## Western Regional Air Partnership

2004 Work Plan

Adopted by the WRAP Board October 14, 2003

### Table of Contents

Executive Summary .......................................................................................... 1

I. Background ........................................................................................................... 14

II. Tribal Options for Implementation Plan Development........................................... 14

III. WRAP Organization and Structure ....................................................................... 15

A. Membership ............................................................................................. 15

B. Charter and Bylaws ..................................................................................... 16

C. WRAP Organization .................................................................................... 16

D. Oversight Committees (Initiativ es and Technical) ........................................ 16

E. Communications Committee ......................................................................... 16

F. Stakeholder Involvement ............................................................................... 16

IV. Project Management ........................................................................................ 17

A. Setting Priorities ........................................................................................ 17

B. Reconciling Conflicts ................................................................................. 18

C. Outreach and Peer Review ........................................................................... 18

D. State and Tribal Coordination ........................................................................ 18

E. Administration and Staffing .......................................................................... 18

F. Contract Management ................................................................................. 19

V. Regional Haze Work Plan ................................................................................. 21 A. Initiatives Oversight Committee ....................................................................... 21 B. Stationary Sources Joint Forum ....................................................................... 21

C. Fire Emissions Joint Forum ............................................................................ 22

D. Air Pollution Prevention Forum ..................................................................... 26

E. Mobile Source Forum ................................................................................. 28

F. Sources In and Near Class I Areas Forum ...................................................... 29 G. Economic Analysis Forum ........................................................................... 29 H. Air Quality Modeling Forum ........................................................................... 30 I. Technical Oversight Committee ..................................................................... 31

J. Emission Forum ........................................................................................ 33

K. Tribal Data Deve lopment Work Group ............................................................... 36

L. Dust Emissions Joint Forum ..................................................................... 38 M. Ambient Monitoring and Reporting Forum .......................................................... 39 N. 309 Coordinating Committee ........................................................................... 40 O. Air Managers Committee .............................................................................. 40

P. Communications Committee .......................................................................... 441 

### EXECUTIVE SUMMARY

This work plan summarizes the activities and expenditures planned by the Western Regional Air Partnership (WRAP) for the calendar year 2004. These include activities initiated in earlier years receiving additional funds in 2004, as well as new activities.

The WRAP was formed in 1997 as a successor organization to the Grand Canyon Visibility Transport Commissions, established by the Cl ean Air Act Amendments of 1990. Since 1997, most of the WRAP’s focus has been on impl ementing the Commission’s recommendations. A major milestone in implementing these recomme ndations is the submission by the end of 2003 of state implementation plans (SIPs) to the U.S. Environmental Protection Agency (EPA) in

accordance with Section 309 of the federal regional haze rule. Mo st of the work on Section 309 SIPs also supports the development of tribal implementation plans (TIPs) and the development of SIPs by the end of 2007 for states subjec t to Section 308 of the regional haze rule.

The completion of Section 309 SIPs (expected for five WRAP states) repr esents a significant accomplishment of the WRAP and will benefit all of its members in future haze control efforts. Nonetheless, legally, they only address the contri bution of emissions from these states to the visibility impairment at 16 Class I areas on th e Colorado Plateau. The contribution of these emissions to other Class I areas (there are ove r 100 other Class I areas in the WRAP region, including tribal ones), and the c ontribution of emissions from othe r WRAP states to all Class I areas remains to be addressed. This is the pr incipal challenge for the WRAP over the next few years, made no easier by the diverse environment and variety of emission sources impacting each

Class I area.

Recognizing this challenge, the WRAP recently completed a long-term strategic plan for the 2003 – 2008 time period 1 , which in turn has provided a st rong basis for this 2004 work plan. Among other things, the strategic pl an (1) identifies major products and milestones; (2) serves as an instrument of coordination; (3) provides the direction and transparency needed to foster stakeholder participation and consensus-based decision making, which are key features of the WRAP process; and (4) provides guidance to the individual plans of WRAP forums and

committees.

In its grant guidance, the EPA id entifies long-term planning issues that should be addressed by regional planning organizations (RPOs), such as an overall course of action, a vision of the planning process, the use of partnerships for jo int planning, assessment of data and tool needs, and cooperation with other RPOs. The WRAP strate gic plan and Sections II, and III, and IV of this work plan address most of these issues. With respect to the remaining issues, the WRAP will work with other RPOs through the techni cal discussion groups facilitated by the EPA, through regular participation in director-level calls and meeti ngs, and as necessary on other issues (e.g., emission inventories and control strategies in borde r regions). The WRAP’s needs for new and improved data and tools are generally assessed within its forums and is refined through the annual work plan de velopment process. Particip ation in inter-RPO discussion groups provides further opportunity to identify and refine these needs.

1 See http://www.wrapair.org2 On a more general level, the WRAP’s pla nning process must accommodate a unique landscape of environmental, social, economic, and politic al issues. The WRAP region includes 116 (or 75 percent) of the nation’s 156 ma ndatory federal Class I areas, half the land mass of the United States (not including Alaska), a very large portion of publicly-owned lands, and numerous tribal jurisdictions (many with large la nd areas). It also emits a minority of total U.S. emissions, borders both Canada and Mexico, and receives pollution from Asia. Most WRAP members will not have to contend with ongoing ozone and pa rticulate matter nonattainment issues, which simplifies air quality planning to some extent , but many WRAP members are faced with rapid population growth and other challeng es to preventing deterioration of air quality. Moreover, the WRAP must be sensitive to other regionally-impor tant environmental issues, such as fire and drought. This presents a unique and challenging environment fo r long-term planning which is best addressed through a single, well-funded and well-organized institutio n at the appropriate political level. The WRAP, with the appropr iate EPA financial support, provides such an institution, especially given its co-management st ructure shared between the Western Governors’

Association and the National Tr ibal Environmental Council. For example, WRAP uses the WGA-developed environmental management principles known as Enlibra. 2 Use of the Enlibra principles has helped garner support from We stern governors and other stakeholders as an example of how environmental issues should be addressed in the region. Such coordination is key to regional haze planning in the West.

Finally, the WRAP’s long-term pla nning process must be prepared to deal with relevant events beyond its control, such as multi-pollutant legislati on and the ramifications of legal challenges to the regional haze rule and the approval of SIPs and TIPs. One way the WRAP contends with these events is to have sufficient staffing to track the issues and to fost er a constructive dialogue among its members.

Table 1 provides a budget for all new and ongoing WR AP activities. A project coding system has been implemented for all new activities to f acilitate project tracking and coordination. Each new activity, including some not shown in the budget because they are performed directly by WRAP staff or through in-kind support from WRAP participants, is described in Section V of this work plan.

Table 2 provides a matrix of projects and forums. Its purpose is to maintain coordination among the many WRAP projects. The matrix highlight s projects where a forum other than the one sponsoring the project should be involved or peri odically updated. For example, the In and Near Forum should be keyed into the Mobile Sources Forum's retrofit demonstration project (MS1). The matrix also contains a column relating most of the new projects to specific points on the Strategic Plan timeline. A copy of the timeline is provided in Figure 1 . A map of the WRAP region and its state, tribal, a nd federal members is shown in Figure 2 . A map of all tribal lands

and tribal Class I areas in the WRAP region is shown in Figure 3 . An updated organizational

chart for the WRAP is shown in Figure 4

.

2 See http://www.westgov.org /wga/initiatives/enlibra3 Table 1. Status Report and 2004 Budget (September 30, 2003).

WGA Acct. # 30-204 (as of 6/30/03)

Project

Code Project Title Projects Budgeted Projects Underway Expenditures

to Date CY04 Funding

Stationary Sources Joint Forum

Analysis of NOx and PM for Section 309 & 308 (REI) 49,985 28,818

NOx and PM Study (Ted Russell) 6,500 6,500

SO2 Monitoring Protocols for Annex (Pechan) 71,110 71,110

ATS/ETS Specifications (PQ) 17,000 13,412

SS1 Identification of BART-Eligib le Sources 75,633 24,367

SS2 Preliminary Determination of Sour ces Subject to BART 100,000

Fire Emissions Joint Forum
Develop Basis for Enhanced Smoke Mgmt. Progs. (Reynolds) 63,704 56,457

2018 Fire Inventory (Air Sciences) 268,780 216,227

Alternatives to Wildland Burning (Jones and Stokes) 13,488

Evaluate Fire Emissions Estimation Systems 14,578

Model Assessment/Sensitivity Runs 50,000
2002 Inventory of Wx, Rx, and WFU for wildland, rangeland, ag 278,754

Modeling to Assess/Establish deminimus levels 100,000
Fire Emissions/Categorizatio n Guidance - diff. Between

restoration & maintenance 40,000

Guidance for implementation of FTS & AEG policies, including policy/tech. options 50,000

FF1 Wildland Fire Emission Trade-Off Model Review 20,000

FF2 Feasibility Criteria/Technical Guidance for Policy for Categorizing Fire Emissions 20,000

FF3 Guidance on Nat/Anth Apportionment, including support for AMRF & TOC projects 50,000

FF4 Support for RMC analysis of fire emissions scenarios 25,000

FF5 Bridge for Fire Tracking Syst em into WRAP EDMS 10,000

FF6 Refine 2018 fire emissions projections, include AK & HI, plus nat./anthro. Split 130,000

FF7 2002 National Wildfire EI (from OAQPS, inter-RPO project) 100,000

FF8 Technical Guidance on Use of Emissions Reduction Techniques (MACTEC) 54,918 12,631 25,000

FF9 Regional coordination of smoke management programs, including workshop 25,000

FF10 Co-Sponsor Fire Emissions Conference 60,000

FF11 Smoke Mgt Techniques to reduce regional haze impacts

on Class I areas 10,0004 WGA Acct. # 30-204 (as of 6/30/03)

Project

Code Project Title Projects Budgeted Projects Underway Expenditures

to Date CY04 Funding

Air Pollution Prevention Forum

Tribal RE/EE (NAU) 4,905

Integration of RE and EE Strategies (Tellus) 25,000 25,000

Van Jamison 196977 552 552

AP2 Forum Meeting Assistance (ICF) 10,971 10,954

PP1 Tech. Assistance to States/Tribes for SIPs/TIPs (GETF) 45,000

PP2 Renewable Energy Tracking and Certificates (Center for Resource Solutions) 14,614 500

PP2 Renewable Energy Tracking and Certificates 73,863 103,023

PP3 Transmission Reform 25,000

PP4 Tracking and Reporting RE and EE Implementation and Impacts of Legislation 50,000

PP5 Displaced Emissions Analysis 25,000

Mobile Sources Forum
Develop Baseline and 2018 Mobile Source Inventories, incl. updates (Environ) 88,499 88,056

Draft Guidance for Promoting Non-Road Demo Projects 20,000

MS1 Support Non-Road Demonstration Projects 75,000 50,000

Sources In and Near Class I Areas Forum

IN1 Emission Inventories Near Class I Areas (Environ) 34,600 70,008 63,678 65,400

