WRAP Regional Haze RuleReasonable Progress Report SupportCassie Archuletacarchuleta@air-resource.comEmily Vanden Hoekevandenhoek@air-resource.comTom Mooretmoore@westgov.org1June 17, 2013Outline3⁄4Background3⁄4Progress Report Support DocumentData SourcesData PreparationRegional, State and Class I Area specificexamples3⁄4Branch ProjectsWRAP Technical Support System UpdatesNatural Conditions Review Document3⁄4Next Steps and Discussion Topics2National Visibility Goal3⁄41977 CAA Amendments (§169a)“Congress hereby declares as a national goal theprevention of any future, and the remedying of anyexisting impairment of visibility in mandatory Class IFederal areas which impairment results from manmade air pollution.”3⁄41999 Regional Haze Rule (40 CFR Part 51 §308and 309)Establishes requirements for implementation plans,plan revisions and periodic progress reviews toaddress regional haze in Federal Class I Areas(e.g. National Parks and Wilderness Areas)3156 Visibility Protected Federal Class I Areas(e.g. National Parks, Wilderness Areas)4Visibility Metrics3⁄4Visual QualitiesThe color, texture, and clarity of a scene3⁄4Visibility Metrics:Extinction/Scattering/Absorption (Mm-1)The fraction of light lost perunit length along a sight pathUsed to represent individual speciesDeciview (dv)An index which is linear with human perception of visibility(Logarithmic transformation of extinction)Used to track visibility impairment for RHR5SulfatesNitratesSoilOrganicsCoarse MassElemental CarbonABSORBERSea SaltSCATTERERS3⁄4Interagency Monitoring of Protected Visual Environments (IMPROVE)Aerosol samplers3⁄4Network that supports RHR3⁄4Began in 1988, expanded in 20023⁄4Several particulate species are measured3⁄424-hour samples every third day3⁄4Light extinction is calculated from aerosol mass and RHMeasuring VisibilityIMPROVE Aerosol Samplers6WRAP IMPROVE Monitoring Sites3⁄4WRAP Class I Areas and IMPROVE Monitoring Sites116 CIAs represented by 87 IMPROVE SitesWRAPFederal CIAs andIMPROVE SitesFederal CIAIMPROVE Monitor7EPA RHR Guidance3⁄4September 2003:Guidance for Tracking Progress Under the Regional HazeRule3⁄4September 2003:Guidance for Estimating Natural Visibility Conditions Underthe Regional Haze Rule3⁄4April 2013:General Principals for the 5-Year Regional Haze Progressreports for the Initial Regional Haze State ImplementationPlans (Intended to Assist States and EPA Regional Officesin Development and Review of the Progress Reports)Note: April 2013 Guidance was released as this supportwork was being finalized8EPA’s Regional Haze Rule2000-2004Baseline2018Interim Goal2064“NaturalConditions”3⁄4EPA introduced concept of a linear “glide slope” from2000-2004 Baseline averages to 2064 “NaturalCondition” estimatesInitial SIPs (due in 2007) planned for a 2018 Interim Goal92000-2004Baseline2018Interim Goal2064“NaturalConditions”2005-2009ProgressPeriodFutureProgress Periods(e.g. 2010-2014, etc.)3⁄4SIP revisions are due every 10 years (next is due in 2018)3⁄4Progress reports are due between full SIP revisionsOriginal 2003 EPA Guidance specifies that progress shouldbe assessed using 5-year successive average period(e.g. 2005-2009, 2010-2014, etc.)RHR Reasonable Progress Reports103⁄4Summary report prepared by ARS on behalf of the WRAP for thewestern statesInvolved extensive consultations with state representativesDesigned with regional, state and CIA specific summaries to providethe technical basis for states to draft their progress reports3⁄4RHR requirements addressed by WRAP progress report:What are current visibility conditions for the most impaired and leastimpaired days?What is the difference between current visibility conditions andbaseline conditions for the most impaired and least impaired days?What is the change in emissions between the baseline period and theprogress period?3⁄4RHR requirements to be addressed by States:What is status of implementation of SIPS measures?Are current implementation plan elements and strategies sufficient tomeet reasonable progress goals?The WRAP Reasonable Haze RuleReasonable Progress ReportSupport Project11The WRAP Reasonable Haze RuleReasonable Progress ReportSupport DocumentOUTLINE3⁄4Glossary of Terms3⁄4Executive Summary3⁄4Introduction3⁄4Regulatory Requirements3⁄4WRAP Regional Summaries3⁄4WRAP 309 States Regional