REPORT OF THE 

GRAND CANYON VISIBILITY TRANSPORT COMMISSION

TO THE UNITED STATES

ENVIRONMENTAL PROTECTION AGENCY

June 1996
i

EXECUTIVE SUMMARY

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

visualexperience for people from around the world.This experience depends onmaintaining

highvisualair qualityinthe region,whichis threatenedbyhaze resulting from projected growth

over the next fifty years. Congress 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 regional issue. Congress created the Grand Canyon Visibility Transport Commission in

1991 to advise the U.S. Environmental ProtectionAgencyonstrategies for protecting visual

air qualityat nationalparks and wilderness areas onthe Colorado Plateau. The Commission

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

strategies. 

The Commissionconducted anextensive reviewof 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

regionalhaze,but limitations and uncertainties remain. Based onthatinformationand its own

deliberations, the PAC developed a setof 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,

1996and approvedthem as the Commissions reportto theEnvironmentalProtectionAgency.

The EPA should use the Commission's recommendations as guidance for developing

nationalstrategies and/or rulemaking.Implementationof allspecificprogramcomponentswill

remainthe responsibilityof tribes, states and theirpolitical 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 cooperationwith the tribes, states and federal agencies as

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

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

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

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

options should not become mandated actions or regulatory programs. 

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 recommends policies based on

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

resources for energy production.
ii

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

the Commission recommends careful tracking of emissions growth that may affect air

quality in these corridors.

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

monitoring the impactsof currentrequirements underthe CleanAirAct and ongoing source

attribution studies. Regional targets for SO2 emissions from stationarysources will be set,

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

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

participants in the Commission's process will develop a detailedplanfor anemissions cap

and market trading program.

• Areas In And Near Parks. The Commission's researchand modeling showthata host of

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

have significant visibilityimpacts. However,theCommissionlackssufficientdata 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,

state, 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.TheCommissionrecognizes thatmobile sourceemissions areprojected

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 nationalstrategies aimedat furtherreducing 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 visibility 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 thatit 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 SO2 emissions. However, data gaps and jurisdictional issues make this a

difficult issue for the Commissionto address directly. The Commission recommendations

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

efforts to complete emissions inventories and increase monitoring capacities. These

matters should receive high priority for regional and national action.

• Fire.The Commissionrecognizes thatfire plays asignificantrole invisibilityonthe 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 and
 

1 Sulphur dioxide (SO2

) for stationary sources and nitrogen oxides (NOx) and volatile organic compounds

(VOC) for mobile sources.

iii

wildfire levels are projected to increase significantly during the studied period. The

Commission recommends the implementation of programs to minimize emissions and

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

• Future RegionalCoordinating Entity. Finally, the Commissionbelieves there is a need

for anentitylike the Commissionto 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, technicaland funding needs of the

Commissionor a newregionalentityand hasaskedtheOperations 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 feasible, Commission recommendations calling for additional

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

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

organizational arrangements have been determined, all tasks whichare notassigned to any

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

Committee. 

The Commission believes that reasonable progress toward the national visibility goal is

achieved to the extent that current CleanAirAct requirements, existing laws and regulations,

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

emissions thatcontribute to visibilityimpairment and ensure long-term protection ofvisibility.

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

be reduced by 30% from the 1990 levels.1
iv
v

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 ................... 78
vi
vii

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 light extinction responsible for haze on the Colorado

Plateau.

Area source: Many small sources ofair pollutioninwhichthe contributionof 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: Best Available Retrofit Technology, a process under the CAA to evaluate the need

and, if warranted, install the most effective pollutioncontrols onanalreadyexisting air

pollution source.

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

Transport Commissionto estimate future haze-causing pollutionand 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 Clean Air Act, and the Clean Air Act Amendments. National airpollution

control is based onthe CleanAirAct, passed in 1970. Congress amended the Clean

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

in 1990 (whenitrequired creationof 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 thatwere 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,

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

Plateau are world famous.

CNG: Compressed Natural Gas, a relatively clean-burning fossil fuel.

EC/OC: Elemental Carbon (such as soot, often the result of fire and diesel engines) and

Organic Carbon (carbon combined with other elements to form complex compounds,

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

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

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

diameter.)

GCVTC: The Grand Canyon Visibility Transport Commission, composed of the governors

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

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

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

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

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

establishedto recommend methods to preserve and improve visibilityontheColorado

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 VOCs.

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

in Grand Canyon National Park.

IAS: Integrated Assessment System, a computer model created by the GCVTC to generate

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

control scenarios.

IMPROVE: Interagency Monitoring of Protected Visual Environments, 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: Low Emission Vehicle/Zero Emission Vehicle, motor vehicle 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: Liquefied Natural Gas, a relatively clean-burning fossil fuel.

LPG: Liquefied Petroleum Gas, a relatively clean-burning fossil fuel such as propane.

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

value, the hazier the air is.
ix

MMA: Maximum Management Alternative, an IAS 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

sources, 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 GCVTC's IAS is a

computer modelofregionalair quality for the Colorado Plateau and uses information

from throughout western North America.

NAAQS: National Ambient Air Quality Standards, levels of air pollution set by the U.S.

EnvironmentalProtectionAgencyto protect public health and welfare. Standards are

setforozone (O3), carbonmonoxide (CO),sulfur dioxide(SO2),nitrogendioxide(NO2),

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

Non-attainmentarea: 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.

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

commongas 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 NOx gases. Nitrogen dioxide (NO2) is yellowish brown, and thus

contributes directly to haze. All the NOx gases react in the air to form haze-causing

aerosols and smog.

NPS: National Park Service, a federal agency charged with protecting the natural and

culturalresources and the processes thatcreate and sustainthem, in the NationalPark

System.

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

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

pollution, and the options available to control that pollution.

OC: Organic Carbon, complex carbon-containing compounds often emitted by plants and

many human activities. OC2.5 is organic carbon of 2.5 micrometers of less. 

PAC: Public Advisory Committee, 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 GCVTC

Commissioners charged the PAC with developing consensus recommendations for

managing visibility.
x

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

PM2.5: 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).

PM10: Aerosols with a diameter smaller than10 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 smaller ones. In addition to creating haze,

higher concentrations ofPM10 canalsocauseirritationof the throatand 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: Prevention of Significant Deterioration. 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 inClass I areas underthe nationalvisibilitygoal. The Clean AirAct indicates that

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

necessary, the energy and non-air quality environmental impacts of reducing

emissions, and the remaining useful life of anyexisting air pollutionsource considered

for these reductions. The GCVTC Public 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 attainsteady improvement of visibility in mandatory Class Iareas, 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 amount of a specific air pollutant that is

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

ROG: Reactive Organic Gases, typically hydrocarbons (HC), but include oxygenated

hydrocarbons.

SIP/TIP: State ImplementationPlan/TribalImplementationPlan, plans devisedbystates and

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

be approved bythe U.S.EnvironmentalProtectionAgency and include public review.

SO2,SOx, sulfates: Compounds composed of oxygen and sulfur. Burning fuels, manufacturing paper, or smelting rock containing sulfur produces sulfur dioxide gas (SO2) which

is converted inthe airto other sulfur oxides (SOx) or haze-causing aerosols (sulfates).

Source: Where air pollutants are released. Sources are usually classified as point, 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: TribalImplementationPlan/State ImplementationPlan, plans devised bystatesand

tribes to meetrequirements of the CleanAirAct 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

thanits 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 another. Determining a transfer

coefficient requires the computer model designer to consider wind directions,

chemicalchanges to the air pollutants as theytravel, loss ofpollutants from the air, and

other factors.

Transmissometer: A device that measures lightextinctionbyshining a light beam of known

brightness throughthe 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 anurbanarea. Plume blight is a distinct band or layer of

visible air pollution, often from a single pollution source.
xii

Visibility impairment: The loss of clarity in the air that results when gases or aerosols

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

distinct plume.

VMT: Vehicle Miles Traveled. This number is a measure of vehicle usage and is used to

calculate the air pollution produced by mobile sources, such as passenger cars,

tailpipe emissions and or road dust.

VOC: Volatile Organic Compound. A carbon-containing material that evaporates, such as

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

ozone formation and may form OC aerosols.
1

I. INTRODUCTION

The ColoradoPlateauisa spectacular landscape of massive landforms, unique geology, and

vividcolors. People from around the world have experiencedthesewondersatGrand Canyon,

Canyonlands, 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 loss of visibility diminishes the unique experience of nature's

work on the Plateau. (See pictures at the end of this Section 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 onthe Plateau. The Colorado Plateauhas some of the best visualair 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 industrialactivityfrom the 1940s to the 1970s. Visibility-impairing emissions

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

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

change 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 potentialthreatto air quality, and poses a challenge to states, tribes,

and the federal government.

The National Visibility Goal Under Federal Law

Congress seta nationalgoalofremedying existing visibilityimpairment,and preventing future

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

United States as part of the CleanAirAct Amendments in 1977.This group includes sixteen

parks and wilderness areas onthe Colorado Plateau, as well as others in the WesternUnited

States. 

Congress adopted two mainstrategies to make progress towards the nationalvisibilitygoal:

Prevention of Significant Deterioration (PSD), which focuses on new or modified major

sources that 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 mostpristine airand receiving the greatest protectionunderthe federal statute.Mandatory

federal Class I areas include all national parks, all national wilderness areas and national

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

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

located west of the Mississippi River.

Prior to either constructionof a major newsource or major modification ofanexisting source,

the PSD program requires applicationto the EnvironmentalProtection Agency (EPA) or the

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

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

under the CAA.

2. The Visibility Protection Program

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

theirState/TribalImplementationPlans (SIPs/TIPs)thattheywill make "reasonable progress"

towardachieving the nationalvisibilitygoalestablished byCongressin1977.TheEPAissued

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

component. The first explicit considerationof triballandswithrespect to air qualityregulations

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 visibilityproblemsdo notrespect state and tribalboundaries. 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 regional haze. Congress also specifically

ordered the EPA to establishavisibilitytransportregionfor Grand CanyonNationalPark, and

to create a Grand Canyon Visibility 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

Tribeshave always had the inherentright to regulate air qualityontribal 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 those
 

2 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. Tribalregulationof air qualityontheColorado Plateauand

across the Transport Region requires full consideration of tribal interests and the active

participation of Indian tribes on the GCVTC.

The Commission's Mandate and Structure

The Grand Canyon visibilityTransport Regionincludes nine states and 211 tribal lands2. 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 theirdesignees of eachof 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.

