Technical Analysis for Arizona and Hawaii Regional 

Haze FIPs: Task 17: Information and Analysis to 

Support Hawaii’s Long-Term Strategy

Contract No: EP-D-07-102

Work Assignment: 5-12

Version: 2

Prepared for: Thomas Webb

Air Planning Office

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 Haydel, Lou Browning, Seth Hartley

and David Ernst

ICF International

Date delivered: April 13, 2012
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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 Qualitative Analysis of Emissions Projections and Renewable Energy, and Impacts on 

Visibility ............................................................................................................... 15

3 Conclusions........................................................................................................................... 16

References.................................................................................................................................... 17
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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): 

Haleakala National Park (HNP) on Maui, and Volcanoes National Park (VNP) on the Big 

Island. 

EPA’s guidance for setting Reasonable Progress Goals (RPGs) toward meeting its 2064 natural 

background visibility targets 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 management 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 CALPUFF 

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 for 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-, shipping 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, 2011, the Hawaiian Electric 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 generating (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 visibility 
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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 practices. Also, the 

visibility impairment due to the Hill plant was above threshold at VNP even with the lowest 

sulfur option. Renewable 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 activities can result in emissions of 

pollutants that are of concern to visibility including NOx, SOx, particulate matter (PM10 and 

PM2.5 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 PM10 of which 2,186 tons were PM2.5 (EPA, 2012); data shown 

in the 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 PM10 and 

PM2.5, respectively. 

Most regulation of construction emissions in Hawaii takes place at the state level. 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 pollution in general and allows the DOH to require mitigation of 

emissions, potentially including certain construction operations that are not covered by more 

specific rules. Section 11-60.1-2 states: “No person, including any public body, shall engage in 

any activity 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 fugitive 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:
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(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 enclose 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 fugitive 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 operation 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 motor vehicles and applies to many construction 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 

period 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 equipment 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 motor vehicle as required by the

provisions of the Act except as permitted or authorized by law.
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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 Sedimentation 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, including the following (Honolulu 2007):

Best Management Practices include, but are not limited to, the following:

l. Install silt fences or other appropriate measures to control sediment runoff at the 

perimeter of projects.

2. Provide gravel or stabilized entrances to reduce mud tracking from truck tires....

4. Cover 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 specific 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....applicable for 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, flue 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 Maui 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 Section 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 that 
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may include watering with trucks or sprinklers, erection of dust fences, limiting the 

area of disturbance, and timely 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 fertilizing, 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 (grasses 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 Deterioration 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, there 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, Chapter 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 modification, the emissions from 

which may affect a CIA, include an analysis of the proposed source's anticipated impacts on 

visibility in the CIA.

Section 11-60.1-93 of the HAR addresses federally enforceable permit terms and conditions and 

specifies that the terms and conditions included in a covered source permit, including any 
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provision designed to limit a source's potential to emit, are federally enforceable unless such 

terms, conditions, or requirements are specifically designated as not 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 proximity 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 2011. 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 

signed 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 vehicle 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 values 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%, respectively. 

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. 
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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 the 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 are 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)

PM10 - Total Sulfur Dioxide (SO2)

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 9,398 603 107 

2005 2008 2018

Kauai 0.79 0.78 0.88

Maui 1.43 1.42 1.60

Hawaii 1.65 1.64 1.84

Honolulu 6.25 6.37 7.09

0

2

4

6

8

10

12

Annual VMT, in billions
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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 about 10%, while NMHC, PM10, and SO2 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 activity 

considering all vehicle types and all relevant pollutant processes. Values are shown on a semilogarithmic 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 control 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

Commercial 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

SO2
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Table 2: EPA Marine Compression Ignition Engine Categories

Category Specification Use

Approximate 

Power 

Ratings

1

Gross Engine Power ≥ 37 kWa

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 

propulsion 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 category.

