermal 

performance of a dwelling—the degree to which a heated house stays warm and a cooled 

house stays cool, is a function of many factors, including how well insulated the house is, 

the integrity of its windows and doors, whether it has been well-sealed to control the 

incursion of outside air, its overall design, its orientation relative to sun and wind, and its 

proximity to nearby vegetation. Of these factors, the first three are usually addressed by 

measures installed during a weatherization retrofit of an existing dwelling ("Residential 

Weatherization"). 

Residential Heating and Cooling—Better-than-Code Building Envelopes for New 

Homes: Although some parts of the West already have state (and sometime local) 

residential building codes that mandate quite high residential building performance, there 

are opportunities to exceed code levels. There are also opportunities to ensure that more 

buildings are actually built to code, through improved code enforcement, and to 

strengthen building codes to other states. For the WRAP energy efficiency analysis, 

incentives were assumed used until 2009 to bring homes to IECC 2000 (International 

Energy Conservation Code) levels ("Residential Building Envelope Impr.--IECC 2000"), 

and that thereafter code changes mandate enhancements in performance beyond the IECC 

2000 level ("Residential Building Envelope Impr.--Enhanced"). 

Residential Lighting—Compact Fluorescent (CFL) Bulbs: Over the last decade or so, 

compact fluorescent light bulbs (CFLs) designed for use in incandescent fixtures – and 

lamps and fixtures specifically designed to use CFL technology – have been making 

inroads in the U.S. market. CFLs use roughly one-quarter of the electricity to produce 

the same amount of light as incandescent bulbs, and last up to 10 times longer 

("Residential CFL Bulbs"). 

Residential Lighting—Indoor CFL Fixtures: CFLs work best when used in fixtures 

specifically designed for them ("Residential CFL Fixtures--Indoor"). 

Residential Lighting—Outdoor CFL Fixtures: Using CFLs in outdoor fixtures 

presents an attractive way to save both money and electricity, as long-lived CFL bulbs 

are used for many hours per day when installed for outdoor security lighting. In addition, 

as many outdoor incandescent bulbs designed for outdoor use are both expensive and 

short-lived, there are significant operation and maintenance savings from using outdoor 

CFL-based fixtures ("Residential CFL Fixtures--Outdoor"). 

Residential Lighting—CFL Torchieres: The "torchiere" style of tall floor lamp gained 

tremendous popularity in recent years as inexpensive units have become widely available. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 69 

Most units use bright, but inefficient, halogen bulbs, while some use incandescent bulbs. 

Their high electricity use and the fire hazards created by high temperature halogen units 

have prompted the development of the CFL torchiere. The CFL torchiere produces the 

same light output as the halogen and incandescent units, using 20-30 percent of the 

electricity and eliminating an important fire risk ("Residential CFL Torchiere"). 

Residential Appliance Standby Loss Reduction: Even when turned off, many 

household electronic devices consume small amounts of electricity. While insignificant 

on an individual device basis, the total energy consumed by standby equipment adds up 

to about 5 percent of current residential electricity use, due to the multitude of devices 

and their steady power drain. The EPA Energy Star program already includes an 

initiative to encourage the reduction in average standby consumption from 4.4 to 1 watt 

per device, a drop of over 75 percent. For WRAP, introduction of measures for standby 

loss reduction were modeled as an incentive program through 2009 ("Residential Appl. 

Standby Loss Red.--Incentive"), and as a mandatory standard thereafter ("Residential 

Appl. Standby Loss Red.--Mandatory"). 

Residential Clothes Washing: Improvements in clothes washers allow clothes to be 

cleaned with less hot water use, and often "spin" clothes faster so that less energy is 

required to dry them. Two types of higher-than-standard-efficiency clothes washers were 

included in the WRAP analysis: vertical-axis Energy Star-qualified machines 

("Residential Energy Star Clothes Washer"), and horizontal-axis washers ("Residential 

SEHA Clothes Washer", where SEHA is "Super-Efficient Home Appliance"). 

 

COMMERCIAL/INSTITUTIONAL SECTOR MEASURES

Commercial/Institutional Cooling—"Package" AC and Chillers: Use of higher-thanstandard efficiency "package" air conditioning (AC) units and centrifugal chillers for 

small-to-medium-sized and large commercial/institutional buildings produce more cold 

air (or chilled water) per unit of electricity input than standard models ("Comml/Instit. AC 

Impr., 20-ton Package Units" and "Comml/Instit. AC Impr., 350-ton Centrif. Units"). 

Commercial/Institutional Cooling—Residential-type Units: Many smaller commercial 

buildings use units that are the same as, or larger but similar to, the AC systems used in 

homes. For the WRAP study, models of room-type air conditioners, central air 

conditioners, and heat pumps with energy efficiency ratings significantly higher than 

standard units were evaluated ("Comml/Instit. AC Impr., Res. Room-type AC", 

"Comml/Instit. AC Impr., Residential-type CAC", "Comml/Instit. AC Impr., Small Heat 

Pump"). 

Commercial/Institutional Cooling—Evaporative Cooling: Evaporative cooling 

technologies use the latent heat of vaporization of water to cool air. One of the most 

promising configurations, indirect-direct evaporative cooling (IDDEC) can substantially 

reduce electricity requirements relative to conventional cooling systems and operate well 

in the relatively low humidity conditions that prevail during Western summers. For 

WRAP measures in three size classes were modeled for use in different types of 

commercial/institutional buildings, based on the size of conventional AC equipment that 

would otherwise be used ("Comml/Instit. AC, IDDEC, 20-ton Equiv. Units", 

"Comml/Instit. AC, IDDEC, 150-ton Equiv. Units", and "Comml/Instit. AC, IDDEC, 350-

ton Equiv. Units"). 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 70 

Commercial/Institutional Cooling—Gas-fired Air Conditioning: Electricity use can 

be reduced by replacing electric air conditioners with gas-fired air conditioners. Gasfired air conditioners use either an absorption cooling cycle or a gas-fired internalcombustion engine that turns an air conditioning compressor. Additional energy is saved 

by using waste heat from the gas-fired engine to heat water. Three gas-fired AC 

configurations were evaluated: without heat recovery ("Comml/Instit. Gas AC, w/o heat 

recovery"), with heat recovery and with the recovered heat avoiding the use of a gas-fired 

water heater ("Comml/Instit. Gas AC, w/ heat recov. (GWH)"), and with the recovered 

heat displacing an electric water heater ("Comml/Instit. Gas AC, w/ heat recov. (EWH)"). 

Commercial/Institutional Cooling—Cooling Tower Variable-Speed Drives: Cooling 

systems for large buildings often have cooling towers, where waste heat is exhausted 

using fans. Variable-speed drives for the fan motors on cooling tower allow the speed of 

the fans to be adjusted to cooling needs, and thus save electricity. Efficiency savings 

were estimated for WRAP using data from different regions of California. For example, 

for the WSCP (Oregon/Western Idaho) region, "Comml/Instit. Cooling Tower VSD--

Valley Climate" denotes an installation in a climate similar to that of the Central Valley in 

California, while "Comml/Instit. Cooling Tower VSD--N. Coast Clim." Uses a California 

North Coast climate as an analog. 

Commercial/Institutional Space Heat: Electricity, and energy overall, can be saved by 

switching from electric resistance heating to gas-fired heating systems, preferably gasfired systems of higher than standard efficiency. In some cases, gas-fired heaters and 

boilers are less expensive to buy (as well as operate) than electric ones of equivalent 

capacity. Three measures were evaluated for WRAP: High efficiency and standard gas 

boilers replacing electric resistance boilers ("Comml/Instit. Space Heat High Eff. Gas 

Boiler" and "Comml/Instit. Space Heat Std. Gas Boiler"), and gas "unit heaters" (standalone or ceiling-mounted, fan-forced heaters often used in spaces such as warehouses or 

workshops; ("Comml/Instit. Space Heat Gas Unit Heater"). 

Commercial/Institutional Ground-Source Heat Pumps: Ground-source heat pumps 

(sometimes called "geothermal" heat pumps) are used for both heating and cooling, and 

differ from typical heat pumps in that they use buried "loops" of piping with water or 

other fluid running through it to extract heat from (or, in cooling mode, exhaust heat to) 

the earth below ground level. The relatively constant temperature of the earth allows the 

heat pump to run more efficiently, under some conditions, than a typical air-source heat 

pump. As the number of hours a ground-source heat pump will need to run depends on 

climate, installations with running times (both heating and cooling) of 1000, 2000, and 

3000 hours per year were assumed ("Comml/Instit. Ground-source HP, 1000 hrs/yr", 

"Comml/Instit. Ground-source HP, 2000 hrs/yr", and "Comml/Instit. Ground-source HP, 

3000 hrs/yr"). 

Commercial/Institutional Water Heat: Water heating electricity use can be reduced 

substantially by switching from standard electric resistance-type water heaters to heatpump-type water heaters ("Comml/Instit. Water Heating, Heat Pump Unit"). Switching 

from electric water heating to natural gas-fired water heating, using both boilers and tanktype water heaters, can also reduce both electricity use and overall energy requirements 

after losses in electricity generation are accounted for ("Comml/Instit. Water Heater Fuel 

Switching", "Comml/Instit. Water Heat Gas Boiler Fuel Switch"). 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 71 

Commercial/Institutional Building "Retrocommissioning": Retrocommissioning is 

defined as "a process of thoroughly identifying the current needs for services within a 

building, assessing the functionality and appropriateness of the equipment now serving 

the building, devising and implementing a systematic plan for repairing, rejuvenating or 

replacing the existing systems, and finally creating operations and maintenance practices 

to assure continued functionality of the systems". It is therefore the process of reviewing 

all of the energy uses in an existing building, and making changes to maintenance and 

operation, and in some cases in equipment, to make sure that the building operates as 

efficiently as possible ("Comml/Instit. Retrocommissioning"). Retrocommissioning 

usually is designed to reduce a building's need for heating, cooling, and/or lighting.

Commercial/Institutional Building Standards: Higher standards for insulation, 

window performance, thermal seals, and other building components help reduce heating 

and cooling energy use. Two levels of building standards, one meeting ASHRAE 

(American Society of Heating, Refrigerating and Air-Conditioning Engineers) 90.1.99 

building guidelines ("Comml/Instit. Building Envelope--ASHRAE Stds."), and one 

exceeding ASRAE guidelines by about 20 percent ("Comml/Instit. Building Envelope--

Enhanced Level"). 

Commercial/Institutional Refrigeration: Commercial sector refrigeration ranges from 

large refrigerators not much different from residential units to walk-in or building-sized 

cold storage rooms or freezers. Options for improving the energy efficiency of 

refrigeration systems in the commercial sector include improving door seals, 

compressors, insulation, and controls. The WRAP analysis included two sets of 

measures, one of which includes measures having payback times of less than two years 

("lower-cost measures", "Comml/Instit. Refrigeration, Low-cost Measures") and the other 

having offering paybacks of between two and five years ("Comml/Instit. Refrigeration, 

High-cost Measures"). 

Commercial/Institutional Lighting—Fluorescent Bulbs and Ballasts: Replacing 

standard bulbs and ballasts in the four-foot fluorescent fixtures that are most common in 

office and other applications with high-efficiency bulbs and ballasts produces significant 

savings ("Comml/Instit. Lighting, Efficient Fluorescent". 

Commercial/Institutional Lighting—Advanced Lighting Measures: This measure 

includes a "package" of "emerging" lighting measures, ranging from use of daylighting to 

lighting controls to the use of advanced bulbs and fixtures, offering average energy 

savings over standard practice of more than 50 percent ("Comml/Instit. Lighting, 

Advanced Measures"). 

Commercial/Institutional Lighting—LED Exit Signs: LEDs are also increasingly 

used in commercial and institutional exit signs in place of incandescent or fluorescent 

bulbs. LED exit signs save a considerable amount of energy, and may not need to be 

replaced for a decade or more, significantly reducing maintenance ("Comml/Instit. LED 

Exit Signs"). 

Commercial/Institutional Clothes Washers: Upgrades in commercial clothes washers, 

as with residential washers, can yield significant energy savings in water heating and 

clothes drying, as well in the washer itself ("Comml/Instit. Efficient Clothes Washers"). 

LED Traffic Signals ("Comml/Instit. LED Traffic Signals"): Light emitting diodes 

(LEDs) have been widely used in electronics for years, are now starting to find new 

lighting applications. As with LED exit signs, long-lasting LED traffic signals, though 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 72 

they cost more per bulb than incandescent signals, dramatically reduce energy use (by 

90%) as well as O&M costs. Although LED traffic signals do not produce the same 

amount of overall light as incandescent signals, the focused points of bright light 

produced by LEDs make them easy for the eye to pick out, and thus ideal for traffic lights 

and other signage. 

Commercial/Institutional/Industrial Electrical Transformers: In larger commercial 

buildings and in industrial installations, transformers are used to "step down" highvoltage power from the electrical grid to usable lower voltages. Transformer losses are 

not substantial, but as each kWh of electricity used in a building typically must pass 

through a transformer, even a small reduction in losses improves the energy-efficiency of 

the entire building. The measures "Comml/Instit/Industrial Transformers (C/I)" and 

"Comml/Instit/Industrial Transformers (Industrial)" model the purchase of higherefficiency "TP-1" transformers instead of standard units. 

INDUSTRIAL SECTOR MEASURES

Industrial Motors Efficiency Improvements: The efficiency of industrial motors can be 

improved in several ways: by replacing failed motors with premium (highest efficiency) 

instead of standard models ("Industrial Premium Motors"), by substituting premium 

motors where motors would otherwise be rewound ("Industrial Prem. Motor vs. 

Rewind"), and by downsizing motors to appropriate capacity for the systems they power 

("Industrial Motor Downsizing"). These types of improvements typically save only 1-4 

percent of motor electricity requirements, but when applied across the large number of 

industrial motors, the savings can be considerable. 

Industrial Motor System Improvements: Even greater savings of motor electricity use 

can be achieved by modifying the design and operation of systems that motors drive: air 

compressors, pumps and valves, fans, and other systems (such as conveyors). For the 

WRAP energy efficiency analysis, the potential savings for improving each of three types 

of motor systems ("Industrial Air Compressor System Measures", "Industrial Fan System 

Measures", and "Industrial Pump System Measures") were evaluated. Savings for these 

measures can range, on average, from 5 percent for fans to nearly 20 percent for pumps 

and air compressors. 

Industrial—Aluminum Production Process Improvements: Primary aluminum 

production – as opposed to secondary production from recycled aluminum feedstocks -- 

is a very energy-intensive process. One of the key options for reducing electricity 

consumption per unit of aluminum produced is to retrofit aluminum production cells for 

higher electrolytic efficiency and lower heat loss ("Industrial Aluminum Process Impr.: 

Cell Retrofit"). Other technological advances are possible, such as advanced forming and 

near net-shape casting. These advances are designed to save energy by producing 

aluminum in shapes that are close to their final form, can provide considerable O&M and 

thermal energy (typically gas energy) savings, though typically small electricity savings 

("Industrial Aluminum Process Impr.: Adv. Forming"). 

Industrial Electrical Transformers: (see listing under Commercial/Institutional sector, 

above) 

COMBINED HEAT AND POWER
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 73 

From half to two-thirds of the energy used for fuel-based electricity generation is 

typically lost as waste heat. Combined heat and power (CHP) systems effectively capture 

this waste heat and supply it to a facility’s process or building heat requirements, and can 

thereby approximately double the overall efficiency of fuel use to 80 percent or so. 

We included in our analysis several types of natural gas-fired CHP systems in 

several size classes: 

Internal Combustion Engines: Internal combustion (IC) engines have been used in 

stationary power generation applications for a century or more, and are a very mature 

technology. Heat from gas-fired water-cooled IC engines can be captured from the 

engine's coolant system via a radiator, and used to heat or pre-heat air or water to help 

provide space or water heat. 

Combustion Turbines: Conventional combustion turbines (CT) are a newer, but still 

quite mature, electric generation option, having been in wide use for decades. Here 

heat can be captured from the hot exhaust gases of the turbine via a heat exchange 

unit, and used for space or water heat, or (more likely) for process heat in industrial 

plants. We incorporated 10 and 40 MW combustion turbines into the industrial sector 

CHP initiative that we evaluated. 

"Micro" Turbines: Micro-turbines (MT) are self-contained CHP devices that are 

new on the market. These units, the size of a large household refrigerator (in the 30 

kW size) produce heat and electricity using a high-speed but very reliable miniature 

turbine coupled to a generator. These units, recently commercialized, will be 

available in size classes other than 30 kW soon, but only the 30 kW units are included 

in our analysis. 

The types of CHP systems included in the commercial/institutional and industrial 

sector WRAP energy efficiency analyses are as follows: 

Commercial CHP: CHP measures in the commercial sector included 30 kW MT 

units, 100 kW IC units, and 800 kW IC units, with some of the units displacing grid 

electricity and heat from electric resistance boilers or water heaters ("Comml/Instit. 

CHP, 30 kW MT repl. Elect. WH", "Comml/Instit. CHP, 100 kW IC repl. Elect. WH", 

and "Comml/Instit. CHP, 800 kW IC repl. Elect. WH"), and other units displacing grid 

electricity and heat from gas-fired boilers or water heaters ("Comml/Instit. CHP, 30 

kW MT repl. Gas WH", "Comml/Instit. CHP, 100 kW IC repl. Gas WH", and 

"Comml/Instit. CHP, 800 kW IC repl. Gas Blr.") 

Industrial CHP: For the industrial sector, our estimate included 800 and 3000 kW 

IC units, and 10 and 40 MW CT units. All co-generated heat from these units was 

assumed to displace gas-fired boilers or process heating equipment ("Industrial CHP, 

800 kW IC repl. Gas Blr.", "Industrial CHP, 3000 kW IC repl. Gas Blr.", "Industrial 

CHP, 10 MW CT repl. Gas Blr.", and "Industrial CHP, 40 MW CT repl. Gas Blr.") 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 74 

ATTACHMENT 2: 

TABULAR SUMMARY OF DSM MEASURE AND PROGRAM 

INPUTS AND ASSUMPTIONS 

WSCR, Residential Sector SUMMARY OF DSM MEASURE AND PROGRAM ASSUMPTIONS

USED IN EVALUATING AN ENERGY EFFICIENCY PORTFOLIO FOR 

THE INTERIOR WEST (WSCR) REGION

PROGRAM /MEASURE

Units of 

Measure 

Application

Measure 

Lifetime 

(years)

Annual kWh 

Savings per 

Unit

Summer 

Peak 

Savings: 

kW/Unit

Incremental 

Installed 

Cost ($/unit)

Incremental 

Annual O&M 

Cost ($/unit)

Program 

Incentives

Ongoing 

Admin. Costs

Start-up Admin. 

Costs

Residential Efficient Cooling Equipment

6.5% of 

spon. Costs $1,000,000

High-efficiency Central AC AC Units 15 863 0.98 $550 $0

70% of incr. 

cost

High-efficiency Room AC AC Units 15 121 0.21 $150 $0

70% of incr. 

cost

Residential Evaporative Cooling

10% of spon. 

Costs $1,000,000

Direct Evaporative Cooling AC Units 15 1,870 2.14 (1,000) $ 63 $ $550

Indirect/Direct Evaporative Cooling AC Units 15 1,578 1.80 (300) $ 63 $ $550

Residential Lighting--CFL Bulbs

50% of spon. 

Costs $500,000

Compact Fluorescent Lamps (CFL) Bulbs 9 60.2 0.0181 $2.50 $0 $3.75

Residential Lighting--CFL Fixtures

65% of spon. 

Costs $1,000,000

CFL Fixtures--Indoor Fixtures 19 167 0.050 $14.21 $1.10

100% of 

incr. cost

CFL Fixtures--Outdoor Fixtures 11 143 0.0128 $17.14 ($10.60)

100% of 

incr. cost

Residential Lighting--Torchieres

20% of spon. 

Costs $500,000 

CFL Torchieres Lamps 20 599 0.1797 $40.00 ($4.88)

75% of incr. 

cost

Residential Appliance Recycling $500,000

Second Refrigerator Pickup Appliances 6 1,149 0.196 $125 $0 $75/unit (see note)

Residential Clothes Washers

15% of spon. 

Costs $500,000 

EnergyStar Vertical Axis Washers Appliances 15 674 0.280 $324 $0

50% of incr. 

cost

SEHA Horizontal Axis Washers Appliances 15 814 0.339 $374 $0

50% of incr. 

cost

EnergyStar Devices, Incentive Program Devices 7 29.8 0.0034 $2.50 $0

50% of incr. 

cost

15% of spon. 

Costs $500,000 

EnergyStar Devices, Mandatory Program Devices 7 29.8 0.0034 $2.50 $0 none none $500,000 

Residential "Weatherization"

6.6% of 

spon. Costs $500,000 

Weatherization of Elect. Heated Homes Homes 15 1,344 1.02 $529 $0

20% of incr. 

cost

0.242

16% of spon. 

Costs $500,000 

Duct Measures, Space Heating Savings Homes 10 212 0.242 $309 $0

70% of incr. 

cost

Duct Measures, Space Cooling Savings Homes 10 153 0.175 $309 $0

70% of incr. 

cost

8.6% of 

spon. Costs

Improvements to IECC 2000 Level Homes 50 230 0.096 $1,161 $0

50% of incr. 

cost $1,000,000 

Enhancements beyong IECC 2000 Homes 50 491 0.205 $2,253 $0 none $3,000,000 

Residential Electronics Standby Loss 

Reduction

Residential Duct Testing and Sealing

Residential New Construction Building Shell 

Improvements
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 75 

PROGRAM /MEASURE

Units of 

Measure 

Application Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Notes

Residential Efficient Cooling Equipment

High-efficiency Central AC AC Units 10,666 21,412 36,058 37,187 37,064 37,239 SEER 13.5 vs. 10.5

High-efficiency Room AC AC Units 4,646 9,316 15,639 15,978 15,941 15,993 SEER 10 vs. 8.5

Residential Evaporative Cooling

Direct Evaporative Cooling AC Units 3,555 7,137 14,423 14,875 14,826 14,895 Evaporative vs. direct cooling

Indirect/Direct Evaporative Cooling AC Units 178 1,784 7,212 7,437 7,413 7,448 IDDEC vs. direct cooling

Residential Lighting--CFL Bulbs

Compact Fluorescent Lamps (CFL) Bulbs 729,749 237,961 994,749 1,018,306 1,041,666 1,065,305 

Residential Lighting--CFL Fixtures

CFL Fixtures--Indoor Fixtures 20,450 62,713 106,859 109,389 111,899 114,438

CFL Fixtures--Outdoor Fixtures 3,870 11,869 20,223 20,702 21,177 21,658

Residential Lighting--Torchieres

CFL Torchieres Lamps 26,812 63,952 140,102 143,420 146,710 150,040

Compares CFL torchiere with 

std halogen or incand. lamp

Residential Appliance Recycling

Second Refrigerator Pickup Appliances 186,004 190,138 0 0 0 0

Measure cost includes pickup 

cost and administrative costs

Residential Clothes Washers

EnergyStar Vertical Axis Washers Appliances 5,463 10,954 18,389 18,790 18,744 18,800

SEHA Horizontal Axis Washers Appliances 5,463 10,954 18,389 18,790 18,744 18,800

EnergyStar Devices, Incentive Program Devices 518,428 1,038,328 1,737,351 1,758,052 1,755,797 1,758,995

Incentive program ends in 

2009

EnergyStar Devices, Mandatory Program Devices 20,173,792 20,105,881 20,265,715 20,489,221 20,484,333 20,522,500 

Mandatory program starts in 

2010

Residential "Weatherization" Includes savings of both

Weatherization of Elect. Heated Homes Homes 16,739 16,944 17,157 17,400 17,637 17,876 heating and cooling energy.

Duct Measures, Space Heating Savings Homes 16,848 17,075 17,292 17,511 17,738 17,997 Winter peak savings

Duct Measures, Space Cooling Savings Homes 15,996 16,211 16,417 16,625 16,841 17,087 Summer peak savings

Improvements to IECC 2000 Level Homes 24,458 24,592 24,963 26,093 25,970 26,144

Incentive program ends in 

2009

Enhancements beyong IECC 2000 Homes 241,068 243,198 244,371 245,181 246,049 246,352

Mandatory program starts in 

2010

Annual Program Participation (in measure units)

Residential Electronics Standby Loss 

Reduction

Residential Duct Testing and Sealing

Residential New Construction Building Shell 

Improvements
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 76 

ATTACHMENT 3: 

EXAMPLES OF ENERGY EFFICIENCY MEASURE AND PROGRAM EVALUATIONS 

PERFORMED FOR THE WESTERN REGIONAL AIR PARTNERSHIP (WRAP) 

The three "text boxes" that follow provide example of the procedures used in the 

evaluation of energy efficiency measures for the Air Pollution Partnership Forum of 

WRAP. The examples shown—for Commercial/Institutional/Industrial Transformers, 

Residential Air Conditioning, and Commercial Refrigeration—illustrate the process used 

in the "bottom-up" (end-use based) energy efficiency analysis carried out for the Interior 

West and Oregon/Western Idaho regions, and provide examples of some of the data 

sources and assumptions used. Each example documents three analytical “steps” for the 

measures and programs considered. The first two steps, compilation of measure costs 

and performance data and measure benefit/cost analysis, and estimation of program 

markets and participation, are carried out and documented in MS ExcelTM workbooks. 

The third step, estimation of program costs and savings, was accomplished using the 

ECO energy-efficiency program analysis software tool, developed by Tellus Institute. 

Commercial/Institutional/Industrial Transformers

Step 1: Compilation of Measure Cost and Performance Data, and Measures 

Benefit/Cost Analysis: 

Incremental costs for commercial-sized units were taken to be $4.42 per kVA, and for 

industrial-sized transformers, $1.81 per kVA (where “kVA” is thousand volt-amps, a 

measure of transformer capacity). These high-efficiency “TP-1” transformers save, for 

commercial and industrial applications, respectively, an average of 23.3 and 7.4 kWh per 

kVA of transformer capacity, relative to standard new transformers34. In order to 

estimate peak savings, a “peak factor” of 0.156 kW per MWh of energy savings was 

used, along with a transformer lifetime of 30 years35. 

The measure cost and savings data described above were used, along with rough 

estimates of avoided energy and capacity costs for electricity generation, to estimate 

benefit/cost ratios for the two transformer measures. Both proved very cost-effective 

(with benefit/cost ratios of about 3.3 for commercial transformers and 2.6 for industrial 

units), and were thus included in the WRAP energy efficiency package. 

 

34 Data on incremental costs and savings for high-efficiency transformers were derived based on Tables 5.4, 

5.7, and 5.8 of Supplement to the "Determination Analysis" (ORNL-6847) and Analysis of the NEMA 

Efficiency Standard for Distribution Transformers, by P. R. Barnes, S. Das, B. W. McConnell, and J. W. 

Van Dyke. This Oak Ridge National Laboratory Report No. ORNL-6925, dated September 1997, was 

received as ORNL6925.pdf from Jan Berry of ORNL, 10/24/01. The designation "TP-1" refers to a 

USEPA EnergyStar program standard for transformers. An ORNL expert on transformer technology (Mr. 

Lance McCord) was consulted regarding estimates for other parameters needed to estimate average 

transformer costs and savings. 

35 The peak factor used, 0.000156 kW per kWh saved, is taken from the "National" worksheet of the 

workbook "neep1017.xls", prepared by various researchers for the NEEP (Northeast Energy Efficiency 

Partnerships, Inc.) energy efficiency analyses, and summarizing national energy savings potential for a 

variety of energy efficiency improvements, most related to appliance or equipment standards. The average 

lifetime of transformers is also from this source. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 77 

Step 2: Program Market and Participation Estimation, and Estimation of 

Administration Costs 

The markets for commercial and industrial transformers in the Interior West (WSCR) 

region were estimated starting with an estimate that of nationwide annual sales of “drytype” transformers in 2000 totaled 22 million kVA36. In order to estimate the fraction of 

these transformers that were sold in each sector, average commercial-sector and 

industrial-sector load factors of 20 and 40 percent, respectively, were applied37. Using 

these load factors, the implied distribution of transformer sales nationally was calculated 

as 14.7 million kVA in the commercial sector, and 7.3 million kVA in the industrial 

sector. Based on WSCR region commercial and industrial electricity sales in 2000 

(61,615 and 54,858 GWh, respectively) and analogous figures for the U.S. as a whole, 

estimated year-2000 sales of transformers in the WSCR were calculated as 870,654 kVA 

in the commercial sector, and 375,684 kVA in the industrial sector38. These year-2000 

sales by sector were then extrapolated through 2018 using the rates of growth in 

commercial and industrial electricity sales included in National Energy Modeling System 

(NEMS) projections for the Mountain Census Region, yielding estimates of the markets 

for transformer sales during the 2002 to 2018 program period. 

Program participation was assumed to be 15 percent of transformer sales in the first 

program year, and 30 percent in subsequent years. This participation rate was based on 

judgment as to what a well-advertised, aggressive program might accomplish, and 

included the assumption of a budget of $500,000 to start up the program (the equivalent 

of perhaps 5 full-time staff, plus funds for developing program marketing materials), and 

a sponsor incentive equal to 50 percent of the incremental cost of the transformers. 

Administrative costs equal to 15 percent of sponsor measure costs were assumed, based 

on consideration of the effort likely to be required to process incentive payments and for 

ongoing program marketing, and the “free- rider” fraction was taken to be 15 percent39. 

Step 3: Program Costs and Savings Estimates 

Measure cost, savings, and lifetime estimates prepared as described in Step 1, above, 

together with estimates of annual program participation for each measure, administrative 

cost factors, sponsor cost fractions, and free-ridership estimates estimated as described in 

Step 2, were entered into the ECO software tool, together with estimates of parameters 

such as discount rates (4.88 percent annually, on a real basis) capital recovery factors 

(based on device lifetimes and the assumed discount rate), and the future inflation rate 

(2.8 percent annually)40. ECO was then used to calculate streams of annual costs (on 

 

36 From the 1997 ORNL report cited earlier. 

37 See, for example, The Cadmus Group, Inc (1999), Metered Load Factors for Low-Voltage, Dry-Type 

Transformers in Commercial, Industrial, and Public Buildings. File 120799_cadmus.pdf, downloaded 

10/23/01 from www.neep.org. 

38 National and state-level electricity sales data from the Energy Information Administration (EIA) of the 

US Department of Energy (USDOE). 

39 “Free-riders” are program participants that would have adopted the measure even in the absence of the 

sponsor’s incentive program. In practice, “free-ridership” is sometimes measured by post-program 

evaluation surveys or by market studies, but in many instances, for planning of DSM programs, values in 

the range of 10 to 20 percent are assumed. 

40 The discount rate used here is similar to real discount rates used by large utilities operating in the West. 
Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations 

Report; October 2002 

 78 

both “expensed” and annualized bases) and savings (electrical energy and peak power) 

for each of the two measures (commercial and industrial transformers) in the program, as 

well as for the program as a whole. Cost data from ECO (presented as customer and 

sponsor measure costs, and sponsor administrative costs) and savings data were 

aggregated with costs from other programs, and savings data were likewise aggregated, 

and the “package” of annual costs and savings results was summarized for consideration 

by the Air Pollution Prevention Forum and for inclusion in air pollution and economic 

impacts modeling using ICF, Inc.’s IPM software tool. 

 

 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

APPENDIX A-13. OTHER GCVTC OPTIONS

This appendix contains work products and references relied upon by Arizona in the 

development of Chapter 13 of the Regional Haze SIP. 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

Appendix A-13a. Arizona’s Assessment of Other Recommendations Of The 

Grand Canyon Visibility Transport Commission

 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

ARIZONA’S ASSESSMENT OF 

OTHER RECOMMENDATIONS 

OF THE 

GRAND CANYON VISIBILITY TRANSPORT COMMISSION

To Satisfy the Requirements of 40 CFR 51.309(d)(9) 

Arizona Department of Environmental Quality 

October 2003
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

Regulatory History and Requirements 

The recommendations of the GCVTC are presented throughout the June 1996 final report with 

varying degrees of specificity. Not all are included in the Regional Haze Rule. However, some 

of the recommendations were intended as a menu of options, with no expectation that any 

geographic area would implement all of them. The GCVTC pointed out in its final report that: 

“Some of the Commission's recommendations ask the EPA to take specific actions or 

institute particular programs, in cooperation with the tribes, states and federal agencies as 

implementing bodies. Other recommendations provide a range of potential policy or strategy 

options for consideration by the EPA and implementing entities. As the EPA develops policies 

and takes actions based on this report, this distinction between "actions" and "options" should be 

maintained with diligence. That is, recommendations intended as policy options should not 

become mandated actions or regulatory programs.” 

[bold emphasis in original.]1

The EPA acknowledged the discretion that should be afforded by states, and the need to report 

on what measures in the preamble to the rule (64 FR 35755): 

“9. Implementation of Additional Requirements. In section 51.309(d)(9), EPA requires SIPs 

to provide for implementation of other GCVTC Report policy and strategy options that 

can be practicably included as enforceable emissions limits, schedules of compliance or 

other enforceable measures to make reasonable progress toward the national visibility 

goal for the 16 Class I areas. The GCVTC’s recommendations included items that are 

not appropriate to directly translate to SIP requirements for every State. The EPA 

supports State choice of appropriate actions on other options and measures identified by 

the GCVTC and has, therefore, established a general provision for SIPs calling for them 

to consider and adopt additional measures as necessary and appropriate. The rule further 

requires States to report to EPA in 2003, 2008, 2013 and 2018 on what measures have 

been adopted and the status of implementation of those measures.” 

(a) Evaluation of additional Grand Canyon Visibility Transport Commission recommendations. 

Pursuant to 40 CFR 51.309(d)(9), Arizona has evaluated the “additional” recommendations of 

the Grand Canyon Visibility Transport Commission, to determine those recommendations have 

be, or may be, implemented based on national, regional, state, and or local initiatives. Arizona 

reviewed the GCVTC’s 1996 report, Recommendations for Improving Western Vistas, to identify 

those recommendations that were not incorporated into Section 309 of the Regional Haze Rule as 

specific requirements. Arizona has concluded that many of the can not be practicably included 

in this SIP at this time. Arizona will review the status of implementation of these 

recommendation in future SIP plan revisions required under 40 CFR 51.309(d)(10). 

(b) Implementation of Additional Recommendations. Based on the evaluation made by the State 

of Arizona, the following are actions and programs that have been adopted that support the 

 

1

 Recommendations for Improving Western Vistas. Grand Canyon Visibility Transport Commission, Western 

Governors' Association. Denver CO, June 1996. Page i. 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

additional recommendations of the GCVTC described in 309(d)(9). As is noted, the majority of 

these programs are related to mobile sources although a limited number of programs in other 

areas have been performed. 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

GCVTC 

Options/ 

Recommenda

tions 

Status of Implementation 

National Strategies for Mobile Sources 

Modeled 

by 

WRAP 

(see 

WRAP 

TSD for 

details) 

1. Adopt 49-

state LEV 

standards 

The National Low Emission Vehicle Program (NLEV) program is a voluntary 

program to introduce cleaner cars and light trucks in all parts of the country. The 

NLEV program will continue to exist until the cleaner Federal Tier 2 emission 

standards become effective in the 2004 model year. 

Regulated by EPA. 

Effective from model year 1996. 

62 FR 31192, June 6, 1997 

Although A.R.S 49-556 allows Arizona to adopt the NLEV program it also provides 

the state an opportunity to adopt the federal Clean Fuel Fleet program in lieu of the 

federal LEV program. The federal Clean Fuel Fleet program was, however, replaced 

by the Cleaner Burning Gasoline program. 

A.R.S 49-556 

Yes 

Yes 

New PM standards for Urban Buses for 1996 and later model years (0.5 g/mile) 

Regulated by EPA. 

Effective from model year 1996. 

61FR 6949, Feb. 23, 1996. 

2. Support Yes 

development 

of heavy duty 

vehicle 

(HDDV) 

standards New stringent emission standards and test procedures for all heavy duty diesel 

vehicles (HDDV) >8,500 lbs Gross Vehicle Weight Rating (GVWR) 

Regulated by EPA 

66 FR 5002, Jan. 18, 2001 

Yes 

Off-road standards for construction and other equipment phased in three stages - Tier 

1 through Tier 3. 

Regulated by EPA. 

Effective from model year 1996 through 2008. 

61 FR 58102, November 12, 1996. 

3. Negotiate Yes 

and adopt offroad standards 

Proposed off-road standards for construction equipment, industrial, agriculture, etc 

(comment period ended Aug 2003). 

Regulated by EPA. 

Effective from model year 2008. 

No 

Federal low sulfur diesel (15 ppm) standard for highway HDDV. Developed as part of 

the new heavy duty engine and vehicle standards and to treat the engine and fuel as 

one system. 

Regulated by EPA. 

Effective from 2007. 

66 FR 5002, Jan. 18, 2001 

4. Promote Yes 

broader 

application of 

cleaner fuels 

Federal Tier II gasoline standard requires refiners to produce gasoline with average 

sulfur standard of 120 ppm (300 ppm cap) beginning in 2004 and by 2006, average 

standard to be reduced to 30 ppm (80 ppm cap). 

Regulated by EPA. 

Phase in beginning 2004. 

