### REPORT OF THE

GRAND CANYON VISIBILITY TRANSPORT COMMISSION

TO THE UNITED STATES

ENVIRONMENTAL PROTECTION AGENCY

June 1996i EXECUTIVE SUMMARY

The Colorado Plateau's national parks and wilderness areas provide a unique, panoramic

visual experience for people from around the world. This experience depends on maintaining

high visual air quality in the region, which is threatened by haze resulting from projected growth

over the next fifty years. C ongress has set a national goal of remedying existing humancaused visibility impairment, and preventing future impairment, at these national parks and

wilderness areas. Congress recognized that not all haze is human-caused and that haze is

a re g ional issue. Congress created the Grand Canyon Visibility Transport Commission in

1991 to advise the U.S. Environmental Protection Agency on strategies for protecting visual

air quality at national parks and wilderness areas on the Colorado Plateau. The Commission

established a Public Advisory Committee (PAC) to obtain broad input as it formulated these

strategies.

The Commission conducted an extensive review of scientific, technical, and other information

with assistance from a range of governmental, business, tribal, and environmental interests.

It developed more comprehensive databases, and new computer modules to analyze these

data and model future air quality. The Commission significantly advanced understanding of

regional haze, but limitations and uncertainties remain. Based on that information and its own

deliberations, the PAC developed a set of emissions management recommendations for the

Commission with a full understanding of progress and limitations in available knowledge.

These recommendations are aimed at protecting clear days and reducing dirty days at

national parks and wilderness areas on the Colorado Plateau. Following a series of public

meetings in April 1996, the PAC and Operations Committee conducted a final review and

approval of these recommendations and forwarded them to the Commission for action. The

Commission formally considered the PAC and Operations Committee reports on June 10,

1996 and approved them as the Commissions report to the Environmental Protection Agency.

T he EPA should use the Commission's recommendations as guidance for devel oping

national strategies and/or rulemaking. Implementation of all specific program components will

remain the responsibility of tribes, states and their political subdivisions, and, in some cases, federal agencies.

Some of the Commission's recommendations ask the EPA to take specific actions or

institute particular programs , in cooperation with the tribes, states and federal agencies as

implementing bodies. Other recommendations provide a range of potential policy or strategy

options for consideration by the EPA and implementing entities. As the EPA develops

policies and takes actions based on this report, this distinction between "actio n s" and

"options" should be maintained with diligence. That is, recommendations intended as policy

options should not become mandated actions or regulatory programs.

The primary recommendations include:

• Air Pollution Prevention. Air pollution prevention and reduction of per capita pollution is

a high priority for the Commission. The Commission recommen ds policies based on

energy conservation, increased energy efficiency and promotion of the use of renewable

resources for energy production.ii

• Clean Air Corridors. Clean air corridors are key sources of clear air at Class I areas, and

the Commission recommends careful tracking of emissions growt h that may affect air

quality in these corridors.

• Stationary Sources. For stationary sources, the Commission recommends closely

monitoring the impacts of current requirements under the Clean Air Act and ongoing source attribution studies. Regional targets for SO 2 emissions from stationary sources will be set,

starting in 2000. If these targets are exceeded, this would trigger a regulatory program,

probably including a regio nal cap and market-based trading. During the next year,

participants in the Commission's process will develop a detailed plan for an emissions cap

and market trading program.

• Areas In And Near Parks. The Commission's research and modeling show that a host of

identified sources adjacent to parks and wilderness areas, including large urban areas,

have significant visibility impacts. However, the Commission lacks sufficient data regarding

the visibility impacts of emissions from some areas in and near parks and wilderness

areas. In general, the models used by the Commission are not readily applicable to such

areas. Pending further studies of these areas, the Commission recommends that local,

stat e, tribal, federal, and private parties cooperatively develop strategies, expand data

collection, and improve modeling for reducing or preventing visibility impairment in areas

within and adjacent to parks and wilderness areas.

• Mobile Sources. The Commission recognizes that mobile source emissions are projected

to decrease through about 2005 due to improved control technologies. The Commission

recommends capping emissions at the lowest level achieved and establishing a regional

emissions budget, and also endorses national strategies aimed at further reducing tailpipe

emissions, including the so-called 49-state low emission vehicle, or 49-state LEV.

• Road Dust. The Commission's technical assessment indicates that road dust is a large

contributor to visib ility impairment on the Colorado Plateau. As such, it requires urgent

attention. However, due to considerable skepticism regarding the modeled contribution of

road dust to visibility impairment, the Commission recommends further study in order to

resolve the uncertainties regarding both near-field and distant effects of road dust, prior to

taking remedial action. Since this emissions source is potentially such a significant

contributor, the Commission feels that it deserves high priority attention and, if warranted,

additional emissions management actions.

• Emissions from Mexico. Mexican sources are also shown to be significant contributors,

particularly of SO 2 emissions. However, data gaps and jurisdictional issues make this a

difficult issue for the Commission to address directly. The Commission recommendations

call for continued binational collaboration to work on this problem, as well as additional

efforts to complete emissions invento ries and increase monitoring capacities. These

matters should receive high priority for regional and national action.

• Fire. The Commission recognizes that fire plays a significant role in visibility on the Plateau.

In fact, land managers propose aggressive prescribed fire programs aimed at correcting

the buildup of biomass due to decades of fire suppression. Therefore, prescribed fire and1 Sulphur dioxide (SO

2 ) for stationary sources and nitrogen oxide s (NO

x ) and volatile organic compounds

(VOC) for mobile sources.

iii wildfire levels are projected to in crease significantly during the studied period. The

Commission recommends the implementation of programs to minimize emis sions and

visibility impacts from prescribed fire, as well as to educate the public.

• Future Regional Coordinating Entity. F inally, the Commission believes there is a need

for an entity like the Commission to oversee, promote, and support many of the recommendations in this report. To support that entity, the Commission has developed a set of

recommendations addressing the future administrative, technical and funding needs of the

Commission or a new regional entity and has asked the Operations Committee to complete

detailed plans by September, 1996. The Commission strongly urges the EPA and

Congress to provide funding for these vital functions and give them a priority reflective of

the national importance of the Class I areas on the Colorado Plateau.

To the maximum extent feas ible, Commission recommendations calling for additional

exploration and study, etc. (necessary for filling information gaps and for r esolving certain

policy issues) should be accomplished by the year 2000. Until such time as future

organizational arrangements have been determined, all tasks which are not assigned to any

particular existing entity should be performed by or under the auspices of the Operations

Committee.

The Commission believes that reasonabl e progress toward the national visibility goal is

achieved to the extent that current Clean Air Act requirements, existing laws and regulations,

and the Commission's recommendations result in a significant near-term decrease in

emissions that contribute to visibility impairment and ensure long-term protection of visibility.

For example by 2000-2010, pollutants from stationary and mobile sources are expected to

be reduced by 30% from the 1990 levels. 1ivv TABLE OF CONTENTS

EXECUTIVE SUMMARY

.............................................. i

GLOSSARY

............................................. vii

SECTION I: INTRODUCTION

........................................ 1

SECTION II: PROCESS FOR DEVELOPING PAC RECOMMENDATIONS

. 5

SECTION III: EMISSION MANAGEMENT RECOMMENDATIONS

........ 26

Guiding Principles

....................................... 26

Air Pollution Prevention

.................................. 28

Stationary Sources

...................................... 32

Mobile Sources

......................................... 38

Area Sources

........................................... 46

Clean Air Corridors

...................................... 51

Emissions Within and Near Class I Areas

................... 53

Transboundary Emissions from Mexico

..................... 56

Future Scientific and Technical Needs

..................... 59

SECTION IV: TRIBAL PERSPECTIVES AND POSITIONS REGARDING

RECOMMENDATIONS

.................................. 66

SECTION V: FUTURE ADMINISTRATIVE NEEDS

..................... 74

SECTION VI: ANALYSIS OF RECOMMENDATIONS

................... 78vivii

GLOSSARY OF TERMS USED IN THIS REPORT

Within each definition, terms defined elsewhere in this glossary are printed in italics

.

Aerosol: Solid particles or liquid droplets that are small enough to be suspended in the air.

Aerosols cause most of the l ight extinction responsible for haze on the Colorado

Plateau

.

Area source: Many small sources of air pollution in which the contribution of each source is

relatively small, but combined may be a significant source of air pollution. A city can

be an area source (although large facilities within the city could release enough air

pollution to warrant their analysis individually as a point source ).

BART: B est A

vailable R etrofit T echnology, a process under the CAA to evaluate the need

and, if warranted, install the most effective pollution controls on an already existing air

pollution source.

BFS/Baseline Forecast Scenario: A computer model used by the Grand Canyon Visibility

Transport Commission to estimate future haze-causing pollution and economics. The

GCVTC based this scenario on current technologies, existing laws, and a variety of

assumptions about how quickly various kinds of pollution sources will be retired and

the type of facilities that will replace them. It is an extension of current policies, and

allows comparisons with other air pollution management scenarios the GCVTC may

propose.

CAA/CAAA: The C lean A ir A ct, and the C lean A ir A ct A mendments. National air pollution

control is based on the Clean Air Act, passed in 1970. Congress amended the Clean

Air Act in 1977 (adding many visibility sections that the GCVTC is addressing), and

in 1990 (when it required creation of the GCVTC

, assigned tribal governments power

under the CAA similar to those of the states).

Class I site/area: In 1977, Congress identified 158 national parks, wilderness areas,

international parks and other areas that were to receive the most stringent protection

from increases in air pollution. It also set a visibility goal for these areas to protect

them from future human-caused haze, and to eliminate existing human-caused haze,

and required reasonable progress toward that goal.

Colorado Plateau: A high, semi-arid tableland in southeast Utah, northern Arizona,

northw est New Mexico, and western Colorado. The unique erosional forms of the

Plateau are world famous.

CNG: C ompressed N atural G as, a relatively clean-burning fossil fuel.

EC/OC: E lemental C arbon (such as soot, often the result of fire and diesel engines) and

O rganic C arbon (carbon combined with other elements to form complex compounds,

often given off by plants and most human activities).viii

Fine mass particulates: A erosols that are smaller than 2.5 micrometers in diameter. (A

micrometer is one mil lionth of a meter, a human hair is about 70 micrometers in

diameter.)

GCVTC: The G rand C anyon V isibility T ransport C ommission, composed of the governors

of eight western states (AZ, CA, CO, NM, NV, OR, UT, WY), five tribes (Acoma, Hopi,

Hualapai, Navajo), four federal land m anagers (Bureau of Land Management, U.S.

Fish and Wildlife Service, U.S. Forest Service, National Park Service), the Columbia

River Inter-Tribal Fish Commission, and the Environmental Protection Agency. The

states and tribes vote, the ot her GCVTC members do not. The Commission was

established to recommend methods to preserve and improve visibility on the Colorado

Plateau . Congress required establishment of the GCVTC through the Clean Air Act

Amendments of 1990.

HC: Hydrocarbons. A group of chemicals containing hydrogen and carbon that often

contribute to air pollution as OC's or VOC's

. They are involved in forming ozone, and

some hydrocarbons are toxic. Term often used interchangeably with VOC s.

Hopi Point: An important air quality monitoring site on the South Rim of the Grand Canyon

in Grand Canyon National Park.

IAS: I ntegrated A ssessment S ystem, a computer model created by the GCVTC to generate

information about future visibility and economic trends under a variety of pollution

control scenarios.

IMPROVE: I nteragency M onitoring of Pro tected V isual E nvi ronments, a group of federal

agencies using a common set of standards to monitor visibility across the United

States. Other nations have also adopted portions or all of the IMPROVE monitoring

techniques.

Inverse megameters, Mm -1 : A measurement unit used for light extinction , the higher the

value, the hazier the air is.

LEV/ZEV: L ow E mission V ehicle/ Z ero E mission V ehicle, motor ve hicle classifications

referring to their tailpipe release of air pollution. Today's ZEV's are generally batterypowered, but may use hydrogen fuel cells and other energy sources in the future.

Light extinction: The "loss" of light as it travels through the air. Light can be truly lost by

being absorbed by gases and aerosols in the air. Light can also be "lost" as it

scatters off gases and aerosols

.

LNG: L iquefied N atural G as, a relatively clean-burning fossil fuel.

LPG: L iquefied P etroleum G as, a relatively clean-burning fossil fuel such as propane.

Mm -1 : Inverse megameters

, a measurement unit used for light ex tinction , the higher the

value, the hazier the air is.ix

MMA: M aximum M anagement A lterna tive, an I AS computer model used to estimate the

maximum visibility improvements possible regardless of the cost of the pollution

controls used. The MMA was used for comparisons, rather than as a policy option.

Mobile source: A pollution source that moves. Mobile sources are often divided into road

sour c es, including cars, trucks, buses, and motorcycles, and non-road sources like

trains, planes, boats, lawnmowers, etc.

Modeling: The use of a computer to mimic reality and predict the future behavior of the

subject under study. Models of complex subjects like visibility are often limited by the

raw data available and the capacity of the computer itself. The G CVTC's IAS is a

computer model of regional air quality for the Colorado Plateau and uses information

from throughout western North America.

NAAQS: N ation al A mbient A ir Q uality S tandards, levels of air pollution set by the U.S.

Environmental Protection Agency to protect public health and welfare. Standards are

set for ozone (O 3 ), carbon monoxide (CO), sulfur dioxide ( SO 2 )

, nitrogen dioxide ( NO 2 )

, lead (Pb), and particulates (solid aerosols ).

Non-attainment area: A geographic region where concentrations of a particular air pollutant

exceed the NAAQS . A particular location may be non-attainment for more than one

pollutant.

NO

x : A mixture of nitrogen dioxide and other nitrogen oxide gases. Nitrogen is the most

common gas in the atmosphere. In high temperature and/or high pressure burning (as

in an engine), the air's nitrogen is broken down and combined with oxygen, forming

unstable or reactive NO

x gases. Nitrogen dioxide (NO 2 ) is yellowish brown, and thus

contributes directly to haze. All the NO

x gases react in the air to form haze-causing

aerosols and smog.

NPS: N ational P ark S ervice, a federal agency charged with prote cting the natural and

cultural resources and the processes that create and sustain them, in the National Park

System.

New Source Review: A review of a new facility that has the potential to emit air pollutants

in amounts spec ified by law. The review is done to establish the impact of the

pollution, and the options available to control that pollution.

OC: O rganic C arbon, complex carbon-containing compounds often emitted by plants and

many human activities. OC 2.5 is organic carbon of 2.5 micrometers of less.

PAC: P ublic A dvisory C ommittee, established by the GCVTC to represent a broad range

of public interests. Members are drawn from all levels of government, business,

industry, environmental organizations, academia, and private citizens. The G CVTC

Commissioners charged the PAC with developing consensus recommendations for

managing visibility.x

Particulates: Solid material small enough to remain suspended in the air.

PM 2.5 : Aerosols

with a diameter smaller than 2.5 micrometers, the most effective size range

to create haze (a micrometer, or micron, is one millionth of a meter, an inch is 25,400

micrometers long).

PM 10 : Aerosols with a diameter smaller than 10 micrometers, on which the EPA has based

current NAAQS . Larger aerosols in this size range (larger than 2.5 micrometers) are

less effective in creating haze than the smalle r ones. In addition to creating haze,

higher concentrations of PM 10 can also cause irritation of the throat and lungs, cancers,

and early death.

Point source: A specific source of air pollution.

Prescribed fire: Fires in wildland areas that are allowed to burn under prescribed

conditions. The "prescription" reflects ecosystem management goals, ability to control

the fire, and air quality concerns.

Prescribed natural fire: A fire started by natural processes (usually lightning) and allowed

to burn as long as it meets prescribed fire conditions.

PSD: P revention of S ignificant D eterioration. A program established under the Clean Air

Act Amendments of 1977, whose goal is to prevent major increases in air pollution in

areas with cleaner air. The program sets the tightest limits on pollution increases from

large point sources

in Class I areas

.

Rayleigh or Rayleigh Scattering: The natural scattering of light caused by nitrogen and

oxygen in the atmosphere which makes the sky look blue. Also called "blue sky."

Reasonable progress: Reasonable progress refers to progress in reducing human-caused

haze in Class I areas under the national visibility goal. The C lean Air Act indicates that

"reasonable" should consider the cost of reducing air pollution emissions, the time

nec e ssary, the energy and non-air quality environmental impacts of reducing

emissions, and the remaining useful life of any existing air pollution source considered

for these reductions. The GCVTC P ublic Advisory Committee has developed the

following definition: "Reasonable progress towards the national visibility goal is

achieving continuous emission reductions necessary to reduce existing impairment

and attain steady improvement of visibility in mandatory Class I areas, and managing

emissions growth so as to prevent perceptible degradation of clean air days."

Re-entrained dust/road dust: Fine and coarse dust stirred up from paved or dirt surfaces

by the passage of vehicles. The dust may include soil particles, tire rubber, soot, and

other materials.

Regional cap: A limit on the amount of specific air pollutants that can be released in a

defined geographic area, or a limit on the amoun t of a specific air pollutant that is

allowed to be in the air in a defined geographic area.xi

ROG: R eactive O rganic G ases, typ ically h ydrocarbons (HC)

, but include oxygenated

hydrocarbons.

SIP/TIP: S tate I mplementation P lan/ T ribal I mplementation P lan, plans devised by states and

tribes to carry out their responsibilities under the Clean Air Act. SIP's and TIP's must

be approved by the U.S. Environmental Protection Agency and include public review.

SO 2 , SO

x , sulfates: Compounds composed of oxygen and sulfur. Burning fuels, manufacturing paper, or smelting rock containing sulfur produces sulfur dioxide gas (SO 2 ) which

is converted in the air to other sulfur oxides (SO

x ) or haze-causing aerosols (sulfates).

Source: Where air pollutants are released. Sources are usually classified as p oint

, mobile

,

or area sources

.

Source attribution: Determining how much a single source contributes to air pollution.

Stationary source: An air pollution source that remains in one place (generally a business

or industrial facility).

Species: A term used to refer to types of pollutants.

TIP/SIP: T ribal I mplementation P lan/ S tate I mplementation P lan, plans devised by states and

tribes to meet requirements of the Clean Air Act as defined by the U.S. Environmental

Protection Agency.

Trading program: In air quality management, a plan under which some limit is set on the

amount of an air pollutant that can be released into the air. If a facility releases less

than its limit, it may trade or sell the ability to release "unused" amount of air pollutant

to another facility, so the second facility can release more than the limit.

Transfer coefficient: In computer modeling of air quality, a geographic area is divided into

"cells." Transfer coefficients are mathematical formulas that tell the computer how

much air pollution to "move" from one cell to an other. Determining a transfer

coefficient requires the computer model designer to consider wind directions,

chemical changes to the air pollutants as they travel, loss of pollutants from the air, and

other factors.

Transmissometer: A device that measures l ight extinction by shining a light beam of known

brightness through the air and measuring how much is lost when the beam reaches a

receiver, usually about 4 miles away.

Urban plume/plume blight: An urban plume is the "cloud" (either visible or invisible) of air

pollution blown downwind of an urban area. Plume blight is a distinct band or layer of

visible air pollution, often from a single pollution source

.xii

Visibility i mpairment: The loss of clarity in the air that results when gases or a erosols

scatter and absorb light. We usually see visibility impairment as a general haze or a

distinct plume.

VMT: V ehicle M iles T raveled. This number is a measure of vehicle usage and is used to

calculate the ai r pollution produced by m obile sources

, such as passenger cars,

tailpipe emissions and or road dust

.

VOC: Volatile O rganic C ompound. A carbon-containing material that evaporates, such as

gasoline, some paints, solvents, dry cleaning fluids, and the like. VOC's contribute to

ozone formation and may form OC aerosols

.1 I. INTRODUCTION

The Colorado Plateau is a spectacular landscape of massive landforms, unique geology, and

vivid colors. People from around the world have experienced these wonders at Grand Canyon,

Canyonland s, Bryce Canyon, Zion, and other national parks and wilderness areas on the

Plateau. The panorama is a visual experience, and air quality is the key to full enjoyment. On

hazy days, when visibility is reduced, the human eye perceives a loss of color, contrast, and

detail in the landscape. That los s of visibility diminishes the unique experience of nature's

work on the Plateau. (See pictures at the end of this S ection which illustrate variations in

visibility at selected sites.)