CongressspecifiedthattheGCVTC should assess scientific, technical, and otherinformation

related to adverse visualair qualityimpactsfrompotentialorprojectedemissions growth from

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

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

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 establishment of "clean air corridors" and whether additional restrictions on

emissions in these corridors are appropriate to protect visibilityat Class Iareasonthe

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 Commissioncreated structures basedonprinciples of broad public input and consensus

in order to carry out its mandate, including establishment 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, business, 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 representationof views onthe

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

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

recommendations. These other committees include the Operations Committee and

committees which report to it: the Alternatives Assessment Committee, the Technical

Committee, and the Communications Committee.

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

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

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

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

ontheCommissionprocessand recommendations areelaborated inSectionIV of this report.

Photographic Illustration of the Problem

The following four pages contain color photographs which illustrate the appearance of the

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

Wilderness areas onthe 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 detailand color of the originals. Note thatthe identificationis 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 

RECOMMENDATIONS

STAGES IN THE COMMISSION'S STUDY PROCESS

Anunderstanding 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 Transport Region.

2. Development of atechnicalbasis for assessing visibilityimpacts 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. Development 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 inventory of emissions for each state on the

Commission, neighboring states (Idaho, Montana, Washington, and Texas), northernMexico

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

stationary sources throughout the Transport Region, and mobile and area sources

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

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

coarseparticles)emissions.Data specific to tribal lands have notbeencheckedforadequacy

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

inventory. 

Based onthis inventory, the Commissionthen developed a series of emission management

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

Commission used three mainemissionmanagement 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 IAS. 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 controls 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 

RECOMMENDATIONS
7

The Commission's committees also developed technicaltools 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 visibilityat specific Class I sites. These coefficients have been refined

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

VISIBILITY ON THE COLORADO PLATEAU

The starting point forunderstanding theCommission'sanalyticalprocess is visibility. In simple

terms, visibilitydepends on three factors: Rayleigh scattering, other naturalimpairment, and

human-caused impairment. Nitrogen and oxygen 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. Humanactivities, from industrialmanufacturing to farming,

also impair visibility.Visibility varies depending onnaturaleffects(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 System (IAS). These figures all include future

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

Figure II-6shows the relative visibilityimpairmentfromnaturaland humancausesat four Class

Iareas onthe Colorado Plateau: Hopi Point, Mesa Verde, Bryce Canyon, and Canyonlands.

Values are shown as anannualaverage beginning in 1990 and continuing to 2040, and also

as anaverage for the 20% of days during the yearwhenvisibilityisworst. 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-6shows thatnatural causes account

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

The remaining visibility impairment at eacharea 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 extinctioncanbe converted to the theoreticaldistance 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

skyor Rayleigh scattering (10 Mm-1), one could theoretically see a horizonfeature 245 miles

distant. If light extinctionis 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 corresponding
8

distance for visibilityis only about 90 miles. Figure II-2 shows thatnaturaland 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 the development of the data

underlying thesefigures, please refer to the GCVTC Report,OptionsforWesternVistas.Note

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

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

identified.Naturalparticles account for approximately 5.4 Mm-1 of light extinctiononanannual

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

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

naturalparticles. In terms of visible distance,human-caused particles reduce visibilityat Hopi

Point by about 66 miles on an annual average basis.

Figure II-4

Using its emissions inventory 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 onthe right side ofFigure II-4, along with its corresponding patternshown in the vertical

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

decline byapproximately 1 Mm-1. This decline is due to emissions reductions. Light extinction

caused bymobile sources is projectedto decline untilapproximately 2005,and thenincrease

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 dayat Class Isites onthe Colorado Plateau. Figure II-5shows 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 humancauses at four Class I areas on

the Colorado Plateau: Hopi Point, Mesa Verde,Bryce Canyon, and Canyonlands. Values 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) whenvisibilityis worst. On eachgraph,

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

The additional layers represent light extinction caused by various humansources: stationary,

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

FigureII-6shows thatnaturalcauses account for approximately 15 Mm-1 to 17Mm-1 ofvisibility

impairment at these four areas onaverage.The remaining visibility impairment at each area

is caused byhumans. This portion of totalvisibilityimpairment is considered manageable by

the Commission, and is the focus for its recommendations.

THE BASELINE FORECAST SCENARIO, BASED ON CURRENT LAW

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

beyond current lawand programs,and developedabaseline or"current law" scenario to meet

thatneed.The Commissionrefers to this scenario as the Baseline Forecast Scenario (BFS).

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

at Class Iareas onthe Colorado Plateau,assuming currentlawis enforced,with no additional

actions to protect visibility.

The Baseline Forecast Scenario is built on the following assumptions:

• Emissions growthordecline is based onchanges in economic demand inthe 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 after that time based on economic

growth

• There is no growth in unpaved road dust beyond 1990

• Emissions from Mexico are held constant

Because visibilityis highly variable, the Baseline Forecast Scenario analyzes the average of

the "best" and "worst" 20% of days, as well as annual averages.
10
11
12
13
14
15
16
17
18
19
20

Figure II-7

Figure II-7shows current and predicted visibilityimpairment through2040 underthe Baseline

Forecast Scenario at the same four Class Iareas discussedabove:Hopi Point, Mesa Verde,

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

the "worst" days, 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.

PAC INTERACTIONS IN DEVELOPING CONSENSUS RECOMMENDATIONS

Members of the PAC represented diverse interests from throughout the West. Given the

divergentperspectivesand concrete interests,the struggle to consensus was difficult at times,

but PAC members maintained a cordialatmosphere of collaborationin theirsearchfor good

policy.Theresulting policy recommendations do notrepresent whatanyone group would have

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

creative solutions which all members of the PAC support. 

The PAC assisted in gathering public input at different phases of this process to refine

emissionmanagement options and evaluationcriteria. In November 1995,the PAC received

a contractor's report entitled Options for Improving Western Vistas. Thatreport summarized

thework of the Commission's committees to thatpoint and discussed the resultsofIntegrated

Assessment System modeling.Based onthatreportand other technical information, and with

continuing input from the Commission's committees and the general public, the PAC

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 the recommendations included herein. To the extent that the

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

public and deliberations of the PAC.

The Commissionsought broad public input to develop itsemissionmanagement options and

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

Commission held several series of public workshops and meetings across the Transport

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

PAC meetings and incorporated into the PAC'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 ensure 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 transfercoefficients—isbrought 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 strategies applied to

sources withinthe Transport Regionto yield desired visibilityconditions at any one of sixteen

Class I sites on the Colorado Plateauover the next fortyyears (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 visibilityat a single Class Isite,

Hopi Point in Grand Canyon National Park. 

TECHNICAL FOUNDATION FOR THE COMMISSION'S RECOMMENDATIONS

Introduction

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

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

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

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

running itthroughabasic computermodel. The Commissionneeded newinformationand new

analytical tools, and its technical committees and outside consultants have done

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

improved understanding of visibility impairment in the Transport Region, and provides the

technical foundation for the Commission's recommendations.

It is important to understand thatthis technicalwork, while representing a significant advance

inknowledge,is notyetcomplete.The large size and complexterrainof the TransportRegion,

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

amount of information thatcould be modeled with current technology were important limiting

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

characterized by varying degrees of uncertainty. In particular, the modeling has, to date,given

alimitedpictureofthe regional,and particularly sub-regional, including tribal,dynamicsofboth

emissions and economics. 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 defined in the context

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

22

Important Technical 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 inventory to date of emissions across the

Transport Region.The Commissiongathered 1990 data from a varietyof sources

to create the most comprehensive inventory yet of emissions for the Transport

Region. This inventory is the cornerstone for most emissions forecasting by the

Integrated Assessment System model.

• TheCommission'scurrentmodeling shows improvements in visibility, under

existingregulations and programs,throughtheyear2000.Afterthat,predicted

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

increases.

• Regional phenomena can contribute to visibility impairment. The

Commission's air qualitymonitoring data and modeling showthata 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 thanapproximately 100 miles. These pollutants oftencross the

boundaries of several states within the Transport Region. Some centrally located

emission sources are frequent contributors to visibility impairment at multiple

receptorsites across the Transport Region, regardless of wind direction.Inaddition,

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 Commission has an improved understanding of the

conditions that 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 terrainduring temperatureinversions.Also,urbanareas (Las Vegas

and Salt Lake City) have beenstudiedand mayhave significant3impacts onvisibility

at the Grand Canyon and Canyonlands, respectively.
23

The Commission's current analyses suggest thatvisibilityimpairment caused by local

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

analyses have significant implications for reducing current visibilityimpairment. In light

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

caution. Years of technicalwork maybe necessarybeforethe relative visibilityimpacts

of local sources can be confirmed.

• The relativevisibilityeffects ofregionaland localemissions are variable,but

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

conditions, and terrain elevations influence the relative visibility impacts ofregional

and localemissions. Both emissiontypes contribute to visibilityimpairment muchof

the year, and either type canbe the dominant cause of impairment onany particular

day regardless of the season or the 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. 

• EmissionsfromMexicoaresignificantandgrowing,particularly contributing

to the SO2 emission budget. Without control strategies for Mexicansources, 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. Meteorology 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 across the

Transport Regionas atoolto model changes in visibility. In the simplest sense,each

sourcearea'stransfer coefficients represent the mathematicalrelationshipbetween

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

receptor. The Integrated Assessment System model indicates that emissions

reductions willyield the greatest visibilityimprovements if theyoccur in sourceareas

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

transfer coefficients but low emissions merit increased attention 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 pollutants travel across the nine-state

Transport 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 Commissionhas 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 Transport Region.

Because the Integrated Assessment System models were designed with aregionaltransport

focus, theyoffer only limited insights into (1) the absolute contributions to visibilityimpairment

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 Assessment

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 undertaken prior to enactment of recommendations for emissions controls on

specific local sources.

There are several reasons for the limitations in the Integrated 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 notreflect 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 this 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 meteorological

factors onpollutant transport, it does notsimulate effectscaused by "smaller" terrain

features such as the Grand Canyon. 

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

This means that an inaccurate projection of local influence on visibility 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 instantaneous, occurring within hours

depending on meteorology.
25

• In addition, uncertainties in the emission inventory, meteorology, atmospheric

chemistryand transportmodeling methods,and background assumptions contribute

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

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

model results.

One other important limitation involves 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 Verde, Canyonlands, and Bryce Canyon.

The most detailed informationcame from one receptor, Hopi Point inGrand CanyonNational

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

Point. However, this single receptor does notprovide 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 RECOMMENDATIONS 

GUIDING PRINCIPLES

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

several general principles.