Summaries3⁄4State SummariesIncludes the following Sections for each stateMonitoring Data•Current Conditions•Differences between Currentand Baseline Conditions•Changes in Visibility ImpairmentEmissions Data•Changes in Emissions•EGU Summaries3⁄4References3⁄4Appendices: Alaska (A) through Wyoming (O)Tables and Charts with 5-year, annual, monthly and dailyaverages and annual trend results for each site(8 pages of tables/charts per site)12Data SourcesMonitoring Data3⁄4IMPROVE data through 20103⁄4Data filling work performed for this project:Substituted data, Sierra Ancha WA, AZ; 2006 – 2008Baseline data estimates (for Zion NP, UT andHaleakala NP, HI)Emissions Data3⁄42002 emissions originally used for RHR planning3⁄42008 emissions from WestJumpAQMS and DEASCO3modeling projects3⁄4AK and HI emissions as provided by states3⁄41996-2010 sum of annual EGU emissions by state13Data Preparation WorkSIAN1 Data Substitutions3⁄4Data SubstitutionsThe RHR requires 3 complete year for each 5-year averageARS previously worked with the WRAP and VISTAS to substitutedata for 15 CIA IMPROVE sites for baseline (2000-2004) yearsFor the WRAP, only the Sierra Ancha site (SIAN1) site requiredprogress period substitutions.3⁄4MethodsSeasonal correlation ofsurrogatesOn Site surrogatesE.g., organic H for POMOff Site surrogatesTONT1 used for SIAN1Note, SIAN1 was used forTONT1 during baseline yearsSierra Ancha WA14Data Preparation WorkBaseline Estimates3⁄4RHR requires a 2000-2004average as a baseline startingpoint3⁄4Two WRAP sites were movedto better represent the CIAs3⁄4Zion National ParkNew ZICA1 site beganmonitoring in 2003(2004 was first full year)Baseline estimated usingprogress/baselineaverage ratiosfrom nearby sites3⁄4Haleakala National ParkNew HACR1 site beganmonitoring in 2007Baseline estimated usingprogress/baseline ratiosfrom HALE1 site15Current Conditions Summaries3⁄440 CFR 51.308 (g)(3)(i) and 51.309(d)(10)(i)(C):What are thecurrent visibility conditions for the most impaired and least impaireddays?Note that current conditions for this report were defined as themost recent successive 5-year average, as per original EPA2003 guidance:“ ...averages over the 2000-2004 time period are the basisagainst which improvements in worst day visibility and lack ofdegradation for the best day visibility are judged. Correspondingaverages are to be calculated over successive 5-year periods, i.e.,2005-2009, 2010-2014, etc.”New (April 2013) EPA Guidance states that:“...the reports should include the 5-year average that includes themost recent quality assured public data available at the time thestate submits its 5-year progress report for review.”16What are Current Visibility Conditions?3⁄4Regional Summary – annual averages, worst days17What are Current Visibility Conditions?3⁄4State/CIA SummariesExample for Oregon’s CIAs:18Differences Between Currentand Baseline Conditions3⁄451.308(g)(3)(ii) and 51.309(d)(10)(i)(C):What is the difference between baselinevisibility conditions and current visibilityconditions for the most impaired and leastimpaired days?Differences presented here are summarizedas the difference between the 2000-2004baseline average and the most recentsuccessive 2005-2009 5-year average.19What is the Difference Between Currentand Baseline Visibility Conditions?20% Best days(RHR says these can’t get worse)20% Worst days(RHR says these must improve)20What Species Have Decreased?3⁄4Map only shows species that decreased (increasing species not shown)3⁄4Sites where DV decreased are highlighted in blue21What Species Have Increased?3⁄4Map only shows species that increased (decreasing species not shown)3⁄4Sites where DV increased are highlighted in purple22What is the difference between current andbaseline visibility conditions?23Current Conditions Summaries3⁄440 CFR 51.308 (g)(3)(iii) and 51.309(d)(10)(i)(C):What is thechange in visibility impairment for the most impaired and leastimpaired days over the past 5 years?Changes in monitoring data for this report were reported ascharacterizations of factors that affected changes, including:10-year annual average trends (robust Kendall-Theil trend statistics)Identification of outliers and extreme events that may have influencedthe 5-year averages.Supported byState-specific Appendices that contain 