Visibility and visual air quality are daily issues for the inhabitants of the Colorado Plateau,

including Indian tribes. They experience, on an almost daily basis, the variations in visibility

at national parks on the Plateau. The Colorado Plateau has some of the best visual air quality

in the United States. Paradoxically, this means that reduced visual air quality that might go

unnoticed in other parts of the United States is starkly apparent on the Plateau. Visual air

quality in the West is quite sensitive to relatively small increases in pollutants.

Research shows that visual air quality in the West experienced a significant decline due to

emissions from industrial activity from the 1940s to the 1970s. Visibility-impairing emissions

began to decli ne in the 1970s following enactment of the federal Clear Air Act. Visual air

quality at national parks and wilderness areas on the Colorado Plateau has not appeared to

c hange since reliable monitoring data became available in the 1980s. However, all the

projections point to continued population and economic growth in the region into the next

century. This growth is a potential threat to air quality, and poses a challenge to states, tribes,

and the federal government.

The National Visibility Goal Under Federal Law

Congress set a national goal of remedying existing visibility impairment, and preventing future

impairment, from manmade pollution at 158 national parks and wilderness areas across the

United States as part of the Clean Air Act Amendments in 1977. This group includes sixteen

parks and wilderness areas on the Colorado Plateau, as well as others in the Western United

States.

Congress adopted two main strategies to make progress towards the national visibility goal:

Pre vention of Significant Deterioration (PSD), which focuses on n ew or modified major

sources tha t exceed specified emission thresholds; and a Visibility Protection Program

directed at existing

sources of emissions that impair visibility.2

1. The PSD Program

The PSD program designates three classes of areas, with those designated Class I having

the most pristine air and receiving the greatest protection under the federal statute. Mandatory

federal Class I areas include all national parks, all national wilderness areas a nd national

memorial parks over

5,000 acres, and all national parks over 6,000 acres in existence in

1977. In addition, states and tribes c an designate Class I areas. Most Class I areas are

located west of the Mississippi River.

Prior to either construction of a major new source or major modification of an existing source,

the PSD program requires application to the Environmental Protection Agency (EPA) or the

state for a permit. The permit is issu ed only if emissions from the new or modified major

source will not exceed, or contribute to the exceeding of, maxim um allowable increments

under the CAA.

2. The Visibility Protection Program

Under the Visibility Protection Program, states and tribes must demonstrate to the EPA in

their State/Tribal Implementation Plans (SIPs/TIPs) that they will make "reasonable progress"

toward achieving the national visibility goal established by Congress in 1977. The EPA issued

its first regu lations under the program in 1980. These regulations did not include a tribal

component. The first explicit consideration of tribal lands with respect to air quality regulations

occurred in the 1990 Amendments to the CAA. These regulations are known as plume blight

regulations and focus on a source or small group of sources to which visibility impairment at

a Class I area can be "reasonably attributed." The EPA regulations require such sources to

adopt the best available retrofit technology, or BART, to reduce emissions reasonably

attributed to them.

The next phase of the EPA's regulations under the Visibility Protection Program focuses on

widespread, regionally homogeneous haze from a multitude of sources that impairs visibility

over a large area. These regulations are still under development.

Regional Haze

Haze and visibility problems do not respect state and tribal boundaries. Congress addressed

this issue when it amended the CAA again in 1990 and authorized the EPA to establish

visibility transport regions as a way to combat regio n al haze. Congress also specifically

ordered the EPA to establish a visibility transport region for Grand Canyon National Park, and

to create a Grand Canyon Visibi lity Transport Commission (hereafter referred to as the

GCVTC or the Commission). The EPA established the Commission in November 1991.

Tribal Authority Under the Clean Air Act

Tribes have always had the inherent right to regulate air quality on tribal lands. Under the 1990

Clean Air Act Amendments (CAAA), the EPA may delegate authority to Indian tribes to

regulate air quality. For example, tribes, like states, can prepare permitting programs under

Title V of the CAAA, and establish Tribal Implementation Plans (TIPs) and submit those2 A list of federally recognized tribes, organized by geographic area, is included as available from the

Bureau of Indian Affairs or the National Tribal Environmental Council.

3 programs to the EPA for approval. Tribal regulation of air quality on the Colorado Plateau and

across the Transport Region re quires full consideration of tribal interests and the active

participation of Indian tribes on the GCVTC.

The Commission's Mandate and Structure

The Grand Canyon visibility Transport Region includes nine states and 211 tribal lands 2 . The

states are: Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and

Wyoming. Idaho has chosen not to participate in the Commission. The GCVTC comprises:

• The Governors or their designees of each of the states in the Transport Region (with the

exception of Idaho);

• The leaders of four Indian tribes (Navajo, Hopi, Hualapai, and Acoma Pueblo) or their

designees; and

• The EPA and federal land managers from the National Park Service, Bureau of Land

Management, Fish & Wildlife Service, and Forest Service, and the Columbia River InterTribal Fish Commission, as ex officio members.

Congress specified that the GCVTC should assess scientific, technical, and other information

related to adverse visual air quality impacts from potential or projected emissions growth from

sources located in the Transport Region. The Commission adopted a work plan and created

a committee structure in order to carry out its tasks. Technical committees drew upon expert

resources in government, private industry, academia, and environmental groups.

The Commission's broad task is to report to the EPA on what measures, if any, are

appropriate to address visual air quality on the Colorado Plateau. This report must address

three areas:

1. The establishme n t of "clean air corridors" and whether additional restrictions on

emissions in these corridors are appropriate to protect visibility at Class I areas on the

Colorado Plateau.

2. The imposition of CAA requirements affecting construction of new, major stationary

sources or major modifications to existing sources in clean air corridors.

3. Regulations to address long-range strategies for regional haze that impairs visibility

in Class I areas on the Colorado Plateau.

The Commission created structures based on principles of broad public input and consensus

in order to carry out its mandate, including establishme nt of a Public Advisory Committee

(PAC). PAC members were drawn from government at the federal, tribal, state, and local

levels; business and industry; educational institutions; and environmental advocacy groups.4

Each Commissioner appointed up to five members to the PAC representing a broad range

of the public, including government, bus iness, industry, environmental organizations,

academia and private citizens. The PAC's tasks were to develop consensus recommendations for the Commission, to serve as a sounding board for the Commission for social and

economic issues affecting visibility, and to provide a balanced representation of views on the

value and impacts of protecting visibility on the Colorado Plateau. The PAC relied on the

extensive scientific and technical work of the oth er GCVTC committees to prepare its

recommendations. These other committees include the Operations Committee and

committ ees which report to it: the Alternatives Assessment Committee, the Technical

Committee, and the Communications Committee.

Following a series of public meetings in April 1996, t he PAC and Operations Committee

conducted a final review and approval of these recommendations in May. The Commission

formally considered the PA C and Operations Committee reports on June 10, 1996 and

approved the recommendations to be forwarded to the EPA for action. Tribal perspectives

on the Commission process and recommendations are elaborated in Section IV of this report.

Photographic Illustration of the Problem

The fol lowing four pages contain color photographs which illustrate the appearance of the

average 20% best and worst days and an average day at fo ur of the National Parks and

Wilderness areas on the Colorado Plateau. A depiction of the average of the 20% worst or

best days means that 10% of the days of the year can be expected to be worse or better,

respectively. Please be aware of the limitations of reproduced photographs. They do not

completely capture the detail and color of the originals. Note that the identification is incorrect

for the location of the Grand Canyon photographs; the photographs were taken from Desert

View.**Illustratons of**

**Visibility at**

**Grand Canyon**

**National Park in**

**Arizona**

San Pedro from Hopi Point

on a “clear” day. 10% of the

days are this good or better.

The Grand Canyon from

Hopi Point on an average

day.

The Grand Canyon from

Hopi Point on a “dirty” day.

10% of the days are this bad

or worse.**Illustratons of**

**Visibility at**

**San Pedro National**

**Wilderness area**

**in New Mexico**

San Pedro on a “clear” day.

10% of the days are this good

or better.

San Pedro on an average day.

San Pedro on a “dirty” day.

10% of the days are this bad

or worse.**Illustratons of**

**Visibility at**

**West Elk National**

**Wilderness area**

**in Colorado**

West Elk on a “clear” day.

10% of the days are this

good or better.

West Elk on an average day.

West Elk on a “dirty” day.

10% of the days are this bad

or worse.**Illustratons of**

**Visibility at**

**Canyonlands**

**National Park**

**in Utah**

Canyonlands on a “clear”

day. 10% of the days are this

good or better.

Canyonlands on an

average day.

Canyonlands on a “dirty”

day. 10% of the days are this

bad or worse.5 II. PROCESS FOR DEVELOPING EMISSIONS MANAGEMENT

RECOMMENDA

TIONS

ST AGES IN THE COMMISSION'S STUDY PROCESS

An understanding of the Commission's research and modeling process provides the context

for its recommendations. There were six phases of the Commission's work:

1. Development of an emissions inventory for the T ransport Region.

2. Development of a technical basis for assessing visibility impacts from changes

in emissions.

3. Development of criteria to evaluate options.

4. Development of emission management options.

5. Development of scenarios based on varying levels of emission management

options, including a baseline or "current law" scenario.

6. Devel opment of a computer-based Integrated Assessment System (IAS) to

compare/evaluate costs and visibility impacts of different scenarios.

The first step in the process was creating an inven tory of emissions for each state on the

Commission, neighboring states (Idaho, Montana, W ashington, and T

exas), northern Mexico

and western Canada. This inventory use s 1990 as its base year , and includes all major

stationary sources throug hout the T r ansport Region, and mobile and area sources

summarized at a county level. It covers ke y gaseous (sulfur dioxide, nitrogen oxides, and

reactive organic gases/ROG) and aerosol (organic carbon, elemental carbon, and fine and

coarse particles) emissions. Data specific to tribal lands have not been checked for adequacy

or accura cy . Figure II-1 provides a graphic presentation of key elements of the emissions

inventory

.

Based on this inventory

, the Commission then developed a series of emission management

scenarios and a method for assessing the visibility and cost impacts of those scenarios. The

Commission used three main emission management frameworks: a regional emission cap;

a visibility standard for the Colorado Plateau; and standardized control technology and

process requirements. These frameworks were refined into a series of scenarios that were

evaluated under the Integrated Assessment System, or IA S. The scenarios included a

baseline or lower bound, which projected effects of applying existing laws and regulatory

programs; an upper bound which included maximum application of control s on emissions

irrespective of costs; and several different intermediate goals. Each scenario reflected

different combinations of options and goals for improving visibility

.6 II. PROCESS FOR DEVELOPING EMISSIONS MANAGEMENT

RECOMMENDA

TIONS7

The Commission's committees also developed technical tools for understanding the effect of

different emission sources on visibility at Class I sites, principally the Grand Canyon. These

tools include transfer coefficients that explain the relationship between pollution sources in

various locations and visibility at specific Class I sites. These coefficients have been refined

continuously to assist the Commission in its understanding of visibility impacts.

VISIBILITY ON THE COLORADO PLA TEAU

The starting point for understanding the Commission's analytical process is visibility

. In simple

terms, visibility depends on three factors: Rayleigh scattering, other natural impairment, and

human-caused impairment. Nitrogen and ox ygen in the atmosphere cause the sky to look

blue; this is Rayleigh scattering. Other natural sources, such as volcanoes, wind-blown dust,

smoke from wildfires, and emissions from trees and plants also cause visibility impacts by

scattering and absorbing sunlight. Human activities, from industrial manufacturing to farming,

also impair visibility

. Visibility varies depending on natural effects (including weather) and their

interactions with human-caused emissions.

Note: All of the figures which follow in this section have been generated using the

Commission's Integrated Assessment Sy stem (IAS). These figures all include future

projections. Projections for 2040 are less reliable than projections for 2000.

Figure II-6 shows the relative visibility impairment from natural and human causes at four Class

I areas on the Colorado Plateau: Hopi Point, Mesa V erde, Bryce Canyon, and Canyonlands.

V alues are shown as an annual average beginning in 1990 and continuing to 2040, and also

as an average for the 20% of days during the year when visibility is worst. Visibility impairment

or light extinction caused by light scattering and absorption that impairs visibility is stated in

"inverse megameters," represented as "Mm -1 ." Figure II-6 shows that natural causes account

for approximately 15 Mm -1 to 17 Mm -1 of visibility impairment at these four areas on average.

The remaining visibility impairment at each area is caused by human activities. This portion

of total visibility impairment is considered manageable by the Commission, and is the focus

for its recommendations.

For ease of comparison, light extinction can be converted to the theoretical distance at which

a human eye could see a large dark horizon feature, such as a tree-covered mountain. As

extinction increases, the distance one can see decreases. For example, if there is only blue

sky or Rayleigh scattering (10 Mm -1 ), one could theoretically see a horizon feature 245 miles

distant. If light extinction is doubled to 20 Mm -1 due to natural and/or human caused aerosols,

visibility would be reduced to about 120 miles.

Figure II-2

Figure II-2 shows annual average light extinction for one Class I area: Hopi Point in Grand

Canyon National Park for 1990, 2000, 2010, and 2040. The dark portion of each vertical bar

is the portion of light extinction caused by Rayleigh scattering or blue sky

. This totals

approximately 10 Mm -1

. The remaining portion of light extinction is caused by natural and

human-caused aerosols. This total ranges from 24 Mm -1 to 25 Mm -1

. The corresponding8

distance for visibility is only about 90 miles. Figure II-2 shows that natural and human-caused

particles account for the majority of light extinction at Hopi Point.

Figure II-3

Figure II-3 shows the relative contributions of natural and human-caused particles to visibility

impairment at Hopi Point. For a complete discussion of t he development of the data

underlying these figures, please refer to the GCVTC Report, Options for Western Vistas

. Note

that the sources identified have not been distinguished by location. Specifically , the relative

c ontribution to visibility impairment from "local" versus "regional" sources has not been

identified. Natural particles account for approximately 5.4 Mm -1 of light extinction on an annual

average basis from 1990 through 2040. Human-caused particles are responsib le for

approximately 9 Mm -1 of light extinction at Hopi Point, roughly double the amount caused by

natural particles. In terms of visible distance, human-caused particles reduce visibility at Hopi

Point by about 66 miles on an annual average basis.

Figure II-4

Using its emissions in ventory and other data, the Commission has identified the major

sources of human-caused light extinction at Hopi Point. This information is shown in Figure

II-4 for the period 1990 to 2040, on an annual average basis. Each source of emissions is

listed on the right side of Figure II-4, along with its corresponding pattern shown in the vertical

bars. Figure II-4 shows that light extinction caused by emissions from utilities is projected to

decline by approximately 1 Mm -1

. This decline is due to emissions reductions. Light extinction

caused by mobile sources is projected to decline until approximately 2005, and then increase

through 2040. The same is true for road dust. However , as noted on page 46, there is

considerable uncertainty surrounding the predictions about road dust.

Figure II-5

Visibility varies from day to day at Class I sites on the Colorado Plateau. Figure II-5 shows the

relative contributions of different human-caused particles to light extinction on the 20% of

"worst" days at Hopi Point.

A comparison of Figure II-5 with Figure II-4 indicates that there is approximately 60% more

light extinction caused by human sources on the average of "worst" days (approximately 17

Mm -1 ) than the annual average (approximately 9 Mm -1 ).

Figure II-6 (4 pages)

Figure II-6 compares light extinction from natural and human causes at four Class I areas on

the Colorado Plateau: Hopi Point, Mesa V erde, Bryce Canyon, and Canyonlands. V alues are

shown as an annual average beginning in 1990 and continuing to 2040, and also as an

average for the 20% of days during the year (71 days) when visibility is worst. On each graph,

the bottom layer represents Rayleigh scattering and other natural causes of light extinction.

The additional layers represent light extinction caused by various human sources: stationary

, area, mobile, and Mexico. The scale on the right of each graph shows visibility in distance.9

Figure II-6 shows that natural causes account for approximately 15 Mm -1 to 17 Mm -1 of visibility

impairment at these four areas on average. The remaining visibility impairment at each area

is caused by humans. This portion of total visibility impairment is considered manageable by

the Commission, and is the focus for its recommendations.

THE BASELINE FORECAST SCENARIO, BASED ON CURRENT LA W

The Commission needed a way to evaluate how its recommendations would affect visibility

beyond current law and programs, and developed a baseline or "current law" scenario to meet

that need. The Commission refers to this scenario as the Baseline Forecast Scenario (BFS).

The Baseline Forecast Scenario is the best possible estimate of future visibility impairment

at Class I areas on the Colorado Plateau, assuming current law is enforced, with no additional

actions to protect visibility

.

The Baseline Forecast Scenario is built on the following assumptions:

• Emissions growth or decline is based on changes in economic demand in the region

• Sources retire at a specific age

• New sources are a mixture of new technology and assumed control levels

• State Implementation Plans under the Clean Air Act for attainment by 2010 are

included, and emissions growth is permitted afte r that time based on economic

growth

• There is no growth in unpaved road dust beyond 1990

• Emissions from Mexico are held constant

Because visibility is highly variable, the Baseline Forecast Scenario analyzes the average of

the "best" and "worst" 20% of days, as well as annual averages.1011121314151617181920

Figure II-7

Figure II-7 shows current and predicted visibility impairment through 2040 under the Baseline

Forecast Scenario at the same four Class I areas discussed above: Hopi Point, Mesa V erde,

Bryce Canyon, and Canyonlands. For each of the four areas, the top line shows visibility on

the "worst" da ys, the middle line shows the annual average visibility; and the bottom line

shows visibility on the "best" days.

Figure II-7 shows the wide difference in air quality on the "best" and "worst" days. There is

virtually no human-caused impairment on the "best" days at these four parks through 2040.

On the "worst" days, visibility impairment is more than doubled, and most of that increase is

caused by human sources. This is particularly significant because the human eye is more

sensitive to changes in the "worst" visibility conditions than the "best" conditions.

P AC INTERACTIONS IN DEVELOPING CONSENSUS RECOMMENDA TIONS

Members of the P AC represented diverse interests from throughout the West. Given the

divergent perspectives and concrete interests, the struggle to consensus was difficult at times,

but P AC members maintained a cordial atmosphere of collaboration in their search for good

policy

. The resulting policy recommendations do not represent what any one group would have

advocated on its own. The recommendations embody concessions, compromises and

creative solutions which all members of the P AC support.

The P A C assisted in gathering public input at different phases of this process to refin e

emission management options and evaluation criteria. In November 1995, the P AC received

a contractor's report entitled Options for Improving Western Vistas

. That report summarized

the work of the Commission's committees to that point and discussed the results of Integrated

Assessment System modeling. Based on that report and other technical information, and with

continuing input from the Commission's committees and the g eneral public, the P A C

developed consensus recommendations for consideration by the Commission. It should be

noted that there is a significant divergence among the scenarios analyzed in the technical

assessment process and t he recommendations included herein. T o the extent that the

recommendations diverge from the Commission's analyses, they reflect the input from the

public and deliberations of the P AC.

The Commission sought broad public input to develop its emission management options and

evaluation cri teria. Beginning in April 1993 and continuing until November 1995, the

Commission held several series o f public workshops and meetings across the T r ansport

Region to provide information and receive feedback. Public comments were discussed at

P AC meetings and incorporated into the P AC's recommendations to the Commission.

CRITERIA FOR ASSESSMENT OF EMISSIONS MANAGEMENT OPTIONS

The Commission developed six criteria for assessing different emission management

strategies:21

1. effectiveness in achieving visibility goals

2. economic effects

3. social effects

4. environmental effects in addition to visibility

5. equity

, and

6. administrative ease and effectiveness

The purpose of these criteria is to ensur e that all significant impacts of different emission

management strategies are considered in making recommendations for the future.

Most of the available scientific and technical information—emissions budgets, emission

management options, scenarios, criteria, and transfer coefficients—is brought together in the

Integrated Assessment System (IAS). The Commission's goal in designing the IAS was to

enable a user to select different combinations of emission reduction st r ategies applied to

sources within the T

ransport Region to yield desired visibility conditions at any one of sixteen

Class I sites on the Colorado Plateau over the next forty years (2000, 2010, 2020, 2030, and

2040). Development of the IAS was a major task, and work continues to expand its

capabilities. Most of the modeling output to date is based on visibility at a single Class I site,

Hopi Point in Grand Canyon National Park.