Gateway Community Demonstration Project 30,392 34,600

IN2 In/Near Strategies for Reasonable Progress 10,000

Economic Analysis Forum

Economic Forecasts & Evaluations (BBC) 59,600 59,516

EA1 Framework Application Test 50,000

EA2 Development of Baseline Economic Data 80,000

EA3 Enhancement of Cost and Benefit Unit Values 45,400 54,600

EA4 Screening Tool 40,000

Air Quality Modeling Forum

Emissions Processing Jump Start Contract (MCNC) 106,733 106,733

2002 Regional Modeling Center (UCR) 530,362 524,866

MF1 2003 Regional Modeling Center (UCR) 675,000 201,152 600,000

Training and Outreach Activities 85,000

MF2 Alaska Modeling 175,965 100,000

Tech-Wide Projects (TOC)

Quality Management Plan 25,000

Geographic Data Display 25,000

Co-sponsor March 2004 Organic Aerosols Workshop 10,000

TOC1 Attribu tion of Haze 50,0005 WGA Acct. # 30-204 (as of 6/30/03)
Project

Code Project Title Projects Budgeted Projects Underway Expenditures

to Date CY04 Funding

Emissions Forum

2018 Inventory, Y2K SO2, 1996 QA Forecast (Pechan) 15,320 15,320

EI Data Base System - Needs Assessment (EA Eng) 35,000 20,290

EF1 EI Data Base System (Development/User Access/Training/QA/Home) 162,496 475,000

2002 Interim EI – fo r source apportionment/haze

attribution exercise in 2004 24,451

EF2 Phase 2 of Representative Community EIs (Phase 1 RFP under development) 175,000 50,000

EF3 Update non-road emissions projections to reflect proposed regulations 50,000

EF4 EI Improvements for Spatial and Temporal Allocations 25,000

EF5 Canadian & Mexican Emissions – to grow, QA, & prepare EI for 2002 base case 25,000

EF6 2002 Base EI (begin gap fill and QA work) 45,000

EF7 Alaska Aviation Inventory 50,000

Tribal Data Development Work Group
Tribal Inventory Gathering & Analysis + Tribal Smoke (ITEP/NAU) 139,177

Tribal Inventory Gathering and Analysis (ITEP/NAU) 345,573 130,613

TW1 Emissions Data Development support (ITEP/NAU continuation) 200,000

TW2 Monitoring Data Analysis (additi on to Causes of Haze) 100,000

TW3 Tribal TSD Guidance / Template Development 50,000

TW4 Program Enhancement 50,000

Dust Emissions Joint Forum

Fugitive Dust Workshop (Panelists) 14,800 14,800

Wind Blown Dust Inventory Improvement (Environ) 182,324 90,355

DF1 Literature Review - Definitions (e.g., natural/manmade)

and Emission Tools 40,000

DF2 Agricultural Dust - Summary of Existing 2002 Inventories and Control Programs 100,000

DF3 Construction Dust - Summary of Existing 2002 Inventories and Control Programs 13,255 86,745

DF4 Road Dust - Summary of Existing 2002 Inventories and Control Programs 100,000

Ambient Monitoring and Reporting Forum

VIEWS Data Base 2003 (CSU) 249,724 126,361

AMR1 VIEWS Data Base 2004 (CSU) - CENRAP in current

grant 50,000 200,000

AMR2 Causes of Haze Report (DRI) 225,000 190,000 64,874

AMR3 Natural Haze Levels Analysis (from OAQPS,inter-RPO project) 75,0006 WGA Acct. # 30-204 (as of 6/30/03)

Project

Code Project Title Projects Budgeted Projects Underway Expenditures

to Date CY04 Funding

309 Coordinating Committee
309a Annex Implementation 50,000

309b 309 Follow-Up 25,000

Air Managers Committee
STIP-II: Model Rule / MOU (WESTAR) 46,861 32,998

STIP-II: State Staff Support (OR) 115,000 86,250

STIP-II: Tribal Staff Support (NM) 28,763 28,763

STIP-II: Contractor Assistance 157,461

AMC1 State Caucus Staff Support (WESTAR) 227,400 144,474 117,000

AMC2 AK Tribal Outreach Coor dinator 50,000 65,000

AMC3 Health+Env. Assessment of Haze- Related Improvements 45,000

AMC4 Traditional Tribal Practices and Regional Haze 55,000

AMC5 308 Template 30,000

Communications Committee
Outreach Assistance (Pat Murdo) 30,827 1,786

Victor Wouters 1,559 1,559

Retool Web Site (Cobalt) 28,263 22,269

Public Outreach and Communication on WRAP Issues 50,550

CC1 Web Site Maintenance (B. Bissey) 40,718 10,119 32,500

CC2 Continue and Expand Publications 8,500
CC3 Update Presentation Material to Tell the WRAP Story 8,000

CC4 Expand Speakers' Bureau 12,000
CC5 Support Forums in Conducting Public Meetings 10,000

CC6 Other Outreach Efforts to Reach Wider Audience 8,000

Subtotal for Contractor Assistance 2,512,947 3,907,489 2,276,992 3,689,735

Travel and Project Management 7/01-12/03 Budget Expenses

to Date 2004 Budget

Travel Reimbursed by WGA 400,185 271,835 139,749
Conference Calls 89,419 55,107 23,291

Meeting Expenses 135,716 95,168 55,216

Other Expenses 38,879 22,337 11,180

WGA Salaries and Benefits 739,522 467,178 289,789

WGA Overhead 458,043 269,028 163,040
NTEC (including $75,000 for economic analysis) 403,000

Subtotal for Travel and Project Management 1,861,764 1,180,651 1,085,265

Subtotal for Contractor Assistance 6,420,436 2,276,992 3,689,735

Grant Total 8,282,200 3,457,643 4,775,000

FY 2001 STAG Grant – $3,962,200
FY 2002 STAG Grant – $4,320,000

Total = $8,282,2007 Table 2. Matrix of Projects and Their Relation to Non-Sponsoring Forums.89 Figure 1. Strategic Plan Timeline.1011 Figure 2. WRAP Region Members, and Federal Areas Covered by the Regional Haze Rule.12 Figure 3. Map of Tribal Lands and Trib al Class I Areas in the WRAP Region.13 Figure 4. WRAP Organizational Chart (updated).14 I. Background

The 1990 Amendments to the Clean Air Act esta blished the GCVTC, which in June of 1996 completed its original mission to recommend stra tegies for improving visibility in the Grand Canyon and other Class I areas on the Colorado Plat eau. Recognizing the ne ed for a process to monitor and coordinate the implementation of its final recommendations, the GCVTC members

created the WRAP. The WRAP includes participants from industry, environmental groups, and other affected parties and opera tes in conjunction with regional organizations such as WESTAR, the Western Governors' Association, and the Na tional Tribal Environmen tal Council. The work products of the WRAP are used by states and tr ibes in the preparati on of their individual implementation plans to meet the requirements of the federal regional haze rule promulgated by the U.S. Environmental Protection Agency (EPA) in 1999.

While the initial focus of the WRAP was to implement the recommendations of the GCVTC in conjunction with federal visibility rules, the requirements of these rules also highlighted the need to implement other regional planni ng processes to improve visibility in all western Class I areas. In March 1999, the WRAP expanded its charter to address all regional air quality issues.

Section 308 of the regional haze rule contains a general requirement for states to submit an implementation plan on a schedule dependent on the attainment status of the fine particulate standard and participation in re gional planning groups. Section 309 of the rule allows a state that is in the GCVTC transport region to submit an implementation plan conforming to the

recommendations of the GCVTC if the state el ects to submit the plan by December 31, 2003. Such plans would satisfy the state's obligati on for planning for the 16 Class I areas in the jurisdiction of the GCVTC. The states w ould then be allowed to defer submittal of implementation plans for other Class I areas unt il December 2008. As described further below, tribes have the option of submitting implementa tion plans at their discretion and containing reasonably severable provisions they deem most appropriate.

II. Tribal Options for Implementation Plan Development

Under the regulatory framework provided by th e Tribal Authority Rule (TAR) (40 CFR 49.1– 49.11) and the regional haze rule, tribal implemen tation of visibility programs through Tribal Implementation Plans (TIPs) is optional. The TAR authorizes but does not require tribes to receive delegation of authority to implement any program, or “reasonably severable elements” of a program, under the Clean Air Act. The preambl e to the regional haze rule explains that “a tribal visibility program is not dependent on strategies selected by the State or States in which the tribe is located.” (64 Fed. Reg. 35714, 35756, July 1, 1999) The net result is th at any tribe in the GCVTC transport region may apply for implem entation of §308 or §309 in whole or in part.

The policy and technical work of the WRAP to a ssist states will simultaneously be designed to assist tribes in the same way. Tribal concerns are being addressed at every level within the WRAP. Tribal and state implementation plan need s may be different. As these differences are identified, project tasks and wo rk plans will be updated to re flect the improved understanding of

tribal needs.15 To ensure that tribal needs are addressed, the acti ve participation of trib al representatives on all

forums has been and will continue to be sought and encouraged. The National Tribal Environmental Council (NTEC) is responsible for coordinating tribal par ticipation in the WRAP and receives funds from EPA for this purpose. Since some tribes do not have the resources or expertise to participate in the WR AP, NTEC provides tribes with analyses and synopses of issues emanating from the WRAP forums and work groups and from sources outside the WRAP. NTEC also facilitates consensus building within the tribal caucus. The Institute for Tribal Environmental Professionals (ITEP) at Northern Arizona University also provides assistance and staff through the Tribal Data Development Work ing Group to address a key tribal need – the acquisition of data necessary to make informed policy decisions.

Finally, it should be noted that the WRAP organizational struct ure provides several checkpoints for tribal input. First and foremost, the WRAP has established equal representation for tribes and states within its management structure, including a tribal Co-Chair of the WRAP. Key positions

are also reserved for tribal re presentatives on all standing comm ittees, forums, and work groups. Public workshops for WRAP work products and tr avel support from the WRAP ensure that the broader tribal community has an opportuni ty for input prior to WRAP action.

III. WRAP Organization and Structure

In September 1997 the WRAP was formed with a membership including states and tribes both within and outside of the GCVTC region. Th e WRAP established oversight committees and forums charged with developing work plan s to implement the GCVTC recommendations.

A. Membership

The WRAP membership currently includes the Gove rnor or his/her designee from 13 states and 11 tribes, two U.S. Cabinet Secretaries and the Administrator of the EPA or their designees:

States Tribes Alaska Campo Band of Kumeyaay Indians

Arizona Cortina Indian Rancheria California Hopi Tribe Colorado Hualapai Nation of the Grand Canyon Idaho Native Village of Shungnak

Montana Nez Perce Tribe New Mexico Northern Cheyenne Tribe

North Dakota Pueblo of Acoma Oregon Pueblo of San Felipe

South Dakota Confederated Tribes of Salish and Kootenai

Utah Shoshone-Bannock Tribes of Fort Hall Washington Wyoming Federal Agencies Department of the Interior Department of Agriculture Environmental Protection Agency16 B. Charter and Bylaws

The WRAP Charter and Bylaws set forth the ba sic operating goals, prin ciples, and operating procedures and are posted on the WRAP website at http://www.wrapair.org/about/index.html

.