65 FR 6698, February 10, 2000 

Yes 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

GCVTC 

Options/ 

Recommenda

tions 

Status of Implementation 

National Strategies for Mobile Sources 

Modeled 

by 

WRAP 

(see 

WRAP 

TSD for 

details) 

Locomotives: 

Standards phased in three stages - Tier 0, Tier 1 and Tier 2 

Regulated by EPA. 

Effective from model year 2001 through model year 2005. 

63 FR 18978, April 16, 1998 

* Model by WRAP note: modeled for a diesel sulfur content of 500 ppm. 

Yes 

Recreational marine diesel engines vessels greater than 50 hp, used in pleasure craft 

and yachts, and cruisers. (Less than 50 hp marine vessels are regulated under the Tier 

2 and Tier 3 federal off-road engine standards). 

Regulated by EPA. 

Phased-in beginning model year 2006. 

67 FR 68242, November 8, 2002. 

No 

Commercial marine diesel engines vessels 

Regulated by EPA. 

Phased-in beginning model year 2004. 

67 FR 68242, November 8, 2002. 

No 

Aircraft gas turbine engines with rated thrust greater than 26.7 kilo newtons. New 

standards align with International Civil Aviation Organization . 

62 FR 25355, May 8, 1997 

Yes 

All federal executive agencies are required to provide information to the Office of 

Management and Budget, regarding improvements made to federal facilities and 

activities aimed towards reducing pollution. 

Exec. Order #12088, 1978 

No 

5. Pursue 

strategies for 

diesel 

locomotives, 

boats, 

airplanes and 

federal 

vehicles 

EPA’s Partnership Plan includes measures such as Transit, Telecommute, rideshare 

and alt fueled fleet vehicles to reduce pollution from mobile sources. 

No 

7. Support 

improved 

control of 

evaporative 

emissions 

On-board refueling vapor recovery system reduces evaporative emission during 

refueling in cars. 

Regulated by EPA. 

Phased-in from 1998- 40%, 1999-80%, 2000-100% 

59 FR 16262, April 6, 1994 

Stage II vapor recovery systems are to be used in gas refueling stations in ozone 

nonattainment areas. 

In Arizona, regulated by ADWM. 

Effective from 1993 

Yes 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

GCVTC 

Options / 

Recomme

ndations 

Status of Implementation 

Mobile Sources – Regional/Local Strategies 

Modeled 

by WRAP 

(see 

WRAP 

TSD for 

details)

1. Establish 

Clean Fuel 

Demonstrati

on Zones

Fuel-based programs in the state 

Area A: 

1. Reformulated gasoline (Arizona Cleaner Burning Gasoline) 

2. Vehicle emissions inspection programs 

3. Stage II vapor recovery systems 

4. Vehicle Fleet Alternative Fuel Vehicle conversion requirement 

Area B: 

1. Oxygenated gasoline 

2. Vehicle emissions inspection program 

Yes

2. Analyze 

Pricing and 

Incentive 

Approaches

Nothing at this time

3. Explore 

Inspection 

Programs 

for Heavy 

Duty 

Vehicles 

Since 1975, ADEQ has implemented a program for heavy duty on-road diesel 

vehicles in Area A and Area B. 

Yes (as 

existed in 

1996) 

 

3. Explore 

Inspection 

Programs 

for Heavy 

Duty 

Vehicles 

(cont.) 

Emissions inspections for diesel vehicles in Area A and Area B. Yes 

 

 

 

All pre-1988 engines operated in Area A to meet 1988 or newer standards (GVWR ≥

26,000 lbs.)1

Effective from January 1, 2004; 

Regulated by ADEQ 

A.R.S 49-542(f)(7) 

3. Explore No 

Inspection 

Programs 

for Heavy 

Duty 

Vehicles 

(cont.) Sulfur content of diesel fuel limited to 500 ppm in Area A. 

Effective from 1993. 

Regulated by ADWM. 

A.R.S. § 41-2083 

Yes 

4. Promote 

vehicle 

maintenance 

Since 1975, the State of Arizona has implemented a vehicle emissions inspection 

program. 

Regulated by ADEQ. 

Arizona Administrative Code, R18-2-1001 through R18-2-1013 

Yes 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

GCVTC 

Options/ 

Recommend

ations 

Status of Implementation 

Other Recommendations 

Modeled 

by 

WRAP 

1. Develop 

emission fees 

programs. 

Fees for emissions are charged in the Operating Permits program, as required 

under 40 CFR Part 70. 

No 

WRAP has acquired emission inventory information for Mexican sources; see 

the WRAP Technical Support Document for regional haze SIPs for a complete 

description. 

2. Develop Yes 

comprehensive 

emissions 

inventory for 

Mexican sources In addition, EPA has funded various entities including the Western Governors' 

Association to work with Mexican to improve the quality of the information. 

No 

 
Appendix A-13 Other GCVTC Options Arizona Regional Haze SIP

Appendix A-13b. Summary of Discussions with Federal Land 

Managers on Emissions In-and-Near the Four 

Arizona GCVTC Class I Areas

 
1

Appendix A-13b. Table 1: Summary of Reported Information Regarding Dust Emissions: Grand Canyon National ParSource Category Activities Within the Class I Area Activities Near the Class I Area (wPaved and unpaved roads 

There are approximately 30-40 miles of scenic paved drives along each rim of the canyon and about 60 miles of unpaved roads (and additional residential and service roads, especially in Grand Canyon Village). Unpaved roads are reported to receive very little traffic and carry less than five percent of the 41 million vehicle miles traveled annually (for comparison, 71 million vehicle miles are traveled in Maricopa County each day). Visitors to the South Rim of the Canyon can use a shuttle bus system (4.8 million boardings in 2001). Road dust mitigation measures include wet sweeping. 

Paved and unpaved dirt roads exist, the canyon. Use of unpaved dirt roaincreased recently in the south. 

Mining activity No activity reported. A limestone mine is located approxi

Park near Peach Springs. Newly esto the northwest of the Park will moactivities. There are numerous uranmining at present.

Agriculture activity No activity reported. No activity reported. Grazing activity Some wildlife grazing is reported. Some livestock and wildlife grazing 

cattle grazing occurs south and nortBLM, and private lands), and family sheep and horse, some cattle) on the 
2

Appendix A-13b. Table 1: Summary of Reported Information Regarding Dust Emissions: Grand Canyon National ParSource Category Activities Within the Class I Area Activities Near the Class I Area (wWind generated emissions 

Several dry lake beds and beaches are potentially sources of wind generated dust but are only a few acres in size. 

Sparsely vegetated areas and increalargest is the Red Lake dry lakebed south of the Canyon. Sparse vegetaCoconino Plateau south of the Park blown dust in the Spring. The Coloarea appears to be rapidly colonized a dust source. 

Off-highway vehicles (OHV) 

There is no off-highway vehicle (OHV) activity Minimal off-highway vehicle activi

Highway Vehicle Management Plan National Forests in the state includinnear the Grand Canyon. When impwill help restrict OHV use to specifiwhen soil and vegetation impacts wpotentially reduce the amount of barerosion. 

Logging activity No significant activity reported. Limited thinning occurs 

adjacent to developed areas for wildfire protection and forest restoration. 

No significant activity reported. Limto developed areas for wildfire prote

Construction activity Various construction projects occur, but are of limited scope 

(a few new buildings, repaving projects, etc.) 

Unknown at this time 

Other area dust sources 

Foot and pack animal (mule) traffic occurs within the Park Unknown at this time 

Residential wood burning 

Approximately 55 woodstoves are used in the Park. Estimated fuel use is 3 cords/year. 

Some residential wood-burning acti

Prescribed burning and Wildfires 

Wildfires have occurred with noticeable smoke emissions. Prescribed fires also occur. 

Occasional wildfires are reported wemissions. Prescribed fires also occ

Point sources No activity reported. Coal fired power plant 20 km east o
1

Appendix A-13b. Table 2: Summary of Reported Information Regarding Dust Emissions: Mt. Baldy Wilderness Area Source Category Activities Within the Class I Area Activities Near the Class I ArePaved and unpaved roads No paved or unpaved roads are reported within the Wilderness 

area. 

More than 3,000 miles of roads sunspecified materials and over 4roads are reported on Forest Servreported to be the most common area. Observed emissions are reported roads or high-speed dirt roads anroad use and climate. Road accenormally from May through Octgenerally reduced from July throincrease in monsoonal rainfall. Rprojects are under development finclude a paving project for a strhigh recreational use gravel road Apache-Sitgreaves National Foreincludes a goal to reduce open ro2.5 miles per square mile by 202Fort Apache Reservation road dearea) is reported to be similar to have less vehicular traffic. 

Mining activity No activity reported. Areas of material mining (cinder 

Materials from these operations 

Agriculture activity No activity reported. Common agricultural activities a

alfalfa. These activities are geneWilderness area. 

Grazing activity No activity reported. Livestock grazing has not been allowed 

within the wilderness area for 10 years. 

Livestock grazing is a common apractices are reported to have imincreased soil loss from wind eroGrazing is generally downwind oManagement Plan includes a goa
2

Appendix A-13b. Table 2: Summary of Reported Information Regarding Dust Emissions: Mt. Baldy Wilderness Area Source Category Activities Within the Class I Area Activities Near the Class I Are

numbers of livestock with estimaA reported potential source of dustock tanks and irrigation reservocan dry out in early summer and wind erosion. 

Wind generated emissions No activity reported. Area winds show a diurnal patter

the southwest. Some localized adensity and low precipitation, padisturbed land subject to wind ergenerally downwind of the wilde

Off-highway vehicles (OHV) 

No activity reported. Frequent OHV activity is reporte

wilderness. An OHV Managemethe 7 national forests in the StateSitgreaves National Forest near Mimplemented, the plan will help rareas and times of the year when will be minimized and potentiallsoil exposed to wind erosion. To has been constructed east of the wATV use (near Springerville and 

Logging activity No activity reported. Logging is currently minimal in 

Emissions generation during logprimarily due to log trucks operalogging activity on the White MoReservation (west) is reported to operations in recently burned-ov

Construction activity No activity reported. Some development is reported to 

though limited private land is av

Other area dust sources No activity reported. Recreational trails are used prim

backpackers. 
3

Appendix A-13b. Table 2: Summary of Reported Information Regarding Dust Emissions: Mt. Baldy Wilderness Area Source Category Activities Within the Class I Area Activities Near the Class I Are

Area ski slopes have good grounthe summer. 

Residential wood burning No activity reported. A small number of wood stove a

approximately six miles northeasWilderness. This activity is not area, though may affect a nearby 

Prescribed burning and Wildfires 

No prescribed fires are planned. Wildfires are reported with noticeable smoke emissions. 

Occasional wildfires are reported emissions. Prescribed fires also 

Point sources No activity reported. Point sources include a power pl

located northeast of the Wilderneproduct fue. A lumber mill is reppower plant is also located northWilderness. 

Other defined sources No activity reported. No activity reported. 
1

Appendix A-13b. Table 3: Summary of Reported Information Regarding Dust Emissions: Petrified Forest National PaSource Category Activities Within the Class I Area Activities Near the Class I APaved and unpaved roads There are approximately 40 miles of two-lane paved road in 

the Park. A 4.5 mile portion of Interstate 40 passes through the northern portion of the park. In addition there are an unknown number of miles of unpaved roads. However, about half of the unpaved roads are closed and the remainder are used only by Park personnel. 

Paved roads and unpaved dirt access the park boundary. Unresidential and truck traffic goI-40 to the Adamana gas plant 

Mining activity No mines are in operation within the Park. An aggregate mine is in operat

southwest of the Park. 

Agriculture activity No agricultural activities are reported within the Park. Some agricultural activities (g

within 50km south of the Park activities within 50km northw

Grazing activity There is grazing of native animals only within the Park. Livestock grazing occurs near 

practices may have impacted closs from wind erosion in certa

Wind generated emissions Some localized areas of naturally occurring open (low 

vegetation density and low precipitation), disturbed land, and dry riverbeds may result in fugitive dust. Wind generated dust is reported to be the most common type observed in the area and is most common in spring. 

Some localized areas of naturavegetation density and low premay result in fugitive dust. Wto be the most common type ocommon in spring. 

Off-highway vehicles (OHV) OHV activity is not allowed. Recreational or OHV activity 

although it is unrestricted, and known. 

Logging activity No activity reported. No activity reported. Construction activity No activity reported. Some population growth and d

area. 

Other area dust sources There are approximately 10 miles of trails that are used only 

for hiking. 

No activity reported. 
2

Appendix A-13b. Table 3: Summary of Reported Information Regarding Dust Emissions: Petrified Forest National PaSource Category Activities Within the Class I Area Activities Near the Class I AResidential wood burning There appears to be some residential word-burning stoves. There appears to be some residPrescribed burning and Wildfires 

Vegetation in the park is shrub and grassland, with few trees. No prescribed fires are currently conducted in or within 50 km of the Park. Wildfires are not common in the area.

No prescribed fires are currentkm of the Park. Wildfires are 

Point sources No activity reported. Coal fired utility power plants 

Park and 52 km southeast of th
1

Appendix A-13d. Table 4: Summary of Reported Information Regarding Dust Emissions: Sycamore Canyon WilderneSource Category Activities Within the Class I Area Activities Near the Class I ArPaved and unpaved roads 

There are no paved roads or unpaved roads within the wilderness area. 

Paved roads exist near the wildeto be increasing in number. The number of unpaved roads ideclining in number, although uincreasing. 

Mining activity No activity reported. There are currently no mines in 

facilities have the potential to creopen. 

Agriculture activity No activity reported. Some agricultural activity occu

Verde areas, south/southwest of 

Grazing activity There is some grazing of domestic animals, however wildlife are 

reported to be the most common grazers in the wilderness. 

There is very little grazing and Mogollon Rim and Colorado pl

Wind generated emissions 

No activity reported. Winds in the area show a diurna

are generally from the south/souduring the day, with lighter dowWind generated dust is reported type of localized source of obseprevalent in April-July timeframweather events in the fall. AreaSycamore Canyon and in the Seare not considered to be frequen

Off-highway vehicles (OHV) 

No activity reported. OHV use is observed to be incr

(fall/winter/spring). This activito the east of the Wilderness aregenerally transported away from westerly winds. 

Logging activity No activity reported. Historically, logging activity (d
2

Appendix A-13d. Table 4: Summary of Reported Information Regarding Dust Emissions: Sycamore Canyon WilderneSource Category Activities Within the Class I Area Activities Near the Class I Ar

trucks) has occurred primarily ecurrent activity is reported. 

Construction activity No activity reported. Growth and development is occ

Cottonwood/Verde Valley and south and southwest of the Wild

Other area dust sources 

Recreational use has increased within the Wilderness, such as hiking, backpacking, and some horseback riding. 

No activity reported. 

Residential wood burning 

No activity reported. Some residential wood-burning 

Prescribed burning and Wildfires 

There have been no prescribed burns reported within the wilderness area.. Occasional wildfires are reported with noticeable smoke emissions. 

Occasional wildfires are reporteemissions. Prescribed fire adjaplanned and occurs in the fall th

Point sources No sources reported. A cement facility is located to t

Perkinsville and is permitted to 

Other No activity reported. There is agricultural burning in 

Verde areas (south/southwest o
Appendix A-14 – Projection of Visibility Arizona Regional Haze SIP

APPENDIX A-14. PROJECTION OF VISIBILITY

This appendix contains work products and references relied upon by Arizona in the 

development of Chapter 14 of the Regional Haze SIP. 

December 2, 2002 

Ms. Alice Edwards 

Air Non-Point & Mobile Sources Program 

Alaska Department of Environmental Conservation 

410 Willoughby Avenue, Suite 303 

Juneau, AK 99801-1795 

Mr. Dennis Schwehr 

Strategic Issues Management Group Inc. 

P.O. Box 2166 

Thompson Falls, MT 59873 

Mr. Bobby Ramirez 

Salt River Pima-Maricopa Indian Community 

10005 E. Osborn Road 

Scottsdale, AZ 85256 

Dear Ms. Edwards, Mr. Schwehr, and Mr. Ramirez: 

The Arizona Regional Haze Emissions Inventory Workgroup (EIWG) would like to provide the 

WRAP Emissions Forum with the results of our review of the 1996 WRAP Emissions Inventory. 

While the EIWG understands that it is not possible to change WRAP's 1996 emissions inventory, 

we are requesting that the WRAP Emissions Forum consider the recommendations. 

The enclosed report, “Review of 1996 WRAP Emissions Inventory For Use in Arizona's 

Regional Haze State Implementation Plan," summarizes EIWG's review and recommendations to 

enhance the inventories for certain emission source categories. An overview of this report will 

be presented by me at ADEQ's December 5, 2002, Regional Haze public workshop. The EIWG 

also requests that issues in the Report related to fire and dust emissions inventories be referred to 

the appropriate WRAP Forums. 
– 2 – 

We appreciate the WRAP’s hard work and diligence in developing an initial comprehensive 

emissions inventory for the western states. ADEQ and its stakeholders are committed to 

working with the Emissions Forum in its future work. For additional information on this report, 

please contact Randy Sedlacek, ADEQ, at 602-771-2352 or rfs@ev.state.az.us. 

Sincerely, 

Steven E. Peplau 

EIWG Chair, 

Maricopa County Air Quality Division Manager 

encl: 1 

cc: Tom Moore, WRAP 

Lee Gribovicz, Wyoming DEQ 
Review of 1996 WRAP Emissions Inventory 

For Use in Arizona's Regional Haze State Implementation Plan 

Emissions Inventory Workgroup 

November 25, 2002 
ii

EXECUTIVE SUMMARY

The Emissions Inventory Work Group (EIWG) reviewed the 1996 Western Regional Air 

Partnership's (WRAP) Emissions Inventory (EI) for use in Arizona's Regional Haze SIPs 

submitted after Year 2003. The majority of the review was based on comparisons 

between the WRAP EI and local emissions inventories developed by Maricopa County, 

Maricopa Association of Governments, Pima County, Pima Association of 

Governments, and Pinal County. Following is a summary of the EIWG's review and 

recommendations to ADEQ for working with WRAP to enhance WRAP emission source 

categories: 

1. Onroad Emissions - The vehicle miles traveled (VMT) data in the 1996 WRAP 

EI were larger than the VMT data in local emissions inventories and did not 

match the seasonal allocation of VMT. The EIWG suggests that local VMT data 

be used for developing the mobile onroad emissions for Arizona Regional Haze 

SIPs submitted after Year 2003, with particular attention to allocating VMT by 

season, because Arizona does not follow the national pattern for maximum VMT 

occurring during the summer season. 

2. Nonroad Emissions - Generally, the nonroad emissions data in the 1996 

WRAP EI were higher than the nonroad emissions data in local emissions 

inventories. Since the temporal pattern of nonroad equipment activity in Arizona 

can be quite different from the national average, the EIWG recommends that 

local Arizona nonroad emissions data be used in the Arizona Regional Haze 

SIPs submitted after Year 2003. 

3. Point Sources - Emissions data for point sources, greater than 100 tons per 

year, in the 1996 WRAP EI were larger than the emissions data for Maricopa 

County, and much larger than the point source emissions data in Pima County 

and Pinal County emissions inventories (e.g., as much as an order of magnitude 

for PM10 emissions from point sources in Pima County). In July 2002, both 

Maricopa and Pima Counties submitted corrected point source emissions data to 

WRAP's contractor. The EIWG recommends that emissions data from the state, 

local governments, and tribal entities be used instead of national surrogates for 

Arizona Regional Haze SIPs submitted after Year 2003. The EIWG also 

recommends that a decision be made whether fugitive dust emissions should be 

included as part of the point source inventory for Arizona Regional Haze SIPs 

submitted after Year 2003. 
iii

4. Area Sources - Emissions data for area sources in the 1996 WRAP EI were in 

relatively good agreement with the emissions data in Maricopa County (except 

for certain subcategories such as NOx from stationary source fuel combustion, 

which were grossly overestimated), but were not in good agreement with the 

emissions data for area sources in Pima County. The EIWG suggests that area 

source emissions in the WRAP EI be reviewed for accuracy before these data 

are used in Arizona Regional Haze SIPs submitted after Year 2003. 

5. Forest Fires - The WRAP EI and the Arizona Smoke Management Program may 

use different emission factors (but use the same activity data) to estimate 

emissions from forest fires. The EIWG suggests that forest fire emissions from 

the WRAP EI be compared to the Arizona Smoke Management Program's and 

for WRAP to lobby USEPA to use the most current emission factors for 

estimating emissions from forest fires (currently WRAP is using AP-42 emission 

factors). 

6. Agricultural / Rangeland Burning - Emissions data on agricultural / rangeland 

burning are planned to be included in the WRAP’s Year 2018 Fire EI. The EIWG 

suggests that the WRAP’s emissions estimates for this category be used, since 

little data are collected on agricultural / rangeland burning in Arizona. In the 

future, a statewide tracking system for the location, size, fuel type, fuel loading, 

and time of burning would greatly benefit the understanding of the contribution of 

this emission source to regional haze. 

7. Biogenics - The WRAP biogenic emission estimates for Maricopa County are 

much smaller than those calculated by the Maricopa Association of Governments 

(MAG) estimates. The EIWG plans to investigate this discrepancy further after 

receiving biogenic emissions data grouped by counties from the WRAP Modeling 

Center at the University of California - Riverside. 

8. Wind Erosion - This emission category is scheduled to be added to the WRAP 

EI after completion of a WRAP research contract. Estimating emissions from 

wind erosion entails accounting for a number of factors including local variations 

in soil type, wind patterns, precipitation patterns, vegetation growth, and 

topography. Due to the inherent complexity of developing wind erosion 

estimates for a region as large as Arizona, the EIWG suggests that the wind 

erosion data produced by the WRAP’s contractor be used in Arizona Regional 

Haze SIPs submitted after Year 2003. 
iv

TABLE OF CONTENTS 

BACKGROUND............................................................................................................... 1 

Federal Mandate .................................................................................................. 1 

History - ADEQ..................................................................................................... 1 

Role of Emissions Inventory Workgroup............................................................... 3 

WRAP Emissions Inventory.................................................................................. 3 

DISCUSSION.................................................................................................................. 3 

Mobile Sources..................................................................................................... 3 

Onroad Emissions - Maricopa County ....................................................... 3 

Onroad Emissions - Pima County.............................................................. 4 

Nonroad Emissions - Maricopa County...................................................... 5 

Nonroad Emissions - Pima County ............................................................ 5 

Point Sources ....................................................................................................... 5 

Maricopa County........................................................................................ 5 

Pinal County .............................................................................................. 6 

Pima County .............................................................................................. 7 

Area Sources........................................................................................................ 8 

Maricopa County........................................................................................ 8 

Pima County .............................................................................................. 9 

Forest Fire .......................................................................................................... 10 

Agricultural / Rangeland Burning........................................................................ 10 

Biogenics............................................................................................................ 10 

Maricopa County...................................................................................... 10 

Pima County ............................................................................................ 10 

Ammonia ............................................................................................................ 11 

Power Plants ...................................................................................................... 11 

Wind Erosion ...................................................................................................... 11 

CONCLUSIONS............................................................................................................ 12 

Onroad Emissions .............................................................................................. 12 

Nonroad Emissions ............................................................................................ 12 

Point Sources ..................................................................................................... 12 

Area Sources...................................................................................................... 13 

Forest Fires ........................................................................................................ 13 

Agricultural / Rangeland Burning........................................................................ 13 

Biogenics............................................................................................................ 13 

Ammonia ............................................................................................................ 13 

Power Plants ...................................................................................................... 13 

Wind Erosion ...................................................................................................... 13 
v

TABLE OF CONTENTS - CONTINUED 

REFERENCES.............................................................................................................. 14 

APPENDIX.................................................................................................................... 15 

Maricopa County Onroad Mobile Source Data (MAG)........................................ 15 

Pima County Onroad Mobile Source Data (MAG) .............................................. 16 

Improving the Estimation of Emissions from Agricultural Burning....................... 16 

LIST OF FIGURES 

Figure 1 - Arizona Class I Areas ..................................................................................... 2 

LIST OF TABLES 

Table 1 - Maricopa County Vehicle Miles Traveled ........................................................ 4 

Table 2 - Pima County Vehicle Miles Traveled ............................................................... 4 

Table 3 - Pima County Onroad Emissions (tons per day) ............................................... 4 

Table 4 - Maricopa County Nonroad Emissions (tons per day) ....................................... 5 

Table 5 - Pima County Nonroad Emissions (tons per day).............................................. 5 

Table 6 - Comparison of Maricopa County and WRAP Point Source Emissions ............ 6 

Table 7 - Comparison of Pinal County and WRAP Point Source Emissions ................... 6 

Table 8 - Comparison of Pima County and WRAP Point Source Emissions .................. 7 

Table 9 - 1996 Pima County Point Sources (> 100 tons per year) .................................. 7 

Table 10 - Comparison of Maricopa County and WRAP Area Source Emissions .......... 9 

Table 11 - Comparison of Pima County and WRAP Area Source Emissions ................. 9 
vi

ACRONYMS AND ABBREVIATIONS 

ADEQ Arizona Department of Environmental Quality 

ATR Automated Traffic Recorders 

CO Carbon Monoxide 

EI Emissions Inventory 

EIWG Emissions Inventory Work Group 

EPA United States Environmental Protection Agency 

GCVTC Grand Canyon Visibility Transport Commission 

GIS Geographic Information System 

HPMS Highway Performance Monitoring System 

MAG Maricopa Association of Governments 

MCESD Maricopa County Environmental Services Division 

NEI National Emissions Inventory 

NH3 Ammonia 

NOx Nitrogen Oxides 

PAG Pima Association of Governments 

PM10 Particulate Matter Less Than Or Equal To 10 Microns 

PM2.5 Particulate Matter Less Than or Equal to 2.5 Microns 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

U.S. United States 

USEPA United States Environmental Protection Agency 

VMT Vehicle Miles Traveled 

VOC Volatile Organic Compounds 

WRAP Western Regional Air Partnership 
1

BACKGROUND

Federal Mandate

As part of the Clean Air Act Amendments in 1977, Congress set a national goal of 

remedying existing visibility impairment, and preventing future impairment, from manmade 

pollution at the 156 national parks and wilderness areas across the United States (see 

Figure 1 for map of Arizona Class I Areas). Section 169 A was added to the Clean Air Act 

to address visibility impairment from existing stationary sources operating in and near 

national parks or wilderness areas. In this case, the visibility impairment could be found 

directly associated with or caused by the stationary source (i.e., reasonably attributable). 

Section 169B was added to address visibility impairment due to regional haze. Regional 

haze is defined as, "visibility impairment that is caused by the emission of air pollutants 

from numerous sources located over a wide geographic area. Such sources include, but 

are not limited to, major and minor stationary sources, mobile sources, and area sources." 

(40 CFR § 51.301). The Regional Haze Rule, adopted July 1, 1999, requires states to 

develop programs to assure reasonable progress toward meeting the national visibility goal. 

The way in which states develop and implement programs to address air pollution is 

through a state implementation plan (SIP) [1]. 

History - ADEQ

The state of Arizona has been actively involved in visibility and regional haze issues, 

beginning with the Grand Canyon Visibility Transport Commission (GCVTC) and continuing 

with the Western Regional Air Partnership (WRAP), the successor organization to the 

GCVTC. Each Arizona work group has a designated person to monitor the WRAP process 

and report items of interest and concern to the relevant group. The WRAP forums are 

expected to produce many work products that will be available for Arizona’s consideration 

as it develops its Regional Haze SIP. 

Beginning in August 2001, ADEQ launched Phase 1 of a stakeholder process to determine 

which schedule to follow in its development of a Regional Haze SIP. The federal Regional 

Haze Rule provides two choices for states and Indian tribes in the nine state GCVTC 

region. States submitting SIPs in 2003 will be implementing GCVTC recommendations per 

40 CFR § 51.309 (“309 SIP”). States submitting SIPs in the 2004-2008 time frame will be 

focusing on a broader range of sources and programs, per 40 CFR § 51.308 (“308 SIP”). 

The stakeholder process that began in August 2001 ended in early November 2001 with a 

consensus that ADEQ pursue the option to submit a SIP by December 31, 2003, in 

accordance with 40 CFR § 51.309. The stakeholders further agreed that the SIP should 

include the eight Arizona mandatory Federal Class I areas outside of the GCVTC region in 

addition to the four GCVTC region Class I areas [1]. 
2
3

Role of Emissions Inventory Workgroup

The Emissions Inventory Work Group is responsible for the review and recommendation of 

emission baseline and projections used in the SIP analysis. Specific responsibility areas 

include: 

• Develop and review emission inventory work products, as needed. 

• Review WRAP emission inventories/projections. 

• Consult with long-term strategy work groups to identify data gaps, and review 

projections of the effect of long-term strategies on emissions. 

• Develop updates for emission inventories/projections to be forwarded to the WRAP 

Regional Modeling Center [1]. 

WRAP Emissions Inventory

The 1996 WRAP emissions inventory (EI) includes four separate inventories for point 

sources, mobile sources, area sources, and fire by county for the thirteen states that are 

WRAP members. ADEQ and some counties in Arizona supplied point source emission 

estimates to the WRAP point source EI. The mobile source emissions were compiled 

by the WRAP Mobile Sources Forum using EPA’s MOBILE6 and NONROAD emissions 

models for onroad and offroad sources. Arizona area source emissions in the WRAP EI 

were based on estimates from the 1996 National Emissions Inventory and did not 

include geogenic wind blown dust from undisturbed natural soils. Fire emissions were 

compiled by the WRAP Fire Emissions Joint Forum [2]. 

DISCUSSION 

The Emissions Inventory Workgroup (EIWG) has met four times: June 19, 2002; July 17, 

2002; August 14, 2002, and September 16, 2002. During these meetings, EIWG members 

reviewed the Arizona portion of the WRAP EI, discussed the methodology used to develop 

the WRAP EI and how to utilize the WRAP EI in Arizona Regional Haze SIPs submitted 

after Year 2003 (e.g., 309G / 308 SIPs), and suggested enhancements to the WRAP EI for 

making Year 2018 forecasts. The following sections summarize the EIWG members’ 

review of the methodology and emissions data for the 1996 WRAP EI source categories. 

Mobile Sources 

Onroad Emissions - Maricopa County

Based on very limited model-compatible data, the WRAP EI’s onroad CO emission rates for 

1996 are comparable to MAG estimates for 1994 (Table 1). The WRAP EI does overstate 

1996 Maricopa County VMT by about 8% in the winter (CO), 13% on an average annual 

day (PM-10), and 25% in the summer (VOC, NOx). In addition, WRAP summer season 

VMT in 1996 (from onroad spreadsheet) is 13% higher than winter VMT. This is opposite to 

MAG’s VMT data that shows higher VMT in the winter than in the summer. 
4

Table 1 – Maricopa County Vehicle Miles Traveled 

1996 WRAP Onroad Inventory 71,538,442 mi/day 

1996 MCESD Onroad Inventory 51,329,514 mi/day 

Difference 20,208,928 mi/day 

% Difference -28.2% 

Both emissions inventories did use the MOBILE6 emissions model. The higher WRAP VMT 

estimates in the summer would explain some, but not all, of the higher VOC and NOx 

emissions listed for Maricopa County in the WRAP EI. 

Onroad Emissions - Pima County

For Pima County, the local VMT value used for the Pima Association of Government’s 

(PAG) 2003 Transportation Improvement Program (TIP) is 10.93% lower than the Year 

2003 VMT (average over 4 seasons) used for the WRAP EI. It is also important to note 

that the Year 2003 VMT used for the TIP only applies to eastern Pima County, which is the 

transportation planning area. The results are displayed in Table 2. 

Table 2 – Pima County Vehicle Miles Traveled 

2003 WRAP Onroad Inventory 21,760,515 mi/day 

2003 TIP 19,382,125 mi/day 

Difference 2,378,390 mi/day 

% Difference -10.93% 

The WRAP average annual daily VMT for Pima County (1996) is 19.4% higher than the 

Highway Performance Monitoring System (HPMS) average annual daily VMT for Pima 

County (1996). A discrepancy also exists with the seasonal VMT allocation in the WRAP EI 

for Pima County. The highest VMT for the WRAP Onroad EI was applied to the summer 

season. However, the summer season in Pima County typically yields the lowest VMT, 

with the spring season having the highest VMT. Table 3 lists the onroad emissions in the 

WRAP EI and the PAG EI. 

Table 3 – Pima County Onroad Emissions (tons per day)

VOC NOx CO

2003 WRAP EI 57.8 53.6 517.7 

2003 PAG Onroad Mobile 37.3 55.9 370.7 

% Difference -35.5% +4.3% -28.4% 
5

Nonroad Emissions - Maricopa County

1996 Maricopa County periodic inventories are lower than the WRAP EI for VOC (-43%) 

and NOx (-84%), and slightly higher (+21%), for CO (Table 4). Note that the periodic 

inventories were developed for a smaller CO/Ozone Nonattainment Area of about 2,000 

square miles versus Maricopa County, which is 9,200 square miles in area, which was used 

for the WRAP EI. The EPA NONROAD model used by WRAP is known to overstate 

nonroad activity levels. It is understood that a new and improved NONROAD model will be 

used by WRAP in the future. This should reduce some, if not all, of the disparity between 

WRAP’s and Maricopa County's estimates of VOC and NOx emissions. 

Table 4 – Maricopa County Nonroad Emissions (tons per day)

VOC NOx CO (winter) PM10

1996 WRAP EI 115.4 196.7 375.1 13.8 

1996 MCESD EI 66.3 32.0 452.4 NA 

%Difference -42.5% -83.7% +20.6% NA 

Nonroad Emissions - Pima County

PAG developed a nonroad mobile source inventory for the Year 2000. The PAG EI 

nonroad mobile emission estimates were compared with the Year 1996 nonroad mobile 

emissions estimates (tons/day) for the WRAP EI and are listed in Table 5. 

Table 5 – Pima County Nonroad Emissions (tons per day)

VOC NOx CO PM10 PM2.5 SO2

1996 WRAP EI 19.30 35.30 220.89 3.82 3.57 6.74 

2000 PAG EI 16.53 20.75 198.90 2.56 2.35 4.90 

%Difference -14.4% -41.2% -10.0% -33.0% -34.2% -27.3% 

Note that the area included in the PAG nonroad EI was the Tucson Air Planning Area 

(TAPA), which includes the bulk of the population within eastern Pima County (~96.5%), 

while the estimate for the WRAP EI includes all of Pima County. 

Point Sources 

Maricopa County 

The accuracy of the data on large point sources (>100 TPY) in the revised WRAP EI 

appears to be in generally good agreement with Maricopa County’s EI (Maricopa 

County submitted updated point source emissions data to WRAP contractors to revise 

the WRAP EI). Table 6 compares Maricopa County’s emissions with the emissions in 

the original WRAP EI. The emissions data that Maricopa County submitted to WRAP 
6

in 2001 contained all point sources included in the 1999 periodic emissions inventory for 

Maricopa County, with some sources having annual emissions as small as ten tons per 

year. Since the WRAP point source data only includes those sources greater than 100 

tons per year, Maricopa County submitted a revised set of point source data to WRAP 

contractors in July 2002. 

 

Table 6 – Comparison of Maricopa County 

and Original WRAP Point Source Emissions (tons per year)

VOC NOX CO 

WRAP Maricopa County 

1996 EI Base Case 

5,866 3,319 736 

Maricopa County 1996 EI 1,489 2,536 266 

% Difference between local and original WRAP/NEI data -75% -24% -64% 

Difference between local and original WRAP/NEI data in 

Tons

-4,377 -783 -469 

Pinal County 

There appear to be large discrepancies between the WRAP EI and Pinal County’s data 

on point source emissions. Tables 7 lists the results of comparing the Pinal County’s 

point source emissions with the WRAP EI. 

Table 7 – Comparison of Pinal County 

and Original WRAP Point Source Emissions (tons per year)

VOC NOX CO SO2 PM10 PM2.5 NH3 

WRAP Pinal County 

1996 EI Base Case 

144 2,076 483 27,974 2,531 990 2 

Pinal County 1996 EI 188 1,059 254 16,678 3,252 267 0.00 

% Differences (Increases 

from using WRAP/NEI 

data)

-23.4 +96 +90.2 +67.7 -22.2 +270.7 Na

Differences (Increases 

from using WRAP/NEI 

data) in Tons

-44 +1,017 +229 +11,296 -721 +723 +2

Grand Total [Differences (Increases from using WRAP/NEI data) in tons]: +10,552
7

Pima County 

There also appear to be large discrepancies between the original WRAP EI and Pima 

County’s data on point source emissions. Table 8 lists the results of comparing the 

Pima County’s point source emissions with the original WRAP EI. In July 2002, Pima 

County also submitted corrected point source emissions data to WRAP contractors and 

the mentioned discrepancies in Pima County’s point source emissions should have 

been corrected in the revised WRAP EI. 

Table 8 – Comparison of 1995 Pima County and 1996 Original WRAP Point 

Source Emissions (tons per year)

VOC NOX CO SO2 PM10 PM2.5 NH3 

WRAP Pima County 

1996 EI Base Case 

358 9,312 4,827 8,338 11,236 6,308 4 

Pima County 1995 EI 56 7,142 5,520 2,787 1,167 

(5,116)* 

NA NA 

% Differences (Increases 

from using WRAP/NEI 

data)

+539 +30.4 -12.5 +199 +862 

(+119)* 

NA NA

Differences (Increases 

from using WRAP/NEI 

data) in Tons

+302 +2170 -693 +5551 +10,069 

(+6,120)* 

+6,308 +4

Grand Total [Differences (Increases from using WRAP/NEI data) in Tons]: +13,995; (+10,046)* 

* Totals with Fugitives 

Five facilities in Pima County were identified as PM10 point sources that emitted more 

than 100 tons per year in 1996 based on Pima County and ADEQ permitted source 

records. These facilities and their associated PM10 emissions are listed in Table 9. 