TECHNICAL FOUNDA TION FOR THE COMMISSION'S RECOMMENDA TIONS

Introduction

In order to ful fill its mandate, the Commission needed a reliable picture of the impacts of

regional haze on visibility at sixteen C lass I areas on the Colorado Plateau, and a way to

assess the changes in visibility and costs associated with differ ent options for managing

emissions. Meeting these needs was not simply a matter of gathering existing data and

running it through a basic computer model. The Commission needed new information and new

analytical tools, and it s technical committees and outside consultants have done

groundbreaking work to meet these needs in only a few year s. This work has significantly

improved understanding of visibility impairment in the T ransport Reg ion, and provides the

technical foundation for the Commission's recommendations.

It is important to understand that this technical work, while representing a significant advance

in knowledge, is not yet complete. The large size and complex terrain of the T ransport Region,

the time, funding, and other resources available for work, significant data gaps, and the

amount of information that could be modeled with current technology were important limiting

factors. As a result, the Com mission's technical data and findings, discussed below , are

characterized by varying degrees of uncertainty

. In particular

, the modeling has, to date, given

a limited picture of the regional, and particularly sub-regional, including tribal, dynamics of both

emissions and econ omics. Nevertheless, the Commission has sufficient confidence in its

overall understanding of the causes of regional haze and its effects on visibility to make the

recommendations presented in Section III.3 In numerous places, this report refers to "significant" contributions to visibility impairment and "significant"

decreases or increases in emissions, but "significant" is not defined. "Significant" will be def ined in the context

of developing implementation plans with full participation by the affected parties.

22 Important T echnical Data Findings

The following are some of the results and technical findings from the Commission's work to

date which form a basis for policy recommendations.

• The most comprehensive inven tory to date of emissions across the

T ransport Region. The Commission gathered 1990 data from a variety of sources

to create the most comprehensive inventory yet of emissions for the T r ansport

Region. This inventory is the cornerstone for most emi ssions forecasting by the

Integrated Assessment System model.

• The Commission's current mode ling shows improvements in visibility , under

existing regulations and programs, through the year 2000. After that, predicted

gains in visibility are offset by increases in economic activity related to population

increases.

• Regional phenomena can contribute to visibili ty impairment. The

Commission's air quality monitoring data and modeling show that a part of the haze

problem can be caused by long-range transport of emissions. Visibility at Class I

sites on the Colorado Plateau is affected by pollutants that have travelled long

distances, i.e., more than approximately 100 miles. These pollutants often cross the

boundaries of several states within the T ransport Region. Some centrally located

emission sources are frequent contributors to visibility impairment at multiple

receptor sites across the T ransport Region, regardless of wind direction. In addition,

Clean Air Corridors are a regional phenomenon of clear air transport from low

emission areas located to the north.

• There is also a local aspect to the haze problem on the Colorado Plateau.

Emissions from sources located roughly under 100 miles away can affect visibility

at Class I sites. These local-source emissions are less diluted than emissions that

travel long distances. The Commissi o n has an improved understanding of the

conditions th at lead to local source impacts on visibility . For example, local

emissions can build up during windless periods, and are subject to being trapped

above low-lying terrain during temperature inversions. Also, urban areas (Las V egas

and Salt Lake City) have been studied and may have significant 3 impacts on visibility

at the Grand Canyon and Canyonlands, respectively

.23

The Commission's current analyses suggest that visibility impairment caused by local

sources may be much greater than predicted by prior studies. If correct, thes e new

analyses have significant implications for reducing current visibility impairment. In light

of their conflict with prior studies, the Commission's results should be treated with

caution. Y

ears of technical work may be necessary before the relative visibility impacts

of local sources can be confirmed.

• The relative visibility effects of regional and local emissions are variable, but

local emissions have a greater impact per ton emitted. Seasons, weather

conditions, and terrain elevations influence the relative visibility impacts of regional

and local emissions. Both emission types contribute to visibility impairment much of

the year , and either type can be the dominant cause of impairment on any particular

day regardless of the season or t he location of a receptor . There is little doubt,

however , that local emissions have a greater visibility impact per ton emitted than

emissions from distant sources.

• Wildfire and prescribed fire play an important role in visibility on the

Colorado Plateau. During coming years, land managers are projecting significant

increases in prescribed fire in order to reduce the effects of wildfire resulting from

past decades of fire suppression. Therefore, prescribed fire has the potential for

outweighing visibility improvements on an episodic basis.

• Emissions from Mexico are significant and growing, particularly contributing

to the SO 2 emission budget. Without control strategies for Mexican sources, they

will have continuing and growing adverse visibility effects.

• Visibility effects are a combination of emissions and meteorology and other

uncontrollable factors, such as wildfire. Me teorology and wildfire can vary

significantly from year to year

. Therefore, in assessing the visibility gains from an

emissions management strategy

, measurements of visibility from any one year may

not show improvements. Data trends from multiple years are needed. In the short

term, gains or losses in visibility may be better represented by the emissions

inventory than from monitoring data at Class I sites.

• Source areas with large transfer coefficients merit particular attention. The

Commission developed transfer coefficients for 95 source areas a cross the

T ransport Region as a tool to model changes in visibility

. In the simplest sense, each

source area's transfer coefficients represent the mathematical relationship between

emissions in that source area and aerosol concentrations at a sp ecific Class I

receptor

. The Integrated Assessment System model indicates that emissions

reductions will yield the greatest visibility improvements if they occur in source areas

having "large" transfer coefficients and large emissions. Source areas having large

transfer coefficients but low emissions merit increased att ention in emissions

planning. Finally

, for any specific reduction in emissions, source areas with large

transfer coefficients will yield the largest improvements in visibility at Class I sites.24

Summary of Data and Model Limitations

The Commission's technical models are designed primarily to assess the regional impacts

of pollutant transport, i.e., to give a picture of how poll utants travel across the nine-state

T ransport Region . The meteorological and air quality models simulate regional scale

phenomena—such as wind—reasonably well. The models are best at demonstrating the

relative effects of regional emissions on visibility . As a result, the Commission has a reliable

understanding of the relative significance of most regional sources. For example, information

shows that Southern California is the largest regional source of visibility-impairing particles

in the T ransport Region.

Because the Integrated Assessment System models were designed with a regional transport

focus, they offer only limited insights into (1) the absolute contributions to visibility impairment

from "local" sources located under approximately 100 miles of Class I sites, and (2) the

visibility impacts of local sources relative to regional sources. The Integrated Asse s sment

System permits qualitative understanding of local source influences, but does not permit

quantitative understanding. In particular

, the Integrated Assessment System model is not

designed to be used for local source attribution. Accordingly , further study on local sources

should be undertake n prior to enactment of recommendations for emissions controls on

specific local sources.

There are several reasons for the limitations in the Int egrated Assessment System model

concerning local source impacts on visibility

.

• Most of the modeling was done using coarse grid cells measuring thirty miles on

each side. Modeling the transport and dispersion of pollutants between adjacent

cells did not reflect the actual physics of such activity . The Commission used a fine

grid (six mile) for several major sources for a limited period of the modeled year

. While th is approach should improve the model's performance, data and time

limitations made it impractical as a substitute for all of the coarse-grid analysis.

• While the Commission's model reliably simulates the effects of meteor ological

factors on pollutant transport, it does not simulate effects caused by "smaller" terrain

features such as the Grand Canyon.

• The model's projected visibility impacts are scaled to reflect actual measurements.

This means that an inaccurate projection of local influence on vi sibility causes a

distortion of the regional influence.

• The model's projections of pollutant concentrations at Class I areas are generally in

the form of seasonal and annual averages, and the 20% best and worst days. Dayto-day variations in pollutant concentrations are not projected. This is a significant

limitation because visibility changes are insta ntaneous, occurring within hours

depending on meteorology

.25

• In addition, uncertainties in the em ission inventory , meteorology

, atmospheric

chemistry and transport modeling methods, and background assumptions contribute

to uncertainties in the modeled relative contributions of sources in the region.

Although these have not been quantified, they could have a significant effect on the

model results.

One other important limitation invo lves the number of receptors where pollution data were

available. The Commission collected data from only six receptors, and ultimately scaled its

modeling for only four of these: Hopi Point, Mesa V erde, Canyonlands, and Bryce Canyon.

The most detailed information came from one receptor

, Hopi Point in Grand Canyon National

Park. As a result, the Commission has a reliable understanding of visibility impacts at Hopi

Point. However , this single receptor does not provide a comprehensive picture for the entire

Grand Canyon, let alone the other 15 Class I sites on the Colorado Plateau.

Even with these limitations, however , the Commission's models and its technical data and

findings provide an adequate foundation for the recommendations presented in the next

section.26 SECTION III: EMISSIONS MANAGEMENT RECOMMENDA TIONS

GUIDING PRINCIPLES

In developing the set of recommendations that follow , the Commission has been guided by

several general principles.

Achieve Reasonable Progress T oward the National Visibility Goal

The overall goal of the Commission's recommendations is to improve visibility on the worst

days and to preserve existing visibility on the best days, at Class I areas on the Colorado

Plateau. Reasonable progress towards the national visibility goal is achieving continuous

emission reductions necessary to reduce existing impairment and attain steady improvement

of visibility in mandatory Class I areas and managing emissions growth so as to prevent

perceptible degradation of clean air days.

Address All Important Sources of Visibility Impairing Emissions

The recommendations are designed to address all important sources of visibility impairing

emissions.

Apply Emissions Control Measures Equitably

The Commission has sought to distribute the burden of improving visibility in an equitable

manner . No single source or geographic region should be unfairly required to bear costs or

limit expansion while others are not. The Commission recognizes that equity considerations

require that past emissions reductions, current levels of control, technical feasibility

, cost of

controls, the time necessary for compliance, the energy and n on-air quality environmental

impacts, the remaining useful life of existing emissions source s, and other relevant equity

factors must be considered in achieving reasonable progress.

Prevent Future Visibility Impairment by Protecting Clear Days

Key strategies, imbedded in many of the rec ommendations, are aimed at protecting the

present sources of clear days at Class I sites on the Colorado Plateau.

Remedy Existing Impairment by Reducing Present Levels of Emissions

Present emissions that cause visibility impairment must be reduced significantly in order to

improve visibility

.27

T ake a Regional Approach

Strategies for both preventing future impairment and remedying existing impairment demand

regional approaches that can be applied, in a coordinated manner

, by tr ibes, states, and

federal authorities throughout the T ransport Region. Such strategies should be developed in

concert with existing cooperative efforts to assess and manage air quality within the region.

Assume that Existing Federal, T ribal and State Laws Will Remain in Force

The recommendations assume that state, tribal and federal air quality laws, programs, and

regulations will remain in force for the foreseeable future.

Consider Costs and Benefits of Emission Control Measures

The Commission has been guided in most cases by estimates of the costs and improvements

to visibility associated with various strategies for controlling emissions.

Develop Action Plans for All Recommendations

The responsible entities should develop detailed plans for implementing Commission

recommendations.

Provide Funding

S pecific funding sources should be identified for implementing the Commission's

recommendations.

Consider Social, Cultural and Environmental Factors

In analyzing the potential impacts of recommendations, social, cultural and environmental

costs and benefits should be considered.

Note: For tribal perspectives and commentary

on the recommendations in this Section, see

Section IV

.28 AIR POLLUTION PREVENTION

Background: Pollution Prevention as Key to Protection of Western Vistas

The spectacular scenery of national parks and wilderness area on the Colorado Plateau is an

important part of our Nation's natural heritage. We have a legal and moral obligation to protect

this national resource for future generations. Visibility in this region is extremely sensitive to

even small increases and decreases in air pollution.

As the population and economy of the West grow

, the only way to prevent further degradation

of this national resource—as well as the air we share generally throughout the West—is to

combine cost-effective pollution control strategies with a greater emphasis on air pollution

prevention, including low or zero emissions technologies and energy conservation. Because

so much of the T

ransport Region is relatively undeveloped, i ncluding tribal lands, regional

stakeholders have the opportunity to take a proactive approach to pollution prevention. In fact,

given expected growth in the T ransport Region, it provides an excellent place to experiment

with an incentive-based approach to managing not only air quality but other environmental

effects of growth.

As demand for more power increases, and the region's power production base evolves, there

is a tremendous opportunity to realize substantial benefits from energy efficiency , as well as

to integrate cleaner

, sustainable energy technologies into all aspects of our society

. The West

enjoys high potential for renewable energy production, especially electrical energy generation

emp l oying solar and wind power

. The relative cost of renewables is declining over time.

Based on forecasts of electrical energy consumption in the T ransport Region by the Western

Systems Coordinating Council, renewables could supply 18

, 000 gigawatt hours of energy

annually by 2002. Others have suggested that this potential could be much higher

(approaching 50,000 gigawatt hours annually) from renewables (geothermal, solar and wind)

by 2002. These latter targets would still only comprise approximately 10% of region-wide

power consumption. A recent study by the Land and W a ter Fund of the Rockies ( How the

West Can Win

, 1996) suggests that renewable energy could comprise 19% of regional power

needs, by adding additional capacity by 2015. The study also concludes that as much as 40%

of projected power needs in 2015 could be met by improved energy efficiency alone..

Based on estimates of renewable energy potential, achieving the above goals for renewables

and efficiency could result in substantial emissions reductions, which could translate into

visibility improvements, as well as secondary environmental and economic benefits. Although

the Commission did not have the resources necessary to model or completely quantify the

effects of its recommendations in this area, it is convinced that, if implemented, they have the

potential to become some of the most successful and cost-effective contributions to improved

visibility

.

Hastening the utilization of renewables requires new and increased investments, assisted by

economic incentives. Huge economic and environmental benefits from improving energy29

efficiency gains are also poss i ble with adequate commitment and investment, since

investment in energy efficiency is the most cost-effective resource option.

RECOMMENDA

TIONS REGARDING AIR POLLUTION PREVENTION

1. Place a high priority on pollution prevention.

Supporting pollution prevention, education about pollution prevention, and innovative

ways of reducing per capita pollution is one of the Commission's highest priorities.

2. Model the effects of renewable energy and pollution prevention.

Potential emissions red uctions, visibility improvements, cost savings, and secondary

benefits associated with renewables, energy efficiency

, and pollution prevention

should be part of future modeling work.

3. Develop economic incentives for pollution prevention efforts.

Economic incentives a re a powerful tool for effecting change. The Commission

supports creation of incentives that encourage low-emission industries to locate in the

T ransport Region, retooling of industries to reduce emissions and increase their

efficient use of energy

, the development of energy production based on renewable

resources, and pro viding consumers with opportunities to reduce their individual

contributions to air pollution. The Commission recommends that feder al power

management suppliers be given incentives to increase renewable energy generation

and pollution prevention actions, and that public utility commiss ions continue to

influence retail power markets to encourage efficiency and investments in renewables.

4. Encourage zero and near-zero emitting technologies.

The Commission encourages zero and near-zero emitting technologies through

incentives, education and infor mation exchange, such as a clearinghouse.

Opportunities should be explored to promote economic development and job creation

through the development and deployment of such technologies.

5. Provide incentives for actions beyond compliance.

Incentives should also be provided to reward efforts that go beyond compliance and/or

achieve early compliance with air pollution-related requirements.

6. Consider charging emission fees.

A variety of market approaches should be analy zed. Emission fees could be

charged for pollution emitted into the air to encourage people and industry to reduce

pollution in the most efficient manner possible. Revenues could be used to substitute

for taxes on property or income or to provide financial assistance to those industries30

or communities wishing to implement pollution prevention projects . Emission fee

caps that exist in some states should be analyzed.

7. Support development of renewable energy sources.

The Commission promotes the transition to power produ c tion based on renewable

resources such as wind, solar

, biomass, and geothermal resources and supports the

establishment and tracking of annual goals for incr e ases in renewable power

generation in the T ransport Region that fosters the sustained, orderly development of

renewables in the region. Specific areas should be identified where renewables have

the potential to supply power where it is now lacking and where renewables are most

cost-effective. Encouraging development of renewables has particularly high potential

for tribal lands (see page 69). The goal of the states in the T ransport Region should

be to achieve annual additions in order that renewables will c omprise 10% of the

regional power needs by 2005 and 20% by 2015.

Progress towards this goal should be evaluated every five years, in conjunction with

regular reviews of emissions reductions and progress toward the national visibility

goal. Incentives provided by tribal, state and federal governments may be necessary

to achieve t his goal. In the interests of equity , the Commission recommends that

spending and investment in energy research and development should be equalized

among fossil fuel-based and renewable energy prog rams. The EP A should

coordinate with the Department of Energy to achieve funding for the range of

pollution prevention programs authorized by the Energy Policy Act and administered

by the Department of Energy's Center of Excellence for Sustainable Development.

All new power generation projects should include a percentage of renewables

associated with them, in order to help achieve regional renewable energy portfolio

goals.

8. Promote energy conservation.

The Commission supports the continued development and implementation of national

energy efficiency standards for motors, appliances and lighting and recommends the

national adoption of California energy efficiency standards. The Commission also

supports the construction of energy efficient buildings, both residential and commercial,

and proposes the reinstatement of incentives for building energy efficient structures

similar to those in place during the early 1970s. The Commission also suggests the

continuation of demand-side management programs, despite current funding

restrictio ns. The Commission recommends that continuing attention be paid to

maintaining the role of energy conservation within the changing electric power industry

markets. Energy conservation programs should be preserved and expanded through

such mechanisms as "system benefit charges" paid at the distribution level, rather than

in the comm odity electricity rate. This approach would be equitable and would not

disadvantage utilities in relation to their competitors.31

9. Promote education and public outreach efforts on preventing pollution.

The Commission encourages the integration of pollution-prevention and renewable

energy concepts in elementary

, secondary

, higher and continuing education programs

and in public environmental education efforts. T eaching by first-hand example, through

the incorporation of energy efficient technologies at school facilities is encouraged.

10. Introduce product labeling.

The Commission recommends a market-based approach to pollution prevention and

energy conservation and efficiency through "green pricing." The EP A, the Federal

Energy Regulatory Commission and the states should institute labeling, on a voluntary

basis at first, but potentially based on national standards, that provides consumers with

information about the pollution potential, energy requirements and relative efficiency

of products. V oluntary product labeling can be beneficial to businesses by providing

more consumer information and improving product attractiveness in the marketplace.

Such approaches could begin with a limited scope, such as providing information to

consumers about the characteristics of their sources of electric power generation.

1 1. Promote the use of clean fuels.

The Commiss ion also supports the regional use of cleaner-burning fuels, including

reformulated gasoline and diesel and extending towards natural gas, electricity and

hydrogen.32 ST A TIONAR Y SOURCES

Background

Emissions from stationary sources throughout the T ransport Region cont r ibute in varying

de grees to light extinction in Class I Areas. The extent to which these sources produce

pollutants that impair visibility is a function of the size of the source and its location in relation

to the protected areas. The GCVTC analytical work addressed three species of pollutants that

are significantly produced by stationary sources: sulfates, nitrates and organic compounds.

Thi s section of the recommendations proposes a program to deal with all species, but

focuses on sulfates, which are the most significant contributor to visibility impairment of the

three.

Because of the significance of the role sulfates have played in the Commission's studies and

analyses related to visibility

, more information is availabl e related to sulfates and their

relationship to light extinction. Additionally , because SO 2 , the dominant precursor to sulfates,

is associated with a relatively small number of large sources, trends in emissions can be

forecasted with a relatively high degree of certainty . Moreover , the Commission is aware of

efforts to restructure the utility industry and should monitor its impact on regional visibility

.

The stationary source proposal envisions relying on the implementation of current programs

through the year 2000 before the implementation of a new regulatory program. Current

programs include those mandated by the federal Clean Air Act and by states and tribes that

have resulted in or are expected to result in the installation of significant emission control

technologies with associated emission reductions. The Basel i ne Forecast Scenario

conservatively estimated only a 6% reduction (13% in the T ransport Region) in the emissions

of sulphur dioxide (SO 2 ) through the year 2000. However

, implementation of current programs

could result in greater reductions in SO 2 emissions in the short term. In particular , a number

of open issues with a bearing on the visibility problem could be resolved prior to 2000. These

include the “source attribution” studies at the Centralia, Mohave and Hayden power plants,

greater than expected emission reductions in the copper smelting industry

, and the imposition

of lower fuel sulfur standards. With these additional reductions not anticipated by the Baseline

Forecast Scenario, it is estimated that actual SO 2 reductions could be closer to 20-30%.

A major component of this proposal is that, if a regulatory program is deemed necessary

, it

may be an in centive-based trading program (e.g., including, but not limited to, a markettrading program.) It is the intent of this recommendation that any trading program include as

many source categories and species of pollutants as is feasible and technically defensible.

