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 (Initiatives 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 Development 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 .......................................................................... 44 
1 

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 Clean Air Act Amendments of 1990. Since 1997, 

most of the WRAP’s focus has been on implementing the Commission’s recommendations. A 

major milestone in implementing these recommendations 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. Most 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 subject to Section 308 of the regional haze rule. 

The completion of Section 309 SIPs (expected for five WRAP states) represents a significant 

accomplishment of the WRAP and will benefit all of its members in future haze control efforts. 

Nonetheless, legally, they only address the contribution of emissions from these states to the 

visibility impairment at 16 Class I areas on the Colorado Plateau. The contribution of these 

emissions to other Class I areas (there are over 100 other Class I areas in the WRAP region, 

including tribal ones), and the contribution of emissions from other WRAP states to all Class I 

areas remains to be addressed. This is the principal 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 period1

, which in turn has provided a strong basis for this 2004 work plan. 

Among other things, the strategic plan (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 identifies 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 joint planning, assessment of data and tool needs, 

and cooperation with other RPOs. The WRAP strategic 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 technical discussion groups facilitated by the EPA, 

through regular participation in director-level calls and meetings, and as necessary on other 

issues (e.g., emission inventories and control strategies in border 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 development process. Participation in inter-RPO discussion 

groups provides further opportunity to identify and refine these needs. 

 

1

 See http://www.wrapair.org
2 

On a more general level, the WRAP’s planning process must accommodate a unique landscape 

of environmental, social, economic, and political issues. The WRAP region includes 116 (or 

75 percent) of the nation’s 156 mandatory 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 land 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 particulate matter nonattainment issues, which 

simplifies air quality planning to some extent, but many WRAP members are faced with rapid 

population growth and other challenges to preventing deterioration of air quality. Moreover, the 

WRAP must be sensitive to other regionally-important environmental issues, such as fire and 

drought. This presents a unique and challenging environment for long-term planning which is 

best addressed through a single, well-funded and well-organized institution at the appropriate 

political level. The WRAP, with the appropriate EPA financial support, provides such an 

institution, especially given its co-management structure shared between the Western Governors’ 

Association and the National Tribal 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 Western 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 planning process must be prepared to deal with relevant events 

beyond its control, such as multi-pollutant legislation 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 foster a constructive dialogue 

among its members. 

 

Table 1 provides a budget for all new and ongoing WRAP activities. A project coding system 

has been implemented for all new activities to facilitate 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 highlights projects where a forum other than the one 

sponsoring the project should be involved or periodically 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, and 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/enlibra
3 

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-Eligible Sources 75,633 24,367 

SS2 Preliminary Determination of Sources 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/Categorization 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 System 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 10,000 
4 

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 Attribution of Haze 50,000 
5 

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 – for 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 (addition 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) 75,000 
6 

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 Coordinator 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 = $8,282,200 
7 

Table 2. Matrix of Projects and Their Relation to Non-Sponsoring Forums.
8 
9 

Figure 1. Strategic Plan Timeline. 
10 
11 

Figure 2. WRAP Region Members, and Federal Areas Covered by the Regional Haze Rule. 
12 

Figure 3. Map of Tribal Lands and Tribal 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 established the GCVTC, which in June of 1996 

completed its original mission to recommend strategies for improving visibility in the Grand 

Canyon and other Class I areas on the Colorado Plateau. Recognizing the need 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 operates in conjunction with regional organizations such as WESTAR, 

the Western Governors' Association, and the National Tribal Environmental Council. The work 

products of the WRAP are used by states and tribes in the preparation 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 planning 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 regional 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 elects to submit the plan by December 31, 2003. 

Such plans would satisfy the state's obligation for planning for the 16 Class I areas in the 

jurisdiction of the GCVTC. The states would then be allowed to defer submittal of 

implementation plans for other Class I areas until December 2008. As described further below, 

tribes have the option of submitting implementation 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 the Tribal Authority Rule (TAR) (40 CFR 49.1– 

49.11) and the regional haze rule, tribal implementation 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 preamble 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 that any tribe in the 

GCVTC transport region may apply for implementation of §308 or §309 in whole or in part. 