Achieve Reasonable Progress Toward 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

emissionreductions necessaryto reduce existing impairment and attainsteadyimprovement

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

limitexpansionwhile others are not. The Commission recognizes that equityconsiderations

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

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

impacts, the remaining useful life of existing emissions sources, 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 recommendations, 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

Take 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 tribes, states, and

federal authorities throughout the Transport 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, Tribal 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 Commissionhasbeenguidedinmostcasesbyestimates 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

Specific 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

Thespectacular sceneryof nationalparks and wilderness area onthe Colorado Plateauis an

important part of our Nation's naturalheritage.We have alegaland moralobligationto 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 wayto 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 lowor zero emissions technologies and energyconservation. Because

so much of the Transport Region is relatively undeveloped, including tribal lands, regional

stakeholders have the opportunityto take a proactive approachto pollutionprevention. In fact,

given expected growth in the Transport 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 formorepowerincreases,and the region's power productionbase evolves, there

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

to integrate cleaner, sustainable energytechnologies into all aspects of our society. TheWest

enjoys highpotentialforrenewable energyproduction, especially electricalenergygeneration

employing solar and wind power. The relative cost of renewables is declining over time.

Based on forecasts ofelectricalenergyconsumptionin the Transport Regionby 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 Water Fund of the Rockies (How the

WestCanWin,1996) suggests thatrenewable energycould comprise19%ofregionalpower

needs,byadding additionalcapacityby2015. The study also concludes that as much as 40%

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

Based onestimatesofrenewable energypotential, achieving the above goals for renewables

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

visibilityimprovements, as wellas secondaryenvironmentaland economicbenefits. 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

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

visibility. 

Hastening the utilization of renewables requires newand increased investments, assisted by

economic incentives. Huge economic and environmental benefits from improving energy
29

efficiency gains are also possible with adequate commitment and investment, since

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

RECOMMENDATIONS 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.

Potentialemissions reductions, 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 are a powerful tool for effecting change. The Commission

supports creationof incentives thatencourage low-emissionindustries to locate in the

Transport Region, retooling of industries to reduce emissions and increase their

efficient use of energy, the development of energy production based on renewable

resources, and providing consumers with opportunities to reduce their individual

contributions to air pollution. The Commission recommends that federal power

management suppliers be givenincentives to increase renewable energy generation

and pollution prevention actions, and that public utility commissions continue to

influence retailpowermarketsto encourage efficiencyand investments in renewables.

4. Encourage zero and near-zero emitting technologies.

The Commission encourages zero and near-zero emitting technologies through

incentives, education and information 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 beprovidedto reward efforts thatgo beyond compliance and/or

achieve early compliance with air pollution-related requirements.

6. Consider charging emission fees.

A variety of market approaches should be analyzed. Emission fees could be

charged for pollutionemitted into the airto encourage people and industryto reduce

pollutionin the most efficient manner possible.Revenuescould beusedto substitute

for taxes onpropertyor income or to provide financialassistance to those industries
30

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 production based on renewable

resources such as wind,solar, biomass, and geothermal resources and supports the

establishment and tracking of annual goals for increases in renewable power

generation in the Transport Region that fosters the sustained,orderly development of

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

the potentialto 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 Transport Region should

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

regional power needs by 2005 and 20% by 2015. 

Progress towards this goal should be evaluated everyfive years, in conjunctionwith

regular reviews of emissions reductions and progress toward the national visibility

goal. Incentives provided by tribal,state and federalgovernments maybe necessary

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

spending and investment in energyresearchand development should be equalized

among fossil fuel-based and renewable energy programs. The EPA should

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

pollutionpreventionprograms authorized by the EnergyPolicyActand 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 regionalrenewable energy portfolio

goals. 

8. Promote energy conservation.

The Commissionsupports the continued development and implementationof national

energy efficiencystandards for motors, appliances and lighting and recommends the

national adoption of California energy efficiency standards. The Commission also

supportsthe constructionofenergyefficientbuildings,bothresidentialand 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

restrictions. The Commission recommends that continuing attention be paid to

maintaining the role of energyconservationwithinthe changing electric power industry

markets. Energy conservation programs should be preserved and expanded through

suchmechanisms as "system benefitcharges"paidatthe distributionlevel,rather than

in the commodity 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

energyconcepts in elementary, secondary, higher and continuing educationprograms

and in public environmentaleducationefforts. Teaching 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 pollutionpreventionand

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

EnergyRegulatoryCommissionand the states should institute labeling,ona voluntary

basisatfirst,butpotentially based onnationalstandards, thatprovides consumerswith

information about the pollution potential, energy requirements and relative efficiency

of products. Voluntary 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. 

11. Promote the use of clean fuels.

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

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

hydrogen.
32

STATIONARY SOURCES

Background 

Emissions from stationary sources throughout the Transport Region contribute in varying

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

pollutants thatimpair visibility is a function of the size of the source and its locationin relation

to the protected areas. The GCVTC analyticalwork addressed threespeciesofpollutantsthat

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

This 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 available related to sulfates and their

relationship to light extinction. Additionally, because SO2, 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 Baseline Forecast Scenario

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

of sulphur dioxide (SO2) throughthe year2000.However, implementationof current programs

could result in greater reductions in SO2 emissions in the short term. In particular, a number

of openissues with a bearing onthe visibilityproblem could be resolved prior to 2000.These

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

greater thanexpected emissionreductions in the copper smelting industry,and the imposition

of lower fuelsulfur standards. With these additionalreductions notanticipatedbythe Baseline

Forecast Scenario, it is estimated that actual SO2 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 incentive-based trading program (e.g., including, but not limited to, a markettrading program.) It is the intent of this recommendationthat 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 expectation that a

comprehensive program would be more effective at improving visibilityand would yield more

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

Commissionrecognizes thatthe inclusionof multiple pollutants and sources, as well as interpollutant/sectortrading,raisesanumberof complexissues(e.g.,emissioninventories,validity

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

could be included.
33

The Commissionalso recommends thatany incentive program containspecific provisions to

encourageand rewardearlyemissionreductions,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 thatgo beyond pollutioncontrols (e.g., investment in renewable energyand energy

conservation measures.) 

RECOMMENDATIONS REGARDING STATIONARY SOURCES

The objectives of the approach outlined below are:

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

• to ensure reasonable progress toward the national goal through continuing

decreases in sulfur dioxide emissions over the long term; and 

• to avoid increases of other visibility-reducing pollutants within the Transport

Region as a whole from stationary sources. 

The Commissionbelieves these objectives are best achieved by relying on diligent

implementationof current regulatory requirements inthe short term while working to

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

The following specific recommendations are presented with the recognitionthatthe

tribal 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 insulfur dioxideemissions and theircontributionto light extinction

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

the installation of SO2 control equipment currently under construction, they can be

projected with a very high degree of confidence (e.g., a 6% reduction in the total SO2

emissions inventory resulting from emissions reductions at the Navajo Generating

Station). In additionto these known reductions, the rate of SO2 emissions decline will

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

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

mentioned above.By the year2000,the amountofSO2 emissions reductions achieved

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

pending matters mayalso affect the amount and rate of SO2 emission reductions that

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

impacts at Class Isites onthe Colorado Plateau of uncontrolled pollution sources and

make expeditious determinations regarding the need for additional pollution controls

pursuant to the Clean Air Act. To the extent decisions are made to require additional
 

4

These "targets" are intended as firm limitations on emissions and have the same effect as a "cap."

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

triggered if the "targets" are exceeded.

 

5

For example, the utility industry is committed to achieving the current baseline projections of 73%

reductions in SO2 emissions from utility sources by 2040. All projected percentage reductions in SO2 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

emissionreductions at existing facilities,theCommissionsupports the adoptionof the

best, most cost-effective strategies.

2. Establishstationarysourceemissiontargets4 asregulatorytriggers.

a) An SO2 emissions target 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 emissionreductions thathasactually

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

comparing the actualreductionto the 13%reductionfrom1990 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

betweenthe projected and actual, unless anyaffectedpartyconvinces

theCommissionoritssuccessor thata different distributionisneeded

(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 now available from sources (all utilities and many

stationary sources have Continuous Emission Monitors). 

b) An ultimate SO2 emissions target for the visibility Transport Region

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

reduction in SO2 emissions projected by the Baseline Forecast

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

continuing emissionreductions and to promote investmentin pollution

prevention(in accordance with five year reviewperiods as described

in #4 below). 
35

c) Various emissions management options for stationary source NOx

and PM will be explored, including considering the establishment of

emissiontargets,in order to avoid any netincrease in thesepollutants

from stationary sources withinthe regionas a whole and to provide a

foundation for future incorporation into a multi-pollutant and possibly

multi-source market-based program.

3. Developaplanforallocating trading credits under a regulatory program

emissions cap.

a) Development of an equitable plan for allocating the trading credits

among existing and future sources will be accelerated. The

Commission expects that the targets will be met based on existing

commitments and other actions thatare 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 future actions,

participantsintheCommission'sprocess are committed to designing

the plan before the EPA takes final action on the Commission*s

recommendations so that the elements of that program can be

incorporatedinto the federalregulatoryprogram. (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 thatall allocations to triballands,ruralareas 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 informationfor development and implementation

of the incentive-based program, owners and operators of existing

facilities located within the Transport Region should: (1) by 1997,

notify states and tribes of existing or planned pollution control or

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

being made to manage their emissions or engage in other

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 exceeded no additional

regulatory program will be required.6 Any source thathas contributed

significantly to achieving the needed reductions by going beyond

compliance or achieving early reductions will be rewarded. For

instance, the following rewards could be included: 

• anexemptionfrom any interimtarget requirements thatmight 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 exceeded7, a regulatory program (most

likely anemissions cap and incentive-basedmarkettrading program)

will be implemented. 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 EPA to complete, within one year, the

source attributionstudycurrentlyunderwayatthe MohavePowerProject. Further, the

Commissionstrongly encourages the EPA to take action consistent with the results

of that study withintwelve months of its completion. The Commission supports the

commitment by the Mohave Power Project to maintainvoluntarily 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 beenthe lack of adequate and reliable monitoring data.In order for any visibility

policy to be effective, there must be anadequate benchmark of existing conditions

against which to measure progress. To obtain a better understanding of visibility

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 Transport Region provide another benchmark against which to

measure progress. Anaccurate 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 that those areas that are presently lower-emitting can receive

appropriate credit.Ifanincentive-basedregulatoryprogram is implementedafterthe

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 mobile 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 notas 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 transported across the Colorado

Plateau. Emissions from an automobile manufactured today are substantially lower—better

than90%lower,ona per-vehicle-mile traveled basis—thanemissions fromone manufactured

thirtyyears ago, in large part due to the Federal Motor Vehicle Emission ControlProgram in

the Clean Air Act and the California motor vehicle emissions control program. However, the

number of vehicles and the totalvehicle miles traveledhave increaseddramatically.This trend

is expected to continue. And while NOx 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 source 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. Furtherreductions can be achieved through a combination of

national, regional and local actions.

