# State ofNewMexico Officeof the Governor BillRichardson Governor



### December26,2003 Mr. RichardE. Greene, RegionalAdministrator U.S. EnvironmentalProtectionAgency, RegionVI 1445 RossAvenue, Suite 1200 Dallas, TX 75202-2733 SUBJECT: REQUEST FOR APPROVAL OF REVISION TO THE STATE IMPLEMENTATIONPLAN FORAIRQUALITY DearMr. Greene, As providedby40 CFRPart51,Appendix Vand40 CFRPart51, SubpartP, I amwriting torequest approval 0 

### f the attacheddocumentation, whichwill 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 companionregulations 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 SIPrevision is applicable to Bernalillo County, NewMexico. 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 correspondingpublic hearings held on October 8, 2003 andNovember 12,2003. Thetwo 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 SIPrevision.**,,~** <..':) :' , 

### To facilitate yourreview andprocessing, the following materials are enclosed: I) SIPCompleteness Checklistspursuantto 40 CFR 51,AppendixV - -(J 7 (.") "-, )



### ..-:-..,: u, 0 r'0 '.:": 

## m c

State Capitol • Room400 • 

### SantaFe, NewMexico 87501 • 5°5-476-2200 • 

### www.govemor.state.nm.us-2-



### 2) Hearingrecords, includingtranscripts and exhibits 3) Comments received December24,2003



### 4) The final AQCB-approved SIP revision for Regional Haze, including the two companionregulations. 5) Othersupportingdocumentation Your favorable consideration ofthis request is appreciated. Ifyou have any questions, please contact Alfredo Santistevan, Director 0 

### f the Albuquerque Environmental Health Department, at (505) 768-2600. Sincerely,

Bill Richardson Governor StateofNewMexico

cc: Alfredo Santistevan, Director, AlbuquerqueEnvironmental HealthDepartment SandraEly, Chief, AirQualityBureau, New Mexico EnvironmentDepartment
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 ofAlbuquerque 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)

AppendixA-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 INM 

### 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 GeographicArea, 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 reportAnnual 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 forthe Regional Haze SIP References

# Thisdocumentcontains OTHERAPPENDICES K‐Oto R‐O.

OTHERAPPENDICES A‐OtoJ‐O
are in a separatedocument.

## WRAP POLICY

FIRE TRACKING SYSTEMS

ApPROVED BY CONSENSUS: WESTERN REGIONAL AIR PARTNERSHIP- APRIL 

### 2, 2003

ApPROVED BY CONSENSUS: FIRE**E~lISSIONS** JOINT 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 WRAPPolicy on Fire Tracking Systems (WRAP FTS Policy) has beendeveloped overa 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 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) Transport Region States may choose to incorporate the Grand Canyon Visibility Transport Commission (GCVTC) Recommendations into theirregional haze implementation plans under Section 309 ofthe Rule. It is the position ofthe 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 ofthe 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 ofthe 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 underboth 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 ofthis Policy is to assist both states and tribes with the development oftheir 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.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 ofthc 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 ofthe regulatory environment and details ofthe 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 ofthe seven essential fire tracking system components. Finally, Section 4 Appendices include: A) a glossary oftenns, 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 AirPartnership 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 ofaFire Tracking System 8 3.3.1. Essential Component I. Date ofBurn 9 3.3.2. Essential Component2. Burn Location 9 3.3.3. Essential Component 3. Area ofBurn 9 3.3.4. Essential Component4. Fuel Type 10 3.3.5. Essential Component 5. Pre-Burn Fuel Loading 10 3.3.6. Essential Component 6. Type ofBurn 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 ofa 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 orderto consistently calculate emissions and to uniformly assess impacts to regional haze: I. Date ofBurn 2. BurnLocation 3. Area ofBurn 4. fuel Type 5. Pre-Burn fuel Loading 6. Type ofBurn 7. "Anthropogenic" or "Natural" Classification C. A fire tracking system should include additional components as needed to support the development and implementation ofannual emission goals and othercontrol 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 offire tracking systems by states and tribes will be done collaboratively with state, tribal, local and federal land managementagencies, and private parties. 

### 2. Background 2.1. Clean AirAct 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).' 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 ofthe GCVTC Recommendations Regarding fire describes the need for a consistent region-wide emissions tracking systemfor prescribed fire, wildfire, and agricultural burning.2

IThe Grand Canyon Visibility Transport COlllmission (GCVTC) was composed ofthe governors ofeight 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. 2Grand Canyon Visibility Transport Commission, Recommendations for Improving Western Vistas, Report to the2.2. Western Regional AirPartnership 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 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 ofall 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 ofthe GCVTC Recommendations into Section 309 ofthe Rule, which may be used by some ofthe 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 ofemissions ofpollutants 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 ofthe 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 orthirteen western slates and thinccn western tribes. The currenl WRAP members include the Stales ofAK, AZ, CA, CO, 10, MT, ND, NM, OR, SD, UT, WA, and WYand the Tribal Nations ofPueblo orAcoma, Campo Band ofKumeyaay Indians, Conina Indian Rancheria, Hopi Tribe, Hualapai Nation or the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederaled Tribes, Pueblo ofSan Felipe, and Shoshone-Bannock Tribes of Fori Hall, Federal WRAP members are the Department oflhe Interior, the Department ofAgriculture, 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.

2An analysis tracking the change over the past 5 years in emissions ofpollutants contributing to visibility impairment from all sources and activities within the State. Emissions changes should be identified by type ofsource 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-yearperiod. 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 ofprograms 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 ofthe 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 ofreasonable 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 ofan enhanced smoke managementprogram, the establishment ofannual emission goals, and the projection offire emissions.

764 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).

32.3.2. 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 mustprovide for: A statewide inventory ofemissions ofpollutants 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 ofthe 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 IFederal areait 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 establishmentoflong-term strategies for states under Section 308. 

### 3. Annotated Policy 3.1. Introduction The WRAP FTS Policy is the result ofthe 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 worktogetherto establish common approaches for emissions inventory development and tracking. I8

15 64 FR 35767, *51.308 (d) (4) (v). 16 64 FR35767, *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.

4The intent ofthe 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 ofthe 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, ifany, 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 aproven 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 mechanismthat is predictable and flexible while meeting the requirements ofthe 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 reflecttechnical advances and policy updates. 3.2. Fire Activity Information Policy Statement A: Fire activity informationfor allfire types is needed in the WRAP region. Afire tracking system that captures this i'!tormation willform the basis of afire emissions inventory compiledannually, 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 ofthe 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 ofthe findings ofthe 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 ofthe sources ofuncertainty in the resulling emission inventory.

5analyses. 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 wiII 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 ofexemptions from regulation and/or tracking ofspecific 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 ofdata 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 ofregional planning organizations and the role ofregional 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 supportthe fire emissions inventory and modeling nceds for regional haze and ambient airquality 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 FR35720.

6Stationary 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 ofstrength, 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 

### Policyfor Categorizing Fire Emissions, and recommendations in the 

### Interim Air Quality Policy on Wildland and PrescribedFires (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 offire sources on both wildland and agricultural lands regardless ofownership, cause ofignition, orpurpose 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 airquality and contribute to regional hazeD Fire Sources were among those specifically acknowledged in the GCVTC Report as contributors to visibility impainnenton an episodic basis: All types of fire (prescribed fire and agricultural burning) must be addressed equitably as partofa visibility protection strategy.24 The use offire 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 offire use is not well known in some areas, and is the cause ofuncertainty as to the contribution ofagricultural burning sources on regional haze. Accordingly, the AAQTF's 

### Air Quality Policy on Agricultural Burning, Recommendation to the 

# u.s. Department ofAgriculture 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) ofthe 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 

### Policyfor 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 ofAir Quality Planning and SLandards, InLerim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998 (herealierreferred 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 ofAgriculture, 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 FR35748.

7TheWRAP 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 ofa state ortribe may require emissions tracking information for these fire source sectors. In addition, these sources may be quantified as area sources within populated areas in otheremissions inventory efforts by states, tribes orthe WRAP. 3.3. Essential Components ofa 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 uniformlyassess impacts to regionalhaze: 1. Date of Burn 2. BurnLocation 3. Area of Burn 4. Fuel Type 5. Pre-Burn FuelLoading 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 ofthe EPA's PrescribedBurning BackgroundDocument and Technical 1njormation Document jarPrescribedBurning BestAvailable ControlMeasures'9 and the National Wildfire Coordination Group's Smoke Management Guide for Prescribed and WildlandFire 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 ofan 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

1HWRAP Policy for Categorizing Fire Emissions, November 15,200I (hereafler referred to as "WRAP Fire Categorization Policy"), p. 24. 1<) U.S. EPA, Office ofAir 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, December200I (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).

8comparahility ofthe subsequent regional modeling analysis and analysis ofvisibility 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 ortribe may consideruseful 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 ofstates/tribes may call for excluding some fires from trackingby the establishment ofa de minimus level, based on number ofacres, tons offuel, or tons ofemissions. The spatial and temporal variability offire and the significance ofvisibility 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. DateofBum It is critical that the temporal resolution ofthe fire activity information be attributed to a specific day for each specific bum in orderto con'elate with "best" and "worst" day visibility monitoring data.J5 3.3.2. Essential Component2. Bum Location It is important that the spatial resolution ofthe fire activity be attributed to a specific location to allow for source/visibility impactrelationships to be established. 3.3.3. Essential Component 3. Area ofBurn The level ofaccuracy ofthe 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, a5111all agricultural burn (e.g., <2,500 acres at 4 Ions/acre consumption or 50 lons PMIll) within 50 kilometers upwind ofa Class Iarea could have agreater visibility impacllhan alarge wildland prescribed fire (e.g., >833 acres at 20 tons/acre consumption or250 tons PM IU) within 100 kilometers downwind ofaClass Iarea. 3S 64 FR 35734. )/l Pelerson, Janice L. 1987. Analysis and reduction ofthe errors ofpredicting prescribed bum emissions. Thesis. Seattle: University ofWashingLon. 70p.

93.3.4. Essential Component4. 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-BurnFuel Loading The pre-burn fuel loading represents the amount offuel 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 ofthe fuel load (e.g., size class infonnation), the more refined the subsequentemissions estimates will be. 3.3.6. Essential Component 6. Type ofBurn Type ofbum represents the predominant configuration ofthe 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 ofburn 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 Policyfor Categorizing Fire EmissionsH The WRAP will be analyzing daily visibility monitoring data annually for Class I areas and reporting on the causes ofhaze 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 ofvisibility from fire as well as to identifY those fire emissions thatneed 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 ofannual emission goals and othercontrolmeasures. Section 309 ofthe 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 Goalsfor Fire (WRAP AEG Policy) emphasizes the use of emission reduction techniques (ERTs) as the basis ofannual 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 ofannual emission goals

)7 WRAP Fire Categorization Policy, p. 8. "64 FR 35771,**~51.309** (6)(v).

10and 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 ofthe 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, subsequentguidance 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: 

### Afire tracking system should include a component that addresses the projection of fire emissions, which is necessary to meet the requirements ofthe RegionalHaze 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 purposes42 Additionally, Section 308 of the Rule asserts that implementation plans must provide for estimates of future projected emissions43 Therefore, a projected estimate offire emissions from all fire source sectors will serve as the basis for the projection ofvisibility 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 ofa fire tracking system may be developed in a variety ofways 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 Updateand 2018 Emissions Inventory for Prescribed Fire, Wildfire and Agricultural Burning (DRAFT), Appendix A, pp. 61-96.

11The 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 offire emissions would need to be submitted to support the periodic progress report schedule (i.e., every five years). Neither ofthese 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 SialemeniE: The developmenl offire Iracking syslems by slales andIribes will be dane collabaralively wilh slale, Iribal, local and federal landmanagemenl agencies. and privaleparlies. 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 Forclarification 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 ofthis Policy. However, this glossary is not intended to be a complete list of all terms and acronyms. 16 Class 1Areas 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 ofthe 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 ofthe Gunnison Wilderness, West Elk Wilderness, Maroon Bells Wilderness, flat Tops Wilderness, Arches National Park, Canyonlands National Park, Capital ReefNational Park, Bryce Canyon National Park, and Zion National Park. 2064 Natural Conditions Goal"

- The ultimate goal ofthe 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 Chiefofthe 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 ofthe 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 ofarea sources. Class IArea

- SeeMandatory Class IArea and Non-Mandatory Class IArea.

* Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1. # Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15,200I, Appendix A.

13Ecosystem 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 ofnatural vegetation that may be accomplishcd through the reduction ofunwanted and/or unnatural levels ofbiomass, 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 resilientcondition. 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 ofthat pollutant. These factors are usually expressed as the weight ofpollutant divided by a unit weight, volume, distance, or duration of the activity emitting the pollutant (e.g., pounds of particulate matteremitted per ton ofbiomass burned). Emissions Forum

- The Emissions Forum is responsible for the oversight ofthe assembly and quality assurance ofthe 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, ofthe amount ofair pollutants discharged into the atmosphere. Federal Class I area - SeeMandatory 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 AirPartnership 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) ofthe Clean Air Act and composed ofthe governors ofeight 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 L 996.

# 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.

14Land 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 AmbientAirQuality Standards. Natural Emissions Source Classification ("natural")" - A categorization that designates which fire emissions can result in a natural reduction ofvisibility 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 ofwildlife 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 ofJanuary 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 ofintroduced or domesticated native forage species that are used primarily for the production oflivestock. They receive periodic renovation and/orcultural 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 ofpollution that is point-like in nature. An example is the smokestack of a coal-fired powerplantor 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 15,200I, Appendix A. ## Glossary Definition from WRAP Policy on Annual Emission Goals for Fire, Appendix A.

15Rangeland"

- 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 ofecological 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 betterunderstand 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 ofregional strategies to reduce emissions ofparticulate 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 ofthe Southeast (VISTAS), and Western Regional AirPartnership (WRAP) for the western states. Rule

- Regional Haze Rule. Regulations published in the Federal Registeron July I, 1999 (64 FR 35714) that require states to establish goals for improving visibility and to develop longterm strategies for reducing emissions ofpollutants that cause visibility impaimlent. SilvicuIture'

- The theory and practice of controlling forest establishment, composition, and growth. The art ofproducing 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 theirresponsibilities under the Clean Air Act. TIPs must be approved by the U.S. Envirorunental Protection Agency and include public review. Transport Region State

- One ofnine 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 15,200I, Appendix A. 

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

16Wildfire 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 regardingFederal 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 ofthe FEJF work. Wildland Fire'

-All types offire (sec definition offire 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 ofAlaska, 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 ofcommittees and forums, composed ofWRAP members and stakeholders who represent a wide range of social, cultural, economic, geographic and technical viewpoints. The WRAP membership is comprised ofthe governors ofthirteen western states and thirteen western tribes. The current WRAP members include the States ofAK, AZ, CA, CO, 10, MT, NO, NM, OR, SO, UT, WA, and WYand the Tribal Nations of Pueblo ofAcoma, Campo Band ofKumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation ofthe Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo ofSan Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the Department of the Interior, the DepartmentofAgriculture, and the Environmental Protection Agency.

#Opemting Definitions from WRAP Policy for Categorizing Fire Emissions, November 15.2001, 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/visibiIitv)

- .Agricultural AirQualityTaskForce 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/t1Ifr 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 JointForum Charge, July 29, 1998 (http://www.wrapair.org/forums/fejf/index.html) Go to the FEJF Charge link Workplan, WRAP

- Fire Emissions JointForum, 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, 200I (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 AirPartnership, 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.govI cgi

-binlciaI'itgwO 0 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, December2001. (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,AnAssessment ofTribalAir Quality Data andPrograms in the Western UnitedStates, September200I (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 ofthe 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 systemessential components. 1.1. Essential Component 1. Date ofBurn Forthe purposes ofthe fire tracking system, the date ofbum 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 activityon each given day. 1.2. Essential Component2. Burn Location Foreach bum, the location should be provided to the nearestmile. 1.3. Essential Component 3. Area ofBurn 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 numberofpiles consumed. 1.4. Essential Component 4. Fuel Type The appropriate emissions factor choice can become complicated when the fire consumes multiple fuel orcovertypes (e.g., grass and sage). Therefore, for the purposes ofthe fire tracking system, the fuel type would optimally represent the predominant fuel orcover type consumed in the fire. Ifadditional 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 Component5. Pre-burn Fuel Loading The pre-bum fuel loading should be expressed as thc weight offuel perunit area in tons peracre. The consumption ofthe fuel will be calculated as part ofthe WRAP emissions inventory system in orderto reduce the propagation offield estimation errors. 1.6. Essential Component 6. Type ofBurn Type ofbum represents the predominant configuration ofthe fuel burned (e.g., pile, windrow, broadcast, underburn). Ifavailable, identification ofpile type (i.e., hand-piled or machine-piled) will enhance the quality ofthe subsequent emissions calculation. Detellllining the Type ofBurn

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 ofburn should have an areaburned and fuel type to allow for subsequentemissions calculations. I.

### 7. Essential Component 7. "Anthropogenic" or "Natural" Classification The "anthropogenic" or "natural" classification applies as it is defined by the WRAP Policyfor Categorizing Fire Emissions, 

### which was developed to clarifY the complex relationship between what is considered a natural source offire and what is considered a human-caused source, as acknowledged in the Rule48 

### The appropliate classification is typically determined prior to the initiation ofthe fire.49 

### 2. Optional Components To support the integration ofthe 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 oftheir 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 

### ofthe 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 ManagementProgramsfor 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 managementprograms 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 ofdaily 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).

212.2. 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 offuel 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 ofthe fuel consumed, but have often been neglected in biomass burning inventories. Infonnation that specifies the quantity (i.e., percentage) ofthe pre-burn fuel load consumed by the fire will enhance the accuracy ofthe 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 ofthe pre-burn fuel load is consumed, resulting in higherthan 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. Ocularestimates are an option, but are notpreferred due to field variability. 2.3 Non-Burning Alternatives Consistent with the WRAP Policy on Annual Emission GoalsjiJr 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 offire 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.

22Additional 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 ofbum, c) plume rise, and d) bum identification code. 

### , 3. Data Collection Methods The ability ofa 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 ofexemptions from regulation, and/or new tracking ofspecific 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 offires. Primary activity data may be collected by the manager responsible for fire operations and forwarded to a data collection point, or an agent ofthe permitting or regulating authority may collect the data. Data might be collected for each operation, or a statistical sample gathered from each category offire, as defined by unique combinations ofessential 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 laterdate. 3.1. DirectData 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 perimeterarea, and aqualitative description offuels at the pointofignition. 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 ofa consistent emissions inventory. AIthough current land management agency data collection efforts do not consistently track all ofthe essential components identified herein, the feasibility ofmodifying the current tracking system to maximize economic efficiency and meet the needs ofboth 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 ofwildland and prescribed fires in the WRAP region.

5J EPA Interim Policy, p. 29.

233.2. Indirect Estimation Direct data collection methods have historically been the primmy means ofdata collection for fire tracking systems. However, emerging technologies may potentially allow for some ofthe fire tracking system essential component information to be addressed via indirect estimation techniques. Indirect estimation techniques have varying degrees ofcomplexity 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 offuel 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 lesservalue than that for the smoldering phase. Emission factors allow the calculation of emissions in pounds of pollutant, ifvegetation type and loading is known. Emissions are determined for a particular vegetation orfuel 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 perton 

### =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 1Forest 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 perton 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 220.4 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 ofAgriculture, 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 4Emission factor

- the mass of particulate matter produced per unit mass of fuel consumed (pounds perton, 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 watervapor, 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 forVisibility 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 ofwildland 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 5K.1. Broadcast Burns Procedures for use of the photo series to determine gross woody fuel (there are currently no photo series specificallyjust 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 diametersize 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 orfuel characteristic as needed. 5. The total gross woody fuel loading can then be calculated by summing the estimates. 6. Ifthe 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 forthe 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 ofthe plant.

Appendix L-G, Page 6b. 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 ofthe sample after it was just clipped. c. Recommended drying procedures: i. Dry sample within 24 hours ofclipping 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 ofthe 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 ofthe 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 ofthe piled volume on the unit. K.4. Definitions Biomass
- the amount of living matter (as in a unit area orvolume 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 ofatmospheric 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 7Fuel Size Class - a category used to describe the diameterofdown dead woody fuels. Fuels within the same size class are assumed to have similarwelting 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 ofany 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 conifertype, 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 forquantifying natural residues in common vegetation types of the Pacific Northwest. USDA Forest Service General
AppendiX L-O, Page 8Technical 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 ofthe 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 9K,§.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 ofvegetation, 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.pdf20 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 RegionalAir 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 ofthe Fire Emissions Joint Forum

# WRAP Policy on Enhanced Smoke ManagementPrograms for Visibility Executive Summary

The Western Regional AirPartnership (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 managemcntoffire 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 implementationplans underSection 309 ofthe Rule. Enhanced smoke management programs are specifically required in Scction 309 ofthe Rule. However, if a state, under Section 308, has determined that fire emissions are contributing to visibility impairmentand 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 meetthe requirements ofthe Rule. Tribes are not subject to the samc 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. The intent ofthis Policy is to assist both states and tribes with the

I The Rule is only applicable to mandatory Class Iareas (see Appendix A & Appendix Bfor 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 Iareas.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 ofthe WRAP ESMP Policy that there are nine elements ofan enhanced smoke management program that are necessary to meet the requirements ofthe 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 managementobjectives, and reduction ofvisibility 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 ofNational Ambient Air Quality Standards [NAAQSJ violations, orprevention ofnuisance 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 offour major sections. Section I is the eight WRAP ESMP Policy statements. Section 2 provides overall background for the WRAP ESMP Policy, including a discussion ofthe 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 oftenns, (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 ManagementPrograms 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 AirAct and Grand Canyon Visibility Transport Commission 2 2.2 Western Regional AirPartnership 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 ofan Enhanced Smoke ManagementProgram 9 3.6.1 Element I Actions to Minimize Emissions from Fire 10 3.6.2 Element 2 Evaluation ofSmoke Dispersion 10 3.6.3 Element 3 Alternatives to Fire 10 3.6.4 Element4 Public Notification ofBurning 11 3.6.5 Element 5 AirQuality 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 SectorOption 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 ManagementProgram: ImplementationGuidance 26 C.l Regional Haze Rule Implementation Plan Process 26 C.2 Elements ofan 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 ofSmoke Dispersion 30 C.2.3 Element 3. Alternatives to Fire 31 C.2A Element4. Public Notification ofBurning 32 C.2.5 Element 5. AirQuality 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 Pennitby 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 SectorAuthority 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 Program39 CA Funding Mechanisms for Enhanced Smoke ManagementPrograms40

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 managementprograms apply to all fire sources. Policy Statement C. Enhanced smoke managementprograms 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 ofemissions produced. Element 2. Evaluation ofSmoke Dispersion Using meteorological conditions to assess the ability to minimize smoke impacts. Element 3. Alternatives to Fire Any method ofremoving orreducing fuels by mechanical, biological orchemical treatments. Element4. Public Notification ofBurning 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/orequipmentthat enable an assessment ofairquality impacts of smoke from fires. Element 6. Surveillance and Enforcement An oversightmechanism that assures adherence to smoke managementefforts as defined by the regional haze implementationplan.

, Published in the Federal Registeron July I. 1999,64 FR 35714.Element 7. Program Evaluation A mechanism to assess the adequacy ofthe enhanced smoke management program in meeting the requirements ofthe Rule. Element 8. BumAuthorization The management approach used to facilitate bumdecision-making. Element 9. Regional Coordination Communication and infonnation sharing across state/tribejurisdictional 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 ofvisibility 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 ofenhanced 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 AirAct 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)' 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

## orthe governors ofeight 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.


### 2All types offire (prescribed fire and agricultural burning) must be addressed equitably as part ofa 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 ofwildfire resulting from past decades offire exclusion.· The GCVTC Report cited the need for minimizing the increase in emissions from all fire programs to the maximum extent feasible7 One of the Report's recommendations called for:

...the development and implementation ofcriteria and requirements for the use of enhanced smoke managementprograms (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 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 of them 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 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

, GCVTC Report, p. 47. 'GCVTC Report, p. 23. 7GCVTC Report, Recommendation 7, p. 50. xGCVTC Report, Recommendation 4, p. 49. 'J The WRAP members include the governors ofthirteen 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 orFort Hall. Fedeml WRAP members are the Department orthe Interior, the Department ofAgriculture, and the Environmental Protection Ageney. 10 WRA.P Charter, Purpose, p. I.


### 3regional 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 CFR49. In these cases, EPA still recognizes that "unlike States, tribes are not required by the TAR to adopt and implement CAA plans orprograms, 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 bestmeans 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 SmokeManagement The elements ofan 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 ofAir 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. DepartmentofAgriculture, November 10, 1999 (hereafterreferred to as "AAQTF Recommendation on AirQuality 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 ofthe 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 toprotect 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 ofthe 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 behalfofthe tribes maintain the ultimate responsibility for the implementation ofthe enhanced smoke managementprogram. 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 definedas those smoke management**~fforts** that specificallyaddress 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 SeeAppendix B for the reference to a map ofClass Iareas.


### 5procedures to address visibility effects that contribute to regional haze. The enhanced smoke management program adds visibility impairment/regional haze considerations to existing smoke managementefforts. 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, ifany, 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 ifthere 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 managementprograms to protect NAAQS, prevent nuisance and/or address visibility. The WRAP ESMP Policy facilitates the integration ofvisibility protection with NAAQS and nuisance protection, in accordance with the Rule: The regional haze program is being promulgated in a mannerthat facilitates inlegralion ofemission management strategies for regional haze with the implementation ofprograms 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: Enhancedsmoke managemenlprograms 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 managementprograms using voluntary measures include NM and ID.

" 64 FR 35719, emphasis added.
6This Policy applies to both wildland and agricultural lands regardless of ownership (i.e., Federal, state, tribal, public, private), cause ofignition (e.g., lightning, arson, accidental human, land management practices) orpurpose ofthe fire (e.g., vegetative residue disposal, hazard reduction, maintain ecosystem health). It is the intent thatthis 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) ofthe 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 managementprograms are requiredfor states underSection 309 of theRegionalHaze Rule. The EPA incorporated all ofthe GCYTC recommendations into Section 309 ofthe Rule, which specifically calls for "[e]nhanced smoke management programs for fire that considervisibility 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 AirAct 118(a). JJ WRAP FireCategorization Policy, p. 24. 24 Ibid, however"industrial property" would not include land such as industrial forestland. "64 FR35771,**~51.309** (d) (6) (iv). "64 FR 35769,**~51.309** (a).

7program may require legislative changes to existing rules or removal ofexemptions from regulation for specific fire sources. The tracking of emissions from all fire (i.e., wildland and agricultural land) is a requirement ofthe Rule for states under Section 309, including the development ofan 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 ofthe necessary elements of an enhanced smoke management program. The Rule under Section 309 further calls for the establishment ofannual 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 workin concert with the WRAP ESMP Policy. 3.5 Section 308 Policy StatementD. Enhancedsmoke managementprograms are a viable toolfor all other states and tribes in the WRAP region to use in the development a/their implementationplans. 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 managementprograms as effective tools to accomplish this: Where smoke impacts from fire are identified as an importantcontributorto regional haze, smoke managelllent programs should be a key componentof 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 ofthe 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 mustconsider, at a minimum, the following factors in developing its long-term strategy [forregional haze]:

27 64 FR 35771.**~51.309** (d) (6) (ii) "64 FR35771,**~51.309** (d) (6) (i).

" 64 FR35771,**~51.309** (d) (6) (v).

'" 64 FR35736. 1I 64 FR35767,**~51.308** (d) (3) (iv).


### 8(E) Smoke management techniques for agricultural and forestry management purposes including plans as currently exist within the States for these purposes32 Ifa 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 ofemissions ofpollutants that contribute to visibility impairment in mandatory Class I areas is a requirement ofthe 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 ofan Enhanced Smoke Management Program PolicyStatementE: Enhancedsmoke managementprograms include nine elements thatare necessary to meet the requirements of the RegionalHaze 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 InterimPolicy 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 theirrelative 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 ofa 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 ofall sources; comparing the baseline visibility conditions with nalural conditions; assessing the contribution to this ofthe different sources (ofwhich 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, §51.30I. 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.
9area (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 ofemissions from onejurisdictionto 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 orcontribute to visibility impainnentin 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 ofa 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 ofthis 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. Fourpotential 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 ofSmoke 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. 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 ofdispersion conditions. 3.6.3. Element 3. Alternatives to Fire Alternatives to fire (as distinguished from alternative methods of burning) include any method ofremoving 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 ofusing 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 ofthe 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.