The policy and technical work of the WRAP to assist 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 needs may be different. As these differences are 

identified, project tasks and work plans will be updated to reflect the improved understanding of 

tribal needs. 
15 

To ensure that tribal needs are addressed, the active participation of tribal 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 participation 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 WRAP, 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 Working 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 structure 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 representatives on all standing committees, forums, and work groups. 

Public workshops for WRAP work products and travel support from the WRAP ensure that the 

broader tribal community has an opportunity 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. The WRAP established oversight committees and 

forums charged with developing work plans to implement the GCVTC recommendations. 

A. Membership 

The WRAP membership currently includes the Governor 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 Agency 
16 

B. Charter and Bylaws 

The WRAP Charter and Bylaws set forth the basic operating goals, principles, 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 forums, committees, and work groups. These 

suborganizations and their relationships are shown in the organization chart in the Executive 

Summary. All the suborganizations include participation from the WRAP membership (states, 

tribes, and federal agencies) and interested stakeholders (industry, environmental groups, local 

governments, academia, etc.). Guidelines for 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 coordination and development of air quality 

strategies necessary to promote the implementation of federal visibility rules. The TOC provides 

general oversight of the technical activities of the WRAP. IOC and TOC members are appointed 

by the WRAP Board, which strives to manage a balance among tribes, states, federal agencies, 

the environmental community, and the industrial community. In turn, the IOC and TOC 

establish forums and work groups and appoint their co-chairs 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 Sources 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 Forum, and Stationary Sources Joint Forum are 

overseen by both the IOC and the TOC, as they address both technical and policy issues. 

E. Communications Committee 

The Communications Committee addresses communication 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 participation from industry, environmental groups, and other affected 

parties. The following categories of representatives are regularly considered for membership in 

committees, forums, and work groups: 
17 

· Industry · Small Business (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 represent 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 such as the Western States Air Resource Council 

(WESTAR Council), the National Tribal Environmental Council (NTEC), and intra- and interagency forums. 

IV. Project Management 

A. Setting Priorities

The WRAP members establish the strategic direction of the organization, setting overall 

priorities for action. Once the WRAP agrees on a direction, issues are further developed and 

priorities refined by the following process: 

• The WRAP identifies issues and requests that 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 identify the major deliverables, skills 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 work groups and work with the co-chairs to 

develop a written charge, including objectives, expectations, and time frames for 

deliverables. 

• Co-chairs of forums and work groups appoint 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 and 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 group can not reach consensus, the issue is referred 

to the oversight committee(s). If the oversight committee(s) can 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 oversight committee(s) can not reach consensus, the 

issue may be referred to the WRAP Board for resolution, or it may be referred back to the forum 

for further debate. When conflicts over priorities and budgets can not be resolved by the 

individual forum, work group or committee, the 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, relevant material will be posted on the WRAP Web 

site and comments will be solicited. 

Work products must be presented to the appropriate 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 communication and coordination that occurs directly 

between WRAP participants, the WRAP will work with the Western States Air Resources 

Council (WESTAR) and the National Tribal Environmental 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 participation remains representative, balanced, and fair. 

Contractors hired with EPA grant 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 functions of the WRAP come from the Communications Committee, 

the National Tribal Environmental Council (NTEC) and the Western Governors’ Association 

(WGA). The Communications Committee has developed a Communications Manual for the 

WRAP’s internal and external communications and assists committees 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 reimbursements, meetings, 

conference calls, public and media inquiries, press releases, Web sites, requests to participate in 

the WRAP, and report publications. Staff assistance includes providing a “sounding board” for 

stakeholders having concerns with the WRAP processes and relating 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 responding to media and public inquiries. 

Under a separate EPA grant, NTEC assists tribal participation in the WRAP by arranging, 

facilitating, and providing reimbursement for tribal caucus meetings; providing coordination 

among tribal representatives of various forums; performing legal and policy analyses on WRAP 

issues; and securing contractor assistance for additional technical and policy analysis. This 

includes providing staff support to the tribal caucus within the WRAP. 

This work plan identifies six staff support positions. The first two are the WRAP co-project 

managers. The co-project managers oversee other staff, share general management 

responsibilities, work with stakeholders to ensure the WRAP’s processes 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 the WGA line item, while funding for the other is 

under the NTEC line item. The third staff support position assists the state 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 tribal 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 sixth assists the Initiatives Oversight Committee 

and its associated forums. These two position 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 period of time; (2) hiring temporary staff at WGA, 

NTEC, or WESTAR; and/or (3) entering 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 receiver of WRAP grants, 

retains the legal responsibility for signing and administering contracts and ensuring that work 

products are completed. These responsibilities are met with input from forums and work groups. 

