State of New Mexico

Office ofthe Governor

Bill Richardson

Governor

December 26,2003

Mr. Richard E. Greene, Regional Administrator

U.S. Environmental Protection Agency, Region VI

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

SUBJECT: REQUEST FOR APPROVAL OF REVISION TO THE STATE

IMPLEMENTATION PLAN FOR AIR QUALITY

Dear Mr. Greene,

As provided by 40 CFR Part 51, Appendix V and 40 CFR Part 51, Subpart P, I am writing

to request approval 0 f t he attached documentation, which w ill serve as the basis for a

revision to the State Implementation Plan (SIP) for New Mexico. Specifically, I am

submitting documentation that will serve to fulfill requirements of 40 CFR 51.309,

known as the "Section 309 Regional Haze SIP element". Two companion regulations are

also being submitted. These are 20.11.21 NMAC, Open Burning and 20.11.46 NMAC,

Sulfur Dioxide Emissions Inventory Requirements; Western Backstop Sulfur Dioxide

Trading Program. The attached proposed SIP revision is applicable to Bernalillo County,

New Mexico.

The Albuquerque/Bernalillo County Air Quality Control Board (AQCB) approved these

proposed revisions to the SIP on November 12, 2003, after a public review period and

corresponding public hearings held on October 8, 2003 and November 12,2003. The two

regulations, 20.11.21 NMAC and 20.11.46 NMAC were filed at the New Mexiw Sfllf,e

Records Center. The effective date for these regulations is December 31, 20@.

believe that the submitted materials provide adequate documentation to sup~rtul,'e

requested SIP revision. ,,~

<..':) :' ,

To facilitate your review and processing, the following materials are enclosed:

I) SIP Completeness Checklists pursuant to 40 CFR 51, Appendix V

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State Capitol • Room 400 • Santa Fe, New Mexico 87501 • 5°5-476-2200 • www.govemor.state.nm.us
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2) Hearing records, including transcripts and exhibits

3) Comments received

December 24,2003

4) The final AQCB-approved SIP revision for Regional Haze, including the

two companion regulations.

5) Other supporting documentation

Your favorable consideration of this request is appreciated. If you have any questions,

please contact Alfredo Santistevan, Director 0 f t he Albuquerque Environmental Health

Department, at (505) 768-2600.

Sincerely,

Bill Richardson

Governor

State ofNew Mexico

cc: Alfredo Santistevan, Director, Albuquerque Environmental Health Department

Sandra Ely, Chief, Air Quality Bureau, New Mexico Environment Department

Enclosures
SECTION 309 REGIONAL HAZE

STATE IMPLEMENTATION PLAN ELEMENT:

ALBUQUERQUE/BERNALILLO COUNTY,

NEW MEXICO

,----------~

FINAL VERSION

Appendices

September 8, 2003

Revised October 5, 2003

City of Albuquerque Environmental Health Department

Air Quality Division

Control Strategies Section

Reviewed and Approved after Public Hearing by:

Albuquerque/Bernalillo County

Alf Quality Control Board (AQCB)

Approval Date: November 12, 2003
OTHER APPENDICES

(as included by the local authority)

Appendix A-O Final Regional Haze Rule (RHR)

(FR Vol. 64, No. 126, July 1, 1999)

Appendix B-O State of New Mexico Letter-Decision to Pursue 309

Appendix C-O Albuquerque/Bernalillo County Open Burning/Smoke Management

Regulation (draft), 20.11.21 NMAC

Appendix 0-0 tJl\ ~u';;af6e~,~eOURt~ Western Backstop Sulfur Dioxide (S02)

Trading Program Regulation (draft), 2g.~.4S ~JMAe ....,.2. .i I NM t.c.

Appendix E-O Western Backstop Sulfur Dioxide (S02) Trading Program Model Rule

Appendix F-O General Definitions in the RHR

Appendix G-O Complete Citation of Stationary Source Requirements in Section 309

(h) and 309 (f)

Appendix H-O WRAP report Stationary Source NOx and PM Emissions in the WRAP

Region: An Initial Assessment of Emissions, Controls and Air Quality

Impacts (draft), May 30, 2003.

Appendix 1-0 Revisions to the RHR to Incorporate Sulfur Dioxide Milestones and

Backstop Emissions Trading Program for Nine Western States and

Eligible Indian Tribes within that Geographic Area, FR Vol. 68, No.

108, June 5,2003. (a.k.a.-The Annex)

Appendix J-O Revisions to the Regional Haze Rule to Correct Mobile Source

Provisions in Optional Program for Nine Western States and Eligible

Indian Tribes within that Geographic Area, Final Rule, July 3, 2003.

Appendix K-O WRAP policy report Fire Tracking Systems, April 2, 2003.

Appendix L-O State of New Mexico Smoke Management Program (SMP)-

Emission Factors and Calculations

Appendix M-O WRAP policy report Enhanced Smoke Management Programs for

Visibility, November 12, 2002.

Appendix N-O WRAP report Annual Emission Goals for Fire Policy, April 2, 2003.

Appendix 0-0 State of New Mexico Appendix-Pollution Prevention (P2)
Appendix P-O

Appendix 0-0

Appendix R-O

OTHER APPENDICES-continued:

(as included by the local authority)

WRAP report Recommendations for Making Attribution Determinations

in the Context of Reasonably Attributable BART, May 22, 2003.

EPA Completeness Criteria for the Regional Haze SIP

References
This document contains

OTHER APPENDICES

K‐O to R‐O.

OTHER APPENDICES

A‐O to J‐O

are in a separate document.
WRAP POLICY

FIRE TRACKING SYSTEMS

ApPROVED BY CONSENSUS:

WESTERN REGIONAL AIR PARTNERSHIP- APRIL 2, 2003

ApPROVED BY CONSENSUS:

FIRE E~lISSIONSJOINT FORUM - DECE~lBER 19, 2002

PREPARED BY:

FIRE TRACKING SYSTEMS TASK TEAM OF THE FIRE EMISSIONS JOINT FORUM

APRIL 2,2003
Executive Summary

The Western Regional Air Partnership (WRAP) is charged with developing technical and policy

tools to assist states (or the delegated regulatory authority) and tribes with implementing the

Regional Haze Rule (Rule).

The WRAP Policy on Fire Tracking Systems (WRAP FTS Policy) has been developed over a sixmonth period through a stakeholder-based consensus process to assist the WRAP region states

and tribes in addressing emissions from fire sources. In this Policy, the WRAP seeks to provide a

consistent framework that states and tribes can use to efficiently develop their individual

implementation plans, long-term strategies, and periodic progress reports. The WRAP recognizes

states' and tribes' authority and responsibility to develop, adopt and implement their regional

haze implementation plans, and recognizes the Rule as the principal document on which states

and tribes should rely.

The Rule requires states to develop implementation plans (SIPs) for addressing regional haze in

the Nation's 156 mandatory Class J areas. Additionally, the Rule requires effective management

of fire sources. The Rule provides two pathways for western states to follow as they implement

the requirements of the Rule: I) develop their regional haze implementation plans per the

nationally applicable provisions of Section 308, or 2) Transport Region States may choose to

incorporate the Grand Canyon Visibility Transport Commission (GCVTC) Recommendations

into their regional haze implementation plans under Section 309 of the Rule.

It is the position of the WRAP FTS Policy that it is necessary to track fire activity information in

the WRAP region using a fire tracking system, which will also provide the information essential

to create a fire emissions inventory. The WRAP FTS Policy identifies seven essential

components of a fire tracking system that represent the minimum spatial and temporal fire

activity information necessary to consistently calculate emissions and to meet the requirements

of the Rule. The resulting emissions will be used in modeling exercises to assess fire impacts to

regional haze.

An emissions inventory and tracking system for fire are specific requirements under Section 309

and a broader requisite under Section 308 of the Rule. The fire tracking system and WRAP

emissions inventory system are regional approaches to the data gathering and tracking initiatives,

which arc specifically encouraged in the Rule. Therefore, the WRAP is advancing the WRAP

FTS Policy for states and tribes under both Sections 308 and 309 to meet the requirements ofthe

Rule.

Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to

assume the regional haze requirements outlined in the Rule may, according to the Tribal

Authority Rule (TAR), seek approval under 40 CFR 49 to be "treated in the same manner as

States." The intent of this Policy is to assist both states and tribes with the development of their

regional haze implementation plans (SIPs/TIPs), and therefore, tribes are included in all

references to states, except where specific requirements and/or deadlines of the Rule are cited.
Most fire emissions inventory and tracking efforts established to date in the WRAP region have

been developed in conjunction with smoke management programs to address public health and

nuisance concerns. Fortunately, fire emissions inventory and tracking efforts regardless of thc

pu'rpose, have some common elements. It is anticipated that the fire tracking system and WRAP

emissions inventory system outlined herein will integrate well with current and future fire

emissions inventory and tracking efforts.

The WRAP FTS Policy document is comprised of four major sections. Section I is the five

WRAP FTS Policy Statements. Section 2 provides overall background for the WRAP FTS

Policy, including a discussion of the regulatory environment and details of the Rule that are

gennane to the WRAP FTS Policy. Section 3 is an annotation of each of the five policy

statements, further explaining and defining them, and a description of the seven essential fire

tracking system components. Finally, Section 4 Appendices include: A) a glossary of tenns, B) a

website references listing, and C) supporting information on fire tracking systems.

ii
TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY

I. POLICY STATEMENTS

2. BACKGROUND I

2.1. Clean Air Act and Grand Canyon Visibility Transport Commission I

2.2. Western Regional Air Partnership 2

2.3. Regional Haze Rule 2

2.3.1. Section 309 3

2.3.2. Section 308 4

3. ANNOTATED POLICY 4

3.1. Introduction 4

3.2. Fire Activity Information 5

3.2.1. Fire Tracking System 5

3.2.2. Emissions Inventory 6

3.2.3. Applicability 7

3.3. Essential Components of a Fire Tracking System 8

3.3.1. Essential Component I. Date of Burn 9

3.3.2. Essential Component 2. Burn Location 9

3.3.3. Essential Component 3. Area of Burn 9

3.3.4. Essential Component 4. Fuel Type 10

3.3.5. Essential Component 5. Pre-Burn Fuel Loading 10

3.3.6. Essential Component 6. Type of Burn 10

3.3.7. Essential Component 7. "Anthropogenic" or "Natural" 10

Classification

3.4. Annual Emission Goals 10

3.5. Fire Emissions Projection II

3.6. Collaborative Development 12

4. APPENDICES 13

Appendix A. Glossary 13

Appendix B. Website References 18

Appendix C. Supporting Information 20

"'
1. Policy Statements

A. fire activity information for all fire types is needed in the WRAP region. A fire tracking

system that captures this information will form the basis of a fire emissions inventory compiled

annually, which is needed to support Regional Haze Rule requirements.

B. A fire tracking system includes the following seven essential components that are necessary in

order to consistently calculate emissions and to uniformly assess impacts to regional haze:

I. Date of Burn

2. Burn Location

3. Area of Burn

4. fuel Type

5. Pre-Burn fuel Loading

6. Type of Burn

7. "Anthropogenic" or "Natural" Classification

C. A fire tracking system should include additional components as needed to support the

development and implementation of annual emission goals and other control measures.

D. A fire tracking system should include a component that addresses the projection of fire

emissions, which is necessary to meet the requirements ofthe Regional Haze Rule.

E. The development of fire tracking systems by states and tribes will be done collaboratively

with state, tribal, local and federal land management agencies, and private parties.

2. Background

2.1. Clean Air Act and Grand Canyon Visibility Transport Commission

In 1990, Congress amended the Clean Air Act (CAA), and as part of these amendments created

the Grand Canyon Visibility Transport Commission (GCVTC).' The GCVTC was charged with

assessing the cun'ent scientific infonnation on visibility impacts and making recommendations

for addressing regional haze in the western United States. The GCVTC signed and submitted

more than 70 recommendations to the Environmental Protection Agency in a report dated .Iune

1996 that indicated that visibility impairment was caused by a wide variety of sources and

pollutants, including fire on a episodic basis, and that a comprehensive strategy was needed to

remedy regional haze.

The second of the GCVTC Recommendations Regarding fire describes the need for a consistent

region-wide emissions tracking system for prescribed fire, wildfire, and agricultural burning. 2

I The Grand Canyon Visibility Transport COlllmission (GCVTC) was composed of the governors of eight weslern

slates (AZ, CA, CO, NM, NV, OR, UT, WY), rour tribes (Acoma Pueblo, Hopi, Hualapai, and Navajo), rour Federal

land management agencies (Bureau of Land Management, U.S. Fish and Wildlife Service, U.S. Forest Service,

National Park Service), the Columbia River Inler-Tribal Fish COlllmission, and the Environmental Protection

Agency.

2 Grand Canyon Visibility Transport Commission, Recommendations for Improving Western Vistas, Report to the
2.2. Western Regional Air Partnership

The Western Regional Air Partnership (WRAP) was established in 1997 as the successor

organization to the GCVTC. The WRAP is a voluntary organization comprised of western

governors, tribal leaders and federal agencies,' and is charged "to identify regional or common

air management issues, develop and implement strategies to address these issues, and fonnulate

and advance western regional policy positions on air quality.,,4 These policies and technical tools

are developed through inclusive, stakeholder-based processes and approved by consensus of the

WRAP.

WRAP participants include state air quality agencies, tribes, federal/state/private land managers,

the EPA, environmental groups, industry, academia and other interested parties. There are over

400 tribes within the WRAP region. The large number of tribes limits the participation of all of

them in WRAP activities, and accordingly, in the development of this Policy. Therefore, the

tribal representatives involved in the development of this Policy may not represent all tribal

concerns.

2.3. Regional Haze Rule

Following the issuance ofthe GCVTC Report, the EPA issued the Regional Haze Rule' (Rule) in

July 1999 to improve visibility in 156 national parks and wilderness areas across the country.

The Rule outlines the requirements for states and tribes to address regional haze in these

mandatory Class I areas. EPA incorporated all of the GCVTC Recommendations into Section

309 of the Rule, which may be used by some of the WRAP states/tribes. The remaining WRAP

states must, and tribes may, utilize the nationally applicable Section 308 provisions ofthe Rule.

Under Sections 308 and 309 of the Rule, states must, while tribes may, address visibility

impainnent in mandatory Class I areas due to emissions from all sources, including fire

activities, which is made possible by an inventory of emissions of pollutants that contribute to

visibility impairment. Further, the Preamble to the Rule calls for the tracking of pollutant

emissions to supplement the tracking of monitored visibility changes for use in periodically

reviewing the progress toward the natural visibility goaL" In regard to the requirements for

periodic progress reports, both Sections 308 and 309 of the Rule call for:

U.S. EPA, June 10, 1996 (herealier reICrred to as "GCVTC Report"), p. 48.

J The WRAP membership is comprised orthe governors or thirteen western slates and thinccn western tribes. The

currenl WRAP members include the Stales of AK, AZ, CA, CO, 10, MT, ND, NM, OR, SD, UT, WA, and WYand

the Tribal Nations of Pueblo or Acoma, Campo Band of Kumeyaay Indians, Conina Indian Rancheria, Hopi Tribe,

Hualapai Nation or the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai

Confederaled Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fori Hall, Federal W RAP members

are the Department oflhe Interior, the Department of Agriculture, and the Environmental Protection Agency.

4 WRAP Charter, Purpose, p. I.

'Published in the Federal Register on July I, 1999,64 FR 35714.

(. 64 FR 35725-35726.

2
An analysis tracking the change over the past 5 years in emissions of pollutants

contributing to visibility impairment from all sources and activities within the

State. Emissions changes should be identified by type of source or activity. The

analysis must be based On the most recent updated emissions inventory, with

estimates projected forward as necessary and ap~ropriate, to account for

emissions changes during the applicable 5-year period.

Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to

assume the rcgional haze requirements outlined in the Rule may, according to the CAA, seek

approval to be treated in the same manner as states, under the Tribal Authority Rule (TAR), 40

CFR 49.8 In these cases, EPA still recognizes that "unlike States, tribes are not required by the

TAR to adopt and implement CAA plans or programs, thus tribes are not subject to mandatory

deadlines for submittal of implementation plans.,,9 Although provision for flexibility in the

submission of programs and implementation plans for tribes is made under TAR, EPA does

"encourage tribes choosing to develop implementation plans to make every effort to submit by

the deadlines to ensure that the plans [TIPs] are integrated with and coordinated with regional

planning efforts."'o

EPA recognizes the WRAP as the Regional Planning Organization that is developing the

necessary policy and technical tools to implement the Rule in the WRAP region. A WRAP

policy, once approved, represents the WRAP's consensus position on the best means for states

and tribes to implement the portion of the Rule at issue. The WRAP recognizes states' and

tribes' authority and responsibility to develop, adopt and implement their regional haze state and

tribal implementation plans, and the seminal guidance to do this is the Rule."

2.3.1. Section 309

Section 309 of the Rule specifically calls for:

[a] statewide inventory and emissions tracking system (spatial and temporal) of

YOC, NOx, elemental and organic carbon, and fine particle emissions from fire. 12

Under Section 309, states must, while tribes may, incorporate a fire tracking system and a

mechanism to generate the required emissions inventory, based on fire activity infonnation, into

their SIPsrrIPs. Further, this is one step ofseveral that will afford statesltribes the demonstration

of reasonable further progress through 2018,13 as required by the Rule. The fire tracking system

will provide information critical to the implementation of other requirements under Section

309' , including the development of an enhanced smoke management program, the establishment

of annual emission goals, and the projection of fire emissions.

7 64 FR 35769, ~51.308 (g) (4) and 64 FR 35772, ~51.309 (d) (10) (i) (D).

'64 FR 35759.

'64 FR 35758.

10 64 FR 35759.

" WRAP Charier, p.1.

"64 FR 35771, ~51.309 (d) (6) (ii).

I) 64 FR 35769, ~51.309 (a).

14 64 FR 35771, ~51.309 (d) (6).

3
2.3.2. Section 308

Although Section 308 of the Rule does not explicitly address the emiSSions inventory and

tracking necessary for programs related to fire, Section 308 of the Rule does assert that the

SIP/TIP must provide for:

A statewide inventory of emissions of pollutants that are reasonably anticipated to

cause or contribute to visibility impainnent in any mandatory Class J area. The

inventory must include emissions for a baseline year, emissions for the most

recent year for which data are available, and estimates of future projected

emissions. The State must also include a conunitment to update the inventory

periodically. IS

In addition, Section 308 of the Rule states that in establishing its long-term strategy for regional

haze,

The State must document the technical basis, including modeling, monitoring and

emissions information, on which the State is relying to determine its

apportionment of emission reduction obligations necessary for achieving

reasonable progress in each mandatory Class I Federal area it affects. 16

And:

The State must identify all anthropogenic sources of visibility impaimlent

considered by the State in developing its long-teml strategy [for regional haze].

The State should consider major and minor stationary sources, mobile sources,

and area sources. 17

These Rule citations support the need for a fire tracking system that will facilitate the

development ofa fire emissions inventory and the establishment oflong-term strategies for states

under Section 308.

3. Annotated Policy

3.1. Introduction

The WRAP FTS Policy is the result of the WRAP region-wide multi-state/multi-tribe planning

and coordination effort. This effort is consistent with the direction provided by EPA in the

Preamble to the Rule that encourages states to work together to establish common approaches for

emissions inventory development and tracking. I

8

15 64 FR 35767, *51.308 (d) (4) (v).

16 64 FR 35767, *51.308 (d) (3) (iii), emphasis added.

17 64 FR 35767, *51.308 (d)(3) (iv). Fire is considered an area source.

" 64 FR 35720.

4
The intent of the WRAP FTS Policy is to assist states (or the delegated authority) and tribes to

address emissions inventory and tracking associated with fire in a way that is adequate for

inwlementation plan development, long-term strategies, and periodic progress reports. The

WRAP FTS Policy identifies for states and tribes in the WRAP region the essential fire activity

infonnation necessary to consistently calculate emissions and to meet the requirements of the

Rule. The resulting emissions will be used in modeling exercises to assess fire impacts to

regional haze.

Most states/tribes in the WRAP region track fire and its subsequent emissions differently and

few, if any, states/tribes address all fire sources. Consequently, fire sources in the WRAP region

are tracked and inventoried at various and inconsistent levels, from daily burn activity and

emissions infonnation to annual emissions summaries, to no tracking. This variability is a proven

obstacle to inter-jurisdictional analysis offire impacts on visibility within the WRAP region. 19 In

addition, transport of fire emissions beyond the WRAP region emphasizes the need for the

development and consistent application of a fire tracking system and subsequent emissions

inventory mechanism that is predictable and flexible while meeting the requirements of the Rule.

The WRAP FTS Policy has been developed to embody appropriate regulatory and policy

requirements and to provide a predictable framework for fire tracking systems that can be

reasonably implemented by states and tribes. The WRAP believes that states maintain the

ultimate responsibility for the implementation ofthe fire tracking system. Tribes, or EPA on their

behalf, may choose to utilize fire tracking systems as a reasonably severable element in their

implementation plans.

The WRAP recognizes states/tribes authority and responsibility to develop, adopt and implement

their regional haze state and tribal implementation plans. The WRAP further recognizes that the

implementation plans will be revisited and revised, per the schedule specified in the Rule, giving

opportunities to refine individual fire tracking systems and subsequent emission inventories to

reflect technical advances and policy updates.

3.2. Fire Activity Information

Policy Statement A: Fire activity information for all fire types is needed in the WRAP

region. A fire tracking system that captures this i'!tormation will form the basis ofa fire

emissions inventory compiled annually, which is needed to support Regional Haze Rule

requirements.

3.2.1. Fire Tracking System

A tracking system for fire is a specific requirement under Section 309 and will be needed to

support general requirements under Section 308 of the Rule. A consistent fire tracking system

based on fire activity information is essential in order to consistently calculate emissions. The

resulting emissions will be used in subsequent regional modeling and visibility monitoring data

19 This is the result of the findings of the WRAP's 1996 fire emission inventory development and modeling efforts,

which were challenged by the dmmatic variability in fire activity information found across the WRAP region, and

consequently was one of the sources of uncertainty in the resulling emission inventory.

5
analyses. Therefore, the WRAP FTS Policy is for states and tribes in the WRAP region to track

fire activity information in their respective jurisdiction using a fire tracking system, which wi II

also provide the infonnation essential to create a fire emissions inventory.

The ability of a state or tribe to implement a fire tracking system with known fire actIvIty

information for all fire sources may require legislative or governmental changes to existing rules,

or removal of exemptions from regulation and/or tracking of specific fire sources. Therefore, the

WRAP FTS Policy allows for the consideration of direct data collection as well as indirect

estimation techniques, where they satisfY the minimum spatial and temporal infonnation

necessary to support emissions inventories and modeling for the WRAP region. In addition, the

WRAP recognizes that progressive implementation may be necessary to attain a level of data

collection that will ensure comparability between the tracking of fire activity infonnation and

monitored visibility changes. Sec Appendix C for general guidance on data collection, and the

Fire Emissions Joint Forum (FEJF) of the WRAP will be exploring viable data collection

methods at a later date.

3.2.2. Emissions Inventory

Infonnation from the fire tracking system will provide the basis for an emISSIOns inventory,

which is a requirement ofthe Rule under Section 309 and will be necessary under Section 308.

In reporting and tracking emissions from fire within the State, States may use

information from regional data gathering and tracking initiatives. 2t'

In keeping with the Rule's Preamble discussion of regional planning organizations and the role

of regional planning in such matters as emission tracking and inventory development, the WRAP

is developing a rcgional emissions inventory system." Statcs/tribes may utilize the WRAP

emissions inventory system as their cmissions invcntory mechanism. Fire emissions will be

calculated using the WRAP regional emissions invcntory system based on fire activity data

supplied by thc respective jurisdiction. States/tribes may choose to calculate fire emissions

internally within their jurisdiction. 80th the fire tracking system and the WRAP emissions

inventory system are regional approaches that are specifically encouraged in the Rule. Further,

these systems will support the fire emissions inventory and modeling nceds for regional haze and

ambient air quality standards such as those for ozone and particulate matter.

The WRAP's regional emissions tracking and forecasting system for point, area, biogenic,

mobile, and fire sources will rcsult in a complete inventory of all emissions of visibility

impairing pollutants (i.e., PM 10, PM'5, SO" NO" YOC, ROC, elemental carbon, ammonia) for

all sources within the WRAP region. The emission inventories will be both temporally and

spatially resolved and will include emissions from both man-made and natural sources. This

effort will facilitate the technical and planning efforts of the WRAP states and tribes by

compiling the emission inventories necessary for regional modeling efforts to analyze visibility

impacts and meet Rule requirements.

'" 64 FR 35771, §51.309 (d) (6) (ii).

2J 64 FR 35720.

6
Stationary Source Milestones and Clean Air Corridors as cited in the Rule will require emissions

to be compiled annually by the WRAP. As fire activity and subsequent emissions are highly

variable in tenns of strength, impact, location and timing, the WRAP FTS Policy specifies that

states will and tribes may provide fire activity infonnation to the WRAP on an annual basis.

3.2.3. Applicability

In keeping with the GCVTC Recommendations, the Rule, the WRAP Policy for Categorizing

Fire Emissions, and recommendations in the Interim Air Quality Policy on Wildland and

Prescribed Fires (EPA Interim Policy)22, the WRAP FTS Policy applies equitably across all land

types and fire sources. The WRAP FTS Policy calls for the tracking of fire sources on both

wildland and agricultural lands regardless of ownership, cause ofignition, or purpose ofthe fire.

All fire sources are included in the WRAP FTS Policy because it is recognized that all fires

(prescribed fire, wildfire, and agricultural burning) have an effect on air quality and contribute to

regional hazeD Fire Sources were among those specifically acknowledged in the GCVTC Report

as contributors to visibility impainnent on an episodic basis:

All types of fire (prescribed fire and agricultural burning) must be addressed

equitably as part of a visibility protection strategy.24

The use of fire by agriculture is well documented and the Agricultural Air Quality Task Force

(AAQTF) has recognized that agricultural burning has the potential to impact visibility in

mandatory Class I Federal areas." However, the extent of fire use is not well known in some

areas, and is the cause of uncertainty as to the contribution of agricultural burning sources on

regional haze. Accordingly, the AAQTF's Air Quality Policy on Agricultural Burning,

Recommendation to the u.s. Department of Agriculture states that " ... the contribution from

agriculture, specifically the impact of burning practices on regional air quality, must be

accurately assessed in relative proportion to the region's total emissions.,,26

Section 118(a) of the Clean Air Act requires that all entities, federal and non-federal, be subject

to the same requirements, authorities and processes, and the Rule is clear that all sources,

facilities, and property are to be treated equitably17 Additionally, stakeholder input garnered in

the development process of the WRAP Policy for Categorizing Fire Emissions supported

consistent consideration of fire between Sections 308 and 309 of the Rule. The WRAP FTS

Policy, therefore, will be applicable and useful to all states and tribes in the WRAP region.

n U.S. EPA, Oflice of Air Quality Planning and SLandards, InLerim Air Quality Policy on Wildland and Prescribed

Fires, April 23, 1998 (herealier referred 10 as "EPA Inlerim Policy").

" GCVTC Report, p. 47.

24 Ibid.

2~ Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recol11l11endalion to the U.S.

Department of Agriculture, November 10, 1999 (hereafter referred to as "AAQTF's Air Quality Policy

Recommendation"), Section IV, E.

2(, AAQTF's Air Quality Policy Recomlllendation, Section VII.

" 64 FR 35748.

7
The WRAP FTS Policy does not apply to Native American cultural non-vegetative buminf>. for

tradJllOnal, relIgIOus, or Ceremonial purposes (e.g., CrematIon, and sweat lodge fires): In

addition, the WRAP FTS Policy does not apply to open burning activities on residential,

commercial, or industrial property (e.g., backyard burning, garbage incineration, residential

wood combustion, and construction debris). However, the WRAP recognizes that the unique air

quality circumstances of a state or tribe may require emissions tracking information for these fire

source sectors. In addition, these sources may be quantified as area sources within populated

areas in other emissions inventory efforts by states, tribes or the WRAP.

3.3. Essential Components of a Fire Tracking System

Policy Statement B: A fire tracking system includes the following seven essential

components that are necessary in order to consistently calculate emissions and to

uniformly assess impacts to regional haze:

1. Date ofBurn

2. Burn Location

3. Area ofBurn

4. Fuel Type

5. Pre-Burn Fuel Loading

6. Type o.fBurn

7. "Anthropogenic" or "Natural" Classification

The seven essential components of a fire tracking system identified in this Policy have been

selected as the minimum spatial and temporal information to be collected consistently and

universally across the WRAP region to ensure comparability between and within states and

tribes, and across the WRAP region. The seven essential components are based, in part, upon

careful review and consideration of the EPA's Prescribed Burning Background Document and

Technical 1njormation Document jar Prescribed Burning Best Available Control Measures'9 and

the National Wildfire Coordination Group's Smoke Management Guide for Prescribed and

Wildland Fire 2001 Edition]O The seven essential components have also becn developed based

on the experience gained through the FEJF's 1996 and 2018 fire emissions inventory preparation

efforts] I J2

The fire tracking system's essential component data will provide the basis for calculating the

emissions for fire through the use of an emissions calculation mechanism, such as the WRAP

emissions inventory system described above, to integrate the appropriate emissions factors and

emission calculation techniques. In order to consistently calculate emissions and ensure the

1H WRAP Policy for Categorizing Fire Emissions, November 15,200 I (hereafler referred to as "WRAP Fire

Categorization Policy"), p. 24.

1<) U.S. EPA, Office of Air Quality Planning and Standards, Prescribed Burning Background Document and

Technicallnlonnation Document for Prescribed Burning Besl Available Control Measures, EPA-450/2-92-003,

Scptember 1992.

)0 National Wildfire Coordination Group, Smoke Management Guide for Prescribed and Wildland Fire, PMS 420-2,

NFES 1279, December 200 I (hereafter referred to as '''NWCG Smoke Management Guide").

JI WRAP Report 1996 Fire Emissions Inventory (DRAFT).

n WRAP Report InLegraled Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and

Agricultural Burning (DRAFT).

8
comparahility of the subsequent regional modeling analysis and analysis of visibility monitoring

data, states/tribes should utilize identical emission factors and calculation techniques in concert

with, the essential fire activity infonnation as described in this Policy]) The FEJF will develop

further guidance, beyond that contained in the FTS Policy, for states/tribes to establish quality

assurance methods, and the procedure and format for the submittal of fire tracking system

infonnation.

There are differences among states and tribes with regard to air quality issues, non-attainment

areas, emissions information, fire source sectors, and state legislative or tribal governmental

requirements. As a result, a state or tribe may choose to augment the seven essential components

with additional infonnation. Appendix C elaborates on additional fire activity and tracking

infonnation that a state or tribe may consider useful when developing its fire tracking system.

The essential component information described in this FTS Policy will be necessary to

accomplish the emissions inventory task as cited in the Rule. However, the WRAP recognizes

that the unique air quality circumstances of states/tribes may call for excluding some fires from

tracking by the establishment of a de minimus level, based on number of acres, tons of fuel, or

tons of emissions. The spatial and temporal variability of fire and the significance of visibility

impacts is highly dependent upon a number of factors such as size, fuel consumption,

meteorology, climate and proximity to a Class I area34 The WRAP FTS Policy does not

prescribe a de minimus level to exclude fires from tracking. States or tribes may wish to establish

de minimus levels, which should be defined in the SIP/TIP and be based on a source-impact

relationship. The FEJF will be assessing potential de minimus levels based on source/impact

relationships to assist states and tribes in this endeavor.

3.3.1. Essential Component 1. Date of Bum

It is critical that the temporal resolution of the fire activity information be attributed to a specific

day for each specific bum in order to con'elate with "best" and "worst" day visibility monitoring

data.J5

3.3.2. Essential Component 2. Bum Location

It is important that the spatial resolution of the fire activity be attributed to a specific location to

allow for source/visibility impact relationships to be established.

3.3.3. Essential Component 3. Area of Burn

The level of accuracy of the emission inventory will depend, most significantly, on the ability to

estimate the area burned (i.e., blackened acres)36

JJ See foolnole 19.

J4 For example, a 5111all agricultural burn (e.g., <2,500 acres at 4 Ions/acre consumption or 50 lons PM Ill) within 50

kilometers upwind ofa Class Iarea could have a greater visibility impacllhan a large wildland prescribed fire (e.g.,

>833 acres at 20 tons/acre consumption or 250 tons PMIU) within 100 kilometers downwind of a Class I area.

3S 64 FR 35734.

)/l Pelerson, Janice L. 1987. Analysis and reduction of the errors of predicting prescribed bum emissions. Thesis.

Seattle: University of WashingLon. 70p.

9
3.3.4. Essential Component 4. Fuel Type

Emissions from fire are highly dependent upon the fuel or cover type (e.g., ponderosa pine,

juniper, orchard residue, rice straw). It is crucial to provide the predominant fuel or cover type

that is burned so that the appropriate emissions factor can be selected to calculate fire emissions.

The fuel type will also help refine fuel consumption estimation.

3.3.5. Essential Component 5. Pre-Burn Fuel Loading

The pre-burn fuel loading represents the amount of fuel present at the bum location. For the

preparation of the fire emissions inventories, the accuracy of the pre-burn fuel-loading

component is vital. The more accurate the pre-bum fuel loading and characteristics of the fuel

load (e.g., size class infonnation), the more refined the subsequent emissions estimates will be.

3.3.6. Essential Component 6. Type of Burn

Type of bum represents the predominant configuration of the fuel bumed (e.g., pile, windrow,

broadcast, underbum). It is important to provide the type of bum so that the appropriate

emissions factor can be selected. Type of burn can also provide information for calculating fuel

consumption.

3.3.7. Essential Component 7. "Anthropogenic" or "Natural" Classification

The "anthropogenic" or "natural" classification is to be detennined per the WRAP Policy for

Categorizing Fire EmissionsH The WRAP will be analyzing daily visibility monitoring data

annually for Class I areas and reporting on the causes of haze on an annual basis. This analysis

will apportion fire emissions to natural visibility conditions and anthropogenic visibility

impairment based on a fire's "anthropogenic" or "natural" classification. The apportionment will

enable states and tribes to address natural reductions of visibility from fire as well as to identifY

those fire emissions that need to be controlled to achieve reasonable progress.

3.4. Annual Emission Goals

Policy Statement C: A .fire tracking system should include additional components as

needed to support the development and implementation of annual emission goals and

other control measures.

Section 309 of the Rule calls for states to establish "annual emission goals for fire, excluding

wildfire, that will minimize emission increases from tire to the maximum extent feasible."J8 The

WRAP Policy on Annual Emission Goals for Fire (WRAP AEG Policy) emphasizes the use of

emission reduction techniques (ERTs) as the basis of annual emission goals. States/tribes may

need to include additional components in their fire tracking system, beyond the listed essential

components, that they deem necessary to support the implementation of annual emission goals

)7 WRAP Fire Categorization Policy, p. 8.

"64 FR 35771, ~51.309 (6)(v).

10
and other control measures. The tracking of additional components such as the ERT used,

emission reductions achieved or other information (e.g., fuel moisture) should be tracked at the

same temporal and spatial resolution of the essential components to allow for regional modeling. ,

The FEJf will develop guidance on additional components to support the implementation of

annual emission goals and other control measures per the WRAP AEG Policy. In addition,

subsequent guidance to Appendix D ofthe WRAP AEG Policy will be developed by the fEJf to

summarize ERT options for common vegetation and crop types for both prescribed fires on

wildland and agricultural burning.

3.5. Fire Emissions Projection

Policy Statement D: A fire tracking system should include a component that addresses

the projection offire emissions, which is necessary to meet the requirements of the

Regional Haze Rule.

When developing long-tenn strategies that will meet the reasonable progress requirements for

both Sections 30839 and 3094

°, states and tribes must consider the anticipated net effect on

visibility due to projected changes in point, area, and mobile source emissions. fire is an area

source. Periodic progress reports are required under both Sections 308 and 309, that specifically

cite the need for future projected emissions.41 fire projections information also supports the

Section 309 requirement for fire programs within a state to evaluate the degree of visibility

impairment from smoke for both planning and operational purposes

42 Additionally, Section 308

of the Rule asserts that implementation plans must provide for estimates of future projected

emissions43 Therefore, a projected estimate of fire emissions from all fire source sectors will

serve as the basis for the projection of visibility conditions due to fire for the most impaired and

least impaired days, and will facilitate planning.

Since the use of fire for resource management is expected to increase

substantially, especially on federal lands, State/Tribal air quality managers will

need information to develop potential annual or seasonal air pollutant emissions

estimates for SIP/TIP planning. 44

The fire emissions projection component of a fire tracking system may be developed in a variety

of ways to address the Rule requirements for future projected emissions from fire. fire emission

projection may be determined by surveys:5 use of growth factors, multipliers or other

techniques.

19 64 FR 35767, §51.308 (d) (3) (v) (G).

40 64 FR 35770, §51.309 (d) (2) and 64 FR 35773, §51.309 (g) (2).

41 64 FR 35769, §51.308 (g) (4) and 64 FR 35772, §51.309 (d) (10) (i) (D).

" 64 FR 35771, §51.309 (d) (6) (i).

4J 64 FR 35767, §51.308 (d) (4) (v).

44 EPA Interim Policy, p. 28.

45 WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and

Agricultural Burning (DRAFT), Appendix A, pp. 61-96.

11
The WRAP Policy on Enhanced Smoke Managemenl Programs for Visibilily includes the

consideration of regional coordination as a necessary element in an enhanced smoke

management program. A fire emissions projection component for the fire tracking system can

provide information critical to the implementation of that element. Inclusion of one-year

projected estimates of fire emissions On an annual basis can facilitate operational smoke

management and regional coordination. One-year projected estimates may also be useful to

estimate a preliminary annual emission goal.

The addition offive-year projected estimates offire emissions into a fire tracking system will aid

in regional planning as required by the Rule, as well as in the demonstration of reasonable

progress over the periods addressed by the long-tenn strategy and progress reports. Five-year

projected estimates of fire emissions would need to be submitted to support the periodic progress

report schedule (i.e., every five years). Neither of these projections should be construed as a

limit.46 The FEJF will develop guidance on the fire emissions projection component to meet the

various regulatory needs identified above and to work in concert with the WRAP emissions

inventory system.

3.6. Collaborative Development

Palicy Sialemeni E: The developmenl offire Iracking syslems by slales and Iribes will be

dane collabaralively wilh slale, Iribal, local andfederal land managemenl agencies. and

privale parlies.

In developing a fire tracking system, states and tribes will use a collaborative process, as per the

GCVTC Report, which includes state, tribal and federal land management agencies and private

pal1ies. Cooperation and collaboration between air regulatory agencies and fire managers is

necessary to design an effective and appropriate emission inventory system47 There are several

efforts underway within federal land management agencies and also within EPA to develop fire

tracking systems. State collaboration with these efforts may lead to greater efficiency and less

need to develop their own individual fire tracking systems for wildland fire. The use of a

collaborative process to develop a fire tracking system and subsequent emissions inventory may

promote economic efficiency by identifying mechanisms and infrastructure opportunities to

avoid the duplication oftime and effort.

Regional haze SIPsfflPs will be revisited and revised, per the schedule specified in the Rule,

thereby providing opportunities to refine the fire tracking system. Future refinements to the fire

tracking system may reflect policy changes and/or technical advances pertinent to mechanism,

infrastructure, and data collection options. The collaborative proeess will help to bring these

changes and advances to the forefront for use in revising the fire tracking system.

46 For clarification on emission limits as they applY to fire, see the WRAP Policy on Annual Emission Goals for

Fire.

47 NWCG Smoke Management Guide, p. 189.

12
4. APPENDICES

APPENDIX A. GLOSSARY

This glossary is intended to provide readers with several operating definitions to facilitate a

consistent review of this Policy. However, this glossary is not intended to be a complete list of

all terms and acronyms.

16 Class 1 Areas on the Colorado Plateau - The Grand Canyon Visibility Transport Commission

Report specified 16 mandatory Class I areas on the Colorado Plateau that were adopted

into Section 309 of the Regional Haze Rule. The 16 Class 1 areas are: Grand Canyon

National Park, Sycamore Canyon Wilderness, Petrified forest National Park, Mount

Baldy Wilderness, San Pedro Parks Wilderness, Mesa Verde National Park, Weminuche

Wilderness, Black Canyon of the Gunnison Wilderness, West Elk Wilderness, Maroon

Bells Wilderness, flat Tops Wilderness, Arches National Park, Canyonlands National

Park, Capital Reef National Park, Bryce Canyon National Park, and Zion National Park.

2064 Natural Conditions Goal" - The ultimate goal of the regional haze program is the absence of

visibility impairment due to human-caused emissions.

AAOTf - Agricultural Air Quality Task force. A task force to address agricultural air quality

issues established by the Chief ofthe Natural Resources Conservation Service.

Agricultural fire/Burning- - Any fire ignited by management actions to meet specific objectives

(i.e., managed to achieve resource benefits) on agricultural land.

Agricultural Land- - Agricultural land includes croplands, pasture, and other lands on which

crops or livestock are produced (PL 104-127, Section I240A). Rangeland will be

included with wildland for the purposes of the fire Emissions Joint forum work.

Alternatives to Burning - See Non-Burning Alternatives to fire definition below.

Anthropogenic Emissions Source Classification ("anthropogenic")" - A categorization that

designates which fire emissions contribute to visibility impairment in a Federal Class 1

area. "Anthropogenic" emissions must be controlled to achieve progress toward the 2064

natural conditions goal for each federal Class 1 area in the WRAP region. This

classification includes natural and human-caused ignitions.

Area Source - A source category of air pollution that generally extends over a large area.

Prescribed burning, field burning, home heating, and open burning are examples of area

sources.

Class I Area - See Mandatory Class I Area and Non-Mandatory Class I Area.

* Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1.

# Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15,200 I, Appendix A.

13
Ecosystem Maintenance# - A prescribed fire or wildfire managed for resource benefits, in an

ecosystem that is currently in an ecologically functional and fire resilient condition, that

is utilized to mimic the natural role offire.

Ecosystem Restoration' - The re-establishment of natural vegetation that may be accomplishcd

through the reduction of unwanted and/or unnatural levels of biomass, which may have

accumulated due to management action. Prescribed fires, wildfires managed for resource

benefits and mechanical treatments may be utilized to restore an ecosystem to an

ecologically functional and fire resilient condition.

Emission Factor - A representative value that attempts to relate the quantity of a pollutant

released to the atmosphere with an activity associated with the release of that pollutant.

These factors are usually expressed as the weight of pollutant divided by a unit weight,

volume, distance, or duration of the activity emitting the pollutant (e.g., pounds of

particulate matter emitted per ton of biomass burned).

Emissions Forum - The Emissions Forum is responsible for the oversight of the assembly and

quality assurance of the emissions inventories and forecasts to be utilized by the WRAP

forums and oversees the development of a comprehensive emissions tracking and

forecasting system.

Emission Inventory - A listing, by source, of the amount of air pollutants discharged into the

atmosphere.

Federal Class I area - See Mandatory Class I Area.

FEJF - Fire Emissions Joint Forum. The Fire Emissions Joint Forum's mission is to address both

policy and technical issues while developing programs and tools relating to prescribed

fire and air quality for the Western Regional Air Partnership and related Western

Regional Air Partnership forums.

Fire' - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland

fire managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.

GCVTC - Grand Canyon Visibility Transport Conunission. The GCVTC was authorized under

Scction 169B(I) of the Clean Air Act and composed of the governors of eight westem

states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi,

Hualapai, and Navajo), four Federal land management agencies (Bureau of Land

Management, U.S. Fish and Wildlife Service, U.S. Forest Service, National Park

Service), the Columbia River Inter-Tribal Fish Commission, and the Environmental

Protection Agency. The Commission was established to reconunend methods to preserve

and improve visibility on the Colorado Plateau, and submitted Recommendations to EPA

in June L996.

# Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15,2001, Appendix A.

* Operating Definilions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1.

14
Land Managers' - When this term appears, it refers inclusively to Federal, state, tribal, and

private land managers.

Mandatory Class I Area - In 1977, Congress identified 156 national parks (over 6,000 acres),

wilderness areas and national memorial parks (over 5,000 acres), and international parks

in existence before August of 1977 that were to receive the most stringent protection

from increases in air pollution. Congress also set a visibility goal for these areas to

protect them from future human-caused haze, and to eliminate existing human-caused

haze, and required reasonable progress toward that goal.

NAAQS - National Ambient Air Quality Standards.

Natural Emissions Source Classification ("natural")" - A categorization that designates which

fire emissions can result in a natural reduction of visibility for each Federal Class I area

in the WRAP region. This classification includes natural and human-caused ignitions.

Natural Visibility Goal - See 2064 Natural Conditions Goal.

Non-Burning Alternatives to Fire## - Techniques that replace fire as a means to achieve a

particular land management objective (e.g., reduction of fuel-loading, manipulation of

fuels, enhancement of wildlife habitat, eco-system restoration, etc.) In this Policy, nonburning alternatives do not include techniques used in conjunction with fire. Techniques

used in conjunction with fire are referred to as ERTs.

Non-Mandatory Class J Area - Class I areas designated by states or tribes, but are not deemed

mandatory by the Clean Air Act. As of January 2002, Class I areas designated by tribes

include: F0l1 Peck Reservation in Montana, Northern Cheyenne Reservation in Montana,

Flathead Reservation in Montana, Yavapai-Apache Reservation in Arizona (Class I status

under litigation), and Spokane Reservation in Washington.

Pasture Land" - Grazing lands comprised of introduced or domesticated native forage species

that are used primarily for the production of livestock. They receive periodic renovation

and/or cultural treatments such as tillage, fertilization, mowing, weed control, and may be

irrigated. They are not in rotation with crops (Natural Resources Conservation Service

National Range and Pasture Handbook, 1997).

Point Source - A source of pollution that is point-like in nature. An example is the smokestack of

a coal-fired power plant or smelter.

Prescribed Fire' - Any fire ignited by management actions to meet specific objectives (i.e.,

managed to achieve resource benefits).

.. Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1.

# Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15,200 I, Appendix A.

## Glossary Definition from WRAP Policy on Annual Emission Goals for Fire, Appendix A.

15
Rangeland" - Land on which the historic climax plant community is predominantly grasses,

grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or artificially

when routine management of that vegetation is accomplished mainly through

manipulation of ecological principles. Rangeland includes natural grasslands, savannas,

shrub lands, most deserts, tundra, alpine conununities, coastal marshes and wet meadows

(Natural Resources Conservation Service National Range and Pasture Handbook, 1997).

Regional Planning Organization - An organization that will first evaluate technical information

on regional haze and related issues to better understand how their states and tribes impact

national park and wilderness areas (Federal Class I areas) across the country. The

organization will then pursue the development of regional strategies to reduce emissions

of particulate matter and other pollutants leading to regional haze. The five Regional

Planning Organizations that receive funding from EPA to address regional haze and

related issues are: Central States Regional Air Partnership (CENRAP) for the central

states, Midwest Regional Planning Organization for the mid-western states, Ozone

Transport Commission (OTC) for the northeastern states, Visibility Improvement State

and Tribal Association of the Southeast (VISTAS), and Western Regional Air Partnership

(WRAP) for the western states.

Rule - Regional Haze Rule. Regulations published in the Federal Register on July I, 1999 (64 FR

35714) that require states to establish goals for improving visibility and to develop longterm strategies for reducing emissions of pollutants that cause visibility impaimlent.

Silvicu Iture' - The theory and practice of controlling forest establishment, composition, and

growth. The art of producing and tending a forest.

SIP - State Implementation Plan. Plans devised by states to carry out their responsibilities under

the Clean Air Act. SIPs must be approved by the U.S. Environmental Protection Agency

and include public review.

Smoke Effects* - The effects on visibility (both plume blight and regional haze), public

nuisance, and the health-based NAAQS due to emissions from fire.

TIP - Tribal Implementation Plan. Plans devised by tribes to carry out their responsibilities under

the Clean Air Act. TIPs must be approved by the U.S. Envirorunental Protection Agency

and include public review.

Transport Region State - One of nine states that make up the Grand Canyon Visibility Transport

Region: Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and

Wyoming.

Wildfire* - Any unwanted, non-structural fire.

# Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15,200 I, Appendix A.

* Operating Definitions from the WRAP FEJF Workplan, February 25,1999, Seelion 1.1.

16
Wildfire Managed for Resource Objectives' - The management of naturally ignited fires,

regardless of land type or ownership, to accomplish specific, pre-stated resource

management objectives in predefined geographic areas with or without a plan in place.

This tenn is considered to be analogous with the tenns Wildland Fire Managed for

Resource Benefits and Prescribed Natural Fire that are used in regulations and policies

regarding Federal wildlands.

Wildland' - An area where development is generally limited to roads, railroads, power lines, and

widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less

frequently than once in 10 years), is not fallow, and is not in the USDA Conservation

Reserve Program (CRP). The land may be neglected altogether or managed for such

purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant

cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is

not "agricultural land" as operationally defined above. Silvicultural land and rangelands

(per the FEJF charge), woodlots, and private timberlands will be included with wildlands

for the purposes of the FEJF work.

Wildland Fire' - All types offire (sec definition of fire above), except fire on agricultural land.

Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire' - These tenns both have

current use in regulations and policies. They are considered to be synonymous and are

used interchangeably in this [FEJF] workplan. These tenns refer to the management of

naturally ignited fires to accomplish specific, pre-stated resource management objectives

in predefined geographic areas outlined in the fire management plan.

WRAP Region - The WRAP region includes over 400 tribes and the states of Alaska, Arizona,

California, Colorado, Idaho, Montana, North Dakota, New Mexico, Oregon, South

Dakota, Utah, Washington, and Wyoming.

WRAP- Western Regional Air Partnership. The WRAP is a collaborative effort of tribal

governments, state governments and Federal agencies to promote and monitor

implementation of Recommendations from the Grand Canyon Visibility Transport

Commission. The WRAP may also address other common western regional air quality

issues as raised by its membership. The activities of the WRAP are conducted by a

network of committees and forums, composed of WRAP members and stakeholders who

represent a wide range of social, cultural, economic, geographic and technical

viewpoints. The WRAP membership is comprised of the governors of thirteen western

states and thirteen western tribes. The current WRAP members include the States of AK,

AZ, CA, CO, 10, MT, NO, NM, OR, SO, UT, WA, and WYand the Tribal Nations of

Pueblo of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi

Tribe, Hualapai Nation ofthe Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe,

Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock

Tribes of Fort Hall. Federal WRAP members are the Department of the Interior, the

Department of Agriculture, and the Environmental Protection Agency.

# Opemting Definitions from WRAP Policy for Categorizing Fire Emissions, November 15.200 1, Appendix A.

>I< Operating Dellnitions from the WRAP FEJF Workplan, February 25,1999, Seetion 1.1.

17
APPENDIX B. WEBSITE REFERENCES

This appendix is intended to provide readers with several website addresses that were used to

locate supporting information for the development ofthis Policy.

Western Regional Air Partnership (WRAP) website

(http://www.wrapair.org)

u.s. Environmental Protection Agency's, Office of Air Quality Planning and Standards,

Visibility website

(http://www.cpa.govIoar/visi biIitv)

- .Agricultural Air Quality Task Force website

(http://fargo.nserl.purdue.edu/faea)

GCVTC Recommendations for Improving Western Vistas, June 10, 1996

(http://www.wrapair.org) Go to the About WRAP link, Go to the GCVTC link

Regional Haze Rule, 40 CFR Part 51, July I, 1999

(http://www.epa.govIltn/oamg/t 1Ifr notices/rhfedreg.pdf)

- Tribal Authority Rule, 63 FR 7253, February 12, 1998

(http://www.epa.gov/fedrgstr/EPA-AJRlI998/February/Day-12/a3451.htm)

Western Regional Air Partnership Charter, Revised November 29, 2001

(http://www.wrapair.org/about/index.html) Go to the Charter link

WRAP, Fire Emissions Joint Forum Charge, July 29, 1998

(http://www.wrapair.org/forums/fejf/index.html) Go to the FEJF Charge link

Workplan, WRAP - Fire Emissions Joint Forum, February 25, 1999

(http://www.wrapair.org/forums/fejf/index.html) Go to the FEJF Workplan link

Policy for Categorizing Fire Emissions, Approved by Consensus by the Western Regional

Air Partnership, November 15, 200 I

(http://www.wrapair.org/forums/fejf/index.html) Go to the Natural Background [ink

WRAP Policy on Enhanced Smoke Management Programs for Visibility, Approved by

Consensus by the Western Regional Air Partnership, November 13,2002

(http://www.wrapair.org/forums/fejf/index.html) Go to the Enhanced Smoke Mgmt.

Programs link

WRAP Policy on Annual Emission Goals for Fire, Approved by Consensus by the Western

Regional Air Partnership, April 2, 2003

(http://www.wrapair.org/forums/fejf/index.html) Go to the Annual Emission Goal link

18
- WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed

Fire, Wildfire and Agricultural Burning (DRAFT)

(http://www.wrapaiLorg/forums/fejf/index.html) Go to the Emissions link

WRAP Report 1996 Fire Emissions Inventory (DRAFT)

(http://www.wrapaiLorg/forums/fejf/index.html) Go to the Emissions link

WRAP Report: Non-Burning Management Alternatives on Agricultural Lands in the Western

United States, Final, May 15,2002

(http://www.wrapaiLorg/forums/fejf/index.html) Go to the Non-Burning All. on

Agricultural Lands link

WRAP Report: Comprehensive Manual on Non-Burning Alternatives (DRAFT)

(http://www.wrapaiLorg/forums/fejf/index.html) Go to the Non-Burning All. on

Wildlands link

U.S. EPA, Interim Air Quality Policy on Wildland and Prescribed Burning, April 23, 1998

(http://www.epa.govIttnloarpg/tIImemoranda/firefnl. pdD

U.S. EPA, Prescribed Burning Background Document and Technicallnfonnation Document

for Prescribed Burning Best Available Control Measures, September 1992

(http://www.epa.govIcgi-bi nlciaI'itgwO0 p-Display&document=clserv:epacinb: 1681 ;&rank=4&template=epa)

National Wildfire Coordination Group, Smoke Management Guide for Prescribed and

Wildland Fire, PMS 420-2, NFES 1279, December 2001.

(http://www.nwcg.gov/pms/pubs/SMG-72.pdD

Smoke Management Program Surveys

I) Wildland Smoke Management Program Survey, January 26,2001

2) Boulder Wildland Smoke Management Program Survey, February 2, 2001

3) Agricultural Burning Smoke Management Program Survey, March 30, 2001

4) Institute for Tribal Environmental Professionals (ITEP) Tribal Smoke Management

Program Survey, An Assessment of Tribal Air Quality Data and Programs in the Western

United States, September 200 I

(http;llwww.wrapaiLorg/forums/fejf/index.html) Go to the Basic Smoke Mgmt. Programs

link

19
APPENDIX C. SUPPORTING INFORMATION

This appendix is intended to provide readers with supporting infonnation on fire tracking

systems, but does not specifically address all sections of the WRAP FTS Policy.

1. Essential Components

The FEJF will develop further guidance, beyond that contained in the FTS Policy, for

states/tribes to establish quality assurance methods, and the procedure and fonnat for the

submittal offire tracking system information. The following is supporting infonnation on the fire

tracking system essential components.

1.1. Essential Component 1. Date of Burn

For the purposes of the fire tracking system, the date of bum represents the fire activity (i.e., area

burned) on any specific day for each burn. For a multiple day bum, multiple entries should

correspond to the fire activity on each given day.

1.2. Essential Component 2. Burn Location

For each bum, the location should be provided to the nearest mile.

1.3. Essential Component 3. Area of Burn

Blackened acres should be determined post-bum. In a pile bum, the area burned should be

represented by the pile dimensions as well as the number of piles consumed.

1.4. Essential Component 4. Fuel Type

The appropriate emissions factor choice can become complicated when the fire consumes

multiple fuel or cover types (e.g., grass and sage). Therefore, for the purposes of the fire tracking

system, the fuel type would optimally represent the predominant fuel or cover type consumed in

the fire. If additional fuel types beyond the predominant type for a given burn are included in the

fire tracking system, the area burned for each fuel type would need to be clearly delineated to

allow for subsequent emissions calculations.

1.5. Essential Component 5. Pre-burn Fuel Loading

The pre-bum fuel loading should be expressed as thc weight offuel per unit area in tons per acre.

The consumption of the fuel will be calculated as part of the WRAP emissions inventory system

in order to reduce the propagation of field estimation errors.

1.6. Essential Component 6. Type of Burn

Type of bum represents the predominant configuration of the fuel burned (e.g., pile, windrow,

broadcast, underburn). If available, identification of pile type (i.e., hand-piled or machine-piled)

will enhance the quality of the subsequent emissions calculation. Detellllining the Type of Burn

20
can be complicated when a burn project includes multiple fuel configurations. For the purposes

of the fire tracking system, the predominant bum type should be reported. If additional fuel

configurations for a given burn are provided in addition to the predominant fire type, each type

of burn should have an area burned and fuel type to allow for subsequent emissions calculations.