C. WRAP Organization

The WRAP is composed of several foru ms, committees, and work groups. These suborganizations and their relationships are show n in the organization chart in the Executive Summary. All the suborganizations include part icipation from the WRAP membership (states, tribes, and federal agencies) and interested stak eholders (industry, envi ronmental groups, local governments, academia, etc.). Guidelines fo r forum procedures (creation, membership, processes, etc.) are posted on the WRAP Web site at http://www.wrapair.org/about/forumguide.htm

.

D. Initiatives Oversight Committee (IOC) and Technical Oversight Committee (TOC)

The IOC provides general oversight for the co ordination and development of air quality strategies necessary to promote the implementation of federal visibility rules. The TOC provides general oversight of the technica l activities of the WRAP. IO C and TOC members are appointed by the WRAP Board, which strives to manage a ba lance among tribes, states, federal agencies, the environmental community, and the industr ial community. In turn, the IOC and TOC establish forums and work groups and appoint their co-c hairs to conduct the specific work of the

WRAP.

Presently, there are 11 forums and work groups. The IOC oversees the Air Pollution Prevention Forum, Economic Analysis Forum, Mobile Sour ces Forum, and Sources In and Near Class I

Areas Forum. The TOC oversees the Emissions Forum, Air Quality Modeling Forum, Ambient Monitoring and Reporting Forum, and Tribal Data Development Work Group. The Fire Emissions Joint Forum, Dust Emissions Joint Fo rum, and Stationary Sources Joint Forum are overseen by both the IOC and the TOC, as they address both techni cal and policy issues.

E. Communications Committee

The Communications Committee addresses co mmunication among the members and groups of

the WRAP as well as outreach and education of the public and interested groups on air quality

issues.

F. Stakeholder Involvement

The WRAP includes par ticipation from industry, environm ental groups, and other affected parties. The following categories of representatives are regularly considered for membership in committees, forums, and work groups:17 · Industry · Small Busi ness (including “green industry”)

· Mobile Sources · Federal Government

· Tribal Governments · State Governments

· Local Governments · Academia · General Public · Environmental Groups

Committee and forum members are expected to re present and communicate with their agencies and constituents. Forum and committee members are responsible for establishing mechanisms

that will ensure this communication occurs. These mechanisms may involve working through trade groups, state and tribal organizations su ch as the Western States Air Resource Council (WESTAR Council), the Na tional Tribal Environmental Counc il (NTEC), and intra- and interagency forums.

IV. Project Management

A. Setting Priorities

The WRAP members establish the strategic di rection of the organi zation, setting overall priorities for action. Once the WRAP agrees on a direction, issues ar e further developed and priorities refined by the following process:

• The WRAP identifies issues and requests th at one or more oversight committees address them, or asks that the oversight committees develop issues and work plans for review by

the WRAP.

• Oversight committees examine the management and technical issues associated with the strategic direction and identif y the major deliverables, ski lls required, and stakeholders

most affected.

• Based on this examination, oversight committees may refer issues to existing forums or work groups or create forums and work groups to generate the deliverables. Oversight committees appoint co-chairs of forums and wo rk groups and work with the co-chairs to develop a written charge, including object ives, expectations, and time frames for

deliverables.

• Co-chairs of forums and work groups appoi nt members, taking into consideration stakeholder balance and the charge from the oversight committee(s).

• Each forum and work group is responsible for developing a detailed work plan to meet the work product and process guidance from its oversight committee(s) and they should issue bi-monthly reports to their oversight committee(s).

• Oversight committees review a nd approve detailed work plans to ensure that all WRAP time lines and process needs are addressed.18 • Depending on the nature of the process, each forum and work group works with its oversight committee(s) to resolve deadline or budgetary conflicts that may arise in the plan development process.

B. Reconciling Conflicts

If an issue arises on which a forum or work grou p can not reach consensus, the issue is referred to the oversight committee(s). If the oversight committee(s) ca n reach consensus on the issue,

that decision is referred to the forum or work group for integration with the forum or work group’s decisions on other issues. If the oversig ht committee(s) can not reach consensus, the issue may be referred to the WRAP Board for reso lution, or it may be referred back to the forum for further debate. When conflicts over pr iorities and budgets can not be resolved by the individual forum, work group or committee, th e issue may be referred to the WRAP Board.

C. Outreach and Peer Review

The WRAP Communications Manual sets forth the process for reviewing work products and policy decisions. At each stage of review, rele vant material will be posted on the WRAP Web

site and comments will be solicited.

Work products must be presented to the appropri ate oversight committees before being presented to the WRAP. The oversight committees may provide feedback to the forums or work groups; the forum or work group has the responsibility to decide whether or not to make changes. Changes the forums or work groups make to work products should be communicated to the oversight committees so recommendations from these groups to the WRAP can be fully

informed.

Major work products are subject to public review through workshops and formal public comment periods. The forums and work groups are responsible for acknowledging public and peer reviewer feedback in the final presentation to the WRAP.

D. State and Tribal Coordination

In addition to the extensive and ongoing communi cation and coordination th at occurs directly between WRAP participants, the WRAP will wo rk with the Western States Air Resources Council (WESTAR) and the National Tribal En vironmental Council (NTEC) as important coordination points to ensure that state and tribal regional haze needs are clearly identified and addressed by the WRAP.

E. Administration and Staffing

Members of committees and forums perform much of the work of the WRAP. The oversight committees monitor forum and work group activities to ensure that work products are developed in a timely manner and that stakeholder participa tion remains representative , balanced, and fair. Contractors hired with EPA gran t funds are relied upon to expand the resources of the WRAP.

Committees and forums direct the work of contractors.19 Support services to the line f unctions of the WRAP come from the Communications Committee, the National Tribal Environmental Council (NTEC ) and the Western Governors’ Association (WGA). The Communications Committee has de veloped a Communications Manual for the

WRAP’s internal and external communications and assists committ ees and forums with outreach strategies for specific products and activities.

WGA and NTEC staff provide overall project management for the WRAP. WGA provides much of the basic logistical support for the WRAP by preparing and managing grant applications, funds, requests for proposals (RFPs), contracts, travel re imbursements, meetings, conference calls, public and media in quiries, press releases, Web site s, requests to participate in the WRAP, and report publications. Staff a ssistance includes providi ng a “sounding board” for stakeholders having concerns w ith the WRAP processes and re lating concerns to forum cochairs, oversight committees, committee co-chairs, facilitators, and the WRAP co-chairs.

During the period covered by the grant, WGA staff will be performing these activities. Additionally, WGA and NTEC staff routinely attend the meetings of the various committees and forums. WGA and NTEC jointly or separately perform tasks related to WRAP and serve as primary contact points by respondi ng to media and public inquiries.

Under a separate EPA grant, NTEC assists tr ibal participation in the WRAP by arranging, facilitating, and providing reimbursement for tr ibal caucus meetings; providing coordination among tribal representatives of various forums ; performing legal and policy analyses on WRAP issues; and securing contractor assistance for ad ditional technical and policy analysis. This includes providing staff support to th e tribal caucus within the WRAP.

This work plan identifies six staff support posi tions. The first two are the WRAP co-project managers. The co-project managers overs ee other staff, share general management responsibilities, work with stake holders to ensure the WRAP’s pr ocesses are fair and equitable, and serve as the primary points of contact for EPA, the media, and the general public. Funding for one of the co-project managers is under th e WGA line item, while funding for the other is under the NTEC line item. The third staff support position assists the stat e caucus of the Air Managers Committee. Funds for this position are identified in the Air Managers Committee budget and provided to the Western States Air Resources Council for management and oversight. The fourth position assists the tr ibal caucus of the Air Managers Committee. Funds for this position are identified in the NTEC line item. The fifth position assists the Technical Oversight

Committee and its associated forums. And the si xth assists the Initiatives Oversight Committee and its associated forums. These two pos ition are identified in the WGA line item.

Other staff support will be sought as needed. Options include (1) contracting with a WRAP state or tribe to dedicate staff support for a defined pe riod of time; (2) hiring temporary staff at WGA, NTEC, or WESTAR; and/or (3) en tering into an agreement with an independent contractor to provide the needed staff support.20 F. Contract Management

WGA and forums jointly manage WRAP contracts. WGA, as the receiv er of WRAP grants, retains the legal responsibility for signing and administering contracts and ensuring that work products are completed. These responsibilities ar e met with input from forums and work groups. Forums and work groups may creat e balanced subgroups for purposes of contract management.

It is the responsibility of the forums and work groups and their respective oversight committees to develop the scope of work for each contract. All contracts are to be developed in accordance with the work plans approved by the WRAP and submitted to the EPA. Once the scope of work has been properly developed, it is transmitted to WGA. WGA is responsible for developing an RFP or sole source justificati on. All RFPs are published in th e Federal Business Opportunities publication, sent to appropriate contractors known to the WRAP, and posted on the WRAP Web

site. Unless time is otherwise a constraint , bidders are provided 30 days to respond.

A review committee is established for the ev aluation of RFPs. The review committee is responsible for scoring each RFP. Scoring is documented and re tained by WGA to substantiate any selection. Once the committee has agreed upon selection of a pot ential contractor, a

memorandum is transmitted to the WGA Execu tive Director along with any necessary supporting materials. The Executive Director make s the final contractor selection. The winning contractor and all losing bidde rs are notified in writing of Executive Director’s decision.

Subsequent to contractor se lection, WGA staff and the appr opriate forum, work group, or committee negotiates a final contract with the winning bidder. All c ontracting is done in accordance with established federal guidelines. The standard contract form includes provisions for record keeping and audit requirements in accordance with OMB Circular 110.

It is the responsibility of th e forum, work group, or committee to monitor the work of the

contractor and to determine whet her all work requirements are being met. When a bill is received, WGA will examine the invoice to match invoice items to requirements outlined in the contract. WGA requires documentation from the c ontractor regarding hour s spent and expenses incurred. WGA also requires copies of any deliv erables prior to rendering payment. If there is any question regarding whether the contractor ha s met the requirements in the scope of work, it is negotiated between the contra ctor, WGA, and the appropriate co-chairs. Once it has been agreed that all work has been completed in a ccordance with the requirements of the contract, payment is rendered by WGA.

WGA is responsible for maintaining all record s and does so in accordance with all federal requirements. This includes submittal of quarterly status reports to EPA. As noted in the previous section, NTEC lets contracts for work done in support of tribal participation. These contracts are funded by a grant separate from th e general WRAP grant, and are subject to the requirements of the single audit ac t and related compliance supplements.21 V. Regional Haze Work Plan

IO1 Reasonable Progress Criteria – The regional haze rule requi res states, when establishing reasonable progress goals, to consider the following statutory fact ors: the cost of compliance, the time necessary for co mpliance, the energy and nonair quality environmental impacts of compliance, and th e remaining useful lif e of any potentially affected source. Furthermore, states must include a demonstration in their SIPs showing

how these factors were taken into considera tion in selecting each goal. The purpose of this task is to explore these factors (e.g., how they have been used or interpreted in other environmental programs) and to provide furt her definition and guida nce with respect to using them in a regional haze SIP demonstration.