Forums and work groups may create 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 justification. All RFPs are published in the 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 evaluation of RFPs. The review committee is 

responsible for scoring each RFP. Scoring is documented and retained by WGA to substantiate 

any selection. Once the committee has agreed upon selection of a potential contractor, a 

memorandum is transmitted to the WGA Executive Director along with any necessary 

supporting materials. The Executive Director makes the final contractor selection. The winning 

contractor and all losing bidders are notified in writing of Executive Director’s decision. 

Subsequent to contractor selection, WGA staff and the appropriate forum, work group, or 

committee negotiates a final contract with the winning bidder. All contracting 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 the forum, work group, or committee to monitor the work of the 

contractor and to determine whether 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 contractor regarding hours spent and expenses 

incurred. WGA also requires copies of any deliverables prior to rendering payment. If there is 

any question regarding whether the contractor has met the requirements in the scope of work, it 

is negotiated between the contractor, WGA, and the appropriate co-chairs. Once it has been 

agreed that all work has been completed in accordance with the requirements of the contract, 

payment is rendered by WGA. 

WGA is responsible for maintaining all records 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 the general WRAP grant, and are subject to the 

requirements of the single audit act and related compliance supplements. 
21 

V. Regional Haze Work Plan 

IO1 Reasonable Progress Criteria – The regional haze rule requires states, when establishing 

reasonable progress goals, to consider the following statutory factors: the cost of 

compliance, the time necessary for compliance, the energy and nonair quality 

environmental impacts of compliance, and the remaining useful life of any potentially 

affected source. Furthermore, states must include a demonstration in their SIPs showing 

how these factors were taken into consideration 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 further definition and guidance 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” identifying 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 task is to develop a process 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 the WRAP and their relationship to Section 308 

SIP requirements. Several members from the MTF 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, and NH3) and regardless of whether or not 

an emissions trading program or other alternative 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 identification across the region to meet the timing 

and other requirements specified in the regional haze rule and WRAP strategic plan. The 

Forum will hire a contractor to provide direct assistance to some states identifying 

BART-eligible sources, to consult with other states and tribes to ensure as much 

consistency as possible, and to develop and 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-eligible source is reasonably anticipated to 

cause or contribute to regional haze, and therefore be subject to BART, if it can be shown 

that the source emits pollutants within a geographic area from which pollutants can be 

emitted and transported downwind to a Class I area. The U.S. Court of Appeals rejected 

this approach, saying it impermissibly constrains state authority – i.e., by forcing a state 

Initiatives Oversight Committee 

Stationary Sources Joint Forum 
22 

to apply BART without any empirical evidence of the source’s contribution. In April 

2004, the EPA is expected to propose an alternative means by which states would 

determine which sources are subject to BART. 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, when 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 change substantially from the proposed rule. 

Determination of BART and/or its equivalent regional emission reductions is planned for 

2005, but could be initiated sooner if necessary by using the preliminary list of sources 

subject to BART and making adjustments 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 approaches it is considering in response to the 

U.S. Court of Appeals decision. It will also 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 technical and policy information needed for 

further action on Categorization/Policy topics. 

2) The second category addresses existing 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 projects, 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 the 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 developed to support the existing WRAP Policy for 

Fire Emissions Joint Forum 
23 

Categorizing Fire Emissions, to refine differences between Restoration and Maintenance 

prescribed burn types, for elements such as vegetative structure, fuel loading, fuel size 

classes, ecosystem function, and fire resilience. Also, to further understand implications 

of the feasibility criteria developed by the FEJF, as used in the various fire policies, a 

needs assessment for further technical 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 assess the impact of various fire emissions 

scenarios, using modeling runs conducted by the WRAP RMC. 

FF5 Fire Tracking System Bridge to the WRAP Emissions Data Management System - 

Implementation of the Fire Tracking System policy includes development of a software 

bridge for fire activity data into the Emissions Data Management System. 