This preference for a “comprehensive” market is based upon the exp ectation that a

comprehensive program would be more effective at improving visibility and would yield more

cost-effective emission reduction strategies for the region as a whole . However , the

Commission recognizes that the inclusion of multiple pollutants and sources, as well as interpollutant/sector trading, raises a number of complex issues (e.g., emission inventories, validity

of reductions, etc.) that would need to be addressed before multiple sources or pollutants

could be included.33

The Commission also recommends that any incentive program contain specific provisions to

encourage and reward early emission reductions, including reductions achieved before 2000.

The Commission recognizes the potential impact this will have on less-developed areas,

including Indian lands. Also, the program should include incentives for emission reduction

measures that go beyond pollution controls (e.g., investment in renewable energy and energy

conservation measures.)

RECOMMENDA

TIONS REGARDING ST A TIONAR Y SOURCES

The objectives of the approach outlined below are:

• to achieve significant reductions in sulfur dioxide emissions in the near term;

• to ensure reasonable pr o gress toward the national goal through continuing

decreases in sulfur dioxide emissions over the long term; and

• to avoid increases of other visibility-red ucing pollutants within the T r ansport

Region as a whole from stationary sources.

The Commission believes these objectives are best achieved by relying on diligent

implementation of current regulatory requirements in the short term while working to

develop an incentive-based approach to ensure long-term protection.

The following specific recommendations are presented with the recognition that the

tr ibal participants support these recommendations and have offered additional

concerns and recommendations in Section IV of this report.

1. Implement existing Clean Air Act requirements through the year 2000.

Implementation of existing Clean Air Act requirements is expected to result in a significant decrease in sulfur dioxide emissions and their contribution to light extinction

in the short term (1990-2000). Because some of these reductions are associated with

the installa tion of SO 2 control equipment currently under construction, they can be

projected with a very high degree of confidence (e.g., a 6% reduction in the total SO 2

emissions inventory resulting from emissions reductions at the Navajo Generating

Station). In addition to these known reductions, the rate of SO 2 emissions decline will

be influenced by ongoing source attribution studies and decisions similar to "best

available retrofit technology" in the T ransport Region , as well as other factors

mentioned above. By the year 2000, the amount of SO 2 emissions reductions achieved

(or represented by enforceable commitments) could be in the range of 20-30%. These

pending matters may also affect the amount and rate of SO 2 emission reductions that

will occur after the year 2000. States and tribes are encouraged to review the visibility

impacts at Class I sites on the Colorado Plateau of uncontrolled pollution sources and

make expeditious determinations regarding the need for additional pollution controls

pursuant to the Clean Air Act. T o the extent decisions are made to require additional4 These "targets" are intended as firm limitations on emissions and have the same ef fect as a "cap."

However, we are reserving the term "cap" to refer to the limits set un der a regulatory program which would be

triggered if the "targets" are exceeded.

5 For example, the ut ility industry is committed to achieving the current baseline projections of 73%

reductions in SO

2 emissions from utility sources by 2040. All projected percentage reductions in SO

2 emissions

within the Transport Region will need to be verified by an updated assessment of the Baseline Forecast

Scenario in the year 2000. Some stationary source categories require additional detailed analysis in order to

produce more reliable projections. For this reason, the percentage reductions in stationary sources as a whole

are expressed here as a range.

34 emission reductions at existing facilities, the Commission supports the adoption of the

best, most cost-effective strategies.

2 . Establish stationary source emission tar gets 4 as regulatory triggers.

a) An SO 2 emissions tar get for stationary sources will be established

effective in the year 2000. The level of the target would be calculated

by (1) determining the amount of emission reductions that has actually

been achieved (or legally committed to) between 1990 and 2000; (2)

comparing the actual reduction to the 13% reduction from 1990 actual

emission levels that was projected by the Baseline Forecast

Scenario; (3) assuming the actual reduction is higher than the

projected reduction, set the emissions target at a level midway

between the projected and actual, unless any affected party convinces

the Commission or its successor that a different distribution is needed

(e.g., emissions growth in undeveloped areas, operational flexibility

needs, deteriorating visibility). As part of this calculation, the 1990

emissions inventory will be compared to the reported emissions to

1995/1996 data no w available from sources (all utilities and many

stationary sources have Continuous Emission Monitors).

b) An ultimate SO 2 emissions target for the visibility T ransport Region

will be established for the year 2040 that locks in the 50-70%

reduction in SO 2 emissions projected by the Baseline Forecast

Scenario. 5 Interim targets may also be needed to ensure steady and

continuing emission reductions and to promote investment in pollution

prevention (in accordance with five year review periods as described

in #4 below).35

c) V ariou s emissions management options for stationary source NO

x and PM will be explored, including considering the establishment of

emission targets, in order to avoid any net increase in these pollutants

from stationary sources within the region as a whole and to provide a

foundation for future incorporation into a multi-pollutant and possibly

multi-source market-based program.

3. Develop a plan for allocating trading credits under a regulatory program

emissions cap.

a) Development of an equitable plan for allo cating the trading credits

a mong existing and future sources will be accelerated. The

Commission expects that the targets will be met based on existing

commitments and other actions that are likely to be required because

of ongoing source attribution studies. However , in order to create

economic incentives for early reductions as well as to provide

flexibility and certainty to sources in planning futu re actions,

participants in the Commission's process are committed to designing

the plan before the EP A takes final action on the Commission * s

recommendations so that the el ements of that program can be

incorporated into the federal regulatory program. (The estimated date

for completing development of the program is June, 1997). A number

of factors will be considered in developing the program, including

measures to:

• prevent new sources from causing the target to be exceeded;

• account for sources which achieve emission reductions early or

have achieved maximum control efficiency;

• ensure that all allocations to tribal lands, rural areas and relatively

undeveloped areas (e.g., clean air corridors) are of practical

benefit; and

• account for the effects of increases or decreases of emissions

on visibility

.

b) In order to generate information for development and implementation

of the inc e ntive-based program, owners and operators of existing

facilities located within the T ransport Region sho uld: (1) by 1997,

notify states and tribes of existing or planned pollution control or

prevention measures; and (2) report biannually on efforts that are

b eing made to manage their emissions or engage in oth e r

transactions to voluntarily meet their emissions reductions

responsibility per the trading credit allocation scheme. These plans

would not be incorporated as enforceable permit conditions or SIP

revisions except as noted below

.6 Reductions actually achieved or subject to legally enforceable commitments will be included in determining

whether the cap has been exceeded.

7 See footnote above.

36 4. Review compliance with targets and establish incentives.

Progress in complying with the emissions target(s) would be assessed in the year

2000 and at five-year intervals thereafter

.

a) In 2000, or any

subsequent five-year review period, if the regional

target in effect at that period has not been e xceeded no additional

regulatory program will be required. 6 Any source that has contributed

significantly to achieving the nee ded reductions by going beyond

co mpliance or achieving early reductions will be rewarded. For

instance, the following rewards could be included:

• an exemption from any interim target requirements that might be

established;

• streamlined treatment in the permitting process;

• ability to bank emissions; or

• bonus allowances if credits are used to achieve development on

tribal lands or other areas that are relatively undeveloped.

Incentives will be further developed and included in the design of the

program.

b) In 2000, or at any subsequent five-year review period, if the regional

emissions target has been exceeded 7

, a regulatory program (most

likely an emissions cap and incentive-based market trading program)

will be imp lemented. Any source that is exceeding the emission

allocation presented in the plan will have no more than five years to

come into compliance and any reductions achieved will be

discounted. Other disincentives will be developed and included in the

design of the program.37

5. Complete source attribution studies.

The Commission strongly encourages the EP A to complete, within one year , the

source attribution study currently underway at the Mohave Power Project. Further

, the

Commission strongly encourages the EP A to take action consistent with the results

of that study within twelve months of its completion. The Commission supports the

commitment by the Mohave Power Project to maintain voluntarily its emissions at or below current levels (e.g., an average of the past two year's emission levels).

6. Develop an improved monitoring and accounting system.

A major deficiency in the technical analysis associated with the GCVTC activities

has been the lack of adequate and reliable monitoring data. In order for any visibility

policy to be effective, there must be an adequate benchmark of existing conditions

against which to measure progress. T o obtain a better understanding of visi bility

throughout the Colorado Plateau, Class I areas other than Hopi Point in the Grand

Canyon need to be included as receptors in visibility modeling and additional

monitoring sites should be established.

Emissions in the T

r ansport Region provide another benchmark against which to

measure progress. An accurate and credible emissions accounting method will be

essential in determining compliance with the emissions targets or caps.

Shortcomings in the emissions inventory need to be remedied, and a method for

routinely tracking emissions needs to be developed.

It is critical that the emissions monitoring and tracking system be developed quickly

so that emission reductions achieved between now and the year 2000 can be

recorded and so t hat those areas that are presently lower-emitting can receive

appropriate credit. If an incentive-based regulatory program is implemented after the

year 2000, early emission reductions achieved before the year 2000 should be

awarded credit, provided established criteria are satisfied.38 MOBILE SOURCES

Background:

Emissions from mob ile sources—including both light- and heavy-duty vehicles, marine

vessels, trains, and airplanes—contribute to visibility degradation on the Colorado Plateau.

Although the relative contribution of mobile source emissions is generally not as large as the

contributions of some other sources, direct emissions and re-entrained road dust from motor

vehicles contribute significantly to urban plumes that are tran sported across the Colorado

Plateau. Emissions from an automobile manufactured today are substantially lower—better

than 90% lower

, on a per-vehicle-mile traveled basis—than emissions from one manufactured

thirty years ago, in large part due to the Federal Motor V ehicle Emission Control Program in

the Clean Air Act and the California motor vehicle emissions control program. However , the

number of vehicles and the total vehicle miles traveled have increased dramatically

. This trend

is expected to continue. And while NO

x and PM emissions from heavy-duty on-road diesel

engines have been reduced 70% and 95%, respectively , since the early 1970's, emissions

from interstate and cross-border truck traffic and urban delivery and transportation vehicles

continue to contribute significantly to total emissions.

Reducing total mobile so u rce emissions is an essential part of any long-term emissions

management program to protect visibility in the western United States generally and on the

Colorado Plateau specifically

. Further reductions can be achieved through a combination of

national, regional and local actions.

RECOMMENDA

TIONS REGARDING MOBILE SOURCES

1. Adopt an emission management objective and establish a regional

emissions budget.

The objective of the recommended strategies desc ribed below is to reduce

emissions of VOC, NO

x , elemental carbon, and fine particulates from the mobile

source s ector and then hold them constant. T o the extent that mobile source

emissions contribute significantly to visibility impairment in the Class I areas of the

Colorado Plateau, an emissions budget should be established for any area with a

significant contribution, beginning in the approximate year in which emissions are

projected to reach a minimum, or 2005. The emissions budget should serve as a

regional planning objective and performance indicator

.39

2. Develop a system for tracking emissions.

In order to periodically assess progress, a system for tracking emissions will need

to be developed. That protocol should take into account the relatively rural nature of

much of the area within the T ransport Region and not impose unnecessary burdens

on small communities, including tribal lands, with air quality bet ter than national

ambient air quality s tandards. National and regional initiatives should ensure

compliance with the regional emissions budget.

3. Suggest targeted local actions.

In addition to national and regional strategies, targeted local actions are needed to

reduce mobile source emissions within the Colorado Pl ateau's Class I areas, in

adjacent communities, and in major urban areas that contribute sign ificantly to

visibility impairment. If the strategies described below and elsewhere in this report

do not keep emissions within the emissions budget, options for expanding and

increasing the accountability of the relevant authorities will need to be considered

and implemented.

Recommended National Strategies

Introduction to Recommended National Strategies

Most of the mobile source-related emissions reductions achieved to date have been

brought about by increasingly stringent tailpipe and evaporative emissions

standards. Further progress in reducing mobile source emissions outside of

California can only be achieved through action on a national level. Although it would

be difficult to justify a national-scale program based strictly on the impact on the

Colorado Plateau, there are numerous initiatives and proposals to address urban

ozone non-attainment problems already being considered for national

implementation that would benefit air quality in the Colorado Plateau's Class I areas.

The EP A should ensure the coordination of the Commiss i on's efforts related to

national standards and programs with other regional organizations (e.g., Ozone

T ransport Commission/Ozone T ransport Assessment Group), because there may

be synergies or conflicts among technologies or fuels aimed at different air quality

goals.

The Commission promotes the following initiatives on a national level:

1. Adopt 49-state LEV standards.

The Commission supports adoption of the nationwide Low Emission V ehicle

standards (49-state LEV), beginning in 2001, and adoption of federal T i er II8 In March 1996, the California Air Resources Board confirmed an agreement with the largest automobile

manufacturers to sell nationwide only cars and light trucks which meet standards equivalent to California's Low

Emission Vehicle (LEV) sta ndards, beginning in 2001. This action was part of a larger agreement in which

the se manufacturers were given greater flexibility in introducing Zero Emission Vehicles (ZEVs) prior to 2003

in California.

9 The heavy duty engine manufacturer s, the U.S. EPA and the California ARB signed a statement of principles

in July 1995, committing to the introduction of a NO

x standard of 2.0 grams per brake-horsepower hour by 2004,

compared to the 1998 CAAA requirement of 4.0.

40 standards in 2004 8

, if determined to be more effective. In the time frame to 2040, the

Commission supports the promotion of ultra-low and zero-emission vehicles.

2. Support development of heavy-duty vehicle standards.

The Commission supports the EP A's current proposal to fu rther reduce NO

x and

particulate emissions from ne w on-road, heavy-duty vehicles by at least 50%,

compar ed to the 1998 requirements contained in the 1990 Clean Air Act

Amendments , while maintaining current stringent PM emission limits. 9 The

Commission re q uests the EP A to pursue additional PM reductions from on-road

vehicles.

3. Negotiate and adopt off-road vehicle standards.

The Commission requests that the EP A continue to pursue the adoption of

additional engine emission standards for new off- road vehicles (heavy-duty

, construction-type) that provide reasonably achievable reductions.

4. Promote broader application of cleaner fuels.

T he Commission requests that the EP A explore broader applicatio n of and

additional reductions in the sulfur content of both gasoline and diesel fuel. The

Commission also supports the promotion of cleaner burning fuels as discussed in

Recommendation #1 1 on page 31.

5. Pursue strategies for diesel locomotives, boats, airplanes and federal

vehicles.

The Commission requests that the EP A pursue fuel standards and control strategies

for diesel locomotives, marine vessels/pleasure craft, airplanes and federal vehicles.

States and tribes are preempted fro m controlling most emissions from these

sources. Emissions from these categories are relatively uncontrolled compared to

other mobile sources (e.g., light-duty cars and trucks) and will continue to increase

with population and economic growth. In particular , the EP A should:41

a) promulgate national NO

x , HC and PM standards for "captive fleet"

marine vessels and work with the International Maritime Organization

to reduce emissions through international standards;

b) finalize the proposed HC standards for recreational boats and

personal watercraft;

c) adopt NO

x standards for new and remanufactured diesel locomotive

engines;

d) strengthen existing national HC standards for aircraft engines;

e) adopt stringent national NO

x standards for aircraft engines; and

f) pursue emission control strategies, such as alternative clean fuels, for

all federal fleets.

6. Support improved control of evaporative emissions

The Commission supports requirements for effective refueling vapor recovery systems

that capture evaporative emissions.

Recommended Regional Strategies

Introduction to Recommended Regional Strategies

T o the extent that mobile source emissions from certain areas are found to contribute

significantly to visibility impairment in the Class I areas of the Colorado Plateau, an

emissions budget should be established, beginning in the approximate year in which

emissions are projected to reach a mi nimum, or 2005. As mentioned above, a

protocol for in ventorying and tracking emissions will need to be developed. The

adoption of more string ent national standards as noted above would help maintain

compliance with the regional mobile source budget. In addition, the Commissioners

promote incentives for the use of clean fuels on a wide basis. Economi c pricing

strategies should als o be analyzed for implementation on a regional scale. The

analysis should include an examination of the extent to which certain populations (for

instance, rural communities, low-income groups or tribes) may be disproportionately

affected. In the event that inequities are identified, alternati ve strategies should be

developed to address the particular needs of those populations. The initiatives which

follow should be pursued.

1. Establish clean fuel demonstration zones.

The feasibility of providing incentives for clean fuel demonstration zones or corridors

for heavy-duty trucks and buses should be assessed by 1998. For example, and at a

minimum, incentives for converting vehicles used for mass transportation and delivery1 0 A privately-initiated effort is already under way to establish LNG fuel stations along the I-15 corridor from

Salt Lake City to St. George, Utah and along the I-15, I-5 and I-80 corridors between Salt Lake City, Los

Angeles and Sacramento. Efforts are also under way in Southern California for electric vehicles and hydrogen

corridors. The Commission supports thes e and similar efforts. If the establishment of a regional mobile source

emissions budget leads to development of a market-based progra m, the Commission should support the

awarding of emissions reduction credits to private entities involved in these types of efforts.

42 within national parks on the Colorado Plateau, as well as in nearby urban areas, to

CNG, LNG, LPG or alcohol-based fuels should be provided. In addition, the Western

states should cooperatively:

a) explore the feasibility of establishing alternative fuel corridors in urban

areas and along major trucking routes (e.g., I-15, I-5, I-80, and I-40); 10

and

b) conduct an analysis comparing the relative emissions from trucks and

trains (including tail pipe/stack emissions as well as road dust, tire

wear , etc.).

2. Analyze pricing and incentive approaches.

A reg ional analysis of economic pricing and incentive approaches should be

conducted by 1998, including an analysis of equity effects of such approaches, that

could be used to reduce reliance on vehicle use and better internalize the true cost

of operating motor vehicles. If such programs were implemented and generated

revenue, these funds could be rebated to drivers (for instance, as a credit against

state income or property taxes), used to develop multi-modal transportation options,

or used to help maintain the existing highway infrastructur e. The Commission

supports states that are implementing programs to curtai l visible emissions and

encourage region-wide adoption of these programs.

3. Explore an inspection program for heavy-duty vehicles.

T ruck traffic contributes to regional visibility impairment, including haze in the Class

I areas in the Colorado Plateau. The Commission supports development of options

and opportunities for implementing an emissions inspection programs for heavyduty

, on-road vehi cles that routinely travel the highways in the T r ansport Region.

Within the limitations of existing interstate commerce regulations and the North

American Free T rade Agreement, the states and tribes could explore programs to

assure compliance with in-use emission requirements, including vehicles involved

in cross-border transport.43

4. Promote vehicle maintenance.

The Co mmission also encourages local authorities to mount public education

campaigns to inform citizens of the air q uality advantages of maintaining their

vehicles properly

. It is critical for control of mobi le source emissions that all

components of a vehicle's emissions control system be maintained according to the

manufacturer's specif ications as detailed in the owner's manual. Such a public

education effort could be coupled with implementation of a mechanics' training and

certification program and state-of-the-art vehicle inspection and maintenance

programs.

Recommended Local Strategies

Introduction to Recommended Local Strategies

Decisions as to how to achieve emissions objectives are best made at the local or

metropolitan level. However

, th e Commission recognizes that mobile source emissions

from some areas have a disproportionate impact on visibility in the Colorado Plateau

Class I areas. Strategies for addressing mobile source emissions within Class I areas

and in adjacent communities are discussed elsewhere in this report. In addition, major

metropolitan areas located near the Colorado Plateau must be encouraged to take

actions to reduce in-use vehicle emissions. The types of programs described below

would be targeted initially at these areas, but consideration should be given to

extending their application on a b roader scale to achieve regional air quality

objectives. Any such extension would be preceded by an analysis of the equity effects

associated with these types of programs in non-urban areas.

1. Promote incentives for innovative and effective approaches.

The Commission challenges states and tribes with major urban areas to develop

funding and other incentive-based schemes that give priority to allocating discretionary

funding to transportation projects that are consistent with the goal of reducing reliance

on single-occupant vehicles. For example, governors could exercise fiscal discretion

(e.g., preferential allocation of state highway/transit, open space, economic

development/enterprise zone funds or rebates of state fees) to reward communities

that find appropriate or innovative ways of reducing reliance on single-occupant

vehicl es. Examples include land use ordinances that favor development in existing

transit/transportation corridors, high density development needed to ensure the viability

of mass transit, and co-located residential, business and commercial development to

support non-vehicular modes of transportation. If possible, this incenti ve-based

approach with state funds could be coupled with a similar preferential allocation of

discretionary federal funding to states and tribes that develop appropriate approaches.44

2. Encourage better integration of transportation, land use and air

quality planning.