RECOMMENDATIONS REGARDING MOBILE SOURCES

1. Adopt an emission managementobjective and establish a regional

emissions budget.

The objective of the recommended strategies described below is to reduce

emissions of VOC, NOx, elemental carbon, and fine particulates from the mobile

source sector and then hold them constant. To 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

muchof the area within the Transport Region and notimpose unnecessaryburdens

on small communities, including tribal lands, with air quality better than national

ambient air quality standards. National and regional initiatives should ensure

compliance with the regional emissions budget. 

3. Suggest targeted local actions.

In additionto national and regional strategies, targeted local actions are needed to

reduce mobile source emissions within the Colorado Plateau's Class I areas, in

adjacent communities, and in major urban areas that contribute significantly 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

Mostof the mobile source-related emissions reductions achievedto 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 throughactionona 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

implementationthatwould benefitairqualityin the Colorado Plateau's Class Iareas.

The EPA should ensure the coordination of the Commission's efforts related to

national standards and programs with other regional organizations (e.g., Ozone

Transport Commission/Ozone Transport 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 Vehicle

standards (49-state LEV), beginning in 2001, and adoption of federal Tier II
 

8

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) standards, beginning in 2001. This action was part of a larger agreement in which

these manufacturers were given greater flexibility in introducing Zero Emission Vehicles (ZEVs) prior to 2003

in California.

 

9 The heavy duty engine manufacturers, the U.S. EPA and the California ARB signed a statement of principles

in July 1995, committing to the introduction of a NOx standard of 2.0 grams per brake-horsepower hour by 2004,

compared to the 1998 CAAA requirement of 4.0.

40

standardsin 20048, 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 EPA's current proposal to further reduce NOx and

particulate emissions from new on-road, heavy-duty vehicles by at least 50%,

compared to the 1998 requirements contained in the 1990 Clean Air Act

Amendments, while maintaining current stringent PM emission limits.9 The

Commission requests the EPA to pursue additional PM reductions from on-road

vehicles. 

3. Negotiate and adopt off-road vehicle standards.

The Commission requests that the EPA 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.

The Commission requests that the EPA explore broader application 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 #11 on page 31.

5. Pursue strategies for diesel locomotives, boats, airplanes and federal

vehicles.

The Commissionrequests thattheEPApursue fuelstandards and controlstrategies

fordiesellocomotives,marine vessels/pleasurecraft,airplanesand federalvehicles.

States and tribes are preempted from 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 EPA should: 
41

a) promulgate national NOx, HC and PM standards for "captive fleet"

marine vessels and work with the InternationalMaritime Organization

to reduce emissions through international standards; 

b) finalize the proposed HC standards for recreational boats and

personal watercraft; 

c) adoptNOx standards for new and remanufactured diesel locomotive

engines; 

d) strengthen existing national HC standards for aircraft engines; 

e) adopt stringent national NOx standards for aircraft engines; and

f) pursue emissioncontrolstrategies, suchas alternative cleanfuels,for

all federal fleets.

6. Support improved control of evaporative emissions

The Commissionsupportsrequirementsforeffective refueling vapor recoverysystems

that capture evaporative emissions.

Recommended Regional Strategies

Introduction to Recommended Regional Strategies

To 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 inwhich

emissions are projected to reach a minimum, or 2005. As mentioned above, a

protocol for inventorying and tracking emissions will need to be developed. The

adoption of more stringent 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. Economic pricing

strategies should also 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, alternative strategies should be

developed to address the particular needs ofthose 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 ata

minimum, incentives for converting vehicles used for mass transportationand delivery
 

10 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 these and similar efforts. If the establishment of a regional mobile source

emissions budget leads to development of a market-based program, 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 feasibilityof establishing alternative fuelcorridors in urban

areas and along major trucking routes (e.g., I-15,I-5, I-80, and I-40);10

and 

b) conduct ananalysis comparing the relative emissions fromtrucksand

trains (including tailpipe/stack emissions as well as road dust, tire

wear, etc.). 

2. Analyze pricing and incentive approaches.

A regional analysis of economic pricing and incentive approaches should be

conducted by 1998, including an analysis of equityeffects of suchapproaches, 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 orpropertytaxes),used to develop multi-modaltransportationoptions,

or used to help maintain the existing highway infrastructure. The Commission

supports states that are implementing programs to curtail visible emissions and

encourage region-wide adoption of these programs.

3. Explore an inspection program for heavy-duty vehicles.

Truck traffic contributes to regional visibility impairment, including haze in the Class

Iareas in the Colorado Plateau. The Commissionsupports development of options

and opportunities for implementing an emissions inspection programs for heavyduty, on-road vehicles that routinely travel the highways in the Transport Region.

Within the limitations of existing interstate commerce regulations and the North

American Free Trade 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 Commission also encourages local authorities to mount public education

campaigns to inform citizens of the air quality advantages of maintaining their

vehicles properly. It is critical for control of mobile source emissions that all

components of a vehicle's emissions controlsystem bemaintainedaccording to the

manufacturer's specifications as detailed in the owner's manual. Such a public

educationeffort 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

metropolitanlevel.However,the Commission recognizes that mobile source emissions

from some areas have a disproportionate impact onvisibilityin the Colorado Plateau

Class Iareas.Strategies for addressing mobile source emissions withinClass Iareas

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 broader scale to achieve regional air quality

objectives. Any suchextensionwould be preceded byan 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 otherincentive-based schemes thatgive priorityto allocating discretionary

funding to transportationprojects thatare 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

vehicles. Examples include land use ordinances that favor development in existing

transit/transportationcorridors,highdensitydevelopmentneededto ensurethe viability

of mass transit, and co-located residential, business and commercialdevelopment to

support non-vehicular modes of transportation. If possible, this incentive-based

approach with state funds could be coupled with a similar preferential allocation of

discretionaryfederalfunding to statesand tribesthatdevelop 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-modaltransportationoptions throughboth public and

private investments;

b) encouraging local,state and tribalgovernments to reduceoreliminate

entry and rate regulations 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 qualityissues

generally (e.g., to showcase various communities' efforts), and

transportation alternatives within and between Class I areas in the

Colorado Plateau specifically.

3. Establish mobile source emissions budgets for selected major

urban areas.

 

To 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 Commission 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, there must be developed a credible and

replicable way of inventorying, tracking and reporting emissions.

a) Develop analytical criteria 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 criteria and an

analytical method for conducting such an analysis, and establish

requirements for adjusting urbanemissionbudgetsfound to be inadequate

to protect downwind areas, as well as accounting and enforcement

mechanisms.
45

b) Consider use of pricing strategies.

The economic pricing analysis called for above may indicate thatthe most

efficient method of complying with emissions budgets would be to institute

pricing strategies for use ofroadways thatinternalize 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 thatincrementalchanges 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 market-based program is deemed appropriate,

accountability for complying with the emissions budget must be clearly

assigned, with consequences attached to failure to maintain emission

levels consistent with the budget. For example, emissions from mobile

sources could be aggregated and responsibility for managing them

delegated to a private or public "broker", or assigned to a local/ regional

governmental entity. Alternatively, individuals (including businesses,

government agencies, etc.) could be given responsibility for managing

emissions 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 Commissionsuggests thatlocalauthorities consider the advantages ofretiring

higher polluting vehicles and develop incentives for citizens to upgrade to newer,

less polluting cars and trucks. 
46

AREA SOURCES

DUST FROM PAVED AND UNPAVED ROADS

Background:

Chapter IIof theCommissions November1995report,OptionsforWesternVistas, discussed

the limitations of the Integrated Assessment System results with respect to paved and

unpaved road dust. More recent modeling has shown that local sources of road dust play a

moreimportantrole thandistant sources. The Commissionhas considered this issue and has

concluded that there are good reasons to discount the Integrated Assessment System's

predictions about the regional importance of this 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. 

RECOMMENDATIONS REGARDING DUST FROM 

PAVED AND UNPAVED ROADS

Actions to address the control or reduction of emissions related to road dust are

found inthe recommendations regarding emissions "In and Near Class IAreas." The

Commission further recommends that voluntary measures be taken in local areas

in and near Class I areas to control emissions of dust from paved and unpaved

roads. Consistent with other Commission recommendations, 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 performance

standards for road dust emissions be developed.

Due to considerable skepticism regarding the modeled contribution of road dust to

visibilityimpairment,theCommissionrecommends further studyin 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 accumulated 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 inthe West and cost $1 billion

dollars in direct suppressioncosts while causing firefighter deaths and serious humanhealth

impacts. Rectifying this problem will take years and is a basic responsibility of wise land

stewardship.Fire is anessentialcomponent of most naturalsystems, and perpetuationof fire

at a level required to maintain ecosystem processes is necessary. The natural role of fire in

the wildland/urbaninterface 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

visibility-impairing aerosols, including organic carbon, elemental carbon, and particulate

matter (PM2.5). Agricultural 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

Wildfire 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 less 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 providesustainable ecosystemswhereenvironmentaland humanhealth impacts

canbe managed.This future desired situationcontrasts withthe current adverse public health

impacts and permanent damage to natural resources and property from wildfires. Wildfires

arecausing exceedancesofambient air qualitystandardsand airquality-triggeredcommunity

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 locationof burns so thatimpacts onhumanhealth are reduced.These

techniques can be expanded to reduce current and future impacts on visibility. Emission

reduction techniques can also be utilized to reduce the quantity of emissions from a

prescribed burn. The appropriateness and effectiveness of emission reduction techniques

varybased onvegetationtype,burnobjectives,location,other environmentalconstraints such

as water quality, and funding.Effective agriculturalsmoke management programs have been

developed in some states using similar measures.

