[File\ pathname] Statement in Support of EPA Considering Alaska as Part of a Marine Emission Control Area Purpose : “ ... describe the adverse health and environmental impacts caused by OGV emissions to U.S. populations, terrestrial and aquatic ecos ys tems, critical habitats, water quality , and areas of cultural and scientific significance. ...” “Our most pressing need is for information which highlights the environmental effects nitrogen and sulfur deposition may have on Alaska's sensitive ecos ys tems. Specifically we are interest ed in any information about the effects NOx, PM, and sulfur emissions have on human health or regional haze/visibility . Any other environmental impacts associated with NOx, PM, or sulfur emissions would also be helpful. .. What would an Emission Control Area ( ECA ) mean? Fuel Sulfur Limits (to address SOx and PM)

 March 2010: 10,000 ppm in ECAs  2012: Global cap falls to 35,000 ppm  2015: ECA cap falls to 1,000 ppm  2020: Global cap falls to 5,000 ppm - subject to a review in 2018; if review indicates fuel will not be available, the date defaults to 2025 Position: The Alaska Department of Environmental Conservation (ADEC) encourages EPA to consider including Alaska’s coastline, including Southeastern and South - central Alaska, the Aleutian Chain, the Northwest and North Slope coasts, in the implementation of an Emission Control Area (ECA). Air quality

values protected by

a future ECA in Alaska include public health, addressing the Regional Haze Rule and visibility concerns, plus ecosy stem integrit y, resi lience and protecting Alaska’s subsistence based cultures. Background:[File\ pathname] Two of Alaska’s three major population centers (Anchorage and Juneau) are coastal, with economies linked to fishing, marine commerce, and tourism . Alaska’s fishing industry and small er population centers are widel y distributed along its coastline. With a warming climate and changes in sea ice, the department anticipates increases in shipping along the coasts of the Beaufort and Chukchi Sea. A ir pollution from marine traffic can affec t human populations both culturally and economically ; a cid rain and runoff can adversel y impact subsistence and commercial food resources. Alaska Natives and rural Alaskans may have disproportionate exposure to emissions from oceangoing vessels b ecause o f their heavy reliance on subsistence foods and their proximity to marine traffic . Alaska ’s Native children have higher rates of respiratory infections and other lung ailments than other Alaskan children. Both asthma and Respiratory Sy ncy tial Virus (RSV) are prevalent in Native, rural Alaskan children and are of concern throughout rural Alaska . Though difficult to draw a direct correlation between these health impacts and emissions from ocean going vessels (OGVs) , there are many communities located adjace nt to the shipping lanes in the Aleutians and in Southeast Alaska. Any effort to reduce air qualit y emissions can potentially mitigate these health concerns.

I. Impacts of Cruise Ship Sulfur Emissions in Alaska: High sulfur emissions from cruise ships are vi sible as a blue haze that hangs over Southeast Alaska towns frequented during the summertime. Periodically , this haze impacts the aesthetic quality of life for locals, and ironicall y diminishes the views of Southeast Alaska for tourists . ADEC estimated total sulfur oxide emissions from cruise ships during one summer season using Juneau, Alaska as an example community . This estimation did not include sulfur emissions from cruise ships underway , only when in port, or “hotelling.” From April 30 through Sep tember 27, 2008, there were 645 individual cruise ship visits to Juneau, or nearl y 4.3 visits a day on average. When in port, cruise ships stay ed in Juneau’s harbor an average of 10.2 hours. Available data indicate that one cruise ship can burn nearl y 2 t ons per hour of intermediate fuel oil (IFO) 380, and nearl y 0.5 tons per hour of marine diesel oil (MDO) during hotelling. This equates to neatl y 7,000 gallons of fuel burned by one cruise ship in one hour. IFO 380 has a fuel sulfur content of[File\ pathname] 2.5% or 25,0 00 parts per million (ppm); MDO has a fuel sulfur content of 0.5% or 5,000 ppm. Based on these data, DEC estimated the total sulfur oxide emissions from cruise ships hotelling in Juneau during one summer season to be greater than 350 tons. These calculatio ns suggest that cruise ships are among the largest source s of sulfur oxide in Alaska; aggregated sulfur oxide emissions in Juneau’s harbor are larger than Cominco mine, large diesel electric utilities in remote Alaska, and man y of the North Slope oil and g as facilities. Cruise ship traffic in southeast Alaska towns is on the rise , and currentl y, there is no limit on the number of cruise ships that can visit a port during any one day . Currently , as many as six cruise ships may visit Juneau per day , and June au is currently building additional dock space to accommodate more cruise ships. These same cruise ships then visit Skagway and Sitka on a daily basis. On July

