**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

1 

### GUIDA **NCE TOPICS**  **Topic III: The**  **URP and**  **RPG Framework**  **Relevant Background**  The current RHR requires states to determine 2000

- 2004 baseline manmade visibility impairment conditions for the 20% best and 20% worst day s, and to determine natural visibility conditions for the same two sets of days. States project their visibility conditions for the end of the planning period for the 20% best and 20% worst days using a photochemical air quality modeling sys tem to project the net effect of their long term strat egy

of emission controls. The projected values are referred to as reasonable progress goals (RPGs)

. The RPGs are used in later progress reports as points of comparison to most recent visibility conditions. Progress reports are required to include a state d etermination of whether the SIP is adequate to ensure that the progress goals will be achieved by the end of the planning period. The existing URP and RPG framework for setting RPGs and tracking progress towards those goals is susceptible, at some Class I areas, to substantial year - to - year variability due to natural events with significant visibility impacts, such as large wildfires and dust storms. This is illustrated for one Class I area in the following figure of annual deciview values for the 20% worst day s. This variability is dampened but not always removed b y the use of a 5

- ye ar moving average.

In addition, because the analy tical procedure for setting RPGs does not distinguish between domestic and international anthropogenic emissions, the current R PG framework can mask progress that a state air agency may be making

. Virtually all stakeholders were concerned and recommended that the EPA provide rule changes or guidance for visibility

progress metrics that focuses on reducing controllable emissions. In response to this feedback, we intend to issue guidance that focuses visibility progress metrics on reducing U.S. anthropogenic emissions

.**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

2 **Issues A. Issue Statement**  **– Addressing the**  **Impact of Natural Events** Questions 1. Is it appropriate to remove (or possibly adjust) days that are dominated by natural events from the 20% worst set of day s , for event types whose impact varies a lot from year to ye ar , as a way

of making more evident an y progress that has been and will be a chieved by control of anthropogenic sources ? Are such event ty pes limited to wildfires and dust storms, or are other event ty pes of concern? 2. After internal discussion and close reading of the RHR as a whole , including definitions, the EPA workgroup currently believes that removing (or possibl y adjust ing ) day s that are dominated by

natural events is consistent with the existing Regional Haze Rule (RHR)

. Do you agree, or do you believe the RHR would need to be amended to allow this? If you agree that the RHR allows this, should the rule be amended for clarity on this issue ? Here are relevant definitions from the RHR: Visibility impairment means an y humanl y perceptible change in visibility (light extinction, v isual range, contrast, coloration) from that which would have existed under natural c onditions. Most impaired days means the average visibility impairment (measured in deciviews) for the twenty percent of monitored day s in a calendar year with the highest amount of visibility impairment. 3. What are the most important of the following factors that EPA and others could consider when developing a method for removing (or possibly adjusting) day s with poor visibility due to natural causes? o Good science. o Consistency

.  Should there be o ne c ommon , consensus method across Class I areas and states, poss ibly

with area

- specific details? Or, should the state with the Class Iarea pick the method?
 Is consensus and commonality more important among the western states because they

have closely

spaced Class I areas an d many fires , compared to the east ? o Resource burden (data, labor, and calendar time )

.  Because every

Class I area will be tracked, every IMPROVE site

- day

will need to be assessed, over the next several decades. This is different than for exceptional events for purposes of the NAAQS. o Objectiv ity . How important is it that the assessment of an IMPROVE site

- day be objective once the method and criteria have been established, versus it involving an element of judgment such as in a weight

- of

- evidence approach? 4. Sho uld the approach aim (i) to remove the influence only of natural events that are highl y irregular in their impacts in different ye ars (which may be sufficient to eliminate highl y irregular trend lines) , and then (ii) rank the day s to identify the 20% with the highest light**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

3 extinction (even though these generall y would not be the 20% most impaired by manmade causes, strictl y speaking) ?