Utilizationof mechanicaltreatments suchas logging or firewood sales to remove fuels will be

necessary in some areas prior to prescribed burning. The potential use of mechanical

treatments is limited, however, since large areas of the West are notphysically available due

to inaccessibility, slope or soil sensitivity. Significant emission reductions from mechanical

treatment would only occur in timber areas. Administrative constraints, suchas wilderness or

habitatprotection,alsoimposelimitations.Approximately30% of the totaltimber area has the

potentialto be treated using mechanical methods. In areas where mechanicaltreatments 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 protectionof visibilityin 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.

RECOMMENDATIONS REGARDING FIRE

1. Plan for the visibility impacts of smoke.

TheCommissionrecommends thatthe EPA requireallfederal,state,tribal,and private

prescribed fire programs to incorporate smoke effects in planning and applicationby

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,tribaland private land managers, in conjunctionwith relevantregulatory

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 In 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 could have an

adverse impact on health and visibility;

b) identifyareaswheremechanicaltreatmentscould substantiallyreduce

emissions and subsequent impacts on health and welfare;

c) in the areas identified, assess the feasibility of biomass utilization

(woody material use), market development, and non-statutory

administrative barriers11; and

d) assess meteorological information needs, air quality monitoring

needs, smoke dispersion model needs, interstate planning needs,

wildfire/prescribed fire trade-offs (economics, air quality and other

resource effects), and emissionfactor 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 programs (including

alternative management practices) and emissionreductionstrategies 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 management 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

between 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 year 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. 

TheCommissionrecommendsthatthe federal land managementagenciesand their

state, tribal, local and private counterparts identify and remove non-statutory

administrative barriers to emission reduction strategies by the year 2000, to the

maximum extent feasible. In removing such barriers, the Commission intends that

subsequent actions will be undertaken consistent with applicable laws and

regulations. 
51

CLEAN AIR CORRIDORS

Background 

One finding of the Commission's process is thatcleanair corridors exist. One suchsource of

cleanair studied by theCommissioncoversmajorportions of Nevada,southernUtah, eastern

Oregonand southwesternIdaho.This area provides cleanair days atGrand CanyonNational

Park. Projected emissions growth through 2040 within the studied clean air corridor is not

expected to have a perceptible negative effect onvisibilityat Class Isites. Cleanair 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 airfor all Class Isites onthe Colorado Plateau are protected, additionaldata collection

and analysis will be needed.

RECOMMENDATIONS REGARDING CLEAN AIR CORRIDORS

1. Do not establish special targeted programs at present.

TheCommissionconsideredwhetherspecialprograms or regulations wereneeded

in clean air corridors in order to protect the cleanair provided to Class Isites onthe

Colorado Plateau. Given the Commission's findings, there is no present need for

special targeted policies or regulatoryprograms to controlemissions growth within

clean air corridors beyond existing laws and programs. 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, aregionaltracking and

accounting system is needed to make sure that the frequency of clear days

increases or does not decrease at Class Isites and thatthe Commission's present

assumptions regarding populationand economic growth and the resulting effectson

increased 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 thatcause 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 cleanair 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 effects 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 withinand near Class I areas contribute to impaired visibility. Transportationrelated emissions and otheremissions from energyuse are of particular concern. Prescribed

fire emissions are also aconcernsinceland managersplanto increasenecessaryprescribed

fire activities in order to restore natural fire cycles and preserve natural ecosystems. 

Nationalpark generalmanagement plans and forestland 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 sustainabilityconcepts

into all plans and 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 morein-parktransportationsystems(suchas low-emission

shuttles), conversionof 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. 

RECOMMENDATIONS REGARDING EMISSIONS 

WITHIN AND NEAR CLASS I AREAS

1. Implement park and wilderness planning processes.

Federal land managers, throughtheirplanning 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 withintheClassIarea

does not cause visibility to deteriorate;
54

b) human-caused sources within the Class I area (or that result from

activities within the area) that contribute to existing visibility

impairment are mitigated; and

c) prescribed fire programs (excluded from 1a. and b. above), after

considering and applying non-fire alternatives whenever possible,

seek 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

examined and cooperative, enforceable management strategies developed and

implemented among tribal, local, state,federal, and private interests, as necessary,

to assure reasonable progress toward no human-caused impact on visibility (the

nationalvisibility goal). The development of management strategies must take into

account suchequity-related concerns as relative contributionto visibilityimpairment

and whether any one population(suchas lower-income groups) is unfairly burdened

by the strategies. Regulatoryand planning authorities have a pivotalrole in assuring

that sources near Class I areas are inventoried 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 systematic approach to address this issue. For example, existing regulatory

requirements for long-term visibility strategies and their review and revisionno less

than every three years should be enforced.

To this end, all land managers should:

a) be vigilant and aggressively pursue opportunities to participate in

external planning arenas where decision-making could have effects

on visibility in nearby Class I areas;

b) review permit applications for new or modified stationary sources

proposed for construction and operation near Class I areas; and

c) request that the appropriate regulatory authority (or authorities)

propose emissions reduction strategies for nearby sources that

contribute to existing visibility impairment, either during development

of the visibilityprotectionplans or during the required periodic review

of such plans.

Regulatoryprogramsshould provideexemptions for tribal ceremonialpractices and

for people who are dependent on a single source (wood or coal) of heating 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 nearbysource impacts onthe Class

I areas. Regulatory agencies should develop criteria for these plans that are

consistent across the Transport Region. An important element of this activity is the

development and maintenance of an emissions inventory, tracking, and reporting

program for eachClass Iarea. 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 include them in land management plans for lands located

near these areas. 
56

TRANSBOUNDARY EMISSIONS FROM MEXICO

Background

Pollution from stationary, mobile and area-wide emission sources in Mexico contributes to

visibility degradation in the Colorado Plateau's Class I areas. Expected economic

development in the border region 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 developemissions inventories,establishbinationalinstitutions and bilateral

agreements to facilitate cooperation, and create incentives for implementation of costeffective air pollution abatement strategies. 

RECOMMENDATIONS REGARDING EMISSIONS FROM MEXICO

Mexicansourcesare a significant contributor, particularly ofSO2 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 inventoriesand 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 anemissions inventoryforthe entire border

region. The Commission supports these efforts.

2. Establish binational institutions and agreements. 

The Commission urges the EPA, the U.S.State Department, and affected states to

make effective use of opportunities provided by existing binational treaties and

agreements. For example,AnnexV to the 1983 La PazAgreement directs the EPA

and INE (the National Institute of Ecology of Mexico) to assess the causes of, and

develop solutions to,air qualityproblems in border sister cities. As a result, the U.S.

and Mexicangovernments have developedanenvironmentalplanfor the border that

isperiodicallyrevised (next revision: summer1996);theNationalCoordinatorsmeet

regularly to discuss progress; and working groups composed of federal and state

officials (e.g., the Border Air Working Group) have been established to address
57

pollution problems in various media. The Border Governors' Association also

examines environmentalproblems in the border region. The Commissionsupports

these activities and is prepared to work cooperatively with these groups as

necessary/appropriate.

3. Develop community mechanisms for cooperative transboundary

planning.

While pollutiontransport from Mexico affects the West generally, localcommunities

in the border region are most severely affected and have the greatest need to

develop cooperative, creative approaches. Greater local involvement in decision

making will likely lead to more effective and expeditious pollution abatement

strategies. The Commission supports the designation 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 Mexicangovernments arecurrentlynegotiating aninternationalagreement

to institutionalize such an approach in the "Paso del Norte" region(ElPaso,Texas;

Dona Ana County, New Mexico; and Ciudad Juarez, Chihuahua). The Commission

supports this effort and recommends 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 bythe North American Free Trade 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 will have marked effects on regional air quality (e.g.,

emission control technology on major industrial or electricity-generating facilities).

5. Provide incentives for transboundary investment in pollution

control.

The Commission encourages the EPA to explore the feasibility of allowing U.S.

industries to earn emission reduction credits for investment in pollution control and

prevention projects in Mexico. These might be applied to existing Clean Air Act

programs for nonattainment areas or as part of a western regional emissions

management program implemented to protect visibility. Criteria and procedures for

awarding appropriate credits should be developed 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 internationalnegotiations directed at the Paso delNorte region

mentioned above include consideration of conducting a feasibility analysis for an

internationalemissions trading program.The Commissionshould supportthiseffort.

Conversely, the Commissionsupports disincentives to discourage U.S.companies
58

from investing in facilities in Mexico that do not achieve 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-distancepollutionofClassIareasonthe Colorado Plateau.

The Commissionencouragesthe respective federalgovernmentsto pursue,through

international negotiations and agreements, implementation of pollution reduction

strategies aimed at specific facilities thatmaybe found to have identifiable impacts

on the Colorado Plateau. 
 

12

For a more comprehensive discussion of technical and scientific needs, see "Subcommittee Report on

the Future Needs of the Commission," November 6, 1995, developed by a subcommittee of the Public Advisory

Committee.

59

FUTURE SCIENTIFIC AND TECHNICAL NEEDS

Introduction12

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 future regional policy

recommendations and development of appropriate implementation strategies by tribes, states

and federalagencies. In order to implement some of the recommended programs, additional

technicaldata 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 recommendations call for establishing mobile source

emissions budgets for selected major urbanareas, whichwill 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 Commission's projections regarding the relative

insensitivity of sources of clear air prove correct.

TransboundaryEmissions fromMexico:Cooperative workwithMexicanofficials and

corporations requires an accurate emissions inventory.

Air Quality on Tribal Lands: There is a need for more comprehensive emissions

inventories for areas onand near tribal areas as well as monitoring of air qualityon

tribal lands. The limitations of present models do not permit modeling of impacts on

tribal lands. 
60

Ingeneral,four types of initiatives are required to meetthe technicalneedsoffutureprograms:

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 inventory 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 aregionaltrading 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

inventory 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 EPA, it will be

necessary to measure and report on reasonable progress toward the goal of remedying

existing and preventing future impairment of visibilityin mandatoryClass Iareas. This implies

that federal, state, tribal, and local air quality agencies must 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

visualair qualitydata collectionin the GCVTC region. There are sixteen Class I areas onthe

Colorado Plateauthathave 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 Verde National Park

• Petrified Forest National Park

• Weminuche National Wilderness Area
 

13 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 onthe central

ColoradoPlateau,existing visibilityinthe vast majorityof the region, especially ontribal 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 ofregional models is needed to more accurately showthe 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 additionto technical inputs described above, information

related to the current levels of controls and installed technologies on sources, the control

options that are available for sources (including costs and efficiencies), and methods to

projectchangesin 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 assessment criteria

must be improved. 