In order to avoid incremental degradation of visual air quality as the population and

economy of the West continue to grow , the Commission encourages sustainable

community and economic development by:

a) promoting multi-modal transportation options through both public and

private investments;

b) encouraging local, state and tribal governments to reduce or eliminate

entry and rate regulation s in the transit industry as a means of

fostering greater competition;

c) establishing a clearinghouse for information about sustainable

communities and methods for integrating multi-modal transportation

systems with land use planning; and

d) sponsoring conferences on transportation, land and air quality issues

generally (e.g., to showcase various communities' eff orts), and

transportation alternatives within a nd between Class I areas in the

Colorado Plateau specifically

.

3. Establish mobil e source emissions budgets for selected major

urban areas.

T o the extent that mobile source emissions from certain major urban areas are found

to contribute significantly to visibility impairment in the Colorado Plateau's Class I

areas, the Commiss ion requests that local emissions budgets be developed

specifically for mobile sources. (Most areas are already required to do this under the

CAAA for purposes of assuring conformity of transportation plans and programs.)

Methods for managing mobile source emissions budgets need to be explored further

. Regardless of which approach is taken, th ere must be developed a credible and

replicable way of inventorying, tracking and reporting emissions.

a) Develop analytical criteri a and accounting methods for

implementing emission budgets.

If the proposed emission budgets allow an increase in current emission

levels, an analysis will be needed to assess whether the budgets ensure

protection of NAAQS, PSD increments, and visibility in downwind Class

I areas. In this event, the Commission would develop crit eria and an

ana lytical method for conducting such an analysis, and establish

requirements for adjusting urban emission budgets found to be inadequate

to protect downwind areas, as well as ac counting and enforcement

mechanisms.45

b) Consider use of pricing strategies.

The economic pricing analysis called for above may indicate that the most

efficient method of complying with emissions budgets would be to institute

pricing strategies for use of roadways that internalize the cost of operating

motor vehicles so that individuals have an incentive to modify their travel

behavior

. The consideration of such pricing strategies should take into

account the possibility that incremental changes in price, in absolute dollar

terms, will have a larger effect on rural areas and lower-income

populations.

c) Develop an accounting system for market-based programs.

If some sort of ma rket-based program is deemed appropriate,

accountability for com plying with the emissions budget must be clearly

assigned, with consequences attached to failure to main tain emission

levels consistent with the budget. For example, emissions from mobile

sources could be aggregated and responsibility for mana ging them

delegated to a private or public "broker", or assigned to a local/ regional

governmental entity

. Alternatively

, individu als (including businesses,

government agencies, etc.) could be given responsibility for managing

em issions from vehicles they own or control. In any event, if emissions

trading were allowed, credible methods would be needed for certifying the

validity and value of emissions reductions at the start of the program and

ensuring their permanence over time.

4. Suggest retiring high-emitting vehicles.

The Commission suggests that local authorities consider the advantages of retiring

higher polluting v

e hicles and develop incentives for citizens to upgrade to newer

, less polluting cars and trucks.46 AREA SOURCES

DUST FROM P A

VED AND UNP A

VED ROADS

Background:

Chapter II of the Commissions November 1995 report, Options for Western Vistas

, discussed

the limitations of the Integrated Assessment System results with respect to p aved and

unpaved road dust. More recent modeling has shown that local sources of road dust play a

more important role than distant sources. The Commission has considered this issue and has

concluded that there are good reasons to discount th e Integrated Assessment System's

predictions about the regional importance of t his source of emissions until more study is

completed. For example, the large magnitude of emissions projected for this source are tied

to projections of future growth in population and vehicle-miles-traveled, whereas road dust

effects on visibility are generally localized, especially with respect to large, coarse material

which settles out of the air relatively close to roadways.

RECOMMENDA

TIONS REGARDING DUST FROM

P A VED AND UNP A

VED ROADS

Actions to address the control or reduction of emissions related to road dust are

found in the recommendations regarding emissions "In and Near Class I Areas." The

Commission further recommends that voluntary measures be taken in local areas

in and near Class I areas to control emissions of dust from pa ved and unpaved

roads. Consistent with other Commission recommendatio ns, there is also a

recognized need to develop an accurate emissions inventory and an improved air

quality model for controlling or managing this specific source sector

. Finally

, if

visibility impacts are validated, the Commission recommends that per f ormance

standards for road dust emissions be developed.

Due to considerable skepticism regarding the modeled contribution of road dust to

visibility impairment, the Commission recommends further study in order to resolve the

uncertainties regarding both near-field and distant effects of road dust, prior to taking

remedial action. Since this emissions source is potentially such a significant

contributor

, the Commission feels that it deserves high priority attention and, if

warranted, additional emissions management actions.47 FIRE

Background: Fire Emissions and Visibility

Fire has played a major role in the development and maintenance of most ecosystems in the

West. The long-term future of the West is dependent on healthy ecosystems that are capable

of sustaining natural processes and human uses.

An increase of accumula ted forest fuels in the West has occurred because of past land

management practices, including decades of fire suppression. Evident ecosystem changes

include increasing tree densities, disrupted nutrient cycling, and altered forest structure. As

a result, wildfires are becoming larger in size, unnaturally destructive, and more dangerous

and costly to control. In 1994, wildfire burned 3.1 million acres in the West and cost $1 billion

dollars in direct suppression costs while causing firefighter deaths and serious human health

impacts. Rectifyin g this problem will take years and is a basic responsibility of wise land

stewardship. Fire is an essential component of most natural systems, and perpetuation of fire

at a level required to maintain ecosystem processes is necessary . The natural role of fire in

the wildland/urban interface must also be addressed to protect life and property

. A substitute

for fire and its natural role has not been found in many ecosystems. The objective of future

prescribed fire programs is to cooperatively meet land management, human health and

visibility objectives.

Emissions from fire (wildfire and prescribed fire) are an important episodic contributor to

visibilit y-impairing aerosols, including organic carbon, elemental carbon, and particulate

matter (PM 2.5 ). Agricultura l burning emissions and their effects have been identified as a

concern of the GCVTC but have not been quantified due to a lack of data. All types of fire

(prescribed fire and agricultural burning) must be addressed equitably as part of a visibility

protection strategy

. This may require state legislation in some cases.

Discussion of Management Alternatives

Wil dfire impacts are increasingly uncontrollable or unmanageable, due to excessive fuel

loads, except through the application of prescribed fire and/or mechanical means, such as

brush removal and logging. Field experience has shown that prescribed fire can reduce the

size, frequency

, and intensity of wildfires. Areas that have been treated with prescribed fire

demonstrate much les s burning in the tops of trees and a slowing of wildfire spread.

Prescribed fire therefore promotes better fire control, predictable fire effects and allows for

management of emissions as compared to wildfire.

The future use of prescribed fire and the restoration of fire in its natural role with natural fuel

loadings will provide sustainable ecosystems where environmental and human health impacts

can be managed. This future desired situation contrasts with the current adverse public health

impacts and permanent damage to natural resources and property from wildfires. Wildfires

are causing exceedances of ambient air quality standards and air quality-triggered community

evacuations with greater frequency

. Prescribed fire programs will influence future wildfire in

many locations of the West. However , infrequent large-scale forest replacement wildfire will

still occur naturally in some vegetation types.48

Land managers employ emission reduction and smoke management techniques to reduce

air quality impacts of prescribed fire. Current smoke management techniques take into

account the timing and location of burns so that impacts on human health are reduced. These

techniques can be expanded to reduce current and future impacts on visibi lity . Emission

reduction tec hniques can also be utilized to reduce the quantity of emissions from a

prescribed burn. The appropriateness and effectiveness of emission reduction techniques

vary based on vegetation type, burn objectives, location, other environmental constraints such

as water quality

, and funding. Effective agricultural smoke management programs have been

developed in some states using similar measures.

Utilization of mechanical treatments such as logging or firewood sales to remove fuels will be

necessary in some areas prior to prescribed burning. The p o tential use of mechanical

treatments is limited, however , since large areas of the West are not physically available due

to inaccessibility

, slope or soil sensitivity

. Significant emission reductions from mechanical

treatment would only occur in timber areas. Administrative constraints, such as wilderness or

habitat protection, also impose limitations. Approximately 30% of the total timber area has the

potential to be treated using mechanical methods. In areas where mechanical treatments are

used alone, some level of prescribed fire treatment may still be necessary . Mechanical

treatment cannot replace the natural role of fire in ecosystem health and sustainability

processes.

In order to address the fuels problem and ensure adequate protection of visibility in the West,

funds will need to be greatly increased. With the development of increased prescribed fire

programs, it is crucial to fund smoke management programs that protect public health and

visibility , while meeting the underlying land management objectives.

RECOMMENDA

TIONS REGARDING FIRE

1. Plan for the visibility impacts of smoke.

The Commission recommends that the EP A require all federal, state, tribal, and private

prescribed fire programs to incorporate smoke effects in planning and application by

the year 2000.

2. Implement an emissions tracking system for all fire activities.

A consistent emissions tracking system for prescribed fire, wildfire, and agricultural

burning should be implemented region-wide.

3. Improve integrated assessment of emissions.

Federal, state, tribal and private land managers, in conjunction with relevant regulatory

agencies and interested parties, should improve the current integrated assessment of

emissions from prescribed fire , wildfire and agricultural burning by 1999. The

assessment should:1 1 I n identifying areas where alternatives to burning are appropriate, it is not the intent of the Commission

to require actions that are inconsistent with applicable laws or regulations.

49 a) identify specific areas where fire activities have or coul d have an

adverse impact on health and visibility;

b) identify areas where mechanical treatmen t s could substantially reduce

emissions and subsequent impacts on health and welfare;

c) in the areas identifie d, assess the feasibility of biomass utilization

(woody material use), market development, and non-statutory

administrative barriers 1 1 ; and

d) assess meteorological information needs, air quality monitoring

needs, smoke dispersion model ne eds, interstate planning needs,

wildfire /prescribed fire trade-offs (economics, air quality and other

resource effects), and emission factor research (vegetation/fuels and

effects of emission reduction techniques).

4. Enhance smoke management programs.

The Commission recommends the development and implementation of criteria and

requirements for the use of enhanced smoke management program s (including

alternative management practices) and emission reduction strategies in the identified

areas. Such programs should consider factors of efficiency , economics, law

, land

management objectives, and reduction of visibility impacts. States, tribes, state and

federal land management agencies and private parties should create and implement

smoke m anagement programs that address public health, visibility and land

management objectives by the year 2000, using the results of the assessment listed

in Recommendation #3.

5. Develop cooperative funding mechanisms.

The Commission promotes the development of cooperative funding mechanisms

bet ween burners and regulatory agencies to implement increased smoke management

programs and integrated assessment costs.

6. Promote public education programs.

The Commission supports the creation of a public education program regarding the

role of fire in air quality

, to be undertaken by land managers and other interested

governmental and private groups.50

7. Establish annual emission goals for fire programs.

The Commission recommends that annual emission goals for all fire programs,

where appropriate, be established by the yea r 2000. These goals will be set to

minimize emission increases from such programs to the maximum extent feasible.

The goals will be established cooperatively by states, tribes, state and federal land

management agencies and their private sector counterparts.

8. Remove administrative barriers to the use of alternatives to burning.

The Commission recommends that the federal land management agencies and their

state, tribal, local and priva te counterparts identify and remove non-statutory

administrative barriers to emission re duction strategies by the year 2000, to the

maximum extent feasible. In removing such barriers, the Commission intends that

subsequent actions will be undertaken cons istent with applicable laws and

regulations.51 CLEAN AIR CORRIDORS

Background

One finding of the Commission's process is that clean air corridors exist. One such source of

clean air studied by the Commission covers major portions of Nevada, southern Utah, eastern

Oregon and southwestern Idaho. This area provides clean air days at Grand Canyon National

Park. Projected emissions growth through 2040 within the studied clean air corridor is not

expected to have a perceptible negative effect on visibility at Class I sites. Clean air corridors

also influence visibility at other Class I sites in the Colorado Plateau, although the precise

relationships have not been fully established at this time. In order to ensure that sources of

clear air for all Class I sites on the Colorado Plateau are protected, additional data collection

and analysis will be needed.

RECOMMENDA

TIONS REGARDING CLEAN AIR CORRIDORS

1. Do not establish special targeted programs at present.

The Commission considered whether special programs or regulations were needed

in clean air corridors in order to protect the clean air provided to Class I sites on the

Colorado Plateau. Given the Commission's findings, there is no present need for

special targeted policies or regulatory programs to control emissions growth within

clean air corridors beyond existing laws and prog rams. In addition, clean air

corridors will be covered by other regional initiatives recommended elsewhere in

this report.

2. Improve regional tracking and monitoring.

Because uncertainties in data and forward projections exist, a regional tracking and

accounting system is needed to make sure that the frequency of clear days

increases or does not decrease at Class I sites and that the Commission's present

assumptions regarding population and economic growth and the resulting effects on

in creased emissions prove reliable. In addition to these concerns, a regional

tracking and accounting system should:

a) within areas that are sources of clear air , identify patterns of growth

or specific sites of growth that cause significant emissions increases

having a negative impact on visibility at one or more Class I sites on

the Colorado Plateau;52

b) in areas outside of clean air corridors, identify significant emissions

growth that begins to impair the quality of air in the corridor and

thereby reduce the frequency of clean air days at Class I sites; and

c) continue technical studies to see whether other sources of clear air

exist and take measures, if needed, to protect against future

degradation of air quality in these areas.

3. Establish triggers for additional action.

The occurrence of any of the conditions described in paragraph #2 above should

trigger analysis of the e ffects of increased emissions and the implementation of

additional measures to protect clean air days, if necessary

.53 EMISSIONS WITHIN AND NEAR CLASS I AREAS

Background

Emissions from within and near Class I areas contribute to impaired visibility

. Transportationrelated emissions and other emissions from energy use are of particular concern. Prescribed

fire emissions are also a concern since land managers plan to increase necessary prescribed

fire activities in order to restore natural fire cycles and preserve natural ecosystems.

National park general management plans and forest land management plans are appropriate

ways to address some contributions to visibility impairment at Class I areas. National Park

Service (NPS) nation-wide policy is to mitigate visibility impairment and other air quality

effects from in-park sources by reducing emissions and incorporating sustainability concepts

into all plans an d management decisions. The NPS has already implemented several

innovative approaches to pollution prevention in many Colorado Plateau parks and intends

to do more. These actions include more in-park transportation systems (such as low-emission

shuttles), conversion of park vehicle fleets to cleaner fuels, increasing energy efficiency , and

taking other steps at parks on the Colorado Plateau.

The Commission recognizes the importance of visibility issues related to emission sources

in and near Class I areas, and supports funding for these transportation, energy

, and other

programs that help improve visibility

.

RECOMMENDA

TIONS REGARDING EMISSIONS

WITHIN AND NEAR CLASS I AREAS

1. Implement park and wilderness planning processes.

Federal land managers, through their planning processes, should strive to limit and

reduce visibility impairing emissions within Class I areas. Land managers should

also use existing opportunities, such as the states’ required consultation process

with federal land managers in the review of state visibility protection plans

(discussed below), to inform the appropriate regulatory authority regarding agency

actions and strategies taken or planned within Colorado Plateau Class I areas to

prevent or reduce pollution emissions that affect visibility

.

Specifically , such plans or actions would assure that:

a) emissions growth from human-caused sources within the Class I area

does not cause visibility to deteriorate;54

b) human-caused sources within the Class I area (or that result f r om

activities within the are a) that contribute to existing visibility

impairment are mitigated; and

c) prescribe d fire programs (excluded from 1a. and b. above), after

considering and applying non-fire alte rnatives whenever possible,

see k to minimize emissions and visibility impacts through smoke

management and emissions reduction measures.

2. Develop strategies for nearby communities and activities.

All significant sources or combinations of sources near each Class I area must be

exami ned and cooperative, enforceable management strategies developed and

implemented among tribal, local, state, federal, and private interests, as necessary

, to assure re a sonable progress toward no human-caused impact on visibility (the

national visibility goal). The development of management strategies must take into

account such equity-related concerns as relative contribution to visibility impairment

and whether any one population (such as lower-income groups) is unfairly burdened

by the strategies. Regulatory and planning authorities have a pivotal role in assuring

that sources near Class I areas are inve ntoried and assessed, and that their

emissions are mitigated with regard to visibility impacts on these areas. Existing

planning and regulatory mechanisms should be strengthened and funded to create

a systemati c approach to address this issue. For example, existing regulatory

requirements for long-term visibility strategies and their review and revision no less

than every three years should be enforced.

T o this end, all land managers should:

a) be vigilant and aggressively pursue o pportunities to participate in

external planning arenas where decision-making could have effects

on visibility in nearby Class I areas;

b) r eview permit applications for new or modified stationary sources

proposed for construction and operation near Class I areas; and

c) request that the appropriate regulatory auth o rity (or authorities)

pro pose emissions reduction strategies for nearby sources that

contribute to existing visibility impairment, either during development

of the visibility protection plans or during the required periodic review

of such plans.

Regulatory programs should provide exemptions for tribal ceremonial practices and

for people who are dependent on a single source (wood or coal) of heati ng and

cooking.55

3. Apply existing regulatory requirements.

Regulatory and planning authorities are already required to develop, maintain, and

enforce visibility protection plans for mitigating nearby source impacts on the Class

I areas. Regulatory agencies should develop criteria for these pl ans that are

consistent across the T ransport Region. An important element of this activity is the

development and maintenance of an emissions inventory

, tracking, and reporting

program for each Class I area. The authorities must consult and actively involve the

respective Class I area land manager(s) throughout the process.

4. Utilize other planning processes.

Federal land managers and authorities in local political subdivisions and on tribal

lands should perform analyses of potential visibility impacts to Class I areas on the

Colorado Plateau and inc lude them in land management plans for lands located

near these areas.56 TRANSBOUNDAR Y EMISSIONS FROM MEXICO

Background

Pollution from stationary

, mobile and area-wide emission sources in Mexico contributes to

visibility degradation in the Colorado Plate au's Class I areas. Expected economic

development in the border regi on will likely exacerbate transboundary pollution transport

unless steps are taken to reduce and prevent pollution. The Commission lacks the authority

to address these transboundary pollution problems directly

, but should support several

ongoing efforts to develop emissions inventories, establish binational institutions and bilateral

agreements to facilitate cooperation, and create incentives for implementation of costeffective air pollution abatement strategies.

RECOMMENDA

TIONS REGARDING EMISSIONS FROM MEXICO

Mexican sources are a significant contributor

, particularly of SO 2 emissions. However

, data gaps and jurisdictional issues make this a difficult issue for the Commission to

address directly

. The recommendations below call for continued binational

collaboration to work on this problem, as well as additional efforts to complete

emissions inventories and increase monitoring capacities. The Commission feels that

they should receive high priority for regional and national action.

1. Develop a comprehensive emissions inventory

.

Characterizing and quantifying emissions from sources in Mexico provide a

necessary foundation for developing emissions management options. Some data

exist as a result of past or ongoing governmental efforts. In addition, the Western

Governors' Association, in cooperation with Mexican government officials, is

developing methodologies for preparing an emissions inventory for the entire border

region. The Commission supports these efforts.

2. Establish binational institutions and agreements.

The Commission urges the EP A, the U.S. State Department, and affected states to

mak e effective use of opportunities provided by existing binational treaties and

agreements. For example, Annex V to the 1983 La Paz Agreement directs the EP A

and INE (the National Institute of Ecology of Mexico) to assess the causes of, and

develop solutions to, air quality problems in border sister cities. As a result, the U.S.

and Mexican governments have developed an environmental plan for the border that

is periodically revised (next revision: summer 1996); the National Coordinators meet

regularly to discuss progress; and working groups composed of federal and state

officials (e.g., the Border Air Working Group) have been establis hed to address57

pollution problems in various media. The Border Governors' Association also

examines environmental problems in the border region. The Commission supports

these activities and is prepared t o work cooperatively with these groups as

necessary/appropriate.

3. Develop community mechanisms for cooperative transbo undary

planning.