IO2 Process for Identifying Control Strategies – The WRAP strategic plan identifies a “navigational challenge” identi fying and selecting emission control strategies among the large number of those potentially available. It also provides some general ideas on how to “narrow the field.” The purpose of this ta sk is to develop a pr ocess by which the most effective control strategies will be identified and refined.

This is a new forum which is replacing the Market Trading Forum (MTF). It will focus more broadly on stationary source issues throughout th e WRAP and their relationship to Section 308 SIP requirements. Several members from the MT F may participate on the SSJF, but several new members are likely and appropriate given the change in scope.

SS1 Identification of BART-Eligible Sources – This identification is required for all visibilityimpairing pollutants (SO2, NOx, PM, VOC, an d NH3) and regardless of whether or not an emissions trading program or other alterna tive measure is implemented in lieu of the best available retrofit technology (BART). Several WRAP states have requested assistance to either identify BART-eligible sources, cross-check their procedures with those in other states, and/or coordinate iden tification across the regi on to meet the timing and other requirements specified in the region al haze rule and WRAP strategic plan. The Forum will hire a contractor to provide di rect assistance to some states identifying BART-eligible sources, to consult with othe r states and tribes to ensure as much consistency as possible, and to develop a nd maintain a regional database of such

information.

SS2 Preliminary Determination of Sources Subject to BART – In its 1999 regional haze rule,

the EPA said states should find that a BART-e ligible source is reasonably anticipated to cause or contribute to regiona l haze, and therefore be subjec t to BART, if it can be shown that the source emits pollutants within a ge ographic area from which pollutants can be emitted and transported downwind to a Class I ar ea. The U.S. Court of Appeals rejected this approach, saying it impermissibly constrai ns state authority – i.e., by forcing a state Initiatives Oversi g ht Committee

Stationar y Sources Joint Forum22 to apply BART without any empirical eviden ce of the source’s contribution. In April 2004, the EPA is expected to propose an al ternative means by which states would determine which sources are subject to BA RT. The Forum will make a preliminary determination of sources subject to BART based on this proposal. The determination would be finalized sometime after April 2005, wh en the EPA is expected to finalize the rule. Waiting until April 2005 to initiate any of this work would not be prudent given the time needed to develop an alternative program to BART under 308(e)(2) and the possibility that the final rule may not cha nge substantially from the proposed rule.

Determination of BART and/or its equivalent regional emis sion reductions is planned for 2005, but could be initiated sooner if necessary by using the preliminary list of sources subject to BART and making adjustme nts after the rule is finalized.

SS3 Addressing Changes to the BART Provisions of the Regional Haze Rule – This task will include discussions with the EPA about the appr oaches it is considering in response to the U.S. Court of Appeals decision. It will al so include developing formal comments on the EPA’s proposal. (No funding requested.)

The FEJF projects identified in the existing 2003 WRAP Workplan, and the proposed FEJF projects for the 2004 WRAP Workplan, fall into three main categories:

1) The first category provides analyses of t echnical and policy information needed for further action on Categorization/Policy topics.

2) The second category addresses exis ting and future Technical Needs , specifically emissions inventory development and related modeling analyses.

3) The third category of projects is designed to assist WRAP members with Coordination and Implementation of existing fire policies and programs.

The relationship amongst the 2003 and 2004 FEJF pr ojects, and the remainder of the WRAP Work Plan is also presented schematically below, at the end of the FEJF work plan.

Categorization/Policy

FF1 Wildland Fire Emissions Trade-off Model Review - As fire management programs evolve, and as directed by the GCVTC, the applicability of the Wildland Fire Emissions

Trade-off Model will be reviewed for use in applying existing and future WRAP policies and guidance pertaining to smoke management of fire. Recommendations from this assessment have possible linkage to both th e Enhanced Smoke Management Program and

the Annual Emissions Goal policies.

FF2 User Guidance and Review of Feasibility Criteria for Categorizing Fire Emissions

- Further user guidance will be develo ped to support th e existing WRAP Policy for Fire Emissions Joint Forum23 Categorizing Fire Emissions , to refine differences between Restoration and Maintenance prescribed burn types, for elements such as vegetative structure, fu el loading, fuel size classes, ecosystem function, and fire resilien ce. Also, to further understand implications of the feasibility criteria developed by the FE JF, as used in the various fire policies, a

needs assessment for further technica l and policy guidance will be developed.

FF3 Guidance On Apportionment of Natural and Anthropogenic Emissions - The Ambient Monitoring & Reporting Forum’s Causes of Haze Analysis project, and the Technical Oversight Committee’s Attribution of Haze project, will be supported by the FEJF through development of technical approaches to apportioning the impact of fire emissions between natural and anthropogenic source categories.

Technical Needs

FF4 Modeling Assessment of the Impact of Various Fire Emissions Scenarios - Provide support to the Regional Modeling Center to as sess the impact of various fire emissions scenarios, using modeling runs conducted by the WRAP RMC.

FF5 Fire Tracking System Bridge to th e WRAP Emissions Data Management System

- Implementation of the Fire Tracking System policy includes development of a software bridge for fire activity data into th e Emissions Data Management System.

FF6 Refinement of Existing 2018 Fire Emissions Projections - Existing 2018 fire emissions projections for the contiguous WRAP region for wildfire, pres cribed fire, and wildland fire use on wildland, rangeland, and agricultu ral lands will be refined, while also including Alaska and Hawaii fire emissions. This refinement also includes categorization of natural and anthropogenic fire sources.

FF7 2002 National Wildfire Emissions Inventory ( separate $100,000 from OAQPS, national project, WRAP has lead RPO responsibility ) - The 2002 emissions inventory for wildfire will be developed through an inter-RPO effort funded by EPA, based on a scope of work discussed amongst the RPOs. The FEJF has le ad RPO responsibilities for this project.

Coordination & Implementation

FF8 Technical Guidance on Use of Emissions Reduction Techniques – This project was funded and started in 2003, and requires addi tional funding to complete in 2004. The project report direc tly supports Annual Emissions Go al reporting requirement in §309.

FF9 Regional Coordination of Smoke Management Programs - Options for implementing regional coordination of wild land and agricultural prescrib ed fire smoke management programs, information sharing, and public notification will be developed, and then presented and reviewed at a facilita ted conference, to be held in 2004.

FF10 Co-Sponsor Fire Emissions Conference – As fire emissions are particularly important to understand for regional haze planning in the WRAP region, the FEJF has identified the24 need to host a fire technical conference to include national fire emissions experts in 2004. Conference topics include, but are not limite d to: 1) Methods to assess plume rise characteristics; 2) Technical assessment of fire parameters used for regional modeling; 3)

Methods to assess and track emission reduction techniques; 4) Use of technical tools to assist in tracking burning activity for emi ssion inventory purposes, including remote sensing; 5) Treatment of fire sources in regional modeling (e xpectations versus reality); and 6) Fire emissions structur e for SMOKE processor. Init ial discussions with EPA and national fire experts via EPA- facilitated conference calls are being conducted in 2003 to refine the topics and prepare material for the conference.

FF11 Effects of Smoke Management Techniques In Reducing Regional Haze Impacts on Class

I Areas - As smoke management techniques ar e used across the WRAP region, and are useful and economic methods for reducing smoke impacts on Class I areas, an analysis of these techniques and their benefits in reducing haze will be conducted.25Fire Emissions Joint Forum Work Plan ActivitiesRegional Modeling Center Support(fireemissions QA, troubleshooting, sensitivity)Categorization/PolicyTechnicalNeedsCoordination &ImplementationFire Tracking System Bridge to the WRAPEmissions Data Management SystemRefinement of Existing 2018 FireEmissions Projections2002 National Wildfire EmissionsTechnical Guidance on Use ofEmissions Reduction TechniquesRegional Coordination of SmokeManagement ProgramsCo-Sponsor Fire EmissionsConferenceEffects of Smoke ManagementTechniques In Reducing RegionalHaze Impacts on Class I areasWildland Fire Emissions Tradeoff Model ReviewUser Guidance and Review ofFeasibility Criteria forCategorizing Fire EmissionsGuidance On Apportionment ofNatural and AnthropogenicEmissions§308 SIP/TIPPreparation§309ImplementatioDevelop Basis for EnhancedSmoke Management Programs2018 Fire InventoryAlternatives to Wildland BurningEvaluate Fire Emissions EstimationModel Assessment/Sensitivity2002 Inventory of Wx, Rx, andWFU for wildland, rangeland,agricultural landsModeling to Assess/Establishde minimus levelsFire Emissions/CategorizationGuidance (difference betweenrestoration & maintenance)Guidance for implementation ofFire Tracking System&AnnualEmissions Goalpolicies26 The AP2 Forum’s work plan is based largely on the renewable energy and energy efficiency policy adopted by the WRAP Board 3 and on its subsequent manageme nt directive to the IOC and

AP2 Forum. 4 . Specifically, the management directive states:



### • Forward the recommendations and reports of th e Air Pollution Prevention Forum to states

and tribes for their consideration and us e in the development of State/Tribal Implementation Plans for regional haze;



### • Provide states and tribes who follow the 309 path with technical assistance (including data, information, analytical tools) and policy assistance (i ncluding model legislation, rules, and policies) needed to incorporat e the renewable energy and energy efficiency

recommendations of the AP2 Forum into th e Pollution Prevention section of their regional haze SIPs and TIPS;



### • Monitor the Transport Region’s progress to wards achieving the GCVTC 10/20 renewable energy goal and implementation of the re newable energy and energy efficiency recommendations of the AP2 Forum; and



### • Assist the efforts of Western states and trib es to establish a single institution in the WRAP region that will register , certify, issue, track, and oversee trading of renewable energy certificates in the West.

PP1 Technical Assistance

– This task will allow the continuation of technical assistance (including data, information, evaluation of analytical tools) and policy assistance (including model legislation, rule s, and policies) needed by st ates, tribes, and air quality agencies to incorporate the renewable ener gy and energy efficiency recommendations of

the AP2 Forum into the Pollution Prevention se ction of regional haze SIPs and TIPs. Funding for this task will support state energy o ffices, tribal authori ties, and air agency efforts to compile and develop:



### ◦ Renewable energy resource inventories of existing and planned generation capacity;

resource assessments of the most cost-e ffective renewable energy opportunities in a state, and documentation and descripti on of programs relied on to achieve the GCVTC 10/20 goal;



### ◦ Program descriptions of existing and pl anned energy conservation and efficiency programs states will rely on to reduce emissions;



### ◦ Methodologies for applying results of the AP2 Forum’s regional modeling of energy costs, emissions reductions, and economic impacts of adopting the Forum’s renewable energy recommendations and energy efficiency “best practices” at the state

3 WRAP Policy: Renewable Energy and Energy Efficiency As Pollution Prev ention Strategies For Regional Haze; April 2003; pg. 1-2.