 If this is the preferred approach , then identifying site

- day s with visibility impairment from highl y i rregular natural event s might rel y on a threshold for determining that a site

- day has been sufficiently affected by such natural sources to merit special treatment. How should a threshold ( s ) be picked?
 In this approach, o nce a site

- day has been identified as having been dominated by

an irregularly

occurring event such as a fire or dust storm, should that day

be removed completel y , or should the monitoring data for that day be adjusted b y replacing some PM component concentrations with default values? Removing days has the potential of changing the apparent transport linkage between manmade sources and Class I areas.
 How should the default values be picked? I s the IMPROVE protocol for data substitution when valid filter data is not obtained appropriate?
 If a day

is removed , should the next

- ranked day be brought into the 20% most impaired group? 5. Or, should the approach aim (i) to determine natural and manmade contributions to light extinction for every

day , and then (ii) rank the days to identify the 20% with the highest manmade impairment ?

 This approach directl y address es the CAA goal of reducing manmade visibility impairment.
 If this is the preferred approach, a method would be needed to allocate and adjust PM components between natural and manmade sources

. 6. Given the goal of focusing the framework on control of manmade emissions , the factors for consideration listed in Question 3, and the two possible approaches for removing or adjusting IMPROVE data, what would be the most appropriate anal yt ical method, under each of the two approaches ? Possible analy tical methods that have been discussed within EPA and con sidered to have some promise include the following: o Using fixed thresholds (possibly site

- specific but the same for all years) for carbon, fine soil, and coarse PM to ide ntify site

- day s as having been dominated by fires or dust storms , which are the most obvious irregularl y occurring natural sources , and substituting default IMPROVE values for these PM components. o Using trajecto ries and emissions inventories to allocate mo nitored PM species concentrations among natural sources (including fires) and manmade sources. 1 o Regional scale air quality modeling with source apportionment based on emission inventories including fires. 7. Is it possible and appropriate to distingu ish between wild fires and wildland prescribed fires when removing (or adjusting) day s from the 20% worst set? I s it a significant problem if we cannot recommend or require a practical method for making this distinction, or is it a de minimis departure from th e ideal?

1 Some meeting attendees may already be familiar with exploratory work of this nature by Scott Copeland.**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

4 8. Is there a useful role for pollutant

- specific glide paths as a supplement to the glide path anal ys is required by

the RHR, either as interpreted in the first planning period or reinterpreted as described in these questions? **B . Issue Statement**  **– Non**  **- U.S. Anthropogenic Emissions**  Stakeholders have also expressed concern that monitored most recent period visibility impairment can include the effects of non

- U.S. emissions which no state can influence, ye t the 2064 natural conditions end point does no t include such impacts, at least in principle. Questions 1. If EPA were to propose to change the RHR in this area so that impacts of non

- U.S. anthropogenic emissions were consistently included or excluded from elements on the URP and RPG framework, which is n ot currentl y certain, how could these impacts be estimated, on a consistent basis? o If these impacts were allowed to be added to the 2064 end point of the URP line, how could global scale modeling be used to estimate the impacts of non

- U.S. anthropogenic em issions? 2. Assuming that without a rule change the impact of anthropogenic sources outside the U.S. cannot be added to the 2064 end point of the URP line, how else can guidance help air agencies, and the public who comment on draft SIPs and on progress repo rts, focus on progress being made in the control of anthropogenic sources within the U.S? o For example, would it be helpful if EPA recommended that SIPs and progress reports include a second, informational

- only URP diagram that is based on the 2064 end point including impacts from non

- U.S. anthropogenic sources? **C . Issue Statement**  **– Natural Conditions and**  **2000 -**  **2004 Baseline Visibility Conditions** Modifying the way

that baseline visibility

on the 20% most impaired day s is determined, by removing (or adjusting) some of the day s that have the worst 20% overall visibility , would raise the issue of consistency between the resulting metric tracked for progress reports, the 2000