3 rd , 2008, A DEC staff witnessed a plume of visible cruise ship exhaust from nearl y 3 nautical m iles away as he approached Skagway , Alaska (see Picture 1, below). As shown, this exhaust plume traversed the entire width of Ly nn Canal, the largest fjord in the world.

Picture 1. Approaching Skagway on the Alaska State Ferry, July 3, 2008. T he fo llowing pictures were taken July 24, 2008 from West Juneau, on Douglas Island, looking towards Juneau. Weather conditions were fairl y typ ical this day with moderate winds blowing from the southeast, and some light rain. When the weather is humid, which i s ty pical in Juneau, cruise ship haze is more visible. Skagway is located in this fjord .[File\ pathname] Pictures 2 - 4. Cruise Ship exhaust over Juneau, with Mt. Roberts in the background. Alaska July 24, 2008.[Fi le\ pathname] As the pictures show, the plumes from each cruise ship comingle into a visible plume over Alaska’s capitol city . There were three cruise ships in Juneau when these pictures were taken; this is below average. On day s when there are four or five cruise ships, and other vessels in port, the plume is much more visible. The last time air quality m onitoring occurred in downtown Juneau was nearly 8 y ears ago. The monitoring did not find violations of federal sulfur oxide standards. At th at time, PM2.5 was not monitored. If resources are available, ADEC is considering reinstating ambient monitoring in downtown Juneau during the summer of 2009 to determine current levels of PM2.5 and sulfur oxides. This would provide updated information on ambient air impacts from cruise ship emissions in the port. The most practical solution to the high levels of s ulfur being emitted into local communities from cruise ships in port is lowering sulfur in the fuel burned b y the cruise ships as part of a sulfur emission control area (SECA) . Using the same calculations as above and capping the sulfur at 1% per the ECA r equirements in 2010 reduces the tons per season of sulfur emissions to a little over 300 tons. The 2015 cap of 0.1% sulfur reduces the season sulfur oxides emissions to nearl y 35 tons per ye ar. This is an impressive reduction. II. Regional Haze: The visibility problems associated with high sulfur ship emissions complicate Alaska’s ability to comply with the federal regional haze rule. The regional haze rule establishes specific State Implementation Plan (SIP) requirements and strategies for states to bring vis ibility in designated Class Iareas to natural conditions by 2064. States must develop long - term plans for reducing pollutant emissions that contribute to visibility degradation and must establish interim goals aimed at improving visibility in Class I are as. SIPs must address haze caused by all sources of pollutants that impair visibility including haze caused from smoke, vehicles, electric utility and industrial fuel burning, and other activities that generate pollution. Visibility in Alaska’s Class I areas is impacted b y uncontrollable sources of pollution, such as wildfires, transport of pollutants from Europe and Asia, volcanic activity , and sea salt deposition. Fuel quality controls on mobile sources, like marine shipping, are of paramount importanc e in addressing regional haze impacts.[Fi le\ pathname] Simeonof National Wildlife Refuge (NWR) and Tuxedni NWR are coastal Class Iareas of special concern for how to achieve visibility goals. The department believe s that controlling emissions from ocean - going vessels will be crucial to controlling regional haze in Alaska. Shipping and other port emissions from along the Pacific Coast have been shown to contribute significantl y to atmospheric aerosol concentrations over large areas of the western United States (Xu et al. 2006; Dominguez et al. 2008)) . Based on IM PROVE air monitoring, existing shipping routes and modeled emissions along the Alaskan coast, ADEC believes aerosols impact visibility at Alaska’s Class I areas. Figures 1 and 2 demonstrate that with even a cursory examination of Corbett’s work (Corbett et al. 2006, 2007), we see major shipping lanes pass by Simeonof NWR, a Class I area for r egional h aze purposes.