4 Ibid.; pg 3. Air Pollution Prevention Forum27 level. This will allow states to comply with section 309(d )(8)(iv) that requires states to develop short and long term projecti ons of emissions reductions, visibility improvements, energy cost savi ngs, and secondary economic benefits associated with the GCVTC renewable energy goals a nd energy efficiency activities.



### ◦ Identify or develop model rules or le gislation for renewable energy and energy efficiency policies to ensure consistent treat ment between states and tribes within the WRAP region.

PP2 Renewable Energy Tracki ng and Certificates Project – Under this task, the Forum will

work with the Western Governors’ Associ ation to convene a regional meeting of stakeholders to collaboratively develop a “blue pr int” that will define the critical features

needed to:



### ◦ Conduct a needs assessment and develop a si ngle set of functional requirements for a certificates-based renewable generation tracking and accounting system in the
Western Interconnect;



### ◦ Develop a standard set of market design and operating guidelines for trading RECs

within the Western Interconne ction to support establishmen t of a single institution in the West responsible for registering, i ssuing, tracking, and verifying renewable energy certificates; and



### ◦ Create of an independent, regional genera tion tracking system to provide data necessary to substantiate the number of megawatt hours generated from renewable energy sources and to support verifica tion, tracking, and trading of RECs.

PP3 Transmission Reform – Participate in regional proceed ings and planning processes to promote policies and rules that elimin ate transmission access, pricing, and

interconnection barriers to renewable en ergy resources and su pport development of renewable energy generation in the region. Tasks include:



### ◦ New transmission products under FERC Order 888. Work with interested parties and stakeholders who may be considering deve loping alternative transmission products beyond firm and non-firm products that would be more favorable to wind power and reflect the intermittent nature of wind resources;



### ◦ Interconnection standards and rules that do not discriminate against wind power in these areas. Intervention in WAPA pro ceedings for setting rules for renewable interconnection. Participation in FERC interconnection rules and standards proceedings; and



### ◦ Planning and construction of new transm ission. Participate in SSG-WI and sub regional transmission planning processes. Develop renewable scenarios to be included in transmission modeling scenarios that identify the most cost effective generation and transmission additions for the Western Interconnect. Also work with transmission-owning organizati ons to evaluate how much wi nd can be integrated into the grid (PacifiCorp IRP/transmission).28 PP4 Tracking and Reporting – Pursuant to interest expre ssed by the IOC and the WRAP, the

Forum will maintain activities associated with tracking and reporting of AP2 activities. Funding for this task will support:



### ◦ Forum meetings at least two times a year to consider needed ch anges in the tracking and reporting function and potential advice to the WRAP on how to best enable renewable energy and energy efficiency to contribute to achieving haze and other air quality goals in the West, including NOx 5 ;



### ◦ Reports: Support the completi on of the AP2 Forum’s final reports for distribution to states and tribes who are considering us ing renewable energy and energy efficiency measures as pollution prevention strategies in their regional haze SIP filings under either Section 309 or 308;



### ◦ Tracking and Monitoring: Monitor and report developments in the region that impact the AP2 recommendations – e.g., federal Renewable Portfoli o Standards, carbon constraints, etc. Provid e WRAP members up-to-date in formation on progress being made in implementing the renewable ener gy and energy efficiency recommendations, and the success of incorporating such measures into SIPs. It would also ensure that the recommendations remain relevant give n changing external circumstances; and



### ◦ Provide to the WRAP web site updated inform ation on actions that have been taken to implement the AP2 Forum recommendations.

PP5 Displaced Emissions Analysis and Ti me-Specific Marginal Emissions Rates – The Forum will host a series of meetings with experts to identify renewable energy and energy efficiency data collection and measurement protocols in western states and evaluate available emissions displacement tools that coul d be used by states to help energy offices and air quality managers develop credible, st ate-specific estimates of emissions displaced by adopting different renewabl e energy programs and energy e fficiency best practices found in the AP2 reports. The Forum’s anal ysis, to date, has focused only on regionalscale impacts. Emissions displacement tool s similar to those developed by OTAG for NOx could help individual states establish reporti ng, monitoring, evaluation, and modeling protocols that would enable them to meet potentially higher verification standards required by EPA for Section 308 SIPs and other types of SIPs

MS1 Continued Support for Nonroad Demonstration Projects – Funds for this task will be used to directly support a demonstrat ion project(s). A por tion of the funds may also be used to

hire a consultant to advise , coordinate, and evaluate nonr oad retrofit projects being funded throughout the region.

5 Washington DC regional government body has proposed that wind energy purchases be included as one option to reduce ozone emissions that contribute to smog. The Metropolitan Washington Air Quality Committee decided to include wind energy purchases from the Allegheny region as a contingency measure in the June 2, 2003 draft of its State Implementation Plan for ground-level ozone. Mobile Sources Forum29 MS2 Nonroad Retrofit Credits – The MSF will work with the EPA and other stakeholders to implement a program that uses retrofits of existing sources to generate credits for compliance with new engine emission sta ndards under the forthcoming Tier IV nonroad diesel regulations, should it in clude such a compliance option.

MS3 Review of EPA Analyses and Proposals – The MSF will review and where appropriate

recommend WRAP comments on EPA technical analyses (e. g., for small nonroad diesel engines) and regulator y proposals (e.g., advanced noti ce of proposed rulemaking for ocean-going vessels and locomotives).

IN1 Update Near Inventory and Displays – The In/Near website will be updated with new features and new maps and data for 2002 (in lieu of 1996). Funding is also needed to compensate for higher-than-expected costs for developing the 1996 in/near inventory in

2003.

IN2 In/Near Strategies for Reasonable Progress – Since some of the in/near strategies may be voluntary, episodic, seasonal, or of such size that would not be "captured" in a regionalscale air quality model, how could states/tribes take credit for such strategies in their regional haze plans? This analysis may i nvolve legal, technical, and policy issues, and

should be done in close c onsultation with the IOC.

EA1 Framework Application Test – The forum, in consultation with the IOC, will select one or more potential or historical emission c ontrol strategies as a basis for a realistic “application test” of its recently completed economic analysis framework. The test will include assessment of impacts on a cross section of tribes.

EA2 Development of Baseline Economic Data – Baseline economic and demographic data (2002 and 2018) are needed by the Forum to assess economic impacts of proposed strategies. A particular chal lenge will be the collection of tribal baseline data. This portion of the effort must be coordinated w ith the Tribal Data De velopment Work Group,

and the overall effort must be coordinated w ith the Emissions Forum since its emissions baseline should be predicated on the same ec onomic and demographic data as used in the

economic assessments.

EA3 Enhancement of Cost and Benefit Unit Values – The net benefit cal culated for an air pollution policy will depend heavily on the cost unit values (e.g., $/ton) and the benefit unit values (e.g., $/deciview). These values are often available from only a limited number of studies, partly because of the expe nse of conducting such research. Under this task, the Forum will seek partners to support an effort at improving its cost and benefit unit values, especially with respect to visibili ty benefits. Any revised unit values will be Sources In and Near Class I Areas Forum

Economic Anal y sis Forum30 incorporated into the economic analysis framework.

EA4 Screening Tool – The economic analysis framework discussed above involves a relatively comprehensive analysis. It will most likely be applied on occasion to assess “packages” of control strategies. As a co mplement, the Forum will develop a screening tool based on the framework (e.g., a light-weigh t version of the framework) to be applied more routinely and cost-effectively for asse ssing and ranking a vari ety and number of individual potential control strategies.

EA5 Coordination and Outreach – An ongoing and inherent task of the Forum will be the

coordination with other forums. As note d above, the Emissions Forum and Economic Analysis Forum should co-develop and share a common set of economic and demographic baseline data. In addition, th e Economic Analysis Forum will need air quality model outputs from the Air Quality Modeling Forum and it should use GIS data

in concert with the Areas Within and Near Class I Areas Forum. A critical area of coordination will be with tribal issues (e .g., baseline data, distributional impacts, and alternative values). The EAF may also be asked to help the IOC compile and rank available control strategies. Finally, Outreach to other WRAP forums and stakeholders (including the public) is important to ensure proper use and understanding of economic principles and analytical re sults, especially since formal , comprehensive (e.g., both costs and benefits) economic analysis is not typically a part of WRAP member activities. To improve coordination and outreach, the Forum will host a one-day workshop which will

include results from Tasks 1 and 4 above.

The Air Quality Modeling Forum has two ma jor areas of activity planned for 2004. The Regional Modeling Center will continue opera tion, to implement many of the tools and improvements developed in 2003, and using the same team of contractors. A list of tasks is provided below, with a final RMC workplan to be prepared by December 2003 for calendar year 2004. The final workplan will be amended into the existing RMC contract. The second major area of activity is to initiate modeling for Class I areas in Alaska. The Alaska modeling work in 2004 will build upon the results of the meteorological modeling project slated to begin in 2003. Also, the RMC will plan to conduct some fire em issions sensitivity analyses funded by the Fire

Emissions Joint Forum.

MF1 Regional Modeling Center (continue in 2004) – The RMC has completed §309 modeling for regional haze plans due December 2003, is implementing improvements to existing modeling tools, and is developing and testing new analysis tools. Based on work to be completed in 2003, example projects under consideration for the 2004 RMC workplan

include:

• Preparation and reporting of geographic source apportionment results based on modeling the “Interim 2002” emissions inventory;

• Further analysis of model performance in regard to the contribution of natural emissions to visibility impairment; Air Q ualit y Modelin g Forum31 • Further improvement of WRAP region chem ical speciation and temporal allocation profiles for point and area sources;

• Development of a Quality Assurance Project Plan for RMC activities;

• Testing and improvement of the windbl own dust emissions modeling methodology;

• Sensitivity modeling runs for aircraft cruising emissions from aircraft;

• Further improvement of source apportionm ent techniques in the emissions and air quality models;

• Further improvement of QA/QC functions in the emissions and air quality modeling computer codes; and

• Integration of global-scal e estimates of model doma in boundary conditions into WRAP modeling analyses.

MF2 Alaska Modeling – Based on the results of a 2003 pr oject evaluating th e performance of modeled estimates of meteorological parameters , for a region thought to affect 3 of the 4 Alaskan Class I areas, air quality modeling to estimate the impact of various source categories will be completed in 2004.

MF3 Fire Emissions Sensitivity Modeling (funded by FEJF) – This project is described, and the associated funding needs are identifie d, in the Fire Emissions Joint Forum 2004 budget request. No funds are requested by the Air Quality Modeling Forum for this project.