While pollution transport from Mexico affects the West generally , local communities

in the border region are most severely affected and have the greatest need to

develop coop e rative, creative approaches. Greater local involvement in decision

making will likely lead to more effectiv e and expeditious pollution abatement

strategies. The Commission supports the des ignation of international air quality

management districts in border cities and the establishment of community-based

binational committees charged with developing air quality management plans. The

U.S. and Mexican governments are currently negotiating an international agreement

to institutionalize such an approach in the "Paso del Norte" region (El Paso, T exas; Dona Ana County

, New Mexico; and Ciudad Juarez, Chihuahua). The Commission

supports this effort and reco mmends that the respective federal governments

consider expanding this type of approach to other border communities.

4. Finance air pollution control projects.

The Commission recommends that the governments of the U.S. and Mexico utilize

several new institutions established by the North American Free T rade Agreement

to improve air quality

. Although there are critical needs in the areas of water supply

and treatment, the Commission urges the Border Environmental Cooperation

Commission (BECC) and the North American Development Bank (NADBANK) to

apply available capital for border infrastructure projects to high priority air pollution

problems whose resolution w ill have marked effects on regional air quality (e.g.,

emission control technology on major industrial or electricity-generating facilities).

5. P rovide incentives for transboundary investment in pollution

control.

The Commission encourages the EP A to explore the feasibility of al lowing U.S.

industries to earn emission reduction credits for investment in pollution control and

prevention projects in Mexico. The se might be applied to existing Clean Air Act

programs for nonattain m ent areas or as part of a western regional emissions

management program implemented to protect visibility

. Criteria and procedures for

awarding appropriate credits should be develope d to provide an incentive for

investment in transboundary pollution control projects that would have a beneficial

impact on air quality in border communities and throughout the western United

States. The ongoing international negotiations directed at the Paso del Norte region

mentioned above include consideration of conducting a feasibility analysis for an

international emissions trading program. The Commission should support this effort.

Conversely

, the Commission supports disincentives to discourage U.S. companies58

from investing in facilities in Mexico that do not achiev e pollution control levels

comparable to those required in the United States.

6. Pursue pollution control projects at specific major sources in

Mexico.

The construction and operation of major stationary sources in Mexico may be a

significant cause of long-distance pollution of Class I areas on the Colorado Plateau.

The Commission encourages the respective federal governments to pursue, through

international negotiations and agreements, implementation of polluti on reduction

strategies aimed at specific facilities that may be found to have identifiable impacts

on the Colorado Plateau.1 2 For a more comprehensive discussion of technical and scientific needs, see " Subcommittee Report on

th e Future Needs of the Commission," November 6, 1995, developed by a subcommittee of the Public Advisory

Committee.

59

FUTURE SCIENTIFIC AND TECHNICAL NEEDS

Introduction 12

Many of the recommendations in this report call directly for continued, expanded or improved

collection of technical information in order to provide the basis for futu re regional policy

recommen dations and development of appropriate implementation strategies by tribes, states

and federal agencies. In order to implement some of the recommended programs, additional

technical data will have to be collected, interpreted and modeled on an ongoing and regional

basis.

The following sections of this report and related recommendations include reference to

technical needs:

Stationary Sources: In order to track emissions targets and/or to implement a

regional cap and trading program, an improved emissions monitoring and

accounting system will be needed.

Mobile Sources: The r ecommendations call for establishing mobile source

emissions budgets for selected major urban areas, which will require accurate data

collection.

Area Sources: The recommendations call for improved modeling of road dust

effects, setting up an emissions tracking system for all fire activities, and improved

integrated assessment of emissions.

Clean Air Corridors: Regional tracking and monitoring of emissions is needed in

order to make sure that the Commiss ion's projections regarding the relative

insensitivity of sources of clear air prove correct.

T ransboundary Emissions from Mexico: Cooperative work with Mexican officials and

corporations requires an accurate emissions inventory

.

Air Quality on T

ri bal Lands: There is a need for more comprehensive emissions

inventories for areas on and near tribal areas as well as monitoring of air quality on

tribal lands. The limitations of present models do not permit modeling of impacts on

tribal lands.60

In general, four types of initiatives are required to meet the technical needs of future programs:

improved emissions inventories, expanded monitoring of visual air quality , refined modeling

capacities, and improved assessment information and methods.

Emissions Inventory

The emissions inventory developed by the Commission represents all known emissions of

visibility-impairing pollutants from all known sources. Programs which call for assessment of

reasonable progress toward the national air quality goal based on targeted emission

reductions, or on model-projected estimates of improvements, will require an accurate and

complete emissions inventory

. The current GCVTC emissions invent ory represents

cooperative work among many in the region and an advance in comprehensive data

collection, but the emissions inventory process can and should be improved.

A substantial

effort will be needed to coordinate and update continuously the emissions

inventory to reflect actual emissions in the region on a year-by-year basis. In addition, any disparity in methods for developing emission estimates by any entity , whether federal, state

or tribal, must be adjusted or equalized in order to assure a consistent inventory . This will be

particularly critical if a regional trading program is implemented where tons of emissions from

one state or tribal land may be traded for tons of emissions from another

. If the emissions

in ventory methodologies are different, then it will be difficult to assess the true impact of

trading programs among various jurisdictions.

Air Quality Monitoring

Now that the Commission has completed these recommendations to the EP A, it wil l be

necess ary to measure and report on reasonable progress toward the goal of remedying

existing and preventing future impairment of visibility in mandatory Class I areas. This implies

that federal, state, tribal, and local air quality agencies mus t be committed to a long-term

monitoring program.

The current federal visibility monitoring program (IMPROVE) distributed monitoring sites to

address national needs at Class I areas throughout the country . IMPROVE has led to limited

visual air quality data collection in the GCVTC region. There are sixteen Class I areas on the

Colorado Plateau that have been selected as requiring visibility protection. Of these sixteen

sites, limited monitoring is currently being done at only six sites:

• Bryce Canyon National Park

• Canyonlands National Park

• Grand Canyon National Park

• Mesa V erde National Park

• Petrified Forest National Park

• Weminuche National Wilderness Area13 The accomplishments and limitations of the present model are discussed in Section II.

61 While these sites are reasonably representative of visual air quality conditions on the central

Colorado Plateau, existing visibility in the vast majority of the region, especially on tribal lands,

has only been inferred from the current IMPROVE data set.

Modeling

In general terms, air quality models are needed to convert emissions from all sources and

areas into an estimate of visibility impairment at the key receptors (Class I sites) on the

Colorado Plateau. The Commission's committees and contractors have developed a model

that roughly approximates how weather and emissions result in air quality at Class I sites. 13

Further development of regional models is needed to more accurately show the relationships

among emissions sources and effects at specific Class I sites under specific conditions, in

order to resolve the limitations of the present model. Further

, future modeling efforts should

assess expected wide-reaching effects from electric utility industry restructuring.

Assessment Information and Methods

The key inputs to the IAS include, in addition to technical inputs described above, information

related to the current levels of controls and installed technol ogies on sources, the control

options that are available for sources (including costs and efficiencies), and methods to

project changes in the future. These need to be significantly improved to reduce uncertainties

in assessing or forecasting the effects of emissions management options. In addition, the

methods for evaluating overall economic effects and other secondary assess ment criteria

must be improved.

RECOMMENDA TIONS REGARDING FUTURE

SCIENTIFIC AND TECHNICAL NEEDS

The Commission foresees that the following regional scientific and technical work will

need to be done. The tasks may be performed by a combination of state, tribal, and

federal organizations, with coordination by a regional body

.

EMISSIONS INVENTOR Y

1. Secure adequate long-term funding.

Emissions inventories require significant human and financial resources. Enough

resources must be allocated to the task from state and federal sources.62

2. Develop and update a regional emissions inventory

.

A quality inventory must be completed and then updated on a regular basis. A

complete plan should be de veloped prior to the start of data collection. All states,

tribes, and federal agencies should follow this plan, so that data collection methods are

compatible for all areas and sources.

3. Standardize comprehensive data collection.

Inconsistencies and gaps in the emissions inventory should be addressed, including

the following:

a) current inconsistencies in the way s states collect and quantify

emissions data;

b) emissions inventory information for agricultural activities;

c) all data collection for a single calendar year;

d) a mechanism to accept/reject/determine factors to fill in data gaps;

e) information regarding current levels of controls; and

f) emissions inventory data specific to tribal lands.

4. Develop agreements on how data will be used.

Agreement should be reached on how and for what purposes the data will be used. For

instance, states, tribes and federal agencies should determine whether inventories and

analyses developed for regional programs and policy development can or should be

incorporated into national databases.

5. Develop adequate trained human resources.

Agencies should be staffed to conduct and maintain emissions inventories. In the past,

the EP A has not placed a high priority on emissions inventories eve n though they

provide the basis for state or tribal implementation plans, rulemaking and application

of Section 169B of the Clean Air Act.

6. Address the need for micro-inventories.

A greater emphasis should be placed on micro-inventories of emissions for areas in

and near Class I Areas and other areas of concern, such as tribal lands. Modeling

indicates that nearby sources may have a greater impact on visibility than sources at

a greater distance on a per ton basis. As such, comprehensive micro-inventories are

needed for the near-field around Class I areas. Without them, it will be impossible to63

reliably identify that portion of the contribution to visibility impairment caused by longrange transport of regional haze.

7. Agree on an emissions forecasting methodology

.

Agreement should be reached on the source of information and methods to be used

to forecast future em ission changes related to economic growth and anticipated

effects from control programs.

AIR QUALITY MONITORING

1. Continue and expand the number of monitoring sites and frequency

of sampling.

The current

IMPROVE monitoring network only measures aerosol samples twice a

week and at only a few Class I sites. Thus, five-sevenths of the time, the chemical

make-up of the particulates contributing to visibility impairment is unkn own.

Consideration should be given to exp anding the coverage or redeployment of

resources in the IMPROVE network to enhance completeness of the data set, including

on tribal lands. In addition, background surveillance sites could be established at

intermedi ate locations between the Class I areas and large regional sources

(metropolitan areas) to provide a better understanding of the intermediate course of

atmospheric chemistry and transport. Monitoring should be maintained at existing sites

in order to allow for long-term trend analysis.

2. Establish three essential components.

The three fundamental components of a future visibility monitoring program should be:

1 ) light extinction measurements from transmissometers; 2) aerosol chemi stry

m easurements from fine/coarse-mass-particulate samplers; and 3) meteorolo gical

measurements of wind speed, direction, temperature, and humidity

. T r ibal lands would

be particularly appropriate sites for tracking and monitoring case studies.

MODELING

Both sophisticated and reduced form models are needed. Once these methods and

data are in hand, any simulation can be prepared. In other words, the two types of

issues placed before the GCVTC of subregional or reg ion-wide issues can be

assessed with equal facility

.

1. Develop a comprehensive, sophisticated model.

A comprehensive model must be able to mat ch its p redictions of air pollution and

visual air quality with actual observations of both factors. This model should generate

output at least on a twelve-hour basis using emissions and meteorological64

observations on this time scale. T o reproduce the observations on a space and time

basis, there is a need for accurate emissions data over the entire modeling area,

reliable wind fields, cloud and other climatological data, and samplings of pollutants

and visual air quality

, as well as dependable algorithms for the physics and chemistry

of transport and the transformation of pollutants during transport and deposition. This

model is likely to be sufficiently complicated that it would have to be run on a

sophisticated computer

. T o the extent that interpretation of fine grid geography or of

urban plumes is necessary to match the data, this capability should be included. The

model must also be able to accurately model both near-field (within about 30 miles)

and far-field effects.

2. Develop a "Reduced Form Model."

A second type of model will be needed for assessing the effects of control options on

emissions and visual air quality

. This would be a reduced form model (RFM) that can

be installed on a personal computer and run in seconds to minutes to convert

emissions into estimates of ambient fine particle loadings and visual air quality . This

model should relate emissions of various species from the source regions of the entire

study area to data collected at receptor sites in the Class I areas of interest.

The RFM needs to be able to replicate the predictions of the more comprehensive

model. Therefore, the transfer coefficients should be constructed by the comprehensive

model for use in the RFM.

3. Assess impacts of new sources.

The existing visibility protection program requires a review of visibility impairment

from new or modified major stationary sources to prev ent adverse impact on

visibility in nearby Class I areas as part of the source permitting process. This is

currently done following guidance issued by the Inter- A gency Workgroup for Air

Quality Modeling. This review is needed to prevent future attributable impairment.

T o assess reg ional impacts, new sources should be incorporated as part of the

process to address "reasonable progress." As noted above, EP A should develop

appropriate guidance on new

, large-scale regional models which will be able to

incorporate all source impacts.

4. Obtain improved meteorological data.

Large-scale regional models are highly dependent on input of meteorological data.

The wide separation between locations that measure winds aloft (i.e., National

Weather Service balloon stations) contributes a high degree of uncertainty to the

results of the modeling. Consideration should be given to expanding the network of

sites that collect upper air soundings. In addition, local meteorological data at the

Class I areas are needed to identify potential local source impacts. The coordination

of region-wide intermittent control systems (such as region-wide smoke

management) will necessitate an expansion in the meteorological data collection

network in order for such a system to be effective.65

ASSESSMENT TOOLS AND METHODOLOGY

1. Undertake more detailed economic studies.

More detailed economic studies are needed in order to determine more accurately

the costs of controls and, of more importance, to understand the effects, both

positive and negative, past and future, that these costs have on the local and

regional economies and their growth. Potential economic effects needing more

study include: economic benefits of cleaner air (such as to tourism), impacts of costs

on companies and individuals that pay them (for instance, effects on profits,

competitiveness and disposable income), and the feedback of control expenditures

into other industries in the region (such as pollution controls, parts and services and

electricity production to operate controls).

2. Develop better assessment tools and methods.

In order to provide an objective analysis of the effects of emissions management

strategies for regional haze, specific components of research and development are

needed, including:

a) expanded and improved inventory of control options and costs for use

in assessments;

b) establishment of a mechanism to aggregate sources into assessment

groups consistent with the spacial distribution of air quality modeling

and economic assessment regions;

c) improved econometric analysis tools and techniques to characterize

more accurately subregional, including tribal, impacts; and

d) upgraded methodological approaches f or performing secondary

assessments.66 SECTION IV : TRIBAL PERSPECTIVES

AND POSITION REGARDING RECOMMENDA TIONS

Introduction

The following section provides background regarding tribal participation in the Commission

process and the legal framework for tribal relatio nships with states and the federal

government. T ribal participants in the process have also provided their unique perspectives

on the Commission's recommendations, commenting on how those recommendations may

affect tribal lands and peoples.

In large part, the tribal participants support the guiding principles set forth in Section III of this

report and agree with the Commission's recommendations, as discussed in more detail

below

. In some instances, however , the tribal participants wish to highlight certain points

made in this repor t or provide a distinct perspective and emphasis arising from tribal

experience. These views are also set forth in this section.

The T ribal Environment

It is the philosophy of most Indian tribes that the quality of life of their members is intimately

related to the quality of their environment, and that people and nature should be in harmony

and balance. Vista s are important to tribes in spiritual and cultural ways but they are also

important for economic reasons. The pristine and visible beauty of their homelands are often

the reason for tourist visitations. These visitations support tourism and many cottage

industries on the reservations and provide revenue for tribal governments.

As "harmony" requires, tribes also recognize that tribal populations are increasing and tribal

governme nts must address the needs of their developing nations. T r ibes are working to

develop their economic infrastructure so that they can achieve self-sufficiency and provide for

their people, including revenues for tribal governments. T ribal governments provide community

services, such as road maintenance, water

, environmental protection, education, health care,

day care and other social services. As in any community

, the demand for these services is

expected to grow with the population, and tribes desire to grow economically to support these

demands.

In order to achieve these goals, tribes cannot be unfairly burdened by regional or federal

regulations. Any recommendations must ensure that emission control burdens do not fall

disproportionately upon tribes. It must be remembered that tribes, by and large, have not

contributed to the visibility problem in the region, precisely because of the lack of economic

development in Indian country . Therefore, what is fair for states may not necessarily be fair for

tribes. T ribal economies are much less developed than those of states, and tribes must have

the opportunity to progress to reach some degree of parity with states in this regard. Further

, economic and cultural differences may magnify the effects of recommended emission

controls.67

Acknowledgements

T ribal government approval and support of the Commission's recommendations is reserved

to individual tribal government discretion. This reservation is not i ntended to represent

rejection of efforts to arrive at consensus-based policy recommendations. Rather , it is based

upon the legal and historic status of tribes as individual tribal nations; as sovereigns, tribal

governments have the prerogative to deal direct ly with the federal government and may

choose to do so in regard to western visibility protection and improvement. Whatever actions

tribal governments ultimately choose to direct or pursue, they nevertheless have found value

in working within the GCVTC process and have directed tribal representatives to learn from

the GCVTC deliberations and contribute to the best of their abilities toward achieving a good

that will benefit all people in the West.

A number of tribes have been represented on the Commission and on the various committees

established by the Commission. Although these "tribal participants," as they are called in this

report, do not represent all 21 1 tribes in the T ransport Region, as individual participants in the

GCVTC process they have joined together and reached consensus on a number of issues,

as reflected in this report. When this report presents tribal positions on the Commission's

recommendations, therefore, it is presenting the views of these tribal participants.

Co-Management Principles

The Grand Canyon Visibility T ransport Region, as defined by the EP A, includes 21 1 tribes.

Therefore, visibility improvement and protection strategies ultimately adopted by the EP A

must be selected and implemented not only in light of statutory requirements of reasonable

progress toward visibility

, but also in light of certain basic principles of Indian law

. The GCVTC

recognizes and respects that the federal and tribal governments have a unique government-togovernment relationship that is bui lt on historic legal principles. The Commission's

recommendations must be considered, not in terms of a federal-state framework, but in terms

of a federal-state-tribal framework. These principles of Indian law and their ramifications for

the Commission are set forth below

.

T ribal Sovereignty

It is a basic principle of Indian law that tribes have inherent sovereignty over tribal

lands, or "Indian country

. " Moreover

, if a tribe does not assert its jurisdiction in a particular instance, then the federal government may have jurisdiction in the tribe’s

place, but a state governme n t could not. As a result, emission management

strategies will be implemented within Indian country by tribal governments or

, failing

that, by the federal government, but not by state governments.68

Federal T

rust Responsibility

The Courts have found that the federal government bears a trust responsibility toward

American Indian tribes . This imposes fiduciary duties on the conduct of federal

agencies toward Indian tribes and t heir natural resources. The trust relationship

therefore presents a second basis, in addition to the principle of tribal sovereignty

, for

the EP A and other federal agencies involved in the GCVTC process to ensure that

tribal interests are protected in any regulatory scheme.

T ribal Self-Determination

As acknowledged by Congress in the Indian Self-Determination and Education

Assistance Act, there must be "effective and meaningful participation by th e Indian

people in the planning, conduct and administration" of programs affecting Indian

people [25 U.S.C. § 450a(b)]. These principles are also embedded in the EP A policy

for the Administration of Environmental Programs on Indian Reservations (November

8, 1984) in which

the EP A states that it will "view T r ibal Governments as the

appropriate non-Federal parties for m aking decisions and carrying out program

responsibilities affecting Indian reservations, their environments, and the health and

welfare of the reservation populace." Each tribe is the decision-maker for its own future

and is responsible for ensuring that the needs and right s of its people are met and

protected. T

ribal concerns must be taken into account in formulating recommendations.

T ribal Impacts Reports and Studies

T ribal participants feel that the report Impact Projections of Emission Management

Scenarios on Western T ribal Lands (January 1996), was inadequate and provided only very

genera l conclusions. The various other studies undertaken by the Commission did not

adequately evaluate and describe the unique economic structures and demographic patterns

of Indian tribes, nor their unique cultures and aspirations. Also, the studies very narrowly

focused on straight line economic cost/benefit analysis. Other values are important to tribes:

quality of life, freedom of religion and choice in lifestyle, to name a few

. Future studies should

address these important areas of concerns so that the tribes, and those concerned about

impacts on tribes, will be able to more fully evaluate management option impacts.

T ribes were greatly disappointed that secondary assessment studies were not fully carried

out. Little or no work was done to identify impacts on health and welfare, land and water uses,

solid and hazardous waste disposal, threatened and endangered species, and terrestrial and

a quatic ecosystems. This information would have been of great interest to the tr ibes and

probably many others.

Program Implementation

T ribal governments have the r esponsibility to develop, implement, and manage programs

within Indian country

. If a tribe chooses not to establish a program, then the federal government

has the trust responsibility to establish a program. Thus if the EP A promulgates a rule based

on a control technology scenario, for example, tribes must have the option of implementing the

rule within Indian country or prompting federal implementation of the rule within Indian country

.69

Similarly

, a market trading scenario in which there was separate tribal participation or federal

participation on behalf of the tribes could be legitimate.