Table 9 – 1996 Pima County Point Sources (> 100 tons per year)

Permitted 

By 

Facility Name PM10 Total With 

Fugitives 

PM10 Total 

Without Fugitives

ADEQ Cypress Sierrita 

(now known as Phelps 

Dodge Sierrita) 

2,633 tons 185 tons 

ADEQ Arizona Portland Cement 1,585 tons 84 tons 

ADEQ Tucson Electric Power 121 tons 121 tons 

PDEQ ASARCO Unknown 650 tons 

PDEQ Silver Bell Mining L.L.C. Unknown 127 tons 

Total 4,339 1,167 
8

As shown in Table 9, fugitive PM10 emissions can make a significant difference in the PM10

emission totals, especially with respect to sources such as mines. Thus, a determination 

needs to be made whether or not fugitive dust emissions should be included as part of the 

point source inventory that will be used in Arizona Regional Haze SIPs submitted after Year 

2003. If it is determined that fugitive dust emissions should be included in the point source 

inventory, then this needs to be applied consistently among all of Arizona counties’ 

emissions inventories. 

In order to ensure more accurate point and area source emission inventory reporting for 

future WRAP EI’s, the EIWG recommends that WRAP rely more on state/local/tribal 

entities for emissions data wherever possible, rather than using national surrogates. 

For example, there was little or no communication between WRAP’s contractor and 

Pinal and Pima counties during the building of the 1996 WRAP EI base case. This 

resulted in some discrepancies in the emissions for these counties that could have been 

corrected with input from the counties. 

Area Sources

The EIWG reviewed the WRAP EI at the county level, and selected several subcategories 

for comparison with locally developed emissions estimates. 

Maricopa County

Four emissions subcategories, that had the potential for large discrepancies between 

WRAP and Maricopa County values, were investigated further: 

• PM10: WRAP data for PM10 from industrial processes agree well with local 1995 

estimates. 

• VOC: WRAP estimates of VOC emissions from solvent use appear to be reasonably 

close to local numbers. 

• NOx: WRAP emission values for NOx from stationary source fuel combustion are 

grossly overestimated for Maricopa County and presumably statewide. 

• CO: WRAP data on emissions from waste disposal, treatment and recovery show 

nearly 9,000 tons of CO emissions from residential incineration in Maricopa County. 

However, there should be nearly no emissions from this source category because 

residential incineration is rare in Maricopa County. 
9

Table 10 compares WRAP estimates of area source emissions in Maricopa County with 

values from the County's 1995 Periodic Emission Inventory. 

Table 10 – Comparison of 1995 Maricopa County 

and 1996 WRAP Area Source Emissions (tons per year)

VOC NOX CO 

WRAP Maricopa County 

1996 EI Base Case 

64,712 36,797 22,470 

Maricopa County 1995 EI 39,550 4,589 1,678 

% Difference (Increases from using WRAP/NEI data) -39% -88% -93% 

Difference (Increases from using WRAP/NEI data) in

Tons

-25,162 -32,207 -20,792 

Pima County

Area source emission totals in the Pima County portion of the WRAP EI were compared 

with Pima County’s emissions data. The difference in the seven emission categories 

ranged from a negative 24% to a plus 107%. Table 11 lists the total emissions and 

differences for area sources in Pima County. 

Table 11 – Comparison of 1995 Pima County 

and 1996 WRAP Area Source Emissions (tons per year)

VOC NOX CO SO2 PM10 PM2.5 NH3 

WRAP Pima County 

1996 EI Base Case 

19,627 4,185 8,435 400 7,294 2,697 1,503 

Pima County 1996 EI 9,443 7,822 11,106 2,213 5,786 NA NA 

% Differences (Increases 

from using WRAP/NEI 

data)

+107 -46.5 -24.1 -81.3 +26 NA NA

Differences (Increases 

from using WRAP/NEI 

data) in Tons

+10,184 --3637 -2671 -1813 +1,508 +2,697 +1,503

Grand Total (Difference / Increases from using WRAP/NEI data in tons): +12,029
10

Forest Fire 

The Arizona Smoke Management Program, conducted by the U.S. Forest Service in 

conjunction with ADEQ, makes daily decisions on which prescribed fires should be 

approved based on weather conditions, fuel loading, location of fires, size of fires, and other 

fires in an air basin. The Arizona Smoke Management Program also tracks wildfire activity 

in Arizona. Annually, there are approximately 100 days when prescribed burning can take 

place in Arizona. The decision to approve a prescribed burn must balance both the need to 

promote forest health and the negative effects of fire on air quality. In the future, the 

number of prescribed fires will likely increase, while the number of wildfires will probably 

remain constant. The WRAP EI uses the activity data collected by the Arizona Smoke 

Management Program. The WRAP EI may use different emission factors than the ones 

use by Arizona Smoke Management Program; therefore, the EIWG suggests that forest 

fire emissions from the WRAP EI be compared to the Arizona Smoke Management 

Program’s and for WRAP to lobby USEPA to use the most current emission factors for 

estimating emissions from forest fires (WRAP is currently using AP-42 emission factors). 

 

Agricultural / Rangeland Burning

Agricultural burning was not included in the 1996 WRAP Fire EI, but it is planned to be 

included in the 2018 Fire Emissions Inventory. Currently, there are little specific data 

collected on agricultural / rangeland burning by WRAP, by counties, or the state of Arizona. 

(See appendix for overview of recommendations for improving collection of activity data for 

agricultural burning emissions). 

Biogenics

Maricopa County 

A comparison of the WRAP estimates of biogenic VOC and NOx emissions with those 

developed as part of the Maricopa County ozone nonattainment area inventory for 1996 

shows that WRAP EI estimates are much smaller (30 to 70 times) than the county-derived 

estimates. The WRAP modeling center in Riverside, California has been requested to 

prepare biogenic emissions, by county in Arizona, to facilitate further investigation of these 

large discrepancies. 

Pima County 

In 1998, PAG contracted with the University of Arizona to develop a biogenic emissions 

inventory for roughly the eastern half of Pima County. This inventory indicated that 50% of 

the total VOCs for this study area are emitted by biogenic sources. In contrast, for the 

Tucson metropolitan study area (developed urban and suburban area without surrounding 

elevated regions), 6% of the total VOCs are emitted by biogenic sources. Pima County 

biogenic emissions will be compared to the WRAP’s biogenic emissions when these data 

are received from the WRAP Modeling Center. 
11

Ammonia

The ammonia emission factors used for the WRAP EI are lower than those used to develop 

the 1994 Maricopa County PM10 inventory. Only livestock emissions could be compared, 

since Maricopa County did not calculate ammonia emissions from crops. The difference in 

the two sets of livestock emissions is proportional to the difference in emission factors, thus 

the activity numbers used in the WRAP EI and the 1994 Maricopa County PM10 Inventory 

are in good agreement. 

Power Plants

The EIWG assumed that power plant emissions in the WRAP EI would be fairly accurate 

because these data are based on the acid rain reports submitted to U.S. agencies. 

Wind Erosion

Emissions from wind erosion were not included in the 1996 WRAP EI. However, WRAP 

recently submitted a Request for Proposal for a contractor to add this emissions category to 

the WRAP EI. 
12

CONCLUSIONS

The WRAP is to be commended for developing a comprehensive emissions inventory for 

the western states. The Arizona portion of the WRAP EI will be an integral part of Arizona 

Regional Haze SIPs submitted after Year 2003. Following are the EIWG’s review and 

recommendations for enhancing certain emission source categories in the WRAP EI for 

use in Arizona Regional Haze SIPs submitted after Year 2003. 

Onroad Emissions 

WRAP’s VMT in Maricopa County overstates Maricopa County‘s VMT with the discrepancy 

being largest for the summer season (e.g., 8% more in winter and 25% more in summer). 

Pima County’s VMT may be also overstated (11%), and as with Maricopa County’s VMT, 

the WRAP seasonal allocation does not agree with Pima County’s data. The EIWG 

suggests that local VMT data be used for developing the mobile onroad emissions for 

Arizona Regional Haze SIPs submitted after Year 2003 with particular attention to 

allocating VMT by season, because Arizona does not follow the national pattern for high 

VMT occurring during the summer season. 

Nonroad Emissions

The WRAP used an updated NONROAD model for developing their nonroad emissions. 

However, a new NONROAD model, to be released soon by EPA, shows significantly lower 

nonroad activity levels. The technical support document being developed by ENVIRON will 

shed more light on the differences in assumptions and models that produced the WRAP EI 

estimates. However, since the temporal pattern of nonroad equipment activity in Arizona 

can be quite different from the national average, the EIWG recommends that local Arizona 

nonroad emissions data be used in the Arizona Regional Haze SIPs submitted after Year 

2003. 

Point Sources

Emissions data for point sources, greater than 100 tons per year, in the 1996 WRAP EI 

were larger than the emissions data for Maricopa County, and much larger than the point 

source emissions data in Pima County and Pinal County emissions inventories (e.g., as 

much as an order of magnitude for PM10 emissions from point sources in Pima County). In 

July 2002, both Maricopa and Pima Counties submitted corrected point source emissions 

data to WRAP's contractor. 

In order to ensure more accurate point and area source emission inventory reporting for 

future WRAP EIs, the EIWG suggests that emissions data from the state, local 

governments, and tribal entities be used, instead of national surrogates, for Arizona 

Regional Haze SIPs submitted after Year 2003. The EIWG also recommends that a decision 

be made whether fugitive dust emissions should be included as part of the point source 

inventory for Arizona Regional Haze SIPs submitted after Year 2003.
13

Area Sources

WRAP data for PM10 emissions from industrial processes and VOC emissions from solvent 

use agree well with Maricopa County data. However, WRAP emission values for NOx from 

stationary source fuel combustion are grossly overestimated for Maricopa County and 

presumably statewide. WRAP data on area source emissions for Pima County were not in 

good agreement with Pima County’s EI data. The EIWG suggests that area source 

emissions in the WRAP EI be reviewed for accuracy before these data are used in Arizona 

Regional Haze SIPs submitted after Year 2003. 

Forest Fires

The WRAP EI and Arizona Smoke Management Program may use different emission factors 

(but same activity data) to estimate emissions from forest fires. The EIWG suggests that 

forest fire emissions from the WRAP EI be compared to the Arizona Smoke Management 

Program’s and for WRAP to lobby USEPA to use the most current emission factors for 

estimating emissions from forest fires. 

 

Agricultural / Rangeland Burning

Emissions data on agricultural / rangeland burning are planned to be included in the 

WRAP’s Year 2018 Fire EI. The EIWG suggests that the WRAP’ emissions estimates for 

this category be used, since there are little data collected on agricultural / rangeland burning 

in Arizona. In the future, a statewide tracking system for the location, size, fuel type and 

loading, and time of burning would greatly benefit the understanding of the contribution of 

this emission source to regional haze. 

Biogenics

The WRAP biogenic emission estimates for Maricopa County are much smaller than 

Maricopa County’s estimates. The EIWG plans to investigate this discrepancy further after 

receiving biogenic emissions data grouped by counties from the WRAP modeling center. 

Ammonia

Ammonia emissions from livestock in the WRAP EI appear to be reasonable when 

compared to Maricopa County’s ammonia emissions data. 

Power Plants

The EIWG assumes that the power plant emissions in the WRAP EI are fairly accurate, 

because these data are based on the acid rain reports submitted to U.S. agencies. 

Wind Erosion

This emission category is scheduled to be added to the WRAP EI after completion of a 

WRAP research contract. Estimating emissions from wind erosion will entail taking into 

account local variations in soil type, wind patterns, precipitation patterns, vegetation growth, 

and topography. Due to the inherent complexity of developing wind erosion estimates for a 

region as large as Arizona, the EIWG suggests that the wind erosion data produced by 

WRAP’s contractor be used in Arizona Regional Haze SIPs submitted after Year 2003. 
14

REFERENCES

1. ADEQ Website (Regional Haze): http://www.adeq.state.az.us/environ/air/plan/haze.html

2. WRAP Website (Emissions Forum): http://www.wrapair.org/forums/ef/index.html

3. Eastern Research Group Inc. (ERG) and Enviro-Tech Communications, technical paper, 

dated February 15, 2002: "Non-Burning Management Alternatives on Agricultural Lands in 

the Western United States, Draft Final, Prepared for The Fire Emissions Joint Forum of the 

Western Regional Air Partnership." 
15

APPENDIX

Maricopa County Onroad Mobile Source Data (MAG)

The following data and assumptions were used in developing MAG’s onroad emission estimates: 

• The 1996 average annual vehicle miles of travel (VMT) used by WRAP in developing onroad 

emissions is 13% higher than comparable 1996 MAG VMT estimates and 15% higher than the 

Highway Performance Monitoring System (HPMS). 

• VMT from 1996 MAG traffic assignment = 58.85 million/weekday in the transportation 

modeling area 

• Factor to expand from MAG modeling area to Maricopa County = 1.11 

• Maricopa County average weekday VMT = 58.85 x 1.11 = 65.32 million/day 

• Factor to convert from average weekday to average annual day (including weekends) = 

.91 

• 1996 Maricopa County average annual daily VMT = 65.32 x .91 = 59.44 million/day 

• 1996 HPMS average annual daily VMT for Maricopa County reported to the Federal 

Highway Administration = 58.66 million/day 

• 1996 WRAP average annual daily VMT (from ENVIRON onroad spreadsheet) for 

Maricopa County = 67.26 million/day 

• Seasonal variations in VMT used by WRAP are not consistent with traffic counts in Maricopa 

County. 

• WRAP summer season VMT in 1996 (from onroad spreadsheet) is 13% higher than winter 

VMT. 

• The WRAP 1996 seasonal VMT estimates are 7.5% higher than the automatic traffic 

recorder-based estimates in winter and 25.3% higher in summer. 

• Automated traffic recorders (ATR) in Maricopa County indicate winter season traffic is 

consistently higher than summer traffic. 

• Based on ATR data, the 1996 VMT in the winter was 59.04 million/day and in the summer 

was 57.08 million/day. 

• The conclusions for Maricopa County onroad and nonroad emissions are derived from analyses 

of spreadsheets obtained from ENVIRON in July 2002. 
16

Pima County Onroad Mobile Source Data (PAG)

PAG calculated the Year 2003 onroad emissions factors using the MOBILE6 emissions model with 

the following inputs: 

• Low altitude only 

• Averaging summer and winter 

• Average freeway speed = 44.8 mph 

• Arterial speed = 35.4 mph 

• Local speed = 12.9 mph 

• The MOBILE6 emission factors were then applied to the estimated VMT for each roadway type 

(provided by PAG-Transportation Planning Division). 

Average Annual Daily VMT for Pima County 

• 1996 HPMS average annual daily VMT for Pima County = 15.71 million/day 

• 1996 WRAP average annual daily VMT for Pima County = 18.75 million/day, an increase of 

+19.4% over the HPMS data. 

Seasonal VMT Allocations - Tucson Permanent Traffic Count Recorders 

• March daily VMT is generally 7% higher than average daily VMT 

• July daily VMT is generally 5% less than average daily VMT 

Improving the Estimation of Emissions from Agricultural Burning

$ As stated in the draft report, Non-Burning Management Alternatives in Agricultural Lands in 

the Western U.S. [3]: “...obtaining agricultural burning data presented a significant 

challenge... Documented agricultural burning activity data exist for only a portion of the 15-

state domain, although agricultural burning is known to occur in nearly every state". 

Accordingly, all 15 western states should consider having mandatory organized smoke 

management programs that track agricultural burning activities. 

• Require all sources which obtain agricultural open burn permits to expand reporting parameters 

to include acres burned, duration of burn, exact location, (example: section/township/range) fuel 

loading specifications, and crop species to permitting agencies. This should be accomplished by 

amending current open burn permit regulations throughout the western region. 

• Capture agricultural burn permit parametric information in a regional database with a common/ 

consistent computerized format that can be easily utilized by various governmental agencies. 

• Display agricultural burning data utilizing a geographic information system (GIS). The goal is to 

illustrate the level of open burning in acres and to show, county by county, burning locations and 

type of residue burned. 

• Every state, local and tribal entity should implement a single agricultural burning reporting 

standard for continuity and consistency of parametric data. 
17

• Periodic agricultural burn site visits (i.e., random checks) should be conducted by governmental 

personnel to verify the accuracy and completeness of burning information provided by sources. 

• Resolve, or at least note differences, in permitted agricultural burn restrictions between counties 

or other localities. For example, Pima County and Maricopa County no longer allow the burning 

of agricultural fields as part of their counties’ open burning programs, whereas Pinal County 

continues to allow burning of agricultural fields. Pima County and Maricopa County do allow 

burning of ditch banks. 

• Establish a statewide agricultural burning program for tracking agricultural burning for location, 

size, fuel type and loading, and time of burning. To take it a step further, this program could be 

used as a control measure by making daily approval / disapproval of agricultural burning similar 

to the Arizona Smoke Management Program for prescribed forest fires. Currently, ADEQ’s 

statewide open burn permits are issued in advance for one year and only have restrictions on 

the time of day and season to conduct the agricultural burning. No data are collected on size, 

fuel type and loading, and time of burning as part of ADEQ’s open burn permits. 
Steven E. Peplau 

Division Manager 

1001 N. Central Ave. # 695 

Phoenix, Arizona 85004 

Phone: (602) 506-6701 

Fax: (602) 506-6179 

Maricopa County 

Environmental Services 

Air Quality

July 8, 2003 

Ms. Alice Edwards 

Air Non-Point & Mobile Sources Program 

Alaska Department of Environmental Conservation 

410 Willoughby Avenue, Suite 303 

Juneau, AK 99801-1795 

Mr. Dennis Schwehr 

Strategic Issues Management Group Inc. 

P.O. Box 2166 

Thompson Falls, MT 59873 

Mr. Bobby Ramirez 

Salt River Pima-Maricopa Indian Community 

10005 E. Osborn Road 

Scottsdale, AZ 85256 

Dear Ms. Edwards, Mr. Schwehr, and Mr. Ramirez: 

The Arizona Regional Haze Emissions Inventory Work Group (EIWG) would like to 

provide the WRAP Emissions Forum with the results of our review of the WRAP’s 

projections for Year 2018. It is important to note that if the EIWG’s suggestions for 

improving the 1996 WRAP emissions inventory (December 2, 2002 letter from 

EIWG to WRAP) are not implemented before applying the growth factors for the 

Year 2018, then the Year 2018 WRAP emissions inventory will reflect the same 

errors noted in the Year 1996 WRAP emissions inventory. 

Following are general observations and comments from the EIWG, and specific 

comments from two EIWG members, Maricopa Association of Governments (MAG) 

and Pima Association of Governments (PAG) regarding vehicle miles traveled 

(VMT) and population projections. 

General Observation of Long-Range Econometric Projections 

The Arizona Regional Haze Emission Inventory Work Group examined the accuracy 

of earlier projections of population growth used by the Grand Canyon Visibility 

Transport Commission that relied on the REMI model. The REMI modeling 

performed by the GCVTC subdivided the state into three economic sub-regions. The 

projections of the 2000 population were compared to the 2000 Census. Generally, 
2 Steven E. Peplau 

Division Manager 

1001 N. Central Ave. # 695 

Phoenix, Arizona 85004 

Phone: (602) 506-6701 

Fax: (602) 506-6179 

projected annual compound growth factors were lower than the actual, with a 95% 

confidence interval of approximately 1% per year. A similar analysis against Arizona 

Department of Economic Security projections showed that uncertainties in prediction 

could be as high as 3%. Thus, it is reasonable to expect that differences in 

projections from different sources could be 10% per decade. 

There are two major urban areas in Arizona. The following are observations from 

Maricopa Association of Governments (MAG) and Pima Association of Governments 

(PAG) regarding VMT and population projections that could be used by WRAP to 

improve future projections. 

Review of WRAP 2018 VMT and Population Estimates for Maricopa 

County 

The rate of growth (3.1% annually) in average annual VMT for Maricopa County 

between 1996 and 2018, used by the WRAP, is comparable to the VMT growth rate 

based on the ASU Center for Business Research population projections (Middle 

series). However, for the summer season, the rate of growth (3.5% annually) in the 

WRAP projections is much higher, resulting in a 2018 VMT for Maricopa County 

that is about 10-11 % more than 2018 estimates using the latest ASU population 

projections. Since visibility impairment at the Class I areas on the Colorado Plateau 

tends to be highest during the summer, the over-estimation of summer VMT will 

overstate Maricopa County's contribution to regional haze on the 20 % worst days. 

This problem can be corrected in future WRAP modeling for the desert Southwest by 

reversing the seasonal factors so that they are lower in the summer and higher in the 

winter. Appropriate seasonal factors for vehicle travel in Maricopa County can be 

obtained from the Maricopa Association of Governments (see enclosure for 

supporting documentation for calculations). 

MAG’s population data as a whole falls within 10% of the WRAP population data. It 

is useful to compare MAG’s own population projection done in 1993 that predicted a 

population of 2.95 million in the Year 2000. The actual population in the Year 2000 

was 3.1 million, a 4.8% difference. 

Review of MAG Growth Factors for Agricultural Activity 

MAG developed a set of emissions growth factors for agricultural activity projected 

from 1996 to 2018 and compared them with those used in WRAP. Please note that 

MAG’s comments can only be made based on the comparable pairs, since a direct 

comparison between MAG’s and WRAP’s projections cannot be made because many 
3 Steven E. Peplau 

Division Manager 

1001 N. Central Ave. # 695 

Phoenix, Arizona 85004 

Phone: (602) 506-6701 

Fax: (602) 506-6179 

of the SCC codes either use different growth factor references or are not used in 

MAG's inventory. 

The comparison reveals no significant discrepancies between the WRAP and MAG 

agricultural growth factors, except for the emissions from agricultural equipment. 

The surrogate used for agriculture equipment is the harvested area. The Arizona 

Agricultural Statistics showed that the harvested area in Maricopa County decreased 

from 449,160 acres in 1980 to 236,000 acres in 1999. Based on that, the growth 

factor MAG derived for agricultural equipment from 1996 to 2018 is 0.28. However, 

the growth factor for agricultural equipment used in WRAP is 1.61, implying an 

increase in that source category. 

As previously noted, the WRAP growth factor for agricultural equipment is projected 

to increase in the WRAP modeling. Agricultural activity in Maricopa County is, in 

fact, decreasing. The EIWG recommends that the WRAP should examine the growth 

factors for agricultural activities, especially in urbanized counties, to ensure the 

projections are reasonable. 

Review of WRAP 2018 VMT and Population Estimates for Pima 

County 

The Pima Association of Governments (PAG) developed draft population growth 

factors for Pima County based on Year 2000 Census data. These data are still in draft 

form and will be utilized for PAG’s Year 2030 Regional Transportation Plan 

planning process. The projections represent the traffic analysis zones comprising 

eastern Pima County and part of southeastern Pinal County. PAG’s projected growth 

factors were compared with the GCVTC IAS growth factors for population (e.g., 

1990 compared to 2000, 2010, 2020 and 2030). It appears that the IAS Years 2000 

and 2010 growth factors compare well with PAG’s, however the Years 2020 and 

2030 factors used by PAG are higher than those used by the WRAP (e.g., Year 2020 

= 1.956 vs. 1.757 and Year 2030 = 2.303 vs. 1.973). Year 2040 projections have not 

yet been developed by PAG. 

With respect to VMT, it is difficult to compare locally developed data with WRAP 

data because the data have been developed in different formats and for different 

years. However, it is probably safe to assume that the concerns of Maricopa County 

for VMT can be mirrored by Pima County. WRAP's numbers tend to overestimate 

locally-derived VMT numbers, particularly in the summer, which is the worst season 

for regional haze. For the Year 2003, the local VMT value used for the PAG 2003 

Transportation Improvement Program (TIP) is 11% lower than the 2003 VMT used 

for the WRAP EI. In a similar pattern to Maricopa County, the Tucson metropolitan 
4 Steven E. Peplau 

Division Manager 

1001 N. Central Ave. # 695 

Phoenix, Arizona 85004 

Phone: (602) 506-6701 

Fax: (602) 506-6179 

region records its lowest VMT in the summer and its highest VMT in the spring 

season. 

General Observation and Recommendation 

The Emission Inventory Work Group notes that the growth factors used by WRAP 

are within the expected range of uncertainty for long-range projections. In 

development of future projections it is recommended that WRAP consider utilizing 

local population and VMT projections, and seasonally correct for the fact that 

summer activity data is generally lower than the winter. 

We appreciate the WRAP’s hard work and diligence in developing Year 2018 

projections for the western states. ADEQ and its stakeholders are committed to 

working with the Emissions Forum in its future work. For additional information on 

this report, please contact Randy Sedlacek, ADEQ, at 602-771-2352 or 

rfs@ev.state.az.us. 

Sincerely, 

Steven E. Peplau 

EIWG Chair 

Air Quality Division Manager 

Maricopa County Environmental Services Department 

cc: Tom Moore, WRAP 

Lee Gribovicz, Wyoming DEQ 
5 Steven E. Peplau 

Division Manager 

1001 N. Central Ave. # 695 

Phoenix, Arizona 85004 

Phone: (602) 506-6701 

Fax: (602) 506-6179 

ENCLOSURE

Maricopa County VMT projections for 1996-2018 

In May 2001, MAG provided 1996 and 2018 traffic assignments for Maricopa 

County to WRAP consultants. They were also given growth factors for the 

intermediate years: 2003, 2008 and 2013. The MAG traffic assignments were 

produced on the 1272 TAZ system which did not 

cover all of Maricopa County. The consultants were advised to factor the VMT 

produced by the assignments by 11% to expand the VMTs to cover all of Maricopa 

County. Based on the information provided, the VMTs for Maricopa County should 

have been as follows: 

Maricopa County VMT Growth Factors 

(in 1000's per weekday) Provided to ENVIRON 

1996 65,321 

2003 82,850 1.27 

2008 95,176 1.46 

2013 106,386 1.63 

2018 116,854 1.79 

Average annual VMT growth rate: 1996-2018= 2.70% 

Note that the VMTs above represent an average weekday and should have been 

multiplied by .91 to obtain VMT on an average annual day (before applying seasonal 

factors). 

The ASU population projections done by the Center for Business Research in 2001 

show a 2.64% growth rate between 2000 and 2020 (for the Middle projection series). 

MAG is in the process of using these same ASU projections for Maricopa County to 

prepare interim small area population and employment projections that, at the end of 

May, will be presented for approval to the MAG Regional Council. MAG has 

completed preliminary traffic assignments on a 1941 TAZ system using the draft 

interim projections. The resultant VMTs (which include most of the populated areas 

of both Maricopa and Pinal Counties) produce an average annual VMT growth rate of 

about 3.09% for 2000-2020. 

An analysis of the WRAP VMT projections provided by Alison Pollack of 

ENVIRON on 7/11/02 can be found in the attached spreadsheet. 
6 Steven E. Peplau 

Division Manager 

1001 N. Central Ave. # 695 

Phoenix, Arizona 85004 

Phone: (602) 506-6701 

Fax: (602) 506-6179 

The WRAP's average annual growth factors are slightly lower than the factors 

calculated in Environ spreadsheet. However, this does not take into account the overestimation of 1996 VMTs, as documented in the Fall of 2002 for the EIWG. In that 

previous analysis, the WRAP's 1996 VMT estimates were found to be 13% high on 

an average annual basis, 8% high for the winter season, and 25% high for the summer 

season. Reducing the WRAP's 1996 VMTs by these amounts and comparing them 

with the WRAP's projected VMTs, results in the adjusted growth factors shown at the 

bottom of the attached spreadsheet. 

The rate of growth between 1996 and 2018 for the average annual VMT used by the 

WRAP is approximately the same (3.07%) as for the new VMT projections in #2 

above (3.09%). However, in the summer, the rate of growth between 1996 and 2018 

(3.54%) is much higher. Using the latest ASU population projections, results in a 

Maricopa County VMT projection for 2018 that is about 10-11 % higher than VMT 

estimates.
 

ARIZONA DEPARTMENT

OF

ENVIRONMENTAL QUALITY

1110 West Washington Street y Phoenix, Arizona 85007

(602) 771-2300 y www.adeq.state.az.us Janet Napolitano 

Governor 

Stephen A. Owens

Director 

Northern Regional Office 

1515 East Cedar Avenue y Suite F y Flagstaff, AZ 

86004 

(928) 779 0313

Southern Regional Office 

400 West Congress Street y Suite 433 y Tucson, AZ 

85701 

(520) 628 6733

Printed on recycled paper

October 20, 2003 

Tom Moore 

Technical Coordinator 

Western Regional Air Partnership 

Cooperative Institute for Research in the Atmosphere 

Colorado State University 

1375 Campus Delivery 

Fort Collins, CO 80523-1375 

Dear Tom: 

Arizona’s Regional Haze Technical Assessment Work Group (TAWG) met on August 14, 2003, 

to review the draft WRAP Technical Support Document (TSD) for Regional Haze State 

Implementation Plans (July 14, 2003). Informal feedback was provided to you a few days later; 

and TAWG appreciates the changes reflected in the August 27, 2003, draft TSD. In September, 

the group met again to discuss this later version and produced several comments that are attached 

to this letter. The following points summarize the detailed comments. 

• Some technical materials are better relegated to appendices, especially all of the 

Integrated Assessment Section, most of the SMOKE, and some of the CMAQ sections. 

For example, in SMOKE, the specific file names and dates, as well as much of the 

detailed descriptions of the emission processing mechanics, while useful for modelers, 

make it difficult for others to understand the work done. 

• TAWG requests that additional work be done related to redoing the ammonia emissions 

inventory and performing a CMAQ modeling run to determine the sensitivity of fine 

particulates and visibility from Mexican sources. 

• The protracted discussion on the non-road models did not explain which model was used 

to generate which emissions for which are quality modeling run. This needs to be 

clarified. If the NONROAD2002 work was only emission sensitivity testing, then this 

needs to be so stated. The reader is left with the impression that differences in non-road 

estimates are significant and important, but the discussion fails to explain how or whether 

these differences affected the outcome of the modeling. 
• In spite of the descriptions of the many methods employed to construct the inventory, the 

fire emissions section needs a clear explanation of what and why certain emissions were 

used for the 1996 model validation work and what emission were used for the 1996 base 

case. A table that presents these emissions for agricultural, prescribed, and wild fire 

burns for all of the important 1996 and 2018 air quality modeling runs would be helpful. 

 

• It was unclear how point sources emitting <100 tons of sulfur dioxide per year were 

treated. Are they included in the area source totals? 

• Throughout the document, the tabulated data and charts covered different numbers of 

states: sometimes six, sometimes nine, sometimes 13, sometimes 20+. This 

inconsistency should be remedied, if, by no other means, than by giving the subtotals for 

the various group of states in each chart. 

• Several sections would benefit from some basic explanatory material (for example, 

biogenic VOC emissions come from plants and biogenic nitrogen oxide emissions come 

from microbial activity in the soil.) On the first page of the Technical Analysis 

Approach, some introductory material would be helpful before getting in the details of 

emissions. The relationship of emissions inventories, SMOKE, MM5, MCIP, and 

CMAQ could be shown in a simple diagram. The general modeling approach needs to be 

explained in terms of reconstructed visibility. In addition, the general modeling approach 

needs to be discussed in terms of the speciated fine particulates measurements of the 

IMPROVE network. Although this material would amount to no more than two or three 

paragraphs, through it, the reader would be informed at the beginning of all the various 

interlocking pieces of the modeling system. 

On behalf of the Technical Assessment Work Group, I thank you for the opportunity to review 

the draft TSDs and am willing to discuss anything in further detail. I may be reached at (602) 

771-7642. 

Cordially, 

Peter Hyde, Chair 

Arizona Regional Haze Technical Assessment Work Group 

Attachment 

cc: TAWG Members 

 Nancy Wrona 

 Corky Martinkovic 
ARIZONA DEPARTMENT

OF 

ENVIRONMENTAL QUALITY

1110 W. Washington Street • Phoenix, Arizona 85007 

 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens 

Director

Janet Napolitano 

Governor

Southern Regional Office 

400 West Congress Street • Suite 433 • Tucson, AZ 

85701 

(520) 628-6733 Printed on recycled paper 

Northern Regional Office 

1515 East Cedar Avenue • Suite F • Flagstaff, AZ 

86004 

(928) 779-0313

September 23, 2003 

The following comments on the WRAP TSD for regional haze are from various members 

of the Arizona Regional Haze SIP Technical Assessment Work Group. The first set of 

comments comes from an August 14, 2003, meeting, and immediate follow-up. The version 

of the TSD for these comments is July 14, 2003. 

FIRST SET 

COMMENTS ON THE DRAFT REGIONAL WRAP TSD FOR THE REQUIREMENTS 

OF §309 OF THE REGIONAL HAZE RULE 

Shawn Kendall distributed copies of his comments. Discussion and changes suggested to the 

TSD, as posted to the ADEQ website on July 16, 2003, included: 

 (website) – Kendall and Rory MacArthur suggested deleting the subchapter pieces of the 

TSD due to wrong legends appearing on the pdf files. 

 Table of Contents – Change headings for chapters 3-8 to read “Assessment of ...” 

(Kendall). 

 P. 9, line 17 – Change to “with a simplified chemistry” (MacArthur, Kendall). 

 P.11 – MacArthur asked about Mexican emissions. Kendall and others said that this 

information was used and modeled, but not singled out for comment. TAWG members 

agreed that WRAP should be asked to assess the impact of Mexico’s emissions. Kendall 

suggested that WRAP also cross check the inventory for Mexico for new and upcoming 

sources scheduled to begin operations prior to 2018. 

 P. 16 – Hyde noted that emissions inventories are available for Nogales and Agua Prieta, 

Sonora. 

 Bill Wiley commented that the commercial marine emissions information needs to be 

moved up to the international emissions section. 

 P. 16 – Kendall said that it appears that geogenic information was not included, and that 

2018 PM figures will equal those for 1996. He said that PM will need to be able to be 

modeled in the future. 

 MacArthur asked if wind erosion had been calculated for property lots. Don Gabrielson 

said that there is an overall lack of windblown inventory. 

 P. 18, top – Kendall asked about the relevance of the P2 information. The group agreed 

to eliminate the chart, but keep the information. 

 P. 19 – Hyde noted that the charts do not show off-shore emissions. 

 P. 19 – Kendall suggested showing tons reduced in the 2018 pie chart. 

 Wiley asked about sources of NH3 emissions. Gabrielson said that he believes this is 

feed lots and dairies. 
TAWG Draft Meeting Notes, 9-10-03 2

 Gabrielson asked if the pie charts are available showing state-by-state results. Kendall 

said he does not think these are available, but could be generated if the data was obtained. 

 P. 23, line 23 – Hyde asked if the date was necessary. Kendall said this helps explain 

which version of the data was used. 

 Hyde asked about emissions from point sources emitting less than 100 tpy. Kendall said 

this limit was used since this is the value used in determining sources eligible to 

participate in the SO2 trading program. Wiley asked if sources below this threshold were 

included in the area source emission inventory. TAWG members agreed this issue 

should be pursued. 

 P. 24 – The workgroup agreed that the NH3 inventory needs to be reworked. 

 P. 25 – Members commented that the Integrated Assessment Section does not seem 

relevant. 

 P. 27 – Hyde questioned why the PM figures don’t decrease from Table 2 to Table 3. 

 Add a table with the WRAP annex results (Gabrielson). 

 P. 28 – Explain the delineation between stationary source and those under 100 tpy 

(Gabrielson). Also, name the important subcategories (Hyde). 

 P 29, line 1 – Expand the discussion of other windblown dust categories that are not 

included (Gabrielson, Hyde). 

 P. 31, lines 6 and 8 – Kendall suggested improving the subtitle formatting, adding titles 

to these tables, and reviewing the document globally for this concern. 

 Tables 4 and 5 – add column showing the percent change for the nine GCVTC states and 

13 WRAP states (Ruey-in Chiou). 

 P. 32, line 10 – Hyde said that the off-road mobile equipment does not include 

commercial marine. Kendall noted that commercial marine was in a later section. 

 A summary should be added showing relevant emission of aircraft, locomotives, and 

commercial marine (Hyde). 

 P. 32 – MacArthur noted that it was unclear which non-road model was used to calculate 

emissions. 

 P. 34, line 26 – MacArthur asked how nonroad modeling was used. If the results of 

NONROAD2002 weren’t used, this information does not need to be included in this 

preliminary section (Hyde). 

 Add tables to consistently show nonroad sources (Kendall). 

 Break down subcategories of nonroad (Hyde). 

 MacArthur commented that the mobile source significance issue is very sensitive, and 

noted that the WRAP policy group determined that reasonable progress must be made. 

Kendall remarked that the discussion is too detailed to appear in the TSD. Hyde and 

MacArthur said that the mobile information should be improved. 

 Wiley noted a lack of consistency in the states included for analysis. Add a subtotal of 

the nine GCVTC states. 

 MacArthur was concerned that commercial marine and locomotives are discussed 

simplistically. Kendall suggested referencing material used for aircraft, commercial 

marine and locomotive categories. 