I.7. Essential Component 7. "Anthropogenic" or "Natural" Classification

The "anthropogenic" or "natural" classification applies as it is defined by the WRAP Policy for

Categorizing Fire Emissions, which was developed to clarifY the complex relationship between

what is considered a natural source of fire and what is considered a human-caused source, as

acknowledged in the Rule 48 The appropliate classification is typically determined prior to the

initiation ofthe fire. 49

2. Optional Components

To support the integration of the fire tracking system with other policy and technical tools being

developed by the WRAP, there are four optional components of a fire tracking system that

states/tribes should consider in the development of their fire tracking system. The four optional

components include Daily Tracking, Fuel Consumption, Non-Burning Alternatives and

Additional Fire Tracking Information.

2.1. Daily Tracking

Smoke management is a key component in both Sections 308'" and 30951 of the Rule to address

visibility impacts from fire. To meet the smoke management requirements for Section 309, and

potentially as a tool for Section 308, the WRAP has developed its Policy on Enhanced Smoke

Management Programsfor Visibility (WRAP ESMP Policy).

The WRAP ESMP Policy recognizes that the more intensive levels of smoke management

necessitate daily inter- and intra-jurisdictional coordination for approved burns. These types of

smoke management programs may rely upon real-time meteorological data and daily fire activity

information available to cross-jurisdictional authorities, as well as a permitting system to avoid

cumulative smoke impacts and to assist in regional coordination.

To provide information critical to the implementation of daily tracking, it is recommended that

the pre- and post-bum infonnation be collected on a daily basis for the essential components, as

identified in this Policy. Additional daily tracking components, such as burner contact

infonnation, may need to be identified by states/tribes to satisfy the infonnation necessary for

daily coordination.

"64 ~R 35735.

49 WRAP Fire Categorization Policy, p. 12.

'" 64 FR 35767, *51.308 (d) (3) (v) (E).

"64 ~R 35771, *51.309 (d) (6) (i) and *51.309 (d) (6) (iv).

21
2.2. Fuel Consumption

Pre-burn fuel loading is a key component for the calculation of fire emissions, which can be

refined to a large extent based on the fuel that is actually consumed by the fire (i.e., fuel

consumption). The quantity of fuel actually burned in a fire will depend on the pre-bum fuel

loading and fuel moisture condition, the type offuel, climatic and meteorological factors, and the

intensity of the fire. Accuracy and precision is improved with fuel consumption estimates;

however, this parameter can be difficult to estimate. For example, in wildlands the fuel

consumed is often not confined to the fuels on the surface, but may include vegetation canopies

and/or organic soil layers. These fuels may dominate the mass of the fuel consumed, but have

often been neglected in biomass burning inventories.

Infonnation that specifies the quantity (i.e., percentage) of the pre-burn fuel load consumed by

the fire will enhance the accuracy of the emissions estimate and can be provided in the fire

tracking system as an optional component labeled Fuel Consumption. Inaccuracy in Fuel

Consumption can lead to the assumption that all of the pre-burn fuel load is consumed, resulting

in higher than actual emissions.

A number of different options are available to develop the fuel consumption infonnation

necessary to calculate fire emissions. Fuel consumption can be detennined through I) expert

opinion, 2) empirical models, 3) computer simulations (e.g., Consume52), or 4) other on-site

measurements. Field estimates do not always provide precise estimates. When available, the

most accurate methods to determine fuel consumption are the use of computer simulations.

Ocular estimates are an option, but are not preferred due to field variability.

2.3 Non-Burning Alternatives

Consistent with the WRAP Policy on Annual Emission Goals jiJr Fire, non-burning alternatives

are techniques that replace fire as a means to achieve a particular land management objective.

These techniques could be tracked in a fire tracking system, although the temporal scale will not

coincide with the listed essential components. Information may bc available from some burners

to track parameters such as the area where non-burning alternatives were used, the fuels that

were addressed and the specific technique(s) applied. Deternlining an acceptable method for

calculating emissions avcrted through the use of the non-burning altcrnatives would most

appropriately be developed collaboratively.

2.4. Additional Fire Tracking Information

There are differences among states and tribes with regard to air quality issues, emiSSIOns

information, fire source sectors, and state legislative or tribal governmental requirements. As a

result, a state or tribe may select various degrees of fire tracking information; this may include

additional parameters for different fire source sectors and/or smoke effects (i.e., plume blight,

regional haze, public nuisance, and health-based NAAQS), depending upon their projected or

actual impacts.

52 Padfic Northwest Research Station, Forestry Sciences Laboratory, Consume Software, Version 2.1.

22
Additional fire tracking information that a state or tribe may consider adding to a fire tracking

system includes, but is not limited to, a) fuel moisture, b) purpose of bum, c) plume rise, and d)

bum identification code. ,

3. Data Collection Methods

The ability of a state/tribe to implement the fire tracking system with known essential post-bum

activity infomlation for all fire sources may require legislative or governmental changes to

existing rules or removal of exemptions from regulation, and/or new tracking of specific fire

sources. Therefore, consistent with the WRAP's Charter, the FTS Policy allows for the

consideration of direct data collection as well as indirect estimation techniques, where they

satisfy the minimum spatial and temporal infoTInation necessary to support emissions inventories

and modeling for the WRAP region.

There are many ways to obtain the necessary data from a category of fires. Primary activity data

may be collected by the manager responsible for fire operations and forwarded to a data

collection point, or an agent of the permitting or regulating authority may collect the data. Data

might be collected for each operation, or a statistical sample gathered from each category of fire,

as defined by unique combinations of essential infoTInation components. The information might

be observed directly, or inferred from relevant parameters that can be collected more easily or

more accurately than direct observations. The FEJF will be exploring viable data collection

methods at a later date.

3.1. Direct Data Collection

Direct data collection methods cover a wide range, from something as simple as an individual

burner tracking the infoTInation in a log book to something as complex as a centralized burn

authority tracking the information in a database. The burner should ensure that the data and

information submitted to the oversight authority via direct data collection methods is accurate,

timely, and complete.

According to EPA's Interim Policy, "Federal land management agencies currently collect data

on wildland and prescribed fires, however, no standard reporting format is followed."" The data

collected by land management agencies is usually limited to the time and approximate location

ofthe fire, fire perimeter area, and a qualitative description of fuels at the point of ignition.

The WRAP's 1996 fire emissions inventory preparation effort demonstrated that the data

collected by land management agencies for wildland and prescribed fires is insufficient to

support the development of a consistent emissions inventory. AIthough current land management

agency data collection efforts do not consistently track all of the essential components identified

herein, the feasibility of modifying the current tracking system to maximize economic efficiency

and meet the needs of both land management and regulatory agencies should be evaluated. The

modification of current land management agency data collection efforts may prove to be the

most effective and economically efficient method for the tracking of wildland and prescribed

fires in the WRAP region.

5J EPA Interim Policy, p. 29.

23
3.2. Indirect Estimation

Direct data collection methods have historically been the primmy means of data collection for

fire tracking systems. However, emerging technologies may potentially allow for some of the

fire tracking system essential component information to be addressed via indirect estimation

techniques. Indirect estimation techniques have varying degrees of complexity and accuracy, and

range from an annual burner survey for a particular fire source sector, to statistical methods, to

daily remote sensing. Remote sensing might be considered for areas or fire sectors where no

previous tracking for fire sources has been established.

24
Appendix L-O

[from the State of New Mexico Smoke Management Program, Appendix J]

Emission Factors &Calculations

The table below was developed using vegetation type and loading or quantity, and emission

factors. The Air Quality Bureau (AQB) used emission factors from EPA (AP-42) and from

research done at the Pacific Northwest Research Station of the USDA Forest Service (C.C.

Hardy et al.) to develop the table. Additional tables that list these emission factors are

included below. As science improvements are made, the best available emission factors will

be used in the New Mexico Smoke Management Program.

NM Smoke Management Program Emissions Table

Vegetation Type One Ton PM10

Field Crops 65 Acres

Orchard trimmings 5000 Cubic feet piled

material

Shrub land 34 Acres

Forest 23 Acres

Shrub/forest piles 5000 Cubic feet piled

material

Grass 100 Acres

Table J.1. Method to determine, by general vegetation type, what acreage or pile volume

produces one ton of PM 1O.

Emission factors have been developed for certain vegetation (fuel) types and represent the

mass of pollutant (particulate matter) produced per mass of fuel consumed. Emission factors

are different for various fuel types, and are different for different phases of combustion.

Generally, the flaming phase of combustion produces fewer emissions than the smoldering

phase. Accordingly, the emission factor for the flaming phase is of a lesser value than that for

the smoldering phase. Emission factors allow the calculation of emissions in pounds of

pollutant, if vegetation type and loading is known.

Emissions are determined for a particular vegetation or fuel type by multiplying acres burned

times fuel loading in tons per acre by percent consumption times the emission factor for that

fuel type.

Thus, the standard algorithm for estimating emissions is:

Acres X tons per acre X percent consumption X pound per ton = pounds of pollutant

For example: 100 acres x 10 tons/ac x 0.5 (50%) x 22 Ibs/ton = 11,000 Ibs or 5.5

tons.

For Emission Factors, see the tables on the following pages, along with the Chapter 13.1,

Wildfires and Prescribed Burning, in AP-42, Fifth Edition, Volume 1, 10/96 (

www.epa.gov/ttn/chief/ap42 )

Appendix L-O, Page 1
Forest and Rangeland Emission Factors (Hardy et. al.)

el or Combusti

e on Emission Factors

nfigura PM

n Phasea PM10b PM 2.5 CO CO2 CH4 NMHC

(pounds emission per ton fuel consumed)

:OADCAST BURNED SLASH1

uglas

flaming 24.716.6 14.9 143 33854.6 4.2

mlock smoldering 35.027.6 26.1 463 2804 15.2 8.4

fire

average

29.6 23.1 21.8 312 3082 11.0 7.2

rdwood

flaming 23.014.0 12.2 92 33894.4 5.2

smoldering

38.0 25.9 23.4 366 2851 19.6 14.0

fire

average

37.4 25.0 22.4 256 3072 13.2 10.8

nderos

flaming 18.811.5 10.0 89 3401 3.0 36

dge

Ie pine smoldering 48.636.7 34.2 285 2971 14.6 9.6

fire

average

39.6 25.0 22.0 178 32028.2 6.4

(ed 22.0 11.7

niter flaming 9.6 53 34583.0 3.2

smoldering

33.6 25.3 23.6 273 302317.6 13.2

fire

average

29.0 205 18.8 201 316512.8 9.8

niper flaming 21.915.3 13.9 82 3401 3.9 5.5

smoldering

35.1 25.8 23.8 250 305020.5 15.5

fire

average

28.3 20.4 18.7 163 3231 12.0 10.4

.E·AND BURN

ASH1

Ictor 11.4 7.4

~d flaming 6.6 44 34922.4 2.2

smoldering

25.0 15.9 14.0 232 312417.8 12.2

fire

average 12.4 10.8 153 327111.4 8.0

Appendix L-O, Page 2
20.4

me

ad flaming 22.613.6 11.8 101 33499.4 8.2

smoldering

44.2 33.2 31.0 232 302230.0 20.2

fire

average

36.4 256 23.4 185 314321.7 15.2

verage

es" flaming 28.4 19.0 17.1 169 3207 16.6 11.6

:OADCAST BURNED SLASH2

gebru5

flaming 45.031.8 29.1 155 31977.4 6.8

smoldering

45.3 29.6 26.4 212 311812.4 14.5

fire

average

45.3 29.9 26.7 206 312611.9 13.7

aparral flaming 31.616.5 13.5 119 33263.4 17.2

smoldering

40.0 24.7 21.6 197 31449.0 30.6

fire

average

34.1 20.1 17.3 154 32575.7 19.6

REST WILDFIRE3

Appendix L-O, Page 3
___~I:_I~_~_ra,,-,g,,-e,----_I--,3--,O-,-. 0'----_----'1-=2'-'7-'-.0'----__'--- ---'- --"--- _

1 Ward. D.E.; Hardy, C.C.; Sandberg, D.V.; Reinhardt, T.E. 1989. Part III-emissions characterization.

In:, Sandberg, D.V.; Ward, D.E.; Ottmar, R.D., comp.eds. Mitigation of prescribed fire atmospheric pollution

through increased utilization of hardwoods, piled residues, and long-needled conifers.

Final report. U.S. DOE, EPA. Available from: U.S. Department of Agriculture, Forest Service,

Pacific Northwest Research Station. Seattle. WA.

2 Hardy, C.C.; Conrad, S.G.; Regelbrugge, J.C.; Teesdale, D.T. 1996. Smoke emissions from prescribed burning

of southem California chaparral. Res. Pap. PNW-RP-486. Portland, OR: U.S. Department of Agriculture, Forest

Service, Pacific Northwest Research Stalion. 37p.

3 Hardy, C.C.; Ward, D.E.; Enfield, W. 1992. PM2.5 emissions from a major wildfire using a GIS 1 2 rectification

of airborne measurements. In: Proceedings of the 29th annual meeting of the Pacific Northwest International

Section, Air and Waste Management Association: 1992 November 11-13; Bellevue, WA. Pittsburgh, PA: Air and

Waste Management Association.

a Fire average values are weighted-averages based on measured carbon flux.

b PM10 values are calculated, not measured, and are derived from known size-class

distributions of particulates using PM and PM2.5.

Emission Factors for Field Crops -

Vegetation Type PM10 _. PM2.5 --

Alfalfa 31.8 30.4

Barley 15.4 14.9

Corn 12.4 12.0

Cotton 17.717.0

Hay 31.830.4

Oats 22.921.8

Peanuts 17.717.0

Pecans 11.010.3

Pistachio 11.0 10.3

Sorghum 21.420.4

Wheat 11.510.9

Weeds (ditches/ditch banks) 17.7 17.0

Average field crops 17.7 17.0

Average orchard crops 11.0 10.3

- From Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire,

Wildfire, and Agricultural Burning. (draft) Western regional Air Partnership, Fire Emissions

Joint Forum by Air Sciences Inc. August 27, 2002.

-- Pounds pollutant per ton of residue consumed.

J.1. Definitions

Broadcast burning - intentional burning within well-defined boundaries for reduction of fuel

hazard, resource objectives, or both.

Combustion - the rapid oxidation of fuel in which heat and usually flame are produced.

Combustion can be divided into four phases: pre-ignition, flaming, smoldering, and glowing

AppendiX L-O, Page 4
Emission factor - the mass of particulate matter produced per unit mass of fuel consumed

(pounds per ton, grams per kilogram)

Flaming Phase - this phase follows the pre-ignition phase and precedes the smoldering

combustion phase. It is the luminous oxidation of gases evolved from rapid decomposition of

fuel in which water vapor, soot, and tar comprise the visible smoke.

Percent Consumption - the amount of a specified fuel type or strata expressed as a

percentage that is removed through the fire process.

Pile - materials that have been relocated either by hand or machinery and heaped together.

Pyrolysis - the thermal or chemical decomposition of fuel at an elevated temperature

Slash - debris resulting from such natural events as wind, fire, or snow breakage; or such

human activities as road construction, logging, pruning, thinning, or brush cutting. It includes

logs, chunks, bark, branches, stumps, and broken understory trees or brush

Smoldering Combustion Phase - combined process of dehydration, pyrolysis, solid

oxidation, and scattered flaming combustion and glowing combustion, which occur after the

flaming combustion phase of a fire; often characterized by large amounts of smoke

consisting mainly of tars. Emissions are twice that of the flaming combustion phase

J.2. References

Regional Haze Rule

Published in the Federal Register on JUly 1,1999,64 FR 35714.

http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf 35363738

WRAP Policy on Enhanced Smoke Management Programs for Visibility

Approved by the Western Regional Air Partnership, November 12, 2002.

http://www.wrapair.org/forums/fejf/documents/esmptl!policy/030115 ESMP Policy. pdf

Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire,

and ~gricultural Burning. (Draft), August 27, 2002.

http://www.wrapair.org/forums/fejf/documents/emissionsNVGA..1SJ.18EI Draft.pdf

Estimating Fuel Loading

[from State of New Mexico Smoke Management Program, Appendix K]

Fuel, in the context of wildland or agriCUltural fire, refers to all combustible material available

to burn on an area of land. Grass, field crops, brush, timber and slash or thinning residue are

the most common fuels found in New Mexico. Each fuel has its own burning characteristics

based on several inherent factors. These factors include its moisture content, volume,

arrangement and the plant's genetic make up. All of these contribute to how a fire spreads,

its intensity, and its smoke production and emissio ns.

Fuel loading is measured in tons per acre. Grass is considered a light fuel with approximately

Yo tons per acre. On the other end of the spectrum, thick brush, a heavy fuel, can have a

volume of over 21 tons per acre. The intensity of the fire is direc tly related to fuel loading.

Grass burns rapidly with a short period of intense, maximum heat output; brush, on the other

hand, has a long sustained high heat output making it more difficult to control.

There are several way to estimate fuel loading. One is to take measurements of the current

vegetation or debris. Browns transects can be used for woody fuels and clip, dry and weigh

can be used for grass fuels. Other methods include using fuel models (Fire Behavior or

NFDRS, others), photo series, or ocular estimates. There are numerous other methods of

measuring vegetation, but the most common are listed here.

See the list of publications in sections K.5.1. and K.5.2. that follow for further guidance in

determining fuel loading.

Appendix L-O, Page 5
K.1. Broadcast Burns

Procedures for use of the photo series to determine gross woody fuel (there are currently no

photo series specifically just for grass although they are being developed) loading are:

1. Observe each specific fuel size class of residue on the ground (for example, three to nine

inch diameter size class).

2. Select a photo or photos that nearly match or bracket the observed fuel class.

3. Obtain the quantitative value for the characteristic being estimated from the data sheet

accompanying the selected photo (or interpolate between photos).

4. These steps are repeated for each fuel size class or fuel characteristic as needed.

5. The total gross woody fuel loading can then be calculated by summing the estimates.

6. If the general area being inventoried has areas with obvious differences in residue loading,

the user should make separate determinations for each area and then weigh and cumulate

the loading for the whole area.

The procedures for inventorying downed woody material are provided in two U.S. Forest

Service technical reports published by the Inter- Mountain Forest Range and Experiment

Station in Ogden, UT. The "Handbook for Inventorying Downed Woody Material" by James

K. Brown (USDA General Technical Report INT-16, 1974) and the "Graphic Aids for Field

Calculation of

Dead, Downed Forest Fuels" by Hal E. Anderson (USDA General Technical Report INT-45,

August 1978) are the reference documents to be followed when doing a planar intersect

sample.

K.2. Grass/Non-Woody Fuels

Direct Measurement Method

1. Harvest or Clip-and-Weigh Methods:

a. Clipping vegetation to ground level and then weighing it is the most direct and

objective way to measure herbaceous biomass.

b. Clipping can be accomplished with grass shears, sheep shears, power grass

shears, sickles, and hand lawnmowers equipped with grass catchers.

c. Though "clip-and-weigh" methods are highly accurate, they are very time

consuming.

d. Before clipping some things to think about are:

i. Are you clipping plants rooted in the plot or those that occur within or above the

perimeter of the quadrat?

ii. Will species be clipped and weighed separately or will all plants be clipped and

weighed together?

iii. A general rule of thumb is one quadrat per 10 acres. (For the purposes of the NM

SMP)

iv. Quadrats (a 3ft x 3 ft square or 1 yard x 1 yard square) should be randomly

located.

v. Are the plants evenly distributed across the area or is there a lot of variability? The

more variability the more quadrats you may want.

vi. The NM NRCS recommends at least 800 Ibs.lacre for prescribed burning in grassy

fuels.

2. Weighing and Drying Harvested Material:

a. The weight of plant material includes inter- and intra cellular water and external

water such as dew and precipitation. Therefore the weight of freshly harv ested plant material

is highly variable and depends on recent weather, atmospheric conditions, and the water

status of the plant.

Appendix L-G, Page 6
b. Once a sample is dried the percent dry matter equals dry weight divided by fresh

weight, mUltiplied by 100. The dry weight is the weight of the sample after oven drying, and

the fresh weight is the weight of the sample after it was just clipped.

c. Recommended drying procedures:

i. Dry sample within 24 hours of clipping

ii. Place samples in paper bags (grocery bags, lunch bags). Know the weight of the

bag. One quadrat or species per bag.

iii. A forced air oven is best at 60-70° C. and will take 24-48 hours to dry.

iv. The samples can be checked every 4 -8 hours until there is no change in weight.

v. If an oven is not available the samples can be air dried and placed in a dry room

until the weight stabilizes. A drying room can be established by simply turning the heat up in

a room.

vi. Once you have the dry weight, subtract the weight of the bag.

vii. To estimate the pounds per acre use the following formula:

Dry Weight in pounds per square yard X 2.42 (conversion factor)

= tons per acre .

For example, a square yard of pasture was clipped, producing

two pounds per square yard of totally dry material. The following

calculation provides the tons per acre.

2 Ibs per square yard x 2.42 = 4.84 tons per acre

K.3. Pile Burns

To determine tonnage in units that will be (but have not yet been) piled, the transect method

or photo series method as described above can be used.

If units have already been piled, one of the two following methods can be used:

1. Visual estimates of piles.

2. Statistical sample of pile volume.

These methods are described in a publication form the Pacific Northwest Research Station,

Fire and Environmental Research Applications, "Guidelines for Estimating Volumes,

Biomass, and Smoke Production For Piled Slash," 1996, by Colin C. Hardy.

A simpler, but less accurate method in determining pile volume is length multiplied by weight

multiplied by height. This will provide the cubic feet of the pile. MUltiplying this by the number

of piles will give an estimate of the piled volume on the unit.

K.4. Definitions

Biomass - the amount of living matter (as in a unit area or volume of habitat).

Broadcast burning - intentional burning within well-defined boundaries for numerous

objectives.

Brush - a collective term that refers to stands of vegetation dominated by shrubby, woody

plants, or low growing trees.

Dead fuels - fuels with no living tissue in which moisture content is governed almost entirely

by absorption or evaporation of atmospheric moisture (relative humidity and precipitation).

Forest residue - accumulation in the forest of living or dead (mostly woody) material that is

added to and rearranged by human activities such as harvest, cultural operations, and land

clearing.

Fuel- combustible material.

Fuel Loading - the amount of fuel present expressed quantitatively in terms of weight of fuel

per unit area usually tons per acre.

Fuel Model - information describing a particular combination of vegetation, represented in

numerical terms, that is used to simulate fire activity in that vegetation type.

Appendix L-O, Page 7
Fuel Size Class - a category used to describe the diameter of down dead woody fuels. Fuels

within the same size class are assumed to have similar welting and drying properties, and to

preheat and ignite at similar rates during the combustion process.

Herbaceous - having little or no woody tissue and persisting usually for a single growing

season.

Photo Series - a collection of photos that provides a basis for quantifying and describing

existing fuel loads based on vegetation type and fuel size class.

Pile - materials that have been relocated either by hand or machinery and heaped together.

Planar Intersect - involves counting intersections of woody pieces with vertical sampling

planes that resemble guillotines dropped through the downed material.

Quadrat - a two-dimensional sample unit of any size or shape.

Slash - debris resulting from such natural events as wind, fire, or snow breakage; or human

activities as road construction, logging, pruning, thinning, or brush cutting. It includes logs,

chunks, bark, branches, stumps, and broken understory trees or brush.

Transect - a specific area of predetermined size used for sampling, for example, a narrow

strip (measuring tape) used for point-intercept sampling (i.e., sampling points along a line).

k.l;i. References

This list is not complete and new photo series are being developed at this time.

K.5.1 Photo Series

Blonski, Kenneth S. and Schramel, John L. 1981. Photo series for quantifying natural forest

residues: Southern Cascades, Northern Sierra Nevada. USDA Forest Service general

Technical Report PSW-56. Pacific Southwest Forest and Range Experiment Station,

Berkeley California. 145 pages. (Ponderosa Pine, mixed conifer, lodgepole, white fir, red fir,

mountain hemlock)

Fischer, William C. 1981. Photo guide for appraising downed woody fuels in Montana forests:

grand fir - larch - Douglas fir, western hemlock, western hemlock - western redcedar, and

western redcedar cover types. USDA Forest Service General Technical Report INT -96.

Intermountain Forest and Range Experiment Station, Ogden, Utah. 53 pages.

Fischer, William C. 1981. Photo guide for appraising downed woody fuels in Montana forests:

interior ponderosa pine, ponderosa pine-Iarch- Douglas fir, larch-Douglas fir, and interior

Douglas fir cover types. USDA Forest Service General Technical Report INT-97.

Intermountain Forest and Range Experiment Station, Ogden, Utah.133 pages.

Koski, Wayne H. and Fischer, William C. 1979. Photo series for appraising thinning slash in

north Idaho: western hemlock, grand fir, and westem redcedar timber types. USDA Forest

Service General Technical Report INT-46. Intermountain Forest and Range Experiment

Station, Ogden, Utah. 49 pages.

Maxwell, Wayne G. and Ward, Franklin R. 1976. Photo series for quantifying forest residues

in the ponderosa pine type, ponderosa pine and associated species type, lodgepole pine

type. USDA Forest Service General Technical Report PNW-52. Pacific Northwest Forest and

Range Experiment Station, Portland, Oregon. 73 pages.

Maxwell, Wayne G. and Ward, Franklin R. 1976. Photo series for quantifying forest residues

in the coastal Douglas fir-hemlock type, coastal Douglas fir-hardwood type. USDA Forest

Service General Technical Report PNW-51. Pacific Northwest Forest and Range Experiment

Station, Portland, Oregon. 103 pages.

Maxwell, Wayne G. and Ward, Franklin R. 1979. Photo series for quantifying forest residues

in the Sierra mixed conifer type, Sierra true fir type. USDA Forest Service General Technical

Report PNW-95. Pacific Northwest Forest and Range Experiment Station, Portland, Oregon.

79 pages.

Maxwell, Wayne G. and Ward, Franklin R. 1980. Photo series for quantifying natural residues

in common vegetation types of the Pacific Northwest. USDA Forest Service General

AppendiX L-O, Page 8
Technical Report PNW-105. Pacific Northwest Forest and Range Experiment Station,

Portland, Oregon. 230 pages. (Douglas -fir hardwood, hardwoods, Douglas -fir hemlock,

sub alpine fir, mixed conifer, lodgepole pine, ponderosa pine and associated species,

ponderosa pine, brush, juniper, grass)

National Wildfire Coordinating Group. 1997. Photo series for quantifying forest residues in

the southwestern Region: Data compiled from Black Hills ponderosa pine and spruce type

1990; GTR-PNW-105; GTR_PNW-52, 1976; GTR-PSW-56, 1981. PMS 822. Boise, 10:

National Wildfire Coordinating Group, National Interagency Fire Center.227 pages.

(ponderosa pine pre-commercial thinning, partial cut, natural, white fir, juniper, mixed conifer)

Oltmar, Rodger D. and Hardy, Colin C. 1989 Stereo photos series for quantifying forest

residues in coastal Oregon forests: second growth Douglas fir -western hemlock type,

western hemlock-Sitka spruce type, and red alder type. USDA Forest Service General

Technical Report PNW-231. Pacific Northwest Research station, Portland, Oregon. 67

pages.

Oltmar, Rodger D., Hardy, Colin C., and Vihnanek, Robert E. 1990 Stereo photo series for

quantifying forest residues in the Douglas fir -hemlock type of the Wilanielte National Forest.

USDA Forest Service General Technical Report PNW-258. Pacific Northwest Research

Station. Portland, Oregon. 63 pages.

Oltmar Rodger D., Vihnanek, Robert E., and Wright, Clinton S. 1998. Stereo photo series for

quantifying natural fuels. Volume 1: mixed conifer with mortality, western juniper, sagebrush,

and grassland types in the interior Pacific Northwest. PMS 830. Boise, 10: National Wildfire

Coordinating Group, National Interagency Fire Center. 73 pages.

Oltmar, Rodger D. and Vihnanek, Robert E. 1999. Stereo photo series for quantifying natural

fuels. Volume V: Midwest red and white pine, northern tallgrass prairie, and mixed oak types

in the Central and Lake States. PMS 834. Boise, 10: National Wildfire Coordinating Group,

National Interagency Fire Center.99p.

Oltmar Rodger D.; Vihnanek, Robert E. 2000. Stereo photo series for quantifying natural

fuels. Volume III: Lodgepole pine, quaking aspen, and gambel oak types in the Rocky

Mountains. PMS 832. Boise, 10: National Wildfire Coordinating Group, National Interagency

Fire Center. 85 p.

Ottmar Rodger D., Vihnanek, Robert E., and Wright, Clinton S. 2000, Stereo photos series

for quantifying natural fuels. Volume IV: Pinyon-juniper, chaparral, and sagebrush types in

the Southwestern Unites States. PMS 833. Boise, 10: National Wildfire Coordinating Group,

National Interagency Fire Center. 97 p.

Reeves, Hershel C. 1988. Photo guide for appraising surface fuels in east Texas: grass,

clearcut, seed tree, loblolly pine, shortleaf pine, loblolly/shortleaf pine, slash pine, longleaf

pine, and hardwood cover types. Center for Applied Studies, School of Forestry, Stephen F.

Austin State University, Nacogdoches, Texas. 89 pages.

USDA Forest Service. 1990. Photo series for quantifying forest residues in the Black Hills

ponderosa pine type, spruce type. USDA Forest Service publication A-89-1-90. Rocky

Mountain Region. 80 pages.

K.5.2. Fuel Models

Anderson, Hal E. 1982. Aids to Determining Fuel Models for Estimating Fire Behavior. USDA

Forest Service, Intermountain Forest and range Experiment Station General Technical

Report INT-122 Boise, 10.22 pages.

Burgan, R. E.; 1988. 1988 Revisions to the 1978 National Fire-Danger System. USDA Forest

Service, Southeastern Forest Experiment Station, Research paper SE -273, Asheville, North

Carolina, 39p.

Deeming, J. E., R. E. Burgan, and J.D. Cohen, 1977: The National Fire Danger-Rating

System-1978. USDA Forest Service, Intermountain Forest and Range Experiment Station,

General Technical Report INT-39, Ogden, Utah, 63p.

AppendiX L-O, Page 9
K,§.3. General References

Bonham, C.D. 1989 Measurements for terrestrial vegetation. John Wiley & Son, New York,

NY.

D<;lubenmire, R. 1959. A canopy coverage method of vegetational analysis. Northwest

Science 33:43-66.

Pieper, R.D. 1978. Measurement techniques for herbaceous and shrubby vegetation. New

Mexico State University.

Risser, P.G. 1984. Methods for inventory and monitoring of vegetation, litter, and soil surface

condition. IN: Developing strategies for rangeland management. Westview Press, Boulder,

Colorado.

K.5.4. Web References

Regional Haze Rule

Published in the Federal Register on JUly 1,1999,64 FR 35714.

http://www.epa.gov/ttn/oarpg/tllfr_notices/rhfedreg.pdf 20 21 2223

WRAP Policy on Enhanced Smoke Management Programs for Visibility

Approved by the Westem Regional Air Partnership, November 12, 2002.

http://www.wrapair.org/forums/fejf/documents/esmpttipolicy/O30115 ESMP Policy.pdf 24 25

26

Appendix L-O, Page 10
Western Regional Air Partnership Policy

on

Enhanced Smoke Management Programs

for Visibility

Approved by the Western Regional Air Partnership

November 12, 2002

Prepared by:

the Enhanced Smoke Management Program Task Team

of the Fire Emissions Joint Forum
WRAP Policy on

Enhanced Smoke Management Programs

for Visibility

Executive Summary

The Western Regional Air Partnership (WRAP) is charged with developing technical and

policy tools to assist states (or the delegated regulatory authority) and tribes with

implementing the Regional Haze Rule (Rule).

The WRAP Policy on Enhanced Smoke Management Programs for Visibility (WRAP

ESMP Policy) has been developed over an eleven-month period through a stakeholderbased consensus process to assist the WRAP region states and tribes in addressing

emissions from fire sources. In this Policy, the WRAP seeks to provide a consistent

framework that states and tribes can use to efficiently develop their individual

implementation plans. The WRAP recognizes states' and tribes' authority and

responsibility to develop, adopt and implement their regional haze implementation plans,

and recognizes the Rule as the principal document on which statcs and tribes should rely.

The Rule requires states to develop implementation plans

(SIPs) for addressing regional haze in the Nation's 156

mandatory Class I areas. I Additionally, the Rule requires effective

managemcnt of fire sources. The Rule provides two pathways for western states to follow

as they implement the requircments of the Rule: I) develop their regional haze

implementation plans per the nationally applicable provisions of Section 308, or 2)

Transport Region states may choose to incorporate the Grand Canyon Visibility

Transport Commission (GCVTC) recommendations into their regional haze

implementation plans under Section 309 of the Rule.

Enhanced smoke management programs are specifically required in Scction 309 of the

Rule. However, if a state, under Section 308, has determined that fire emissions are

contributing to visibility impairment and that smoke needs to be addressed in its SIP, then

an enhanced smoke management program is a viable tool to accomplish this goal.

Therefore, the WRAP is advancing the WRAP ESMP Policy for states under both

Section 308 and 309 to meet the requirements of the Rule.

Tribes are not subject to the samc requirements of the Rule as states, but tribes wishing to

assume the regional haze requirements outlined in the Rule may, according to the CAA,

seek approval to be treated in the same manner as states, under the Tribal Authority Rule

(TAR), 40 CFR 49. The intent of this Policy is to assist both states and tribes with the

I The Rule is only applicable to mandatory Class I areas (see Appendix A & Appendix B for additional

information on mandaLory Class Iareas). Slates/tribes in the WRAP region may utilize the WRAP ESMP

Policy to protect visibility in non-mandatory Class I areas.
development of their regional haze implementation plans (SIPs/TIPs), and therefore,

tribes are included in all references to states, except where specific requirements and/or

deadlines ofthe Rule are cited.

The WRAP ESMP Policy defines the enhanced smoke management program as smoke

management efforts that specifically address visibility. It is the position of the WRAP

ESMP Policy that there are nine elements of an enhanced smoke management program

that are necessary to meet the requirements of the Rule. According to the Rule, enhanced

smoke management programs are to be included in implementation plans based on the

criteria of efficiency, economics, law, emissions reduction opportunities, land

management objectives, and reduction of visibility impacts.

Smoke management efforts/programs currently in place (sometimes referred to as "basic

smoke management programs") may not specifically address visibility effects in

mandatory Class I areas. The WRAP ESMP Policy explicitly addresses visibility effects

from fire that contribute to visibility impairment in mandatory Class I areas. Fortunately,

smoke management efforts/programs, regardless of the purpose (e.g., visibility

protection, avoidance of National Ambient Air Quality Standards [NAAQSJ violations,

or prevention of nuisance smoke impacts), have many common elements. It is anticipated

that the enhanced smoke management program elements outlined here will integrate well

with current and future smoke management efforts/programs.

The WRAP ESMP Policy document is comprised of four major sections. Section I is the

eight WRAP ESMP Policy statements. Section 2 provides overall background for the

WRAP ESMP Policy, including a discussion of the regulatory environment, the current

context of smoke management in the WRAP region, and details of the Rule that are

germane to the WRAP ESMP Policy. Section 3 is an annotation of each of the eight

policy statements, further explaining and defining them, and including a description of

the nine enhanced smoke management program elements. Finally, Section 4, the

Appendices, include (A) a glossary of tenns, (B) a related documents listing, and (C)

specific examples for states/tribes on the implementation of the nine enhanced smoke

management program elements.

Ii
WRAP Policy

Enhanced Smoke Management Programs

for Visibility

TABLE OF CONTENTS

Executive Summary

l.

2.

The WRAP Policy on Enhanced Smoke Management Programs

for Visibility: Policy Statements

Background

I

2

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission 2

2.2 Western Regional Air Partnership 3

2.3 Regional Haze Rule 3

2.4 Existing Guidanceon Smoke Management 4

3. Annotated Policy 5

3.1 Introduction 5

3.2 Visibility Effects 6

3.3 All Fire Sources 7

3.4 Section 309 7

3.5 Section 308 8

3.6 Elements of an Enhanced Smoke Management Program 9

3.6.1 Element I Actions to Minimize Emissions from Fire 10

3.6.2 Element 2 Evaluation of Smoke Dispersion 10

3.6.3 Element 3 Alternatives to Fire 10

3.6.4 Element 4 Public Notification of Burning 11

3.6.5 Element 5 Air Quality Monitoring II

3.6.6 Element 6 Surveillance and Enforcement II

3.6.7 Element 7 Program Evaluation II

3.6.8 Element 8 Bum Authorization II

3.6.9 Element 9 Regional Coordination II

3.7 Criteria 12

3.8 Application 13

3.8.1 Source Sector Option 13

3.8.2 Situational Option 14

3.8.3 Impact Based Option 15

3.9 Collaborative Development 15

111
4. Appendices

TABLE OF CONTENTS

17

Appendix A. Glossary 18

Appendix B. Related Documents Listing 25

Appendix C. Enhanced Smoke Management Program:

Implementation Guidance 26

C.l Regional Haze Rule Implementation Plan Process 26

C.2 Elements of an Enhanced Smoke Management Program 27

C.2.1 Element \. Actions to Minimize Emissions from Fire 27

C.2.].1 Emissions Reductions Techniques 27

C.2.1.2 Bum Manager Qualification 28

C.2.1.3 Incentives 29

C.2.\.4 Emissions Goal/Target 30

C.2.2 Element 2. Evaluation of Smoke Dispersion 30

C.2.3 Element 3. Alternatives to Fire 31

C.2A Element 4. Public Notification of Burning 32

C.2.5 Element 5. Air Quality Monitoring 33

C.2.6 Element 6. Surveillance and Enforcement 33

C.2.7 Element 7. Program Evaluation 35

C.2.8 Element 8. Burn Authorization 36

C.2.8.1 Pennit by Rule 36

C.2.8.2 Bum Pennitting System 37

C.2.8.3 Centralized Bum Authority 37

C.2.8A Regional Bum Authority 37

C.2.9 Element 9. Regional Coordination 37

C.2.9.1 Source Sector Authority Coordination 38

C.2.9.2 Centralized Authority Coordination 38

C.2.9.3 Regional (Multi-State/Tribe) Coordination 39

C.3 Responsibilities Under an Enhanced Smoke Management Program 39

CA Funding Mechanisms for Enhanced Smoke Management Programs40

IV
1. The WRAP Policy on Enhanced Smoke Management

Programs for Visibility: Policy Statements

Policy Statement A. Enhanced smoke management programs under this Policy are

defined as those smoke management efforts that specifically address visibility effects,

and therefore, may need to be augmented to address public health and welfare issues.

Policy Statement B. Enhanced smoke management programs apply to all fire sources.

Policy Statement C. Enhanced smoke management programs are required for states under

Section 309 ofthe Regional Haze Rule. 2

Policy Statement D. Enhanced smoke management programs are a viable tool for all

other states and tribes in the WRAP region to use in the development of their

implementation plans.

Policy Statement E. Enhanced smoke management programs include nine elements that

are necessary to meet the requirements ofthe Regional Haze Rule, as follow:

Element I. Actions to Minimize Emissions from Fire

Any burning techniques that reduce the actual amount of emissions produced.

Element 2. Evaluation of Smoke Dispersion

Using meteorological conditions to assess the ability to minimize smoke impacts.

Element 3. Alternatives to Fire

Any method ofremoving or reducing fuels by mechanical, biological or chemical

treatments.

Element 4. Public Notification of Burning

Any method that communicates burn information to the burn community, to air

regulators and to the general public. Also includes public education and media

relations.

Element 5. Air Quality Monitoring

Observations and/or equipment that enable an assessment of air quality impacts of

smoke from fires.

Element 6. Surveillance and Enforcement

An oversight mechanism that assures adherence to smoke management efforts as

defined by the regional haze implementation plan.

, Published in the Federal Register on July I. 1999,64 FR 35714.
Element 7. Program Evaluation

A mechanism to assess the adequacy of the enhanced smoke management program in

meeting the requirements ofthe Rule.

Element 8. Bum Authorization

The management approach used to facilitate bum decision-making.

Element 9. Regional Coordination

Communication and infonnation sharing across state/tribe jurisdictional lines.

Policy Statement F. Enhanced smoke management programs will be based on the criteria

of efficiency, economics, law, emission reduction opportunities, land management

objectives, and reduction of visibility impact,) which will detennine the rigor applied to

the nine elements.

Policy Statement G. Enhanced smoke management programs may be applied unifonnly

to source sectors throughout a state's or tribe's jurisdiction or they may be tailored to

source sectors and/or geographic areas to address presumed or confinned visibility

impairment.

Policy Statement H. The development and application of enhanced smoke management

programs, including the consideration ofthe criteria (F), will be done collaboratively with

state, tribal, local and federal agencies, and private parties.

2. Background

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission

In 1990, Congress amended the Clean Air Act (CAA), and as part of these amendments

created the Grand Canyon Visibility Transport Commission (GCVTC)' The GCVTC

was charged with assessing the current scientific information on visibility impacts and

making recommendations for addressing regional haze in the western United States. The

GCVTC signed and submitted more than 70 recommendations to the Environmental

Protection Agency (EPA) in a report dated June 1996 that indicated that visibility

impairment was caused by a wide variety of sources and pollutants, and that a

comprehensive strategy was needed to remedy regional haze.

Fire sources were among those specifically acknowledged III the GCVTC Report as

contributors to visibility impainnent on an episodic basis:

) 64 FR 35771, ~51.309 (d)(6) (iv).

4 The Grand Canyon Visibility Transport Commission (GCVTC) was composed or the governors of eight

western states (AZ, CA, CO, NM, NY, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and

Navajo), four Federal land managemenl agencies (Bureau of Land Managemenl, U.S. Fish and Wildlife

Service, U.S. Forest Service, National Park Service), the Columbia River InLer-Tribal Fish Commission,

and the Environmental Protection Agency.

2
All types of fire (prescribed fire and agricultural burning) must be addressed

equitably as part of a visibility protection strategy. 5

The GCVTC Report acknowledged federal and state land managers' projection of

significant increases in prescribed fire in order to reduce the effects of wildfire resulting

from past decades of fire exclusion.· The GCVTC Report cited the need for minimizing

the increase in emissions from all fire programs to the maximum extent feasible 7 One of

the Report's recommendations called for:

... the development and implementation of criteria and requirements for the use of

enhanced smoke management programs (including alternative management

practices) and emission reduction strategies.s

2.2 Western Regional Air Partnership

The Western Regional Air Partnership (WRAP) was established in 1997 as the successor

organization to the GCVTC. The WRAP is a voluntary organization comprised of

western governors, tribal leaders and federal agencies,9 and is charged "to identify

regional or common air management issues, develop and implement strategies to address

these issues, and formulate and advance western regional policy positions on air

quality."'o These policies and technical tools are developed through inclusive,

stakeholder-based processes and approved by consensus of the WRAP.

WRAP participants include state air quality agencies, tribes, federal/state/private land

managers, the EPA, environmental groups, industry, academia and other interested

parties. There are over 400 tribes within the WRAP region. The large number of tribes

limits the participation of all of them in WRAP activities, and accordingly, in the

development of this Policy. Therefore, the tribal representatives involved in the

development of this Policy may not represent all tribal concerns.

2.3 Regional Haze Rule

Following the issuance of the GCVTC Report, the EPA issued the Regional Haze Rule

(Rule) in July 1999 to improve visibility in 156 national parks and wilderness areas

across the country. The Rule outlines the requirements for states and tribes to address

, GCVTC Report, p. 47.

'GCVTC Report, p. 23.

7 GCVTC Report, Recommendation 7, p. 50.

xGCVTC Report, Recommendation 4, p. 49.

'J The WRAP members include the governors of thirteen western states (AK, AZ, CA, CO, ID, MT, NO,

NM, OR, SO, UT, WA, and WY). Tribal nations selected as WRAP members include Pueblo or Acoma,

Campo Band or Kumcyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation or the Grand

Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of

San Felipe, and Shoshone-Bannock Tribes or Fort Hall. Fedeml WRAP members are the Department or the

Interior, the Department of Agriculture, and the Environmental Protection Ageney.

10 WRA.P Charter, Purpose, p. I.

3
regional haze in these mandatory Class I areas. EPA incorporated all of the GCVTC

recommendations into Section 309 of the Rule, which may be used by some of the

WRAP states/tribes. The remaining WRAP states must, and tribes may, utilize the

nationally applicable Section 308 provisions ofthe Rule.

Tribes are not subject to the same requirements ofthe Rule as states, but tribes wishing to

assume the regional haze requirements outlined in the Rule may, according to the CAA,

seek approval to be treated in the same manner as states, under the Tribal Authority Rule

(TAR), 40 CFR 49. In these cases, EPA still recognizes that "unlike States, tribes are not

required by the TAR to adopt and implement CAA plans or programs, thus tribes are not

subject to mandatory deadlines for submittal of implementation plans."" Although

provision for flexibility in the submission of programs and implementation plans for

tribes is made under TAR, EPA does "encourage tribes choosing to develop

implementation plans. to make every effort to submit by the deadlines to ensure that the

plans [TIPs] are integrated with and coordinated with regional planning efforts.,,12

EPA recognizes the WRAP as the Regional Planning Organization that is developing the

necessary policy and technical tools to implement the Rule in the WRAP region. A

WRAP policy, Once approved, represents the WRAP's consensus position on the

best means for states and tribes to implement the portion ofthe Rule at issue. The WRAP

recognizes states' and tribes' authority and responsibility to develop, adopt and

implement their regional haze state and tribal implementation plans, and the seminal

guidance to do this is the Rule.')

2.4 Existing Guidance on Smoke Management

The elements of an enhanced smoke management program as outlined in this Policy are

based upon careful review and consideration of the Rule and the existing guidance on

smoke management: the EPA's Interim Air Quality Policy on Wildland and Prescribed

Fires (EPA Interim Policy)14 and the Agricultural Air Quality Task Force's (AAQTF)

Recommendation on Air Quality Policy on Agricultural Burning (AAQTF

Recommendation on Air Quality Policy).'5 However, these documents do not specifically

provide guidance for smoke management programs that address visibility effects. The

WRAP ESMP Policy goes beyond the EPA Interim Policy and the AAQTF

Recommendation on Air Quality Policy to address visibility effects and regional haze, as

required by the Rule.

" 64 FR 35758.

12 64 FR 35759.

13 WRAP Chaner, p.l.

14 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and

Prescribed Fires, April 23, 1998 (hereafter referred to as "EPA Interim Policy").

15 Agricultural Air Quality Task Foree, Air Quality Policy on Agricultural Burning, Recommendation to the

U.s. Department of Agriculture, November 10, 1999 (hereafter referred to as "AAQTF Recommendation

on Air Quality Policy").

4
3. Annotated Policy

3.1 Introduction

The WRAP ESMP Policy is the result of the WRAP region-wide multi-state/tribe

stakeholder planning and coordination effort focused on addressing the development of

enhanced smoke management programs that address visibility effects. The intent of the

WRAP ESMP Policy is to assist states (or the delegated authority) and tribes to address

visibility effects associated with fire in a way that is adequate for SIPITIP

implementation.

The WRAP ESMP Policy identifies for states/tribes in the WRAP region the elements of

an enhanced smoke management program to address visibility effects from all types of

fire that contribute to visibility impainnent in mandatory Class I areas. Although the Rule

is only applicable to mandatory Class I areas, state/tribes in the WRAP region may utilize

the WRAP ESMP Policy to protect visibility in non-mandatory Class I areas. '6

Most states/tribes in the WRAP region address fire source sectors differently, as does

EPA in its guidance documents. Consequently, fire sources in the WRAP region are

cUITently regulated at various and inconsistent levels, from rigorous regulation to

regulation with exemption applied, to no regulation. This variability emphasizes the need

for the development and application of an enhanced smoke management program

framework that is predictable and flexible while meeting the requirements of the Rule.

The WRAP ESMP Policy has been developed to embody appropriate regulatory and

policy requirements and to provide a predictable framework for enhanced smoke

management programs that can be rcasonably implemented by states and tribes. The

WRAP believes that states, tribes, or EPA on behalf of the tribes maintain the ultimate

responsibility for the implementation of the enhanced smoke management program.

Thc WRAP recognizes states/tribes authority and responsibility to develop, adopt and

implement their regional haze state and tribal implementation plans. The WRAP further

recognizes that the implementation plans will be revisited and revised, per the schedule

specificd in the Rule, giving opportunities to reline individual enhanced smoke

management programs to reflect technical advances and policy updates.

3.2 Visibility Effects

Policy Statement A. Enhanced smoke management progroms under this Policy

are defined as those smoke management ~fforts that specifically address visibility

effects, and therefore, may need to be augmented to address public health and

welfare issues.

Most current smoke management efforts and programs to date in the WRAP region have

been developed to address public health and/or nuisance concerns, and do not have

16 See Appendix B for the reference to a map ofClass I areas.

5
procedures to address visibility effects that contribute to regional haze. The enhanced

smoke management program adds visibility impairment/regional haze considerations to

existing smoke management efforts.

States/tribes are currently addressing NAAQS and/or nuisance to the extent they deem

appropriate through existing smoke management efforts. Some states/tribes have certified

their smoke management programs under EPA's Interim Policy, both inside and outside

the SIP/TIP process.'7 The EPA certified programs include those mandated by rule, state

statute, and programs based on voluntary measures.'s However, few, if any, states/tribes

have smoke management programs that address all fire sources, (e.g., prescribed fire on

wildlands, wildland fire use, wildfire and agricultural buming), in one unified program.

The WRAP ESMP Policy assumes that states/tribes will mainlain their current smoke

management efforts and/or smoke management programs for NAAQS and/or nuisance.

The WRAP ESMP Policy can be used to establish new programs to address visibility

concems even if there are no other smoke management efforts currently in place. While

the WRAP ESMP Policy provides a framework for visibility/regional haze, states/tribes

may choose to do more in their smoke management programs to protect NAAQS, prevent

nuisance and/or address visibility.

The WRAP ESMP Policy facilitates the integration of visibility protection with NAAQS

and nuisance protection, in accordance with the Rule:

The regional haze program is being promulgated in a manner that facilitates

inlegralion of emission management strategies for regional haze with the

implementation of programs for new NAAQS for Ozone and PM.'9

The elements included in the enhanced sllloke management program as outlined by this

Policy have been selected in an attempt to address direct visibility effects and regional

haze in mandatory Class I areas. It is possible that states/tribes may encounter conflicts

between managing smoke for visibility considerations and smoke management efforts for

NAAQS and/or nuisance. It is therefore recommended that states/tribes coordinate their

efforts to protect visibility with existing or future efforts to address NAAQS and/or

nuisance smoke.

3.3 All Fire Sources

Policy Sialemeni B: Enhanced smoke managemenl programs will apply 10 allfire

sources.

The WRAP ESMP Policy applies to all fire, and maintains the previously established

definitions:

17 A state/lribe certifies "LO EPA that they have adopted and are implementing a smoke management

program that includes the basic components identified in this policy." EPA Interim Policy, p. 7.

HI WRAP states implementing smoke management programs using voluntary measures include NM and ID.

" 64 FR 35719, emphasis added.

6
This Policy applies to both wildland and agricultural lands regardless of

ownership (i.e., Federal, state, tribal, public, private), cause of ignition (e.g.,

lightning, arson, accidental human, land management practices) or purpose of the

fire (e.g., vegetative residue disposal, hazard reduction, maintain ecosystem

health). It is the intent that this Policy be applied equitably across all land types

and sources. 20

All fire source sectors are included in the WRAP ESMP Policy because it is recognized

by EPA that "fire of all kinds (wildfire, prescribed fire, etc.) contributes to regional

haze.,,21 This Policy needs to be applied to all sources addressed by the WRAP Fire

Categorization Policy. In accordance with Section 118(a) of the CAA requires that all

entities, federal and non-federal, be subject to the same requirements, authorities and

processes," the WRAP ESMP Policy will be applied equitably to all fire sources.

The WRAP ESMP Policy specifically does not apply to Native American cultural nonvegetative burning for traditional, religious, or ceremonial purposes (e.g., cremation,

sweat lodge fires)." Nor does it apply to open burning activities on residential,

commercial, or industrial property (e.g., backyard burning, garbage incineration,

residential wood combustion, construction debris)." However, states/tribes may choose

to consider the impacts of these fire sources when developing their regional haze

implementation plans.

The WRAP ESMP Policy applies to smoke impacts in mandatory Class I areas from fire

anywhere in the WRAP region. Each state has an obligation to account for those

emissions it produces that have impacts in its own mandatory Class I areas.

Accountability also extends to states and tribes that have smoke impacts outside their

jurisdictions.

3.4 Section 309

Policy Statement C: Enhanced smoke management programs are required for

states under Section 309 ofthe Regional Haze Rule.

The EPA incorporated all of the GCYTC recommendations into Section 309 of the Rule,

which specifically calls for "[e]nhanced smoke management programs for fire that

consider visibility effects, not only health [NAAQS] and nuisance objectives...."25 Under

Section 309, states must incorporate an enhanced smoke management program into their

SIPs, which will give them the demonstration of reasonable further progress through

2018.'6 The ability of a state/tribe to implement the enhanced smoke management

20 WRAP Policy for Categorizing Fire Emissions, November 15,2001 (hereafter referred to as "WRAP

Fire Categorization Policy"), p 7.

11 64 FR 35735.

n Clean Air Act 118(a).

JJ WRAP Fire Categorization Policy, p. 24.

24 Ibid, however "industrial property" would not include land such as industrial forestland.

"64 FR 35771, ~51.309 (d) (6) (iv).

"64 FR 35769, ~51.309 (a).

7
program may require legislative changes to existing rules or removal of exemptions from

regulation for specific fire sources.

The tracking of emissions from all fire (i.e., wildland and agricultural land) is a

requirement of the Rule for states under Section 309, including the development of an

emissions inventory for YOCs, NOx, elemental and organic carbon, and fine particulate

matter. 27 States/tribes under Section 309 will need to address projected fire emissions in

order to facilitate regional haze planning and operational smoke management.'8 The

tracking of emissions could allow for these projections to be developed. Emissions

tracking will also provide infonmation critical to implementing several of the necessary

elements of an enhanced smoke management program. The Rule under Section 309

further calls for the establishment of annual emission goals for fire that will minimize

emissions increases from fire to the maximum extent feasible.'9 The WRAP is currently

developing policy on both emissions tracking and on the establishment of annual

emissions goals that will work in concert with the WRAP ESMP Policy.

3.5 Section 308

Policy Statement D. Enhanced smoke management programs are a viable tool for

all other states and tribes in the WRAP region to use in the development a/their

implementation plans.

The Rule requires states/tribes to address visibility impainnent in mandatory Class I areas

due to emissions from all sources including fire activities. The Preamble 10 the Rule

emphasizes smoke management programs as effective tools to accomplish this:

Where smoke impacts from fire are identified as an important contributor to

regional haze, smoke managelllent programs should be a key component of

regional and State regional haze planning efforts and long-term strategies.]D

Under Section 308, a state must consider smoke management techniques for agricultural

and forestry lands in its long-term strategy for regional haze. Section 308 of the Rule

states:

The State must identify all anthropogenic sources of visibility impairment

considered by the State in developing its long-term strategy [for regional haze].

The State should consider major and minor stationary sources, mobile sources,

and area sources31

and:

(v) The State must consider, at a minimum, the following factors in developing its

long-term strategy [for regional haze]:

27 64 FR 35771. ~51.309 (d) (6) (ii)

"64 FR 35771, ~51.309 (d) (6) (i).

" 64 FR 35771, ~51.309 (d) (6) (v).

'" 64 FR 35736.

1I 64 FR 35767, ~51.308 (d) (3) (iv).

8
(E) Smoke management techniques for agricu ltural and forestry management

purposes including plans as currently exist within the States for these purposes32

If a state's visibility impairment analysis" shows that fire sources contribute to visibility

impairment in a mandatory Class I area and the state detenllines that fire sources need to

be addressed in its SIP, then the enhanced smoke management program will be a viable

tool to do so. A statewide inventory of emissions of pollutants that contribute to visibility

impairment in mandatory Class I areas is a requirement of the Rule for states choosing to

implement the Rule under Section 308. Further, these states will also be required to

account for future projected emissions.14

3.6 Elements of an Enhanced Smoke Management Program

Policy Statement E: Enhanced smoke management programs include nine

elements that are necessary to meet the requirements ofthe Regional Haze Rule.

The elements included in the enhanced smoke management program as outlined by this

Policy have been selected in an attempt to address direct visibility effects and regional

haze in mandatory Class I areas to improve visibility on the worst days and maintain

visibility on best days.15 The first seven enhanced smoke management program elements

come directly from Section 309 of the Rule that states that SIPs "must include smoke

management programs that include all necessary components including, but not limited

to, actions to minimize emissions, evaluation of smoke dispersion, alternatives to fire,

public notification, air quality monitoring, surveillance and enforcement, and program

evaluation."l" These same smoke management components are also found in the EPA

Interim Policy and the AAQTF Recommendation on Air Quality Policy. 17

The EPA Interim Policy and the AAQTF Recommendation on Air Quality Policy also

advocate a burn authorization component (i.e., Element #8)3H Without a central burn

authority considering the cumulative smoke impacts, it will be difficult on a daily basis

for individual land managers/owners to assess their relative contribution to regional haze.