Figure 1 (Corbett and Wang, 2006)[Fi le\ pathname] Figure 2 (Corbett et al. 2007) Anthropogenic sources of sulfur in the atmosphere ty pically dominate at higher latitudes, 35 - 50 deg N (8 % natural) and 50 - 65 deg (10% natural) (Bates et al , 1992 ). Nevertheless, we have examined natural sources of atmospheric sulfur near the Regional Haze Class I monitoring s ites. Sulfate levels at Alaska IMPROVE sites are not correlated with volcanic activity monitored b y the Alaska Volcano Observatory , nor are they correlated with sea salt which can sometimes be a significant source of sulfur in coastal regions. The sulfur diox ide from the Alaskan p orts emission inventory (Pechan, 2005) alread y exceeds that from the permitted facilities in the Class I Area coastal counties. Ocean - going shipping is not y et included in either inventory , but based on its proximity

to the Aleutian Archipelago , shipping will increase impacts from the marine sector. Evidence for elevated sulfate levels in pristine and remote areas of Alaska Simeonof Class Iarea is located near the tip of the Alaska Peninsula facing the Pacific Ocean. The nearest co mmunity

is Sand Point nearly

60 miles to the north and with a population of around 900 people. Sand Point is home to an IMPROVE monitoring site in one of the most remote areas in the United States. IMPROVE monitoring sites exist because of regional haze r ule[Fi le\ pathname] requirements and have specific data collection objectives and standards for use an. As such, IMPROVE monitoring sites are reliable and comparable across different regions of the country . The Sand P oint/Simeonof IMPROVE monitoring site should be detecti ng levels of sulfate that are very low. However, sulfate levels detectable at Simeonof are c ompar able to sulfate at IMPROVE sites in Redwood and Point Rey es in the L ower 48. Denali and Glacier National Park IMPROVE sites demonstrate LOWER levels of sulfat e. Hawaii Volcanoes seems to have a baseline lower than Simeonof, but has frequent spikes to much higher levels which is consistent with volcanic activity . Not too surprisingly , East Coast Class I areas (Acadia and Shenandoah) are much higher. Why would S imeonof’s sulfate emissions be comparable to IMPROVE sites much closer to major populations? One potential explanation is volcanic activity . The Aleutian Chain is home to many active volcanoes. The signature of sulfate emissions from volcanic activity is episodic, with steady

levels interspersed with spikes of sulfate reflecting nearby volcanic activity . The levels seen at Simeonof, though indeed influenced occasionall y b y nearb y volcanoes, are consistently

elevated related to other Class Iareas consider ing how remote the area is. Sulfate levels at Simeonof do not vary seasonally . Another explanation is the IMPROVE site’s proximity to the Great Northern Shipping Route, a commonly used shipping lane for cargo ships sailing from North America to Asia. See figure #2 for context. T he regional haze rule has a number of requirements with which Alaska must comply . States must develop long - term plans for reducing pollutant emissions that contribute to visibility degradation and within the plans establish goals aimed at improving visibility in Class Iareas. The SIP must address haze caused by all sources of pollutants that impair visibility including haze caused from smoke, vehicles, electric utility and industrial fuel burning, and other activities that generate pollution. By 2064, visibility in Class Iareas must reach background levels. In the interim, goals of some percentage improvement in visibility must be met. Of course, this presents a challenge in Alaska which is alread y considered very close to “background”. Yet reduction of sulfate provides Alaska its most reasonable chance of meeting regional haze requirements. Monitoring at Sand Point shows sulfate is a significant fraction of the total haze causing pollutants. The other contributing emissions ar e , for the most part, uncontrollable . ( See Simeonof[Fi le\ pathname] “A Quick Look at Simeonof Class IArea Visibility” in Appendix A at the end of this document). The data indicates that controlling sulfates is the best option for meeting the required “glidepath” goals.