FF6 Refinement of Existing 2018 Fire Emissions Projections - Existing 2018 fire emissions 

projections for the contiguous WRAP region for wildfire, prescribed fire, and wildland 

fire use on wildland, rangeland, and agricultural 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 lead 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 additional funding to complete in 2004. The 

project report directly supports Annual Emissions Goal reporting requirement in §309. 

 

FF9 Regional Coordination of Smoke Management Programs - Options for implementing 

regional coordination of wildland and agricultural prescribed fire smoke management 

programs, information sharing, and public notification will be developed, and then 

presented and reviewed at a facilitated 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 the 
24 

need to host a fire technical conference to include national fire emissions experts in 2004. 

Conference topics include, but are not limited 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 emission inventory purposes, including remote 

sensing; 5) Treatment of fire sources in regional modeling (expectations versus reality); 

and 6) Fire emissions structure for SMOKE processor. Initial 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 are 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. 
25 

Fire Emissions Joint Forum Work Plan Activities 

Regional Modeling Center Support (fire 

emissions QA, troubleshooting, sensitivity) 

Categorization/ 

Policy

Technical 

Needs 

Coordination & 

Implementation 

Fire Tracking System Bridge to the WRAP 

Emissions Data Management System 

Refinement of Existing 2018 Fire 

Emissions Projections 

2002 National Wildfire Emissions 

Technical Guidance on Use of 

Emissions Reduction Techniques 

Regional Coordination of Smoke 

Management Programs 

Co-Sponsor Fire Emissions 

Conference 

Effects of Smoke Management 

Techniques In Reducing Regional 

Haze Impacts on Class I areas 

Wildland Fire Emissions Tradeoff Model Review 

User Guidance and Review of 

Feasibility Criteria for 

Categorizing Fire Emissions

Guidance On Apportionment of 

Natural and Anthropogenic 

Emissions 

§308 SIP/TIP 

Preparation 

§309 

Implementatio

Develop Basis for Enhanced 

Smoke Management Programs 

2018 Fire Inventory

Alternatives to Wildland Burning

Evaluate Fire Emissions Estimation 

Model Assessment/Sensitivity

2002 Inventory of Wx, Rx, and 

WFU for wildland, rangeland, 

agricultural lands 

Modeling to Assess/Establish 

 de minimus levels 

Fire Emissions/Categorization 

Guidance (difference between 

restoration & maintenance) 

Guidance for implementation of 

Fire Tracking System & Annual 

Emissions Goal policies 
26 

The AP2 Forum’s work plan is based largely on the renewable energy and energy efficiency 

policy adopted by the WRAP Board3 and on its subsequent management directive to the IOC and 

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

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

and tribes for their consideration and use 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 (including model legislation, 

rules, and policies) needed to incorporate the renewable energy and energy efficiency 

recommendations of the AP2 Forum into the Pollution Prevention section of their 

regional haze SIPs and TIPS; 

• Monitor the Transport Region’s progress towards achieving the GCVTC 10/20 renewable 

energy goal and implementation of the renewable energy and energy efficiency 

recommendations of the AP2 Forum; and 

• Assist the efforts of Western states and tribes 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, rules, and policies) needed by states, tribes, and air quality 

agencies to incorporate the renewable energy and energy efficiency recommendations of 

the AP2 Forum into the Pollution Prevention section of regional haze SIPs and TIPs. 

Funding for this task will support state energy offices, tribal authorities, and air agency 

efforts to compile and develop: 

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

resource assessments of the most cost-effective renewable energy opportunities in a 

state, and documentation and description of programs relied on to achieve the 

GCVTC 10/20 goal; 

◦ Program descriptions of existing and planned 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 Prevention Strategies For Regional Haze; 

April 2003; pg. 1-2. 

4

 Ibid.; pg 3.

Air Pollution Prevention Forum 
27 

level. This will allow states to comply with section 309(d)(8)(iv) that requires states 

to develop short and long term projections of emissions reductions, visibility 

improvements, energy cost savings, and secondary economic benefits associated with 

the GCVTC renewable energy goals and energy efficiency activities. 

◦ Identify or develop model rules or legislation for renewable energy and energy 

efficiency policies to ensure consistent treatment between states and tribes within the 

WRAP region. 