Regional coordination (i.e., Element #9) is central to burn authorization, and will

facilitate coordinated decision-making. It is a necessary mechanism to address transport

issues and cumulative effects, especially when considering impacts of a source that may

be large, or many sources that cumulatively are large, but a long distance from a Class I

J2 64 FR 35767, §51.308 (d) (3) (v) (E).

)3 As outlined in the Rule under Section 30S, this process includes calculating the baseline of all sources;

comparing the baseline visibility conditions with nalural conditions; assessing the contribution to this of the

different sources (of which smoke is one); then considering in the development of long lenn strategies:

smoke management techniques, including current smoke management programs that exist; and if not

adequate, considering enforceable emissions limitations and compliance schedules and other measures as

necessary. 64 FR 35765 §5IJ08.

J464 FR 35767, §51J08 (d) (4) (v) and 35769, §51.308 (g) (4).

35 64 FR 35764, §51.30 I.

J6 64 FR 35771 , §51.309 (d) (6) (i), emphasis added.

37 EPA Interim Policy, p. 17-23, and AAQTF Recolllmendation on Air Quality Policy, p. 2.

3!i EPA Interim Policy, p. 18, and AAQTF Recolllmendation on Air Quality Policy, p.1l.

9
area (i.e., greater than 100 km). Regional coordination is emphasized in the Rule as key

to reaching the national visibility goal. In the preamble, the Rule states:

Therefore, States will need to develop strategies in coordination with one another,

taking into account the effect of emissions from one jurisdiction to air quality in

another39

And in the preamble to Section 308, the Rule states:

In developing each reasonable progress goal, the State must consult with those

States which may reasonably be anticipated to cause or contribute to visibility

impainnent in the mandatory Class I Federal area.40

The WRAP ESMP Policy elements include measures to control and/or reduce emissions

from fire (Elements I, 3, and 8); tools to assess and manage the potential impacts from

fire (Elements 2 and 5); and operational components of a successful smoke management

program (Elements 4, 6, 7, and 9). In addition to the elements descriptions that follow,

suggestions for implementation of the nine enhanced smoke management program

elements are included in Appendix C of this document.

3.6.1. Element I. Actions to Minimize Emissions from Fire

A wide range of opportunities to minimize emissions exists depending upon the fire

source and management objectives. Four potential actions that may be used are: emission

reduction techniques, establishing bum manager qualification programs,4 [ developing

incentive programs, and establishing emissions goals.

3.6.2. Element 2. Evaluation of Smoke Dispersion

A variety of tools and methods exist by which a land manager/owner could reduce smoke

impacts over periods ranging from several hours to several days. States/tribes may focus

on the use of specific weather infonnation, fuels information, modeling or a burner

qualification and certification program to assist in the evaluation of dispersion conditions.

3.6.3. Element 3. Alternatives to Fire

Alternatives to fire (as distinguished from alternative methods of burning) include any

method of removing or reducing fuels by mechanical, biological or chemical treatments.

States/tribes may assist land managers/owners to develop and implement alternatives to

fire. Land managers/owners may be required to assess the feasibility of using alternatives

to fire where there are many competing sources or large amounts of burning occurring

that could lead to visibility impairment in mandatory Class I areas. Regulatory authorities

may want to consider incentives to encourage the use of alternatives to burning where

appropriate. The WRAP through its FEJF has commissioned two reports on alternatives

to burning that will aid states and tribes in addressing this element of the ESMP.

)9 64 FR 35728.

4lJ 64 FR 35766, ~51.308 (d) (I) (8) (iv).

41 Slalesilribes could consider adopting existing burn qualification programs sanclioned by land

managemenl agencies.

10
1.6.4. Element 4. Public Notification of Burning

Public notification is a significant part of the CAA, and is inherent in the Rule. Public

notification under an enhanced smoke management program should be at least what is

required by EPA for a celiifiable smoke management program," and may include extra

activities, depending on location. Generally, regardless of what kind of smoke

management program is in place, significant effort should be made to educate and notify

the public about burning, its impacts, as well as its benefits.

3.6.5. Element 5. Air Quality Monitoring

Monitoring of smoke impacts may be a very sophisticated effort using EPA reference

method sampling equipment or it may be as simple as creating a hand-written log of

smoke behavior as assessed visually. Minimal procedures would be most likely in areas

of little bum activity or when farther away from Class I areas.

3.6.6. Element 6. Surveillance and Enforcement

Good communication between regulators and land managers/owners can significantly

reduce the need for surveillance and enforcement. An atmosphere of trust and

cooperation between regulators and land managers/owners can help facilitate emissions

reductions and compliance with air quality regulations. Performance and compliance

standards may be established under various methods of operations.

3.6.7. Element 7. Program Evaluation

Enhanced smoke management programs need to be reviewed on a periodic basis for their

effectiveness by the regulatory authority and affected stakeholders. Fonnal periodic

progress reports could coincide with time intervals used to evaluate reasonable progress.

The Rule requires progress reports every five years. 43 However, shorter review and

evaluation time periods would better determine if enhanced smoke management

programs are effective.

3.6.8. Element 8. Bum Authorization

Bum authorization requirements are expected to vary depending upon the amount of

burning that is occurring, the fire source types that are conducting the burning, and the

degree of impainnent that exists or may be expected to occur as a result of the burning.

The proximity ofmandatory Class I and non-attainment areas may also have a bearing on

the complexity of the bum authorization procedure that should be implemented.

3.6.9. Element 9. Regional Coordination

Coordination of burning activity is critical to avoiding cumulative smoke impacts within

and across source types in mandatory Class I areas. Coordination may range from a

passive mode of information sharing between land managers/owners and/or the public to

a more complex, active coordination in which bum decisions are altered based on

jurisdictional authority and other activities that are occurring or have recently occurred.

Methods for this inter-jurisdictional and regional coordination will need to be developed.

42 EPA Interim Policy, p.17-23.

4J 64 FR 35768, 1.308 (g) and 35772, ~51.309 (d) (10).

II
The development process should be a collaborative one involving state, tribal, local and

federal agencies, and private parties.

3.7 Criteria

Policy Statement F: Enhanced smoke management programs will be based on the

criteria of efficiency, economics, law, emission reduction opportunities, land

management objectives, and reduction of visibility impact!4 which will determine

the rigor applied to the nine elements.

According to the Rule, enhanced smoke management programs are to be included in

implementation plans based on the criteria of efficiency, economics, law, emissions

reduction opportunities, land management objectives, and reduction of visibility impacts.

These criteria will influence the extent to which individual elements of the enhanced

smoke management program are applied or the level of effort that is possible. For

example, legal barriers may need to be removed and/or infrastructure may need to be

developed to implement the enhanced smoke management program. The level of effort

each state/tribe will apply to the nine elements of the enhanced smoke management

program needs to be based on a pre-determined process or metric established by the

regulatory authority that considers the public as well as stakeholders.

Additional examples of how states/tribes might consider the enhanced smoke

management program criteria are listed below.

Efficiency: What are the resources, infrastructure, networking, workforce and

infonnation necessary to reduce visibility impairment in mandatory Class I areas~ Is it

feasible to share these items with another group in order to reduce redundancy or build on

existing expertise?

Economics: What are the costs and incentives of the items Iisted under Efficiency? Are

there ways to economically quantify improvements to regional haze in a local area? What

is the economic trade-off of moving fuels off-site to be converted to another use or

burned elsewhere? What are the economic costs to a landowner to look for emission

reduction alternatives? What are the economic gains from improved habitats, functioning

watersheds, species diversity and healthy ecosystems? What are the economic losses to a

community associated with impairment, (e.g., property values, tourism, etc.)"

Law: Are there federal, state, tribal ordinances, local rules or statutes that prohibit

mechanical treatments or prohibit the regulation of burning~ Are there cont1icts with

management or law pertaining to the Threatened and Endangered Species Act and/or the

Wilderness Act?

Emission Reduction ODDortunities: Where are the opportumtles to consider reducing

emissions through mechanical, biological, or chemical means? Where are the places

where reducing emissions will be best done through smoke management techniques

"64 FR35771, §51.309 (d) (6) (iv).

12
rather than moving fuels off-site or manipulating fuels through chemicals or biological

decomposition or a combination of mechanical treatments and maintenance burning')

Land Management Objectives: Are there places where manipulating fuels is not an option

because of land management objectives, e.g., tribal cultural values, wildlife habitat, crop

requirements, residue removal constraints, or inaccessible terrain? Are there places

where manipulating fuels is more conducive to the land management objective, e.g., areas

targeted for commodity production, watershed protections or tribal cultural activities

sites? Are there places that restoration of ecosystem function may have a high priority?

Reduction of Visibility Impacts: Using the current information and science available to a

state/tribe, how will an enhanced smoke management program decrease impacts to

visibility?

3.8 Application

Policy Statement G: Enhanced smoke management programs may be applied

uniformly to source sectors throughout a state's jurisdiction or they may be

tailored /0 source sec/Drs and/or geographic areas /0 address presumed or

confirmed visibility impairment.

Since emissions from fire sources contribute differently to visibility impairment in Class I

areas and/or may be from different geographical areas, tailoring of an enhanced smoke

management program to a fire source sector and/or a geographic area may be appropriate.

This section presents options for states/tribes to consider in tailoring such a program. The

first two options are built upon a presumption that certain sources or situations contribute

to visibility impairment. The third option relies upon confirmation of impainnent

attributed to a source sector. The options described below may be implemented

independently or in any combination, as deemed appropriate by the state/tribe.

The options explored here are not exhaustive or definitive in structure or design.

However, any selected option must still consider the nine elements as well as the criteria

as specified in the Rule. Application of these or any other options can be considered at

the source sector level, but should also be sensitive to the potential for cumulative

impacts of all fire source sectors. Additionally, state/tribal authorities will want to be

mindful of equitable treatment of sources in the implementation of their enhanced smoke

management programs.

3.8.1 Source Sector Option

Under this option, there is a presumption that certain source sectors are reasonably

expected to contribute to visibility impaimlent based on historical data and/or projected

future burning. Where this presumption exists, states/tribes could choose to apply the

nine enhanced smoke management program elements to those source sectors with a

greater level of effort.

13
3.8.2 Situational Option

This option describes certain situations that, if true, would indicate to the state/tribe the

need for a greater level of effort of implementation of the enhanced smoke management

program elements. The scenarios below can be used by states/tribes in the development

of area and/or source sector-specific enhanced smoke management programs. Each

scenario describes a combination of emission levels, NAAQS status (e.g., non-attainment

area status) and proximity to Class I areas that may indicate the level of enhanced smoke

management program needed.

The following is an example of how this situational option could be applied, and is

modeled after the Prevention of Significant Deterioration (PSD) pennitting

requirements's for major stationary sources (see table in footnote below)46 In this

example, the emissions are the annual totals that would be produced by a fire source

sector. The attainment status accounts for existing non-attainment area (NAA) issues that

a state/tribe may need to address.47 The proximity parameter addresses how close a fire

source sector is to a Class I area. This example is predicated on all three factors applying

simultaneously.

a) Emissions levels:

Attainment status:

Proximity:

b) Emissions levels:

Attainment status:

Proximity:

c) Emissions levels:

Greater than 50 tons/yr of PM 10 (total/year) within

state/tribe for all anthropogenic fire sources

No PM,o or Ozone NAAs

Within and near (i.e., <50 km) a Class J area

Greater than 250 tons/yr ofPM,o (total/year) within

state/tribe for all anthropogenic fire sources

No PM,o or Ozone NAAs

Within 100 km of Class I area

Greater than 100 tons/yr PM '0 (total/year) within state/tribe

for all anthropogenic fire sources

" 40 eFR 52.21.

41, This table provides estimates or acres burned La give an idea of approximate fire size using the available

emission factors ror the source Iype indicated. These numbers are nOL an exact representation or acreages,

emission factor, and ruel loading of all fires ror each type. Note: Agriculture and Rangeland numbers are

the same.

Tons (PM,o) Acres Burned (Annual Total)

Wildland Agriculture Rangeland

(Forest 20 lons/acre (4 tons/acre consumed) (2 Ions/acre consumed)

consumed)

250 833 12,500 12,500

100 333 5,000 5,000

70 233 3,500 3,500

50 167 2,500 2,500

47 When PM1.) NAAs are identified, then PM].:> could also be used in assessing the level orenhanced smoke

managemenl program needed.

14
Attainment status:

Proximity:

d) Emissions levels:

Attainment status:

Proximity:

e) Emissions levels:

Attainment status:

Proximity:

3.8.3 Impact Based Option

Moderate PM,o or Ozone NAA or Maintenance Area

Within 100 km ofClass I area

Greater than 70 tons/yr PM,o (total/year) within state/tribe

for all anthropogenic fire sources

Serious PM,o or Ozone NAA

Within 100 Ian ofClass I area

Greater than 250 tons/yr of PM,o (total/year) within

state/tribe for all anthropogenic fire sources

Any level of Altainment/NAA

Distances farther than 100 Ian

A state/tribe can determine the level of effort of an enhanced smoke management

program based on the relative contribution (i.e., impact) of each of its fire source sectors

and cumulatively all fire source sectors' impacts to visibility impainnent in Class I areas.

One possible approach that could be used is related to deciview, the metric commonly

associated with visibility analyses and also used within the PSD permitting process.

Under this scenario, states/tribes would determine the frequency, magnitude (in

deciview), and duration of a source sector's contribution to visibility impairment (on the

20 percent "worst" visibility days in a calendar year). To prevent degradation of the 20

percent "best" visibility days in a calendar year, the state/tribe may want to increase the

rigor of its enhanced smoke management program if emissions from fire sources

conespond with declining visibility.

In order to determine these components, a visibility impairment assessment could be

conducted using Interagency Monitoring of Protected Visual Environments (IMPROVE)

data, emissions data derived from fire activity data, contemporary visibility modeling

techniques, or other available information. Note that currently, final analysis of

IMPROVE data sometimes lags as much as a year from when data were collected. This

situation may also be true of visibility impairment assessments. Therefore, there may be

lag lime between when impacts were measured and how soon enhanced smoke

management programs could be implemented or revised.

Based on the results of the visibility assessment, the states/tribes could determine what

level of effort of enhanced smoke management program corresponds to the degree of

impact.

15
3.9 Collaborative Development

Policy Stalement H: The development and application of enhanced smoke

managemenr programs, including the consideralion of the criteria (F), will be

done collaboratively with state, tribal, local and federal agencies and private

parlies.

The GCVTC Report cites the importance of a collaborative process in a number of places

with regard to fire 48 EPA's Interim Policy also supports collaborative efforts and

specifies roles for the stakeholders in the process. The underlying tenet of the WRAP

process further conveys the importance of approaching visibility and the Rule with

stakeholder input and use of collaborative processes.

Utilizing land managers and affected publics as well as the responsible air regulatory

entity can result in an enhanced smoke management program that will meet the

expectations of EPA for SIP submittal under Section 309, and may reduce localized

controversy. There are certain steps in the enhanced smoke management program

development process that will need cooperative efforts, such as the establishment of the

criteria to be used by the regulatory entity to detemline the level of effort needed for the

enhanced smoke management program. The criteria for determining the level of effort is

a significant issue as there is a paucity of data on emissions and visibility impairment

from fire sources. This level of effort assessment is also tied to developing funding

mechanisms for the enhanced smoke management program, which the GCVTC urged be

developed cooperatively.

The SIPfTlP development process will be initiated by the respective regulatory entity,

which is the responsible party for initiating the collaborative efforts. The earlier in the

SIP development process that a collaborative effort could be initiated would likely result

in a more valuable result. It is envisioned that, through a collaborative effort, a schedule

and process for implementing the enhanced smoke management program will be created

that is acceptable to both EPA and affected stakeholders. Using a collaborative process

will facilitate the needed equity among fire source sectors as well.

'" GCVTC Reporl, p. 49-50.

16
APPENDICES

17
Appendix A

Glossary

This glossary is intended to facilitate readers' consistent review of this Policy. This

glossary is not intended to be a complete list of all terms and acronyms. An asterisk (')

indicates a definition from Section 1.1 of the WRAP Fire Emissions Joint Forum (FEJF)

Workplan, February 25, 1999. A number sign (#) indicates a definition from the WRAP

Policy for Categorizing Fire Emissions, November 15,2001.

Agricultural Fire/Burning' - Any fire ignited by management actions to meet specific

objectives (i.e., managed to achieve resource benefits) on agricultural land.

Agricultural Land' - Agricultural land includes croplands, pasture, and other lands on

which crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be

included with wildland for the purposes of the FEJF work.

Alternatives to Burning - Land management practices that treat fuel without using fire.

Anthropogenic - Produced by human activities.

Anthropogenic Emissions Source Classification ("anthropogenic")" - A categorization

that designates which fire emissions contribute to visibility impairment in a Federal Class

I area. "Anthropogenic" emissions must be controlled to achieve progress toward the

2064 natural conditions goal [i.e., natural visibility goal] for each Federal Class I area in

the WRAP region. This classification includes natural and human-caused ignitions.

Area Source - A source category of air pollution that generally extends over a large area.

Prescribed burning, field burning, home heating, and open burning are examples of area

sources.

Attainment Area - An area considered to have air quality as good as or better than the

national, state/tribe or local ambient air quality standards. Note that an area may be in

attainment for one or more pollutants but be a non-attainment area for one or more other

pollutants.

Best Available Control Measures (HACM) - A tenn used to refer to the most effective

measures (according to EPA guidance) for controlling small or dispersed particulates and

other emissions from sources such as roadway dust, soot and ash from woodstoves and

open burning of rush, timber, grasslands, or trash.

Best Management Practices (HMPs) - A tenn applied collectively to any administrative

or on-the-ground procedure that reduces the negative impacts of some action. An

example of a Best Management Practice with respect to air quality would be conducting a

prescribed bum when atmospheric ventilation is good, which in turn promotes smoke

dispersal.

18
Class 1Area - See Mandatory Class I Area and Non-Mandatory Class 1Area.

Control of Fire Emissions' - Actions may be taken to control fire emissions by utilizing

best management practices such as the use of alternatives, biomass utilization, and other

emission reduction techniques.

Criteria Pollutants - The 1970 amendments to the CAA required EPA to set National

Ambient Air Quality Standards (NAAQS) for certain pollutants known to be hazardous to

human health. EPA has identified and set standards to protect human health and welfare

for pollutants: ozone, carbon monoxide, particulate matter (PMIO and PM, 5). sulfur

dioxide, lead, and nitrogen oxide. The teon, "criteria pollutants" derives from the

requirement that EPA must describe the characteristics and potential health and welfare

effects of these pollutants. It is on the basis of these criteria that standards are set or

revised.

Cumulative Effects - The effect on the environment that results from the incremental

impact of the action when added to other past, present, and reasonable foreseeable future

actions regardless of what agency, entity or person undertakes such action. Cumulative

effects can result from individually minor but collectively significant actions taking place

over a period oftime.

Deciview - A unit of visibility proportional to the logarithm of the atmospheric

extinction. Under many circumstances a change in one deciview will be perceived to be

the same on clear and hazy days.

Ecosystem Maintenance Buming" - A prescribed fire or wildfire managed for resource

benefits, in an ecosystem that is cuo'ently in an ecologically functional and fire resilient

condition, that is utilized to mimic the natural role of fire.

Ecosystem Restoration Buming' - The re-establishment of natural vegetation that may be

accomplished through the reduction of unwanted and/or unnatural levels of biomass,

which may have accumulated due to management action. Prescribed fires, wildfires

managed for resource benefits and mechanical treatments may be utilized to restore an

ecosystem to an ecologically functional and fire resilient condition.

Emission - Pollution discharged into the atmosphere. Examples of emissions sources are

smokestacks, other vents, and surface areas of commercial or industrial facilities; from

residential chimneys; and from motor vehicle, locomotive, aircraft, or other non-road

engines.

Emission Inventory - A listing, by source, of thc amount of air pollutants discharged into

the atmosphere.

Emission Cap - An enforceable limit on the amount of specific air pollutants that can be

released or on the amount of a specific pollutant that is allowed to be in the air in a

19
defined geographic area, and that has regulatory consequences. See also Emission Goal

and Emission Target.

Emission Goal - A desired future outcome that may be represented by a numeric

indicator, but without regulatory consequences, and as distinguished from a limit (i.e.,

target or cap). See also Emission Cap and Emission Target.

Emission Reduction - A strategy for controlling smoke from prescribed fires that

minimize the amount of smoke output per unit of area treated or other objective unit of

accomplishment.

Emission Target - A finn limit on the amount of specific air pollutants that can be

released or on the amount of a specific pollutant that is allowed to be in the air in a

defined geographic area, but without regulatory consequences (as distinguished from a

cap). See also Emission Cap and Emission Goal.

Enhanced Smoke Management Program (ESM Pl - A program for fire emlSSlOns that

considers visibility effects, in addition to health and nuisance objectives, and is based on

the criteria of efficiency, economics, law, emission reduction opportunities, management

objectives, and reduction of visibility impact.

Federal Class I area - see Class I Area.

Fire" - When this tenn appears, it refers inclusively to wildfire, prescribed natural

fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and

agricultural fire.

Fire Source Sector - A segment of fire attributed to a particular management or

ownership, e.g., wildland prescribed fire, agricultural prescribed fire, wildfire, and

wildland fire use. Also known as a fire sourCe.

Fire Use - A term utilized in federal land management that includes both prescribed fire

and wildland fire use.

Fuel Moisture Content - The quantity of moisture in fuel expressed as a percentage of the

weight when thoroughly dried at 212 degrees F.

Fuel Reduction - The manipulation, including combustion, or removal of fuels to reduce

the likelihood of ignition and/or to lessen potential damage and resistance to control.

Fuel Treatment - Manipulation or removal of fuels to reduce the likelihood of ignition

and/or to lessen potential damage and resistance to control (e.g., lopping, chipping,

crushing, piling and burning).

20
Implementation Plan - Plans devised by states and/or tribes to carry out their

responsibilities under the CAA. SIPs/TIPs must be approved by the U.S. Environmental

Protection Agency and include public review.

Interagency Monitoring of Protected Visual Environments (IMPROVE) - A cooperative

visibility monitoring effort, using a common set of standards across the United States,

between the EPA, federal land management agencies, and state air agencies.

Jurisdiction - A geographic area of authority.

. Land Managers' - When this tenn appears, it refers inclusively to federal, state, tribal,

and private land managers.

Manage Fire Emissions' - Actions may be taken to manage fire emissions to minimize

impacts on visibility, public health, and nuisance concerns. Some management actions

include concepts such as the timing of ignitions for better dispersion and consideration of

downwind air quality and visibility. It may also includc consideration offactors related to

the area to be burned such as the fuel moisture condition and other physical parameters.

Manage fire emissions is analogous to smoke management.

Mandatory Class I Area - An area set aside under the CAA to reccive the most stringent

protection from air quality degradation. Mandatory Class I Fcdcral Areas are (I)

international parks, (2) national wilderness areas and memorial parks larger than 5,000

acres in size, (3) national parks that exceed 6,000 acres in size and which were in

existence when the 1977 CAA amendments were enacted. Thc cxtcnt of a mandatory

Class 1Federal area includes subsequent changes in boundarics, such as park expansions.

Modeling - The artificial simulation or some event or action that has quantifiable results.

Mathematical expressions and computers are frequently used in modeling.

National Ambient Air Ouality Standards (NAAOS) - See Criteria Pollutants.

National Environmcntal Policy Act (N EPA) - Establishes procedures that federal

agencies must follow in making decisions on federal actions that may impact the

environment.

National Visibility Goal - Section 169A of the CAA scts forth a national goal for

visibility which is the "prevention of any future, and the remedying of any existing,

impairment of visibility in Class I areas which impairment results from manmade air

pollution."

Natural Background Condition' - An estimate of the visibility conditions at each Federal

Class I area that would exist in the absence of human-caused impainnent.

Natural Emissions Source Classification ("natural")' - A categorization that designates

which fire emissions can result in a natural reduction of visibility for each Federal Class 1

21
area In the WRAP regIOn. This classification includes natural and human-caused

ignitions.

Natural Ignition" - Fire/burn ignited due to a natural (i.e., non-human-caused) event, e.g.,

fire ignited by lightning or volcanic eruption.

Natural Visibility Goal- The ultimate goal of the regional haze program is the absence of

visibility impainnent due to human-caused emissions.

Non-Attainment Area fNAA) - An area identified by an air quality regulatory agency

through ambient air monitoring (and designated by the EPA) that presently exceeds

federal, state/tribe or local ambient air quality standards. See Attainment Area above.

Non-Mandatory Class I Areas - Class I areas designated by states or tribes, but are not

deemed mandatory by the CAA. As of January 2002, Class I areas designated by tribes

include: Fort Peck Reservation in MT, Northern Cheyenne ReserVation in MT, Flathead

Reservation in MT, Yavapai-Apache Reservation in AZ (Class I status under litigation),

and Spokane Reservation in WA.

Nuisance Smoke - Unwanted smoke that does not exceed NAAQS primarily for

particulate matter.

Particulate Matter - Any liquid or solid particles. "Total suspended particulates" as used

in air quality are those particles suspended in or falling through the atmosphere. They

generally range in size from 0.1 to 100 microns.

Plume Blight - Visual impairmcnt of air quality that manifests itself as a coherent plume.

PMlQ - Particulate matter of aerodynamic diameter less than or equal to 10 micrometers.

Emissions of PM,o are significant from fugitive dust, power plants, commercial boilers,

metallurgical industries, mineral industries, forest and residential fires, and motor

vehicles.

PM,,, _Particulate matter of aerodynamic diameter less than or equal to 2.5 micrometers.

A measure of fine paliicles of particulate matter that comes from fuel combustion,

agricultural burning, woodstoves, etc.

Point Source - A fixed source of pollution. An example is thc smoke stack of a coal-fired

power plant or smelter.

Prescribed Fire' - Any fire ignited by management actions to meet specific objectives,

i.e., managed to achieve resource benefits.

Rangeland" - Land on which the historic climax plant community is predominantly

grasses, grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or

artificially when routine management of that vegetation is accomplished mainly through

22
manipulation of ecological principles. Rangeland includes natural grasslands, savannas,

shrub lands, most deserts, tundra, alpine communities, coastal marshes and wet meadows

(Natural Resources Conservation Service National Range and Pasture Handbook, 1997).

Regional Haze - Visibility impairment caused by the cumulative air pollutant emissions

from numerous sources over a wide geographic area.

Smoke Effects' - The effects on visibility (both plume blight and regional haze), public

nuisance, and the health-based NAAQS due to emissions from fire.

Smoke Intrusion - Smoke from prescribed fire entering a designated area at unacceptable

levels.

Smoke Management Efforts - Programs, practices and techniques to mmlllllZe and/or

reduce smoke emissions or impacts from fire.

State Implementation Plan (SIP)' - See Implementation Plan.

Suppression - A management action intended to protect identified values from a fire,

extinguish a fire, or alter a fire's direction ofspread.

Transport Region State - One of nine states that make up the Grand Canyon Visibility

Transport Region: Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon,

Utah, and Wyoming.

Tribal Implementation Plan (TIP)' - See Implementation Plan.

Visibility Impairnlent - Any humanly perceptible change in visibility (light extinction,

visual range, contrast, coloration) from that which would have existed under natural

conditions.

Wildfire' - Any unwanted, non-structural fire.

Wildfire Managed for Resource Objectives' - The management of naturally ignited fires,

regardless of land type or ownership, to accomplish specific, pre-stated resource

management objectives in predefined geographic areas with or without a plan in place.

This tenn is considered to be analogous with the tenns Wildland Fire Managed for

Resource Benefits and Prescribed Natural Fire that are used in regulations and policies

regarding federal wildlands.

Wildland'- An area where development is generally limited to roads, railroads, power

lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed

less frequently than once in 10 years), is not fallow, and is not in the USDA Conservation

Reserve Program (CRP). The land may be neglected altogether or managed for such

purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant

cover (EPA Interim Air Quality Policy). The land is not "agricultural land" as

23
operationally defined above. Silvicultural land and rangelands (per the FEJF charge),

woodlots, and private timberlands will be included with wildlands for the purposes of the

, FEJF work.

Wildland Fire' - All types of fire (see definition of fire above), except fire on agricultural

land.

Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire' - These tenns

both have current use in regulations and policies. They are considered to be synonymous

and are used interchangeably in this work plan. These terms refer to the management of

naturally ignited fires to accomplish specific, pre-stated resource management objectives

in predefined geographic areas outlined in the fire management plan. Also referred to as

Wildland Fire Use.

24
Appendix B

Related Documents Listing

Regional Haze Rule

Published in the Federal Register on July i, 1999,64 FR 35714.

http://www.epa.gov/ttn/oamg/tl/!r notices/rhfedreg.pdf

Grand Canyon Visibility Transport Commission Report

Grand Canyon Visibility Transport Commission, Recommcndations for Improving Western

Vistas, Report to the U.S. EPA, June 10, 1996.

http://www.wrapair.orgGo to the GCVTC link.

EPA Interim Air Quality Policy on Wildland and Prescribed Fire

U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland

and Prescribed Fires, April 23, 1998.

http://www.epa.gov/nn/oarog/tl/memoranda/tirefnl.pdf

AAQTF Recommendation on Air Quality Policy

Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning,

Recommendation to the U.S. Department of Agriculture, November 10, 1999.

http://fargo.nserl.purdue.edu/!''ca/Archives/20001P0Iicy/Buming%20Policy.htm

Tribal Authority Rule

Published in the Federal Register on February 12, 1998, 63 FR 7253.

hnp://www.epa.gov/fedrgstr/EPA-AIRJI998/FcbruarylDay-12/a345I.htm

WRAP Policy for Categorizing Fire Emissions

Approved by the Western Regional Air Partnership, November 15,2001.

http://www.wrapair.org/commindex.htm Go to the FEJF Task Teams, then Natural Background.

Wildland Fire: Elements of a Basic Smoke Management Program Draft Report

Completed for the FEJF on July 10,200 J.

http://www.wrapair.org/commindex.htl11 Go to the FEJF Task Teams, then Basic Smoke

Management.

Smoke Management Program Surveys

http://www.wrapair.org/commindex.htm Go to the FEJF, then Basic Smoke Management.

I) Wildland Smoke Management Program Survey, January 26, 2001

2) Boulder Wildland Smoke Management Program Survey, February 2, 200 I

3) Agricultural Burning Smoke Management Program Survey, March 30, 2001

4) An Assessment of Tribal Air Quality Data and Programs in the Western United States, The

institute for Tribal Environmcntal Professionals (ITEP), September 200 I

Class I Area Map

http://www.wrapair.org Go to About WRAP, then WRAP Boundaries and Regional Visibility

Planning in the West.

WRAP ESMP Policy 10/15/02 25
Appendix C

Enhanced Smoke Management Program:

Jmplemcntation Guidance

C. I Regional Haze Rule Implementation Plan Process

The Rule requires states to develop State Implementation

Plans (SIPs) for addressing regional haze in the Nation's

156 mandatory Class I areas. 49 Additionally, the Rule requires effective

management offire sources.

In general, the SIPrrlP process includes the following steps: state/tribal agency technical

analyses; identification of necessary emission reductions; identification of control

strategies to achieve emission reductions; demonstration of reasonable further progress;

submittal of slPrrlP to EPA for consideration/approval; public review/comment; EPA

approval of SIP/TIP; five-year state/tribe review for reasonable progress and slPrrlP resubmittal.

Under Section 309, states are required to, and tribes may, have a regional haze

implementation plan that addresses the Class I areas of the Colorado Plateau (the 16

Class I areas specified by the GCVTC) 50 submitted by December 31, 2003. The Rule

stipulates that states must commit to implement all SIP measures from December 31,

2003 through December 31, 2018.51 Further, all mandatory Class I areas in the GCVTC

Transport Region, other than the Colorado Plateau 16, may be addressed in SIPs/TIPs by

the 2008 Section 309 deadline52

Under Section 308 states must, and tribes may, incorporate the requirements of the Rule

into their implementation plans within 12 months of designation as PM2.5 attainment, or

within three years after designation as PM2.5 non-attainment, but no later than December

31, 2008. Under Section 308, all mandatory Class I areas, except those addressed under

Section 309, will be addressed in the SIP/TIP submittal tied to the PM2.5designation. 51

4<) The Rule is only applicable to mandalory Class I areas (see Appendix A & Appendix B for additional

information on mandalory Class I areas). States/tribes in the WRAP region may utilize the WRAP ESMP

Policy to protect visibility in non-mandatory Class I areas.

5(1 The GCYTC Report specified 16 mandatory federal Class I areas on the Colorado Plateau that were

adopted into Section 309 of the Regional Haze Rule. These 16 Class I areas are: Grand Canyon National

Park, Sycamore Canyon Wilderness, Petrified Forest National Park, Mount Baldy Wilderness, San Pedro

Parks Wilderness, Mesa Verde National Park, Weminuche Wilderness, Black Canyon of the Gunnison

Wilderness,·Wesl Elk Wilderness, Maroon Bells Wilderness, Flat Tops Wilderness, Arches National Park,

Canyonlands National Park, Capital Rccf National Park, Bryce Canyon National Park, and Zion National

Park. 64 FR 35770, *51.309 (b) (I).

51 64 FR 35770, ~51.309. EPA Region 9 has detennined that implementation schedules may be negotiated

as part of the SIP/TIP process and has previously accepted up to one year for implementation of SIPfflP

programs.

" 64 FR 35773, *51.309.

53 64 FR35765, *51.308 (b) (I), (2).

WRAP ESMP Policy 10/15/02 26
It is anticipated that the establishment of enhanced smoke management programs will be

incorporated into the SIPs/TIPs submitted to EPA in order to meet the requirements of

the Rule. Within the context of smoke management, it is recommended that states/tribes

integrate their NAAQS and visibility SIPrrlP requirements.

Under the WRAP ESMP Policy there are nine elements of an enhanced smoke

management program that meet the requirements of the Rule. For each of the enhanced

smoke management program elements, there are implementation examples listed to assist

states/tribes in developing their enhanced smoke management programs. This is not

meant to be an exhaustive list, and states/tribes may also want to review the Fire

Emissions Joint Forum (FEJF) draft report on Wildland Basic Smoke Management

Program Elements as well as the EPA Interim Policy and the AAQTF Recommendation

on Air Quality Policy for additional suggestions.54 The level of effort each state/tribe

would apply to the nine elements of the enhanced smoke management program needs to

be based on a pre-determined process or metric developed collaboratively.

C. 2 Elements of an Enhanced Smoke Management Program

C.2.1. Element I. Actions to Minimize Emissions from Fire

A wide range of opportunities to minimize emissions exists depending upon the fire

source. Emission reduction techniques may be as simple as changing ignition timing to

allow for more efficient combustion. Other techniques may include the use of mechanical

means. Options to provide incentives and emission goals may also serve this purpose.

C.2.1.1 Emission Reductions Techniques

Under an enhanced smoke management program, provIsIons are made to account for

emission reduction techniques that are utilized when buming. Documentation of emission

reduction practices that were considered in the planning or implementation of bums also

support annual emission goals and associated emissions tracking requirements. This

documentation may be part of a bum plan or other data collection or reporting system

that is used to meet annual emission goals and associated emissions tracking

requirements as developed by the FEJF.

• Reducing the fuel load to be bumed can reduce emIssIons. This can be

accomplished on forestland by not treating (no burning) portions of the unit,

yarding, consolidating, or isolating non-merchantable material; providing public

firewood access before the burn; finding off-site use for more of the wood before

the burn; using chemicals; burning when non-target fuels have a high fuel

moisture; using alternative mechanical treatments, and rapid mop-up.

• In agriculture, emissions can be reduced by baling and removing some of the

residue, spot burning only needed areas of the field, strip burning and backing

fires. Emissions can also be reduced by moving the burning season into a different

54 See Appendix B, Related Documents Listing.

WRAP ESMP Policy 10/15/02 27
time of the year if changes m fuel consumption or enllSSlOns factors can be

achieved.

• Land managers/owners should strive for the most efficient combustion possible.

Vegetation should be dry and in a condition that will minimize the smoke emitted

during combustion. When pile burning, material should be burned in dirt-free,

not overly compressed, cured, and dry piles. Piled material should be covered if

possible. Fires should be ignited so as to bum as rapidly as possible, in ways that

shift the proportion of the bum from the smoldering phase to the flaming phase.

Minimizing duff consumption and smoldering through fuel moisture

considerations will reduce emissions as well. Land managers/owners should only

bum those fuels essential to meet resource management objectives and bum piles

when other bums are not feasible, such as in snow or rain.

Regulatory authorities and other interest groups may also use WRAP guidance

infonnation, such as its Alternatives to Burning document that is currently under

development by the FEJF, as a reference for specific alternatives. Another resource is the

Smoke Management Guide for Prescribed and Wildland Fire, 2001 Edition (in press)55

C.2.1.2 Bum Manager Qualification

Another manner in which to reduce emissions is a burn manager qualification program

that certifies the land manager/owner is knowledgeable of alternative burning practices

and emission reduction techniques, and i.s capa~le of implementing them. Bum manager

qualification programs already exist in most federal, state and tribal land management

agencIes..

A certification and qualification process could be established by prescribing what training

meets requirements, such as training provided by the National Wildfire Coordination

Group (NWCG), and by implementing training seminars and other institutional

opportunities for 'land managers/owners to gain the necessary skills and knowledge to

implement proper smoke management techniques. Land manager/owner

certification/qualification programs may be similar to those required by federal land

management agencies like those offered by the NWCG. For non-federal land

managers/owners that cannot participate in federal sponsored training, states/tribes could

develop their own certification processes and host training courses such as a "State

Forestry Prescribed Fire Correspondence Course" or an "Interagency Basic Prescribed

Fire Course".

In an enhanced smoke management program, burner qualifications might be required on

pennit applications and tracked by the regulatory agency. Bum size or emission output

might be limited depending on the 'Ievel of burner qualification. For example, a Level I

qualified burner Can burn up to abc acres/tons while a'Level II qualified burner can bum

up to cde acres/tons, and so on.

55 Smoke Management Guide for Prescribed and Wildland Fire, 2001 Edition (in press), produced by Lhe

Nalional Wildfire Coordinaling Group (NWCG) Fire Use Working Team.

WRAP ESMP Policy 10/15/02 28
As examples, a few types of burner qualifications are ~isted below:

• Satisfactory completion of the "State Forestry Prescribed Fire Correspondence

Course" and direct experience in three prescribed burns prior to taking the

course, or satisfactory completion of the "Interagency Basic Prescribed Fire

Course" and direct experience in three prescribed burns before or after the

course.

• Completion of a NWCG or federal/state/tribe land manager equivalent course

dedicated to smoke management or attendance at a state approved smoke

management workshop.

• Successful completion of a training program (which includes home study, 8-hour

classroom session, and a written exam), documented practical experience in

prescribed buming, and a signed agreement to conduct all burns in compliance

with all applicable laws and ordinances,

• Land management agencies and the state/tribe develop and present interagency

training to promote understanding of the regulatory context and affects of air

pollution, fire ecology, and smoke management.

C.2.1.3 Incentives

Providing incentives to landowners and land managers for practicing emission reduction

techniques and utilizing alternatives to burning is yet another option for states/tribes to

include in enhanced smoke management programs. This approach could be seen as

addressing equity issues in that those who make efforts to reduce emissions are rewarded

for their efforts. The reward to the landowner/land manager could be seen in terms of

environmental gains as well as financial gain. The reward to communities could be seen

in retaining property values, and maintaining economic development and tourist-related

industries.

Environmental win-win options may be that by decreasing emissions, a burner is given a

higher priority when allocating burn days. Or, by utilizing alternatives, a higher priority

is given to a burner when attempting to burn. Similarly, financial win-win options may be

to decrease any assessed fees or bum costs when alternatives are used before buming.

The system rewards those that take the extra time, effort and money to utilize cmission

reductions and alternatives. Those who either choose not to, or for land management

constraints, cannot utilize emission reductions/alternatives, would pay more.

Landowners/land managers could be afforded the opportunity to deal with other sources

to negotiate emissions management strategies for financial gain that would result in a net

emissions decrease. In January 200 I, the EPA issued a policy document that provides

infonnation on discretionary economic incentive programs 56 In May 2002, the EPA

provided additional guidance on voluntary and backstop approaches to emissions

reduction in its Section 309 Annex to the Regional Haze Rule for stationary sources of

sulfur dioxide. 57 In an enhanced smoke management program, an incentive may be

)(, EPA Improving Air Quality with Economic Incentive ProgrdlllS (EIP Guidance), January 2001.

"67 FR 30418.

WRAP ESMP Policy 10/15/02 29
available if a landowner/land manager can reduce hislher emissions and gain financially

from not only supplying a marketplace with raw materials, but also receiving payment for

emissions not generated.

C.2.IA Emissions Goal/Limit

Another action that could be taken by regulatory authorities to minimize emissions is to

establish an emissions goal or limit within portions of a state/tribe, the entire state/tribe or

over a multi-state/tribe region. How to meet the goal or limit would be left to the

discretion of the land managers/owners. Establishing such a goal or limit would

encourage land managers/owners to seek alternative methods of burning and alternatives

to burning so as to retain the ability to bum where no alternatives are available.

C. 2.2 Element 2. Evaluation of Smoke Dispersion

A variety oftools and methods exist by which a land manager/owner could reduce smoke

impacts over periods ranging from several hours to several days. Enhanced smoke

management programs could contain the following criteria to support the dispersion

estimation process.

• States/tribes may provide or find ways to provide websites of current weather and

fuels information (i.e., fuel moisture) specific to meet the needs of land

managers/owners. Land managers/owners would utilize this infonnation to time

ignitions during periods of expected good smoke dispersion.

• Acceptable weather and climatic conditions can be prescribed for burning in specific

areas so as to avoid impacting Class I areas.' A predefined set of weather elements

would provide a degree of certainty as to when burning opportunities would be most

likely to occur. Burning should be banned during periods when air stagnation

advisories or air pollution alerts are in effect.

• As described previously, a burner qualification and certification program could be

established that includes advanced training on understanding the relationships

between weather and smoke dispersion. Individuals who have greater knowledge and

understanding of the factors affecting smoke behavior may make better decisions on

when and when not to bum.

• A more sophisticated and more comprehensive effort to evaluate smoke behavior

would be to conduct smoke dispersion modeling in the planning and implementation

process for burning. Dispersion modeling may be conducted by a state/tribal agency

or other delegated regulatory authority. Such modeling results could be used as a

screening approach to detennine if there should be extra reason for concern about the

proposed burn(s). This approach may assist in determining cumulative effects of

multiple burns.

WRAP ESMP Policy 10/15/02 30
• Centralized decision-making of burn decisions with coordination anlong land

managers/owners (either by source type or between sources) would require a more

intensive effort of involvement by groups involved in burning. Land

managers/owners would check-in with a centralized burn authority to receive

infonnation about other source activity prior to conducting a burn.

• A rigorous, timely, centralized decision-making system established with the intent of

providing "go/no-go" decisions affords a greater level of coordination that would rely

on greater infrastructure and resources for support. Meteorologists and other

specialists with knowledge of air quality, fire, weather and fuels interaction would

provide services that direct where and when burning could occur.

C. 2. 3 Element 3. Alternatives to Fire

The WRAP through its FEJF has commissioned two reports on alternatives to burning

that will aid states and tribes in addrcssing this element of the enhanced smoke

management program. These reports show potential methodologies for regulatory entities

and their affected stakeholders to assess the potential for alternative use on both

wildlands and agricultural lands in their respective jurisdiction. These reports also

provide infonnation on barriers to the use of alternatives, which is a requirement of

section 309 of the Rule. States/tribes could establish websites with information describing

the alternatives.

Land managers/owners may be required to assess the feasibility of using alternatives to

fire where there are many competing sources or large a1TIounts of burning occurring.

This assessment could be based on established critcria, such as sustainability or potential

fuel reduction. Bum plans and data systems could contain information that helps track the

practice of using alternatives to fire. Emissions tracking systems5H and reasonable further

progress assessments could use this information to validate landowner/land manager's

implementation of alternative practices as an emissions reduction technique.

Sources of smoke from geographic areas that continue to adversely affect a mandatory

Class I area's 20 percent "worst" and "best" days, according to the Rule, may be required

to implement measures that utilize alternatives to burning to the maximum extent feasible

as a condition of further burning. Incentives could be identified wherein land owners/land

managers have the opportunity to substitute emissions not produced in one area for

emissions produced in another geographic area not affecting a Class I area's visibility as

long as there is a net emissions decrease as a result of using the alternatives.

Geographic areas with sustained sources of adverse smoke impacts in mandatory Class I

areas may consider burn curtailments if programs to minimize emissions, impacts and

alternatives to fire use do not provide the necessary tools to meet reasonable progress

toward tbe natural visibility goal. Such actions could be considered on a fire source basis

so as to not impair one source's ability to use fire because ofthe failure of another source

type to take needed actions to meet the natural visibility goal.

.SH The WRAP's FEJF is currently preparing a policy on emissions tracking systems to assist states/tribes.

WRAP ESMP Policy 10115/02 31
C. 2. 4 Element 4. Public Notification of Burning

Public notification is a significant part of the CAA, and is inherent in the Rule. Public

notification under an enhanced smoke management program should be at least what is

required by EPA for a certifiable smoke management program,59 and may include extra

activities, depending on location. Generally, regardless of what kind of smoke

management program is in place, significant effort should be made to educate and notify

the public about burning, its impacts on visibility as well as its benefits.

Public notification includes public education and media relations, and consists of

activities such as issuing notices through the local news media including name and phone

number of person/agency, fuel type, expected time and date of bum, location of bum, and

the expected plume direction, extent, and duration. Public notification of non-burning

alternatives that have been considered for a project could also be included.

Other means of notification may include the use of a website, public open houses or

meetings, signs at bum sites, distribution of fact sheets that include infonnation on smoke

impacts, brochures, posters, notices, personal contact by phone or visit, or legal

advertisements. It is a good practice to maintain a contact list of interested and affected

publics, and make sure that notification of planned bums gets to everyone on that list. A

plan for notifying the public could be part of the bum plan.

Effective public involvement, notification, and education can decrease complaints and

resistance to burning projects, as well as prepare the public to manage their activities

around scheduled bums. Public notification and education activities can also increase the

public's faith in the different agencies and landowners, knowing that their health and

welfare is being carefully considered in both planning and implementation. A welldeveloped public education and awareness program would not only serve the public but

also fulfills a recommendation from the GCVTC.

Public awareness and education activities may be conducted by states/tribes, land

managers/owners, or in cooperation by all. Training and guidance in public notification

techniques could be provided to land managers/owners not accustomed to conducting

such work, i.e., non-federal land managers/owners. Program administrators might

consider developing an in-state/tribe public notification process to assist the non-federal

land managers/owners. Programs could strive to enhance non-federal land

managers'/owners' ability to involve public in planning by providing training and

guidance, or open forums for disseminating information on planned burning activities

that may affect visibility. If the public is involved in the planning of such activities

regarding potential affects to them, there is less chance of resistance to the bum while it

IS In progress.

.'i9 See Appendix B ReiaLed Documents Listing, EPA Interim Policy.

WRAP ESMP Policy 10/15/02 32
Finally, developing involvement by the community and partIcipation by land

managers/owners in the SJPrrlP and National Environmental Policy Act (NEPA)

planning processes may be beneficial in developing common expectations.

C. 2. 5 Element 5. Air Ouality Monitoring

Monitoring of smoke impacts may be a very sophisticated effort using sampling

equipment and extensive modeling or it may be as simple as creating a log of smoke

behavior.

Minimal procedures would be most likely in areas of little bum activity or when farther

away from Class I areas. On-site record keeping with subsequent submittal to the

state/tribe regulatory authority should be substantive enough for use in analysis of

reasonable further progress tracking or emission reduction programs.

As burning activity increases, states/tribes and land owners/managers could consider

conducting a more widespread and comprehensive monitoring program. The use of

cameras, satellite imagery and aerial monitoring to track and document smoke movement

could be considered. The use of IMPROVE monitored data may have to be supplemented

by air quality monitoring outside of Class I areas to track smoke movement.

Also, using visitor surveys in Class I areas regarding visibility impainment perceived

during their stay may be a way of generating subjective assessments of smoke impacts.

Such information would only be used to provide further validation of impacts, as relying

on surveys alone would be too subjective for states/tribes to administer reasonable smoke

management programs.

C. 2. 6 Element 6. Surveillance and Enforcement

Good communication between regulators, land managers/owners and the public can

significantly reduce the need for surveillance and enforcement. An atmosphere of trust

and cooperation between regulators and land managers/owners can go a long way toward

facilitating emissions reductions and compliance with air quality regulations.

Four primaly methods under which surveillance and enforcement activities may occur

are:

• Voluntary (Land manager/owner self-enforcement)

• Source sector regulator (e.g., Agricultural Bum Manager, Smoke Management

Meteorologist)

• State/tribe oversight

• Centralized regulatory authority (state or tribe)

Criteria and activities described below may be applicable for use in any of the four

methods. Some of the criteria can, obviously, only be enforced by a body that has legal

standing to do so. Whichever of the four methods a state/tribe may choose to implement

would be dependent upon the severity of the visibility impacts that are being addressed.

WRAP ESMP Pol icy 10/15/02 33
If states/tribes have regulations in place that govern smoke impacts, public complaints

can serve to monitor compliance. Such regulations should define criteria for establishing

these smoke impacts. The number and location of public complaints may be used to

monitor air quality impacts of fires. The number of complaints may not necessarily be a

trigger, rather the nature of the complaints and external verification of circumstances

leading to the complaints. In some cases, smoke regulations may apply only to noncertified burning. In such cases certified burners cannot be shut down for complaints

related to visibility, but can be shut down for a threat to health or safety.

Some criteria for taking action on smoke impacting visibility include:

• Is the visibility impact occasional or constant?

• Is the use of property affected?

• What are the economic impacts of both burning and not burning?

• Is the location of the impact within or outside of a Class I area?

• What is the duration of the impairment?

• What is the number of people affected?

• How many complaints have been received?

• Was the bum conducted in compliance with applicable regulations?

• Has the visibility impact been mitigated to the extent practicable?

• Is the public health threatened?

• Is the impact a result of poor planning or of something that could not be

anticipated?

Criteria of perfonnance standards in an enhanced smoke management program must be

stated clearly. Methods for detecting non-compliance could also be defined. Some

criteria or standards might include:

• Numerical standards for optical data at specific Class I areas (e.g., deciviews)

• NAAQS

• Comparison with photos taken of certain pre-detennined visibility conditions

(most impaired, least impaired days)

Accordingly, some methods for detecting compliance might include:

• IMPROVE sites

• Photo points

• NAAQS ambient air monitors

If performance standards are established in code, random audits and inspections can

provide assistance with compliance. Unannounced burn inspections and burn report

audits, including smoke dispersion information, are means of ensuring compliance with

air quality regulations. Aerial observations are another surveillance method.

If no visibility impact-related regulations are in place, violation of NAAQS or violation

of other codified pennit conditions or authorizations might trigger enforcement actions.

Enforcement actions must be based on established statute and regulation, and must be

applied equitably to all land managers/owners. Depending on state/tribe needs and

WRAP ESMP Policy 10/t5/02 34
compliance history, a written report or warning may be issued on the first instance of

, violation, while subsequent observed violations result in appropriate legal action.

Example enforcement actions may include:

• 5-day moratorium on ignitions

• Civil/criminal penalties, depending on how regulations are written

• Burn shutdown/mop-up

• Notice of violation/compliance order

• Liability for cost ofsuppression or damages

• Revocation of permit

• Felony punishment for willful or intentional violation

• Misdemeanor for careless violation

C. 2. 7 Element 7. Program Evaluation

Enhanced smoke management programs need to be reviewed on a periodic basis for their

effectiveness by the regulatory authority and affected stakeholders. It is incumbent upon

the state/tribe to submit progress reports to EPA describing how well the enhanced smoke

management program is being implemented as paIi of meeting reasonable further

progress requirements. Formal periodic progress report intervals could coincide with time

intervals used to evaluate reasonable progress. The Rule requires progress reports every

five years.

60 However, shorter review and evaluation time periods would belter determine

if enhanced smoke management programs are effective.

Generally, daily interaction between land managers/owners and program administrators

can provide a continuous means of program evaluation, but a formal method could be in

place to document periodic evaluations. Annual evaluations of the overall smoke

management program will provide the infonnation needed for periodic reports. Each

element of the enhanced smoke management program should consider evaluating:

• Implementation

• Compliance and enforcement

• Sections needing clarification or improvement

• Progress towards goals

• Recommendation for revisions

• Scientific advancements (modeling or other technological needs)

These annual evaluations could include, but not be limited to:

• An accounting of progress toward defined visibility improvement/impact

reduction goals

• An accounting of progress toward emission reduction goals

• Review of project burning for the next year, as well as additional out-year

planning

• Regional information, considering visibility impacts to and from adjoining

states/tribes

'" 64 FR 35768, §51.308 (g) and 35772, §51.309 (d)( 10).

WRAP ESMP Policy 10/15/02 35
• Bum activity summaries

• Burning restrictions or air quality alerts

• Significant smoke intrusions or visibility impacts

• Summaries ofIMPROVE and other monitored air quality data

• Emission inventory summaries

• Information tracking summaries

• Smoke complaint summaries

• Discussion of alternatives to burning

In an enhanced smoke management program, federal land managers responsible for

protecting air quality related values in Class I areas should be given the opportunity to

provide input to annual program evaluations.

Where MOUs or other agreements govern smoke management programs, an annual

meeting should be held where members share successes and failures, data is summarized

and the program is evaluated. In cases where review criteria are established in state code,

perfonnance can be compared against standards. Pennit files may be kept for a period of

time, including complaint files, and statistics generated to evaluate trends in the program.

C. 2. 8 Element 8. Burn Authorization

Bum authorization requirements are expected to vary depending upon the amount of

burning that is occurring, the fire source types that are conducting the burning, and the

degree of impainnent that exists or may be expected to occur as a result of the burning.

The proximity of non-attainment areas may also have a bearing on the complexity of the

burn authorization procedure that should be implemented. Four broad levels ofstringency

may be considered in the development and adoption of an enhanced smoke management

program.

• Establish a pennit-by-rule system

• Establish a burn permitting system by source sector or a coalition of source

sectors

• Establish a centralized bum authority

• Establish a regional bum authority

Establishment of any of these authorization situations would also entail the development

of coordination procedures described in (9) below.

C.2.8.1 Pennit by Rule

The AAQTF Recommendation on Air Quality Policy describes a process in which a set

of requirements are established under which burning may take place. These requirements

may include acreage, time of year, time of day and meteorological factors." I A written

pennit mayor may not bc required. As long as the conditions are met, then burning may

occur. There is no daily decision-making by a coordinating authority in this scenario.

(,I AAQTF Recommendation on Air Quality Policy, p.9.

WRAP ESMP Policy 10/15/02 36
Such a system may be applicable for any fire source type in geographic areas of low fire

use. This system should, however, still allow for the collection of enough infonnation by

an appropriate regulatory authority so that source activity and emissions may be tracked.

C.2.8.2 Burn Pennitting System

A bum permitting system that is established by fire source type would include a local

burn manager and/or state, tribe, local agency, whose responsibility is to develop the

conditions under which burning may occur and then ensure that burning occurs within the

requirements that are established. The elements described in this WRAP ESMP Policy

would be implemented by the burn manager to ensure that visibility in Class I areas is

protected.

C.2.8.3 Centralized Burn Authority

A more intensive level of smoke management would involve the creation ofa centralized

authority at the state, tribal or local level that provides daily coordination and approval of

burns if significant state/tribe-wide burning is occurring. The centralized authority may

be responsible for activities of one particular source type or a combination of sources.

This type of program could include the detailed use of meteorological information, burn

information and a permitting system to avoid cumu lative impacts ofsmoke from a variety

of bums.

C.2.8.4 Regional Bum Authority

Establishment of a regional burn authority may be required if there are continued and

extensive inter-state impacts from burning. States/tribes would agree to have oversight of

burning by an authority that equitably considers buming opportunities for all source types

while addressing the Class I area impacts over broad areas. A regional burn authority

would likely, in most cases, 'be working with the most severe and persistent problems.

C. 2. 9 Element 9. Regional Coordination

Coordination of burning activity is critical to avoiding cumulative visibility impacts

within and across source types. Coordination may range from a passive mode of

infonnation sharing between land managers/owners and/or the public to a more complex,

active coordination in which burn decisions are altered based on other activities that are

occurring or have recently occurred.

