WRAP Regional Haze Rule

Reasonable Progress Report Su

Cassie Archuletacarchuleta@air-resource.cEmily Vanden Hoekevandenhoek@air-resourcTom Mooretmoore@westgov.org

J
Outline

3⁄4 Background3⁄4 Progress Report Support Document

 Data Sources Data Preparation Regional, State and Class I Area specifi

examples

3⁄4 Branch Projects

 WRAP Technical Support System Upda Natural Conditions Review Document

3⁄4 Next Steps and Discussion Topics 
National Visibility Goa

3⁄4 1977 CAA Amendments (§169a)

 “Congress hereby declares as a national go

prevention of any future, and the remedying existing impairment of visibility in mandatory Federal areas which impairment results from made air pollution.”

3⁄4 1999 Regional Haze Rule (40 CFR Part 51 §3

and 309)

 Establishes requirements for implementation 

plan revisions and periodic progress reviews address regional haze in Federal Class I Are(e.g. National Parks and Wilderness Areas)
156 Visibility Protected Federal Class 

(e.g. National Parks, Wilderness A
Visibility Metrics

3⁄4 Visual Qualities

 The color, texture, and clarity of a scene

3⁄4 Visibility Metrics:

 Extinction/Scattering/Absorption (Mm-1

)

 The fraction of light lost per unit length along a s Used to represent individual species

 Deciview (dv)

 An index which is linear with human perception o

(Logarithmic transformation of extinction)

 Used to track visibility impairment for RHR
Sulfates

Nitrates Soil

Organics

Coarse Mass

Elemental C

ABSORBE

Sea Salt

SCATTERERS

3⁄4 Interagency Monitoring of Protected Visual Environment

Aerosol samplers

3⁄4 Network that supports RHR3⁄4 Began in 1988, expanded in 2002

3⁄4 Several particulate species are measured

3⁄4 24-hour samples every third day3⁄4 Light extinction is calculated from aerosol mass and 

Measuring Visibility

IMPROVE Aerosol Samplers
WRAP IMPROVE Monitoring 

3⁄4 WRAP Class I Areas and IMPROVE Monitoring Sites

 116 CIAs represented by 87 IMPROVE Sites

WRAP

Federal CIAs and

IMPROVE Sites

Federal CIA

IMPROVE Monitor
EPA RHR Guidance

3⁄4 September 2003:

Guidance for Tracking Progress Under the RegionaRule

3⁄4 September 2003:

Guidance for Estimating Natural Visibility Conditionthe Regional Haze Rule

3⁄4 April 2013:

General Principals for the 5-Year Regional Haze Proreports for the Initial Regional Haze State ImplemenPlans (Intended to Assist States and EPA Regional in Development and Review of the Progress Report

 Note: April 2013 Guidance was released as this sup

work was being finalized
EPA’s Regional Haze Ru

2000-2004

Baseline

2018

Interim Goal

206

“Nat

Condit

3⁄4 EPA introduced concept of a linear “glide slope

2000-2004 Baseline averages to 2064 “NaturaCondition” estimates

 Initial SIPs (due in 2007) planned for a 2018 Interim 
2000-2004

Baseline

2018

Interim Goal

206

“Nat

Condit

2005-2009

Progress

Period Future

Progress Periods

(e.g. 2010-2014, etc.)

3⁄4 SIP revisions are due every 10 years (next is due in 3⁄4 Progress reports are due between full SIP revisions

 Original 2003 EPA Guidance specifies that progress 

be assessed using 5-year successive average period(e.g. 2005-2009, 2010-2014, etc.)

RHR Reasonable Progress R
3⁄4 Summary report prepared by ARS on behalf of the WRAP 

western states

 Involved extensive consultations with state representative Designed with regional, state and CIA specific summaries 

the technical basis for states to draft their progress reports

3⁄4 RHR requirements addressed by WRAP progress report:

 What are current visibility conditions for the most impaired 

impaired days?

 What is the difference between current visibility conditions 

baseline conditions for the most impaired and least impair

 What is the change in emissions between the baseline pe

progress period?

3⁄4 RHR requirements to be addressed by States:

 What is status of implementation of SIPS measures? Are current implementation plan elements and strategies 

meet reasonable progress goals?

