## Technical Analysis for Arizona and Hawaii Regional

Haze FIPs : Task 17

: Information and Analysis to Support Hawaii’s Long

- Term Strategy

Contract No: EP

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Prepared for: Thomas Webb

Air Planning Offic e U.S. EPA Region 9 75 Hawthorne Street San Francisco, CA 94105

Prepared by: Uma Shankar and Sarav Arunachalam

Institute for the Environment University of North Carolina at Chapel Hill

Mark Reed, Juanita H a ydel, Lou Browning, Seth Hartley and David E rnst ICF International

Date delivered : April 1 3 , 20 1 2EMAQ LOE (EPA Contract EP

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## Contents

1 Introduction

................................ ................................ ................................ ............................ 1

2 Work Performed and Deliverable Summary

................................ ................................ ...... 1

2.1 Emission reductions due to ongoing pollution control programs

................................ ... 1

2.2 Measures to mitigate the impacts of construction activities

................................ ........... 2
2.2.1 State of Hawaii Requirements

................................ ................................ ............. 2
2.2.2 County Requirements

................................ ................................ .......................... 4

2. 3 Emission Limitations and Schedules for Compliance

................................ .................... 5
2.3.1 Regulatory Basis for Emission Limitations

................................ ......................... 5
2.3.2 Point Sources

................................ ................................ ................................ ....... 6
2.3.3 On

- Road Mobile Sources

................................ ................................ .................... 6
2.3.4 Commercial Marine Vessel Emissions

................................ ................................ 8

2.4 Source Retirement and Replacement Schedules

................................ ........................... 11

2.5 Smoke Management Plans

................................ ................................ ............................ 12
2.5.1 Agriculture Management

................................ ................................ ................... 12
2.5.2 Forestry management

................................ ................................ ........................ 13

2.6 Enforceability of Control Measures

................................ ................................ .............. 15

2.7 Qualit ative Analysis of Emissions Projections and Renewable Energy, and Impacts on

Visibility

................................ ................................ ................................ ............... 15

3 Conclusions

................................ ................................ ................................ ........................... 16

References

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## 1 Introduction

WA 5

- 12 states the following objective for the regional haze assessments to be performed for
emission sources in Arizona :

The technical analysis for Hawaii ’s Regional Haze FIP is focused on BART control options for four sources, updates of Hawaii’s emissions inventory (EI), and a compilation of information for Hawaii’s long

- term strategy. There are two Class I areas covered by these analyses that receive visibility protection under the Regional Haze Rule (RHR):
Halea kala National Park (HNP) on Maui, and Volcanoes National Park (VNP) on the Big
Island.
EPA’s guidance for setting R easonable P rogress G oal s (RPGs) toward meeting its 2064 natural background visibility target s under the Regional Haze Program describes long

- term strategy as “the compilation of ‘enforceable emissions limitations, compliance schedules, and other measures as necessary to achieve the [RPGs],’ and is the means through which the State ensures
that its RPG will be met. ”

Under this task, UNC and ICF collected information and performed qualitative analyses to support EPA’s development of a long

- term strategy for a regional haze program in Hawaii in accordance with the requirements of 40 CFR 51.308(d)(3)(iv) and (v). Hawaii has only one smoke managemen t plan to date, so there is a need to look at long

- term strategies for addressing regional haze in the state, and assess how each of those would affect visibility in the Hawaii Class I areas. Analysis of information covered the following factors:

 Emission reductions due to ongoing air pollution control programs, including C AL PUFF modeling performed by Trinity Consulting on four facilities named in the Work Plan

 Measures to mitigate the impacts of construction activities

 Emission limitations and schedules fo r compliance

 Source retirement and replacement schedules

 Smoke management plans and techniques for agricultural and forestry management

 Enforceability of emission limitations and control measures

 Projected changes in visibility due to point

- , area

- , shippi ng and mobile

- source emissions

, including the impacts of renewable sources of energy



## 2 Work Performed and Deliverable Summary

2.1 Emission reductions due to ongoing pollution control programs

In a letter to EPA Region IX on October 11, 201 1

, the Hawaiian Electr ic Company (HECO), on behalf of Maui Electric Company (MECO), and Hawaii Electric Light Company (HELCO) submitted an analysis of visibility impairment at the two Hawaii Class I Areas (CIAs), VNP and
HNP due to baseline emission from four electric power gen era ting (EPG) stations . These are namely Kanoelehua Hill, Puna and Shipman plants on the Big Island and Kahului Plant on Maui. The analysis also quantified the possible visibility benefits from burning lower sulfur fuels at these plants , from the baseline of 2% down to 0.5%. As expected the reduction in visibilityEMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 2 impact over baseline was greatest for the lowest sulfur content for all the facilities at either CIA, and in all modeled years. The impacts of all the facilities were, in general, worst at VNP due to the facilities on the Big Island, and at HNP due to the Maui facility (Kahului)

. HECO stated in its transmittal of these results to EPA Region IX that some of the analyzed reductions in sulfur content are not yet available in current refinement practic es. Also, the visibility impairment due to the Hill plant was above threshold at VNP even with the lowest sulfur option

. R enewable energy and energy conservation options are also being aggressively pursued by the state under new initiatives, as described in Section 2. 7

.



