Western Regional Air Partnership 

2003 Work Plan 

Adopted by the WRAP Board 

November 12, 2002 
 

Table of Contents

 Executive Summary ...................................................................................... ES-1 

I. Overview ........................................................................................... 1 

II. Background ............................................................................................................. 1 

III. Tribal Options for Implementation Plan Development .......................................... 2 

IV. WRAP Organization and Structure ......................................................................... 2 

A. Membership .............................................................................................. 3 

B. Charter and Bylaws ...................................................................................... 3 

C. WRAP Organization .................................................................................... 3 

D. Coordinating Group ..................................................................................... 3 

E. Oversight Committees (Initiatives and Technical) ....................................... 4 

F. Communications Committee .......................................................................... 4 

G. Stakeholder Involvement ............................................................................... 4 

V. Project Management ......................................................................................... 5 

A. Setting Priorities ......................................................................................... 5 

B. Reconciling Conflicts ................................................................................... 5 

C. Outreach and Peer Review ............................................................................. 6 

D. State and Tribal Coordination .......................................................................... 6 

E. Administration and Staffing ............................................................................ 6 

F. Contract Management ................................................................................... 8 

VI. Regional Haze Work Plan ................................................................................... 9 

 A. Market Trading Forum .................................................................................. 9 

 B. Fire Emissions Joint Forum ............................................................................ 13 

 C. Air Pollution Prevention Forum ....................................................................... 15 

 D. Mobile Source Forum ................................................................................... 17 

 E. Sources In and Near Class I Areas Forum ........................................................ 20 

 F. Economic Analysis Forum ............................................................................. 22 

 G. Air Quality Modeling Forum .......................................................................... 24 

 H. Emission Forum ......................................................................................... 27 

 I. Tribal Data Development Work Group .............................................................. 30 

 J. Research and Development / Dust Joint Forum ................................................ 32 

 K. Ambient Monitoring and Reporting Forum .......................................................... 35 

 L. Air Managers Committee .............................................................................. 37 

 M. Communications Committee .......................................................................... 39 

Appendix A: Preliminary Long-Term Budget 

 Appendix B: Market Trading Forum Work Plan 

 Appendix C: Preliminary 2004-05 Work Plan for the Fire Emissions Joint Forum
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EXECUTIVE SUMMARY 

The WRAP is reaching a turning point in 2003. Most major technical and policy products 

needed for Section 309 SIPs have been completed, products for Section 308 SIPs must now be 

more directly addressed, and these products must complement the longer term (i.e., 2008) needs 

for Section 309 SIP revisions. As the WRAP turns its attention to longer term and Section 308 

requirements, its planning process is made more complicated by the recent decision of the U.S. 

Court of Appeals for the District of Columbia Circuit in the case of the American Corn Growers 

Association versus the U.S. Environmental Protection Agency. This decision creates more 

uncertainty as to how states will determine which BART-eligible sources should be subject to 

BART and how the visibility benefits of BART should be determined. It also raises uncertainty 

about when §308 SIPs will be due, which may be earlier than originally planned by some states. 

Finally, the state of Alaska has joined the WRAP, which adds considerable complexity through 

additional data and analytical requirements and the consideration of another 200 tribes. A map 

of the WRAP region and its members is shown in Figure 1. 

All major WRAP products needed for §309 SIPs should be completed by the end of 2002. Many 

of these products, the efforts behind them, and the knowledge garnered from them will also 

benefit the §308 SIP development process. A summary of the major §309 products is shown in 

Table 1. Activities and projects planned for 2003 fall into three categories: (1) miscellaneous 

products needed to complete the §309 SIPs but not necessarily critical to making decisions on 

§309 SIP submittals or the strategies therein; (2) new projects and extensions of existing projects 

intended to support §308 SIPs and the longer-term needs of §309 SIPs; and (3) efforts needed to 

evaluate haze and develop a SIP for Alaska. Major activities in each of these categories are 

summarized in Tables 2, 3, and 4. A list of all the activities to be funded by the grant for this 

work plan is provided in the budget in Table 5. (Note, many activities conducted by the WRAP 

do not appear as line items but are included within staff salaries or provided in-kind through 

member participation.) 

A long-term conceptual schedule for WRAP activities is shown in Table 6. The schedule 

assumes that §308 SIPs would be due by the end of 2007. This end date is based on recent 

indications by EPA intended to promulgate health-based PM2.5 SIPs as soon as possible while 

providing the maximum opportunity to harmonize their development with regional haze SIPs. 

Some organizational changes within the WRAP since the last work plan update include the 

addition of Alaska, the addition of a Dust Emissions Joint Forum, the transition of the Mobile 

Sources Joint Forum to the Mobile Sources Forum (now a policy forum under the Initiatives 

Oversight Committee), and the transition of the Northern Air Managers Committee to the Air 

Managers Committee (which now includes state and tribal air directors from the entire WRAP 

region). Finally, a work group has been formed under the Air Managers Committee called the 

STIP-II Work Group comprised of SIP writers to update the state and tribal implementation plan 

templates and perform other work needed to ensure that WRAP products and services are as 

helpful as possible to the process of adopting §309 SIPs and TIPs. Many of these changes are 

shown in the organizational chart in Figure 2. 
 ES-2 

Four full time staff members have been added to facilitate WRAP activities. The first position 

assists the state caucus of the Air Managers Committee, the second assists the tribal caucus of 

the Air Managers Committee, the third assists the Technical Oversight Committee and its 

associated forums, and the fourth assists the Initiatives Oversight Committee and its associated 

forums. 

Finally, the WRAP Web site is being updated to accommodate the growing number of WRAP 

products and interested parties, including the general public. The new Web site will be more 

consistent with modern-day design standards and will make it easier to find people and 

documents and to track WRAP activities. The new Web site should be on line by 2003. 

Long-Term Planning 

In its FY02 grant guidance to Regional Planning Organizations (RPOs), the EPA asks that the 

work plan be coupled with an updated description of what is anticipated to be the general work 

plan for several years. The description should provide an indication of the RPOs’ course of 

action, including its vision of the direction for the planning process, how it will develop 

partnerships and jointly determine this direction, how it will assess data needs, what tools it will 

need, and how it will work with other RPOs. 

Much of the information requested above is provided in Sections III, IV, and IV of this 

document. The WRAP will work with other RPOs through the technical discussion groups 

facilitated by EPA, through regular participation in director-level calls and meetings, and as 

necessary on other issues (e.g., emission inventories and control strategies in border regions). 

The WRAP’s needs for new and improved data and tools are generally assessed within its 

forums and is refined through the annual work plan development process. Participation in interRPO discussion groups provides further opportunity to identify and refine these needs. Some 

specific long-term needs are identified in the preliminary long-term budget in Appendix B. This 

budget and the activities therein will be the subject of a WRAP work group to convene early next 

year to flesh out a more detailed technical work plan for §308 SIPs. An outline of this work plan 

was presented and discussed at the WESTAR technical conference in September 2002. 

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

of environmental, social, economic, and political issues. The WRAP region includes the vast 

majority of Class I areas, half the land mass of the United States (not including Alaska), a very 

large portion of publicly-owned lands, and numerous tribal jurisdictions (many with large land 

areas). It also emits a minority of total U.S. emissions, borders both Canada and Mexico, and 

receives pollution from Asia. Most WRAP members will not have to contend with ongoing 

ozone and particulate matter nonattainment issues, which simplifies air quality planning to some 

extent, but many WRAP members are faced with rapid population growth and other challenges 

to preventing deterioration of air quality. Moreover, the WRAP must be sensitive to other 

regionally-important environmental issues, such as fire, drought, and endangered species. This 

presents a unique and challenging environment for long-term planning which is best addressed 

through a single, well-funded and well-organized institution at the appropriate political level. 

The WRAP, with the appropriate EPA financial support, provides such an institution, especially 

given its co-management structure shared between the Western Governors’ Association and the 
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National Tribal Environmental Council. For example, WRAP uses the WGA-developed 

environmental management principles known as Enlibra 

(http://www.westgov.org/wga/initiatives/enlibra). Use of the Enlibra principles has helped 

garner support from western governors and other stakeholders as an example of how 

environmental issues should be addressed in the region. Such coordination is key to regional 

haze planning in the west. 

The WRAP’s long-term planning process must be prepared to deal with relevant events beyond 

its control, such as multi-pollutant legislation and the ramifications of legal challenges to the 

regional haze rule and other regulations. One way the WRAP can contend with these events is to 

have sufficient staffing to track the issues and to promote a constructive dialogue among its 

members. 

In the long-term, the WRAP will continue to examine and develop innovative market-based 

approaches to achieving emission reductions. Examples include the possible expansion of the 

SO2 market trading program (to include additional states and/or tribes, and possibly additional 

pollutants and source sectors) and the creation of a market for trading renewable energy 

certificates. Finally, the WRAP must continue its outreach activities and its efforts to 

incorporate new science as it becomes available. 

Table 1. Major WRAP Products For Section 309 SIPs, 

To Be Completed By The End of 2002. 

 Projections of visibility improvements for all Class I areas in the contiguous WRAP 

region resulting from §309 strategies.

 A definition and policy on clean air corridors.

 A model rule, draft MOU, and SO2 emission monitoring protocols for non-utility 

sources needed to implement the backstop emission trading program.

 A demonstration that the backstop emissions trading program for SO2 will achieve 

greater reasonable progress than source-specific BART for the other Class I areas, 

as defined in §309(g).

 A final report on the WRAP mobile source inventory.

 Determination of any areas in which mobile source emissions or road dust emissions 

significantly contribute to visibility impairment in any of the 16 Class I areas.

 A final report on the WRAP fire emissions inventory.

 An enhanced smoke management program.

 Fire emission goals and tracking system.

 A final report on recommended pollution prevention measures and emission and 

economic impacts

 1996 and 2018 base case air quality simulations.

 
 ES-4 

Table 2. Miscellaneous WRAP Products For Section 309 SIPs, 

To Be Completed in 2003.

 A regional technical support document for implementation plans.

 Stationary source NOx and PM report.

 Specifications for an emission and allowance tracking system for the SO2 backstop 

emission trading program.

 Facilitation of allowance allocation formulas and a policy on geographic 

enhancements.

 Support for documenting the implementation status of regional and local mobile 

source control strategies recommended in the GCVTC final report.

 Support for identifying and documenting state-specific pollution prevention goals and 

programs.

 Support for documenting the implementation status of other recommendations in the 

GCVTC final report.

Table 3. New Projects And Extensions Of Existing Projects 

Intended To Support §308 SIPs And The Longer-Term Needs Of §309 SIPs. 

 Identification of BART-eligible sources.

 Updated emissions inventories mobile sources.

 Updated and new emissions inventories for fire.

 Development of representative communities for emission inventories in rural areas.

 A “Tribal Emissions Inventory Software Solution” tool for use by tribes (and others), 

to facilitate development of accurate and consistent emissions inventories using a 

geographic information system as the framework

 Creation of an emissions data management system to support tracking requirements 

for clean air corridors, the SO2 emission backstop trading program, fire emissions, 

and other programs as necessary.

 Significant new work on the definition of dust (geogenic material) observed on 

IMPROVE PM10 filters, classification of natural and anthropogenic dust emissions, 

and technical investigations to better define the physical characteristics of dust 

aerosols.

 Characterization of emission sources near Class I areas.

 Outreach and development of emission management plans for gateway communiteis.

 Support for demonstration projects addressing existing non-road mobile sources.

 Building regional capacity to develop and trade renewable energy credits.

 Development of a common economic analysis framework and an efficient in-house 

assessment capacity.

 A major effort to characterize the “Causes of Haze” at each Class I area in the 

WRAP region using IMPROVE monitoring and associated meteorological data to 

derive source category impacts, seasonal variations, trends, contribution of natural 

sources, et cetera.

 Extensive expansion of air quality modeling capabilities, including testing of new 

codes, development of emission and meteorological files for 2002, further model 
 ES-5 

evaluation, improvements to the ammonia inventory, nesting of model grids, testing of 

plume-in-grid modules, implementation of process analysis techniques, and 

development of standardized post-processing tools.

 Development of a WRAP-wide technical quality assurance management plan.

Table 4. Projects To Evaluate Haze And Develop A SIP For Alaska. 

 Representative community emissions inventories are planned for Alaskan villages, 

which have distinctly different activity patterns for visibility-impairing emissions. 

 Develop a meteorological model to cover a large portion of the land area of the state 

for simulating the effect of emissions regulated by the State of Alaska at 2 of the 

state’s 4 Class I areas; the areal extent of the meteorological model would capture 

most of the (human) population and a representative mix of emissions sources. 

 Emissions inventory work for fire, area, and stationary sources.
 ES-6 

Table 5. WRAP Budget for CY03. 