Many tribes are just beginning to develop environmental programs, and these pro grams receive very minimal funding from the EP A, if any . T

ribal governments also lack the tax base

available to states to help fund environmental programs independently . Therefore, tribal

implementation of visibility programs will require policy development support, technical

assistance, and program funding.

In the implementation of an emissions trading program, special consideration for tribes is

necessary

. Given that ma ny tribal lands are "underdeveloped," tribes should be allocated

some additional share of trading credi ts to allow for future development, much as "clean"

states were under the acid rain trading program.

T ribes, states, local governments and federal agencies must find innovative ways to support

implementation of regional haze programs. Memoranda of Understanding or Memoranda of

Agreement, and/or other state/tribal/federal agreements, could be utilized to share resources,

expertise and responsibility

.

TRIBAL P ARTICIP ANTS' POSITIONS ON COMMISSION RECOMMENDA TIONS

As discussed above, the tribal participants for the most part concur in the Commission's

recommendations set forth in this report. Specifically , the tribal participants agree with all six

of the assessment criteria listed on page 20-21 of this report, although the tribal participants

feel tha t the criteria were not uniformly applied. The tribal participants also have certain

additional recommendations and perspectives which are presented below

.

Air Pollution Prevention

Some of the most pristine, and yet the most threatened, ecosystems are found within the lands

of indigenous peoples. The lack of many basic necessities, such as sustainable employment

and adequate housing, creates the need for immediate economic development. Coupled with

this is the lack of environmental protection infrastructure to manage and check efforts to

develop economic opportunities which are proceeding without consideration for the traditional

Indian commitment to resource conservation. T ribal communities, like others in the T ransport

Region, have the opportunity to take a proactive approach to pollution prevention and to avoid

the mistakes of the past which have resulted in environmental degradation. Future initiatives

should make sure that growth planning and development is coup led with environmental

mitigation.

In the first subsection of Section III of this report, various pollution prevention recommendations

are offered, including economic incentives for pollution prevention efforts, encouragement of

zero and near-zero emitting technologies, and development of alternative (i.e., renewable)

power sources. The importance of these recommendations is indicated by the prominence

they receive in the Executive Summar y of this report (they are listed as the first

recommendation). T

r ibal participants support this recommendation wholeheartedly

.70

However

, the extent to which deployment of renewable energy will improve visibility is not, nor

can it be, stated with certainty , based on the modeling outputs available.

The modeling of renewable energy control scenarios is of paramount importance, particularly

to western tribes. A significant number of tribes (33) are actively pursuing development of

renewable energy and end-use effici e ncy technology applications. These development

options involve remote electrification, bulk power generation, improving reservation economic

conditions and reducing the emissions associated with fossil fuel generation. The Energy

Policy Act of 1992 has intensified tribal interest in renewables by authorizing the Department

of Energy to prov ide grants to tribes to evaluate the feasibility of renewable energy

development.

The fact that western reservations are prominent within prime solar and wind energy resource

areas and a number are situated in major electricity transmission corridors has focussed

Congressional and t ribal attention on joint ventures and other strategies for securing

investment capital to build and operate bulk renewable electric generation capacity . Clearly

, apart from the inc o me obtained through wholesale power sales, renewable energy

development will have great added value to tribal governments in the form of revenues from

payments for accrued "air credits," and wages from jobs in a vertica lly integrated electric

power industry

.

T ribal participants support the recommendations to establish goals for bringing renewable

power on line, but modeling efforts clearly need to be expanded to include the impacts of this

recommendation. More specific details should underlie this recommendation, including goals,

incentives and a timeline for adding renewables to the resource mix.

Stationary Sources

T ribal participants are concerned that PSD and the current visibility program (§ 169A) under

the Clean Air Act insufficien tly address the national goals of preventing and remedying

visibility impairment in Class I areas c aused by human-induced air pollution. Government

Accounting Office estimates indicate that sources accounti ng for up to 90% of pollutants

emitted near five Class I areas are exempt from PSD requirements, which apply only to new

sources. Existing sources and small new sources are ignored by PSD. In addition, § 169A

(existing sources) concentrates only on visible plumes, rather than regional haze, and very few

existing sources have been required to implement BART controls.

T ribal participants in the Commission process s upport the stationary source

recommendations presented in Section III of this report with the following additional concerns

and recommendations:71

1. All uncontrolled and undercontrolled stationary sources should be subject

to equivalent emission standards as controlled sources.

2. An emissions cap should be set for SO 2

.

3. A better inventory and better modeling should be developed for PM.

4. If a cap is established for a particular pollutants, minor sources on tribal

lands should be inventoried since they may not currently appear in state

inventories.

5. Data from the Federal Energy Regulatory Commission should be used as

a basis for f orecasts of future electric utility emissions and for

recommendations regarding emission reduction goals. This will also

enable the Comm i ssion to identify opportunities for early retirement of

high-emitting facilities.

6. The effects of increased wholesale and retail competition in the utility

industry must be taken into account in predicting future emission levels.

Moreover

, if an emission trading strat egy is adopted, tribal participants recommend the

following:

1. T ribes must be involved in the development of the trading scenario.

2. Credits should not be based on historical emissions, but should be based

on equitable factors, including t he need to preserve opportunities for

economic development on tribal lands. In general, these lands are currently

lacking in economic bases and have not contributed to the visibility

problems.

3. Whatever body administers the trading program must be representative of

all of the groups involved.

4. The cap should be defined by region, not by state.

Mobile Source Controls

As programs are initiated, participating governments should receive compliance assurance

assistance and equitable funding to administer their respective programs. In addition, tribal

communities would benefit immensely from educational programs explaining the n eed for

controls and demonstrating vehicle maintenance methods for minimizing vehicle emissions.

T ribal participants are concerned about mobile source emissions from federal vehicles on or

near Indian lands, especially sites run by the Departments of Defense and Energy . Federal

air traffic in these areas is of particular concern.72

Area Sources

There are major gaps in delineating accurately the contribution of tribal land sources to

visibility impairment. V ery few air quality monitoring programs have been placed in or near

tribal lands. T

o more accurately inventory emissions sources, monitoring capability should be

significantly improved on and near tribal lands.

Wood Burning

Many rural Indian homes rely on wood-burning stoves as the sole source for cooking

and residential heating. Programs should include a sole-source heating/cooking and

ceremonial burning exemption from visibility and other air quality regulations on tribal

lands.

Dirt Roads

There are numerous dirt roads within Indian country

. If paving is required as a visibility

protection measure, financial assistance will be needed. In addition, non-paving options

should be considered.

Forest Management Practices

Many tribal lands include forest lands which the tribes often manage with prescribed

fire. Although fire can contribute significantly to visibility impairment, tribal participants

recognize that fire is an important management tool. T ribal participants recommend

that the various jurisdictions (federal, tribal, state, etc.) develop and implement time,

place and manner constraints that minimize visibility impairments.

In addition, forest land managers need to take into consideration the needs of tribal

communities i n their practice of religion and traditional cultural activities. Some of

these activities may be pr otected under the provisions of the American Indian

Religious Freedom Act. The availability of and access to areas where traditional

medicines and sp iritual foods are located should not be diminished by fire

management practices.

Clean Air Corridor Controls

T ribes should not be penalized for having clean air and littl e economic development.

Therefore, no inequitable restrictions should be imposed on tribal and other corridor residents

and/or economic growth.

Future Scientific and T echnical Needs

There is a need for the development of comprehensive emission inventories on and near tribal

lands. These inventories may be used to provide more accurate data for future studies, and

to prioritize regulatory development. T ribal participants recommend that the EP A assist tribes

in this effort. In future tribal population and socio-economic studies, the data collection process

should be designed to work more closely with tribes.73

Future modeling tools need to be able to accommodate political subdivisions smaller than

large counties. The economic modelling system needs to be adapted to tribal situations. The

distinctive characteristics of tribal lands deserve special attention. Given the diversity of tribal

populations and land bases, the broad-based regional and state level impact analyses do not

provide sufficient and accurate data. Also, the unique economic structure and demographics

of tribal peoples may be missed in the broader regional analysis.

T ribes need to be meaningfully involved in the development and implementation of future

technical studies and in accommodating the special needs of tribes in various study methods

and tools. T

ribes will need the services of their own experts to help with these efforts, and will

need financial assistance to obtain such experts.

Future Administrative Needs

Indian tribes have rarely been asked to participate in region-wide policy development such

as that undertaken by the Commission. Although not all tribes have been involved, the tribal

participants agree in principle that the work of an administrative body on air quality issues

should continue.74 SECTION V . FUTURE ADMINISTRA TIVE NEEDS

Background

The Grand Canyon Visibility T ransport Commissi on represents an experiment in regional

policy development through cooperative partnership among state, tribal and federal

governmental entities. The Commission has also engaged a broad range of interested parties

from industry

, environmental organizations, academics, technical experts, elected officials,

and various citizens' organizations. Throughout this process, the Commission has provided

a means fo r cooperative development of improved scientific information and for

intergovernmental consideration of policy recommendations. The following recommendations

regarding future administrative needs draw on this experience.

RECOMMENDA

TIONS FOR FUTURE ADMINISTRA TIVE STRUCTURES

1. Continue a regional air quality entity , similar to the Commission.

The implementation and ongoing review of regional haze management strategies will

require the work of an entity similar to the present Commi ssion, most likely in a

streamlined structure, based on the evaluation performed in recommendation #4

be low . The Commission therefore recommends that the functions of the GCVTC

should continue, in order to further develop this important partnership and perform vital

policy and implementation functions as outlined in #3 below

.

The name GCVTC focuses disproportionately on the Grand Canyon and should be

changed to ref lect the larger geographic entity it serves. The primary role of the

Commission, or its successor

, will continue to be coordination and monitoring in order

to recommend policies to the appropriate entities. States, tribes and federal agencies

will undertake implementation actions.

An equitable body of state, tribal and federal representatives should convene, as

necessary but at least annually , for the purpose of: discussing visibility and other air

quality issues, including public health concerns, and coordin ating data collection

efforts, and making recommendations to the EP A on reasonable progress and other

air quality issues.14 See Section III, Future Scientific and Technical Needs.

75 2. Integrate efforts of an administrative body with other reg i onal air

quality needs and planning efforts.

It is expected that the EP A will soon undertake new air quality initiatives that also

require regional approaches. The participating entities should explore expanding the

scope and structure of a successor body to address regional haze and other fine

particulate impacts on visibility and health throughout the Western United States. (If the

mandate is expanded the name of the successor body should reflect the new mission.)

3. Establish functions of a successor entity

.

After it makes its initial recommendations to the EP A

, the Commission or its

successor should, through its subgroups, perform functions including, but not limited

to, the following:

a) tracking and providing feedback to the EP A on EP A's interpretation

and implementation of Commission recommendations;

b) coordinating implementation of inter-jurisdictional mechanism s for

addressing regional haze, including monitoring activities;

c) tracking implementation of programs for addressing regional haze to

ensure equity;

d) assessing emissions and visibility data to determine if reasonable

progress is being made towa rds the national visibility goal, and

recommending adjustments to regional haze management strategies,

as necessary;

e) promoting the development of innovative, cost-effective mechanisms

for addressing regional haze;

f) coordinating research and development efforts on visibility and

airborne particulate assessment methodologies in the West to ensure

that such efforts are focussed on concerns relevant to policy

formulation 14 ;

g) prov iding a forum for interested parties to offer input on the

development of regional haze policies;

h) promo ting and supporting educational programs furthering visibility (or

expanded air quality) goals, in public schools, in higher education and

to the general public;

i) supporting energy-conservation measures; and76

j) promoting outreach an d communications programs for tribal

communities in order to address the remot e ness and educational

needs of most Indian reservations.

4. Evaluate and review Commission structures.

In order to create efficient, effective and sustainable long-term structures, an evaluation

of the Commission's present and past functioning should be conducted. Such a review

should examine the composition of the Commission, operational structures, and

management arrangements, and should generate recommendations regarding future

functional arrangements. T o ensure neutrality in the evaluation, the review should be

conducted by an independent outside source. Following such an evaluation, each

participating governmental entity will be consulted about whether and how it will take

part in future activities.

During the period through its report to the EP A in the spring of 1996, the Commission

has functioned with governors or other high-level state, tribal and federal leaders

serving as Commissioners. If the Commission becomes an ongo ing body

, consideration should be given to whether other federal, state and tribal officials may

be the most appropriate appointees as Commissioners. Any future management or

administrative structures should consist of an equitable body of federal, state and tribal

representatives. Public participation in future efforts should be ensured through the use and creation of publicly accessible working groups.

5. Develop ongoing funding mechanisms.

In order to es timate the resources, human and financial, that will be necessary to

sustain this work (e.g., basic administrative functions, specific research and monitoring

activitie s), a projected five-year budget should be developed in conjunction with

development of a comprehensive plan for future operations.

The EP A should provide ongoing financial support for the basic admini strative

functions of the Commission or its successor

. Work should continue in cooperation

with the EP

A to support efforts to secure such funding. In the course of evaluating all

current Commission functions (see #4 above), the benefits and feasibility of additional

sources of funds for specific activities should be explored, including:

a) visibility surcharges on entrance fees for Class I areas within the

Colorado Plateau;

b) dedicated air permit or emission fees; and

c) redistribution of existing air pollution control funds.

Equitable funding should be made available to tribal, state and federal officials to

support participation in ongoing data collections and modeling efforts.77

6. Planning process for future functions.

The Commission is convinced that its functions must continue in some form in order

to ensure that regional haze management strategies which are implemented meet with

regional approval. In order to continue the functions of the Commission without any

hiatus, the Commission directs the Operations Committee to:

a) Follow up on the Commission’s recommendations, mon itor

interpretation by EP A of the Commission’s recommendations,

seek funds for future operations, and perform needed interim

tasks;

b) Prepare a comprehens ive set of recommendations regarding

how and in what form to continue the Commission by early

S eptember 1996, building on the recommendations in this

section above. These recommendations will include provisions

regarding:

• the structure of the Commission and any subsidiary bodies;

• the participation of states, tribes, and federal agencies on

the Commission;

• involvement of stakeholder representatives in Commission

processes;

• administrative arrangements;

• the scope of Commission activities; and

• changes in the Commission’s by-laws needed to implement

a reconstituted Commission.

By mid-September 1996, the Operations C ommittee will distribute its detailed

recommendations as above to the Commissioners by mailed ballot for action.

Note: For tribal perspectives and commentary on these recommendations, see

Section IV

.78

SECTION VI: ANAL YSIS OF THE COMMISSION'S RECOMMENDA TIONS

Introduction

This section present s the Commission's analysis of the likely effects associated with its

recommendations. The analysis attempts to address these key questions:

1. How will the Com mission's recommendations affect visibility at Class I sites in the

T ransport Region?

2. What are the likely economic effects, both direct and indirect, of the Commission's

recommendations?

3. What are the likely environmental, so cial, equity , and administrative effects of the

Commission's recommendations?

The analysis is divided into two main parts. The first is a summary , using graphs, of likely

visibility ef

fects associated with the Commission's recommendations, where effects are

known. Such effects are not, in all cases, known. The second part is a detailed discussion of

the Commission's recommendations in light of the evaluation criteria identified in Section II

of this report (page 20-21).

Visibility Gains from the Commission's Recommendations

The overall goal of the Commission's recommendations is to improve visibility on the worst

days and to preserve existing visibility on the best days, at Class I areas on the Colorado

Plateau. The recommendat ions focus on reducing emissions from sources that presently

contribute to visibility impairment and are likely to do so in the future.

The Baseline Forecast Scenario described in Section II (page 9) projects the way in which

current federal, state, and tribal laws and programs are likely to affect visibility at Class I areas

on the Colorado Plateau through 2040. The Commission used this "current law" scenario to

e valuate the a dditional improvements in visibility that its recommendations are likely to

achieve in order to meet the national visibility goal.

Figure VI-1 consists of two graphs. The first, labeled Figure VI-1A: "Visibility Range

Determined by the Integrated Assessment System", represents th e range of estimated

visibility conditions between the baseline forecast assumptions and a maximum emissions

management alternative in the Integrated Assessment System. The darkly shaded area on

the graph represents the difference between the estimated visibility conditions resulting from

current air quality programs and the maximum improvement from emissions control actions

that were included within the Integrated Assessment System.79

One limitation of the Integrated Assessment System is that several source categories were

not characterized as incorporating cleaner emissions technologies over time as is likely under

current and future air quality management programs. T o address this shortcoming, the

Commission developed a "bounding" estimate of the upper limit visibility conditions that could

result from making adjustments to the Integrated Assessment System baseline assumptions

for both growth of certain sources and future controlled emissions from certain sources.

The second graph labeled Figure VI-1B: "Visibility Range Expected from Recommendations",

reflects this approach. The darkly shaded area of this graph represents the diffe rence between holding visibility constant from the year 2000 to a maximum potential improvement

from changes in the Integrated Assessment System baseline assumptions and future source

control levels. T

o define the maximum source control, certain source categories were

assumed to reduce their contribution to extincti on over time in a way similar to Integrated

Assessment System source categories that had technological improvements of appr oximately

74% reduction from 1990 levels of impact. This probably results in an overprediction of the

likely effect, how

ever it is a reasonable estimate of the maximum effect for this bounding

exercise.

The Integrated Assessment System source categories that were adjusted for this estimate

are: industrial/commercial fuels, non-road diesel, industrial processes, solvent use, a portion

of other point sources, and other area sources. The estimate also reflects a change in the

baseline assumptions for paved road dust in the Integrated Assessment System. This graph

assumes small growth in paved road dust from increased vehicle miles traveled to the year

2000 and then a leveling off. This was based on uncertainty of the current contribution of road

dust to light extinction. Overall, the graph demonstrates the Commission's belief that, under

its definition of "reasonable progress," most source categories will improve efficiency and

reduce emissions over time. The emissions reductions and associated visibility change

plotted in this graph would be tracked and checked by monitoring long-term trends.

The lightly shaded region on the bottom of both graph s in Figure VI-1 represents the

"background" light extinction from natural causes (e.g., windblown dust). On average, this

amount of extinction represents the best annual average extinction possible if all the effects

of human-caused impairment are addressed. Currently approximately 20% of the days have

this visibility level. This is approximately equivalent to the best visibility conditions pictured in

the Introduction and plotted in Figure II-7. Human activities that were not included in the

Integrated Assessment System options for control are approximately 2 Mm

- 1 above this

"background" level . While the improvement in extinction associated with the

recommendations in the second graph in Figure VI-1 may appear small, they will correspond

to much larger changes on some days. While these graphs show effects only at Hopi Point,

the Commission's recommendations are likely to result in approximately the same range of

visibility benefits at other Class I areas.808182

ANAL YSIS OF SPECIFIC COMMISSION RECOMMENDA TIONS

Introduction

This section reviews in greater detail the likely effects of the Commission's recommendations

in light of the evaluation criteria described in Section II. The Commission has divided its six

criteria into two groups: visibility benefits and economic effects in one group, and social,

environmental, equity

, and administrative effects in another . The first part of this section is an

overview of the Commission's effort s to develop rough cost estimates for its

recommendations. The second part of this sect ion discusses specific Commission

recommendations. Visibility and costs are addres sed in connection with each set of

recommendations. The remaining four criteria are discussed as a separate group.

The Commission's recommendations reflect, but are substantially different from the scenarios

developed initially by its technical committees. The Commission represents a range of

interests, and its recommendations exh ibit the real world of give and take among these

interests. The Commission could not simply decide t o adopt one of its earlier scenarios

because Commission members needed to address a range of concerns not reflected in those

scenarios. One such example is recommendations supporting pollution prevention and

renewable energy

. In addition, the Commission's early scenarios could not have anticipated

all the different combinations of controls that would be considered.

As a result, there is not a perfect fit among the Commission's recommendations, the early

scenarios used in modeling, and prior reports to the Commission. Where some or all of a

recommendation is not part of an earlier scenario, it is possible only to estimate its visibility

benefits or economic costs at this time. An examination of the Commission's

recommendations requires a synthesis of its earlier analytical work and new analyses that

reflect the control choices recommended by the Commission. The results of the work of the

Commission's technical committees are discussed below

.

Certain points should be kept in mind when looking at modeling results that show visibility

effects. One is that data about visibility effects often are stated in terms of an annual average.