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

work with the Western Governors’ Association to convene a regional meeting of 

stakeholders to collaboratively develop a “blue print” that will define the critical features 

needed to: 

◦ Conduct a needs assessment and develop a single 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 Interconnection to support establishment of a single institution in 

the West responsible for registering, issuing, tracking, and verifying renewable 

energy certificates; and 

◦ Create of an independent, regional generation tracking system to provide data 

necessary to substantiate the number of megawatt hours generated from renewable 

energy sources and to support verification, tracking, and trading of RECs. 

PP3 Transmission Reform – Participate in regional proceedings and planning processes to 

promote policies and rules that eliminate transmission access, pricing, and 

interconnection barriers to renewable energy resources and support 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 developing 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 proceedings for setting rules for renewable 

interconnection. Participation in FERC interconnection rules and standards 

proceedings; and 

◦ Planning and construction of new transmission. 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 organizations to evaluate how much wind can be integrated into 

the grid (PacifiCorp IRP/transmission). 
28 

PP4 Tracking and Reporting – Pursuant to interest expressed 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 changes 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 NOx5; 

◦ Reports: Support the completion of the AP2 Forum’s final reports for distribution to 

states and tribes who are considering using 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 Portfolio Standards, carbon 

constraints, etc. Provide WRAP members up-to-date information on progress being 

made in implementing the renewable energy and energy efficiency recommendations, 

and the success of incorporating such measures into SIPs. It would also ensure that 

the recommendations remain relevant given changing external circumstances; and 

◦ Provide to the WRAP web site updated information on actions that have been taken to 

implement the AP2 Forum recommendations. 

 

PP5 Displaced Emissions Analysis and Time-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 could be used by states to help energy offices 

and air quality managers develop credible, state-specific estimates of emissions displaced 

by adopting different renewable energy programs and energy efficiency best practices 

found in the AP2 reports. The Forum’s analysis, to date, has focused only on regionalscale impacts. Emissions displacement tools similar to those developed by OTAG for 

NOx could help individual states establish reporting, 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 demonstration project(s). A portion of the funds may also be used to 

hire a consultant to advise, coordinate, and evaluate nonroad 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 Forum 
29 

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 standards under the forthcoming Tier IV nonroad 

diesel regulations, should it include 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 regulatory proposals (e.g., advanced notice 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 involve legal, technical, and policy issues, and 

should be done in close consultation with the IOC. 

EA1 Framework Application Test – The forum, in consultation with the IOC, will select one 

or more potential or historical emission control 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 challenge will be the collection of tribal baseline data. This 

portion of the effort must be coordinated with the Tribal Data Development Work Group, 

and the overall effort must be coordinated with the Emissions Forum since its emissions 

baseline should be predicated on the same economic and demographic data as used in the 

economic assessments. 

EA3 Enhancement of Cost and Benefit Unit Values – The net benefit calculated 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 expense 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 visibility benefits. Any revised unit values will be 

Sources In and Near Class I Areas Forum 

Economic Analysis Forum 
30 

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 complement, the Forum will develop a screening 

tool based on the framework (e.g., a light-weight version of the framework) to be applied 

more routinely and cost-effectively for assessing and ranking a variety 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 noted above, the Emissions Forum and Economic 

Analysis Forum should co-develop and share a common set of economic and 

demographic baseline data. In addition, the 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 results, 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 major areas of activity planned for 2004. The 

Regional Modeling Center will continue operation, 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 emissions 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 Quality Modeling Forum 
31 

• Further improvement of WRAP region chemical 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 windblown dust emissions modeling methodology; 

• Sensitivity modeling runs for aircraft cruising emissions from aircraft; 

• Further improvement of source apportionment 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-scale estimates of model domain boundary conditions into 

WRAP modeling analyses. 

MF2 Alaska Modeling – Based on the results of a 2003 project evaluating the 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 identified, 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 completed the preparation 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 region. 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 analyses and discussions among the TOC, IOC, the Air Managers 

Committee, all Forums, and the WRAP Board are anticipated to occur, to result in consensus on 

needed emissions reductions by source sector, to achieve reasonable progress toward the national 

visibility goal for the planning 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, integrating and synthesizing 

three major types of information – monitoring, 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 Projects (TOC)
32 

 geographic source areas of emissions that contribute to impairment at each mandatory 

federal Class I area (also including existing and potential tribal Class I areas); 

 mass and species distributions of emissions by source categories within each 

contributing geographic source area; and 

 amount of natural and manmade emissions affecting each Class I area. 