Projects CY03 

 Proposed 

Market Trading Forum 

Analysis of NOx and PM for Section 309 and 308 65,000 

ATS/ETS Specifications 50,000 

Identify BART-Eligible Sources 30,000 

Fire Emissions Joint Forum 

Wildland Emission Trade-Offs Review (Fire Emissions Tradeoff Model) 30,000 

Model Assessment/Sensitivity Runs 50,000 

Prepare SIP/TIP Technical Support Document Fire Emissions chapter 10,000 

Expand Ag Alternatives Report - more involvement of stakeholders 100,000 

Technical Guidance on ERT Use (supports annual emissions goal reporting) 40,000 

2002 Inventory of Wx, Rx, and WFU for wildland, rangeland, ag 125,000 

2018 Projections of Wx, Rx, and WFU for wildland, rangeland, ag 50,000 

Modeling to Assess de minimus Tracking Levels 100,000 

Addtl. Guidance on Policy for Categorizing Fire Emissions 40,000 

WRAP policy to coordinate regional ESMP implementation including workshop 60,000 

Guidance to support implementation of the Fire Tracking System (FTS) Policy 25,000 

Co-Sponsor National Fire Conference 30,000 

Air Pollution Prevention Forum 

Tracking and Reporting RE and EE Implementation and Impacts of Legislation 40,000 

Develop Market Guidelines and Verification Protocols for Regional Credit Trading 80,000 

Technical Assistance to States/Tribes for SIPs/TIPs 50,000 

Energy Efficiency Screening Tool for State-Specific Impacts 50,000 

Mobile Sources Joint Forum 

Draft Guidance for Promoting Non-Road Demonstration Projects 20,000 

Support Non-Road Demonstration Projects 50,000 

VMT/Energy Reduction Demonstration Projects and Guidance 25,000 

Sources In and Near Class I Areas Forum 

Gateway Community Demonstration Project 60,000 

Economic Analysis Forum 

Development of In-House Modeling Capabilities 85,000 

Air Quality Modeling Forum 

Regional Technical Center (UCR) 600,000 

Alaska Modeling 200,000 

Emissions Forum 

Improvements for NH3 45,000 

Emission Inventory Data Base System - Development / User Access Capability 122,400 

Update On-Road and Non-Road Inventories with New Emissions Models 40,000 

Develop Representative Community EI's (Phase 1) - (incl. Alaska) 175,000 
 ES-7 

Research & Development Forum / Dust Tasks 

Followup Secondary Org Aerosols Analysis Work 10,000 

Stacked Filter Unit and Module D Data Analysis 31,000 

Ambient Monitoring and Reporting Forum 

Establish and Maintain VIEWS Database (CSU) 249,724 

Establish and Maintain VIEWS Database -- CENRAP's 04 contribution 50,000 

Causes of Haze Report (DRI) -- 3 years 225,000 

Tech-Wide Projects 

Quality Management Plan 25,000 

Geographic Data Display 25,000 

Air Managers Committee 

State/Tribal Caucus Staff Support (WESTAR) -- Includes Travel 117,400 

STIP II Contractor Assistance / Program Enhancement 111,476 

Alaska Tribal Coordinator 50,000 

Communications Committee 

Web Site Administration (B. Bissey) 30,000 

Retool Web Site 15,000 

WRAP Sheet and Handout Material 7,000 

Presentation Material on WRAP 8,000 

Speaker's Bureau 9,000 

Support Forums and Committees 5,500 

Partner with Other Agencies/Programs to Widen Audience 3,500 

Travel and Project Management 

Travel Reimbursed by WGA 180,000 

Conference Calls 40,000 

Meeting Expenses 50,000 

Other Expenses 20,000 

WGA Salaries and Benefits 370,000 

WGA Overhead 240,000 

Subtotals 

Subtotal for Contractor Assistance 3,420,000 

Subtotal for Travel and Project Management 900,000 

Subtotal for NTEC 305,000 

GRAND TOTAL 4,625,000 
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Table 6. Long-Term Conceptual Schedule For WRAP Activities.* 

Target Date Technical Activity Policy Activity Target Date 

2002 Emissions inventory base year Scoping workgroup on WRAP long-term work plan and activities late 2002 – early 2003 January 2003 to September 2004 (21 months) 

1) Model upgrades/evaluation/testing new tool development (see Modeling Forum activity list for the RMC) 2) EI improvement work (see EF list) 

June 2004 2002 WRAP emissions inventories complete October 2004 

Placeholder – EPA releases 2002 NEI (with one state review incorporated – WRAP to use as a filler) 

Policy Forums begin to identify all likely control strategy options and regulatory framework for Regional Haze SIPs/TIPs 

mid-2004 (18 months) 

March 2005 (9 months) 

WRAP RMC completes emissions processing quality assurance, model input formatting, met modeling and provides updated base and projection year emissions files 

Policy Forums sort control strategy options into regional and state/tribe, ranking the list for each of 

the 2 strategy groupings 

end of 2005 (18 months) 

September 2005 (6 months) 

Base year and 2018 modeling completed – identifying source apportionment by jurisdiction for source categories 

July 2006 (9 months) 

2018 regional control strategies’ modeling completed 

early 2007 Regional Technical Support Document complete States and tribes prepare and submit SIPs/TIPs 11-12/2007 (16 months) * Assumes harmonized RH/PM2.5 SIP due date of 11-12/07, based on changes during the TEA-21 Congressional reauthorization by 9/03, and designations of 

PM2.5 attainment and nonattainment areas in late 2004.
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Figure 1. Map Of The WRAP Region. 
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Figure 2. WRAP Organizational Chart. 
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I. Overview 

This work plan describes the Western Regional Air Partnership (WRAP) activities currently in 

progress or planned to meet the requirements of the Regional Haze Rule. This work plan 

includes steps leading to state and tribal implementation plans that are required to address 

regional haze visibility impairment under a national program (40 CFR 51.308) or an optional 

regional program for states and tribes in the Grand Canyon Visibility Transport Commission's 

(GCVTC) transport region (40 CFR 51.309). This plan addresses specific requirements of the 

regional haze rule and identifies the work products needed by each of the members to meet those 

requirements. This is an update and revision to the WRAP’s work plan October 31, 2001. 

II. Background 

The 1990 Amendments to the Clean Air Act established the GCVTC, which in June of 1996 

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

Canyon and other Class I areas on the Colorado Plateau. Recognizing the need for a process to 

monitor and coordinate the implementation of its final recommendations, the GCVTC members 

created the WRAP. The WRAP includes participants from industry, environmental groups and 

other affected parties and operates in conjunction with regional organizations such as WESTAR, 

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

products of the WRAP are used by states and tribes in the preparation of their individual 

implementation plans to meet the requirements of the federal regional haze rule promulgated by 

the U.S. Environmental Protection Agency (EPA) in 1999. 

While the initial focus of the WRAP was to implement the recommendations of the GCVTC in 

conjunction with federal visibility rules, the requirements of these rules also highlighted the need 

to implement other regional planning processes to improve visibility in all western Class I areas. 

In March 1999, the WRAP expanded its charter to address all regional air quality issues. 

Section 308 of the regional haze rule contains a general requirement for states to submit an 

implementation plan on a schedule dependent on the attainment status of the fine particulate 

standard and participation in regional planning groups. Section 309 of the rule allows a state that 

is in the GCVTC transport region to submit an implementation plan conforming to the 

recommendations of the GCVTC if the state elects to submit the plan by December 2003. Such 

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

of the GCVTC. The states would then be allowed to defer submittal of implementation plans for 

their other Class I areas until 2008. As described further below, tribes have the option of 

submitting implementation plans at their discretion and containing provisions they deem most 

appropriate. For the purpose of this planning document CFR 51.308 will be referred to as the 

National Rule or §308, and CFR 51.309 will be referred to as the GCVTC Rule or §309. 

In preparing this plan, the WRAP assumes that several of its members will elect to submit 

implementation plans by the end of 2003 consistent with the requirements of §309. Periodically 

thereafter, states and tribes will submit implementation plans under §308 or update plans under 

§309 on a schedule consistent with regulatory requirements and their administrative capabilities. 

This work plan has been established to accommodate this anticipated staggered schedule, and 
2

work will evolve as WRAP members establish specific dates for the submission of their 

implementation plans. The WRAP forums will develop and deliver technical analyses and 

control strategy components to address the major source categories identified in the regional 

haze rule in order to meet the regional haze planning needs of western states and tribes. 

III. Tribal Options for Implementation Plan Development 

Under the regulatory framework provided by the Tribal Authority Rule (TAR) (40 CFR 49.1– 

49.11) and the regional haze rule, tribal implementation of visibility programs through Tribal 

Implementation Plans (TIPs) is optional. The TAR authorizes but does not require tribes to 

receive delegation of authority to implement any program, or “reasonably severable elements” of 

a program, under the Clean Air Act. The preamble to the regional haze rule explains that “a 

tribal visibility program is not dependent on strategies selected by the State or States in which the 

tribe is located.” (64 Fed. Reg. 35714, 35756, July 1, 1999). The net result is that any tribe in 

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

The policy and technical work of the WRAP to assist states will simultaneously be designed to 

assist the tribes in the same way. Tribal concerns are being addressed at every level within the 

WRAP process. Tribal and state implementation plan needs may be different. As these 

differences are identified, project tasks and work plans will be updated to reflect the improved 

understanding of tribal needs. 

To ensure that tribal needs are addressed, the active participation of tribal representatives on all 

forums has been and will continue to be sought and encouraged. The National Tribal 

Environmental Council (NTEC) is responsible for coordinating tribal participation in the WRAP 

and receives funds from EPA for this purpose. Since some tribes do not have the resources or 

expertise to participate in the WRAP, NTEC provides tribes with analyses and synopses of issues 

emanating from the WRAP forums and work groups and from sources outside the WRAP. 

NTEC also facilitates consensus building within the tribal caucus. The Institute for Tribal 

Environmental Professionals (ITEP) at Northern Arizona University also provides assistance and 

staff through the Tribal Data Development Working Group to address a key tribal need – the 

acquisition of data necessary to make informed policy decisions. 

Finally, it should be noted that the WRAP organizational structure provides several checkpoints 

for tribal input. First and foremost, the WRAP has established equal representation for tribes and 

states within its management structure, including a tribal Co-Chair of the WRAP. Key positions 

are also reserved for tribal representatives on all standing committees, forums, and work groups. 

Public workshops for WRAP work products and travel support from the WRAP \ 

ensure that the broader tribal community has an opportunity for input prior to WRAP action. 

IV. WRAP Organization and Structure 

In September 1997 the WRAP was formed with a membership including states and tribes both 

within and outside of the GCVTC region. The WRAP established oversight committees and 

forums charged with developing work plans to implement the GCVTC recommendations. 
3

A. Membership 

The WRAP membership currently includes the Governor or his/her designee from 13 states and 

10 tribes, two U.S. Cabinet Secretaries and the Administrator of the EPA or their designees: 

States Tribes 

Alaska Campo Band of Kumeyaay Indians 

Arizona Cortina Indian Rancheria 

California Hopi Tribe 

Colorado Hualapai Nation of the Grand Canyon 

Idaho Nez Perce Tribe 

Montana Northern Cheyenne Tribe 

New Mexico Pueblo of Acoma 

North Dakota Pueblo of San Felipe 

Oregon Confederated Tribes of Salish and Kootenai 

South Dakota Shoshone-Bannock Tribes of Fort Hall 

Utah 

Washington Federal Agencies 

Wyoming Department of the Interior 

 Department of Agriculture 

 Environmental Protection Agency 

B. Charter and Bylaws 

The WRAP Charter and Bylaws set forth the basic operating goals, principles and operating 

procedures and are posted on the WRAP website at http://www.wrapair.org. 

C. WRAP Organization 

The WRAP is composed of several forums, committees and work groups, all of which include 

participation from the WRAP membership (states, tribes and federal agencies) and interested 

stakeholders (industry, environmental groups, etc.). 

D. Coordinating Group 

The Coordinating Group is made up of the co-chairs of the IOC, TOC, International Projects 

Committee, Communications Committee, and the Air Managers Committee. The WRAP may 

adjust membership of the Group to ensure balanced representation. The Group oversees 

development and coordination of the strategic work plans of the WRAP, promotes collaborative 

work relationships among committees and forums to avoid duplication and maximize 

productivity, makes interim appointments to committees between WRAP meetings, provides 

administrative leadership to carry out the activities of the work plan, helps identify process 

problems, budget needs and financial planning, and may make recommendations to the WRAP. 
4

E. Initiatives Oversight Committee (IOC) and Technical Oversight Committee (TOC) 

The IOC provides general oversight for the coordination and development of air quality 

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

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

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

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

forums and work groups and appoint their co-chairs to conduct the specific work of the WRAP. 

Presently, there are 11 forums and work groups. The IOC oversees the Air Pollution Prevention 

Forum, Market Trading Forum, Economic Analysis Forum, and Sources In and Near Class I 

Areas Forum. The TOC oversees the Emissions Forum, Air Quality Modeling Forum, Ambient 

Monitoring and Reporting Forum, and Tribal Data Development Work Group. The Fire 

Emissions Joint Forum and the Dust Emissions Joint Forum are overseen by both the IOC and 

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

F. Communications Committee 

The Communications Committee addresses communication among the members and groups of 

the WRAP as well as outreach and education of the public and interested groups on air quality 

issues. 

G. Stakeholder Involvement 

The WRAP includes participation from industry, environmental groups and other affected 

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

committees, forums, and work groups: 

· Industry · Small Business (including “green industry”) 

· Mobile Sources · Federal Government 

· Tribal Governments · State Governments 

· Local Governments · Academia 

 · General Public · Environmental Groups 

Committee and forum members are expected to represent and communicate with their agencies 

and constituents. Forum and committee members are responsible for establishing mechanisms 

that will ensure this communication occurs. These mechanisms may involve working through 

trade groups, state and tribal organizations such as the Western States Air Resource Council 

(WESTAR Council), the National Tribal Environmental Council (NTEC) and intra- and interagency forums. 
5

V. Project Management 

A. Setting Priorities

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

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

priorities refined by the following process: 

· The WRAP identifies issues and requests that one or more oversight committees 

address them, or asks that the oversight committees develop issues and work plans for 

review by the WRAP. 

· Oversight committees examine the management and technical issues associated with 

the strategic direction and identify the major deliverables, skills required and 

stakeholders most affected. 

· Based on this examination, oversight committees may refer issues to existing forums 

or work groups or create forums and work groups to generate the deliverables. 

Oversight committees appoint co-chairs of forums and work groups and work with 

the co-chairs to develop a written charge, including objectives, expectations, and time 

frames for deliverables. 

· Co-chairs of forums and work groups appoint members, taking into consideration 

stakeholder balance and the charge from the oversight committee(s). 

· Each forum and work group is responsible for developing a detailed work plan to 

meet the work product and process guidance from its oversight committee(s). They 

issue bi-monthly reports to their oversight committees, which should be posted on the 

Web site. 

· Oversight committees review and approve detailed work plans to ensure that all 

WRAP time lines and process needs are addressed. 

