# Evaluation of State Emission Trends Analysis

Technical Support Document

for the EPA’s

Proposed Action on the

New Mexico Regional Haze Five-Year Progress Report State Implementation Plan

November 2, 20152 For information in this technical sup port document, please contact:

James E. Grady Air Planning Section U.S. Environmental Protection Agency- Region 6

1445 Ross Avenue
Dallas, Texas 75202-2733 (214) 665-6745 grady.james@epa.gov3 Emissions Reductions

Clean Air Markets Division (CAMD) impl ements the provisions of 40 CFR § 75, which requires an hourly accounting of emissions from sources part icipating in an emissions cap and trade program under the Acid Rain Control Program, the NO X Budget Trading Program, or the Clean Air Interstate Rule. Most of the CAMD sources are traditional power plants that sell electricity to the electrical grid. There are other types of sources th at report to CAMD that are not considered to be EGUs, such as petroleum refineries and cement kilns. However, in New Mexico, the CAMD data represents EGUs only. The annual unit level CAMD NO X and SO 2 emissions data from 2001-2014 were downloaded by the EPA for use in this progress report review.

The EPA prepared Table 1 and Figure 1 below to compare to the results that NMED provided in Figure 3.6 of the progress report SIP. The EPA showed that SO 2 emissions from point sources dropped 22,230 tpy to 16,548 tpy from 2008-201 2, reflecting a 25.5% reduction. Similarly, NO 2 emissions reduced 68,800 tpy to 59,603 tpy, refl ecting a 13.4% reduction. These emission reductions are slightly lower than what NMED provided in figu re 3.6 of the progress report SIP, but show similar

trends.

Table 1: New Mexico Emissions from CAMD 1

Year SO 2 (tpy) NO X (tpy)
2001 62,198 83,340
2002 50,818 78,362
2003 50,841 77,135
2004 38,361 74,139
2005 30,527 75,285
2006 31,153 78,025
2007 26,659 71,187
2008 22,230 68,800
2009 19,283 66,291
2010 16,556 59,935
2011 17,810 61,947
2012 16,548 59,603
2013 17,722 57,253
2014 12,030 43,591

1 Source: U.S. EPA Clean Air Market Division www.epa.gov/airmarket/4 Visibility Progress

The EPA has provided table 2 below and subsequent glide path charts from the WRAP website 2 to provide a visualization of how New Mexico is pr ogressing with their RPGs. The 2018 RPGs in the progress report SIP are slightly higher than the uniform rate of progress to meet 2064 natural conditions. However, other important issues are cons idered in developing mandatory Federal Class I area progress goals. Other reasonable progress factors in the CAA are as follows:

 The costs of compliance;

 The time necessary for compliance;

 The energy and non-air quality environmental impacts of compliance; and

 The remaining useful life of any existing source subject to such requirements.

Table 2: New Mexico RPG Comparison

Class I Area 2018 RPG (dv) 2018 Uniform Rate of Progress (dv) 2064 Natural Conditions (dv)

Bandelier National Monument 11.9 10.8 6.3 Bosque del Apache Wilderness Area 13.59 12.1 6.7

Gila Wilderness Area 12.99 11.6 6.7

Carlsbad Caverns National Monument 16.93 14.7 6.7

Salt Creek Wilderness Area 17.33 15.4 6.8

San Pedro Parks Wilderness Area 9.8 9.1 5.7 Wheeler park Wilderness Area 10.23 9.4 6.1

White Mountain Wilderness Area 13.27 12.1 6.8

2 Data from the following WRAP website: http://vis ta.cira.colostate.edu/TSS/Results/HazePlanning.aspx 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,00020012002200320042005200620072008200920102011201220132014tpy

Date 

### Figure 1 New Mexico Emissions from CAMD

SO2 (tpy) NOx (tpy)567 Emissions Progress

The EPA preferably views the “applicable five-year period” to represent the five years that have elapsed since the State submitted its RH SIP. There is room for state discretion in the reports regarding the five-year period that is considered to be most practical and useful for meeting this requirement. There is an inevitable time delay in developing and reporting inventories and thus trends over the most recent five years will not be available. 3 New Mexico did include the latest inventory updates for

EGUs.

The progress report SIP included New Mexico’s baseline emissions inventory from 2002 and an estimated emissions inventory for a progress period from 2008. The baseline period was represented using a 2002 inventory developed by the WRAP for use in the initial WRAP RH SIP strategy

3 General Principles for the 5-Year Region al Haze Progress Reports for the Initia l Regional Haze State Implementation P lans (Intended to Assist States and EPA Regional Offices in De velopment and Review of the Progress Reports , EPA, April 2013.8 development. The progress period was represented by a 2008 inventory, which leveraged recent WRAP inventory work for the West-wide Jumpst art Air Quality Modeling Study (WestJumpAQMS) and the Deterministic & Empirical Assessment of Smoke’s Contribution to Ozone (DEASCO3) modeling project efforts.

The pollutants inventoried include SO 2 , NO X , ammonia (NH 3 ), volatile organic compounds (VOCs), primary organic aerosol (POA), elemental carbon (E C); Fine soil reported as the crustal or soil components of PM 2.5 ; and coarse mass as the difference between PM 10 and PM 2.5 mass measurements (PMC). The inventories were categorized for all major visibility-impairing pollutants under major source groupings either as anthropogenic or na tural. The anthropogenic source categorization included point and area sources; on and off-road mob ile sources; area oil and gas; fugitive and road dust; and anthropogenic fire. The natural source categorization included natural fire, wind-blown dust, and biogenic sources.

A comparison of emissions inventory data showed that emissions of the key visibility-impairing pollutants SO 2 and NO X , dropped. SO 2 decreased from 50,667 tpy in 2002 to 27,545 tpy in 2008, including a 12,754 reduction in point sources from 2002-2008. NO X decreased from 345,974 tpy to 228,199 tpy, including a 37,885 tpy redu ction in point sources from 2002-2008.

The largest differences for point source inventories were decreases in SO 2 , NO X and VOCs. Note that this is consistent with the summary of annual EG U emissions as included in Figure 3.21, showing

decreases in SO 2 and NO X emissions. Please note that NO X and SO 2 point source emissions for 2008- 2012 are already under the 2018 WRAP projections. New Mexico expects overall SO 2 , NO X and PM EGU emissions to continue to decline due to BART implementation. Installation of NO X SNCR controls will occur on two of the units at the beginni ng of 2016 and two other units will retire at the

end of 2017. Both actions should result in further visibility improvement at Class I areas affected by

New Mexico sources.

Area source inventories showed decreases in SO 2 and VOCs and increases in NO X and NH 3 . New Mexico mentioned that these changes may be due to a combination of population changes and differences in methodologies used to estimate these emissions.

On-road mobile source inventory comparisons showed decreases in SO 2 , NH 3 and VOCs, but increases in most other parameters, including NO X . Off-road mobile source inventories showed

decreases in NO X , SO 2 , VOCs, and EC, and slight increases in fine soil and coarse mass.

For all parameters, especially POAs, VOCs, and EC, natural fire emission inventory estimates decreased, and anthropogenic fire inventories increased. Comparisons between VOC inventories showed large decreases in biogenic emissions, which was consistent with other contiguous WRAP States. Fine soil and coarse mass increased for the windblown dust inventory comparisons and the combined fugitive/road dust inventories. Large va riability in changes in windblown dust was observed for the adjoining WRAP States.