 P. 42 – Wiley noted that six states were used in the table, and that too many different 

domains are referenced. Remove Table 6 and change text on p. 43 to read “see Chapter 8 

for a detailed discussion.” 
TAWG Draft Meeting Notes, 9-10-03 3

 Hyde said that it is not clear whether 1996 and 2018 prescribed fire figures were included 

in the base case. He would like additional information included. Kendall commented 

that WRAP used 2018 “typical” wildfire data. 

 Wiley asked about missing agricultural burning information. Kendall replied that 

agricultural burning is quite low. 

 Kendall distributed the draft of Table 14-1 and Appendix A-14.1a,b, and c and said that 

the TSD should report whether typical or actual 1996 data was used for model 

calibration. He also noted that the anticipated growth in prescribed fire is not shown. 

Kendall and Wiley commented that the fire emissions data for 1996 is missing. Kendall 

said that the spread sheets provided by WRAP don’t show the change, but the pie charts 

do. 

 P. 47 – Add tables showing 1996 acreage and emissions of fires; plus, a similar summary 

for 2018 (Hyde). 

 P. 56, biogenic emissions – Replace the detailed variable list with a narrative description 

of the ASCII file. Show total VOC emissions in Table 10. Describe where biogenics 

emissions come from and how they are produced. Revamp this section and include a 

discussion of biogenics as the largest source of VOCs. 

 Windblown dust – Discuss how days with windblown dust would impact results. Table 

11 is too extensive. Change to a description of the scenarios in the TSD and move the 

table to the appendix. 

 P. 64-66 – Clarify which states the pie charts represent. 

 SMOKE section – Most of the section needs to go into an appendix. The introductory 

paragraph should include generic information on how a computerized tool manipulates 

files to produce usable information for use in air quality. 

 Gabrielson asked about the target audience of the document. The group agreed that the 

body of the TSD should be aimed at the technical/policy analysts, with detailed 

information needed for reconstructing the modeling in appropriate appendices. 

 P. 65-70 pie charts – Kendall asked if one-day averages are relevant. Hyde responded 

positively, saying that if the average weekday was used, the information is relative, 

except perhaps in fire emissions. 

 P. 65, scales for off-road for VOCs for biogenics; and p. 67, SO2 columns – Delete these 

pie charts and reduce the corresponding narrative. 

 P. 86 – Hyde suggested writing this in layman’s terms as much as possible. Eliminate 

tables 22, 23, 24 and much of the discussion. 

 P. 87, line 6 – The TSD currently reads “performed well.” Chiou suggested that actual 

performance information replace this conclusion. 

 Gabrielson suggested that overall, the narrative should address somewhat technical 

policymakers and other information should be shifted to the back of the document. There 

was general work group agreement. 

 P. 93 – Kendall suggested adding a flow model. 

 Gabrielson suggested that each discussion of a model include information about where 

the reader can get more information. 

 MacArthur commented that the MSIP was known to have a bug and asked if the 

subsequent WRAP modeling addressed this issue. 

 Kendall commented on how robust the CMAQ modeling is, compared to other models. 

MacArthur agreed, saying that this should be a consideration. 
TAWG Draft Meeting Notes, 9-10-03 4

o Kendall was concerned about the lack of information on PM speciation (elemental 

carbon and organic carbon). P. 91, line 2 – Add a lead paragraph that compares and 

contrasts the GCVTC air quality modeling with the described anticipated modeling, 

including the benefits. 

 MacArthur requested more information about performance in the summer versus winter 

months. 

 P. 101 – Hyde suggested that the axis on the scatter plots be reduced in value, which 

would result in showing more accurate information. The group agreed that this was not a 

crucial issue. 

 P. 113 – Add language to the effect that many of the 20% dirtiest days occur in the 

summer, when the model performance is best. 

 P. 114, line 20 and globally – eliminate use of “we” (Kendall). 

 P. 114, line 20 – Wiley said this section needs to explain that this is the best model 

available, and that it works best in the summer. Kendall said that there should be an 

acknowledgment that there are other ways to evaluate a model rather than paired-in-timeand-space, and include language to the effect “nonetheless, the modeling represents the 

best available science...” 

 P. 114, line 20 – Paragraph should be changed to support the use of the modeling results 

in general, since this is the best available modeling, and acknowledge that it works best 

in the summer, which is during Arizona’s 20% worst days (Kendall, Wiley, MacArthur). 

 Gabrielson commented that these “other approaches” that could be used would have 

more uncertainty than this model. Kendall suggested acknowledging uncertainties with a 

neutral voice, and eliminate personal expressions and the use of “we.” 

 P. 114, line 36. Gabrielson said the reference to §308 was not relevant and should be 

replaced with future SIP processes, since 309(g) is also a future path. Other changes also 

accepted by the group included: 

o Line 22 – uncertainty in the meteorology and chemistry results in constant 

uncertainty for prescribing new emissions control strategies. 

o Line 28 – Change “that that” to “than that.” 

o Line 29 – Strike “we believe that.” 

o Line 31 – SOx emissions which constitutes a policy question. 

o Line 32 – Add, “should ideally be based...” 

 P. 117 – Gabrielson suggested moving the formula for light extinction to p. 11 in the 

WRAP analytical approach and include a discussion of the use of the equation versus 

forensic observation to explain the difference between a mathematical analysis of 

visibility, and a direct measurement. Point to the location where readers can find 

additional information. Kendall recommended leaving the current materials in place but 

adding a paragraph in the introduction to explain the differences between measured light 

extinction, modeled light extinction, and the policy basis for using modeled light 

extinction (focus on PM mass speciated measurements for control strategy development 

and elimination of meteorology (humidity) as a variable for control strategy 

development). 

 P. 118 – Hyde said that the “1-2 deciview” reference should be more specific. 

 Kendall noted increases in emissions in the 20% best days at four parks may be due to 

anticipated increases in prescribed fires. 

 P. 121, line 14 – explain results (Hyde). 
TAWG Draft Meeting Notes, 9-10-03 5

 P. 121, line 22 – Delete the sentence that begins on line 22. Add fire information. 

(Hyde.) 

 P. 121, line 26 – Explain why 1996 data is not used in tables 30 and 31 (Gabrielson). 

 Kendall said to replace “1996 baseline” with from the 1997-2001 current visibility 

conditions. Explain the three different baselines and why the baseline from the most 

recent five years is used. 

 P. 127, Figure 24 – Map shows tribal information which is irrelevant in this context. 

Delete Figure 24; Figure 25 can be used. (Kendall.) 

 Chapter 4 – Change 13 WRAP states to 9 GCVTC states. 

 MacArthur – 

o Add a chart similar to Figure 36 showing the ammonium nitrate delta and ammonium 

sulfate. 

o Explain which mobile source model was used for representation on nonroad diesel 

rule and how it was used. 

 Wiley was concerned about the stationary source Figure 33 conclusion. He said to add 

stationary source-only with SO2, or remove. Figure 33 doesn’t belong in this section. 

 Kendall – 

o Additional comments are included in the memo previously distributed. 

o Concerned that it looks as if WRAP endorses EPA draft guidance default values for 

natural conditions without appropriate peer review. 

o Concerned that Chapter 9 appears to provide “presumptive reasonable progress 

goals” based on the EPA draft guidance default values for natural conditions which 

may challenge future SIP efforts by states establishing natural conditions based on 

improved science. 

o Add modeling results for mobile sources, since the rule change is not finalized. 

MacArthur would like the history of mobile source significance included. Kendall 

noted that the information is in the body of the SIP, and is not appropriate for the 

TSD. 

 Gabrielson – Wants to see a clear statement of fire emissions modeling regarding 1996 

and 2018 and what actual data was used for computing the relative reduction factors. 

 Kale Walch did not have additional comments. 

• Chris Janick, Salt River Project --What is the basis for the 100 acre wildfire threshold? I 

would think they should be included in some fashion or another, rather than excluded 

altogether, unless there is some reason to believe all of those are insignificant compared 

to the larger fires. 

• Shawn Kendall, The Kendall Group, Inc. -- Table 4 and 5 present area source emissions 

(pg 30), but nowhere is there a list of the source category codes that were included in this 

inventory. The SCC codes should be in an appendix for each of the key emission 

inventories presented (stationary, area, mobile-on road, mobile-non road, road dust, fires 

etc). 
TAWG Draft Meeting Notes, 9-10-03 6

SECOND SET: FROM TELEPHONE CALL OF SEPTEMBER 10, 2003 

The following comments are on the August 27, 2003 version of the TSD 

 P. 159 – Rory MacArthur said that a figure showing the delta of ammonium nitrate 

increases/reductions with SO2 reductions had not been added to the TSD. This data is 

available on the WRAP website under “better than BART” information. Kendall and 

MacArthur agreed to add the figure to Chapter 3, in the SO2 BART sensitivity section. 

MacArthur will ask Gail Tonnesen to draft language, and will forward the draft to Hyde. 

 P. 118, line 24 – Kendall said this paragraph is improved, and asked TAWG members to 

review it. 

 P. 45 – Hyde would like to see a major revision to the document regarding fire emissions 

inventories which details: the emissions that were used, for what reason, and in which 

model run. Kendall reviewed pp. 47 and 55, which provides contradictory information 

on agriculture burning. Hyde will ask for a modified smoke section, and a table showing 

what data went into what modeling. 

 (global) – Kendall said that the emissions inventories used to validate the model should 

be shown, overall. Hyde agreed that the information should be provided as a courtesy to 

the reader, even if it is noted elsewhere in the document. 

 P. 119 – Hyde noted the document reads “no prescribed or agriculture burning.” He was 

also concerned about using the typical wildfire information for 1996. 

 Hyde asked about the 1996 and 2018 deciview values. He questioned whether there 

would be a different prediction by using these artificially lowered 1996 emissions 

compared to actual values. Kendall reviewed the Class I Areas in Table 2.2.2.1 for 

deciview changes from 1996 to 2018. Eight of the 16 are predicted to get worse, and all 

are located in the southern Colorado/northern New Mexico area. Kendall asked if the 

culprit may be the use of 1996 as typical wildfire data. He said that he believes there is a 

lot of smoke contamination, but can’t make this determination because the data is not 

presented. 

MacArthur reviewed additional items: 

 P. 16 – Graphic is not appearing properly in the Acrobat version of the document. 

 P. 67, table 1.2.1.3a – 1996 legend does not correspond with figure in the Acrobat 

version. 

 P. 68 – Road dust does not look like the pie chart that is shown for PM. Legend graphics 

are unrelated to the graphics used in the pie charts. Kendall said the Word version should 

also be checked. 

 The non-road discussion has not been improved. Throughout the document, the reader 

does not know what they did or what they used. Kendall said that 2002 information was 

not used. Hyde agreed that this should be addressed similarly to the fire emissions, with 

additional references to which data was used to support which modeling. Hyde said that 

this must be updated for the December version of the document. 

 It is not clear whether MOBILE5B or MOBILE6 was used. Kendall thinks that the 1996 

modeling was MOBILE5B. The document should specify what modeling was used in 

NEI6. 
TAWG Draft Meeting Notes, 9-10-03 7

Kendall noted that it will be necessary to know what WRAP is doing with 2018 CENRAP 

inventory for next year. He said that the TSD is acceptable for the SIP in its current form, but 

would prefer to see improvements such as exposing fire, mobile and road data used for modeling 

in the text. 

THIRD SET 

The following comments are from Peter Hyde, and concern the August 27, 2003 version of the 

TSD. 

Section 1.1.7 Fire emissions, pp 48-55 

P 46, line 40 

“The 2018 fire projections should not be compared directly with the 1996 fire emission 

inventories. Etc. Etc.” 

Recognizing the unique difficulties of constructing fire emission inventories, and acknowledging 

the uncertainties inherent in the 2018 forecast, this plea for a “separation” falls on deaf ears and 

would be best removed. Fire emissions are of particular importance in western states, and base 

year estimates will be compared with future year estimates, despite the plea. 

This section – the entirety of fire emissions -- is in desperate need of some tabular emissions data 

and of an additional subsection that explains what model runs used what emissions. The tabular 

data should present the following: 

 wildfires prescribed fire ag fire Total 

1996 actual 

wildfire 

 

1996 average 

wildfire 

2018 average 

wildfire 

These data would go a long ways to understanding the relative importance of each type of 

emissions. 

Of particular aggravation is the impossibility of finding out what emissions went into each model 

run. Yes, one can consult tables in the emissions processing or modeling sections, but the 

narrative needs to give the reader – in this section – a clear picture of which emissions went into 

which model run and why. For example, on page 119, Table 1.2.6.1 states that the 1996 base 

case for model validation had actual wildfire but no prescribed fire emissions. Why not 

prescribed fire emissions? The same table states that the 1996 base case with typical wildfire 

uses average wildfire emissions, but 2018 emissions for prescribed and ag burning emissions. 

How is one to make sense of this? The reader needs to come away from this section 
TAWG Draft Meeting Notes, 9-10-03 8

understanding not only how the inventories were compiled; but, more importantly, what 

decisions were made and why about which inventories actually went into which model runs. 

This section also lacks a discussion on how reducing the actual wildfire emissions to average 

wildfire emissions – a fivefold reduction -- might affect the outcome of the projected visibility 

values. Although this discussion might fit better in the modeling section, it needs to come in 

somewhere. The following considerations should be weighed: 

• Wildfire emissions are 41% of the base year inventory, dropping to 14% of the future 

year inventory of PM2.5 . Prescribed fire emissions are 3% of the base year and 27% of 

the future year PM2.5 . How are these significant contributions to PM2.5 affected by the 

five-fold reduction from actual to typical wildfires? 

• If we use average wildfire emissions in both 1996 and 2018, instead of the actuals for 

both years, then effectively we are artificially reducing the size of a constant contributor 

to visibility impairment. As the size of this constant decreases, there is more latitude for 

change in the variable contributors. The net change in visibility, then, may be inflated 

by this wildfire reduction. Perhaps some sensitivity tests would be in order to estimate 

the magnitude of this somewhat artificial emissions change. 

• Some discussion of the wildfire and prescribed f ire emissions in the period 1997-2001 

would seem to be in order, given that this is the baseline visibility period. For example, 

those Class I areas subject to above average fire emissions would have projections that 

error on the high side, and visa versa. 

2.2.2 Visibility modeling results using relative reduction factors 

The explanation of projected visibility increases and decreases at Class I areas, based on their 

proximity to large power plants slated for SO2 reductions, or alternatively, subject only to 

increasing emissions from the nonroad sector, sounds convincing, but a quick matching of the 

SO2 emission changes (Figure 2.2.2.1, page 131) with the visibility changes brings up a pattern 

of ambiguities that defies this paradigm. The table below gives the percentage change in 

visibility for the 20% best and 20% worst visibility days for the 16 Class I areas, along with the 

SO2 emission changes in the four counties contiguous with and generally west of the site. The 

emission changes are in tons per year. Negative percentages are visibility decreases; positive are 

visibility increases. The Class I areas are presented in the order of visibility changes for the 

worst days. 
TAWG Draft Meeting Notes, 9-10-03 9

Class I area best worst County 1 county 2 county 3 County 4 Total 

San Pedro Parks -39.8 -15.2 750 750 15000 0 16500

West Elk -25.5 -5.6 0 0 0 750 750

Maroon Bells-Snowmass -25.8 -5.2 0 0 0 750 750

Flat Tops -27.7 -5.1 0 0 750 -15000 -14250

Bryce 9.1 -3.9 0 0 0 0 0

Capitol Reef 13.4 -3.4 0 0 0 750 750

Arches 11.8 -2.6 750 0 750 0 1500

Canyonlands 13.0 -2.6 750 750 0 0 1500

Weminuche 13.7 1.9 00000

Black Canyon 15.4 3.5 0 0 0 750 750

Grand Canyon 0.8 5.5 -50000 750 750 -25000 -73500

Mesa Verde 20.0 6.6 0 15000 750 0 15750

Petrified Forest 20.3 7.8 -50000 15000 750 750 -33500

Zion 35.4 10.8 750 -25000 0 0 -24250

Mount Baldy 0.2 14.5 750 15000 -750 750 15750

Sycamore Canyon 23.0 24.5 -50000 750 750 -750 -49250

 

Of the top four areas with the greatest degradation on the best days, only one, San Pedro Parks, 

has a large S02 increase; of the other three, two have almost no change and one has a large 

decrease. Among the best performing areas – the last five entries in the table – Mesa Verde 

shows decided improvement despite a hefty SO2 increase, and Mount Baldy shows less 

improvement with the same increase in SO2 emissions. While county-wide emission changes do 

not equate with source-receptor dynamics, a more in-depth discussion, or at least one that 

acknowledges these ambiguities, would be appropriate here. 

Several other aspects of these projected visibility changes warrant further discussion. For 

example, it would be illuminating to explore the contrast between the percentage changes in 

visibility between the best and worst days. With three exceptions -- Grand Canyon, Mount 

Baldy, and Sycamore Canyon – the visibility change for the best days is on average four times 

that of the worst days. Is this readily understood from a physical or mathematical basis? Four 

Utah sites display improvement for the best days but degradation for the worst days. How can 

this be explained by emission changes? Two sites exhibit virtually no change in the best days 

but considerable improvement in the worst: Grand Canyon and Mount Baldy. Can we really be 

cleaning the air to the tune of a 14.5% visibility improvement for the worst days at Mount Baldy, 

without a concomitant improvement for the best days? Attempting to answer this set of 

questions would be doing the inquisitive reader a service. 

 

Section 1.2.4 Model Performance Results (p 112) 

L 31 “The model substantially underpredicts soil and coarse mass. This most likely can be 

attributed to the lack of a fugitive dust emissions inventory...” 

This explanation is inadequate if not misleading. Area source dust emissions were inventoried, 

as were unpaved and paved road dust. The only omission was wind-blown dust, which, on an 
TAWG Draft Meeting Notes, 9-10-03 10

annual basis, with a frequency of 3 to 7 events per year, would not be expected to perturb a 100- 

sample comparison. A more likely reason for the underprediction can be found on page 43, line 

10, where the authors state that the net effect of revising silt loading values, of revising average 

daily traffic counts, and of incorporating transport fractions was an 89% decrease in road dust 

emissions from the original estimate. Maybe the original estimates weren’t so bad after all. In 

any case, the lack of a wind-blown inventory cannot explain the underprediction. 

Section 1.2.5 Model Uncertainties and Quality Assurance 

P 116 

This discussion explains “two key issues [about] assessing the model performance for use in the 

309 analysis.” [ line 40] 

A third issue ought to be recognized, and is stated as follows: 

Virtually all air quality models, including CMAQ, were developed principally to predict shortterm, episodic, relatively high air pollutant concentrations. The application of these models to 

predicting speciated fine particulates concentrations in pristine areas on an annual basis 

constitutes a use for which they were not expressly designed. It should surprise no one that the 

model performance in this arena has been questionable in certain aspects. 

4.2 Stationary source NOx and PM sensitivity testing 

P 155, line 14 

“The fact that stationary source NOx emissions are not as well controlled as stationary source 

PM10 emissions in the West actually lends some relevance to the outcome that NOx emissions 

are altered more in the sensitivity analysis than PM10 emissions.” 

This sentence is confusing. Usually the “outcome” of a model sensitivity test is a change in 

pollutant concentrations, not emissions. If NOx emissions are altered more, then it’s because of 

the greater contribution of point-source NOx to the total inventory. If they comprise a greater 

share of the inventory because they’re not well controlled, then OK. My suspicion is that even if 

they were well controlled, they would still contribute more to the inventory than the 10% PM10. 

I’m still confused. 
Appendix A-14 – Projection of Visibility Arizona Regional Haze SIP

Appendix A-14b. Summary of Emission Inventories used in WRAP Modeling
Appendix A-14b. Table 1.

Changes in Emissions - 1996 vs 2018 w/309 Programs

(Thousands of Tons per Year)

A. ARIZONA EMISSIONS BY SOURCE CATEGORY PM2.5 CM SOX 

Area Sources 1996 23.0 49.0 3.2 

2018 w/309 25.2 48.2 5.3 

% Change 10% -2% 68% 

Point Sources 1996 11.7 10.6 195.8 

2018 w/309 9.5 17.2 113.9 

% Change -18% 63% -42% 

Mobile Sources - On-Road 1996 4.6 0.6 2.9 

2018 w/309 1.7 0.1 0.8 

% Change -63% -88% -74% 

Mobile Sources - Non-Road 1996 9.0 0.7 9.2 

2018 w/309 7.6 0.5 12.6 

% Change -16% -18% 37% 

Road Dust 1996 4.5 21.2 - 

2018 w/309 5.2 21.0 - 

% Change 16% -1% N/A 

 Sub-Total - Non-Fire Emissions 1996 52.8 82.1 211.2 

2018 w/309 49.3 87.1 132.6 

% Change -7% 6% -37% 

Agricultural Burning 1996 0.2 0.0 0.0 

2018 w/309 0.1 0.0 0.0 

% Change -73% -80% -83% 

Prescribed Fire on Wildlands 1996 65.8 11.8 4.6 

2018 w/309 64.8 11.7 4.6 

% Change -1% -1% -1% 

Wild Fire 1996 29.1 4.8 2.1 

2018 w/309 29.1 4.8 2.1 

% Change 0% 0% 0% 

 Sub-Total - Fire Emissions 1996 95.1 16.7 6.7 

2018 w/309 94.0 16.5 6.6 

% Change -1% -1% -1% 

TOTAL EMISSIONS IN ARIZONA 1996 147.9 98.8 217.9 

2018 w/309 143.3 103.6 139.3 

% Change -3% 5% -36% 

Appendix A-14b. Table 1. Page 1
Appendix A-14b. Table 1.

Changes in Emissions - 1996 vs 2018 w/309 Programs

(Thousands of Tons per Year)

B. EMISSIONS IN FIVE 309 STATES (AZ,NM,OR,UT,WY) PM2.5 CM SOX 

Area Sources 1996 148.6 279.7 37.3 

2018 w/309 197.0 282.1 46.8 

% Change 33% 1% 25% 

Point Sources 1996 54.2 41.5 541.3 

2018 w/309 54.7 50.4 384.9 

% Change 1% 21% -29% 

Mobile Sources - On-Road 1996 14.9 1.9 10.7 

2018 w/309 5.9 0.3 2.1 

% Change -60% -86% -80% 

Mobile Sources - Non-Road 1996 27.1 2.2 47.9 

2018 w/309 26.0 2.1 74.4 

% Change -4% -3% 55% 

Road Dust 1996 20.5 96.3 - 

2018 w/309 25.0 108.5 - 

% Change 22% 13% - 

 Sub-Total - Non-Fire Emissions 1996 265.3 421.6 637.2 

2018 w/309 308.7 443.3 508.2 

% Change 16% 5% -20% 

Agricultural Burning 1996 3.2 0.2 0.2 

2018 w/309 1.2 0.1 0.1 

% Change -62% -64% -67% 

Prescribed Fire on Wildlands 1996 230.2 41.4 16.2 

2018 w/309 224.0 40.3 15.8 

% Change -3% -3% -3% 

Wild Fire 1996 111.4 18.5 7.9 

2018 w/309 111.4 18.5 7.9 

% Change 0% 0% 0% 

 Sub-Total - Fire Emissions 1996 344.9 60.1 24.3 

2018 w/309 336.7 58.9 23.7 

% Change -2% -2% -2% 

TOTAL EMISSIONS IN FIVE 309 STATES 1996 610.2 481.7 661.4 

2018 w/309 645.3 502.2 532.0 

% Change 6% 4% -20% 

Appendix A-14b. Table 1. Page 2
Appendix A-14b. Table 1.

Changes in Emissions - 1996 vs 2018 w/309 Programs

(Thousands of Tons per Year)

C. EMISSIONS IN THE NINE GCVTC STATES PM2.5 CM SOX 

Area Sources 1996 304.3 698.2 61.0 

2018 w/309 352.4 698.7 74.7 

% Change 16% 0% 22% 

Point Sources 1996 97.9 77.1 770.4 

2018 w/309 110.1 101.1 510.0 

% Change 12% 31% -34% 

Mobile Sources - On-Road 1996 39.8 9.1 20.6 

2018 w/309 23.0 8.6 5.4 

% Change -42% -6% -74% 

Mobile Sources - Non-Road 1996 67.9 5.7 140.1 

2018 w/309 61.1 5.1 175.3 

% Change -10% -11% 25% 

Road Dust 1996 59.8 272.8 - 

2018 w/309 66.5 278.2 - 

% Change 11% 2% - 

 Sub-Total - Non-Fire Emissions 1996 569.7 1,062.9 992.2 

2018 w/309 613.1 1,091.6 765.5 

% Change 8% 3% -23% 

Agricultural Burning 1996 15.8 0.8 1.0 

2018 w/309 6.5 0.4 0.5 

% Change -59% -58% -50% 

Prescribed Fire on Wildlands 1996 387.4 69.7 27.3 

2018 w/309 384.8 69.3 27.1 

% Change -1% -1% -1% 

Wild Fire 1996 223.9 37.2 15.8 

2018 w/309 223.9 37.2 15.8 

% Change 0% 0% 0% 

 Sub-Total - Fire Emissions 1996 627.0 107.7 44.1 

2018 w/309 615.2 106.8 43.4 

% Change -2% -1% -1% 

TOTAL EMISSIONS IN THE NINE GCVTC STATES 1996 1,196.7 1,170.6 1,036.3 

2018 w/309 1,228.3 1,198.4 808.9 

% Change 3% 2% -22% 

Appendix A-14b. Table 1. Page 3
Appendix A-14b. Table 1.

Changes in Emissions - 1996 vs 2018 w/309 Programs

(Thousands of Tons per Year)

D. EMISSIONS IN THE 13 WRAP STATES PM2.5 CM SOX 

Area Sources 1996 523.2 1,398.2 141.8 

2018 w/309 578.0 1,403.0 167.4 

% Change 10% 0% 18% 

Point Sources 1996 118.1 89.9 1,196.5 

2018 w/309 132.0 115.1 763.8 

% Change 12% 28% -36% 

Mobile Sources - On-Road 1996 48.8 10.3 28.3 

2018 w/309 26.3 8.7 6.5 

% Change -46% -15% -77% 

Mobile Sources - Non-Road 1996 95.0 8.0 213.3 

2018 w/309 84.2 7.1 272.1 

% Change -11% -12% 28% 

Road Dust 1996 84.4 399.9 - 

2018 w/309 93.7 410.7 - 

% Change 11% 3% - 

 Sub-Total - Non-Fire Emissions 1996 869.5 1,906.3 1,579.9 

2018 w/309 914.3 1,944.6 1,209.8 

% Change 5% 2% -23% 

Agricultural Burning 1996 20.9 1.1 1.4 

2018 w/309 9.4 0.5 0.7 

% Change -55% -55% -49% 

Prescribed Fire on Wildlands 1996 445.5 80.2 31.4 

2018 w/309 442.7 79.7 31.2 

% Change -1% -1% -1% 

Wild Fire 1996 231.5 38.4 16.3 

2018 w/309 231.5 38.4 16.3 

% Change 0% 0% 0% 

 Sub-Total - Fire Emissions 1996 698.0 119.7 49.1 

2018 w/309 683.6 118.6 48.3 

% Change -2% -1% -2% 

TOTAL EMISSIONS IN THE 13 WRAP STATES 1996 1,567.4 2,026.0 1,629.0 

2018 w/309 1,597.8 2,063.2 1,258.1 

% Change 2% 2% -23% 

Appendix A-14b. Table 1. Page 4
Appendix A-14b. Table 1.

Changes in Emissions - 1996 vs 2018 w/309 Programs

(Thousands of Tons per Year)

Year Definitions

"1996" is the WRAP Inventory used for validation of WRAP Modeling to generate relative reduction factors "2018 w/309" is the WRAP Inventory projection assuming all 309 programs are implemented.Pollutant Definitions"PM2.5" - Fine Particulate Matter < 2.5 Micron"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Micron"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulate

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

Appendix A-14b. Table 1. Page 5
Appendix A-14b. Table 2. 

WRAP Emissions by Pollutant

(Thousands of Tons Per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY SOURCE CATEGORY 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

Area Sources 23.0 25.2 25.2 49.0 48.2 48.2 

Point Sources 11.7 20.1 9.5 10.6 18.1 17.2 

Mobile Sources - On-Road 4.6 1.7 1.7 0.6 0.1 0.1 

Mobile Sources - Non-Road 9.0 7.6 7.6 0.7 0.5 0.5 

Road Dust 5.2 4.5 5.2 21.2 21.0 21.0 

 Sub-Total - Non-Fire Emissions 52.8 59.9 49.3 82.1 88.0 87.1 

Agricultural Burning 0.2 0.2 0.1 0.0 0.0 0.0 

Prescribed Fire on Wildlands 65.8 65.8 64.8 11.8 11.8 11.7 

Wild Fire 29.1 29.1 29.1 4.8 4.8 4.8 

 Sub-Total - Fire Emissions 95.1 95.1 94.0 16.7 16.7 16.5 

TOTAL EMISSIONS IN ARIZONA 155.0 147.9 143.3 98.8 104.7 103.6 

B. EMISSIONS IN FIVE 309 STATES (AZ,NM,OR,UT,WY) 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

Area Sources 148.6 197.0 197.0 279.7 282.1 282.1 

Point Sources 54.2 72.0 54.7 41.5 54.7 50.4 

Mobile Sources - On-Road 14.9 5.9 5.9 1.9 0.3 0.3 

Mobile Sources - Non-Road 27.1 26.0 26.0 2.2 2.1 2.1 

Road Dust 25.0 20.5 25.0 96.3 108.5 108.5 

 Sub-Total - Non-Fire Emissions 265.3 326.0 308.7 421.6 447.7 443.3 

Agricultural Burning 3.2 3.2 1.2 0.2 0.2 0.1 

Prescribed Fire on Wildlands 230.2 230.2 224.0 41.4 41.4 40.3 

Wild Fire 111.4 111.4 111.4 18.5 18.5 18.5 

 Sub-Total - Fire Emissions 344.9 344.9 336.7 60.1 60.1 58.9 

TOTAL EMISSIONS IN FIVE 309 STATES 610.2 670.8 645.3 481.7 507.8 502.2 

C. EMISSIONS IN THE NINE GCVTC STATES 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

Area Sources 304.3 352.4 352.4 698.2 698.7 698.7 

Point Sources 97.9 127.4 110.1 77.1 105.4 101.1 

Mobile Sources - On-Road 39.8 23.0 23.0 9.1 8.6 8.6 

Mobile Sources - Non-Road 67.9 61.1 61.1 5.7 5.1 5.1 

Road Dust 66.5 59.8 66.5 272.8 278.2 278.2 

 Sub-Total - Non-Fire Emissions 569.7 630.4 613.1 1,062.9 1,095.9 1,091.6 

Agricultural Burning 15.8 15.8 6.5 0.8 0.8 0.4 

Prescribed Fire on Wildlands 387.4 387.4 384.8 69.7 69.7 69.3 

Wild Fire 223.9 223.9 223.9 37.2 37.2 37.2 

 Sub-Total - Fire Emissions 627.0 627.0 615.2 107.7 107.7 106.8 

TOTAL EMISSIONS IN THE NINE GCVTC STATES 1,196.7 1,257.4 1,228.3 1,170.6 1,203.7 1,198.4 

D. EMISSIONS IN THE 13 WRAP STATES 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

Area Sources 523.2 578.0 578.0 1,398.2 1,403.0 1,403.0 

Point Sources 118.1 149.0 132.0 89.9 119.4 115.1 

Mobile Sources - On-Road 48.8 26.3 26.3 10.3 8.7 8.7 

Mobile Sources - Non-Road 95.0 84.2 84.2 8.0 7.1 7.1 

Road Dust 93.7 84.4 93.7 399.9 410.7 410.7 

 Sub-Total - Non-Fire Emissions 869.5 931.3 914.3 1,906.3 1,948.9 1,944.6 

Agricultural Burning 20.9 20.9 9.4 1.1 1.1 0.5 

Prescribed Fire on Wildlands 445.5 445.5 442.7 80.2 80.2 79.7 

Wild Fire 231.5 231.5 231.5 38.4 38.4 38.4 

 Sub-Total - Fire Emissions 698.0 698.0 683.6 119.7 119.7 118.6 

TOTAL EMISSIONS IN THE 13 WRAP STATES 1,567.4 1,629.3 1,597.8 2,026.0 2,068.6 2,063.2 

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Micron

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulate

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

Fine Material < 2.5 Micron (PM2.5) Coarse Material (> 2.5 micron) (CM)

Soil and Dust Particulate Emissions

Appendix A-14b. Table 2. Page 1
Appendix A-14b. Table 2. 

WRAP Emissions by Pollutant

(Thousands of Tons Per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY SOURCE CATEGORY

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN ARIZONA

B. EMISSIONS IN FIVE 309 STATES (AZ,NM,OR,UT,WY)

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN FIVE 309 STATES

C. EMISSIONS IN THE NINE GCVTC STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE NINE GCVTC STATES

D. EMISSIONS IN THE 13 WRAP STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE 13 WRAP STATES

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Mi

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulat

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 5.3 3.2 5.3 49.3 79.0 79.0 

 131.5 195.8 113.9 108.7 138.6 134.6 

 0.8 2.9 0.8 140.5 47.3 47.3 

 12.6 9.2 12.6 98.6 66.2 66.2 

 - - - - - - 

 150.2 211.2 132.6 397.1 331.1 327.1 

 0.0 0.0 0.0 0.1 0.1 0.0 

 4.6 4.6 4.6 49.3 49.3 48.6 

 2.1 2.1 2.1 7.5 7.5 7.5 

 6.7 6.7 6.6 56.9 56.9 56.1 

 156.9 217.9 139.3 454.0 388.0 383.2 

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 46.8 37.3 46.8 158.2 227.8 227.8 

 481.1 541.3 384.9 512.7 587.8 556.7 

 2.1 10.7 2.1 439.7 132.6 132.6 

 74.4 47.9 74.4 388.5 309.9 309.9 

 - - - - - - 

 604.4 637.2 508.2 1,499.2 1,258.2 1,227.1 

 0.2 0.2 0.1 1.2 1.2 0.4 

 16.2 16.2 15.8 178.8 178.8 172.7 

 7.9 7.9 7.9 28.7 28.7 28.7 

 24.3 24.3 23.7 208.7 208.7 201.8 

 628.7 661.4 532.0 1,707.9 1,466.9 1,428.8 

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 74.7 61.0 74.7 297.2 377.8 377.8 

 642.1 770.4 510.0 849.4 885.7 852.7 

 5.4 20.6 5.4 1,458.3 407.8 407.8 

 175.3 140.1 175.3 984.3 700.3 700.3 

 - - - - - - 

 897.6 992.2 765.5 3,589.1 2,371.6 2,338.5 

 1.0 1.0 0.5 8.0 8.0 3.2 

 27.3 27.3 27.1 297.5 297.5 292.5 

 15.8 15.8 15.8 57.6 57.6 57.6 

 44.1 44.1 43.4 363.0 363.0 353.3 

 941.7 1,036.3 808.9 3,952.1 2,734.6 2,691.8 

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 167.4 141.8 167.4 352.6 449.6 449.6 

 985.9 1,196.5 763.8 1,085.0 1,133.2 1,104.2 

 6.5 28.3 6.5 1,755.7 485.3 485.3 

 272.1 213.3 272.1 1,367.8 949.4 949.4 

 - - - - - - 

 1,431.9 1,579.9 1,209.8 4,561.0 3,017.5 2,988.5 

 1.4 1.4 0.7 10.1 10.1 4.3 

 31.4 31.4 31.2 342.3 342.3 336.7 

 16.3 16.3 16.3 59.6 59.6 59.6 

 49.1 49.1 48.3 412.0 412.0 400.5 

 1,481.0 1,629.0 1,258.1 4,973.0 3,429.5 3,389.0 

Sulfur Dioxide (SOX) Oxides of Nitrogen (NOX)

Precursor Gases Forming Sulfate and Nitrate Particles

Appendix A-14b. Table 2. Page 2
Appendix A-14b. Table 2. 

WRAP Emissions by Pollutant

(Thousands of Tons Per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY SOURCE CATEGORY

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN ARIZONA

B. EMISSIONS IN FIVE 309 STATES (AZ,NM,OR,UT,WY)

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN FIVE 309 STATES

C. EMISSIONS IN THE NINE GCVTC STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE NINE GCVTC STATES

D. EMISSIONS IN THE 13 WRAP STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE 13 WRAP STATES

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Mi

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulat

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

1996 2018 Base 2018 w/309

 140.5 115.4 140.5 

 17.2 10.5 10.8 

 55.6 150.4 55.6 

 27.0 51.5 27.0 

 - - - 

 240.1 327.8 233.8 

 0.2 0.2 0.0 

 28.0 28.0 27.6 

 16.4 16.4 16.4 

 44.6 44.6 44.1 

 284.7 372.3 277.8 

1996 2018 Base 2018 w/309

 541.2 560.6 541.2 

 115.1 83.5 100.3 

 136.7 424.0 136.7 

 114.7 189.9 114.7 

 - - - 

 907.7 1,258.0 893.0 

 2.9 2.9 1.0 

 97.3 97.3 94.8 

 62.9 62.9 62.9 

 163.1 163.1 158.7 

 1,070.8 1,421.1 1,051.7 

1996 2018 Base 2018 w/309

 1,156.1 1,094.6 1,156.1 

 266.2 193.1 251.4 

 359.0 1,268.8 359.0 

 277.3 463.2 277.3 

 - - - 

 2,058.5 3,019.7 2,043.8 

 15.3 15.3 5.8 

 164.1 164.1 163.2 

 126.3 126.3 126.3 

 305.7 305.7 295.4 

 2,364.2 3,325.3 2,339.2 

1996 2018 Base 2018 w/309

 1,508.3 1,411.9 1,508.3 

 303.7 224.5 289.3 

 444.4 1,565.5 444.4 

 365.1 621.3 365.1 

 - - - 

 2,621.5 3,823.2 2,607.1 

 20.3 20.3 8.5 

 188.7 188.7 187.8 

 130.6 130.6 130.6 

 339.6 339.6 327.0 

 2,961.1 4,162.9 2,934.1 

Volatile Organic Carbon (VOC)

Gases Forming Organic Particles

Appendix A-14b. Table 2. Page 3
Appendix A-14b. Table 3.