101.6.4. Element4. Public Notification ofBurning Public notification is a significant part ofthe 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 aboutburning, its impacts, as well as its benefits. 3.6.5. Element 5. AirQuality Monitoring Monitoring ofsmoke 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 oflittle bum activity orwhen 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 undervarious methods ofoperations. 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 ofimpainnent that exists or may be expected to occur as a result ofthe burning. The proximity ofmandatory Class Iand non-attainment areas may also have a bearing on the complexity ofthe bum authorization procedure that should be implemented. 3.6.9. Element9. Regional Coordination Coordination ofburning 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 ofinformation 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).

IIThe development process should be a collaborative one involving state, tribal, local and federal agencies, and private parties. 3.7 Criteria Policy StatementF: Enhancedsmoke managementprograms willbe basedon the criteria ofefficiency, economics, law, emission reduction opportunities, land management objectives, andreduction of visibility impact!4 which willdetermine the rigorappliedto thenine 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 ofvisibility 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 ofeffort 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 managementprogramcriteria 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 anothergroup in orderto reduce redundancy orbuild on existing expertise? Economics: What are the costs and incentives ofthe 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).

12rather than moving fuels off-site or manipulating fuels through chemicals or biological decomposition or acombination ofmechanical treatments and maintenance burning') Land Management Objectives: Are there places where manipulating fuels is not an option because ofland 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 managementobjective, e.g., areas targeted for commodity production, watershed protections or tribal cultural activities sites? Are there places thatrestoration ofecosystem function may have a high priority? Reduction ofVisibility 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'sjurisdiction or they may be tailored /0 source sec/Drs and/or geographic areas /0 address presumed or confirmedvisibility impairment. Since emissions from fire sources contribute differently to visibility impairment in Class I areas and/or may be from different geographical areas, tailoring ofan enhanced smoke management program to a fire source sectorand/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 orin 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 ofthese 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 ofequitable treatment ofsources in the implementation oftheir enhanced smoke management programs. 3.8.1 Source SectorOption 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 greaterlevel ofeffort.

133.8.2 Situational Option This option describes certain situations that, iftrue, would indicate to the state/tribe the need for a greater level ofeffort ofimplementation ofthe 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 ofemission levels, NAAQS status (e.g., non-attainment area status) and proximity to Class I areas that may indicate the level ofenhanced 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: Greaterthan 50 tons/yr ofPM 10 (total/year) within state/tribe for all anthropogenic fire sources No PM,o orOzone NAAs Within and near (i.e., <50 km) aClass Jarea Greaterthan 250 tons/yr ofPM,o (total/year) within state/tribe for all anthropogenic fire sources No PM,o orOzone NAAs Within 100 km ofClass I area Greaterthan 100 tons/yr PM '0 (total/year) within state/tribe for all anthropogenic fire sources

" 40 eFR 52.21. 41, This table provides estimates oracres burned La give an idea ofapproximate fire size using the available emission factors ror the source Iype indicated. These numbers are nOL an exact representation oracreages, emission factor, and ruel loading ofall 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.

14Attainment 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 orMaintenance Area Within 100 km ofClass Iarea Greaterthan 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 Iarea Greater than 250 tons/yr of PM,o (total/year) within state/tribe for all anthropogenic fire sources Any level ofAltainment/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) ofeach ofits fire source sectors and cumulatively all fire source sectors' impacts to visibility impainnentin 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 ofa source sector's contribution to visibility impairment (on the 20 percent "worst" visibility days in a calendar year). To prevent degradation ofthe 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 ofProtected 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 ofvisibility impairment assessments. Therefore, there may be lag lime between when impacts were measured and how soon enhanced smoke management programs could be implemented orrevised. Based on the results ofthe visibility assessment, the states/tribes could determine what level ofeffort of enhanced smoke management program corresponds to the degree of impact.

153.9 CollaborativeDevelopment Policy Stalement H: The development and application of enhanced smoke managemenrprograms, including the consideralion ofthe criteria (F), will be done collaboratively with state, tribal, local andfederal agencies andprivate parlies. The GCVTC Report cites the importance ofacollaborative process in a number ofplaces with regard to fire48 EPA's Interim Policy also supports collaborative efforts and specifies roles for the stakeholders in the process. The underlying tenet ofthe WRAP process further conveys the importance of approaching visibility and the Rule with stakeholder input and use ofcollaborativeprocesses. 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 ofthe criteria to be used by the regulatory entity to detemline the level ofeffort needed for the enhanced smoke management program. The criteria for determining the level ofeffort is a significant issue as there is a paucity ofdata 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 ofall terms and acronyms. An asterisk (') indicates a definition from Section 1.1 ofthe 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 ofthe FEJF work. Alternatives to Burning

-Land managementpractices that treat fuel without using fire. Anthropogenic

- Producedby human activities. Anthropogenic Emissions Source Classification ("anthropogenic")" - A categorization that designates which fire emissions contribute to visibility impairment in aFederal 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 ofair pollution that generally extends over a large area. Prescribed burning, field burning, home heating, and open burning are examples ofarea 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 ofrush, timber, grasslands, ortrash. 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 ofa Best ManagementPractice with respect to airquality would be conducting a prescribed bum when atmospheric ventilation is good, which in turn promotes smoke dispersal.

18Class 1Area

- See Mandatory Class IArea and Non-Mandatory Class 1Area. Control ofFire Emissions'

- Actions may be taken to control fire emissions by utilizing best management practices such as the use ofalternatives, biomass utilization, and other emission reduction techniques. Criteria Pollutants

- The 1970 amendments to the CAA required EPA to set National AmbientAir 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 ofthe action when added to other past, present, and reasonable foreseeable future actions regardless ofwhat agency, entity or person undertakes such action. Cumulative effects can result from individually minorbut 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 offire. Ecosystem Restoration Buming'

- The re-establishment ofnatural 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 ecosystemto an ecologically functional and fire resilient condition. Emission

- Pollution discharged into the atmosphere. Examples ofemissions sources are smokestacks, other vents, and surface areas ofcommercial or industrial facilities; from residential chimneys; and from motor vehicle, locomotive, aircraft, or other non-road engines. Emission Inventory - A listing, by source, ofthc amount ofair pollutants discharged into the atmosphere. Emission Cap

- An enforceable 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

19defined 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 orcap). See also Emission Cap and Emission Target. Emission Reduction - A strategy for controlling smoke from prescribed fires that minimize the amount ofsmoke output per unit ofarea 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 ofa 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 (ESMPl - A program for fire emlSSlOns that considers visibility effects, in addition to health and nuisance objectives, and is based on the criteria ofefficiency, economics, law, emission reduction opportunities, management objectives, andreduction ofvisibility impact. Federal Class Iarea - see Class IArea. 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 knownas afire sourCe. Fire Use - A term utilized in federal land management that includes both prescribed fire and wildland fire use. Fuel Moisture Content

- The quantity ofmoisture in fuel expressed as a percentage ofthe weight when thoroughly dried at 212 degrees F. Fuel Reduction

- The manipulation, including combustion, or removal offuels to reduce the likelihood ofignition and/orto lessen potential damage and resistance to control. Fuel Treatment

- Manipulation or removal offuels to reduce the likelihood ofignition and/or to lessen potential damage and resistance to control (e.g., lopping, chipping, crushing, piling and burning).

20Implementation 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 ofProtected Visual Environments (IMPROVE) - A cooperative visibility monitoring effort, using a common set ofstandards across the United States, between the EPA, federal land management agencies, and state air agencies. Jurisdiction - A geographic area ofauthority

.

. 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 ofignitions for betterdispersion and consideration of downwind airquality and visibility. Itmay 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 ofa mandatory Class 1Federal area includes subsequentchanges in boundarics, such as parkexpansions. Modeling

- The artificial simulation orsome event or action that has quantifiable results. Mathematical expressions and computers are frequently used in modeling. National AmbientAirOuality Standards (NAAOS)

- See CriteriaPollutants. National Environmcntal Policy Act (NEPA)

- 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 ofvisibility in Class I areas which impairment results from manmade air pollution." Natural Background Condition'

- An estimate ofthe visibility conditions at each Federal Class Iarea that would existin the absence ofhuman-caused impainnent. Natural Emissions Source Classification ("natural")' - A categorization that designates which fire emissions can result in a natural reduction ofvisibility for each Federal Class 1

21area 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 orvolcanic eruption. Natural Visibility Goal- The ultimate goal ofthe regional haze program is the absence of visibility impainnentdue 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 orlocal ambient airquality 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 ofJanuary 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 impairmcntofairquality that manifests itselfas a coherentplume. PMlQ

- Particulate matter ofaerodynamic diameter less than or equal to 10 micrometers. Emissions ofPM,o are significant from fugitive dust, power plants, commercial boilers, metallurgical industries, mineral industries, forest and residential fires, and motor vehicles. PM,,,

_ Particulate matter ofaerodynamic 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 ofpollution. An example is thc smoke stack ofa coal-fired powerplantor 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 ofthat vegetation is accomplished mainly through

22manipulation ofecological 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 atunacceptable levels. Smoke Management Efforts

- Programs, practices and techniques to mmlllllZe and/or reduce smoke emissions orimpacts 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 ofnine 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 ofnaturally 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 notfallow, 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 ofthe



### , FEJF work.

Wildland Fire'

- All types offire (see definition offire 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 Registeron 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 TransportCommission, 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 ofAir Quality Planning and Standards, Interim AirQuality 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. DepartmentofAgriculture, November 10, 1999. http://fargo.nserl.purdue.edu/!''ca/Archives/20001P0Iicy/Buming%20Policy.htm Tribal Authority Rule Published in the Federal Registeron 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 AirPartnership, November 15,2001. http://www.wrapair.org/commindex.htm Go to the FEJF Task Teams, then Natural Background. Wildland Fire: Elements ofa Basic Smoke Management Program Draft Report Completed for the FEJF on July 10,200J. 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, 200I 3) Agricultural Burning Smoke Management Program Survey, March 30, 2001 4) An AssessmentofTribal Air Quality Data and Programs in the Western United States, The institute for Tribal Environmcntal Professionals (ITEP), September200I 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 SmokeManagementProgram: J

### mplemcntation 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 ofreasonable further progress; submittal ofslPrrlP to EPA for consideration/approval; public review/comment; EPA approval ofSIP/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 ofthe Rule into their implementation plans within 12 months ofdesignation 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 Iareas. 5(1 The GCYTC Report specified 16 mandatory federal Class I areas on the Colorado Plateau that were adopted into Section 309 ofthe 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 RccfNational 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 ofthe SIP/TIP process and has previously accepted up to one year for implementation ofSIPfflP programs. " 64 FR 35773, *51.309. 53 64 FR35765, *51.308 (b) (I), (2).

WRAP ESMP Policy 10/15/02 

### 26It is anticipated that the establishment ofenhanced 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 ofsmoke 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 ofthe Rule. For each ofthe 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 ofthe enhanced smoke management program needs to be based on a pre-determined process ormetric developed collaboratively. C. 2 Elements ofan 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. Othertechniques may include the use ofmechanical 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 ofemission reduction practices that were considered in the planning or implementation ofbums also support annual emission goals and associated emissions tracking requirements. This documentation may be part ofa 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 ofthe 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 

### 27time 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 duringcombustion. 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 ofthe 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 otherbums are not feasible, such as in snow orrain. Regulatory authorities and other interest groups may also use WRAP guidance infonnation, such as its Alternatives to Burning document that is currently under developmentby 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 BumManager Qualification Another manner in which to reduce emissions is a burn manager qualification program that certifies the land manager/owner is knowledgeable ofalternative burning practices and emission reduction techniques, and i.s**capa~le** ofimplementing 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 whattraining 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 theregulatory agency. Bum size or emission output might be limited depending on the'Ievel ofburner 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 CoordinalingGroup (NWCG) Fire Use Working Team.

WRAP ESMP Policy 10/15/02 28As examples, a few types ofburnerqualifications are**~isted** below:

• Satisfactory completion ofthe "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 ofa 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 aburnerwhen 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, cannotutilize 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 200I, the EPA issued a policy document that provides infonnation on discretionary economic incentive programs56 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 AirQuality with Economic Incentive ProgrdlllS (EIP Guidance), January 2001. "67 FR 30418.

WRAP ESMP Policy 10/15/02 

### 29available ifa 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 notgenerated. 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 ofa 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 ofburning and alternatives to burning so as to retain the ability to bum where no alternatives are available. C. 2.2 Element2. Evaluation ofSmoke 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 ofcurrent 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 ofexpected 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 ofweather elements would provide a degree ofcertainty as to when burning opportunities would be most likely to occur. Burning should be banned during periods when air stagnation advisories or airpollution 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 greaterknowledge and understanding ofthe 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 ifthere 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 ofcoordination that would rely on greater infrastructure and resources for support. Meteorologists and other specialists with knowledge ofair 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 ofthe Rule. States/tribes could establish websites with information describing the alternatives. Land managers/owners may be required to assess the feasibility ofusing 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 orpotential fuel reduction. Bum plans and data systems could contain information that helps track the practice ofusing alternatives to fire. Emissions tracking systems5H and reasonable further progress assessments could use this information to validate landowner/land manager's implementation ofalternative practices as an emissions reduction technique. Sources ofsmoke from geographic areas that continue to adversely affect a mandatory Class Iarea'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 offurther 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 anet emissions decrease as aresult ofusing the alternatives. Geographic areas with sustained sources ofadverse smoke impacts in mandatory Class I areas may consider burn curtailments ifprograms 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 ofanother source type to take needed actions to meet the natural visibility goal.

.SH The WRAP's FEJF is currently preparing apolicy on emissions tracking systems to assist states/tribes.

WRAP ESMP Policy 10115/02 31C. 2. 4 Element4. Public Notification ofBurning Public notification is a significant part ofthe 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 aboutburning, 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 ofperson/agency, fuel type, expected time and date ofbum, location ofbum, and the expected plume direction, extent, and duration. Public notification of non-burning alternatives thathave been considered for a projectcould also be included. Other means of notification may include the use of a website, public open houses or meetings, signs atbum sites, distribution offact 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 ofinterested and affected publics, and make sure that notification ofplanned bums gets to everyone on that list. A plan for notifying the public could be partofthe bumplan. 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 arecommendation 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 ofresistance to the bum while it IS In progress.

.'i9 See Appendix B ReiaLed Documents Listing, EPA Interim Policy.

WRAP ESMP Policy 10/15/02 

### 32Finally, 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. AirOuality 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 oflittle 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 furtherprogress tracking oremission 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 ofIMPROVE monitored data may have to be supplemented by air quality monitoring outside ofClass 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 ofgenerating subjective assessments ofsmoke impacts. Such information would only be used to provide further validation ofimpacts, as relying on surveys alone would be too subjective for states/tribes to administerreasonable smoke managementprograms. 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 oftrust and cooperation between regulators and land managers/owners can go a long way toward facilitating emissions reductions and compliance with airquality 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 ortribe) Criteria and activities described below may be applicable for use in any of the four methods. Some ofthe criteria can, obviously, only be enforced by a body that has legal standing to do so. Whichever ofthe four methods a state/tribe may choose to implement would be dependent upon the severity ofthe visibility impacts that are being addressed.

WRAP ESMP Policy 10/15/02 

### 33Ifstates/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 ofpublic complaints may be used to monitor air quality impacts offires. The number ofcomplaints 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, butcan be shutdown 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 ofproperty affected?

• What are the economic impacts ofboth burning and not burning?

• Is the location ofthe impactwithin oroutside ofa Class I area?

• What is the duration ofthe impairment?

• What is the number ofpeople affected?

• How many complaints have been received?

• Was the bum conducted in compliance with applicable regulations?

• Has the visibility impact been mitigated to the extentpracticable?

• Is the public health threatened?

• Is the impact a result of poor planning or of something that could not be anticipated? Criteria ofperfonnance standards in an enhanced smoke management program must be stated clearly. Methods for detecting non-compliance could also be defined. Some criteria orstandards 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 ofensuring compliance with air quality regulations. Aerial observations are another surveillance method. Ifno visibility impact-related regulations are in place, violation ofNAAQS or violation ofother 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 34compliance 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 ofviolation/compliance order

• Liability for cost ofsuppression or damages

• Revocation ofpermit

• Felony punishment for willful or intentional violation

• Misdemeanor for careless violation C. 2. 7 Element7. Program Evaluation Enhanced smoke managementprograms 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, shorterreview and evaluation time periods would belterdetermine ifenhanced smoke managementprograms are effective. Generally, daily interaction between land managers/owners and program administrators can provide a continuous means ofprogram 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 ofthe enhanced smoke management program should considerevaluating:

• 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 ofprogress 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 orvisibility impacts

• Summaries ofIMPROVE and othermonitored air quality data

• Emission inventory summaries

• Information tracking summaries

• Smoke complaint summaries

• Discussion ofalternatives 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 inputto 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 ofimpainnent that exists or may be expected to occur as a result ofthe burning. The proximity ofnon-attainment areas may also have a bearing on the complexity ofthe burn authorization procedure that should be implemented. Four broad levels ofstringency may be considered in the development and adoption ofan enhanced smoke management program.

• Establish apennit-by-rule system

• Establish a burn permitting system by source sector or a coalition ofsource sectors

• Establish acentralized bum authority

• Establish aregional bum authority Establishment ofany ofthese authorization situations would also entail the development ofcoordination procedures described in (9) below. C.2.8.1 Pennitby Rule The AAQTF Recommendation on Air Quality Policy describes a process in which a set ofrequirements are established under which burning may take place. These requirements may include acreage, time ofyear, time ofday 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 AirQuality Policy, p.9.

WRAP ESMP Policy 10/15/02 36Such a system may be applicable for any fire source type in geographic areas oflow fire use. This system should, however, still allow for the collection ofenough 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 underwhich 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 CentralizedBurn Authority A more intensive level ofsmoke management would involve the creation ofacentralized authority at the state, tribal or local level thatprovides daily coordination and approval of burns ifsignificant state/tribe-wide burning is occurring. The centralized authority may be responsible for activities ofone particular source type or a combination ofsources. This type ofprogram could include the detailed use ofmeteorological information, burn information and a permitting system to avoid cumulative impacts ofsmoke from a variety ofbums. C.2.8.4 Regional Bum Authority Establishment ofa 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 mostcases, '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 orhave recently occurred. Coordination can occur at locations that reflect the affected level ofconcern. 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 37A common mode ofcoordination regardless ofthe complexity and magnitude ofburning 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 ofknown significantusers offire (name, phone number)

• Identification ofairsheds or air administered units

• Possible identification ofClean AirCorridors

• Updateable database of non-attainment and maintenance areas for criteria pollutants ofconcern

• Identification ofthe centralized burn authority that maintains oversight A minimal level ofcoordination would include the use ofwebsites to post burn activity. This passive mode of coordination would be used regardless ofthe 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 acommOn webpage or series ofwebpages. 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 ofother 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 ofdifferent 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 ofburn 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 38quality, 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. Ifstates'/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 ofburns and their smoke impacts. A segment offires 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 oflongerduration and have the greaterpotential 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 ManagementProgram 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 behalfof 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 ofthe contribution

WRAP ESMP Policy 10/15/02 39to visibility impairment in Class I areas. It is also incumbent upon the regulatory authority to develop a SIPfflP that is consistent with Section 118 ofthe CAA pertaining

, to equitable treatment offederal activities."2 Finally, failure ofthe 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 ofthe year; in others, extensive infomlation on a daily basis regarding planned and accomplished burning will be required. C.4 Funding Mechanisms for Enhanced Smoke ManagementPrograms Funding for enhanced smoke management programs can come from many possible sources. Further, funding mechanisms will depend on the magnitude or complexity ofthe enhanced smoke management program needed. The following is a list of possible methods for funding enhanced smoke management programs: A. Funds obtained from users ofprescribed 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

• PermitFees

• Emissions-based Fees

• Acreage-based Fees 

### B. Funds Obtained from Users ofClass 

### IAreas C. Grants and/or AppropriatedFunding • A combination ofmany 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 ofResources

• 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 AirAct §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 TaskTeam ofthe 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 overa six-month period through astakeholder-based consensus process to assistthe WRAP region states and tribes in addressing emissions from fire sources. In this Policy, the WRAP seeks to provide aconsistentframeworkthatstates and tribes can useto efficiently develop their individual implementation plans. The WRAP recognizes states' and tribes' authority and responsibility to develop, adoptand implementtheirregional hazeimplementationplans, and recognizes theRuleas the principal document on which states and tribes should rely. TheRulerequires states to develop implementation plans(SIPs) for addressingregional haze in the Nation's 156 mandatory Class Iareas. Additionally, theRule requires effective managementoffire sources. The Rule provides two pathways for western states to follow as they implement the requirements ofthe Rule: I) develop their regional haze implementation plans per the nationally applicable provisions ofSection 308, or2) Transp0l1 Region states may choose to incorporatc the Grand Canyon Visibility Transport Commission (GCVTC) Recommendations into their regional haze implementation plans under Section 309 ofthe Rule. The GCVTC recognized that projected increases in fire activity will result in episodic impacts on visibility in the West, and called forthedevelopmentofannual emission goals thatwould minimize these impacts. Section 309 ofthe Rule specifically requires the establishment ofannual emission goals that minimize emission increases from fire to the maximum extent feasible. Further, these goals mustbe developed in cooperation with states, tribes, land management agencies and private entities. The WRAPdefines theannual emissiongoal as aquantifiablevaluethatis used to measureprogress each yeartoward thedesired outcome ofachieving theminimumemission increase from fire. In this WRAP AEG Policy, the WRAP outlines a process by which states/tribes may establish annual emission goals, basedon the utilization ofcurrently availableemissionreductiontechniques (ERTs), to include in theirregional haze implementation plans.Although Section 309 ofthe Rule specificallyrequires the establishmentofannual emission goals, the strategy outlined here forthe utilization ofERTs could be considered by states and tribes that choosetofollow therequirements ofSection 308 ofthe Ruleand/ormay beused toprotectvisibility in non-mandatory Federal Class I areas.' Tribes are not subject to the same requirements ofthe Rule as states, buttribes wishing to assume the regional hazerequirements outlinedinthe Rule may, accordingtotheCAA, seekapprovaltobe treatedin the same manneras states, undertheTribal AuthorityRule (TAR), 40CFR49. Theintent 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 ofthe Rule are cited. 

### In the case ofannual emission goals, the WRAP considers themaviable 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 offour major sections. Section I is the seven WRAPAEGPolicy statements. Section2provides overallbackground forthe WRAPAEGPolicy. Section 3 is an annotation ofeach ofthe seven policy statements, further explaining and defining them. Finally, the Appendices include (A) aglossary oftenns, (B) arelated documents listing, (C) additional guidance for states/tribes on the implementation ofannual emission goals, and 0) an example ofa table that will be developed as a separate guidance document by the WRAP Fire Emissions JointForum for use with annual emission goals.

1 The Rule is onlyapplicable to mandatory Class 

### rareas. States/tribes in the WRAP region may utilize the AEG Policy 10 protect visibility in non-mandatory Class Iareas. ii

### WRAP Policy AnnualEmission Goals for Fire

TABLE 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 StatementA: 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 StatementF: 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

IIITABLE OF CONTENTS

2. Regional Haze Implementation Plans 2.1 Section 

### 30S/309 Requirements 2.2 Submission ofPeriodic Reports 3. Use ofERTs 3.I Califomia 3.2 Oregon 3.3 Washington 3.4 Utah 16 16 17 17 IS IS IS IS 4. Establishment ofAnnual Emission Goals 19 4.I CurrentERT Application 19 4.2 Non-burning Alternatives and Annual Emission Goals 19 4.3 Determination ofAppropriate ERTs 20 4.4 Feasibility Criteria 2 I 4.5 Existing Guidance Documents 2 I 4.6 Research Needs 22 4.7 Calculation ofAverted Emissions 22 Appendix D: ERT & Associated Emission Averted Table 24

IV

### 1. 

### WRAP Policy on Annual Emission Goals for Fire Policy Statements A) Theestablishmentand implementationofannual emission goals is aviable techniquetocontroll fire emissions for WRAP states and tribes. Annual emission goals are required for states under Section 309 ofthe Regional Haze Rule. B) Annual emission goals will achieve the minimum emission increase from fire. Annual emission goals are quantifiable values that are distinctfrom emission limits. C) Annual emission goals are applied to all fire sources (excluding wildfire) due to theirpotential 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 feasibilitycriteria,and landmanagementobjectives. F) States, tribesorthe designated authority will establish annual emissiongoals incooperation with federal land management agencies and private entities on ayearly basis. G) States and tribes will need to develop a procedure for verifying the use ofemission reduction techniques and for tracking the achievement ofannual emission goals. 

### 2. Background
2.1 Clean AirAct and Grand Canyon Visibility Transport Commission In 1990, Congress amended theClean AirAct(CAA), and as partofthese 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 addressingregional haze in thewestern United States. TheGCVTC signed and submitted morethan 70reconunendations to theEnvirorunentalProtection Agency(EPA) inareportdatedJune 1996that indicated thatvisibility impainnentwas causedby awide variety ofsources and pollutants, and that acomprehensive strategy was needed to remedy regional haze.

2 "Control" as used in this Policymeans the use oftechniques that result in aquantifiable reduction in emissions from individual fire sources. 3TheGCVTC wascomposedofthegovernors ofeightwesternstates (AZ,CA,CO,NM,NV, OR,UT,WY), fourtribes (Acoma Pueblo, Hopi, Hualapai,andNavajo), fourFederal 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 importantepisodiccontributorto visibility-impairing aerosols, includingorganiccarbon, elemental carbon, and particulate matter (PM2.S).'" The GCYTC Report also stated that agricultural burning emissions and theireffects have been identified as a concern, but have not been quantified due to insufficientdata5
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 orcommon air management issues, develop and implement strategies to address these issues, and formulate and advance western regional policy positions on air quality.,,7These policies and technical tools are developedthroughinclusive, stakeholder-basedprocessesandapprovedbyconsensusofthe WRAP. WRAPparticipantsinclude stateairquality agencies, tribes, federal/state/private landmanagers, the EPA, environmental groups, industry, academia and other interested parties. There are over 400 tribes within the WRAP region. The large numberoftribes limits the participation ofall 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 ofthe 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 Iareasdue to emissions from all sources, includingfire activities. EPA incorporated all ofthe GCYTCrecommendations 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 theregional hazerequirements outlinedin the Rule may, accordingto the CAA, seekapproval tobe treated in the same manneras states, under the Tribal Authority Rule (TAR), 40 CFR49. 8 In these



# ,GCVTC Report, p. 47. sIbid. 6 The WRAP membership is comprised ofthe governors ofthirteen western states and thirteen western tribes. The currentWRAPmembers includethe States ofAK, AZ, CA, CO,!D, MT, ND, NM, OR, SD, UT, WA, andWY, andthe TribalNations ofPuebloofAcoma, CampoBandofKumcyaayIndians, CortinaIndian Rancheria,HopiTribe,Hualapai Nation ofthe Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo ofSan Felipe, and Shoshone-Bannock Tribes ofFort Hall. Federal WRAP members are the Department ofthe Interior, theDepartmentofAgriculture, and the Environmental Protection Agency. 7 WRAP Charter, Purpose, p. I. x64 FR 35759. 2cases, EPA still recognizes that "unlike States, tribes are not required by the TAR to adopt and implementCAAplans orprograms, thus tribes are notsubjectto mandatorydeadlines for submittal ofimplementation plans.,,9 Although provision for flexibility in the submission ofprograms 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 recognizesthe WRAPas the Regional PlanningOrganizationthatisdevelopingthe 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 bestmeans for states and tribes to implementthe portion ofthe Rule at issue. The WRAP recognizes states' and tribes' authority and responsibility to develop, adopt and implementtheirregionalhaze state and tribal implementationplans, and the seminal guidance to do this is the Rule. '1 States are required by the Rule to submitperiodic reports to the EPA to assess the adequacyofthe implementationplan. Ifthe statedetenllines thatthe implementationplan is ormay beinadequatetomeetreasonableprogressgoals, the state isrequired to developadditional 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 ofthe WRAP AEG Policy is to assist states (or the delegated authority) and tribes to address smoke impacts on visibility associated with fire in away 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 ofemission reduction techniques (ERTs) to meet the annual emission goals requirementoftheRule. Althoughthis PolicypromotestheuseofERTstomeettheannualemission goals requirement ofSection 309 ofthe Rule, it does notprescribe how each state/tribe integrates this Policy into its regional haze SIP/TIP or limit the use of alternative approaches to the implementation ofannual 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 ofannual emission goals. Further, states are responsible for incorporatingintotheirimplementationplans federally enforceableprocessesto minimizeemission increases from fire, whether they choose to use ERTs or some other method that meets Rule requirements. Tribes, orEPAontheirbehalf, may choose toutilize, as a severableelement, annual '64 FR 35758. '0 64 FR 35759.