5-year,annual, monthly and daily average tables and charts for each CIA(intended as reference for further investigation of factors thataffected change).Note that new (April 2013) EPA Guidance states that:“... the ‘change in visibility impairment for the most impaired andleast impaired days over the past 5 years’ is comparing the 5-yearaverage for the beginning of the 5-year time period with the 5-yearaverage at the end of the 5-year time period.”24Annual Average TrendsAmmonium NitrateAmmonium NitrateAll Measured DaysAnnual Average TrendsAmmonium Nitrate20% Worst daysAnnual Average Trends255-Year Average Differences vs. Annual TrendsAmmonium SulfateAmmonium Sulfate20% Worst daysAnnual Average TrendsAmmonium Sulfate20% Worst daysDifference Between 5-yearProgress and Baseline Periods265-year Averages andAnnual Trends3⁄4Example ofincreasing5-year averageAmmonium Sulfate, with adecreasingtrend27What Factors Are Affecting Baseline toProgress Year Differences?3⁄4Outlier years, e.g.The THSI1 site in OR showed and increase in dv average (+0.8dv), mostly due to anincrease in coarse mass (80%of increase), which was affected by higher than averagemeasurements in 2009Three Sisters WA, OR (THSI1)High Coarse Mass28What Factors Are Affecting Baseline toProgress Year Differences?3⁄4Seasonality effects from best/worst day identificationWorst days are identified from a sum of all species measurements, sosporatic events such as firecan drive the worst days into different seasons of different yearsExample below shows a higher ammonium sulfate average on the worst day in 2008, due toidentification of more daysin the high sulfate season.20022008YearAll DaysAverage(Mm-1)Worst DayAverage(Mm-1)20025.3 7.820084.9 9.0Diff.-0.4 Mm-1+2.2 Mm-1Average AmmoniumSulfateMore worst days in May – Jul.More worst days in Aug. – Oct.Chiricahua WA (CHIR1), AZ29Emissions SummaryRequirements3⁄451.308(g)(4) and 51.309(d)(10)(i)(D)?:For pollutants that affectvisibility at CIAs, how have total emissions in the state changedover the past 5 years?Compared using 2 inventory years, at two points in time2002 WRAP supported data used in initial SIP•Plan02d data for most states•Plan02c for California•2005 for HI2008 WRAP supported data (contiguous States only)•WRAP WESTJUMP08 inventory(http://wrapair2.org/WestJumpAQMS.aspx)•Comprehensive inventory developed for upcoming WRAPmodeling efforts•Began with 2008 NEI v2, with a number of enhancements(e.g. oil and gas, windblown dust, biogenics, fires)2008 State provided data (AK and HI)30What Are the Changes in Emissions?3⁄4Differences in emissions characterized as state level sums for eachpollutant and categoryPollutants: SO2, NOX, NH3, VOCs, POA, EC, Fine Soil and coarse massSource Categories: Point, Area, On-road mobile, Off-road Mobile, Fugitive Dust,Wildland fires, anthropogenic fires, Biogenics and Windblown Dust31Comparisons of Area and Off-RoadMobile NOXEmissions3⁄4Report includesLOTSof caveats about changes in inventory methodology that affectthe differencesE.g., in example below, differences are likely Influenced by reclassification of locomotives andsome categories of marine vessels from“Off-Road” to “Area” (aka “non-point”) in 2008320100,000200,000300,000400,000500,000600,000700,000800,000900,000 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010AnnualEGUEmissionsWRAPRegion1996‐2010SO2(tpy)NOX(tpy)What are the Changes in Emissions?Annual EGU Plots3⁄4Report includes regional and statespecific charts showing annual totals for ElectricalGenerating Unit (EGU) emissions3⁄4Reductions in SO2and NOXemissions from EGUs are generally critical elements ofeach State’s regional haze strategy3⁄4More informative than comparisons of 2002vs. 2008 inventories because these sourcesare more consistently tracked year-to-year (EPA’s Air Markets Program Database)33RHR Reasonable Progress ReportSupport Document3⁄4Primary PurposesProvide technical basis for States to meet RHR requirementsfor monitoring and emissions data analysis3⁄4Secondary Purposes:Opportunity for States to provide additional feedback on newWESTJUMP 2008 inventoriesNote, these had smaller workgroup review processes, but thisproject provided perspective on new emissions summaries ascompared to 2002Provides some support in anticipation of 2018 SIP revisions3⁄4Branch Projects (summarized briefly on next slides)Updates to WRAP TSS website to support progressassessmentsNatural Conditions Summary Paper34Branch Project:WRAP Technical Support System Website Updateshttp://vista.cira.colostate.edu/tss/Results/HazePlanning.aspx• Tools were originally developed to support initial SIPs forWRAP states• Several updates were recently added to support progressreports (examples of updates shown on next 2 slides)• ARS will host a TSS training later in June, 201335Example TSS update:WRAP TSS Glide Slope DisplaysGlide Slope DisplayOptions:• Successive Averages(e.g. 2000-2004,2005-2009, etc.)