Page 1

ENVIRON 773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA
(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com

C: \ Documents and Settings \ vbuyok \ My Documents \ 308 SIP 2007

- 2008 \ Wyoming TSD \ WRAP_PRP18bandPRP18cmv_Regional_Modeling_Analysis_081209_Chap. 5.doc

MEMORAND U M

To: Tom Moore and Lee Gribovicz, WRAP

From: Gerard Mansell

Date: 1 2 August 2009

Subject: A nalysis of WRAP 2018 Preliminary Reasonable Progress Emissions Scenarios

versions “b” and “cmv” in Regional CMAQ Air Quality Modeling an d Projected Visibility Conditions

I NTRODUCTION

Background

The R egional Haze Rule sets a 60

- year timeline for states to improve visibility within mandatory federal Class I areas from Baseline (2000

- 04) levels to Natural Conditions by 2064. States are required to show that Reasonable Progress is expected to be made toward this goal over the course of intermediary planning periods. Reasonable Progress is defined by the EPA both in terms of w hat can

be measured , attributed to sources, and projected usin g current scientific understanding, and, when reviewing controls for existing facilities, specific compliance

- related statutory factors. EPA has prepared Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program 1

, oriented toward cont rol of traditional stationary point sources. To address the complex mix of anthropogenic and natural, controllable and uncontrollable sources affecting Class I areas in the WRAP region, t he WRAP has developed a n emissions projection methodology to address the technical requirements of determining Reasonable Progress for controllable anthropogenic sources. This methodology is based on existing EPA guidance and recommendations from WRAP forums and workgro ups which includes the development and periodic revis ions of regional emission inventor y projection s and using photochemical air quality grid modeling using the Community Multi

- scale Air Quality modeling system (CMAQ).

The latest versions of the WRAP regional emission inventories, based on updates and revis ions completed during Spring 2009 were incorporated into the CMAQ modeling system in order to estimate future year 2018 regional air quality and visibility. This regional emissions projection scenario for CMAQ modeling is called the 2018 Preliminary Reaso nable Progress inventory “version b” (PRP18b). Additionally, an emission sensitivity simulation was performed to investigate the impacts of 2018 projected emissions from Commercial Marine Vessels in the Eastern Pacific (PRP18cmv)

.

1 EPA, 2007. Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program. June 1, accessed 8/12/09 at:

http://www.epa.gov/ttncaaa1/t1/memoranda/rea sonable_progress_guid071307.pdfPage 2

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com This technical Memor andum summarizes these regional air quality simulations and provides an analysis and evaluation of the results with respect to regional haze and visibility across the WRAP region.

WRAP Emission Inventory Scenarios

The most recent versions of the WRAP emission inventories for regional haze planning include:

2002 Base Case Version B

-- The 2002 Base Case (Base02b) emission scenario was developed for use in the model performance evaluation, to determine whether the gridded air quality models performed w as sufficiently well to justify continuing to use the model for planning purposes. The emissions configuration included actual point source, area sources, mobile sources from MOBILE6 with California mobile sources form EMFAC, biogenic emissions

from the BE IS3 model, ammonia emissions and wind blown dust emissions were from models developed with WRAP funding, and actual wildfire, prescribed fires, and agricultural burning emissions for 2002 were used in this scenario. The model was extensively evaluated by

c omparing simulated concentrations of PM2.5 to ambient monitoring data for all available monitoring networks, and WRAP concluded that the model did perform sufficiently well to continue using the either the CMAQ or the CAMx models for planning purposes. The input data and model performance evaluation for this case are described in detail in Tonnesen et. al (2006).

2002 Planning Case Version D

– The 2002 P lanning (Plan02d) emission scenario represents a typical 2002 annual inventory of emissions from all sou rce sectors derived from a number of sources, including state/county emission inventory submittals, permits, MOBILE6 modeling, or other modeled estimates based on activity levels. The planning inventories are used to provide representative baseline visibil ity conditions for comparisons and assessments of progress towards achieving natural visibility conditions in the future years.

2018 Preliminary Reasonable Progress Version A

– The P reliminary R easonable P rogress emissi on inventory for 2018 (PRP18a) inco rporates growth and all known existing and/or planned emission controls and a preliminary estimate of SO 2 reductions from BART controls across the WRAP region.

In spring of 2009, the WRAP developed two additional emission scenarios for air quality modeli ng, based on the PRP18a scenarios as follows:

2018 Preliminary R easonable Progress Version B

– The Preliminary Reasonable Progress emission inventory scenario for 2018 (PRP18b) is used to evaluate the regional haze air quality for future year 2018 conditi ons with all known and exp ected controls as of March 200 9 and provide predicted 2018 future year air quality and visibility conditions in the Western Class I

A reas for regional haze plans. The m odeling results based on this emission inventory are used

to gauge reasonable progress with respec t to future year visibility. The PRP18b scenario was developed to incorporate the latest inventory updates completed during 2009, as described

below.

2018 Preliminary Reasonable Progress, CMV Sensitivity

– The Prelimi nary Reasonable Progress, CMV Sensitivity emissions inventory for 2018 ( PRP18cmv ) was developed to evaluate the sensitivity of regional air quality and visibility conditions to updated calendar yearPage 3

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com 2018 emiss i ons for t he Pacific Off

- shore region. This e missions inventory scenario is identical to the PRP18b with the exception of the updated Pacific Off

- shore emissions.