WRAP Emissions by Year

(Thousands of Tons per Year)

Modeled Pollutants >>> PM2.5 CM SOX NOX VOC

A. ARIZONA EMISSIONS BY SOURCE CATEGORY 1996 1996 1996 1996 1996

Area Sources 23.0 49.0 3.2 49.3 115.4 

Point Sources 11.7 10.6 195.8 108.7 10.5 

Mobile Sources - On-Road 4.6 0.6 2.9 140.5 150.4 

Mobile Sources - Non-Road 9.0 0.7 9.2 98.6 51.5 

Road Dust 21.2 4.5 - - - 

 Sub-Total - Non-Fire Emissions 52.8 82.1 211.2 397.1 327.8 

Agricultural Burning 0.2 0.0 0.0 0.1 0.2 

Prescribed Fire on Wildlands 65.8 11.8 4.6 49.3 28.0 

Wild Fire 29.1 4.8 2.1 7.5 16.4 

 Sub-Total - Fire Emissions 95.1 16.7 6.7 56.9 44.6 

TOTAL EMISSIONS IN ARIZONA 98.8 147.9 217.9 454.0 372.3 

B. EMISSIONS IN FIVE 309 STATES (AZ,NM,OR,UT,WY) 1996 1996 1996 1996 1996

Area Sources 148.6 279.7 37.3 158.2 560.6 

Point Sources 54.2 41.5 541.3 512.7 83.5 

Mobile Sources - On-Road 14.9 1.9 10.7 439.7 424.0 

Mobile Sources - Non-Road 27.1 2.2 47.9 388.5 189.9 

Road Dust 96.3 20.5 - - - 

 Sub-Total - Non-Fire Emissions 265.3 421.6 637.2 1,499.2 1,258.0 

Agricultural Burning 3.2 0.2 0.2 1.2 2.9 

Prescribed Fire on Wildlands 230.2 41.4 16.2 178.8 97.3 

Wild Fire 111.4 18.5 7.9 28.7 62.9 

 Sub-Total - Fire Emissions 344.9 60.1 24.3 208.7 163.1 

TOTAL EMISSIONS IN FIVE 309 STATES 610.2 481.7 661.4 1,707.9 1,421.1 

C. EMISSIONS IN THE NINE GCVTC STATES 1996 1996 1996 1996 1996

Area Sources 304.3 698.2 61.0 297.2 1,094.6 

Point Sources 97.9 77.1 770.4 849.4 193.1 

Mobile Sources - On-Road 39.8 9.1 20.6 1,458.3 1,268.8 

Mobile Sources - Non-Road 67.9 5.7 140.1 984.3 463.2 

Road Dust 272.8 59.8 - - - 

 Sub-Total - Non-Fire Emissions 569.7 1,062.9 992.2 3,589.1 3,019.7 

Agricultural Burning 15.8 0.8 1.0 8.0 15.3 

Prescribed Fire on Wildlands 387.4 69.7 27.3 297.5 164.1 

Wild Fire 223.9 37.2 15.8 57.6 126.3 

 Sub-Total - Fire Emissions 627.0 107.7 44.1 363.0 305.7 

TOTAL EMISSIONS IN THE NINE GCVTC STATES 1,196.7 1,170.6 1,036.3 3,952.1 3,325.3 

D. EMISSIONS IN THE 13 WRAP STATES 1996 1996 1996 1996 1996

Area Sources 523.2 1,398.2 141.8 352.6 1,411.9 

Point Sources 118.1 89.9 1,196.5 1,085.0 224.5 

Mobile Sources - On-Road 48.8 10.3 28.3 1,755.7 1,565.5 

Mobile Sources - Non-Road 95.0 8.0 213.3 1,367.8 621.3 

Road Dust 399.9 84.4 - - - 

 Sub-Total - Non-Fire Emissions 869.5 1,906.3 1,579.9 4,561.0 3,823.2 

Agricultural Burning 20.9 1.1 1.4 10.1 20.3 

Prescribed Fire on Wildlands 445.5 80.2 31.4 342.3 188.7 

Wild Fire 231.5 38.4 16.3 59.6 130.6 

 Sub-Total - Fire Emissions 698.0 119.7 49.1 412.0 339.6 

TOTAL EMISSIONS IN THE 13 WRAP STATES 1,567.4 2,026.0 1,629.0 4,973.0 4,162.9 

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Micron

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulate

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

Appendix A-14b. Table 3. Page 1
Appendix A-14b. Table 3.

WRAP Emissions by Year

(Thousands of Tons per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY SOURCE CATEGORY

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN ARIZONA

B. EMISSIONS IN FIVE 309 STATES (AZ,NM,OR,UT,WY)

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN FIVE 309 STATES

C. EMISSIONS IN THE NINE GCVTC STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE NINE GCVTC STATES

D. EMISSIONS IN THE 13 WRAP STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE 13 WRAP STATES

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Mi

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulat

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

PM2.5 CM SOX NOX VOC

2018 Base 2018 Base 2018 Base 2018 Base 2018 Base

 48.2 25.2 5.3 79.0 140.5 

 18.1 20.1 131.5 138.6 17.2 

 0.1 1.7 0.8 47.3 55.6 

 0.5 7.6 12.6 66.2 27.0 

 21.0 5.2 - - - 

 88.0 59.9 150.2 331.1 240.1 

 0.0 0.2 0.0 0.1 0.2 

 11.8 65.8 4.6 49.3 28.0 

 4.8 29.1 2.1 7.5 16.4 

 16.7 95.1 6.7 56.9 44.6 

 104.7 155.0 156.9 388.0 284.7 

2018 Base 2018 Base 2018 Base 2018 Base 2018 Base

 282.1 197.0 46.8 227.8 541.2 

 54.7 72.0 481.1 587.8 115.1 

 0.3 5.9 2.1 132.6 136.7 

 2.1 26.0 74.4 309.9 114.7 

 108.5 25.0 - - - 

 447.7 326.0 604.4 1,258.2 907.7 

 0.2 3.2 0.2 1.2 2.9 

 41.4 230.2 16.2 178.8 97.3 

 18.5 111.4 7.9 28.7 62.9 

 60.1 344.9 24.3 208.7 163.1 

 507.8 670.8 628.7 1,466.9 1,070.8 

2018 Base 2018 Base 2018 Base 2018 Base 2018 Base

 698.7 352.4 74.7 377.8 1,156.1 

 105.4 127.4 642.1 885.7 266.2 

 8.6 23.0 5.4 407.8 359.0 

 5.1 61.1 175.3 700.3 277.3 

 278.2 66.5 - - - 

 1,095.9 630.4 897.6 2,371.6 2,058.5 

 0.8 15.8 1.0 8.0 15.3 

 69.7 387.4 27.3 297.5 164.1 

 37.2 223.9 15.8 57.6 126.3 

 107.7 627.0 44.1 363.0 305.7 

 1,203.7 1,257.4 941.7 2,734.6 2,364.2 

2018 Base 2018 Base 2018 Base 2018 Base 2018 Base

 1,403.0 578.0 167.4 449.6 1,508.3 

 119.4 149.0 985.9 1,133.2 303.7 

 8.7 26.3 6.5 485.3 444.4 

 7.1 84.2 272.1 949.4 365.1 

 410.7 93.7 - - - 

 1,948.9 931.3 1,431.9 3,017.5 2,621.5 

 1.1 20.9 1.4 10.1 20.3 

 80.2 445.5 31.4 342.3 188.7 

 38.4 231.5 16.3 59.6 130.6 

 119.7 698.0 49.1 412.0 339.6 

 2,068.6 1,629.3 1,481.0 3,429.5 2,961.1 

Appendix A-14b. Table 3. Page 2
Appendix A-14b. Table 3.

WRAP Emissions by Year

(Thousands of Tons per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY SOURCE CATEGORY

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN ARIZONA

B. EMISSIONS IN FIVE 309 STATES (AZ,NM,OR,UT,WY)

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN FIVE 309 STATES

C. EMISSIONS IN THE NINE GCVTC STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE NINE GCVTC STATES

D. EMISSIONS IN THE 13 WRAP STATES

Area Sources

Point Sources

Mobile Sources - On-Road

Mobile Sources - Non-Road

Road Dust

 Sub-Total - Non-Fire Emissions

Agricultural Burning

Prescribed Fire on Wildlands

Wild Fire

 Sub-Total - Fire Emissions

TOTAL EMISSIONS IN THE 13 WRAP STATES

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Mi

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulat

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

PM2.5 CM SOX NOX VOC

2018 w/309 2018 w/309 2018 w/309 2018 w/309 2018 w/309

 48.2 25.2 5.3 79.0 140.5 

 17.2 9.5 113.9 134.6 10.8 

 0.1 1.7 0.8 47.3 55.6 

 0.5 7.6 12.6 66.2 27.0 

 21.0 5.2 - - - 

 87.1 49.3 132.6 327.1 233.8 

 0.0 0.1 0.0 0.0 0.0 

 11.7 64.8 4.6 48.6 27.6 

 4.8 29.1 2.1 7.5 16.4 

 16.5 94.0 6.6 56.1 44.1 

 103.6 143.3 139.3 383.2 277.8 

2018 w/309 2018 w/309 2018 w/309 2018 w/309 2018 w/309

 282.1 197.0 46.8 227.8 541.2 

 50.4 54.7 384.9 556.7 100.3 

 0.3 5.9 2.1 132.6 136.7 

 2.1 26.0 74.4 309.9 114.7 

 108.5 25.0 - - - 

 443.3 308.7 508.2 1,227.1 893.0 

 0.1 1.2 0.1 0.4 1.0 

 40.3 224.0 15.8 172.7 94.8 

 18.5 111.4 7.9 28.7 62.9 

 58.9 336.7 23.7 201.8 158.7 

 502.2 645.3 532.0 1,428.8 1,051.7 

2018 w/309 2018 w/309 2018 w/309 2018 w/309 2018 w/309

 698.7 352.4 74.7 377.8 1,156.1 

 101.1 110.1 510.0 852.7 251.4 

 8.6 23.0 5.4 407.8 359.0 

 5.1 61.1 175.3 700.3 277.3 

 278.2 66.5 - - - 

 1,091.6 613.1 765.5 2,338.5 2,043.8 

 0.4 6.5 0.5 3.2 5.8 

 69.3 384.8 27.1 292.5 163.2 

 37.2 223.9 15.8 57.6 126.3 

 106.8 615.2 43.4 353.3 295.4 

 1,198.4 1,228.3 808.9 2,691.8 2,339.2 

2018 w/309 2018 w/309 2018 w/309 2018 w/309 2018 w/309

 1,403.0 578.0 167.4 449.6 1,508.3 

 115.1 132.0 763.8 1,104.2 289.3 

 8.7 26.3 6.5 485.3 444.4 

 7.1 84.2 272.1 949.4 365.1 

 410.7 93.7 - - - 

 1,944.6 914.3 1,209.8 2,988.5 2,607.1 

 0.5 9.4 0.7 4.3 8.5 

 79.7 442.7 31.2 336.7 187.8 

 38.4 231.5 16.3 59.6 130.6 

 118.6 683.6 48.3 400.5 327.0 

 2,063.2 1,597.8 1,258.1 3,389.0 2,934.1 

Appendix A-14b. Table 3. Page 3
Appendix A-14b. Table 4.

WRAP Emissions County State

(Thousands of Tons Per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY COUNTY 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 Apache Co 12.8 12.9 13.3 4.1 4.3 4.4 

 Cochise Co 2.8 3.0 2.9 4.0 4.2 4.1 

 Coconino Co 31.5 31.8 31.6 8.4 8.7 8.7 

 Gila Co 14.0 14.7 14.8 4.8 5.3 5.4 

 Graham Co 8.9 8.9 8.7 3.5 3.4 3.4 

 Greenlee Co 5.6 6.0 6.1 2.3 2.6 2.6 

 La Paz 0.9 0.9 0.8 1.9 1.9 1.9 

 Maricopa Co 18.4 16.7 16.6 27.0 26.2 26.1 

 Mohave Co 8.9 8.9 8.3 3.7 3.7 3.6 

 Navajo Co 13.5 13.6 13.7 5.7 5.6 5.6 

 Pima Co 14.2 20.2 9.4 12.7 17.3 16.3 

 Pinal Co 4.6 5.5 5.5 9.6 10.8 10.7 

 Santa Cruz Co 0.6 0.6 0.6 1.3 1.3 1.3 

 Yavapai Co 8.1 8.3 8.1 4.7 4.8 4.8 

 Yuma Co 3.1 3.0 2.8 5.1 4.7 4.7 

TOTAL EMISSIONS IN ARIZONA 155.0 147.9 143.3 98.8 104.7 103.6 

B. EMISSIONS IN 309 SIP STATES 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 Arizona 147.9 155.0 143.3 98.8 104.7 103.6 

New Mexico 131.9 133.7 125.4 107.6 116.6 115.2 

Oregon 185.5 229.8 227.7 148.0 147.0 146.8 

Utah 85.4 92.5 87.3 63.7 74.7 71.6 

Wyoming 59.5 59.9 61.6 63.7 64.8 65.1 

SUB-TOTAL EMISSIONS IN 309 SIP STATES 610.2 670.8 645.3 481.7 507.8 502.2 

C. EMISSIONS IN OTHER GCVTC STATES 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

California 316.5 315.3 314.9 302.7 298.4 298.8 

Colorado 110.6 113.8 112.7 219.0 234.8 234.6 

Idaho 124.1 119.3 116.6 120.0 111.7 111.6 

Nevada 35.3 38.1 38.7 47.2 51.0 51.1 

SUB-TOTAL EMISSIONS IN OTHER GCVTC STATES 586.6 586.5 582.9 688.9 695.9 696.2 

TOTAL EMISSIONS IN GCVTC NINE STATE REGION 1,196.7 1,257.4 1,228.3 1,170.6 1,203.7 1,198.4 

D. EMISSIONS IN OTHER WRAP STATES 1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

Montana 94.7 94.3 95.1 166.0 170.9 171.1 

Norht Dakota 74.8 73.0 71.3 253.3 254.7 255.0 

South Dakota 66.6 66.2 65.8 234.5 240.5 240.4 

Washington 134.6 138.3 137.4 201.6 198.9 198.3 

TOTAL EMISSIONS IN OTHER WRAP 370.7 371.8 369.6 855.4 865.0 864.8 

TOTAL EMISSIONS IN 13 WRAP STATE REGION 1,567.4 1,629.3 1,597.8 2,026.0 2,068.6 2,063.2 

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Micron

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulate

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

Soil and Dust Particulate Emissions

Fine Material < 2.5 Micron (PM2.5) Coarse Material (> 2.5 micron) (CM)

Appendix A-14b. Table 4. Page 1
Appendix A-14b. Table 4.

WRAP Emissions County State

(Thousands of Tons Per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY COUNTY

 Apache Co 

 Cochise Co 

 Coconino Co 

 Gila Co 

 Graham Co 

 Greenlee Co 

 La Paz 

 Maricopa Co 

 Mohave Co 

 Navajo Co 

 Pima Co 

 Pinal Co 

 Santa Cruz Co 

 Yavapai Co 

 Yuma Co 

TOTAL EMISSIONS IN ARIZONA

B. EMISSIONS IN 309 SIP STATES

 Arizona 

New Mexico

Oregon

Utah

Wyoming

SUB-TOTAL EMISSIONS IN 309 SIP STATES

C. EMISSIONS IN OTHER GCVTC STATES

California

Colorado

Idaho

Nevada

SUB-TOTAL EMISSIONS IN OTHER GCVTC STATES

TOTAL EMISSIONS IN GCVTC NINE STATE REGION

D. EMISSIONS IN OTHER WRAP STATES

Montana

Norht Dakota

South Dakota

Washington

TOTAL EMISSIONS IN OTHER WRAP

TOTAL EMISSIONS IN 13 WRAP STATE REGION

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Mi

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulat

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 43.7 36.1 27.8 43.5 43.3 42.9 

 7.9 9.5 7.9 20.7 13.3 13.1 

 7.6 66.4 7.7 54.5 63.9 62.8 

 30.5 40.1 31.6 12.6 11.9 12.0 

 0.7 0.7 0.7 6.6 5.0 4.8 

 0.6 0.5 0.6 5.8 6.2 6.3 

 0.2 0.1 0.2 2.0 1.1 1.1 

 7.5 6.7 7.4 165.0 116.3 115.5 

 1.2 1.0 1.1 11.3 9.4 9.0 

 24.2 13.5 24.1 32.2 33.9 32.7 

 14.3 11.9 11.1 52.6 46.2 45.9 

 16.1 29.3 16.6 18.4 15.8 15.8 

 0.2 0.2 0.2 2.5 1.4 1.4 

 1.5 1.3 1.6 16.6 14.7 14.6 

 0.8 0.6 0.8 9.5 5.6 5.4 

 156.9 217.9 139.3 454.0 388.0 383.2 

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 156.9 217.9 139.3 454.0 388.0 383.2 

 173.8 180.0 157.9 330.2 286.7 274.3 

 64.8 44.5 46.3 369.7 282.2 279.8 

 72.7 66.8 65.6 269.6 221.1 202.7 

 160.5 152.2 122.9 284.5 288.9 288.8 

 628.7 661.4 532.0 1,707.9 1,466.9 1,428.8 

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 91.1 122.8 90.4 1,497.1 738.5 737.5 

 128.7 136.1 94.6 421.3 271.3 268.9 

 41.6 46.1 40.6 144.9 105.2 103.9 

 51.5 69.7 51.4 181.1 152.7 152.7 

 313.0 374.8 276.9 2,244.3 1,267.7 1,263.0 

 941.7 1,036.3 808.9 3,952.1 2,734.6 2,691.8 

1996 2018 Base 2018 w/309 1996 2018 Base 2018 w/309

 58.3 62.9 48.7 191.1 147.2 147.6 

 336.7 318.6 268.2 251.9 197.2 201.4 

 60.2 49.0 56.3 120.6 73.9 73.3 

 84.0 162.3 75.9 457.3 276.5 275.0 

 539.3 592.7 449.2 1,020.8 694.9 697.2 

 1,481.0 1,629.0 1,258.1 4,973.0 3,429.5 3,389.0 

Precursor Gases Forming Sulfate and Nitrate Particles

Sulfur Dioxide (SOX) Oxides of Nitrogen (NOX)

Appendix A-14b. Table 4. Page 2
Appendix A-14b. Table 4.

WRAP Emissions County State

(Thousands of Tons Per Year)

Modeled Pollutants >>>

A. ARIZONA EMISSIONS BY COUNTY

 Apache Co 

 Cochise Co 

 Coconino Co 

 Gila Co 

 Graham Co 

 Greenlee Co 

 La Paz 

 Maricopa Co 

 Mohave Co 

 Navajo Co 

 Pima Co 

 Pinal Co 

 Santa Cruz Co 

 Yavapai Co 

 Yuma Co 

TOTAL EMISSIONS IN ARIZONA

B. EMISSIONS IN 309 SIP STATES

 Arizona 

New Mexico

Oregon

Utah

Wyoming

SUB-TOTAL EMISSIONS IN 309 SIP STATES

C. EMISSIONS IN OTHER GCVTC STATES

California

Colorado

Idaho

Nevada

SUB-TOTAL EMISSIONS IN OTHER GCVTC STATES

TOTAL EMISSIONS IN GCVTC NINE STATE REGION

D. EMISSIONS IN OTHER WRAP STATES

Montana

Norht Dakota

South Dakota

Washington

TOTAL EMISSIONS IN OTHER WRAP

TOTAL EMISSIONS IN 13 WRAP STATE REGION

Data Column Definitions

"1996" is the WRAP Inventory used for model validation 

"2018 Base" is the WRAP Inventory w/o 309 Programs

"2018 w/309" is the WRAP Inventory w/ 309 Programs

Pollutant Definitions

"PM2.5" - Fine Particulate Matter < 2.5 Micron

"CM" - Coarse Material (Soils/Dusts) > 2.5 Micron & < 10 Mi

"SO2" - Sulfur Dioxide - Precursor to Sulfate Particles

"NOX" - Oxides of Nitrogen - Precursor to Nitrate Particulat

"VOC" - Volitile Organic Carbon Gases - Precursor to "OC"

1996 2018 Base 2018 w/309

 11.9 15.0 12.0 

 6.5 9.6 6.4 

 23.7 26.3 23.7 

 9.3 11.0 9.3 

 6.4 7.8 6.3 

 2.8 3.2 2.8 

 1.6 2.3 1.6 

 128.5 167.6 122.1 

 9.0 10.4 8.8 

 13.5 18.2 13.6 

 39.8 55.5 39.7 

 10.9 15.7 10.9 

 2.6 3.7 2.6 

 9.6 14.0 9.6 

 8.5 12.2 8.3 

 284.7 372.3 277.8 

1996 2018 Base 2018 w/309

 284.7 372.3 277.8 

 157.0 200.0 153.5 

 425.0 588.7 423.5 

 130.3 172.2 122.4 

 73.8 87.8 74.4 

 1,070.8 1,421.1 1,051.7 

1996 2018 Base 2018 w/309

 883.2 1,332.6 880.8 

 203.9 297.2 203.4 

 125.9 167.7 122.6 

 80.5 106.7 80.7 

 1,293.4 1,904.2 1,287.5 

 2,364.2 3,325.3 2,339.2 

1996 2018 Base 2018 w/309

 96.2 126.3 96.5 

 90.7 102.7 89.4 

 63.1 82.7 62.6 

 347.0 525.9 346.4 

 597.0 837.5 594.9 

 2,961.1 4,162.9 2,934.1 

Gases Forming Organic Particles

Volatile Organic Carbon (VOC)

Appendix A-14b. Table 4. Page 3
Appendix A-18 – Public Participation Arizona Regional Haze SIP

APPENDIX A-18. PUBLIC PARTICIPATION

This appendix contains work products and references relied upon by Arizona in the 

development of Chapter 18 of the Regional Haze SIP. 

 1110 W. Washington Street • Phoenix, Arizona 85007 

 (602) 771-2300 • www.adeq.state.az.us

ARIZONA DEPARTMENT

OF 

ENVIRONMENTAL QUALITY

Stephen A. 

Owens 

Director

Janet Napolitano 

Governor

Northern Regional Office 

1515 East Cedar Avenue • Suite F • Flagstaff, AZ 

86004 

(928) 779-0313

Southern Regional Office 

400 West Congress Street • Suite 433 • Tucson, AZ 

85701 

(520) 628-6733 Printed on recycled paper 

MEMORANDUM 

DATE: October 24, 2003 

TO: Regional Haze Stakeholders 

FROM: Nancy C. Wrona, Director 

 Air Quality Division 

SUBJECT: Public Comment Period and Public Hearing Dates 

 Proposed Regional Haze State Implementation Plan 

On Friday, October 24, 2003, Arizona’s proposed Regional Haze State Implementation Plan 

(SIP) will be available for public review and comment. The proposed SIP will be available in 

electronic format via the ADEQ Web page at www.adeq.state.az.us/environ/air/haze/html. It 

will also be available for review in hard copy format at both the ADEQ library and the Flagstaff 

City/Coconino County Library. 

Two public hearings are scheduled: Monday, November 24, 2003, 5:00 p.m., Room 250, 

ADEQ, 1110 W. Washington Street, Phoenix; and Monday, November 24, 2003, 4:30 p.m., 

Flagstaff City/Coconino County Library, Program Room, Flagstaff. The close of public 

comment is 5:00 p.m., Wednesday, December 3, 2003. 

ADEQ greatly appreciates the sustained and valued input many stakeholders contributed to the 

development of the Regional Haze SIP, and we look forward to your continued involvement with 

the Regional Haze SIP development under Section 309(g) of the Regional Haze Rule. 

If you have any questions, please call me at (602) 771-2308 or Corky Martinkovic at (602) 771-

2372; (800) 234-5677, extension 771-2372, or martinkovic.deborrah@ev.state.az.us. Comments 

on the proposed SIP should be sent directly to Corky Martinkovic at the above e-mail or by fax 

at (602) 771-2366. 
Public Notice

Printed on recycled paper

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 

PUBLIC HEARING 

ON ARIZONA’S REGIONAL HAZE STATE IMPLEMENTATION PLAN 

The Arizona Department of Environmental Quality (ADEQ) will hold a public hearing to receive 

comments on Arizona’s proposed Regional Haze State Implementation Plan (SIP) to address 

visibility impairment at four of Arizona’s Class I areas (e.g., national parks and wilderness areas) 

as part of the 16 Class I areas on the Colorado Plateau. This SIP specifically addresses the 

requirements under the federal Regional Haze Rule, 40 CFR 51.309. 

A public hearing on the proposed Regional Haze SIP will be held on Monday, November 24, 

2003, at 5:00 p.m., ADEQ, Room 250, 1110 W. Washington Street, Phoenix, Arizona (602-254-

5790). All interested parties will be given an opportunity at the public hearing to submit relevant 

comments, data, and views, orally and in writing. Written comments must be received at ADEQ 

by 5:00 p.m. on Wednesday, December 3, 2003. ADEQ anticipates completion of the final SIP 

by early December. The deadline for submittal to EPA is December 31, 2003. 

All written comments should be addressed, faxed, or e-mailed to: 

Corky Martinkovic 

Air Quality Planning Section 

Arizona Department of Environmental Quality 

1110 W. Washington Street 

Phoenix, AZ 85007 

FAX: (602) 771-2366 

E-Mail: dam@ev.state.az.us 

Copies of the proposal are available for review beginning Friday, October 24, 2003, at the 

following locations: 

Arizona Department of Environmental Quality Library 

First Floor – General Services 

1110 W. Washington Street 

Phoenix, AZ 85007 

Lorraine Cona, (602) 771-2217; 771-4389 (fax) 

The proposed SIP is also available at ADEQ Web page for Regional Haze at 

www.adeq.state.az.us/environ/air/plan/haze.html

 
Public Notice

Printed on recycled paper

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 

PUBLIC HEARING 

ON ARIZONA’S REGIONAL HAZE STATE IMPLEMENTATION PLAN 

The Arizona Department of Environmental Quality (ADEQ) will hold a public hearing to receive 

comments on Arizona’s proposed Regional Haze State Implementation Plan (SIP) to address 

visibility impairment at four of Arizona’s Class I areas (e.g., national parks and wilderness areas) 

as part of the 16 Class I areas on the Colorado Plateau. This SIP specifically addresses the 

requirements under the federal Regional Haze Rule, 40 CFR 51.309. 

A public hearing on the proposed Regional Haze SIP will be held on Monday, November 24, 

2003, at 4:30 p.m., Flagstaff City/Coconino County Library, Program Room, Flagstaff, Arizona 

(928-779-7670). All interested parties will be given an opportunity at the public hearing to 

submit relevant comments, data, and views, orally and in writing. Written comments must be 

received at ADEQ by 5:00 p.m. on Wednesday, December 3, 2003. ADEQ anticipates 

completion of the final SIP by early December. The deadline for submittal to EPA is December 

31, 2003. 

All written comments should be addressed, faxed, or e-mailed to: 

Corky Martinkovic 

Air Quality Planning Section 

Arizona Department of Environmental Quality 

1110 W. Washington Street 

Phoenix, AZ 85007 

FAX: (602) 771-2366 

E-Mail: dam@ev.state.az.us 

Copies of the proposal are available for review beginning Friday, October 24, 2003, at the 

following locations: 

City of Flagstaff/Coconino County Library (see address above) 

Arizona Department of Environmental Quality Library 

First Floor – General Services 

1110 W. Washington Street 

Phoenix, AZ 85007 

Lorraine Cona, (602) 771-2217; 771-4389 (fax) 

The proposed SIP is also available at ADEQ Web page for Regional Haze at 

www.adeq.state.az.us/environ/air/plan/haze.html

 
Public Notice

Printed on recycled paper

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 

PUBLIC HEARING 

ON ARIZONA’S REGIONAL HAZE STATE IMPLEMENTATION PLAN 

The Arizona Department of Environmental Quality (ADEQ) will hold a public hearing to receive 

comments on Arizona’s proposed Regional Haze State Implementation Plan (SIP) to address 

visibility impairment at four of Arizona’s Class I areas (e.g., national parks and wilderness areas) 

as part of the 16 Class I areas on the Colorado Plateau. This SIP specifically addresses the 

requirements under the federal Regional Haze Rule, 40 CFR 51.309. 

A public hearing on the proposed Regional Haze SIP will be held on Monday, November 24, 

2003, at 4:30 p.m., Flagstaff City/Coconino County Library, Program Room, Flagstaff, Arizona 

(928-779-7670). Concurrently, a public hearing will be held on Monday, November 24, 2003, at 

5:00 p.m., ADEQ, Room 250, 1110 W. Washington Street, Phoenix, Arizona (602-254-5790). 

All interested parties will be given an opportunity at the public hearing to submit relevant 

comments, data, and views, orally and in writing. Written comments must be received at ADEQ 

by 5:00 p.m. on Wednesday, December 3, 2003. ADEQ anticipates completion of the final SIP 

by early December. The deadline for submittal to EPA is December 31, 2003. 

All written comments should be addressed, faxed, or e-mailed to: 

Corky Martinkovic 

Air Quality Planning Section 

Arizona Department of Environmental Quality 

1110 W. Washington Street 

Phoenix, AZ 85007 

FAX: (602) 771-2366 

E-Mail: dam@ev.state.az.us 

Copies of the proposal are available for review beginning Friday, October 24, 2003, at the 

following locations: 

City of Flagstaff/Coconino County Library (see address above), and 

Arizona Department of Environmental Quality Library 

First Floor – General Services 

1110 W. Washington Street 

Phoenix, AZ 85007 

Lorraine Cona, (602) 771-2217; 771-4389 (fax) 

The proposed SIP is also available at ADEQ Web page for Regional Haze at 

www.adeq.state.az.us/environ/air/plan/haze.html 


Appendix A-18 – Public Participation Arizona Regional Haze SIP

Appendix A-18b. Hearing Agendas, Sign-in Sheets, Transcripts, and 

Certifications
Order of agenda items is subject to change. For additional information regarding the meeting, please call 

Corky Martinkovic, ADEQ Air Quality Division, at (602) 771-2372 or 1-800-234-5677, Ext. 771-2372. 

Persons with a disability may request a reasonable accommodation such as a sign language interpreter, by 

contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 4794. Requests should be made as 

early as possible to allow sufficient time to make the arrangements for the accommodation. This 

document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829.

Public Hearing Agenda

Printed on recycled paper

Pursuant to [cite 40 CFR § 51.102 for SIP hearings and ARS § 49-425 for air quality rule hearings], notice is hereby given 

that the above referenced meeting is open to the public. 

Public Hearing

Arizona Proposed Regional Haze State Implementation Plan 

Monday, November 24, 2003, 5:00 p.m. 

Arizona Department of Environmental Quality, Room 250 

1110 W. Washington Street, Phoenix, Arizona 

AGENDA

1. Welcome and Introductions 

2. Purposes of the Oral Proceeding 

3. Procedure for Making Public Comment 

4. Brief Overview of the Arizona Proposed Regional Haze State Implementation Plan 

5. Question and Answer Period 

6. Oral Comment Period 

7. Adjournment of Oral Proceeding 




 PUBLIC HEARING 11/24/2003

 1

 1 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY

 2

 3 IN THE MATTER OF ARIZONA'S )

 PROPOSED REGIONAL HAZE STATE ) PUBLIC HEARING

 4 IMPLEMENTATION PLAN. )

 )

 5

 6

 7

 8

 9

 10

 11

 12 At: Phoenix, Arizona

 13 Date: November 24, 2003

 14 Filed:

 15

 16 REPORTER'S TRANSCRIPT OF PROCEEDINGS

 17

 18

 19

 ARIZONA REPORTING SERVICES, INC.

 20 Court Reporting

 Suite Three

 21 2627 North Third Street

 Phoenix, Arizona 85004-1103

 22

 By: MICHELE E. BALMER, RPR

 23 Certified Court Reporter

 Certificate No. 50489

 24 Prepared for:

 25 ADEQ

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 2

 1 BE IT REMEMBERED that the above-entitled and

 2 numbered matter came on regularly to be heard before

 3 the Arizona Department of Environmental Quality at

 4 1110 West Washington Street, Room 250, Phoenix,

 5 Arizona, commencing at 5:00 p.m. on the 24th day of

 6 November, 2003.

 7

 BEFORE: CATHY O'CONNELL, HEARING OFFICER

 8

 9 APPEARANCES:

 10 THERESA A. PELLA, Environmental Program

 Manager, Air Quality Planning Section on

 11 behalf of ADEQ;

 12 IRA DOMSKY, Air Quality Division on

 behalf of ADEQ;

 13

 14 MICHELE E. BALMER

 Certified Court Reporter

 15 Certificate No. 50489

 16

 17

 18

 19

 20

 21

 22

 23

 24

 25

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 3

 1 HEARING OFFICER O'CONNELL: Good evening,

 2 ladies and gentlemen. I now open this oral proceeding.

 3 The subject of this oral proceeding is the Arizona

 4 Proposed Regional Haze State Implementation Plan.

 5 It is Monday, November 24, 2003 at 5:01 p.m.

 6 The location is room 250, Arizona Department of

 7 Environmental Quality, 1110 West Washington Street,

 8 Phoenix, Arizona.

 9 My name is Cathy O'Connell, and I have been

 10 appointed by the Director of the Arizona Department of

 11 Environmental Quality to preside at this proceeding.

 12 The purposes of this proceeding are to provide

 13 the public an opportunity, one, to hear about the

 14 substance of the proposed State Implementation Plan;

 15 two, to ask questions regarding the proposed plan; and

 16 three, to present oral argument, data and views

 17 regarding the proposed plan in the form of comments on

 18 the record.

 19 Representing the Department are myself, Theresa

 20 Pella of the Air Quality Planning Section, and Ira

 21 Domsky of the Air Quality Division.

 22 The procedure for making a public comment on

 23 the record is straightforward. If you wish to comment,

 24 you need to fill out a speaker slip, which is available

 25 at the sign-in table, and give it to me. Using speaker

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 1 slips allows everyone an opportunity to be heard, and

 2 allows us to match the name on the official record with

 3 the comments.

 4 You may also submit written comments to me

 5 today in person or by mail, e-mail, or fax, to Corky

 6 Martinkovic -- and I'm going to spell that for you.

 7 The first name is Corky, C-O-R-K-Y. The last name is

 8 Martinkovic, M-A-R-T-I-N-K-O-V-I-C -- by the end of the

 9 comment period.

 10 The comment period ends at 5:00 p.m. on

 11 Wednesday, December 3, 2003. If mailed, e-mailed or

 12 faxed, written comments must be postmarked no later

 13 than December 3, 2003.

 14 Submit your comments to Corky Martinkovic, Air

 15 Quality Planning Section, Arizona Department of

 16 Environmental Quality, 1110 West Washing Street,

 17 Phoenix, Arizona, 85007. The fax number is area code

 18 (602) 771-2366. Corky's e-mail address is -- and I'll

 19 spell this all out for you -- Martinkovic,

 20 M-A-R-T-I-N-K-O-V-I-C, period, Deborrah,

 21 D-E-B-O-R-R-A-H, @ev.state.az.us.

 22 Her business cards are also at the table up

 23 there, and it includes her e-mail address if you did

 24 not get that.

 25 Comments made during the formal comment period

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 1 are required by law to be considered by the Department

 2 in the preparation of the final State Implementation

 3 Plan. This is done through the preparation of a

 4 responsiveness summary in which the Department responds

 5 in writing to written and oral comments made during the

 6 formal comment period.

 7 The agenda for this hearing is simple. First,

 8 Theresa will present a brief overview of the proposed

 9 State Implementation Plan.

 10 Next, I will conduct a question and answer

 11 period. The purpose of the question and answer period

 12 is to provide information that may help you in making

 13 comments on the State Implementation Plan.

 14 Thirdly, I will conduct the oral comment period

 15 of this proceeding. At that time, I will begin to call

 16 speakers in the order in which I have received speaker

 17 slips.

 18 Please be aware that any comments you make at

 19 today's hearing that you want the Department to

 20 formally consider must be given either in writing or on

 21 the record during the oral comment period of this

 22 proceeding.

 23 At this time, Theresa Pella will give a brief

 24 overview of the proposed State Implementation Plan.

 25 MS. PELLA: Thank you, Cathy.

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 1 Can you hear me in the back? Okay.

 2 What I'm going to briefly do is kind of talk

 3 about the purpose of the plan in general, and then what

 4 each of the specific chapters are so folks who are not

 5 familiar with the process we've been going through kind

 6 of know what is in what chapter.