- 2004 baseline visibility conditions, and natural conditions. Questions 1. Should baseline conditions (the 2000

- 2004 starting point for the URP line), projected 2028 air quality

conditions, and n atural conditions (the 2064 end point of the URP line ) to the extent possible be re

- determined for each Class Iarea on a basis that is consistent with the exclusions used for the most recent period ? o For example, consistency between the 2028 projection (the RPG) and the metric that is tracked on a rolling 5

- ye ar average basis might be improved by similarly removing from the modeling base ye ar , for example 2014, an y days that were similarly affected by

natural events , before calculating and appl y relative response factors
. o Assuming that the approach in Question 4 above (removal/adjustment only of day s affected by very

irregular natural events) is followed, c onsistency might also mean that estimates of natural conditions should be revised to represent natur al**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

5 conditions except for the influence of such irregular natural events, i.e., natural conditions in the absence of such irregular natural sources would need to be estimated

. This would require a reconsideration of the 20% worst natural visibility conditio ns that were used in the first planning period because at least in concept these values were meant to reflect contribution s from all natural sources including irregular extreme events. o Assuming that the approach in Question 5 above (allocation of all light extinction between manmade and natural sources on all day s) is followed, then in concept the natural visibility

conditions that were used in the first planning period would be appropriate for use. 2. What other consistency issues need to addressed, and how? 3. More generall y, should the values used for natural conditions in the SIPs for the first planning period (those recommended b y the “Natural Conditions II” workgroup) be reconsidered? How should this be approached?

**D . Issue Statement**  **– Translating the Long**  **Term Strategy into Reaso nable Progress Goal**  **s** This is the topic of the EPA guidance document “Modeling Guidance for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5 and Regional Haze,” a draft revision of which is currently

available for comme nt, dated December 2014. This draft revision contains only minor changes to the regional haze sections, but further changes will be made to maintain alignment between this guidance document and any new EPA guidance on the RPG framework. EPA expects that th e basic concept will be maintained that the 2028 RPG should be set by projecting the air quality outcome that will be produced b y the measures in the long term strategy
. Question 1. What issues, for example the issue of the base ye ar for modeling, should EPA address more specifically

or differently? o**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

6 

### Topic IV: Reasonable Progress and Long Term Strategy **(Four Factors)**  **Relevant Background**  For the next (and subsequent) regional haze planning periods, RH SIPs will focus on achieving additional emission reductions needed to make reasonable progress towards the goal of preventing and remedyi ng impairment in visibility at Class Iareas due to manmade air pollution. The Clean Air Act and the RHR require that four factors must be considered in determining whether the long term strategy in the SIP provides for reasonable progress towards this goal:

 T he costs of compliance

.  T he time necessary

for compliance

.  T he energy

and non

- air quality

environmental impacts of compliance

.  T he remaining useful life of any potentially affected sources

. The URP and RPG framework play a role in the assessment of whether a SIP provides for reasonable progress. Under the current RHR, the URP line (or “glidepath”) is an anal yt ical framework. Adopting a 20% worst day s RPG for a Class Iarea (corresponding to the long term strategy) that is on the URP line does not per se mean that a SIP provides for reasonable progress at that Class Iarea. An RPG that is above the URP line does not per se mean that a SIP does not provide reasonable progress. The RHR provides that if the RPG for the worst 20% of day s that corresponds to the long term strategy is above the URP line, the state must demonstrate, based on the four factors, that the rate of progress that would be necessary for the implementation plan to attain natural conditions by 2064 is not reasonable; and that the progress goal adopted by the State is reasonable. The State mus t also provide to the public for review as part of its implementation plan an assessment of the number of years it would take to attain natural conditions if visibility

improvement continues at the rate of progress selected by the State as reasonable. The RHR say s that the RPG for 20% best day s, i.e., the projected visibility conditions at the end of the planning period resulting from the long term strategy , may not be higher than in the baseline period