III. Boreal an d Arctic ecosystems are susceptible to damage from marine emissions with potential subsequent impact on subsistence food resources: Industrial and naturally

occurring aerosols cause ecological damage to boreal and arctic ecos ys tems . Man y reports, although not all, come from industrial regions subject to a wider range of pollutants than solely NOx and SOx. Documented damage to northern ecos ys tems includes forest and tundra defoliation, ph ys iologic stress responses, changes in growth rates, changes in biogeo chemical cycling and soil deposition, changes in species composition and life cycles, and large - scale changes in remotel y sensed land cover (Oppenheimer, 1989; Kry uchkov, 1993; Freedman et al., 1990; Alexey ev, 1995; Rees and Williams, 1997; Virtanen et al. , 2002; Tutubalina and Rees, 1999, 2001; Savard et al., 2002; Addison et al. , 1984; Savard et al.,2004 ) . The effects of sulfur dioxide and other sulfur compounds on vegetation, food webs, and ecos ys tem health have also been widel y documented for most othe r biogeographic regions . Three factors are of specific concern for Alaskan ecosy stems: 1. Lichens are important components of boreal, subarctic, and arctic ecos ys tems, by anchoring food webs and influencing plant succession: Damage to lichen populations h as widesprea d effects in Alaskan ecos ys tems . But, l ichens are among the most sensitive organisms to sulfur dioxide. L ichens are so sensitive they are frequentl y used as biological indicators of sulfur pollution. Ex amples, manuals, and protocols for usin g lichens as bioindicators may be found at: http://gis.nacse.org/lichenair/?page=reports (USDA Forest Service) and http://www. nhm.uio.no/botanisk/bot - mus/lav/sok_rll.htm (The Bry ologist) . A study conducted in areas within the Tongass National Forest in Southeast Alaska found evidence of sulfur emission impacting lichen communities. The study included specific efforts to[Fi le\ pathname] d etermin e patterns of contaminant accumulation in lichens near downtown Juneau , on Mt . Roberts (directl y north of downtown Juneau), and at Greens Creek mining facility on Admiralt y Island (19 miles south of Juneau). Sulfur exceeding Forest Service thresholds were found at all these sites, but the Mt. Roberts results are particularly illuminating as the mountain rises behind downtown Juneau and the docks where the cruise ships moor (see pictures 2 - 4). Li chens from Mt . Roberts were above forest service thresholds for sulfur at the 175, 600, and 910 foot levels (Dillman 2007). The authors conclude the main source of sulfur and nitrogen found in lichens from Mt . Roberts is likely the burning of fossil fuels by cruise ships and other vehicles and equipment in downtown Juneau. Lichen biodiversity

and abundance have been inventoried at multiple sites alo ng the Alaska coast, including Class I Areas for r egional h aze, National Parks, and National Forest lands (Talbot et al., 1992, 2000, 2001, 2002). The inventoried sites co ntain a wide variet y of lichens from the enti re range of sulfur sensitivity , from those most susceptible to sulfur dioxide to those less susceptible. Given the results of the Forest Service study cited above and sensitivity of the lichen species known to b e present, we expect sulfur oxides emissions from marine vessels to be alread y impacting coastal plant communities. 2. Subsistence Resources: Lichens are a particularl y important food source for caribou, which in turn are important to Alaskans as a subsisten ce food. One issue of concern and current research is the potential role damage to lichens may be having on the Southern Alaska Peninsula Caribou Herd. This herd’s range adjoins the Alaska coast near a major ocean - going shipping route. The Southern Alas ka Peninsula Caribou Herd has been decreasing in size, exhibiting both poor calf survival and low pregnancy rates which are t ypicall y a sign of dietary