### 2.2 Measures to mitigate the impacts of construction activities
The potential sources of emissions from construction include exhaust from fuel

- burning equipment on the site; vehicles working on the site, delivering materials, and hauling away excavate; employee vehicles; fugitive dust from exposed earth, material stockpiles, and vehicles on roadways, especially unpaved site accesses; and fuel combustion and machinery at related facilities such as asphalt or cement plants. Construction activit ies can result in emissions of pollutants that are of concern to visibility including NO
x , SO
x , particulate matter (PM 10 and
PM 2.5 from engine exhaust and as fugitive dust from roadways and material handling) and primary organic aerosols. The EPA National Emissions Inventory (NEI) estimates that emissions of construction dust in Hawaii for 2008 (the most recent year for which data are available) totaled 21,858 tons of PM 10 of which 2,186 tons were PM 2.5 (EPA

, 2012) ; data shown
in th e sector summary are for primary (filterable plus condensable) PM. These construction dust emissions comprised 54% and 22% of the statewide emissions from all sources of PM 10 and
PM 2.5 , respectively.

Most regulation of construction emissions in Hawaii takes place at the state l evel. Hawaii’s four counties have ordinances that regulate construction emissions, primarily fugitive dust. There is no regulation of construction emissions below the county level of government because there are no incorporated towns or cities in Hawaii.

2.2.1 State of Hawaii Requirements The State of Hawaii regulates construction emissions under the Hawaii Administrative Rules

, Chapter 11

- 60.1 . These regulations are administered by the Hawaii Department of Health (DOH)

. Section 11

- 60.1

- 2 prohibits air pollut ion in general and allows the DOH to require mitigation of emissions, potentially including certain construction operations that are not c overed by more specific rules. Section 11

- 60.1

- 2 states : “ No person, including any public body, shall engage in

any ac tivity which causes air pollution or causes or allows the emission of any regulated or
hazardous air pollutant without first securing approval in writing from the director. The written approval from the director shall not release any person from compliance with any other applicable statutes, local laws, regulations, or ordinances. ”

Section 11

- 60.1

- 33 regulates f ugitive dust emissions, including prohibition of visible fugitive
dust . This section states:
(a) No person shall cause or permit visible fugitive dust to become airborne without taking reasonable precautions. Examples of reasonable precautions are:EMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 3 (1) Use of water or suitable chemicals for control of fugitive dust in the
demolition of existing buildings or structures, construction operations, the grading of roads, or the clearing of land; (2) Application of asphalt, water, or suitable chemicals on roads, material stockpiles, and other surfaces which may result in fugitive dust; (3) Installation and use of hoods, fans, and fabric filters to enclo se and vent the handling of dusty materials. Reasonable §11

- 60.1

- 33 60.1

- 42 containment methods shall be employed during sandblasting or other similar operations; (4) Covering all moving, open

- bodied trucks transporting materials which may
result in fugit ive dust; (5) Conducting agricultural operations, such as tilling of land and the application
of fertilizers, in such manner as to reasonably minimize fugitive dust; (6) Maintenance of roadways in a clean manner; and (7) Prompt removal from paved streets of earth or other materials that have been transported there by trucking, earth

- moving equipment, erosion, or other

means. (b) Except for persons engaged in agricultural operations or persons who can demonstrate
to the director that the best practical op eration or treatment is being implemented, no person shall cause or permit the discharge of visible fugitive dust beyond the property lot line on which the fugitive dust originates.

Section 11

- 60.1

- 34 regulates m otor vehicles and applies to many constructi on activities that
involve vehicles:

(a) No person shall operate a gasoline

- powered motor vehicle that emits visible smoke while upon streets, roads, or highways. (b) No person shall operate a diesel

- powered motor vehicle that emits visible smoke for a

pe riod of more than five consecutive seconds while upon streets, roads, or highways. (c) No person shall cause, suffer, or allow any engine to be in operation while the motor
vehicle is §11

- 60.1

- 35 60.1

- 43 stationary at a loading zone, parking or servicing area, route terminal, or other off street areas, except: (1) During adjustment or repair of the engine at a garage or similar place of repair; (2) During operation of ready

- mix trucks, cranes, hoists, and certain bulk carriers, or other auxiliary equipme nt built onto the vehicle or equipment that require power takeoff from the engine, provided that there is no visible discharge of smoke and the equipment is being used and operated for the

purposes as originally designed and intended. This exception shall not apply to operations of air conditioning equipment or systems; (3) During the loading or unloading of passengers, not to exceed three minutes;
and (4) During the buildup of pressure at the startup and cooling down at the closing
down of the engine for a period of not more than three minutes. (d) No person shall remove, dismantle, fail to maintain, or otherwise cause to be inoperative any equipment or feature constituting an operational element of the air pollution control system or mechanism of a moto r vehicle as required by the provisions of the Act except as permitted or authorized by law.EMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 4 2.2.2 County Requirements Hawai’i County , in which VNP is located, regulates construction emissions through its County Code. Chapter 10 of the Code, Erosion and Sedimen tation Control, several provisions within Article 2, Permits, and Article 3, Conditions and Specifications, require dust control measures.