. The RHR does not explicitly require a state to consider visibility impacts of individual sources when selecting additional controls for inclusion in its long term strategy . EPA has stated that states may

consider such impacts, and EPA has done so in developing FIPs. All stakeholders expressed concern w ith the existin g EPA guidance for setting RPGs, and recommended that EPA more clearl y articulate expectations for how to consider the reasonable progress four factors and visibility benefits and how to conduct a demonstration showing that these factors we re taken into consideration in establishing RPGs. EPA has received mixed input on the topic of the role of visibility impacts in developing the long term strategy . Some stakeholders recommended that visibility be made an explicit “fifth” factor. Some stak eholders were concerned that a possible outcome of having visibility impacts be considered a fifth factor could be that few additional controls would be incorporated into the long term strategy

even though man y additional control options with some visibili ty benefits**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

7 may be available, because each in isolation would have onl y a small effect compared to the visibility threshold values that were typically used for BART purposes in the first planning period. **Issues A.**  **Issue Statement –**  **Determining cross -** **state impacts**  These determinations are important because they affect state

- to - state consultation requirements and the analy sis of what additional emission controls are needed to make reasonable progress for each Class I area. In the first planning period, states used a variety of methods to make these determinations, some based on explicit modeling and some not. Questions 1. Were an y of the methods used in previous SIPs particularl y strong or weak in terms of technical validity? 2. How resource intensive were these methods? Will resources be available to use these methods again? 3. Should EPA provide additional guidance on way s in which this can be done? What should it say

about the analy sis method? About the threshold for a contribution to create a linkage? 4. Should EPA app rove a new SIP submission for this element if it simply carries over the attribution findings of the previous ly approved SIP regarding which Class I areas are affected , without new analy sis? Should this only be possible if certain conditions are met? For example, if the state’s emissions have not increased, should EPA approve the SIP if it relied on the same anal ys is conducted for the first planning period? 5. Should these linkages be based on most recent conditions, or on projections of state

- to state impacts in 2028 (or a convenient projection year near 2028) assuming “on the books” controls? **B. Issue Statement**  **– L**  **inkage between the URP and**  **the determination**  **of whether the long**  **term strategy provides reasonable progress**  Questions 1. How s hould EPA guidance address situations where a long term strategy and corresponding RPG for the 20% worst day s indicate that a state is on or below the URP line ? For example, should such situations constitute reasonable progress, without further source - specific four factor anal ys is? 2. Should EPA guidance encourage states to adopt long term strategies and RPGs for the 20% best day s that provide for definite improvement on those day s? How much improvement? **C . Issue Statement**  **– Tiering (or s**  **creen ing out**  **) source** **s for the**  **four factor analysis** How can the process or criteria EPA may recommend in guidance for determining whether additional controls are needed for reasonable progress be structured in a common sense**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

8 manner ? For example, w ould a low

- resource tiering (or screening) procedure and criteria be useful , with different recommendations for further anal ys is for sources in different tiers ? Questions 1. What procedure and criteria are appropriate? o For example, i s there a value of Q/d that would be appropriatel y recommended for this purpose? o Is there an alternative screening method to Q/d? o If the screening step uses emissions, should it be based on most recent emissions or emissions projected to 2 028? o Can one of the four factors be used on an individual basis to screen out a source, or to prevent it from being screened out? o Can visibility

impacts be used to screen out a source, or to prevent it from being screened out? 2. Should the FLMs be able to id entify to a state, at some defined earl y point in the SIP development timeline, a particular source that may not be screened out of a robust four factor anal ys is ? **D . Issue Statement**  **– The**  **four factor analys is**  Questions In General 1. What aspects of the BART guidelines (for each factor) are applicable to and appropriate for reasonable progress analy ses? 2. Should EPA recommend a presumption that certain controls are needed for reasonable progress, for any