stress (ADF&G, 2008; Manning and Butler, 2007; Valkenburg and Keech, 2002). The herd is now being manag ed b y predator control and a complete hunting ban, including a ban on subsistence. There are few, if any , remaining options for management of this herd. One area of ongoing attention is the food base for this herd, including lichen where available. If regu lation of marine fuels could potentially enhance lichen biomass in the area, it[Fi le\ pathname] would contribute in turn to maintenance of an important subsistence resource for local human populations. Subsistence hunting and plant gathering activities by Native and non - N ative Alaskans include use of a wide range of marine and land - based resources along Alaska’s coasts. Air pollution affects these resources in several way s. Contaminants accumulate in the foods themselves, and air pollution damages and changes ecos ys tems, making food resources less available (Shannon, 1999). 3. Ecosy stem resilience: Other areas of concern with marine shipping emissions are impacts on ecosy stems already stressed through climate change and potential for acid rain in remote areas lacking current monitoring . Climate change is serious in Alaska. Changes in temperatures, storm activity , and sea ice stress Alaska Native and rural community abilities to anticipate and adapt to changes in subsistence resources. How is it affecting coastal ecos ys tems? Alaskan ecos ys tems are alread y disproportionately

affected by

climate change, with many indicators of ecosy stem stress present. These indicators include melting permafrost, declines in annual growth of dominant tree species, changes in shrub and tree dis tributions, expanding pest outbreaks, increased methane efflux from forests and wetlands. Multiple stresses on ecos ys tems ty picall y act synergistically (Chapin et al. 2006, 2008; Arctic Climate Impact Assessment, 2004; US Global Change Research Program, N ational Assessment Sy

nthesis Team. 2000). Some Alaskan natural areas, such as L ake Clark National Park and Preserve, have been identified as particularly

susceptible to acid deposition because of poor buffering capability of aquatic ecosy stems. Sources fo r airborne contamination in the L ake Clark region include emissions from offshore oil/gas development in Cook Inlet, coal extraction at the Beluga coal field, and international transport from Asia and Europe (National Park Service, 2006). It may at some po int be possible to quantify how much sulfate from marine traffic is reaching Alaska’s Class I areas and this national park (Dominguez et al., 2008).[Fi le\ pathname] Participation in a marine ECA would diminish at least one of these man y stressors on Alaska’s ecos ys tems an d would be one more protection for maintaining Alaska’s ecosy stems and th e cultures that depend on them .[Fi le\ pathname] Bibliography Addison, P.A. , S. S. Malhotra and A. A. Khan. 1984. Effect of sulfur dioxide on wood y boreal forest species grown on native soils and ta iling s. J Environ Qual 13:333 - 336. ADF&G. 2008. Predator Management for the Southern Alaska Peninsula Caribou Herd. Alaska Dept. of Fish and Game, Div ision of Wildlife Conservation. Alexey ev, V. 1995. Impacts of air pollution on far north forest vegetat ion. Science of the Total Environment 160/161: 605 - 617. Arctic Climate Impact Assessment. 2004. Impacts of a warming arctic. Cambridge University Press. 140 pp. http://www.acia.uaf.edu/ Arctic Monitoring and Assessment Programme. 2006. Arctic Pollutio n: Acidification and Arctic Haze. Oslo, Norway . 28 pp. Bates, T.S.; B. K. Lamb, A. Guenther; J. Dignon; R. E. Stoiber . 1992. Sulfur Emissions to the Atmosphere from Natural Sources. Journal of Atm ospheric Chemistry 14: 315 - 337. Bryologist: Recent Literature on Lichens. Series. http://www.nhm.uio.no/b otanisk/bot - mus/lav/sok_rll.htm Chapin, Stuart F. III , A . L. L ovecraft, E . S. Zavaleta, J . Nelson, M . D. Robards, G . P. Kofinas, S . F. Trainor, G . D. Peterson, H . P. Huntington, and R . L. Naylor. 2006. Policy strat egies to address sustainability

of Alaskan boreal forests in response to a directionall y changing climate. PNAS 103 (45): 16637