Coordination can occur at locations that reflect the affected level of concern. When bums

are located near Class I areas or non-attainment areas, coordination will be carried out at

a level that is appropriate. If burns are located adjacent to state/tribe boundaries,

coordination will occur appropriate to the smoke transport/emission path and quantity.

WRAP ESMP Policy 10/15/02 37
A common mode of coordination regardless of the complexity and magnitude of burning

would be information sharing via use of the web. Operationally, certain information

, needs to be established and updated as needed. This would include:

• Burn information (size, location, ignition date, etc.)

• Names and locations of sensitive reccptors and/or special protection zones;

sensitive receptors should include sensitive populations

• Locations ofmonitors (state, tribe, EPA or local)

• Database of known significant users offire (name, phone number)

• Identification of airsheds or air administered units

• Possible identification ofClean Air Corridors

• Updateable database of non-attainment and maintenance areas for criteria

pollutants of concern

• Identification of the centralized burn authority that maintains oversight

A minimal level of coordination would include the use of websites to post burn activity.

This passive mode of coordination would be used regardless of the burn authorization

method that is in placc in a particular geographic area. Land managers/owners and

regulators could use this infonnation to encourage and promote voluntary coordination

among land managers/owners. Burn locations and weather conditions may be posted or

linked at a commOn webpage or series of webpages.

C.2.9.1 Source Sector Authority Coordination

A more advanced coordination concept is that of using burn managers or smoke

coordination centers to actively time burning to avoid cumulative smoke impacts from

burns within a source sector. In addition to creating awareness of other sectors' burning

via tracking information on the web, radio or phone communications would be used to

distribute that burning information to land managers/owners.

A step further in this process is active managcment of burning with coordination

occUlTing between burn managers of different source types. Considerations that would

be taken into account by the burn managers are parameters such as special weather

conditions needed for a particular burn, fire safety considerations, etc. These

considerations can be identified in the early periods of burn planning so that all parties

are aware ofthe rationale behind burn decisions.

C.2.9.2 Centralized Authority Coordination

A centralized coordination authority within a state/tribe provides for a greater level of

control of smoke production and reduction of impacts. In this scenario, potential

state/tribe-wide impacts may be better managed and problems avoided than is the case

with more fragmented coordination points. Central authorities for each source type

would coordinate activities or one central authority would coordinate activities across all

source types. In most cases this coordination would occur through a statewide

coordination center that has access to information from all burning sources. Such a

coordination center would also be more likely to have sophisticated meteorological, air

WRAP ESMP Policy 10/15/02 38
quality, modeling and fire behavior and effects expertise upon which decisions would be

made.

C.2.9.3 Regional (Multi-Stateffribe) Coordination

Burning that creates inter-jurisdictional impacts may require the establishment and use of

multi-state/tribal coordination infonnation procedures. If states'/tribes' Class J areas are

consistently and measurably being impacted by smoke from outside of their own

boundaries, then more infonnation sharing may be needed on day-to-day burning

activities. State/tribe centralized coordination centers would share infonnation and

resources to limit cumulative impacts from external sources as well as from those within

its own boundaries.

Each state's/tribe's central coordination center would prioritize burns in areas that would

be most likely to create cross-jurisdictional impacts. On a regional basis, acres or

emissions may be limited by each state's/tribe's bum authority to minimize air quality

impacts in neighboring areas. Regional meteorological and air quality infonnation would

be shared by coordination centers, with the result being regional approval and real-time

tracking of burns and their smoke impacts.

A segment of fires that arc considered to be natural under the WRAP Fire Categorization

Policy may best be suited for regional coordination opportunities. Such fires are more

likely to be of longer duration and have the greater potential for generating regional haze.

Coordination in this casc may range from monitoring smoke from such fires and

rcporting impacts to nearby states/tribes, to limiting other burning until the smoke from

the natural fires has abated.

Methods for this inter-jurisdiction and regional coordination will necd to be dcvcloped.

The development process should be a collaborative one, involving state, tribal, local and

federal agencies, and private parties. Entities to be involved in this process could include

WRAP, the Western States Air Resources Council (WESTAR), the National Tribal

Environmental Council (NTEC), the Wildfire Leadership Council, the Western States

Fire Managers, and national/regional agricultural organizations.

C. 3 Responsibilities Under an Enhanced Smoke Management Program

Throughout all the enhanced smoke managemcnt program elemcnts outlined in this

Policy, it is assumed that the regulatory authority (i.e., state, tribe, or EPA on behalf of

the tribe) has the oversight for the enhanced smoke management program through its

implementation plan, although it may choose to delegate implementation to another

entity, e.g., county, municipality, fire source sector representative or other nongovernmental organization.

It is the regulatory authority's responsibility to ensure that the mechanisms and

infrastructure are in place to implement the enhanced smoke management program. The

state/tribe is responsiblc to track emissions and detennine the amount of the contribution

WRAP ESMP Policy 10/15/02 39
to visibility impairment in Class I areas. It is also incumbent upon the regulatory

authority to develop a SIPfflP that is consistent with Section 118 of the CAA pertaining

, to equitable treatment of federal activities."2 Finally, failure of the regulatory authority to

develop appropriate and necessary oversight and responsibilities may result in EPA's

disapproval ofthe regional haze SIP/TIP.

It is the land manager's/owner's responsibility to meet the enhanced smoke management

program requirements. The land manager/owner needs to ensure that data and

information submitted to the regulatory authority are accurate, timely, and complete. In

some instances this may be no more onerous than a fonn faxed by the land

manager/owner to the regulatory authority at the end of the year; in others, extensive

infomlation on a daily basis regarding planned and accomplished burning will be

required.

C.4 Funding Mechanisms for Enhanced Smoke Management Programs

Funding for enhanced smoke management programs can come from many possible

sources. Further, funding mechanisms will depend on the magnitude or complexity of the

enhanced smoke management program needed. The following is a list of possible

methods for funding enhanced smoke management programs:

A. Funds obtained from users of prescribed fire.

a. Memorandum of Understanding (MOU)/Memorandum of Agreement

(MOA)/Consortium Funds

• Each member/signatory pays an annual membership fee and there is an

additional per acre fee for accomplished bums.

b. Fees

• Permit Fees

• Emissions-based Fees

• Acreage-based Fees

B. Funds Obtained from Users of Class I Areas

C. Grants and/or Appropriated Funding

• A combination of many sources including EPA grants, state/tribe, city and

county govemments, fire protection assessments, property taxes.

• General revenue program/appropriated funds received from a legislative

body.

D. Provision of Resources

• Fire source sector provides personnel or other resources to aid or manage

the enhanced smoke management program in lieu of direct pelTI1it

payments to defray overall costs of the enhanced smoke management

program.

'" Clean Air Act §118 (a).

WRAP ESMP Policy 10/15/02 40
Western Regional Air Partnership Policy

on

Annual Emission Goals for Fire

Approved by the Western Regional Air Partnership

April 2, 2003

Prepared by the Annual Emission Goals Task Team

of the

Fire Emissions Joint Forum
WRAP Policy

Annual Emission Goals for Fire

Executive Summary

The Western Regional Air Partnership (WRAP) is charged with developing technical and policy

tools to assist states (or the delegated regulatory authority) and tribes with implementing the

Regional Haze Rule (Rule).

The WRAP Policy on Annual Emission Goals for Fire (WRAP AEG Policy) has been developed

over a six-month period through a stakeholder-based consensus process to assist the WRAP region

states and tribes in addressing emissions from fire sources. In this Policy, the WRAP seeks to

provide a consistent framework that states and tribes can use to efficiently develop their individual

implementation plans. The WRAP recognizes states' and tribes' authority and responsibility to

develop, adopt and implement their regional haze implementation plans, and recognizes the Rule as

the principal document on which states and tribes should rely.

The Rule requires states to develop implementation plans (SIPs) for addressing regional haze in the

Nation's 156 mandatory Class I areas. Additionally, the Rule requires effective management offire

sources. The Rule provides two pathways for western states to follow as they implement the

requirements of the Rule: I) develop their regional haze implementation plans per the nationally

applicable provisions of Section 308, or 2) Transp0l1 Region states may choose to incorporatc the

Grand Canyon Visibility Transport Commission (GCVTC) Recommendations into their regional

haze implementation plans under Section 309 of the Rule.

The GCVTC recognized that projected increases in fire activity will result in episodic impacts on

visibility in the West, and called for the development ofannual emission goals that would minimize

these impacts. Section 309 ofthe Rule specifically requires the establishment of annual emission

goals that minimize emission increases from fire to the maximum extent feasible. Further, these

goals must be developed in cooperation with states, tribes, land management agencies and private

entities.

The WRAP defines the annual emission goal as a quantifiable value that is used to measure progress

each year toward the desired outcome ofachieving the minimum emission increase from fire. In this

WRAP AEG Policy, the WRAP outlines a process by which states/tribes may establish annual

emission goals, based on the utilization ofcurrently available emission reduction techniques (ERTs),

to include in their regional haze implementation plans.
Although Section 309 ofthe Rule specifically requires the establishment ofannual emission goals,

the strategy outlined here for the utilization of ERTs could be considered by states and tribes that

choose to follow the requirements ofSection 308 ofthe Rule and/or may be used to protect visibility

in non-mandatory Federal Class I areas.'

Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to assume

the regional haze requirements outlined in the Rule may, according to the CAA, seek approval to be

treated in the same manner as states, under the Tribal Authority Rule (TAR), 40 CFR 49. The intent

of this Policy is to assist both states and tribes with the development of their regional haze

implementation plans (SIPs/TIPs), and therefore, tribes are included in all references to states,

except where specific requirements and/or deadlines of the Rule are cited. In the case of annual

emission goals, the WRAP considers them a viable tool for all tribes in the WRAP region to use to

achieve the minimum emission increase from fire.

The WRAP AEG Policy document is comprised of four major sections. Section I is the seven

WRAP AEG Policy statements. Section 2 provides overall background for the WRAP AEG Policy.

Section 3 is an annotation of each of the seven policy statements, further explaining and defining

them. Finally, the Appendices include (A) a glossary oftenns, (B) a related documents listing, (C)

additional guidance for states/tribes on the implementation of annual emission goals, and 0) an

example of a table that will be developed as a separate guidance document by the WRAP Fire

Emissions Joint Forum for use with annual emission goals.

1 The Rule is only applicable to mandatory Class rareas. States/tribes in the WRAP region may utilize the AEG

Policy 10 protect visibility in non-mandatory Class I areas.

ii
WRAP Policy

Annual Emission Goals for Fire

T ABLE OF CONTENTS

Executive Summary

1. The WRAP Policy on Annual Emission Goals for Fire 1

Policy Statements

2. Background 1

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission I

2.2 Western Regional Air Partnership 2

2.3 Regional Haze Rule 2

3. Annotated Policy 3

3.1 Introduction 3

3.2 Policy Statement A: AEGs Required Under Section 309 4

3.3 Policy Statement B: Annual Emission Goal Defined 4

3.4 Policy Statement C: Applicability 5

3.5 Policy Statement D: Emission Reduction Techniques (ERTs) 6

3.5.1 Implementation Options 8

3.6 Policy Statement E: Feasibility Criteria 9

3.7 Policy Statement F: Utilizing Collaborative Processes 10

3.8 Policy Statement G: Tracking Procedure 10

4. Appendices 11

Appendix A: Glossary II

Appendix B: Related Documents Listing 14

Appendix C: Annual Emission Goal Implementation Guidance 16

I. Applicability 16

III
TABLE OF CONTENTS

2. Regional Haze Implementation Plans

2.1 Section 30S/309 Requirements

2.2 Submission of Periodic Reports

3. Use of ERTs

3. I Califomia

3.2 Oregon

3.3 Washington

3.4 Utah

16

16

17

17

IS

IS

IS

IS

4. Establishment of Annual Emission Goals 19

4. I Current ERT Application 19

4.2 Non-burning Alternatives and Annual Emission Goals 19

4.3 Determination of Appropriate ERTs 20

4.4 Feasibility Criteria 2 I

4.5 Existing Guidance Documents 2 I

4.6 Research Needs 22

4.7 Calculation of Averted Emissions 22

Appendix D: ERT & Associated Emission Averted Table 24

IV
1. WRAP Policy on Annual Emission Goals for Fire

Policy Statements

A) The establishment and implementation ofannual emission goals is a viable technique to controll

fire emissions for WRAP states and tribes. Annual emission goals are required for states under

Section 309 of the Regional Haze Rule.

B) Annual emission goals will achieve the minimum emission increase from fire. Annual emission

goals are quantifiable values that are distinct from emission limits.

C) Annual emission goals are applied to all fire sources (excluding wildfire) due to their potential

impacts on visibility.

0) The minimum emission increase from fire is accomplished through the optimal application of

emission reduction techniques, which provides the basis for annual emission goals.

E) The use of emission reduction techniques to achieve annual emission goals is subject to

economic, safety, technical and environmental feasibility criteria, and land management objectives.

F) States, tribes or the designated authority will establish annual emission goals in cooperation with

federal land management agencies and private entities on a yearly basis.

G) States and tribes will need to develop a procedure for verifying the use of emission reduction

techniques and for tracking the achievement of annual emission goals.

2. Background

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission

In 1990, Congress amended the Clean Air Act (CAA), and as part ofthese amendments created the

Grand Canyon Visibility Transport Commission (GCVTC)3 The GCVTC was charged with

assessing the current scientific infonnation on visibility impacts and making recommendations for

addressing regional haze in the western United States. The GCVTC signed and submitted more than

70 reconunendations to the Envirorunental Protection Agency (EPA) in a report dated June 1996 that

indicated that visibility impainnent was caused by a wide variety ofsources and pollutants, and that

a comprehensive strategy was needed to remedy regional haze.

2 "Control" as used in this Policy means the use of techniques that result in a quantifiable reduction in emissions from

individual fire sources.

3The GCVTC was composed ofthe governors ofeight western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes

(Acoma Pueblo, Hopi, Hualapai, and Navajo), four Federal land management agencies (Bureau ofland Management,

U.S. Fish and Wildlife Service, u.s. Forest Service, National Park Service), the Columbia River Inter~Tribal Fish

Commission, and the Environmental Protection Agency.
The GCYTC Report recognized that fire plays a significant role in visibility on the Colorado

Plateau. According to the GCYTC Report, emissions from wildfire and prescribed fire are "an

important episodic contributor to visibility-impairing aerosols, including organic carbon, elemental

carbon, and particulate matter (PM2.S).'" The GCYTC Report also stated that agricultural burning

emissions and their effects have been identified as a concern, but have not been quantified due to

insufficient data5

2.2 Western Regional Air Partnership

The Western Regional Air Partnership (WRAP) was established in 1997 as the successor

organization to the GCYTC. The WRAP is a voluntary organization comprised of western

governors, tribal leaders and federal agencies,6 and is charged "to identify regional or common air

management issues, develop and implement strategies to address these issues, and formulate and

advance western regional policy positions on air quality.,,7 These policies and technical tools are

developed through inclusive, stakeholder-based processes and approved by consensus ofthe WRAP.

WRAP participants include state air quality agencies, tribes, federal/state/private land managers, the

EPA, environmental groups, industry, academia and other interested parties. There are over 400

tribes within the WRAP region. The large number oftribes limits the participation of all ofthem in

WRAP activities, and accordingly, in the development of this Policy. Therefore, the tribal

representatives involved in the development ofthis Policy may not represent all tribal concerns.

2.3 Regional Haze Rule

Following the issuance of the GCYTC Report, the EPA issued the Regional Haze Rule (Rule) in

July 1999 to improve visibility in 156 national parks and wilderness areas across the country. The

Rule outlines the requirements for states and tribes to address visibility impairment in mandatory

Class I areas due to emissions from all sources, including fire activities. EPA incorporated all ofthe

GCYTC recommendations into Section 309 ofthe Rule, which may be used by some ofthe WRAP

states/tribes. The remaining WRAP states must utilize the nationally applicable Section 308

provisions ofthe Rule.

Tribes are not subject to the same requirements ofthe Rule as states, but tribes wishing to assume

the regional haze requirements outlined in the Rule may, according to the CAA, seek approval to be

treated in the same manner as states, under the Tribal Authority Rule (TAR), 40 CFR 49. 8 In these

,

GCVTC Report, p. 47.

sIbid.

6 The WRAP membership is comprised of the governors of thirteen western states and thirteen western tribes. The

current WRAP members include the States ofAK, AZ, CA, CO,!D, MT, ND, NM, OR, SD, UT, WA, and WY, and the

Tribal Nations of Pueblo ofAcoma, Campo Band ofKumcyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai

Nation of the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes,

Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the Department of the

Interior, the Department of Agriculture, and the Environmental Protection Agency.

7 WRAP Charter, Purpose, p. I.

x 64 FR 35759.

2
cases, EPA still recognizes that "unlike States, tribes are not required by the TAR to adopt and

implement CAA plans or programs, thus tribes are not subject to mandatory deadlines for submittal

ofimplementation plans.,,9 Although provision for flexibility in the submission of programs and

implementation plans for tribes is made under TAR, EPA does "encourage tribes choosing to

develop implementation plans to make every effort to submit by the deadlines to ensure that the

plans [TIPs] are integrated with and coordinated with regional planning efforts."'o

EPA recognizes the WRAP as the Regional Planning Organization that is developing the necessary

policy and technical tools to implement the Rule in the WRAP region. A WRAP policy, once

approved, represents the WRAP's consensus position on the best means for states and tribes to

implement the portion of the Rule at issue.

The WRAP recognizes states' and tribes' authority and responsibility to develop, adopt and

implement their regional haze state and tribal implementation plans, and the seminal guidance to do

this is the Rule. '1 States are required by the Rule to submit periodic reports to the EPA to assess the

adequacy ofthe implementation plan. Ifthe state detenllines that the implementation plan is or may

be inadequate to meet reasonable progress goals, the state is required to develop additional strategies

to address deficiencies in the plan. These strategies are then submitted to EPA for approval.

3. Annotated Policy

3.1 Introduction

The WRAP AEG Policy is the result of the WRAP region-wide, multi-state/tribe stakeholder

planning and coordination effort. The intent of the WRAP AEG Policy is to assist states (or the

delegated authority) and tribes to address smoke impacts on visibility associated with fire in a way

that is adequate for SIP/TIP implementation.

The WRAP AEG Policy provides states and tribes with a consistent method for the identification,

use, and tracking of emission reduction techniques (ERTs) to meet the annual emission goals

requirement ofthe Rule. Although this Policy promotes the use ofERTs to meet the annual emission

goals requirement of Section 309 of the Rule, it does not prescribe how each state/tribe integrates

this Policy into its regional haze SIP/TIP or limit the use of alternative approaches to the

implementation of annual emission goals.

This WRAP AEG Policy has been developed to embody appropriate regulatory and policy

requirements and to provide a predictable framework for annual emissions goals that can be

reasonably implemented by states and tribes. The WRAP believes that states maintain the ultimate

responsibility for the implementation of annual emission goals. Further, states are responsible for

incorporating into their implementation plans federally enforceable processes to minimize emission

increases from fire, whether they choose to use ERTs or some other method that meets Rule

requirements. Tribes, or EPA on their behalf, may choose to utilize, as a severable element, annual

'64 FR 35758.

'0 64 FR 35759.

" WRAP Charier, p.l.

3
emission goals in their implementation plans. The WRAP recognizes that the implementation plans

will be revisited and revised, per the schedule specified in the Rule, giving opportunities to refine

individual programs for annual emission goals that reflect technical advances and policy updates. ,

3.2 Annual Emission Goals Required Under Section 309

Policy Statement A: The establishment and implementation 0/annual emission goals is a

viable technique to controlfire emissions/or WRAP states and tribes. Annual emission goals

are required/or states under Section 309 o/the Regional Haze Rule.

In this Policy, the WRAP seeks to provide a consistent and equitable framework that states and

tribes can use to efficiently develop their regional haze implementation plans (SIPs/TIPs). Under

Section 309, the Rule calls for "establishment ofannual emission goals for fire (excluding wildfire)

that will minimize emission increases from fire to the maximum extent feasible.,,1l The Policy can

be considered by all other states and tribes as a means to control fire emissions, and annual emission

. goals are a viable technique for controlling fire emissions if a state's or tribe's visibility impainnent

analysis for Section 308 of the Rule shows that fire sources contribute to visibility impainnent in a

mandatory Class I area.

3.3 Annual Emission Goal Defined

Policy Statement B: Annual emission goals will achieve the minimum emission increasefrom

fire. Annual emission goals are quantifiable values that are distinct{rom emission limits.

In its Report, the GCVTC acknowledged federal and state land managers' projection of"significant

increases in prescribed fire in order to reduce the effects of wildfire resulting from past decades of

fire suppression.,,13 The Rule also recognized that "forest fuels have built up over many years due to

past management practices designed to protect public health and safety through fire suppression."

And further, that this has " ...Ied to an increased risk ofcatastrophic wildfire ..... which would need to

be offset by "the increased use of prescribed fire ....,,14

This increase in fire activity prompted the GCVTC to recommend the establishment of annual

emission goals that would minimize increases from fire emissions, which the Rule then adopted as a

requirement under Section 309. 15 The Rule utilizes the GCVTC's terminology in Section 309 and in

the Preamble, both in its section on the Treatment of the GCVTC Recommendations and in the

Annex to the GCVTC Report. 16 Therefore, for its definition of "annual emission goal" the WRAP

looked to the GCVTC Report.

Although not fonnally defined, the tenn "goal" is specifically used in the GCVTC Report in the

contexts ofboth Area Sources and Air Pollution Prevention to focus efforts on a desired outcome."

12 64 FR 35771 ~51.309 (d)(6)(v). 13 GCVTC Report, p. 23.

14 64 FR 35735.

15 GCVTC Report. p. 50.

16 64 FR 35748 and 35756.

" GCVTC Report. p. 30.

4
This desired outcome may have a numeric meas'ure associated with it, but is distinct from a lilnit.

The GCVTC defines both the terms "cap" and "target" as emissions limits, and uses them in its

section on Stationary Sources. I. The GCVTC also distinguishes between "target" and "cap" as

follows:

... "targets" are intended as finn limitations on emissions and have the same effect as a

"cap." However, we are reserving the tenn "cap" to refer to the limits set under a

regulatory program, which would be triggered if the "targets" are exceeded. 19

In using the term goal, and not target or cap, the GCVTC clearly intended the annual emission goal

to be something other than an emission limit, and that it not have the attendant regulatory

consequences of a cap, as supported by the specific use ofthese terms in its Report. Therefore, the

WRAP AEG Policy defines annual emission goals as quantifiable indicators ofprogress toward the

desired outcome of minimizing increases from fire emissions.

In distinguishing between goals and limits, it is not the intent of this Policy to preclude the

establishment of emission limits. However, it currently does not appear that an adequate fire

emissions inventory exists throughout the WRAP Region to support the establishment of an

emissions limit on fire sources.'o The WRAP does recognize that scientific advances may support

the feasibility of an emissions limit (either target or cap) in the future.

3.4 Applicability

PoliCY Statement C: Annual emission goals are applied to all fire sources (excluding

wildfire) due to their potential impacts on visibility.

The Rule, the GCVTC and WRAP policy development to date acknowledge that all types of fire

must be addressed equitably as part of a visibility protection strategy since all fire contributes to

regional haze.'1 Therefore, the WRAP AEG Policy applies to all fire sources, except for wildfire,

which is specifically excluded in Section 309 of the Rule 22

"GCVTC Report, p. xi and pp. 32-37.

19 GCVTC Report, p. 34, fool note 4.

20 In order to implement all emission limit, states/tribes would need to havc emissions inventory data adequate to

establish an emissions bascline, establish lhe baseline, conduct periodic evaluations ofthe effectiveness ofthe basel ine,

and institute sufficient enforcemcnlmcchanisms. Even so, the basel inc may not be a reliablc tool due to the variability of

fire emissions.

21 GCVTC Report, p. 47. 64 FR 35735, WRAP ESMP and Fire Calegorizalion Policies.

22 64 FR 35771 §51.309 (d)(6)(v).

5
The Rule excludes wildfire from the annual emission goals requirement of Section 309 due to the

inability to directly control the emissions from wildfires. The same concern would be relevant to

states under Section 308 or tribes that choose to use annual emission goals as a method to control

fire emissions.

This Policy applies to federal, tribal, and state land managers and to private landowners that use

prescribed fire, wildland fire used for resource benefits (WFU)2J or agricultural burning to achieve

land management objectives on agricultural land or wildland.24 In accordance with Section 118(a)

ofthe CAA requiring that all entities, federal and non-federal, be subject to the same requirements,

authorities and processes,25 the WRAP AEG Policy will be applied equitably to all fire sources,

excluding wildfire.

The WRAP AEG Policy specifically does not apply to Native American cultural non-vegetative

burning for traditional, religious, or ceremonial purposes (e.g., cremation, sweat lodge fires).'6 Nor

does it apply to open burning activities on residential, commercial, or industrial property (e.g.,

backyard burning, garbage incineration, residential wood combustion, construction debris).27

However, states/tribes may choose to consider the impacts of these fire sources when developing

their regional haze implementation plans.

3.5 Emission Reduction Techniques CERTs)

Policy Statement D: The minimum emission increasefromfire is accomplished through the

optimal application ofemission reduction techniques, which provides the basisfor annual

emission goals.

The WRAP AEG Policy provides a practical approach to establishing annual emission goals that

states and tribes can use in their implementation plans. The WRAP has developed the AEG Policy to

address three issues central to this visibility protection strategy.

First, annual emission goals are to be developed on an annual basis, for each year, and therefore

need to be based on a measure that can be determined in one year's time. The annual level of fire

activity is dependent on a variety ofexternal factors such as crop type planted, funding for federal or

state fire programs, weather, etc. These factors will also influence the potential use offire emission

control strategies. In order to accommodate this variability and address the annual nature of the

Rule requirement, annual emission goals are to be determined each year through a collaborative

process between burners and the regulatory jurisdiction.

Second, since annual emission goals are not emission limits, the goal is based on the sole purpose of

minimizing emission increases from fire to the maximum extent feasible; therefore, annual emission

23 Also known as Prescribed Natural Fire (PNF).

24 WRAP Policy for Categorizing Fire Emissions, November 15,2001 (hereafter referred to as "WRAP Fire

Categorization Policy"), p. 8. See also Appendix C for further details.

2S Clean Air Act § 118(a).

26 WRAP Fire Categorization Policy, p. 24.

27 Ibid, however "industrial property" would not include land such as industrial forestland.

6
goals can reasonably be tied to actions that have this result. Under this Policy, the process for

establishment ofthe annual emission goal, rather than the specific numeric value (which varies from

year to year), will be included in implementation plan submittal. In other words, the goal will focus

on the efforts to minimize emissions; this process, being in the implementation plan, will be

federally enforceable.

Third, the WRAP region represents wide variety with regard to basic fire activity tracking, fire

emissions data, and fire use, and therefore, the annual emission goals strategy will need to be one

that is both flexible and practical. The strategy must also be capable of being implemented using

tools and information currently available to meet the Section 309 deadline ofDecember 31, 2003.

To address these issues, the WRAP AEG Policy focuses on minimizing fire emission increases

through the control ofemissions on all fire projects where feasible. Control offire emissions means

utilizing methods that result in a reduction ofthe total amount ofemissions generated from each fire

project. Control offire emissions is accomplished by using emission reduction techniques (ERTs),

methods proven to reduce fire emissions.,.

ERTs include biomass utilization prior to burning, increasing combustion efficiency, and others.'9

Additionally, methods exist for tracking and calculating the emissions averted from the use ofERTs

for a broad array of vegetation types. For the purposes of this Policy, non-burning alternatives are

not ERTs. Non-burning alternatives are techniques that replace fire as a means to achieve a

particular land management objective (e.g., reduction of fuel-loading, enhancement of wildlife

habitat, etc.)30

Control measures are distinct from smoke management techniques, which are currently used in the

West by land managers to minimize smoke impacts on public health, nuisance and visibility. A key

smoke management technique is the timing of ignitions for better smoke dispersion with the

intention of avoiding smoke impacts to sensitive areas (e.g., non-attainment areas, Class I areas,

nearby communities). Smoke management techniques may give consideration to downwind air

quality (e.g., nuisance impacts and National Ambient Air Quality Standards [NAAQSD and

visibility/regional haze.

The emission reductions that are achieved through the use of ERTs are calculated on a projectspecific basis, otherwise refelTed to as the operational phase of the fire project. The decision to burn

a specific area has already been made prior to the implementation of a specific project; therefore,

project-specific basis refers to projects where fire will be used to meet land management objectives.

Annual emission goals, under this Policy, are established annually and apply to the upcoming year's

projects where fire has been determined as the best tool for meeting specific land management

objectives. The annual emission goal in this case would be the sum of emission reductions from all

fire projects where ERTs are used across the state or tribal jurisdiction, for the upcoming year.

28 The GCVTC projected that the use of optimal smoke management measures (which include the use of ERTs) could

decrease fine particle (PM2.5) emissions from prescribed fires by approximately 15-20%. This resulted in modeled

visibility improvements over the planning period of the GCVTC. GCVTC Report, p. 87.

29 See Appendix C for more examples ofspecitic ERTs and the application ofERTs.

30 For a more detailed discussion of non-burning alternatives, see Section 4.2 of Appendix C.

7
3.5.1 Implementation Options

Two options for the utilization ofERTs to meet the annual emission goal have been outlined below.

These options are based on current use of ERTs, science and technology. The first option is based

on estimations ofemissions averted through the application ofERTs, and allows the calculation of

an annual numeric value that indicates progress toward minimizing increases from fire emissions.

The second option is provided for instances where estimates of emissions averted are not feasibly

calculated due to insufficient data. ln this second option, the annual numeric value is based on total

percent use of ERTs with subsequent emission reductions inferred.

The two options explored here are not exhaustive or definitive in structure or design. Application of

these or any other options can be considered for each individual fire source sector or for

combinations ofthem. All options for use ofERTs are subject to the feasibility criteria as outlined in

Policy Statement E. Additionally, state/tribal authorities will want to be mindful of equitable

treatment of sources in the implementation of ERTs.

In eithcr Option I or Option 2, state/tribes will need to detennine the appropriate ERTs to be used

for specific vegetation or crop types that will be treated to allow attainment of land management

objectives. It is a common practice to apply a certain ERT to a specific vegetation or crop type,

although more than one ERT may be feasible for a certain vegetation or crop type. Next, in

establishing annual emission goals, the designation ofall appropriate ERTs for each ofthe identified

vegetation or crop type needs to be completed.

For use in this process, Appendix 0 provides an example ofa table that will correlate the use of

ERTs with emissions averted. Appendix 0 wi II be augmented by subsequent guidance by the WRAP

Fire Emissions Joint Forum (FEJF) that will summarize ERT options for common vegetation and

crop types for both prescribed fire on wildlands and agricultural burning. This guidance document

can be used in combination with known local practices to detennine appropriate ERTs for the

respective vegetation or crop type.

Option I

Once applicable ERTs for the respective vegetation or crop type are agreed upon, the

potential percentage use of ERTs is determined subject to the feasibility criteria for the

specific project. The potential percentage use is estimated by detennining the portion ofthe

project where ERTs are to be applied. Then an estimate of the emissions averted can be

made. The annual emission goal is the emissions averted through the use of ERTs for all

projected fire projects across the state or tribal jurisdiction.

8
Option 2

An estimate of emissions averted may not be feasible if ERT emission factors are not

available (i.e., the specific amount ofemissions reduction has not been determined through

research). In this case, the annual emission goal is the percent of total acres on which ERTs

are used where fire is to be employed across a state or tribal jurisdiction for the upcoming

year.

Although annual emission goals using ERTs can be established unilaterally across fire source sectors

for either Option I or 2, there are benefits to establishing them by source sector so as to account for

differences in management practices between agricultural and wildland burning, as well as in the

availability of ERTs. Establishing the annual goal using ERTs by source sector may also alleviate

equity issues since the goal is applied across projects with similar vegetative or crop types and land

management objectives. The annual goal should be established after the evaluation ofall potentially

applicable ERTs.

This Policy encourages states/tribes to coordinate with neighboring states/tribes to improve the

knowledge base of ERTs and to maintain consistency in calculating emissions averted. Interstate

coordination is key for minimizing visibility impacts in mandatory Federal Class I areas and for

addressing regional haze in the WRAP region31

3.6 Feasibility Criteria

Policy Statement E: The use ofemission reduction techniques to achieve annual emission

goals is subject to economic, safety, technical and environmental/easibUity criteria, and

land management objectives.

The feasibility of ERT use is variable and dependent on criteria as established in the WRAP Fire

Categorization Policy:

Per the GCVTC Recommendations, economic, safety, technical and environmental

considerations are part of the application of emission controls for the implementation of

this Policy statement. Due to these considerations, the control of emissions from some

fire types may not be feasible, which wi II be determined by the land manager in

collaboration with the applicable air quality regulatory authority.32

The WRAP AEG Policy also recommends that land management objectives be included in these

criteria during the decision-making process to ensure that ERTs are used appropriately and at levels

ofusage that are feasible. Itshould be noted that the specific land management objective for an area

could preclude the use ofa specific ERTwhere that ERT would prevent the attainment of the land

management objective, e.g., ifthe land management objective is to reduce downed large fuels in an

area, the use of burning under high fuel moisture of large woody fuels (i.e., the ERT being

31 64 FR 35728.

32 WRAP Fire Categorization Poliey, p. II.

9
considered) would not be an option. See Appendix C for more detailed infonnation on the

application ofERTs.

3.7 Utilizing Collaborative Processes

Policy Slatemeni F: States. Iribes or Ihe designated aUlhorily will eSlablish annual emission

goals in cooperalion wilhjederalland managemenl agencies andprivale enlilies on a yearly

basis.

Section 309 of the Rule requires that annual emission goals are "established in cooperation with

States, tribes, Federal land management agencies, and private entities 33 In addition, the WRAP's

policies on fire to date endorse the importance ofusing this collaborative process. Annual emission

goals will be reviewed and revised on a yearly basis. Coordination within states and across

jurisdictional boundaries is key for minimizing visibilit~ impacts in mandatory Federal Class I areas

and for addressing regional haze in the WRAP region. 4

3.8 Tracking Procedure

Policy Slatemeni G: Siaies and Iribes will need 10 develop a procedurejor verifying Ihe use

ofemission reduclion lechniques andjorlracking Ihe achievemenl ofannual emission goals.

A procedure for verifying the use of ERTs should be developed. Such a procedure could also

faci litate the state's/tribe's ability to ensure accountability ofindividual sources in utilizing ERTs. A

state's/tribe's fire tracking system, as based on the WRAP Fire Tracking System (FTS) Policy, could

be augmented to provide a repository for the verification infonnation.

The verification ofthe use ofsome ERTs could also be done indirectly, for example by tracking fuel

moisture.

Procedures for tracking the actual emissions averted (Option I) and/or the actual percent of total

acres On which ERTs are used (Option 2) should be developed. At year-end, these actual values can

then be compared to the estimated value(s) for that year to assess whether annual emission goals are

being met and for the purposes of establishing the next year's annual emission goals. A

state's/tribe's fire tracking system could be developed to support the tracking ofthe achievement of

annual emission goals.

States/tribes can utilize the tracking procedure for the annual emission goal as a means for assessing

the effectiveness ofthe control measures (i.e., ERTs) in their SIPs/TIPs. States under Section 309 are

required to submit periodic reports to EPA that assess the effectiveness of their control measures,

including " ...a summary of the emissions reductions achieved throughout the State through

implementation ..." ofsuch measures35

J3 64 FR 35771 §51.309(d)(6)(v).

34 64 FR 35728.

35 64 FR 35772 §51.309(d)( 1O)(i)(A).

10
4. Appendices

Appendix A

Glossary

Agricultural Fire/Burning - Any fire ignited by management actions to meet specific objectives (i.e.,

managed to achieve resource benefits) on agricultural land.

Agricultural Land - Agnculturalland includes croplands, pasture, and other lands on which crops or

livestock are produced. Rangeland will be included with wildland for the purposes of the Fire

Emissions Joint Forum work.

Alternatives to Burning - See Non-buming Alternatives definition below.

Best Available Control Measures (BACM) - A term used to refer to thc most effective measures

(according to EPA guidance) for controlling small or dispersed particulates and other emissions from

sources such as roadway dust, soot and ash from woodstoves and open burning of brush, timber,

grasslands, or trash.

Best Management Practices <BMPs) - A term applied collectively to any administrative or on-theground procedure that reduces the negative impacts of some action. An example of a Best

Management Practice with respect to air quality would be conducting a prescribed bum when

atmospheric ventilation is good, which in tum promotes smoke dispersal.

Control - To reduce emissions from an individual fire source.

Class I Area - An area set aside under the Clean Air Act to receive the most stringent protection

from air quality degradation. Mandatory Class I Federal Areas are: I) international parks, 2)

national wilderness areas and memorial parks larger than 5,000 acres in size, 3) national parks that

exceed 6,000 acres in size and which were in existence when the 1977 Clean Air Act amendments

were enacted. The extent of a mandatory Class I Federal area includes subsequent changes in

boundaries, such as park expansions. Class I areas can also include lands designated by states or

tribes, but these areas are not deemed mandatory by the Clean Air Act.

Emission - Pollution discharged into the atmosphere from smokestacks, other vents, and surface

areas of commercial or industrial facilities; from residential chimneys; from motor vehicle,

locomotive, aircraft, or other non-road engines; and from area sources such as fire.

Emission Cap - An enforceable limit on the amount ofspecific air pollutants that can be released or

on the amount ofa specific pollutant that is allowed to be in the air in a defined geographic area, and

that has regulatory consequences. See also Emission Goal and Emission Target.

11
Emission Goal - A desired future outcome that may be represented by a numeric indicator, but

without regulatory consequences, and as distinguished from a limit (i.e., target or cap). See also

Emission Cap and Emission Target.

Emission Reduction Technique (ERT) - A technique for controlling emissions from prescribed fires

to minimize the amount of emission output per unit of area bumed.

Emission Target - A finn limit on the amount ofspecific air pollutants that can be released or on the

amount of a specific pollutant that is allowed to be in the air in a defined geographic area, but

without regulatory consequences (as distinguished from a cap). See also Emission Cap and Emission

Goal.

Enhanced Smoke Management Program (ESMP) - A program for fire that considers visibility

effects, in addition to health and nuisance objectives, and is based on the criteria of efficiency,

economics, law, emission reduction opportunities, management objectives, and reduction of

visibility impact.

fire - When this tenn ~pp~ars, it refers inclusively to wildfire, prescribed natural fire/wildland fire

managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.

Land Managers - When this term appears, it refers inclusively to federal, state, tribal, and private

land managers.

Non-burning Alternatives to Fire - Techniques that replace fire as a means to achieve a particular

land management objective (e.g., reduction offuel-loading, manipulation offuels, enhancement of

wildlife habitat, ecosystem restoration, etc.). In this Policy, non-burning alternatives do not include

techniques used in conjunction with fire. Techniqucs used in conjunction with fire are referred to as

ERTs.

Prescribed fire - Any fire ignited by management actions to meet specific objectives, i.e., managed

to achieve resource benefits.

Rangelands - Land on which the historic climax plant community is predominantly grasses, grasslike plants, forbs, or shrubs. Includes lands re-vegetated naturally or artificially when routine

management of that vegetation is accomplished mainly through manipulation of ecological

principles. Rangeland includes natural grasslands, savannas, shrub lands, most deserts, tundra,

alpine communities, coastal marshes and wet meadows (Natural Resources Conservation Service

National Range and Pasture Handbook, 1997.)

Regional Haze - Visibility impainnent caused by the cumulative air pollutant emissions from

numerous sources over a wide geographic area.

Smoke Effects - The effects on visibility (both plume blight and regional haze), public nuisance, and

the health-based NAAQS due to emissions from fire.

12
Smoke Management - Progrmlls, practices, and techniques to minimize and/or reduce smoke

emissions or impacts from fire.

State Implementation Plan (SIP) - Plans devised by states to cany out their responsibilities under the

Clean Air Act. SiPs must be approved by the U.S. Environmental Protection Agency and include

public review.

Transport Region State - One of nine states that make up the Grand Canyon Visibility Transport

Region: Arizona, California, Colorado, idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming.

Tribal Implementation Plan (TiP) - Plans devised by tribes to cany out their responsibilities under

the Clean Air Act. TiPs must be approved by the U.S. Environmental Protection Agency and

include public review.

Wildfire - Any unwanted, non-structural fire.

Wildland - An area where development is generally limited to roads, railroads, power lines, and

widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less frequently than

once in 10 years), is not fallow, and is not in the USDA Conservation Reserve Program (CRP). The

land may be neglected altogether or managed for such purposes as wood or forage production,

wildlife, recreation, wetlands, or protective plant cover (EPA Interim Air Quality Policy on

Wildlands and Prescribed fires). The land is not "agricultural land" as operationally defined above.

Silviculturalland and rangelands (per the fEJf charge), woodlots, and private timberlands will be

included with wildlands for the purposes of the fEJf work.

13
Appendix B

Related Documents Listing

Regional Haze Rule

Published in the federal Register on July I, 1999,64 fR 35714.

http://www.epa.gov/ttn/oamg/tIIfr notices/rhfedreg.pdf

EPA Interim Air Quality Policy on Wildland and Prescribed Fire

U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland

and Prescribed fires, April 23, 1998.

http://www.epa.govIttn!oamg/tIImemoranda/firefnI.pdf

Prescribed Burning Background Document and Technical Information Document for

Prescribed Burning Best Available Control Measures

U.S. EPA, Office of Air Quality Planning and Standards, September 1992.

Research Triangle Park, NC. EPA-450/2-92-003.

http://www.epa.gov/ttncaaal/tlbid.htmi

AAQTF Recommendation on Air Quality Policy

Agricultural Air Quality Task force, Air Quality Policy on Agricultural Burning,

Recommendation to the U.S. Department of Agriculture, November 10, 1999.

http://fargo.nserl.purdue.edu/faca/Archives/2000/Policy/Burning%20Policy.htm

Tribal Authority Rule

Published in the federal Register on february 12, 1998,63 fR 7253.

http://www.epa.!!ov/fedrgstr/EPA-AIR/1998/february/Day-12/a3451.htm

Smokc Management Guide for Prescribed and Wildland Fire

National Wildfire Coordinating Group fire Use Working Team (NWCG), 2001 Edition.

http://www.nwcg.gov

On the WRAP Website (http://www.wrapair.org);

Grand Canyon Visibility Transport Commission Report

Grand Canyon Visibility Transport Commission, Recommendations for Improving Western

Vistas, Report to the U.S. EPA, June 10, 1996. Go to About WRAP, then the GCVTC link.

WRAP Policy for Categorizing Fire Emissions

Approved by the Western Regional Air Partnership, November 15,2001. Go to the fEJf Task

Teams, then Natural Background.

WRAP Policy on Enhanced Smoke Management Programs

Approved by the Western Regional Air Partnership, November 12,2002. Go to the fEJf Task

Teams, then Enhanced Smoke Management Programs.

14
WRAP Policy on Fire Tracking Systems

Approved by the Western Regional Air Partnership, April 2, 2003. Go to the FEJF Task Teams,

then Fire Tracking Systems.

Non-Burning Management Alternatives on Agricultural Lands in the Western United

States

Go to FEJF Task Teams, then Non-Burning Alternatives on Agricultural Lands.

WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for

Prescribed Fire, Wildfire and Agricultural Burning (DRAFT).

Go to FEJF Task Teams, then Emissions.

WRAP Charter

Go to About, the to Charter.

.Class I Area Map

Go to About, then the WRAP Map.

15
Appendix C

Annual Emission Goal Implementation Guidance

I. Applicability

As this Policy builds On the WRAP Fire Categorization Policy, the scope and applicability in regard

to the "anthropogenic" or "natural" classifications defined by the WRAP Fire Categorization Policy

is clarified below. Those interested should consult the WRAP Fire Categorization Policy for further

detail.

Fire Categories36 WRAP AEG Policy Applicability

"Natural" Sources

• Wildfire Exempted by Rule

• Prescribed fire (including WFU) Covered

used for ecosystem maintenance

purposes

• Native American cultural burning Covered

for traditional, religious, and

ceremonial purposes

"Anthropogenic" Sources

• Prescribed fire (including WFU) Covered

used for any purpose except

ecosvstem maintenance

Other Sources

• Native American cultural non- Not Covered

vegetative burning

• Other open burning activities Not Covered

2. Regional Haze Jmplementation Plans

2.) Section 308/309 Requirements

It is anticipated that annual emission goals will be incorporated into the Section 309 implementation

plans submitted to EPA in order to meet the requirements ofthe Rule. States/tribes complying with

Section 309 are required to have a regional haze implementation plan that addresses the 16

mandatory Federal Class 1 areas of the Colorado Plateau submitted by December 31, 2003, with

implementation ofcertain control measures, including annual emission goals, by the following year.

All other mandatory Federal Class J areas in the GCVTC transport region will be addressed by 2008

under the Section 308 or 309 implementation plan schedule.

)(, WRAP Fire Categorization Policy, p.8.

16
Although Section 309 of the Rule specifically requires the establishment of annual emission goals

for fire, the methods that are promoted in this Policy could be considered by states/tribes that choose

to follow the requirements of Section 308 of the Rule as a viable means to control fire emissions.

The Rule requires under Section 309 that annual emission goals for fire (excluding wildfire) be

established through 2018 as a means for demonstrating reasonable progress requirements. 37 The

WRAP considers this approach to have merit beyond 201838 Section 309 states may need to

consider developing further contingency measures, e.g., a regional application of annual emission

goals, in their implementation plans if the annual emission goals do not adequately minimize

emission increases from fire. The annual emission goal approach is a viable strategy to control fire

emissions and, therebY, make reasonable progress toward the attainment of natural conditions by

2064, as required by the Rule.

2.2 Submission of Periodic Reports

Beginning in 2008, stales are required by the Rule to submit periodic reports to the EPA to assess

the adequacy ofits implementation plan, including assessing the adequacy ofcertain elements, such

as the annual emission goals. These periodic reports are due every five years. Ifthe state determines

that the implementation plan is or may be inadequate to meet reasonable progress goals, the state is

required to develop additional strategies to address deficiencies in the plan. These strategies are then

submitted to EPA for approval.

3. Use or ERTs

ERTs are proven to be effective methods to control fire emissions and are applied in different ways

by regulatory authorities. for example, some regulatory authorities promote the use ofERTs as part

ofa voluntary management program while others enforce the use ofERTs through rule making. For

example, the California Agricultural Burning Guidelines enforce the use of ERTs by specifying

requirements for the burning ofrice, barley, oat, and wheat straw. The Guidelines require the use of

a "crackle test" to detennine ifthe fuel is dry enough to burn. In the state ofWashington, wildland

land managers are encouraged to use techniques, such as fans, crane piling, mass ignition,

accelerated mop-up, and other methods of increasing combustion efficiency and reducing the

smoldering stage of burning.

Although a few states in the WRAP region do promote or require the use of ERTs and specify

burning conditions that must be met in order to burn, currently no systems are in place to track the

emissions averted from the application of such methods across all fire source sectors. CUITently

programs do exist in some areas for tracking of emissions averted through the use of ERTs for

wildland prescribed fires.

37 64 FR 35771 §51.309 (d)(6)(v).

38 WRAP Initiatives Oversight Committee (lOC), Transmittal Leuer, November 15,200 I, Appendix C of the

WRAP Fire Categorization Policy.

17
The following paragraphs provide a summary ofsome ofthe current efforts by regulatory entities to

use ERTs as a means to reduce emissions from prescribed fire and agricultural burning.

3.1 California

Title 17 of the California Code of Regulations requires district smoke management programs to

include general burning requirements for agricultural burning, prescribed burning, and prescribed

fires in wildland and wildland/urban interface areas. In addition to the general requirements, the law

includes specific requirements for rice, barley, oat, and wheat straw, such as certain firing techniques

and specific burning windows. There are also specific fuel moisture burning requirements for rice

straw burning.

3.2 Oregon

In Oregon the rules for agricultural burning include, but are not limited to, measures to ensure that

crop residues are evenly distributed and in good burning condition, rapid ignition techniques are

employed, and alternatives to open burning of fields are considered. For prescribed fires on

wildlands, the Oregon Smoke Management Program requires land managers to consider utilization

of residue, fuel reduction measures, alternate treatment practices, and reduction of prescribed

burning emissions to achieve emissions reduction goals established within the Oregon Visibility

Protection Plan. Burning during the spring when the 1ODD-hour and larger fuels have high fuel

moisture is promoted. Post-burn reports require the tracking of fuel moisture content, ignition

method, and other infonnation to support calculation of ERT use.

3.3 Washington

In Washington, wildland land managers are encouraged to use techniques, such as fans, crane piling,

mass ignition, accelerated mop-up, and other methods of increasing combustion efficiency and

reducing the smoldering stage of burning. No tracking ofspecific ERTs is required. The Washington

Smoke Management Plan for silvicultural burning does establish a tracking system to measure

progress toward specifIc emission reduction targets. Bum days and specific burning conditions are

established by the Department of Ecology for agricultural burning and a permitting system is in

place.

3.4 Utah

Agricultural burning is not regulated by the State of Utah. However, counties require such bums to

be conducted during optimal dispersion conditions. State air quality regulations require wildland

land managers to take measures to prevent smoke impacts. State law requires identification of best

management practices including the use of ERTs. Land managers are required to identiJY the

techniques that are employed in addition to fuel moisture and ignition method in their daily

emissions report.

18
4. Establishment of Annual Emission Goals

4.1 Current ERT Application

Research has shown that ERTs can result in emission reductions, which, in turn, reduce smoke

impacts on air quality. According to the National Wildfire Coordination Group's (NWCG) Smoke

Management Guidefor Prescribed and Wildland Fire, methods used to reduce emissions generated

from prescribed burning on wildlands are: reducing the area burned, reducing fuel loading, reducing

fuel production, reducing fuel consumed, scheduling burning before new fuels appear, and

increasing combustion efficiency.'9

EPA's Prescribed Burning Background Document and Technical Information Document for

Prescribed Burning Best Available Control Measures states that the methods for reducing the

amount of emissions generated from agricultural burning include: reducing the acres burned

annually, altering the fuel distribution, improving firing techniques, and buming under optimum fuel

moisture. 40

4.2 Non-burning Altematives and Annual Emission Goals

Annual emission goals, under this Policy, are established annually and apply to the upcoming year's

projects where fire has been previously determined as the best tool for meeting specific land

management objectives. Therefore, this Policy makes a distinction between those ERTs that are used

with fire and those techniques that replace fire (i.e., non-burning alternatives, sometimes grouped

with ERTs)41 For public lands, non-burning alternatives that replace fire are typically considered in

long-tenn programmatic plans and do not coincide with annual operational plans for fire projects. By

the time the project plan is being implemented, the decision to use fire as a tool to meet the land

management objective has been made.

Land management decisions for federal land managers and possibly other land managers are made

years in advance ofactual project implementation and for multi-year periods, under long-tennland

management plans or project plans. These plans, and the supporting NEPA analyses, are the process

under which alternatives to burning and levels of management application of fire are established.

This land management decision process is on a different temporal/spatial scale from project level

operations. In addition, the decision by federal land managers to replace fire is based on other

environmental considerations that cannot be adequately addresscd on an operational basis, which is

the focus ofthe application of ERTs for annual emission goals, as dcfined by the Policy. Although

specific projects may also go through a NEPA analysis during which non-burning alternatives may

39 NWCG 'S Smoke Management Guide For Prescribed And Wildland Fire, 2001 Edition (hereafter referred to as

"200 I Smoke Management Guide"), pages 143-151.

40 EPA'5 Prescribed Burning Background Document and Technicallnfofmation Document for Prescribed Burning

Best Available Control Measures, September 1992, (hereafter referred to as "EPA's BAeM Documcnt"), p. 9-13.

41 Sec the Glossary In Appendix A for the definition of non-burning alternatives as used in this Policy. This

definition is not meant to contradict EPA's as described in its BACM Document, but rather refers to the application

of non-burning alternatives specific to annual emission goals, as defined in this Policy.

19
be assessed, again, these are typically done well in advance of the operational effort.

In,distinguishing between ERTs used on fire projects and non-burning alternatives used to replace

fire on other land management projects, it is the WRAP's intent only to clarify the application of

ERTs as the basis for annual emission goals. The WRAP supports efforts to utilize alternatives to

burning (such as collection and removal of residue for use offsite with no subsequent on-site

burning) in land management and fire management plans or other equivalent long-tenn plans. The

use of non-burning alternatives is one of the key elements of the enhanced smoke management

program as defined by the WRAP ESMP Policy. Further, the WRAP encourages each state/tribe to

work cooperatively with land managers to develop ways to identify, implement, and track all

feasible non-burning alternatives 42

Several guidance documents provide information on the use of various types of non-burning

alternatives that could be used by land managers. WRAP's 2001 Non-Burning Management

Alternatives on Agricultural Land~ in the Western United States identifies potential non-burning

management alternatives for agricultural burning including methods for assessing the impacts of

alternatives. The WRAP's draft Comprehensive Manual on Non-Burning Alternatives provides a

catalogue ofaltematives to prescribed burning on wildlands, including a risk versus benefit decisionmaking process related to the use ofalternatives. Although these guidance documents are useful for

identifying non-burning alternatives, methods for calculating the benefits of using non-burning

alternatives are not universally available for the WRAP region.

4.3 Determination of Appropriate ERTs

The opportunity for the application of ERTs varies greatly. The 2001 Smoke Management Guide

states, "ERTs vary widely in their applicability and effectiveness by vegetation ty~e, burning

objective, region of the country, and whether fuels are natural or activity-generated.'"

For example, a maintenance burn in a brush vegetative type within a wilderness area may have

virtually no options for ERT application. Alternatively, multiple ERTs may be applicable in a

ponderosa pine vegetation type where activity such as logging or thinning has occurred. The

applicability ofa particular technique or practice will depend, in part, on the objectives ofthat burn.

For example, the objective of a prescribed burn on wildlands may be to create open space for

wildlife. A backing fire, which is a firing technique that is used to reduce the amount of emissions

generated, may not produce sufficient fire characteristics to achieve the management objective.

It is important to note that while ERTs offer an excellent tool for meeting goals for visibility

protection, ERTs may cause negative effects such as soil compaction, nutrient loss, and impaired

water quality on other valuable resources. Therefore, it is imperative that ERTs are used carefully,

and that land managers and air regulators are provided the information and training necessary to

make informed decisions.

42 See the WRAP Policy on Fire Tracking Systems.

'3200 I Smoke Management Guide, p. 141.

20
4.4 Feasibility Criteria

The use of ERTs should be based on economic, safety, technical and environmental feasibility

criteria, as well as land management objectives. The WRAP recommends that education and training

are also included as feasibility criteria. It is imperative that education and training are provided to

ensure that ERTs are used appropriately. All of the above criteria will affect the application of

certain ERTs for vegetation or crop types, burning objectives, and area in the WRAP region.

Examples of how to apply the feasibility criteria are listed below.

Economic: What are the economic costs of applying a certain ERT? Is a specific ERT more

economical than others? Any ERT that significantly reduces crop yields or exceeds the cost ofa

crop is not likely to be accepted by farmers or growers. The same concern is relevant to the

application of ERTs on wildlands.

Safety: Are certain ERTs not feasible due to public and firefighter safety concerns? Are certain

ERTs not feasible due to concerns related to containment of the fire, i.e., keeping the fire within

certain boundaries? Do certain ERTs minimize the possibility of nuisance and hazard smoke?

Technical: Are the equipment and resources available to utilize a specific ERT? Are sufficient

training programs available in the use of ERTs for the land managers?

Environmental: Are there specific air quality and non-air quality environmental limitations (e.g.,

vegetation/crop type, fire type, time ofyear, area in WRAP region, soil compaction, water quality,

etc.) that influence the use of certain ERTs?

Land Management Objectives: Is a certain ERT not feasible due to conflicts with land management

objectives? Do certain ERTs maximize the likelihood ofachieving the land management objective

ofthe burn?

4.5 Existing Guidance Documents

Several guidance documents provide information on the use and effectiveness of various types of

ERTs that could be used by land managers to control fire emissions and reduce smoke impacts.

EPA's HACM Document, the 2001 Smoke Management Guide, and the GCVTC's Fire Emission

Project'4 are three examples.

EPA's HACM Document provides infonnation on ERTs for both wildland and agricultural burning.

The HACM Document is one of the best comprehensive references on potential ERTs for

agricultural burning. Most of the WRAP states do not have agricultural smoke management

programs, so the demand for additional research is minimal. Once agricultural smoke management

programs are developed, further research on common ERTs for agricultural burning applications

may be available.

44 WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and

Agricultural Burning (DRAFT), Appendix A, Pl'. 61-96.

21
The 2001 Smoke Management Guide presents information on the use and effectiveness of ERTs,

fr~quency of specific ERT usage, and qualitative assessment of emission reductions achieved

through the use ofERTs. The majority ofthe infonnation presented in the Guide was gathered from

fire practitioners at three national workshops held during the fall of 1999. Much ofthe research into

ERTs and subsequent emissions benefits for wildlands, such as the Consume software program"s

has been conducted in the Pacific Northwest, although the general principles are applicable

elsewhere in the WRAP Region.