Integrate and synthesize the above data into clear explanations of the estimated causes of 

impairment for each Class I area, including: 

 Document the assumptions, methods, and uncertainties 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 execute this project. It is anticipated that the 

contractor will need to: 

 Attend initial Workgroup meetings and distill members’ opinions and results of 

discussions into a schedule and methodology to accomplish the tasks outlined above; 

 Possibly subcontract with independent experts for analytical work; 

 Gather and format the resulting information and data from WRAP Forums, 

independent experts, and other related air quality analyses, 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 integrating knowledge gained from measurements, 

receptor models, and chemical transport models to make optimal PM management decisions. 

Rationale. The policy maker is faced with an increasingly 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, receptor models, and chemical transport models would 

help to ensure that optimal use is made of existing knowledge when establishing PM 

management strategies. These approaches must account for inherent 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 regulatory programs for the 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 complete inventory of all emissions of visibilityimpairing pollutants within the WRAP region. The Emissions Forum will work closely with the 

Tribal Data Development Workgroup 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 projects consistent with 

the WRAP Strategic Plan, starting 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 geographic 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 assistance 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, assist with training and protocol development, 

prepare scheduled and unscheduled reports and data queries, ensure security, and provide 

estimates of emissions for non-reporting years. 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 manual 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 assessment 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 maintenance 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 expected to populate the database with inventory updates. The 

data will be used: 

• To allow §309 states to track SO2 emissions against milestones; 

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

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

• To provide input for visibility modeling. 

Emissions Forum 
34 

EF2 Second Phase of Representative Community Emissions Inventories (Phase 1 RFP under 

development) – Phase I of this project will collect as much local activity 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 expanded by using data from the representative 

communities as surrogates for other similar communities. Specifically, the activity 

information collected within these representative areas could then be used as surrogates 

for other similar-sized communities as appropriate, 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, additional communities that might benefit include those on 

tribal lands, as well as “In-and-Near” communities adjoining Class I areas. 

EF3 Update Non-Road Emissions Projections to Reflect Proposed Regulations - The existing 

emissions inventory for non-road mobile sources does not include the recently proposed 

non-road emissions standards. These new standards 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 surrogate for the 2002 base year emissions. 

EF4 EI Improvements for Spatial 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 large point sources if it is shown that default 

profiles contained in SMOKE are inappropriate for these WRAP region sources. For 

categories identified by RMC, new profiles will be compiled, based on existing source 

information available for Western sources. This is necessary to properly model visibility 

impacts, perform source apportionment analyses, and develop effective control strategies. 

Work on this project in 2003 involves the assessment of the accuracy and appropriateness 

of SCC profiles currently used in SMOKE. Sources with incorrect SCCs will be 

corrected. Inappropriate profiles 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 (1999) will be available soon. These data 

will require quality assurance review and preparation 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 the emissions to 2002 levels. Other RPOs may 

have an interest in this work, and cost-sharing 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 prepared. It will include updates of dust and 

ammonia emissions as inputs to the modeling process. 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 2003 
35 

will be used to fulfill the needs 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 emission inventory from major SO2 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 are 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 inventory of Alaska. This project would 

inventory a subset of the airports and airstrips within the state. The focus would be on 

facilities most likely to impact Class I areas. 

EF8 Joint Projects and Coordination with Other RPOs - The Emissions Forum will participate 

in two joint inter-RPO 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 resolution. The existing model uses default 

nationwide emissions factors. The new model will recognize geographic differences in 

ammonia emissions, principally from livestock and poultry operations. 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 quality assurance, which will reduce the 

errors and reruns that have plagued the 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 WRAP 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 considerably underestimate the aircraft emission inventories. Little 

has been done on analyzing cruising emissions 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 SOx and NOx 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 the 
36 

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 the 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, collection, and appropriate use of 

technical air pollution data for tribes in the WRAP region. The Work Group coordinates the 

preparation and review of technical tools for use by tribes, and acts as a clearinghouse for 

technical information used by WRAP Forums and 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 option to submit visibility implementation plans or 

“reasonably severable” elements thereof. Tribes are encouraged to participate in Regional 