" WRAP Charier, p.l. 3emission goals in theirimplementationplans. TheWRAPrecognizes thatthe implementationplans will be revisited and revised, perthe 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 StatementA: The establishment andimplementation

## 0/ annual emission goals is a viable techniquetocontrolfireemissions/or WRAPstatesandtribes. Annualemissiongoals are required/orstates underSection 309o/the RegionalHaze 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 Section309, the Rulecallsfor "establishmentofannualemissiongoals forfire (excludingwildfire) thatwill minimizeemission increases fromfire to themaximumextentfeasible.,,1l ThePolicy can beconsideredbyall otherstates and tribes as ameans tocontrol fireemissions, andannual emission

. goalsareaviable techniqueforcontrollingfireemissions ifastate'sortribe's visibilityimpainnent

analysis for Section 308 ofthe Rule shows thatfire sources contribute to visibility impainnentin a mandatory Class Iarea. 3.3 Annual Emission Goal Defined PolicyStatementB:Annualemissiongoals willachieve theminimumemission increasefrom fire. Annualemissiongoals are quantifiable values thatare distinct{rom emission limits. In its Report, theGCVTCacknowledgedfederal and state land managers' projectionof"significant increases inprescribed fire in orderto reduce the effects ofwildfire resulting from pastdecades of fire suppression.,,13 TheRule alsorecognizedthat"forestfuels havebuiltup overmanyyears dueto pastmanagementpractices designed to protectpublic health and safety through fire suppression." Andfurther, thatthis has "

...Iedtoan increasedriskofcatastrophicwildfire

..... whichwouldneedto be offsetby "the increased use ofprescribed fire

....,,14 This increase in fire activity prompted the GCVTC to recommend the establishment ofannual emissiongoals thatwouldminimizeincreases from fireemissions, which theRule thenadoptedas a requirementunderSection 309. 15The Ruleutilizes theGCVTC's terminologyin Section 309andin the Preamble, both in its section on the Treatment ofthe GCVTC Recommendations and in the Annex to the GCVTC Report. 16Therefore, 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 ofbothAreaSources and AirPollutionPrevention to focus efforts on adesiredoutcome."

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. 4This 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 referto the limits setunder a regulatory program, which would be triggered ifthe "targets" are exceeded.19 

### Inusing the termgoal, andnottargetorcap, theGCVTC clearly intended the annual emission goal to be something other than an emission limit, and that it not have the attendant regulatory consequences ofacap, as supported by the specific use ofthese terms in its Report. Therefore, the WRAPAEG Policydefines annual emission goals as quantifiableindicators ofprogress toward the desired outcome ofminimizing increases from fire emissions. 

### In distinguishing between goals and limits, it is not the intent of this Policy to preclude the establishment ofemission 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 limiton fire sources.'o The WRAP does recognize thatscientific advances may support the feasibility ofan emissions limit (either target orcap) in the future. 3.4Applicability PoliCY Statement C: Annual emission goals are applied to allfire sources (excluding wildfire) due to theirpotential impacts on visibility. The Rule, the GCVTC and WRAP policy development to date acknowledge that all types offire must be addressed equitably as part ofa 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 ofthe Rule22

"GCVTC Report, p. xi and pp. 32-37. 19 GCVTC Report, p. 34, foolnote 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, conductperiodicevaluations ofthe effectiveness ofthe baseline, and institute sufficientenforcemcnlmcchanisms. Even so, thebaselinc may notbeareliablc tool due to the variabilityof 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). 5The Rule excludes wildfire from the annual emission goals requirement ofSection 309 due to the inability to directly control the emissions from wildfires. The same concern would be relevant to states under Section 308 ortribes 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 forresource benefits (WFU)2J oragriculturalburningto achieve land managementobjectives onagricultural land orwildland.24 Inaccordance with Section 118(a) oftheCAArequiringthatall entities, federal and non-federal, be subjecttothe samerequirements, 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 fortraditional, religious, orceremonialpurposes (e.g., cremation, sweatlodgefires).'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 considerthe impacts ofthese fire sources when developing their regional haze implementation plans. 3.5 Emission Reduction Techniques CERTs) PolicyStatementD: The minimumemission increasefromfire isaccomplishedthrough the optimalapplication of emission reduction techniques, whichprovides the basisforannual emissiongoals. The WRAP AEG Policy provides apractical approach to establishing annual emission goals that states andtribes canuseintheirimplementationplans. TheWRAP has developedtheAEGPolicyto 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 thatcan be determined in one year's time. The annual level offire activity isdependent onavarietyofexternal factors suchas croptypeplanted, fundingforfederal or state fire programs, weather, etc. These factors willalsoinfluence the potentialuse offire emission control strategies. In order to accommodate this variability and address the annual nature ofthe Rule requirement, annual emission goals are to be determined each year through a collaborative process between burners and the regulatoryjurisdiction. Second, sinceannual emission goals are notemission limits, thegoal is basedonthe solepurposeof minimizingemission increases fromfire tothemaximumextentfeasible; therefore, annual emission

23Also known as Prescribed Natural Fire (PNF). 24 WRAP Policy for Categorizing Fire Emissions, November 15,2001 (hereafter referred to as "WRAPFire Categorization Policy"), p. 8. See also Appendix C for further details. 2S Clean AirAct § 118(a). 26 WRAP Fire Categorization Policy, p. 24. 27 Ibid, however "industrial property" would not include land such as industrial forestland. 6goals can reasonably be tied to actions that have this result. Under this Policy, the process for establishmentoftheannual emissiongoal, ratherthanthe specific numeric value (whichvaries from yeartoyear), will beincludedin implementationplansubmittal. In otherwords, thegoal 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 ofbeing implemented using tools and information currently available to meetthe Section 309 deadline ofDecember31, 2003. To address these issues, the WRAP AEG Policy focuses on minimizing fire emission increases through the control ofemissions onall fire projects where feasible. Control offireemissions means utilizingmethods thatresultinareductionofthetotal amountofemissions generatedfrom each fire project. Control offire emissions is accomplishedby using emissionreduction techniques (ERTs), methods proven to reduce fire emissions.,. ERTs include biomass utilization priorto burning, increasing combustion efficiency, and others.'9 Additionally, methods existfortracking andcalculatingtheemissions averted from theuseofERTs for abroad array ofvegetation types. Forthe purposes ofthis 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 offuel-loading, enhancement ofwildlife habitat, etc.)30 Control measures aredistinctfrom smoke managementtechniques, which are currently used in the Westby land managers tominimize smoke impacts on public health, nuisanceandvisibility. Akey smoke management technique is the timing ofignitions for better smoke dispersion with the intention ofavoiding 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 ofERTs are calculated on a projectspecific basis, otherwiserefelTedto as theoperational phase ofthe fire project. Thedecisiontoburn a specific area has already been made prior to the implementation ofa specific project; therefore, project-specific basisrefers toprojects where fire will beused to meetlandmanagementobjectives. Annualemissiongoals, underthis Policy, are establishedannually andapplytotheupcomingyear's projects where fire has been determined as the best tool for meeting specific land management objectives. The annual emissiongoal in this case wouldbe the sumofemissionreductions from all fire projects where ERTs are used across the state ortribaljurisdiction, for the upcoming year.
28 The GCVTC projected that the use ofoptimal smoke management measures (which include the use ofERTs) could decrease fine particle (PM2.5) emissions from prescribed fires by approximately 15-20%. This resulted in modeled visibility improvements over the planning period ofthe GCVTC. GCVTC Report, p. 87. 29 See Appendix C formore examples ofspecitic ERTs and the application ofERTs. 30 For a more detailed discussion ofnon-burning alternatives, see Section 4.2 ofAppendix C. 73.5.1 Implementation Options Twooptions fortheutilizationofERTstomeetthe annual emissiongoal havebeenoutlinedbelow. These options are based on currentuseofERTs, science and technology. The first option is based on estimations ofemissions averted throughthe application ofERTs, and allows the calculation of an annual numeric value thatindicates progress toward minimizing increases from fire emissions. The second option is provided for instances where estimates ofemissions averted are not feasibly calculated dueto insufficientdata. 

### ln this second option, the annual numeric value is based on total percent use ofERTs with subsequentemission reductions inferred. Thetwooptionsexploredherearenotexhaustiveordefinitivein structureordesign. Applicationof these or any other options can be considered for each individual fire source sector or for combinations ofthem. Alloptions foruseofERTs are subjecttothefeasibility criteriaasoutlinedin Policy Statement E. Additionally, state/tribal authorities will want to be mindful of equitable treatment ofsources in the implementation ofERTs. In eithcrOption I orOption 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 ofland 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 establishingannualemissiongoals, thedesignation ofall appropriateERTsforeachoftheidentified vegetation orcrop type needs to be completed. For use in this process, Appendix 0 provides an example ofa table that will correlate the use of ERTs withemissionsaverted. Appendix 0 wiIIbeaugmentedby subsequentguidancebytheWRAP 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 guidancedocument can be used in combination with known local practices to detennine appropriate ERTs for the respective vegetation orcrop type. Option I Once applicable ERTs for the respective vegetation or crop type are agreed upon, the potential percentage use ofERTs is determined subject to the feasibility criteria for the specific project. Thepotentialpercentage use is estimatedbydetennining theportion ofthe project where ERTs are to be applied. Then an estimate ofthe emissions averted can be made. The annual emission goal is the emissions averted through the use ofERTs for all projected fire projects across the state or tribaljurisdiction.

8Option 2 An estimate ofemissions averted may not be feasible ifERT emission factors are not available (i.e., the specific amountofemissions reduction has notbeen determined through research). In this case, the annual emission goal is the percentoftotal acres onwhich ERTs are used where fire is to be employed across a state or tribaljurisdiction for the upcoming year. Althoughannual emissiongoalsusingERTs canbeestablishedunilaterallyacross fire sourcesectors foreitherOption I or

### 2, there are benefits to establishingthemby source sectorso as to accountfor differences in managementpractices between agricultural and wildland burning, as well as in the availability ofERTs. Establishing the annual goal using ERTs by source sectormay also alleviate equity issues sincethegoal is appliedacross projects with similarvegetative orcroptypes and land managementobjectives. Theannualgoal shouldbeestablishedaftertheevaluationofallpotentially applicable ERTs. This Policy encourages states/tribes to coordinate with neighboring states/tribes to improve the knowledge base ofERTs 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 PolicyStatementE: The use of emission reduction techniques to achieve annualemission goals is subject to economic, safety, technicalandenvironmental/easibUity criteria, and landmanagementobjectives. The feasibility ofERT use is variable and dependent on criteria as established in the WRAP Fire Categorization Policy: Perthe GCVTC Recommendations, economic, safety, technical and environmental considerations are part ofthe application ofemission controls for the implementation of this Policy statement. Due to these considerations, the control ofemissions from some fire types may notbe feasible, which wiII be determined by the land managerin collaboration with the applicable airquality regulatory authority.32 The WRAP AEG Policy also recommends that land management objectives be included in these criteriaduringthedecision-makingprocessto ensurethatERTs are usedappropriatelyandatlevels ofusagethatare feasible. Itshouldbe noted thatthe specific landmanagementobjective foranarea couldpreclude the use ofa specific ERTwhere that ERTwould preventthe attainment ofthe land managementobjective, e.g., ifthe landmanagementobjective isto reducedowned largefuels in an area, the use ofburning under high fuel moisture of large woody fuels (i.e., the ERT being

31 64 FR 35728. 32 WRAP Fire Categorization Poliey, p. II. 9considered) would not be an option. See Appendix C for more detailed infonnation on the application ofERTs. 3.7 Utilizing Collaborative Processes PolicySlatemeniF: States. IribesorIhedesignatedaUlhorilywilleSlablishannualemission goals incooperalionwilhjederallandmanagemenlagenciesand privaleenliliesonayearly basis. Section 309 ofthe Rule requires that annual emission goals are "established in cooperation with States, tribes, Federal land management agencies, and private entities33 In addition, the WRAP's policies on fire to date endorse the importance ofusingthis collaborativeprocess. Annualemission goals will be reviewed and revised on a yearly basis. Coordination within states and across jurisdictionalboundariesiskey forminimizing**visibilit~** impactsinmandatoryFederal ClassIareas and for addressing regional haze in the WRAP region. 4 3.8 Tracking Procedure PolicySlatemeni 

### G: Siaies andIribes willneed 10develop aprocedure jorverifyingIhe use of emission reduclion lechniquesandjorlrackingIheachievemenlof annualemissiongoals. A procedure for verifying the use ofERTs should be developed. Such a procedure could also facilitatethe state's/tribe's ability toensureaccountabilityofindividual sources in utilizing ERTs. A state's/tribe'sfire tracking system, asbasedon theWRAP FireTrackingSystem(FTS) Policy, could be augmented to provide a repository for the verification infonnation. The verificationofthe use ofsomeERTs couldalso bedone indirectly, forexample bytrackingfuel moisture. Procedures for tracking the actual emissions averted (Option I) and/or the actual percent oftotal acres Onwhich ERTs areused (Option2) shouldbe developed. Atyear-end, these actual values can then be comparedtotheestimated value(s) forthatyearto assess whetherannualemissiongoals are being met and for the purposes of establishing the next year's annual emission goals. A state's/tribe's fire tracking systemcouldbe developed to supportthe trackingoftheachievementof annual emission goals. States/tribescan utilize thetrackingprocedure forthe annualemissiongoalas ameans forassessing theeffectivenessofthecontrolmeasures (i.e., ERTs)in theirSIPs/TIPs. StatesunderSection309are required to submit periodic reports to EPA that assess the effectiveness oftheir 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

- Anyfire ignitedbymanagementactions to meetspecificobjectives (i.e., managed to achieve resource benefits) on agricultural land. Agricultural Land

- Agnculturallandincludes croplands, pasture, andotherlands onwhich cropsor livestock are produced. Rangeland will be included with wildland for the purposes ofthe Fire Emissions JointForum 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 (accordingtoEPAguidance) forcontrollingsmallordispersedparticulates andotheremissionsfrom sources such as roadway dust, soot and ash from woodstoves and open burning ofbrush, timber, grasslands, ortrash. BestManagementPractices <BMPs) - Aterm applied collectively to any administrative oron-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 underthe 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 largerthan 5,000 acres in size, 3) national parks that exceed 6,000 acres in size and which were in existence when the 1977 Clean AirAct amendments were enacted. The extent ofa 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, othervents, and surface areas of commercial or industrial facilities; from residential chimneys; from motor vehicle, locomotive, aircraft, orothernon-road engines; and from area sources such as fire. Emission Cap

- An enforceable limiton the amountofspecific airpollutants thatcan be released or on the amountofaspecificpollutantthatis allowed to bein the airin adefinedgeographic area, and thathas regulatory consequences. See also Emission Goal and Emission Target.

11Emission 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 ReductionTechnique (ERT) - A technique for controllingemissionsfromprescribedfires to minimize the amount ofemission outputper unit ofareabumed. Emission Target - Afinn limiton theamountofspecificairpollutants thatcanbereleased oron the amount ofa specific pollutant that is allowed to be in the air in a defined geographic area, but withoutregulatoryconsequences(as distinguished from acap). Seealso EmissionCapand 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 ofefficiency, economics, law, emission reduction opportunities, management objectives, and reduction of visibility impact. fire

- When this tenn**~pp~ars,** itrefers 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 managementobjective(e.g., reduction offuel-loading, manipulation offuels, enhancementof wildlifehabitat, ecosystemrestoration, etc.). 

### Inthis Policy, non-burningalternatives do notinclude techniques used inconjunctionwith fire. Techniqucsused in conjunctionwith firearereferredto as ERTs. Prescribedfire

-Anyfire ignitedbymanagementactions to meetspecific objectives, i.e., managed to achieve resource benefits. Rangelands

- Land onwhich the historic climax plantcommunity 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 overa wide geographic area. SmokeEffects

-Theeffects onvisibility (bothplumeblightand regional haze), publicnuisance, and the health-based NAAQS due to emissions from fire.

12Smoke Management - Progrmlls, practices, and techniques to minimize and/or reduce smoke emissions orimpacts from fire. StateImplementationPlan(SIP)

- Plans devisedby states tocanyouttheirresponsibilities underthe Clean AirAct. SiPs mustbe approved by the U.S. Environmental Protection Agency and include public review. Transport Region State

- One ofnine states that make up the Grand Canyon Visibility Transport Region: Arizona, California, Colorado, idaho, Nevada, NewMexico, Oregon, Utah, andWyoming. Tribal Implementation Plan (TiP)

-Plans devised by tribes to cany outtheirresponsibilities 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 notcultivated(i.e., the soil is disturbed less frequently than oncein 10years), is notfallow, and is notin theUSDAConservation 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 Prescribedfires). The land is not"agriculturalland" as operationallydefinedabove. Silviculturalland and rangelands (perthefEJfcharge), woodlots, and privatetimberlands will be included with wildlands for the purposes ofthe fEJf work.

13

### Appendix B Related Documents Listing Regional Haze Rule Published in the federal Registeron July I, 1999,64 fR 35714. http://www

### .epa.gov/ttn/oamg/tIIfr 

### notices/rhfedreg.pdf EPA Interim Air Quality Policyon Wildland and Prescribed Fire U.S. EPA, Office ofAirQuality Planning and Standards, InterimAir Quality Policy on Wildland and Prescribed fires, April 23, 1998. http://www

### .epa.govIttn!oamg/t

### IImemoranda/firefnI.pdf Prescribed Burning Background Document and Technical Information Document for Prescribed Burning BestAvailable Control Measures U.S. EPA, Office ofAirQuality 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, AirQuality Policy on Agricultural Burning, Recommendation to the U.S. Department ofAgriculture, November 10, 1999. http://fargo.nserl.purdue.edu/faca/Archives/2000/Policy/Burning%20Policy.htm Tribal Authority Rule Published in the federal Registeron 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 TransportCommission, 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 AirPartnership, November 15,2001. Go to the fEJf Task Teams, then Natural Background. WRAP Policy on Enhanced SmokeManagement Programs Approved by the Western Regional AirPartnership, November 12,2002. Go to the fEJfTask Teams, then Enhanced Smoke ManagementPrograms.
14

### WRAP Policy on FireTracking Systems Approved by the Western Regional AirPartnership, April 2, 2003. Go to the FEJF TaskTeams, then FireTracking Systems. Non-Burning Management Alternatives on Agricultural Lands in the Western United States Go to FEJF TaskTeams, 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 TaskTeams, 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 Policybuilds On the WRAP FireCategorizationPolicy, the scopeandapplicabilityinregard to the "anthropogenic"or"natural"classificationsdefinedbytheWRAPFireCategorizationPolicy is clarifiedbelow. Thoseinterestedshouldconsultthe WRAP FireCategorizationPolicyforfurther 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 

## • Otheropen burning activities Not Covered 2. Regional Haze Jmplementation Plans 2.) Section 308/309 Requirements Itis anticipated thatannual emissiongoals will be incorporatedinto theSection 309 implementation plans submittedto EPA in orderto meetthe 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 1areas ofthe Colorado Plateau submitted by December 31, 2003, with implementationofcertain controlmeasures, includingannualemissiongoals, by the following year. All othermandatoryFederal Class 

### Jareas in theGCVTC transportregion will beaddressedby2008 under the Section 308 or 309 implementation plan schedule.

)(,WRAP Fire Categorization Policy, p.8. 16Although Section 309 ofthe Rule specifically requires the establishmentofannual emission goals forfire, themethods thatarepromotedinthis Policycouldbeconsideredby states/tribesthatchoose to follow the requirements ofSection 308 ofthe 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 considerdeveloping furthercontingency measures, e.g., aregional application ofannual emission goals, in their implementation plans ifthe annual emission goals do not adequately minimize emissionincreases from fire. Theannual emission goal approach is aviable strategy to control fire emissions and, therebY, make reasonable progress toward the attainment ofnatural conditions by 2064, as required by the Rule. 2.2 Submission ofPeriodic Reports Beginning in 2008, stales are required by the Rule to submitperiodic reports to the EPA to assess the adequacyofits implementationplan, including assessing the adequacy ofcertainelements, such as theannual emissiongoals. These periodic reports aredueeveryfive years. Ifthe statedetermines thattheimplementationplan is ormay be inadequateto meetreasonable progress goals, the state is required todevelopadditional strategiesto address deficienciesin theplan. These strategies arethen submitted to EPA for approval. 

### 3. Use

## orERTs ERTs areproven to beeffective methods to control fire emissions andare applied indifferentways byregulatory authorities. forexample, someregulatory authoritiespromote theuseofERTs as part ofavoluntarymanagementprogramwhileothersenforcetheuseofERTs through rulemaking. For example, the California Agricultural Burning Guidelines enforce the use ofERTs by specifying requirements forthe burningofrice, barley, oat, andwheatstraw. TheGuidelinesrequiretheuseof a "crackle test" to detennine ifthe fuel is dry enough to burn. In the stateofWashington, 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 stageofburning. Although a few states in the WRAP region do promote or require the use ofERTs and specify burning conditions that mustbe metin orderto burn, currently no systems are inplace to trackthe emissions averted from the application ofsuch methods across all fire source sectors. CUITently programs do exist in some areas for tracking ofemissions averted through the use ofERTs for wildlandprescribed fires.

3764 FR 35771 §51.309 (d)(6)(v). 38 WRAP Initiatives Oversight Committee (lOC), Transmittal Leuer, November 15,200I, Appendix C ofthe WRAP Fire Categorization Policy. 17Thefollowing paragraphsprovideasummaryofsomeofthecurrentefforts byregulatoryentities to use ERTs as a means to reduce emissions from prescribed fire and agricultural burning. 3.1 California Title 17 ofthe California Code ofRegulations requires district smoke management programs to include general burning requirements for agricultural burning, prescribed burning, and prescribed fires inwildlandand wildland/urban interfaceareas. 

### Inadditiontothegeneralrequirements, the law includes specific requirementsforrice, barley, oat, andwheatstraw, suchascertainfiringtechniques 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, butarenotlimited 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, theOregon SmokeManagementProgramrequires land managers toconsiderutilization ofresidue, fuel reduction measures, alternate treatment practices, and reduction ofprescribed 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 offuel moisture content, ignition method, and otherinfonnation to supportcalculation ofERT use. 3.3 Washington 

### InWashington, wildland landmanagers areencouragedtousetechniques, suchas fans, cranepiling, mass ignition, accelerated mop-up, and other methods ofincreasing combustion efficiency and reducingthe smoldering stageofburning. Notracking ofspecific ERTsisrequired. TheWashington Smoke Management Plan for silvicultural burning does establish a tracking system to measure progress toward specifIc emission reduction targets. Bum days and specificburning conditions are established by the Department ofEcology for agricultural burning and a permitting system is in place. 3.4 Utah Agricultural burning is notregulatedby the StateofUtah. However, countiesrequire suchbums to be conducted during optimal dispersion conditions. State airquality regulations require wildland land managers to take measures to prevent smoke impacts. State law requires identification ofbest management practices including the use ofERTs. Land managers are required to identiJY the techniques that are employed in addition to fuel moisture and ignition method in their daily emissions report.

184. Establishment ofAnnual Emission Goals 4.1 CurrentERT Application Research has shown that ERTs can result in emission reductions, which, in turn, reduce smoke impacts on air quality. Accordingto the National Wildfire Coordination Group's (NWCG) Smoke Management Guide forPrescribedandWildlandFire, methods usedtoreduceemissions generated from prescribedburning onwildlands are: reducingthe areaburned, 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 Documentfor PrescribedBurning BestAvailable Control Measures states that the methods for reducing the amount of emissions generated from agricultural burning include: reducing the acres burned annually, alteringthe fuel distribution, improvingfiringtechniques, andbumingunderoptimumfuel moisture.40
4.2 Non-burning Altematives and Annual Emission Goals Annual emissiongoals, underthis Policy, areestablished annuallyandapplyto theupcoming year's projects where fire has been previously determined as the best tool for meeting specific land managementobjectives. Therefore, this Policymakes adistinctionbetweenthoseERTsthatareused with fire and those techniques that replace fire (i.e., non-burning alternatives, sometimes grouped withERTs)41 Forpublic lands, non-burning alternatives thatreplace fire are typicallyconsidered in long-tennprogrammaticplans anddo notcoincidewith annual operational plans forfire 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 managementdecisions for federal land managers and possibly otherland managers are made years in advance ofactual projectimplementation and for multi-yearperiods, underlong-tennland managementplans orprojectplans. Theseplans, andthe supportingNEPA analyses, aretheprocess under which alternatives to burning and levels ofmanagement application offire 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 thatcannotbeadequately addresscd onanoperationalbasis, which is the focus ofthe application ofERTs for annual emission goals, as dcfined by the Policy. Although specificprojects may also gothrough aNEPA analysis during which non-burningalternatives may

39NWCG'S Smoke Management Guide For Prescribed And Wildland Fire, 2001 Edition (hereafter referred to as "200I Smoke ManagementGuide"), pages 143-151. 40 EPA'5 Prescribed Burning Background Document and Technicallnfofmation Document for Prescribed Burning Best Available Control Measures, September 1992, (hereafterreferred to as "EPA's BAeM Documcnt"), p. 9-13. 41 Sec the Glossary In Appendix A for the definition ofnon-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 ofnon-burning alternatives specific to annual emission goals, as defined in this Policy. 19be assessed, again, these are typically done well in advance ofthe 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 ofresidue for use offsite with no subsequent on-site burning) in land managementand fire management plans orotherequivalentlong-tenn plans. The use ofnon-burning alternatives is one ofthe key elements ofthe enhanced smoke management program as definedbythe WRAPESMPPolicy. Further, theWRAPencourageseach state/tribe to work cooperatively with land managers to develop ways to identify, implement, and track all feasible non-burning alternatives42 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 onAgricultural**Land~** in the Western UnitedStates identifies potential non-burning management alternatives for agricultural burning including methods for assessing the impacts of alternatives. The WRAP's draft Comprehensive Manual onNon-BurningAlternatives provides a catalogueofaltemativestoprescribedburningonwildlands, includingariskversusbenefitdecisionmakingprocess related totheuseofalternatives. Althoughtheseguidancedocuments areuseful for identifying non-burning alternatives, methods for calculating the benefits ofusing non-burning alternatives arenotuniversally available for the WRAP region. 4.3 Determination ofAppropriate ERTs The opportunity for the application ofERTs varies greatly. The 2001 SmokeManagementGuide states, "ERTs vary widely in their applicability and effectiveness by vegetation**ty~e,** burning objective, region ofthe country, and whether fuels are natural oractivity-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 applicabilityofaparticulartechniqueorpracticewill depend, inpart, on theobjectives ofthatburn. For example, the objective ofa prescribed burn on wildlands may be to create open space for wildlife. A backing fire, which is afiring technique that is used to reduce the amountofemissions generated, maynotproduce 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 waterqualityon othervaluable resources. Therefore, itis imperative thatERTs areused 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. '3200I Smoke Management Guide, p. 141. 204.4 Feasibility Criteria The use ofERTs should be based on economic, safety, technical and environmental feasibility criteria, aswellas landmanagementobjectives. TheWRAPrecommends thateducationandtraining are also included as feasibility criteria. Itis imperative thateducation and training are provided to ensure that ERTs are used appropriately. All ofthe above criteria will affect the application of certain ERTs for vegetation orcrop types, burning objectives, and area in the WRAP region. Examples ofhow to apply the feasibility criteria are listed below. Economic: What are the economic costs ofapplying 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 ofERTs 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 ofthe fire, i.e., keeping the fire within certain boundaries? Do certain ERTs minimize the possibility ofnuisance and hazard smoke? Technical: Are the equipment and resources available to utilize a specific ERT? Are sufficient training programs available in the use ofERTs for the land managers? Environmental: Are there specific airquality and non-air quality environmental limitations (e.g., vegetation/crop type, fire type, timeofyear, areain WRAPregion, soil compaction, waterquality, etc.) that influence the use ofcertain ERTs? LandManagementObjectives: Is acertainERTnotfeasible due toconflicts with landmanagement objectives? Do certainERTsmaximizethelikelihoodofachieving the land managementobjective ofthe burn? 4.5 Existing Guidance Documents Several guidance documents provide information on the use and effectiveness ofvarious 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 HACMDocumentprovidesinfonnationonERTsforbothwildlandandagriculturalburning. The HACM Document is one of the best comprehensive references on potential ERTs for agricultural burning. Most ofthe WRAP states do not have agricultural smoke management programs, so the demand for additionalresearch isminimal. 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. 21The 2001 Smoke Management Guide presents information on the use and effectiveness ofERTs,**fr~quency** of specific ERT usage, and qualitative assessment ofemission reductions achieved throughthe use ofERTs. Themajority oftheinfonnation presented in theGuidewas gathered from fire practitioners atthreenational workshops held during the fall of1999. Muchoftheresearch into ERTs and subsequentemissions 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 aregion-wide basis. Included in the assessmentwas percentageof feasible use ofERTs for these wildland vegetation and fire types, with the emissions reduced as a result ofthe use ofERTs also evaluated. 4.6 Research Needs ERTs have beenproventoreducefireemissions throughdocumented research, butmoreresearchis needed to make them a more quantifiable tool for land managers. The 1999 Air Quality Policy on Agricultural Bumingemphasized this factby stating, "Emissionreduction technologyto reducethe impact ofpollutants emitted from agricultural burning on ambient concentrations is needed,,46 The identification ofcommon ERTs for agricultural burning is a difficult task since most ofthe 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 ofERTs 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 outsideofthe Pacific Northwest. 4.7 Calculation ofAverted Emissions According to the 200I Smoke Management Guide, "The overall potential for emission reductions from prescribed fire depends on the frequency ofuse ofemission reduction techniques and the amount ofemission 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 ofemission reduction that each method offers. Consume 2.1, a fuel consumption andemissions model, can beused to estimatepotential emissionreductions thatmaybeachieved by

45 Pacific Northwest Research Station, Forestry Scienees Laboratory, Consume Software, Version 2.1. 46AgriculturalAirQualityTask Force's (AAQTF) AirQualityPolicy on Agricultural Burning,Recommendation to the U.S. Department ofAgriculture,November 10, 1999. 472001 Smoke Management Guide, p. 152. 22employing certain ERTs4S The WRAP recognizes the need for amore comprehensive guide forestimatingpotential emission reductions achieved through the use ofERTs for agricultural burning and wildland fire. This guidance will be developed by the WRAP in a similar format to that ofAppendix 0 to support states' andtribes' use ofannualemission goals. Appendix0 provides atablethatlists ERToptions thatcanbeappliedby land managers and thecorrespondingemissions avertedbyusing aparticular ERT. The 200] Smoke ManagementGuide contains several tables that may be useful to states/tribes in orderto establishannual emission goals. Thetables include information onthe frequency ofuse of specific ERTs by region ofthecountry, the general effectiveness ofspecific ERTs, the significant constraintslimitingthewiderapplicationofERTs, and thepotential emissionreductions thatmaybe achieved byemploying variousERTs as estimated by Consume2.1. Thereare some limitations to theinfonnationcontainedinthe200I SmokeManagementGuide, as somevegetation types thatare found in the WRAP region arenot included. Thesetables shouldbeutilizedwith theunderstanding thattheeffectiveness ofaparticularERTmay vary considerably. Considering all burning nationally, ifERTs were optimally used, emissions could probably be reduced by approximately 20-25 percent assuming all otherfactors (vegetation types, acres, etc.) were held constant and land management goals were still met49 Individual states/tribes orregions may be able to achieve greateremission reductions than this ormuch less depending on the states' orregions' individual situations.