Honolulu County (City and County of Honolulu) requires Best Management Practices related to construction emissions, i ncluding the following (Honolulu 2007):

B est M anage m ent Pract ic es include, but are not li m ited to, the f ollo wing:
l. In s tall silt fences or other appropriate meas ur es to control sedi m ent runoff at the perimeter of projects

. 2. Provide gravel or stabilized entrances to reduce mud tracking from t ru ck tires

.... 4. Co ver stockpiles

.... 7. Plan the construction phasing to reduce exposed; ground areas. 8. Grass or mulch the disturbed or exposed areas as soon as possible

. Kaua’i County does not have an ordinance speci fic to construction emissions. However,
Sediment and Erosion Control Ordinance No. 808 , administered by the Kaua’i County Department of Public works, specifies: “ Best Management Practices to be used to control dust emissions, sedimentation, and erosion to the maximum extent practicable by watering with truck or sprinklers, erection of dust and silt fences, limiting the area of disturbance, and timely grassing of disturbed areas. ” To implement Ordinance No. 808 , the Kaua’i County Department
of Public works issued a manual (Kaua’i County 2004), which states:

“ Dust control measures are used to stabilize soil from wind erosion, and reduce dust generated by construction activities

.... a pplicable f or heavily traveled and disturbed areas, wet suppression (watering), chemical dust suppression, gravel or asphalt surfacing, temporary gravel construction entrances, equipment wash

- out areas, and haul truck covers can be employed as dust control applications. Permanent or temporary vegetation and mulching and silt fences can be employed for areas of occasional or no construction
traffic. Preventive measures would include minimizing surface areas to be disturbed, limiting on

- site vehicle traffic to 15 miles per hour, and controlling the number and activity of vehicles on a site at any given time. ”

Maui County , in which HNP is located, regulates construction emissions through its Code of Ordinances. In the Code, Chapter 20.04.010

– Air Pollution establishes a general prohibition of air pollution nuisances and states: “ It is declared to be a public nuisance and unlawful for any person, firm or corporation in the County of Maui to cause, permit or allow to escape into the open air, smoke, soot, poisonous gases, dirt, dust or debris of any kind from any smokestack, chimney, flu e or incinerator, or any opening of any building, or from any smoldering or open fires under his or its charge or control in such a manner or in such a place as to cause annoyance, detriment, or injury to the health of persons or damage to property. ”

The M aui County Code of Ordinances, Chapter 20.08

– Soil Erosion and Sedimentation Control

, requires the use of Best Management Practices (bmps [ sic ]) in all instances, and requires a permit for certain construction activities. Several bmps specified in Sectio n 20.08.035 apply to construction air pollutant emissions, including the following:

B. Dust control. All areas disturbed by construction activities shall control dust
emissions to the maximum extent practicable through the application of bmps thatEMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 5 may incl ude watering with trucks or sprinklers, erection of dust fences, limiting the
area of disturbance, and ti mely grassing of finished areas....
D. Erosion controls. All disturbed areas shall be stabilized with erosion control

measures that may include: staging construction: clearing only areas essential for construction; ...[when] stockpiling topsoil, covering the stockpile to prevent dust, and reapplying the topsoil; covering or stabilizing all soil stockpiles; using wind erosion control;

... using seeding and fertili zing, mulching, sodding, matting, blankets, bonded fiber matrices, or other effective soil erosion control technique; and providing vehicle wheel wash facilities for vehicles before they leave the site

.... G. Timing of control measure implementation. Timing of control measure implementation shall be in accordance with the approved erosion control plan if such plan is required. At a minimum disturbed areas of construction sites that will not be

re

- disturbed for twenty

- one days or more will be stabilized (grass es or graveled) by
no later than the fourteenth day after last disturbance.



### 2.3 Emission Limitations and Schedules for Compliance

2.3.1 Regulatory Basis for Emission Limitations

Hawaii air quality is governed by the Federal Clean Air Act and Amendments including the
Title 40, Code of Federal Regulations, Part 50, National Primary and Secondary Ambient Air Quality Standards , consisting of:

 Part 51, Requirements for Preparation, Adoption, and Submittal of Implementation Plans

 Part 52.21, Prevention of Significant Dete rioration of Air Quality

 Part 53, Ambient Air Monitoring Reference and Equivalent Methods

 Part 58, Ambient Air Quality Surveillance

 Part 60, Standards of Performance for New Stationary Sources

 National Emission Standards for Hazardous Air Pollutants

 Part 63, National Emission Standards for Hazardous Air Pollutants for Source Categories

 Part 70, State Operating Permit Programs

In addition to the above, t here are a number of state laws and regulations that are associated with the control of air pollution in Hawaii

. The Hawaii Revised Statutes ( HRS), Chapter 342B, Air
Pollution Control provides for the control of air pollution. The Hawaii Administrative Rules ( HAR ), including HAR, Title 11, Chapter 59, Ambient Air Quality Standards

, and HAR, Title 11, Chapt er 60.1, Air Pollution Control

, authorize and direct the Clean Air Branch of the Hawaii Department of Human Health.

With respect to visibility, these rules ( §11

- 60.1

- 146 ) require that any covered source ’s permit application for a proposed major stationary source or major m odification, the em issions from which may affect a CIA , include an analysis of the proposed source's anticipated impacts on visibility in the CIA

.

Section 11

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- 93 of the HAR addresses f ederally enforceable permit terms and conditions an d specifies that the t erms and conditions included in a covered source permit, including anyEMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 6 provision designed to limit a source's potential to emit, are federally enforceable unless such terms, conditions, or requirements are specifically designated as n ot federally enforceable. Terms
and conditions left undesignated become federally enforceable upon permit issuance provided
the Administrator does not object during the forty

- five

- day review period.