– 16643. Chapin, Stuart F. III, S . F. Trainor, O . Huntington, A .L . Ovecraft, E. Zavaleta, D . C. Natcher, A.D . Mcguire, J . L. Nelson, L . Ray , M . Calef, N . Fresco, H . Huntington, T.S . Rupp, L . Dewilde, and R . L. Naylor. 2008. Increasing Wildfire in Alaska’s Boreal Forest: Pathway s to Potential Solutions of a Wicked Problem. BioScience 58: 531 - 539 Corbett, James , W. Chengfeng. 2006. Estimat ion, Validation, and Forecasts of Regional Commercial Marine Vessel Inventories Forecast Inventories for 2010 and 2020. West Coast SECA Team Meeting, 11 December 2006; California Air R esources Board, Sacramento, CA.[Fi le\ pathname] Corbett, James , J . Firestone , C . Wang. 2007. Estimation, Validation, And Forecasts Of Regional Commercial Marine Vessel Inventories: Final Report. Prepared for the California Air Resources Board and the California Environmental Protection Agency and for the Commission for Environmental C ooperat ion of North America. 5 April 2007: ARB Contract Number 04 - 3 46; CEC Contract Number 113.11. Dillman, Karen L, L . H. Geiser and G . Brenner. “Air Quality Biomonitoring with Lichens: The Tongass National Forest”. 2007. USFS Tongass National For est. unpublished report Dominguez, Gerardo, T . Jackson, L . Brothers, B . Barnett, B . Ngu ye n, and M . H. Thiemens. 2008. Discovery

and measurem ent of an isotopically distinct source of sulfate in Earth’s atmosphere. PNAS _ September 2, 2008 _ v ol. 105 _ no. 35 _ 12769

– 12773 . Freedman, B. , V . Zobens, T.C . Hutchinson, W.I . Gizy n . 1990. Intense, natural pollution affects Arctic tundra vegetation at the Smoking Hills, Canada. Ecology 71 (2): 492 - 503. Kry uchkov, Vasiliy

V. 1993. Extreme Anthropogenic Loads and the Northern Ecos y stem Condition. Ecologica l Applications 3 (4): 622 - 630. Manning, Elizabeth, and L . Butler. 2007. Caribou in Trouble On Alaska Peninsula. Alaska Fish and Wildlife News, Alaska Dept. of Fish and Game, August 2007. National Park Service. 2006. Ecological P rofile of Lake Clark National Park & Preserve in Vital Signs Monitoring Plan, Southwest Alaska Network, Appendix 2, 152 - 157 Oppenheimer, M. 1989. Climate change and environmental pollution: phy siological and biological interactions. Climatic Change 15 (1

–2 ):255

–270. Pechan, E.H. & Associates. 2005. Commercial marine inventories for select Alaskan ports: final report. Prepared for Alaska Department of Environmental Conservation. June, 2005. Rees W. G. and M. Williams 1997. Monitoring changes in land cover i nduced by atmospheric pollution in the Kola Peninsula, Russia, using Landsat - MSS data. International Journal of Remote Sensing 18 (8): 1703 - 1723.[Fi le\ pathname] Savard M, C . Bégin , M. Parent . 2002, Are industrial SO2 emissions reducing CO2 uptake b y the boreal forest? Geology 30 (5):403 - 406. Savard MM, C . Bégin , M. Parent, A . Smirnoff, J. Marion . 2004. Effects of smelter sulfur dioxide emissions: a spatiotemporal perspective using carbon isotopes in tree ring s. J Environ Qual. 33(1):13 - 26. Shannon Mala Bard, 1999. Globa l Transport of Anthropogenic Contaminants and the Consequences for the Arctic Marine Ecos ys tem. Marine Pollution Bulletin 38: 356 - 379. Talbot, S.S., S.L Talbot , J.W . Th omson , W.B. Schofield. 2000. L ichens of Izembek National Wildlife Refuge, Westernmost Al aska Peninsula. The Bryologist 103(2): 379