· Depending on the nature of the process, each forum and work group works with its 

oversight committee(s) to resolve deadline or budgetary conflicts that may arise in the 

plan development process. 

· The Coordinating Group manages general work, ensures budgetary consistency and 

coordination among the different groups and the overall direction of the WRAP. 

B. Reconciling Conflicts

If an issue arises on which a forum or work group can not reach consensus, the issue is referred 

to the oversight committee(s). If the oversight committee(s) can reach consensus on the issue, 

that decision is referred to the forum or work group for integration with the forum or work 

group’s decisions on other issues. If the oversight committee(s) can not reach consensus, the 
6

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

for further debate. 

When conflicts over priorities and budgets can not be resolved by the individual forum, work 

group or committee, the Coordinating Group will recommended a resolution. The Coordinating 

Group’s recommendation will be based on the policy direction from the WRAP, the work tasks 

required to accomplish that direction and consultation with the forums, work groups and 

committees. Where major changes in directions or deliverables are required, the Coordinating 

Group will seek the approval of the WRAP Board prior to directing such changes. 

C. Outreach and Peer Review

The WRAP Communications Manual sets forth the process for reviewing work products and 

policy decisions. At each stage of review, relevant material will be posted on the WRAP Web 

site and comments will be solicited. 

Work products must be presented to the appropriate oversight committees before being presented 

to the WRAP. The oversight committees may provide feedback to the forums or work groups; 

the forum or work group has the responsibility to decide whether or not to make changes. 

Changes the forums or work groups make to work products should be communicated to the 

oversight committees so recommendations from these groups to the WRAP can be fully 

informed. 

Policy work products are subject to public review through workshops and formal public 

comment periods. Technical work products are reviewed by the Research and Development 

Forum, an independent contractor engaged to perform peer review, or by a specialty technical 

workshop on the work product. The forums and work groups are responsible for acknowledging 

public and peer reviewer feedback in the final presentation to the WRAP. 

D. State and Tribal Coordination

In addition to the extensive and ongoing communication and coordination that occurs directly 

between the WRAP and its member states and tribes, the WRAP will work with the Western 

States Air Resources Council (WESTAR) and the National Tribal Environmental Council 

(NTEC) as important coordination points to ensure that state and tribal regional haze needs are 

clearly identified and addressed by the WRAP. 

E. Administration and Staffing

Members of committees and forums perform much of the work of the WRAP. The oversight 

committees monitor forum and work group activities to ensure that work products are developed 

in a timely manner and that stakeholder participation remains representative, balanced, and fair. 

Contractors hired with EPA grant funds are relied upon to expand the resources of the WRAP. 

Committees and forums direct the work of contractors. 
7

Support services to the line functions of the WRAP come from the Communications Committee, 

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

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

WRAP’s internal and external communications and assists committees and forums with outreach 

strategies for specific products and activities. 

WGA and NTEC staff provide overall project management for the WRAP. WGA provides 

much of the basic logistical support for the WRAP by preparing and managing grant 

applications, funds, requests for proposals (RFPs), contracts, travel reimbursements, meetings, 

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

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

stakeholders having concerns with the WRAP processes and relating concerns to forum cochairs, oversight committees, committee co-chairs, facilitators, and the WRAP co-chairs. 

During the period covered by the grant, WGA staff will be performing these activities. 

Additionally, WGA and NTEC staff routinely attend the meetings of the various committees and 

forums. WGA and NTEC jointly or separately perform tasks related to WRAP and serve as 

primary contact points by responding to media and public inquiries. 

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

facilitating and providing reimbursement for tribal caucus meetings; providing coordination 

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

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

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

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

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

responsibilities, work with stakeholders to ensure the WRAP’s processes are fair and equitable, 

and serve as the primary points of contact for EPA, the media, and the general public. Funding 

for one of the co-project managers is under the WGA line item, while funding for the other is 

under the NTEC line item. The third staff support position assists the state caucus of the Air 

Managers Committee. Funds for this position are identified in the Air Managers Committee 

budget and provided to the Western States Air Resources Council for management and oversight. 

The fourth position assists the tribal caucus of the Air Managers Committee. Funds for this 

position are identified in the NTEC line item. The fifth position assists the Technical Oversight 

Committee and its associated forums. And the sixth assists the Initiatives Oversight Committee 

and its associated forums. These two position are identified in the WGA line item. 

Other staff support will be sought as needed. Options include (1) contracting with a WRAP state 

or tribe to dedicate staff support for a defined period of time; (2) hiring temporary staff at WGA, 

NTEC, or WESTAR; and/or (3) entering into an agreement with an independent contractor to 

provide the needed staff support. 
8

F. Contract Management 

WGA and forums jointly manage WRAP contracts. WGA, as the receiver of WRAP grants, 

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

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

Forums and work groups may create balanced subgroups for purposes of contract management. 

It is the responsibility of the forums and work groups and their respective oversight committees 

to develop the scope of work for each contract. All contracts are to be developed in accordance 

with the work plans approved by the WRAP and submitted to the EPA. Once the scope of work 

has been properly developed, it is transmitted to WGA. WGA is responsible for developing an 

RFP or sole source justification. All RFPs are published in the Federal Business Opportunities 

publication, sent to appropriate contractors known to the WRAP, and posted on the WRAP Web 

site. Unless time is otherwise a constraint, bidders are provided 30 days to respond. 

A review committee is established for the evaluation of RFPs. The review committee is 

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

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

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

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

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

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

committee negotiates a final contract with the winning bidder. All contracting is done in 

accordance with established federal guidelines. The standard contract form includes provisions 

for record keeping and audit requirements in accordance with OMB Circular 110. 

It is the responsibility of the forum, work group or committee to monitor the work of the 

contractor and to determine whether all work requirements are being met. When a bill is 

received, WGA will examine the invoice to match invoice items to requirements outlined in the 

contract. WGA requires documentation from the contractor regarding hours spent and expenses 

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

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

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

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

payment is rendered by WGA. 

WGA is responsible for maintaining all records and does so in accordance with all federal 

requirements. This includes submittal of quarterly status reports to EPA. As noted in the 

previous section, NTEC lets contracts for work done in support of tribal participation. These 

contracts are funded by a grant separate from the general WRAP grant, and are subject to the 

requirements of the single audit act and related compliance supplements. 
9

VI. Regional Haze Work Plan 

A. Market Trading Forum Summary (details in Appendix C, except where noted)

Background

Section 309 of the regional haze rule contains a requirement for states and tribes to develop 

emission milestones for SO2 and a backstop regional cap-and-trade program for SO2 that would 

be implemented if the milestones were not met through voluntary means. The regional haze rule 

divides the development of this program into two parts. The first requirement was the submittal 

of an Annex to the Grand Canyon Visibility Transport Commission’s report to provide the 

detailed structure of the backstop program. The Annex was completed and submitted to the EPA 

on September 29, 2000. The Market Trading Forum (MTF) has now shifted its work to the 

second phase, which is to provide additional documentation so that states and tribes can include 

the backstop trading program into SIPs and TIPs that are due by December 31, 2003. 

States and tribes also have the option to develop SIPs and TIPs under Section 308 of the regional 

haze rule using similar or different strategies to improve visibility in western Class I areas. 

Implementation Plans under section 308 of the rule will be due sometime between 2004 and 

2008, depending on the circumstances in each area. 

Work Plan

The tasks under development by the MTF fall into three main categories. The first provides 

information primarily intended for states and tribes to better understand the impact of 

implementing the SO2 milestones and backstop trading program. Such information may help 

states decide whether to submit implementation plans under Section 308 or 309. Tribes will 

need to make a similar decision, but are not subject to the same deadlines as the states. 

1. Critical Mass

This project uses economic modeling to estimate how the benefits of the backstop 

trading program may be affected by varying levels of state and tribal participation. 

Details are provided in the 2002 work plan. This project will be completed in 2002. 

2. RA BART/Geographic Enhancements

This project is intended to better define geographic enhancements and develop a 

process guideline for determining reasonable attribution. The MTF also expects to 

finalize an MOU that addresses the circumstances under which FLMs will certify 

impairment. This project should be completed in 2002 or early 2003. 
10

3. Other Class I Areas

This project will review the results air quality modeling results to determine whether 

“greater reasonable progress than BART” has been met for all Class I areas. This 

project should be completed in 2002. 

4. Allocations

This project will finalize the allocation estimates for all source categories and provide 

examples of how the various pieces of the allocation methodology will work together. 

Details are provided in the 2002 work plan. This project should be completed in 

2002. 

5. Tribal Set-Aside

The process for distributing these 20,000 allowances among tribes needs to be 

defined. The MTF should provide support to the tribal caucus, as requested, when the 

tribal caucus addresses this issue. 

6. Tribal Issues and Capacity Development 

When requested, the MTF should lend support to overarching tribal issues which also 

relate to stationary sources, such as cultural considerations, economic impacts on 

specific tribal lands, and data gaps. 

The second category of tasks provides documentation needed as soon as possible for Section 309 

SIPs to be implemented by the deadline of December 31, 2003. 

1. Model Rule and MOU 

This project will revise the draft model rule and MOU submitted as part of the Annex 

to ensure that they are consistent with stakeholder agreements and work properly 

within the framework of existing state and tribal regulations. This project will be 

completed in early 2003. 

2. Monitoring Protocols 

This project will produce detailed monitoring protocols to ensure that all source 

categories subject to the Annex will have monitoring requirements comparable to 40 

CFR 75 after the trading program is triggered. This project may also seek refinement 

of the reporting and record-keeping requirements currently in the Model Rule. This 

project will be completed in early 2003. 

The final category of tasks provides additional documentation to be included in Section 309 SIPs 

and/or to help states and tribes develop plans under Section 308. Some of these tasks do not 

need to be started in 2003 but need to be included in the overall WRAP planning process. Other 
11

tasks may require several years to complete and are therefore included in the near-term priorities 

of the MTF. 

1. Stationary Source NOx and PM 

This project will satisfy the reporting requirement of Section 309(d)(4)(v). The report 

will assess potential emission control strategies, their environmental, economic and 

tribal impact, the need to establish milestones for NOx and PM, and future integration 

into multi-pollutant and multi-source programs. The report should include all WRAP 

states and should also address NOx and PM BART requirements in Section 308 and 

309. This project should be completed in the spring of 2003. 

2. Allowance and Emissions Tracking System Specifications 

If the backstop trading program is triggered, an allowance and emissions tracking 

system will be needed to determine compliance with the program. The system will 

include the ability to track allowances in the tribal set-aside and to ensure a secure 

and seamless connection between the tribal set-aside tracking system and the main 

allowance tracking system. The system itself does not need to be created at this time, 

but specifications need to be included in SIPs and TIPs to ensure that a uniform, 

region-wide compliance system will be in place after the program is triggered. The 

ATS and ETS of EPA’s Acid Rain Program could be used as the starting point for the 

system, or a new system could be designed to meet the needs of the WRAP. This 

project should be completed in the spring of 2003. 

3. Expansion of SO2 Backstop Trading Program 

The MTF should evaluate the impacts of a possible expansion of the program to 

WRAP states and tribes that are outside of the Grand Canyon visibility transport 

region. 

4. Identification of BART-Eligible Sources for All Visibility-Impairing Pollutants 

This task is required by Section 308(e) and will support SIP revisions due in 2008 

under Section 309. 

5. Stationary Sources Under Section 308 

The MTF should provide background information on stationary sources of all 

visibility-impairing pollutants for development of plans under Section 308. 

6. Tracking of SO2 Sources 

The MTF should keep track of stationary SO2 sources, including new and planned 

energy sources (e.g., utilities, refineries, and renewable energy sources), their SO2

emissions, and potential impacts on milestone assumptions. 
12

Funding

Funding is already available for developing SO2 monitoring protocols and for partial analysis of 

stationary sources of NOx and PM. Additional funds are needed for this analysis ($50,000), for 

developing ATS/ETS specifications ($50,000), and to help states and tribes identify BARTeligible sources ($30,000). 
13

B. Fire Emissions Joint Forum 

The tasks under development by the FEJF fall into two main categories. The first category 

provides information primarily intended for states to better understand the WRAP Enhanced 

Smoke Management Program (ESMP) policy, the related fire emissions goals, and the fire 

emissions tracking policy, all needed under Section 309. Tribes will need to make a similar 

decision, but are not subject to the same deadlines as the states. 

The FEJF plans to document Section 309 fire emissions inventory work in the regional Technical 

Support Document, reflecting fire technical input data ($5,000). The FEJF also plans to 

independently assess the results of the up to 5 fire emissions sensitivity runs to be conducted in 

mid-2003 by the WRAP Regional Modeling Center. The assessment will address emissions 

inventory issues, pollutant speciation, plume height approach, variances in total net emissions, 

and other key assumed parameters in the context of the regional model results ($50,000). 

Beyond the assessment of fire emissions inputs to the regional model, the FEJF also needs to 

assess de minimis levels for fire activity data tracking and the potential use of a smoke 

management program-level screening tool using source/receptor based model scenarios. This 

analysis to is intended to develop recommendations on the level(s) of de minimis activity 

tracking for ESMP public notification and regional coordination ($100,000). 

The FEJF also plans to expand its existing Agricultural Alternatives Report to include 

quantitative examples of more crop types and regions, with greater involvement of agricultural 

stakeholder community ($100,000). The FEJF plans to develop further user guidance to support 

its existing Policy for Categorizing Fire Emissions, to refine differences between Restoration 

and Maintenance prescribed burns in terms of vegetative structure, fuel loading, fuel size classes, 

ecosystem function and fire resilience ($40,000). In support of completing another Section 309 

requirement, the FEJF will develop user guidance to support its Fire Tracking System Policy

(FTS) identifying a specific format, parameters, structure, and methods of emission calculation 

for required and optional FTS elements ($25,000). As fire management programs evolve, the 

FEJF has identified the need to assess the applicability of the Fire Emissions Trade-off Model for 

use in WRAP policies and guidance pertaining to smoke management of fire. The 

recommendations from this assessment have possible linkage to both ESMP and AEG ($15,000 

carry-forward and $30,000 new). The FEJF will also develop WRAP policy and guidance to 

support the ESMP Regional Coordination element, including dissemination to users through a 

workshop ($60,000). 