The WRAP Reasonable Haze R

Reasonable Progress Repor

Support Project
The WRAP Reasonable Haze R

Reasonable Progress Repor

Support Document

OUTLINE3⁄4 Glossary of Terms3⁄4 Executive Summary3⁄4 Introduction3⁄4 Regulatory Requirements3⁄4 WRAP Regional Summaries3⁄4 WRAP 309 States Regional Summaries3⁄4 State Summaries

 Includes the following Sections for each state

 Monitoring Data

• Current Conditions• Differences between Current and Baseline Conditions

• Changes in Visibility Impairment

 Emissions Data

• Changes in Emissions• EGU Summaries

3⁄4 References3⁄4 Appendices: Alaska (A) through Wyoming (O)

 Tables and Charts with 5-year, annual, monthly and daily averages and annual trend res

(8 pages of tables/charts per site)
Data Sources

Monitoring Data3⁄4 IMPROVE data through 20103⁄4 Data filling work performed for this project:

 Substituted data, Sierra Ancha WA, AZ; 200 Baseline data estimates (for Zion NP, UT an

Haleakala NP, HI)

Emissions Data3⁄4 2002 emissions originally used for RHR plannin3⁄4 2008 emissions from WestJumpAQMS and DE

modeling projects

3⁄4 AK and HI emissions as provided by states3⁄4 1996-2010 sum of annual EGU emissions by s
Data Preparation Work

SIAN1 Data Substitutions

3⁄4 Data Substitutions

 The RHR requires 3 complete year for each 5-year averag ARS previously worked with the WRAP and VISTAS to su

data for 15 CIA IMPROVE sites for baseline (2000-2004) 

 For the WRAP, only the Sierra Ancha site (SIAN1) site req

progress period substitutions.

3⁄4 Methods

 Seasonal correlation of

surrogates

 On Site surrogates

 E.g., organic H for POM

 Off Site surrogates

 TONT1 used for SIAN1 Note, SIAN1 was used for

TONT1 during baseline years

Sie
Data Preparation Work

Baseline Estimates

3⁄4 RHR requires a 2000-2004

average as a baseline startingpoint

3⁄4 Two WRAP sites were moved

to better represent the CIAs

3⁄4 Zion National Park

 New ZICA1 site began

monitoring in 2003(2004 was first full year)

 Baseline estimated using

progress/baselineaverage ratiosfrom nearby sites

3⁄4 Haleakala National Park

 New HACR1 site began

monitoring in 2007

 Baseline estimated using

progress/baseline ratiosfrom HALE1 site
Current Conditions Summa

3⁄4 40 CFR 51.308 (g)(3)(i) and 51.309(d)(10)(i)(C): What a

current visibility conditions for the most impaired and leadays?

 Note that current conditions for this report were defin

most recent successive 5-year average, as per origin2003 guidance:

 “ ...averages over the 2000-2004 time period are 

against which improvements in worst day visibility and degradation for the best day visibility are judged. Correaverages are to be calculated over successive 5-year 2005-2009, 2010-2014, etc.”

 New (April 2013) EPA Guidance states that:

 “...the reports should include the 5-year average that i

most recent quality assured public data available at the state submits its 5-year progress report for review.”
What are Current Visibility Cond

3⁄4 Regional Summary – annual averages, wor
What are Current Visibility Cond

3⁄4 State/CIA Summaries

 Example for Oregon’s CIAs:
Differences Between Cur

and Baseline Condition

3⁄4 51.308(g)(3)(ii) and 51.309(d)(10)(i)(C

What is the difference between baselinvisibility conditions and current visibilitconditions for the most impaired and leimpaired days?

 Differences presented here are summa

as the difference between the 2000-20baseline average and the most recent successive 2005-2009 5-year average
What is the Difference Between Cu

and Baseline Visibility Condition

20% Best days

(RHR says these can’t get worse)

20% Worst days(RHR says these must 
What Species Have Decreas

3⁄4 Map only shows species that decreased (increasing speci3⁄4 Sites where DV decreased are highlighted in blue
What Species Have Increase

3⁄4 Map only shows species that increased (decreasing speci3⁄4 Sites where DV increased are highlighted in purple
What is the difference between curren

baseline visibility conditions?
Current Conditions Summa

3⁄4 40 CFR 51.308 (g)(3)(iii) and 51.309(d)(10)(i)(C):What 

change in visibility impairment for the most impaired and impaired days over the past 5 years?