 7 So if you're interested in making a comment on

 8 a particular subject, hopefully this will help direct

 9 you as to where to go look for that particular issues

 10 or items that you're looking for.

 11 So I'm going to take about 15, 20 minutes, and

 12 I would appreciate it if you have questions, jot them

 13 down on the little handout slips that you have, and

 14 hold them until the question/answer session so we can

 15 kind of keep the flow moving here.

 16 But anyway, to get us started, this is -- as

 17 was indicated, this is the proposed State

 18 Implementation Plan for Arizona's Regional Haze SIP

 19 developed under 40 CFR Section 309.

 20 And this SIP has a specific purpose, and that

 21 specific purpose is to address -- is to address things

 22 that the Grand Canyon Visibility Transport Commission,

 23 which was formed as part of the Clean Air Act Section

 24 169(B), developed as recommendations and submitted to

 25 EPA back in 1996.

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 1 And as a result of that, EPA came out with a

 2 regional haze rule, which was basically a two-phase

 3 regional haze rule, with Phase One being Section 309.

 4 And that section is basically taking a look at the

 5 Grand Canyon Visibility Transport Commission's 1996

 6 report, and giving a status on what the state and what

 7 has happened at the regional level since 1996.

 8 And so that's kind of what this plan really is.

 9 And so the initial slide said that there were -- in

 10 addition to Arizona, there's four other states who are

 11 doing SIPs under Section 309. Those four states are

 12 Utah, Wyoming, New Mexico, and Oregon.

 13 In addition, there is a local air quality

 14 control district in New Mexico, Bernalillo County,

 15 which has statutory authority in that state to do a

 16 regional haze SIP, and they've also done a regional

 17 haze SIP. So there's six of these plans that are out

 18 there, and we're actually the last state to do our

 19 public hearing. All of the others have gone through

 20 theirs.

 21 So what is in our plan? The first part of it,

 22 the first three chapters, are kind of just background.

 23 Mostly background information. It does state in the

 24 Executive Summary that this plan is only for Arizona's

 25 four Grand Canyon plateau areas, and only for areas

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 1 that are under the State's jurisdiction. We do not

 2 have jurisdiction to do controls or regulations on

 3 tribal lands, so nothing in this plan relates to tribal

 4 lands. It also includes a description of those four

 5 Class I areas and lists the other -- all of the 16

 6 ones.

 7 The four areas that we're talking about in this

 8 plan are, of course, the Grand Canyon, Mount Baldy,

 9 Sycamore Canyon Wilderness and -- I just lost it. The

 10 fourth one is the Petrified Forest. Thank you.

 11 So after the introductory chapters, Chapter 4

 12 is kind of an initial technical chapter. What we tried

 13 to do in 4 was take the technical science, the science

 14 of regional haze, and put it into layman terms so the

 15 average reader could understand what regional haze is,

 16 what are the types of sources that emit the pollutants

 17 that form regional haze, and kind of as background

 18 information.

 19 So, of course, your types of sources are

 20 similar to the types of sources that we need to address

 21 in this plan via the Transport Commission's Report are

 22 stationary sources, most notably SO2 from large

 23 stationary sources. We needed to take a look at mobile

 24 sources. We needed to take a look at fire. We needed

 25 to take a look at road dust, and then we also needed to

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 1 look at pollution prevention. So those are the five

 2 main categories that this particular plan addresses.

 3 And pollutants that cause haze, that contribute

 4 to haze, some that we're all very familiar with as

 5 criteria pollutants, most notably particulates, both

 6 fine particulates and course particulates. Again, S02,

 7 NOX, and ammonia.

 8 So we start getting into -- Chapter 5 starts

 9 moving into the specific measures and kind of what

 10 we're doing. Actually, Chapter 5 is kind of a cleanup.

 11 For us it's a cleanup chapter to remove a Federal

 12 Implementation Plan that's been on the books in Arizona

 13 since the mid-1980s.

 14 This, again, goes back to a requirement of 169

 15 of the Clean Air Act that required states to actually

 16 do a visibility state implementation plan and submit

 17 that to EPA in the early '80s. Arizona, along with 30

 18 some other states, failed to submit those SIPs, and so

 19 ultimately we all got FIP'd. We got issued with

 20 Federal Implementation Plans.

 21 This particular chapter addresses the main

 22 component of what Arizona needs to do to request from

 23 EPA the removal of that particular FIP. So it's kind

 24 of taking away a long-term FIP there.

 25 And it's connected to regional haze, because

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 1 the term -- and it actually should be reasonably. That

 2 should be a "Y," not an "E" -- Reasonably Attributable

 3 Visibility Impairment is a situation where a federal

 4 land manager who has control over a federal area, a

 5 park or a forest, can actually certify that there is

 6 visibility impairment at that park or forest, or

 7 whatever national land.

 8 And then that federal land manager notifies the

 9 agency that has jurisdiction over that, and the agency

 10 then has to set into motion some plan to do an analysis

 11 of, number one, is there really some impairment; number

 12 two, if there is impairment, can it be attributed to a

 13 single source or small group of sources; and number

 14 three, if that is correct, then what is going to be

 15 done to resolve that impairment or improve the

 16 visibility for that particular area.

 17 So DEQ started on a stakeholder process 2000 --

 18 a few years ago to actually develop a state rule to

 19 establish a process on what would happen if a federal

 20 land manager does certify impairment at a particular

 21 Class I area. And what this rule does is actually

 22 promulgates those specific requirements. And it has

 23 gone through the rulemaking process. We finished the

 24 stakeholder process. It's gone before the Governor's

 25 Regulatory Review Counsel. In September I think it was

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 1 approved by GRRC, and so right now we're waiting for

 2 the notice of final rulemaking to be published in the

 3 Arizona Administrative Register.

 4 And we're anticipating that that publish date

 5 -- or it's actually been published. It's been

 6 published. We're doing -- under a new law, a rule

 7 becomes effective 60 days after it's been published in

 8 the register. So it has been published in the register

 9 60 days before December 2nd. So we've got a rule that

 10 will be a final rule, and so we're going to include

 11 that final version in the plan that goes to EPA.

 12 So one of the other things that the federal

 13 rule requires and required the Grand Canyon Commission

 14 to do is to take a look at a clean air corridor. And

 15 the Commission itself had actually identified a clean

 16 air -- one clean air corridor on the plateau. And this

 17 is a map of what that corridor looks like.

 18 And you'll see that it actually stops at the

 19 Northern Arizona border. So no part of Arizona is

 20 included in that clean air corridor. So as it relates

 21 to what we needed to put in our regional haze SIP, it

 22 was pretty much minimal. We could put in just the

 23 regional analysis that explained that there is one

 24 clear air corridor, but none of that part is in the

 25 state of Arizona. So that's what Chapter 6 pretty much

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 1 contains.

 2 Chapter 7 starts getting into one of the source

 3 categories of specifics that we needed to address, and

 4 that is the stationary sources. And what that chapter

 5 includes in it is specific for S02. It talks about the

 6 showing of the 13 percent S02 reduction that came from

 7 stationary sources in the region from 1990 to the 2000

 8 time frame.

 9 It also talks about -- it includes a summary of

 10 NOX and PM stationary source report that's recently

 11 been completed by the WRAP, which is the Western

 12 Regional Air Partnership. And it includes a commitment

 13 from the state to continue to further study NOX and PM

 14 as we move forward in the planning process.

 15 And it also includes a trading commitment from

 16 Arizona to complete a trading rule program. And

 17 Chapter 8 actually gets into more details about that

 18 particular trading program.

 19 And what's in the proposed SIP is a regional --

 20 is the model rule that was developed by a regional

 21 group of state folks and EPA folks. And what we're

 22 doing now is we're actually hoping to have an Arizona

 23 specific trading rule to include with the final SIP

 24 when it goes to EPA. The model rule was used as a

 25 placeholder. EPA would like us to include our own

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 1 state rule as much as possible. So we've been working

 2 with the stationary source work group that was formed

 3 to develop these particular two chapters, had been

 4 involved in review of the model rule, the regional

 5 model trading rule, and so they're familiar with what

 6 that says. And we'll be probably going back to them

 7 for a final read through before we finish that

 8 particular process for Arizona's rule.

 9 So it also includes the bottom line there,

 10 geographical enhancement. One of the requirements is

 11 that you need to look at beyond kind of the region

 12 where you're at. And if you identify sources that may

 13 be contributing to problems outside of a particular

 14 Class I area, then you need to look at potential

 15 control strategies for those sources.

 16 So this particular part of this chapter

 17 actually goes back to -- points a finger back to the

 18 Chapter 5 which is the Reasonably Attributable

 19 Visibility Impairment chapter. So we figure we can use

 20 what we call the RAVI rule to help us comply with any

 21 requirements under the geographical enhancement portion

 22 of the EPA rule.

 23 Chapter 9 is mobile sources. And mobile

 24 sources was one of those subjects that was of great

 25 interest to our stakeholders and our work group. And

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 1 that was one of those issues that kind of midstream EPA

 2 came out with a proposed rule which ultimately, if it

 3 goes final, will kind of make this chapter a lot easier

 4 than what it reads now.

 5 What you see in the proposed SIP, we've got two

 6 versions of that chapter. Version number one is what

 7 will be in the final SIP if EPA's proposed rule to

 8 basically -- decision that says that mobile sources

 9 were not a significant category for the 309 SIP, and,

 10 therefore, that's what we will put in there is and give

 11 the date of EPA's final rule.

 12 The other version that's in there is a version

 13 that says if the EPA rule does not go final before the

 14 Arizona SIP gets submitted to EPA, we're going to

 15 include the version in there that commits Arizona to

 16 look at mobile sources and potential necessary controls

 17 if the emissions trend for mobile sources does not

 18 continue to go down. Right now there is a downward

 19 trend for all mobile sources both on road and off road

 20 if you group them together.

 21 And so we've got a commitment in there to look

 22 at that if EPA's rule that's pending before them

 23 doesn't get finalized. So that's why you see two

 24 versions in there.

 25 Chapter 10 is where we address the rule

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 1 requirements for fire, and that includes -- basically

 2 there were a lot of new things that we had to look at

 3 for our prescribed fire program that we've got and

 4 we've had in place for several, several years.

 5 But we looked at ways on how we could enhance

 6 that program by revising our rules and including some

 7 specific emission reduction techniques, and also

 8 committing to participating in the emissions tracking

 9 system that's being developed at the regional level to

 10 better track fire emissions. It's one of the great

 11 unknowns in the world of haze right now, and so this is

 12 one way that we're trying to get a handle on what

 13 occurs in Arizona and also report that at the federal

 14 level.

 15 So the crux of this chapter is the rule

 16 revisions that we're making not only to our open

 17 burning rules, but also to our range management fire

 18 and range management rules. And those particular set

 19 of rules have gone to the Governor's Arizona Regulatory

 20 Review Counsel.

 21 Again, these rule revisions were developed by

 22 our stakeholder work group, which we had a lot of great

 23 support. And so we're getting to the final stages of

 24 that.

 25 So the rules themselves are scheduled to

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 1 hopefully be on the GRRC's calendar for action in their

 2 January meeting. I think it's January 6th is their

 3 date. And following that, assuming that the GRRC

 4 approves those rules, they'll go final, get published.

 5 Or they'll get published in the Arizona Administrative

 6 Register, and then be final 60 days after that.

 7 So we're probably looking at an effective date for

 8 those rule revisions to be about end of March, first

 9 part of April.

 10 Chapter 11 in the SIP is the road dust issue.

 11 And this was one of those things that at the regional

 12 level as well as the state level it was rather

 13 difficult to get a handle on road dust. There's just a

 14 whole lot of technical issues out there and just work

 15 that needs to be done that we're trying to figure out

 16 how to do in order to adequately capture road dust.

 17 And this is the -- the in-and-near approach

 18 refers to the fact that road dust is one of those

 19 things that because it's mostly large particulates, you

 20 will have your emissions most closely to individual

 21 Class I areas. You don't get a lot of transport from

 22 large, large particles. And so there is a WRAP group,

 23 the in-and-near group, that has been looking at how to

 24 better get a handle on road dust.

 25 So this chapter, the bottom line is that we

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 1 commit to continue to working and studying that

 2 particular issue along with other states and interested

 3 stakeholders.

 4 The pollution prevention chapter, Chapter 12,

 5 was another one that was a lively stakeholder process

 6 that we went through as this chapter was developed by

 7 the stakeholders. What's in there now is the list of

 8 those renewable energy and energy efficient programs

 9 that have been identified as being implemented now

 10 within the state, throughout the state, or also

 11 programs that have funding, they are funded, and have

 12 some start date on them.

 13 The primary component, the standard that we

 14 looked at and the work group used was the Environmental

 15 Portfolio Standard which is already being managed by

 16 the Arizona Corporate Commission.

 17 There were some nonconsensus items that this

 18 particular work group came up with that were eventually

 19 submitted up to the ADEQ Director Steve Owens for

 20 further consideration.

 21 And we just heard Director Owens has reviewed

 22 those recommendations. And because he doesn't want to

 23 slow up the SIP process, you know, he's not suggesting

 24 or recommending or directing the Air Quality Division

 25 to change what's in the proposed SIP at this point in

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 1 time. So if there are questions or there's specific

 2 comments that anybody wants to make related to what's

 3 in the proposed SIP, you're encouraged to make them

 4 during the public comment period.

 5 The remaining chapters is other GCVTC

 6 recommendations. In addition to those five main

 7 categories, there were several other recommendations

 8 that were included in that 1996 report. And what this

 9 chapter is is just kind of a list of what those others

 10 are and a status check on the various measures that

 11 were not addressed elsewhere in the SIP.

 12 Projection of Visibility Improvement. Again,

 13 this one is kind of one of the technical chapters. One

 14 of the things that we need to do is to actually show

 15 for each of those Class I areas what is the projected

 16 visibility improvement between the base year of 1996

 17 and the projected year for the planning period, which

 18 is out to 2018. So this chapter includes a table and

 19 lists all of the 16 areas, and how much the visibility

 20 is expected to improve based upon the control measures

 21 that had been identified earlier in the SIPs.

 22 15 and 16, these are kind of just catch-all

 23 chapters. Because this is a regional haze plan and we

 24 put the SIPs together using a regional process as

 25 opposed to kind of going our own route as a state, this

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 1 chapter contains a commitment for Arizona to continue

 2 to work with other states and other stakeholders via

 3 the WRAP process. And so it also, again, acknowledges

 4 that the SIP is not applicable to tribes per the Clean

 5 Air Act and the regional haze rule and others. The

 6 tribal authority rule has the option of submitting

 7 their own regional haze SIPs.

 8 The Chapter 16 is a commitment to periodic

 9 review. This particular SIP goes to EPA the end of

 10 2003. We have to take a look and review in 2008. We

 11 also have to review it in 2013. And then we have to do

 12 a final review in 2018.

 13 So I guess the message here is, you know, this

 14 is not a plan that we submit to EPA and falls in a

 15 black hole. We have to continue to pay attention to

 16 what's in it and periodically go back and check on the

 17 measures that we include in there and give a status

 18 check on whether or not they're working, how they're

 19 working, should we do more type stuff. So that will be

 20 in 2008 is the first one.

 21 This particular chapter is just a commitment

 22 that Arizona will submit a second or a follow-up SIP

 23 for all of the other Class I areas that we've got in

 24 this state. So this map shows you the four Class I

 25 areas that this December SIP is being submitted to EPA

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 1 for. Then the next stage -- one of the next stages

 2 that we'll be working on is putting together -- we have

 3 to do a regional haze SIP for those other eight

 4 particular areas. And we will be working with

 5 stakeholders starting next year on putting together

 6 plans for those particular areas.

 7 And this just gives you -- if you haven't found

 8 them yet, or you haven't seen the technical supporting

 9 document in the appendices or the two big binders that

 10 are over there. So we didn't -- we only brought one

 11 copy. So if you're interested, you can go over there.

 12 But this just gives you the websites of information on

 13 where you can find additional documents.

 14 And a reminder that the public comment period

 15 closes at 5:00 p.m. on December 3. Comments go to

 16 Corky Martinkovic as Cathy mentioned. And that's it.

 17 So thank you very much for listening.

 18 HEARING OFFICER O'CONNELL: Well, that

 19 concludes the explanation period of this proceeding on

 20 the proposed State Implementation Plan.

 21 Are there any questions before we move to the

 22 oral comment period?

 23 Sir, could you give us your name for the court

 24 reporter.

 25 MR. SCHLEGEL: Sure. Jeff Schlegel.

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 1 S-C-H-L-E-G-E-L.

 2 On the slide on Chapter 7, stationary sources,

 3 the second bullet, what caused the -- what largely

 4 caused the 13 percent S02 reduction during that decade?

 5 MS. PELLA: Ira, can you fill that in, please?

 6 MR. DOMSKY: I would say most of it related to

 7 the cleanup of the smelters to get into compliance with

 8 sulphur dioxide national ambient air quality standard.

 9 There are other improvements that were made at other

 10 sulphur dioxide sources throughout the West in addition

 11 to that. And Navajo generating station, that was --

 12 scrubbed it 90 percent starting in October 1999 for all

 13 of its units.

 14 MS. ORMOND: Amanda Ormond. O-R-M-O-N-D.

 15 You talked about the recommendations that were

 16 afforded by the pollution prevention work group. There

 17 were four specific recommendations.

 18 Can you comment on each recommendation and what

 19 exactly was the outcome of each recommendation? I can

 20 tell you what they are if you like. I'm just curious.

 21 Because to say, well, we're not doing anything in this

 22 SIP, I don't know what that means. I don't know.

 23 These were very specific recommendations.

 24 MS. PELLA: Right. Okay. If you wouldn't

 25 mind, Amanda, because I don't have them in front of me

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 1 right now.

 2 MS. ORMOND: The first one was to advocate for

 3 an energy policy where it has a direct effect on

 4 regional haze. And the example was given at the state

 5 legislature at the Corporation Commission or with the

 6 Governor's office for DEQ to provide technical

 7 information on policies that would affect either

 8 positively or negatively regional haze.

 9 So the question is is the Department not going

 10 to do that function between now and, I guess, the first

 11 reporting period in 2008?

 12 MR. DOMSKY: Can I help you?

 13 MS. PELLA: You sure can.

 14 MR. DOMSKY: Okay. The status right now is

 15 that the Director is reviewing the recommendations.

 16 And he has not made a decision on what specifically we

 17 will do, including what changes he would like to see in

 18 the regional haze SIP.

 19 So we will be discussing that with him over the

 20 next two to three weeks in order to weigh exactly what

 21 it was -- what it will be that he thinks ought to be in

 22 the regional haze SIP. And then if the recommendations

 23 are not something that he believes should be in the

 24 regional haze SIP, what else the Department might do to

 25 implement portions or all of the specific

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 1 recommendations.

 2 And that's the status. That's all we can say

 3 at this point.

 4 MS. ORMOND: And that was my concern was that

 5 these were submitted in July, and we've never found out

 6 what happened with them.

 7 So the answer is that they're still under

 8 consideration; is that right?

 9 MR. DOMSKY: That's the answer. Yes.

 10 MS. ORMOND: Will there be an opportunity,

 11 since the public comment period ends December 3rd which

 12 is next Wednesday, is this -- whatever decisions are

 13 made by the Department then will go into the plan and

 14 then there's no opportunity for public comment after

 15 that? I'm just trying to get an idea of process.

 16 MR. DOMSKY: That would be correct. We have to

 17 respond to comments that we receive, and we're

 18 authorized to make changes to the SIP in response to

 19 those comments. Just because the plan is going to be

 20 submitted by December 31st of this year, this is a

 21 process that really takes us through the year 2064.

 22 And even for this first planning period that

 23 ends in 2018, there will ample opportunity to make

 24 amendments to the plan, to add additional policies,

 25 statutes, whatever is appropriate that will shore up

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 1 the regional haze program that the State will be

 2 implementing.

 3 MS. ORMOND: Okay.

 4 MS. KNIGHT: A follow-up. This is Gaye Knight,

 5 G-A-Y-E, K-N-I-G-H-T, with the City of Phoenix.

 6 Just a clarification then. When I read the

 7 plan, I won't see those four recommendations because

 8 they have not been included in the plan?

 9 MR. DOMSKY: They have not been included in

 10 this draft plan.

 11 MS. KNIGHT: But there's a subcommittee report

 12 someplace?

 13 MR. DOMSKY: Right.

 14 MS. ORMOND: They're not on the web. They're

 15 nowhere.

 16 MS. PELLA: Aren't they under the work group

 17 meetings? Yeah.

 18 MS. ORMOND: I don't think so. Okay. Yeah.

 19 MS. PELLA: I thought those --

 20 MR. DOMSKY: They should have been posted.

 21 MS. PELLA: Yeah.

 22 MS. ORMOND: And so just a follow-up on that

 23 follow-up, one of the questions I have, too, is that

 24 how does an average citizen or a person monitor,

 25 especially in the pollution prevention section, that

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 1 DEQ is doing some things so when it comes to 2018 they

 2 can show progress?

 3 What I heard you say was that there will be

 4 potentially additions and changes to the plan. My

 5 understanding I thought was that you wouldn't really

 6 report on the plan until 2008. You're saying that

 7 there is possible changes between now and 2008 with

 8 updates, revisions, all kinds of different things

 9 possible.

 10 MR. DOMSKY: We can reopen the SIP at any time

 11 that it's appropriate, whether we get instructions from

 12 the Governor, from the legislature, if there are other

 13 things that -- changes that EPA requires us to put in.

 14 We have to in 2008 do a full review and what we

 15 call a true-up to the State Implementation Plan. But

 16 that doesn't bar us from taking additional actions in

 17 the intervening years.

 18 MS. ORMOND: Okay. Thank you.

 19 HEARING OFFICER O'CONNELL: Any other

 20 questions?

 21 Gaye.

 22 MS. KNIGHT: Gaye Knight with the City of

 23 Phoenix again. Just I wanted to see her four

 24 recommendations. How does the public see her four

 25 recommendations? She said that the subcommittee made

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 1 some --

 2 MS. PELLA: I will verify, but I think they're

 3 up on the website under the work groups. They should

 4 be under the pollution prevention work group section of

 5 the regional haze SIP. I'm pretty sure they were.

 6 I'll verify that, and if they're not we'll get them

 7 loaded. But these are the papers that were presented

 8 to the SAC, to the Stakeholders Advisory Committee.

 9 But they should be up there.

 10 MS. KNIGHT: Okay. Thank you.

 11 HEARING OFFICER O'CONNELL: Any other questions

 12 before we move on?

 13 (No response.)

 14 HEARING OFFICER O'CONNELL: All right. Then

 15 this concludes the question and answer period of this

 16 proceeding.

 17 I'm going to now open the proceeding for oral

 18 comments. And I'm going to call speakers in the order

 19 in which I have received speaker slips.

 20 I've only received two speaker slips. Speaker

 21 slips are on the table right in the front. If you wish

 22 to speak, I need a speaker slip.

 23 The first speaker is Wayne Leipold.

 24 L-E-I-P-O-L-D. The floor is yours, sir.

 25 MR. LEIPOLD: Madam Hearing Officer, I'm going

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 1 to be brief. I have written comments that I will

 2 submit to you.

 3 HEARING OFFICER O'CONNELL: Thank you, sir.

 4 MR. LEIPOLD: My name is Wayne Leipold. I'm

 5 Chief Environmental Engineer at Phelps Dodge Miami

 6 facility which -- and there's a copper smelter located

 7 at that facility.

 8 My comments are being offered in support of the

 9 Regional Haze State Implementation Plan for the State

 10 of Arizona that ADEQ is proposing to submit. Most of

 11 my comments relate specifically to the smelter set-

 12 aside portion. And one of my comments answers a

 13 question that was asked during the question and answer

 14 period, so I would just like to read that part.

 15 To show the commitment from these two sectors,

 16 the two sectors being the utility sector, the

 17 coal-fired utility sector and the smelting sector, I

 18 would like to review their emissions for the years 1990

 19 and 2000. In 1990, the smelters and coal-fired power

 20 plants emitted approximately 611,000 tons of sulphur

 21 dioxide, or approximately 74 percent of the 829,000

 22 tons emitted by all of the sources that emitted at

 23 least 100 tons in the nine state region.

 24 In the year 2000, the total emissions had been

 25 reduced to 622,000 tons, or a 25 percent reduction,

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 1 with 112,000 tons of that coming from the copper

 2 smelters. Some of them were due to the temporary

 3 cessation of two smelters. But even without -- but

 4 even with them taken out, the reduction would have been

 5 in the order of 70,000 tons. The electric utility

 6 sector reduction was approximately 54,000 tons.

 7 HEARING OFFICER O'CONNELL: Thank you.

 8 Second speaker, Mr. Schlegel. Jeff Schlegel.

 9 Did I pronounce it correctly?

 10 MR. SCHLEGEL: Yes, you did. Thank you. This

 11 is Jeff Schlegel from the Southwest Energy Efficiency

 12 Project.

 13 First I would like to thank ADEQ for preparing

 14 the SIP and note our support for the SIP. I want to

 15 speak to one recommendation that was already discussed

 16 from the pollution prevention work group, and that was

 17 recommendation number 4.

 18 A group of --- a majority group of the work

 19 groups supported a nonconsensus recommendation that

 20 ADEQ should increase its support to preserve and expand

 21 energy conservation and energy efficiency efforts.

 22 There were two parts to this. One was to preserve and

 23 expand existing efforts. The other part was to expand

 24 energy efficiency efforts based on new activities, new

 25 efforts.

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 1 Section 309 noted that the SIP must provide for

 2 programs to preserve and expand energy conservation

 3 efforts, but it stopped there. What was unclear was

 4 that the section did not say existing, planned, future,

 5 or other words that may have made that section clearer.

 6 And it did not state a goal explicitly for energy

 7 efficiency as it did for renewables. The Grand Canyon

 8 Visibility Transport Commission had set a goal for

 9 renewables, the 20 percent goal, but it did not set a

 10 similar goal for energy efficiency.

 11 The work group discussed this at some length,

 12 as work group members will remember. And the majority

 13 of the group felt that simply listing existing programs

 14 is not enough, and it does not meet the requirement of

 15 preserving and expanding energy efficiency. Therefore,

 16 that group went forward and made some recommendations,

 17 again, majority recommendations, that would preserve

 18 and expand energy conservation, both existing efforts

 19 and additional efforts.

 20 The reason that the group made this

 21 recommendation was that Arizona is a high load growth

 22 state, meaning that it's a state that has both

 23 population growth and electricity usage growth. And as

 24 all of us know, the more electricity is used, the more

 25 emissions there will be, all else being equal. And we

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 1 recommended a significant portfolio of energy

 2 efficiency efforts that we recommended ADEQ support.

 3 The bottom line is that now -- now there are

 4 opportunities before the Arizona Corporation Commission

 5 for ADEQ to actually begin to take action. The Arizona

 6 Corporation Commission is reviewing energy efficiency

 7 programs and renewables programs. And the

 8 recommendations that we made to ADEQ could be

 9 implemented today if ADEQ would take such action.

 10 And we again reiterate our recommendation

 11 number 4, and encourage ADEQ to increase its support

 12 for energy efficiency efforts. Thank you.

 13 HEARING OFFICER O'CONNELL: Thank you, sir.

 14 The third speaker slip, Amanda Ormond.

 15 MS. ORMOND: As Jeff Schlegel mentioned, the

 16 majority of the pollution prevention work group members

 17 came up with four recommendations which heretofore have

 18 not been addressed by the Arizona Department of

 19 Environmental Quality related to the State

 20 Implementation Plan.

 21 Number one was to advocate for energy policies

 22 which have a direct effect on reducing regional haze.

 23 And this is at the Corporation Commission, at the

 24 legislature, or the Governor's office.

 25 The second one was that ADEQ should directly

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 1 support the Environmental Portfolio Standard, because

 2 that was identified by the group as the number one

 3 thing that would address -- or the number one policy

 4 that would address the regional haze 10/20 goal.

 5 The third one is that the Department of

 6 Environmental Quality should quantify the impacts and

 7 benefits of energy efficiency and renewable energy in

 8 compliance. This is especially important given the

 9 fact that in 2008 the State is going to be responsible

 10 for coming back and showing progress in energy

 11 efficiency and renewable energy.

 12 Without having quantified what are the

 13 reductions and costs and benefit of doing this program,

 14 the Department is going to have a very difficult time

 15 in coming back and saying what progress has been

 16 achieved. Because if no baseline information is

 17 collected, they'll have nothing to benchmark off of.

 18 So I would encourage the Department to look

 19 carefully at those recommendations and incorporate as

 20 they see fit those recommendations into this current

 21 State Implementation Plan which is to be submitted in

 22 2003.

 23 I would also like to say that I believe that

 24 the plan is incomplete in the fact that it proposes no

 25 future actions, nor any kind of strategies that the

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 1 State will make between now and 2008 to achieve the

 2 10/20 goal. There is not anything beyond a listing of

 3 programs, as Mr. Schlegel stated.

 4 Also, I would like to caution the Department.

 5 Because in the energy efficiency section, there is a

 6 comprehensive listing of programs that are operated by

 7 the Arizona Department of Commerce and Energy office.

 8 That office does not have secure funding through 2008.

 9 In fact, they're funding may only go through the next

 10 couple of years.

 11 If the State of Arizona relies upon those

 12 energy efficiency programs in this particular SIP, then

 13 when it comes to 2008 either you're going to need to

 14 report on what happened to those. And I would

 15 recommend that you only include those programs that you

 16 have a reasonable certainty that will be around when

 17 2008 comes around.

 18 Thank you.

 19 HEARING OFFICER O'CONNELL: Thank you. Speaker

 20 number four, Douglas V. Fant. F-A-N-T. Mr. Fant.

 21 MR. FANT: Yes, ma'am. Thank you. Speaking on

 22 behalf of myself.

 23 I would like to talk about some renewables

 24 issues that might be incorporated into the draft SIP

 25 revisions. You're probably familiar with the effort by

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 1 the Western Governor's Association to create a regional

 2 renewable energy credit trading system. It's moving

 3 into high gear, and it's slated for completion and --

 4 completion in early 2005, implementation by June 2005.

 5 And what it will allow, of course, are

 6 renewable energy credits to trade regionally in the

 7 Western -- probably in the Western Grid. It may

 8 include some of the what I call eastern interconnect

 9 territories on the far east side of the states like

 10 Montana, Colorado. That's an issue to be handled in

 11 the future.

 12 But the Western Governor's Association -- and

 13 this program will probably end up at the Western

 14 Electricity Coordinating Council, WECC, will set up a

 15 system to track, verify, and authorize RECs on a

 16 regional basis.

 17 It might be worthwhile, even though it's late

 18 in the game. All of the programs in the SIP, of

 19 course, are nonbinding in terms of renewable energy

 20 currently, but at least incorporating this thought into

 21 the final SIP that this effort is underway.

 22 Along those lines it might be worthwhile, and

 23 it might be an adjunct or a product that grows from the

 24 SIP, it may be worthwhile for the Arizona Department of

 25 Environmental Quality to quantify the values of the

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 1 offsets in these RECs for haze for particulate matter,

 2 with potential credits to trade for on a regional basis

 3 in terms of satisfying the regional haze SIP

 4 requirements. And that might be a way to encourage

 5 renewable energy, to allow actual offsets to qualify

 6 under the SIP.

 7 On December 15, here in about two or three

 8 weeks, the Western Governor's Association is sponsoring

 9 a series of meeting on the first steps on implementing

 10 the WREGIS. That's the actual physical tracking system

 11 for the regional program.

 12 I might encourage the Arizona Department of

 13 Environmental Quality to come to the meetings and try

 14 and get individuals on these various committees so they

 15 potentially can push the regional program in the

 16 direction which would be positive for the State of

 17 Arizona in terms of satisfying its SIP requirements for

 18 regional haze or, of course, NOX, S02, NOX, SOX, C02,

 19 if that becomes an issue in the future. It's tradeable

 20 currently already on a commercial basis, and it may

 21 have an enforcement value too.

 22 So I just wanted to raise those points and

 23 suggest that perhaps a reference to the WGA's regional

 24 REC program might be incorporated into Chapter 12, or a

 25 least the appendix. I think it's A-12 in the appendix

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 1 for Chapter 12 in the SIP. Just a thought.

 2 HEARING OFFICER O'CONNELL: Thank you.

 3 Speaker number five, Gaye Knight. The floor is

 4 yours.

 5 MS. KNIGHT: Gaye Knight with the City of

 6 Phoenix again.

 7 On page 99 of the draft plan, it mentions that

 8 the City of Phoenix Park & Ride Photovoltaic project is

 9 in the planning process or in a planning stage.

 10 I've had recent discussions with our legal

 11 staff, and it's very important that anything that is

 12 included in the SIP must be approved by our counsel in

 13 order for it to be acceptable, even if it's something

 14 that's well underway.

 15 And so we can't legally include anything that a

 16 city or any government agency has done unless they pass

 17 a resolution recognizing -- giving you the blessing to

 18 say, yes, you can mention that in your SIP.

 19 Even though the language on page 99 is somewhat

 20 tempered by the text above it, I don't believe our

 21 counsel -- no one contacted me. I don't believe we had

 22 a representative on that P-2 subcommittee. And so --

 23 and I see other things from, like, the City of

 24 Scottsdale.

 25 I just wondered if all of those cities where

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 1 you mentioned some project either existing or planned

 2 for the future have to be approved and be accompanied

 3 by a resolution. So that needs some further legal

 4 review and we can discuss it in additional detail

 5 later.

 6 HEARING OFFICER O'CONNELL: Thank you. Any

 7 other speakers wishing to make formal comments on the

 8 record?

 9 (No response.)

 10 HEARING OFFICER O'CONNELL: Therefore, I

 11 conclude the oral comment period of this proceeding.

 12 I encourage everyone to submit written comments

 13 on the proposed State Implementation Plan. Your

 14 participation is an essential part of the process.

 15 MR. FANT: Excuse me. I'm sorry. I didn't

 16 mean to interrupt. When are the written comments due?

 17 HEARING OFFICER O'CONNELL: I was just coming

 18 to that.

 19 Again, you may submit written comments by mail,

 20 e-mail or fax to Corky Martinkovic. And her business

 21 card is on the table here. That will give you her

 22 correct address and e-mail.

 23 The end of the comment period is 5:00 p.m.,

 24 Wednesday, December, 3, 2003. Please make sure your

 25 comments if mailed, e-mailed, or faxed are postmarked

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 1 no later than December 3, 2003.

 2 I want to thank you all for attending this

 3 hearing. The time is now 5:50. I now close this oral

 4 proceeding.

 5 (The Public Hearing concluded at 5:50 p.m.)

 6

 7

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 1 STATE OF ARIZONA )

 ) ss.

 2 COUNTY OF MARICOPA )

 3

 4

 5

 6 I, MICHELE E. BALMER, Certified Court Reporter

 7 No. 50489 for the State of Arizona, do hereby certify

 8 that the foregoing printed pages constitute a full,

 9 true and accurate transcript of the proceedings had in

 10 the foregoing matter, all done to the best of my skill

 11 and ability.

 12

 13 WITNESS my hand this 8th day of December, 2003.

 14

 15

 16

 MICHELE E. BALMER

 17 Certified Court Reporter

 Certificate No. 50489

 18

 19

 20

 21

 22

 23

 24

 25

 ARIZONA REPORTING SERVICE, INC. (602) 274-9944

 Realtime Specialists Phoenix, AZ

Order of agenda items is subject to change. For additional information regarding the meeting, please call 

Corky Martinkovic, ADEQ Air Quality Division, at (602) 771-2372 or 1-800-234-5677, Ext. 771-2372. 

Persons with a disability may request a reasonable accommodation such as a sign language interpreter, by 

contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 4794. Requests should be made as 

early as possible to allow sufficient time to make the arrangements for the accommodation. This 

document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829.

Public Hearing Agenda

Printed on recycled paper

Pursuant to [cite 40 CFR § 51.102 for SIP hearings and ARS § 49-425 for air quality rule hearings], notice is hereby given 

that the above referenced meeting is open to the public. 

Public Hearing

Arizona Proposed Regional Haze State Implementation Plan 

Monday, November 24, 2003, 4:30 p.m. 

Program Room, Coconino Library 

300 West Aspen Avenue, Flagstaff, Arizona 

AGENDA

1. Welcome and Introductions 

2. Purposes of the Oral Proceeding 

3. Procedure for Making Public Comment 

4. Brief Overview of the Arizona Proposed Regional Haze State Implementation Plan 

5. Question and Answer Period 

6. Oral Comment Period 

7. Adjournment of Oral Proceeding 


Transcripts_Flagstaff Public Hearing_11-24-03.txt

 1

 1 

 2 

 3 

 4 

 5 TRANSCRIPT OF PUBLIC HEARING

 6 ARIZONA'S REGIONAL HAZE STATE IMPLEMENTATION PLAN

 7 

 8 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY

 9 

10 

11 

12 

13 Flagstaff, Arizona

14 November 24, 2003

15 4:36 p.m.