The second category of tasks are to designed to provide technical and policy support for 

completing Section 309 work and moving into Section 308 work, building on the regional 

visibility management approach defined in the work products for Section 309 plans. The 

following technical and policy analysis work tasks will begin in 2003, and are to be completed in 

2004. 

In 2003, the FEJF plans to begin to build a 2002 base year fire emission inventory covering 

wildfire, prescribed fire, and wildland fire use on wildland, rangeland, and agricultural lands in 

the WRAP region, including Hawaii and Alaska ($125,000 in 2003, $125,000 in 2004). This 

inventory would be complete by mid-2004. Also in 2003, the FEJF plans to begin refining its 
14

existing 2018 fire emissions projections for the contiguous WRAP region for wildfire, prescribed 

fire, and wildland fire use on wildland, rangeland, and agricultural lands across the WRAP 

region, including Alaska and Hawaii ($50,000 in 2003, $50,000 in 2004). This project would 

also be completed in mid-2004. 

The FEJF has identified the need to host a fire technical conference in 2004, to include, but not 

be limited to: 1) Methods to assess plume rise characteristic; 2) Technical assessment of fire 

parameters used for regional modeling; 3) Methods to assess and track emission reduction 

techniques; 4) Use of technical tools to assist in tracking burning activity for emission inventory 

purpose, including remote sensing; 5) Treatment of fire sources in regional modeling 

(expectations vs. reality); and 6) Fire emissions structure for SMOKE processor ($30,000 in 

2003 for planning, $30,000 in 2004 for conference expenses). 

The FEJF needs to develop technical guidance on Emissions Reduction Techniques (ERTs) 

applicable for wildland, rangeland, and agricultural burning for use in the establishment and 

support of Annual Emission Goals. The guidance will include applicability criteria and 

calculation techniques by vegetation/crop type, emission factors, economics, and emissions 

averted including identification of new ERTs ($40,000 in 2003, $40,000 in 2004). 
15

C. Air Pollution Prevention Forum 

Background

Having completed all the regional analyses necessary for supporting Section 309 SIPs, the 

Forum, in accordance with interests expressed by the IOC and the WRAP, is shifting its longterm focus to the tracking and reporting requirements of Section 309 and to the implementation 

of its regional recommendations, primarily through encouragement of regional actions. In the 

short-term, the Forum has identified two additional projects: one to provide technical assistance 

developing Section 309 SIPs and one to provide a planning and assessment tool for all states 

with respect to energy efficiency measures. 

Work Plan

1. Tracking and Reporting ($40,000) 

A tracking and reporting function would provide WRAP members with up-to-date information 

on the implementation status of the renewable energy and energy efficiency recommendations 

made by the Forum and endorsed by the WRAP Board. It would also track the success of 

incorporating such measures into SIPs/TIPs and ensure that the recommendations remain 

relevant given changing external circumstances. The Forum would meet at least once a year to 

consider needed changes in the tracking and reporting function and potential advice to the 

WRAP on how to best enable renewable energy and energy efficiency to contribute to achieving 

air quality goals. Specifically, the Forum would: 

 

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

implement the Forum’s recommendations, 

 Monitor and report developments that impact the Forum’s recommendations (e.g., 

federal Renewable Portfolio Standard and carbon constraints), and 

 Hold a meeting of the Forum at least once per year. 

2. Develop Market Guidelines and Verification Protocols for Regional Credit Trading 

($80,000) 

The Forum believes there are renewable energy policies that are more efficient and effective at 

increasing development of renewable energy generation if adopted at the regional level. 

Creating a single institution in the West that will issue, track, and oversee trading of Renewable 

Energy Certificates is a regional policy both the Forum and the Western Governors Association 

endorse. 

The Forum and western governors recognize that renewable energy has environmental attributes 

that can be sold separately from the electricity generated as Renewable Energy Credits (RECs). 

Markets for RECs provide a strategy to overcome transmission barriers and provide consumers 

access to the most economical renewable energy resources. RECs lower the costs of renewable 

energy and, in combination with other public policies, can accelerate the development of the 

West’s most promising renewable resources, further improving air quality in the west. 
16

This task will allow the Forum to work with the Western Governor’s Association and other 

stakeholders to develop a blueprint for: 

 A single institution in the West to issue RECs and track and oversee their trading; 

 A standard set of market design and operating guidelines for trading RECs within the 

Western Interconnection; and 

 An independent, regional generation tracking system to provide data necessary to 

substantiate the number of megawatt hours generated from renewable energy sources 

and support verification, tracking, and trading of RECs. 

(A detailed scope of work is available upon request.) 

3. Technical Assistance to States/Tribes for SIPs/TIPs ($50,000) 

This task will provide states and tribes who submit Section 309 plans with information and 

expertise needed to fully develop, customize, and adopt the pollution prevention portions of their 

SIPs and TIPs. Specifically, funding for this task will help states and tribes develop: 

 Inventories of existing and planned renewable energy generation capacity, 

assessments of the most cost-effective renewable energy opportunities, and 

documentation of programs relied on to achieve the GCVTC 10/20 goal. 

 Program descriptions of existing and planned energy conservation and efficiency 

programs states will rely on to reduce emissions; 

 Methodologies for applying results of the Forum’s regional modeling to the state and 

tribal level. (The regional modeling provided information on the energy costs, 

emissions reductions, and economic impacts of adopting the Forum’s renewable 

energy recommendations and energy efficiency “best practices”.) This will allow 

states to comply with Section 309(d)(8)(v), which requires states to develop short and 

long term projections of emissions reductions, visibility improvements, energy cost 

savings, and secondary economic benefits associated with the GCVTC renewable 

energy goals and energy efficiency activities. 

4. Energy Efficiency Screening Tool for State-Specific Impacts ($50,000) 

With funding for this project, the Forum will develop a simple screening tool (e.g., an interactive 

spreadsheet) to help state energy offices and air quality managers evaluate the state-specific 

impact of adopting different energy efficiency “best practice” options found in the Forum’s 

reports. The modeling that has been done focused on regional impacts. This screening tool 

would help states determine impacts (e.g. energy savings, emissions reduction) of each option 

based on state demographics and other variables, such as weather, electricity loads, and resource 

balances. 

Funding

See amounts provided above. 
17

D. Mobile Sources Forum 

Background

The objective of the Mobile Sources Forum (MSF) is to provide technical support and policy 

direction, from stakeholder perspectives, to states and tribes for use in the mobile source portion 

of their regional haze SIPs and TIPs. The primary emphasis of the MSF has been to develop – 

with assistance from contractors, states, and metropolitan planning organizations – the most 

accurate and regionally consistent base and future year mobile source emission inventories (EI). 

This emphasis is shifting, however, to the evaluation of mobile source significance levels, the 

development of emissions control strategies for any areas found to be significant, and the 

promotion of non-road emission reductions, VMT reductions, and smart growth concepts. 

Under the regional haze rule, states submitting Section 309 SIPs must (1) compile statewide 

inventories, (2) determine whether any areas of the state contribute significantly to visibility 

impairment in any of the 16 Class I Areas, (3) establish emission budgets and tracking systems 

for any such areas, and (4) provide interim reports to EPA and the public on the implementation 

status of the regional and local strategies recommended in the final report of the GCVTC. Items 

(1) and (4) are also pertinent to states submitting plans under Section 308, as is the Forum’s 

growing emphasis on non-road sources, VMT reductions, and smart growth concepts. The 

Forum should also investigate and propose, if appropriate, WRAP comments on any EPA 

proposed rule governing non-road mobile source emissions. 

Status

Mobile source emission inventories have been completed for the years 1996, 2003, 2008, 2013, 

and 2018. The Forum has also identified proposed criteria for determining where mobile sources 

may be significant contributors to visibility impairment. The Forum is working with the 

Modeling Forum to determine whether any of the criteria are exceeded for any of the 16 Class I 

Areas and, as a result, may adjust the proposed criteria accordingly. 

As the MSF takes on a more policy-based agenda, some of the more technical issues will be 

coordinated through other forums. Specifically, tribal mobile source data gathering efforts are 

being coordinated through the Tribal Data Development Work Group. Updates to the WRAP 

mobile source inventory using new versions of EPA emission factor models will be managed by 

the Emissions Forum. Finally, improving the accuracy of paved and unpaved road dust 

inventories is being coordinated through the Research and Development / Dust Forum. With 

respect to dust, data is poor for unpaved road vehicle miles traveled and silt content and moisture 

levels. 

Work Plan

1. Develop Road Dust Control Measures, If Significant ($0)

Section 309(d)(7) requires the first implementation plan for §309 states to “include an 

assessment of the impact of dust emissions from paved and unpaved roads on visibility 
18

conditions in the 16 Class I Areas. If such dust emissions are determined to be a significant 

contributor to visibility impairment in the 16 Class I areas, the State must implement emissions 

management strategies to address the impact as necessary and appropriate.” Once better dust 

emission factors and inventories have been developed by the Research & Development/Dust 

Forum, modeling will be done to determine the significance of road dust based on the Mobile 

Source Forum’s significance criteria. If road dust from a §309 state or tribe is significant, model 

control strategies should be available for inclusion in the first §309 SIP. 

 

2. Status of Regional and Local Mobile Source Control Strategies ($0)

Section 309(d)(5)(iv) of the regional haze rule requires states to submit “interim reports to EPA 

and the public in years 2003, 2008, 2013, and 2018 on the implementation status of the regional 

and local strategies recommended by the Commission Report to address mobile source 

emissions.” WRAP staff will work with state staff to identify such strategies and describe them 

in such a way so as to be suitable for use in a report to be included in a 309 SIP. In the course of 

this process, strategies initially identified in the GCVTC may be identified for deletion or 

addition for the purpose of highlighting the most promising strategies and for establishing a more 

pertinent set of programs to be revisited when the next interim report is due in 2008. 

3. Develop Guidance for Supporting Emission Reduction Demonstration Projects for 

Existing Non-Road Mobile Sources ($20,000) 

It is becoming increasingly apparent that non-road mobile sources will outweigh on-road sources 

as contributors to regional haze. By the end of the first regional haze planning period (2018), 

non-road mobile sources are expected to emit almost as much VOCs as on-road sources, twice as 

much NOx as on-road sources, three times as much PM as on-road sources, and comprise 21% of 

the total SO2 inventory. Moreover, non-road sources – which include among other things 

agricultural and mining equipment and locomotive engines – may be more dispersed than 

on-road sources, thereby having a more consistent, widespread impact on Class I Areas in the 

West. 

Clearly, stricter standards for new non-road engines and their fuels are critical to minimizing 

emissions from this source category. However, given the many years required to implement new 

standards and to displace dirtier, in-use engines with cleaner ones, air quality benefits will only 

accrue over the very long term unless strategies are explored for reducing emissions from 

existing sources. Such strategies can be implemented at the local and regional level. 

Demonstration projects, in particular, can be an effective means for local and regional 

organizations to identify and support the most promising strategies. However, given the number 

and diversity of non-road categories and the various approaches to reducing their in-use 

emissions – e.g., cleaner fuels, exhaust retrofits, inspection programs, and economic incentives – 

potential demonstration projects should be carefully examined before receiving support from 

agencies with limited resources. 

Thus, the MSF will draft a report summarizing recent demonstration projects from across the 

country and technologies and/or approaches that may be ripe for demonstration. This report may 

be used by agencies in the WRAP region to scope out the most promising demonstration projects 
19

for their support. A contractor with expertise in this field will draft the report and help 

coordinate a workshop. The workshop will provide an opportunity to review the report, to 

educate WRAP members, for managers of successful non-road programs to share their 

experience, and possibly for certain technologies to be showcased. 

4. Co-Fund At Least One Non-Road Demonstration Project ($50,000) 

Based on the guidance developed in Task 3, the MSF will co-fund a demonstration project in the 

WRAP region. This money will be used to leverage larger sums available from organizations 

such as the EPA. Results from this project will be communicated to WRAP members and 

stakeholders with assistance from the Communications Committee. 

5. VMT/Energy Reduction Demonstration Project ($25,000) 

It is anticipated that this project will be jointly managed with the AP2 Forum in partnership with, 

and additional funding from, the Climate Neutral Network. (Please see 

www.climateneutral.com.) It is anticipated that a demonstration project will be developed to 

encourage VMT reductions or reductions in the rate of VMT growth that will address not only 

WRAP targeted pollutants but also greenhouse gases that are the subject of the Network’s 

efforts. Potential topics discussed to date have been variable motor fuel taxes or vehicle 

registration fees adjusted to the miles driven and fuel consumption of the vehicle. Also, 

insurance premiums might be geared to a VMT basis. Other topics must be identified before one 

appropriate for a demonstration project is designed and implemented. 

Funding

See amounts provided above. 
20

E. Sources In and Near Class I Areas Forum 

Background

The Grand Canyon Visibility Transportation Commission recommended 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 on the Colorado Plateau. The purpose of the Emissions In and Near Class I 

Areas Forum of the WRAP is to help implement those recommendations throughout the WRAP 

region. To that end, the Forum has established two main objectives: 

 Quantify emissions for selected parks in the WRAP region and gather information 

regarding pollution prevention and minimization activities in those parks; and 

 Focus on one local gateway community to serve as a template as to how other 

gateway communities could deal with near-park issues, including a local emissions 

inventory to identify and quantify emission sources associated with a representative 

gateway community, and to identify local pollution prevention and minimization 

activities. 