Planning Organizations, EPA is committed to supporting tribal involvement, and tribes have 

been actively engaged in specific TDDWG and general 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 quality and emissions on tribal lands is needed 

in order for tribes to participate in a meaningful way in the WRAP decisions, and to better 

determine what, if any, regulatory actions are needed 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 deadlines 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 there 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 technical tools and information 

for WRAP region tribes, but expand the support to allow interested tribes 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, training sessions will be offered for the Tribal 

Professional by ITEP. Project elements of the 2004 ITEP effort include: 

• TEISS Software Support (software distribution 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 Development Work Group
37 

• Alaska tribal support (ITEP will work the state of Alaska, and interested Alaskan 

Native Corporations to distribute, and provide voice and electronic support, for the 

use of TEISS in Alaska); 

• TEISS Software User Workshops (Two workshops, designed for both new [3.5 days] 

and experienced [2.5 days] TEISS users, will be developed and conducted at the 

Tribal Air Monitoring Support (TAMS) Center’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 information 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 contractor will be analyzing data from all 

speciated monitoring sites which are helpful to explaining the answers to the Causes of 

Haze questions detailed in the existing multi-year contract. The answers will be prepared 

for each WRAP region mandatory Federal Class 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 Class I area" IMPROVE data; 

2) Data from relatively nearby, representative IMPROVE monitors (including tribal 

IMPROVE sites) which are not "In or next to the Class I area"; and/or 

3) Data from nearby non-IMPROVE monitoring 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 category impacts can be quantified using the data 

analyzed for Causes of Haze from nearby monitoring sites, and answer the Causes of 

Haze questions for those reservations, based on expert judgment; and 

3) Analyze the need and identify representative locations for additional regional haze 

monitoring sites on reservations 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 individual tribes. To date, state- and countylevel emissions data have been used to analyze visibility improvements associated with 

various control strategies. When submitting a TIP, the tribe would need to provide a 

Technical Support Document (TSD) with the TIP, or have future WRAP regional TSD 

work products provide sufficient data resolution in the proper formats. The purpose of 

this project is to describe the TSD data and 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 projects 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 will 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 Indian Nations could exercise their religious 

and ceremonial practices without being regulated by the Regional Haze Rule. 

The Dust Emissions Joint Forum is a new forum 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 interpretation 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 appropriate strategies for reducing anthropogenic sources of dust 

affecting Class I areas. At its discretion, the Forum may also develop 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 quantifying the contribution of dust to haze in 

Class I areas. 

DF1 Establish Dust Definitions and 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 attributes, such as those used in routine 

monitoring and modeling analyses. Under this task, the Forum will also identify 

Dust Emissions Joint Forum 
39 

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, and the effectiveness of 

such controls. For each category, state, tribal, and local inventories (especially locally-generated 

inventories, inventories for PM nonattainment areas, and year 2002 inventories) 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 control options and performance 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 may relate to the source 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 Forum continued to provide access to regional 

haze monitoring data through operation of the inter-RPO VIEWS website, and has initiated the 

comprehensive, multi-year Causes of Haze Analysis 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 projects in 2004 is described next: 

AMR1 VIEWS Data Base 2004 Operations (CENRAP portion in current grant) – The 

Visibility Information Exchange Web Site (VIEWS) began operation in 2002, building 

from the earlier WRAP Ambient Monitoring Database. VIEWS receives joint, annual 

funding by all 5 RPOs, each contributing $50,000, through a WGA contract. A 

Steering Committee composed of RPO representatives, EPA, and Federal Land 

Managers oversees the operation of the database and website, and tracks deliverables 

from the annual VIEWS workplan. IMPROVE and other visibility-related data are 

displayed and available for analysis 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 source categories that contribute to haze. 

These reports will also document the use of spatial and meteorological analysis 

methods to estimate the impacts from within 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 visibility conditions for the §308 glide paths), 

Ambient Monitoring and Reporting Forum 
40 

and will be documented in this report. Deliverables from this analysis project will 

directly support the TOC’s Attribution of Haze project. 