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

NOx 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 each of the two CIAs of interest 

(VNP and HNP) were provided by EPA and are listed in Table 4. A radius of 150 km was chosen 

for each park following EPA recommendations and is shown in Figure 3. Ports of interest within 

the two CIAs are listed in Table 5. The emission reductions within these areas are discussed 

below.
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Table 4: Center of Class 1 Areas

Monitor Latitude Longitude

Haleakala (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 radius of the 

monitor locations. As can be seen, PM10 and PM2.5 decrease by 84% and SOx by 97%. There 
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was a 16% reduction in installed power (calls times total propulsion power) between 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 PM10 PM2.5 SOx CO2

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 1nautical 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 radius of the 

monitor locations. PM10 and PM2.5 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-port and near-port emissions for ports within Maui Class 1 Area.

Analysis 

Year

Tons per Year

NOx CO HC PM10 PM2.5 SOx CO2

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 these projected emissions from marine vessels, the dramatic decreases in two of the 

visibility-impairing pollutants (PM10/PM2.5] and SOx) more than offset the increase in NOx. Thus 

this source category is not expected to be a major source of visibility impairment in the state of 

Hawaii. 

2.4 Source Retirement and Replacement Schedules

Since the time of the last emission inventory completed by Environ International in 2010, several 

small electric power generating (EPG) units in Hawaii have been retired. This includes 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 operating at a utilization of about 3%. HELCO, MECO, and 

Kauai Island Utility Cooperative (KIUC) 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 

commitment to meeting the state’s future energy needs using clean energy resources, including 

energy efficiency and renewable resources. This was solidified in the Clean Energy Initiative and 
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the supporting Hawaii Clean Energy Agreement1, which is a Memorandum 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, including transportation. The agreement focuses 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 in 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 and 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 big 

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 lightly 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 only 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 aging 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 plants 

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 strong 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 Management Plans

2.5.1 Agriculture Management

Air quality depends on sound practices for managing agricultural waste burning, and prescribed 

burning for fuel suppression. A state-by-state survey of smoke management programs (ECR, 

2001a) conducted for the Western Governors’ Association (WGA) shows that Hawaii’s 

agricultural fire emissions 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 

Consumer 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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sugarcane; the sugarcane crop is cultivated mostly on Maui. The burns occur usually from March 

– November; burn permits are required, 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 before 

burns. Records are required to be kept of burned 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 management 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 blurred 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 conditions 

under which agricultural burns 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 25,000 acres in 2005. 

Volcano activity on the Big Island always poses a fire danger, but the problem can be 

exacerbated by the absence of comprehensive fuel suppression plans through prescribed burns.
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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 Wildlife 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 management for forests in Hawaii (ECR, 2001b) prescribed 

burning practices to control fuel were not in place. Burn permitting was the process through 

which all fires were controlled and prescribed burning appeared to be applicable only to the 

sugarcane producers, based on the survey responses. Since the time of the survey, wildland fire 
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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 reserves, 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 reduce 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 through 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 resources, 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 reductions in output 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-fuel based generation in the future, the Clean Energy 

Agreement 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 

compromising 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 units. 

The state RPS was subsequently amended. Established in 2001 and expanded in 20092, 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 different from the electricity demand 

 

2 On 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.
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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 that 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 goals by creating the Energy Efficiency Portfolio Standard, with the same goal of demandside 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 2011, 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 benefit 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 visibility 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 State and county regulations and 

permit requirements related 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 quantify the role of construction emissions 

in visibility impairment in the State. An analysis of monitoring data at the Class I areas 

will address that possibility. Based on our review, we believe that coarse PM from

construction activities will have no significant 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 Regional 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 for 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 visibility target. 

iv. Source retirement and replacement schedules: Several point sources have been retired 

since the last inventory, and fossil-fuel plants are expected to be replaced within the next 

15-20 years.
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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; agricultural 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 

done 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 

governed 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 could 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 of Consumer Advocacy and the Hawaiian Electric Companies 

indicates no new fossil-fuel based generation larger than 2MW. Renewable energy will 

be used to replace fossil-fuel sources on all the islands. The combined effect of these 

retirement/replacement schedules should decrease NOx, SOx 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 (PM2.5 and SOx) more than offset increases in the third 

(NOx). 

References

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Governors’ Association by EC/R Incorporated, March 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. The National 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/net/2008inventory.html. 
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