48OUmar, RogerD.; Reinhardt, TimothyE.; Anderson, Gary; DeHerrera,Paul 1. Consume2.1 User'sGuide. Gen. Tech. Rep. PNW-GTRxxx. Portland, OR: U.S. DepartmentofAgriculture, ForestService,PacificNorthwestResearch Station. 49J.Petersonand B. Leenhouts, "WhatWildland FireConditionsMinimizeEmissionsandHazardousAirPollutantsand Can Land Management Goals Still Be Mel"" (Draft). August 20. 1997. 23

### APPENDIXD Example ofERT & Associated Emission Averted Table (This example demonstrates the future guidance thatwill 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 ERTEmissions = 0.1 Maintenance All Brush, Sage, Total Emissions x Desert Shrub, 0.9 Annual Grass, Perennial Grass

24Appendix State of New Mexico Pollution Prevention Appendix Appendix G: Pollution Prevention Renewable EnergyResources Renewable energy sources, including solar, wind, hydropower, biomass, and geothennal, currently provide less than 1% (or 5.6 trillion BTUs) ofNew Mexico's annual energy needs. The contribution ofrenewable 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 ofconsumption, by sector, for renewable energy in New Mexico. Table 6. Renewable Energy Consumption in New Mexico, 1999* Energv Source Million KWH Consumed Sector 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

Renewable Energv Production by Resource, 1999* Table 7. 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) J19 Million 1.4 (Note4) 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. SouthwestTechnology 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 ofrenewable 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.

NM Regional Haze SIP Proposed 7118103 Page G-ISolar Overview. The position ofNew 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 ofthe 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 theprimary contactwhere 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 ofsolar energy research, development, and demonstration (RD&D) projects involving technologies such as solarthennal 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 ofdomestic energy RD&D, including solarenergy. 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 ofSolar 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 over40,000 active and passive solar systems were installed in New Mexico. When oil' prices fell and the federal tax credit for use ofsolar 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 ofprotecting and maintaining proper access to sunlight. It also includes provisions allowing local governments to create their own ordinances or zoning rules pel1aining to protection ofsolar rights. New Mexico was first among the 50 states to enact a solaraccess 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 solarenergy resources and experiences more than 3,200 hours ofsunshine per year. This results in a range ofsolar energy on a horizontal surface---depending on location and season---ofabout 900 to 2600 BTUs per square foot per day (3 to 8 kilowatt-hours (kWh) per square meterperday).

NM Regional Haze SIP Proposed 7118/03 Page G-2The potential for converting solarenergy 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 ofcrude 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 SantaFe 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 ofthe sun's light and thermal energy has long been recognized in New Mexico. Over $4 million worth ofenergy 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 peryear in utility costs for each home. Although less than five percent ofthe 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 of250 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 ofalternative 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 ofwindows,
NM Regional Haze SIP Proposed 7/18/03 Page G-3sunspaces, 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, solarprofessionals 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. NewMexico State Fair. and New Mexico SolarEnergyAssociation's SolarFiesta. 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 ofresidential 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 SolarBuildings 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% ofhouseholds on the Navajo Reservation, 5% ofthe Jicarilla Apache Reservation, 3% ofZuni Pueblo, 2% ofAcoma 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 largestPY system on Indian lands. It is expected to produce 25,000

NM Regional Haze SIP Proposed 7118/03 Page G-4kWh ofelectricity, save 43 tons ofcoal, conserve I million gallons ofwater, and reduce carbon dioxide emissions by 27 tons peryear. 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 ofsystems eligible for net metering. 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 Centerto create betterconditions 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 Collegealso 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 ofelectricity from wind power plants has dropped to about 3 or 4 cents perkilowatt-hour (kWh), very close to the cost ofpower from fossil-fuel sources. Public utilities across the country and around the world are beginning to include wind in their mix ofenergy sources. In October 2002, the Public Service Company ofNew 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 ofFort Sumner, in Quay and De bacacounties. Jt will be the third largest wind powerplant 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 ofthe power it produces, enough to supply about 90,000 homes.

NM Regional Haze SIP Proposed 7/18/03 Page G-5PNM plans to ask state regulators for approval ofa "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 orcommits to buying power from a new facility, it looks notjustat currenteconomic 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 ofpower 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 ofPNM's overall generation capacity, which is the portfolio's peak potential output. However, because ofthe intennittent nature of wind, the facility is expected to comprise about 4 percent of the energy actually produced by or forPNM overthe course ofa given year. The Wind Energy Centerwill 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 oftaxes 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 permanentjobs to be created. This $40 million figure does not include the infusion ofmoney 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 ofwind 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 yearupon request to assist FPL Energy in their evaluation ofpotential sites. The Wind Power Program is continuing detailed wind energy resource assessment ofthe most promising sites for commercial development. The potential for electricity generation from wind is enonnous in some areas ofNew Mexico, especially on the eastern plains. New Mexico ranks twelfth in wind electric potential and is among twelve states in the midsection ofthe country that, together, have 90% ofthe total commercial wind electric potential in the contiguous United States. The annual wind energy potential ofNew 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 aposition to export wind electric power.

NM Regional Haze SIP Proposed 7/18103 Page G-6ECMD 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 ofwind speed data collected at six promising sites. Three years ofdata have been provided for two of those sites. Monitoring ofan additional seventh site on Argonne Mcsa, southwest ofSanta Rosa, was commenced in August 2002. Such data are vital to commercial development ofwind power plants because they allow accurate estimates ofpowerplantproduction. ECMD's Wind Power Program has provided studies ofthe potential cconomic benefits ofwind power operations to five counties: Colfax, Eddy, Lea, Otero, and Quay. The results ofthese 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 Powerin 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 ofthe state using the latest techniques. Several pieces oflegislation 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 ofone 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 ofEnergy and Sandia National Laboratories. The purpose ofthe 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 ofeconomical 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.

NM Regional Haze SIP Proposed 7/18/03 Page 0-7Second, 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 ofwind 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 otherDOE 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 ofand access to the resource are critical to the economical use ofbioenergy. For this reason the creation ofbioenergy is often found at the point ofavailability ofa waste stream, with a facility's size detennined by that stream. Wood burning for heating is perhaps the most traditional use ofbioenergy in New Mexico, and this continues to be the largest use. The other common use of bioenergy in New Mexico involves the production ofmethane from municipal wastewater sludge. This fuel is then bumed to heat the digestion process, and in some cases to also generate electricity for operation ofthe plant. Resources andProduction 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 competitorwith the timberproducts industry. This is equivalent to about 3.6 x 

### 10'2 BTU. Albuquerque and Las Cruces are using the anaerobic digestion ofmunicipal wastewater sludge to generate methane gas. The gas then fuels the production ofelectricity and heat to power the wastewater facilities. Los Alamos and Carlsbad are using the resulting methane to heat the

NM Regional Haze SIP Proposed 7/1 8/03 PageG-8digesting process and/or water. Several sawmills burn waste wood to provide heat for wood drying kiIns. 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 ofthis 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. RecenlDevelopmenl 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 ofa small (5-15 kilowatts electricity; 50 kW ofuseful 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 oflumber mill residues and forest thinning for fueling bioenergy projects in SilverCity and Angel Fire. Rapid growth ofthc New Mexico dairy industry has greatly increased the availability ofmanure 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 ofusing 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 ofDona 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-9Hurley 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 ofTechnology, 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 ofgeothennal 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 270jobs. One ofthe largest geothermal aquaculture facilities in the nation is also located in New Mexico, in the Animas Valley south ofLordsburg. 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 ofany geothermal electric generation plants ofcommercial 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-IODona 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 BurgettFloral 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. RecentDevelopments 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 ofa 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 providingtechnical assistance and information for geothermal development in the state.
Summary ofNew Mexico's Total Energy Sales, Generation Capacity and Production Public Service Company ofNew Mexico

NM Regional Haze SIP Proposed 7/18/03 Page G-IIPNM providesjurisdictional retail electric service to a large area ofnorth 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 PNMOperatingStatistics-NewMexico

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-Kreport found at: http://www.see."ov/Arehives/edgar/dara/I]084?6/0001 10842602000015/000] 108426-02-0000I5.lXt b 3/ 2002 D 

## c PNMGenerafJn afJacilv- ecem er PlantName Location Capacity-Net Fuel Source %, ofTotal Capacity by (meeawalts) Fuel Source San Juan Waterflow, NM 765 MW Coal Coal: 67% FourComers 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 ofgas-fired capacity, bringing its total available capacity to 1,653 MW. PNM Electric Plant Ownership: San Juan-PNM owns 50% ofUnits 1,2,3; and 38.5% ofUnit 4 FaurCamers-PNM owns 13% ofUnits 4,5. Palo Verde-PNM owns 10.2% ofUnits 1,2,3 Source: U.S. Securities and Exchange Commission, 1O-K Report for the yearending December31, 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 ofretail kWh sales by sector are shown below (in thousands ofkilowatt-hours):

NM Regional Haze SIP Proposed 7/18/03 Page G-12ElPaso OperatingSlatistics-Texas andNew 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 ElPaso Generating Capacity-December 31, 2002 PLANTNAME LOCATION Capacity-Net FUELSOURCE % ofTotal Capacity by (mecawatts) Fuel Source FourCorners 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: FourCorners-El Paso owns 7% ofUnits 4, 5. Palo Verde···-EI Paso owns 15.8% ofUnits 1,2,3 Source: U.S. Securities and Exchange Commission, IO-K Report for the yearending December 31,2002. Southwestern Public Service Company/Xcel Table 13. SPS/Xcel OperatingStatistics-Texas andNew 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 71t8/03 Page G-I]SPS/Xcel Generating Capacity-December31.2002 PLANTNAME LOCATION Capacity-Net FUEL SOURCE % ofTota] 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°;', PlantX 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 forthe ycar ending December31, 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 ofNew Mexico; this arrangement continues through December 31, 2006. Purchased Power Costs. During 2002, TNP's consolidated average cost per Kilowatt-Hour (kWh) ofpurchased power was 4.05 cents per kWh. In 2001, prior to retail competition, TNP's average cost ofpurchased power was 4.58 cents per kWh.

TNP Operating Stafislics-Texas andNeVi' 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!22767/000093066I0300 I293/d1Ok.hlm

NM Regional Haze SIP Proposed 7/18/03 Page G-14RegionalModelingAnalysis The WRAP AirPollution Prevention Forum commissioned the ICF Consulting Group to analyze the potential emission reductions, costs, and secondary regional economic impacts ofmeeting the 10/20 goals and energy efficiency recommendations (lCF, 2002). The analysis of this case incorporates the results ofthe 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 ofnitrogen (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 ofSO, 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 ofutility 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/t8/03 Page G-15MTF, 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

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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

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293

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128 1(,
27.010 Ik

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NM Regional Haze SIP Proposed 7IJ8103 1,057,674 1,511,694 2,663,616 656,277 567,147 294.759 233

.. '<:;09 PageG-17MTF 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 NOxemission changes in the airpollutionprevention 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-18Renewable Resource Potential Maps New Mexico Biomass Potential (from Renev.'able Energy Atlas of the West, Land and Water Fund ofthe Rockies, DATE)



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NM Regional Hne SIP Proposed 7/1 8/0) Page G-21Renewable Energy Genera/ion andConsumption in New Mexico Ne,w Mexico produces 684 MW ofelectricity. Ofthis total, 0.66 MW are produced from wind energy. Renewable energy generation is less than one percent oftotal 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 percentofNew 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 10/20goals ofthe 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

Preparedby: The WESTAR Council

Prepared for: The Air Managers Committee, Western Regional AirPartnership

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, AlaskaDepartment ofEnvironmental Conservation; Mike Sundblom, Arizona Department ofEnvironmental Quality; Deb Wolfe, MontanaDepartment ofEnvironmental Quality; DanaMount, North DakotaDepartmentofHealth; Dave DuBois, New Mexico Environment Department; Colleen Delaney, Utah DepartmentofEnvironment Quality; Alan Newman, Washington Departmentof

Ecology; LisaReiner, QuinaltIndian Nation; Bruce Polkowsky and Kristi Gebhart, National Park Service; and Kristin Gaston and Bob Lebens, WESTAR.
Prepared for: The AirManagers Committee ofthe Western Regional AirPartnership in fulfillment ofthe Western Governors' Association contract#30203-13

May 2003Acknowledgements 

### The recommendations regarding the attribution process, the applicable technical approaches and the examples in 

### this reportare the product ofthe RA BART Phase 11 Working Group. The WESTARCouncil acknowledges the generous supportofall the Working Group members. Alice Edwards, AlaskaDepartmentofEnvironmental Conservation; Mike Sundblom, Arizona Department ofEnvironmental Quality; Deb Wolfe, Montana Departmentof Environmental Quality; DanaMount, North Dakota DepartmentofHealth; Dave DuBois, New Mexico Environment Department; ColleenDelaney, Utah DepartmentofEnvironmentQuality; LisaReiner, QuinaltIndian Nation; Bruce Polkowsky and Kristi Gebhart, National ParkService; andKristin Gaston and Bob Lebens, WESTAR. Authors ofthe AttributionTechniques (Section VI) are Mike Sundblom (Monitoring); Kristi Gebhart (ReceptorModeling); and Dave DuBois (Source Modeling), with assistance from Ajith Kaduwela, CaliforniaAir Resources Board. Bruce Polkowsky and Colleen Delaney drafted the certification section and provided liaison betweenthe Western Regional Air Partnership MarketTradingForumand the Working Group. Alan Newman, Washington DepartmentofEcology drafted the portion ofthe reportoutlining the example process to which DanaMount also contributed. Kristin Gaston drafted the regulatory context section and along with Bob Lebens, edited the report.

### EXECUTIVE SUMMARY This reportrecommends a general procedure and applicable technical approaches that may be used by states and tribes to assess reasonable attribution in response to aFederal land manager (FLM) certification ofvisibility impairmentin a Class Iarea (Certification). WESTARfonned the Reasonably Attributable Best Available RetrofitTechnology (RA BART) Phase II Working Group with Federal land management agency staffand members of state and tribal airquality agencies knowledgeable aboutRA BART and associated monitoring and modeling techniques. Toprovide the necessary framework, the reportprovides background infonnation about both the certificationprocess and the attribution detennination process. However, the recommendations focus on the general principles ofthe attribution assessment process and the technical criteriaused in the assessment. The recommendations are summarized below: General Principles: The attribution assessment should be:

o Acollaborativeprocess thatrelies on existing data with minimal additional analyses.

o Technically and legallydefensible.

o Accomplished at areasonable cost and within areasonable time frame.

o No more complex than necessary.

o Perfonned by state ortribal agency staff.

o Adequate to determine whetherornot 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 orcontribute to" visibility impairment. Visibility-impairing pollutants ofconcern must be identified. Factors toconsider in assessing impairment include: duration, frequency, geographic extent, magnitude, and time ofoccurrence. Identifydistance 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 ofimpairmentas practicable rather than relying on a single indicator. Consider level ofuncertainty in the assessment. Use EPA guideline models wheneverpracticable.

### Table ofContents



### I. Background I
A. Introduction and Purpose B. Regulatory Context 

### II. Federal LandManagerCertification 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 BestAvailable RetrofitTechnology (RA BART) is the portionof EPA's visibility rule published in 1980 and codified in 40 CFR51.302-51.306 that deals with visibility impacts from one source or a small groups ofsources. RA BARTrefers to reasonably attributable visibility impainnent and best available retrofittechnology for eligible sources and emission limits, and emissions controls as defined by the statute and the rules. Some confusion exists regarding the application ofRA BART, the process ofassessing sources ofvisibility 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 orinstalls BART-like controls oraftera state implements atrading 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 documenthow 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 areahas visibility problems differing from the regional visibility impairmentconditions at otherareas. 

### In addition, RA BART is effective when BART-eligible sources in the vicinity ofthe protected area are causing orcontributing to identified visibility impainnent2 First, this reportrecommends attribution process principles and assessment techniques a state ortribe may consider in an attribution assessment to identify if, and to whatdegree, an existing source or small group ofsources causes orcontributes to visibility impainnent. The report focuses on RAVI and does not specifically address impairmentdue to regional haze. Although this report includes references to regional haze, such references serve only to place the attribution process in the largercontextofthe broad regulatory framework that addresses visibility impairment, including the regional haze regulations. Second, this report includes no recommendations with regard to establishing athreshold 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 ifan 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 ortribe should select from the techniques summarized in Section IV. Section IV(CJ includes five examples ofthe attribution assessment process, each providing arange oftechniques to be used

I WESTARCouncil, RA BARTandRA BART-like Case Studies, June 2001. 2This 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 thatmay require additional data Third, this report includes specific infonnation about the current policy ofFLM agencies regarding certifications ofimpairment (Certification), butmakes no recommendations regarding the certificationprocess. This reportmakes no recommendations regarding stateprocess following an attribution determination norexamines options for perfonning the BestAvailable RetrofitTechnology (BART) analysis orthe incorporation ofBARTrequirements into State ImplementationPlans (SIPs). 

### TribalImplementation The recommendations inthis document are intended to help states assess reasonable attribution following Certification by an FLM. Subject to the requirements ofthe Clean AirAct, 42 USC 7601(d) and the Tribal Authority Rule, 40 CFR49.1-49.11, a tribe may accept responsibility for making reasonably attributable detenninations in response to aCertification by an FLM when aBART-eligible source identified by the FLM in the Certification is on the tribe's land. Theregional haze rule also explicitlyrecognizes the authority oftribes to implementthe provisions ofthatrule ontribal lands. Thoseprovisions createthe following framework: I. Absent special circumstances, reservation lands are not subject to statejurisdiction. 2. Federallyrecognized tribes may apply for and receive delegation offederal authority to implementCAA programs (including visibility regulation), or "reasonably severable" elements ofsuch programs. The mechanism for this delegation is aTribal Implementation Plan (TIP). A reasonably severable element is one that is not integrally related toprogramelements thatare notincluded inthe plan submittal, and is consistent with applicable statutory andregulatory requirements. 3. Where a tribe does not seekdelegation through aTIP, the Environmental Protection Agency (EPA), as necessary and appropriate, will promulgate aFederal Implementation Plan (FlP) within a reasonable timeframe to protectairquality on tribal lands. Accordingly, these recommendations also may assist afederally recognized tribe that chooses to adopta 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 othercases, however, the recommendations may be modified to meetthe unique situation ofthe tribe and the nature ofits airprogram, including its mannerofdefining "reasonably severable elements" and its method ofdividing responsibilities between the tribe andEPA. Because ofthese differences, the recommendations that follow do not referto tribes every time states are referenced. 

### B. 

### Regulatory Context The national goal for visibility is set forth in the Clean AirAct (CAA) at42 USC 7491: "the prevention ofany future, and the remedying ofany existing, impairment ofvisibility in mandatory Class IFederal areas which impainnent results from manmade airpollution." The requirements apply to 156designated Class Iareas.



### 2As stated previously, Congress required that states provide aremedy 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 ofemissions causing orcontributing to visibility impainnent, and requirements for the application ofBART on such sources. EPA promulgated rules pursuantto 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 reportrefers to a "source" within the meaning ofthis regulation, the phrase "ora small group ofsources" is implied.) The requirementto install BestAvailable RetrofitTechnology controls on existing sources is akey elementofthe visibility protection provisions in the CAA demonstrating the need to focus onpollution emitted from a specific set ofexisting sources. Sources are potentially subject to BART controls ifthey meetthe following criteria: 1. A major stationary source from I of26 source categories identified in the CAA and regulations (see Appendix A); 2. Potential to Emit (PTE) 250tons per year ofany air pollutant; and, 3. Not in operationpriorto August 7, 1962 and "inexistence" on August7, 1977. In the 1980 visibility rule, EPA used the tenn "existing stationary facility" to define a facility that metthe above criteria. However, to avoid any confusion about whetherthatterm encompassed a largergroup ofsources, EPA now uses the tenn "BART-eligible source." The tenn "BART-eligible source" is used throughout this report for similar reasons, butthe reader should be aware that some sections ofthe visibility rule still refer to "existing stationary facilities." Forpurposes ofthe attributiondiscussion 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 ofmiles, and therefore, regional haze must be addressed as a broaderregional issue. The 1980visibility rule focused on direct visibility impacts ofan individual source or small group ofsources. The 1999 revisions are commonly referred to as the regional haze rule, although the 1999rule incorporates the earlierrequirements for BART as well as the new regional haze provisions. To remedy RAVI, the regulations outline aprocess 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 managercertifies impainnent; 2. The state identifies existing sources thatcause orcontribute to the visibility impairment; and

3

### 3. The state perfonns aBART analysis to detennine whatcontrols, ifany, are required on any existing source that meets the BART criteriaand has been identified as contributing to the impairment. AllributionProcess The language of40 CFR 51.302(c)(4)(i) provides the basic principle upon which the state will rely during the attributionprocess. That section states thatthe attribution mustindicate each [BART-eligible source] "which may reasonably beanticipatedto cause orcontribute to impairmentof visibility."Whetherornot the impainnent is "reasonably attributable" is detennined by "visual observation orothertechnique the state deems appropriate." (40 CFR 51.301(s)). Because the state is responsible for identifying sources, this reportprovides recommendations for the state to considerwhen itundertakes an attribution detennination. Once visibility impairment is identified, RAVI is addressed on acase-by-casebasis. Under the 1980 regulation, a state evaluates BART-eligible sources only after an FLM certifies the existence ofvisibility impairment. However, in the context ofthe current**re~ional** 

### haze rule, states must also address BART requirements for regional haze (RH BART). Several options existfor addressing RH BART. For example, ratherthan require asource-specific BART emission limit, a state may choose to develop atrading program, eitherregionally orwithinits ownjurisdiction, that achieves greater reasonable progress than case-by-caseRH BART. Ifa state develops atrading program, the time period to achieve the emissions reductions may be extended. As aresult, visibility conditions at a specific Class Iarea initially may remain static or even deteriorate during the early implementation period. During this time, FLMs have indicated thatthe RAVI process may beutilized to provide steady and continuing improvement in visibility. Within the contextofthe regional haze rule, this may be an example ofa "geographic enhancement." As noted above, the recommendations in this report apply only to case-by-case applications ofBART and are not intended to apply to the broaderregional haze rule such as amarket-based trading program implemented as part ofthe 1999 rule. A state may find it difficult to detennine a source/receptor link forRAVI 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 whatcontrols, 

## if any, are required After the attribution detennination, the state is required to perfonn aBART analysis to detennine what types ofcontrols, ifany, should beplaced onthe source(s) found to be contributingto the impairment. The following factors affect the BARTdetennination: 1. Available technology; 2. Costs ofcompliance; 3. Energy and non airquality environmental impacts ofcompliance;

3 The RH BART provision was remanded to EPA by the U.S. Court ofAppeals as aresult ofthe ruling inAmerican Com GrowersAssociation v. EPA, No. 9901348 (DC Cir. May 24, 2002)
4

### 4. Remaining useful life ofthe source; and, 5. Degree ofimprovement thatcan be anticipated to result from the use ofthe controls. As noted above, this rep0rl does notprovide guidance regarding stateprocess following an attribution determination nordoes itexamine options for implementing the BART requirement.

56

### II. FEDERAL LAND MANAGER CERTIFICATION OF IMPAIRMENT The Federal land managers monitor visibility through anationwide monitoring network, known as Interagency Monitoring ofPROtected Visual Environments (IMPROVE). The IMPROVE networkhas 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 overtime 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 influencedby 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 BARTunder 51.308 No distinction exists between emission reductions needed to address RH BART and reductions to address RAVI, therefore, the BARTprocess will address both types ofvisibility impairment. 2. Trading Program under 51.308 The FLMs anticipate thatthe following screening criteriamay 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 similarto 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 otheraspects ofthe trading program. Potential Screening Process Criteria: (i) Sulfate, nitrate, organic carbon, otherfine particulate, etc., levels in the Class I area are not decreasing.4 (ii) One ormore BART-eligible sources ofS02, NO" VOC, PM 10, etc., 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 pollutants thatcontribute to visibility impainnent. 3. Milestones and Backstop Trading Programunder 51.309 The FLMs plan to sign a MemorandumofUnderstanding (MOU) with the participating states to define the screening criteriathe FLMs will use to certify impainnent.

4 The decrease orapollutant (or secondary species ofthat pollutant) would be measured from the beginning ofthe market oremissions tradingprogram, and such atrading program would take along time (10 to 15 years) to reach the level ofreduction that "meets" BART. The decreasewould be tested over the first 5 to 10 years. A very quick lime frame for reductions would negate the need for RA BART criteria.