The Technical Oversight Committee (TOC) has co mpleted the preparatio n of the §309 Technical Support Document in 2003, and plans to begin providing technical analyses in 2004, to support the activities described WRAP Strategic Plan. To begin providing information for the multi-year process outlined in the Strategic Plan, the TOC requests funding in 2004 to complete an Attribution of Haze analysis for all Class I areas in the WRAP re gion. This project will be the first step in a process that will be complemented by 2005 analysis activities of both the Initiatives Oversight Committee (IOC) and the TOC. Then , during late 2005 and the first half of 2006, significant collaborative analys es and discussions among the TO C, IOC, the Air Managers Committee, all Forums, and the WRAP Board are anti cipated to occur, to result in consensus on needed emissions reductions by source sector, to achieve reasonable progress toward the national visibility goal for the pla nning period to end in 2018.

TOC1 Attribution of Haze - This project envisions a team of cross-disciplinary group of experts,

from both within and exterior to the WRAP organization, in tegrating and synthesizing three major types of information – mon itoring, modeling, emissions inventory – to describe the extent of the geographic and source type contributions to visibility impairment at each Class I area in the WRAP region. The project, directed by a TOClead workgroup, would accomplish the following:

Identify the: Tech-Wide Pro j ects ( TOC )32  geographic source areas of emissions that co ntribute to impairment at each mandatory federal Class I area (also including exis ting and potential trib al Class I areas);

 mass and species distributions of emissi ons by source categor ies within each contributing geographic source area; and

 amount of natural and manmade emi ssions affecting each Class I area.

Integrate and synthesize the above data into clear explan ations of the estimated causes of impairment for each Class I area, including:

 Document the assumptions, methods, and uncerta inties used in the integrated analyses of modeling, monitoring, and emissions data; and

 Provide succinct, clear summaries suitable for policy makers, of the estimated areas and sources of impairment for each Class I area, including the extent of uncertainty

about the estimates.

The TOC requests funding for contractor support to exec ute this project. It is anticipated that the

contractor will need to:

 Attend initial Workgroup meetings and di still members’ opinions and results of discussions into a schedule and methodology to accomplish the tasks outlined above;

 Possibly subcontract with independe nt experts for analytical work;

 Gather and format the resulting inform ation and data from WRAP Forums, independent experts, and ot her related air quality anal yses, all for review by the Workgroup;

 Draft a “Attribution of Haze Report” for review and comment by the Workgroup; and

 Complete and publish a “Final Attribution of Haze Report”.

The need for this type of analytical approach is well-articulated in the NARSTO PM Science Assessment for Policy Makers (Primary Recommendation #6):

"Develop a more systematic approach for integr ating knowledge gained from measurements, receptor models, and chemical transport models to make optimal PM management decisions.

Rationale. The policy maker is faced with an incr easingly complex array of information to use in managing PM. Informed judgment is required to know how best to use this information, which may arise from methods with which the policy maker has no direct personal experience and which may even appear to be contradictory. Systematic approaches for integrating diverse information from measurement networks, recepto r models, and chemical transport models would help to ensure that optimal use is made of existing knowledge when establishing PM management strategies. These appr oaches must account for inhere nt uncertainties in each type of information."33 The ongoing objective of the Emissions Forum is to provide the WRAP with all emissions data and support information necessary to analyze the need for emissions reductions, develop implementation plans, and enable adoption of regu latory programs for th e applicable provisions of the federal Regional Haze Rule. This includes compiling emission inventories for mobile, point, and area source emission sectors, for the WRAP region and adjacent areas of Canada and

Mexico. The Emissions Forum will also collect emission inventory data from other WRAP forums and combine them, in order to provide a co mplete inventory of all emissions of visibilityimpairing pollutants within the WRAP region. Th e Emissions Forum will work closely with the Tribal Data Development Workgr oup to assure compatibility of information coming from tribal data sources, and to minimize duplication of effort between these similar efforts.

A major focus of the 2004 work plan is to carry out emission inventory proj ects consistent with the WRAP Strategic Plan, starti ng with the development of a website-hosted, Emissions Data Management System (EDMS). Also, a Phase I Interim Emission Inventory for 2002 will be prepared to facilitate geogra phic source apportionment and attribution of haze analyses. The Emissions Forum will also compile or estimate emission inventory information annually, to facilitate tracking of various emission-related regulatory commitments under the Regional Haze Rule. Projects outlined below will describe the efforts needed to carry out these activities.

EF1 Emission Data Management System (Development/User Access/Training/QA/Home)

– To be constructed and on-line by late 2004, the EDMS will undergo thorough testing prior to use. The EDMS is to be housed in a location to be determined, and operated by a Data Base Administrator (DBA) with the assi stance of an Analyst. The DBA and Analyst will provide specified quality assurance checks of input and output, coordinate with users to ensure data accuracy and consistency, assi st with training and protocol development, prepare scheduled and unscheduled reports and data queries, ensure security, and provide estimates of emissions for non-reporting year s. The EDMS hardware and server will be internet-capable to allow inputs and outputs by users. User training will be provided for states, local agencies, and tribes. A user manua l and protocol will be developed to enable consistency of input, quality assurance, and missing data procedures. The development plan for the EDMS is based upon a needs asse ssment project completed in July 2003.

Once the database has been brought completely on-line in late 2004, it will be necessary to have a long-term maintenan ce agreement with an entity to ensure quality control,

assistance to states and tribes and to answer database queries. States and tribes, through a web-based database, are expect ed to populate the database wi th inventory updates. The

data will be used:

• To allow §309 states to track SO 2 emissions against milestones;

• To allow emissions monitoring in the Clean-Air Corridor;

• To allow §308 and §309 states to m easure reasonable progress; and

• To provide input for visibility modeling. Emissions Forum34 EF2 Second Phase of Representative Community Emissions Inventories (Phase 1 RFP under development) – Phase I of this project will collec t as much local activ ity and source type data and information as possible, to develop an emission inventory for rural Alaska native villages, to be based on the emissions sources within “representative” communities. The Alaska emission inventory would then be expa nded by using data from the representative communities as surrogates for other simila r communities. Specifically, the activity information collected within these representati ve areas could then be used as surrogates

for other similar-sized communities as a ppropriate, or to improve EPA top-down estimates for many source categories. In 2004, once Phase 1 is well underway, Phase 2 of this project will expand to include other rural areas, including tribal lands, within the contiguous WRAP region. For tribal emissions , this project will be coordinated with implementation of the TEISS tool. For small communities in the more rural portions of the contiguous WRAP region, a dditional communities that mi ght benefit include those on tribal lands, as well as “In-and-Near ” communities adjoining Class I areas.

EF3 Update Non-Road Emissions Projec tions to Reflect Proposed Regulations - The existing emissions inventory for non-road mobile sour ces does not include the recently proposed

non-road emissions standards. These new st andards will reduce emissions projections already conducted for the years 2008, 2013 and 2018 and, to some extent, 2003. The

2003 emission estimate will be used as a surr ogate for the 2002 base year emissions.

EF4 EI Improvements for Spa tial and Temporal Allocations - SCC profile investigations and updates being performed by the RMC in 2003 may reveal the need to amend profiles for large area source categories and for specific larg e point sources if it is shown that default profiles contained in SMOKE are inappropria te for these WRAP region sources. For categories identified by RMC, new profiles will be compiled, based on existing source

information available for Western sources. Th is is necessary to properly model visibility impacts, perform source apportionment analyses , and develop effective control strategies. Work on this project in 2003 involves the asse ssment of the accuracy and appropriateness of SCC profiles currently used in SMOKE. Sources with incorrect SCCs will be corrected. Inappropriate profile s will be identified for replacement in the 2004 phase of this project.

EF5 Canadian & Mexican Emissions (QA and prepare EI for modeling) - Emissions inventories from Canada (1999) and Mexico (1 999) will be available soon. These data will require quality assurance review and prep aration for the emissions processor in order to be incorporated as surrogate 2002 emissions inventories. In addition, if possible, growth factors will be applied to grow th e emissions to 2002 levels. Other RPOs may

have an interest in th is work, and cost-shari ng opportunities may develop.

EF6 2002 Base Year Emission Inventory (begin gap fill and QA work) - In order to follow EPA guidance and meet §308 requirements, a complete inventory of 2002 emissions for point, area and mobile sources must be prep ared. It will include updates of dust and ammonia emissions as inputs to the modeling pr ocess. States are expected to compile and submit these data to the EDMS and NEI beginning in mid-2004, although a final inventory may not be available until mid- 2005. The mobile source projections for 200335 will be used to fulfill the n eeds of a 2002 emissions inventory. Point and area source inputs from states and tribes will require a full evaluation for accuracy, completeness and consistency. Data gaps are expected and must be addressed. These tasks, preparation of model-ready files, and an em ission inventory from major SO 2 sources in §309 states must be performed in accordance with Annex requirements, all to be completed in 2004.

EF7 Alaska Aviation Inventory - With terrain conditions that are often inhospitable to motor vehicle travel, a scarcity of roads, and large distances between communities, travel by aircraft is commonplace in Alaska. There ar e about 600 public airports and more than 3,000 airstrips throughout the state. Because of this, emissions from aircraft can have a

substantial effect on the total emissions i nventory of Alaska. This project would inventory a subset of the air ports and airstrips within the state. The focus would be on facilities most likely to impact Class I areas.

EF8 Joint Projects and C oordination with Other RPOs - The Emissions Forum will participate in two joint inter-R PO projects, both of which are expected to begin work in 2003 and be completed in 2004. The first project is the development of a new ammonia model capable of better temporal and spatial reso lution. The existing model uses default

nationwide emissions factors. The new mode l will recognize geographic differences in ammonia emissions, principally from lives tock and poultry opera tions. There is no budget requested for this joint project in WRAP Workplan, as EPA OAQPS is providing funding to the Midwest RPO as the lead RPO. The work will be coordinated with the ammonia emissions inventory improvement project being conducted by WRAP Regional Modeling Center in 2003.

The second joint project is the development of a new Open Emissions Model (OPEM). OPEM is a new emissions processor, to have distinct advantages over the two existing models, EMS and SMOKE. The best features of EMS and SMOKE will be incorporated into OPEM to produce a more open, usable, and readily accessible emission processor. OPEM will be Linux-based with a focus on qua lity assurance, which will reduce the errors and reruns that have plagued th e RMC modeling work. There is no budget requested for this joint project in WRAP Workplan, as EPA OAQPS is providing funding to the Midwest RPO as the lead RPO. The Midwest RPO project manager has included state emissions modeling experts from the WR AP region to assure a coordinated product usable by the RMC.

EF9 Cruising Height Aviation Inventory - Typically, airport and aircraft emissions are estimated below the default mixing height of 3,000 feet in the EDMS model. While this may be appropriate for a nonattainment area inventory, regional haze is focused on transport of pollutants over long ranges at altitude. The exclusion of emissions at cruising altitude may considerab ly underestimate the aircraft emission inventories. Little has been done on analyzing cruising emissi ons from aircraft. The 1997 California Air

Resources Board’s Southern California Ozone Study (SCOS97) looked at cruising

emissions from aircraft and found that emissions for SO

x and NO

x were higher than the emissions below the mixing height. The Emissions Forum has requested that the Modeling Forum consider undertaking a sensitivity analysis to help determine the36 potential impact that cruising emissions from aircraft could have on visibility in the WRAP region. If these emissions appear to be worth characterizing in greater detail a project would be developed to estimate th e emissions with work expected to be performed in 2005. No budget resources are requested for 2004.