Status

The Forum is in the process of receiving from its contractor the final reports on emissions in 

eight Class I areas on the Colorado Plateau. These reports indicate that in-park emissions are 

only a small percent of those in surrounding counties. Emission control strategies within many 

parks, therefore, do not appear to be of critical, region-wide importance to restoring or protecting 

visibility in the West. However, the U.S. National Park Service would like to lead by example 

and minimize in-park missions, thereby reducing visibility impacts of any in-park activities. A 

memo from the Forum summarizing this work will be provided to the WRAP in the near future. 

Additional Class I area inventories are being developed separately by the U.S. National Park 

Service. The purpose of these studies, like the ones sponsored by the WRAP, is to verify the 

relative significance of emissions in Class I areas, determine regulatory compliance, and identify 

opportunities for emission reductions in order to maintain low or no level of impact from 

emissions in Class I areas. 

Work Plan

Having completed most of its work on sources in Class I areas, the Forum is shifting focus to 

sources near Class I areas. A long-standing goal of the Forum has been to identify a “gateway 

community” potentially impacting a Class I area and to conduct a demonstration project 

involving that community. The demonstration project would identify the significant pollution 

sources and successful efforts at controlling those sources, engage and educate local 

communities and federal land managers, and encourage the development of local visibility 

protection plans. 
21

The Forum has decided that such a demonstration project would be most successful if the Forum 

first studied the types, magnitudes, and trends of human activities near Class I areas throughout 

the West. Such a study would identify how many and which Class I areas are at greatest risk 

from nearby emissions and the types of human activities likely to be responsible. With such 

information, the Forum can determine if gateway communities pose the greatest type of nearby 

risk – relative, for example, to point sources, prescribed fires, and dispersed outdoor activities – 

and if so, which type of community (e.g., residential, commercial/tourist, and ski resort) and 

which community in particular would hold the most promise for a demonstration project, both in 

terms of reducing the community’s own impact and as providing an example for other gateway 

communities. 

When this work is complete, the Forum will proceed with a gateway demonstration project, 

provided gateway communities are indeed a significant risk to western Class I areas. With the 

completion of the above study, information will be available to the WRAP that provides a clear 

landscape of human activities around Class I areas. Such information could be used to develop 

micro emission inventories to support local modeling studies or for general comparison to 

broader geographic regions and emission source categories. 

Funding

The Forum expects the analysis of emissions near Class I areas and the gateway demonstration 

project to cost approximately $135,000. Currently, the Forum has in its budget $75,000 in 

uncommitted CY02 funds. The Forum therefore requests $60,000 in CY03 funds to complete its 

work. 
22

F. Economic Analysis Forum 

Background

The Economic Analysis Forum’s (EAF) primary objective is to assist western states and tribes 

with economic assessments of compliance strategies under EPA’s Regional Haze Rule (RHR). 

The EAF will help educate states, tribes and other stakeholders regarding the economic 

considerations of relevant air quality strategies under the RHR. This will provide more complete 

information to support state and tribal decision making processes. 

Tasks for 2003 include (1) an ongoing, informal refinement of the scoping process undertaken in 

2002 to determine individual state and tribal economic analysis needs, (2) the ongoing 

development of a common economic analysis framework initiated in 2002 to guide the 

evaluation of air quality strategies, (3) assisting other WRAP forums with economic analyses, 

and (4) assisting states and tribes with economic analyses. These are described below. 

Work Plan

1. Refine the Forum’s Understanding of State and Tribal Needs for Economic Analysis 

The EAF needs to assess economic analysis needs of individual WRAP states and tribes as they 

move forward with choosing compliance strategies under the RHR and related regulations. 

States need to decide whether to adopt SIPs under Section 308 or 309, and tribes may be faced 

with similar choices in their approach to developing regional haze plans. States and tribes also 

need to choose compliance strategies – within the context of their respective SIPs and TIPs – to 

meet RHR requirements. 

State, tribal, and other stakeholder input will be sought on their needs for economic assessment. 

This will be done in-house by EAF members and WGA staff members using a standard set of 

questions. This process will be completed in 2002, but will be repeated as necessary to receive 

continual input from states and tribe regarding their economic assessment needs. 

2. Continue Developing a Common Economic Analysis Framework 

The EAF and its associated partners (e.g., an in-house contractor, member of academia, or 

private consultant) will develop – starting in 2002 – a common economic analysis framework to 

assist states, tribes, and other stakeholders in systematically and consistently evaluating different 

emission reduction strategies. This framework will provide, to the extent possible, standardized 

cost-benefit, distributional, and other relevant economic information, including a common set of 

assumptions. The framework must identify the appropriate analytical tools; the current 

availability of those tools to WRAP forums, states, tribes, and other stakeholders; and the 

relative strengths and weaknesses of those tools with respect to competing analytical approaches. 

To ensure the framework’s ongoing utility to states and tribes, the EAF and its associated 

partners should continually review related economic analyses and their applicability to the 

regional haze planning process. 
23

3. Develop “in-house” Modeling Capabilities 

It is generally more expensive and less efficient to hire a large consulting firm each time a 

different economic issue requires attention. The EAF will therefore attempt to develop an inhouse modeling capability to provide accessible, responsive, and cost-effective analyses of 

emission reduction strategies, including those for PM and NOx. In addition, the EAF will 

explore a variety of models for this task, besides the ones that have already been used in the 

WRAP. A relatively simple, yet effective model would be one that EAF members might be able 

to understand themselves, and thus provide more direct support. 

4. Assist other WRAP Forums with Economic Analyses 

The EAF will lend economic expertise to other WRAP forums upon request. This will include 

interpretation of economic analyses and efforts to ensure they are accessible and useful to states 

and tribes. 

5. Assist States and Tribes with Economic Analyses and Strategy Choices 

The EAF will lend economic expertise to WRAP states and tribes upon request. The precise 

nature of the work under this task will be made more explicit as the RHR process progresses, and 

as economic needs of states and tribes become more apparent. It is possible that relatively 

simple extensions and/or interpretations of current analyses will be adequate for many SIP/TIP 

decision process. In some cases, however, additional effort will probably be needed. The inhouse modeling capabilities described above will be particularly useful in these cases. 

In addition to ad hoc support, the EAF is considering a comprehensive regional economic 

analysis for the entire WRAP, include an economic forecast. This analysis would provide 

information specific to western economies (e.g., utilities, tourism, and others) and include 

compliance costs and other economic issues, such as distributional impacts. This would 

probably be completed by early to mid 2004. 

Funding

Most of the tasks above would be performed by EAF members and their partners and with funds 

already secured in 2002. However, $85,000 is needed in 2003 to develop the in-house modeling 

capabilities. 
24

G. Air Quality Modeling Forum 

The Modeling Forum will undertake two major projects: one for the continued operation of the 

Regional Modeling Center and one for modeling of Alaska. 

1. Regional Modeling Center 

The regional modeling center will test and evaluate the modeling system to determine 

improvements to be made to the data and the modeling system. Meteorological fields will be 

developed for the new base year of 2002. Base model runs will be developed for 2002, 

incorporating the 2002 inventory when available. Setting up and testing of model nesting of 

higher-resolution sub-grids in areas where local influences of urban areas on Class I areas is 

important. Additional tasks are listed below: 

 Test new model codes for SMOKE, MCIP, and CMAQ 

 Update SMOKE for SAPRAQ chemical mechanism 

 Develop and process 2002 meteorological fields 

 Process 2002 emissions 

 Test model with 2002 inputs 

 Update NH3 processing and inventory 

 Test SAPRAQ chemical mechanism 

 Test new aerosol mechanism 

 Training 

 Incorporate version control mechanism 

 Test the Lambert Conformal version of REMSAD 

 Develop/Process local emission inventory for model nesting 

 Develop/Demonstrate model nesting 

 Develop Training for model nesting 

 Standardize post-production tools 

 Investigate 2-way nesting in model 

 Test plume-in-grid 

 Make system more turn-key 

 Conduct process analysis to better understand the model’s performance 

2. Development of Modeling for Alaska 

Alaska poses some unique problems for WRAP modeling. It is geographically far enough 

removed from the rest of the WRAP region that including it in the regional modeling would not 

be efficient. Also, the relative sparsity of sources in much of the state would potentially dictate 

the application of different modeling techniques. The meteorology of Alaska also requires some 

special consideration. International transport from Eurasia is also a significant issue in the 

Class I areas of Alaska. There are 4 Class I areas in Alaska: Denali National Park and Preserve, 

Tuxedni Wilderness, Simeonof Wilderness, and Bering Sea Wilderness (see map below). The 

two largest cities in Alaska are Anchorage and Fairbanks. Each may impact Denali, whereas 

Anchorage may impact Tuxedni. Simeonof and Bering Sea are more isolated from the source 
25

regions of Alaska. IMPROVE monitoring at the Bering Sea Wilderness is not occurring due to 

its isolation. 

This project is aimed at providing an initial, credible evaluation of the potential contributions to 

regional haze in the Class I areas of Alaska that are more likely to be affected by in-state 

emissions, namely Tuxedni and Denali. This project is analyzing a situation that has not 

previously been analyzed. There is a need for some fundamental technique development and 

evaluation before the tools are ready for use in SIP development. The meteorological field 

development will be particularly complex in this region. The meteorology has to handle flows in 

complex terrain combined with maritime influences. The terrain varies from sea level to 20,000 

feet. Therefore, the scope and cost is necessary to get credible results. 

To date, no regional haze modeling analyses have been performed for Alaska. Further work in 

future years may be needed to make the system work, so work should be initiated now to prepare 

a SIP in time for a 2007 deadline. 

Task 1: Develop appropriate methods for running MM5 over central Alaska, including 

Cook Inlet, the Alaska Range, to North of Fairbanks. 

Task 2: Run MM5 for this region for several time periods representing different seasonal 

and meteorological conditions and evaluate the meteorological model results. 

Task 3: If the model runs are credible, run the model for 2002. 

Task 4: Run a Lagrangian model, such as CALPUFF, for the largest point sources in the 

region (up to about 10). 

Task 5: Run the model chosen in Task 4 to evaluate the potential for impacts from the 

urban areas of Anchorage and Fairbanks 

Funding

For the Regional Modeling Center, a request is made for $600,000 per year, continuing 

indefinitely. For Alaska modeling, a request of $200,000 is made for CY03, and approximately 

$100,000 for years thereafter. 
26
27

H. Emissions Forum 

Background

The objective of the Emissions Forum is to provide the WRAP with all emissions information 

necessary to implement applicable provisions of the Federal Regional Haze Rule. This includes 

compiling emission inventories for the point and area source emission sectors, for the WRAP 

states and adjacent areas within the WRAP modeling domain. The Emissions Forum will also 

collect emission inventory data from the Mobile Source Forum and the Fire Emissions Joint 

Forum, and combine that mobile and fire emissions information with point and area source data 

in order to provide a complete inventory of all emissions of visibility impairing pollutants 

necessary to analyze visibility impacts within the WRAP region. The Emissions Forum will 

work closely with the Tribal Data Development Workgroup to assure compatibility of 

information coming from Tribal sources, and to minimize duplication of effort between these 

similar data collection efforts. 

The Emissions Forum will also provide forward (and backward) projections of any base year 

emissions data to look at potential visibility impacts at other times. The Emissions Forum will 

compile emission inventory information annually, to facilitate tracking of various emissionrelated commitments under the Regional Haze Rule, such as the Market Trading Stationary 

Source Milestones or Clean Air Corridors tracking. In order to store and retrieve this emissions 

information, and make it available to public and private users, the Emissions Forum will develop 

a central database storage system for the WRAP, and will select a location/institution to house 

this information. In order to assure the accuracy of any data stored in this central database, the 

Emissions Forum has begun quality assurance activities designed to identify and remove 

incorrect information from the compilations. Also to improve the quality of the WRAP 

emissions inventory information, the Emissions Forum will conduct investigations into the 

appropriateness of activity data and emission factors that are used in the calculation of these 

emission inventories, and provide guidance to state, local and tribal air quality agencies for the 

protocol to be used in preparation of proper data for submittal to the WRAP regional database. 

Specific work, schedules and budget needs are described below. 

Status

Emissions inventories for point, area, mobile, and fire sources were completed for §309 analysis 

during 2002. Some monies for improving temporal and spatial accuracy, completing error 

checking and corrections for 1996 and 2018 inventories, and initiating the development of the 

Emission Inventory Database System remain unspent. These monies (~$260k) are planned for 

use in completing those projects, as a transition to the starting new projects for §308 analyses 

identified in the next section. 
28

Work Plan

1. Emission Inventory Data System Development, Protocol and Training 

 

Development of a regional GIS-based emissions data system will be based upon a needs 

assessment to be performed in early 2003. The needs assessment will determine the needs of 

other forums, states, and tribes that are expected to use the database system. Development of the 

database will be completed in 2003. Starting in 2004, next steps include development of a 

protocol to ensure consistency in data methods and emissions factors. Training of state and tribal 

emission inventory staff that use the database or enter inventories is expected to begin in 2004. 

Protocol development and user training is expected to occur in 2004. 

2. Maintenance of an Emissions Inventory 

Once the database has been developed, it will be necessary to have a long-term maintenance 

agreement with an entity to ensure quality control, assistance to states and tribes and to answer 

database queries. States and tribes, through a web-based database, are expected to populate the 

database with inventory updates. For example, the data will be used: 

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

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

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

• To provide input for visibility modeling; and 

• Other inventory, reporting, and tracking uses as necessary. 

Annual costs to maintain the inventory system, perform quality checks, answer queries, and 

prepare special reports are currently estimated at $100,000 per year. User access capability, 

consisting of a server and software will also be included as part of the development project in 

2003. 

3. Emissions Inventory Improvements 

A. Chemical Speciation and Temporal Allocations. The WRAP currently uses the 

SMOKE emissions processor to prepare emission inventories for photochemical 

models to assess regional haze impacts. SMOKE incorporates a default profile to 

allocate emissions into chemical speciation factors and temporally for each source 

category. It is known that errors exist in the source category codes assigned to 

many sources, which produces errors in temporal allocations and chemical 

speciation assignments. In addition, the allocation profiles are national defaults and 

may not be representative of western sources. Further, profiles for individual 

sources may differ significantly within the same source category. These errors and 

shortcomings can produce potentially significant errors in visibility modeling. 