The GCVTC's Fire Emission Project assessed the potential application of ERTs by wildland

vegetation type and fire type on a region-wide basis. Included in the assessment was percentage of

feasible use of ERTs for these wildland vegetation and fire types, with the emissions reduced as a

result ofthe use of ERTs also evaluated.

4.6 Research Needs

ERTs have been proven to reduce fire emissions through documented research, but more research is

needed to make them a more quantifiable tool for land managers. The 1999 Air Quality Policy on

Agricultural Buming emphasized this fact by stating, "Emission reduction technology to reduce the

impact of pollutants emitted from agricultural burning on ambient concentrations is needed,,46

The identification of common ERTs for agricultural burning is a difficult task since most of the

WRAP states do not have smoke management programs to address agricultural burning, and

therefore the demand for such infonnation is not great. Information regarding availability,

applicability, and cost effectiveness of ERTs can be found in various research documents, but a

comprehensive guide does not currently exist.

The research on ERTs for wildland fire was predominantly conducted in the Pacific Northwest.

Although the general principles are applicable elsewhere in the WRAP Region, more research is

needed on ERTs for wildland fire, with emphasis placed on vegetation types located outside ofthe

Pacific Northwest.

4.7 Calculation of Averted Emissions

According to the 200 I Smoke Management Guide, "The overall potential for emission reductions

from prescribed fire depends on the frequency of use of emission reduction techniques and the

amount of emission rcduction that each method offers.,,47 Therefore, in order to detennine the

potential for emission reductions from prescribed fire, land managers will need to calculate the

specific amount of emission reduction that each method offers. Consume 2.1, a fuel consumption

and emissions model, can be used to estimate potential emission reductions that may be achieved by

45 Pacific Northwest Research Station, Forestry Scienees Laboratory, Consume Software, Version 2.1.

46Agricultural Air Quality Task Force's (AAQTF) Air Quality Policy on Agricultural Burning, Recommendation to the

U.S. Department ofAgriculture, November 10, 1999.

47 2001 Smoke Management Guide, p. 152.

22
employing certain ERTs 4S

The WRAP recognizes the need for a more comprehensive guide for estimating potential emission

reductions achieved through the use of ERTs for agricultural burning and wildland fire. This

guidance will be developed by the WRAP in a similar format to that of Appendix 0 to support

states' and tribes' use ofannual emission goals. Appendix 0 provides a table that lists ERToptions

that can be applied by land managers and the corresponding emissions averted by using a particular

ERT.

The 200] Smoke Management Guide contains several tables that may be useful to states/tribes in

order to establish annual emission goals. The tables include information on the frequency ofuse of

specific ERTs by region ofthe country, the general effectiveness ofspecific ERTs, the significant

constraints limiting the wider application ofERTs, and the potential emission reductions that may be

achieved by employing various ERTs as estimated by Consume 2.1. There are some limitations to

the infonnation contained in the 200 I Smoke Management Guide, as some vegetation types that are

found in the WRAP region are not included.

These tables should be utilized with the understanding that the effectiveness ofa particular ERT may

vary considerably. Considering all burning nationally, if ERTs were optimally used, emissions

could probably be reduced by approximately 20-25 percent assuming all other factors (vegetation

types, acres, etc.) were held constant and land management goals were still met49 Individual

states/tribes or regions may be able to achieve greater emission reductions than this or much less

depending on the states' or regions' individual situations.

48 OUmar, Roger D.; Reinhardt, Timothy E.; Anderson, Gary; DeHerrera, Paul 1. Consume 2.1 User's Guide. Gen. Tech.

Rep. PNW-GTRxxx. Portland, OR: U.S. Department ofAgriculture, Forest Service, Pacific Northwest Research Station.

49 J. Peterson and B. Leenhouts, "What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and

Can Land Management Goals Still Be Mel"" (Draft). August 20. 1997.

23
APPENDIXD

Example of ERT & Associated Emission Averted Table

(This example demonstrates the future guidance that will be issued by the FEJF.)

ERT Category Practice Treatment Size Vegetation TJ'pe Smolder Equation Reduction

Class Factor

All Ponderosa Pine N/A ERT Emissions = 0.1

Total Emissions x

0.9

Pinyon/Juniper N/A

Increased Backing First Entry Woodland, Oak ERT Emissions =

Combustion Fires All Brush, Sage, Total Emissions x 0.1

Efficiency Desert Shrub, 0.9

Annual Grass,

Perennial Grass

Ponderosa Pine, N/A

Pinyon/Juniper,

Woodland, Oak ERT Emissions = 0.1

Maintenance All Brush, Sage, Total Emissions x

Desert Shrub, 0.9

Annual Grass,

Perennial Grass

24
Appendix

State of New Mexico Pollution Prevention Appendix

Appendix G: Pollution Prevention

Renewable Energy Resources

Renewable energy sources, including solar, wind, hydropower, biomass, and geothennal,

currently provide less than 1% (or 5.6 trillion BTUs) of New Mexico's annual energy needs.

The contribution of renewable energy has dropped from 6.6 trillion BTUs reported in 1997. This

is contrary to the fact that our renewable energy resource base is very large and diverse. Table 6

provides a breakdown of consumption, by sector, for renewable energy in New Mexico.

Table 6. Renewable Energy Consumption in New Mexico, 1999*

Sector Energv Source Million KWH Consumed

Residential

Commercial

Industrial

Solar

Wood

Geothermal

Wood

Geothermal, Wind, and Solar

Wood and Wastc

147

996

29

147

176

147

Total 1,642

Sourcc: DOE/EIA State Encrgy Data Rcportl999, printed May 2001.

*most current data available

Table 7. Renewable Energv Production by Resource, 1999*

Resource

Fucl Wood

Alcohol Fuels

Hydroelectric

Gcothermal

Wind

Total

KWH Value ($ Millions)

1,026 Million 6.5 (Note I)

346 Million 23.3 (Notc 2)

230 Million 15.2 (Notd)

J 19 Million 1.4 (Note 4)

1.7 Million 0.119 (Note 5)

1,772.7 Million 46.51

Notes: *most current data available

I. DOE/EIA Energy Price and Expenditure Report, 1999.

2. Data from High Plains Ethanol Plant, Portales, NM; 15 million gal/yr @ $1.559 per

gallon.

3. Edison Electric Institutc, Ycarbook 2000; valuc bascd on average NM electricity

cost of $0.0663/kWh.

4. Southwest Technology Dcvelopmcnt Institutc, NMSU; average NM natural gas cost

of $3.62/million BTU.

5. Southwestem Public Service Company, Amarillo, TX; Clovis, New Mexico wind

turbine, average NM electric price.

A significant amount of renewable energy research, development, and demonstration (RD&D) in

New Mexico occurs through federal government programs at Sandia National Laboratories

(SNL). At the time this was written, before federal government funds were appropriated, SNL

funding for solar thennal systems and buildings in FY 2003 is estimated to be $3-4 million and

the photovoltaics program is expected to receive $5 million. In other renewable energy RD&D

areas, the previous FY 2002 appropriations were: energy storage at $6.5 million; geothennal

drilling technology at $6.4 million; wind at $3.9 million; and biopower electricity at $1.1 million.

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Solar

Overview. The position of New Mexico as a leader in solar energy in the 1970s and 1980s

attracted private, state, and federal funding, resulting in significant benefits to New Mexico and

the Nation. funding has fluctuated since that time. Many solar pioneers of the private sector

have survived, evolved, and continued forward to provide innovative products and services to the

state and the world. ECMD has been involved in most state-funded solar programs and

continues to be the primary contact where the state is involved.

At federal laboratories in New Mexico, research funding for solar technologies was dropped at

Los Alamos National Laboratory and has decreased at Sandia National Laboratories (SNL).

SNL conducts a wide range of solar energy research, development, and demonstration (RD&D)

projects involving technologies such as solar thennal concentrating collectors, photovoltaic (PV)

system components, solar buildings, and manufacturing. The new mission of enhanced U.S.

energy security appears to have led to increased emphasis at federal laboratories for most types

of domestic energy RD&D, including solar energy.

The solar industry is made of manufacturers, equipment suppliers, greenhouse and glazing

suppliers, passive solar builders, installers, and service companies that repair systems. Most

businesses marketing solar technologies are members of the New Mexico Solar Energy

Association (NMSEA) and the New Mexico Solar Energy Industries Association (NMSEIA). In

NMSEA's 2001 Directory of Solar Professionals, 30 architects and designers, 42 builders, 6

education professionals, 4 engineers, 3 financing institutions, 43 solar technology companies, 6

greenhouse designers and builders, and 25 green building product and service companies are

listed. NMSEA's resources can be accessed at www.l1msea.org or 1-888-886-6765.

In the 1980s there existed both federal and state solar tax credits. During that decade over 40,000

active and passive solar systems were installed in New Mexico. When oil' prices fell and the

federal tax credit for use of solar was eliminated in December 1985, the impact on the solar

energy industry was immediate. At the beginning of 1985, approximately 250 solar businesses

were in operation employing about 2,000 people. By the end of 1985 about 80% of these

businesses had closed. However, in recent years there appears to be increased activity for solar

businesses in New Mexico, due to renewed homeowner interest in PV systems.

The Solar Rights Act of 1978 allows property owners to create solar easements for the purpose

of protecting and maintaining proper access to sunlight. It also includes provisions allowing

local governments to create their own ordinances or zoning rules pel1aining to protection of solar

rights. New Mexico was first among the 50 states to enact a solar access law and also implement

tax incentives for solar systems.

Resources. Energy from the sun is an enonnous energy source. New Mexico ranks 2"d among

all states in the U.S. in solar energy resources and experiences more than 3,200 hours ofsunshine

per year. This results in a range of solar energy on a horizontal surface---depending on location

and season---of about 900 to 2600 BTUs per square foot per day (3 to 8 kilowatt-hours (kWh)

per square meter per day).

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The potential for converting solar energy to electricity and heat in New Mexico with existing and

emerging technologies is also great. The State's average daily energy consumption is about 904

billion BTUs (265 million kWh) or 161,425 hanels of crude oil, which could also be collected as

solar energy within an 18 square-mile area. Table I presents the average solar radiation for

selected New Mexico communities.

Table 8. Average Solar Radiation in New Mexico

AREA

Albuquerque

Carlsbad

Chama

Las Cruces (EI Paso)

Las Vegas

Lordsburg

Los Alamos

Santa Fe

Taos

BTUs/SQUARE FOOTIDAY

HORIZONTAL SURFACE VERTICAL SURFACE

1,827 1,423

1,825 1,210

),560 1,200

1,900 1,380

1,675 1,250

1,900 1,275

1,535 1,262

1,625 1.210

1,575 1,200

AVERAGE 1,755 1,297

Source: Los Alamos Scientific LaboratOly, USDOE, Passive Solar Design Handhook, Vol. 2, 1980;

and NeH' Mexico Climate Manual, Solar and Weather Data, New Mexico Energy Research and

Development Institute 2-72-4523, 1985.

Production. Direct use of the sun's light and thermal energy has long been recognized in New

Mexico. Over $4 million worth of energy was supplied by active and passive solar systems in

1990, by system types such as solar water heating, solar thermal space heating, and PV. As an

example, a PV collector array the size of a football field would directly produce 1.2 million

kilowatt-hours of electricity per year, or the electricity needed to power about 122 homes.

Assuming a conservative retail electricity cost of five cents per kilowatt-hour, this PV system

could offset $500 per year in utility costs for each home.

Although less than five percent of the solar installations in New Mexico generate electricity, PV

systems include a 47-kilowatt array at the Southwest Regional Experiment Station at New

Mexico State University in Las Cruces, operated by Southwesl Technology Development

Jnstitute; and upwards of 250 one-kW inigation units in various areas. SNL estimated that there

were approximately 2,000 PV systems in New Mexico in 1990.

Electric utilities in the state are required to provide information on alternative energy systems to

remote customers with less than a 25-kW load who request line extensions. This requirement

applies when the cost of the requested line extension is greater than 15 times the estimated

annual revenue from the line extension. In such cases, utilities must provide customers with

information on suppliers of alternative energy systems.

Another type of solar energy production is commonly provided in New Mexico through

innovative architecture in buildings: passive solar design. Following design guidelines published

by the National Renewable Energy Laboratory, it is possible for strategic placement of windows,

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sunspaces, thermal storage walls, and mass (e.g., concrete, brick, adobe), as well as appropriate

orientation and insulation, to enable the sun to provide up to 80% of a home's annual space

heating needs in New Mexico. This can be achieved without compromising cooling needs. The

sun can also be utilized to integrate daylighting, thereby offsetting electricity costs associated

with lighting. Passive solar design is also applied to commercial buildings and schools in New

Mexico.

By integrating passive solar design, solar water heating, and PY in residential home design it is

conceivable to greatly reduce or eliminate the need for conventional electricity, heating, and

cooling energy sourCes. Many success stories exist in New Mexico of living "off-grid." As

noted above, solar professionals resident in New Mexico are available for design assistance.

Recent Developments. Significant activities have been conducted with solar energy in New

Mexico over the past few years. ECMD has implemented major projects that use our extensive

solar resource. ECMD each year provides public infonnation and educational activities on solar

energy at various conferences, workshops, and other venues, including the Taos Solar Festival.

New Mexico State Fair. and New Mexico Solar Energy Association's Solar Fiesta.

ECMD is refocusing its solar program to feature demonstrations of solar water heating and

photovoltaic systems. Solar water heating and photovoltaic systems will be sited at public

school facilities in several New Mexico climate zones. System commissioning will include

training and establishment of operations and maintenance plans. The demonstrations are

intended to educate and involve students, faculty, staff, and communities at public schools;

collect system performance data in different New Mexico climate zones; evaluate incentives for

solar technology applications; and address, in consultation with the solar industry, related issues

such as state agency administration of residential tax credits, system certification, and system

monitoring. Solar systems will be designed, installed, and commissioned through a collaborative

effort of ECMD, other state agencies, public schools/institutions of higher education, New

Mexico Solar Energy Association (NMSEA) and Solar Energy Industries Association

(NMSEIA), DOE, and the Solar Buildings Program at Sandia National Laboratories.

ECMD is collaborating with NMSEA, Southwest Research and Information Center, and other

organizations to finance and install PY systems for low-income communities without electricity

service. Several large areas in New Mexico, such as the Pajarito Mesa west of the City of

Albuquerque, remain without utility-provided electricity, but could be served with PY

technologies. Similarly, electricity service is not available to 37% of households on the Navajo

Reservation, 5% of the Jicarilla Apache Reservation, 3% of Zuni Pueblo, 2% of Acoma Pueblo.

The majority of households in unincorporated Colonias communities along the border with

Mexico are also without electricity service. These communities often resort to expensive means

of producing their own electricity, using power sources such as diesel generators and car

batteries. PY systems could possibly be a less expensive alternative for the critical needs of

lighting and operating simple appliances.

ECMD provided funding to the All-Indian Pueblo Council to install an II-kW PY carport at the

Indian Pueblo Cultural Center in Albuquerque. This 1999 installation is the largest commercial

PY array in the state and the largest PY system on Indian lands. It is expected to produce 25,000

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kWh of electricity, save 43 tons of coal, conserve I million gallons of water, and reduce carbon

dioxide emissions by 27 tons per year. The system will save the Cultural Center over $3,400 per

year in electricity costs. The carport also provides shade for II parking spaces and will be

visible to 400,000 visitors annually.

In Septembcr 1999, the New Mexico Public Regulation Commission (PRC) issued a rule

requiring all utilities regulated by the PRC to offer net metering for cogeneration facilities and

small power producers with systems of 10 kW or less. Municipal utilities are exempt because

they are not regulated by the PRe. There is no statewide cap on the number of systems eligible

for net meteri ng.

The use of solar energy in our New Mexico State Parks has improved their safety and

convenience. ECMD installed 29 PV lighting systems at visitor centers, pay stations, and other

locations in 15 State Parks. Also, a PV aeration system was installed in a pond at the Rio Grande

Nature Center to create better conditions for aquatic life.

It should also be noted that older systems installed in the early 1980s at state facilities have been

kept operational. ECMD made improvements in the 1990s to both 16,000-square-foot solar

water heating systems at the Central and Southern New Mexico Correctional Facilities. The

Northern New Mexico Community College also received ECMD assistance to reactivate solar air

heating systems on two major campus buildings.

Wind

Overview

Wind is a proven, cost-effective, and environmentally attractive source of power. recent

technological innovations in wind turbine design have resulted in increased effectiveness and

reduced cost. The cost of electricity from wind power plants has dropped to about 3 or 4 cents

per kilowatt-hour (kWh), very close to the cost of power from fossil-fuel sources. Public utilities

across the country and around the world are beginning to include wind in their mix of energy

sources.

In October 2002, the Public Service Company of New Mexico (PNM) announced an agreement

with FPL Energy to develop the first commercial-sized wind power plant in New Mexico.

Known as the New Mexico Wind Energy Center, it will be 204 megawatts in capacity and will

be located in eastern New Mexico, about 20 miles northeast of Fort Sumner, in Quay and De

baca counties. Jt will be the third largest wind power plant in the country.

Construction will begin in late 2002, with the plant operational in less than a year. Construction

on a facility ofthis size typically takes six to nine months to complete. The wind facility will be

composed of 136 separate towers, each 210 feet tall, with turbine blades that measure more than

110 feet in length. The facility will send power to PNM's electric grid. FPL Energy will

construct, own and operate the facility. PNM will purchase all of the power it produces, enough

to supply about 90,000 homes.

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PNM plans to ask state regulators for approval of a "green tariff' program sometime in 2003 that

will allow interested customers to buy wind-generated electricity for a small monthly premium.

Any power from the facility not directed toward the residential and business customer

subscription program would be sold on the wholesale market, either within New Mexico or

outside the state.

PNM sees the power produced by this facility as a way to recognize and respond to interest

within New Mexico in renewal energy and to strengthen the company's wholesale generation

portfolio for years to come. When PNM plans a new facility or commits to buying power from a

new facility, it looks not just at current economic conditions but also at conditions that may exist

several years down the road.

Energy produced at the Wind Center will likely replace an equivalent amount of power coming

from facilities powered by fossil fuels, since the majority of power on the grid comes from

fossil-fuel sources. The addition of energy from the New Mexico Wind Energy Center will

change PNM's generation portfolio. Wind will comprise 8 percent of PNM's overall generation

capacity, which is the portfolio's peak potential output. However, because of the intennittent

nature of wind, the facility is expected to comprise about 4 percent of the energy actually

produced by or for PNM over the course of a given year.

The Wind Energy Center will bring more than $40 million into rural De Baca and Quay counties

over 25 years. This includes $450,000 per year in payments in lieu of taxes to be made to the

county governments and school districts; about $550,000 per year in lease payments to

landowners; and an estimated $500,000 in salaries for the permanent jobs to be created. This

$40 million figure does not include the infusion of money resulting from the 125-150 temporary

jobs that will be created while the facility is being constructed in 2003.

Resource Assessment

The Energy Conservation and Management Division (ECMD) of the New Mexico Energy,

Minerals and Natural Resources Department, through its Wind Power Program, has performed a

critical role in the development of wind power in the state. In pal1icular, the high-quality data

ECMD provided to FLP Energy and PNM were very valuable to the development ofthe recently

announced 204-megawatt project dcscribed above. ECMD continued data collection at Frio

Draw for a third year upon request to assist FPL Energy in their evaluation of potential sites.

The Wind Power Program is continuing detailed wind energy resource assessment of the most

promising sites for commercial development. The potential for electricity generation from wind

is enonnous in some areas of New Mexico, especially on the eastern plains. New Mexico ranks

twelfth in wind electric potential and is among twelve states in the midsection of the country

that, together, have 90% of the total commercial wind electric potential in the contiguous United

States. The annual wind energy potential of New Mexico has been estimated to be 435 billion

kWh. New Mexico has the potential to produce many times its own electrical consumption,

which puts it in a position to export wind electric power.

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ECMD has provided detailed wind resource assessments of the state and "investment-graue"

wind data to 33 wind power developers, PNM, landowners and others. Several developers are

actively working to develop projects in New Mexico. ECMD has provided two years of wind

speed data collected at six promising sites. Three years of data have been provided for two of

those sites. Monitoring of an additional seventh site on Argonne Mcsa, southwest of Santa Rosa,

was commenced in August 2002. Such data are vital to commercial development of wind power

plants because they allow accurate estimates of power plant production.

ECMD's Wind Power Program has provided studies of the potential cconomic benefits of wind

power operations to five counties: Colfax, Eddy, Lea, Otero, and Quay. The results of these

studies have been presented to public officials and residents ofthese counties.

ln 2002 the program completed development ofthe following products:

•

•

•

•

New Mexico Wind Power Plant Site Scrcening Model

Guidelines for Developers and Investors Interested in Wind Power in New Mexico

New Mexico Wind Development Handbook

Mesa Redonda Case Study Report. This study addresses the following issues:

environmental, archaeological, cost estimating, transmission, permitting, geotechnical,

micro-siting, production, and visual impacts.

Currently underway is a project to develop a high-resolution (200 meters) wind map of the state

using the latest techniques.

Several pieces of legislation were passed during the 2002 Legislative Session, most notably thc

Renewable Energy Production Tax Credit (Senate Bill 187) that allows a taxpayer who owns a

qualified energy generator, certified by the Energy, Minerals and Natural Resources Department,

to be eligible for a tax credit of one cent per kilowatt-hour. The credit may be deducted from the

taxpayer's New Mexico corporate income tax liability. In addition, House Bill 143 amended the

Industrial Revenue Bond Act to include electrical generation facilities such as wind farms. This

legislation (H.B. 143) also amended the Gross Receipts and Compensating Tax Act to exempt

from gross receipts taxes certain wind generation equipment sold to public entities.

ECMD hosted in October 2002 the first-every Ncw Mexico Wind Conference in partnership with

the US Dcpal1ment of Energy and Sandia National Laboratories. The purpose of the conference

was to provide information relating to New Mexico's wind resources and to explore mechanisms

by which to encourage greater development and use ofthis energy resource.

Research

Sandia National Laboratories conducts an ongoing wind energy research program that employs a

multi-faceted approach to the development of economical wind systems for power generation.

First, it conducts applied research in aerodynamics, structural dynamics, fatigue, materials,

manufacturing, controls, and systems integration to understand unsolved technology problems

and to provide better design tools. A major new effort in applied research is the investigation of

rare atmospheric events that significantly impact wind turbine long-tenn structural integrity.

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Second, Sandia applies its analytical and experimental capabilities to solve specific industry

technical problems that are impeding the deployment of reliable, cost-effective solutions for

domestic and intemationalmarkets. Finally, advanced manufacturing techniques are being used

to reduce cost and increase reliability of wind turbine blades. Follow-on efforts will consider the

complete product life cycle, with emphases on fully integrated design, agility, and tools to

support a design-for-manufacturing process. In all three approaches, Sandia uses formal and

infomlal teaming aJTangements to work closely with wind turbine manufacturers, wind farm

developers/operators and other DOE laboratories.

Hydropower

New Mexico's hydroelectric capacity is 78.4 megawatts from nine plants: Navajo Reservoir (30

MW), Elephant Butte (24.3 MW), Abiquiu (15 MW), El Vada (8.8 MW), Farmington (200 kW),

Alamogordo (60 kW), Raton (30 kW), Cloudcroft (15 kW), Reserve (10 kW). Although not a

substantial portion of the state's total generating capacity, hydropower could play a more

significant role in meeting site-specific needs.

Many undeveloped small hydropower sites exist in New Mexico, including river sites and

existing dams, but numerous constraints limit the potential. These constraints include financing,

multiple-use issues, regulatory balTiers, economic issues, and environmental impacts.

Bioenergy

Bioenergy is produced from biological feedstock or other products made from such feedstock.

The feedstock may be either produced or harvested explicitly for such use, such as grain milo

and firewood, or may be a waste stream from agricultural, municipal or industrial sources.

Distribution of and access to the resource are critical to the economical use of bioenergy. For

this reason the creation of bioenergy is often found at the point of availability of a waste stream,

with a facility's size detennined by that stream.

Wood burning for heating is perhaps the most traditional use of bioenergy in New Mexico, and

this continues to be the largest use. The other common use of bioenergy in New Mexico

involves the production of methane from municipal wastewater sludge. This fuel is then bumed

to heat the digestion process, and in some cases to also generate electricity for operation of the

plant.

Resources and Production

The best available research on New Mexico fuelwood indicates that 197,000 cords were

harvested in J986, which is neither a significant drain on the growing stock inventory nor a

competitor with the timber products industry. This is equivalent to about 3.6 x 10'2 BTU.

Albuquerque and Las Cruces are using the anaerobic digestion of municipal wastewater sludge

to generate methane gas. The gas then fuels the production of electricity and heat to power the

wastewater facilities. Los Alamos and Carlsbad are using the resulting methane to heat the

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digesting process and/or water. Several sawmills burn waste wood to provide heat for wood

drying ki Ins.

The waste stream bioenergy resource in New Mexico has been studied in detail. The total

potential for energy production in this sector is large, at 35 trillion BTU per year, although a

significant share of this resource is allocated for other uses such as particleboard manufacture.

The largest sources in this sector are sawmill/wood product waste and municipal solid waste.

Recenl Developmenl

The U.S. Forest Service (USFS) is working with the New Mexico Energy, Minerals and Natural

Resource Depal1ment's (EMNRD) Forestry Division and Energy Conservation and Management

Division on a wood chip-fueled power system at Jemez Mountain School.

EMNRD is also leading efforts to investigate forest thinning energy projects for the Ruidoso and

Las Vegas areas. The USFS' Forest Products Laboratory, National Renewable Energy

Laboratory and Community Power Corporation are testing the beta version of a small (5-15

kilowatts electricity; 50 kW of useful heat), modular forest products gasifier at local businesses

in Glencoe (SBS Wood Shavings) and Cuba (American Medal Products). In addition, the USFS

is studying the use of lumber mill residues and forest thinning for fueling bioenergy projects in

Silver City and Angel Fire.

Rapid growth of thc New Mexico dairy industry has greatly increased the availability of manure

in New Mexico. EMNRD's Energy Conservation and Management Division is working with the

US Department of Energy and the Dairy Producers of New Mexico on a project to create

electricity and hcat from Ihis waste. Dona Ana County pecan growers are exploring the

feasibility of using pecan grove waste to fuel generation ofclectricity.

Geothermal

Overview

New Mexico has significant low-temperature «194 degrees Fahrenheit) geothennal resources

long its westem border and in close proximity to the Rio Grande from north to south. Our state

is also blessed with considerable moderate to high temperature resources, including those in the

Rincon area of Dona Ana County, near Cotton City in Hidalgo County, and the Valles Caldera

area in the Jemez Mountains (Sandoval County). The table below provides a summary of

geothermal sites in New Mexico. Common low-temperature applications are space and water

heating, while electricity can be generated from high-temperature sources.

Site Temoerature (OF) Flow flwm) # Wells Deoth (ft.)

Dona Ana Countv:

Las Cruces 156.9 3 9 2572

Radium SorinQs 170.1 NA 8 121

Grant Countv:

Favwood 127.4 3 I NA

NM Regional Haze SIP

Proposed 7/18103

Page G-9
Hurley 144 NA I 521.7

San Juan/Sherman 138.2 3 8 NA

Hidalgo County:

Colton City 225 200 13 439

McKinley County

Ft. Wingate 131 23 I 1942

Rio Arriba County:

Oio Caliente/Gallegos 132.1 NA 2 88

San Miguel County

Las Vegas 131.3 NA 2 NA

Sandoval County

Jemez/San Ysidro 136 150 I 239

Jemez Springs 163.9 52 6 NA

Valencia County

Valencia 176 NA I 721

Source: WItcher, J.e., 1995. A Geothemlal Resource Database, New MexIco; Southwest

Technology Development Jnstitute, New Mexico State University, Technical Report to Oregon

Institute of Technology, Geo-Heat Center, 32 p.

Production and Use

Geothermal reSources in New Mexico have been used directly in a significant manner for over

20 years. In the 1980's, a large district heating system was installed at New Mexico State

University (NMSU) in Las Cruces; and the largest geothermal greenhouses in the nation were

constructed. A key factor responsible for encouraging the development and uSe of geothennal

energy at that time was a $600,000 appropriation from the New Mexico State Legislature for

geothermal research, development and demonstration projects. Thc Energy Conservation and

Management Division of EMNRD, with substantial technical assistance from the Southwest

Technology Development Institute (SWTDI) at NMSU, established and implemented the

geothermal RD&D projects. Subsequently, SWTDI constructed a geothermal greenhouse

research and business incubator facility in Las Cruces, as well as a geothermal aquaculture

facility co-located on site. As a direct result of these efforts, four commercial greenhouses

totaling over 30 acres have been established in southern New Mexico. SWTDI estimates that

these four geothel1l1ally heated greenhouses represent a capital investment of more than $10

million, generating at least $14 million in annual sales and about 270 jobs.

One of the largest geothermal aquaculture facilities in the nation is also located in New Mexico,

in the Animas Valley south of Lordsburg. This facility is owned and operated by Americulture,

Inc. The following table provides information on the various direct-use geothermal applications

in New Mexico. To date, however, the state has not witnessed construction of any geothermal

electric generation plants of commercial scale.

Site Temperature Flow Energy (10· Application

(OF) «(!pm) BTlJs/yr)

Catron County NA NA NA ReS0l1 & Spas - Bubbles Hot

Snrinl!s

NM Regional Haze SIP

Proposed 7!18103

Page G-IO
Dona Ana Countv:

Las Cruces Area 142 417 45.9 District Healing (NMSU)

148 50 1.8 Greenhouse - SWTDI

(NMSU)

Radium Snrings 148 700 27.6 Greenhouse - J & K Growers

160 2600 119 Greenhouse - 2"0 largest

nationallv Masson Farm

Hidalgo County: 245 2000 209 Greenhouse - Largest

Cotton Citv nationally Burgett Floral

185 NA 0.7 Greenhouses/Aquaculture -

McCants/AmeriCulture

Rio Aniba Countv 115 60 2.0 Resorts & Suas - Oio Caliente

Sandoval County NA NA NA Resorts & Spas - McCauley

Hot Springs, Jemez Springs

Bathhouse

165 40 1.3 Space Heating - Jemez Springs

Fire DeUaI1ment

Sierra County 113 NA NA Resorts & Spas - Truth or

Consequences

Total 407.3

In FY 2000-01, DOE directly funded a number of private-sector resource assessment and

demonstration projects in southern New Mexico, which are now getting underway.

Recent Developments

The Energy Conservation and Management Division (ECMD) of EMNRD has facilitated

promotional and technical information exchanges on geothermal energy through a variety of

activities. ECMD held the first-ever New Mexico Geothermal Energy Conference in

Albuquerque in April 2002, in partnership with DOE and Sandia National Laboratories, to

provide information on New Mexico's geothermal resources and to explore mechanisms by

which to encourage further development. In addition, ECMD and the Southwest Technology

Development Institute (SWTDJ) at NMSU secured through a national competition US DOE

funding in the amount of $50,000 for dcvelopment of a Geothermal Information Clearinghouse

in New Mexico. ECMD continues to coordinate the eff0l1s of the New Mexico Geothermal

Energy Working Group, which was established in pal1nership with Sandia National Laboratories

under the auspices of DOE's Geopowering the West program; the group promotes the

development and use of New Mexico's geothermal resources. SWTDI remains a leader in

providing technical assistance and information for geothermal development in the state.

Summary of New Mexico's Total Energy Sales, Generation Capacity and Production

Public Service Company of New Mexico

NM Regional Haze SIP

Proposed 7/18/03

Page G-II
PNM provides jurisdictional retail electric service to a large area of north central New Mexico,

including the City of Albuquerque and the City of Santa Fe, and certain other areas of New

Mexico. For the years 1997 through 2001, retail KWh sales have grown at a compound annual

rate of approximately 2.65%. PNM's peak demand for summer (2001) was 1,397 MW; and

winter, 1,294 MW

PNM Operating Statistics-New Mexico

2002 2001

Retail Energy Sales (kWh in thousands):

Residential

Commercial

Industrial

Other

Total retail

2,298,542

3,254,576

1,612,723

240,665

7,406,506

2,197,889

3,213,208

1,603,266

240,934

7,255,297

Data from 10-K report found at:

http://www.see."ov/Arehives/edgar/dara/I]084?6/0001 10842602000015/000] 108426-02-0000 I5.lXt

PNMGenerafJn cafJacilv-December 3/ 2002

Plant Name Location Capacity-Net Fuel Source %, of Total Capacity by

(meeawalts) Fuel Source

San Juan Waterflow, NM 765 MW Coal Coal: 67%

Four Comers Fruitland, NM 192MW Coal

Reeves Albuquerque, NM 154MW Gas/Oil Gas/Oil: 4%

Las Vegas Las Vegas, NM 20MW Gas/Oil

Palo Verde Wintersburg, AZ 390MW Nuclear Nuclear: 29%

Renewables: 0%

Totals 1,521 MW 100%

Notes: PNM also has a power purchase agreement under which it has access to 132 MW of gas-fired

capacity, bringing its total available capacity to 1,653 MW.

PNM Electric Plant Ownership:

San Juan-PNM owns 50% of Units 1,2,3; and 38.5% of Unit 4

FaurCamers-PNM owns 13% of Units 4,5.

Palo Verde-PNM owns 10.2% of Units 1,2,3

Source: U.S. Securities and Exchange Commission, 1O-K Report for the year ending December 31, 2002.

EI Paso Electric Company

In 2001, EI Paso had retail jurisdictional sales in New Mexico of 1,305,122 MWh. [EPE

testimony before the NM PRC, April 15, 2002, Utility Case #3619] Comparisons of retail kWh

sales by sector are shown below (in thousands of kilowatt-hours):

NM Regional Haze SIP

Proposed 7/18/03

Page G-12
El Paso Operating Slatistics-Texas and New Mexico

2002

Retail Energy Sales (kWh in thousands):

2001 2000

Residential

Commercial and industrial, small

Commercial and industrial, large

Sales to public authorities

Total retail

1,870,931

2,076,758

1,161,815

1,212,180

6,321,684

1,789,199

2,069,517

1,174,235

1,185,521

6,218,472

1,767,928

2,026,768

1,142,163

1,177,883

6,114,742

Data from 10-K report found at:

http://www.sec.gov/Archives/ednr!dala/31978/00009306610300116SidIOk.htm#lx715 5

El Paso Generating Capacity-December 31, 2002

PLANT NAME LOCATION Capacity-Net FUELSOURCE % of Total Capacity by

(mecawatts) Fuel Source

Four Corners Fruitland, NM 104MW Coal Coal: 6%

Newman EI Paso, TX 482MW Gas/Oil

Rio Grande Sunland Park, NM 246MW Gas/Oil Gas/Oil: 25%

Coooer EI Paso, TX 68 MW Gas/Oil

Palo Verde Wintersburg, AZ 600 MW Nuclear Nuclear: 52%)

Hueeo Mt. Horizon City, TX 1.32 MW Wind Rencwables: < I0/0

Totals 1,521 MW 100%

El Paso Electric Plant Ownership:

Four Corners-El Paso owns 7% of Units 4, 5.

Palo Verde···-EI Paso owns 15.8% of Units 1,2,3

Source: U.S. Securities and Exchange Commission, IO-K Report for the year ending December 31,2002.

Southwestern Public Service Company/Xcel

Table 13. SPS/Xcel Operating Statistics-Texas and New Mexico

2002

Retail Energy Sales (kWh in thousands):

Residential

Commercial and industrial

Public Authorities and other

Total retail

3.300

12,044

549

15,893

2001 2000

3,212 3,467

12,404 12,383

549 608

16,165 16,458

Data from IO-K report found at:

http://www.sec.goY!Archives/edgar!data!9252I i000095013403003112!c75034.oIOvk.htm

NM Regional Haze SIP

Proposed 71t 8/03

Page G-I]
SPS/Xcel Generating Capacity-December 31.2002

PLANT NAME LOCATION Capacity-Net FUEL SOURCE % of Tota] Capacity by

(mel!awatts) Fuel Source

Harrington Amarillo, TX 1,066MW Coal Coal: 74%

Tolk Muleshoe, TX 1,080MW Coal

Jones Lubbock, TX 486MW Gas Gas: 26°;',

Plant X Earth, TX 442MW Gas

Nichols Amarillo, TX 457MW Gas

Cunningham Hobbs, NM 267MW Gas (steam)

Cunningham " 220MW Gas tturbine)

Maddox Hobbs, NM 118MW Gas (steam)

Maddox " 65MW Gas (turbine)

Moore County Amarillo, TX 48MW Gas

Riverview Electric Citv, TX 23MW Gas (turbine)

Carlsbad Carlsbad, NM 13MW Gas (turbine)

CZ-I,2 Pamoa, TX 39MW Steam/Nitrogen N/A

Wind Turbine Texico, NM 0.66MW Wind Renewables: < I %

Totals 4,324MW 100%

Sourcc: U.S. Sccuritics and Exchange Commission, 10-K Report for the ycar ending December 31, 2002.

Texas-New Mexico Power Company

Purchased Power. TNP has no operating generation facilities in New Mexico. All power

purchased and distributed to its customers comes from Public Service Company of New Mexico;

this arrangement continues through December 31, 2006.

Purchased Power Costs. During 2002, TNP's consolidated average cost per Kilowatt-Hour

(kWh) of purchased power was 4.05 cents per kWh. In 2001, prior to retail competition, TNP's

average cost of purchased power was 4.58 cents per kWh.

TNP Operating Stafislics-Texas and NeVi' Me.xico

Sales (MWh):

Residential

Commercial

Industrial

Sales for resale

Other

Total

2002

2,622,978

2,095,666

J,957,920

1,978,194

110,592

8,766,350

2001

2,555,472

2,089,978

1,466,178

291,958

99,884

9,203,470

2000

2,582,081

2,069,046

4,610,059

281,017

101,563

9,643,766

Data from 10-K report found at:

http://www scc.gov/Archivcs/cdgar/data!22767/000093066I 0300 I293/d 1Ok.hlm

NM Regional Haze SIP

Proposed 7/18/03

Page G-14
Regional Modeling Analysis

The WRAP Air Pollution Prevention Forum commissioned the ICF Consulting Group to analyze

the potential emission reductions, costs, and secondary regional economic impacts of meeting the

10/20 goals and energy efficiency recommendations (lCF, 2002). The analysis of this case

incorporates the results of the ICF analysis for the Air Pollution Prevention Forum in a scenario

that includes 2018 milestone case emission estimates for non-utility point sources.

The estimated sulfur dioxide (SO,) and oxides of nitrogen (NO,) emissions by utility unit for

existing facilities, and by State for new sources, were provided by the ICF Consulting Group.

The percentage changes in SO, and NO, emissions by unit were applied to the 2018 Milestone

Case emissions to estimate air pollution prevention case emissions for this analysis. The ICF

model also provided estimated SO, and NO, reductions for new sources. These new source

emission reductions were applied to the utility units in each State in proportion to 2018 milestone

case emissions. Because oflhe regional SO, trading program, the regional SO, emissions total is

the same in the air pollution prevention case as it was for the milestone case. There is some

shifting of SO, emissions among units and States, though. Regional NO, emissions decline by

about 14 thousand tons (air pollution prevention case versus milestone case). A State-level

summary of utility emission changes by State from the 2018 milestone case is provided below.

The tribal new source changes were allocated to Arizona. States not listed had no emissions

change.

State

Arizona

Colorado

Nevada

New Mexico

Utah

Wyoming

Regional Changes

Air Pollution Prevention Case Emissions Change

NO, tpy SO, tpy

-3,267 5,558

-1,370 -1,119

-430 -307

-7,053 -5,135

-780 -595

-1,374 1,598

-14,274 0

The following table presents the air pollution prevention case results for point sources in the

GCVTC transport region States. In the air pollution prevention case, GCVTC transport region

point source SO, emissions are 510,000 tons.

NM Regional Haze SIP

Proposed 7/t 8/03

Page G-15

MTF, Ftype FIPSST State

Code

State VOC NO,

20]8 Elllis~iolls (tPy)

CO SO, PM 10 NH,

Utility

Utility

Utility

Utility

Utility

Utility

Utility

Utility

Ulility

35 NM

3H ND

40 OK

41 OR

46 SD

4H TX

49 UT

53 WA

56 WY

N,~

Mexico

NOlth

Dakota

Oklahoma

Oregon

Soulh

Dakota

Texas

Utah

WashinglOn

Wyoming

Jk3

1.357

1,614

5 I

130

11.173

430

257

1,23!i

27,708

H4,762

lOX,55X

XH,543

10,094

17,542

219,X50

75,229

19,152

102,439

1,507.582

7,077

15,!i0!i

15,797

424

615

127,621

5,317

2,133

11.346

274,569

65,756

132.X36

79.824

3,935

11,102

471,544

23,763

H,721

69.3H3

1,717,088

9.161

3.604

2.3H9

257

55

23,362

2,561

2.955

11.100

88,569

2,707

2,(195

1,6H2

177

40

17.IX2

1,135

2,033

6.612

51,884

4

15

314

o

I

2.5!i3

3

o

o

4,105

2

2

2

J

J

3

3

J

J

3

3

J

3

3

3

3

3

3

3

3

Smellers

Smellers

Smeller!>

All

Others

All

Olhcr~

All

Olher:-

All

Olhers

All

Olhers

All

Olhers

All

Olher:.

All

Olhers

All

Others

All

Olhers

All

Others

All

Olhers

All

Others

All

Olhers

All

Others

All

Olhers

All

Olhers

All

Olhers

All

Others

All

Others

All

Others

All

Others

04

35

49

04

05

06

Ok

1(,

19

20

27

29

3(J

JI

32

35

Jk

40

41

46

4k

49

53

56

AZ

NM

UT

AZ

AR

CA

co

ID

IA

KS

LA

MN

MO

MT

NE

NY

NM

ND

OK

OR

so

TX

UT

WA

Wy

Arizol1a

N,~

Mexico

Umh

Arizona

Arkansas

Califolnl,j

Colorado

Idaho

lo.... a

Kansa"

Louisian(l

Minllesota

Mis,<,()Url

Monlana

Ncbra!>ka

Nnada

N,"

Mexico

North

Dakota

Okl.lholll<l

Oregoll

South

Dakota

Texas

Utah

Washinglon

Wyoming

2JI

10

k

249

9,!i44

IX,150

104337

43,7li4

275

12,553

:n,2X3

150,IXO

45,()40

91,069

7.451

12,954

1,740

n,14X

610

75,019

235X3

IA23

.136,691

12.1;; II

26,253

27,473

1,345

772

230

2,348

41,93H

22J)J7

106,707

4X.767

7,295

30.194

103540

241,227

93,179

42,155

I!i536

15,074

H.601

63.171

11.493

117,6H5

21,794

4,534

404.510

27,!i51

45,665

35,74 I

407

14 I

92

639

24,305

116,921

152.122

47.H5H

6.4 I(I

10,551

7H.427

576,HM

95,5HO

194,103

57,226

21.165

26.741

52.616

7.939

240.024

107,!iHH

()

458,311

55.474

27J,X4X

59,242

44564

35.236

1.036

80,836

2,267

X,972

31,197

]0,701

13,(,[ :;

3H.779

5,510

!i9,299

22,(124

76.64X

14,57X

6,602

::\.:154

32,129

50,975

16.566

4,453

172

170562

11,434

22,562

23,HHO

2,282

1,247

322

3.850

21.021

32.693

45.419

29.746

6.979

10,999

IH,XOI

35.74()

127,527

77,[63

II 105

II 163

16.652

1,32!i

1,9!i1

11,559

13.3HO

714

42,770

1!i,(194

11.365

20,940

1,2!i3

24k

IJO

1,661

6,5!i3

17,331

24,400

17,24()

4.314

6.16!i

13,120

26J13H

56.3X!i

2H.954

5,H!i2

4,41!i

5,!i56

1,439

6,24H

9563

392

n.xoo

10,979

7,974

13,145

o

o

47

4.

22

25.325

26,900

175

,

13.74(,

19.237

72.114

1,267

](J,]72

293

19

k('

128

1(,

27.010

Ik

1,756

1.111

6,660

LlS3

NM Regional Haze SIP

Proposed 7IJ 8103

1,057,674 1,511,694 2,663,616 656,277 567,147 294.759 233 ..'<:;09

PageG-17
MTF Ftype FIPSST State State

Code

VOC

2018 Emissions (tpy)

NO, CO SO, PM" PM,", NH,

Totals 1,085,632 3,021,623 2,938,824 2,454,201 659,566 348,303 237,661

The following table shows the electricity generating units in the GCVTC Transport Region with

predicted SO, and NOx emission changes in the air pollution prevention case.

Air Pollution Prevention Case Electricitv Generating Unit Emissions

Pollution

Percentage Milestone Prevention

Change' Case 2018 Case 2018 Dillerence

State Count" Unit IDORISID Plant NOx SO, NOx SO, NOx SO, NOx SO,

AZ Navajo 113 APS Choll, -40.52% -40.51 % 2.066 1.050 1,229 625 -837 -425

AZ Navajo 3 113 APS Cholla 0 344.45 4.081 2,292 4.081 10.189 0 7.896

CO Montrose 527 Nucla 0 -2.36 1,038 1,530 1.038 1,494 0 -36

NM SanJuan 2451 San Juan Generating -36.25 -36.25 6.926 7,170 4,415 4.571 -2,511 -2.599

NM San Juan 3 2451 San Juan Generating: -40.48 -25.07 9,911 8.459 5.899 6,338 -4,012 -2,121

W" Sweetwater BWn 8066 Pacitlcorp-Jim Brid!!er -0.04 5542 10,171 4.838 10,167 7.519 -4 2.681

34,193 25,338 26,829 30,734 -7,364 5,396

"'Compared with the 20 18 Milestone Case.

These model-eslimated changes occur at 6 units at 4 plants in 4 States (Arizona, Colorado, New

Mexico, and Wyoming). Expected SO, emission increases occur at Cholla #2 and Pacific CorpJim Bridger. These emission increases are offset by decreases in SO, emissions at Cholla #1,2

San Juan Generating Station units, and at Nucla. NO, emissions in the air pollution prevention

case are always lower than or equal to those in the milestone case. The largest NOx emission

reductions in the pollution prevention case occur in New Mexico at San Juan Generating Station.

NM Regional Haze SIP

Proposed 7/18/03

Page G-18
Renewable Resource Potential Maps

New Mexico Biomass Potential (from Renev.'able Energy Atlas of the West, Land and Water

Fund of the Rockies, DATE)

•

#

o

T~I PoLmli.)! (lMlbti.1;

n!!>- ..Xl)

t-"1 m.OOI-i,500, i

2.9"A~:'_),9J.I,.

• mCG1-:I.20000)

Leaend

ClI.Je,; y

Tran~n Lin~1..

New Mexico Geothermal Potential (from Renewllble Energy Atlas or the West. Land ~md Water

Fund of the Rockies, DATE)

G~olrc.m..'1 P01CT\ci~ In t"" IN.-<<.tprh t tn- ~rl ",... t'fr.-C

Leqend

G8ulfH-'f;la~'/"Ie"~,;-

•

; .../ 11.ansmr;;.sor. L'Jl<:lS

# IIH~:s!a1E' HJgn·....·iJ:r;:.

o \I\i,:::;len I R~9bn

, "" I.~ ,(J' IVa:

NM Regional Haze SIP

Proposed 7/1 8/03
New Mexico Solar Potential (from Renewable Energy Atlas of the West, Land and Water Fund

of the Rockies, DATE)

""nuilll Sol",. "ol.,,~ia' i<rl

FI.ot Pial" C.<>IlulOr (I"VI

Legend

• atH;~'

/'</ 'Trans:m;ssi:ln Li!1a~

.If '"IMsta1.13 ffigh·....·'lys

o Was-lam RegIOn

fl.'lo.-=Jf,Jl RNotJ!S.

The following wind potential map is from the Ne\v Mexico Energy, Minerals and Natural

Resources Department, Energy Conservation and Management Division.

NM Rcgion~1 Haze SIP

Proposed 711 R/OJ

Page G-20
.,.

~~-.

(.i)-~:'

f~_7¢

t ?O_1S g

to-o '. W< ~.

~\,I .(,.s

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N

,

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.......

"

"

1,"'......"10 ...... ,.

Mexico at 50 meters

r

/ .:\

\;~ ",-' --

'.-, / "1" [""" ... --i' )

/

"

\

/

,f

.t' •• j.....

-ri .. _

.... "IJ<.~l::.

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l(.an,,'l,JQI' 1!t!'l);,JO:;.e.t=:rl[· :2bojltl6QS,:«'I:«~ Tne-!:¥"..slTltl"",;:"hr.... ~i:Jm ....l~...,~,.aot ::I.e-.,

T~\·'.'>d~Il>'I$"OI'1;lh.tP' ... PQ\~'ERIII~cT:i" ,\. 1..,131' l/.J(\'\·..ulCSr.*~~(l)fl:)rxJl.

::1f'1l ·U!·iccllr~d"'"'l~~~fl "'.l"I!fIm:j~

i

(,

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I,

I

--.

'- "f"'-"

_.......,)

, -.... -....., ......:.....

; r":.:c:-,=,-:. -

TrueWind Solutions

0~._25 ... 100 150 2?2,.lies

- - kilOmeters

0 37,5 75 l:~: -1'50 225 300

Wind Speed Map of New

,-"

- U'(iQt)J.tI

N~.spj5tJ..n :Nl..Jo~rrl"::

NM Regional Hne SIP

Proposed 7/1 8/0)

Page G-21
Renewable Energy Genera/ion and Consumption in New Mexico

Ne,w Mexico produces 684 MW of electricity. Of this total, 0.66 MW are produced from wind

energy. Renewable energy generation is less than one percent of total energy generation in New

Mexico. Renewable energy consumption in New Mexico is 1,642 million kilowatt-hours. Total

energy consumption in New Mexico is 25 J billion kilowatt-hours. Renewable energy sources,

including solar, wind, hydropower, biomass, and geothermal, currently provide less than one

percent of New Mexico's annual energy needs.

New Mexico will rely on the programs outlined in Tables G-I and G-2 in Section G to meet the

10/20 goals of the Regional Haze Rule.

NM Regional Haze SIP

Proposed 7/18/03

Page G-22
Recommendations for Making

Attribution Detemlinations

in the Context of

Reasonably Attributable BART

Prepared by: The WESTAR Council

Prepared for: The Air Managers Committee, Western Regional Air Partnership

May 2003
Recommendations for Making

Attribution Determinations

in the Context of

Reasonably Attributable BART

Prepared by:

The WESTAR Council RA BART Phase JJ Working Group: Alice Edwards, Alaska Department

ofEnvironmental Conservation; Mike Sundblom, Arizona Department ofEnvironmental

Quality; Deb Wolfe, Montana Department of Environmental Quality; Dana Mount, North

Dakota Department of Health; Dave DuBois, New Mexico Environment Department; Colleen

Delaney, Utah Department of Environment Quality; Alan Newman, Washington Department of

Ecology; Lisa Reiner, Quinalt Indian Nation; Bruce Polkowsky and Kristi Gebhart, National

Park Service; and Kristin Gaston and Bob Lebens, WESTAR.

Prepared for:

The Air Managers Committee ofthe Western Regional Air Partnership

in fulfillment ofthe Western Governors' Association contract #30203-13

May 2003
Acknowledgements

The recommendations regarding the attribution process, the applicable technical

approaches and the examples in this report are the product of the RA BART Phase 11 Working

Group. The WESTAR Council acknowledges the generous support of all the Working Group

members. Alice Edwards, Alaska Department of Environmental Conservation; Mike Sundblom,

Arizona Department ofEnvironmental Quality; Deb Wolfe, Montana Department of

Environmental Quality; Dana Mount, North Dakota Department of Health; Dave DuBois, New

Mexico Environment Department; Colleen Delaney, Utah Department ofEnvironment Quality;

Lisa Reiner, Quinalt Indian Nation; Bruce Polkowsky and Kristi Gebhart, National Park Service;

and Kristin Gaston and Bob Lebens, WESTAR.

Authors ofthe Attribution Techniques (Section VI) are Mike Sundblom (Monitoring);

Kristi Gebhart (Receptor Modeling); and Dave DuBois (Source Modeling), with assistance from

Ajith Kaduwela, California Air Resources Board. Bruce Polkowsky and Colleen Delaney

drafted the certification section and provided liaison between the Western Regional Air

Partnership Market Trading Forum and the Working Group. Alan Newman, Washington

Department ofEcology drafted the portion of the report outlining the example process to which

Dana Mount also contributed. Kristin Gaston drafted the regulatory context section and along

with Bob Lebens, edited the report.
EXECUTIVE SUMMARY

This report recommends a general procedure and applicable technical approaches that may

be used by states and tribes to assess reasonable attribution in response to a Federal land manager

(FLM) certification of visibility impairment in a Class I area (Certification).

WESTAR fonned the Reasonably Attributable Best Available Retrofit Technology (RA

BART) Phase II Working Group with Federal land management agency staff and members of

state and tribal air quality agencies knowledgeable about RA BART and associated monitoring

and modeling techniques. To provide the necessary framework, the report provides background

infonnation about both the certification process and the attribution detennination process.

However, the recommendations focus on the general principles ofthe attribution assessment

process and the technical criteria used in the assessment.

The recommendations are summarized below:

General Principles:

The attribution assessment should be:

o A collaborative process that relies on existing data with minimal additional

analyses.

o Technically and legally defensible.

o Accomplished at a reasonable cost and within a reasonable time frame.

o No more complex than necessary.

o Perfonned by state or tribal agency staff.

o Adequate to determine whether or not visibility impainnent is attributable to an

existing stationary source potentially subject to BART.

Technical Criteria:

o

o

o

o

o

•

o

Emissions from BART-eligible sources must "cause or contribute to" visibility

impairment. Visibility-impairing pollutants of concern must be identified.

Factors to consider in assessing impairment include: duration, frequency,

geographic extent, magnitude, and time of occurrence.

Identify distance from source to Class I area to detennine appropriate tools for

characterization ofthe impainnent.

Quantitative results are preferable, although qualitative results such as

photographs may be adequate.

Use as many different indicators of impairment as practicable rather than relying

on a single indicator.

Consider level of uncertainty in the assessment.

Use EPA guideline models whenever practicable.
Table of Contents

I. Background I

A. Introduction and Purpose

B. Regulatory Context

II. Federal Land Manager Certification ofImpairment 7

III. The Attribution Determination Process 11

IV. General Principles and Criteria 17

A. General Principles ofthe Attribution Process

B. Technical Criteria

C. Examples ofthe Attribution Process

V. Techniques 31

A. Monitoring

B. Source Modeling

C. Observational Modeling

VI. Appendix

RA BART Rule (40 CFR 51.300-306)
I. BACKGROUND

A. Introduction and Purpose

Reasonably Attributable Best Available Retrofit Technology (RA BART) is the portion of

EPA's visibility rule published in 1980 and codified in 40 CFR 51.302-51.306 that deals with

visibility impacts from one source or a small groups of sources. RA BART refers to reasonably

attributable visibility impainnent and best available retrofit technology for eligible sources and

emission limits, and emissions controls as defined by the statute and the rules. Some confusion

exists regarding the application of RA BART, the process of assessing sources of visibility

impairment, and the technical tools available for an RA BART attribution detennination. RA

BART is a statutory requirement, although certain ofthe requirements may no longer be

applicable when a source complies with BART or installs BART-like controls or after a state

implements a trading program under 51.308(e)(2) or any trading program under 51.309, and ifno

remaining visibility impacts continue from one source or a small group ofsources.

This report, therefore, addresses the RA BART attribution process and builds upon case

studies WESTAR developed in 2001 to examine and document how Reasonably Attributable

Visibility Impainnent (RAVI) had been addressed in previous assessments.'

The Federal land managers (FLMs) advocate maintaining RA BART as a tool because RA

BART is effective when new monitoring indicates that a previously un-monitored area has

visibility problems differing from the regional visibility impairment conditions at other areas. In

addition, RA BART is effective when BART-eligible sources in the vicinity ofthe protected area

are causing or contributing to identified visibility impainnent2

First, this report recommends attribution process principles and assessment techniques a

state or tribe may consider in an attribution assessment to identify if, and to what degree, an

existing source or small group ofsources causes or contributes to visibility impainnent. The

report focuses on RAVI and does not specifically address impairment due to regional haze.

Although this report includes references to regional haze, such references serve only to place the

attribution process in the larger context ofthe broad regulatory framework that addresses

visibility impairment, including the regional haze regulations.