The purpose of the Work Group is support the development, colle ction, and appropriate use of technical air pollution data for tribes in th e WRAP region. The Work Group coordinates the preparation and review of t echnical tools for use by tribes , and acts as a clearinghouse for technical information used by WRAP Forums a nd Committees. Under the Regional Haze Rule, and in accordance with the Tribal Authority Rule , tribes are not required to implement any particular provisions of the Rule, but have the op tion to submit visibility implementation plans or “reasonably severable” elements thereof. Trib es are encouraged to participate in Regional Planning Organizations, EPA is committed to suppor ting tribal involvement, and tribes have been actively engaged in specific TDDWG and ge neral WRAP activities. While tribes within the 9-state GCVTC transport region have the option of submitting §308 or §309 implementation plans, independent of the state in which the tribe is located, the focus of WRAP activities is now migrating toward development of §308 plans.

For many issues, more information regarding air qua lity and emissions on tribal lands is needed in order for tribes to participate in a meani ngful way in the WRAP decisions, and to better determine what, if any, regulatory actions are ne eded by individual tribes. Thus the mission of

the TDDWG is to assist the tribes and the WRAP in acquiring the information, and building the tribal capacity, which will be needed for tribes to make informed decisions regarding whether and how to implement TIPs. Although SIP dead lines do not apply, EPA encourages tribes to coordinate any TIP submittals with states to the extent practicable. Given the less-advanced state of tribal air program development, this means ther e is a need to develop tribal data capacity as quickly as possible in order to achieve consistency with the 2004 to 2008 time frame.

The 2004 TDDWG workplan proposes to continue developing tec hnical tools and information for WRAP region tribes, but expand the support to allow interested trib es to prepare TIPs addressing the impacts of air pollution on their lands. The workplan has 4 major elements:

TW1 Emissions Data Development Support - In 2003, the development of the Tribal Emissions Inventory Software Solution (TEISS) was completed. For 2004, the TDDWG is proposing to continue the contract with ITEP for the implementation and training on TEISS, and to test the software before making it available to the Tribes to compile their respective emissions inventory data. Also, tr aining sessions will be offered for the Tribal Professional by ITEP. Project elements of the 2004 ITEP effort include:

• TEISS Software Support (software distribut ion to interested tribes, promotion, technical assistance by phone and E-Mail);

• Ongoing contact with the tribal users (to monitor how well TEISS is meeting tribal needs, and software upgrades as needed); Tribal Data Develo p ment Work Grou p37 • Alaska tribal support (ITEP will work the state of Alaska, and interested Alaskan Native Corporations to distribute, and pr ovide voice and electronic support, for the use of TEISS in Alaska);

• TEISS Software User Workshops (Two work shops, designed for both new [3.5 days] and experienced [2.5 days] TEISS users, wi ll be developed and conducted at the Tribal Air Monitoring Support (TAMS) Cente r’s training facility in Las Vegas, NV or at an EPA facility that can provide a computer lab free of cost for the training); and

• Emission Inventory Technical Support and Outreach (ITEP will maintain a comprehensive website to provide informa tion on the technical aspects of EI work that are unique to tribes).

TW2 Monitoring Data Analysis - The Ambient Monitoring & Reporting Forum’s (AMRF) existing Causes of Haze Analysis project is analyzing data from an extensive list of regional haze monitoring sites. The AMRF c ontractor will be anal yzing data from all speciated monitoring sites which are helpful to explaining the answer s to the Causes of Haze questions detailed in the existing multi-year contract. The answers will be prepared for each WRAP region mandatory Federal Cla ss I area (not all of which have on-site monitoring data). Answers about Causes of Haze at each WRAP region mandatory

federal Class I area will have the benefit of:

1) "In or next to the Cl ass I area" IMPROVE data;

2) Data from relatively nearby, representa tive IMPROVE monitors (including tribal IMPROVE sites) which are not "In or next to th e Class I area"; and/or

3) Data from nearby non-IMPROVE monitori ng locations, where those speciated data are helpful in explaining Causes of Haze.

A separate proposal and contract between the existing AMRF contractor and the TDDWG will be prepared to provide "answers for the Causes of Haze questions on tribal

lands". The AMRF contractor will be asked to provide "answers to the Causes of Haze questions" at the other reservations without monitoring data, based on expert judgment. This will not be possible for all reservations , as the IMPROVE network is aimed at the Regional Haze Rule reasonable progress tracking at mandatory Federal Class I areas. The TDDWG requests funding to issue an RFP with the following tasks:

1) Answer Causes of Haze questions at the WRAP region tribal IMPROVE monitoring sites and tribal Class I areas;

2) Identify reservations where source categor y impacts can be quan tified using the data analyzed for Causes of Haze from nearby m onitoring sites, and answer the Causes of Haze questions for those reservations, based on expert judgment; and

3) Analyze the need and identify representati ve locations for additional regional haze monitoring sites on reservati ons which the IMPROVE and other, related monitoring networks do not cover adequately.38 TW3 Tribal Regional Haze TSD Guidance/Template Development – In order for tribes to develop TIPs for regional haze, WRAP technical work will have to provide sufficient data resolution in appropriate formats for indi vidual tribes. To da te, state- and countylevel emissions data have been used to anal yze visibility improvements associated with various control strategies. When submitting a TIP, the tribe would need to provide a Technical Support Document (T SD) with the TIP, or have future WRAP regional TSD work products provide sufficient data resolu tion in the proper formats. The purpose of this project is to describe the TSD data a nd proper formats needed by an individual tribe to support TIP preparation, particularly for those tribes that have never previously prepared a TIP.

TW4 Program Enhancement - This is a set-aside for projects that cannot be anticipated at this time. Following are some potential projec ts that could be initiated in 2004:

1) A collaborative project with the Economic Analysis Forum to form a valid and reliable database in the Indian Country;

2) Contractor support for tribal data needed by the Emissions Forum;

3) Collaboration with the Technical Oversight Committee (TOC) as it relates to their 2004 “Source Apportionment” project in Indian Country; and

4) The Tribal Data Development Work Group w ill also be fully supportive of efforts to address the “Tribal Traditional Practices and Regional Haze”. These practices have been exempted by the WRAP so that the Indi an Nations could exer cise their religious and ceremonial practices without bei ng regulated by the Regional Haze Rule.

The Dust Emissions Joint Forum is a new foru m whose mission is to (1) improve the WRAP dust emissions inventory, including the magnitude and spatial, temporal, and particle size distribution of dust emissions; (2 ) coordinate interpre tation of modeling and monitoring results with respect to dust, including the apportionment of haze to natural and anthropogenic sources of dust; and (3) identify the most a ppropriate strategies for reduci ng anthropogenic sources of dust affecting Class I areas. At its discretion, the Forum may also deve lop a research agenda to guide and coordinate efforts within the air quality community and may evaluate the usefulness of existing monitoring and modeling techniques for qua ntifying the contribution of dust to haze in

Class I areas.

DF1 Establish Dust Definitions a nd Identify Dust Emission Tools – The Forum will develop a consensus definition(s) of dust. Issues to be resolved will likely include the definition of natural versus man-made dust and whether or how to define dust according to source types, particle attributes, or operational at tributes, such as those used in routine monitoring and modeling analyses. Under th is task, the Forum will also identify Dust Emissions Joint Forum39 alternative dust emissions tools that could be used by the WRAP . Both parts of this task will be supported by a literature review done under contract.

The following three tasks are aimed at improving the WRAP’s understanding of emissions from the three largest anthropogenic source categories, their control options, an d the effectiveness of such controls. For each category, state, tribal, an d local inventories (especially locally-generated inventories, inventories for PM nonattainment areas, and ye ar 2002 inventorie s) will be summarized and compared. The same will be done for control options and effectiveness. The objective is to identify areas or sectors within the regional inventory that could be substantially improved and to develop a regional menu of co ntrol options and perf ormance characteristics based on actual experiences in the West. Most of the data collection and synthesis would be

done under contract. The forum may also carry out additional work to improve the WRAP’s wind-blown dust inventory, especially as it ma y relate to the sour ce categories below.

DF2 Agricultural Dust – (See above description.)

DF3 Construction Dust – (See above description.)

DF4 Road Dust – (See above description.)

In 2003, the Ambient Monitoring & Reporting Foru m continued to provide access to regional haze monitoring data through operation of the in ter-RPO VIEWS website, and has initiated the comprehensive, multi-year Causes of Haze Analys is project. These projects are ongoing. Also, the Forum has received separate funding from EPA to analyze Natural Haze Levels on behalf of all 5 RPOs, to better understand the accuracy of default EPA Natural Conditions Estimates. Work planned on these three proj ects in 2004 is described next:

AMR1 VIEWS Data Base 2004 Operations (CENRAP portion in current grant) – The Visibility Information Exchange Web S ite (VIEWS) began operation in 2002, building from the earlier WRAP Ambient Monitoring Da tabase. VIEWS receives joint, annual funding by all 5 RPOs, each contributi ng $50,000, through a WGA contract. A Steering Committee composed of RPO repr esentatives, EPA, and Federal Land Managers oversees the operation of the data base and website, and tracks deliverables from the annual VIEWS workplan. IMPROVE and other visibility-related data are displayed and available for an alysis and/or downloading at: http://vista.cira.colostate.edu/views/

.

AMR2 Causes of Haze Analysis - The Causes of Haze Analysis project began in early 2003, and is designed to provide as much as information as can be estimated using monitoring data concerning the aerosol species and s ource categories that contribute to haze. These reports will also document the use of spatial and meteorological analysis methods to estimate the impacts from with in and outside the WRAP region. These assessments of monitoring data will be used in refining EPA default estimates of natural contributions to haze (i.e., natural vi sibility conditions for the §308 glide paths), Ambient Monitorin g and Re p ortin g Forum40 and will be documented in this report. Deliverables from this analysis project will directly support the TOC’s A ttribution of Haze project.

AMR3 Natural Haze Levels Analysis ( separate $75K from OAQP S, national project, WRAP has lead RPO responsibility ) – This project is designed to analyze default natural conditions values listed in EPA guidance, and identify refinements to these estimates of

natural conditions at mandato ry federal Class I areas.

This is a new committee being formed to coordinate the post-submittal implementation of Section 309 SIPs and TIPs, if applicable. This includes tracking emissions for the backstop SO2 trading program and addressing i ssues related to that program (e.g., expansion to other states under Section 308). After the SIPs are subm itted (by December 31, 2003), the EPA expects to conduct a six-month completeness review, follo wed by an 18-month process to review the substance of the SIPs, propose approval, take pu blic comment, and take final action. This process may require interactions between the EP A and the 309 states, potential revisions/updates to certain SIP elements, and coordination among th e 309 states themselves. All these activities would be conducted under the purview of the 309 Coordinating Committee. Committee members will be comprised primarily of states submitting Section 309 SIPs and tribes interested in submitting Section 309 TIPs.