2.3.2 Point Sources

Based upon the emission strength and proxim ity to the two Hawaii Class I Areas , four oil

- fired plants, namely Kanoelehua Hill, Puna and Shipman plants on the Big Island and Kahului Plant
on Maui were analyzed for control options by Trinity Consultants and submitted to EPA Region
IX Air Division in October 201 1 . The options considered were various levels of reduction in the residual oil sulfur content from the baseline 2% to 0.5%. At the time of HECO’s submission of
these results to EPA not all the grades of low

- sulfur oil were available. Since then Hawaii has
si gn ed the Clean Energy Agreement, committing to reducing the reliance on fossil

- fuel

- based energy, as well as investing in renewable sources such as wind energy and energy efficiency.

2.3.3 On

- Road Mobile Sources Visibility

- impairing emissions from motor vehicles will change in future years compared to present values due to two main factors: increase in vehicle activity, particularly miles traveled, and decreasing emissions from control programs.

We determined present and historical values of vehic le miles traveled (VMT) in the State of Hawaii using Highway Performance Monitoring System (HMPS) reports for 2005 and 2008. Although these reports of vehicle mileage by island for various road types do not separate VMT by vehicle type (which is critical for emissions estimation) that was determined from separate data source and is documented in the Task 16 report of this Work Assignment (WA)

. We estimated the change in total VMT and by vehicle type for 2018 by applying VMT growth
rates to 2010 HPMS value s uniformly for all counties. These annualized VMT growth rates were calculated for light

- duty vehicles, commercial light trucks, and freight trucks using AEO data, as discussed in the Task 16 report. The annualized rates are 1.59%, 2.49%, and 2.45%, respe ctively.

Results are presented in Figure 1 . Statewide, VMT is expected to grow 12% from 2008 (considered current values) to 2018, or at an annualized rate of about 1.1% per year.EMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 7 Figure 1

. Total VMT by county, in billions of vehicle miles traveled (VMT) per year for 2005,

2008, and 2018

We determined emissions for each year by performing analysis with the MOVES model , as discussed in the report on Task 16 of this WA

. Table 1 presents th e principal results of that analysis: the total of key primary emissions for each species of concern for each year and county. Note that the total PM components listed here are the sum of exhaust, brake wear, and tire wear. Additional details and species a re discussed in the Task 16 report.

Table 1

. Summary Table of On

- road vehicle emissions (metric tons) by county for key pollutants in 2005, 2008, and 2018

Year County Oxides of Nitrogen (NOx) Non

- Methane Hydrocarbons ( NMHC ) PM 10 - Total Sulfur Dioxide (SO 2 )

2005 Hawaii 3,546 2,042 113 58

Honolulu 14,203 8,475 432 216

Kauai 1,746 913 53 28

Maui 3,259 1,871 105 52

2008 Hawaii 2,530 1,441 97 17

Honolulu 9,713 5,957 374 67

Kauai 1,198 661 43 8

Maui 2,256 1,338 89 15

2018 Hawaii 925 646 70 12

Honolulu 3,361 2,688 278 50

Kauai 454 309 30 6

Maui 836 636 64 11

2005 Statewide 22,754 13,301 703 354

2008 Statewide 15,696 9,398 603 107EMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 8 2018 Statewide 5,575 4,280 441 79

It is clear from Table 1 that most pollutants show significant decreases over recent years, a trend projected to continue for the foreseeable future. Annualized reductions of NOx emissions from
2008 to 2018 are a bout 10%, while NMHC, PM 10 , and SO 2 are about 8%, 3%, and 3%, respectively.

This trend is due to the decrease in composite emissions factors for all species predicted by the
MOVES model. Figure 2 shows these composite factors

– total emissions per total a ctivity considering all vehicle types and all relevant pollutant processes. Values are shown on a semi

logarithmic chart so all pollutants may be compared.
Figure 2

. Composite emission factors for HI, statewide for key pollutants in 2005, 2008, and

2018

These decreasing emission rates overwhelm the increasing activities and lead to net reductions in emissions. The current version of the model, MOVES2010a, is EPA’s state

- of

- the

- art tool for estimating emissions from highway vehicles

, is based on analysis of millions of emission test
results

, and includes emission factor reductions from “booked” regulations, including new car and light truck greenhouse gas emissions standards.

Thus the predicted reductions in emission rates from motor vehicle emission cont rol programs are feasible. As these emissions are related to visibility impairment, the net reduction in emissions noted above will translate to a net reduction in visibility impairment from on

- road
motor vehicles.