RECOMMENDATIONS REGARDING FUTURE 

SCIENTIFIC AND TECHNICAL NEEDS

The Commission foresees that the following regional scientific and technicalwork 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 INVENTORY

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 developed prior to the start of data collection. All states,

tribes,and federalagencies should followthis plan, so thatdata collectionmethodsare

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 ways 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.

Agreementshould be reached onhowand for whatpurposes the data will beused.For

instance,states,tribesand federalagenciesshould determine whetherinventoriesand

analyses developed for regional programs and policy development can or should be

incorporated into national databases. 

5. Develop adequate trained human resources.

Agencies should bestaffedto conduct and maintainemissions inventories. In the past,

the EPA has not placed a high priority on emissions inventories even though they

provide the basis for state or tribal implementationplans, 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 ona per ton basis. As such, comprehensive micro-inventories are

needed for the near-field around Class I areas. Without them, it will be impossible to
63

reliably identify that portion of the contribution to visibilityimpairment caused by longrange transport of regional haze.

7. Agree on an emissions forecasting methodology. 

Agreement should be reached onthe source of informationand methods to be used

to forecast future emission changes related to economic growth and anticipated

effects from control programs. 

AIR QUALITY MONITORING

1. Continueandexpandthenumberofmonitoringsitesandfrequency

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 unknown.

Consideration should be given to expanding the coverage or redeployment of

resourcesinthe IMPROVE network to enhance completeness ofthe data set,including

on tribal lands. In addition, background surveillance sites could be established at

intermediate locations between the Class I areas and large regional sources

(metropolitan areas) to provide a better understanding of the intermediate course of

atmosphericchemistryand transport.Monitoring should bemaintainedatexisting sites

in order to allow for long-term trend analysis. 

2. Establish three essential components.

The three fundamental components of a future visibilitymonitoring program should be:

1) light extinction measurements from transmissometers; 2) aerosol chemistry

measurements from fine/coarse-mass-particulate samplers; and 3) meteorological

measurements ofwind speed,direction,temperature,and humidity. Tribal lands would

be particularly appropriate sites for tracking and monitoring case studies.

MODELING

Both sophisticated and reducedformmodels 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 region-wide issues can be

assessed with equal facility. 

1. Develop a comprehensive, sophisticated model.

A comprehensive model must be able to match its predictions of air pollution and

visualair quality with actual observations of both factors. This model should generate

output at least on a twelve-hour basis using emissions and meteorological
64

observations on this time scale. To 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. To 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 controloptions 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 transfercoefficientsshould beconstructedby 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 prevent 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-Agency Workgroup for Air

Quality Modeling. This review is needed to prevent future attributable impairment.

To assess regional impacts, new sources should be incorporated as part of the

process to address "reasonable progress." As noted above, EPA 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 regionalmodels are highly dependent oninput 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 givento expanding the network of

sites that collect upper air soundings. In addition, local meteorological data at the

Class Iareas are needed to identifypotentiallocalsourceimpacts.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

studyinclude:economic benefits of cleaner air(suchas 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 controlexpenditures

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 regionalhaze,specific components ofresearchand development are

needed, including:

a) expandedand improved inventoryof controloptions and costs for use

in assessments;

b) establishmentofamechanismto 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 for performing secondary

assessments. 
66

SECTION IV: TRIBAL PERSPECTIVES 

AND POSITION REGARDING RECOMMENDATIONS 

Introduction

The following section provides background regarding tribal participation inthe Commission

process and the legal framework for tribal relationships with states and the federal

government. Tribal participants in the process have also provided theirunique 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 report or provide a distinct perspective and emphasis arising from tribal

experience. These views are also set forth in this section. 

The Tribal 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. Vistas are important to tribes in spiritual and cultural ways but they are also

important for economic reasons. The pristine and visible beautyof theirhomelands 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

governments must address the needs of their developing nations. Tribes are working to

develop theireconomic infrastructure so thattheycanachieve self-sufficiencyand provide for

theirpeople,including revenuesfortribalgovernments.Tribalgovernmentsprovidecommunity

services, suchas road maintenance,water, environmentalprotection, education, health care,

day care and other social services. As in any community, the demand for these services is

expected to growwith the population, and tribes desire to groweconomicallyto 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,whatis fairfor states maynotnecessarily be fairfor

tribes. Tribal economies are muchless developed thanthose of states, and tribes must have

the opportunityto 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

Tribalgovernment approval and support of the Commission's recommendations is reserved

to individual tribal government discretion. This reservation is not intended to represent

rejectionof 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 directly with the federal government and may

choose to do so in regard to westernvisibilityprotectionand 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 theirabilities toward achieving a good

that will benefit all people in the West.

Anumberoftribes have beenrepresented onthe Commissionand onthe various committees

established by the Commission. Althoughthese "tribal participants," as theyare called in this

report, do not represent all 211 tribes in the Transport Region, as individualparticipants 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 Transport Region, as defined by the EPA, includes 211 tribes.

Therefore, visibility improvement and protection strategies ultimately adopted by the EPA

must be selected and implemented not only in light of statutory requirements of reasonable

progress toward visibility, but also in light of certainbasic principlesofIndianlaw.The GCVTC

recognizesand respects thatthe federaland tribalgovernmentshave aunique government-togovernment relationship that is built on historic legal principles. The Commission's

recommendations must be considered,notin terms of a federal-state framework,butinterms

of a federal-state-tribal framework. These principles of Indian law and their ramifications for

the Commission are set forth below.

Tribal 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 government could not. As a result, emission management

strategies will be implemented withinIndian country by tribal governments or, failing

that, by the federal government, but not by state governments. 
68

Federal Trust Responsibility

The Courts have found that the federalgovernment bears a trustresponsibility toward

American Indian tribes. This imposes fiduciary duties on the conduct of federal

agencies toward Indian tribes and their natural resources. The trust relationship

therefore presents a second basis, in addition to the principle oftribal sovereignty, for

the EPA and other federal agencies involved in the GCVTC process to ensure that

tribal interests are protected in any regulatory scheme. 

Tribal Self-Determination

As acknowledged by Congress in the Indian Self-Determination and Education

Assistance Act, there must be "effective and meaningful participation by the 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 EPA policy

for the Administration ofEnvironmentalPrograms onIndian Reservations (November

8, 1984) in which the EPA states that it will "view Tribal Governments as the

appropriate non-Federal parties for making decisions and carrying out program

responsibilities affecting Indian reservations, their environments, and the health and

welfare of the reservationpopulace." Eachtribeis the decision-maker for its own future

and is responsible for ensuring that the needs and rights of its people are met and

protected.Tribal concerns mustbetakeninto accountinformulating recommendations.

Tribal Impacts Reports and Studies

Tribal participants feel that the report Impact Projections of Emission Management

Scenarios on Western Tribal Lands (January1996), was inadequate and provided only very

general conclusions. The various other studies undertaken by the Commission did not

adequatelyevaluate and describe the unique economic structures and demographicpatterns

of Indian tribes, nor their unique cultures and aspirations. Also, the studies very narrowly

focused on straight line economic cost/benefitanalysis. Other values are important to tribes:

qualityof life, freedom of religion and choice inlifestyle,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.

Tribes were greatly disappointed that secondary assessment studies were not fully carried

out. Little or no work was done to identifyimpacts onhealth and welfare,land and water uses,

solid and hazardous waste disposal, threatened and endangeredspecies,and terrestrialand

aquatic ecosystems. This information would have been of great interest to the tribes and

probably many others.

Program Implementation

Tribal governments have the responsibility to develop, implement, and manage programs

withinIndiancountry. If a tribe chooses notto establishaprogram,thenthe federalgovernment

has the trustresponsibility to establish a program. Thus if the EPA promulgates a rule based

onacontroltechnologyscenario,for example,tribes must have the optionofimplementing the

rule withinIndiancountryor prompting federal implementationof the rule withinIndiancountry.
69

Similarly, a markettrading scenario inwhichthere was separate tribalparticipationor federal

participation on behalf of the tribes could be legitimate.

Many tribes are just beginning to develop environmental programs, and these programs

receive very minimal funding from the EPA, if any. Tribal 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 many tribal lands are "underdeveloped," tribes should be allocated

some additional share of trading credits to allow for future development, much as "clean"

states were under the acid rain trading program.

Tribes, states, local governments and federalagencies must find innovative ways to support

implementationofregional haze programs. Memoranda of Understanding or Memoranda of

Agreement,and/or other state/tribal/federalagreements, could beutilizedto shareresources,

expertise and responsibility.

TRIBAL PARTICIPANTS' POSITIONS ON COMMISSION RECOMMENDATIONS

As discussed above, the tribal participants for the most part concur in the Commission's

recommendations setforth in this report. Specifically, the tribal participants agree with all six

of the assessment criteria listed onpage 20-21 of this report, although the tribal participants

feel that 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 yetthe most threatened,ecosystemsarefound withinthe lands

of indigenous peoples. The lack of many basic necessities, suchas sustainable employment

and adequate housing,createsthe need for immediate economic development. Coupledwith

this is the lack of environmental protection infrastructure to manage and check efforts to

developeconomicopportunitieswhichareproceeding without considerationforthe traditional

Indiancommitment to resource conservation. Tribal communities, like others in the Transport

Region,have the opportunityto take a proactive approachto pollutionpreventionand to avoid

the mistakes of the past which have resulted inenvironmentaldegradation. Future initiatives

should make sure that growth planning and development is coupled with environmental

mitigation. 

Inthe firstsubsectionofSectionIIIof this report, various pollutionpreventionrecommendations

are offered, including economic incentives for pollutionpreventionefforts, encouragement of

zero and near-zero emitting technologies, and development of alternative (i.e., renewable)

power sources. The importance ofthese recommendations is indicated by the prominence

they receive in the Executive Summary of this report (they are listed as the first

recommendation). Tribal participants support this recommendation wholeheartedly.
70

However, the extent to whichdeployment ofrenewable energy will improve visibilityis not, nor

can it be, stated with certainty, based on the modeling outputs available. 

The modeling ofrenewable energycontrolscenarios is of paramount importance,particularly

to western tribes. A significant number of tribes (33) are actively pursuing development of

renewable energy and end-use efficiency technology applications. These development

options involve remote electrification,bulk powergeneration,improving reservationeconomic

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 provide grants to tribes to evaluate the feasibility of renewable energy

development.

The fact thatwesternreservations are prominent withinprime solarand wind energyresource

areas and a number are situated in major electricity transmission corridors has focussed

Congressional and tribal attention on joint ventures and other strategies for securing

investment capitalto build and operate bulk renewable electric generation capacity. Clearly,

apart from the income 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 vertically integrated electric

power industry. 