particular source or ty

pe s of source? Cost of Compliance 3. During the development of the first plannin g period SIPs, the RH program was criticized for requiring some sections of the Control Cost Manual to be used, even when they contained outdated information. Should EPA plan to again recommend adherence to the OAQPS Control Cost Manual generall y, or recommend adherence to onl y s pecific sections of the Cost Manual in order to limit room for misunderstanding? Should some of Cost Manual principles be recommended, but not via reference to the Cost Manual itself? o For BART
- eligible sources, the appropriate approach to consideration of existing controls, especiall y if installed recently, has been a source of controvers y i n the first planning period. Opinions have differed on whether and whe n controls that have been recentl y installed should be used as the baseline for calculating costs and visibility

benefits of potential additional controls, versus the earlier condition of the source. This issue is related to considering “average costs” ver sus “marginal costs” of controls that have not yet been installed. o What are your views on this issue in the context of reasonable progress analysis?**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

9 o What additional or revised guidance on these topics do you recommend EPA adopt for the second planning period? 4. Should state and EPA decisions to require or not require specific additional controls in the first planning period , that had particular costs associated with them, be used to establish cost benchmarks to guide to decisions on what controls are needed for reasonable progress in the next planning period? How? T ime Necessary for C ompliance 5. Except for BART, n either the CAA nor the existing RHR set specific deadlines for when sources must comply

with any new requirements in a state’ s next Regional Haze SIP, so states have discretion in establishing reasonable compliance deadlines for measures in their SIPs. What recommendations should EPA give in new guidance on selecting a compliance deadline, once it has been determined that additi onal control of a specific source is needed for reasonable progress? What are the advantages and disadvantages of recommending the BART compliance deadline approach , which is as expeditiously as practicable but not more than 5 years after EPA approval of the SIP ? Should EPA’s guidance include recommended compliance deadlines for particular controls?

E nergy and Non

- Air quality Environmental Impacts of C ompliance 6. Should EPA recommend any particular approach to how these impacts should be taken into considerat ion? Inparticular, should there be any change from the BART Guidelines approach on this topic? Remaining Useful Life 7. The BART Guidelines require that only enforceable source closures can be considered in determining the remaining useful life of a source, for example for purposes of calculating annualized costs. Should new EPA guidance recommend the same approach be applied for reasonable progress purposes, or should reliance on non

- enforceable industry plans and forecasts be endorsed? **E . Issue Statement**  **– Consideration of visibility impacts**  Questions 1. H ow should visibility impacts be considered in assessing whether a source should be controlled under reasonable progress ? 2. The BART Guidelines required that visibility impacts for BART

- eligible sources be deter mined relative to natural conditions, not current conditions. This aspect of the Guidelines has been upheld by federal courts of appeals. Should natural conditions also be used for reasonable progress anal ys is? 3. What specific visibility metrics should EPA encourage states to consider in the next planning period ? 4. Can a threshold or bright line for visibility impact for a source be recommended for use in some way , when anal ytical methods for determining visibility impact may

vary?**D RAFT**  **February 3, 2015**  **Pre -**  **Meeting Materials for the EPA -**  **FLM -**  **RPO -**  **States -**  **Tribes Meeting** 

**on the Fut ure of the Regional Haze Program** 

10 5. How should the cumulative vi sibility impact of many

small sources on many

Class I areas be taken into account in deciding what is necessary for reasonable progress at all area s ? 6. In the first planning period, EPA did not require but did allow states to consider cost/deciview metrics. Should EPA encourage the use of a cost/deciview metric, to inform air agency

decision makers and public comment on draft SIPs for the second planning period ? **F . Issue Statement**  **– Smaller point sources, area source** **s , and mobile sources**  Question 7. Are there source categories that are of high interest to air agencies or stakeholders, for which EPA guidance might help facilitate dialog and reasoned decision making? What could EPA usefully

say about these categories?