2.3.4 Commercial Marine Vessel Emissions

Commer cial marine vessels include ocean going vessels, tugs pulling barges, ferries, commercial fishing vessels, and work boats. Ships are categorized by the propulsion engines they use

, as shown in Table 2

. 0.00

0.01 0.10 1.00 10.00

2000 2005 2010 2015 2020 Composite Emission Factor (g/mi) NOx

NMHC

PM10

SO2EMAQ LOE (EPA Contract EP

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Category Specification Use Approximate Power Ratings

1 Gross Engine Power ≥ 37 kW a

Displacement < 7 liters per cylinder Small tugs, fishing and workboats. Smaller auxiliary

engines < 1,000 kW

2 Displacement ≥ 7 and < 30 liters

per cylinder OGV auxiliary engines, larger tug, ferry, fishing and workboat propul sion engines 1,000

– 3,000 kW

3 Displacement ≥ 30 liters per cylinder OGV propulsion > 3,000 kW

a EPA assumes that all engines with a gross power below 37 kW are used for recreational applications and are treated separately from the commercial marine ca tegory. For Category 3 vessels and foreign flag Category 2 vessels, the North American Emission Control Area regulations specify sulfur levels in fuel and NOx controls as shown in Table 3

. Table 3. : North American ECA Requirements

Requirements Outside ECA Inside ECA
NO
x 20% reduction in new

vessels by 2011 80% reduction in new vessels by 2016 Fuel Sulfur (%) 2012: 3.50%

2020: 0.50%
The 2020 fuel standard could be delayed to 2025; subject to 2018 fuel availability review 2010

- 14: 1.00%
2015: 0.10%

U .S. flag Category 1 and 2 ships must use ultra

- low sulfur diesel fuel (ULSD) with a sulfur level of 15 ppm starting 2012. In addition, the non

- road marine rule (EPA, 2008) specifies NOx and
PM reduction in Tier 3 and Tier 4 standards that start phasing in 2013 through 2018.

The locations of the visibility and PM monitors representing e ach of the two CIAs of interest (VNP and HNP) were p rovided by EPA and are listed in Table 4

. A radius of 150 km was chosen for each park following EPA recommendations and i s shown in Figure 3

. Ports of interest within
the two CIAs are listed in Table 5. The emission reductions within these areas are discussed
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- 12.016. v 2 April 1 3 , 2012 10 Table 4 : Center of Class 1 Areas

Monitor Latitude Longitude

Ha l eakala (HACR) 20o 45' 30.6" N 156o 16' 56.28" W

Hawaii (HAVO) 19o 25' 50.84" N 155o 15' 28.44 W

Figure 3 : Class 1 Areas

Table 5 : Ports of Interest within the two Class 1 Areas

Class 1 Area Ports of Interest

Maui (HACR) Kahului, Maui

Lahaina, Maui

Kona, Hawaii

Kawaihae, Hawaii

Hawaii (HAVO) Hilo, Hawaii

Kona, Hawaii

Kawaihae, Hawaii



### 2.3.4.1 Hawaii Class I Area

Emission reductions from 2005 to 2018 are shown in Table 6

. These include all three categories of ships in port (within 1 nautical mile [nm] of port) and near port (from 1 to 30 nm from a port for ships that stop at that port). It does not include innocent passage of ships travelling by a port but not stopping or travel outside the 30 nm radius but still within the 150 km ra dius of the
monitor locations. As can be seen, PM 10 and PM 2.5 dec rease by 84% and SO
x by 97%. ThereEMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 11 was a 16% reduction in installed power (calls times total propulsion power) betw een 2005 and
2018 in VNP

. Table 6 : In Port and Near Port Emissions for Ports within the Hawaii CIA.

Analysis Year Tons per Year

NOx CO HC PM 10 PM 2.5 SOx CO 2

2005 619.03 55.84 21.19 59.79 55.14 642.02 40,777

2018 545.80 53.03 22.11 9.28 8.56 20.24 34,436

Reductions

- 12%

- 5% 4%

- 84%

- 84%

- 97%

- 16%



### 2.3.4.2 Maui Class I Area

Emission reductions from 2005 to 2018 are shown in Table 7

. These include all three categories of ships in port (within 1 nautical mile [ nm ] of port) and near port (from 1 to 30 nm from a port for ships that stop at that port). It does not include innocent passage of ships travelling by a port but not stopping or travel outside the 30 nm radius but still within the 150 km ra dius of the
monitor locations. PM 10 and PM 2.5 are seen to decease by 75% and SOx by 95%. There was a
29% increase in installed power between 2005 and 2018 in the Maui CIA

. Table 7 : In

- p ort and n ear

- p ort e missi ons for p orts within Maui Class 1 Area

.

Analysis Year Tons per Year

NOx CO HC PM 10 PM 2.5 SOx CO 2

2005 802.73 82.99 26.39 71.65 66.28 761.46 50,642

2018 979.17 103.52 40.51 17.76 16.42 36.87 65,409

Reductions 22% 25% 53%

- 75%

- 75%

- 95% 29%

Based on th ese projected emissions from marine vessels, the dramatic decreases in two of the visibility

- impairing pollutants (PM 10 /PM 2.5 ] and SO
x ) more than offset the increase in NO
x . Thus this source category is not expected to be a major source of visibility impai rment in the state of
Hawaii.



### 2.4 Source Retirement and Replacement Schedules

Since the time of the last emission inventory comp let ed by Environ International in 2010, several
small electric power generating ( EPG ) units in Hawaii have been retired. This incl udes a total of
about 35 MW including several small substation

- distributed generators and two small wind farms. ICF reviewed the last set of Integrated Resource Plans (IRPs) to assess the extent to which the utilities announced plans for retirements. HECO indicated that Wauai Units 3 and 4 would be placed into emergency reserve or retired in 2011 and 2014, respectively. Wauai Unit 3 does appear to still be in service and opera ting at a utilization of about 3% . HELCO, MECO, and
K auai Island Utility Cooperati ve (K IUC ) had no plans to retire any of their units in their last IRP.