309a Annex Implementation – The Committee will be responsible for (a) the annual regional emissions report (for comparison to the mile stones) and periodic audits of emissions tracking, (b) addressing any remaining or ne w issues related to the backstop trading program (e.g., tracking and supporting state rule adoptions, consideration of allowance price disclosure, etc.), and (c) addressing issues related to other states or tribes interested in opting into the program.

309b 309 Follow-Up – As the EPA reviews and takes action on submitted SIPs, issues are likely to arise that will require some ongoing effort by the WRAP to help resolve in a

coordinated fashion.

The year 2003 was the second year of activity for the Air Manager’s Committee (AMC). The AMC has served a point of coordination among the st ate and tribal air managers, to assure needs of air agency managers are met as the various policy and technical forums perform their work. Much of the focus of AMC over the last two years has been to ensure, as much as possible, that

essential elements of 309 SIPs and TIPs are id entified and addressed, to create a framework for increased participation by tribes, and to identify and address several state /tribal issues. This work has been implemented through support of state and tribal cau cus staff, via WGA, WESTAR, and NTEC. The AMC identified a numb er of unresolved ques tions regarding EPA interpretation of the Regional H aze rule, and worked with EPA to gain some level of consistency among the EPA regions as they begin their review of submittals at the end of the year. The Air Mana g ers Committee 309 Coordinatin g Committee41 AMC sponsored the preparation of enhanced templates for 309 SIPs and TIPs (STIP-II), and provided shared oversight with MTF on other projects related to BART.

2004 will mark the beginning of the 308 planning pr ocess in earnest. The AMC will continue to support the state and tribal caucus staff, to sponsor or oversee projects related to air managers’ interests and needs, and to supplement the work of the WRAP forums program enhancements as

needed.

AMC1 Caucus Staff Support – Each caucus has staff support: the Tribal Caucus through NTEC (with additional support dire ctly from WRAP) and the State Caucus through a WGA

contract with WESTAR. The caucus sta ff positions are generally responsible for disseminating information between WRAP comm ittees and forums and their respective caucuses, and to facilitate communication be tween the two caucuses and with the AMC as a whole. They are also responsible for issue definition, outreach, and coordination.

AMC2 Alaska Tribal Outreach Coordinator Position – An individual will be hired to conduct a variety of outreach activities for the 229 tribes located in Alas ka. A number of activities, in addition to those typically associated w ith employee recruitment, will be conducted as part of this hiring process to assure long-term success of the position. First, an assessment tool (e.g., questionnaire) will be se nt to Alaskan Natives and to determine what role the Coordinator should be playing. For example, there are jurisdictional issues

that are of concern to Alaskan Natives due to the Alaskan Native Settlement Claims Act (1971) and the Alaska National Interest Lands Conservation Act (1980). Because of such issues, not all Alaskan Natives are sure of what areas that they have jurisdiction over. Second, collaboration will be s ought with Alaskan Native organi zations to build a pool of individuals who can advise and participate in the hiring and management process of the Coordinator. Third, Native Village visits will be important to give a firsthand look at the issues facing Alaskan Natives.

AMC3 Health-Based Effects of Regional Haze – Within the WRAP, little attention has been given to the health effects of air pollutants associated with haze, yet information on the health consequences of haze pollution and the he alth benefits of haze controls could be gleaned from on-going WRAP activities, such as those related to air quality modeling, ambient monitoring, and socioeconomic analys is. Distilling health -related information from WRAP activities will provide added va lue to WRAP members and may generate

further interest from individua ls and organizations that ma y not otherwise be compelled to participate, such as some public interest groups, tribes, and members of the general public.

The AMC will attempt to boost the health-relevance of the WRAP’s haze-related activities by first recruiting an expert in the ar ea of air quality and h ealth to draft a report which (a) summarizes what the available litera ture implies about the health significance of various PM constituents and PM precursor s which may pose a health risk in the West (b) identifies WRAP data that can be used to assess health effects, (c) identifies data gaps in the WRAP region (particula rly on tribal lands) which c ould provide significantly more health-related information, and (d) recommends ways in which the WRAP can use its42 current and forthcoming data (including filled data gaps) to estimate the health effects of

haze and the health benefits of haze contro ls. Next, WRAP staff will conduct a workshop to disseminate the information in the report – a group of speakers will be on hand to offer their own interpretation of the material in ad dition to providing some additional insights – and discuss next steps for the WRAP w ith respect to regional haze and health.

AMC4 Traditional Tribal Practices and Regional Haze – Tribal traditi onal practices (e.g., ceremonial, cultural, religious) are regularly affected by regional haze or the policies

intended to curb such haze. On the one ha nd, tribes are concerned with protecting their traditional practices from the air pollutants th at obscure visibility. For instance, some tribal members have noted the importance of being able to see near by icons for religious purposes. On the other hand, tribes engage in traditional practices that involve such activities as burning. In some cases, the WRAP has acknowledged these practices and exempted them from policies adopted by the organization (see, for example, “Enhanced Smoke Management Plan” policy document pr oduced by the Fire Emissions Joint Forum and adopted by the WRAP Board).

No comprehensive documents currently exist that address the traditional practices of Indian tribes throughout the WR AP region and how these practic es interact with regional haze and the policies adopted to address such haze. Documents that address these issues

will serve to meet the needs and concerns of the tribes within the WRAP region and also help the organization develop eff ective policies on regional haze.

The first document will describe why tribes n eed to be concerned with regional haze and

how their involvement in the WRAP serves to reduce the haze that in terferes with their traditional practices. This document, among other things, will highlight some of the traditional tribal practices that are a ffected by visibility in the west.

The second document will discern what some of the traditional tribal practices are that utilize fire and other activities which may contribute to regional haze. This document will help WRAP participants to understa nd these traditional practices and their importance to tribes. In understanding the importance of such practices, WRAP participants will be better equipped to draft policies that meet the need and concerns of all involved with the process of addressing regional haze.

Both documents will serve as educational t ools for WRAP participants (and members of other regional planning organi zations) who regularly work wi th and/or live near tribal lands. These documents will be a compila tion of published and unpublished information about tribal practices and cu ltural values. Inclusion of unpublished information in the

documents will necessitate tribal review and approval. In addition to the two documents,

there could be additional versions , directed at specific audience s, such as other tribes and non-tribal audiences. It is anticipated that the documents will be professionally developed into a bound document fo r distribution to WR AP participants and others in the WRAP region.43 AMC5 308 Template Development – To date WRAP efforts have focused primarily on section 309 of the Regional Haze Rule, to accommodate the SIP submittal deadline for transport states. Tribes are not subject to specific deadlines to submit TIPs. Much of the WRAP’s 309 work will also be applicable for states and tribes meeting the 308 requirements, but considerable foundation work remains, and mu st be accomplished prior to the next SIP submittal date of 2007 (or 2005, if Congress doe s not reauthorize TEA-21, including the

2007 date. In view of the time constraints stat es and tribes within the region should begin

collaborative discussions soon to determine wh at is needed to suppor t WRAP activities in the near term, and what they will need later on to implement control strategies

This project envisions an ad hoc workgroup, made up of key pl anners from states, tribes and EPA and with AMC oversight. The workgroup would develop a set of understandings about what the states and tribes must do near-term to support the information and expertise n eeds of the WRAP, and later to successfully develop and implement their individual 308 SIPs and TI Ps. Differences between state and tribe requirements would be incorporated into a final work product, which would include development of one or more outlines, or templates upon which states and tribes could

construct their individual SI Ps and TIPs. The workplans and reports from the other forums, committees and workgr oups would feed into this process. This project is supportive of the WRAP strategic plan.

Prospective workgroup members would be identif ied and a final workplan for the project would be ready at the beginning of the cal endar year. AMC would ensure adequate representation on the workgroup, including stat e, tribal and EPA staff, and other appropriate stakeholders. The workplan a nd budget for 2004 would have been developed by an earlier workgroup.

AMC6 TIP/FIP Framework – Underlying many issues for tribes in the WRAP has been an uncertainty about EPA policy for implementatio n of the haze rule on tribal lands. Although the Tribal Authority Rule provides an overall framework, many details remain to be filled in. These may include policies for determining when federal implementation is necessary or appropriate; decisions on whet her to use a regional FIP or tribe specific FIPs for particular provisions; and guidan ce on which elements of 309 or 308 TIPs may be “reasonably severable.” During the STIP-II process, many such questions were brought into sharper focus. Some were answered while others remain open.

Under the oversight of the AMC, a tribal workgroup will work with EPA to develop a policy to determine when federal implemen tation is appropriate, and guidance on reasonable severability. This effort will be coordinated with any national efforts within EPA to develop implementation policy in a broade r context. (Note that publicly available drafts of EPA’s 2003 GPRA strategic plan ha ve included a target of developing similar policies nationwide by 2008). No funding is cu rrently requested for this task. If

contractual needs are identified, a funding request may be made to the AMC or to the next WRAP work plan, depending upon the timing.44 CC1 Web Site Maintenance - primary communications tool for the WRAP. Consider additional funding for transition to new Oper ations/Maintenance Contract for improved performance.

CC2 Continue and Expand Publications – This work is intended for both internal and external audiences and includes the following:

• Collect inputs, draft and publish The WRAP Sheet on the Web site;

• Print, mail, and/or fax hard copies of Th e WRAP Sheet to selected recipients; and

• Produce brochures, fact sheets, and other ha ndout materials for c onferences, exhibits, and public meetings.

CC3 Update Presentation Materi als to Tell the WRAP Story :

• Tailor the WRAP 301A, 401 and Tribal vers ion presentations to meet needs of various forums/committees; and

• Convert presentations to va rious video formats (CD, VHS, 35mm, etc.) and make copies for multiple venues.

CC4 Expand Speakers' Bureau – Assure exposure of WRAP stor y to state and tribal general audiences throughout the WRAP region. Tailor to individual audien ces as appropriate:

• Develop and maintain data ba se of prospective audiences;

• Work with state and tribal air director s/forum and committee chairs and follow up on contacts to schedule presentations; and

• Coordinate presentation and support materials for all scheduled events.

CC5 Support WRAP Forums and Committees in Conducting Public Meetings – Inform and obtain public input on WRAP products and related SIP/TIP development efforts:

• Assist with arrangements for meeting venues; and

• Coordinate presentation and support materials for all scheduled events.

CC6 Other Outreach Efforts to Reach Wider Audience - Investigate part nering with other agencies/programs with shared goals – e.g., Pollution Prevention Roundtable for AP2 presentation:

• Identify potential partnerships and follow up to develop cooperative ventures; and

• Participate in joint ventures with mutual benefit. Communications Committee