• Rolling Averages(e.g. 2000-2004,2001-2004, 2002-2006, etc.)• With and without 2018projections and 2064Natural ConditionsSuccessive Averages(w/ natural conditions)Rolling Averages(w/o natural conditions)36Example TSS update:County Level Emission Summaries3⁄4Support document contains State level emissions summaries3⁄4County level summaries are available from the WRAP TSS37Branch Project:Natural Conditions Summary Project3⁄4ARS drafteda general literature review, whichpresented some background on NaturalConditions and a summary of current status, issues and options in one report. Includessome discussion of:EPA “Default Conditions”Revised “Natural Conditions II”Newer work, including:A fairly comprehensive 2008 Natural Conditions review and sensitivity study by Ivar Tombach, PhDDiscussion topics, brainstorming and feedback from a May, 2013 WESTAR MeetingMap Depicting “Natural Conditions II” estimates used in initial State SIPS38What’s Next?Discussion Topics (slide 1 of 3)3⁄4How should States use WRAP support document inprogress reports?Summary products address monitoring and emissions inventoryRHR requirements.States can copy/edit background and summary text out ofdocument.States can copy and paste charts from report body and appendix.States can also use WRAP TSS products to further tailor datarepresentations and examples.Other ideas?Note that AZ has already made use of some of the informationin these reports to support current SIP/FIP revisions.39What’s Next?Discussion Topics (slide 2 of 3)3⁄4What do States need in addition to the progress report and WRAPTSS support?Progress ReportDOES NOTaddress controls. State ProgressReports should document whatis known about controlsproposed in initial SIPs, and compare to 2018 interim goals.Note that:Several measures were incorporated into WRAP’s 2018projections•What measures were incorporated into projections?•What measures have been implemented?Some measures were not incorporated into 2018 projections,but were referenced in initial SIPs (e.g. final BART controls)•What additional measures were proposed?•What additional measures were implemented?•Note that some states still don't know how their FIPs will beresolved for BART controls40What’s Next?Discussion Topics (slide 3 of 3)3⁄4When should progress reports be submitted?For 308 states:RHR states “The first progress report isdue 5 years from submittal of thefirst implementation plan...” (51.308(g))Note that 308 deadlines are based on submittal dates,NOTapprovaldates.For 309 states:RHR states “Each Transport Region State must submit to theAdministrator periodic reports in the years 2008, 2013, and 2018.”(51.309(d)(10))Some reports are not due for a while.What are the advantages to preparingthese sooner, rather than later?Consistency for all WRAP states?•Note that the WRAP states are represented by 4 EPA regions (6, 8, 9and 10). Is consistency preferred forsubmittals, or will each regionhave its own specific requirements?Availability of Resources?•Will new analysis be required for progress reports submitted up to5-years from now?41Website Links andContact Information3⁄4The RHR progress period support document and natural conditionsdocument will be made available on the WRAP website:http://www.wrapair2.org/default.aspx3⁄4Dynamic RHR data summary tools are available from the WRAP TSS:http://www.wrapair2.org/default.aspxNote that ARS will host a TSS orientation training later this month.3⁄4WRAP contact:Tom Mooretmoore@westgov.org970-491-88373⁄4ARS contacts:Cassie Archuleta, primary author and monitoring data summariescarchuleta@air-resource.com970-484-7941Emily Vanden Hoek, emissions data summariesevandenhoek@air-resource.com970-484-794142