Second, this report includes no recommendations with regard to establishing a threshold

level at which reasonably attributable impairment exists. Instead, the working group outlined a

recommended general process and recommended technical procedures that may be used as

guidelines if an attribution assessment is necessary. Due to the circumstances unique to each

attribution assessment and the requirement that the assessment be conducted on a case-by-case

basis, recommending one specific analysis for every situation was not possible. A state or tribe

should select from the techniques summarized in Section IV. Section IV(CJ includes five

examples of the attribution assessment process, each providing a range oftechniques to be used

I WESTAR Council, RA BART and RA BART-like Case Studies, June 2001.

2 This document specifically relates to RA BART and does not address broader issues relating to long-term visibility

strategies. FLMs generally do not intend to issue Certifications citing specific sources except for situations involving

BART sources.

I
based on available data. The examples also recommend more refined analyses that may require

additional data

Third, this report includes specific infonnation about the current policy of FLM agencies

regarding certifications ofimpairment (Certification), but makes no recommendations regarding

the certification process. This report makes no recommendations regarding state process

following an attribution determination nor examines options for perfonning the Best Available

Retrofit Technology (BART) analysis or the incorporation ofBART requirements into State

Implementation Plans (SIPs).

Tribal Implementation

The recommendations in this document are intended to help states assess reasonable

attribution following Certification by an FLM. Subject to the requirements ofthe Clean Air Act,

42 USC 7601(d) and the Tribal Authority Rule, 40 CFR 49.1- 49.11, a tribe may accept

responsibility for making reasonably attributable detenninations in response to a Certification by

an FLM when a BART-eligible source identified by the FLM in the Certification is on the tribe's

land. The regional haze rule also explicitly recognizes the authority oftribes to implement the

provisions ofthat rule on tribal lands. Those provisions create the following framework:

I. Absent special circumstances, reservation lands are not subject to state jurisdiction.

2. Federally recognized tribes may apply for and receive delegation offederal authority to

implement CAA programs (including visibility regulation), or "reasonably severable"

elements of such programs. The mechanism for this delegation is a Tribal

Implementation Plan (TIP). A reasonably severable element is one that is not integrally

related to program elements that are not included in the plan submittal, and is consistent

with applicable statutory and regulatory requirements.

3. Where a tribe does not seek delegation through a TIP, the Environmental Protection

Agency (EPA), as necessary and appropriate, will promulgate a Federal Implementation

Plan (FlP) within a reasonable timeframe to protect air quality on tribal lands.

Accordingly, these recommendations also may assist a federally recognized tribe that

chooses to adopt a TIP to implement the RA BART provisions. In some cases, a tribe may be

able to utilize the recommendations in much the same way as states. In many other cases,

however, the recommendations may be modified to meet the unique situation of the tribe and the

nature ofits air program, including its manner of defining "reasonably severable elements" and

its method of dividing responsibilities between the tribe and EPA. Because of these differences,

the recommendations that follow do not refer to tribes every time states are referenced.

B. Regulatory Context

The national goal for visibility is set forth in the Clean Air Act (CAA) at 42 USC 7491: "the

prevention of any future, and the remedying of any existing, impairment of visibility in

mandatory Class I Federal areas which impainnent results from manmade air pollution." The

requirements apply to 156 designated Class I areas.

2
As stated previously, Congress required that states provide a remedy for visibility

impairment that was "reasonably attributable" to one source or a small group ofsources. (42

USC 7491). Congress directed EPA to ensure that all SIPs contained measures necessary to

make reasonable progress toward meeting the national goal, including requirements for

identifYing major sources of emissions causing or contributing to visibility impainnent, and

requirements for the application ofBART on such sources. EPA promulgated rules pursuant to

Congress's directive to provide guidelines to the states on appropriate techniques and methods

for implementing the SIP requirements. (40 CFR 51.302(c)). (Note: when this report refers to a

"source" within the meaning ofthis regulation, the phrase "or a small group ofsources" is

implied.)

The requirement to install Best Available Retrofit Technology controls on existing sources

is a key element ofthe visibility protection provisions in the CAA demonstrating the need to

focus on pollution emitted from a specific set of existing sources. Sources are potentially subject

to BART controls if they meet the following criteria:

1. A major stationary source from I of 26 source categories identified in the CAA and

regulations (see Appendix A);

2. Potential to Emit (PTE) 250 tons per year of any air pollutant; and,

3. Not in operation prior to August 7, 1962 and "in existence" on August 7, 1977.

In the 1980 visibility rule, EPA used the tenn "existing stationary facility" to define a

facility that met the above criteria. However, to avoid any confusion about whether that term

encompassed a larger group ofsources, EPA now uses the tenn "BART-eligible source." The

tenn "BART-eligible source" is used throughout this report for similar reasons, but the reader

should be aware that some sections of the visibility rule still refer to "existing stationary

facilities." For purposes of the attribution discussion in this paper, these tenns are

interchangeable.

In 1999, EPA added two new sections to the visibility rule to address regional haze (40 CFR

51.308 and 51.309). Pollutants causing regional haze may be transported hundreds of miles, and

therefore, regional haze must be addressed as a broader regional issue. The 1980 visibility rule

focused on direct visibility impacts of an individual source or small group of sources. The 1999

revisions are commonly referred to as the regional haze rule, although the 1999 rule incorporates

the earlier requirements for BART as well as the new regional haze provisions.

To remedy RAVI, the regulations outline a process to identifY and control emissions from

sources that are directly impacting visibility at specific Class I areas (40 CFR 51.302). Three

primary steps in this process are:

I. The Federal land manager certifies impainnent;

2. The state identifies existing sources that cause or contribute to the visibility

impairment; and

3
3. The state perfonns a BART analysis to detennine what controls, if any, are required

on any existing source that meets the BART criteria and has been identified as

contributing to the impairment.

Allribution Process

The language of 40 CFR 51.302(c)(4)(i) provides the basic principle upon which the state

will rely during the attribution process. That section states that the attribution must indicate each

[BART-eligible source] "which may reasonably be anticipated to cause or contribute to

impairment ofvisibility." Whether or not the impainnent is "reasonably attributable" is

detennined by "visual observation or other technique the state deems appropriate." (40 CFR

51.301(s)). Because the state is responsible for identifying sources, this report provides

recommendations for the state to consider when it undertakes an attribution detennination.

Once visibility impairment is identified, RAVI is addressed on a case-by-case basis. Under

the 1980 regulation, a state evaluates BART-eligible sources only after an FLM certifies the

existence of visibility impairment. However, in the context ofthe current re~ional haze rule,

states must also address BART requirements for regional haze (RH BART). Several options

exist for addressing RH BART. For example, rather than require a source-specific BART

emission limit, a state may choose to develop a trading program, either regionally or within its

own jurisdiction, that achieves greater reasonable progress than case-by-case RH BART.

If a state develops a trading program, the time period to achieve the emissions reductions

may be extended. As a result, visibility conditions at a specific Class I area initially may remain

static or even deteriorate during the early implementation period. During this time, FLMs have

indicated that the RAVI process may be utilized to provide steady and continuing improvement

in visibility. Within the context ofthe regional haze rule, this may be an example of a

"geographic enhancement." As noted above, the recommendations in this report apply only to

case-by-case applications of BART and are not intended to apply to the broader regional haze

rule such as a market-based trading program implemented as part ofthe 1999 rule.

A state may find it difficult to detennine a source/receptor link for RAVI difficult when

there are other sources located in the area, including international sources. However, the regional

haze rule provisions do not alter the requirement to undertake the attribution assessment.

State determines what controls, ifany, are required

After the attribution detennination, the state is required to perfonn a BART analysis to

detennine what types of controls, if any, should be placed on the source(s) found to be

contributing to the impairment. The following factors affect the BART detennination:

1. Available technology;

2. Costs of compliance;

3. Energy and non air quality environmental impacts of compliance;

3 The RH BART provision was remanded to EPA by the U.S. Court of Appeals as a result ofthe ruling in American

Com Growers Association v. EPA, No. 9901348 (DC Cir. May 24, 2002)

4
4. Remaining useful life of the source; and,

5. Degree ofimprovement that can be anticipated to result from the use ofthe controls.

As noted above, this rep0rl does not provide guidance regarding state process following an

attribution determination nor does it examine options for implementing the BART requirement.

5
6
II. FEDERAL LAND MANAGER CERTIFICATION OF IMPAIRMENT

The Federal land managers monitor visibility through a nationwide monitoring network,

known as Interagency Monitoring of PROtected Visual Environments (IMPROVE). The

IMPROVE network has recently been expanded and the FLMs anticipate reliable trend data for

the new IMPROVE sites between the years 2006 and 2008. The FLMs plan to evaluate the

current visibility conditions in Class I areas as well as trends occurring over time to identify

areas where visibility is not improving.

The FLMs generally will use a screening process to identify Class I areas that may be

affected by RAVI. This screening process will be influenced by the approach the state relies

upon to address RH BART in its SIP. There are three approaches that may be used.

I. Case-by-Case Review ofRH BART under 51.308

No distinction exists between emission reductions needed to address RH BART and

reductions to address RAVI, therefore, the BART process will address both types of visibility

impairment.

2. Trading Program under 51.308

The FLMs anticipate that the following screening criteria may be appropriate, but will not

make a final decision until a 308 trading program has been developed. The screening criteria

associated with this approach may be simi lar to the screening criteria associated with the trading

program option under 51.309. However, the FLMs have indicated that the screening criteria

ultimately selected for 51.308 will depend on how the trading program is structurcd, the selected

emissions cap, and other aspects ofthe trading program.

Potential Screening Process Criteria:

(i) Sulfate, nitrate, organic carbon, other fine particulate, etc., levels in the Class I

area are not decreasing. 4

(ii) One or more BART-eligible sources ofS02, NO" VOC, PM 10, etc., are located

within 100 miles of the mandatory federal Class I area.

(iii) The BART-eligible sources identified in (ii) are not already well-controlled for

pollutants that contribute to visibility impainnent.

3. Milestones and Backstop Trading Program under 51.309

The FLMs plan to sign a Memorandum of Understanding (MOU) with the participating

states to define the screening criteria the FLMs will use to certify impainnent.

4 The decrease ora pollutant (or secondary species of that pollutant) would be measured from the beginning of the

market or emissions trading program, and such a trading program would take a long time (10 to 15 years) to reach

the level of reduction that "meets" BART. The decrease would be tested over the first 5 to 10 years. A very quick

lime frame for reductions would negate the need for RA BART criteria.

7
Screening Process criteria;5

(i) Sulfate levels in the Class I area are not decreasing.

(ii) One or more BART-eligible sources ofS02 are located within 100 miles ofthe

mandatory federal Class I area.

(iii) The BART-eligible sources identified in (ii) are not already well-controlled for

S02 (85% or better S02 control for coal-fired utility boilers).

Goal: For FLMs to complete the certification process between 2006 and 20086

These criteria were influenced by the design ofthe 309 trading program including emission

reduction estimates, shape ofthe declining emission cap, inclusion ofsources that were not

BART-eligible, and inclusion of new source growth under the cap.

Although geographic enhancements do not need to be addressed under the first approach,

they must be addressed in the two trading programs described above because emission

reductions may occur more gradually in the context of a trading program. The FLMs do not

anticipate certifying impainnent under these circumstances but do intend to notify the state as

part ofthe SIP development process if concerns arise regarding "hot spot" impacts from sources

that may directly affect specific Class I areas.

Note: BARTfor regional haze has been addressedfor SOl under this option. Regional haze

BART for NO, and PM will be addressed in SIP revisions that are due in 2008.

In all three cases discussed above, if the FLM detennines that a certification of visibility

impairment is necessary, the FLM will send an official Certification to the state. The

Certification will generally include the following infonnation:

1. Class I area(s) impacted;

2. Basis of certification (photographic documentation, monitoring, modeling, etc.);

3. Type ofimpairment certified: plume impact, or layered or unifonn haze;

4. Pollutant(s) of interest; and,

5. Preliminary identification ofsource(s) believed responsible for impact.

FLM, State, and EPA roles in RA BART

FLMs are responsible for certifying impainnent. The Certification demonstrates the FLM's

detennination that there is evidence of visibility impainnent from one source or a small group of

sources.

;Ii Within the context of established regional mileslOnes for S02 and a backstop trading program, the FLMs have said

it is appropriate Lo use the following screening process in making these recommendations as part ofthe Certification.

Voluntary Emissions Reduction Program for Major Industrial Sources ofSulfuf Dioxide in Nine Western States and

A Baekstop Trading Program. An Annex to the Report of the Grand Canyon Visibility Transport Commission.

Submitted by the Western Regional Air Partnership to the U.S. Environmental Protection Agency, p. 61, September

29,2000.

(, This goal will not in any way restrict the ability of the FLMs to eertify impairment at a later date if it is necessary

to fulfill their statutory obligations. ibid.

8
Following the Certification, states have the following regulatory obligations: (1) identify

facilities that "emit an air pollutant which may be reasonably anticipated to cause or contribute to

any visibility impainnent" in that Class I area, and (2) for sources subject to BART, the state

must identify the BART level of control technology. If the source does not have adequate control

in place, the state must establish a BART limit in the SIP.

EPA has two major responsibilities for the RA BART requirement. First, in the states that do

not have a SIP in place to address the RA BART requirements, but where the program is

implemented through a FIP, EPA will conduct the BART analysis and establish any BART

emission limits. Second, for the states with SIPs that include RA BART regulations, EPA will

provide federal enforcement ofstate-established BART emission limits.

9
10
III. THE ATTRIBUTION DETERMINATION PROCESS

This section recommends a process for the state to follow in order to complete an attribution

detennination after receipt of a Certification from an FLM under 40 CFR 51.302(c)(l).

The Certification focuses on the existence of visibility impainnent. While the FLM may

identify sources or even sources areas that contribute to the Certification, the fonnal

identification ofsources is a state responsibility.

The state should make a detailed review of the data supporting the Certification to detennine

which sources or source areas require further evaluation. If the data are insufficient to identify

specific sources or source areas, the state may request that the FLM perfonn more detailed

analyses to further substantiate the impairment set forth in the Certification.

If the state detennines sufficient infonnation exists to proceed, the state should begin the

process by: (1) evaluating which sources are BART-eligible, and (2) reviewing the impainnent

infonnation provided by the FLM in support ofthe Certification.

1. Evaluate which sources are BART-eligible

Congress and EPA established criteria to detennine which sources are subject to BART. The

categories ofsources subject to BART are listed in 40 CFR 51.301, the definition of "existing

stationary facility," and also are included in Appendix A ofthis report.

The state must confinn that the potential source or group ofsources is subject to the RA

BART process by examining the potential source emissions and the dates of operation.

The criteria for detennining if a source is BART-eligible may be complicated if a source has

multiple units that were constructed at different times and a state may be unable to detennine if a

specific source would qualify as BART-eligible. EPA published guidelines in 1980 to aid states

in implementing the 1980 rule.' In addition to the 1980 guidelines for detennining BARTeligibility, EPA also has proposed guidelines that include criteria for determining if a source is

BART-eligible8 These guidelines are expected to be re-proposed in 2004, promulgated in 2005

and codified at 40 CFR Part 51 as Appendix Y. The state should refer to both sets of guidelines

to detennine if a source is BART-eligible, although the proposed guidelines are not binding until

final promulgation occurs.

When using the applicability criteria in Appendix Y, the state should look for information

readily available from existing state data such as pelmitting history, emission inventory, or other

similar databases.

7 U.S. Environmental Protection Agency, Guidelinesfor Determining Best Available Retrofit Technology/or Coa/-

fired Power pions ond Other Existing Stolionory Focilities. EPA-450f3-80-009(b), Office ofAir Quality Planning

and Standards, Research Triangle Park, N.D., November 1980 (1980 BART Guidelines).

'66 FR 38108 Proposed Guidelinesfor Best Avoilable Retrofit Technology (BART) (July 20, 2001). EPA will repropose these guidelines as a result oflhe remand in American Corn Growers v. EPA.

II
1. If a database of Potential To Emit (PTE) is not available, state emission inventories

can be a useful screening tool to detennine whether a source meets the size criteria

(for example, identify all sources with emissions greater than 100 tons/year of

visibility impairing pollutants). Operating pennit applications may also contain

infonnation about the PTE of a source, or individual units within a source.

2. State business records may be useful to determine when the facility was constructed

or when it commenced operation. Newspaper article searches or a detailed historical

review of each source may also provide useful infonnation.

3. The state should require the source to provide infonnation regarding the construction

dates ofindividual emission units.

4. Institutional memory within the air agency can be invaluable if records of

construction dates ofmajor emission units are not available, although memories will

not withstand legal challenges like hard documentary data.

5. New Source Review pennitting records may be useful to identify new units that were

constructed after 1977, detennine the PTE ofthe source, or detennine if

reconstruction has occurred. (Note: the draft guidelines in Appendix Y state that

modifications at a source do not affect applicability unless the change qualifies as

reconstruction ofthe source).

If the source or group ofsources identified in the Certification is not BART-eligible, the

state should infonn the FLM of its finding. The state should look in the vicinity of all the sources

suspected of causing or contributing to the impaimlent identified in the Certification. If no

BART-eligible sources exist, an attribution assessment is unnecessary.

2. Review Support Inforlllation in the FLM Certification

Initially, the state should acquire all the supporting infonnation the FLM used in the

Certification and independently evaluate the data. This initial review will help the state

detennine if the infonnation is sufficient to support a reasonable attribution detennination.

The state should consider the type of impairment in the Certification: (a) plume impact

visibility impairment, (b) unifonn haze visibility impainnent, or (c) layered haze visibility

impainnent:

(a) Plume impact is the impainnent addressed by the original visibility protection

program under which the state must make a reasonable attribution

detennination before proceeding to the BART analysis (40 CFR 51.301-

51.307).

(b) In some instances, unifonn haze may be thought to be source-specific haze

from a BART-eligible source. If a state can successfully demonstrate there is a

source emitting any air pollutant that may reasonably be anticipated to cause or

contribute to any impainnent of visibility, the state should consider that portion

of the uniform haze to be impact from the identified source(s) and, therefore,

consider the source to be subject to BART.

(c) The visibility impainnent may also be defined as layered haze, a condition that

results when aerosols are "trapped" under stagnant air mass conditions.

12
Once the FLM has issued a Certification, the responsibility for the attribution assessment

shifts to the state. If a state does attribute impainnent to a source, the state must be able to defend

its finding that one or more BART-eligible sources did cause or contribute to visibility

impairment in the Class I area. However, the Ninth Circuit Court of Appeals established a low

threshold for unacceptable visibility impainnent9

3. Evaluate Existing Data not included in the Certification

When analyzing supporting data, the state should determine if additional infonnation exists

that was not available to the FLM. Examples include special project camera studies or ambient

monitoring data collected by the state or local air pollution control agency, the potential or actual

PSD pennit applicant, 10 or the university. In certain situations, another agency may have

previously collected infonnation that could be used in an attribution detennination.' , These data

should be reviewed to detennine whether they support the FLM Certification.

To conclude this portion of the attribution process, the state may wish to prepare a report that

summarizes its initial evaluation ofthe Certification. The purpose of the report is to carefully

document the state's findings and conclusions about its decisions. The report would address two

questions:

First, the report would assess whether any BART-eligible source(s) exist that potentially

contributed to visibility impainnent as described in the Certification. The report would contain a

preliminary detennination of whether the sources are BART-eligible and, if possible, analyze

each source's relative contribution to the impairment (based on available source/receptor

information).

Second, the report would assess the impairment data. This assessment would include the

state's evaluation of the supporting data in the Certification and an analysis of any additional

data used in the attribution assessment. The data gaps found in this review would be identified

along with any recommendations for strategies to obtain the missing information. The state may

use these recommendations to determine the next steps in the attribution process.

If the state believes the Certification is supported by sufficient data, proceeds with an

attribution assessment and makes a detennination that the data does or does not indicate a source

subject to BART, the attribution process is complete. However, if the state detennines the data is

insufficient to complete an attribution assessment, the evaluation process ends, and the state may

proceed to the next step---identification of data gaps and the studies necessary to obtain this

infonnation.

, See Central Ariz. Water Conservation Dist v. EPA. 990 F.2d 1531 (9th Cir. 1993): See also discussion in RA BART

and RA BART-like Case Studies.

10 For example, a PSD pennit applicant may be required to obtain pre-application ambient air quality infonnation,

and that infonnation may not have been available to or known to the FLM.

11 In Washington state, the plume ofa defunct copper smeller has been traeed by its arsenic deposition. If this were

an active facility, this ground tracing of the plume could be used to support a source/receptor connection in an

attribution dClenninatioll.

13
4. Identify data gaps and necessary studies to fill the gaps

As part of the data review, the state should note gaps or inconsistencies in the available data.

Examples of data gaps and inconsistencies may include:

I. Missing photos in a sequence of photos,

2. Poor resolution ofthe plume or its source in the photos,

3. Back trajectory analyses done with a very large grid resolution or poor techniques,

4. IMPROVE monitor data missing at critical periods,

5. Lack of association between the source's emissions and monitored data at the receptor,

6. Special studies performed during a time when a source that potentially contributed to

the impairment was not operating,

7. Contemporaneous studies with contradictory results that cannot be explained,

8. Ambient studies that use naturally occurring tracers and, when the suspected source(s)

are tested, the tracers do not exist or exist at levels far below (or above) the level

indicated by the ambient study results,

9. Tracer studies where the tracer was not found at the anticipated receptors,

10. No explicit exploration ofwhether wildfire or other natural events significantly caused

or contributed to one or more of the impairment episodes,

II. Other differences or inconsistencies in the available data.

Once any data gaps have been identified, the state should decide which studies are necessary

to obtain the missing information sufficient to complete an attribution assessment. The state

should design potential studies and detennine the resource needs of those studies. The amount of

work necessary will depend on the availability of the information and how critical the

infonnation is to the attribution assessment. Section IV provides technical criteria and examples

of the technical process the state may consider at this point in the process.

5. Consultation Process

The WESTAR review of previous RAVI assessments demonstrated the importance of

including all stakeholders in the design of any data collection plans or modeling protocols.

Competing studies can be very inefficient, expensive, and time-consuming, and ultimately may

not help the state make a final decision.

Ifstakeholders are involved in the design of any data collection efforts or modeling

protocols, disagreements may be resolved before the state or source continues with any

additional studies. The state should consider involving the following stakeholders in the

consultation process:

I. Affected sources

2. Neighboring states and tribes

3. Environmental Protection Agency

4. Federal land managers

5. Local environmental groups

6. Local permitting agencies

14
7. Local government representatives

6. Completion and Review ofAdditional Visibility Studies

When the additional visibility studies, if any, are complete, the state should evaluate the

resulting data. The technical staffmay wish to finalize the report and make recommendations

based on the scientific aspects ofthe data.

7. Final Deterlllillation ofReasonably Attributable Visibility Impairment

The state may reach anyone ofthe following conclusions:

I. The impairment certified by the FLM is reasonably attributable to the identified BARTeligible source(s) for specific pollutants;

2. The impairment certified by the FLM is reasonably attributable to the source(s)

identified by the FLM and additional sources not identified by the FLM for specific

pollutants;

3. There is inadequate data to support a determination that the impainnent is due to the

source(s) identified by the FLM;

4. The impairment is reasonably attributable to other adjacent BART-eligible sources for

specific pollutants; or

5. The impairment certified by the FLM is not reasonably attributable to a BART-eligible

source.

15
16
IV. GENERAL PRINCIPLES AND CRITERIA

This section provides general principles and technical criteria for the state to consider after

receipt of an FLM Certification. After receipt ofsuch a Certification, the state must determine

whether BART-eligible sources "emit any air pollutant which may reasonably be anticipated to

cause or contribute to any visibility impairment in any" Class I area. While these principles and

technical criteria should generally be useful and applicable, each state must decide what is

required to support its individual determination.

Part A contains general principles to guide the development of a conceptual framework for

the attribution assessment process. Part B contains evaluation criteria to guide the decisions

regarding a technical framework for the attribution assessment process.

Conceptually, the statutory framework for an attribution detennination ("may reasonably be

anticipated to cause or contribute to visibility impairment") should be the general principle

guiding the attribution process. EPA maintains, and the Ninth Circuit agreed, that an affinnative

attribution decision is possible even with considerable uncertainty and a low triggering threshold.

However, each state should decide individually what is required to support its determination.

A. General Principles ofthe AI/ribation Process

Attribution process criteria address factors likely to influence the perfonnance ofthe state

attribution assessment. These criteria provide parameters to define and implement the attribution

assessment process given resource constraints, legal considerations, administrative

decisionmaking requirements, and other relevant factors. The general principles include the

following:

I. Whenever possible, an attribution assessment should be a collaborative process that

relies on existing data with a minimum of additional analysis (see section Ill). If

supplemental data are needed, field studies should be designed in a collaborative

process between affected states and tribes, identified sources, Federal land managers,

EPA, and the general public. Past experience has shown that competing technical

studies often result in an unnecessarily expensive and unduly complicated process.

2. Attribution assessments should be technically and legally defensible.

3. Attribution assessments should be accomplished at a reasonable cost and within a

reasonable time frame.

4. Attribution assessments should be no more complex than necessary, recognizing that

the circumstances surrounding a Certification may vary greatly. State or tribal agency

staffshould be capable of performing the attribution assessment and making the final

detennination, although contractors may be used for certain types of modeling or

monitoring.

5. Reasonably attributable visibility impairment can only be identified if a source/receptor

17
links a potentially BART-eligible source or small group ofsources to a Class I area.

B. Technical Criteria

The technical criteria address the appropriateness of available analytical techniques from a

scientific perspective. The rule defines visibility impairment to mean "any humanly perceptible

change in visibility (light extinction, visual range, contrast, cOloration) from that which would

have existed under natural conditions."

The technical criteria include the following:

I. The BART source must emit an air pollutant that may reasonably be anticipated to

cause or contribute to any ofthe impairment The visibility-impairing pollutants of

concern must be identified.

2. The attribution assessment should address the unique visibility impairment in the FLM

Certification for the Class I area. Some factors to consider include:

a. Duration: source's length of effect on visibility per episode;"

b. Frequency: how often episodes of impainnent occur;

c. Geographic extent: how much ofthe Class I area is affected by the impainnent;

d. Magnitude: how much visibility impainnent is due to the source's emissions; and

e. Time of occurrence: including time of day and time of year.

These factors need to be considered together, because they affect each other. An

infrequent occurrence of a large magnitude episode may meet the criteria. A frequent

occurrence of a small magnitude episode may also meet the criteria. The FLM may

provide infonnation about these criteria in the Certification, and the state should review

this infonnation as a starting point for its assessment The state may consider other

factors and data, as appropriate.

3. The attribution assessment should identitY the distance from the source to the Class I

area. This distance will affect the choice oftools appropriate for characterizing the

specific source's impact on visibility impairment

4. To the extent possible, the attribution assessment should be quantitative. Under certain

circumstances, qualitative infonnation, such as photographs or time-lapse video of

distinct plumes or source-specific haze events, may be adequate.

5. The state should use as many approaches or indicators ofimpairment as practicable

12 Based on previous cases, most impairment episodes are relatively short-lasting one to several hours-which may

affect monitoring and other assessment techniques.

18
rather than relying on a single method. The assessment may rely on air monitoring and

modeling techniques and other supporting scientific data. Consistency between source

and observational techniques strengthens the analysis.'3

6. The state should consider the level of uncertainty in the assessment.

7. EPA guideline models should be used whenever practicable. When other models are

used, additional technical discussions with EPA may be necessary.

C. Examples ofthe Attribution Process

The state should consult this section after evaluation of the FLM Certification. At this point,

the state will already have decided what gaps need to be filled to complete the attribution

assessment.

The recommendations in this report recognize that each attribution detennination will be

unique. Because an attribution detennination is a fact-specific and individual detennination, it is

not possible to recommended a single technical approach for a state to follow. A combination of

monitoring and modeling techniques is usually appropriate, but instead of attempting to cover all

possible combinations oftechniques, this report provides five selected scenarios. The general

principles and technical criteria identified in sections A and B are incorporated into these

scenarios. The goal is to provide the state with references for use when it is creating its own

individualized technical procedure.

In addition to the scenarios, this report provides detailed tables and narrative descriptions of

techniques that may be considered and/or substituted for the techniques in the scenarios (see

Section V).

Scenario 1: Limited data/one source

Data input Small amount of existing data (i.e., one IMPROVE site with data for 2-3 years)

Evidence of "local" impact.

Limited meteorological data.

Where it is likely that one major source contributes to impainnent, a combination ofthe

following techniques is suggested:

I. Examine IMPROVE data, including quality assurance

2. Look at extinction budget to identify visibility-impairing pollutants

3. Perfonn some analysis of when the episodes are occurring

4. Perfonn a simple back trajectory analysis using a method such as HYSPLIT

5. Look at relationships between particulate species

6. Examine source emissions data for correlations with ambient monitoring

7. Perform dispersion model based on data and capabilities such as VISCREEN or

CALPUFF Lite

13 WESTAR Council, RA BART alld RA BART-like Case Studies, June 2001.

19
8. Examine other data such as source owner data, deposition data, or photographic

evidence

The results ofthis initial analysis may not always be conclusive. This level ofreview may be

adequate if a sourcelreceptor relationship can be identified. However, ifthe results are

inconclusive, more data and/or more refined analyses may be necessary and may help the state

reach an attribution determination. The state should consider how the available data and choice

of techniques might affect its ability to assess the effectiveness ofthe controls in remedying the

impairment.

It may be efficient to look ahead to the data and analytical needs of a potential BART

analysis. For example, the state may wish to use a more refined model that would be useful for

both attribution and remedy assessment.

Assuming there is a two-year time period14 to collect data and analyze additional infonnation,

the following techniques also can be considered:

I. Better source characterization, including measurement of emissions oftrace elements

(source profiles) for use in CMB modeling

2. Met monitoring or modeling

3. Camera site, possibly with time-lapse video

4. Additional aerosol monitoring, episodic or saturation

5. In plume trajectory by aircraft, if available

6. Fine time-resolved optical monitoring, such as nephelometer, transmissometer,

aethelometer combined with pollutant monitoring (e.g., S02, NOx, real time PM) for

monitoring of episodes

7. More refined chemical visibility model, such as CALPUFF

8. Repeat initial techniques with new data

The technical criteria are listed below, followed by techniques that may be used to obtain results

about the criteria.

I. The impainnent must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified.

Techniques: Back trajectory, species relationships, relationship between source

emissions and ambient monitoring, dispersion model refined by camera, aerosol, in

plume, optical monitoring, and refined dispersion models.

2. The attribution assessment must address the unique visibility impainnent certified by

14 The 1999 regional haze rule revised the requirements for general plan requirements for visibility protection. As a

result, plan revisions are required once every five years, rather than the Long Teml Strategy review requirement of

every three years. If an FLM eertifies RAVI at least 6 months prior to a plan revision, section 51.302 requires that

the State Plan revision address such Certifieations. Given this 5-ycar cycle, we have presumed for this report that an

attribull0n analysis should take about two years to complete in order to allow time for the BART engineering

analysis, ifneeded.

20
the FLM for the Class I area. Some factors to consider include:

a. Duration: source's length of effect per episode

Techniques: Monitoring, dispersion model, back trajectory, camera

b. Frequency: how often the impairment occurs

Techniques: Monitoring, dispersion model, back trajectory, camera

c. Geographic extent: how much ofthe Class I area is impaired

Techniques: Monitoring, dispersion model, additional data on deposition and other

studies

d. Magnitude: how much impainnent is due to the source

Techniques: Dispersion model, receptor model

e. Time of occurrence

Techniques: Monitoring, dispersion model, back trajectory, camera

3. Uncertainty of results: Each analytical method will have its own level of uncertainty.

These individual uncertainties should be kept in mind as outputs are compared within

the overall assessment. If the results of different techniques are the same or similar

(within the uncertainties ofthe techniques), then the overall level ofuncertainty is likely

to decrease.

Scenario 2: Moderate data/multiple sources

Data input: Moderate amount of existing data (i.e., one IMPROVE site with data for six or

more years)

Evidence of an increasing trend in sulfate

Meteorological data likely from several stations

Assuming the Certification identifies multiple BART sources of different types within a 100-

mile radius, a combination of the following techniques is suggested:

I. Examine IMPROVE data, including quality assurance

2. Look at extinction budget to identify visibility-impairing pollutants

3. Perfonn some analysis of when the episodes are occurring

4. Perfonn multiple back trajectory analyses using a method such as HYSPLIT

5. Look at relationships between particulate species

6. Examine source emissions data for correlations with ambient monitoring

7. Perfonn dispersion model based on data and capabilities such as CALMETICALPUFF

8. Examine other data such as source owner data, deposition data, or photographic

evidence

9. Wind fields/Synoptic analyses

10. Comparison of different episodes

II. UNMIX, PMF and/or CMB

21
12. Analysis of any regional modeling already conducted, such as CMAQ

13. Long term visual monitoring, such as camera data or transmissometer data, compared to

met data to identify quadrants of concern

The results ofthis initial analysis may not be conclusive. This level ofreview may be

adequate if a source/receptor relationship can be identified.

However, if the results are inconclusive, more data and/or more refined analyses may be

necessary and may help the state reach an attribution determination. The state should consider

how the available data might affect the ability to assess the effectiveness ofthe controls in

remedying the impairment. It may be efficient to look ahead to the data and analytical needs of a

potential BART analysis. For example, the state may wish to use a more refined model that

would be useful for both attribution and remedy assessment.

Assuming there is a two-year time period to collect data and analyze additional information, the

following techniques also can be considered:

1. Emissions inventory

2. Analysis of a nested domain within the regional model

3. Source profiles (natural tracers)

4. Additional source measurements, such as stack testing

5. Met monitoring or modeling

6. Camera

7. Additional aerosol monitoring, episodic or saturation

8. Monitoring to measure additional parameters, such as precursors, ammonia and

oxidants

9. In plume trajectory by aircraft, if available, to characterize plume chemistry

10. Fine time-resolved optical monitoring, such as nephelometer, transmissometer,

aethelometer combined with pollutant monitoring (e.g., SO" NOx, real time PM) for

monitoring episodes.

11. Repeat initial techniques with new data

The technical criteria are listed below, followed by techniques that may be used to obtain results

about the criteria.

I. The impainnent must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified.

Techniques: Back trajectory, species relationships, relationship between source

emissions and ambient monitoring, dispersion model refined by camera, aerosol, in

plume, optical monitoring, and refined dispersion models.

2. The attribution assessment must address the unique visibility impainnent certified by

the FLM for the Class I area. Some factors to consider include:

a. Duration: each source's length of effect per episode

22
Techniques: Monitoring, dispersion model, back trajectory, camera

b. Frequency: how often the impairment occurs by source

Techniques: Monitoring, dispersion model, back trajectory, receptor model, camera

c. Geographic extent: how much of the Class I area is impaired

Techniques: Monitoring, dispersion model, additional data on deposition and other

studies

d. Magnitude: how much impainnent is due to each individual source

Techniques: Dispersion model, receptor model

e. Time of occurrence

Techniques: Monitoring, dispersion model, back trajectory, camera

Scenario 3: No IMPROVE data, Certification by modeling evidence

Data input: Detailed modeling of a source and specific visibility impairment using a

CALPUFF run, or detailed (nested) run of regional model.

Detailed emissions data and meteorological data were input to the model.

No IMPROVE data available for this specific Class I area (monitoring may be at a

"representative site")

Some optical data, photographic data, and limited aerosol data from other

networks

Assuming the Certification points to a specific source, a combination ofthe following techniques

is suggested:

I. Examine IMPROVE data for any nearby Class I areas (especially those included in the

modeling domain) to better understand the regional conditions and compare with model

outputs ofthe unique effect

2. Review the model's outputs on "high impact" days and compare with actual

meteorological data ofthe area (to confirm transport, inversions, or other aspects ofthe

model which may create the unique impact)

3. Review source emissions data used in the model

4. Review other monitoring data (optical measurements, deposition data, ozone data, etc.)

to collaborate model predictions

5. Examine any photographic evidence

The results of this initial analysis may not always be conclusive. This level of review may be

adequate if a source/receptor relationship can be identified. Because no visibility-specific particle

monitoring is available in this case, the key to attribution is to detennine that the source

emissions are indeed reaching the Class I area on days when impairment exists. Ifthe results are

inconclusive, more data and/or more refined analyses may be necessary and may help the state

reach an attribution determination. The state shou Id consider if the avai lable data and modeling

information supplied with this Certification could be used to detennine the effectiveness ofthe

23
controls in remedying the impairment. It may be efficient to look ahead to the data and analytical

needs ofa potential BART analysis if additional or different modeling will be necessary.

Additional data collection and analyses that might be considered:

1. Better source profiles or newer emissions infonnation

2. Met monitoring or modeling

3. Camera

4. New aerosol monitoring (episodic or saturation)

5. In plume trajectory by aircraft, if available

6. Repeat initial analytical techniques with new data

The technical criteria are listed below, followed by techniques that may be used to obtain results

about the criteria.

I. The impainnent must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified.

Techniques: Confirm model inputs, compare with any new particle monitoring at Class 1

area. Examine perfonnance of the model, and perfonn uncertainty analyses.

2. The attribution assessment must address the unique visibility impainnent certified by the

FLM for the Class 1 area. Some factors to consider include:

a. Duration: source's length of effect per episode

Techniques: Monitoring, dispersion model, back trajectory, camera

b. Frequency: how often the impainnent occurs

Techniques: Monitoring, dispersion model, back trajectory, camera

c. Geographic extent: how much of the Class I area is impaired

Techniques: New monitoring and examination of dispersion model outputs,

additional data on deposition and other studies

d. Magnitude: how much impainnent is due to the source

Techniques: Dispersion model

e. Time of occurrence

Techniques: Monitoring, dispersion model, back trajectory, camera

Scenario 4: Direct Photographic Evidence

Data input: The FLM certified impairment in a wilderness area based on photographic

evidence. Photographs taken over a period of two years showed a distinct haze

in a valley located in the wilderness area when the wind is from the east. A

series of photographs during two episodes showed a distinct plume that

24
originates at an existing stationary source constructed in 1965 and located ten

miles east ofthe wilderness area. The photographic series showed that the

plume traveled into the wilderness area.

Aerial photos during one episode also show a distinct plume that travels into

the wilderness area. The wilderness area does not have an IMPROVE site. A

Class I area located 50 miles to the north has an IMPROVE site that was

representative for the area. This monitoring site does not show decreased

visibility on the days when haze was photographed in the wilderness valley.

Assuming the Certification identifies one BART source, the following steps are suggested:

I. Review the photographic evidence and determine whether the photographs show a clear

connection between the source and the haze documented in the wildemess area.

In this example, the photographic evidence showed a clear connection between the

source and the haze in the wildemess area. Qualitative information, such as

photographic evidence that establishes a sourcelreceptor link, is allowed under EPA

regulations that define reasonable attribution as determined by "visual observation or

other technique the State deems appropriate." (40 CFR 51.301 (s)).

The results ofthis initial analysis may not always be conclusive. If the photographic

evidence is not compelling, the state may reach a different conclusion. The state may detennine

that the impainnent, as documented by the FLM, was not reasonably attributable to the source

identified in the Certification. The FLM would then need to gather additional infonnation to

support a Certification. Alternatively, if the state detennines that the source may be causing the

haze but the qualitative evidence is not quite sufficient to detennine attribution, the state could

initiate a data collection effort to provide better information regarding visibility impairment at

the Class I area. Such techniques may include:

I. Better source characterization, including measurement of emissions of trace elements

(source profiles) for use in CMB modeling

2. Met monitoring or modeling

3. Additional aerosol monitoring (episodic or saturation)

4. In plume trajectory by aircraft, if available

5. Fine time-resolved optical monitoring, such as nephelometer, transmissometer, or

aethelometer combined with pollutant monitoring (e.g., S02, NOx, real time PM) for

monitoring of episodes.

6. More refined chemical visibility model, such as CALPUFF

The technical criteria are listed below, followed by techniques that may be used to obtain results

about the criteria.

I. The impairment must be related to emissions from specific sources. The visibilityimpairing pollutants of concem should be identified.

Techniques: Back trajectory, species relationships, relationship between source

emissions and ambient monitoring, dispersion model refined by camera, aerosol, in

25
plume, optical monitoring, and refined dispersion models.

2. The attribution assessment must address the unique visibility impainnent certified by

the FLM for the Class I area. Some factors to consider include:

a. Duration: source's length of effect per episode

Techniques: Monitoring, dispersion model, back trajectory, camera

b. Frequency: how often the impainnent occurs

Techniques: Monitoring, dispersion model, back trajectory, camera

c. Geographic extent: how much ofthe Class I area is impaired

Techniques: Monitoring, dispersion model, additional data on deposition and other

studies

d. Magnitude: how much impainnent is due to the source

Techniques: Dispersion model, receptor model

e. Time of occurrence

Techniques: Monitoring, dispersion model, back trajectory, camera

3. Uncertainty ofresults: Each analytical method will have its own level of uncertainty.

These individual uncertainties should be kept in mind as outputs are compared within

the overall assessment. If the results of different techniques are the same or similar

(within the uncertainties ofthe techniques), then the overall level of uncertainty is likely

to decrease.

The final step in the attribution process scenario would be to veritY that the source was

operating on the days whcn the haze was observed in the area. The state should also detennine if

the source was experiencing unusual upset conditions during the times identified. In this

example, the source was detennined to have been operating nonnally. The state would then issue

a detennination that the visibility impairment at the Class I area was reasonably attributable to

the existing stationary facility.

Scenario 5: Data Rich

Data input: A large special visibility study recently was conducted.

Four months of data spanning two seasons was collected including:

I. At one "receptor" site in a Class I area there were multiple meteorological, optical, and

particulate samplers including extensive measurements of particle compositions, size

distributions, scattering, absorption, light extinction, ions, oxidants, relative humidity,

temperature, vertical wind profiles, SOl, photographs, and concentrations offour unique

tracers released from four different sources ofinterest. There were co-located samplers

measuring several parameters in more than one way. There are at least some one, six,

and twelve-hour particle measurements in addition to twenty-four hour samples.

26
2. This rcccptor sitc has been an IMPROVE site for several years and these data are also

available.

3. At thirty-five other sites in the region, called "satellite" sites there was an IMPROVE

Module-A sampler taking daily twenty-four hour samples which were analyzed for fine

mass, S, soil elements, trace metals, and elemental H from which organics can be

estimated. The unique tracers were also measured at many ofthese sites.

4. Aircraft sampling of plumes from source(s) ofinterest was conducted.

5. An extensive current emissions inventory was created.

6. Wind profilers were deployed at two to three sites in addition to the receptor site.

7. Measurements ofthe chemical composition of resuspended local dust, smoke from

burning local fuels, and emissions from local point and area sources ofinterest were

collected in order to create "source profiles" to be used in receptor modeling.

Assuming the certification identifies a BART source within 100 miles ofthe Class I area

from which a unique tracer was released, a combination ofthe following techniques is

suggested:

I. Examine fine particle data, including quality assurance. Use the collocated data to

assess accuracy and precision. The one, six, and twelve-hour data should average up to

match the twenty-four hour data and ifreasonable, be used to examine the diurnal

cycles in the fine particle concentrations.

2. Look at the extinction budget to identify visibility-impairing pollutants. Because size

distributions were measured, the extinction budget can be estimated from Mie scattering

calculations as well as by using simple techniques that assume bulk scattering and

absorption efficiencies. Check to see if measured scattering plus absorption add up to

the measured and reconstructed extinction.

3. Compare the special study data to historical IMPROVE and archived meteorological

data to determine the representativeness ofthe study period.

4. Perfonn some analysis of when the episodes are occurring. EOF analysis can be helpful

to summarize the massive data set. Use the photographs to create a time-lapse

visualization ofthe scene at the receptor site.

5. Perfonn back trajectory analyses using HYSPLlT, CAPITA Monte Carlo or ATAD.

Examine whether the trajectories change substantially when the study's wind-profiler

data are included. Dctennine whether trajectories are consistent with tracer

concentrations.

6. Look at relationships between particulate species (factor analysis) to see if they identify

source types.

7. Look at the spatial and temporal patterns of trace elements and the major constituents of

the fine mass. This may suggest dominant source areas and transport patterns for

different source types. Use EOF analysis to detennine the patterns that explain most of

the covariance in the data. Check to see how well these are reconciled with the back

trajectory modeling and the detenninistic modeling. Check to see ifthe same dominant

sources were indicated.

8. Examine source emissions data for correlations with ambient monitoring.

9. Perform dispersion model such as CALMET/CALPUFF.

27
10. Analyze wind fields, synoptic conditions, and satellite photos. Check to see if they were

consistent with more sophisticated meteorological modeling. Look for unusual

conditions such as wild fires, hurricanes, stagnation episodes, etc. Look to see if

modeled and observed cloud patterns were comparable.

II. Compare the meteorological and chemical characteristics of different episodes

12. UNMIX, PMF and CMB can help determine major source types and when they were

important.

If, at this point, similar source/receptor relationships have been identified using several

different techniques, this level ofreview is adequate. If the results are inconclusive, and there are

differing points of view about the frequency, duration, or significance ofthe attribution to the

BART-eligible source, more analyses may be necessary. Often in a large study, measurements

are made, but not immediately analyzed in the lab due to cost. lfthis is the case, more samples

could be analyzed. It is unlikely that any additional field monitoring would be required.

The technical criteria are listed below, followed by techniques that may be used to obtain

results about the criteria.

I. The impairment must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified.

Techniques: Reconstructed particle mass and light extinction including examination of

the reconstructions in different size ranges and at different sites in the region, analysis

ofresponses of light scattering to relative humidity, back trajectory analyses,

examination of inter-species relationships compared to measured source profiles,

dispersion modeling with sophisticated models such as REMSAD and CMAQ, analysis

of wind fields and dispersion by comparison to measured tracer concentrations,

computer animation ofspatial patterns ofspecies ofinterest, use ofreceptor models

such as TMBR, DMB, and TAGlT that utilize unique tracer information, or other

receptor models such as CMB, UNMlX, and PMF that do not require tracer

infonnation, but can use it. When so many different models can be used, model

reconciliation is usually a part of a data-rich scenario.

2. The attribution assessment must address the unique visibility impairment certified by

the FLM for the Class I area. Some factors to consider include:

a. Duration: each source's length of effect per episode

Techniques: Monitoring, dispersion Illodel, back trajectory, camera

b. Frequency: how often the impairment occurs by source

Techniques: Monitoring, dispersion model, back trajectory, receptor model, camera

c. Geographic extent: how much of the Class I area is impaired

Techniques: Monitoring, dispersion model, analysis of spatial patterns using data

from the satellite sites.

28
d. Magnitude: how much impairment is due to each individual source

Techniques: Dispersion model, receptor model

e. Time of occurrence

Techniques: Monitoring, dispersion model, back trajectory, camera

3. Uncertainty of results: In this case, the ability of a model to predict the observed tracer

concentrations is an indicator ofthe model's uncertainty.

29
30
V. TECHNIQUES

A. Monitoring

Introduction

This section describes a variety of ambient air monitoring methods that, if appropriate,

might be used to support an attribution analysis. The methods described include those most

commonly used in pollution studies or ambient monitoring programs and should not be

considered an exhaustive list ofpotential methods. Methods include, IMPROVE, filter based

aerosol, continuous aerosol (includes optical methods such as the nephelometer), continuous gas

and canister sampling, transmissometer, scene (includes film, video, digital), and tracer or

aircraft methods.

Several ofthe methods described are currently in use as a part of national, state, local, tribal,

or private ambient monitoring networks. These sites are generally located in urban areas, but

those near the area ofstudy could be used in the attribution analysis thereby reducing the cost of

monitoring.

The IMPROVE network is designed to assess visibility in Class I areas and routinely

measure visibility impairing pollutants. These sites offer value to the attribution analysis ifthey

are located in the area ofstudy.

The RA BART case studies show additional examples ofthe methods used during source

attribution studies. The case studies also show that methods, other than ambient monitoring, may

be used to support the analysis. Existing programs such as CASTNET (dry deposition network),

surface water deposition studies, or snow deposition studies may provide additional data for the

attribution analysis.

Although not specifically listed as a monitoring technique, meteorological monitoring is an

important element the attribution analysis. Collection of meteorological data can range from

simple wind, temperature, and relative humidity measurement to an array of acoustic wind

profilers. The complexity of the meteorological monitoring program depends on data needs and

the availability of existing data. As with ambient monitoring, meteorological data may be

available at sites located near the study area and offers reduced monitoring cost.

1. IMPROVE

Overview: The Interagency Monitoring of PROtected Visual Environments (IMPROVE)

program is a cooperative measurement effort governed by a steering committee composed of

representatives from Federal and regional-state organizations. The IMPROVE monitoring

program was established in 1985 to aid the creation of Federal and State implementation plans

for the protection of visibility in Class I areas (156 national parks and wilderness areas) as

stipulated in the 1977 amendments to the Clean Air Act. The objectives of IMPROVE are to: (I)

establish current visibility and aerosol conditions in mandatory class I areas; (2) identify

chemical species and emission sources responsible for existing man-made visibility impairment;

31
(3) document long-tenn trends for assessing progress towards the national visibility goal; and (4)

with the enactment ofthe regional haze rule, provide regional haze monitoring representing all

visibility-protected federal class I areas where practical.

Magnitude: Possible when used in conjunction with appropriate analytical techniques.

Frequency: Possible when used in conjunction with appropriate analytical techniques; Limited

by twenty-four hour sample integration, and one-in-three day sampling frequency.

Duration: Possible when used in conjunction with appropriate analytical techniques; Limited by

24 hour sample integration, and one-in-three day sampling frequency.

Principle: Twenty-four hour integrated filter-based ambient monitor; Gravimetric analysis for

PM2.' (Module D) and PM,o); S from Particle Induced X-ray Emission (PIXE); N03 from ion

chromatography (denuded nylon filter from Module C); Organic and elemental carbon from

Thennal Optical Reflectance (TOR); H from Proton Elastic Scattering (PESA).

Uncertainty: All elemental S if from sulfate; All sulfate is ammonium sulfate; N03(Denuder

efficiency is close to 100%. All nitrate is from ammonium nitrate);

Average organic molecule is 70% carbon; Carbon (organic and elemental) is defined by the

analytical method; Fine soil based on elemental composition; Course mass (PM,o - PM2.,)

consists only of insoluble soil particles.

Strengths: Regulatory indicator for regional haze rule; Long tenn data record in or near many

federal Class I areas; Extensive network currently in place.

Limitations: Integrated twenty-four hour sample; one-in-three day sampling interval; Nitrate

losses due to volatilization from filter; Not capable of distinguishing between primary particulate

and atmospherically transfonned particulate.

Level ofExpertise Required: Standard operating procedures available for routine operation and

maintenance; Chemical analysis must be conducted by appropriate laboratory.

Regulatory Context: Regional Haze rule; Included in SIP Visibility Plan

2. FILTER-BASED AEROSOL

Overview: Filter-based aerosol monitoring is used to identify chemical species and obtain

concentration measurements of atmospheric constituents that contribute to visibility impairment.

Primary techniques include filter-based aerosol samplers that collect samples on various

substrates in various size ranges such as PM2., or PM,o. Aerosol monitoring can provide fme

mass concentration, course mass concentration, optical absorption, major and trace elements,

organic and elemental carbon, and sulfate, nitrate, and chloride ions. A variety of methods are

available to conduct filter based aerosol monitoring. Many methods are approved as an EPA

reference method, while some are not, but may offer variability that the reference method does

not.

32
Magnitude: Possible when used in conjunction with appropriate analytical techniques.

Frequency: Possible when used in conjunction with appropriate analytical techniques; Limited

by 24-hour sample integration and sampling frequency (daily sampling is possible depending on

instrument selected).

Duration: Possible when used in conjunction with appropriate analytical techniques; Limited by

24-hour sample integration and sampling frequency (daily sampling is possible depending on

instrument selected).

Principle: The methods used for analyses of these filter media include gravimetry (electromicrobalance) for mass; X-ray fluorescence (XRF) and particle induced X-ray emission (PIXE)

for trace elements; Ion chromatography (lC) for anions and selected cations; Controlledcombustion for carbon; Gas chromatography/mass spectroscopy (GC/MS) for semi-volatile

organic particles; Special measurement needs may include determining particle size and

morphology through optical and/or electron microscopy.

Strengths: Large network of urban monitoring available; Filter based sampling allows for a

variety of chemical/elemental analysis.

Limitations: Integrated twenty-four hour sample; Generally operated on one-in-three or one-insix day sampling interval (daily sampling is possible depending on instrument selected); Not

capable of distinguishing between primary particulate and atmospherically transformed

particulate.

Level of Expertise Required: Standard operating procedures available for routine operation and

maintenance; Chemical analysis must be conducted by appropriate laboratory.

Regulatory Context: Commonly used in NAAQS/SIP compliance monitoring networks.

3. CONTINUOUS AEROSOL

Overview: Aerosols can be measured continuously using several different methods. Optical

measurement of aerosols can be measured using an instrument such as a nephelometer to

measure light scattering (bscat) or a aethelometer to measure light absorption (babs) by aerosols

(black carbon). Continuous instruments such as TEOM or BETA can provide PM10 or PM2.5

aerosol concentration.

Magnitude: Possible when used in conjunction with appropriate analytical techniques.

Frequency: Possible when used in conjunction with appropriate analytical techniques; Limited

by twenty-four hour sample integration and sampling frequency (daily sampling is possible

depending on instrument selected).

33
Duration: Possible when used in conjunction with appropriate analytical techniques; Limited by

twenty-four hour sample integration and sampling frequency (daily sampling is possible

depending on instrument selected).

Strengths: Continuous measurement with at least hourly time resolution; Nephelometers and

Aethelometers are commonly used to support Class I area monitoring programs and an existing

data record may be available in some areas.

Limitations: Continuous aerosol measurement with methods such as TEOM and BETA are

generally made in urban areas to support NAAQS compliance networks; Not capable of

distinguishing between primary particulate and atmospherically transfonned particulate.

Level ofExpertise Required: Standard operating procedures available for routine operation and

maintenance.

Regulatory Context: Commonly used in Class I area monitoring networks or urban NAAQS

compliance networks.

4. CONTINUOUS GASEOUS

Overview: A variety of gaseous pollutants, such as Ozone (03), Carbon Monoxide (CO),

Nitrogen Dioxide (NOx), nitric oxide (NO), ammonia (NH3), hydrogen peroxide (H,O,), sulfur

dioxide (SO,), Organics, and HAPSrrOXICS, can be measured continuously. Gaseous

monitoring is generally conducted with instruments that continuously draw sample air and

periodically (as frequently as once per second) analyze the sample. Canister systems collect an

ambient air sample over a specific period oftime in clean evacuated canisters. The canisters are

then subject to subsequent analysis at a laboratory using a method such as GC/f1D. This method

is able to provide time-integrated samples from several hours to twenty-four hours or more.

Regular checks ofthe flow rate, stability, reproducibility, precision, and accuracy ofthese

instruments must be conducted on a regular schedule in order to ensure data quality.

Magnitude: Possible when used in conjunction with appropriate analytical techniques.

Frequency: Possible when used in conjunction with appropriate analytical techniques.

Duration: Possible when used in conjunction with appropriate analytical techniques.

Strengths: Continuous measurement with hourly time resolution; Monitors available to identify

variety ofpollutants.

Weaknesses/Limitations: Generally require conditioned environment and frequent perfonnance

checks.

Practical Considerations: Data may be available from established urban area monitoring

networks and some Class I area monitoring networks; Additional cost ($/year) for new sites.

34
Level of Expertise Required: Standard operating procedures available for routine operation and

maintenance.

Regulatory Context: Commonly used in urban NAAQS compliance and HAPS/TOXICS

networks.

5. TRANSMISSOMETER

Overview: Transmissometers measure the amount oflight transmitted through the atmosphere

over a known distance (generally between 0.5 km and 10.0 km) between a light source of known

intensity and a receiver. The transmission measurements are electronically converted to hourly

averaged light extinction (b,,,).

Magnitude: Possible when used in conjunction with appropriate analytical techniques.

Frequency: Possible when used in conjunction with appropriate analytical techniques.

Duration: Possible when used in conjunction with appropriate analytical techniques.

Uncertainties: A transmissometer must be installed in stable locations with a clear and

unobstructed path to avoid interference with the signal.

Strengths: Continuous measurement ofb,,, in many Class I areas and some urban areas.

Limitations: Not capable ofidentitYing pollutants contributing to visibility impairment.

Level of Expertise Required: Standard operating procedures available for routine operation and

maintenance; Data processing/quality aSSUranCe requires high level of expertise.

Regulatory Context: Commonly used in Class I area monitoring networks and in some urban

areas.

6. SCENE

Overview: Scene monitoring refers to the use ofstill and/or time-lapse photography (including

digital imagery) to provide a qualitative representation of visual air quality. Scene monitoring

data quality objective recommendations are to document the appearance ofscenes ofinterest

under a variety of air quality and illumination conditions at different times of day and different

seasons. Scene monitoring documents the visual condition observed at a monitoring site. The

data collection schedule can be tailored to capture the periods when visibility impairment is most

likely to occur at specific sites. Time-lapse movies (generally time-lapse video or super 8 rnm

film) Can be used at monitoring sites and during special studies to document the visual dynamics

of a scene or source.