7Screening Process criteria;5 (i) Sulfate levels in the Class I area are not decreasing. (ii) One ormore BART-eligible sources ofS02are 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: ForFLMs to complete the certificationprocess between 2006 and 20086 These criteriawere influenced by the design ofthe 309 trading program including emission reduction estimates, shape ofthe declining emission cap, inclusionofsources that were not BART-eligible, and inclusion ofnew source growth under the cap. Although geographic enhancements do not need to be addressed underthe first approach, they mustbe addressed in the two trading programs described above because emission reductions may occurmore gradually in the contextofa trading program. TheFLMs do not anticipate certifying impainnent underthese circumstances but do intend to notify the state as partofthe SIP development process ifconcerns arise regarding "hot spot" impacts from sources that may directly affect specific Class I areas. 

### Note: BARTforregionalhaze has been addressedforSOl underthis option. Regionalhaze BART forNO, andPMwill be addressedin SIP revisions thataredue in 2008. In all three cases discussed above, ifthe FLM detennines that a certification ofvisibility impairment is necessary, theFLM will send an official Certification to the state. The Certification will generally include the following infonnation: 1. Class Iarea(s) impacted; 2. Basis ofcertification (photographic documentation, monitoring, modeling, etc.); 3. Type ofimpairmentcertified: plume impact, or layered orunifonn haze; 4. Pollutant(s) ofinterest; and, 5. Preliminary identification ofsource(s) believed responsible for impact. 

### FLM, State, andEPA roles in RA BART FLMs are responsible for certifying impainnent. The Certification demonstrates the FLM's detennination that there is evidence ofvisibility impainnent from one source or a small group of sources.

;Ii Within thecontext ofestablished regional mileslOnes for S02 and abackstop tradingprogram, the FLMs have said it isappropriate 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 ofthe Grand Canyon Visibility Transport Commission. Submittedby 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 ofthe FLMs to eertify impairment ata laterdate ifit is necessary to fulfill theirstatutory obligations. ibid.

8Following the Certification, states have the following regulatory obligations: (1) identify facilities that "emitan airpollutantwhich may be reasonably anticipated to cause orcontribute to any visibility impainnent" in that Class I area, and (2) for sources subjectto BART, the state mustidentify the BART level ofcontrol technology. Ifthe source does nothave adequate control in place, the state mustestablish a BART limit in the SIP. EPA has two majorresponsibilities for the RA BART requirement. First, in the states that do nothave 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 thatinclude RA BART regulations, EPA will provide federal enforcementofstate-established BART emission limits.

910

### III. THEATTRIBUTION DETERMINATION PROCESS This section recommends aprocess for the state to follow in orderto complete an attribution detennination afterreceiptofaCertification from an FLM under40 CFR 51.302(c)(l).
The Certification focuses on the existence ofvisibility impainnent. While the FLM may identify sources oreven sources areas thatcontribute to the Certification, the fonnal identification ofsources is a state responsibility. The state should make adetailed review ofthe data supporting the Certificationto detennine which sources or source areas require further evaluation. Ifthe dataare insufficientto identify specific sources or source areas, the state may requestthat the FLM perfonn more detailed analyses to further substantiatethe impairment setforth in the Certification. Ifthe state detennines sufficientinfonnation exists to proceed, the state should beginthe process by: (1) evaluating which sources are BART-eligible, and (2) reviewing the impainnent infonnationprovided bythe FLM in supportofthe Certification. 1. 

### Evaluate which sourcesareBART-eligible Congress and EPA establishedcriteriato detennine which sources are subjectto BART. The categories ofsources subjectto BARTare listed in 40 CFR 51.301, the definition of"existing stationary facility," and also are included in Appendix A ofthis report. The state mustconfinn that the potential source orgroup ofsources is subject to the RA BART process by examining the potential source emissions and the dates ofoperation. The criteria for detennining ifa source is BART-eligible may be complicated ifa source has multiple units that were constructed at different times and a state may be unable to detennine ifa 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 ifa source is BART-eligible8 These guidelines are expected to bere-proposed in 2004, promulgated in 2005 and codified at40 CFRPart51 as Appendix Y. The state should referto both sets ofguidelines to detennine ifa 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, orother similardatabases.

7 U.S. Environmental Protection Agency, Guidelinesfor DeterminingBestAvailableRetrofit Technology/or Coa/- firedPowerpions ondOtherExistingStolionory Focilities. EPA-450f3-80-009(b), Office ofAirQuality Planning and Standards, Research Triangle Park, N.D., November 1980 (1980 BART Guidelines). '66 FR 38108 ProposedGuidelinesforBestAvoilable Retrofit Technology (BART) (July 20, 2001). EPA will repropose these guidelines as aresultoflhe remand inAmerican Corn Growers v. EPA.
II1. 

### Ifadatabase ofPotential To Emit (PTE) is not available, state emission inventories can be auseful screening tool to detennine whether a source meets the size criteria (for example, identify all sources with emissions greaterthan 100 tons/yearof visibility impairing pollutants). Operating pennitapplications may also contain infonnation aboutthe PTE ofa source, orindividual units within a source. 2. Statebusiness records may beuseful to determine when the facility was constructed orwhen itcommenced operation. Newspaper article searches oradetailed historical review ofeach source may also provideuseful infonnation. 3. The state should require the source to provide infonnationregarding the construction dates ofindividual emissionunits. 4. Institutional memory within the air agency can be invaluable ifrecords of constructiondates ofmajoremissionunits are not available, although memories will notwithstand legal challenges like hard documentary data. 5. New Source Review pennitting records may beuseful to identify new units thatwere constructed after 1977, detennine the PTE ofthe source, ordetennine if reconstruction has occurred. (Note: the draft guidelines in Appendix Y statethat modifications at a source do not affect applicability unless the change qualifies as reconstruction ofthe source). Ifthe source orgroup ofsources identified in the Certification is not BART-eligible, the state should infonn the FLM ofits finding. The state should look inthe vicinity ofall the sources suspected ofcausing orcontributing to the impaimlent identified in the Certification. Ifno BART-eligible sources exist, an attribution assessment is unnecessary. 2. ReviewSupportInforlllation 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 ifthe infonnation is sufficient to supporta reasonable attribution detennination. The state should considerthe type ofimpairmentin the Certification: (a) plume impact visibility impairment, (b) unifonn haze visibility impainnent, or (c) layered haze visibility impainnent: (a) Plume impactis the impainnentaddressed by the original visibility protection program underwhich the state must make a reasonable attribution detenninationbeforeproceeding 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 aBART-eligible source. Ifa state can successfully demonstrate there is a source emitting any air pollutantthatmay reasonably be anticipated to cause or contribute to any impainnentofvisibility, the state should considerthatportion ofthe uniformhaze to be impactfrom the identified source(s) and, therefore, considerthe source to be subjectto BART. (c) The visibility impainnentmay also bedefined as layered haze, a conditionthat results when aerosols are "trapped" under stagnant airmass conditions.

12Once the FLM has issued a Certification, the responsibility for the attribution assessment shifts to the state. Ifa state does attribute impainnent to a source, the state mustbe able to defend its finding that one ormore BART-eligible sources did cause orcontribute to visibility impairmentin the Class Iarea. However, the Ninth Circuit CourtofAppeals established alow threshold for unacceptable visibility impainnent9 

### 3. EvaluateExistingData notincludedin the Certification When analyzing supporting data, the state should determine ifadditional infonnation exists that was not available to the FLM. Examples include special projectcamera studies orambient monitoring data collected by the state or local airpollution control agency, thepotential oractual PSD pennitapplicant, 10orthe university. In certain situations, another agency may have previously collected infonnation thatcould be used in an attribution detennination.', These data should be reviewed to detennine whetherthey supportthe FLM Certification. To conclude this portion ofthe attribution process, the state may wish to prepare areportthat summarizes its initial evaluation ofthe Certification. The purpose ofthe report is to carefully documentthe 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 thatpotentially contributed to visibility impainnentas described in the Certification. The report would contain a preliminary detennination ofwhetherthe sources are BART-eligible and, ifpossible, analyze each source's relative contribution to the impairment (based on available source/receptor information). Second, the report would assess the impairmentdata. This assessment would include the state's evaluation ofthe supporting data in the Certification and an analysis ofany additional dataused 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. Ifthe state believes the Certification is supported by sufficientdata, proceeds with an attribution assessment and makes a detennination thatthe data does ordoes not indicate asource subject to BART, the attribution process is complete. However, ifthe state detennines thedata is insufficient to complete an attribution assessment, the evaluation process ends, and the state may proceed to the next step---identification ofdata gaps and the studies necessary to obtain this infonnation.

, See CentralAriz. Water Conservation Distv. EPA. 990 F.2d 1531 (9th Cir. 1993): See also discussion in RA BART andRA 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 smellerhas been traeed by its arsenic deposition. Ifthis were an active facility, this ground tracing ofthe plume could be used to support a source/receptor connection in an attribution dClenninatioll.
13

### 4. Identify datagaps andnecessarystudies tofillthegaps As partofthe datareview, the state should note gaps orinconsistencies in the available data. Examples ofdata gaps and inconsistencies may include: I. Missingphotos in a sequence ofphotos, 2. Poorresolution ofthe plume orits source in the photos, 3. Back trajectory analyses done with a very large grid resolution orpoortechniques, 4. IMPROVE monitordatamissing atcriticalperiods, 5. Lack ofassociation betweenthe source's emissions and monitored dataat the receptor, 6. Special studies performedduring atime when a source thatpotentially contributed to the impairmentwas notoperating, 7. Contemporaneous studies with contradictory results thatcannot be explained, 8. Ambient studies thatuse naturally occurring tracers and, when the suspected source(s) are tested, the tracers do notexistorexistat levels far below (orabove) the level indicated by the ambient study results, 9. Tracer studies where the tracerwas not found at the anticipated receptors, 10. No explicitexploration ofwhether wildfire orothernatural events significantly caused orcontributedto one ormore ofthe impairment episodes, II. Otherdifferences 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 ofthose studies. The amount of work necessary will depend on the availability ofthe information and how critical the infonnation is to theattribution assessment. Section IV provides technical criteriaand examples ofthe technical process the state may considerat thispointin the process. 

### 5. Consultation Process The WESTARreview ofprevious RAVI assessments demonstrated the importance of including all stakeholders in the design ofany datacollectionplans ormodeling protocols. Competing studies can be very inefficient, expensive, and time-consuming, andultimately may not help the state make a final decision. Ifstakeholders are involved in the design ofany datacollectionefforts ormodeling protocols, disagreements may be resolved before the state or source continues with any additional studies. The state shouldconsiderinvolving the following stakeholders in the consultation process: I. 

### Affected sources 2. Neighboring states andtribes 3. Environmental Protection Agency 4. Federal land managers 5. Local environmental groups 6. Local permitting agencies

147. Local government representatives 

### 6. Completion andReviewof Additional VisibilityStudies 

### When the additional visibility studies, ifany, are complete, the state shouldevaluate the resulting data. The technical staffmay wish to finalize the report and makerecommendations based on the scientific aspects ofthe data. 7. FinalDeterlllillation of ReasonablyAttributable VisibilityImpairment 

### 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 impairmentcertified 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 datato supportadetermination thatthe impainnent is due to the source(s) identified by the FLM; 4. The impairment is reasonably attributable to otheradjacentBART-eligible sources for specific pollutants; or 5. The impairmentcertified by the FLM is notreasonably attributable to aBART-eligible source.

1516

### IV. GENERAL PRINCIPLES AND CRITERIA This sectionprovides general principles and technical criteriafor the state to considerafter receipt ofan FLM Certification. Afterreceipt ofsuch a Certification, the state mustdetermine whetherBART-eligible sources "emit any airpollutantwhich may reasonably be anticipated to causeorcontribute to any visibility impairmentin any" Class I area. While these principles and technical criteria should generally be useful and applicable, each state mustdecide what is required to supportits individual determination. PartA contains general principles to guide the developmentofa conceptual framework for the attribution assessmentprocess. PartB contains evaluation criteriato guide the decisions regarding a technical framework for the attribution assessment process. Conceptually, the statutory framework for anattribution detennination ("may reasonably be anticipated to cause orcontribute to visibility impairment") should be the general principle guiding the attribution process. EPA maintains, and the Ninth Circuit agreed, thatan affinnative attribution decision is possible even with considerable uncertainty and a low triggering threshold. However, each state should decide individually what is required to supportits determination. A. GeneralPrinciples of theAI/ribation Process Attributionprocess criteria address factors likely to influence the perfonnance ofthe state attribution assessment. These criteriaprovide parameters to define and implementthe attribution assessmentprocess given resource constraints, legal considerations, administrative decisionmaking requirements, and otherrelevantfactors. The general principles include the following: I. Wheneverpossible, an attribution assessment should be acollaborativeprocess that relies on existing data with a minimum ofadditional 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. Pastexperience has shown thatcompeting technical studies oftenresult in an unnecessarily expensive and unduly complicated process. 2. Attribution assessments should be technically and legally defensible. 3. Attribution assessments should be accomplished at areasonable 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 ofperforming the attribution assessment and making the final detennination, although contractors may be used for certain types ofmodeling or monitoring. 5. Reasonably attributable visibility impairmentcan only be identified ifa source/receptor

17

### links apotentially BART-eligible source or small group ofsources to aClass Iarea. B. Technical Criteria The technical criteriaaddress the appropriateness ofavailable analytical techniques from a scientific perspective. The rule defines visibility impairmentto mean "any humanly perceptible change in visibility (lightextinction, visual range, contrast, cOloration) from thatwhich would have existed undernatural conditions." The technical criteriainclude the following: I. The BART source mustemitan airpollutantthatmay reasonably be anticipated to cause orcontribute to any ofthe impairment The visibility-impairing pollutants of concern mustbe identified. 2. The attribution assessment should address the unique visibility impairment in the FLM Certification for the Class Iarea. Some factors to consider include:

a. Duration: source's length ofeffecton visibility perepisode;" b. Frequency: how oftenepisodes ofimpainnentoccur;

c. Geographic extent: how much ofthe Class Iareais affected by the impainnent; d. Magnitude: how much visibility impainnent is due to the source's emissions; and

e. Time ofoccurrence: including time ofday and time ofyear. These factors need to be considered together, because they affecteach other. An infrequentoccurrence ofa large magnitude episode may meet the criteria. A frequent occurrence ofa small magnitude episode may also meet the criteria. The FLM may provide infonnationaboutthese criteriain the Certification, and the state should review this infonnation as a starting point for its assessment The state may considerother factors and data, as appropriate. 3. The attribution assessment should identitY the distance from the source to the Class I area. This distance will affectthe choice oftools appropriate for characterizing the specific source's impacton visibility impairment 4. To the extentpossible, the attributionassessment should be quantitative. Undercertain circumstances, qualitative infonnation, such as photographs or time-lapse video of distinctplumes or source-specific haze events, may be adequate. 5. The state should use as many approaches or indicators ofimpairmentas practicable

12 Based on previouscases, most impairment episodesare relatively short-lasting one to several hours-which may affectmonitoring and other assessment techniques.
18ratherthan relying on a single method. The assessmentmay rely on airmonitoring and modeling techniques and other supporting scientific data. Consistency between source and observational techniques strengthens the analysis.'3 6. The state should considerthe level ofuncertainty in the assessment. 7. EPA guideline models should be used wheneverpracticable. When othermodels are used, additional technical discussions with EPA may be necessary. 

### C. Examples of theAttributionProcess The state should consult this section afterevaluation ofthe FLM Certification. Atthis point, the state will already have decided what gaps need to be filled to complete the attribution assessment. The recommendations in this reportrecognize thateach attributiondetennination will be unique. Because an attribution detennination is afact-specific and individual detennination, it is notpossible to recommended a single technical approach for a state to follow. Acombination of monitoring and modeling techniques is usually appropriate, but instead ofattempting to cover all possible combinations oftechniques, this reportprovides five selected scenarios. The general principles and technical criteriaidentified in sections A and B are incorporated into these scenarios. The goal is to provide the state with references for use when itis creating its own individualizedtechnical procedure. In addition to the scenarios, this report provides detailed tables and narrative descriptions of techniques thatmay be considered and/or substituted for the techniques in the scenarios (see Section V). Scenario 1: Limited data/one source Datainput Small amount ofexisting 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, acombination ofthe following techniques is suggested: I. Examine IMPROVE data, including quality assurance 2. Look atextinction budgetto identify visibility-impairing pollutants 3. Perfonn some analysis ofwhen the episodes are occurring 4. Perfonn asimple backtrajectory analysis using a method such as HYSPLIT 5. Look atrelationships betweenparticulate 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 BARTalldRA BART-like Case Studies, June 2001.
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### 8. Examine otherdata such as source ownerdata, deposition data, or photographic evidence The results ofthis initial analysis may not always be conclusive. This level ofreview may be adequate ifa sourcelreceptorrelationship canbe identified. However, ifthe results are inconclusive, more data and/ormore refined analyses may be necessary and may help the state reach an attribution determination. The state should considerhow the available data and choice oftechniques might affect its ability to assess the effectiveness ofthe controls in remedying the impairment. It

### may be efficient to lookahead to the dataand analytical needs ofa potential BART analysis. Forexample, the state may wish to use amore refined model that would be useful for both attribution and remedy assessment. Assuming there is a two-year time period14 

### to collectdata and analyze additional infonnation, the following techniques also canbe considered: I. 

### Bettersource characterization, including measurement ofemissions oftrace elements (source profiles) foruse in CMB modeling 2. Metmonitoring ormodeling 3. Camera site, possibly with time-lapse video 4. Additional aerosol monitoring, episodic or saturation 5. 

### Inplume trajectory by aircraft, ifavailable 6. Fine time-resolved optical monitoring, such as nephelometer, transmissometer, aethelometercombined with pollutantmonitoring (e.g., S02, 

### NOx, real time PM) for monitoringofepisodes 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 ofconcern should be identified. Techniques: Backtrajectory, species relationships, relationship between source emissions and ambientmonitoring, dispersion model refined by camera, aerosol, in plume, optical monitoring, and refined dispersion models. 2. The attribution assessmentmustaddress the unique visibility impainnentcertified 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. Ifan FLM eertifies RAVI at least 6 months prior to aplan revision, section 51.302 requires that the State Plan revision address such Certifieations. Given this 5-ycar cycle, we have presumed for this report thatan attribull0n analysis should take about twoyears to complete in order to allow time for the BARTengineering analysis, ifneeded.

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### the FLM for the Class Iarea. Some factors to considerinclude:

a. Duration: source's length ofeffectper episode Techniques: Monitoring, dispersion model, back trajectory, camera b. Frequency: how often the impairmentoccurs Techniques: Monitoring, dispersion model, back trajectory, camera

c. Geographic extent: how much ofthe Class Iareais impaired Techniques: Monitoring, dispersion model, additional dataon deposition and other studies d. Magnitude: how much impainnent is due to the source Techniques: Dispersion model, receptormodel

e. Time ofoccurrence Techniques: Monitoring, dispersion model, back trajectory, camera 3. Uncertainty ofresults:Each analytical method will have its own level ofuncertainty. These individual uncertainties should be kept in mind as outputs are comparedwithin the overall assessment. Ifthe results ofdifferent techniques are the same orsimilar (within the uncertainties ofthe techniques), then the overall level ofuncertainty is likely to 

### decrease. Scenario 2: Moderate data/multiple sources Data input: Moderate amount ofexisting data (i.e., one IMPROVE site with data for six or more years) Evidence ofan increasing trend in sulfate Meteorological data likely from several stations Assuming the Certificationidentifies multiple BART sources ofdifferenttypes within a 100- mile radius, acombination ofthe following techniques is suggested: I. Examine IMPROVE data, including quality assurance 2. Lookatextinctionbudget to identify visibility-impairing pollutants 3. Perfonn some analysis ofwhen the episodes are occurring 4. Perfonnmultiple back trajectory analyses using amethod such as HYSPLIT 5. Lookat relationships betweenparticulate species 6. Examine source emissions data for correlations with ambientmonitoring 7. Perfonndispersion model based on data and capabilities such as CALMETICALPUFF 8. Examine otherdata such as sourceownerdata, deposition data, orphotographic evidence 9. Wind fields/Synoptic analyses 10. Comparison ofdifferentepisodes II. UNMIX, PMF and/orCMB

21

### 12. Analysis ofany regional modeling already conducted, such as CMAQ 13. Long termvisual monitoring, such as cameradata or transmissometerdata, compared to metdata to identify quadrants ofconcern Theresults ofthis initial analysis may notbe conclusive. This level ofreview may be adequate ifa source/receptorrelationship can be identified. However, ifthe results are inconclusive, more data and/ormore refined analyses may be necessary and may help the statereach an attribution determination. The state shouldconsider how the available datamight affect the ability to assess the effectiveness ofthe controls in remedying the impairment. Itmay be efficient to look ahead to the data and analytical needs ofa potentialBART analysis. Forexample, the state may wish to use amore refined model that would beuseful forboth attribution andremedy assessment. Assuming there is atwo-year time period to collectdata and analyze additional information, the following techniques also canbe considered: 1. Emissions inventory 2. Analysis ofanested domain within the regional model 3. Source profiles (natural tracers) 4. Additional source measurements, such as stack testing 5. Metmonitoringormodeling 6. Camera 7. Additional aerosol monitoring, episodic or saturation 8. Monitoring to measure additional parameters, such as precursors, ammoniaand oxidants 9. In plume trajectory by aircraft, ifavailable, to characterize plume chemistry 10. Fine time-resolved optical monitoring, such as nephelometer, transmissometer, aethelometercombined withpollutantmonitoring (e.g., SO" NOx, real time PM) 

### for monitoring episodes. 11. Repeat initial techniques with new data The technical criteriaare listed below, followed by techniques thatmay be used to obtain results aboutthe criteria. I. The impainnentmust be related to emissions from specific sources. The visibilityimpairing pollutants ofconcern should be identified. Techniques: Backtrajectory, species relationships, relationship between source emissions and ambientmonitoring, 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 Iarea. Some factors to considerinclude:

a. Duration: each source's length ofeffect perepisode

22

### Techniques: Monitoring, dispersion model, backtrajectory, camera b. Frequency: how often the impairmentoccurs by source Techniques: Monitoring, dispersion model, backtrajectory, receptormodel, camera

c. Geographic extent: how much ofthe Class Iareais impaired Techniques: Monitoring, dispersion model, additional data on deposition and other studies d. Magnitude: how much impainnentis due to each individual source Techniques: Dispersionmodel, receptor model

e. Time ofoccurrence Techniques: Monitoring, dispersion model, backtrajectory, camera Scenario 3: No IMPROVE data, Certification by modeling evidence Data input: Detailed modeling ofa source and specific visibility impairmentusing a CALPUFF run, ordetailed (nested) run ofregional model. Detailedemissions data and meteorological datawere input to 

### the model. No IMPROVE data available for this specific Class Iarea (monitoring may be at a "representative site") Some optical data, photographic data, and limited aerosol data from other networks Assuming theCertification points to a specific source, acombination ofthe following techniques is suggested: I. 

### Examine IMPROVE datafor any nearby Class Iareas (especially those included in the modeling domain) to betterunderstand 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, orotheraspects ofthe model which may create the unique impact) 3. Review source emissions dataused in the model 4. Review othermonitoring data (optical measurements, deposition data, ozone data, etc.) to collaboratemodel predictions 5. Examine any photographic evidence Theresults ofthis initial analysis may not always be conclusive. This level ofreview may be adequate ifa source/receptorrelationship can be identified. Because no visibility-specific particle monitoring is available in this case, the key to attribution is to detennine thatthe source emissions are indeed reaching the Class Iarea on days when impairment exists. Ifthe results are inconclusive, more dataand/ormore refined analyses may be necessary and may help the state reach an attribution determination. The state shouId consider ifthe available dataand modeling information supplied with this Certification could be used to detennine the effectiveness ofthe



### 23controls in remedying the impairment. It may be efficient to look ahead to the dataand analytical needs ofapotential BART analysis ifadditional 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 ormodeling 3. Camera 4. New aerosol monitoring (episodic or saturation) 5. In plume trajectory by aircraft, ifavailable 6. Repeat initialanalytical techniques with new data The technical criteria are listed below, followed by techniques thatmay be used to obtain results about the criteria. I. The impainnentmust be related to emissions from specific sources. The visibilityimpairing pollutants ofconcern shouldbe identified. Techniques: Confirm model inputs, compare with any new particle monitoring at Class 1 area. Examine perfonnance ofthe model, and perfonnuncertainty analyses. 2. The attribution assessment must address the unique visibility impainnent certified by the FLM for the Class 1area. Some factors to consider include:

a. Duration: source's length ofeffectperepisode 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: New monitoring and examination ofdispersion model outputs, additional dataon deposition and other studies d. Magnitude: how much impainnent is due to the source Techniques: Dispersion model

e. Time ofoccurrence Techniques: Monitoring, dispersion model, back trajectory, camera Scenario 4: Direct Photographic Evidence Data input: The FLM certified impairment in a wilderness areabased onphotographic evidence. Photographs takenover aperiod oftwo years showed a distincthaze in a valley located in the wilderness area when the wind is from the east. A series ofphotographs during two episodes showeda distinctplume that

24originates 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 distinctplume 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 sitedoes 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 whetherthe photographs show a clear connection between the source and the haze documented in the wildemess area. 

### In this example, the photographic evidence showed aclearconnection between the source and the haze in the wildemess area. Qualitative information, such as photographic evidence that establishes a sourcelreceptorlink, is allowed underEPA regulations thatdefine reasonable attribution as determined by "visual observation or othertechnique the State deems appropriate." (40 CFR 51.301 (s)). The results ofthis initial analysis may not always be conclusive. Ifthe photographic evidence is not compelling, the state may reach adifferent conclusion. The state may detennine that the impainnent, as documented by the FLM, was notreasonably attributable to the source identified in the Certification. The FLM would then need to gather additional infonnation to support a Certification. Alternatively, ifthe state detennines that the source may be causing the haze but the qualitative evidence is not quite sufficientto detennine attribution, the state could initiate adata collection effort to provide better information regarding visibility impairment at the Class Iarea. Such techniques may include: I. Better source characterization, including measurement ofemissions oftrace 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, ifavailable 5. Fine time-resolved optical monitoring, such as nephelometer, transmissometer, or aethelometercombined with pollutantmonitoring (e.g., S02, NOx, real timePM) for monitoring ofepisodes. 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 ofconcem should be identified. Techniques: Backtrajectory, species relationships, relationship between source emissions and ambient monitoring, dispersion model refined by camera, aerosol, in

25

### plume, optical monitoring, andrefined dispersion models. 2. The attribution assessmentmust address the unique visibility impainnent certified by the FLM for the Class Iarea. Some factors to consider include:

a. Duration: source's length ofeffectper episode Techniques: Monitoring, dispersion model, back trajectory, camera b. Frequency: how often the impainnentoccurs Techniques: Monitoring, dispersion model, backtrajectory, camera

c. Geographic extent: how much ofthe Class Iarea is impaired Techniques: Monitoring, dispersion model, additional data on deposition and other studies d. Magnitude: how much impainnentis due to the source Techniques: Dispersionmodel, receptormodel

e. Time ofoccurrence Techniques: Monitoring, dispersion model, back trajectory, camera 3. Uncertainty ofresults:Each analytical method will have its own level ofuncertainty. These individual uncertainties should be keptin mind as outputs are comparedwithin the overall assessment. Ifthe results ofdifferent techniques are the same or similar (within the uncertainties ofthe techniques), then the overall level ofuncertainty is likely to decrease. The final step in the attribution process scenario would be to veritY that the source was operating on thedays whcn the haze was observed in the area. The state should also detennine if the source was experiencing unusual upsetconditions during the times identified. Inthis example, the source was detennined to have been operating nonnally. The state wouldthen issue adetennination that the visibility impairmentatthe Class Iarea was reasonably attributable to the existing stationary facility. Scenario 5: Data 

### Rich Data input: A large special visibility study recently was conducted. Four months ofdata spanning two seasons was collected including: I. 

### Atone "receptor" site in aClass I area there were multiple meteorological, optical, and particulate samplers including extensive measurements ofparticle compositions, size distributions, scattering, absorption, light extinction, ions, oxidants, relative humidity, temperature, vertical wind profiles, 

### SOl, photographs, and concentrations offourunique 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-hourparticle measurements in addition to twenty-fourhour samples.