Accurate modeling is essential for visibility management plans. Work that is 

required to investigate and correct source category code assignments and allocation 

profiles should be largely completed in mid-2003. However, it is anticipated that 

complete emissions inventory updates with corrected information and incorporation 
29

of new profiles to SMOKE may not be completed until 2003. In addition, there 

may be need to assess the temporal and speciation profiles for individual sources to 

obtain accurate information for modeling purposes. At this time, it is expected that 

such work may not begin until 2004. 

B. Data Gaps and Incorrect Data. It is known that the current baseline emission 

inventory of 1996 contains errors and data gaps. These have been generally identified 

in a Quality Assurance check performed in 2002. Missing or incorrect data must be 

corrected in order to accurately model projected emissions and visibility impacts. 

Corrections to the 1996 data for sources larger than 100 tons per year will be made in 

2002. Emission projections for 2018 will then be rerun in 2002. In addition, work on 

gaps in pollutant data such as ammonia must be completed in 2002 and 2003, 

followed by organics in 2004. In collaboration with the Modeling and Dust 

Emissions Forums, a project entitled “Determining Fugitive Dust Emissions from 

Windblown Dust” to provide PM10 and PM2.5 windblown dust inventories, and an 

algorithm for calculating these inventories using the CMAQ model. Future work on 

windblown dust emission inventories, by updating land use, meteorological, and/or 

emissions factors may be necessary starting in 2004. 

Funding

The Forum requests that the ~$260k remaining in the EF CY02 budget be programmed as noted 

in the attached spreadsheet, to begin the tasks identified above. Further, the EF requests new 

funding in the amount of ~$382k for CY03 as noted in the spreadsheet, to complete the tasks 

identified above. The EF will begin work on Alaska emissions inventory projects in CY03." 
30

I. Tribal Data Development Workgroup 

1. Software Training 

It is anticipated that the final version of the tribal emission inventory software solution (TEISS) 

will be completed in June 2003. After completion, ITEP will begin distributing the software to 

tribes in the WRAP Region. ITEP will conduct a 4-day long workshop on the use of the EI 

software in the summer or fall of 2003. It is anticipated that the workshop will be conducted in 

Flagstaff, AZ for ten selected tribal air quality professionals. The workshop will provide a 

thorough understanding of the operation of TEISS, Quality Assurance/Quality Control on the 

tribal data input to TEISS, the generation of reports and a firm knowledge of the science behind 

the emissions estimations. After successful completion of the training, these professionals will 

be available to train other tribes in the use of the EI software and will also be available for 

telephone consultation. 

ITEP will promote TEISS by attending four tribal environmental conferences to demonstrate it to 

tribal environmental professionals. The software would be demonstrated at the National Tribal 

Environmental Council’s annual conference and at EPA regional tribal environmental 

conferences for regions eight, nine, and ten. Instruction on TEISS will be included in all future 

ITEP Emission Inventory Workshops. Demonstrations at these conferences will be conducted 

by ITEP staff or one of the TEISS trained tribal environmental professionals. ITEP will 

coordinate the efforts of the trained tribal air quality professionals in providing assistance to 

other tribes and demonstrating software. 

2. Emission Inventory Seminar/Symposium 

ITEP will host a 2-day advanced EI seminar to focus on more advanced aspects of EIs. Tribes 

who have completed EIs will give presentations on their work. ITEP will facilitate discussions 

and/or presentations of how emissions estimating techniques used by tribes can be improved, 

how tribal EIs can be improved in general, how the EI data can be used, how to address future 

emission concerns (development, new facilities, etc.), dealing with data sensitivity issues, 

participating in RPOs. Tribes, EPA and RPO representatives will be invited. The seminar would 

be conducted in the spring or summer of 2004. The dates for the seminar will be set in early 

2004 to avoid conflicts with other workshops, meetings, or conferences. The location will be 

selected from among the WRAP states and tribes. 

3. Emission Inventory Support 

A full-time Technical Specialist will be employed by ITEP to provide training and assistance to 

tribes in the WRAP region who wish to complete EIs for their reservations. The technical 

specialist will develop data gathering methods and templates, where appropriate, to assist tribes 

in gathering data specific to their reservation for use in TEISS. Funds will be provided to allow 

the technical specialist to travel to four reservations over the year to provide on-site assistance to 

tribal environmental professionals conducting emission inventories. ITEP will maintain a 

website providing technical information specific to tribal emission inventories and RPO 
31

participation. This website will be part of ITEP’s website and will include links to NTEC, 

WRAP, EPA and other relevant websites to reinforce and advertise the use of those sites. 

4. Tribal Data Support 

At present, ITEP receives numerous calls from WRAP forums and contractors to the forums who 

need information on or from tribes to include in their decision-making processes. Under this 

task, ITEP will gather tribal data required by WRAP. The following bullets list data and work 

efforts to be delivered to TDDWG. TDDWG will provide direction over time to ensure that the 

data collected is responsive to the current and future needs of the WRAP. 

 ITEP will continue its efforts to collect tribal emissions inventories (EIs) as they 

become available and approved by the tribes for release to the WRAP and the 

National Emission Inventory. This work will continue as needed. As tribes who 

choose to use TEISS will be able to submit to NEI on their own, it is expected that 

this service will be required less and less over the next five years. 

 ITEP staff will attend WRAP forum meetings as necessary to remain up-to-date on 

data needs and to present data collected. Through attending these meetings, ITEP 

will be able to more easily assess tribal data needs. 

 Tribal GIS data, relevant to WRAP, will be compiled and maps made easily available 

to tribal representatives and WRAP forums as appropriate. These maps could be used 

to determine tribal populations and lands affected by WRAP activities, identify tribes 

who may have a stake in certain WRAP processes, and other purposes as identified 

by the TDDWG. 

 Under this task, ITEP will maintain and update databases of tribal information and 

provide maps and data analysis as requested by TDDWG. 

 As a repository for tribal environmental data, ITEP will continue to gain informed 

release of data from participating tribes. All requests for tribal data, already released 

by tribes to ITEP and TDDWG, will be responded to in a timely manner. Tribes will 

be informed of the release of their data, including to whom and for what purpose their 

data was released, at the same time that the data is released. If ITEP suspects that 

there may be a conflict of interests over releasing data held in this repository, the tribe 

will be contacted prior to release of any data. Where potential conflicts exist, people 

requesting tribal data will be strongly encouraged to work directly with the tribe in 

question. 
32

J. Research and Development / Dust Joint Forum 

Background

For the purposes of preparing a CY03 work plan and budget, the activities of the Research & 

Development (R&D) Forum will be subsumed into the recently created Dust Emissions Forum, a 

joint technical and policy Forum. A limited number of R&D projects will continue, and/or be 

refocused on dust technical and policy work, to support both §309 and §308 of the Regional 

Haze Rule. The R&D Forum will be taking a hiatus as an active Forum, at least during CY03. 

Dust Emissions Forum Rationale

Analysis of IMPROVE filter data collected in the WRAP domain have shown that fine soil and 

coarse particles are responsible for about 6 to 26% of the annual average reconstructed aerosol 

light extinction. Fine soil can account for about 10 to 30% of the fine particulate mass. Coarse 

material is generally equal to or greater than the total fine particle loading on the average. The 

contribution of fine soil to the aerosol extinction on the haziest days in the West is almost always 

below 10%, but can be as high as 40%. Coarse material generally contributes less than 20%, but 

is frequently higher, reaching as high as 90% of the aerosol extinction. 

Windblown local and regional wind-generated aerosol (including natural organic material) and 

mechanically resuspended particles probably account for the bulk of the emissions of these 

categories, but global transport of wind-produced aerosol is also possible. Examples of some 

source categories include dust from disturbed soil (both local and global transport), construction 

activities, agricultural activities, vehicles traveling on paved and unpaved roads, smoke from 

burning vegetative material, material storage piles, mining activities, and sea salt. 

Much uncertainty hampers apportionment of dust. For example, 

a. What fraction of the coarse material is attributable to windblown and 

mechanically resuspended particles? 

b. What are the transport and transformation characteristics of these particles? What 

are the “sinks?” Are they hygroscopic? What is their contribution to light 

extinction (scattering and absorption)? 

c. What fraction of these materials can be considered “natural?” 

d. What fraction of observed dust is local in origin and what fraction is due to 

emissions outside the United States? 

e. What is the adequacy of ambient monitoring capabilities? 

Because of the relatively large contribution to visibility impairment of coarse material and 

possibly fine soil, it is important that WRAP be able to conduct an apportionment of sources of 

primary particulate matter in order to effectively assess the causes of visibility impairment and 
33

identify appropriate control measures. For these reasons, the Dust Emissions Forum was 

established by the Technical and Initiatives Oversight Committees as a joint technical and policy 

Forum. Mark Scruggs, presently a Co-Chair of the R&D Forum, will serve as the Dust 

Emissions Co-Chair. 

Status

The Dust Emissions Forum has outlined topics for work, and Mark Scruggs has drafted a Forum 

charge. Also, Mark has assembled a list of potential members, and is actively recruiting these 

individuals; some of the R&D Forum members may remain involved. The Dust Emissions 

Forum will likely have its first official meeting in Winter 2002-03. Formal adoption of the 

following proposed work plan by the Forum is expected at that time. Work on the projects not 

yet started will begin after the initial Forum meeting. 

Work Plan

The Dust Emissions Forum has identified several projects to be completed with combinations of 

existing CY02 and proposed CY03 monies, as detailed in Appendix A: 

1. A “Wind-Blown Dust Inventory Improvement” project, to create a methodology using land 

use and meteorology data to prepare a CMAQ model-ready inventory. This project is funded 

with $125,000 of CY02 funds provided by the Emissions Forum, and reprogramming the 

$29,795 in the “Road Dust EI” line under R&D/Dust on the attached spreadsheet. The RFP 

for this project has been advertised, responses are due September 6, 2002, and the project is 

scheduled for completion in April 2003. 

2. A “Module D Speciation and Analysis” project, to perform chemical analyses on the particles 

collected on Module D filters, (representing the PM2.5 to PM10, or coarse size fraction) 

measured by the IMPROVE samplers in the WRAP region. Data from this project will begin 

to answer the questions about the composition of Module D particles, and the adequacy of 

ambient monitoring capabilities. This project will use $100,000 of reprogrammed CY02 

R&D funds, and anticipates needing an additional $10,000 in new CY03 funding. 

3. An “Emissions/AQ Model Revisions and Testing” project, to revise and test emissions 

models for fugitive dust. This project will use $50,000 of reprogrammed CY02 R&D funds. 

4. A “Follow-up Secondary Organic Aerosols Analysis Work” project to begin in 2003, to build 

on the analytical recommendations of a March 2003 National Science Foundation-funded 

workshop on Development of Research Strategies for Sampling and Analysis of Organic and 

Elemental Carbon Fractions in Atmospheric Aerosols. The recommendations for analysis 

from this workshop are important to §308 control strategy evaluations, as organic material 

and light absorbing carbon are responsible for about 15 to 38% and about 5 to 15%, 

respectively, of the average reconstructed aerosol light extinction at Class I Areas in the 

WRAP region. An amount of $10,000 in CY03 has been identified for this project, to be 

contributed to a larger analysis effort by academics, EPA, FLMs, and potentially other RPOs. 
34

5. A “Stacked Filter Unit and Module D Data Analysis” project to begin in 2003, using the 

chemical composition data from SFUs operated in the 1970s and ‘80s, together with the 

IMPROVE Module D data from the 1980s and ‘90s, will look at historical trends in 

composition and source apportionment. This project will be coordinated with the Ambient 

Monitoring and Reporting Forum. $21,000 is needed for this project in CY03. 

In CY04, the Dust Emissions Forum has identified the need for a “Dust – Evaluation of Natural 

Background Emissions” project, in the amount of $100,000. This project would analyze and 

classify dust emissions in a manner similar to the Fire Emissions Joint Forum’s Recommended 

Policy for Categorizing Fire Emissions, dated August 30, 2001. 

Funding

See tasks above. 
35

K. Ambient Monitoring and Reporting Forum 

Background

The Ambient Monitoring and Reporting Forum=s work plan for 2003, and continuing into 2004 

and beyond, is presently focused on two projects: 1) Expanding the scope and utility of WRAP’s 

web-based ambient monitoring database, including production of Annual Data Reports, and 2) 

Beginning a two-to-three year project to produce a major web-based report referred to as the 

“Causes of Haze@ analysis. Completing the web database and preparing the first of the everyfifth-year “Causes of Haze” reports lays the groundwork for the AMRF to provide data and the 

necessary analytical interpretations relative to both §309 and §308 of the Regional Haze Rule. 

Status

Ambient Monitoring Database 

The existing WRAP ambient air monitoring database web site, operated by Colorado State 

University’s Cooperative Institute for Research in the Atmosphere (CIRA), will receive a new 

name and begin providing a broader array of data and data analysis tools covering the entire 

country under an agreement between the nation’s Regional Planning Organizations (RPOs). The 

new Visibility Information and Exchange Web Site (VIEWS) will replace WRAP’s current 

ambient monitoring database and will incorporate other databases at 

http://vista.cira.colostate.edu. VIEWS will include all of the functions previously available in 

the WRAP database, but will also add data and data analysis tools for the rest of the country. The 

site’s data analysis tools will allow users to customize reports that can be easily downloaded. 

The WRAP Annual Ambient Data Report will be published electronically once per year and 

distributed through the WRAP (soon to be VIEWS) ambient database web site. It will feature 

data summaries for the previous calendar year as well as some simple trends to promote 

comparison of current year=s data with that from previous years. The overall approach will be to 

develop a core set of analysis software that generates standard statistical and graphical 

summaries of the data for every year=s annual report. Over the years the software that generates 

these material will be enhanced so that the scope of the reports will evolve over the years. 