Our understanding of the Clean Energy Agreement is that the utilities have agreed not to add any
new fossil fuel

- based generation over 2MW. The state and utilities have made a strong

co mmitment to meeting the state’s future energy nee ds using clean energy resources, including energy efficiency and renewa ble resources. This was solidified in the Clean Energy Initiative andEMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 12 the supporting Hawaii Clean Energy A greement 1 , which is a Memorand um of Understanding among the State of Hawaii, Division of Consumer Advocacy, and Hawaiian Electric Companies

. The agreement creates benchmarks and standards for all aspects of energy consumption in the state, i ncluding transportation. The agreement focuse s on a two

- fold approach to promoting clean energy. The first is to increase end use efficiency by 4,300 GWh/year by 2030 through energy efficient homes and appliances and by retrofitting infrastructure where necessary. This would lead to a 30% reduction i n projected demand by 2030. The second approach is to meet 40% of Hawaii’s remaining electricity demand with clean energy, where demand is defined as electricity sales plus efficiency savings. The agreement commits the parties to accelerate the addition of new, clean energy resources on all islands, including 1,000 MW of renewable energy resources on Oahu (which may include approximately 400 MW of wind power from Lanai or Molokai); 60 MW on the Island of Hawaii; and 50 MW on Maui.

Given these initiatives an d laws, there would seem to be a high probability that the Hawaiian utilities will be reducing output from some of their aging oil units over the next several years in response to the increased renewable resources, particularly for HELCO and HECO. On the b ig island of Hawaii, the addition of the Hu Honua Bioenergy facility will provide additional 24 MW of firm capacity fueled by eucalyptus trees grown on the island. This will allow HELCO to explore the possibility of retiring several of the older and more l ightly used oil combustion turbine and steam turbine units. As the oldest, least efficient, and second smallest facility in their portfolio, the 15 MW Shipman plant may be a candidate for retirement, as would the 7.5 MW Waimea facility, which operated at o nly 3.6% of capacity in 2008. The 21 MW Kanoelehua plant is also a very strong candidate for retirement, because it has a relatively high heat rate, and
because it only operated at 0.36% of its operating capacity in 2008.

On Oahu, there are also several ag ing oil plants that could have their output reduced substantially with the increase in clean energy resources. These units could potentially retire. Waiau and Honolulu are the two oldest and least efficient oil facilities that are owned by HECO; both plan ts from both have been mentioned before as possibilities for retirement in their most recent IRP.

Honolulu units 8 and 9 and Waiau units 3 and 4 could also be strong candidates for retirement in the next several years. The remaining Waiau units are also st rong possibilities as the H Power expansion, Honua Power Biomass, Campbell Industrial Park, and Honolulu International Airport Emergency Power facilities all increasingly provide power generation to Oahu’s grid using
biomass instead of oil.



### 2.5 Smoke Managemen t Plans

2.5.1 Agriculture Management

Air quality depend s on sound practices for managing agricultural waste burning, and prescribed burning for fuel suppression. A state

- by

- state survey of smoke management programs ( ECR

, 2001 a ) conducted for the Western Governo rs’ Association (WGA) shows that Hawaii’s agricultural fire emission s come from crop waste combustion over roughly 30,000 acres of

1 On October 20, 2008, Governor Lingle announced an Energy Agreement among the State of Hawaii, Division of
Consum er Advocacy, and Hawaiian Electric Companies. The pact streamlines the goal to separate Hawaii from dependence on oil and improve energy efficiency

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- 12.016. v 2 April 1 3 , 2012 13 sugarcane ; the sugarcane crop is cultivated mostly on Maui

. The burns occur usually from March

– November ; b urn permits are r equired, and weather conditions under which burns are permitted
are broadcast to facilitate controlled burning . Notifications of the relevant authorities in each county (Fire Alarm Bureau, Police Central Dispatch, local fire station, etc.) are required bef ore burn s . Records are required to be kept of burn ed area, time of day, prevailing wind conditions, amount of rainfall in the preceding 24 hours, type of material, and other pertinent data required by the Department of Health. While there is no smoke manag ement plan as such, widespread and persistent haze conditions are used as a criterion for not permitting agricultural burns. Haze in this case is defined as existing on all visible ridges, with a bluish appearance within a distance of
5

- 10 miles, and a blu rred appearance beyond 10 miles ; permittees are required to consult with local police to determine whether the haze is wide

- spread. A robust smoke management program might include posting more objective and quantitative requirements for the visibility cond itions
under which agricultural burn s are permitted.

2.5.2 Forestry management

Visibility

- impairing particulate emissions are highest in the current inventory for wildfires after

non

- point and dust sources, at ~ 9700 tons per year (TPY). The biggest contributor to wildfire emissions in the current inventory was a large fire that burned over 2 5,000 acres in 2005.
V olcano activity on the Big Island always poses a fire danger, but the problem can be exacerbated by the absence of comprehensive fuel suppression plan s through prescribed burns

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- 12.016. v 2 April 1 3 , 2012 14 Table 9. Frequency of smoke management method used by region (NE: Northeast; MW: Midwest; SW: Southwest ; PNW: Pacific Northwest

, and INT: Intermountain ). Alaska is included in PNW, and Hawaii in SE

.