### 26

### 2. This rcccptor sitc has been an IMPROVE site for several years and these data are also available. 3. Atthirty-five other sites in the region, called "satellite" sites there was an IMPROVE Module-A samplertaking daily twenty-fourhour samples which wereanalyzed for fine mass, S, soil elements, trace metals, and elemental H from which organics canbe estimated. The unique tracers were also measured atmany ofthese sites. 4. Aircraft sampling ofplumes from source(s) ofinterestwas conducted. 5. An extensive currentemissions inventory was created. 6. Windprofilers were deployed attwo to three sites in addition to the receptor site. 7. Measurements ofthe chemical composition ofresuspended local dust, smoke from burning local fuels, and emissions from local pointand area sources ofinterestwere collected in orderto create "source profiles" to beused in receptormodeling. Assuming the certification identifies aBART source within 100 miles ofthe Class I area from which aunique tracerwas released, acombination ofthe following techniques is suggested: I. 

### Examine fine particle data, including quality assurance. Use the collocateddatato assess accuracy and precision. The one, six, and twelve-hourdata should average up to match the twenty-fourhourdata and ifreasonable, be used to examine the diurnal cycles in the fine particle concentrations. 2. Lookatthe extinction budgetto identify visibility-impairing pollutants. Because size distributions were measured, the extinction budgetcan be estimated from Mie scattering calculations as well as by using simple techniques that assume bulk scattering and absorption efficiencies. Checkto see ifmeasured scattering plus absorption add up to the measured and reconstructed extinction. 3. Compare the special study datato historical IMPROVE and archived meteorological datato determine the representativeness ofthe study period. 4. Perfonn some analysis ofwhen 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 backtrajectory analyses using HYSPLlT, CAPITAMonte Carlo orATAD. Examine whetherthe trajectories change substantially when the study's wind-profiler data are included. Dctennine whethertrajectories are consistent with tracer concentrations. 6. Look at relationships between particulate species (factoranalysis) to see ifthey identify source types. 7. Look atthe spatial and temporal patterns oftrace elements and the majorconstituents of the fine mass. This may suggestdominant source areas and transportpatterns for different source types. Use EOF analysis to detennine the patterns thatexplainmostof the covariance in the data. Check to seehow well these are reconciled with the back trajectory modeling and the detenninistic modeling. Checkto see ifthe same dominant sources were indicated. 8. Examine source emissions datafor correlations with ambientmonitoring. 9. Performdispersion model such as CALMET/CALPUFF.

27

### 10. Analyze wind fields, synoptic conditions, and satellite photos. Checkto see ifthey were consistentwith more sophisticated meteorological modeling. Look for unusual conditions such as wild fires, hurricanes, stagnationepisodes, etc. Lookto see if modeled and observed cloud patterns were comparable. II. Compare the meteorological and chemical characteristics ofdifferentepisodes 12. UNMIX, PMF and CMB canhelp determine major source types and when they were important. If, atthis point, similar source/receptorrelationships have beenidentified using several different techniques, this level ofreview is adequate. Ifthe results are inconclusive, and there are differing points ofview aboutthe frequency, duration, or significance ofthe attribution to the BART-eligible source, more analyses may be necessary. Oftenin alarge study, measurements are made, butnot immediately analyzed inthe labdue to cost. lfthis is the case, more samples couldbe analyzed. It 

### is unlikely that any additional field monitoring would berequired. The technical criteriaare listed below, followed by techniques thatmay beusedtoobtain results aboutthe criteria. I. 

### The impairmentmustbe related to emissions from specific sources. The visibilityimpairing pollutants ofconcern shouldbe identified. Techniques: Reconstructed particle mass and light extinction including examination of the reconstructions in different sizeranges and at different sites inthe region, analysis ofresponses oflight scattering to relative humidity, backtrajectory analyses, examination ofinter-species relationships compared to measured source profiles, dispersion modeling with sophisticatedmodels such as REMSAD and CMAQ, analysis ofwind fields and dispersion by comparison to measured tracerconcentrations, computeranimation ofspatial patterns ofspecies ofinterest, use ofreceptormodels such as TMBR, DMB, and TAGlT thatutilize unique tracer information, orother receptormodels such as CMB, UNMlX, and PMF that do not require tracer infonnation, butcanuse it. When so many different models canbeused, model reconciliation is usually apartofadata-rich scenario. 2. The attribution assessment must address the unique visibility impairment certified by the FLM for the Class Iarea. Some factors to consider include:

a. Duration: each source's length ofeffectper episode Techniques: Monitoring, dispersion Illodel, backtrajectory, camera b. Frequency: howoften the impairmentoccurs by source Techniques: Monitoring, dispersion model, back trajectory, receptormodel, camera

c. Geographic extent: how much ofthe Class I areais 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: Dispersionmodel, receptormodel

e. Time ofoccurrence Techniques: Monitoring, dispersion model, back trajectory, camera 3. Uncertainty ofresults: In this case, the ability ofa model to predict the observed tracer concentrations is an indicatorofthe model's uncertainty.



### 2930

### V. TECHNIQUES A. Monitoring Introduction This sectiondescribes a variety ofambient airmonitoring methods that, ifappropriate, might be usedto support an attribution analysis. The methods described include those most commonly used inpollution 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 inuse as a part ofnational, state, local, tribal, orprivate ambient monitoring networks. These sites are generally located inurban areas, but those nearthe 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 areaofstudy. The RA BART case studies show additional examples ofthe methods used during source attribution studies. The case studies also show that methods, otherthan ambient monitoring, may be used to supportthe analysis. Existing programs such as CASTNET (dry deposition network), surface waterdeposition 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 ofmeteorological data can range from simple wind, temperature, and relative humidity measurement to an array ofacoustic wind profilers. The complexity ofthe meteorological monitoring program depends on data needs and the availability ofexisting data. As with ambient monitoring, meteorological data may be available at sites located near the study areaand offers reduced monitoring cost.

1. IMPROVE Overview: The Interagency Monitoring ofPROtected Visual Environments (IMPROVE) program is a cooperative measurement effort governed by a steering committee composed of representatives from Federaland regional-state organizations. The IMPROVE monitoring program was established in 1985 to aid the creation ofFederal and State implementation plans for theprotectionofvisibility inClass I areas (156 national parks and wilderness areas) as stipulated in the 1977 amendments to the CleanAir Act. The objectives ofIMPROVE 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-tenntrends for assessing progress towards the national visibility goal; and (4) 

### with the enactmentofthe regional hazerule, provide regional haze monitoring representing all visibility-protected federal class Iareas where practical. Magnitude: Possible when used in conjunction with appropriate analytical techniques. Frequency: Possible whenusedin conjunction with appropriate analytical techniques; Limited by twenty-fourhour sample integration, and one-in-three day sampling frequency. Duration: Possible whenused in conjunction with appropriate analytical techniques; Limited by 24 

### hoursample integration, and one-in-three day sampling frequency. Principle: Twenty-fourhourintegrated filter-based ambientmonitor; Gravimetric analysis for PM2.' (Module D) and PM,o); S from Particle Induced X-ray Emission (PIXE); N03 from ion chromatography (denudednylon filter from Module C); 

### Organic and elemental carbon from Thennal Optical Reflectance (TOR); H 

### from Proton Elastic Scattering (PESA). Uncertainty: All elemental S iffrom sulfate; All sulfate is ammonium sulfate; N03(Denuder efficiency is close to 100%. 

### All nitrate is from ammoniumnitrate); Average organic molecule is 70% 

### carbon; Carbon (organic and elemental) is defined by the analytical method; Fine soil basedon elemental composition; Course mass (PM,o

- PM2.,) consists only ofinsoluble soil particles. Strengths: Regulatory indicator for regional hazerule; Long tenn datarecord in ornearmany federal Class I 

### areas; Extensive network currently inplace. Limitations: Integrated twenty-fourhour sample; one-in-three day sampling interval; Nitrate losses due to volatilization from filter; Notcapable ofdistinguishing between primaryparticulate and atmospherically transfonned particulate. Level ofExpertise Required: Standard operating procedures available for routine operation and maintenance; Chemical analysis mustbe 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 ofatmospheric constituents thatcontribute to visibility impairment. Primary techniques include filter-based aerosol samplers thatcollect samples on various substrates in various size ranges suchas PM2 ., orPM,o. Aerosol monitoring canprovide fme mass concentration, course mass concentration, optical absorption, major and trace elements, organic and elemental carbon, and sulfate, nitrate, and chloride ions. A variety ofmethods are available to conduct filter based aerosol monitoring. Many methods are approved as anEPA reference method, while some are not, but may offervariability thatthe reference method does not.

32Magnitude: Possible when used inconjunction 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 sampleintegration and sampling frequency (daily sampling is possible depending on instrument selected). Principle: The methods used for analyses ofthese filter media include gravimetry (electromicrobalance) for mass; X-ray fluorescence (XRF) and particle inducedX-ray emission (PIXE) for trace elements; Ion chromatography (lC) for anions and selectedcations; Controlledcombustion forcarbon; Gas chromatography/mass spectroscopy (GC/MS) for semi-volatile organic particles; Special measurement needs may include determiningparticle size and morphology through optical and/orelectron microscopy. Strengths: Large network ofurban monitoring available; Filterbased sampling allows for a variety ofchemical/elemental analysis. Limitations: Integrated twenty-fourhour sample; Generally operated on one-in-three orone-insix day sampling interval (daily sampling is possible depending on instrument selected); Not capable ofdistinguishing betweenprimary particulate and atmospherically transformed particulate. Level ofExpertise Required: Standard operating procedures available for routine operation and maintenance; Chemical analysis mustbe 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 differentmethods. Optical measurementofaerosols can be measured using an instrument such as a nephelometer to measure lightscattering (bscat) or aaethelometer to measure light absorption (babs) by aerosols (blackcarbon). Continuous instruments such as TEOM orBETAcanprovide PM 10orPM2.5 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-fourhoursample integration and sampling frequency (daily sampling is possible depending on instrument selected).



### 33Duration: 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 supportNAAQS 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 inClass I area monitoring networks or urban NAAQS compliance networks. 4. CONTINUOUS GASEOUS Overview: A variety ofgaseous 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 airand periodically (as frequently as once per second) analyze the sample. Canister systems collect an ambientairsample over a specific period oftime in clean evacuated canisters. The canisters are then subjectto 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 ormore. Regularchecks ofthe flow rate, stability, reproducibility, precision, and accuracy ofthese instruments mustbe conducted on aregular 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: Datamay be available from established urban area monitoring networks and some Class I area monitoring networks; Additional cost ($/year) for new sites.

34Level ofExpertise 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 overaknown distance (generally between 0.5 km and 10.0 km) between a light source ofknown intensity and areceiver. The transmission measurements are electronically converted to hourly averaged lightextinction (b,,,). Magnitude: Possible when used inconjunction with appropriate analytical techniques. Frequency: Possible when used inconjunction with appropriate analytical techniques. Duration: Possible when used in conjunction with appropriate analytical techniques. Uncertainties: A transmissometermustbe installed in stable locations with a clearand unobstructed path to avoid interference with the signal. Strengths: Continuous measurementofb,,, in many Class I areas and some urban areas. Limitations: Notcapable ofidentitYing pollutants contributing to visibility impairment. Level ofExpertise Required: Standard operating procedures available for routine operation and maintenance; Data processing/quality aSSUranCe requires high level ofexpertise. 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 ofvisual airquality. Scene monitoring dataquality objective recommendations are to document the appearance ofscenes ofinterest underavariety ofairquality and illumination conditions at different times ofday 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 ofascene or source. Magnitude: Cannot provide aquantitative measurement ofvisibility impainnentbutcan qualitatively illustrate various levels ofvisibility impairment.

35

### Frequency: Possible depending on the methodused. Time-lapse video may be able to demonstrate the frequency ofthe impainnent. The use ofstill photography to document impairment frequency depends upon the numberofimages acquired overtime. 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 numberofimages acquired overtime. Uncertainties: n/a Strengths: Provides image/video record Limitations: Notcapable ofidentifying pollutants contributing to visibility impainnent. Level ofExpertise Required: Standardoperating procedures available for routine operation and maintenance. Regulatory Context: Commonly used in Class Iarea monitoring networks and in someurban 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. Tracermethods, lidar systems and aircraft based measurements will be described individually. TracerMethods: Atracerelementorcompound is a substance with unique characteristics that allows positive identification atvery low concentrations. The tracercompound ofchoice will vary by source type and composition ofthe plumebeing tracked. In general, the tracermust 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 notpossible due to potential environmental risk, a near-substitute compound may beused. When usedto detennine potential source impacts, the chosen compound is released from a source stackand downwind monitors are usedto detectthe presence ofthe compound. LidarMethods: A lidartransmits shortpulses oflaser lightinto the atmosphere. The laserbeam loses lightto scattering as ittravels. Ateach range, some ofthe light is backscattered into adetector. Because the lighttakes longerto return from the more distantranges, the time delay ofthe retumpulses can be convertedto the corresponding distance betweenthe atmospheric scattererandthe lidar. The end resultis aprofile ofatmospheric scattering versus distance. Analysis ofthis signal can yield infonnation aboutthe distribution ofaerosols in the atmosphere. The amountofbackscatter indicates the density ofthe scatters. This can beusedto measure cloud base heightortrack

36plumes ofpollution. Otherproperties ofthe atmosphere can also be deduced from the lidarreturn signals. A frequency shift in the lightbecause ofthe Dopplereffectpermits measurementof wind speeds. By detecting the amount ofdepolarization, one can discriminate between liquid droplets and nonspherical iceparticles. Differential Absorption Lidar (DIAL) uses absorption, as evidencedby reducedbackscatter from greaterdistances, to measure the concentration of atmospheric gases. ARaman Iidardetects particularatmospheric components (such as water vapor) by measuring the wavelength-shifted return from selectedmolecules (NOAA). AircraftBased Measurements: Aircraftbasedmeasurement systems utilize specially equipped aircraft to make pollutantand meteorological measurements at various elevations throughout the study domain. The aircraft canbe equipped with amultitude ofgaseous, aerosol, optical and meteorological equipment. This measurementmethodprovides the advantage ofvertical profiles ofvarious parameters, the ability to trackpoint 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 TracerMethods, Lidar Aerosol Continuous 35mmfilm/8mm systems, Aircraft based methods, canister video, digital measurements

sampling, etc. Pollutant PM 10 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** ofDay No No Yes Likely Part of Possible No FLM r'ertification?

39Monitoring 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 canprovided

alculation, retwork nephelometer**~ariety** ofpossible provides light**~ncomplicated** emporal and spatial historical rationwide ommonly located inpollutants**~xtinction** pperational esults, tracermethods

ecord prnearClass Iareas**~alue,** equirements canprovide sourceihistorical eceptordata**~ecord** eaknessesl Fixed location ntegrated 24 hour EOM, BETA, etc, penerally require IFixed location !Numberofstill Complex and relatively Limitations n or near Class**~ample** generally pommonly located inf;onditioned 'n ornearClass'mages limited, xpensive to operate, Iareas, also f;ollected on one-**~rban** areas**~nvironment** for areas**~ideo** requires equires specialized ocated in n-three schedule, properoperation, torage and raining and knowledge everal urban f;ommonly in ommonly located outine review o operate and analyze lIreas !urban areas nurban areas esults Distinguish Possible with Ipossible with other!No Possible with other!No Possible with Possible with other BART Sources?btheranalvsis !analysis nalysis otheranalysis nalysis 

### Practical Considerations Cost Moderate; varies depending on the number ofinstruments

### ~ow**~igh**



### 40

### B. SourceModeling
Introd uction Given the complex natural environment, the state must choose the configuration ofmodeling techniques thatwill provide the most information on the contributing source or sources of impairment within the limited resources ofcurrenttechnology, data, budgets, time and staff availability. 

### 1. Physical Models Physical models are those that simulate the meteorology and airquality over an area. Modeling relies on a numerical or analytical model to estimate particulate concentrations in space and time. Because ofits nature and sources, particulate matter is difficult to model over all spatial scales. Many air quality models that are currently availablewere 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 ofdata 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-orderclosure models (Bowne and Lundergan, 1983). Kinematic models are the simplestboth mathematically and conceptually. These models simplify the non-linear equations ofturbulent motion, thereby pennitting a closed analytical approximation to describe pollutantconcentration (Green el aI., 1980). First-order closure models are based on the assumption ofan 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-orderclosure models involve a series ofalgorithm 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 receptorresult from the complex interaction ofmeteorology, chemical transformations and emissions from nearby and distant sources. Forexample, a monitor located nearan 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 ofmeters to no more thanonekilometer 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 CFRpart 58.

41

### a. Micro-Scale (10 to 100 m): This scale does not apply to scenarios relevantto the attribution problem. Modeling atthe microscale is usually done by simple Gaussian plume models such as ISCST3. Measurements in urban areas can show considerable variations atthis scale while those in pristineareas would not. Variations often occurwhen monitors are located close to a low-level emissions source, such as abusy roadway, construction site, within acommunity thatuses wood stoves, orashortindustrial 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 significantdifferences between locations that are 

### ---O.! to 0.5 km 

### apart. These differences may occurnearlarge industrial areas with many differentoperations ornearlarge construction sites. Monitors with middle-scale zones ofrepresentationare often source-oriented, used to detennine the contributions from emitting activities with multiple, individual sources to nearby community exposure monitors.

c. Neighborhood Scale (500 mto 4 km): 

### Neighborhood-scale monitors do not show significant differences inparticulateconcentrations with spacing ofa few kilometers. This dimension is oftenthe size ofemissions and modeling grids used in large urban areas for PM source assessment, so this ZOne ofrepresentation ofa monitoris the only one that should beused to evaluate such models. Sources affecting neighborhood-scale sites typically consistofsmall individual emitters, such as clean, paved, curbed roads, uncongested traffic flow without a significantfraction ofheavy-duty vehicles, orneighborhooduse 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 ofkilometers. These monitors represent a mixture ofparticles from many sources within the urban complex, including those from the smaller scales. PM measurements aturban-scale locations are not dominatedby any particular neighborhood, however. Urban-scale sites are often located at higherelevations 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 ofa few hundredkilometers. Backgroundconcentrations are oftenmore consistent for specific chemical compounds, such as sulfate ornitrate, than they are for PM mass concentrations. Regional-scale PM is acombination ofnaturally-occurring aerosol from windblown dust and marine aerosol as well as particles generated in urban and industrial areas thatmay be more than 1,000 km 

### distant. Regional-scale sites are best located in rural areas away from local sources, and at higherelevations. National parks, national wilderness areas, and many state and county parks and reserves are appropriate areas for regional-scale sites. Many ofthe IMPROVE sites characterizePM 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 evenwhen they are separated by more than 1,000 km. 

### They are hundreds ofkilometers from the nearest significantemitters. Though these sites measure a mixture ofnatural and dilutedmanmade source contributions, the marunadecomponentis at its minimumexpected concentration. TheJarbidge Wilderness IMPROVE site in northern Nevada is agood example ofacontinental-scale background site forparticulate matterin North America.



### 42e. Global-Scale Aackground (>10,000 km): Global-scale background monitors are intendedto quantifY concentrations transported between differentcontinents as well as naturally-emitted particles and precursors from sea spray, volcanoes, and windblown dust. Yellow sand from China has been detected at the MaunaLoa, HI, laboratory (Darzi and Winchester, 1982; Braaten and Cahill, 1986), as well as onthe North American continent. Red dustfrom Africa's Sahara deserthas been detected atMt Yunque, Puerto Rico and over the southeastern United States. Otherglobal-scale sites include McMurdo, Palmer, and Ahmundson-Scott stations in Antarctica (Lowenthal 

### etaI., 1996), Pt. Barrow, Alaska, and Mace Head, Ireland. 

### 3. Chemical Composition This section illustrates how the chemical composition ofaerosols is an important consideration in the choice ofparticulate mattermodels. The knowledge ofhowthe aerosol's composition varies over an area will playa key role inthe attribution study design. The relative abundance ofchemical components inthe atmosphere closely reflect the characteristics ofemission sources. Majorchemical components ofPM2.5 and PMIO mass in urban and rural areas consistofnitrate, 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. Forexample, on the continental scale, the eastern U.S. fine particulate cbemical compositions are differentthan those ofthe western states. 

### In the easternportion ofthe U.S., nonurbanPM2.5 is dominated by secondary sulfate, organics and elemental carbon (EPA, 1996). The datato support this conclusion are based onthe IMPROVE and CASTNET networks. These networks provide abackground fine-fraction aerosol database because the monitoring sites are primarily located in national parks and wilderness areas. Analysis ofthis network shows thatthe 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 nearthe ocean and urban areas where the aerosol will be primarily influenced by sea saltand combustionparticles, respectively. The typical PM2.5 chemical compositions vary by season (Chow et aI., 1993a; 1996a, Watson et aI., 1997), and consistofthe following majorcomponents: a. Organic Carbon: Organic carbon is composed ofgases and particles containing combinations ofcarbonand hydrogenatoms. Organic compounds found in ambient airmay also be associated with otherelements and compounds, particularly oxygen, nitrogen, sulfur, halogens, and metals. Particulate organic carbon consists ofhundreds, possibly thousands, of separate compounds (Rogge et aI., I993a). The mass concentration oforganic carbon canbe accurately measured, as can carbonate carbon (Chow etaI., 1993b), butonly about tenpercentof the specific organic compounds that itcontains have been measured. Vehicle exhaust (Rogge et aI., 1993b), residential and agricultural burning (Rogge et aI., 1998), meatcooking (Rogge et aI., 1991), fuel combustion(Rogge et aI., 1997), road dust(Rogge et aI., 1993c), andparticle formation from heavy hydrocarbongases (Pandis et aI., 1992), are the major sources oforganic 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 etaI., 1994a, 1998) being the largestcontributor.

c. Sulfate: Ammonium sulfate ((NH4S04), ammonium bisulfate (NH4HS04), and sulfuric acid (H2S04), are the most common sulfate compounds inPM2 . 5.These compounds are water-soluble and reside almostexclusively in the PM2 .5 

### sizefraction. Sodium sulfate (Na2S04) has been found in coastal areas where sulfuric acidhas beenneutralized by sodium chloride (NaCl) in sea sail. Although gypsum (Ca2S04) and some othergeological compounds contain sulfate, these are not easily dissolved in waterforchemical analysis and are more abundant inthe coarse fraction than inPM2 .5; they are usuallyclassified in the geological fraction. d. Nitrate: Ammoniumnitrate (NH4 NO)) is the mostabundantnitrate compound, alarge fraction ofPM2.5 occurs during winter, and amoderate fraction occurs during fall. Sodiumnitrate (NaNO)) is found in the PM2.5 and coarse fractions nearthe oceans and salt playas. Small quantities ofsodium nitrate have been found in summertime particulatematterinlandowing to transport from the ocean (Chow etaI., 1996b).

e. Ammonium: Ammonium sulfate (NH4S04) and ammonium nitrate (NH,NO)) are the most commoncompounds containing ammonium from reactions between sulfuric acid, nitric acid, and ammonia gases. While mostofthe sulfurdioxide and oxides ofnitrogen originate from fuel combustion in stationary and mobile sources, mostofthe ammoniaderives from living things, especially animal husbandry practiced in dairies and feedlots. f. 

### Geological Material: Suspended dustconsists mainly ofoxides ofaluminum, silicon, calcium, titanium, iron, and othermetal oxides. In areas surrounded by substantial terrain (i.e., mountains), eons ofrunoffproduce mineral compositions in soils thatcanbe fairly homogeneous, with the exception ofplaces where dry lake beds exist thathave accumulated salt deposits. Industrial processes such as steelmaking, smelting, and mining have distinctgeological compositions. Forinstance, cement production and distribution facilities may use alcareous, siliceous, argillaceous, and ferriferous minerals that may notbe natural to the region, with limestone (CaCO)) being the most abundant (GreeretaI., 1992). Suspended geological material resides mostly in the coarse particle fraction (Houcket ai, 1989,1990), and typically constitutes -50% ofPMlo while only contributing 5 to 15% ofPM2 .5(Watson etaI., 1994b). g. Sodium Chloride: Salt is found in suspended particles nearoceans, open playas, and after de-icing materials are applied. Bulksea watercontains 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, sodiumchloride is often neutralized by nitric or sulfuric acid in urban airwhere it is encountered as sodiumnitrate or sodium sulfate. h. Liquid Water: Soluble nitrates, sulfates, ammonium, sodium, other inorganic ions, and some organic material (Saxenaand Hildemann, 1997) absorb water vapor from the atmosphere, especially whenrelative humidity exceeds 70% (Tang and Munkelwitz, 1993). Sulfuric acid absorbs some waterordeliquesces at all humidities. Particles containing these compounds grow

44into the dropletmode as they take on liquid water. Some ofthis wateris retained when particles are sampled and weighed for mass concentration. The precise amount ofwaterquantified in a PM,., depends onits ionic compositionand the equilibration relative humidity appliedpriorto laboratory weighing. Ambientmass 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 ofprimary particles are, on average, proportional to the quantities that are emitted. Secondaryparticles are those that fonn in the atmosphere from gases that are directly emitted by sources. Sulfurdioxide, ammonia, and oxides ofnitrogen are the precursors for sulfuric acid, ammoniumbisulfate, ammonium sulfate, and ammoniumnitrate particles. "Heavy" volatile organic compounds orHYOe (those containing more than eightcarbon atoms) may also change into particles. The majority ofthese transformations result from intense photochemical reactions that also create high ozone levels. Secondaryparticles usually form over several hours ordays and attain aerodynamic diameters in the accumulation mode between 0.1 and I /lm. Several ofthese particles, notably those containing ammonium nitrate, are volatile and transfer mass betweenthe gas and particle phase to maintain a chemical equilibrium. This volatility has implications for ambientconcentrationmeasurements as well as for gas and particle concentrations in the atmosphere. Ambientconcentrations ofsecondary aerosols are notnecessarily proportional to quantities ofemissions since the rate at which they fonn may be limited by factors otherthan the concentration ofthe precursorgases. Secondaryparticulate ammoniumnitrate concentrations depend ongaseous ammonia and nitric acid concentrations as well as temperature and relative humidity. Anearby source ofammoniamay cause a localized increase in PM,., concentrations by shifting the equilibrium from the gas to the particulate ammoniumnitrate phase (Watson et aI., 1994c). Ammonium sulfate may form rapidly from sulfurdioxide and ammonia gases in the presence ofclouds and fogs, or slowly in dry air. Because fine particle deposition velocities are slowerthan those ofthe gaseous precursors, PM,., may travel much farther than the precursors, and secondary particles precursors are often found far from theiremissions sources and may extend overscales exceeding 1,000km. 

### 4. Particle Formation Ammonium nitrate and ammonium sulfate aerosols are the mostprevalent secondary particles found aturban 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. Sulfurdioxide 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 thatreactwith a wide variety ofatmospheric constituents. The gas-phase transfonnation rate appears to be controlledmore by the presence or absence of the hydroxyl radical and its competing reactions ofothergases than by the sulfurdioxide concentrations.



### 45

### In the presence offogs orclouds, sulfurdioxide dissolves in droplets where itexperiences aqueous reactions that are much faster than gas-phase reactions. When ozone and hydrogen peroxide are dissolved in the droplet, the sulfurdioxide is quickly oxidized to sulfuric acid. Whenammonia is dissolved in the droplet, the sulfuric acidis neutralized to ammonium sulfate. Ifthe fog orcloudevaporates and relative humidity decreases below 100 

### percent, the sulfate particle exists as a small droplet that includes aportion ofliquid water. As the relative humidity further decreases below 70 

### percent, the dropletevaporates and a small, solid sulfate particle remains. Thereactions within the fog droplet are very fast, and the rate is controlled by the solubility oftheprecursorgases. Aqueous transfonnation rates ofsulfur dioxideto sulfate are 10 

### to 100 

### times as fast as gas-phaserates. These chemical reactions are critical to understanding PM 

### concentrations in areas and downwind ofareas thatemits large amounts ofS02. The location and S02 emissions output oflargepoint sources such as coal and oil fired powerplants need to be mapped and compared with transportpatterns inorder to detennine the impactofammonium sulfateparticles on ambient surface concentrations. Fogs serve as an environment forcreating particles and as vehicles for particle removal. During heavy fogs, particles and precursor gases are scavenged as fog droplets grow to sizes that settlerapidly to the surface. The extentand intensity ofthese fogs is so poorly characterized, however, that it is notyetpossible 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 inthe presence ofultraviolet radiation; 2) 

### change to short-lived species which takeplace in otherchemical reactions; 3) fonn organic nitrates; or4) oxidize to fonn nitric acid. The majorpathway 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 ofammonia, it is neutralized to particulate ammonium nitrate. This is an importantprocess in secondaryparticleproduction because many agricultural areas surrounding populated urban areas contain large ammonia sources. Chow and Egami (1997) show that SanJoaquin Valley ammoniaconcentrations are large during winter. Conversionrates for nitrogen dioxide to nitric acid, ranging from less than onepercentper hourto ninety percent per hour. These rates are typically five to ten times the conversion rates for sulfate fonnation. Though they vary throughout atwenty-fourhourperiod, these rates are significantduring 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 designby the need to locate and map possible sources ofammonia. Significantsources of ammonia are associated with animal husbandry and fertilizerapplications. Locating and estimating ammoniaemissions will be adifficult taskbecause it is not traditionally tabulated in emission inventories and requires further research to refine the methodology to measure the emISSIOns. 