Feedback from users of the report will be a primary source of information for the direction of 

this evolution. The report will consist primarily of the standard output from this software and 

will have only a modest amount of year-specific commentary describing some of the prominent 

features of these automated products. 

Causes of Haze Report 

The SOW for this project was prepared and the RFP advertised during Spring and Summer 2002; 

negotiations leading to selection of a contractor will be complete by summer’s end. The effort 

envisioned for the Causes of Haze report could require more than 24 months to accomplish and 

may cost as much as half to three quarters of a million dollars per five-year report. 
36

Work Plan

The report on the @Causes of Haze@ will include as much as information as can be estimated 

using monitoring data concerning the aerosol species and source categories that contribute to 

haze. These reports will also document the use of spatial and meteorological analysis methods to 

estimate the impacts from within and outside the WRAP region. These assessments of 

monitoring data will be used in refining EPA default estimates of natural contributions to haze 

(i.e., natural visibility conditions for the §308 glide paths), and will be documented in this report. 

Some of the methods required to conduct assessment used in the Causes of Haze report are nonstandard and need to be refined and evaluated by a broad group of technical experts. These 

include methods to refine estimates of natural visibility conditions, more accurately calculate 

extinction from aerosol data, and better define the sub regions with similar haze characteristics. 

Monitoring data should be used to test the reasonableness of our knowledge and understanding 

of the entire air quality system. The Causes of Haze report will attempt to illuminate answers to 

the following questions. For example, are the emission rates by pollutant species roughly 

consistent with the ambient aerosol species? Do the air quality models agree generally with the 

monitored aerosol species and visibility data? Is the measured and aerosol reconstructed 

extinction coefficient data similar? These types of closure assessments are important methods to 

either build confidence or identify problems that must be addressed. 

Funding

The AMRF requests a total of $275,000 for CY03 as detailed in the attached spreadsheet, 

$50,000 for VIEWS and $225,000 for the Causes of Haze project. Beginning in CY04, the 

AMRF anticipates the VIEWS amount will level out at $50,000/year for the foreseeable future. 

To be completed in CY05, the Causes of Haze report will need another $450,000. 
37

L. Air Managers Committee 

Background

The Air Managers Committee (AMC) was authorized in November 2001 by the WRAP board as 

a standing committee. AMC membership includes state and tribal air directors from within the 

WRAP region or their designated senior staff, and federal agencies involved in WRAP as exofficio members. The purpose of the AMC is to inform air managers of WRAP processes and 

products; provide a forum for air managers to identify and discuss priority issues related to 

WRAP, and to forward issues to the appropriate forum(s) to address; and to direct resources to 

specific needs not addressed in the work plans of other forums and committees. The AMC also 

serves as a forum to discuss issues between states and tribes and to resolve such matters prior to 

elevating them to the WRAP board of directors. The main points of AMC contact with the rest of 

WRAP are through the other standing committees: IOC, TOC and Communications Committee. 

Organizationally, the AMC is made up of a state caucus and a tribal caucus, with a member of 

each caucus appointed as co-chair. 

Work Plan

1. Caucus Staff Support 

Each caucus has staff support - the Tribal Caucus through NTEC, with additional support 

directly from WRAP; The State Caucus through a WGA contract with WESTAR. The caucus 

staff positions are generally responsible for disseminating information between WRAP 

committees and forums and their respective caucuses, and to facilitate communication between 

the two caucuses and with AMC as a whole. They are also responsible for issue definition, 

outreach and coordination. 

Some funding is also set-aside in this budget to provide for an Alaska tribal coordinator. 

Part of the reason AMC was formed is because the air managers are unable themselves or 

through their agency staffs, to participate first-hand in every aspect of WRAP proceedings. This 

creates gaps in the each air manager’s understanding of WRAP’s work products and uncertainty 

about implications for their respective air programs. Thus it is important that the caucus staff 

members attend the most significant meetings, workshops and conference calls, and provide 

summaries to all the air directors. This may involve travel to as many as 20-25 meetings each 

year by each staff member, as well as the associated telephone, supplies and other items. 

Caucus Staff Support Budget 

State Caucus Staff support 

 Personnel (incl. Indirect) $ 74,500 

 Travel (WESTAR) 22,500 

 Overhead @ 21% 20,400 

 Sub-Total $117,400 
38

2. AMC Program Enhancement 

Experience has shown that it is impossible to prepare a work plan for a complex project that 

addresses all contingencies. For example, unanticipated events, such as the recent D.C. Circuit 

Court Case, may create the need for supplemental technical work in addition to that contained in 

scheduled work plans. AMC proposes that the WRAP set aside an enhancement fund of $150,00, 

to be initially placed in the AMC budget to address unanticipated needs. These funds may be 

used as needed to augment existing project budgets or to fund new priority projects sponsored 

either by the AMC directly or by other WRAP committees and forums. 

Funding

Caucus staff support: $117,400* 

Program Enhancement: $150,000

Total: $267,400 

* There may be additional costs associated with the Alaska tribal coordinator 
39

M. Communications Committee 

1. Update and maintain web site - primary communications tool for the WRAP 

 A. Update/Redesign Web Site 

 B. Maintain Web Site 

2. Continue and expand publications for both internal and external audiences 

 A. Collect inputs, draft and publish The WRAP Sheet on the Web Site 

 B. Translate The WRAP Sheet into Spanish and post on the Web Site 

 C. Print and mail hard copies of The WRAP Sheet to selected recipients 

 D. Produce brochures, fact sheets and other handout materials for conferences, 

exhibits and public meetings 

3. Update and develop alternate presentation materials to tell the WRAP story 

A. WRAP 301A, 401 and Tribal versions (tailor to meet needs of various 

forums/committees) 

B. Convert to various video formats and make duplicate copies for multiple venues 

(CD, VHS, 35mm, etc.) 

4. Expand speakers' bureau activity to assure exposure of WRAP story to state and tribal 

general audiences throughout the WRAP region (tailor to individual audiences as 

appropriate) 

 

 A. Develop and maintain data base of prospective audiences 

 B. Work with state and tribal air directors/forum and committee chairs and follow up 

on contacts to schedule presentations 

 C. Coordinate presentation and support materials for all scheduled events 

5. Support WRAP forums and committees in conducting public meetings to inform and 

obtain public input on WRAP work products and related state SIP/tribal TIP development 

efforts 

 

 A. Assist with arrangements for meeting venues 

 B. Coordinate presentation and support materials for all scheduled events 

6. Consider other public outreach efforts to reach wider audience - investigate partnering 

with other agencies/programs with shared goals (i.e. Pollution Prevention Roundtable 

for AP2 presentation) 

 

 A. Identify potential partnerships and follow up to develop cooperative ventures 

 B. Participate in joint ventures with mutual benefit 
Appendix A 

Preliminary Long-Term Budget 
 A-1 

WRAP Preliminary Long-Term Budget 

Projects CY04 

Proposed 

CY05 

Proposed 

CY06 

Proposed 

Market Trading Forum 

Analysis of NOx and PM for Section 309 and 308 100,000 200,000 100,000 

Determine Sources Subject to BART 100,000 

Fire Emissions Joint Forum 

Technical Guidance on ERT Use (supports annual emissions goal reporting) 40,000 

2002 Inventory of Wx, Rx, and WFU for wildland, rangeland, ag 125,000 

2018 Projections of Wx, Rx, and WFU for wildland, rangeland, ag 50,000 

Co-Sponsor National Fire Conference 30,000 

Tech guidance on natural/anthropogenic apportionment 50,000 100,000 

Investigate/summarize smoke management techniques to reduce RH impacts 60,000 

Develop feasibility criteria for use in Categorizing Fire Emissions and ESMP 20,000 

Develop credit policy for use of alternatives to burning for Annual Emissions Goal 30,000 

Develop Fire EI for "large" sources in Mexico and Canada (include remote sens.) 120,000 

Develop Fire EI for 2018 and 2064 sorted by natural and anthropogenic sources 112,500 112,500 

Policy/technical options to refine Annual Emissions Goal using FTS 25,000 

Assess use/develop guidance of Remote Sensing for Fire EI Development 75,000 

Develop bridge to transfer FTS data into Emissions Data System 10,000 

Establish workgroup to assess use of biomass for energy production 100,000 

Air Pollution Prevention Forum 

Tracking and Reporting RE and EE Implementation and Impacts of Legislation 50,000 

Develop Market Guidelines and Verification Protocols for Regional Credit Trading 40,000 

Technical Assistance to States/Tribes for SIPs/TIPs 50,000 50,000 

Mobile Sources Joint Forum 

Smart Growth Toolkit and Workshop 50,000 

Sources In and Near Class I Areas Forum 

Gateway Community Demonstration Project 50,000 50,000 50,000 

Economic Analysis Forum 

Development of In-House Modeling Capabilities 75,000 75,000 75,000 

Air Quality Modeling Forum 

Regional Technical Center (UCR) 600,000 600,000 600,000 

Alaska Modeling - Placeholder until further review by AQMF 100,000 100,000 100,000 

Emissions Forum 

Emission Inventory Data Base System - Home and Caretaker 100,000 100,000 100,000 

Develop Representative Community EI's (Phase 2) - (incl. Alaska) 50,000 

Emission Inventory Data Base System - User Protocol 45,000 

Emission Inventory Data Base System - User Training 50,000 

Incorporate updated Canada and Mexico information 5,000 

Electronic Database Enhancement (incl. Alaska) 75,000 

Transfer Alaska EI to Established Grid 75,000 

Develop Alaska "Below Mixing Height" Aviation EI 50,000 

Develop Alaska "Cruising Height" Aviation EI 100,000 

Improvements for Organics 85,000 

Detailed Speciation for Significant Sources unknown 

Tribal Data Development Work Group 

Tribal Inventory Gathering and Analysis (ITEP/NAU) 200,000 200,000 200,000 

Research & Development Forum / Dust Tasks 

Dust - Evaluation of Natural Background 100,000 100,000 

Ambient Monitoring and Reporting Forum 

Establish and Maintain VIEWS Database (CSU) 50,000 50,000 50,000 

Causes of Haze Report (DRI) -- 3 years 225,000 225,000 
 A-2 

Air Managers Committee 

State/Tribal Caucus Staff Support (WESTAR) -- Includes Travel 117,400 117,400 117,400 

STIP II Contractor Assistance / Program Enhancement 150,000 150,000 150,000 

Communications Committee 

Web Site Administration (B. Bissey) 30,000 30,000 30,000 

Public Outreach and Communication on WRAP Issues 40,000 40,000 40,000 

Travel and Project Management 

Travel Reimbursed by WGA 150,000 150,000 150,000 

Conference Calls 35,000 35,000 35,000 

Meeting Expenses 40,000 40,000 40,000 

Other Expenses 15,000 15,000 15,000 

WGA Salaries and Benefits 325,000 325,000 325,000 

WGA Overhead 195,000 195,000 195,000 

Subtotals 

Subtotal for Contractor Assistance 3,424,900 2,484,900 1,612,400 

Subtotal for Travel and Project Management 760,000 760,000 760,000 

Subtotal for NTEC 305,000 305,000 305,000 

GRAND TOTAL 4,489,900 3,549,900 2,677,400 
Appendix B 

Market Trading Forum Work Plan 
Market Trading Forum Work Plan Page B-1 July 25, 2002 

Market Trading Forum Charge 

And Work Plan for FY 2003

July 25, 2002 

Mission

The Market Trading Forum (MTF) shall make recommendations to the Western Regional Air 

Partnership (WRAP) and related WRAP forums regarding emission control strategies for 

stationary sources, and the development of integrated, market-based programs that include other 

source categories, such as mobile and area sources. The MTF shall use the following broad 

guidelines. 

1. Develop information and supporting documentation that will be needed by states and 

tribes to implement the provisions of the Annex in the state and tribal implementation 

plans (SIPs and TIPs) in 2003. 

2. Where possible, use innovative, market-based strategies to achieve the emission goals for 

stationary sources. Consider the development of multi-pollutant, multi-source trading 

programs that will encourage the most cost-effective emission reductions to achieve 

visibility improvement goals. 

3. Consider other regulatory requirements, such as new source review and the development 

of new SIPs and TIPs for PM2.5 to ensure that the scope and timing of emission control 

strategies are integrated with complementary programs. 

Background

The Market Trading Forum began meeting in August 1997 to develop the details of the 

stationary source recommendations of the Grand Canyon Visibility Transport Commission 

(GCVTC), primarily the establishment of emission milestones for SO2 and a backstop regional 

cap-and-trade program for SO2 that would be implemented if the milestones were not met 

through voluntary means. 

In July 1999, the EPA published a revision to 40 CFR Part 51, Subpart P, Protection of 

Visibility, that accepted the recommendations of the GCVTC recommendations and established 

requirements for western states and tribes to develop SIPs and TIPs by December 31, 2003, 
Market Trading Forum Work Plan Page B-2 July 25, 2002 

based on these recommendations. States and tribes also have the option to develop SIPs and 

TIPs using different strategies to improve visibility at western Class I areas at a later date. 

The WRAP submitted the Annex by October 1, 2000, as required by the rule, that established 

emission milestones and the details of a backstop cap-and-trade program. On May 6, 2002, EPA 

proposed amendments to section 309 of the regional haze rule to incorporate the provisions of 

the Annex. In order for a state to submit a SIP or TIP under Section 309, it must adopt the 

necessary provisions of the Annex into its SIP and submit the revision to EPA by December 31, 

2003. Tribes may submit TIPs at a later date. A plan revision must then be submitted in 2008 to 

address additional stationary source provisions for NOx and PM. 

States and tribes also have the option to develop SIPs and TIPs using different strategies to 

improve visibility at western Class I areas. Implementation Plans that are not based on the 

Grand Canyon Commission strategies will be due sometime between 2004 and 2008, depending 

on the circumstances in each area. 