From the National Wildlif e Coordination Group, 2001

. The Environ inventory held fire emissions constant at the 2005 levels in its 2018 projections for Hawaii, possibly because of the lack of a large

- scale smoke management plan . According to the WGA survey of 2001 on smoke manageme nt for forests in Hawaii (ECR, 2001b) p rescribed burning practices to control fuel were not in place. Burn permitting was the process through
which all fires we re controlle d and prescribed burning appeared to be applicable only to the sugarcane producers

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- 12.016. v 2 April 1 3 , 2012 15 management plans have been implemented and are administered through the U.S. Fish & Wildlife Service at some of the National Wildlife Refuges (NWRs) in Hawaii, e.g., Kealia Pond
NWR on Maui, and Hakalau Forest NWR near Hilo on the Big Island

. The Hawaii Department of Land and Natural Resources (DLNR) Division of Forestry and Wildlife “ takes measures for the prevention, control, and extinguishment of wildland fires within forest reser ves, public hunting areas, wildlife and plant sanctuaries, and natural area reserves ”

. The Smoke Management Guide published by the National Wildfire Coordination Group (NWCG, 2001) lists a number of steps (Table 9) for emission redistribution that can redu ce the impacts and emissions from prescribed burns. The practices used in the Southeast cover Hawaii wildland fire prevention

.



### 2.6 Enforceability of Control Measures

40 CFR 51.308(d)(3)(v)(F) of the Regional Haze Rule (RHR) requires that emission limitations
and control measures used to meet RPGs are enforceable . In addition to this requirement, the Regional Haze Plan may impose certain schedules for requisite emission reductions toward these
RPGs. Any additional emissions reductions would be enforceable thro ugh the facilities operating permits.



### 2.7 Qualitative Analysis of Emissions Projections and Renewable Energy, and Impacts on Visibility

The estimated emissions for the sources identified for BART and Reasonable Progress analysis in Hawaii, including sources at the Kanoelehua, Hill, Puna, Shipman, and Kahului power plants

, indicate significant potential reductions in emissions at these plants due to the control technology . The methodology was based on a set of assumptions about the growth in clean

energy resou rces, and the corresponding reduction in fossil

- fuel emissions based on their technology, fuel and efficiency and how those would influence the plant’s utilization. Using these simple heuristics, these plants could experience significant red uctions in outp ut through 2018, or retirement. Thus existing control technologies in the current climate of fossil

- fuel emissions reductions in Hawaii are expected to facilitate the meeting of its long

- term visibility goals.

In addition to limiting the size of fossil

- f uel based generation in the future, t he Clean Energy
A greement also indicates that the utilities will retire existing, less efficient fossil

- fired units by “removing such units from normal daily operating service as expeditiously as possible without

compro mising service reliability”. The agreement also indicates that the parties would seek legislative changes to the existing Renewable Portfolio Standard (RPS) to increase it to 25% (from 20%) by 2020 and 40% by 2030, with limits on biofuel use in utility uni ts.
The state RPS was subsequently amended. Established in 2001 and expanded in 2009 2 , the RPS requires that 40% of the net electricity sales must come from renewable sources by the end of 2030. In this situation, electricity sales are fundamentally diffe rent from the electricity demand

2 O n June 25, 2009 Hawaii Governor Linda Lingle signed into law three energy bills designed to promote the development of in

- state renewable energy technology and energy efficiency. HB 1464 extends and increases Hawaii’s current renewable electricity portfolio standard (RPS) to 40% by 2030; HB 1464 establishes a separate energy efficiency standard for electric utilities designed to achieve energy savings of 4,300 GWh by the year 2030.EMAQ LOE (EPA Contract EP

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- 12.016. v 2 April 1 3 , 2012 16 terminology used in the Agreement because they do not include the efficiency savings component.
In addition to the establishing a 2030 goal, the agreements include binding benchmark requirements along the way to ensure tha t the utilities build up their portfolios over time. The utilities must meet 10% of their net electricity sales from renewable sources by the end of 2010, 15% by the end of 2015, and 25% by the end of 2020. The 2009 expansion also formalized one of the goa ls by creating the Energy Efficiency Portfolio Standard, with the same goal of demand

side reduction of 4,300 GWh/year by 2030. Currently, Hawaii appears to be on a track that
would allow it to meet its replacement goals for fossil

- fuel based energy ; in 20 11

, HECO and its subsidiaries supplied 12% of their electricity sales from renewable sources.

A strategy that could be considered for assessing the visibility benefits of these renewable energy sources is to derive a metric for the renewable energy benefi t in terms of an equivalent percent
reduction in sulfur. Previous control strategy analyses have established the visibility benefit per percent reduction in sulfur, which could then be used to translate the renewable energy source’s benefit in improving vi sibility toward meeting Hawaii’s Reasonable Progress Goals.