AMR3 Natural Haze Levels Analysis (separate $75K from OAQPS, 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 mandatory 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 issues related to that program (e.g., expansion to other states 

under Section 308). After the SIPs are submitted (by December 31, 2003), the EPA expects to 

conduct a six-month completeness review, followed by an 18-month process to review the 

substance of the SIPs, propose approval, take public comment, and take final action. This 

process may require interactions between the EPA and the 309 states, potential revisions/updates 

to certain SIP elements, and coordination among the 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 milestones) and periodic audits of emissions 

tracking, (b) addressing any remaining or new 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 state 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 identified 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 caucus staff, via WGA, 

WESTAR, and NTEC. The AMC identified a number of unresolved questions regarding EPA 

interpretation of the Regional Haze 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 Managers Committee 

309 Coordinating Committee 
41 

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 process 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 directly from WRAP) and the State Caucus through a WGA 

contract with WESTAR. The caucus staff positions are generally responsible for 

disseminating information between WRAP committees and forums and their respective 

caucuses, and to facilitate communication between 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 Alaska. A number of activities, 

in addition to those typically associated with 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 sent 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 sought with Alaskan Native organizations 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 health benefits of haze controls could be 

gleaned from on-going WRAP activities, such as those related to air quality modeling, 

ambient monitoring, and socioeconomic analysis. Distilling health-related information 

from WRAP activities will provide added value to WRAP members and may generate 

further interest from individuals and organizations that may 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 area of air quality and health to draft a report 

which (a) summarizes what the available literature implies about the health significance 

of various PM constituents and PM precursors 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 (particularly on tribal lands) which could provide significantly more 

health-related information, and (d) recommends ways in which the WRAP can use its 
42 

current and forthcoming data (including filled data gaps) to estimate the health effects of 

haze and the health benefits of haze controls. 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 addition to providing some additional insights – 

and discuss next steps for the WRAP with respect to regional haze and health. 

 

AMC4 Traditional Tribal Practices and Regional Haze – Tribal traditional practices (e.g., 

ceremonial, cultural, religious) are regularly affected by regional haze or the policies 

intended to curb such haze. On the one hand, tribes are concerned with protecting their 

traditional practices from the air pollutants that obscure visibility. For instance, some 

tribal members have noted the importance of being able to see nearby 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 produced 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 WRAP region and how these practices 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 effective policies on regional haze. 

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

how their involvement in the WRAP serves to reduce the haze that interferes with their 

traditional practices. This document, among other things, will highlight some of the 

traditional tribal practices that are affected 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 understand 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 tools for WRAP participants (and members of 

other regional planning organizations) who regularly work with and/or live near tribal 

lands. These documents will be a compilation of published and unpublished information 

about tribal practices and cultural 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 audiences, such as other tribes and 

non-tribal audiences. It is anticipated that the documents will be professionally 

developed into a bound document for distribution to WRAP 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 must be accomplished prior to the next SIP 

submittal date of 2007 (or 2005, if Congress does not reauthorize TEA-21, including the 

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

collaborative discussions soon to determine what is needed to support 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 planners 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 needs of the WRAP, and later to successfully develop and 

implement their individual 308 SIPs and TIPs. 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 SIPs and TIPs. The workplans and reports from the other 

forums, committees and workgroups would feed into this process. This project is 

supportive of the WRAP strategic plan. 

Prospective workgroup members would be identified and a final workplan for the project 

would be ready at the beginning of the calendar year. AMC would ensure adequate 

representation on the workgroup, including state, tribal and EPA staff, and other 

appropriate stakeholders. The workplan and 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 implementation 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 whether to use a regional FIP or tribe specific 

FIPs for particular provisions; and guidance 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 implementation is appropriate, and guidance on 

reasonable severability. This effort will be coordinated with any national efforts within 

EPA to develop implementation policy in a broader context. (Note that publicly available 

drafts of EPA’s 2003 GPRA strategic plan have included a target of developing similar 

policies nationwide by 2008). No funding is currently 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 Operations/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 The WRAP Sheet to selected recipients; and 

• Produce brochures, fact sheets, and other handout materials for conferences, exhibits, 

and public meetings. 

CC3 Update Presentation Materials to Tell the WRAP Story: 

• Tailor the WRAP 301A, 401 and Tribal version presentations to meet needs of 

various forums/committees; and 

• Convert presentations to various video formats (CD, VHS, 35mm, etc.) and make 

copies for multiple venues. 

CC4 Expand Speakers' Bureau – Assure exposure of WRAP story to state and tribal general 

audiences throughout the WRAP region. Tailor to individual audiences as appropriate: 

• Develop and maintain data base of prospective audiences; 

• Work with state and tribal air directors/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 partnering 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