Magnitude: Cannot provide a quantitative measurement of visibility impainnent but can

qualitatively illustrate various levels of visibility impairment.

35
Frequency: Possible depending on the method used. Time-lapse video may be able to

demonstrate the frequency ofthe impainnent. The use ofstill photography to document

impairment frequency depends upon the number of images acquired over time.

Duration: Possible depending on the method used. Time-lapse video may be able to demonstrate

the impainnent frequency. The use ofstill photography to document impainnent frequency

depends upon the number ofimages acquired over time.

Uncertainties: n/a

Strengths: Provides image/video record

Limitations: Not capable ofidentifying pollutants contributing to visibility impainnent.

Level of Expertise Required: Standard operating procedures available for routine operation and

maintenance.

Regulatory Context: Commonly used in Class I area monitoring networks and in some urban

areas.

7. TRACER METHODS, L1DAR SYSTEMS, AIRCRAFT BASED MEASUREMENTS

Overview: The methods described in this section are more specialized methods generally

reserved for special studies as opposed to the previously described methods that are used more

routinely. Tracer methods, lidar systems and aircraft based measurements will be described

individually.

Tracer Methods:

A tracer element or compound is a substance with unique characteristics that allows positive

identification at very low concentrations. The tracer compound of choice will vary by source

type and composition ofthe plume being tracked. In general, the tracer must have very low

natural background concentrations and ideally would have the same chemical form and

properties as the compound being tracked. In ambient applications where use ofthe ideal tracer

is not possible due to potential environmental risk, a near-substitute compound may be used.

When used to detennine potential source impacts, the chosen compound is released from a

source stack and downwind monitors are used to detect the presence ofthe compound.

Lidar Methods:

A lidar transmits short pulses oflaser light into the atmosphere. The laser beam loses light to

scattering as it travels. At each range, some ofthe light is backscattered into a detector. Because

the light takes longer to return from the more distant ranges, the time delay ofthe retum pulses

can be converted to the corresponding distance between the atmospheric scatterer and the lidar.

The end result is a profile of atmospheric scattering versus distance. Analysis ofthis signal can

yield infonnation about the distribution of aerosols in the atmosphere. The amount of backscatter

indicates the density of the scatters. This can be used to measure cloud base height or track

36
plumes of pollution. Other properties of the atmosphere can also be deduced from the lidar return

signals. A frequency shift in the light because ofthe Doppler effect permits measurement of

wind speeds. By detecting the amount of depolarization, one can discriminate between liquid

droplets and nonspherical ice particles. Differential Absorption Lidar (DIAL) uses absorption, as

evidenced by reduced backscatter from greater distances, to measure the concentration of

atmospheric gases. A Raman Iidar detects particular atmospheric components (such as water

vapor) by measuring the wavelength-shifted return from selected molecules (NOAA).

Aircraft Based Measurements:

Aircraft based measurement systems utilize specially equipped aircraft to make pollutant and

meteorological measurements at various elevations throughout the study domain. The aircraft

can be equipped with a multitude of gaseous, aerosol, optical and meteorological equipment.

This measurement method provides the advantage of vertical profiles of various parameters, the

ability to track point source plumes, and the ability to establish boundary conditions for future

analytical and modeling exercises.

References:

NOAA, Atmospheric Light Division, Environmental Technology Laboratory,

http://www2.etl.noaa.gov/DIAL_lidar.html

U.S. Environmental Protection Agency, Visibility Monitoring Guidance (EPA-454/R-99-003),

June 1999.

National Research Council, Protecting Visibility in National Parks and Wilderness Areas,

National Academy Press, Washington D.C., 1993, pp. 315-357.

37
38
Table 1. Monitoring Techniques

~riteria Monitoring Method

IMPROVE Filter Based Continuous Aerosol Gaseous; Transmissometer Scene Tracer Methods, Lidar

Aerosol Continuous 35mmfilm/8mm systems, Aircraft based

methods, canister video, digital measurements

sampling, etc.

Pollutant

PM10 Yes Yes Yes No No No All Possible

PM2,5 Yes Yes Yes Yes No No

INOx (Site specific) No No Yes No No

S02 (Site specific) No No Yes No No

Sulfate Yes Yes No No No No

Nitrate Yes Yes No No No No

Carbon Yes Yes No No No No

Organics Yes Yes No Yes No No

Other Reconstructed Nephelometer - HAPS, TOXICS Total Visual

extinction Bscat Extinction Parameters

Aethelometer - Babs

~isibility/Concentration Changes

~agnitude Yes Yes All Possible All Possible All Possible No All Possible

Frequency Yes Yes All Possible All Possible All Possible Yes All Possible

Duration Yes Yes Yes

~ime of Day No No Yes

Likely Part of Possible No

FLM

r'ertification?

39
Monitoring Techniques (continued)

Principal

pualitativel Quantitative Qualitative Qualitative/Quantitative

buantitative

Strengths Reconstructed ~arious chemical ,-"ontinuous ~ontinuous ~ontinuous Relatively Lidar and airplane based

extinction flnalysis, large neasurement, lneasurement, lneasurement, nexpensive, ystems can provided

alculation, retwork nephelometer ~ariety of possible provides light ~ncomplicated emporal and spatial

historical rationwide ommonly located in pollutants ~xtinction pperational esults, tracer methods

ecord pr near Class I areas ~alue, equirements can provide sourceihistorical eceptor data

~ecord

eaknessesl Fixed location ntegrated 24 hour EOM, BETA, etc, penerally require IFixed location !Number ofstill Complex and relatively

Limitations n or near Class~ample generally pommonly located in f;onditioned 'n or near Class 'mages limited, xpensive to operate,

I areas, also f;ollected on one- ~rban areas ~nvironment for areas ~ideo requires equires specialized

ocated in n-three schedule, proper operation, torage and raining and knowledge

everal urban f;ommonly in ommonly located outine review o operate and analyze

lIreas !urban areas n urban areas esults

Distinguish Possible with Ipossible with other!No Possible with other!No Possible with Possible with other

BART Sources? bther analvsis !analysis nalysis other analysis nalysis

Practical Considerations

Cost Moderate; varies depending on the number ofinstruments ~ow ~igh

40
B. Source Modeling

Introduction

Given the complex natural environment, the state must choose the configuration of modeling

techniques that will provide the most information on the contributing source or sources of

impairment within the limited resources of current technology, data, budgets, time and staff

availability.

1. Physical Models

Physical models are those that simulate the meteorology and air quality over an area.

Modeling relies on a numerical or analytical model to estimate particulate concentrations in

space and time. Because of its nature and sources, particulate matter is difficult to model over all

spatial scales. Many air quality models that are currently available were designed to be applied

over the regional scale with grid sizes from four to forty kilometers. Modeling requires detailed

meteorological fields and emissions inventory over the entire domain. The compilation of data

required to run these models can require much effort and expertise. Efforts are underway by

government agencies in the U.S. to generate and archive both emissions and estimated activity

levels ofmany source types in geographical information systems.

Numerical source-oriented models are designed to simulate atmospheric diffusion or

dispersion and estimate concentrations at defined receptors. Numerical source models can be

grouped as kinematic, first-order closure, or second-order closure models (Bowne and

Lundergan, 1983). Kinematic models are the simplest both mathematically and conceptually.

These models simplify the non-linear equations ofturbulent motion, thereby pennitting a closed

analytical approximation to describe pollutant concentration (Green el aI., 1980). First-order

closure models are based on the assumption of an isotropic pollutant concentration field.

Consequently, turbulent eddy fluxes are estimated as being proportional to the local spatial

gradient ofthe transport quantities. The Eulerian grid models, Lagrangian particle models, and

trajectory puff/plume models are included in this category. Second-order closure models involve

a series of algorithm transformations ofthe equations ofstate, mass continuity, momentum, and

energy by using the Boussinesque approximation and Reynold's decomposition theory (Holton,

1992; Stull, 1988).

2. Spatial Scales

The model's applicable spatial scales playa large role meeting the analysis' objectives and

its ability to accurately assess spatial variability. PMro and PM2.5 concentrations modeled or

measured at any receptor result from the complex interaction of meteorology, chemical

transformations and emissions from nearby and distant sources. For example, a monitor located

near an operating construction site will be impacted more by the daily construction activity than

the surrounding area. That site may be classified as representing an area ofa few tens of meters

to no more than one kilometer depending on the size ofthe construction area and fugitive dust

control measures.

The dimensions given below are nominal rather than exact and are presented as defined in

40 CFR part 58.

41
a. Micro-Scale (10 to 100 m): This scale does not apply to scenarios relevant to the attribution

problem. Modeling at the microscale is usually done by simple Gaussian plume models such as

ISCST3. Measurements in urban areas can show considerable variations at this scale while those

in pristine areas would not. Variations often occur when monitors are located close to a low-level

emissions source, such as a busy roadway, construction site, within a community that uses wood

stoves, or a short industrial stack. Fortunately, compliance monitoring site exposure criteria

avoids microscale influences even for source-oriented monitoring sites.

b. Middle Scale (100 to 500 m): Middle-scale monitors show significant differences between

locations that are ---O.! to 0.5 km apart. These differences may occur near large industrial areas

with many different operations or near large construction sites. Monitors with middle-scale zones

ofrepresentation are often source-oriented, used to detennine the contributions from emitting

activities with multiple, individual sources to nearby community exposure monitors.

c. Neighborhood Scale (500 m to 4 km): Neighborhood-scale monitors do not show significant

differences in particulate concentrations with spacing of a few kilometers. This dimension is

often the size of emissions and modeling grids used in large urban areas for PM source

assessment, so this ZOne ofrepresentation ofa monitor is the only one that should be used to

evaluate such models. Sources affecting neighborhood-scale sites typically consist ofsmall

individual emitters, such as clean, paved, curbed roads, uncongested traffic flow without a

significant fraction of heavy-duty vehicles, or neighborhood use ofresidential heating devices

such as fireplaces and wood stoves.

d. Urban Scale (4 to 100 km): Urban-scale monitors show consistency among measurements

with monitor separations oftens of kilometers. These monitors represent a mixture of particles

from many sources within the urban complex, including those from the smaller scales. PM

measurements at urban-scale locations are not dominated by any particular neighborhood,

however. Urban-scale sites are often located at higher elevations and away from highly traveled

roads, industries, and residential heating.

e. Regional-Scale Background (100 to 1,000 km): Regional-scale background monitors show

consistency among measurements for monitor separations of a few hundred kilometers.

Background concentrations are often more consistent for specific chemical compounds, such as

sulfate or nitrate, than they are for PM mass concentrations. Regional-scale PM is a combination

of naturally-occurring aerosol from windblown dust and marine aerosol as well as particles

generated in urban and industrial areas that may be more than 1,000 km distant. Regional-scale

sites are best located in rural areas away from local sources, and at higher elevations. National

parks, national wilderness areas, and many state and county parks and reserves are appropriate

areas for regional-scale sites. Many ofthe IMPROVE sites characterize PM regional scale

background in different regions ofthe United States.

f. Continental-Scale Background (1,000 to 10,000 km): Continental-scale background

monitors show little variation even when they are separated by more than 1,000 km. They are

hundreds ofkilometers from the nearest significant emitters. Though these sites measure a

mixture of natural and diluted manmade source contributions, the marunade component is at its

minimum expected concentration. The Jarbidge Wilderness IMPROVE site in northern Nevada

is a good example of a continental-scale background site for particulate matter in North America.

42
e. Global-Scale Aackground (>10,000 km): Global-scale background monitors are intended to

quantifY concentrations transported between different continents as well as naturally-emitted

particles and precursors from sea spray, volcanoes, and windblown dust. Yellow sand from

China has been detected at the Mauna Loa, HI, laboratory (Darzi and Winchester, 1982; Braaten

and Cahill, 1986), as well as on the North American continent. Red dust from Africa's Sahara

desert has been detected at Mt Yunque, Puerto Rico and over the southeastern United States.

Other global-scale sites include McMurdo, Palmer, and Ahmundson-Scott stations in Antarctica

(Lowenthal et aI., 1996), Pt. Barrow, Alaska, and Mace Head, Ireland.

3. Chemical Composition

This section illustrates how the chemical composition of aerosols is an important

consideration in the choice of particulate matter models. The knowledge of how the aerosol's

composition varies over an area will playa key role in the attribution study design.

The relative abundance of chemical components in the atmosphere closely reflect the

characteristics of emission sources. Major chemical components of PM2.5 and PMIO mass in

urban and rural areas consist of nitrate, sulfate, ammonium, carbon, geological material, sodium

chloride, and liquid water.

Chemical compositions can vary spatially in all scales ofthe atmosphere and depend on

sources surrounding the monitoring site. For example, on the continental scale, the eastern U.S.

fine particulate cbemical compositions are different than those ofthe western states. In the

eastern portion ofthe U.S., nonurban PM2.5 is dominated by secondary sulfate, organics and

elemental carbon (EPA, 1996). The data to support this conclusion are based on the IMPROVE

and CASTNET networks. These networks provide a background fine-fraction aerosol database

because the monitoring sites are primarily located in national parks and wilderness areas.

Analysis ofthis network shows that the western U.S. nonurban PM2.5aerosol is predominantly

carbon in nature. Nitrate also contributes significantly to the fine particle mass budget

particularly in central and coastal California. Within these generalizations, obvious departures

will be found especially near sources such as near the ocean and urban areas where the aerosol

will be primarily influenced by sea salt and combustion particles, respectively.

The typical PM2.5 chemical compositions vary by season (Chow et aI., 1993a; 1996a,

Watson et aI., 1997), and consist ofthe following major components:

a. Organic Carbon: Organic carbon is composed of gases and particles containing

combinations of carbon and hydrogen atoms. Organic compounds found in ambient air may also

be associated with other elements and compounds, particularly oxygen, nitrogen, sulfur,

halogens, and metals. Particulate organic carbon consists of hundreds, possibly thousands, of

separate compounds (Rogge et aI., I993a). The mass concentration of organic carbon can be

accurately measured, as can carbonate carbon (Chow et aI., 1993b), but only about ten percent of

the specific organic compounds that it contains have been measured. Vehicle exhaust (Rogge et

aI., 1993b), residential and agricultural burning (Rogge et aI., 1998), meat cooking (Rogge et aI.,

1991), fuel combustion (Rogge et aI., 1997), road dust (Rogge et aI., 1993c), and particle

formation from heavy hydrocarbon gases (Pandis et aI., 1992), are the major sources of organic

carbon in PM2.

5.

43
b. Elemental Carbon: Elemental carbon is black, often called "sool." Elemental carbon

contains pure, graphitic carbon, but it also contains high molecular weight, dark-colored,

nonvolatile organic materials such as tar, biological material (e.g., coffee), and coke. Elemental

carbon usually accompanies organic carbon in combustion emissions, with diesel exhaust

(Watson et aI., 1994a, 1998) being the largest contributor.

c. Sulfate: Ammonium sulfate ((NH4S04), ammonium bisulfate (NH4HS04), and sulfuric acid

(H2S04), are the most common sulfate compounds in PM2.

5. These compounds are water-soluble

and reside almost exclusively in the PM2.5 size fraction. Sodium sulfate (Na2S04) has been found

in coastal areas where sulfuric acid has been neutralized by sodium chloride (NaCl) in sea sail.

Although gypsum (Ca2S04) and some other geological compounds contain sulfate, these are not

easily dissolved in water for chemical analysis and are more abundant in the coarse fraction than

in PM2.5; they are usually classified in the geological fraction.

d. Nitrate: Ammonium nitrate (NH4NO)) is the most abundant nitrate compound, a large

fraction of PM2.5 occurs during winter, and a moderate fraction occurs during fall. Sodium nitrate

(NaNO)) is found in the PM2.5 and coarse fractions near the oceans and salt playas. Small

quantities ofsodium nitrate have been found in summertime particulate matter inland owing to

transport from the ocean (Chow et aI., 1996b).

e. Ammonium: Ammonium sulfate (NH4S04) and ammonium nitrate (NH,NO)) are the most

common compounds containing ammonium from reactions between sulfuric acid, nitric acid, and

ammonia gases. While most ofthe sulfur dioxide and oxides of nitrogen originate from fuel

combustion in stationary and mobile sources, most ofthe ammonia derives from living things,

especially animal husbandry practiced in dairies and feedlots.

f. Geological Material: Suspended dust consists mainly of oxides of aluminum, silicon,

calcium, titanium, iron, and other metal oxides. In areas surrounded by substantial terrain (i.e.,

mountains), eons ofrunoff produce mineral compositions in soils that can be fairly

homogeneous, with the exception of places where dry lake beds exist that have accumulated salt

deposits. Industrial processes such as steelmaking, smelting, and mining have distinct geological

compositions. For instance, cement production and distribution facilities may use alcareous,

siliceous, argillaceous, and ferriferous minerals that may not be natural to the region, with

limestone (CaCO)) being the most abundant (Greer et aI., 1992). Suspended geological material

resides mostly in the coarse particle fraction (Houck et ai, 1989,1990), and typically constitutes

-50% of PMlo while only contributing 5 to 15% of PM2.5(Watson et aI., 1994b).

g. Sodium Chloride: Salt is found in suspended particles near oceans, open playas, and after

de-icing materials are applied. Bulk sea water contains 57±7% chloride, 32±4% sodium, 8±1%

sulfate, 1.l±0.1% soluble potassium, and 1.2±0.2% calcium (Pytkowicz and Kester, 1971). As

noted above, sodium chloride is often neutralized by nitric or sulfuric acid in urban air where it is

encountered as sodium nitrate or sodium sulfate.

h. Liquid Water: Soluble nitrates, sulfates, ammonium, sodium, other inorganic ions, and some

organic material (Saxena and Hildemann, 1997) absorb water vapor from the atmosphere,

especially when relative humidity exceeds 70% (Tang and Munkelwitz, 1993). Sulfuric acid

absorbs some water or deliquesces at all humidities. Particles containing these compounds grow

44
into the droplet mode as they take on liquid water. Some ofthis water is retained when particles

are sampled and weighed for mass concentration. The precise amount of water quantified in a

PM,., depends on its ionic composition and the equilibration relative humidity applied prior to

laboratory weighing.

Ambient mass concentrations contain both primary and secondary particles. Primary

particles are directly emitted by sources and usually undergo few changes between source and

receptor. Atmospheric concentrations of primary particles are, on average, proportional to the

quantities that are emitted.

Secondary particles are those that fonn in the atmosphere from gases that are directly

emitted by sources. Sulfur dioxide, ammonia, and oxides of nitrogen are the precursors for

sulfuric acid, ammonium bisulfate, ammonium sulfate, and ammonium nitrate particles. "Heavy"

volatile organic compounds or HYOe (those containing more than eight carbon atoms) may also

change into particles. The majority of these transformations result from intense photochemical

reactions that also create high ozone levels. Secondary particles usually form over several hours

or days and attain aerodynamic diameters in the accumulation mode between 0.1 and I /lm.

Several of these particles, notably those containing ammonium nitrate, are volatile and transfer

mass between the gas and particle phase to maintain a chemical equilibrium. This volatility has

implications for ambient concentration measurements as well as for gas and particle

concentrations in the atmosphere.

Ambient concentrations ofsecondary aerosols are not necessarily proportional to quantities

of emissions since the rate at which they fonn may be limited by factors other than the

concentration of the precursor gases. Secondary particulate ammonium nitrate concentrations

depend on gaseous ammonia and nitric acid concentrations as well as temperature and relative

humidity. A nearby source of ammonia may cause a localized increase in PM,., concentrations

by shifting the equilibrium from the gas to the particulate ammonium nitrate phase (Watson et

aI., 1994c). Ammonium sulfate may form rapidly from sulfur dioxide and ammonia gases in the

presence of clouds and fogs, or slowly in dry air. Because fine particle deposition velocities are

slower than those ofthe gaseous precursors, PM,., may travel much farther than the precursors,

and secondary particles precursors are often found far from their emissions sources and may

extend over scales exceeding 1,000 km.

4. Particle Formation

Ammonium nitrate and ammonium sulfate aerosols are the most prevalent secondary

particles found at urban and non-urban sites throughout the U.S. during the winter. These

particles can form when gas molecules are attracted to and adhere to existing particles.

Sulfur dioxide gas changes to particulate sulfate through gas- and aqueous-phase

transfonnation pathways. In the gas-phase pathway, ultraviolet sunlight induces photochemical

reactions creating oxidizing species that react with a wide variety of atmospheric constituents.

The gas-phase transfonnation rate appears to be controlled more by the presence or absence of

the hydroxyl radical and its competing reactions of other gases than by the sulfur dioxide

concentrations.

45
In the presence of fogs or clouds, sulfur dioxide dissolves in droplets where it experiences

aqueous reactions that are much faster than gas-phase reactions. When ozone and hydrogen

peroxide are dissolved in the droplet, the sulfur dioxide is quickly oxidized to sulfuric acid.

When ammonia is dissolved in the droplet, the sulfuric acid is neutralized to ammonium sulfate.

If the fog or cloud evaporates and relative humidity decreases below 100 percent, the sulfate

particle exists as a small droplet that includes a portion of liquid water. As the relative humidity

further decreases below 70 percent, the droplet evaporates and a small, solid sulfate particle

remains. The reactions within the fog droplet are very fast, and the rate is controlled by the

solubility ofthe precursor gases. Aqueous transfonnation rates ofsulfur dioxide to sulfate are 10

to 100 times as fast as gas-phase rates. These chemical reactions are critical to understanding PM

concentrations in areas and downwind of areas that emits large amounts of S02. The location and

S02 emissions output of large point sources such as coal and oil fired power plants need to be

mapped and compared with transport patterns in order to detennine the impact of ammonium

sulfate particles on ambient surface concentrations.

Fogs serve as an environment for creating particles and as vehicles for particle removal.

During heavy fogs, particles and precursor gases are scavenged as fog droplets grow to sizes that

settle rapidly to the surface. The extent and intensity ofthese fogs is so poorly characterized,

however, that it is not yet possible to determine where and when particle fonnation overtakes

particle deposition, thereby adding to the PM2., concentration loading.

Nitrogen oxide converts to nitrogen dioxide, primarily by reaction with ozone. Nitrogen

dioxide can: I) change back to nitrogen oxide in the presence of ultraviolet radiation; 2) change

to short-lived species which take place in other chemical reactions; 3) fonn organic nitrates; or 4)

oxidize to fonn nitric acid. The major pathway to nitric acid is a reaction with hydroxyl radicals

that transforms nitrogen dioxide to nitric acid. Nitric acid deposits from the atmosphere fairly

rapidly but, in the presence of ammonia, it is neutralized to particulate ammonium nitrate. This is

an important process in secondary particle production because many agricultural areas

surrounding populated urban areas contain large ammonia sources. Chow and Egami (1997)

show that San Joaquin Valley ammonia concentrations are large during winter. Conversion rates

for nitrogen dioxide to nitric acid, ranging from less than one percent per hour to ninety percent

per hour. These rates are typically five to ten times the conversion rates for sulfate fonnation.

Though they vary throughout a twenty-four hour period, these rates are significant during both

daytime and nighttime hours, in contrast to the gas-phase sulfate chemistry that is most active

during daylight hours. The important nitric acid-ammonia reaction has implications to network

design by the need to locate and map possible sources of ammonia. Significant sources of

ammonia are associated with animal husbandry and fertilizer applications. Locating and

estimating ammonia emissions will be a difficult task because it is not traditionally tabulated in

emission inventories and requires further research to refine the methodology to measure the

emISSIOns.

While ammonium sulfate is a fairly stable compound, ammoniuin nitrate is not. Its

equilibrium with gaseous ammonia and nitric acid is strongly influenced by temperature and

relative humidity. Atmospheric particle nitrate can occur in atmospheric aerosol particles as solid

ammonium nitrate or as ionized mmnonium nitrate in aerosol particles containing water. In both

46
the solid and ionized fonns, anunonium nitrate is in equilibrium with gas-phase nitric acid and

mnmoma.

For fixed relative humidity, increasing temperature decreases the particle nitrate fraction.

This is a consequence of the direct relation between the equilibrium constants and temperature.

As temperature increases, the equilibrium constants increase, which means higher gas-phase

pressures can be supported, thereby reducing the particle nitrate fraction. For fixed humidity,

decreasing temperature increases the particle nitrate fraction. As temperatures approach O°C, the

curves approach limiting values. Particle fractions of one are used for ion ratios greater than or

equal to one, and particle fractions are detennined by the amount of available ammonia for ion

ratios less than one. For the higher temperatures, increasing relative humidity increases the

particle nitrate fraction. This is a consequence ofliquid water present for the 60% and 80%

relative humidity cases. When there is sufficient ammonia present with 30% relative humidity,

more than 90% of the nitrate is in the particle phase for temperatures less than 20°C. More than

half of the particle nitrate is gone at temperatures above 30°C, and all ofit disappears at

temperatures above 40°C.

Atmospheric water is another important component ofsuspended particulate matter. The

sharp rise in liquid water content at relative humidities between 55% and 75% is known as

deliquescence. A precise humidity at which soluble particles take on liquid water depends on the

chemical mixture and temperature. Particles containing these compounds grow into the droplet

mode as they take on liquid water, so the same concentration ofsulfate or nitrate makes a much

larger contribution to light extinction when humidities are high (>70 percent) than when they are

low «30 percent). Excess liquid water is also measured as part ofthe PM2.5 mass when sampled

by light scattering continuous monitors or when filters have not been equilibrated at relative

humidities less than 30% prior to weighing.

Some of the organic carbon in suspended particles is also ofsecondary origin. Secondary

organic compounds in particulate matter include aliphatic acids, alcohols, aromatic acids, nitroaromatics, carbonyts, esters, phenols, and aliphatic nitrates (Grosjean and Seinfeld, 1989;

Grosjean, 1992, Pandis et aI., 1992, 1993; Seinfeld and Pandis, 1998). Nonnally, primary

organic carbon particles are more prevalent than secondary organics with exceptions such as

those found in Los Angeles where conditions of clear skies and high photochemical smog are

frequent. Although secondary organic aerosol was thought to be minimal during winter in central

California, recent analyses (Strader et aI., 1998) demonstrate that it could be as much as 20% of

twenty-four hour organic carbon in some samples. This occurs because low wintertime

temperatures lower the saturation vapor pressure for semi-volatile organic compounds. This is

probably minor during winter and fall when photochemical reactions are not dominant.

The exact precursors ofsecondary organics are not well understood, but they are believed to

consist of heavy hydrocarbons with more than seven carbon atoms. Odum (1997) identifies

aromatics as the major group of commonly measured reactive organic gases that affect both

ozone and secondary aerosol fonnation.

47
5. Source Modeling Techniques

Before selecting a modeling technique, it is wise to establish a conceptual model. A

conceptual model describes the relevant physical and chemical processes that affect emissions.

transport, and transformation specific to the region ofinterest. It is the starting point for any

source apportionment process. Conceptual models take advantage of the large body ofscientific

knowledge already acquired. They identify the sources that are likely to be present and eliminate

those that are not. They examine meteorological conditions that affect concentrations and focus

further modeling on the conditions conducive to the high concentrations.

Modeling techniques relevant to attribution are split into several categories depending

complexity, physical attributes, purpose and cost to execute. The following tables on pages 55 to

62 provide a matrix of detailed information on specific models grouped in these categories.

a. Puff Modeling Techniques

These models are based on a Lagrangian framework where air parcels are tracked spatially

and temporally. They can include chemical mechanisms as well as deposition effects. The most

commonly used puff model is the CALMET/CALPUFF (Scire et aI., 2000).

b. Grid Modeling Techniques

For estimating PM2.

5 levels, Eulerian models that include aerosol modules simulating the

physical and chemical processes governing particulate concentrations in the atmosphere are more

suitable than Lagrangian models such as plume trajectory models. Eulerian three-dimensional

models may use either a simplified treatment of atmospheric chemistry (usually used to address

long-tenn particulate concentrations at urban sites) or include a more detailed atmospheric

chemistry treatment (usually used to simulate only a few days of episodes due to their

compositional cost).

Commonly used long-term Eulerian models with simplified atmospheric processes include

(Seigneur et aI., 1997):

• Urban Airshed Model Version V (UAM-V).

• Urban Airshed Model with version V with Linear Chemistry (UAM-LC)

• Regulatory Modeling System for Aerosol and Deposition (REMSAD).

Short-term Eulerian models with complex atmospheric processes include:

• Urban Airshed Model Version V with Aerosols (UAM-AERO),

• Urban Airshed Model with Aerosol Inorganic Module (UAM-AIM).

• SARMAP Air Quality Model with Aerosols (SAQM-AERO).

• Community Multi-scale Air Quality Model (CMAQ)

48
• Comprehensive Air Quality Model with extensions (CAMx)

All ofthe above mentioned Eulerian models have been developed by various scientists from

universities, federal and state agencies, and the private sector. These particulate air quality

models provide a three-dimensional treatment to simulate the fate and transport of atmospheric

contaminants. All ofthese Eulerian models include gas phase chemistry and aerosol dynamics

and simulate atmospheric inorganics (such as sulfate, nitrate, and ammonium), but some ofthese

models do not include the treatment of organics (i.e., REMSAD and UAM-LC).

c. Lagrangian Trajectory Model Techniques

The advantages of using Lagrangian models are the ease of use, the ability to perform many

trajectories and perform back trajectories. Commonly used Lagrangian models include

HYSPLIT (Draxler and Hess, 1997) and FLEXPART (Stohl and Siebert, 2001).

d. Meteorological Modeling Techniques

Meteorological models describe transport, dispersion, vertical mixing, and moisture in time

and space. Meteorological models consist ofstraight line, interpolation (termed diagnostic), and

first principle (termed prognostic) fonnulations, with increasing levels of complexity and

requirements for computational and data resources.

The straight line model is applied to hourly wind directions from a single monitor, assuming

an air mass travels a distance equal to the wind velocity in the measured direction, regardless of

the distance from the monitoring site. This model is applicable for a few hours oftransport in flat

terrain, typically for evaluating a single emissions source.

Interpolation models integrate wind speed and directions from multiple measurement

locations, including upper air measurements provide by remote sensors or balloon launches. The

more advanced ofthese models allow barriers, such as mountains, to be placed between

monitors. Wind fields, therefore, show different directions and velocities at different horizontal

and vertical positions. Interpolation wind models are applicable to domains with a large number

of well-placed monitors and for estimating the movement of air masses from many sources over

transport times ofmore than half a day. The number and placement of monitors, especially upper

air monitors, is especially important in mountainous terrain and in coastal areas where winds are

unusual.

First principle models (Stauffer and Seaman, 1994; Seaman et aI., 1995; Koracin and Enger,

1994) embody scientists' best knowledge of atmospheric physics and thermodynamics,

employing basic equations for conservation and transfer of energy and momentum. Also known

as "prognostic models," first principle models purport to need no data other than values from a

sparse upper air network for interpolation. They are computationally intensive, often requiring

supercomputers but have become more practical and cost-effective as workstation and desktop

computers become more powerful. Modem versions use "four-dimensional data assimilation" or

FDDA that compare model-calculated wind, humidity, and temperature fields with

measurements and "nudge" model outputs toward observations.

49
A more complex meteorological model is not necessarily a better model for a specific

application. One ofthe most widely used first principle model is the Fifth-Generation

NCAR/Penn State Mesoscale Model or MM5 model (Grell et aI., 1995). The MM5

meteorological model has been adopted as the platform for central California air quality studies

(Seaman et. aI., 1995). MM5 input data consist of wind speed, wind direction, temperature,

atmospheric pressure, and relative humidity at ground level, within the boundaty layer, and

above the boundary layer. In many cases in valley situations ten-meter vertical resolution is

needed within the surface layer, 30-50 m resolution is needed in the valley wide layer, and 100 m

resolution is needed above the valleywide layer up to -2000 magi (Watson et aI., 1998). Time

resolution is at least hourly for these measurements. Measurements are needed where large

differences are expected, although this is largely unknown for winter.

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NOAA Tech Memo ERL ARL-224, December 1997. Prepared by Air Resources

Laboratory, NOAA, Silver Spring, MD.

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Green, A.E.; Singhal, R.P.; and Venkateswar, R. (1980). Analytic extensions ofthe Gaussian

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Grell, G.A.; Dudhia, J.; and Stauffer, D.R. (1995). A description ofthe fifth-generation Penn

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CO.

Grosjean, D.; and Seinfeld, J.H. (1989). Parameterization ofthe formation potential ofsecondary

organic aerosols. Atmos. Environ., 23: 1733-1747.

Grosjean, D. (1992). in-situ organic aerosol fonnation during a smog episode: estimated

production and chemical functionality. Atmos. Environ., 26A:953-963.

Holton, J.R. (1982). An introduction to Dynamic Meteorology. Academic Press, New Yark, NY.

Houck, J.E.; Chow, J.e.; and Ahuja, M.S. (1989). The chemical and size characterization of

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Houck, J.E.; Goulet, J.M.; Chow, J.e.; Watson, J.G.; and Pritchett, L.e. (1990). Chemical

characterization of emission sources contributing to light extinction. In Transactions,

Visibility and Fine Particles, Mathai, e.V., Ed. Air and Waste Management Association,

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Koracin, D.; and Enger, L. (1994). A numerical study of boundary-layer dynamics in a mountain

valley. Part 2: Observed and simulated characterisitcs of atmospheric stability and local

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Lowenthal, D.H.; Chow, J.e.; Watson, J.G.; Dipple, W.A.; and Mazzera, D.M. (1996). PMIO

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Pytkowicz, R.M.; and Kester, D.R. (1971). The physical chemistry ofsea water. Oceanogr. Mar.

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Rogge, W.F.; Hildemann, L.M.; Mazurek, M.A.; and Cass, G.R. (1991). Sources offine organic

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1125.

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and seasonal variation. Atmos. Environ., 27A: 1309-1330.

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52
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formation in winter. Prepared for California Air Resources Board, Sacramento, CA, by

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acid, and ammonia equilibrium in wintertime Phoenix, Arizona. JA WMA, 44:405-412.

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53

Source Modeling and Back Trajectory Attribution Techniques

Table 2. Puff, Visibility and Trajectory Modeling Attribution Techniques

Evaluation Criteria

Chemical Mechanisms

CALPUFF

Visibility Models

VISCREEN PLUVUEII

Models

Lagrangian Trajectory Models

RAPTAD FLEXPART

Docs the model simulate Yes; reactions for NO NO NO NO NO

aqueous phase chemistry? (I f 504 and NOJ

it docs wh<'ll chemistry

mechanism is used and docs it

include fog/cloud chemistry)

Docs the model simulate gas Yes NO NO NO NO NO

phase chemistry? (if it docs,

what chemical mechanism is

imolemented)

Simulate secondary organic 4 species model NO NO NO NO NO

aerosols

Inorganic PM (i.e. ions, 5°4, 504• NOJ NO NO NO NO NO

N03, etc)

Size distributions (scction<ll or Coarse and fine NO NO Only for deposition NO

modal) modes

Applicable spatial scales Micro- to regional Neighbor-hood to Neighborhood to Neighborhood to global Neighborhood to global scalc

scalc urban scalc global scale scalc

Applicablc tcmporal scales Episodic or Long N/A NIA Episodic or Long Episodic or Long term Episodic or Long tcrm

(episodic or long tcrm tcrm lcrm

applications)

Docs thc model havc thc YES YES YES YES YES YES

capability to distinguish

BART sourccs?

Docs thc model havc the NO; only [IS NO NO NO NO NO

capability to ingcsl field background v<'llucs

measurements (PM, HNOJ,

H20 2, NHJ, etc)

55
Air Quality Models (continued)

Evaluation Criteria

CALPUFF

Vlsibilif)' Models

YISCREEN PLUYUEIl HYSPLIT

Lagrangian Trajectory Models

RAPTAD FLEXPART

51 1 Ity o e me

Docs the model simulate NO NO NO NO NO NO

background regional haze

Point source treatment (plume YES YES YES YES YES YES

rise, plume in grid)

Docs the model have the YES NO NO YES NO YES

capability to calculate wet and

dry deposition?

Visibility treatment: Extinction (total • • NO NO NO

(extinction, deeiview, visu~l and for S04, NO.1,

range) EC, DC, tine,

coarse), Deeiviews

put Reauirements

Meteorological data required Gridded; able to • • Gridded Gridded Griddcd (ECMWF, MM5)

(single site, gridded, number run with single site (FNL, EDAS, (Usc HOTMAC's

of levels, etc) MM5) prediction)

Emission data required (single Multiple point, • • Multiple point Single stack or multiple • stack, multiple poinl sources, area, volume sources, gridded point sources

griddcd, etc) inventOty

Allow for initial and boundary YES NO NO NO NO NO

conditions (is iT required or

not applicable)

Has the model been compared YES YES YES YES YES NO

against field program data?

Has the model been peer

reviewed?

Docs enough data exist now Usc CALMET YES YES Griddcd mel data Usc HOTMAC to obtain • to run the model (Docs data with existing available on NOAA wind and turbulence data

exist in a format ready for the sta[ions or MM ARL fip S;IC (FNL,

model? Arc current databases data EDAS); adaptable

adequate for the model?) to read in MM5

In

Vi 'bT M d r

56
Air Quality Models (continued)

VisibilifJ' Models Evaluation Criteria

CALPUFF VISCREEN PLUVUEII HYSPLIT

Lagrangian Trajectory Models

RAPTAD FLEXPART

Practical Considerations

No informatIOn avallablc at thIS tIme

Costs to ntn (hardware Inexpensive; PC, Inexpensive; PC, Inexpensive; Inexpensive; PC, Inexpensive: Linux PC. Inexpensive; Linux PC, Redhat; ean be

platforms, file storage, Windows, up 10 DOS, 1MB PC, DOS, Windows, 20MB Redhat compiled on PC

opcrating system) 20GB (with 1MB

CALMET)

Have protocols or procedures FLAG for Class I FLAG for Class I FLAG for NO NO NO

been developcd to run and AQRVs AQRVs Class I

intcrorct the model? AQRVs

Is the source code available? YES YES YES NO YES YES

Are beginning user training YES; by EPA; APTI EPA; APT! NO YES NO

classes available? EanhTeeh, BEELine

Are user SUpp0i1 groups YES; one list-serve YES; through EPA YES; through NO YES NO

available? SCRAM EPA SCRAM

Level of expel1ise required to Moderate; able to Simple; able to run on Simple; able Simple; able to nm Simple to run: GUI Moderate; must compile source code for

run and interpret results run PC DOS PC DOS and windows to run 011 PC on PC running allows the user to easily PC, Linux or UNIX; knowledge of met

(Level of Linux, UNIX, PC programs; DOS and Windows run the program input formats

skills required) knowledge of Windows

atmospheric Knowledge is needed to

ehemistry & interpret results

physics

Output visualization required YES NO NO YES~ has built in YES; has built in YES

to interpret output nllmbers visualization visualization

Other strengths • • • • Applicable from building • scale to terrain scale.

Availability Eal1hTeeh EPA EPA NOAA Air Yamada Science & Art; http://www.forst.uni·

www.~rc.c()m Resource http://www.ysasoft,eom muenehcn.dc/EXT/LST/METEO/stohl/f

Laboratory; lexpart.html

www.arl.noaa.gov/s

s/models/hyspl il.ht

ml

•

57
Source Modeling and Back Trajectory Attribution Techniques

Table 3. Eulerian Grid Based Modeling Attribution Techniques

Air Quality Models

Evaluation Criteria

Chemical Mechanisms

CMAQ REMSAD CAMx

Grid Models

UAM-AERO UAM-VPM URM CalGrid

Does the model simulate aqueous phase 35 equilibria ~nd 99 I reaction for 504 I reaction for SO~ 35 equilibria and 99 • 2 reactions for sulfate NO

chemistry? (I f it docs, what chemistry reactions for 504 and reactions for 504 and

mechanism is used and docs it include NOJ NO}

fog/cloud chemistry)

Docs the model simulate gas phase CBM-IV (93 CBM-IV CB·!V with enhanced SAPRC97 CB LCC YES (both CBM-I V

chemistry? (i f it docs, what chemical reactions) or RADM2 (93 reactions) or isoprene or (I R5 reactions) (aboLit 100 reactions) and SAPRC)

mechanism is implemented) (158 reactions) RADM2 (158 SAPRC97

reactions)

Simulate secondary organic aerosols Primary from Primary from Primary from Secondary from gas Primary from Primary from NO

emissions; secondary emissions emissions; secondary phase reactions of emissions emissions; secondary

from organics from gas phase organic precursors from gas phase

reactions of organic using yields reactions of organic

preelH-sors lising precursors using

yields production fractions

Inorganic PM (i.e. ions, S04, NO." etc) S04, NO.1 and other 504, NO." NH4, and S04, NO.1, NH4, el, SO" NO" NH4. CI, 504, NO), NH4, and 504, NO.1, NH4, Ct, NO

material other material other ions and other ions and other materials other ions and

materials materials materials

Size distributions (sectional or modal) Lognormal; three PM2..'i fraction, coarse Discrete bins, user Discrete bins, user Lognormal bins; user Discrete bins; user NO

modes: Aitken, mode specified lip to 10 specified up to 10 specified specified

Accumulation and

eoase

Applicable spatial scales Mesoscale Mesoscale Mcsoseale Urban seale Urban scale Mesoscale Urban to Regional

Applicable temporal scales (episodic or long Episodic Long term Episodic Episodic Episodic Episodic Episodic

tcrm applications)

Docs the model have the capability to YE5; using plume in NO YES NO NO NO NO

distinguish BART sources? grid

58
Air Quality Models (continued)

UAM-VPM URM CalGrid

Grid Models

REMSAD CAMx UAM-AERO

Evaluation Criteria

emleal Mechanisms lcontinued\

Docs the model have the capability to ingest YES; as initial and Uses default profiles YES; as initial and YES; as initial and YES; as initial and YES; as initial and YES; as initial and

field measurements boundary conditions boundary conditions boundary conditions boundary conditions boundary conditions boundary conditions

(PM,HNO),H 2OZ,NHJ,ele)

sibility Modelln$!

Docs the model simulate background regional YES YES YES YES (with YES YES NO

haze processing)

Point source treatment (plume rise, plume in Plume in grid NO Plume in grid NO NO NO NO

grid)

Docs the model have the capability to YES YES YES YES YES YES YES

calculate wet and dry deposition?

Visibility treatment: (extinction, deeiview, Extinction (total and Extinction (total and NO YES (with • • NO

visual mnge) for S04, NO), EC, for S04, NO), Ee, processing)

OC, fine, coarse), OC, fine, coarse),

Deeiviews Deeiviews

pul ReQUirements

Meteorological data required (single site, Gridded Gridded Gridded Gridded Gridded Gridded Griddcd CALMET

gridded, number of levels, etc) date

Emission data required (single stack, multiple Gridded Gridded Gridded Gridded Gridded Griddecl Gridded

point sources, gridded, etc)

Allow for initial and boundary conditions (is YES YES YES YES YES YES YES

it required or not applicable)

Has the model been compared against field YES YES YES YES YES YES YES

program data? Has the model been peer

reviewed?

Docs enough data exist now to run the model Extensive need for Extensive need for Extensive need for Extensive need for Extensive need for • Extensive need for

(Docs dam exist in a format ready for the detailed emissions detailed emissions detailed emissions detailed emissions detailed emissions detailed emissions

model? Arc current databases adequate for and meteorological and meteorological and meteorological and meteorological and meteorological and meteorological

the model?) fields fields fields fields fields fields

Vi

In

Ch

59
Evaluation Criteria

Practical Considerations

CMAQ

Air

REMSAD CAMx

Grid Models

UAM-AERO UAM-VPM URM CalGrid

Costs to nm (hardware platforms. tile storage. Can be nm Can be run Can be run Can be run Can be run Can be run Can be run

operating system) inexpensively; Linux inexpensive; Linux inexpensively; Linux inexpensively; Linux inexpensively; Linux inexpensively; Linux inexpensively; Linllx

PC, up to I TB PC PC PC PC PC PC

(annual runs)

Has a prolOeo! or procedures been developed NO; but RPOs have NO; but RPOs have NO NO NO NO NO

to nm the model? regional haze regional haze

protocols protocols

Is the source code available? YES • YES YES YES YES YES

Are beginning user training classes available? YES; through EPA NO YES; through SAl NO NO NO NO

and RPOs and RPOs

Arc user support groups available? YES; through EPA NO NO NO NO NO NO

and RPOs

Level of expertise required to run and Considerable • Moderate to Moderate to • • Moderate

interpret results (Level of Linl1x, UNIX, PC expel1ise in UNIX or extensive extensive

skills required) Linllx; knowledge of

atmospheric

chemist!)' & physics

Output visualization required to interpret YES; use PAVE YES; lise PAVE YES YES YES YES YES

output numbers

Availability EPA; Sharon LeDuc SAl; Sharon Douglas ENVIRON; Ralph SAl; Sharon Douglas SAl; Sharon Douglas Georgia Tech; Ted CaliFornia Air

919-541-1335 415-507-7108 Morris 415-899-0700 415-507-7108 415-507-7108 Russel, Talat Odman Resources Board

* No inFormation available at this rime

60
A T h ' Ta e bl 4 Meteoro O!!lca1M0 derIn!! Un'butlOn ec maues

Dial!nostic Models Mesoscale Prmmostic Models

CALMET Diagnostic Wind RAMS MM5 Eta· ARPS HOTMAC Evaluation Criteria Model

Applicable spatial scales Urban to regional Urban to regional Urban to global Urban to global Urban to global Urban to global Urban to

scale scale scale scale scale scale mesoscale

Applicable temporal Hourly to annual Hourly to annual Hourly to annual Hourly to annual Hourly to annual Hourly to annual Hourly to annual

scales

Docs enough data exist in Depends on area Depends on area Depends on area Depends on area Depends on area Depends on area Depends on area

organization now to run

the model? Arc (he

existing monitoring

networks adequate within

the domain?

For the prognostic NIA NIA Yes Yes Yes Yes Yes

models: Capable of

FDDA?

For the prognostic N/A N/A NOAA is running Several federal NOAA is running It ean be No

models: Arc files the model for the agencies and Ihe Eta model and initialized using

available (archived) from easL eoasL regional fields available NCEP analyses

real-time? consortiums arc through NCEP ftp files as well as

running MMS site individual

observations

Data storage/archival Depends on Depends on Depends on Depends on Depends on Depends on Depends on

requirements for modeling domain, modeling domain, modeling domain, modeling domain, modeling domain, modeling domain, modeling domain,

simulation of episodic grid size, number of grid size, number grid size, number grid size, number grid size, number grid size, number grid size, number

and annual events species and length of species and of species and of species and of species and of species and of species and

ofsimulation length of length of length of length of length of length of

simulation simulation simulation simulation simulation simulation

Simulate No No Yes minutes to Yes minutes to Yes minutes to Yes minutes to Yes minutes to

clouds/preci pitation days days days days days

fields? At what time

intervals?

Has the model been Yes Yes Yes Yes Yes Yes Yes

compared against field

program data? Has the

model been peer

reviewed?

61
Meteorolol!ical Modeling Attribution TechniQues (continued)

Dial!nostic Models Mesoscale Pro2nostic Models

CALMET Diagnostic Wind RAMS MM5 Eta ... ARPS HOTMAC Evaluation Criteria Model

Tools available [0 Yes - Unix. Linux, Yes - Unix, Yes - Unix, Linux Yes - Unix, Linux Yes - Unix, Linux Yes - Unix, Linux Yes - Bl1i1t~in

visualize output fields? Windows Lintlx, Windows GUI; Unix, Linux,

What oDcratinll systems? Windows

Arc user groups, Yes Yes Yes Yes No Yes Yes

listscrvers available when

roblcms arise?

Cost to run (hardware, PC Windows, PC PC Linux, UNIX; PC Linux; licensed PC Linux, UNIX; PC Linux, UNIX; PC Linux, UNIX; PC Linux; licensed

software) Linux; Free source Free source code Free source code Free source code FfCC source code source code

code

Level of expertise Moderate Moderate High High High High High

required to run and

interprct results (Level of

Linux, UNIX, PC skills

rCQuired)

Availability of user Ycs Yes Yes Yes No Yes Yes

training

Is the sou rec code Ycs Yes Yes Yes No Yes Yes

available?

Has a protocol or Yes Yes Yes Yes Yes Yes Yes

procedures been

developed to run the

model?

Strengths Relatively easy to Relatively easy to Detailed 3·0, Detailed 3-0, Detailed 3-D, Detailed 3-0, Detailed 3-0,

usc; little observed usc; little observed complex flow in complex flow in complex flow in complex flow in complex flow in

data needed data needed time time time time time

Weaknesses/ Parameterization Parameterization Large computer Large computer Large computer Large computer No real time data

Limitations depended; may no! depended; may not time; time time; time time; time time; lime initializmion

capture variolls capture various consuming to consuming to consuming to consuming to

flows flows debut.!: debut.!: debu. debu.

* WhIle the Eta IS not considered a mesoscale model, II has been used to Simulate meteorology down to 10 km gnd scales. The workstatIon Eta 1S avatlable from

NOAA and used experimentally by some NWS oflices.

• No information available at this time

62
C. Observational Modeling Techniques

Jnlroduclion

Observational or receptor modeling refers to a group of analysis techniques in which

monitoring data collected at or in the region of a receptor are analyzed in various ways in order

to infer infonnation about the pollutants and the sources of the pollutants causing visibility

impairment.

These types of models often are used as the first technique for source apportionment in order

to get an initial understanding of the source-receptor relationships in a region. They are also used

to verify or reconcile deterministic models, and to aid in planning intensive monitoring studies.

Results of observational models can either be quantitative or qualitative. Quantitative results

are estimates ofthe fractions ofa measured species that can be attributed to a single source or

attributed among several sources or source areas. Qualitative results include such infonnation as

the wind directions and other meteorological conditions most associated with high

concentrations, or inferences about probable source types based on the relationships between

trace elements at a single site, or information about source areas based on the spatial and

temporal patterns in the concentrations ofa single species. Often several observational models

are used together to fonn hypotheses about the important source areas and source types affecting

the concentrations at a receptor.

Advantages of receptor models are that they are generally quick and inexpensive to run and

require relatively little input data. Disadvantages include the necessity of employing simplifYing

assumptions such as linear relationships and often the results are limited to averages over long

periods of time or large spatial areas. Subjective user judgment is required to choose appropriate

input data and/or interpret the results of many receptor models. As an example, suppose the

UNMIX model data located a source associated with high concentrations ofBr, K, elemental

carbon, and organic carbon, and another source associated with high Se and S. It is the judgment

of the modeler regarding the relationship of the individual species to a specific source that

detennines that first source is "smoke" and the second is "coal-fired power plants."

Receptor models could potentially be grouped in several different ways, based on their

different attributes. Here they are somewhat arbitrarily put into four categories, with each

category requiring incrementally more particulate data at the receptor: I) back-trajectory

analyses; 2) analyses ofinterspecies relationships; 3) analyses ofspatial and temporal patterns;

and 4) analyses that require a unique tracer. Some models that fall into each category are listed

below:

Category 1. Back-Trajectory Analyses

a. Residence Time Analyses including residence time, source contribution function,

conditional probability, and so forth. These give qualitative infonnation about source

areas and transport patterns.

63
b. Trajectory Mass Balance - Regression of residence time of back trajectories in selected

source areas against concentrations yielding quantitative source attributions.

Category 2. Analyses of Interspecies Relationships

a. Chemical Mass Balance (CMB) - Quantitative source attributions are obtained by a

weighted regression of known source profiles against measured concentrations ofseveral

species.

b. UNMIX - By looking for "edges" in the relationships between species, UNMIX

estimates both the source profiles and the quantitative source contributions from each

source.

c. Positive Matrix Factorization (PMF) - PMF, like UNMIX, uses the relationships between

species to estimate the number and composition ofthe sources and the quantitative source

contributions.

d. Enrichment Factors (EF) - The "enrichment" of certain ratios oftrace elements is used to

qualitatively infer source types impacting a receptor.

Category 3. Analyses of Spatial and Temporal Patterns

a. Empirical Orthogonal Function Analysis (EOF) - Analysis ofspatial and temporal

patterns leading to qualitative infonnation about locations of dominant source areas,

frequency and timing ofsource impacts and meteorological conditions associated with

them.

b. Receptor Model Applied to Patterns in Space (RMAPS) - With additional assumptions

applied to EOFs, quantitative source attributions are estimated.

Category 4. Tracer Analyses

a. Tracer Mass Balance Regression (TMBR) - Tracer concentrations, possibly weighted by

other factors, are regressed against concentrations of the species ofinterest to give a

quantitative estimate of the contribution from the source that emitted the tracer.

b. Differential Mass Balance (DMB) - The differential ratios of tracer to pollutant between

source and receptor are adjusted based on simple chemistry and meteorology to give an

estimate ofthe contribution of the tracer source to the receptor.

c. Tracer-Aerosol Gradient Interpretive Technique (TAGIT) - By comparing the ratios of

tracer to concentration ofinterest at "background" sites to the ratios at tracer-affected

sites, a quantitative attribution ofthe tracer source to the receptor is estimated.

Following are brief descriptions of each of these models and a few references giving further

details and examples of their use.

lao Qualitative Back Trajectory Residence Time Analyses

There are several methods ofstatistically analyzing the relationships between where air

masses arrived from and the concentrations measured at a receptor. These include, but are not

limited to: I) where was air most likely to arrive from when concentrations are high; 2) ifair

arrived from a given area, what is the probability that the concentration at the receptor was high

when the air mass arrived there; 3) what is the mean (or median or maximum or distribution) of

64
concentrations at the receptor when air masses arrived from a given area. Selected References:

Ashbaugh et al. (1985), Gebhart et al. (2001), Poirot and Wishinski (1986).

Data Needed: A time series of concentrations of the species ofinterest. One or more back

trajectories ofthree to five days duration corresponding to each concentration. Back trajectories

can be calculated by any ofseveral methods including ATAD, Hysplit, the CAPITA Monte

Carlo Model, as well as others. Standard National Weather Service upper air data can be used as

input, though more detailed meteorological data can be input if available. Dispersion can be

included in some of these models.

Model Assumptions: Errors in trajectory placement are random and uncorrelated. Variations

in deposition, chemistry, emissions, and so forth, have less influence on measured concentrations

on average than variations in transport directions.

Biggest Potential Problems: Results ofthese types of analyses are qualitative rather than

quantitative. Results are more statistically robust when averaged over long time periods, usually

a minimum of one season and preferably several years. Nearby sources cannot be resolved. User

judgment is required to choose trajectories of an appropriate type, height, and length and also to

choose appropriate definitions of "high" concentrations. Some concentrations that vary

seasonally may have all "high" concentrations in a single season, necessitating some

compensation in the analysis. Model results are probably more appropriate for species such as

particulate sulfate that are relatively unifonn over large spatial scales, rather than, for example,

particulate nitrate, which is more volatile and seems to be more related to local sources than

long-range transport.

lb. TrMB (Trajectory Mass Balance)

This is a multiple linear regression of the frequency ofoccurrence oftrajectory endpoints in

each ofseveral source areas against the corresponding concentrations at the receptor. The result

is the average attribution of a single species among up to about 25 source areas over a long time,

for example, one season or year, or several years. Selected references: Gebhart and Maim (1989),

Stohl (1998).

Data Needed: Time series of concentrations of the pollutant ofinterest at a single site. One

or more back trajectories associated with each concentration. Input data for these are upper air

winds, temperatures, and moisture over a large area. Often data are obtained from the standard

National Weather Service observations, but other data such as higher resolution wind fields,

wind profiler data specific to a given study, can also be used if available. Emission data can be

used if available, but must vary in time to be useful. Simple chemistry andlor deposition can be

used if data are available. The user defines the size and locations ofthe source areas to be

considered.

Model Assumptions: Average contributions of each source area can be written as a linear

combination ofthe contributions from several source areas. Average chemistry and deposition

are adequate to explain average source contributions. Errors in back trajectories are random and

nonnally distributed.

65
Biggest Potential Problems: No attribution to single sources--{)nly to source areas.

Attributions must be averaged over long time periods. Nearby sources cannot be modeled

accurately. Subjectivity in choosing source areas. Violation of assumptions oflinear chemistry.

2a. Chemical Mass Balance (CMB)

CMB is a multiple linear regression of measured concentrations against known source

profiles. It is used for the attribution of all measured chemical species among several sources for

each concentration measurement period for a single monitoring site. Regressions are weighted by

the uncertainties in both the source profiles and the concentrations. Selected References: Watson

et al. (1984 and 200 I).

Data Needed: Concentrations and measurement uncertainties of both the chemical species of

interest and of as many trace elements as possible are necessary for each time period and location

for which attributions are desired. IMPROVE data can be used. A source profile is needed for

each source. These are the relative amounts of each emitted chemical species and the

uncertainties in these values.