Tribal 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

Tribal participants are concerned that PSD and the current visibilityprogram (§ 169A) under

the Clean Air Act insufficiently address the national goals of preventing and remedying

visibility impairment in Class I areas caused by human-induced air pollution. Government

Accounting Office estimates indicate that sources accounting 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 onvisible plumes, rather thanregionalhaze,and veryfew

existing sources have been required to implement BART controls. 

Tribal participants in the Commission process support the stationary source

recommendations presented in SectionIIIof 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 SO2.

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 EnergyRegulatoryCommissionshould be used as

a basis for forecasts of future electric utility emissions and for

recommendations regarding emission reduction goals. This will also

enable the Commission 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 strategy is adopted, tribal participants recommend the

following: 

1. Tribes must be involved in the development of the trading scenario.

2. Credits should not be based onhistoricalemissions, but should be based

on equitable factors, including the need to preserve opportunities for

economic development ontriballands. In general, these lands are currently

lacking in economic bases and have not contributed to the visibility

problems. 

3. Whatever bodyadministers the trading program mustberepresentative 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 need for

controls and demonstrating vehicle maintenance methods for minimizing vehicle emissions.

Tribalparticipants are concerned about mobile source emissions from federal vehicles onor

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. Very few air quality monitoring programs have been placed in or near

tribal lands. To more accurately inventoryemissions 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 residentialheating. Programs should include a sole-source heating/cooking and

ceremonialburning 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

protectionmeasure,financialassistance 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. Althoughfire cancontribute significantly to visibilityimpairment, tribal participants

recognize that fire is an important management tool. Tribal 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 in their practice of religion and traditional cultural activities. Some of

these activities may be protected under the provisions of the American Indian

Religious Freedom Act. The availability of and access to areas where traditional

medicines and spiritual foods are located should not be diminished by fire

management practices. 

Clean Air Corridor Controls

Tribes should not be penalized for having clean air and little economic development.

Therefore,noinequitable restrictions should be imposed ontribaland othercorridorresidents

and/or economic growth.

Future Scientific and Technical Needs 

There is a need forthe developmentofcomprehensive emissioninventoriesonand near tribal

lands. These inventories may be used to provide more accurate data for future studies, and

to prioritize regulatorydevelopment. Tribalparticipants recommend thattheEPAassist tribes

inthiseffort.Infuture tribalpopulationand socio-economicstudies,the data collectionprocess

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 specialattention. Giventhe diversityof tribal

populations and land bases, the broad-based regionaland 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.

Tribes need to be meaningfully involved in the development and implementation of future

technicalstudies and in accommodating the specialneeds of tribes in various studymethods

and tools. Tribes 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 ADMINISTRATIVE NEEDS

Background

The Grand Canyon Visibility Transport Commission represents an experiment in regional

policy development through cooperative partnership among state, tribal and federal

governmentalentities. The Commissionhasalsoengagedabroadrangeofinterestedparties

from industry, environmental organizations, academics, technical experts, elected officials,

and various citizens' organizations. Throughout this process, the Commission has provided

a means for cooperative development of improved scientific information and for

intergovernmentalconsiderationofpolicyrecommendations.Thefollowing recommendations

regarding future administrative needs draw on this experience.

RECOMMENDATIONS FOR FUTURE ADMINISTRATIVE STRUCTURES

1. Continue a regional air quality entity, similar to the Commission.

The implementation and ongoing review of regionalhaze management strategies will

require the work of an entity similar to the present Commission, most likely in a

streamlined structure, based on the evaluation performed in recommendation #4

below. 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 reflect the larger geographic entity it serves. The primary role of the

Commission, or its successor, will continue to be coordinationand monitoring in order

to recommend policies to the appropriate entities. States, tribes and federalagencies

will undertake implementation actions. 

An equitable body of state, tribal and federal representatives should convene, as

necessarybut at least annually, for the purpose of: discussing visibilityand other air

quality issues, including public health concerns, and coordinating data collection

efforts, and making recommendations to theEPAonreasonable 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 regional air

quality needs and planning efforts.

It is expected that the EPA 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 onvisibilityand health throughout the WesternUnitedStates.(If the

mandate isexpanded the name of the successor body should reflect the newmission.)

3. Establish functions of a successor entity.

After it makes its initial recommendations to the EPA, 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 EPA on EPA's interpretation

and implementation of Commission recommendations;

b) coordinating implementation of inter-jurisdictional mechanisms for

addressing regional haze, including monitoring activities;

c) tracking implementation ofprograms for addressing regionalhaze to

ensure equity;

d) assessing emissions and visibility data to determine if reasonable

progress is being made towards the national visibility goal, and

recommending adjustmentsto regionalhaze managementstrategies,

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 assessmentmethodologies in the Westto ensure

that such efforts are focussed on concerns relevant to policy

formulation14; 

g) providing a forum for interested parties to offer input on the

development of regional haze policies;

h) promoting and supporting educational programs furthering visibility (or

expanded air quality) goals, in publicschools,in higher educationand

to the general public; 

i) supporting energy-conservation measures; and
76

j) promoting outreach and communications programs for tribal

communities in order to address the remoteness and educational

needs of most Indian reservations. 

4. Evaluate and review Commission structures.

In order to create efficient, effective and sustainable long-termstructures,anevaluation

oftheCommission'spresentand 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. To 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 throughits report to the EPA 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 ongoing 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 consistofanequitable bodyof federal, state and tribal

representatives. Public participationin futureeffortsshould beensuredthroughthe use

and creation of publicly accessible working groups.

5. Develop ongoing funding mechanisms.

In order to estimate the resources, human and financial, that will be necessary to

sustainthiswork(e.g.,basicadministrative functions,specific researchand monitoring

activities), a projected five-year budget should be developed in conjunction with

development of a comprehensive plan for future operations. 

The EPA should provide ongoing financial support for the basic administrative

functions of the Commission or its successor. Work should continue in cooperation

with the EPA to support efforts to secure such funding. In the course of evaluating all

current Commissionfunctions (see #4 above), the benefits and feasibilityof additional

sources of funds for specific activities should be explored, including: 

a) visibility surcharges onentrance fees for Class Iareas 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 thatregionalhaze managementstrategieswhichare implemented meetwith

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, monitor

interpretation by EPA of the Commission’s recommendations,

seek funds for future operations, and perform needed interim

tasks;

b) Prepare a comprehensive set of recommendations regarding

how and in what form to continue the Commission by early

September 1996, building on the recommendations in this

section above. These recommendations will include provisions

regarding:

• the structure of theCommissionand any subsidiarybodies;

• the participation of states, tribes, and federal agencies on

the Commission;

• involvement of stakeholder representatives inCommission

processes;

• administrative arrangements;

• the scope of Commission activities; and

• changesin theCommission’sby-laws neededto implement

a reconstituted Commission.

By mid-September 1996, the Operations Committee will distribute its detailed

recommendations as above to the Commissioners by mailed ballot for action.

Note: Fortribalperspectivesand commentaryontheserecommendations,see

Section IV.
78

SECTION VI: ANALYSIS OF THE COMMISSION'S RECOMMENDATIONS

Introduction

This section presents the Commission's analysis of the likely effects associated with its

recommendations. The analysis attempts to address these key questions:

1. How will the Commission's recommendations affect visibility at Class I sites in the

Transport Region?

2. What are the likely economic effects, both direct and indirect, of the Commission's

recommendations?

3. What are the likely environmental, social, 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 effects 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 recommendations 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 programsarelikely to affect visibilityat Class Iareas

on the Colorado Plateau through 2040. The Commission used this "current law" scenario to

evaluate the additional 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 the 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 graphrepresents the difference between the estimated visibilityconditions 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

notcharacterized as incorporating cleaner emissions technologiesovertimeas is likelyunder

current and future air quality management programs. To address this shortcoming, the

Commissiondevelopeda "bounding" estimate of the upperlimitvisibilityconditions thatcould

result from making adjustments to the Integrated Assessment System baseline assumptions

for both growth of certain sources and future controlled emissions from certain sources. 

Thesecond graphlabeledFigureVI-1B:"VisibilityRangeExpectedfromRecommendations",

reflects this approach. The darkly shaded area of this graph represents the difference

between holding visibility constant from the year 2000 to a maximum potential improvement

from changes inthe Integrated Assessment System baseline assumptions and future source

control levels. To define the maximum source control, certain source categories were

assumed to reduce their contribution to extinction over time in a way similar to Integrated

AssessmentSystemsourcecategories thathadtechnologicalimprovementsofapproximately

74% reduction from 1990 levels of impact. This probably results in an overprediction of the

likely effect, however 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 graphs 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 visibilitylevel. 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 inthe second graphinFigure VI-1 mayappear 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. 
80
81
82

ANALYSIS OF SPECIFIC COMMISSION RECOMMENDATIONS

Introduction

This sectionreviews ingreater detailthe 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 sectionis an

overview of the Commission's efforts to develop rough cost estimates for its

recommendations. The second part of this section discusses specific Commission

recommendations. Visibility and costs are addressed in connection with each set of

recommendations. The remaining four criteria are discussed as a separate group. 

The Commission'srecommendations reflect,butaresubstantiallydifferent from the scenarios

developed initially by its technical committees. The Commission represents a range of

interests, and its recommendations exhibit the real world of give and take among these

interests. The Commission could not simply decide to adopt one of its earlier scenarios

becauseCommissionmembersneededto address a range of concerns notreflectedinthose

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 thatdata about visibilityeffects often are stated in terms of anannualaverage.

This average 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 onthe Colorado Plateau, due

to wind patterns. On days whenthose improvements are observed, they will be much greater

than the annual average.

Another important point is thatmost of the modeling to date addresses visibilityeffects at only

one receptor: Hopi Point in Grand Canyon National Park. This receptor is not necessarily

representative ofall Class Isites, but it offered a substantialamount of high-qualitydata.Hopi

Point may have unique localized influences, and it is also influenced by emissions from a

combinationof directions thatmaynotoccur at otherClassIareas.Toaddress these potential

limitations, the Commission has analyzed three other Class I areas. This broader approach

makesmoreemissionsource regions relevant to the analysis, but is notacomplete 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 recommendations at this time. The recommendations are largely

conceptual in nature, and the direct and indirect costs and benefits will vary

depending on when and how specific strategies are implemented.