### While ammonium sulfate is afairly stable compound, ammoniuin nitrate is not. Its equilibrium with gaseous ammonia and nitric acid is strongly influenced by temperature and relative humidity. Atmosphericparticle nitrate can occur

### in atmospheric aerosol particles as solid ammoniumnitrate oras ionizedmmnoniumnitrate in aerosol particles containing water. 

### Inboth



### 46the solid and ionized fonns, anunonium nitrate is in equilibrium with gas-phase nitric acid and mnmoma. Forfixed relative humidity, increasing temperature decreases the particle nitrate fraction. This is a consequence ofthedirectrelation between the equilibrium constants and temperature. As temperature increases, the equilibriumconstants increase, which means higher gas-phase pressures can be supported, thereby reducing the particle nitrate fraction. Forfixed humidity, decreasing temperature increases the particle nitrate fraction. As temperatures approach O°C, the curves approach limiting values. Particle fractions ofone are used for ion ratios greaterthan or equal to one, and particle fractions are detennined by the amount ofavailable ammonia for ion ratios less than one. Forthe highertemperatures, increasing relative humidity increases the particle nitrate fraction. This is aconsequence ofliquid waterpresent forthe 60% and 80% relative humidity cases. When there is sufficientammonia present with 30% relative humidity, more than 90% ofthe nitrate is in the particle phase for temperatures less than 20°C. More than halfofthe particle nitrate is gone at temperatures above 30°C, and all ofitdisappears at temperatures above 40°C. Atmospheric wateris another importantcomponentofsuspended particulate matter. The sharp rise in liquid watercontentatrelative humidities between 55% and 75% is known as deliquescence. A precise humidity at which soluble particles take on liquid waterdepends 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 ornitrate makes a much largercontribution to lightextinction when humidities are high (>70 percent) than when they are low «30 percent). Excess liquid water is also measured as partofthe PM2.5 mass when sampled by light scattering continuous monitors orwhen filters have not been equilibrated atrelative humidities less than 30% priorto weighing. Some ofthe 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 carbonparticles are more prevalentthan secondary organics with exceptions such as those found in Los Angeles where conditions ofclear skies and high photochemical smog are frequent. Although secondary organic aerosol was thoughtto be minimal during winterin central California, recent analyses (Straderet aI., 1998) demonstrate that it couldbe as much as 20% of twenty-four hourorganic carbon in some samples. This occurs because low wintertime temperatures lower the saturation vaporpressure for semi-volatile organic compounds. This is probably minorduring winter and fall when photochemical reactions are notdominant. The exact precursors ofsecondary organics are notwell understood, butthey are believed to consistofheavy hydrocarbons with more than seven carbon atoms. Odum (1997) identifies aromatics as the major group ofcommonly measured reactive organic gases that affectboth ozone and secondary aerosol fonnation.

475. Source Modeling Techniques Before selectinga modeling technique, itis wise to establish aconceptual model. A conceptual model describes the relevantphysical and chemical processes that affect emissions. transport, and transformation specific to the region ofinterest. Itis the starting point for any source apportionmentprocess. Conceptual models take advantage ofthe 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 furthermodeling on the conditions conducive to the high concentrations. Modeling techniques relevant to attribution are split into several categories depending complexity, physical attributes, purpose and costto execute. The following tables on pages 55 to 62 provide a matrix ofdetailed information on specific models grouped in these categories.



### a. PuffModeling Techniques These models are based on a Lagrangian framework where airparcels are tracked spatially and temporally. They can include chemical mechanisms as well as deposition effects. The most commonly used puffmodel is the CALMET/CALPUFF (Scire et aI., 2000). b. Grid Modeling Techniques Forestimating 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 eithera simplified treatment ofatmospheric chemistry (usuallyused to address long-tenn particulate concentrations aturban sites) or include a more detailed atmospheric chemistry treatment (usually used to simulate only a few days ofepisodes due to their compositional cost). Commonly used long-term Eulerian models with simplified atmospheric processes include (Seigneuret aI., 1997):

• Urban Airshed Model Version V (UAM-V).

• Urban Airshed Model with version V with LinearChemistry (UAM-LC)

• Regulatory Modeling Systemfor 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 athree-dimensional treatmentto simulate the fate and transport ofatmospheric 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 notinclude the treatmentoforganics (i.e., REMSAD and UAM-LC).



### c. LagrangianTrajectory Model Techniques The advantages ofusing Lagrangian models are the ease ofuse, the ability to performmany trajectories and performbacktrajectories. Commonly used Lagrangian models include HYSPLIT (Draxlerand 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 consistofstraight line, interpolation (termed diagnostic), and firstprinciple (termed prognostic) fonnulations, with increasing levels ofcomplexity and requirements forcomputational and data resources. The straight line model is applied to hourly wind directions from a single monitor, assuming an airmass travels adistance 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 asingle emissions source. Interpolation models integrate wind speed and directions from multiple measurement locations, including upper airmeasurements provide by remote sensors orballoon launches. The more advanced ofthese models allow barriers, such as mountains, to be placed between monitors. Wind fields, therefore, show differentdirections and velocities at different horizontal and vertical positions. Interpolation wind models are applicable to domains with alarge number ofwell-placed monitors and for estimating the movement ofairmasses from many sources over transporttimes ofmore than halfaday. The number and placementofmonitors, especially upper airmonitors, is especially important in mountainous terrain and in coastal areas where winds are unusual. Firstprinciple models (Stauffer and Seaman, 1994; Seaman etaI., 1995; Koracin and Enger, 1994) embody scientists' bestknowledge ofatmospheric physics and thermodynamics, employing basic equations for conservation and transferofenergy and momentum. Also known as "prognostic models," first principle models purportto need no data other than values from a sparse upper airnetwork for interpolation. Theyare computationally intensive, often requiring supercomputers but have become more practical and cost-effective as workstation and desktop computers become more powerful. Modemversions use "four-dimensional data assimilation" or FDDA thatcompare model-calculated wind, humidity, and temperature fields with measurements and "nudge" model outputs toward observations.

49

### A more complex meteorological model is notnecessarily a bettermodel for aspecific application. One ofthe mostwidely used first principle model is the Fifth-Generation NCAR/Penn State Mesoscale Model orMM5 model (Grell etaI., 1995). The MM5 meteorological model has been adopted as the platform for central Californiaairquality studies (Seaman et. aI., 1995). MM5 inputdataconsistofwind 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-metervertical resolution is needed within the surface layer, 30-50mresolution is needed inthe valley wide layer, and 100m resolution is needed above the valleywide layerup to -2000 magi (Watson etaI., 1998). Time resolution is at leasthourly for these measurements. Measurements are needed where large differences are expected, although this is largely unknown for winter. References: Bowne, N.E.; and Londergan, RJ. (1983). Overview, results and conclusions for the EPR! plume model validation and developmentproject: Plains site. ReportNo. EA-3074 PROJECT 1616. Prepared by Electric Powerand Research Institute, Palo Alto, CA. Braaten, D.A.; and Cahill, T.A. (1986). Size and composition ofAsian dust transported to Hawaii. Almos. Environ., 

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### Chow, J.e.; Watson, J.G.; Pritchett, L.e.; Pierson, W.R.; Frazier, e.A.; and Purcell, R.G. (1993b). The DRI Thermal/Optical Reflectance Carbon Analysis System: Description, Evaluation and Applications in U.S. airquality studies. Almos. Environ., 

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### Watson, J.G.; Chow ,J.e.; Rogers, e.F.; Dubois, D.; and Cahill, e.F. (1997). Analysis of historical PMIO and PM,.5 measurements in Central California. Prepared forCalifornia AirResources Board, Sacramento, CA, by Desert Research Institute, Reno, NV. Watson, J.G.; Fujita, E.M.; Chow, J.e.; Zielinska, 8.; 

### Richards, L.W.; Neff, W.O.; and Dietrich,D. (1998). Northern Front Range AirQuality Study. Final report. Prepared for Colorado State University, FortCollins, CO, 

### by Desert Research Institute, Reno, NV. Watson, J.G.; DuBois, D.W.; DeMandel, R.; Kaduwela, A.; Magliano, K.; McDade, e.; Mueller, P.K.; Ranzieri, A.; Roth, P.M.; and Tanrikulu, S. (1998). Aerometric monitoring program plan for the CaliforniaRegional PM2.5/PMIO Air Quality Study. Report No. DRI documentNo. 9801.105. Prepared by Division ofAtmospheric Sciences, Desert Research Institute, Reno, NV.

53

### Source Modeling and BackTrajectory 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? (ifit 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)

55Air 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 oflevels, etc) MM5) prediction) Emission data required (single Multiple point, 

### • • Multiple point Single stack ormultiple 

### • 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 currentdatabases data EDAS); adaptable adequate for the model?) to read in MM5 In Vi 'bT M d 

### r

56Air 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 ofexpel1ise 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 ofmet (Level ofLinux, UNIX, PC programs; DOS and Windows run the program input formats skills required) knowledge of Windows atmospheric Knowledge is needed to ehemistry & interpretresults

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/hysplil.ht ml 

### •

57

### Source Modeling and Back Trajectory Attribution Techniques Table 3. Eulerian Grid Based Modeling Attribution Techniques

AirQuality 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? (Ifit 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-IV chemistry? (ifit 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 oforganic using yields reactions oforganic

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 ormodal) 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

58Air Quality Models (continued)

CalGrid URM UAM-VPM Grid Models UAM-AERO CAMx REMSAD 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),H2OZ ,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, numberoflevels, 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



### 59Evaluation 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 ITB 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 ofexpertise required to run and Considerable 

### • Moderate to Moderate to 

## • • Moderate interpret results (Level ofLinl1x, 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



### 60T h ' A 'b 1M d 

## r T bl 4 M

a e eteoro O!!lca 0 e In!! 

### Un utlOn 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 Urbanto 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 ofepisodic grid size, numberof grid size, number grid size, number grid size, number grid size, number grid size, number grid size, number and annual events species and length ofspecies and ofspecies and ofspecies and ofspecies and ofspecies and ofspecies 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/precipitation 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 usergroups, Yes Yes Yes Yes No Yes Yes listscrvers available when roblcms arise? Costto 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 ofexpertise Moderate Moderate High High High High High required to run and interprct results (Level of Linux, UNIX, PC skills rCQuired) Availability ofuser Ycs Yes Yes Yes No Yes Yes training Is the sourec 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 orreceptormodeling refers to a group ofanalysis techniques in which monitoring data collected at orin the region ofareceptor are analyzed in various ways in order to inferinfonnation aboutthe pollutants and the sources ofthe pollutants causing visibility impairment. These types ofmodels often are used as the first technique for source apportionment in order to get an initial understanding ofthe source-receptorrelationships in aregion. They are also used to verify orreconcile deterministic models, and to aid inplanning intensive monitoring studies. Results ofobservational models can either be quantitative orqualitative. Quantitative results are estimates ofthe fractions ofa measured species thatcan be attributed to a single source or attributed among several sources or source areas. Qualitative results include such infonnation as the wind directions and othermeteorological conditions most associated with high concentrations, or inferences aboutprobable 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 togetherto fonn hypotheses aboutthe important source areas and source types affecting the concentrations at areceptor. Advantages ofreceptormodels are that they are generally quick and inexpensive to runand require relatively little inputdata. Disadvantages include the necessity ofemploying simplifYing assumptions such as linearrelationships and often the results are limited to averages over long periods oftime or large spatial areas. Subjective userjudgmentis required to choose appropriate inputdata and/orinterpret the results ofmany receptormodels. 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 thejudgment ofthe modelerregarding the relationship ofthe individual species to a specific source that detennines that first source is "smoke" and the second is "coal-fired powerplants." Receptormodels could potentially be grouped in several different ways, based on their different attributes. Here they are somewhatarbitrarily 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 aunique 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 transportpatterns.

63

### b. Trajectory Mass Balance

- Regression ofresidence time ofback trajectories in selected source areas againstconcentrations yielding quantitative source attributions. Category 2. Analyses ofInterspecies Relationships a. Chemical Mass Balance (CMB)

- Quantitative source attributions are obtained by a weighted regression ofknown sourceprofiles againstmeasured concentrations ofseveral species. b. UNMIX

- By looking for "edges" in the relationships between species, UNMIX estimates both the sourceprofiles 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. EnrichmentFactors (EF)

- The "enrichment" ofcertain ratios oftrace elements is used to qualitatively infer sourcetypes impacting areceptor. Category 3. Analyses ofSpatial and Temporal Patterns a. Empirical Orthogonal Function Analysis (EOF)

- Analysis ofspatial and temporal patterns leading to qualitative infonnation about locations ofdominant source areas, frequency and timing ofsource impacts and meteorological conditions associated with them. b. ReceptorModel Applied to Patterns in Space (RMAPS)

- With additional assumptions applied to EOFs, quantitative source attributions are estimated. Category 4. TracerAnalyses a. TracerMass Balance Regression (TMBR)

- Tracerconcentrations, possibly weighted by otherfactors, are regressed againstconcentrations ofthe species ofinterest to give a quantitative estimate ofthe contribution from the source that emitted the tracer. b. DifferentialMass Balance (DMB)

- The differential ratios oftracer to pollutant between source and receptor are adjusted based on simple chemistry and meteorology to give an estimate ofthe contribution ofthe tracer source to the receptor. c. Tracer-Aerosol Gradient Interpretive Technique (TAGIT)

- By comparing the ratios of tracer to concentration ofinterestat "background" sites to the ratios at tracer-affected sites, aquantitative attribution ofthe tracer source to the receptoris estimated. Following are brief descriptions ofeach ofthese models and a few references giving further details and examples oftheiruse. lao 

### Qualitative BackTrajectory Residence Time Analyses There are several methods ofstatistically analyzing the relationships between where air masses arrived from and the concentrations measured at areceptor. These include, butare not limited to: I) where was airmost likely to arrive from when concentrations are high; 2) ifair arrived from agiven area, whatis the probability that the concentration at the receptorwas high when the airmass arrived there; 3) what is the mean (ormedian ormaximum or distribution) of



### 64concentrations atthe receptor when airmasses arrived from a given area. Selected References: Ashbaugh etal. (1985), Gebhartet al. (2001), Poirot and Wishinski (1986). DataNeeded: Atime series ofconcentrations ofthe species ofinterest. One ormore back trajectories ofthree to five days duration corresponding to each concentration. Backtrajectories can be calculated by any ofseveral methods including ATAD, Hysplit, the CAPITAMonte Carlo Model, as well as others. Standard National Weather Serviceupper airdatacanbe used as input, though more detailed meteorological data can be inputifavailable. Dispersion can be included in some ofthese models. Model Assumptions: Errors in trajectoryplacement 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 ofanalyses are qualitative ratherthan quantitative. Results are more statistically robust when averaged over long timeperiods, usually aminimum ofone season andpreferably several years. Nearby sources cannot beresolved. User judgmentis required to choose trajectories ofan 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, ratherthan, forexample, 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 amultiple linearregression ofthe frequency ofoccurrence oftrajectory endpoints in each ofseveral source areas againstthe corresponding concentrations at the receptor. The result is the average attribution ofasingle species among up to about 25 source areas overalong time, for example, one season oryear, or several years. Selected references: Gebhartand Maim (1989), Stohl (1998). DataNeeded: Time series ofconcentrations ofthe pollutant ofinterest at a single site. One ormore backtrajectories associated with each concentration. Inputdata forthese are upperair winds, temperatures, and moisture over alarge area. Often data are obtained from the standard National Weather Service observations, but otherdata such as higherresolution wind fields, wind profilerdata specific to a given study, can also be used ifavailable. Emission data can be used ifavailable, butmustvary in timeto be useful. Simple chemistry andlordeposition can be used ifdata are available. The userdefines the size and locations ofthe source areas to be considered. Model Assumptions: Average contributions ofeach source area can be written as alinear combination ofthe contributions from several source areas. Average chemistry and deposition are adequate to explain average source contributions. Errors in backtrajectories are random and nonnally distributed.

65

### Biggest Potential Problems: No attribution to single sources--{)nly to source areas. Attributions mustbe averaged overlong time periods. Nearby sources cannotbe modeled accurately. Subjectivityin choosing source areas. Violation ofassumptions oflinearchemistry. 2a. Chemical Mass Balance (CMB) CMB is amultiple linearregression ofmeasured concentrations againstknown source profiles. It

### is used forthe attributionofall measuredchemical species among several sources for each concentration measurement period for a single monitoring site. Regressions are weighted by the uncertainties inboth the sourceprofiles and the concentrations. Selected References: Watson etal. (1984 and 200I). DataNeeded: Concentrations and measurementuncertainties ofboth the chemical species of interestand ofas many trace elements as possible are necessary for each time period and location for which attributions are desired. IMPROVE datacan be used. A source profile is needed for each source. These are the relative amounts ofeach emitted chemical species andthe uncertainties in these values. Model Assumptions: Compositions ofsource emissions are constantoverthe period of ambientand source sampling. Chemical species do notreact 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 theiremissions characterized. The sources' compositions are linearly independentofeach other. The numberofsources or source categories is less than orequal to the numberofchemical species. Measurement uncertainties are random, uncorrelated and nonnally distributed. Biggest Potential Problems: The model cannotdirectly 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 "secondaryparticles." Itis also possible to use "fractionated" or "aged" sourceprofiles where an attempt is made to pre-determine the chemical processes thatoccurred between SOUrce and receptorand then adjustthe sourceprofile accordingly. Obtaining all necessary SOUrce profiles can be difficult. In some studies, otherreceptormodels have estimated source profiles. 2b. 

### UNMIX Fora selection ofmeasured species, UNMIX uses singular value decomposition with additional non-negativity constraints to estimate the numberofsources, 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 andrelates these to sources. Selected References: Henry (I

### 997a, 1999), Lewis etal. (1998). DataNeeded: A time series ofconcentrations ofseveral species measured at a single site. IMPROVE data canbe used.



### 66Model Assumptions: Concentrations are linearcOlnbinations ofan unknown number of sources ofunknown composition. Contributions from sources are positive. Source compositions are approximately constant in time. Foreach source there are some samples that contain little or no contribution from that source. Biggest Potential Problems: Amaximum ofseven SOurces can be identified. There is some subjectivity in choosing fitting species, number ofsources, how to deal with missing Orbelow detection limitvalues, and which time periods and species should be analyzed together. Sources ofsecondary species will probably violate the assumption ofconstant source composition. This can cause multiple sources to be identified for a single physical source thatimpacts the receptor under differing conditions. Supplemental analysis may be required to deconvolute these. 2c. Positive Matrix Factorization (PMF) PMFuses an iterative weighted least squares method to decompose atime-by-species matrix to estimate the number and composition ofthe sources and the contributions ofeach source to each measured species. It will also calculate errorestimates for these values. Selected References: Paatero and Tapper (1994), Paatero (1997); Xie elal. (1999). Data Needed: Atime series ofconcentrations and theiruncertainties for several species at a single monitoring location. IMPROVE data can be used. Model Assumptions: Concentrations are linearcombinations ofan unknown number of sources ofunknown composition. Contributions from sources are positive. Source compositions are approximately constant in time. Biggest Potential Problems: Correlations in detection limits oruncertainties as well as in concentrations can influence the results. Forexample, PMF may detect positive correlations between species eitherdue to source activity (desirable) ormeasurementprotocol changes (undesirable). 2d. Enrichment Factors (EF) The differences in ratios ofelemental 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/Cahas been linked to Saharan dust, high Br/Pb may indicate lead is linked to autos ratherthan 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 ofconcentrations oftrace elements and the species ofinterest. Some historical information aboutthe "standard" crustal, sea salt, orotherratios for aregion. Model Assumptions: Elemental ratios depend mostly on enrichmentoftrace elements by a source and have less dependence on meteorology. The reference ratios are constant.

67

### BiggestPotential Problems: Attributions are generally to source areas, notto 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 ofameasured species are obtainedby singular value decomposition. Associations between the spatial patterns and source areas and/ortransport ofairpollutants into the study areacan often be inferred, but are qualitative. The original datamatrix 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). DataNeeded: Measurements ofa single airpollutantofinterestat several sites for several time periods. Typically used are concentrations measured atfifteen to forty sites for thirty or more time periods. There mustbemore 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 aphysical meaning that canbe inferred, such as transportofemissions from a source into the study area or local stagnation. BiggestPotential Problems: Source attributions are qualitative, not quantitative and interpretation ofthe spatial patterns is subjective. The model requires a site by time matrix with no missing values, so some method ofeliminating orfilling in both missing and below detection limit values is necessary. 3b. Receptor Model Applied to Patterns in Space (RMAPS) Detennines the average attribution ofa single species among a few source areas by decomposing the time by site matrix ofconcentrations into a source matrix and atime weighting matrix. Similarto UNMIX, the edges in the scatterplots between sources and non-negativity requirements are used to 

### constrainthe identification ofsources. Selected References: Henry (1997 b, c, d), White (1999). DataNeeded: Time series ofconcentrations ofthe pollutantofinterestat several sites within aregion. The model previously has been used in special studies such as ProjectMOHAVE and PREVENT where there are fifteen to forty sites within a one ortwo state region collecting data daily for several weeks ormonths. Model Assumptions: Average contributions ofeach source areacan be written as a nonnegative linearcombination ofthemajorprincipal components ofthe data. The spatial scale of the pollutantis large compared to the spacing ofthe sampling sites. BiggestPotential Problems: Ifthe secondmajor assumption is violated, the concentrations ofthe pollutantateach site will have little correlation with the other sites; therefore the model would not apply because it relies on the common variations among sites.



### 684a. Tracer Mass Balance Regression (TMBR) also called Multiple Linear Regression (MLR) on Marker Species Estimates the attribution ofthe aerosol species ofinterest by a source or source type, which emitted oremits aunique tracer. Uncertainty estimates are also generated ifincluded in the regression. The model is aregression ofthe tracer, possibly weightedby otherfactors against the species ofinteres!. SelectedReferences: MaIm et al. (l989 a, b, c). DataNeeded: Time series ofambientconcentrations and theiruncertainties forthe aerosol species being apportioned and also the tracerspecies. Model Assumptions: The tracer(s) are uniquely emitted by non-overlapping groups of sources. Source emissions are constantoverthe period ofambient 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 berelated to RH, where RH was a surrogate for time the airmass spentin clouds. Measurement errors are random, uncorrelated, and normally distributed. BiggestPotential Problems: Tracerconcentrations are not often available. Source profiles, deposition, and conversion all vary in time and space. 4b. DifferentialMass Balance (DMB) DMB estimates the fraction ofa species ofinterestattributable to a single source thatcan be tagged with aunique tracer. The ratio ofmeasured tracerto measured sulfate ornitrate is assumed to be related to the fractional contribution ofthe traced source. The ratio is adjusted based on the estimated difference between the ratio at the source to the ratio atthe receptor. Travel times between the source and receptor are estimated based on winds, and then by using simple estimates ofdispersion, deposition and oxidation, the tracer to secondary species ratio is adjusted. Selected References: Maim (1989b, c). Data Needed: Time series oftracerconcentrations and concentrations and emission rates of the species ofinterest and its precursors, for example, sulfurdioxide and sulfate. Estimates of wind speed and direction, mixing heights, deposition and oxidation rates. Model Assumptions: Wind direction does notchange during transport time. The rates for deposition and conversion are first-order and invariant in space and time along the transportpath between the source and the receptor. The ratio ofthe emission rates for the species ofinterestor its parent species and the traceris known. BiggestPotential Problems: Simple chemistry and meteorology may notbe adequate, especially for long transport times, complex terrain, and/orchanging chemicalregimes. Tracer concentrations unique to a single source are often not available. The fraction ofattributable concentration may only be calculable to within arange based on the reasonable ranges ofrate coefficients.



### 69

### 4c. Tracer-Aerosol Gradient Interpretive Technique (TACIT) Results are the attribution ofprimary or secondary species associated with the source "tagged" by atracerrelease. TAGITcomputes attributions on a sample period-by-sample period basis. Foreach sampleperiod, background concentration ofthe species ofinterest is determined by averaging the concentrations ofthe species atnearby sites thatdo nothave tracer concentrations and are significantlyabove background. These sites are presumed tobe unaffected by the tracer-tagged source and thus represent the average background. This background foreach sampleperiod is then subtracted from the concentration ofthe species of interestatimpacted receptor sites for corresponding sample periods. The difference is the concentration attributable to the tagged source. Green (200I), Kuhns et al. (1999), Pitchford et al. (2000). DataNeeded: Concentrations ofaunique tracer from a source ofinterest and simultaneous concentrations ofapollutantofinterestat several sites in aregion. Model Assumptions: There is no impact from the tagged source ifthe tracerconcentration is less than the level considered to be "significantly" above its' background. Background concentrations ofthe species ofinterestdo not vary systematically in space. BiggestPotential Problems: Assuming no impact from the tagged source when tracer is not statistically above background can lead to an underestimation ofattribution. Measured tracer concentrations often have large uncertainties. Some sampling periods will have anegative concentration attributed to the tagged source. References: Ashbaugh, Lowell L., 

### William C. Maim, Willy Z. Sadeh (1985) "A Residence Time Probability Analysis ofSulfurConcentrations at Grand Canyon National Park," Atmospheric Environment, 

### 19, 1263-1270. Gebhart, Kristi A., 

### SoniaA. Kreidenweiss, and William C. MaIm (2001) "Back-Trajectory Analyses ofFine Particulate MatterMeasured at Big BendNational Parkin the Historical Database and the 1996 Scoping Study" Science of the TotalEnvironment, 

### 276,185-204. Gebhart, Kristi A. andWilliam C. Maim (1989) "Source ApportiorunentofParticulate Sulfate Concentrations atThree National Parks in the Eastern United States," in Transactions of theA&WMAIEPA Specialty Conference-VisibilityandFineParticles, 

### Estes Park, CO, Oct. 15-19, 1989, pp. 898-913, C.V. Mathai, Ed. Gebhart, Kristi A. andWilliam C. Maim (1997) "Spatial and Temporal Patterns in Particle Data Measuredduring the MOHAVE Study," J. of theAir & Waste ManagementAssoc., 47, 

### 119-135 Green, Mark, 2001 (Informal paper, BRAVOl

70Henry, R.S. (1997a) "History and fundamentals ofmultivariate air quality receptor models," Chemometrics andIntelligentLaboratorySystems, 37, 37-42. Henry, R.C. (1997b) "ReceptorModel Applied to Patterns in Space (RMAPS) Part 1- Model Description"JA&WMA, 47, 216-219. Henry, R.C. (1997c) "ReceptorModel Applied to Patterns in Space (RMAPS) Part 11- Apportionment ofAirborne Particulate Sulfurfrom Project MOHAVE" JA&WMA, 47, 220-225. Henry, R.C. (1997d) "ReceptorModel Applied to Patterns in Space (RMAPS) Part 111- Apportionment ofAirborne 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 numberoffactors," Chemometrics andIntelligentLaboratorySystems, 48, 91-97. Lewis, C.W., R.C. Henry, and J.H. Shreffler (1998) "An Exploratory Look at Hydrocarbon Data from the Photochemical AssessmentMonitoring Stations Network"

### J. Air& Waste ManagementAssoc. 48, 71-76. Henry, Ronald

## c., Vi-Jin Wang, and Kristi A. Gebhart (1991) "The Relationship Between Empirical Orthogonal Functions and Sources ofAir 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," AtmosphericEnvironment, 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 ofthe 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 PieIke, Roger Stocker, and John Watson (1989) "National Park Service Report On the Winter Haze Intensive TracerExperiment" 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 ofsulfurand light extinction using receptormodeling techniques,"Journal of theAir& Waste Management Association, 

### 47, 250-258. MaIm, William

## c., Kristi A. Gebhart, and Ronald C. Henry (1990) "An Investigation ofthe Dominant Source Regions ofFine Sulfur in the Western United States and theirAreas of Influence,"AtmosphericEnvironment, 

### 24A, 3047-3060. Paatero, P. (1997) "Least squares formulation ofrobustnon-negative factor analysis," Chemometrics andIntelligentLaboratorySystems, 

### 37, 15-35. Paatero, P. and U. Tapper (1994) "PositiveMatrix Factorization

- aNonnegative FactorModel with Optimal Utilization ofError-Estimates ofDataValues," Environmetrics, 

### 5, 111-126. Parekh, P.P., B. Ghauri, and L. 

### Husain (1989) "Identification ofPollution Sources of Anomalously Enriched Elements,"AtmosphericEnvironment, 

### 23,1435-1442. Perru, K.D., T.A. Cahill, R.A. Eldred, and D.O. Dutcher (1997) "Long-rangeTransportofNorth African dust to the eastern United States,"J. Geophys. Res., 

### 102, 11,225-11,238. Pitchford, Marc, Mark Green, Hampden Kuhns, and RobertJ. Farber (2000) "Characterization of Regional Transportand Dispersion UsingProject MOHAVE Tracer Data" J. Air& Waste Manage. Assoc. 