Model Assumptions: Compositions ofsource emissions are constant over the period of

ambient and source sampling. Chemical species do not react with each other, for example, they

add linearly. All sources with a potential for significantly contributing to the receptor have been

identified and have had their emissions characterized. The sources' compositions are linearly

independent of each other. The number ofsources or source categories is less than or equal to the

number of chemical species. Measurement uncertainties are random, uncorrelated and nonnally

distributed.

Biggest Potential Problems: The model cannot directly apportion secondary species such as

sulfates, nitrates, and secondary organics. There are some workarounds for this. The usual tactic

is to apportion these species between the known primary sources and a source designated as

"secondary particles." It is also possible to use "fractionated" or "aged" source profiles where an

attempt is made to pre-determine the chemical processes that occurred between SOUrce and

receptor and then adjust the source profile accordingly. Obtaining all necessary SOUrce profiles

can be difficult. In some studies, other receptor models have estimated source profiles.

2b. UNMIX

For a selection of measured species, UNMIX uses singular value decomposition with

additional non-negativity constraints to estimate the number ofsources, the source compositions,

and the source contributions to each sample at a single monitoring site. UNMIX attempts to find

the "edges" in the relationships between species and relates these to sources. Selected

References: Henry (I997a, 1999), Lewis et al. (1998).

Data Needed: A time series of concentrations ofseveral species measured at a single site.

IMPROVE data can be used.

66
Model Assumptions: Concentrations are linear cOlnbinations of an unknown number of

sources of unknown composition. Contributions from sources are positive. Source compositions

are approximately constant in time. For each source there are some samples that contain little or

no contribution from that source.

Biggest Potential Problems: A maximum ofseven SOurces can be identified. There is some

subjectivity in choosing fitting species, number of sources, how to deal with missing Or below

detection limit values, and which time periods and species should be analyzed together. Sources

ofsecondary species will probably violate the assumption of constant source composition. This

can cause multiple sources to be identified for a single physical source that impacts the receptor

under differing conditions. Supplemental analysis may be required to deconvolute these.

2c. Positive Matrix Factorization (PMF)

PMF uses an iterative weighted least squares method to decompose a time-by-species matrix

to estimate the number and composition of the sources and the contributions of each source to

each measured species. It will also calculate error estimates for these values. Selected

References: Paatero and Tapper (1994), Paatero (1997); Xie el al. (1999).

Data Needed: A time series of concentrations and their uncertainties for several species at a

single monitoring location. IMPROVE data can be used.

Model Assumptions: Concentrations are linear combinations of an unknown number of

sources of unknown composition. Contributions from sources are positive. Source compositions

are approximately constant in time.

Biggest Potential Problems: Correlations in detection limits or uncertainties as well as in

concentrations can influence the results. For example, PMF may detect positive correlations

between species either due to source activity (desirable) or measurement protocol changes

(undesirable).

2d. Enrichment Factors (EF)

The differences in ratios of elemental concentrations between a reference sample and a

measured sample are used to determine how sources may have "enriched" the concentrations of

certain species. Some examples include: high Al/Ca has been linked to Saharan dust, high Br/Pb

may indicate lead is linked to autos rather than industry, high Se is linked to coal burning, heavy

metals are linked to smelting, V and Ni are linked to residual oil combustion. Selected

References: Lawson and Winchester (1979), Parekh et al. (1989), Perru (1997), Roshid and

Griffiths (1993).

Data Needed: Time series of concentrations of trace elements and the species ofinterest.

Some historical information about the "standard" crustal, sea salt, or other ratios for a region.

Model Assumptions: Elemental ratios depend mostly on enrichment of trace elements by a

source and have less dependence on meteorology. The reference ratios are constant.

67
Biggest Potential Problems: Attributions are generally to source areas, not to single sources.

3a. Empirical Orthogonal Function Analysis (EOF)

A few (typically two to six) spatial patterns that explain most ofthe covariance in the spatial

and temporal patterns of a measured species are obtained by singular value decomposition.

Associations between the spatial patterns and source areas and/or transport of air pollutants into

the study area can often be inferred, but are qualitative. The original data matrix can be

approximately reconstructed by linearly recombining these few patterns. Selected References:

Gebhart and Maim (1997), Henry et al. (1991), Maim et al. (1990), Maim and Gebhart (1997).

Data Needed: Measurements ofa single air pollutant ofinterest at several sites for several

time periods. Typically used are concentrations measured at fifteen to forty sites for thirty or

more time periods. There must be more time periods than sites. Data from special studies are

often analyzed in this way.

Model Assumptions: Only a few spatial patterns are required to explain a large majority of

the covariance in the spatial and temporal patterns. These patterns have a physical meaning that

can be inferred, such as transport of emissions from a source into the study area or local

stagnation.

Biggest Potential Problems: Source attributions are qualitative, not quantitative and

interpretation of the spatial patterns is subjective. The model requires a site by time matrix with

no missing values, so some method of eliminating or filling in both missing and below detection

limit values is necessary.

3b. Receptor Model Applied to Patterns in Space (RMAPS)

Detennines the average attribution of a single species among a few source areas by

decomposing the time by site matrix of concentrations into a source matrix and a time weighting

matrix. Similar to UNMIX, the edges in the scatterplots between sources and non-negativity

requirements are used to constrain the identification ofsources. Selected References: Henry

(1997 b, c, d), White (1999).

Data Needed: Time series of concentrations ofthe pollutant of interest at several sites within

a region. The model previously has been used in special studies such as Project MOHAVE and

PREVENT where there are fifteen to forty sites within a one or two state region collecting data

daily for several weeks or months.

Model Assumptions: Average contributions of each source area can be written as a nonnegative linear combination of the major principal components ofthe data. The spatial scale of

the pollutant is large compared to the spacing ofthe sampling sites.

Biggest Potential Problems: Ifthe second major assumption is violated, the concentrations

ofthe pollutant at each site will have little correlation with the other sites; therefore the model

would not apply because it relies on the common variations among sites.

68
4a. Tracer Mass Balance Regression (TMBR) also called Multiple Linear Regression

(MLR) on Marker Species

Estimates the attribution ofthe aerosol species of interest by a source or source type, which

emitted or emits a unique tracer. Uncertainty estimates are also generated ifincluded in the

regression. The model is a regression ofthe tracer, possibly weighted by other factors against the

species of interes!. Selected References: MaIm et al. (l989 a, b, c).

Data Needed: Time series of ambient concentrations and their uncertainties for the aerosol

species being apportioned and also the tracer species.

Model Assumptions: The tracer(s) are uniquely emitted by non-overlapping groups of

sources. Source emissions are constant over the period of ambient sampling. Deposition and

conversion are constant for all sampling periods and can be estimated by first-order

approximations. In the WHlTEX application, sulfate oxidation rates were assumed to be related

to RH, where RH was a surrogate for time the air mass spent in clouds. Measurement errors are

random, uncorrelated, and normally distributed.

Biggest Potential Problems: Tracer concentrations are not often available. Source profiles,

deposition, and conversion all vary in time and space.

4b. Differential Mass Balance (DMB)

DMB estimates the fraction of a species ofinterest attributable to a single source that can be

tagged with a unique tracer. The ratio ofmeasured tracer to measured sulfate or nitrate is

assumed to be related to the fractional contribution of the traced source. The ratio is adjusted

based on the estimated difference between the ratio at the source to the ratio at the receptor.

Travel times between the source and receptor are estimated based on winds, and then by using

simple estimates of dispersion, deposition and oxidation, the tracer to secondary species ratio is

adjusted. Selected References: Maim (1989b, c).

Data Needed: Time series oftracer concentrations and concentrations and emission rates of

the species ofinterest and its precursors, for example, sulfur dioxide and sulfate. Estimates of

wind speed and direction, mixing heights, deposition and oxidation rates.

Model Assumptions: Wind direction does not change during transport time. The rates for

deposition and conversion are first-order and invariant in space and time along the transport path

between the source and the receptor. The ratio of the emission rates for the species ofinterest or

its parent species and the tracer is known.

Biggest Potential Problems: Simple chemistry and meteorology may not be adequate,

especially for long transport times, complex terrain, and/or changing chemical regimes. Tracer

concentrations unique to a single source are often not available. The fraction of attributable

concentration may only be calculable to within a range based on the reasonable ranges ofrate

coefficients.

69
4c. Tracer-Aerosol Gradient Interpretive Technique (TACIT)

Results are the attribution of primary or secondary species associated with the source

"tagged" by a tracer release. TAGIT computes attributions on a sample period-by-sample period

basis. For each sample period, background concentration of the species ofinterest is determined

by averaging the concentrations ofthe species at nearby sites that do not have tracer

concentrations and are significantly above background. These sites are presumed to be

unaffected by the tracer-tagged source and thus represent the average background. This

background for each sample period is then subtracted from the concentration ofthe species of

interest at impacted receptor sites for corresponding sample periods. The difference is the

concentration attributable to the tagged source. Green (200 I), Kuhns et al. (1999), Pitchford et

al. (2000).

Data Needed: Concentrations of a unique tracer from a source ofinterest and simultaneous

concentrations of a pollutant ofinterest at several sites in a region.

Model Assumptions: There is no impact from the tagged source if the tracer concentration is

less than the level considered to be "significantly" above its' background. Background

concentrations ofthe species of interest do not vary systematically in space.

Biggest Potential Problems: Assuming no impact from the tagged source when tracer is not

statistically above background can lead to an underestimation of attribution. Measured tracer

concentrations often have large uncertainties. Some sampling periods will have a negative

concentration attributed to the tagged source.

References:

Ashbaugh, Lowell L., William C. Maim, Willy Z. Sadeh (1985) "A Residence Time Probability

Analysis of Sulfur Concentrations at Grand Canyon National Park," Atmospheric

Environment, 19, 1263-1270.

Gebhart, Kristi A., Sonia A. Kreidenweiss, and William C. MaIm (2001) "Back-Trajectory

Analyses of Fine Particulate Matter Measured at Big Bend National Park in the Historical

Database and the 1996 Scoping Study" Science ofthe Total Environment, 276,185-204.

Gebhart, Kristi A. and William C. Maim (1989) "Source Apportiorunent of Particulate Sulfate

Concentrations at Three National Parks in the Eastern United States," in Transactions of

the A&WMAIEPA Specialty Conference-Visibility and Fine Particles, Estes Park, CO,

Oct. 15-19, 1989, pp. 898-913, C.V. Mathai, Ed.

Gebhart, Kristi A. and William C. Maim (1997) "Spatial and Temporal Patterns in Particle Data

Measured during the MOHAVE Study," J. ofthe Air & Waste Management Assoc., 47,

119-135

Green, Mark, 2001 (Informal paper, BRAVOl

70
Henry, R.S. (1997a) "History and fundamentals ofmultivariate air quality receptor models,"

Chemometrics and Intelligent Laboratory Systems, 37, 37-42.

Henry, R.C. (1997b) "Receptor Model Applied to Patterns in Space (RMAPS) Part 1- Model

Description" JA&WMA, 47, 216-219.

Henry, R.C. (1997c) "Receptor Model Applied to Patterns in Space (RMAPS) Part 11-

Apportionment of Airborne Particulate Sulfur from Project MOHAVE" JA&WMA, 47,

220-225.

Henry, R.C. (1997d) "Receptor Model Applied to Patterns in Space (RMAPS) Part 111-

Apportionment of Airborne Particulate Sulfur Western Washington State" JA&WMA,47,

226-230.

Henry, R.C. (1999) "Comparing a new algorithm with the classic methods for estimating the

number offactors," Chemometrics and Intelligent Laboratory Systems, 48, 91-97.

Lewis, C.W., R.C. Henry, and J.H. Shreffler (1998) "An Exploratory Look at Hydrocarbon Data

from the Photochemical Assessment Monitoring Stations Network" J. Air & Waste

Management Assoc. 48, 71-76.

Henry, Ronald c., Vi-Jin Wang, and Kristi A. Gebhart (1991) "The Relationship Between

Empirical Orthogonal Functions and Sources of Air Pollution," Atmospheric

Environment, 25A, 503-509.

Kuhns et al. (1999)

Lawson, D.R. and J.W. Winchester (1979) "A Standard crustal aerosol as a reference for

elemental enrichment factors," Atmospheric Environment, 13, 517-523.

MaIm, William C, Hari K. Iyer, and Kristi Gebhart (I989a) "Application ofTracer Mass Balance

Regression to WHITEX Data" in Transactions ofthe A&WMA/EPA Specialty

Conference: Visibility and Fine Particles, Estes Park, CO, Oct. 15-19, 1989, pp. 806-818,

C.V. Mathai, Ed.

MaIm, William c., Hari K.lyer, John Watson, and Douglas A. Latimer (1989b) "Survey ofa

Variety ofReceptor Modeling Techniques," Transactions of the A&WMA/EPA Specialty

Conference-Visibility & Fine Particles, Estes Park, CO, Oct. 15-19, 1989, pp. 781-805,

C.V. Mathai, Ed.

MaIm, William, Kristi Gebhart, Douglas Latimer, Thomas Cahill, Robert Eldred, Roger Pie Ike,

Roger Stocker, and John Watson (1989) "National Park Service Report On the Winter

Haze Intensive Tracer Experiment" National Park Service, Air Quality Division,

Research Branch, Fort Collins, CO, Dec. 4, 1989

71
Maim, William C. and Kristi A. Gebhart (1997) "Source apportionment of sulfur and light

extinction using receptor modeling techniques," Journal ofthe Air & Waste Management

Association, 47, 250-258.

MaIm, William c., Kristi A. Gebhart, and Ronald C. Henry (1990) "An Investigation of the

Dominant Source Regions of Fine Sulfur in the Western United States and their Areas of

Influence," Atmospheric Environment, 24A, 3047-3060.

Paatero, P. (1997) "Least squares formulation of robust non-negative factor analysis,"

Chemometrics and Intelligent Laboratory Systems, 37, 15-35.

Paatero, P. and U. Tapper (1994) "Positive Matrix Factorization - a Nonnegative Factor Model

with Optimal Utilization of Error-Estimates of Data Values," Environmetrics, 5, 111-126.

Parekh, P.P., B. Ghauri, and L. Husain (1989) "Identification of Pollution Sources of

Anomalously Enriched Elements," Atmospheric Environment, 23,1435-1442.

Perru, K.D., T.A. Cahill, R.A. Eldred, and D.O. Dutcher (1997) "Long-range Transport of North

African dust to the eastern United States," J. Geophys. Res., 102, 11,225-11,238.

Pitchford, Marc, Mark Green, Hampden Kuhns, and Robert J. Farber (2000) "Characterization of

Regional Transport and Dispersion Using Project MOHAVE Tracer Data" J. Air &

Waste Manage. Assoc. 50: 733-745. (This is not exactly TAGIT, but the 1999 reference

may be a conference paper.)

Poirot, Richard L. and Paul R. Wishinski (1986) "Visibility, Sulfate and Air Mass history

Associated with the Summertime Aerosol in Northern Vermont," Atmospheric

Environment, 20, 1457-1469.

Roshid, M. and R.F. Griffiths (1993) "Ambient K, S, and Si in fine and coarse aerosols ofKuala

Lumpur, Malaysia," Journal ofAerosol Science, 24, 597-60 I.

Stohl, A. (1998) "Computation, Accuracy and Applications of Trajectories - A Review and

Bibliography," Atmospheric Environment, 32, 947-966.

Watson, John G., John A. Cooper, and James J. Huntzicker (1984) 'The Effective Variance

Weighting for Least Squares Calculations Applied to the Mass Balance Receptor Model,"

Atmospheric Environment, 18, 1347-1355.

Watson, John G., Judith C. Chow and Eric M. Fujita (2001) "Review of volatile organic

. compound source apportionment by chemical mass balance" Atmospheric Environment,

35, 1567-1584.

White, Warren H. (1999) "Phantom Spatial Factors: An Example," J. ofthe Air & Waste

Management Assoc., 49,345-349.

72
Xie, Yu-Long, Philip K. Hopke, Pentti Paatero, Leonard A. Barrie, and Shao-Meng Li (1999)

"Identification of Source Nature and Seasonal Variations of Arctic Aerosol by Positive

Matrix Factorization," J. a/the Atmospheric Sciences, 56, 249-260.

73
74
Table 5. Observational Modeling Techniques

Analvses of Back Traiectories

Criteria Residence Time & Conditional Concentration Cluster lilt No Hit Trajectory Mass Balance

Source Contribution rrohahilil)' Statistics by Air Mass Analysis

Function lIistory (Mean, Mu,

Median)

Quantitative Source Attribution? No No No No No V"

Number ofsources thm cnn be distinguisl1ed? Typically only about \!(aximum of 10 15 I/grid cell, typically 2·15 I 20-30 max

10 or fewer transpoTl 50x50 (2500), though

pmlerns arc usually only aboul 5-20

dislinguishilble Inmsport pattems are

distin 'uishable

Averaging Time of Result? Weeks to yenrs Weeks to years Weeks 10 years Weeks to years Daily, Months to years

possibly

hourly

Previous use aI Class I Areas? (See Text for References) Yes V" V" V" V" V"

M,Hwitude ofimoacls? No No Yes No No V"

Frequenc of imoacts? Yes No No V" V., V"

Duration ofim aCls? V" No No V., Ves Ves

Time of Day ofimpacts? Depends on particle Depends on particle Depends on particle Depends on Ves Depends on panicle data

data data data particle data

Time of Year ofimoacts? Yes Ves V., Yes Ves Ves

Appropriate for what source-receptor distances? Regional Scale Regional Scale Regional Scale Regional Scale Regional Regional Scale

Scale

Anribution ofSecondarv Snecies? Yes Yes Yes Yes Ves Ves

Cost to run? Minimal Minimal Minimal Minimal Minimal Minimal

Code Available? No No No No No No

Equations and/or algorithms availl'lble? V" Yes Yes Ves None needed V"

Comouter Hardware Needed PC PC PC PC PC PC

Additional software necessary? Any programming Any programming Any programming Any Graphing or Any programming language or

lanb'lJage or statistical language or language or statistical programming mapping statistical package and graphics

package and graphics statistical package package and graphics language or software that and/or mapping sol\ware that

and/or mapping and gr"phics andior and/or mapping statistical allows allows overlay of data on a map

software that allows mapping software softwnre that allows package and overlay of

overlay of datn on a {hat allows overlay overlay of data on a graphics and/or dala on a

map of data on a map mnp mapping mnp

software that

allows overlay

of dala on a mao

EPA Annroved Model? No No No No No No

75
Observational Modelinl! Techniques(continued)

Analyses of inter-species relationships Analyses of Spatial and Temporal

Patterns

Criteria CMB PMF UNMIX Factor Analvsis EOF RMAPS

Quantitative Source Attribution? Yes Yes Yes No No Yes

Number of sources that can be Usually < Usually < 7 < Number ofspecies Usually 4-8 Usually 4-8 transport

distinguished? 10 10 analvzed transport oatterns oatterns

Averaging Time afResult? Same as Same as Same as Same as Same as monitoring

monitoring monitoring monitoring data monitoring data data

data data

Previous use at Class TAreas? (See Text for Yes No? No? Yes Yes Yes

References)

Maenitude ofimnacts? Yes Yes Yes No No Yes

FreQuency ofimpacts? Yes Yes Yes Yes Yes Yes

Duration of impacts? Yes Yes Yes No Yes Yes

Time of Day of impacts? Depends on Depends on Depends on input Depends on input Depends on input Depends on input data

input data input data data data data

Time of Year of impacts? Yes Yes Yes Yes Yes Yes

Appropriate for what source-receptor Urban to Urban to Urban to regional Urban to regional Regional Scale Regional Scale

distances? regional regional scales scales

scales scales

Attribution of Secondary Species? With With With additional Yes Yes Yes

additional additional information

information information

Cost to run? Free to $700 to Currently free to Minimal Minimal Minimal

purchase, purchase, purchase,

minimal to minimal to minimal to run,

run run $100 (student)-

1500 (full) for

MATLAB

Code Available? Yes Yes Yes No No No

Equations and/or algorithms available? Yes Yes Yes Yes Yes Yes

Computer Hardware Needed PC PC PC PC PC PC

Additional software necessary? No No MATLAB with Any statistics Any statistics Any statistics package

optimization package package with with ability to do

toolbox ability to do singular value

singular value decompositions

decompositions

EPA Model" Yes No? Yes? No No No

76
Observational Modelin2 Techniques (continued)

Analvses of Unique Tracer Data

Criteria TMBR OMR TAGIT

Ouantitative Source Attribution? Yes Yes Yes

Number ofsources that can be 1-3 1-3 IItracer

distinguished?

Averaging Time ofResult? Same as Same as particulate data

particulate data

Previous use at Class 1 Areas? (See Yes Yes Yes

Text for References)

Magnitude of impacts? Yes Yes Yes

Frequency of impacts? Yes Yes Yes

Duration ofimpacts? Yes Yes Yes

Time of Day of impacts? Depends on particulate data Depends on Depends on particulate data

particulate data

Time of Year of impacts? Yes Yes Yes

Appropriate for what source-receptor Urban to Regional Scale Urban to Regional Regional Scale

distances? Scale

Attribution of Secondary Species? Yes Yes Yes

Cost to run? Minimal Minimal Minimal

Code Available? No No No

Equations and/or algorithms Yes Yes Yes

available?

Computer Hardware Needed PC PC PC

Additional software necessary? Any programming language, Any programming Any programming language, spreadsheet,

spreadsheet, or statistical language, or statistical package

package spreadsheet, or

statistical package

EPA Model? No No No

77
Appendix A: RA BART Rule (40 CFR 51.300-306)

Sec. 51.300 Purpose and applicability.

Authority: Secs. 110, 114, 121, 160-169, 169A, and 30 I ofthe Clean Air Act, (42 U.S.c.

7410,7414,7421,7470-7479, and 7601).

Source: 45 FR 80089, Dec. 2, 1980, unless otherwise noted.

(a) Purpose. The primary purposes ofthis subpart are to require States to develop programs to

assure reasonable progress toward meeting the national goal of preventing any future, and

remedying any existing, impairment of visibility in mandatory Class I Federal areas which

impairment results from manmade air pollution; and to establish necessary additional procedures

for new source pennit applicants, States and Federal Land Managers to use in conducting the

visibility impact analysis required for new sources under Sec. 51.166. This subpart sets forth

requirements addressing visibility impairment in its two principal fonns: . 'reasonably

attributable" impairment (i.e., impairment attributable to a single source/small group ofsources)

and regional haze (i.e., widespread haze from a multitude ofsources which impairs visibility in

every direction over a large area).

(b) Applicability. (l) General Applicability. The provisions ofthis subpart pertaining to

implementation plan requirements for assuring reasonable progress in preventing any future and

remedying any existing visibility impainnent are applicable to:

(i) Each State which has a mandatory Class I Federal area identified in part 81, subpart 0, of

this title, and Each State in which there is any source the emissions from which may reasonably

be anticipated to cause or contribute to any impairment of visibility in any such area.

(ii)The provisions of this subpart pertaining to implementation plans to address reasonably

attributable visibility impairment are applicable to the following States: Alabama, Alaska,

Arizona, Arkansas, California, Colorado, Florida, Georgia, Hawaii, Idaho, Kentucky, Louisiana,

Maine, Michigan, Minnesota, Missouri, Montana, Nevada, New Hampshire, New Jersey, New

Mexico, North Carolina, North Dakota, Oklahoma, Oregon, South Carolina, South Dakota,

Tennessee, Texas, Utah, Vennont, Virginia, Virgin Islands, Washington, West Virginia,

Wyoming.

(3) The provisions ofthis subpart pertaining to implementation plans to address regional haze

visibility impairment are applicable to all States as defined in section 302(d) of the Clean Air Act

(CAA) except Guam, Puerto Rico, American Samoa, and the Northern Mariana Islands.

[45 FR 80089, Dec. 2,1980, as amended at 64 FR 35763, July I, 1999]

Sec. 51.30 I Definitions.

For purposes of this subpart:

Adverse impact on visibility means, for purposes ofsection 307, visibility impairment which

interferes with the management, protection, preservation, or enjoyment ofthe visitor's visual

experience ofthe Federal Class I area. This detennination must be made on a case-by-case basis

taking into account the geographic extent, intensity, duration, frequency and time of visibility

impairments, and how these factors correlate with (I) times of visitor use ofthe Federal Class I
area, and (2) the frequency and timing of natural conditions that reduce visibility. This tenn does

not include effects on integral vistas.

Agency means the U.S. Environmental Protection Agency.

BART-eligible source means an existing stationary facility as defined in this section. Best

Available Retrofit Technology (BART) means an emission limitation based on the degree of

reduction achievable through the application of the best system of continuous emission reduction

for each pollutant which is emitted by an existing stationary facility. The emission limitation

must be established, on a case-by-case basis, taking into consideration the technology available,

the costs of compliance, the energy and nonair quality environmental impacts of compliance, any

pollution control equipment in use or in existence at the source, the remaining useful life ofthe

source, and the degree ofimprovement in visibility which may reasonably be anticipated to

result from the use of such technology.

Building, structure, or/acility means all ofthe pollutant-emitting activities which belong to the

same industrial grouping, are located on one or more contiguous or adjacent propenies, and are

under the control of the same person (or persons under common control). Pollutant-emitting

activities must be considered as part ofthe same industrial grouping if they belong to the same

Major Group (i.e., which have the same two-digit code) as described in the Standard Industrial

Classification Manual, 1972 as amended by the 1977 Supplement (U.S. Government Printing

Office stock numbers 4101-0066 and 003-005-00176-0 respectively).

Deciview means a measurement of visibility impairment. A deciview is a haze index derived

from calculated light extinction, such that unifonn changes in haziness correspond to unifonn

incremental changes in perception across the entire range of conditions, from pristine to highly

impaired. The deciview haze index is calculated based on the following equation (for the

purposes of calculating deciview, the atmospheric light extinction coefficient must be calculated

from aerosol measurements):

Deciview haze index = 10 lllc (b",110Mm") Where be" = the atmospheric light extinction

coefficient, expressed in inverse megameters (Mm").

Existing stationary/acility means any of the following stationary sources of air pollutants,

including any reconstructed source, which was not in operation prior to August 7, 1962, and was

in existence on August 7,1977, and has the potential to emit 250 tons per year or more of any air

pollutant. In detennining potential to emit, fugitive emissions, to the extent quantifiable, must be

counted.

Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour

heat input,

Coal cleaning plants (thennal dryers),

Kraft pulp mills,

Ponland cement plants,

Primary zinc smelters,

Iron and steel mill plants,

Primary aluminum ore reduction plants,

Primary copper smelters,

Municipal incinerators capable of charging more than 250 tons of refuse per day,

Hydrofluoric, sulfuric, and nitric acid plants,

Petroleum refineries,

Lime plants,

Phosphate rock processing plants,
Coke oven batteries,

Sulfur recovery plants,

Carbon black plants (furnace process),

Primary lead smelters,

Fuel conversion plants,

Sintering plants,

Secondary metal production facilities,

Chemical process plants,

Fossil-fuel boilers of more than 250 million British thermal units per hour heat input,

Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels,

Taconite ore processing facilities,

Glass fiber processing plants, and

Charcoal production facilities.

Federal Class 1 area means any Federal land that is classified or reclassified Class I.

Federal Land Manager means the Secretary ofthe department with authority over the Federal

Class I area (or the Secretary's designee) or, with respect to Roosevelt-Campobello International

Park, the Chainnan of the Roosevelt-Campobello International Park Commission.

Federally enforceable means all limitations and conditions which are enforceable by the

Administrator under the Clean Air Act including those requirements developed pursuant to parts

60 and 61 ofthis title, requirements within any applicable State Implementation Plan, and any

pennit requirements established pursuant to Sec. 52.21 of this chapter or under regulations

approved pursuant to part 51, 52, or 60 of this title.

Fixed capi/al cost means the capital needed to provide all ofthe depreciable components.

Fugitive Emissions means those emissions which could not reasonably pass through a stack,

chimney, vent, or other functionally equivalent opening.

Geographic enhancement/or the purpose ofSec. 51.308 means a method, procedure, or

process to allow a broad regional strategy, such as an emissions trading program designed to

achieve greater reasonable progress than BART for regional haze, to accommodate BART for

reasonably attributable impainnent.

Implementation plan means, for the purposes ofthis part, any State Implementation Plan,

Federal1mplementation Plan, or Tribal1mplementation Plan.

Indian tribe or tribe means any Indian tribe, band, nation, or other organized group or

community, including any Alaska Native village, which is federally recognized as eligible for the

special programs and services provided by the United States to 1ndians because of their status as

Indians.

In exis/ence means that the owner or operator has obtained all necessary preconstruction

approvals or permits required by Federal, State, or local air pollution emissions and air quality

laws or regulations and either has (I) begun, or caused to begin, a continuous program of

physical on-site construction of the facility or (2) entered into binding agreements or contractual

obligations, which cannot be cancelled or modified without substantial loss to the owner or

operator, to undertake a program of construction ofthe facility to be completed in a reasonable

time.

In operation means engaged in activity related to the primary design function of the source.

Ins/alia/ion means an identifiable piece of process equipment.
Integral vista means a view perceived from within the mandatory Class I federal area ofa

specific landmark or panorama located outside the boundary ofthe mandatory Class I federal

arya.

Least impaired days means the average visibility impairment (measured in deciviews) for the

twenty percent of monitored days in a calendar year with the lowest amount of visibility

impairment.

Major stationary source and major modification mean major stationary source and major

modification, respectively, as defined in Sec. 51.166.

Mandatory Class I Federal Area means any area identified in part 81, subpart D ofthis title.

Most impaired days means the average visibility impairment (measured in deciviews) for the

twenty percent of monitored days in a calendar year with the highest amount of visibility

impairment.

Natural conditions includes naturally occurring phenomena that reduce visibility as measured

in terms of light extinction, visual range, contrast, or coloration.

Potential to emit means the maximum capacity of a stationary source to emit a pollutant under

its physical and operational design. Any physical or operational limitation on the capacity of the

source to emit a pollutant including air pollution control equipment and restrictions on hours of

operation or on the type or amount of material combusted, stored, or processed, shall be treated

as part ofits design if the limitation or the effect it would have on emissions is federally

enforceable.

Secondary emissions do not count in determining the potential to emit of a stationary source.

Reasonably allributable means attributable by visual observation or any other technique the

State deems appropriate. Reasonably attributable visibility impairment means visibility

impairment that is caused by the emission of air pollutants from one, or a small number of

sources.

Reconstruction will be presumed to have taken place where the fixed capital cost ofthe new

component exceeds 50 percent ofthe fixed capital cost of a comparable entirely new source. Any

final decision as to whether reconstruction has occurred must be made in accordance with the

provisions of Sec. 60.15 (I) (I) through (3) of this title.

Regional haze means visibility impairment that is caused by the emission of air pollutants from

numerous sources located over a wide geographic area. Such sources include, but are not limited

to, major and minor stationary sources, mobile sources, and area sources.

Secondary emissions means emissions which occur as a result ofthe construction or operation

of an existing stationary facility but do not come from the existing stationary facility. Secondary

emissions may include, but are not limited to, emissions from ships or trains coming to or from

the existing stationary facility.

Significant impairment means, for purposes of Sec. 51.303, visibility impairment which, in the

judgment ofthe Administrator, interferes with the management, protection, preservation, or

enjoyment ofthe visitor's visual experience ofthe mandatory Class 1federal area. This

determination must be made on a case-by-case basis taking into account the geographic extent,

intensity, duration, frequency and time ofthe visibility impairment, and how these factors

correlate with (I) times of visitor use ofthe mandatory Class I federal area, and (2) the

frequency and timing of natural conditions that reduce visibility.

State means "State" as defined in section 302(d) ofthe CAA.

Stationary Source means any building, structure, facility, or installation which emits or may

emit any air pollutant.
Visibility impairment means any humanly perceptible change in visibility (light extinction,

visual range, contrast, coloration) from that which would have existed under natural conditions.

Visibility in any mandatory Class 1 Federal area includes any integral vista associated with

that area.

[45 FR 80089, Dec. 2, 1980, as amended at 64 FR 35763, 35774, July I, 1999]

Sec. 51.302 Implementation control strategies for reasonably attributable visibility impairment.

(a) Plan Revision Procedures. (I) Each State identified in Sec. 51.300(b)(2) must have

submitted, not later than September 2, 1981, an implementation plan meeting the requirements of

this subpart pertaining to reasonably attributable visibility impainnent.

(2)(i) The State, prior to adoption of any implementation plan to address reasonably

attributable visibility impainnent required by this subpart, must conduct one or more public

hearings on such plan in accordance with Sec. 51.102.

(ii) In addition to the requirements in Sec. 51.102, the State must provide written notification

ofsuch hearings to each affected Federal Land Manager, and other affected States, and must

state where the public can inspect a summary prepared by the Federal Land Managers of their

conclusions and reconunendations, ifany, on the proposed plan revision.

(3) Submission of plans as required by this subpart must be conducted in accordance with the

procedures in Sec. 51.103.

(b) State and Federal Land Manager Coordination. (I) The State must identify to the Federal

Land Managers, in writing and within 30 days ofthe date of promulgation of these regulations,

the title of the official to which the Federal Land Manager of any mandatory Class I Federal area

can submit a recommendation on the implementation of this subpart including, but not limited to:

(i) A list ofintegral vistas that are to be listed by the State for the purpose of implementing

section 304,

(ii) Identification ofimpairment of visibility in any mandatory Class I Federal area(s), and

(iii) Identification of elements for inclusion in the visibility monitoring strategy required by

section 305.

(2) The State must provide opportunity for consultation, in person and at least 60 days prior to

holding any public hearing on the plan, with the Federal Land Manager on the proposed SIP

revision required by this subpart. This consultation must include the opportunity for the affected

Federal Land Managers to discuss their:

(i) Assessment ofimpainnent of visibility in any mandatory Class I Federal area, and

(ii) Recommendations on the development of the long-term strategy.

(3) The plan must provide procedures for continuing consultation between the State and

Federal Land Manager on the implementation of the visibility protection program required by

this subpart.

(c) General plan requirements for reasonably attributable visibility impairment. (l) The

affected Federal Land Manager may certify to the State, at any time, that there exists reasonably

attributable impairment of visibility in any mandatory Class I Federal area.

(2) The plan must contain the following to address reasonably attributable impairment:

(i) A long-tenn (10-15 years) strategy, as specified in Sec. 51.305 and Sec. 51.306, including

such emission limitations, schedules of compliance, and such other measures including schedules
for the implementation ofthe elements of the long-tenn strategy as may be necessary to make

reasonable progress toward the national goal specified in Sec. 51.300(a).

(ii) An assessment of visibility impairment and a discussion of how each element ofthe plan

relates to the preventing offuture or remedying of existing impainnent of visibility in any

mandatory Class I Federal area within the State.

(iii) Emission limitations representing BART and schedules for compliance with BART for

each existing stationary facility identified according to paragraph (c)(4) ofthis section.

(3) The plan must require each source to maintain control equipment required by this subpart

and establish procedures to ensure such control equipment is properly operated and maintained.

(4) For any existing reasonably attributable visibility impairment the Federal Land Manager

certifies to the State under paragraph (c)( I) ofthis section, at least 6 months prior to plan

submission or revision:

(i) The State must identify and analyze for BART each existing stationary facility which may

reasonably be anticipated to cause or contribute to impairment of visibility in any mandatory

Class I Federal area where the impairment in the mandatory Class I Federal area is reasonably

attributable to that existing stationary facility. The State need not consider any integral vista the

Federal Land Manager did not identify pursuant to Sec. 51.304(b) at least 6 months before plan

submission.

(ii) If the State determines that technologicial or economic limitations on the applicability of

measurement methodology to a particular existing stationary facility would make the imposition

of an emission standard infeasible it may instead prescribe a design, equipment, work practice, or

other operational standard, or combination thereof, to require the application ofBART. Such

standard, to the degree possible, is to set forth the emission reduction to be achieved by

implementation ofsuch design, equipment, work practice or operation, and must provide for

compliance by means which achieve equivalent results.

(iii) BART must be determined for fossil-fuel fired generating plants having a total generating

capacity in excess of750 megawatts pursuant to "Guidelines for Determining Best Available

Retrofit Technology for Coal-fired Power Plants and Other Existing Stationary Facilities"

(1980), which is incorporated by reference, exclusive of appendix E, which was published in the

Federal Register on February 6,1980 (45 FR 8210). It is EPA publication No. 450/3-80-009b

and is for sale from the U.S. Department ofCommerce, National Technicallnfonnation Service,

5285 Port Royal Road, Springfield, Virginia 2216 I. It is also available for inspection at the

Office of the Federal Register Infonnation Center, 800 N0I1h Capitol NW., suite 700,

Washington, DC.

(iv) The plan must require that each existing stationary facility required to install and operate

BART do so as expeditiously as practicable but in no case later than five years after plan

approval.

(v) The plan must provide for a BART analysis of any existing stationary facility that might

cause or contribute to impainnent of visibility in any mandatory Class I Federal area identified

under this paragraph (c)(4) at such times, as detennined by the Administrator, as new technology

for control of the pollutant becomes reasonably available if:

(A) The pollutant is emitted by that existing stationary facility,

(B) Controls representing BART for the pollutant have not previously been required under this

subpart, and

(C) The impainnent of visibility in any mandatory Class I Federal area is reasonably

attributable to the emissions of that pollutant.
[45 FR 80089, Dec. 2,1980, as amended at 57 FR40042, Sept. 1, 1992; 64

FR 35764, 35774, July I, 1999]

Sec. 51.303 Exemptions from control.

(a)(l) Any existing stationary facility subject to the requirement under Sec. 51.302 to install,

operate, and maintain BART may apply to the Administrator for an exemption from that

requirement.

(2) An application under this section must include all available documentation relevant to the

impact of the source's emissions on

visibility in any mandatory Class I Federal area and a demonstration by the existing stationary

facility that it does not or will not, by itself or in combination with other sources, emit any air

pollutant which may be reasonably anticipated to cause or contribute to a significant impairment

of visibility in any mandatory Class I Federal area.

(b) Any fossil-fuel fired power plant with a total generating capacity of750 megawatts or

more may receive an exemption from BART only if the owner or operator ofsuch power plant

demonstrates to the satisfaction of the Administrator that such power plant is located at such a

distance from all mandatory Class I Federal areas that such power plant does not or will not, by

itself or in combination with other sources, emit any air pollutant which may reasonably be

anticipated to cause or contribute to significant impainnent of visibility in any such mandatory

Class I Federal area.

(c) Application under this Sec. 51.303 must be accompanied by a written concurrence from the

State with regulatory authority over the source.

(d) The existing stationary facility must give prior written notice to all affected Federal Land

Managers ofany application for exemption under this Sec. 51.303.

(e) The Federal Land Manager may provide an initial recommendation or comment on the

disposition ofsuch application. Such recommendation, where provided, must be part ofthe

exemption application. This recommendation is not to be constll.led as the concurrence required

under paragraph (h) of this section.

(I) The Administrator, within 90 days of receipt of an application for exemption from control,

will provide notice of receipt of an exemption application and notice of opportunity for public

hearing on the application.

(g) After notice and opportunity for public hearing, the Administrator may grant or deny the

exemption. For purposes ofjudicial review, final EPA action on an application for an exemption

under this Sec. 51.303 will not occur until EPA approves or disapproves the State

Implementation Plan revision.

(h) An exemption granted by the Administrator under this Sec. 51.303 will be effective only

upon concurrence by all affected Federal Land Managers with the Administrator's determination.

[45 FR 80089, Dec. 2,1980, as amended by 64 FR 35774, July 1,1999]

Sec. 51.304 Identification ofintegral vistas.

(a) On or before December 31, 1985 the Federal Land Manager may identify any integral

vista. The integral vista must be identified according to criteria the Federal Land Manager
develops. These criteria must include, but are not limited to, whether the integral vistl is

important to the visitor's visual experience ofthe mandatory Class I Federal area. Adoption of

criteria must be preceded by reasonable notice and opportunity for public comment on the

proposed criteria.

(b) The Federal Land Manager must notify the State of any integral vistas identified under

paragraph (a) ofthis section, and the reasons therefor.

(c) The State must list in its implementation plan any integral vista the Federal Land Manager

identifies at least six months prior to plan submission, and must list in its implementation plan at

its earliest opportunity, and in no case later than at the time ofthe periodic review ofthe SIP

required by Sec. 51.306(c), any integral vista the Federal Land Manager identifies after that time.

(d) The State need not in its implementation plan list any integral vista the identification of

which was not made in accordance with the criteria in paragraph (a) ofthis section. In making

this finding, the State must carefully consider the expertise ofthe Federal Land Manager in

making the judgments called for by the criteria for identification. Where the State and the

Federal Land Manager disagree on the identification of any integral vista, the State must give the

Federal Land Manager an opportunity to consult with the Governor of the State.

[45 FR 80089, Dec. 2, 1980, as amended by 64 FR 35774, July I, 1999]

Sec. 51.305 Monitoring for reasonably attributable visibility impairment.

(a) For the purposes of addressing reasonably attributable visibility impairment, each State

contlining a mandatory Class I Federal area must include in the plan a strategy for evaluating

reasonably attributable visibility impairment in any mandatory Class I Federal area by visual

observation or other appropriate monitoring techniques. Such strategy must take into account

current and anticipated visibility monitoring research, the availability of appropriate monitoring

techniques, and such guidance as is provided by the Agency.

(b) The plan must provide for the consideration of available visibility data and must provide a

mechanism for its use in decisions required by this subpart.

[45 FR 80089, Dec. 2,1980, as amended at 64 FR 35764, July I, 1999]

Sec. 51.306 Long-tenn strategy requirements for reasonably attributable visibility impainnent.

(a)(I) For the purposes of addressing reasonably attributable visibility impainnent, each plan

must include a long-tenn (10-15 years) strategy for making reasonable progress toward the

national goal specified in Sec. 51.300(a). This strategy must cover any existing impairment the

Federal Land Manager certifies to the State at least 6 months prior to plan submission, and any

integral vista ofwhich the Federal Land Manager notifies the State at least 6 months prior to plan

submission.

(2) A long-term strategy must be developed for each mandatory Class I Federal area located

within the State and each mandatory Class I Federal area located outside the State which may be

affected by sources within the State. This does not preclude the development of a single

comprehensive plan for all such areas.
(3) The plan must set forth with reasonable specificity why the long-tenn strategy is adequate

for making reasonable progress toward the national visibility goal, including remedying existing

and preventing future impainnent.

(b) The State must coordinate its long-tenn strategy for an area with existing plans and goals,

including those provided by the affected Federal Land Managers, that may affect impainnent of

visibility in any mandatory Class I Federal area.

(c) The plan must provide for periodic review and revision, as appropriate, of the long-tenn

strategy for addressing reasonably attributable visibility impainnent. The plan must provide for

such periodic review and revision not less frequently than every 3 years until the date of

submission ofthe State's first plan addressing regional haze visibility impainnent in accordance

with Sec. 51.308(b) and (c). On or before this date, the State must revise its plan to provide for

review and revision of a coordinated long-tenn strategy for addressing reasonably attributable

and regional haze visibility impairment, and the State must submit the first such coordinated

long-tenn strategy. Future coordinated long-tenn strategies must be submitted consistent with the

schedule for periodic progress reports set forth in Sec. 51.308(g). Until the State revises its plan

to meet this requirement, the State must continue to comply with existing requirements for plan

review and revision, and with all emission management requirements in the plan to address

reasonably attributable impainnent. This requirement does not affect any preexisting deadlines

for State submittal of a long-tenn strategy review (or element thereof) between August 30, 1999,

and the date required for submission ofthe State's first regional haze plan. In addition, the plan

must provide for review ofthe long-term strategy as it applies to reasonably attributable

impairment, and revision as appropriate, within 3 years of State receipt of any certification of

reasonably attributable impairment from a Federal Land Manager. The review process must

include consultation with the appropriate Federal Land Managers, and the State must provide a

report to the public and the Administrator on progress toward the national goal. This report must

include an assessment of:

(I) The progress achieved in remedying existing impairment of visibility in any mandatory

Class I Federal area;

(2) The ability ofthe long-tenn strategy to prevent future impainnent of visibility in any

mandatory Class I Federal area;

(3) Any change in visibility since the last such report, or, in the case ofthe first report, since

plan approval;

(4) Additional measures, including the need for SIP revisions, that may be necessary to assure

reasonable progress toward the national visibility goal;

(5) The progress achieved in implementing BART and meeting other schedules set forth in the

long-term strategy;

(6) The impact of any exemption granted under Sec. 51.303;

(7) The need for BART to remedy existing visibility impairment of any integral vista listed in

the plan since the last such report, or, in the case of the first report, since plan approval.

(d) The long-tenn strategy must provide for review ofthe impacts from any new major

stationary source or major modifications on visibility in any mandatory Class I Federal area. This

review of major stationary sources or major modifications must be in accordance with Sec.

51.307, Sec. 51.166, Sec. 51.J60, and any other binding guidance provided by the Agency

insofar as these provisions pertain to protection of visibility in any mandatory Class I Federal

areas.
(e) The State must consider, at a minimum, the following factors during the development ofits

long-tenn strategy:

(1) Emission reductions due to ongoing air pollution control programs,

(2) Additional emission limitations and schedules for compliance,

(3) Measures to mitigate the impacts of construction activities,

(4) Source retirement and replacement schedules,

(5) Smoke management techniques for agricultural and forestry management purposes

including such plans as currently exist within the State for these purposes, and

(6) Enforceability of emission limitations and control measures.

(I) The plan must discuss the reasons why the above and other reasonable measures considered

in the development ofthe long-term strategy were or were not adopted as part ofthe long-term

strategy.

(g) The State, in developing the long-term strategy, must take into account the effect of new

sources, and the costs of compliance, the time necessary for compliance, the energy and nonair

quality environmental impacts of compliance, and the remaining useful life of any affected

existing source and equipment therein.

[45 FR 80089, Dec. 2,1980, as amended at 64 FR 35764, 35774, July 1, 1999]
Appendix Q-O

EPA Completeness Criteria for the Regional Haze SIP

Appendix V to Part 51 --

Criteria for Determining the Completeness of Plan Submissions

1.0. Purpose

This appendix V sets forth the minimum criteria for determining whether a State

implementation plan submitted for consideration by EPA is an official submission for

purposes of review under § 51.103.

1.1 The EPA shall return to the submitting official any plan or revision thereof which fails to

meet the criteria set forth in this appendix V, and request corrective action, identifying the

component(s) absent or insufficient to perform a review of the submitted plan.

1.2 The EPA shall inform the sUbmitting official whether or not a plan submission meets the

requirements of this appendix V within 60 days of EPA's receipt of the submittal, but no later

than 6 months after the date by which the State was required to submit the plan or revision. If

a completeness determination is not made by 6 months from receipt of a submittal, the

submittal shall be deemed complete by operation of law on the date 6 months from receipt. A

determination of completeness under this paragraph means that the submission is an official

submission for purposes of § 51.103.

2.0. Criteria

The following shall be included in plan submissions for review by EPA:

2.1. Administrative Materials

(a) A formal letier of submittal from the Governor or his designee, requesting EPA approval

of the plan or revision thereof (hereafter "the plan").

(b) Evidence that the State has adopted the plan in the State code or body of regulations; or

issued the permit, order, consent agreement (hereafter "document") in final form. That

evidence shall include the date of adoption or final issuance as well as the effective date of

the plan, if different from the adoption/issuance date.

(c) Evidence that the State has the necessary legal authority under State law to adopt and

implement the plan.

(d) A copy of the actual regulation, or document submitted for approval and incorporation by

reference into the plan, including indication of the changes made to the existing approved

plan, where applicable. The submittal shall be a copy of the official State regulation

/document signed, stamped, dated by the appropriate State official indicating that it is fully

enforceable by the State. The effective date of the regulation/document shall, whenever

possible, be indicated in the document itself.

(e) Evidence that the State followed all of the procedural requirements of the State's laws

and constitution in conducting and completing the adoption/issuance of the plan.

(f) Evidence that public notice was given of the proposed change consistent with procedures

approved by EPA, including the date of publication of such notice.

Appendix 0-0, Page 1
(g) Certification that public hearings(s) were held in accordance with the information provided

in the public notice and the State's laws and constitution, if applicable.

(h) Compilation of public comments and the State's response thereto.

2.2. Technical Support

(a) Identification of all regulated pollutants affected by the plan.

(b) Identification of the locations of affected sources including the EPA

attainmentlnonattainment designation of the locations and the status of the attainment plan

for the affected areas(s).

(c) Quantification of the changes in plan allowable emissions from the affected sources;

estimates of changes in current actual emissions from affected sources or, where

appropriate, quantification of changes in actual emissions from affected sources through

calculations of the differences between certain baseline levels and allowable emissions

anticipated as a result of the revision.

(d) The State's demonstration that the national ambient air quality standards, prevention of

significant deterioration increments, reasonable further progress demonstration, and visibility,

as applicable, are protected if the plan is approved and implemented. For all requests to

redesignate an area to attainment for a national primary ambient air quality standard, under

section 107 of the Act, a revision must be submitted to provide for the maintenance of the

national primary ambient air quality standards for at least 10 years as required by section

175A of the Act.

(e) Modeling information required to support the proposed reVISion, inclUding input data,

output data, models used, justification of model selections, ambient monitoring data used,

meteorological data used, justification for use of offsite data (where used), modes of models

used, assumptions, and other information relevant to the determination of adequacy of the

modeling analysis.

(f) Evidence, where necessary, that emission limitations are based on continuous emission

reduction technology.

(g) Evidence that the plan contains emission limitations, work practice standards and

recordkeeping/reporting requirements, where necessary, to ensure emission levels.

(h) Compliance/enforcement strategies, including how compliance will be determined in

practice.

(i) Special economic and technological justifications required by any applicable EPA policies,

or an explanation of why such justifications are not necessary.

2.3. Exceptions

2.3.1. The EPA, for the purposes of expediting the review of the plan, has adopted a

procedure referred to as "parallel processing." Parallel processing allows a State to submit

the plan prior to actual adoption by the State and provides an opportunity for the State to

Appendix Q-O, Page 2
consider EPA comments prior to submission of a final plan for final review and action. Under

these circumstances, the plan submitted will not be able to meet all of the requirements of

paragraph 2.1 (all requirements of paragraph 2.2 will apply). As a result, the following

exceptions apply to plans submitted explicitly for parallel processing:

(a) The letter required by paragraph 2.1(a) shall request that EPA propose approval of the

proposed plan by parallel processing.

(b) In lieu of paragraph 2.1(b) the State shall submit a schedule for final adoption or issuance

of the plan.

(c) In lieu of paragraph 2.1(d) the plan shall include a copy of the proposed/draft regulation or

document, including indication of the proposed changes to be made to the existing approved

plan, where applicable.

(d) The requirements of paragraphs 2.1(e)-2.1(h) shall not apply to plans submitted for

parallel processing.

2.3.2. The exceptions granted in paragraph 2.3.1 shall apply only to EPA's determination of

proposed action and all requirements of paragraph 2.1 shall be met prior to publication of

EPA's final determination of plan approvability.

[55 FR 5830, Feb. 16, 1990, as amended at 56 FR 42219, Aug. 26,1991; 56 FR 57288, Nov.

8,1991]

Appendix 0-0, Page 3
Appendix R-O

References (from the 8-27-'03 TSD document)

Air Sciences, Inc. 2002a: "1996 Fire Emission Inventory", prepared for the Emissions Task

Team of the WRAP Fire Emissions Joint Forum, March 2002.

Air Sciences, Inc. 2002b: "Integrated Assessment Update and 2018 Emissions Inventory for

Prescribed Fire, Wildfire, and Agricultural Burning", prepared for the Emissions Task Team of

the WRAP Fire Emissions Joint Forum, March 2002.

Carter, W. P. L., 1999: "Documentation of the SAPRC-99 Chemical Mechanism for VOC

Reactivity Assessment", Draft report to the Califomia Air Resources Board, Contracts 92-329

and 95-308, 9/13/99.

Dennis R.L., Byun D.W., Novak J.H., Galluppi K.J., Coats C.J. and Vouk M.A., 1996: "The

next generation of integrated air quality modeling: EPA's Models-3", Atmos. Environ., 30,

1925-1938.

DOE, 2000: U.S. Department of Energy, "Annual Energy Outlook 2001, with Projections

through 2020", DOE/EIA-0383 (2001), Energy Information Administration, Office of

Integrated Analysis and Forecasting, Washington, DC, December 2000.

EA Engineering, Science, and Technology, 2003: "Needs Assessment for Evaluation and

Design of an Emissions Data Reporting, Management, and Tracking System", draft report to

the Emissions Forum, June 26.

EPA, 1997: "Guidance for Demonstrating Attainment of Air Quality Goals for PM25 and

Regional Haze." Draft 1.1. March 27.

EPA, 1999: "Science Algorithms of the EPA Models-3 Community Multiscale Air Quality

(CMAQ) Modeling System" (eds. Byun, D., and Ching, J.), EPA Tech. Rep. EPA-600/R99/030. Available from EPA/ORD, Washington, D. C., 20460.

EPA, 2001: U.S. Environmental Protection Agency, "Procedures Document for National

Emission Inventory Criteria Air. Pollutants, 1985-1999," EPA-454/R-01- 006, Office of Air

Quality Planning and Standards, Research Triangle Park, NC.

EPA, 2001: "Draft Guidance for Tracking Progress Under the Regional Haze Rule." Office of

Air Quality Planning and Standards, Research Triangle Park, NC. September 27.

EPA, 2001: "Draft Guidance for Estimating Natural Visibility Conditions Under the Regional

Haze Rule." Office of Air Quality Planning and Standards, Research Triangle Park, NC.

September 27.

Federal Register, 1999: 40 CFR Part 51. Regional Haze Regulations, Final Rule. Volume 64,

No. 126. July 1.

Gery M. W., Whitten G. Z., Killus J. P. and Dodge M. C. ,

mechanism for urban and regional-scale computer modeling".

Research 94, 12925-12956.

Appendix R-O, Page 1

1989: "A photochemical

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Grell, A. G., J. Dudhia, and D. R. Stauffer, 1994: "A description of the fifth-generation Penn

State/NCAR mesoscale model (MM5)". NCAR Tech. Note NCARITN 398+STR, National

Center for Atmospheric Research, Boulder, CO.

Houyoux, M.R., Vukovich, J. M. ; Coats, C. J., Jr. ; Wheeler, N. J. M. ; Kasibhatla, P. S.,

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to Record, provided with confidential December 2002 NONROAD2002 model release.

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Houyoux, M., et. aI., 2003. "Final Report: WRAP Regional Modeling Center - Short-Term

Modeling Analysis", UNC - Chapel Hill, Carolina Environmental Program, March 31.

ICF, 2002: ICF Consulting Group, "Economic Assessment of Implementing the 10/20 Goals

and Energy Efficiency Recommendations," prepared for the WRAP Air Pollution Prevention

Forum, October 2002.

Odum, J.R; Hoffman, T.; Bowman, F.; Collins, D.; Flagan, RC.; and Seinfeld, J.H., 1996:

"Gas/particle partitioning and secondary aerosol formation". Environ. Sci. and Technol.

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Pechan, 2001: E.H. Pechan & Associates, Inc., "Economic Growth Analysis System, Version

4.0 Reference Manual, Final Draft," prepared for U.S. Environmental Protection Agency,

Office of Air Quality Planning and Standards, Research Triangle Park, NC, January 26,2001.

Pechan, 2002: Technical Memorandum: Revisions to the 1996 WRAP Point Source

Emissions Data Base, E.H. Pechan & Associates, Inc., prepared for the WRAP Emissions

Forum, August 2002.

PES, 2001: Pacific Environmental Services, Inc., and Eastern Research Group, Inc.,

"Development of the 1996 Base Year Emission Inventory for Regional Haze Analyses,"

Research Triangle Park, NC and Sacramento, CA, prepared for WRAP Emissions Forum,

August 2001.

Pierce, T., C. Geron, L. Bender, R Dennis, G. Tonnesen, and A. Guenther, 1998: "Influence

of increased isoprene emissions on regional ozone modeling", Journal of Geophysical

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Pollack, et. aI., 2003: "Development Of WRAP Mobile Source Emission Inventories"

ENVIRON Corporation, Prepared for Western Governors' Association, in press.

SAIC. 2001. "Interpolating Relative Humidity Weighting Factors to Calculate Visibility

Impairment and the Effects of Improve Monitor Outliers." EPA No. 68-D-98-113, WA No. 3-

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1-0825-08-2566-000, Application/Utilization of GVS Techniques in Analyzing Particulate

Appendix R-O, Page 2
Matter (PM) and Regional Haze (RH) Policy and Control Issues". Letter from Richard

Gardner, Science Applications International Corporation (SAIC) to Thomas E. Rosenthal,

Integrated Policy & Strategies Group, OAQPS, AQSSD (MD-15), U.S. Environmental

Protection Agency Research Triangle Park, Nort h Carolina 27711, July 3.

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WRAP, 2003: Western Governors' Association, "Stationary Source NOx and PM Emissions in

the WRAP Region: An Initial Assessment of Emissions, Controls, and Air Quality Impacts",

Market Trading Forum draft, May 30.

Appendix R-O, Page 3