This a verage includes effects for "clear" days as well as "dirty" days. Most emissions

reductions, however , are directed at improving air quality on dirty days, and using an annual

average understates their short-term effect. For example, the effects of emissions reductions

achieved in Los Angeles will only be observed 25% of the time on the Colorado Plateau, due

to wind patterns. On days when those improvements are observed, they will be much greater

than the annual average.

Another important point is that most of the modeling to date addresses visibility effects at only

one receptor: Hopi Point in Grand Canyon Nationa l Park. This receptor is not necessarily

representative of all Class I sites, but it offered a substantial amount of high-quality data. Hopi

Point may have unique localized influences, and it is also influenced by e missions from a

combination of directions that may not occur at other Class I areas. T o address these potential

limitations, the Commission has analyzed three other Class I areas. This broader approach

makes more emission source regions relevant to the analysis, but is not a complete substitute

for modeling all Class I areas.83

Preliminary Cost Scenario

It is not possible to estimate reliably the economic costs and benefits of the

Commission's recommendati o ns at this time. The recommendations are largely

conceptual in nature, and the d irect and indirect costs and benefits will vary

depending on when and how specific strategies are implemented.

The Commission has developed preliminary rough projections of the direct and indirect costs

of achieving visibility improvements at Class I areas on the Colorado Plateau. Direct costs are the costs of imposing emission controls to improve visibility

. Indirect costs are the additional

effects on the region's economy from imposing those controls, including wages, employment,

and "feedback" of expenditures into the regional economy

.

Sources of emissions in the West previously have incurred costs in order to comply with

requirements of the federal Clean Air Act, and state and tribal programs covering all aspects

of air quality

. These costs will continue. The Commission's focus is on any additional costs,

beyond those resulting from compliance with current law

, that may

be associated with

improving visibility at Class I areas on the Colorado Plateau.

As a first step, the Commission has developed rough estimates of some of the potential costs

and benefits associated with emission management options that bear some similarity to its

recommendations. These emission managem e nt options were designed early in the

Commission's process, and do not match the Commission's recommen dations. The

Commission's rough estimates using these early options show the following:

1. There will be no significant incremental cost associated with the Commission's

recommendations in the short term because they reflec t diligent implementation of

existing programs and new programs likely to be implemented for other reasons.

2. If the full set of recommendations is implemented, including a market-based emissions

cap and trading program, the potential range of costs after 2010 under the Commission's

preliminary rough estimate is from $500 million to $1.8 billion per year

. (These cost

estimates were generated by the IAS based on optimization runs for 25% and 80% of the

Maximum Management Alternative.) This translates roughly into a 0.1% decrease in

gross regional product in peak years, or approximately $10 per person, and an overall

increase of jobs in the region of approximately 0.5% through 2040.

These rough estimates are only the first step in developing an estimate of costs associated

with the Commission's recommendations. They do not reflect any cost savings or economic

benefits that may be associated with these emission reductions, such as health care savings

and enhanced property values.

Analysis of Air Pollution Prevention Recommendations

Visibility and Cost Effects

There currently is no quantitative assessment of the visibility improvements that might result

from the Commission's recommendations in this area, or of their likely economic effects.84

Intuitively

, substituting non-emitting or lower emitting technologies likely will result in improved

visibility

. This includes enco u raging "clean" sources of energy in new industries. Several

recomm endations will probably have direct economic effects. One example is

recommendation #3, which supports economic incentives to promote industrial retooling that

reduces emissions. Another example is recommendation #6, which suggests the possibility

of charging emission fees for air pollution.

Analysis of Stationary Source Recommendations

Visibility and Cost Effects

The recommendations regarding stationary sources involves establishing emission reduction

targets for sulfur dioxide consistent with those anticipated under the Baseline Forecast

Scenario, which was designed to reflect requirements under current r egulations. It is

anticipated that the emission reduction targets will be achieved through compliance with

current regulations and voluntary and economically driven decision making of sources.

Therefore, no additional costs would be incurred to impose controls if the targets are met. The

only cost of the program would be the administ rative aspects of collecting and analyzing

information on emission trends in the T ransport Region.

If emission reducti ons are not achieved through compliance with current regulations and

voluntary and economically driven decision making, then a program would be established to

enforce more rigid reductions. Earlier studies showed that a regional emissions cap and

market trading program is the most cost-effective approach to deal with regional haze.

However , equity and administrative issues associated with this type of program are complex

and need to be dealt with thoroughly in developing a detailed implementation plan. Under this

"back stop" program, some costs of controls may be expected, but cannot be quantified at

this time.

The incorporation of other pollutant species into the stationary source program will have

similar emission reduction effects. T o the extent that long range targets are established on

the basis of expectations under current regulatory requirements, then no additional costs

associated with the visibility program would be incurred, other than monitoring and

assessment. It is anticipated that annual average light extinction from 1990 through 2040 at

Hopi Point would be improved between 0.8 and 1.0 Mm -1

, depending on the actual control

levels achieved for those stationary sources sectors which have not been analyzed in detail.

Analysis of Mobile Source Recommendations

Visibility and Cost Effects

The Commission's recommendations incorporate national, regional, and local strategies for

addressing mobile source emissions. In reviewing these recommendations and their

projected effects, it is important to bear in mind that the Commission's model appears to

understate urban effects and that mobile sources are a significant part of urban emissions.

As a result, it is likely that the model underpredicts mobile source impa cts on visibility

, primarily from tailpipe emissions.85

Current modeling shows that approximately 30% (3.5 Mm -1 ) of the annual human-caused light

extinction at Hopi Point in the year 200 0 is caused by mobile sources (roads, on-road

vehicles, off-road vehicles, aviation, marine, and locomotives). Most of this impact (2.5 Mm -1 )

is attributed to road dust under current modeling; the balance (1 Mm -1 ) comes from tailpipe

emissions.

As part of a national strategy

, the Commission recommends supporting the 49-state LEV . A

recent study by the AAMA shows that the 49-state LEV is likely to reduce emissions of NO

x and VOC from on-road vehicles below the BFS by at least 35% by 2020. According to the

Commission's model, this would translate into only a small annual visibility improvement at

Hopi Point. However , more work is required to determine whether the model underestimates

this impact.

Potential visibility benefits from all other mobile source categories (off-road vehicles, boats,

airplanes, locomotives) are approximately 1 1% of the total mobile source contribution based

on current modeling.

The Commission has not modeled the visibility effects of its pro posed regional and local

mobile source initiatives. The same limitation applies to estimates of the costs associated

with imposing mobile sour ce controls. Depending on the costs associated with different

categories, it may be cost-effective to achieve the relatively small visibility benefits associated

with different national strategi es noted above. Additional work is required to develop this

information.

Analysis of Area Sources/Fire Recommendations

Visibility and Cost Effects

Millions of wildland acres in the T ransport Region are at risk from catastrophic wildfire. These

areas will burn eventually

, and the fires will impair visibility at Class I areas on the Colorado

Plateau. The Commission's models indicate tha t emissions from fire, both wildfire and

prescribed fire, is likely to have the single greatest impact on visibility at Class I areas through

2040. Current modeling indicates that, at certain times, increased visibility impairment from

fire is likely to exceed the potential visibility improvements associated with other Commission

recommendations.

The Fire Emissions Project of the Commission found that, historically

, fire occurred on

approximately 35 million acres annually

. This corresponds to an annual visibility impact of 8-13

Mm -1

. Current prescribed fire programs across the T ransport Region cover approximately 1.2

million acres annually

. In 1995, PM 2.5 emissions from prescribed fire were estimated to be

approximately 75,000 tons per year , less than 1% of total PM 2.5 emissions from all sources

in the T ransport Region. The proposed future prescribed fire program s of land managers

would treat approximately 6 million acres annually by the year 2040, increasing the relative

contribution to 3% of total PM 2.5 emissions in the T ransport Region. This projected target is

consistent with current land management agency fire policies, but is dependent on available

resources and funding. Significant increases in fire on all wildlands will occur

, whether by

managed prescribed fire or by uncontrolled wildfire, if proposed prescribed fire programs are

not implemented.86

Fire has seasonal impacts on visibility; it is not a constant influence. During certain periods

(days or weeks) of intense fire activity , the visibility impacts of prescribed fire may be much

greater than the average annual impacts. Most wildfires oc cur in the summer and fall;

prescribed fires are used in the spring, summer

, and fall. The clearest days on the Colorado

Plateau occur during the winter . As a result, increased fire emissions are likely to make the

worst 20% of days even worse, rather than impair visibility on clear days. Both prescribed fire

and wildfire activity are dependent on weather conditions, resulting in visibility effects that can

fluctuate widely from year to year

. T a ble VI-1 shows the range of visibility impacts that are

projected to occur from the use of prescribed fire and wildfire.

T ABLE VI-1

Annual Average 1 Prescribed Fire/Wildfire Visibility Impacts in Mm -1

Y ear Prescribed Fire

Baseline 2 Prescribed Fire

with Maximum

Controls 3 Wildfire 4

1990-2000 0.3 - 0.5 NA 0.1 - 1.0

2010 1.5 - 2.0 1.4 - 1.7 0.1 - 1.0

2040 1.6 - 2.2 1.4 - 1.9 0.1 - 1.0

1 Seasonal impacts may be 2-3 times higher than the annual average.

2 Baseline projections in 2010 an d 2040 reflect projected prescribed fire programs under current land

management policies. Emissi ons may be overestimated due to fiscal and personnel constraints and National

Ambient Air Quality Standards requirements.

3 Prescribed fire emissions can be reduced through smoke reduction mea sures (mechanical treatment, etc.).

These impacts may be further mitigated by managing the timing of burning based on meteorology

.

4 Alth ough the Commission believes that increased use of prescribed fire activity will result in long-term

reductions of wildfire emissions, the Commission has been unable to quantify this benefit.87

The Commission's recommendat ions focused on ways to limit the increased visibility

impairment from fire that could occur through 2040. Since land managers will be increasing

their use of prescribed fire techniques to reduce wildfires, there is an opportunity to reduce

the growth in visibility impairment projected to occur

.

It is important to bear in mind that fire has highly variable effects on visibility , even on a daily

basis. The Commission's model cannot reflect this variability

.

Even using "optimal" smoke management measures, prescribed fire's contribution to annual

visibility impair ment at Hopi Point could increase by 400% between 1995 and 2040. The

Commission's fire modeling projects that use of optimal smoke management measures could

decrease fine particle (PM 2.5 ) emissions from prescribed fires by approximately 15-20%. This

would limit the increased visibility impairment at Class I areas that likely will be caused by

prescribed fires through 2040. In practice, land managers consider daily weather conditions

to minimize effects from prescribed burning. The Commission's model does not permit an

analysis of how these decisions, based on weather conditions, influence smoke impacts.

Using "optimal" smoke management and emission reduction measures is projected to cost

approximately $500-$2,000 per ton of PM 2.5 reduction. Reducing PM 2.5 emissions by 15-20%

over projected increases is estimated to cost approximately $65-$75 million annually

.

Analysis of Clean Air Corridors Recommendations

The Commission is not recom mending any special programs or regulations for clean air

corridors beyond existing law

. The basis for this approach is model results showing that

projected emissions growth in the studied clean ai r corridor is not expected to have a

perceptible impact on visibility at Class I sites.

Analysis of Recommendations Regarding Emissions Within and Near Class I Areas

Visibility and Cost Impacts

The Commission's recommendations address a range of transportation and energy-related

emissions, as well as emissions from prescribed fire, that occur both within and near Class

I areas.

Particle emissions in and near Class I areas deserve particular attention because they have

potential immediate consequences for visibility

. Approximately two-thirds of par ticles

measured at Hopi Point consist of fine soil and coarse material (PM 2.5 and PM 10 ). Fine soil

from sources near and distant from Class I areas accounts for about one-third of the visibility

impairment caused by particles. Sources of coarse material have relatively small spheres of

influence, i.e., coarse material generally doesn't travel far

. As a result, the data from Hopi Point

indicate that sources of coarse material located close to Class I areas, such as unpaved

roads, are likely to be more important to visual air quality than regional sources. Forest fires

burning close to or within Class I areas can also be expected to have significant impacts on

visibility , since they emit coarse and fine dust as well as elemental and organic carbon.88

The Commission recommends improved planning to reduce visibility effects from sources of

coarse material and fine dust both within and near Class I areas. The Commission's model

does not allow modeling of the potential visibility impacts of this recommendation. The same

modeling limitation applies to the recommendation that strategies be deve loped to limit

emissions from local sources.

T he Commission has not quantified the visibility benefits associated wi th its

recommendations concerning other transportation and energy-related emissio ns. The

Commission has not developed any cost analysis for these recommendations.

Analysis of T ransboundary Emissions Recommendations

Visibility and Cost Effects

The Commission's mode l presently shows that emissions from Mexico result in annual

average visibility impacts at Hopi Point of approximately 1.68 Mm

- 1

. Of this amount,

approximately 1 Mm -1 is attributed to industrial and residential sources near the U.S.-Mexico

border . Of the remainder , approximately half is attributed to specific stationary sources; the

remainder to off-shore shipping emissions that travel across Mexico to the United States. This

is approximately 17% of manageable visibility impairment at Hopi Point on an annual average basis. Using an annual average likely understates the impact of these emissions on a given

day

, because meteorological conditions limit their influence to approximately 25% of the year

. It is likely that on certain days the light extinction is much greater . The Commission has not

modeled visibility impacts at other Class I areas.

Most of the transboundary emissions (about 60%) are SO

x , and most come from area sources

within Mexico. At least one smelter located within Mexico is projected to be responsible for

approximately 14% (0.24 Mm -1 ) of the annual total transboundary light extinction at Hopi Point.

The Commission is aware of reports that this source is scheduled to be shut down within the

next few years.

A comprehensive emissions inventory will give a clearer picture of the different sources of

transboundary emissions. Programs to finance air pollution control projects, to provide

incentives for transboundary investment in pollution control, and to retire major emitting

sources are likely to have visibility benefits at Hopi Point. However

, more work is required on

the emissions inventory before these benefits can be quantified.

One important issue associated with these emissions is whether they are "manageable" in

the same way that emissions from sources located within the United States are manageable.

The Commission is u nable at this time to estimate the potential costs associated with its

recommendations.89

Analysis of Scientific and T echnical Needs Recommendations

The Commission has made a number of recommendations that include additional monitoring,

data collection and reporting. These activities are the key to implementing many of its other

recommendations. It is not practical at this time to estimate the costs associated with these

activities.

Discussion of Environmental, Social, Equity , and Administrative Effects

The Commission's recommendations are a mix of the specific and the general. While analysis

of the economic, social, environ mental, equity , and administrative impacts of s pecific

recommendations can yield robust conclusions, predicting the effects of g enera l

recommendations is at best an uncertain process. This is particularly true for the 21 1 Indian

tribes located on the Colorado Plateau, whose peoples have unique economies and lifestyles.

These issues are addressed more fully in Section IV on "T ribal Perspectives" in this report.

The Commission's economic model also has certain limitations. The process for evaluating

criteria other than costs relies primaril y on data from the economic model, which present

impacts at the level of a large county . The economic model is not designed to address rural

areas with small populations, or Indian tribes, and its ou tput has limited utility at best in

assessing impacts for these groups.

The Commission's equity concerns include addressing the following questions: Are the

sources causing the problem paying for/contributing fairly to the solution? Are sources causing

the problem paying for the solution in proportion to their current contribution and current control

levels? The Commission's formal assessments have not analyzed whether some income

groups will be affected more than others or whether there are ethnic patterns to the outcomes

of the recommendations. These issues are of particular concern to areas which are relatively

underdeveloped within the T ransport Region.

With respect to equity for rural and underdeveloped areas, including most tribal lands, it is

important to note that such area s have not contributed significantly to the regional haze

problem. One method for measuring equity is to ensure that all groups contribute fairly to

solutions, relative to their role as an emissions source and their economic position (that is, in

proportion to the ability to pay).

While the Commission has sought to distribute the burden of its recommendation equitably

, inadequacies in the primary and secondary assessment process (e.g., lack of emissions data

for tribal lands, inability of the economic model to analyze areas smaller than a county , and

l ack of tribal data inputs to economic modeling) require continued vigilance to guarantee

strong application of the equity criterion in all implementation plans and in mon itoring the

impacts of the Commission's recommendations.

With these limitat ions in mind, the Commission offers its perspective on the so-called

"secondary" impacts associated with its recommendations.

T ourism

. One issue relevant to all the Commission's recommendations is tourism in the

region. Research conducted for the Commission shows that national parks in the West are90

important contributors to the economy as well as the quality of life. National parks in the study

generated over 100,000 jobs and almost $5 billion in gross regional product in 1994. Most

park visitors come to enjoy the scenery

. Any noticeable impairment of visibility could

significantly affect park visits and, as a result, the regional economy . However , there currently

are no studies that assess the link between air quality and park visits, so stronger conclusions

cannot be drawn.

Air Pollution Prevention

. The Commission's recommendations concerning a ir pollution

prevention illustrate the limitations of projecting effects at this time. The recommendations

themselves ar e general in nature. Because they were not modeled, there presently is no

information about the costs and benefits. Nevertheless, there is reason to believe that

promoting alternative energy sources would have so me economic benefits, in the form of

increased investment in alternative technologies and increased employment in the alternative

technology sector

. Some Indian tribes have invested significant resources in this area, and

could benefit economically from expansion of alternative energy technologies and creation of

incentives for their use. T o the extent there are economic benefits to Indian tribes investing in

these technologies, it is reasonable to e xpect some social benefits. "Clean" technologies

would likely have an overall positive impact on the environment of the region. However

, a more

specific conclusion would require knowledge of the specific technologies under consideration.

Stationary Sources

. T

urning to the recommend ations about stationary sources, there are

some important concerns. Under a regional cap/trading program, there are f undamental

questions about how initial credits will be alloca t ed and how reductions would be timed. If

credits are allocated simply on the basis of historical emissions, there are potential equity

issues for new emissions sources. This concern has been raised specifically by Indian tribes.

There also are significant equity an d other issues about how such a program affects subregions where companies may sell their credits and move away , or conversely how it would

affect areas where industries that acquire pollution credits are located.

Mobile Sources . T

o the extent that national strategies, such as the 49-state LEV or low sulfur

fuels, are adopted, the average costs of implementation will decrease because they are

spread over a large area and population.

The Commission is aware of the potential equity impacts associated with some of its mobile

source recommendations. One example is retiring high-emitting vehicles. These vehicles tend

to be owned by persons without the economic means to acquire newer

, low-emitting vehicles.

This recommendation also poses potential equity issues for Indian tribes. Another example

is enhanced inspection and maintenance programs. These can have differential impacts on

lower income groups, and raise equity concerns.

Area Sources/Fire

. The use of prescribed fire has clear significance for the health of

ecosystems throughout the West. A better understanding of fire's role in ecosystem health

underlies the recommendation supporting the increased use of prescribed fire, along with

smoke management techniques. In the long run, this recommendation will result in

environmental benefits in the T ransport Region.91

Mechanical treatment will be labor-intensive and may provide significant employment

opportunities. Substantial subsidies may be required for some use of the biomass resulting

from mechanical treatment programs. Biomass utilization may be possible in some energy

markets, and the development of other woody material markets is also possible.

There are social and equity issues associated with fire policy

. One of these involves Indian

tribes that conduct their own timbe r , agriculture, and habitat management operations. Any

policy that restricts the ability of these tribes to develop these operations could have an impact

disproportionate to that felt by other groups, such as federal lan d managers. This issue is

discussed further in the section on "T ribal Perspectives."

Emissions Within and Near Class I Areas . The Commission's recommendations are likely

to affect communities located "within and near" Class I areas. These could be major urban

centers, smaller rural communities, or Indian tribes. One potential emissions source in these

communities is unpaved roads. Measures to reduce dust could have disproportionate impacts

on these communities, and on groups within each community

. Paving roads can increase use,

thereby causing a range of economic and social impacts. Depending on who paid to pave

roads, there could be significant equity impacts as well. Pollutant "plumes" from urban areas

also raise equity issues involving who should bear the cost of addressing mobile and area

source emissions that are part of these plumes.

T ransbounda ry Emissions . Communities located close to the border may be bearing a

disproportionate share of the impact from transborder emissions. These same communities

probably would reap the greatest benefit from emissions reductions, but may be unable to

contribute financially to emission reduction strategies. This issue is also addre s sed in the

section on "T

ribal Perspectives."