 Changes in monitoring data for this report were repo

characterizations of factors that affected changes, inc

 10-year annual average trends (robust Kendall-Theil trend  Identification of outliers and extreme events that may hav

the 5-year averages.

 Supported by State-specific Appendices that contain 5-

annual, monthly and daily average tables and charts fo(intended as reference for further investigation of factoaffected change).

 Note that new (April 2013) EPA Guidance states that

 “... the ‘change in visibility impairment for the most imp

least impaired days over the past 5 years’ is comparing average for the beginning of the 5-year time period witaverage at the end of the 5-year time period.”
Annual Average Trends

Ammonium Nitrate

Ammonium NitrateAll Measured DaysAnnual Average Trends

Ammonium Nitrate20% Worst daysAnnual Average Trend
5-Year Average Differences vs. Annua

Ammonium Sulfate

Ammonium Sulfate20% Worst daysAnnual Average Trends

Ammonium Sulfate20% Worst daysDifference Between 5-yProgress and Baseline 
5-year Averages and

Annual Trends

3⁄4Example of increasing 5-year avera

Ammonium Sulfate, with a decreas
What Factors Are Affecting Basel

Progress Year Differences? 

3⁄4 Outlier years, e.g.

 The THSI1 site in OR showed and increase in dv average (+0.8dv), mo

increase in coarse mass (80% of increase), which was affected by highe

measurements in 2009

Three Sisters WA, OR (THSI1)

Hig
What Factors Are Affecting Basel

Progress Year Differences? 

3⁄4 Seasonality effects from best/worst day identification

 Worst days are identified from a sum of all species measurements, so sporatic events 

can drive the worst days into different seasons of different years

 Example below shows a higher ammonium sulfate average on the worst day in 2008, d

identification of more days in the high sulfate season. 

20022008

Year

A

A

(

2002 2008 

Diff. -0

Averag

More worst days in May – Jul.

More worst days in Aug. – Oct.

Chiricahua WA (CHIR1), AZ
Emissions Summary 

Requirements

3⁄4 51.308(g)(4) and 51.309(d)(10)(i)(D)?: For pollutants 

visibility at CIAs, how have total emissions in the state over the past 5 years?

 Compared using 2 inventory years, at two points i

 2002 WRAP supported data used in initial SIP

• Plan02d data for most states• Plan02c for California• 2005 for HI

 2008 WRAP supported data (contiguous States onl

• WRAP WESTJUMP08 inventory 

(http://wrapair2.org/WestJumpAQMS.aspx) 

• Comprehensive inventory developed for upcom

modeling efforts

• Began with 2008 NEI v2, with a number of enha

(e.g. oil and gas, windblown dust, biogenics, fire

 2008 State provided data (AK and HI) 
What Are the Changes in Emiss

3⁄4 Differences in emissions characterized as state level sums for 

pollutant and category

 Pollutants: SO

2, NO

X, NH

3, VOCs, POA, EC, Fine Soil and coarse 

 Source Categories: Point, Area, On-road mobile, Off-road Mobile, 

Wildland fires, anthropogenic fires, Biogenics and Windblown Dus
Comparisons of Area and Off-R

Mobile NO

X Emissions

3⁄4 Report includes LOTS of caveats about changes in inventory methodo

the differences

 E.g., in example below, differences are likely Influenced by reclassification o

some categories of marine vessels from “Off-Road” to “Area” (aka “non-poin
0

100,000200,000300,000400,000500,000600,000700,000800,000900,000

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

Annual EGU Emissions

WRAP Region 1996‐2010

SO2 NOX 

What are the Changes in Emiss

Annual EGU Plots

3⁄4 Report includes regional and state specific charts showing annual tota

Generating Unit (EGU) emissions

3⁄4 Reductions in SO2 and NOX emissions from EGUs are generally critica

each State’s regional haze strategy

3⁄4 More informative than comparisons of 2002 vs. 2008 inventories beca

are more consistently tracked year-to-year (EPA’s Air Markets Program 
RHR Reasonable Progress R

Support Document

3⁄4 Primary Purposes

 Provide technical basis for States to meet RHR requ

for monitoring and emissions data analysis

3⁄4 Secondary Purposes:

 Opportunity for States to provide additional feedbac

WESTJUMP 2008 inventories

 Note, these had smaller workgroup review processes, 

project provided perspective on new emissions summcompared to 2002

 Provides some support in anticipation of 2018 SIP re

3⁄4 Branch Projects (summarized briefly on next s

 Updates to WRAP TSS website to support progress 

assessments

 Natural Conditions Summary Paper 
Branch Project:

WRAP Technical Support System Website U

http://vista.cira.colostate.edu/tss/Results/HazePlanni

• Tools were originally developed to support initial SIP

WRAP states

• Several updates were recently added to support pro

reports (examples of updates shown on next 2 slide

• ARS will host a TSS training later in June, 2013 
Example TSS update:

WRAP TSS Glide Slope Disp

Glide Slope Display Options:• Successive Averages 

(e.g. 2000-2004, 2005-2009, etc.)

• Rolling Averages

(e.g. 2000-2004, 2001-2004, 2002-2006, etc.)

• With and without 2018 

projections and 2064 Natural Conditions

Successive Averages(w/ natural conditions)

Rolling Averages(w/o natural conditions)
Example TSS update:

County Level Emission Summ

3⁄4 Support document contains State level emissions summ3⁄4 County level summaries are available from the WRAP T
Branch Project:

Natural Conditions Summary P

3⁄4 ARS drafted a general literature review, which presented some backgro

Conditions and a summary of current status, issues and options in one some discussion of:

 EPA “Default Conditions” Revised “Natural Conditions II” Newer work, including:

 A fairly comprehensive 2008 Natural Conditions review and sensitivity study by Ivar Tomb Discussion topics, brainstorming and feedback from a May, 2013 WESTAR Meeting

Map Depicting “Natural Conditions II” estimates used in initial State S
What’s Next?

Discussion Topics (slide 1 o

3⁄4 How should States use WRAP support docum

progress reports?

 Summary products address monitoring and emissio

RHR requirements.

 States can copy/edit background and summary text o

document.

 States can copy and paste charts from report body an States can also use WRAP TSS products to further ta

representations and examples.

 Other ideas?

 Note that AZ has already made use of some of the i

in these reports to support current SIP/FIP revisions
What’s Next?

Discussion Topics (slide 2 o

3⁄4 What do States need in addition to the progress report a

TSS support?

 Progress Report DOES NOT address controls. State 

Reports should document what is known about contproposed in initial SIPs, and compare to 2018 interim Note that:

 Several measures were incorporated into WRAP

projections

• What measures were incorporated into projection• What measures have been implemented?

 Some measures were not incorporated into 2018 

but were referenced in initial SIPs (e.g. final BAR

• What additional measures were proposed?• What additional measures were implemented?

• Note that some states still don't know how their FI

resolved for BART controls
What’s Next?

Discussion Topics (slide 3 o

3⁄4 When should progress reports be submitted?

 For 308 states:

 RHR states “The first progress report is due 5 years from subm

first implementation plan...” (51.308(g))

 Note that 308 deadlines are based on submittal dates, NOT ap

dates.

 For 309 states:

 RHR states “Each Transport Region State must submit to the 

Administrator periodic reports in the years 2008, 2013, and 20(51.309(d)(10))

 Some reports are not due for a while. What are the advantages to 

these sooner, rather than later?

 Consistency for all WRAP states?

• Note that the WRAP states are represented by 4 EPA reg

and 10). Is consistency preferred for submittals, or will eahave its own specific requirements?

 Availability of Resources?

• Will new analysis be required for progress reports submit

5-years from now?
Website Links and

Contact Information

3⁄4 The RHR progress period support document and natural cond

document will be made available on the WRAP website:

 http://www.wrapair2.org/default.aspx

3⁄4 Dynamic RHR data summary tools are available from the WR

 http://www.wrapair2.org/default.aspx Note that ARS will host a TSS orientation training later thi

3⁄4 WRAP contact:

 Tom Moore

 tmoore@westgov.org 970-491-8837

3⁄4 ARS contacts:

 Cassie Archuleta, primary author and monitoring data sum

 carchuleta@air-resource.com 970-484-7941

 Emily Vanden Hoek, emissions data summaries

 evandenhoek@air-resource.com 970-484-7941