– 389. Talbot, S.S., S.L .Talbot, J.W. Thomson, F.J. Daniels, W.B. Schofield . 2002. L ichens from Simeonof Wilderness, Shumagin Islands, Southwestern Alask a. The Bryologist 105(1): 111. Talbot, S.S., S.L Talbot , J.W . Th omson , W.B. Schofield. 2001. L ichens from St. Matthew and St. Paul I slands, Bering Sea, Ala ska. The Bry ologist 104(1): 47. Talbot, Stephen S., S . L . Talbot , and J . W. Thomson. 1992. L ichens of Tuxedni Wilderness Area, Alaska. The Bry ologist 95(1): 20 - 30. US Global Change Research Program, National Assessment Sy nthesis Team. 2000. Climate Change Impacts on the United States, The Potential Consequences of Climate Variability and Change, Overview: Alaska. http://www.usgcrp.gov/usgcrp/L ibrary /nationa lassessment/overviewalaska.htm Valkenburg, Patrick , an d M . Keech. 2002. Population dy namics of Interior and southwest Alaska caribou herds, 1 July

2001 - 30 June 2002. Alaska Dept. of Fish and Game, Federal aid in wildlife restoration research performance report, grant W - 27 - 5, project 3.45. Juneau, Alaska. Virtanen, Tarmo , K . Mikkola, E . Patova, A . Nikula. 200 2. Satellite image analy sis of human caused changes in the tundra vegetation around the city of Vorkuta, north - European Russia. Environmental Pollution 120 (3): 647 - 658.[Fi le\ pathname] Toutoubalina, O.V., and W.G. Rees . 1999. Remote sensing of industrial impact on Arctic vegetation around Noril’sk, Northern Siberia: preliminary results. International Journal of Remote Sensing 20: 2979 - 2990. Tutubalina, O. V., and W.G . Rees . 2001. Vegetation degradation in a permafrost region as seen from space: Noril’sk, 1961 - 1999. Cold Regions Science and Technology 32, 191 - 203. USDA Forest Service. 2008. http://gis.nacse.org/lichenair/?page=reports National L ichens & Air Quality Database and Clearinghouse: L ichen Monitoring i n US National Forests and Parks Reports, Publications and Other Resources. See: Alaska Re gion; Pacific Northwest Region. Jin Xu, D . DuBois, M . Pitchford, M . Green and V . Ety emezian. 2006. Attribution of sulf ate aerosols in Federal Class I areas of the western United States based on trajectory regression anal ys is. Atmospheric Environment 40(19): 3433 - 3447.[Fi le\ pathname] Appendix A: A quick look at Simeonof Class I Area Visibility: 1) The regulatory requirement under the Re gional Haze Rule is to im prove visibility on the worst days from 18.56 deciviews (dv) to 15.7 dv by 2064. This is not a huge amount, but the control options are few. 2) How does sulfate affect visibility at Simeonoff? This plot of light extinction due to su lfate (Y - axis) against date (X - axis) shows that best days (B) and w orst days (W) have very different amounts of sulfate.

3. If w e look at all the aerosols affecting visibility at Simeonof, w e see that sea salt, sulfate, organic carbo n, coarse mass, and elemental carbon,(represented by different colors below), are important. Sulfate, coarse particulates (CM), elemental carbon (EC), and organic carbon (OMC) and sea salt all contribute to visibility impairment (Y - axis) at Simeonof.[Fi le\ pathname] 4. If w e take out the emission sources that we can’t control (sea salt, organic carbon associated with wildfires, coarse mass (on a coastal island, think silt), we get the plot below . Of the controllable aerosols, sulfate (in yellow) i s the most important. Controlling sulfate is probably the best way, perhaps the only way, to improve visibility at Simeonof.

Image and data sources: Visibility Information Exchange Web System (VIEWS), Annual summary tools: Composi tion http://vista.cira.colostate.edu/dev/web/AnnualSummarydev/Composition.aspx Interagency Monitoring of Protected Visual Environments (I MPROVE), Air Monitoring Data. http://vista.cira.colostate.edu/improve/Data/data.htm