The Commissionhas developed preliminaryroughprojections of the directand indirect costs

of achieving visibilityimprovementsatClassIareasontheColorado Plateau. Direct costs are

the costs of imposing emission controls to improve visibility. Indirect costs are the additional

effects onthe region's economyfrom 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 ofthe federalCleanAirAct, 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 afirststep,theCommissionhas developed roughestimates of some of the potentialcosts

and benefits associated with emission management options that bear some similarity to its

recommendations. These emission management options were designed early in the

Commission's process, and do not match the Commission's recommendations. 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 reflect 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 potentialrange of costsafter2010undertheCommission's

preliminary rough estimate is from $500 million to $1.8 billion per year. (These cost

estimates weregeneratedbythe IAS based onoptimizationruns 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 notreflect any cost savings or economic

benefits thatmaybe associated with these emissionreductions, 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 encouraging "clean" sources of energy in new industries. Several

recommendations will probably have direct economic effects. One example is

recommendation#3,whichsupports economic incentives to promote industrialretooling that

reduces emissions. Another example is recommendation#6,whichsuggests the possibility

of charging emission fees for air pollution. 

Analysis of Stationary Source Recommendations

Visibility and Cost Effects

Therecommendations regarding stationarysourcesinvolves establishing emissionreduction

targets for sulfur dioxide consistent with those anticipated under the Baseline Forecast

Scenario, which was designed to reflect requirements under current regulations. 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 costswould beincurred to impose controls if the targets are met. The

only cost of the program would be the administrative aspects of collecting and analyzing

information on emission trends in the Transport Region. 

If emission reductions 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 bedealtwith thoroughly in developing a detailed implementationplan. 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. To 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 through2040 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 impacts on visibility,

primarily from tailpipe emissions.
85

Currentmodeling shows thatapproximately 30% (3.5 Mm-1) of the annualhuman-caused light

extinction at Hopi Point in the year 2000 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 nationalstrategy, 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 NOx

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 whetherthe modelunderestimates

this impact.

Potential visibility benefits from all other mobile source categories (off-road vehicles, boats,

airplanes, locomotives) are approximately 11% of the total mobile source contributionbased

on current modeling.

The Commission has not modeled the visibility effects of its proposed regional and local

mobile source initiatives. The same limitation applies to estimates of the costs associated

with imposing mobile source controls. Depending on the costs associated with different

categories,itmaybe cost-effective to achieve the relativelysmallvisibilitybenefitsassociated

with different national strategies 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 Transport Regionare atrisk 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 that emissions from fire, both wildfire and

prescribed fire,is likely to have the single greatestimpact onvisibilityat Class Iareas through

2040. Current modeling indicates that, at certain times, increased visibility impairment from

fireis likelyto exceed the potentialvisibilityimprovements associated with other Commission

recommendations.

The Fire Emissions Project of the Commission found that, historically, fire occurred on

approximately35millionacresannually. This corresponds to anannualvisibilityimpactof8-13

Mm-1. Current prescribed fireprogramsacrossthe Transport Regioncover approximately 1.2

million acres annually. In 1995, PM2.5 emissions from prescribed fire were estimated to be

approximately 75,000 tons per year, less than 1% of total PM2.5 emissions from all sources

in the Transport Region. The proposed future prescribed fire programs of land managers

would treat approximately 6 million acres annually by the year 2040, increasing the relative

contribution to 3% of total PM2.5 emissions in the Transport Region. This projected target is

consistent with current land management agency fire policies, but is dependent onavailable

resources and funding. Significant increases in fire on all wildlands will occur, whether by

managedprescribedfireor byuncontrolled 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 occur 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 evenworse,rather thanimpair visibilityonclear days. Both prescribed fire

and wildfire activityaredependent onweather conditions, resulting in visibilityeffects thatcan

fluctuate widely from year to year. Table VI-1 shows the range of visibility impacts that are

projected to occur from the use of prescribed fire and wildfire.

TABLE VI-1

Annual Average1 Prescribed Fire/Wildfire Visibility Impacts in Mm-1

Year Prescribed Fire

Baseline2

Prescribed Fire

with Maximum

Controls3

Wildfire4

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 and 2040 reflect projected prescribed fire programs under current land

management policies. Emissions 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 measures (mechanical treatment, etc.).

These impacts may be further mitigated by managing the timing of burning based on meteorology.

4 Although 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 recommendations 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. 

Evenusing "optimal" smoke management measures, prescribed fire's contribution to annual

visibility impairment at Hopi Point could increase by 400% between 1995 and 2040. The

Commission's fire modeling projectsthatuseofoptimalsmokemanagement measures could

decreasefine particle (PM2.5)emissions fromprescribed fires byapproximately15-20%.This

would limit the increased visibility impairment at Class I areas that likely will be caused by

prescribed fires through2040.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-$2,000per tonofPM2.5 reduction.Reducing PM2.5 emissions by15-20%

over projected increases is estimated to cost approximately $65-$75 million annually. 

Analysis of Clean Air Corridors Recommendations

The Commission is not recommending 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 air 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 oftransportationand 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 Iareas deserve particular attention because they have

potential immediate consequences for visibility. Approximately two-thirds of particles

measured at Hopi Point consist of fine soil and coarse material (PM2.5 and PM10). Fine soil

from sources near and distant from Class Iareas accounts for about one-third of the visibility

impairment caused by particles. Sources of coarse material have relatively small spheres of

influence,i.e.,coarsematerialgenerally doesn't travelfar.As a result, the data fromHopiPoint

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 Commissionrecommends improved planning to reduce visibilityeffects from sources of

coarse material and fine dust both within and near Class I areas. The Commission's model

does notallow modeling of the potential visibilityimpacts of this recommendation. The same

modeling limitation applies to the recommendation that strategies be developed to limit

emissions from local sources.

The Commission has not quantified the visibility benefits associated with its

recommendations concerning other transportation and energy-related emissions. The

Commission has not developed any cost analysis for these recommendations.

Analysis of Transboundary Emissions Recommendations

Visibility and Cost Effects

The Commission's model 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 industrialand residential sources near the U.S.-Mexico

border. Of the remainder, approximately half is attributed to specific stationary sources; the

remainderto off-shoreshipping emissions thattravelacross Mexico to theUnitedStates.This

is approximately 17% ofmanageable visibilityimpairmentatHopiPoint onanannualaverage

basis. Using an annual average likely understates the impact ofthese emissions on a given

day, because meteorologicalconditions limittheirinfluence to approximately25%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 transboundaryemissions (about60%)areSOx,and mostcome 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 annualtotaltransboundarylightextinctionatHopi Point.

The Commissionis aware ofreports 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 visibilitybenefits 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 waythatemissions from sources located withinthe United States are manageable.

The Commission is unable at this time to estimate the potential costs associated with its

recommendations.
89

Analysis of Scientific and Technical Needs Recommendations

TheCommissionhasmade a number ofrecommendations thatincludeadditionalmonitoring,

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 mixofthe specificand the general.While analysis

of the economic, social, environmental, equity, and administrative impacts of specific

recommendations can yield robust conclusions, predicting the effects of general

recommendations is at best an uncertain process. This is particularly true for the 211 Indian

tribeslocatedontheColoradoPlateau,whosepeoples have unique economies and lifestyles.

These issues are addressed more fully in Section IV on "Tribal Perspectives" in this report.

The Commission's economic model also has certainlimitations. The process for evaluating

criteria other than costs relies primarily 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 output has limited utility at best in

assessing impacts for these groups. 

The Commission's equity concerns include addressing the following questions: Are the

sourcescausing the problempaying for/contributing fairly to the solution?Aresourcescausing

the problempaying forthe solutionin proportionto theircurrent contributionand currentcontrol

levels? The Commission's formal assessments have not analyzed whether some income

groups will be affected more than others or whetherthere are ethnic patterns to the outcomes

of the recommendations. These issues are of particular concern to areas which are relatively

underdeveloped within the Transport Region. 

With respect to equity for rural and underdeveloped areas, including most tribal lands, it is

important to note that such areas 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 theirrole as anemissions 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 primaryand secondaryassessmentprocess(e.g.,lack of emissions data

for tribal lands, inability of the economic model to analyze areas smaller than a county, and

lack of tribal data inputs to economic modeling) require continued vigilance to guarantee

strong application of the equity criterion in all implementation plans and in monitoring the

impacts of the Commission's recommendations.

With these limitations in mind, the Commission offers its perspective on the so-called

"secondary" impacts associated with its recommendations.

Tourism. 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 are
90

important contributors to the economyas well as the qualityof 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 thatassess the link betweenair qualityand parkvisits, so stronger conclusions

cannot be drawn.

Air Pollution Prevention. The Commission's recommendations concerning air pollution

prevention illustrate the limitations of projecting effects at this time. The recommendations

themselves are 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 some economic benefits, in the form of

increased investment inalternative technologiesand increased employment in the alternative

technology sector. Some Indian tribes have invested significant resources in this area, and

could benefiteconomically from expansionof alternative energytechnologies and creationof

incentives for their use.To the extent there are economic benefits to Indian tribes investing in

these technologies, it is reasonable to expect some social benefits. "Clean" technologies

would likely have anoverall positive impact onthe environmentofthe region.However, a more

specific conclusionwould requireknowledgeofthe specific technologiesunderconsideration.

Stationary Sources. Turning to the recommendations about stationary sources, there are

some important concerns. Under a regional cap/trading program, there are fundamental

questions about how initial credits will be allocated and how reductions would be timed. If

credits are allocated simply on the basis of historical emissions, there are potential equity

issues for newemissions sources. This concernhas beenraised specifically by Indiantribes.

There also are significant equity and 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. To the extent thatnationalstrategies, suchas 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 Commissionis aware of the potentialequityimpacts associated with some of its mobile

sourcerecommendations.One example is retiring high-emitting vehicles.Thesevehiclestend

to be owned bypersons 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 Transport 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 timber, agriculture, and habitat management operations. Any

policy thatrestricts the abilityofthesetribesto developtheseoperations could have animpact

disproportionate to that felt by other groups, such as federal land managers. This issue is

discussed further in the section on "Tribal 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 ruralcommunities, or Indian tribes. One potential emissions source inthese

communitiesisunpavedroads.Measuresto reducedustcould have disproportionate impacts

onthesecommunities,and ongroups withineachcommunity.Paving roads canincrease 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 urbanareas

also raise equity issues involving who should bear the cost of addressing mobile and area

source emissions that are part of these plumes.

Transboundary 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 addressed in the

section on "Tribal Perspectives."