16 

17 

18 

19 

20 

21 

22 

 NORTHERN ARIZONA REPORTERS REPORTED BY:

23 413 NORTH SAN FRANCISCO, SUITE 2 JOHN A. DALSIN, RPR

 FLAGSTAFF, ARIZONA 86001 AZ CCR NO. 50270

24 TELEPHONE: (928) 774-0442

 1-800-544-4313

25 FAX: (928) 779-3624

 NORTHERN ARIZONA REPORTERS 

 2

 1 

 2 Transcript of public meeting on Arizona's 

 3 Regional Haze State Implementation Plan, held by the 

 4 Arizona Department of Environmental Quality, on Monday, 

Page 1
Transcripts_Flagstaff Public Hearing_11-24-03.txt

 5 November 24, 2003, in the Jan Romero Stevens Community 

 6 Room of the Flagstaff City - Coconino County Public 

 7 Library, 300 West Aspen Street, Flagstaff, Arizona, 

 8 called to order at 4:36 p.m., reported by John A. 

 9 Dalsin, a Registered Professional Reporter and a 

10 Certified Court Reporter in and for the State of 

11 Arizona. 

12 - - -

13 

14 

15 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY PERSONNEL:

16 ERIC C. MASSEY, Environmental Program Manager, 

 Air Quality Division; Meeting Chairperson

17 

 DEBORRAH "CORKY" MARTINKOVIC, Environmental

18 Program Specialist, Air Quality Division

 

19 

 

20 

21 

22 

23 

24 

25 

 NORTHERN ARIZONA REPORTERS 

 3

 1 I N D E X PAGE

 2 WELCOME AND INTRODUCTION - Chairperson Massey 3

 3 PURPOSES OF THE ORAL PROCEEDING 4

 4 PROCEDURE FOR MAKING PUBLIC COMMENT 4

 5 BRIEF OVERVIEW OF THE ARIZONA PROPOSED RHSIP 6

 6 QUESTION AND ANSWER PERIOD 15

 7 ORAL COMMENT PERIOD 15

 8 ADJOURNMENT OF ORAL PROCEEDING 18

Page 2
Transcripts_Flagstaff Public Hearing_11-24-03.txt

 9 

10 

11 

12 

13 

14 

15 P R O C E E D I N G S

16 CHAIRPERSON MASSEY: I now open this oral 

17 proceeding.

18 WELCOME AND INTRODUCTIONS

19 CHAIRPERSON MASSEY: Good afternoon, and thank 

20 you for coming.

21 This oral proceeding is on the Arizona 

22 Proposed Regional Haze State Implementation Plan. This 

23 is a proposed plan to direct the State of Arizona. 

24 It is now Monday, November 24th, 2003, 

25 4:36 p.m. The location is Coconino Library, 300 West 

 NORTHERN ARIZONA REPORTERS 

 4

 1 Aspen Avenue, Flagstaff, Arizona. My name is Eric 

 2 Massey, and I have been appointed by the Director of 

 3 the Arizona Department of Environmental Quality to 

 4 preside at this hearing. 

 5 PURPOSES OF THE ORAL PROCEEDING

 6 CHAIRPERSON MASSEY: The purposes of this 

 7 proceeding are to provide the public an opportunity to 

 8 do three things today. 

 9 The first is to hear about the substance 

10 of the proposed State Implementation Plan; second is to 

11 ask questions regarding the proposed plan; and the 

12 third is to present oral arguments, data and views 

13 regarding the proposed plan in the form of comments on 

Page 3
Transcripts_Flagstaff Public Hearing_11-24-03.txt

14 the record. 

15 Representing the Department are myself 

16 and Corky Martinkovic of the Air Quality Planning 

17 Section. 

18 PROCEDURE FOR MAKING PUBLIC COMMENTS

19 CHAIRPERSON MASSEY: The procedure for making a 

20 public comment on the record is straightforward. If 

21 you wish to comment, you need to fill out a speaker 

22 slip, which are available at the sign-in table, and 

23 give it to me. Using speaker slips allows everyone an 

24 opportunity to be heard and allows us to match the name 

25 on the official record with the comments. 

 NORTHERN ARIZONA REPORTERS 

 5

 1 You may also want to submit written 

 2 comments to me today in person; or by mail, e-mail or 

 3 fax, to Corky Martinkovic by the end of the comment 

 4 period. The end of the comment period is 5:00 o'clock 

 5 on Wednesday, December 3rd, 2003. And that is 5:00 

 6 o'clock p.m. If mailed, e-mailed or faxed, written 

 7 comments must be "postmarked" no later than December 

 8 3rd of 2003. 

 9 Submit your written comments to: Corky 

10 Martinkovic, Air Quality Planning Section, Arizona 

11 Department of Environmental Quality, 1110 West 

12 Washington street, Phoenix, Arizona, 85007, or by fax 

13 at 602 - 771-2366, or by e-mail at martinkovic.

14 deborrah@ev.state.az.us 

15 For additional information, I would 

16 recommend that you pick up one of Corky's business 

17 cards in the back. 

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18 Comments made during the formal comment 

19 period are required by law to be considered by the 

20 Department in the preparation of the final State 

21 Implementation Plan. This is done through the 

22 preparation of a responsiveness summary in which the 

23 Department responds in writing to written and oral 

24 comments made during the formal comment period. 

25 The agenda for this is simple. First, we 

 NORTHERN ARIZONA REPORTERS 

 6

 1 will present a brief overview of the proposed State 

 2 Implementation Plan.

 3 Next, I will conduct a question-and- 

 4 answer period. The purpose of the question-and-answer 

 5 period is to provide information that may help you in 

 6 making comments on the proposed State Implementation 

 7 Plan. 

 8 Third, I will conduct the oral comment 

 9 period. At that time I will begin to call speakers in 

10 the order that I have received speaker slips. 

11 Please be aware that any comments you 

12 make at today's hearing that you want the Department to 

13 formally consider must given either in writing or on 

14 the record during the oral comment period of this 

15 proceeding. 

16 At this time Corky Martinkovic will give 

17 a brief overview of the proposed State Implementation 

18 Plan. 

19 BRIEF OVERVIEW OF THE ARIZONA PROPOSED RHSIP

20 PROGRAM SPECIALIST MARTINKOVIC: For the 

21 overview of the Arizona Proposed State Implementation 

22 Plan, today what I am going do is take you through 

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23 basically what is in the State's Implementation Plan 

24 chapter by chapter. 

25 The purpose of the State Implementation 

 NORTHERN ARIZONA REPORTERS 

 7

 1 Plan, the purpose of "the Plan", is to address the 

 2 Clean Air Act Section 169, the National Visibility Goal 

 3 requirements. 

 4 Basically, the National Visibility Goal 

 5 asks for all states to protect visibility in the 

 6 national parks and wilderness areas and remedy any 

 7 existing visibility impairments and prevent any future 

 8 impairment. 

 9 It is also to fulfill the requirements of 

10 the federal Regional Haze Rule. 

11 Arizona and four other western states are 

12 doing a plan under Section 309 of the Regional Haze 

13 Rule. 

14 And for your information, the four other 

15 states are Utah, New Mexico, Wyoming and Oregon. 

16 The Executive Summary & Background, 

17 Chapters 1 through 3. 

18 The Executive Summary, which is a normal 

19 stage of the Implementation Plan, provides a general 

20 overview of the State Implementation Plan, or SIP for 

21 short. 

22 Chapter 1 gives the background and 

23 regulatory history. 

24 Chapter 2 gives the physical, demographic 

25 and economic descriptions of the state of Arizona. 

 NORTHERN ARIZONA REPORTERS 

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 8

 1 And Chapter 3 gives descriptions of the 

 2 four Class I areas and a list of the 16 Colorado 

 3 Plateau areas. 

 4 The four Class I areas in this particular 

 5 system we are dealing with are: the Grand Canyon 

 6 National Park; Mount Baldy; Petrified Forest; and 

 7 Sycamore Canyon. 

 8 Chapter 4 is basically what we call our 

 9 "technical chapter". It deals with "What Is Haze" and 

10 discusses what pollutants contribute and how they 

11 contribute to regional haze; what types of sources emit 

12 those pollutants; what visibility is like at the 16 

13 Grand Canyon Visibility Transport Commission Class I 

14 areas; and then the summary of Arizona's visibility 

15 monitoring strategy. 

16 Chapter 5 we call the "RAVI chapter". It 

17 stands for Reasonable Attributable Visibility 

18 Impairment. Visibility in specific stationary sources. 

19 "Stationary sources" are utilities, or smelters or 

20 other sources that are permanently located in specific 

21 areas and do not move around. 

22 This chapter also contains commitments to 

23 fulfill Sections 51.302 through 307 of the Regional 

24 Haze Rules to remove the Federal Implementation Plan, 

25 which now exists in the state of Arizona. 

 NORTHERN ARIZONA REPORTERS 

 9

 1 It also contains Arizona's RAVI rule, 

 2 which will be effective December 2nd, '03, that 

 3 establishes the procedures to determine controls should 

 4 a stationary source be certified and found 

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 5 attributable. 

 6 Chapter 6 deals with "Clean Air 

 7 Corridor". 

 8 This chapter contains a summary of the 

 9 Grand Canyon Visibility Transport Commission's 

10 conclusion that there is one clean air corridor on the 

11 Colorado Plateau. And Arizona does not have any part 

12 of the clean air corridor held within the state.

13 It also contains a commitment for Arizona 

14 to cooperate in regional emissions tracking program 

15 for clean air corridors. 

16 This is a map of the clean air corridor. 

17 It's not too clear here, but Arizona is down to the 

18 Grand Canyon (indicating on projection). Arizona is 

19 the lowest state there. That shows where the clean air 

20 corridor is located. 

21 Chapter 7 is the "Stationary Sources" 

22 chapter, which contains a brief history of the 

23 stationary sources approach and rationale for the 

24 backstop market trading program, otherwise known as the 

25 "Annex" under the Regional Haze Rule. 

 NORTHERN ARIZONA REPORTERS 

 10

 1 It also contains the monitoring 

 2 requirements, the showing of thirteen percent sulfur 

 3 dioxide, or SO-2, reduction, and a summary of the NOx 

 4 and PM Report. 

 5 It also contains a commitment to complete 

 6 the Arizona rule for the trading program as soon as 

 7 practicable. 

 8 Chapter 8 is "WEB Trading Program for 

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 9 Stationary Sources". This is the actual trading 

10 program. 

11 The SO-2 Milestones and Backstop Trading 

12 Program contains milestones, the default allocation 

13 process, pre-trigger and post-trigger requirements for 

14 monitoring and record keeping and geographical en15 hancement. 

16 I should say at this point: If anybody 

17 has some questions about these specific things, feel 

18 free to ask them during the presentation. 

19 Chapter 9, "Mobile Sources". 

20 Chapter 9 contains an explanation of the 

21 GCVTC's work, WRAP's subsequent technical analysis and 

22 federal regulatory actions. 

23 And "GCVTC" stands for Grand Canyon 

24 Visibility Transport Commission, and "WRAP" is the 

25 Western Regional Air Partnership. 

 NORTHERN ARIZONA REPORTERS 

 11

 1 This also contains a summary of Arizona's 

 2 approach and conclusions to non-significance deter-

 3 mination issue for multiple sources. 

 4 And it contains two versions to account 

 5 for probable federal rule revision, which was proposed 

 6 on July 3rd -- That should be "03". Excuse me. It 

 7 says "02", but it should read "03". 

 8 And it is my understanding that that rule 

 9 should be becoming final shortly. We have not received 

10 any further information at this point. 

11 Chapter 10 is the "Fire" chapter, which 

12 contains the Enhanced Smoke Management Plan, including 

13 emission reduction techniques, or "ERTs", for short, 

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14 and the tracking system to track emissions from various 

15 types of fires.

16 It contains commitment to develop a 

17 process for dealing with administrative barriers to 

18 nonburning activities, and contains revisions to 

19 R18-2-602, which is Arizona's open burning rule, and 

20 Article 15, which is Arizona's range management rule 

21 submitted to the Governor's Regulatory Review Council 

22 for final action this past November 17, 2003. 

23 Chapter 11 is the chapter on "Road Dust", 

24 which contains GCVTC's acknowledgment that dust 

25 requires additional tracking and modeling. 

 NORTHERN ARIZONA REPORTERS 

 12

 1 It also contains a commitment to track 

 2 emissions from paved and unpaved road dust. 

 3 It discusses the "In & Near" approach, 

 4 suggested as a way to address road dust under 309(g), 

 5 which is a supplemental section, and future SIP 

 6 revisions as modeling and inventories improve. 

 7 Chapter 12 is the "Pollution Prevention" 

 8 chapter, which contains a list of current renewable 

 9 energy and energy efficient programs in Arizona.

10 The primary component in this chapter is 

11 the Environmental Portfolio Standard, administered by 

12 the Arizona Corporation Commission. 

13 And it also has ADEQ considering the 

14 future role in energy programs and how best to 

15 contribute to the regional energy goal, which is a 

16 ten-point goal, outlined in the Regional Haze Rule. 

17 Chapter 13 is a section in the GCVTC 

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Transcripts_Flagstaff Public Hearing_11-24-03.txt

18 recommendations called "Other GCVTC Recommendations", 

19 and we opted to put this in a separate chapter for 

20 clarity. It provides a review of recommendations from 

21 the 1996 report not addressed elsewhere in the SIP. 

22 And categorical by stationary, mobile, 

23 area and multi-sector. 

24 It includes a summary of the federal land 

25 managers' information provided for the four Class I 

 NORTHERN ARIZONA REPORTERS 

 13

 1 areas covered by this SIP. 

 2 Chapter 14 is what we call the 

 3 "Projection chapter". "Projection of Visibility 

 4 Improvement". 

 5 It includes the 1996 and 2018 emission 

 6 inventory information for the following source 

 7 categories: area, stationary point, mobile (on- and 

 8 non-road), road dust (paved and unpaved), fire 

 9 emissions (prescribed, agricultural and wildfire) and 

10 biogenic. 

11 It also includes projected improvement 

12 from 1996 to 2018 for each of the 16 Colorado Plateau 

13 Class I areas, considering identified control 

14 strategies. 

15 Chapters 15 and 16 are part of the 

16 "Coordination and Review" that are contained in almost 

17 all Arizona's SIP, and includes two things: Arizona's 

18 commitment to participate in regional planning via the 

19 WRAP, and coordinate with other stakeholders; 

20 acknowledgement that Arizona's SIP is not applicable to 

21 tribes; and a commitment, within Chapter 16, to 

22 periodically review for determination of reasonable 

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23 progress. 

24 Chapter 17 is the "309(g) Commitment". 

25 Declaration of Arizona's commitment to 

 NORTHERN ARIZONA REPORTERS 

 14

 1 address the remaining eight Class I areas in a SIP 

 2 revision under the requirements of 40 CFR 51.309(g). 

 3 Briefly, what this means is: There are 

 4 twelve Class I areas in Arizona. We are tackling the 

 5 first four in the 309 SIP. What we need to address are 

 6 the remaining eight. And the Regional Haze Rule allows 

 7 us to do that under 309, Section (g), of the Regional 

 8 Haze Rule. And we will be working on that SIP within 

 9 the year 2004. 

10 This is just a map of the Arizona Class 

11 I Area. You will see the red ones. They are the ones 

12 we are dealing with right now. And the remaining blue 

13 ones are the eight that we will be addressing in the 

14 309(g) SIP. 

15 Along with the base SIP, the actual SIP 

16 document itself, there are two other major documents 

17 that come along with the SIP. One is the Western 

18 Regional Air Partnership Technical Support Document, 

19 which is also listed on their WRAP web page, which is 

20 wrapair.org. 

21 We also have it posted on the ADEQ web 

22 page. And the appendices are referenced for the 309 

23 states. They also are on the WRAP web page. 

24 We have the SIP, the TSD and the 

25 appendices for Arizona also on the Arizona Regional 

 NORTHERN ARIZONA REPORTERS 

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 15

 1 Haze website, which is listed there. 

 2 And again, I remind you that the public 

 3 comment period closes at 5:00 p.m. on December 3rd. 

 4 CHAIRPERSON MASSEY: This concludes the 

 5 explanation period of this proceeding on the proposed 

 6 State Implementation Plan. 

 7 QUESTION AND ANSWER PERIOD

 8 CHAIRPERSON MASSEY: Are there any questions 

 9 before we go to the oral comment period? 

10 (No audible response.)

11 CHAIRPERSON MASSEY: OK. Hearing none, this 

12 concludes the question-and-answer period of this 

13 proceeding on the proposed State Implementation Plan. 

14 ORAL COMMENT PERIOD

15 CHAIRPERSON MASSEY: I now open this proceeding 

16 for oral comments. 

17 Mr. Carl Bowman?

18 MR. BOWMAN: My name is Carl Bowman. I am the 

19 Air Quality Specialist with the National Park Service 

20 at Grand Canyon National Park. 

21 I am very glad to be here this afternoon. 

22 In fact, I have been looking forward to it since August 

23 15th, 1991. That afternoon I was a somewhat bewildered 

24 participant at the first formative meeting of some 

25 "thing" called the "Grand Canyon Visibility Transport 

 NORTHERN ARIZONA REPORTERS 

 16

 1 Commission". 

 2 Since that time, we in the National Park 

 3 Service have been working with hundreds of others 

 4 through the Commission and its successor organization, 

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 5 the Western Regional Air Partnership, to develop a 

 6 regional plan to address the haze that can obscure the 

 7 magnificent vistas of the Grand Canyon as well as the 

 8 other Class I areas of the Colorado Plateau. Today we 

 9 see this work coming to fruition here in Arizona with 

10 the draft State Implementation Plan for Regional Haze 

11 before us. 

12 As a participant in the plan's 

13 development process, I would like to commend the 

14 Arizona Department of Environmental Quality for their 

15 effort in developing this plan with an open, stake16 holder - based process. This process relies heavily on 

17 the various groups affected by this plan. Government, 

18 industry and environmental groups were all welcome at 

19 the table. I am sure it wasn't easy for ADEQ leading 

20 this process, considering and consolidating the many 

21 viewpoints offered and producing this plan. In the 

22 end, though, I believe we have a plan that will guide 

23 us along the path to reduce the haze of air pollution 

24 in our parks and wilderness areas. 

25 The draft plan meets our expectations and 

 NORTHERN ARIZONA REPORTERS 

 17

 1 appears to meet the requirements under the Regional 

 2 Haze Rule promulgated by the EPA. We do have a few 

 3 comments that we believe will clarify some portions of 

 4 the plan. 

 5 The provisions regarding future emission 

 6 milestones for nitrogen oxides and particulate matter 

 7 in Section 7.3 can still use a bit of tweaking. This 

 8 should avoid any inadvertent impressions that decisions 

Page 14
Transcripts_Flagstaff Public Hearing_11-24-03.txt

 9 have already been made regarding future options and 

10 best available retrofit technology for these 

11 pollutants. 

12 Section 8.5 discusses the criteria the 

13 National Park Service intends to follow for certifi14 cation of visibility impairment by sources of sulfur 

15 dioxide. A memorandum of agreement regarding these 

16 criteria has not been formally completed between the 

17 National Park Service and the State of Arizona; 

18 however, we are prepared to move forward on the basis 

19 of the existing draft agreement used for Section 8.5. 

20 We will address these issues in more 

21 detail and some other minor points in our written 

22 comments, which we will submit before the close of the 

23 comment period on December 3rd. We have worked long 

24 and hard to get to this point, and I look forward to 

25 seeing the difference we can make. 

 NORTHERN ARIZONA REPORTERS 

 18

 1 CHAIRPERSON MASSEY: Thank you. 

 2 I have no other speaker slips at this 

 3 time. Are there any others that would like to make 

 4 oral comments? 

 5 (No audible response.)

 6 ADJOURNMENT OF ORAL PROCEEDING

 7 CHAIRPERSON MASSEY: Seeing no additional 

 8 speaker slips, this concludes the oral comment period 

 9 of this proceeding. 

10 I encourage everyone to submit written 

11 comments on the proposed State Implementation Plan. 

12 Your participation is an essential part of this 

13 process. 

Page 15
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14 Again, you may also submit written 

15 comments by mail, e-mail or fax to Corky Martinkovic by 

16 the end of the comment period. The end of the comment 

17 period is 5:00 p.m. on Wednesday, December 3rd, 2003. 

18 If mailed, e-mailed or faxed, written comments must be 

19 "postmarked" no later than December 3rd, 2003. 

20 Please submit your written comments to: 

21 Corky Martinkovic, Air Quality Planning Section, 

22 Arizona Department of Environmental Quality, 110 West 

23 Washington Street, Phoenix, Arizona 85007; or by fax at 

24 602 - 771-2366; or by e-mail at martinkovic.

25 deborrah@ev.state.az.us

 NORTHERN ARIZONA REPORTERS 

 19

 1 Thank you all for attending. 

 2 The time is 4:54 p.m., and I now close 

 3 this oral proceeding. 

 4 (The public hearing concluded at 4:54 p.m.,

 5 November 24, 2003.)

 6 - - -

 7 

 8 

 9 

10 

11 

12 

13 

14 

15 

16 

17 

Page 16
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18 

19 

20 

21 

22 

23 

24 

25 

 NORTHERN ARIZONA REPORTERS 

 20

 1 STATE OF ARIZONA )

 ) REPORTER'S CERTIFICATE

 2 COUNTY OF COCONINO )

 3 

 4 I, John A. Dalsin, do hereby certify that 

 5 I am a Certified Court Reporter within the State of 

 6 Arizona and a Registered Professional Reporter;

 7 I further certify that the foregoing 

 8 proceedings were taken in stenotypy by me at the time 

 9 and place herein set forth and were thereafter reduced 

10 to typewritten form, and that the foregoing constitutes 

11 a true and correct transcript of the notes taken at 

12 that time;

13 I further certify that I am not related 

14 to nor employed by or for any of the parties or 

15 attorneys herein nor in any way interested in the 

16 outcome of the within action;

17 In witness whereof I have hereto affixed 

18 my signature this 5th day of December, 2003.

19 

 

20 

 

21 _______________________________

 JOHN A. DALSIN

22 Arizona Certified 

Page 17
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 Court Reporter No. 50270

23 

24 

25 

 NORTHERN ARIZONA REPORTERS 

Page 18

Appendix A-18 – Public Participation Arizona Regional Haze SIP

Appendix A-18c. Written Comments Received During Comment Period
F:\raid\WinKendallGroup\ADEQ02-002\030801_Parts\031231_Final\Comments\AEPCO Comments_Downey.rtf

November 26, 2003

Corky Martinkovic

Air Quality Planning Section

Arizona Department of Environmental Quality

1110 W. Washington St.

Phoenix, AZ 85007

RE: COMMENTS ON REGIONAL HAZE STATE IMPLEMENTATION PLAN

Arizona Electric Power Cooperative, Inc. (AEPCO) is a customer-owned, nonprofit,

electric utility with approximately 300 employees headquartered in Benson, Arizona. We 

are the owner/operator of Apache Generating Station (Apache Station), a 560 MW

generating station with two gas/coal-fired steam electric generation units, one gas/oilfired combined cycle steam generation unit, and three gas/oil-fired turbine units. Apache 

Station supplies power to six electric distribution cooperatives, which serve more than

270,000 people in portions of Arizona, California and New Mexico.

As you are aware, AEPCO has participated as a stakeholder in the Arizona Department of 

Environmental Quality’s (ADEQ) process to develop the draft revisions to the State

Implementation Plan (SIP) that will implement regional haze regulations in Arizona. 

Previous to this effort, through our affiliation with WEST Associates, we provided input 

to the Grand Canyon Visibility Transport Commission (GCVTC) and its successor body, 

the Western Regional Air Partnership, as they worked on their recommendations and

plans to reduce visibility impairment in the national parks and wilderness areas of the

Colorado Plateau.

Throughout our involvement we have continued to support and advocate the approach to 

visibility management that is presented in Arizona’s draft SIP. Specifically, AEPCO

supports the SIP’s recognition that to realize progress in achieving visibility goals we

must have a program that encompasses not only industrial facilities, but also a wide range 

of emission sources that contribute to visibility degradation, including vehicles,

agricultural activities and forest fires. We also strongly support the SIP’s adoption of the 

GCVTC’s recommendation to implement a voluntary program for sulfur dioxide (SO2) 

emissions reductions from industrial sources. This program is structured to ensure that
Regional Haze SIP Comments

Page 2

November 26, 2003

F:\raid\WinKendallGroup\ADEQ02-002\030801_Parts\031231_Final\Comments\AEPCO Comments_Downey.rtf

the reduction commitments from these sources are achieved by including a “backstop” 

cap-and-trade program that would be imposed if voluntary efforts were unsuccessful.

The pursuit of SO2 reductions per the program included in the regional haze SIP is

beneficial to the environment as it offers reductions from major sources of emissions not 

addressed by Best Available Retrofit Technology (BART) regulations. In addition,

relying on voluntary reductions and a “backstop” emissions trading program is a more

cost-effective approach to regulation than a typical command-and-control program.

We understand that this SIP is an initial step in implementing regional haze regulations in 

Arizona and additional work has yet to be accomplished in developing and proceeding

with the details of the visibility management programs included in the SIP. We look

forward to our continuing role as a stakeholder in these efforts, and appreciate ADEQ’s 

broad inclusion of those affected by these rules in the agency’s activities to date.

If you have any questions regarding these comments, please contact Kara Downey at

(520) 586-3631 or kdowney@ssw.coop.

Sincerely,

Mark W. Schwirtz

Senior Vice President & Chief Operating Officer

Via Facsimile and Electronic Mail

c/ J. Andrew

K. Downey

P. Cooper

P. Ledger

R. Hewlett

M. Nelson

File: ADEQ Correspondence, Air Quality
Dec 3, 2003 

Deborrah Martinkovic, 

Air Quality Division

Arizona Department of Environmental Quality

1110 W. Washington St.

Phoenix, AZ 85007

 Re: Regional Haze State Implementation Plan - Draft of October 24, 2003 

Dear Ms. Martinkovic

Arizona Public Service Company (APS) has actively participated in the state stakeholder 

process and strongly supports the Arizona Section 309 Regional Haze State 

Implementation Plan (SIP). We believe the draft plan meets all federal and state 

requirements and provides effective and workable strategies towards making ‘reasonable 

progress’ on reducing regional haze in Arizona and the west.

To maximize public participation and plan effectiveness, this plan was developed in 

coordination with the Western Regional Air Partnership (a coalition of western states and 

Indian nations) and provided numerous opportunities for all stakeholders to be involved. 

This outreach and cooperation has resulted in an innovative plan that demonstrates real 

progress and stakeholder ownership.

APS has engaged in the development of this innovative regional haze program through 

the Grand Canyon Visibility Transport Commission and the subsequent Western 

Regional Air Partnership. We have also been active in the State Regional Haze process

and, although we are disappointed by the resolution of the state SO2 allocation 

methodology as incorporated in the backstop-trading program, we remain committed to 

the overall program success. Please see additional comments in the attachment.

.

Thank you for the opportunity to participate

Sincerely

William D. Wiley

Senior Environmental Policy Advisor

Attachment- Specific comments
APS Comments On

Regional Haze State Implementation Plan for Arizona

Public Review Draft October 24, 2003

APS appreciates the opportunity to participate in the state regional haze process and 

supports submittal of the Arizona 309 Regional Haze State Implementation Plan (SIP). 

We believe, however that the SIP would be enhanced with the following changes.

1. Please clarify in the SIP that references and appendices are for reference only and are 

not enforceable as part of this SIP (e.g. TSD, NOx/PM report, P2 appendix, etc.).

2. Sections 7 and 8. These Sections refer to Stationary Source requirements and the 

Backstop SO2 Trading program. Please clarify what is required under the expanded 10-

year record-keeping requirement. Does it include all documents currently required under 

our Title V permits (this includes hourly emissions values and monitor maintenance 

records), or is there a selected subset, i.e. annual emissions inventory or Title IV annual 

emission sums?

3. Table 8-2 (page 42). Table 8-2 erroneously suggests that APS’ Four Corners Power 

Plant, which is located on the Navajo Nation Indian Reservation, is subject to the 

jurisdiction of the Navajo Nation. This is not accurate. The plant is subject to EPA 

Region IX jurisdiction, not Navajo jurisdiction. We strongly encourage the state to 

address this issue in a clarifying footnote, next to entry 10 on Table 8-2 (“Navajo 

Nation”), stating, “Although the Four Corners Power Plant is located on the Navajo 

Nation Indian Reservation, the plant is subject to environmental regulation by EPA 

Region IX.” We understand that this same issue applies to SRP’s Navajo Power Plant in 

Page, Arizona. 

4. Section 8.1.3 – Determination of Program Trigger- Changes in flow rate

measurements. The new test methods (2F, 2G, and 2H) are not used to continuously 

monitor flow rates. Instead, they may be used to initially characterize a continuous flow 

monitor system and then be used for ongoing quality assurance audits. Importantly, 

reductions in flow rates are not realized unless a continuous flow monitor is first recharacterized using one or all of the new methods (Question 3.13 of EPA’s Part 75 

Emissions Monitoring Policy Manual – October 28, 2003). Using the new methods 

should only reduce the reference method flow rate, resulting in the reference method 

being lower than the flow monitor reads. Also, Acid Rain regulations require that all 

hourly measurements be biased based on the most recent quality assurance testing. 

However, this bias is only applied when the flow monitor reads are lower than the 

reference method. Therefore, a source that chooses to use one or all of the new methods 

for ongoing quality assurance without first re-characterizing the monitor will not reduce 

the flow rates measured by the continuous flow monitor.
Further, the new methods were published for use in mid 1999 as EPA’s answer to several 

claims that conventional methods resulted in overestimating flow rates. However, EPA 

has subsequently determined that, in fact, this may not be the case (Question 3.6 of 

EPA’s Part 75 Emissions Monitoring Policy Manual – October 28, 2003). EPA now 

believes these claims are counterbalanced by evidence that little or no overestimation has 

been seen. 

Because of this recent information published by EPA, the language in this section 

requiring adjustments based on the use of the new flow methods should be deleted. If the 

language is not deleted then it should be clarified that adjustments should only be 

required when an existing flow monitor is re-characterized using the new methods and 

where the monitor’s coefficients had to be changed because the old and new methods 

produced different results. 

5. Section 8.3.1 (g) renewable energy allocations. Please clarify that renewable energy 

allocations are only available for renewable energy physically located within the 

participating five state 309 region. 

6. Section 8.3.1 (g) (6). We believe this Section should be revised to specifically provide 

for public notice and comment prior to finalizing the State (and facility specific) 

Allocation Report for Arizona. 

7. Section 12 Pollution Prevention and Renewable Energy Programs. All participants in 

the pollution prevention subcommittee supported this section of the SIP . APS supports 

the current language of the proposed SIP, as it recognizes the importance of existing 

programs and authorities in supporting renewable energies and energy efficiency in 

Arizona. The Arizona Corporation Commission is reviewing these programs in ongoing 

workshops and is the appropriate authority for evaluating their place in the state’s energy 

mix, while considering energy reliability and affordability. ADEQ need not and should 

not duplicate regulatory efforts in these areas.

8. Miscellaneous. There are several typographical errors and minor corrections needed 

throughout the document. (e.g. pg.15- Mt Baldy is in ‘eastern’ AZ., pg. 21- ‘Mesa Verde 

National Park’, pg. 37- backstop ‘market’ instead of ‘marking’, etc). 
I attended the comment meeting last night and thank you for an informative, capsulated 

presentation of the Arizona SIP. I have a couple follow-up questions:

1. I do not find the City of Phoenix four recommendations on the website. Would you 

please direct me to the location?

2. Are any power plants or proposed power plants desiganted as stationary sources?

Caroline Butler, CLA

Legal Division

Arizona Corporation Commission

1200 West Washington

Phoenix, Arizona 85007

Phone: 602-542-3402

FAX: 602-542-4870
To the Editor:

With "Officials map war on haze," the Tribune maintains it's practice 

of uncritically filling print with press releases from self-serving 

government bureaucracies. Why the unquestioning acceptance that 

"officials" can indeed "do something" about the haze? It's bad enough 

the headline declares another "war" --along with the War on Drugs, the 

War on Hunger, and the War on Obesity, presumably-- but there's no 

apparent attempt to keep public officials honest. For example, there 

are no answers to tough questions for ADEQ director Steve Owens, 

questions such as,

"Mr. Owens, how much will the haze be reduced by your planned measures? 

How will you measure this reduction? How long will it take to meet the 

planned reduction? How will you know when to declare 'victory'? How 

much will this cost taxpayers? Will there be a limit to the amount 

expended for haze reduction? What additional sacrifices may be required 

of valley residents? Will there be a cost-benefit analysis? If plans 

are predicted to be uneconomical or improvement negligible, will we be 

told to just live with the haze? How did Congress come to 'target' the 

Tonto National 'Forest' for this blessing?"

The result of this new war declaration is predictable: we're in for 

another open-ended expenditure of public funds wasted on a declared 

problem that can be realistically solved only by the mass exodus of 

residents from the Valley of the Sun. But not to worry, Valleyites, 

short of that extreme measure the parasite classes will continue to 

provide the illusion they're "doing something" about it, at your 

expense, of course. And if there is still haze after ten years, why, 

they'll just work harder at it! And meanwhile, the Tribune will 

continue transcribing instead of reporting.

Richard D. Welling

Mesa
The camer's and instrument's are not going to get

rid of anything. 

The picture of the inversion on the front page of the 

Rrib show's you how to do it.

Duane Harrison

navigatordhr@wmconnect.com

Corky Martinkovic:

There are natural means of ridding

ourselves of pollution using off the 

shelf product's.

Concentrate on the answer and not 

the problem.

Duane Harrison

Navigatordhr@wmconnect.com
Regarding the plan to reduce haze in scenic areas. I am not sure if you are 

taking comments about the Superstition Wilderness, but I have heard that 

Maricopa County is about to grant a permit modification to allow SRP to burn 

diesel at the San Tan plant when natural gas supplies are low. The haze around 

the plant in the winter is already thick in the winter. The Superstitions are much 

less visible in the area of the San Tan plant than from Mesa where the air is 

clearer. Is there anything the state can do about this being allowed? Sincerely, 

Suzanne Pager
FYI - without attachments

LC

>Date: Wed, 12 Nov 2003 14:06:12 -0700

>To: dam@ev.state.az.us

>From: Lee Comrie <LComrie@pagnet.org>

>Subject: Regional Haze SIP

>Cc: mswg@pagnet.org,mm

>

>As Chair of the Mobile Source Working Group, and on behalf of its members, 

>I would like to notify you of an apparent error in Appendix A-9. Mobile 

>Sources. The appendix includes a letter sent to Ms. Wrona from myself 

>dated July 10, 2003 with the attached report entitled "Arizona Regional 

>Haze Mobile Source Working Group Mobile Source Significance 

>Determination". This version was later updated to reflect the comments 

>and suggestions made at the Stakeholder Advisory Committee meeting held on 

>July 24, 2003. I am attaching the updated letter and report to replace 

>the previous version for inclusion in this Appendix. I would also like to 

>add that an overall review of the document for typographical errors is 

>needed. Please contact me if you have any questions.

>LC

>

>Leonore "Lee" Comrie

>Air Quality Manager

>

>Pima Association of Governments

>177 N. Church Ave., Suite 405

>Tucson, AZ 85701

>

>Ph: (520) 792-1093 Fax: (520) 620-6981
December 3, 2003 

Deborrah Martinkovic 

Arizona Department of Environmental Quality 

1110 W. Washington Street 

Phoenix, Arizona 85007 

RE: Comments on the Arizona Regional Haze State Implementation Plan 

Dear Ms. Martinkovic: 

This letter provides comments on the pollution prevention portion of Arizona 

Department of Environmental Quality’s (ADEQ) Regional Haze State Implementation 

Plan (Haze SIP). Environmental Defense, Grand Canyon Trust, the Southwest Energy 

Efficiency Project and Western Resource Advocates (formerly the Land and Water Fund of 

the Rockies) have participated in and monitored the development of the Arizona Haze SIP 

through the efforts of Rick Moore (Stakeholder Advisory Committee Member) and 

Amanda Ormond and Jeff Schlegel (Pollution Prevention Work Group Members). 

We commend the state on the stakeholder process used to develop the entire Haze 

SIP. The process allowed a broad constituency to play an active role in the development of 

the components related to energy efficiency and renewable energy. We also recognize and 

applaud the efforts of the Pollution Prevention Work Group (P2WG) Chair and Co-Chair, 

Ursula Kramer and Ray Williamson, respectively, and the assistance of Theresa Rigney, 

ADEQ. 

The state has done a good job addressing many of the pollution prevention 

requirements in the (RHR) 40 CFR 51.309(d)(8). However, in reviewing and comparing 

the requirements of the Regional Haze Rule with the SIP draft presented for public 

comment, we find serious, material omissions in the pollution prevention section (Chapter 

12). 

By its own admission, the ADEQ has developed the 2003 SIP as a “baseline” or 

“foundational” SIP and, as such, the plan lacks any commitment to action. The Pollution 

Prevention section of the SIP is little more than a catalogue of existing programs or efforts. 

The Haze SIP, as drafted, proposes no future actions. The plan does not: 

• propose any strategy that the state will undertake to ensure that progress will be 

made towards achieving the goal that renewable energy will comprise 10 percent of 

the regional power needs by 2005 and 20 percent by 2015, nor 
Page 2 of 4 

Comments on Arizona Haze SIP 

• propose strategies to expand energy efficiency efforts. 

The state is required to report on progress made in the area of pollution prevention 

between submittal of the plan in 2003 and the first reporting period in 2008. Unless the 

state develops a strategy to promote renewable energy and calculates its contribution to the 

10/20 renewable energy goal, the requirement that it “explain why meeting the State’s 

contribution was not feasible” will be a hollow exercise. In addition, if no commitments to 

action are enumerated in the plan there will be no way for the public and interested parties 

to monitor the state’s progress over the next five years. Therefore, the state should 

include, in the 2003 SIP, what concrete actions it is going to take toward meeting the 

10/20 renewable energy goals. 