Related References

Voluntary Emission Reduction Program for Major Industrial Sources of Sulfur Dioxide 

in Nine Western States and a Backstop Market Trading Program, an Annex to the Report 

of the Grand Canyon Visibility Transport Commission, Western Regional Air 

Partnership, September 29, 2000. 

Recommendations for Improving Western Vistas, Report of the Grand Canyon Visibility 

Transport Commission to the United States Environmental Protection Agency, June 10, 

1996. 

40 CFR Part 51, Subpart P, Protection of Visibility 

Voluntary Emissions Reduction Program for Major Industrial Sources of Sulfur Dioxide 

in Nine Western States and A Backstop Market Trading Program: An Annex to the 

Report of the Grand Canyon Visibility Transport Commission, and Appendices, Western 

Regional Air Partnership, September 29, 2002. 

Additional background information, including meeting minutes, technical materials, and working 

draft documents can be found on the MTF page on the WRAP web site, located at 

www.wrapair.org. 

Structure of the Forum

A number of critical tasks need to be completed to address the stationary source requirements for 

the regional haze rule, as well as the development of market based strategies to achieve the 

visibility improvement goals in the most cost effective manner. These tasks need to be 

coordinated to ensure that there is consistency with the recommendations of the GCVTC report 

and the Annex, however, the tasks will also require the input of a large number of stakeholders 
Market Trading Forum Work Plan Page B-3 July 25, 2002 

and technical experts. The MTF relies on a number of targeted workgroups to address the 

specific tasks outlined in this work plan. These workgroups will develop specific 

recommendations under the broader policy guidance and supervision of the MTF. The 

remaining tasks in this work plan that do not require additional expertise will be addressed 

directly by the MTF. This discussion of the subject matter jurisdiction for these workgroups is 

intended to provide general guidance. Once the workgroups are formed, the MTF will work with 

the workgroups to refine their scope of work as appropriate. 

Allocations Workgroup (Utility and Non-utility)

Finalize allocation estimates for all source categories, and provide examples of how the various 

pieces of the allocation methodology will work together. 

Tracking and Record Keeping Workgroup

The Annex provides an overview of the tracking and record keeping requirements both prior to 

and after the backstop program has been triggered. Additional detail will be needed in the 309 

SIPs and TIPs. 

1. Monitoring Protocols. Detailed monitoring protocols should be developed for all 

source categories that are subject to the backstop trading program to ensure that the 

monitoring is equivalent to the requirements of 40 CFR 75. Reporting and recordkeeping requirements are currently in the Model Rule but may be refined under this task. 

2. Allowance and emissions tracking system (after program is triggered). If the backstop 

trading program is triggered, an allowance and emissions tracking system will be needed 

to determine compliance with the program. The system itself does not need to be created 

at this time, but a framework is needed that a contractor could then use to build a system 

in the future. The acid rain ATS and ETS could be used as the starting point for the 

system, or a new system could be designed to meet the needs of the WRAP. 

3. New energy development impacts on milestone assumptions. Track the development 

of new and planned energy sources (utilities, refineries, renewable energy sources) 

Prepare a report to submit to the WRAP at their Spring 2003 meeting that describes the 

SO2 emissions from these new energy sources, as well as SO2 emission changes from 

existing energy production and other industrial sources. 

MTF Tasks and Deliverables 

1. RAVI/Geographic Enhancements. The SO2 milestones were developed to meet the 

requirements for regional haze visibility impairment through a backstop trading program, in lieu 

of case-by-case BART determinations. Prior to 2018 when BART will be satisfied for all 

eligible BART sources participating in the 309 backstop regional trading program, there may be 

“hot spot” issues, where individual sources or a small group of sources uniquely affect visibility 

at a Class I area. The visibility rule addresses this issue through the application of BART due to 

reasonably attributable visibility impairment (RAVI). The interaction between these two 
Market Trading Forum Work Plan Page B-4 July 25, 2002 

requirements in the context of a trading program in lieu of BART is referred to as geographic 

enhancements. 

A. Finalize the draft MOU between the states, tribes, and the federal land managers to 

address the circumstances under which the FLMs would determine that reasonably 

attributable visibility impairment (RAVI) is occurring at a Class I area. This MOU will 

be submitted as part of the implementation plans in 2003. 

B. Prepare a consensus document that describes how the RAVI/BART process will be 

implemented under the Annex. Discussions continue among interested stakeholders 

participating in the MTF to specify areas of concern to each affected interest and work 

toward agreement on how to resolve differences. 

2. Tribal Set-Aside. The Annex contains a tribal set-aside of 20,000 tons of SO2 allowances. 

The process for distributing these allowances among tribes needs to be defined. The WRAP 

comments on EPA’s proposed approval of the Annex noted that the tribal set-aside distribution 

methodology was not needed in the short term, but should be completed no later than 1 year after 

the program has been triggered. The IOC does not anticipate that the program will be triggered 

in the near term. The MTF should provide support to the tribal caucus, as requested, when the 

tribal caucus addresses this issue. 

3. Model Rule and MOU. The MTF should work with the Air Managers Committee to finalize 

the model rule and MOU for use in the section 309 SIPs and TIPs and to ensure that these 

documents are consistent with the Annex agreements. 

A. Develop additional protocols and guidance documents for the backstop trading 

program, as identified by the Air Managers Committee in their review of the model rule 

and MOU, to ensure regional consistency. 

B. Review, modify if necessary and adopt, as appropriate, the products of the 

AMC/WESTAR process on adapting the MOU and Model Rule for implementation into 

SIPs and TIPs. 

4. Stationary Source NOx and PM. The MTF should prepare a report, as outlined in 40 CFR 

51.309(d)(4)(v), that addresses stationary source emissions of NOx and PM. This report should 

be submitted to the WRAP for consideration by the spring of 2003 to allow states and tribes time 

to include the report in their SIP/TIP submittals in December 2003. The report should address 

the following items. 

A. Assessment of emissions control strategies. Prepare a report, as outlined in 40 CFR 

51.309(d)(4)(v) which assesses emission control strategies for stationary source NOx and 

PM and the degree of visibility improvement that would result from such strategies. 

B. Backstop Trading Program. Evaluate and discuss the need to establish milestones for 

NOx and PM to avoid any net increase in these pollutants from stationary sources within 

the Grand Canyon visibility transport region, and to support future development and 
Market Trading Forum Work Plan Page B-5 July 25, 2002 

implementation of a multi-pollutant, and possibly multi-source market-based program. 

backstop trading program for NOx and PM. 

(i) Evaluate the benefits and possible difficulties that would be encountered by 

allowing interpollutant trading for stationary sources to meet the visibility 

improvement goals for the region. 

(ii) Evaluate the benefits and possible difficulties that would be encountered by 

expanding the backstop trading program to other source categories, such as area 

sources and mobile sources. 

(iii) Develop a support document that proposes mechanisms and their feasibility 

for expanding the program to include non-GCVT Region states and tribes. 

C. Impact on Tribal Lands. Identify potential effects that stationary source emission 

reduction strategies for NOx and PM may have on tribal lands, including impacts on 

economic development. Identify any critical data gaps regarding stationary source 

emissions on tribal lands, and make recommendations for addressing these data gaps. 

D. BART Requirements for section 309 SIPs. The 2003 SIP/TIP must provide for an 

implementation plan revision by December 31, 2008 that contains any long-term strategy 

and BART requirements for stationary source PM and NOx. The report in 2003 should 

address the potential for emission reductions that will be achieved due to the 

establishment of milestones and a backstop trading program for SO2. 

(i) The report should also address whether the MTF should consider the 

establishment of milestones for NOx and PM, as outlined in task 2, that will 

achieve greater reasonable progress than would be achieved through the 

installation and operation of source-specific BART. 

(ii) If a trading program is not recommended, the report should identify options 

and supply background technical information to assist states and tribes in the 

development of case-by-case BART analyses for NOx and PM. 

E. BART Requirements for section 308 SIPs. The report should identify options and 

supply background technical information to assist states and tribes in the development of 

BART determinations for all visibility impairing pollutants, as required in 40 CFR 

51.308(e). 

5. Section 308 Stationary Sources. 

A. The MTF should prepare a report that identifies stationary source categories in the 

region, projected emissions from these categories, emission control options including 

costs and expected benefits, and recommendations regarding the need for regional control 

strategies to address the visibility impact due to emissions from these sources. This 

report is intended to provide background information that states and tribes may use to 
Market Trading Forum Work Plan Page B-6 July 25, 2002 

determine whether additional emission reduction strategies, beyond those required to 

meet the requirements for BART, are needed to meet the visibility improvement goals of 

section 308 of the regional haze rule. 

(i) Evaluate the use of innovative, market-based solutions to achieve emission 

reductions from stationary sources in the region, including trading programs, 

clean air investment funds, and emission fees. 

B. Expansion of Backstop Trading Program to WRAP states and tribes outside of the 

Grand Canyon Transport Region. Make recommendations regarding the expansion of the 

regional SO2 milestones and backstop trading program to WRAP states and tribes that are 

outside of the Grand Canyon visibility transport region. 

(i) Evaluate the effect of expansion on the demonstration that the SO2 milestones 

achieve greater reasonable progress than BART. 

(ii) Identify any regulatory barriers that would prevent expansion of the program. 

6. Tribal Issues and Capacity Development. Overarching issue that should be addressed by the 

MTF and each of the workgroups in regards to the individual tasks. 

Note: The Tribal Caucus is currently evaluating the issue of data development, and the best way 

to provide tribal input into the various forums of the WRAP. This language is included as a 

placeholder, and will be revised as part of this broader tribal effort.

A. Identify tribal cultural considerations that may affect the control of stationary source 

emissions in the region. Identify potential regulatory burdens or other economic impacts 

that may affect tribal lands due to specific stationary source emission reduction strategies. 

B. Identify data gaps, including emissions data for tribal stationary sources, as well as 

other technical limitations that need to be addressed before strategies can be developed 

for specific source categories or geographic regions. Make recommendations regarding 

ways to resolve these data gaps and improve the technical basis. 

Collaborative Requirements

The MTF should coordinate with other forums to ensure that common issues are addressed and 

to ensure that there are not significant overlapping work products, or significant gaps that are not 

being addressed by any forums. In particular, the MTF should maintain on-going 

communication with the Emissions Forum, Modeling Forum and the Pollution Prevention Forum 

to ensure that overlapping issues are addressed. 
Market Trading Forum Work Plan Page B-7 July 25, 2002 

Process Requirements 

The Market Trading Forum should: 

1. Follow the general guidelines developed by the WRAP for all forums. 

2. Adhere to the objectives described above, and meet schedules for deliverables. 

3. Provide meeting minutes to the IOC, as well as short quarterly reports that will be 

posted on the web. 

Membership Criteria

The MTF should be comprised of a mixture of policy and technical experts. Experience with the 

development of the Annex is important to ensure that the overall goals of the Annex are 

maintained, however, additional expertise will be needed to complete the tasks outlined in this 

post-Annex work plan. The IOC recommends that the composition of the MTF be re-evaluated 

to ensure broad stakeholder representation. This evaluation will consider the current stakeholder 

categories and the number of participants for each category. Once the stakeholder categories and 

numbers are defined, the MTF will consider applications for membership. The MTF will give 

special consideration to the input of the stakeholder groups in identifying new and continuing 

members. At least 50% of the membership should have experience with developing the Annex 

to ensure that the broad goals and negotiated agreements of the Annex are maintained. 

In addition, the MTF should establish workgroups, as needed, that are comprised of technical 

and policy experts to develop some of the specific work products as discussed above. Joint 

workgroups that are coordinated with the TOC may be needed in some cases. The MTF will 

designate individuals to participate in the workgroups, although the workgroups will be given the 

opportunity to add members in order to address specific technical or policy needs. As stated 

above, all work products developed by the workgroups must be reviewed by the MTF. 
Appendix C 

Preliminary 2004-05 Work Plan 

for the Fire Emissions Joint Forum 
 C-1

Preliminary 2004-05 Work Plan 

for the Fire Emission Joint Forum 

Develop technical guidance on apportionment of fire emissions data (Natural and 

Anthropogenic) with monitored IMPROVE data for purposes of determining baseline visibility 

conditions and reasonable further progress demonstration. ($50,000 in 2004, $100,000 in 2005) 

Develop feasibility criteria for technical guidance and refinement for Policy for Categorizing 

Fire Emissions Program Management and Classification Criteria, as well as the elements of an 

ESMP. ($20,000 in 2004) 

Investigate and summarize smoke management techniques for fire sources that reduce regional 

haze impacts on Class I areas. Techniques that should be assessed include use of meteorological 

conditions, dispersion characteristics, burning of smaller units, etc. ($60,000 in 2004) 

Develop Emission Inventory for large fire sources from Mexico and Canada. Include assessment 

of use of remote sensed data for this purpose. ($120,000 in 2004) 

Develop Emission Inventory of 2018 and 2064 of fire sources apportioned by natural and 

anthropogenic categorization. ($112,500 in 2004, $112,500 in 2005) 

Develop policy for credit for use of alternatives to burning. Assess examples (CA) and others 

for incorporation into Annual Emissions Goal/Reasonable Further Progress. ($30,000 in 2004) 

Develop policy and technical options that refine Annual Emissions Goal Policy to accommodate 

Fire Tracking System (Baseline emissions data, short-term fire projections, etc)($25,000 in 2004) 

Development of the bridge for the transfer of FTS data into WRAP Centralized Emission and 

Inventory System. ($10,000 in 2005) 

Assess the potential use of remote sensing for fire emissions inventory development including 

consideration of cost, accuracy, and methods. Develop technical guidance for WRAP use of 

remote sensing for fire emissions inventories. ($75,000 in 2005) 

Establish a workgroup with Pollution Prevention Forum to assess use of biomass/vegetative 

material for energy production (material availability, energy content, barriers, technology, 

pollution trade-off). ($100,000 in 2005)