## 3 Conclusions

The following is a summary of our conclusions in each of the areas considered in the Hawaii LTS toward meeting its visibility goals.

i. Ongoing pollution control programs: The State of Hawaii’s clean energy programs will likely decrease emissions from the significant point sources on Maui and the island of Hawaii. However, these state programs do not provide for federally enforceable emissions reductions. So, while we expect emissions of point sources to go down, the plan cannot assume that they will unless additional controls are applied.

ii. Impact of construction activities: We have reviewed the Sta te and county regulations and permit requirements rela ted to construction emissions. We did not identify any studies on the contribution of emissions from construction activities to visibility impairment in
Hawaii CIAs , and therefore, we are unable to quan tify the role of construction emissions in visibility impairment in the State

. An analysis of monitoring data at the Class I areas will address that possib ility. Based on our review, we believe that coarse PM from
construction activities will have no sign ificant impact on the CIAs as it gets deposited near construction sites and does not contribute significantly to the long

- range transport of PM. Current Hawaii regulations adequately address construction activities and satisfy the requirement in the Region al Haze Rule to consider “measures to mitigate the impacts of construction activities,” because the regulations already require measures to minimize
emissions from these sources.

iii. Emission limitations and schedules for compliance: The projected schedule fo r retirement and/or replacement by renewable energy of point sources indicates that these small point source emissions will not prevent Hawaii from meeting its long

- term visibilit y target.

iv. Source retirement and replacement schedules: S evera l point sources have been retired since the last inventory, and fossil

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- 12.016. v 2 April 1 3 , 2012 17 v. Smoke management plans and techniques for agricultural and forestry management : Sound forest management plans for fuel suppression are needed, given the probability of wildfire ignition by lava; agricultura l waste disposal alternatives to crop waste
combustion also need to be part of Hawaii’s long

- term strategy for visibility. This will be important for both air quality and returning carbon to the soil in the future, as studies
do n e in Brazil on alternatives to pre

- harvest burning of sugarcane crop have shown ( Machado Pinheiro et al., 2010).

vi. Enforceability of emission limitations and control measures : the RHR is the main
enforceable rule that ensures the emission controls needed to meet the RPGs for visibility. Fuel sampling and robust recordkeeping will further the goals of controlling power plant emissions. Dust emissions from paved and unpaved roads are already

govern ed by enforcement of regulations on construction activities. Fire emissions from crop waste combustion and prescribed burning are governed by burn permits and restrictions on burn conditions; a comprehensive smoke management program coul d be beneficial in implementing effective smoke control measures.

vii. Projected changes due to point

- , area

- , shipping and mobile

- source emissions including the impact of renewable energy: The Clean Energy Agreement between the State of Hawaii, the Division o f Consumer Advocacy and the Hawaiian Electric Companies
indicates no new fossil

- fuel based genera tion larger than 2MW. Renewable energy will be used to replace fossil

- fuel sources on all the islands. The combined effect of these retirement/replacement sche dules should decrease NO
x , SO
x and PM emissions significantly over the next 25 years.

The decreasing emission trends of on

- road mobile source emissions in all species emitted overwhelm the increasing activities and lead to net reductions in emissions . The EPA
MOVES model, predicts achievable reductions in emission rates from motor vehicle emission control programs. We conclude that the net reduction in emissions noted above will translate to a net reduction in visibility impairment from on

- road motor vehicles.

Commercial marine vessels are an important source of emissions for the Hawaiian Islands. Our analysis of commercial vessel emissions in 2005 and 2018 was part of the updated inventory. It shows that dramatic decreases in shipping emissions of two of three visibility

- impairing pollutants ( PM 2.5 and SO
x ) more than offset increases in the third ( NO
x )

.



## References

ECR, 2001a. Agricultural burning smoke management program survey prepared for the Western Governors’ Association by EC/R Incorporated, Marc h 30, 2001, Contract No. 30202

- 11.
ECR, 2001b. Wildland smoke management program survey prepared for the Western Governors’ Association by EC/R Incorporated, January 26, 2001, Contract No. 30202

- 11.
EPA (U.S. Environmental Protection Agency). 2012. T he N ational Emissions Inventory. Sector
Summaries , Office of Air Quality Planning and Standards, U. S. Environmental Protection Agency, Research Triangle Park, NC

. http://www.epa.gov/ttnchie1/n et/2008inventory.html

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- 12.016. v 2 April 1 3 , 2012 18 EPA, 2008. Final Regulatory Impact Analysis: Control of Emissions of Air Pollution from Locomotives and Marine Compression

- Ignition Engines L ess Than 30 Liters per Cylinder

, EPA420

- R

- 08

- 001a, May 2008. http://www.epa.gov/otaq/regs/nonroad/420r08001a.pdf

Honolulu (City and County of Honolulu)

, 2007. Information Sheet: Controlling Soil Erosion and
Sedimentation

. http://honoluludpp.org/downloadpdf/engineering/soil.pdf
Kaua’i County, Hawaii. 2004. Interim Construction Best Management Practices (BMP' s ) for
Sediment and Erosion Control for the County of Kaua'i

. http://www.kauai.gov/Government/Departments/PublicWorks/Engineering/DesignampPermi tting/tabid/133/Default.aspx

NW C G (National Wildfire Coordination Group ) , 2001. Smoke Management Guide for
Prescribed and Wildland Fire 2001 Edition , Hardy, C. C., R. D. Ottmar, J. L. Peterson,
J. E

. Core, and P. Seamon (eds.), National Interagency Fire Center, 3833 S . Development Ave., Boise, ID 83705

. http://www.nwcg.gov

. Machado Pinheiro, E

., E . Lima, M. Ceddia, S. Urquiaga, B. Alves, and R. Boddey, 2010. Impact of pre

- harvest burning versus trash conservation on soil carbon and nitrogen stocks on a sugarcane plantation in the Brazilian Atlantic forest region

, P lant and Soil, 333 ( 1

- 2 )

, 71

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. Pitchford, M., 2005. Causes of haze update. Presented to the WRAP Attribution of Haze Working Group, May 26, 2005.