For example, the Arizona Corporation Commission is currently considering 

changes to, and possible expansion of, the existing environmental portfolio standard and 

the return of funding to energy efficiency programs. The ADEQ could commit in the 2003 

SIP to monitor this regulatory process and provide technical input on benefits from 

expansion of renewable energy and energy efficiency programs on regional haze. This 

action was recommended by a majority of members of the pollution prevention work group 

for consideration by ADEQ. 

 The RHR requires reporting certain types of data related to renewable energy and 

energy efficiency. Although Arizona does provide detailed information on existing and 

planned renewable energy generation data and energy efficiency programs, information is 

lacking in the following areas: 

 40 CFR 51.309(d)(8)(i) clearly requires the state’s plan to include “the State’s 

anticipated contribution toward the renewable energy goals for 2005 and 2015.” While the 

SIP does quantify that Arizona’s current contribution is about 0.08% in 2002, nowhere in 

the pollution prevention section, Chapter 12, nor elsewhere in the plan, does Arizona 

quantify its anticipated contribution to the 10/20 goals for 2005 and 2015, as required by 

the RHR. The State needs to provide numbers that reflect Arizona’s anticipated 

contribution to the regional renewable energy goals of 10 percent by 2005 and 20 

percent by 2015. 

The RHR section 40 CFR 51.309(d)(8)(iii) requires the state to document 

“programs to preserve and expand energy conservation efforts”. Energy efficiency efforts 

can be one of the most cost-effective approaches for reducing emissions from power plants 

and addressing regional haze. Table 12-8 in the state’s draft plan provides a list of energy 

efficiency programs. With the exception of the first two of the 34 programs in Table 12-8, 

the programs listed were existing programs as of 2002, and there is no information 

provided on programs that will be, or are expected to be, expanded in the future. Simply 

listing existing energy efficiency programs is not sufficient to meet the RHR requirement 

to “preserve and expand energy conservation efforts.” The non-consensus 

recommendations submitted to the ADEQ from the majority of the P2WG members 

provided a list of energy efficiency efforts that the ADEQ should consider supporting. The 
Page 3 of 4 

Comments on Arizona Haze SIP 

ADEQ should state in the 2003 its commitment to pursue such efforts. The state needs to 

add information on actions or programs to expand energy efficiency efforts 

(including future programs it will support) as required in 40 CFR 51.309(d)(8)(iii). 

Also related to the efficiency programs listed in Table 12-8 by virtue of being 

included in this section, it is presumed that all energy efficiency programs listed in the 

table are the programs that the state anticipates will be preserved and reported on in 2008. 

This is problematic because the State Energy Office operates the majority of programs 

listed, yet the Energy Office does not have funding through 2008 to operate all programs 

listed. Energy Office funding is predominately from Petroleum Violation Escrow (PVE) 

funds, which are limited and nearly exhausted. If these programs are discontinued, due to 

lack of funding, the state will not have preserved energy efficiency programs. In fact it 

will have reduced the state’s energy efficiency programs. Indeed, a core Clean Air Act 

(CAA) requirement of all SIPs is the duty of the state to have adequate funding to carry out 

the programs in the plan. See CAA §110(a)(2)(E), 42 U.S.C. § 7410(a)(2)(E). The State 

should review the list of energy efficiency programs listed in Table 12-8 and only 

include those programs that the state believes will be fully funded and in existence 

through the first reporting period in 2008. Alternatively, the state should add 

qualifying language explaining that, absent additional funding, the listed Energy 

Office programs are likely to be eliminated prior to reporting in 2008.

In the same table few programs provide quantification of actual or expected energy 

reductions. This information is needed for future milestone reports to document progress 

in energy conservation. Although baseline information on energy use reduction 

resulting from energy efficiency programs is not required to be reported in the 2003 

SIP, the state should develop and collect this data for use in reporting progress in 

2008. 

To satisfy the requirement of 40 CFR 51.309(d)(8)(iv) to provide “documentation 

of the potential for renewable energy resources” the state has included resource maps from 

the National Renewable Energy Laboratory. However, information on the total electricity 

generation potential for various renewable energy sources cannot be derived from these 

maps. We suggest that Arizona use the Renewable Energy Atlas of the West (as other 

states have) for satisfying this provision of the rule, since the atlas provides estimates 

of the electricity generation potential from each renewable resource for each state in 

the West. 

The submittal of the 2003 Arizona Haze SIP in December culminates over a decade 

of work to define methods and enact policy and regulations to reduce haze-causing 

emissions. The Grand Canyon Visibility Transport Commission clearly recognized the 

potential contributions of energy efficiency and renewable energy to help reduce regional 

haze and lower the cost of compliance. The Western Regional Air Partnership and its Air 

Pollution Prevention Forum spent several years developing products and recommendations 

for use by states related to energy. Arizona professionals have spent hundreds of hours 

participating on various work groups and forums to develop the draft Haze SIP. While the 
Page 4 of 4 

Comments on Arizona Haze SIP 

state has done a good job addressing many of the requirements in the pollution prevention 

section of the RHR, it needs to address the above items to submit a complete Haze SIP. 

In conclusion, to complete the job, we strongly encourage ADEQ to identify 

specific energy efficiency and renewable energy measures to be carried out, to determine 

Arizona’s contribution to the region’s renewable energy goals, to increase its direct 

involvement in state-sponsored initiatives and legislation related to renewable energy and 

energy efficiency, and to quantify the benefits of these programs. These are core 

requirements of the regional haze program under 40 CFR 51.309 and, importantly, the 

lasting foundation for cleaner, healthier air. 

We look forward to reviewing ADEQ’s modifications in the pollution prevention 

section of this SIP. 

 

Respectfully submitted, 

Vickie Patton Rick Moore 

Attorney Associate Director 

Environmental Defense Grand Canyon Trust 

Howard Geller John Nielsen 

Executive Director Energy Project Director 

Southwest Energy Efficiency Project Western Resource Advocates


N3615(8213) 

Deborrah Martinkovic, Air Quality Planning Section 

Air Quality Division 

Arizona Department of Environmental Quality 

1110 West Washington Street 

Phoenix, Arizona 85007 

Dear Ms. Martinkovic 

Thank you for the opportunity to comment on the final draft of Arizona’s State Implementation Plan 

for Visibility Protection and Regional Haze. As you know, visibility protection is a critical air quality 

concern for Grand Canyon National Park and the other National Park System units in Arizona and on 

the Colorado Plateau. Like the State of Arizona, we have been partners in this effort since the first 

formative meeting for the Grand Canyon Visibility Transport Commission in August 1991, and are 

pleased to see the Commission’s work, and that of the Western Regional Air Partnership that built on 

it, reaching this stage. 

Arizona’s proposal, which is based on the recommendations of the Grand Canyon Visibility Transport 

Commission (GCVTC) as codified in Environmental Protection Agency’s (EPA) regional haze rule 

under 40CFR 51.309, will implement measures to improve visibility by reducing regional haze in the 

16 mandatory federal Class I areas on the Colorado Plateau (located in the States of Colorado, New 

Mexico, Utah and Arizona) through the year 2018. On a periodic basis, additional measures may need 

to be adopted by the State to ensure that reasonable progress is being made to attain the national 

visibility goal of no human-caused impairment to visibility in mandatory federal Class I areas. Using 

the templates developed by the Western Regional Air Partnership (WRAP), Arizona’s proposed plan 

appears to contain all the major components required for inclusion in State implementation plans as 

specified in EPA’s regional haze rule. 

We appreciate the open, participatory process you have used in developing this plan. We believe 

hearing and incorporating the views of stakeholders from across the State have benefited this effort. 

Since the National Park Service was able to participate in developing the Plan, we were able to resolve 

our issues and concerns, and have few comments at this stage. 

We do believe section 7.3 (regarding future regulation of nitrogen oxides and particulate matter) needs 

some adjustment to better reflect the findings of the Western Regional Air Partnership and the 

requirements of Section 309(d)(4)(ii-iv) of the Regional Haze Rule. 

A Memorandum of Agreement between the State of Arizona and the National Park Service regarding 

certification of impairment by sulfur dioxide sources has not been signed. However, we are ready to 

move forward on the basis of the draft Agreement developed through the Western Regional Air 

Patnership. 
 A line-by-line review of these and other minor issues is attached to this letter. 

We look forward to continued progress in reducing the haze over the National Parks and Wilderness 

Areas of Arizona and her surrounding states as we move on to address the other eight Class I areas of 

southern Arizona and those in nearby states under Section 51.309(g) of the Regional Haze Rule. 

If you have any questions, please don’t hesitate to contact Mr. Carl Bowman, Grand Canyon National 

Park’s Air Quality Specialist, at (928) 638-7817 or carl_bowman@nps.gov. 

Sincerely 

Joseph F. Alston 

Superintendent 

attachment 

bcc with attachment: 

GRCA: Jeff Cross 

ARD-DEN: John Bunyak, Brian Mitchell, Bruce Polkowsky 

 National Park Service - AIR 

P. O. Box 25287 

 Denver, CO 80225-0287 

IMRO: John Reber 

PEFO: Lee Baiza (Supt.), Karen Beppler-Dorn (Res.Mgmt.) 

Petrified Forest National Park 

P.O. Box 2217 

Petrified Forest National Park, AZ 86028 
Attachment 

Regional Haze State Implementation Plan for the State of Arizona, Public Review Draft of 10/24/03 

Specific line comments by the National Park Service, Grand Canyon National Park 

page: line 

15:18 Geographic error, “land on the western eastern side of the state and is one of the many extinct 

volcanoes found throughout the state.” 

21:31 Typographic error, “Mesa Vera Verde National Park, Colorado – Spanish for “green table,” 

Mesa Verde allows visitors to experience” 

21:44 Typographic error, “large amount of visitors every year. There are over 100,000 miles of trail, 

and despite peaks that rise” 

22:9-12 This section describes Oregon’s Black Canyon National Wilderness Area, rather than 

the Black Canyon of the Gunnison National Wilderness Area in Colorado. A possible 

substitute is taken from the park’s website, “The Black Canyon of the Gunnison's unique and 

spectacular landscape was formed slowly by the action of water and rock scouring down 

through hard Proterozoic crystalline rock. No other canyon in North America combines the 

narrow opening, sheer walls, and startling depths offered by the Black Canyon of the 

Gunnison.” Other statistics that may be of use include the depth of the gorge (up to 2,600’ 

deep), visitation in 2002 (174,349), and the portion of the Canyon within the park (the most 

spectacular 12 miles of the total 53). 

23:27 This may be a bit of an oversimplification, since the eye only responds to visible, not all, light. 

Suggested change: “frequencies, or wavelengths, of visible light simultaneously.” 

24: Figure 4.1 This illustration is a good way to explain these concepts. 

27:25-26 In addition to the state-sponsored IMPROVE monitoring, the National Park Service has 

maintained IMPROVE monitors (transmissometer and particle samplers) in Petrified Forest and 

Grand Canyon national parks since 1987, providing a long baseline of visibility measurements 

. 

39:17 The wording of Section 7.3 does a better job than previous versions to reflect Arizona’s 

commitment to evaluate the need for additional NOx and PM controls. However, line 25 goes 

somewhat beyond the WRAP NOx and PM report’s, and thus Arizona’s, findings on the 

adequacy of this work to support a determination. The report states, “The WRAP’s current 

modeling system, while sufficient for analyzing the regional impact of some emission changes, 

is not predicting nitrate concentrations well enough to support a decision on whether or 

not stationary source NOx controls are an effective way at achieving reasonable progress

– the results are simply too uncertain. Several improvements to the modeling system are 

underway, but until the model produces better nitrate results, other means of assessment will be 

necessary to determine the appropriate level of NOx control in future SIPs” (Stationary Source 

NOx and PM Emissions in the WRAP Region: An Initial Assessment of Emissions, Controls, 

and Air Quality Impacts, pp I-4&5, emphasis added). 
 Given the current indeterminate need for controls, the SIP should also address how this need 

will be determined. Although this determination could be implied from the wording of lines 

25- 28, it would be better to simply state that the determination process and necessary programs 

will be part of the 2008 SIP revision. Suggested wording of lines 23-28 to clarify these issues 

is: 

 

23 included in Appendix A-7c. The report represents the State of Arizona’s initial 

assessment of stationary 

24 source NOx and PM strategies for regional haze. The State of Arizona has can not 

determined that the need for NOx and PM 

25 strategies are not needed at this time. The State of Arizona commits to adopting longterm strategies and 

26 Best Available Retrofit Technology (BART) requirements for stationary sources of 

NOx and PM as a SIP 

27 revision in 2008, addressing long-term strategies and Best Available Retrofit 

Technology (BART) requirements for stationary sources of NOx and PM. if Arizona 

determines such emission control strategies are needed to demonstrate 

28 reasonable progress.

48:42-48 These lines call for the backstop trading program to be triggered by either a “consensus” 

(line 42) or a “unanimous” (line 45) decision by participating states and tribes. The language 

should be consistent to avoid later misunderstanding, should consensus to trigger the program 

be reached without unanimous assent, or to make clear Arizona’s intentions if consensus is 

reached without unanimity. 

68:17 The language in section 8.5(a)(1)(i-iii) generally agrees with the most recent Draft 

Memorandum of Agreement posted to the WRAP website 

(http://wrapair.org/forums/mtf/documents/ravi_bart/MOAonRA_BARTrev012003.doc). The 

Agreement has not yet been completed and signed between the National Park Service and the 

State of Arizona. The following language corrects discrepancies between the Draft SIP and 

Draft MOA: 

69:1 Clarify the status of the agreement, “Park Service and U.S. Forest Service intend agree

to use the following screening process in making” 

69:7 Update criterion, “(ii) There are BART-eligible sources of sulfur dioxide within 150 km

100 miles of the mandatory Federal” 

 

77:13 Missing verb, “smoke. In addition, a statewide inventory and emissions tracking system must

be established for volatile” 

78:18 Typographic error, “including the State Department of Agriculture, State Land Department, 

Federal Land Managers’s,” 

79: Table 10-1 is a good addition to the Plan. 

118 Descriptions of the two National Parks describe them as “recreational” areas, while their 

statutory purpose is as preserves (the courts have determined the “conserve” phrase of 16 USC 

1 §1 as the primary, and the “provide” phrase as the secondary purpose of national parks: “... 
which purpose is to conserve the scenery and the natural and historic objects and the wild life 

therein and to provide for the enjoyment of the same in such manner and by such means as will 

leave them unimpaired for the enjoyment of future generations”). The following corrections 

reflect this fundamental purpose. 

118:21-22 Recreational use of national parks is limited to those activities that do not 

compromise the long-term preservation of their features. A correction reflecting this mission 

and better defining the park’s high use is, “and adjacent uplands. This high use recreational 

area natural preserve is under the jurisdiction of the U.S. National Park Service. Intensive use 

is confined to relatively small areas on the North and South rims, while most of the park is 

remote and primitive.” 

118:37 In land management, the term “multiple use” includes activities such as grazing and 

mining, which are not permitted in the Park. Correction, “this multi-use tourist and recreational 

area popular preserve includes information on wind generated emissions. A” 

124: Table 14.3 Typographic error, “Capital Capitol Reef national Park” 

125: Table 14.4 Typographic error, “Capital Capitol Reef national Park” 

Appendix A-13b. Table 1 (Grand Canyon National Park): 

 Point Sources within 50 km: add a coal fired power plant 20 km east of the Park (Navajo) 

Appendix A-13b. Table 3 (Petrified Forest National Park): 

Paved and Unpaved Roads: There are approximately 40 miles of two-lane paved road in the 

Park, and a 4.5 mile portion of Interstate 40 passes through the northern portion. 

Wind-generated emissions: add “dry riverbeds” to the sources of windblown dust both within 

and adjacent to the Park. 

Prescribed Burning and Wildfire: Vegetation in the park is shrub and grassland, with few trees. 

No prescribed fires are currently conducted in or within 50 km. of the park. Wildfires (grass) 

are rare. 

Point Sources: Coal fired power plants are 35 km west (Cholla) and 52 km southeast 

(Coronado) of the Park. 











Embedded e-mail from Chris Janick attached to SRP’s formal comments

Corky:

SRP's comments on the draft SIP are presented in the attached letter (you will receive a 

copy in the mail as well). In addition to those comments, there is one other item that

should be changed. Page 97, under the heading "Green Pricing", makes reference to 

SRP's Solar Choice program and solar equipment at Santan. This program has been 

replaced with what we now call EarthWise Energy (as referenced in a few other parts of 

the Pollution Prevenion section), and now includes not only solar, but other renewable 

energy sources as well. In addition, in order to make room for the expansion of our 

Santan plant, the solar equipment referenced in this paragraph was relocated to the 

Rogers Substation (as reflected in Appendix A-12b). As such, SRP requests that this 

paragraph be revised to read as follows:

Salt River Project: SRP provides a renewable energy purchase option to its 

customers. Dubbed EarthWise Energy, SRP customers can purchase 100-watt blocks of 

renewable capacity for $3.00 per month. For more details see 

http://www.eren.doe.gov/greenpower/gp_munipu.html#srp






































One South Church Avenue, Post Office Box 711 

Tucson, Arizona 85702 

Area Code 520 

Telephone 571-4000 

December 3, 2003 

Ms. Deborrah Martinkovic 

Air Quality Division Sent via e-mail 

Arizona Dept. of Environmental Quality and facsimile 

1110 W. Washington Street 

Phoenix, AZ 85007 

RE: Comments to the ADEQ proposed Regional Haze SIP published October 24, 2003 

Dear Ms. Martinkovic: 

Tucson Electric Power (TEP), a wholly-owned subsidiary of UniSource Energy Corporation 

(NYSE: UNS), is pleased to submit these comments regarding the Regional Haze State 

Implementation Plan (SIP). TEP owns and operates electric generation, transmission, and distribution 

assets and serves more than 350,000 customers in Southern Arizona. TEP generates electricity both 

from firing fossil fuels as well as renewable resources. 

On October 24, 2003, the Arizona Department of Environmental Quality issued, for public comment, 

a proposed Regional Haze State Implementation Plan (SIP). This SIP has been prepared to satisfy 

Arizona’s obligations, under delegated authority by the Environmental Protection Agency, for 

addressing Regional Haze. The Regional Haze Rule became effective on August 30, 1999, and 

delegated States are required to incorporate the requirements of the rule into their SIPs. As Arizona 

has selected to prepare a SIP in accordance with 40 CFR Part 51, Section 309, the SIP document is 

due no later than December 31, 2003. 

TEP has been actively involved in the deliberations leading up to and including the preparation of this 

SIP. In 2001, ADEQ initiated a stakeholder process to evaluate which of the available regulatory 

schemes the State would use to satisfy the requirements of the Regional Haze Rule. TEP participate 

in that process and we supported the outcome, to prepare a “309 SIP.” More recently TEP 

participated in the Stationary Sources and Pollution Prevention workgroups, which were charged with 

providing recommendation to ADEQ relating to the preparation of this SIP. 

TEP supports the process under which the SIP was developed and commends ADEQ for their efforts 

in soliciting stakeholder input. 

TEP was unable to provide comments to the entire SIP and has limited its comments to the two areas 

in which has actively participated as interested stakeholder during the SIP draft development: the 

Stationary Sources and the Pollution Prevention workgroups. Our specific comments follow. 

Comments related to Chapter 8 – SO2 Milestones and Backstop Trading Program

Page 51, Section 8.3.1 

TEP agrees that for Category 1 utility sources the floor allocation should be based on a “clean unit” 

emission rate for each unit. TEP also and very strongly believes that the heavier burden should be 

borne by the BART eligible sources since the purpose of the Regional Haze program is to specifically 
Ms. Deborrah Martinkovic 

Arizona Dept. of Environmental Quality 

December 3, 2003 

Page 2 

address those sources. As such, the “clean unit” definition for purposes of allocating the floor portion 

of the allowances need not be the same for all units. 

TEP worked very hard and cooperated with several utility stakeholders as well as members of the 

WRAP and ADEQ during the SIP development to set forth an allocation methodology that would be 

fair to all participants. Several meetings were held including one in Tucson, Arizona, where an 

agreement was seemingly reached, only to be later discarded. At that meeting, the following 

assumptions/agreements were made for purposes of defining “clean unit.” 

 1. Coal-fired units that in 1999 were operating with a baghouse for particulate control, but 

otherwise uncontrolled for SO2, would be assumed to be at 20% control efficiency. 

2. BART eligible sources that in 1999 were operating with a control efficiency below 70% 

would be assumed to have a control efficiency of 85%. Units that were controlled at between 

70% and 80% were assumed to increase control efficiency by 5%. Units controlled above 

80% would remain at that level. 

3. Sources with known mandated future controls, other than BARTable sources, would be 

assumed controlled at that level. 

4. Units not subject to BART: 

a. For sources with existing control at or below 50% assume a control efficiency of 

50%. 

b. For sources with existing controls between 50% and 70% assume a control 

efficiency of 70%. 

c. Sources with existing controls above 70% assume the existing level of controls. 

5. For purposes of floor allocations to all sources assume operation at 85% capacity factor. 

TEP strongly suggests that the above “clean unit” definition be adopted. The above “clean unit” 

definition addresses all the principles and equity issues described in the SO2 Milestone/Backstop 

Trading Program at page 52. It would also provide the stakeholders with the certainty and direction 

regarding potential future capital expenditures to address compliance with Regional Haze and/or 

other SO2 compliance programs. 

Certainty was fundamental in TEP's, and the other utilities, support of the Regional Haze Section 309 

option. 

The Arizona Utility Stakeholders also provided, as a group, an allocation methodology that utilizes 

the method used by the Market Trading Forum (MTF) in establishing the milestone levels and is 

based on the opt-in/opt-out table. This methodology also would allow each state to establish statespecific allocation methodologies by assigning a specific number of SO2 allowances to each state and 

then specify an allocation methodology in each individual SIP. 

TEP strongly suggests that either the “clean unit” definition as above for “floor” allocations or the 

total allocation methodology that has previously been submitted by the Arizona Utilities be adopted 

into the SIP. 
Ms. Deborrah Martinkovic 

Arizona Dept. of Environmental Quality 

December 3, 2003 

Page 3 

Page 58, Section 8.3.3 

In Section 8.3.1, WEB sources are divided into two categories. Category 1 are those WEB sources 

that commence operation prior to January 1, 2003, while Category 2 are those that commence 

operation after January 1, 2003. Category 1 would be eligible to receive reducible portions of the 

allocation, while Category 2 would not. Both would receive floor allocations. The Category 2 

allocations are to be taken from the new source set aside. 

The draft rule at R18-2-1610.B defines an existing source as one that commences operation prior to 

the program trigger and new web source as one commencing operation after the program trigger. 

Therefore, a unit that commences operation after January 1, 2003, but before the program trigger date, 

would be considered an existing unit. 

Section 8.3.3, Distribution of the New Source Allocations, sets the availability of these allowances for 

a new WEB source and an existing WEB source. However, a Category 2 WEB source that 

commences operation after January 1, 2003, but before the program trigger date would, for purposes 

of receiving allocations under Section 8.3.3, be an existing source. It is not clear how such a source 

would receive its share of allocations. TEP suggests that the new source set-aside be available for 

three categories instead of two. The third category to be added under Section 8.3.3 is as follows: 

 8.3.3(1)(c) – Category 2 floor allocations as established in Section 8.3.1(1)(b)(iii). 

Comments related to Chapter 12 – Pollution Prevention and Renewable Energy Programs

TEP fully supports the pollution prevention provisions of the SIP as presented in Chapter 12. This 

chapter represents the consensus recommendations of the Pollution Prevention Workgroup, in which 

TEP participated, and which deliberated for nearly a year in order to formulate a consensus position. 

In accepting the consensus recommendation and rejecting certain non-consensus recommendations, 

ADEQ recognized two important concepts relating to the pollution prevention provisions of the 

Regional Haze Rule. 

First, the Regional Haze Rule does not mandate the implementation of any specific energy policies. 

EPA clarified the relationship between the “10/20 goals” and States’ requirements relating to the 

pollution prevention by stating in the preamble to the rule that “The [10/20] goals themselves are not 

enforceable and States are not required to meet the renewable energy goals.” “Rather, EPA is setting 

enforceable requirements for the States to assess progress toward [the] goals...” 

Secondly, Arizona’s contribution to the “10/20 goal” should be commensurate with the renewable 

resources available. Section 12.1 of the SIP references a letter sent by the Pollution Prevention 

Workgroup to the co-chairs of the WRAP Pollution Prevention Forum, which provides comments to 

the WRAP document titled “Renewable Energy and Energy Efficiency as Pollution Prevention 

Strategies for Regional Haze.” This letter, which represents the consensus position of the P2WG, 

presents the workgroup’s concerns relating to the proposed method for assigning each State’s 

contribution to the “10/20 goals.” Arizona’s most abundant renewable resource is solar energy; 

therefore, Arizona should work to develop this resource. However, as the incremental costs of 

producing electricity from solar energy is considerably higher than other resources, Arizona’s 

contribution will have to be less than that of other States in the region. 
Ms. Deborrah Martinkovic 

Arizona Dept. of Environmental Quality 

December 3, 2003 

Page 4 

In addition to these two points, it is important to note that, based on the work of the WRAP, even if 

the 10/20 goals were met and certain energy efficiency measures were adopted, there is expected to 

be a mere 2% decrease in NOx emissions for the region and essentially no decrease in SO2 emissions. 

Thank you for the opportunity to provide these comments and for the excellent work you and other 

ADEQ staff have done in preparing the proposed SIP and for allowing for substantial stakeholders 

input. 

If you have any questions, please call me at (520) 884-3642. 

Sincerely, 

TUCSON ELECTRIC POWER COMPANY 

Cosimo De Masi 

Manager, Corporate Environmental Services 
Appendix A-18 – Public Participation Arizona Regional Haze SIP

Appendix A-18d. Responsiveness Summary
RESPONSIVENESS SUMMARY 

to 

Testimony Taken at Oral Proceedings and Written Comments Received on 

Arizona Regional Haze State Implementation Plan 

The oral proceedings on the Arizona Regional Haze State Implementation Plan (SIP) 

were held at 4:30 p.m., Monday, November 24, 2003, at Coconino Library, Flagstaff, 

Arizona; and at 5:00 p.m., Monday, November 24, 2003, at Arizona Department of 

Environmental Quality, Phoenix, Arizona. The public comment period closed at 5:00 

p.m., Wednesday, December 3, 2003. Oral and written comments received and Arizona 

Department of Environmental Quality’s (ADEQ) responses are described below. During 

its final review of the proposed SIP, ADEQ determined some further clarifications were 

appropriate. These clarifications are also included below. 

1) Issue: There is no information in the SIP regarding impacts to the Tonto National 

 Forest or the Superstitions. Response: This SIP addresses the federal mandatory 

 Class I areas in Arizona that are part of the Colorado Plateau. The Superstition 

 Wilderness Area is a Class I area, but is not part of the Colorado Plateau and will 

 be addressed in a later SIP under Section 309(g) of the Regional Haze Rule. The 

 Tonto National Forest is not a federally protected Class I area and will not be 

 addressed under the requirements of the Regional Haze Rule. 

2) Issue: The Pollution Prevention Chapter of this SIP does not include language 

 that discusses how ADEQ would act to preserve and promote renewable energy 

 and energy efficiency programs. Response: Detailed reports prepared by the 

 Regional Haze Pollution Prevention Work Group (P2WG) that present differing 

 views of ADEQ’s role in energy-related programs have been reviewed by the 

 Director and are considered invaluable as ADEQ continues to take an active role 

 in energy policy in Arizona. ADEQ believes this SIP meets the initial

 requirements of the Regional Haze Rule as it pertains to energy programs under 

 Section 309. 

3) Issue: Some of the programs listed in the Pollution Prevention Chapter could be 

 eliminated due to a loss of funding. Removal of these programs could then be 

 considered a retreat from the requirements of the SIP, or continued funding of a 

 program could be required under the federal enforceability of a SIP. Response: 

 This SIP is a “snap-shot in time” of renewable energy and energy efficiency 

 programs already in place or planned in response the requirements of the 

 Regional Haze Rule. A listing of these programs in the SIP does not make them 

 federally enforceable. Also, programs associated with pollution prevention are 

 reviewed in relation to the regional Energy Renewable Goal and are not 

 considered control measures. 

4) Issue: The SIP should include a pointer (with greater detail in future SIP 

 revisions) to the concept of Renewable Energy Credits (RECs) currently being 

 investigated by the Western Governors’ Association. Response: ADEQ is 
 aware of the REC concept and understands the Western Regional Air 

 Partnership (WRAP) Air Pollution Prevention Forum (AP2 Forum) may be 

 looking into this in greater detail in the near future. Inclusion of RECs in this 

 SIP, however, is premature. 

5) Issue: The Pollution Prevention Chapter of this SIP does not include a 

 quantification of energy programs related to the regional Renewable Energy Goal 

 nor an approach for tracking program impact. In addition, Arizona did not use the 

Renewable Energy Atlas of the West for documenting the potential of renewable 

 energy resources. Response: The Regional Haze Pollution Prevention Work 

 Group (P2WG) attempted to quantify contributions and potentials related to 

 energy programs and their impact on regional haze. The task was difficult due to 

 formula assumptions modeled on regional characteristics that did not serve 

 Arizona-specific conditions enough to make the results reliable. Work on this 

 issue is included within Sections 12.9 through 12.11 of the Pollution Prevention 

 Chapter of this SIP. Additional information can be found in related sections of 

 the Technical Support Document submitted with this SIP. ADEQ will consider 

 the use of the Renewable Energy Atlas of the West in any future work related to 

 the regional Renewable Energy Goal. 

 

6) Issue: It is unclear where the four recommendations on pollution prevention 

 developed by the City of Phoenix were included in this SIP, and if any Arizona 

 utilities were classified as stationary sources. Response: The four 

 recommendations were developed not by the City of Phoenix but by the 

 Regional Haze Pollution Prevention Work Group. The recommendations, 

 presented as nonconsensus reports, are posted to the ADEQ Web page under Air 

 Quality Planning, Regional Haze, Pollution Prevention Work Group (P2WG) at 

http://www.adeq.state.az.us/environ/air/plan/haze.html. A list of sources 

 classified as stationary sources, including utilities, can be located in both 

 Chapter 5 and Chapter 8 of this SIP. 

7) Issue: ADEQ should not have developed this SIP as current products 

 available could prevent air pollution. Response: ADEQ appreciates the 

 comment but is required by law to develop a SIP to address the existing 

 conditions that contribute to regional haze as well as activities that could prevent 

 future impairment. 

8) Issue: Numerous issues related to the stationary source program, SO2 Milestones 

 and Backstop Trading Program (see SO2 Milestones/Backstop Chapter of this 

 SIP), are yet unresolved. Response: Arizona will be an active participant in the 

 Western Regional Air Partnership (WRAP) forums such as the Stationary Sources 

 Forum, formerly Market Trading Forum, and the newly created Coordination 

 Committee (described in the Stationary Sources Chapter of this SIP). It is 

 ADEQ’s understanding that work will commence in 2004 to discuss and revise as 

 necessary the SO2 Milestones and Backstop Trading Program. 

 
9) Issue: It is not clear if the 10-year record keeping requirement for sources 

 participating in the WEB Trading Program includes all the existing required 

 documents under the current 5-year requirement or a “selected subset” of 

 documents. Response: It is ADEQ’s understanding that any documents retained 

 under the current 5-year retention requirement in the WEB Trading Program Rule 

 would be expanded to cover 10 years. In addition, any records pertinent to 

 satisfying the pre-trigger requirements of the Web Trading Program Rule would 

 also be retained for 10-years. Any clarification to the specifics of the trading 

 program, however, will be reviewed and revised as necessary as outlined in No. 8 

 of this Responsiveness Summary. Any necessary revisions or clarifications to the 

 WEB Trading Program Rule will be made prior to the rule’s final approval by the 

 Governors’ Regulatory Review Council. 

10) Issue: Table 8-2 (Chapter 8 of this SIP) leads to a possible misconception that 

 the Four Corners Power Plant is not under the jurisdiction of the Region IX of the 

 EPA. Response: This table is a duplicate of the Table included in the federal 

 Regional Haze Rule for the stationary source emission reduction program, and is 

 included in the program description of all states submitting a SIP under Section 

 309 of the Regional Haze Rule. Clarification should be provided at the federal 

 rule level, and then incorporated into the SIPs. 

11) Issue: It should be clarified that renewable energy allocations (under the WEB 

 trading Program) are only available for renewable energy physically located 

 within the participating five states participating in SIPs under Section 309 of the 

 Regional Haze Rule. Response: The WEB Trading Program is a regional 

 program and one state cannot dictate the specifics of the program. As stated 

 earlier, however, any clarification to the specifics of the trading program, 

 however, will be reviewed and revised as necessary as outlined in No. 8 of this 

 Responsiveness Summary. 

12) Issue: Section 8.3.1(g)(6) of the Web Trading Program (Chapter 8 of this SIP) 

 should be revised to specifically provide for public notice and comment prior to 

 the finalizing of the State’s (and facility specific) Allocation Report for Arizona. 

Response: A necessity to develop a proposed Allocation Report for Arizona 

 would also necessitate a SIP revision. This SIP revision would be subject to 

 public notice and comment, including the Allocation Report for Arizona. Again, 

 as stated previously, any clarification to the specifics of the trading program, 

 will be reviewed and revised as necessary as outlined in No. 8 of this 

 Responsiveness Summary. 

 

13) Issue: There should be clarification in the SIP that references and appendices are 

 for reference only and are not enforceable as part of this SIP. Response: It is 

 ADEQ’s understanding that only those programs or activities that constitute 

 committed measures or incorporated state-specific rules are considered federally 

 enforceable. Programs or activities related to goals versus control measures have 

 been noted throughout the SIP. 
14) Issue: (1) Arizona should not commit to a specific regional haze implementation 

 approach until after EPA has responded to the court’s remand of the RHR 

 (Regional Haze Rule); (2) the Department’s proposed SIP does not meet the 

 minimum requirements of either Arizona statute or 40 CFR §51.309 and Arizona 

 must therefore pursue a RHR SIP under 50 CFR §51.308; and (3) The RHR 

 Section 309 Annex is not a rational or cost-effective approach for improving 

 visual air quality in Arizona or other western states. Response: ADEQ 

 appreciates the analysis of these issues, but does not share in the conclusions. 

 EPA has stated that the court’s remand of the RHR does not affect states wishing 

 to pursue an implementation approach under Section 309 of the RHR, and 

 believes the Arizona SIP complies with the requirements of the Regional Haze 

 Rule. 

15) Issue: Work completed by the Western Regional Air Partnership (WRAP) 

 regarding the emission reduction milestones under the Annex (stationary source 

 SO2 reduction program) provide greater reasonable progress than would be 

 achieved by the application of best available retrofit controls for all federal 

 mandatory Class I areas in the region, not just the 16 Class I areas on the 

 Colorado Plateau. This would include the remaining eight Class I areas in 

 Arizona not addressed by this SIP. Response: ADEQ concurs with WRAP’s 

 findings, but this SIP addresses the 16 Class I areas on the Colorado Plateau, four 

 of which are contained in the northern portion of Arizona. This issue will be 

 revisited as Arizona continues to address regional haze in a SIP under Section 

 309(g) of the Regional Haze Rule as well as the SIP revisions required for 

 periodic review. This issue is discussed further in the Technical Support 

 Document that accompanies this SIP. 

16) Issue: Language in the Stationary Sources Chapter of this SIP needs to better 

 reflect the findings of the Western Regional Air Partnership (WRAP) regarding 

 the future regulation of nitrogen oxides and particulate matter. Response: 

ADEQ believes the language is appropriate for this SIP, and the inclusion of the 

 NOx – PM Report as an Appendix to this Chapter discusses the need for further 

 analysis of these pollutants related to regional haze. ADEQ will be an active 

 participant with the Western Regional Air Partnership in this endeavor. 

17) Issue: The 1996 mobile sources emissions inventory and the subsequent mobile 

 source emissions projections developed by the Western Regional Air Partnership 

 (WRAP) over-estimated emissions for Maricopa County. Response: ADEQ is 

 aware of this issue and the Regional Haze Emissions Inventory Work Group 

 (EIWG) addressed the concern in their report to the WRAP. The EIWG report is 

 included in Appendix A-14 to Projection of Visibility Chapter of this SIP. 

18) Issue: Page 97 of the proposed SIP under the heading, “Green Pricing,” in the 

 Pollution Prevention Chapter that references SRP’s Solar Choice program and 

 solar equipment at Santan needs to be corrected. This program is now called, 
 “EarthWise Energy” and includes not only solar but other renewable energy 

 sources as well. Response: ADEQ has made the clarification. 

19) Issue: There were several expressions of support for the SIP, and the WEB 

 Trading Program specifically. Response: ADEQ appreciates the positive 

 comments and commitment to the national visibility goal. 

20) Issue: There were several expressions of appreciation for the opportunity to 

 participate in the development of this SIP. Response: ADEQ appreciates their 

 involvement and contribution to this SIP and encourages their on-going support 

 and participation. 

21) ADEQ initiated changes to the SIP include the following: Updates related to 

 final regulations, appendix documents, and Technical Support Document (TSD); 

 and spelling, grammatical, and formatting corrections throughout the document.