### 50: 733-745. (This is notexactly TAGIT, but the 1999 reference may be a conference paper.) Poirot, Richard L. 

### and Paul R. Wishinski (1986) "Visibility, Sulfate and AirMass history Associated with the SummertimeAerosol in Northern Vermont,"Atmospheric Environment, 

### 20, 1457-1469. Roshid, M. and R.F. Griffiths (1993) "AmbientK, S, and Si in fine and coarse aerosols ofKuala Lumpur, Malaysia," Journalof AerosolScience, 

### 24, 597-60I. Stohl, A. (1998) "Computation, Accuracy and Applications ofTrajectories - A Review and Bibliography," AtmosphericEnvironment, 

### 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 ReceptorModel," AtmosphericEnvironment, 

### 18, 1347-1355. Watson, John G., Judith C. Chow and Eric M. Fujita (2001) "Review ofvolatile organic

. compound source apportionmentby chemical mass balance"AtmosphericEnvironment,



### 35, 1567-1584. White, Warren H. (1999) "Phantom Spatial Factors: An Example,"J. of theAir& Waste ManagementAssoc., 

### 49,345-349.

72Xie, Yu-Long, Philip K. Hopke, Pentti Paatero, Leonard A. Barrie, and Shao-Meng Li (1999) "Identification ofSource Nature and Seasonal Variations ofArctic Aerosol by Positive Matrix Factorization,"J. a/theAtmosphericSciences, 56, 249-260.



### 73

### 74

### Table 5. Observational Modeling Techniques Analvses ofBackTraiectories 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 ofResult? 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 ofimoacts? Yes No No V" V., V" Duration ofim aCls? V" No No V., Ves Ves Time ofDay ofimpacts? Depends on particle Depends on particle Depends on particle Depends on Ves Depends on panicle data data data data particle data Time ofYear ofimoacts? Yes Ves V., Yes Ves Ves Appropriate for what source-receptordistances? 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 ofdata on a map software that allows mapping software softwnre that allows package and overlay of overlay ofdatn on a {hat allows overlay overlay ofdata on a graphics and/or dala on a map ofdata on a map mnp mapping mnp software that allows overlay ofdala on a mao EPA Annroved Model? No No No No No No

75

### Observational Modelinl! Techniques(continued) Analyses ofinter-species relationships Analyses ofSpatial and Temporal Patterns Criteria CMB PMF UNMIX Factor Analvsis EOF RMAPS Quantitative Source Attribution? Yes Yes Yes No No Yes Numberofsources that can be Usually < Usually < 7 <Numberofspecies 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 ofimpacts? Yes Yes Yes No Yes Yes Time ofDay ofimpacts? Depends on Depends on Depends on input Depends on input Depends on input Depends on inputdata input data input data data data data Time ofYearofimpacts? 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 ofSecondary 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 singularvalue singularvalue decompositions decompositions EPA Model" Yes No? Yes? No No No



### 76

### Observational Modelin2 Techniques (continued) Analvses ofUnique TracerData 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 1Areas? (See Yes Yes Yes Text for References) Magnitude ofimpacts? Yes Yes Yes Frequency ofimpacts? Yes Yes Yes Duration ofimpacts? Yes Yes Yes Time ofDay ofimpacts? Depends on particulate data Depends on Depends on particulate data particulate data Time ofYear ofimpacts? Yes Yes Yes Appropriate for what source-receptor Urban to Regional Scale Urban to Regional Regional Scale distances? Scale Attribution ofSecondary Species? Yes Yes Yes Costto run? Minimal Minimal Minimal Code Available? No No No Equations and/or algorithms Yes Yes Yes available? ComputerHardware 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 30I ofthe Clean AirAct, (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 ofpreventing any future, and remedying any existing, impairmentofvisibility in mandatory Class IFederal areas which impairment results from manmade airpollution; and to establish necessary additional procedures for new sourcepennitapplicants, States and Federal Land Managers to use in conducting the visibility impactanalysis 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., impairmentattributable to a single source/small group ofsources) and regional haze (i.e., widespread haze from amultitude ofsources which impairs visibility in every direction over a large area). (b) Applicability. (l) General Applicability. The provisions ofthis subpartpertaining to implementationplan requirements for assuring reasonable progress in preventing any future and remedying any existing visibility impainnentare applicable to: (i) Each State which has a mandatory Class IFederal area identified in part 81, subpart0, 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 ofvisibility in any such area. (ii)The provisions ofthis subpartpertaining to implementationplans to address reasonably attributable visibility impairmentare 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, WestVirginia, Wyoming. (3) The provisions ofthis subpartpertaining to implementationplans to address regional haze visibility impairment are applicable to all States as defined in section 302(d) ofthe Clean AirAct (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. 51.30I Definitions. Forpurposes ofthis subpart: Adverse impacton visibility means, for purposes ofsection 307, visibility impairmentwhich interferes with the management, protection, preservation, orenjoyment ofthe visitor's visual experience oftheFederal Class Iarea. This detennination mustbe made on a case-by-casebasis taking into accountthe geographic extent, intensity, duration, frequency and time ofvisibility impairments, and how these factors correlate with (I) times ofvisitoruse ofthe Federal Class I

### area, and (2) the frequency and timing ofnatural conditions that reduce visibility. This tenn does not include effects onintegral vistas.

Agencymeans the U.S. Environmental ProtectionAgency. BART-eligiblesource means an existing stationary facility as defined in this section. Best Available Retrofit Technology (BART) means an emission limitation based onthe degree of reduction achievable through the application ofthe best system ofcontinuous emission reduction for each pollutantwhich is emittedby an existing stationary facility. The emission limitation must be established, on acase-by-casebasis, taking into consideration the technology available, the costs ofcompliance, the energy and nonairquality environmental impacts ofcompliance, any pollution control equipmentinuse orin existence atthe source, the remaining useful life ofthe source, and the degree ofimprovement in visibility which may reasonably be anticipated to result from the use ofsuch technology.

Building, structure, or/acilitymeans all ofthe pollutant-emitting activities which belong to the same industrial grouping, are locatedon one or more contiguous oradjacent propenies, and are under the control ofthe sameperson (orpersons undercommon control). Pollutant-emitting activities must be considered as partofthe same industrial grouping ifthey belong to the same MajorGroup (i.e., whichhave the same two-digitcode) as described inthe Standard Industrial ClassificationManual, 1972as amendedby the 1977 Supplement(U.S. GovernmentPrinting Office stocknumbers 4101-0066 and 003-005-00176-0 respectively).

Deciviewmeans a measurementofvisibility impairment. A deciview is ahaze index derived from calculated lightextinction, such thatunifonn changes inhaziness correspond to unifonn incremental changes in perception across the entire range ofconditions, from pristine to highly impaired. The deciview haze index is calculated based on the following equation (forthe purposes ofcalculating deciview, the atmospheric lightextinction coefficient mustbe calculated from aerosol measurements): Deciview haze index = 

### 10 lllc (b",110Mm") Where be" = 

### the atmospheric light extinction coefficient, expressed ininverse megameters (Mm").

Existingstationary/acilitymeans any ofthe following stationary sources ofairpollutants, includingany reconstructed source, which was not in operationprior to August7, 1962, and was in existence onAugust 7,1977, and has the potential to emit 250 tons peryearormore ofany air pollutant. In detennining potential to emit, fugitive emissions, to the extentquantifiable, must be counted.

Fossil-fuel fired steam electric plants ofmore than 250 million British thermal units perhour heat input,

Coal cleaning plants (thennal dryers), Kraftpulp mills, Ponland cement plants, Primary zinc smelters, Iron and steel mill plants, Primary aluminumore reductionplants, Primary copper smelters, Municipal incinerators capable ofcharging more than 250 tons ofrefuse per day, Hydrofluoric, sulfuric, and nitric acid plants, Petroleumrefineries, Lime plants, Phosphate rockprocessing plants,Coke oven batteries, Sulfurrecovery plants, Carbon blackplants (furnace process), Primary lead smelters, Fuel conversionplants, Sinteringplants, Secondary metal production facilities, Chemicalprocess plants, Fossil-fuel boilers ofmore than 250 million British thermal units perhourheatinput, Petroleum storage and transferfacilities with a capacity exceeding 300,000 barrels, Taconite ore processing facilities, Glass fiberprocessing plants, and Charcoal production facilities. Federal Class 1area means any Federal land that is classified orreclassified Class I. Federal Land Managermeans the Secretary ofthe department with authority overthe Federal Class I area (orthe Secretary's designee) or, with respect to Roosevelt-Campobello International Park, the Chainnan ofthe Roosevelt-Campobello International ParkCommission. Federally enforceable means all limitations and conditions which are enforceable by the Administratorunderthe Clean AirAct including those requirements developed pursuant to parts 60 and 61 ofthis title, requirements within any applicable State Implementation Plan, and any pennitrequirements established pursuant to Sec. 52.21 ofthis chapterorunder regulations approved pursuantto part 51, 52, or60 ofthis title. Fixedcapi/alcostmeans the capital needed toprovide all ofthe depreciable components. FugitiveEmissions means those emissions which could notreasonably pass through a stack, chimney, vent, orotherfunctionally equivalentopening.

Geographic enhancement/orthepurpose of Sec. 51.308 means amethod, procedure, or process to allow abroad regional strategy, such as an emissions trading programdesigned to achieve greaterreasonable progress than BART forregional haze, to accommodate BART for reasonably attributable impainnent.

Implementationplan means, for the purposes ofthis part, any State Implementation Plan, Federal1mplementationPlan, orTribal1mplementation Plan.

Indian tribe ortribe means any Indian tribe, band, nation, orotherorganized group or community, including any AlaskaNative village, which is federally recognized as eligible for the special programs and services provided by the United States to 1ndians because oftheir status as Indians.

In exis/ence means that the owneroroperatorhas obtained all necessary preconstruction approvals orpermits required by Federal, State, orlocal airpollution emissions and airquality laws orregulations and eitherhas (I) begun, orcaused to begin, a continuous program of physical on-site construction ofthe facility or(2) entered into binding agreements orcontractual obligations, which cannotbe cancelled ormodified without substantial loss to the owneror operator, to undertake aprogramofconstruction ofthe facility to be completed in a reasonable time.

In operation means engaged in activity related to the primary design function ofthe source. Ins/alia/ion means an identifiablepiece ofprocess equipment.

### Integralvista means a view perceived from within the mandatory Class Ifederal areaofa specific landmarkorpanoramalocated outside the boundary ofthe mandatory Class Ifederal arya.



### Least impaireddays means the average visibility impairment (measured in deciviews) for the twenty percentofmonitored days in acalendaryear with the lowest amount ofvisibility impairment.



### Majorstationarysource and majormodification mean major stationary source and major modification, respectively, as defined in Sec. 51.166.



### Mandatory Class IFederalArea means any area identified in part 81, subpartD ofthis title. 

### Most impaireddays means the average visibility impairment (measured in deciviews) forthe twenty percentofmonitored days in a calendaryear with the highest amount ofvisibility impairment.



### Naturalconditions includes naturally occurring phenomena thatreduce visibility as measured in terms oflightextinction, visual range, contrast, orcoloration.



### Potential to emitmeans the maximumcapacity ofa stationary source to emita pollutantunder its physical and operational design. Any physical oroperational limitation on the capacity ofthe source to emit apollutant including airpollution control equipment and restrictions on hours of operation oron the type oramount ofmaterial combusted, stored, orprocessed, shall be treated as part ofits design ifthe limitation or the effect itwould have on emissions is federally enforceable. Secondary emissions do notcount in determining the potential to emit ofa stationary source.



### Reasonablyallributable means attributable by visual observation orany other technique the State deems appropriate. Reasonably attributable visibility impairment means visibility impairmentthat is caused by the emission ofairpollutants from one, ora small number of sources.



### Reconstruction will be presumed to have taken place where the fixed capital costofthe new component exceeds 50 percentofthe fixed capital costofa comparable entirely new source. Any final decision as to whetherreconstruction has occurred mustbe made in accordance with the provisions ofSec. 60.15 (I) (I) through (3) ofthis title.



### Regionalhaze means visibility impairmentthat is caused by the emission ofairpollutants from numerous sources located overa 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 occuras a result ofthe construction oroperation ofan existing stationary facility butdo notcome from the existing stationary facility. Secondary emissions may include, but are not limited to, emissions from ships ortrains coming to orfrom the existing stationary facility.



### Significant impairment means, for purposes ofSec. 51.303, visibility impairmentwhich, in the judgment ofthe Administrator, interferes with the management, protection, preservation, or enjoyment ofthe visitor's visual experienceofthe mandatory Class 1federal area. This determination mustbe made on a case-by-casebasis taking into account the geographic extent, intensity, duration, frequency and time ofthe visibility impairment, and how these factors correlate with (I) times ofvisitoruse ofthe mandatory Class Ifederal area, and (2) the frequency and timing ofnatural conditions thatreduce visibility.



### State means "State" as defined in section 302(d) ofthe CAA. 

### Stationary Source means any building, structure, facility, orinstallation which emits ormay emitany airpollutant.Visibility impairmentmeans any humanly perceptible change in visibility (lightextinction, visual range, contrast, coloration) from that which would have existedundernatural conditions.

Visibility in anymandatory Class1Federalarea 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 Implementationcontrol strategies for reasonably attributable visibility impairment. (a) Plan Revision Procedures. (I) Each State identified in Sec. 51.300(b)(2) musthave submitted, not laterthan September2, 1981, an implementationplan meeting the requirements of this subpartpertaining to reasonably attributable visibility impainnent. (2)(i) The State, priorto adoption ofany implementation plan to address reasonably attributable visibility impainnentrequiredby this subpart, mustconduct one ormore public hearings on suchplaninaccordance 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 otheraffected States, and must state where the public caninspect asummary prepared by the Federal Land Managers oftheir conclusions and reconunendations, ifany, on the proposed plan revision. (3) Submission ofplans as requiredby this subpartmustbe conducted in accordance with the procedures in Sec. 51.103. (b) State and Federal Land ManagerCoordination. (I) The State must identify to the Federal Land Managers, in writing and within 30 days ofthe date ofpromulgation ofthese regulations, the title ofthe official to which the Federal Land Managerofany mandatory Class IFederal area can submit arecommendation on the implementation ofthis subpart including, butnot limited to: (i) A listofintegral vistas that are to be listed by the State for the purpose ofimplementing section 304, (ii) Identification ofimpairment ofvisibility in any mandatory Class IFederal area(s), and (iii) Identification ofelements for inclusion in the visibility monitoring strategy required by section 305. (2) The State mustprovide opportunity forconsultation, in person and at least 60 days prior to holding any public hearing on the plan, with the Federal Land Manageron 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 ofvisibility in any mandatory Class IFederal area, and (ii) Recommendations on the development ofthe long-term strategy. (3) The plan must provide procedures for continuing consultationbetween the State and Federal LandManageron the implementation ofthe visibility protectionprogram required by this subpart. (c) General planrequirements forreasonably attributable visibility impairment. (l) The affected Federal Land Manager may certify to the State, at any time, that there exists reasonably attributable impairmentofvisibility in any mandatory Class IFederal area. (2) The plan mustcontainthe 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 ofcompliance, and such othermeasures including schedules

### for the implementationofthe elements ofthe long-tenn strategy as may be necessary to make reasonable progress toward thenational goal specified in Sec. 51.300(a). (ii) An assessmentofvisibility impairment and a discussion ofhow each elementofthe plan relates to the preventing offuture orremedying ofexisting impainnentofvisibility in any mandatory Class IFederal areawithin the State. (iii) Emissionlimitations representing BART and schedules for compliance with BART for each existing stationary facility identified according to paragraph (c)(4) ofthis section. (3) The planmust require each source to maintain control equipmentrequired by this subpart and establishprocedures to ensure such control equipmentis properly operated and maintained. (4) Forany existing reasonably attributable visibility impairmentthe FederalLand Manager certifies to the Stateunderparagraph (c)( I) 

### ofthis section, at least 6months priorto plan submission orrevision: (i) The Statemustidentify and analyze forBART each existing stationary facility which may reasonably be anticipated to cause orcontributeto impairmentofvisibility in any mandatory Class IFederal areawhere the impairment inthe mandatory Class IFederal areais reasonably attributable to that existing stationary facility. The State need not considerany integral vistathe Federal LandManagerdid not identify pursuant to Sec. 51.304(b) at least 6months before plan submission. (ii) Ifthe Statedetermines thattechnologicial oreconomic limitations onthe applicability of measurementmethodology to aparticular existing stationary facility would make the imposition ofan emission standard infeasibleitmay insteadprescribe adesign, equipment, workpractice, or otheroperational standard, orcombinationthereof, to 

### require the application ofBART. Such standard, to the degree possible, is to set forth the emission reduction to be achieved by implementationofsuch design, equipment, workpractice oroperation, and mustprovide for compliance by means which achieve equivalentresults. (iii) BART mustbe determined for fossil-fuel fired generatingplants having a total generating capacity in excess of750 megawatts pursuantto "Guidelines for Determining BestAvailable RetrofitTechnology for Coal-fired PowerPlants and Other Existing Stationary Facilities" (1980), which is incorporated by reference, exclusive ofappendix E, which was published inthe Federal Registeron 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, Virginia2216I. It 

### is also available for inspection at the Office ofthe Federal RegisterInfonnation Center, 800 N0I1h Capitol NW., suite 700, Washington, DC. (iv) The plan must require that each existing stationary facility required to install and operate BARTdo so as expeditiously as practicable butin no caselater than five years after plan approval.

(v) The plan must provide for a BART analysis ofany existing stationary facility that might cause orcontributeto impainnentofvisibility in any mandatory Class IFederal area identified underthis paragraph (c)(4) at such times, as detennined by the Administrator, as new technology forcontrol ofthe pollutant becomes reasonably available if: (A) Thepollutant is emitted by thatexisting stationary facility, (B) Controls representing BART for the pollutant have notpreviously been required underthis subpart, and (C) The impainnentofvisibility in any mandatory Class IFederal areais reasonably attributable to the emissions ofthatpollutant.[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 subjectto the requirement under Sec. 51.302 to install, operate, and maintain BARTmay apply to theAdministrator for an exemption from that requirement. (2) An application underthis section mustinclude all available documentation relevant to the impactofthe source's emissions on visibility in any mandatory Class IFederal areaand a demonstration by the existing stationary facility thatitdoes not orwill not, by itselforin combination with other sources, emit any air pollutantwhich may be reasonably anticipated to cause orcontribute to a significant impairment ofvisibility in any mandatory Class IFederal area. (b) Any fossil-fuel fired powerplantwith a total generating capacity of750 megawatts or more may receive an exemption from BART only ifthe owneroroperatorofsuch powerplant demonstrates to the satisfaction ofthe Administratorthat such powerplantis located at such a distance from all mandatory Class I Federal areas that such powerplantdoes not or will not, by itselfor in combination with other sources, emitany airpollutant which may reasonably be anticipated to cause orcontribute to significantimpainnentofvisibility in any such mandatory Class I Federal area. (c) Application underthis 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 priorwritten notice to all affected Federal Land Managers ofany application for exemption underthis Sec. 51.303. (e) The Federal Land Manager may provide an initial recommendation orcommenton the disposition ofsuch application. Such recommendation, where provided, must be partofthe exemption application. This recommendation is notto be constll.led as the concurrence required underparagraph (h) ofthis section. (I) The Administrator, within 90 days ofreceipt ofan application for exemption from control, will provide notice ofreceiptofan exemptionapplication and notice ofopportunity for public hearing on the application. (g) Afternotice and opportunity for public hearing, the Administratormay grant ordeny the exemption. Forpurposes of judicial review, final EPA action on an application for an exemption underthis Sec. 51.303 will not occuruntil EPA approves ordisapproves the State ImplementationPlan revision. (h) An exemption granted by the Administratorunderthis Sec. 51.303 will be effective only upon concurrence by all affectedFederal Land Managers with the Administrator's determination. [45 FR 80089, Dec. 2,1980, as amendedby 64 FR 35774, July 1,1999] Sec. 51.304 Identification ofintegral vistas. (a) On orbefore December31, 1985 the Federal Land Manager may identify any integral vista. The integral vistamustbe identified according to criteria the Federal Land Manager

### develops. These criteriamust include, but are not limited to, whetherthe integral vistl is important to the visitor's visual experience ofthe mandatory Class IFederal area. Adoption of criteriamust bepreceded by reasonable notice and opportunity forpublic commenton the proposed criteria. (b) The Federal Land Managermustnotify the State ofany integral vistas identified under paragraph (a) ofthis section, and the reasons therefor. (c) The Statemust list in its implementationplan any integral vistathe Federal Land Manager identifies at least six months priorto plan submission, and mustlistin its implementationplan at its earliest opportunity, and in no case later than atthe time ofthe periodic review ofthe SIP required by Sec. 51.306(c), any integral vista the FederalLandManager identifies afterthattime. (d) The State need not in its implementationplan listany integral vista the identificationof which was notmade in accordance with the criteriainparagraph (a) ofthis section. In making this finding, the State must carefully consider the expertise ofthe Federal Land Managerin making thejudgments called for by the criteriafor identification. Where the State andthe Federal Land Managerdisagree on the identification ofany integral vista, the State mustgive the Federal Land Manageran opportunity to consultwith the Governorofthe 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 ofaddressing reasonably attributable visibility impairment, each State contlining amandatory Class IFederal area must include in the plan a strategy for evaluating reasonably attributable visibility impairment inany mandatory Class IFederal areaby visual observation orotherappropriate monitoring techniques. Such strategy must take into account currentand anticipated visibility monitoring research, the availability ofappropriate monitoring techniques, and such guidance as is provided by the Agency. (b) The plan mustprovide for the consideration ofavailable visibility data and mustprovide 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 ofaddressing reasonably attributable visibility impainnent, each plan must include a long-tenn (10-15 years) strategy formaking reasonable progress toward the national goal specified in Sec. 51.300(a). This strategy mustcoverany existing impairmentthe Federal Land Managercertifies to the State at least 6 months priorto plan submission, and any integral vista ofwhich the Federal Land Managernotifies the State at least 6 months prior to plan submission. (2) A long-term strategy mustbe developed for each mandatory Class IFederal arealocated 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 notpreclude the developmentofa 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 mustcoordinate its long-tenn strategy for an area with existing plans and goals, including those provided by the affected Federal Land Managers, that may affect impainnentof visibility in any mandatory Class IFederal area. (c) The plan mustprovide for periodic review and revision, as appropriate, ofthe long-tenn strategy for addressing reasonably attributable visibility impainnent. The plan mustprovide for suchperiodic review and revision not less frequently than every 3 years until the date of submission ofthe State's firstplan addressing regional haze visibility impainnent in accordance with Sec. 51.308(b) and (c). On orbefore this date, the State must revise its plan to provide for review and revision ofa 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 mustbe submitted consistentwith 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 mustcontinue to comply with existing requirements forplan review and revision, and with all emissionmanagement requirements in the plan to address reasonably attributable impainnent. This requirementdoes not affect any preexisting deadlines for State submittal ofa long-tenn strategy review (or elementthereof) between August 30, 1999, and the date required for submission ofthe State's first regional haze plan. In addition, the plan mustprovide for review ofthe long-term strategy as it applies to reasonably attributable impairment, and revision as appropriate, within 3 years ofState receipt ofany certificationof reasonably attributable impairment from aFederal 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 Administratoronprogress toward the national goal. This report must include an assessmentof: (I) The progress achieved in remedying existing impairment ofvisibility in any mandatory Class IFederal area; (2) The ability ofthe long-tenn strategy to prevent future impainnentofvisibility in any mandatory Class IFederal 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 impactofany exemption grantedunder Sec. 51.303; (7) The need for BARTto remedy existing visibility impairmentofany integral vista listed in the plan since the last such report, or, in the case ofthe first report, since plan approval. (d) The long-tenn strategy mustprovide for review ofthe impacts from any new major stationary source ormajor modifications on visibility in any mandatory Class IFederal area. This review ofmajorstationary sources ormajormodifications mustbe in accordance with Sec. 51.307, Sec. 51.166, Sec. 51.J60, and any otherbinding guidance provided by the Agency insofar as these provisions pertainto protectionofvisibility in any mandatory Class IFederal areas.

### (e) The State mustconsider, at aminimum, the following factors during the development ofits long-tenn strategy:

(1) Emission reductions due to ongoing airpollution control programs, (2) Additional emissionlimitations and schedules forcompliance, (3) Measures to mitigate the impacts ofconstruction activities, (4) Source retirement and replacement schedules, (5) Smoke management techniques for agricultural and forestry managementpurposes including suchplans as currently existwithin the State for these purposes, and

(6) Enforceability ofemission limitations and control measures. (I) 

### Theplan mustdiscuss the reasons why the above and otherreasonable measures considered inthe developmentofthe long-term strategy were orwere not adopted as partofthe long-term strategy.

(g) The State, in developing the long-term strategy, musttake into account the effectofnew sources, and the costs ofcompliance, the time necessary for compliance, the energy and nonair quality environmental impacts ofcompliance, andthe remaining useful life ofany affected existing source and equipmenttherein. [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 ofthe 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 afterthe 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 ofthe 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, ifapplicable. (h) Compilation of public comments and the State's response thereto. 2.2. Technical Support (a) Identification ofall 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 ofthe 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 ofthe 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 ofoffsite 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 ofwhy 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 2consider 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 ofthe 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 ofthe 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 forthe Emissions TaskTeam 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, December2000. 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 Journal of GeophysicalGrell, 

### 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 CenterforAtmospheric Research, Boulder, CO. Houyoux, M.R., Vukovich, J. M. ; Coats, C. J., Jr. ; Wheeler, N. J. M. ; Kasibhatla, P. S., 2000: "Fast emissions modeling with the sparse matrix operator kernel emissions modeling system". J. Geophys Res., 105: 9079-9090. Harvey, Craig. 2002. "Comparison of Draft NONROAD2002 to Prior Draft Version." Memo to Record, provided with confidential December 2002 NONROAD2002 model release. December 9. 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, October2002. 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. 30:2580-2585. Pechan, 2002: E.H. Pechan & Associates, Inc., "WRAP Emissions Forecasts for 2018
- Draft Report", prepared for the WRAP Emissions Forum May 2002 (Revised), Pechan Rpt. No. 01.12.002/9409.000 (Rev.). 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 ofAir Quality Planning and Standards, Research Triangle Park, NC, January26,2001. 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 Research, vol. 103, pp. 25611-25629. 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- 39. SAIC, 2003: "EPA Contract No. 68-D-98-113, Work Assignment No. 5-78, SAIC Project No. 1-0825-08-2566-000, Application/Utilization of GVS Techniques in Analyzing Particulate
Appendix R-O, Page 2Matter (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, North Carolina 27711, July 3. USDA, 2001: U.S. Department of Agriculture, "Agricultural Baseline Projection Tables to 2010," Staff Report WAOB-2001-1, Office of the Chief Economist, prepared by the Interagency Agricultural Projections Committee, available from http://usda.mannlib.comell.edu/, accessed December2001. 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