The PRP18b emission scenario was developed based on updates to the PRP18a emissions inventories completed during calendar year 2009. Th ese updates include the following:

Update of California 2018 on

- road and non

- road emission inventories ( PDF ) Update of 2018 locomotive emissions ( PDF ) Update of WRAP 2018 stationary point source emissions ( PDF ) Update of WRAP 2018 area source emissions ( PDF ) Mexico 2018 projection s ( PDF ) 2

A discussion of the development of the PRP18b and PRP18cmv inventories in presented in the next section, as well as a summary of final emi ssions used in CMAQ modeling efforts.

EMISSION INVENTORIES

The development of the PRP18b and PRP18cmv emission scenarios, SMOKE processing and emission summaries and discussion are provided in this section.

Emission Scenario Development

A summary of the various inventory versions, by source sector and geographic region, used in the development of the PRP18b and PRP18cmv scenario s are provided below.

PRP18b

The PRP18b emission scenario was based on previous emission inventories with specific updates as noted above. The following source sectors and inventory versions were unchanged from the PRP18a

scenario:

From Base02a

o BEIS3 biogenic emissions (includes soil NO)

o Windblown fugitive PM dust emissions

– all components from WRAP WB Dust model

o WRAP NH 3 from WRAP NH 3 model

o Ontario, Canada point fires

From Plan02a

o WRAP baseline wildfires

o WRAP baseline wildland fire use

o Offshore commercial shipping: no change (see Plan02a)

From Base18a:

o WRAP (except California) non

- road mobile (annual and seasonal)

From Ba se18b:

o CENRAP on

- road mobile

o WRAP baseline prescribed fires (natural and anthropogenic)

o WRAP baseline agricultural fires

o WRAP baseline non

- federal rangeland fires

2 ERG, 2009. Mexico 2018 Emissions Projections for Point, Area, On

- Road Motor Vehicle and Nonroad Mobile Sources. Technical Memorandum prepared for Lee Gribovicz and Tom Moore, WRAP. April 27.Page 4

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com From PRP18a:

o Non

- WRAP stationary area

o Non

- WRAP stationary point

o Non

- WRAP mobile sources (on

- road & off

- road)

o WRAP Oil & Gas

o Fugitive dust

o CENRAP & VISTAS point fires

o Offshore Area, Gulf of Mexico

o Gridded Offshore Shipping (Gulf of Mexico and Atlantic: Corbet/ENVIRON inventory)

o Canada

- 2020 inventory

o Mexico

– Road dust extracted from Phase II area inventory and had transport factors applied.

The following emission updates were included in simulation PRP18b:

Stationary Area

o WRAP: Updated 2018 inventory

o Mexico: Phase III inventory and updates to gridding data

Non

- road Mobile

o WRAP: Updated 2018 inventory for California

o Mexico: Phase III inventory and updates to gridding data (annual)

On

- road Mobile

o WRAP: Updated 2018 inventory for California

o Mexico: Phase III inventory and updates to gridding data Fugitive Dust

o WRAP: Extracted from Updated 2018 stationary area source inventory

o Mexico: Extracted from Phase III inventory Stationary Point

o WRAP: Updated 2018 inventory

o VISTAS: Updated 2018 Best & Final inventory

o Mexico: Phase III inventory

PRP18cmv

The PRP18_cmv emission scenario was based on the PRP18b scenario with the only change being the replacement of the Pacific Offshore inventory with the updated 2018 CMV inventory for the Eastern Pacific, and some corrections to units and chemical speciation for VOC emissions, as discussed below.

The emis sions estimates for each of the sectors and regions described above were modeled using the SMOKE emissions modeling system to generate CMAQ model

- ready emission s data for air quality modeling. A discussion of the results of the SMOKE modeling for the PP18 b and PRP18cmv scenarios is provided below.

Emission Inventory Summary and Discussion

PRP18b

The objective of emissions simulation PRP18b was to incorporate emissions inventory updates completed during 2009 by WRAP contractors to create a new future yea r, annual 36

- km grid resolutionPage 5

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com emissions dataset for air quality modeling. U pdated 2018 PRP inventories (for selected source categories

– see above) for the WRAP states were obtained and processed through SMOKE. The

RMC also obtained updated 2018 invento ries for the VISTAS states, year 2020 inventories for Canada and new 2018 national inventories for Mexico (Phase III). T hese updated inventory data were incorporated into the existing emissions data from the PRP18a emissions scenario to develop the

PRP18b emissions.

The RMC received new data for the WRAP states and tribes that included 2018 PRP inventories for the stationary area, stationary point, on

- road mobile, and non

- road mobile sectors. F ugitive dust PM

emissions sources were extracted from the stat ionary area inventory using the list of sources consistent with simulation PRP18a (originally developed during Base18b modeling). The changes to the WRAP stationary area inventory impacted only some of the states in the region. The states impacted by this inventory update included California, Idaho, Nevada, South Dakota, and Washington. The WRAP stationary point inventory update impacted all 13 states and some of the Tribes. The on

- road mobile updates only impacted California and the non

- road mobile updat es impacted all of the states in the WRAP region. The rest of the inventory sectors in the WRAP region remained unchanged in

simulation PRP18b relative to PRP18a.

U pdated 2018 stationary point inventory emissions data for the VISTAS RPO were also include d in

simulation PRP18b. T he 2018 best & final inventory from the VISTAS RPO was used as a replacement to the 2018 point inventory used in simulation PRP18a. No other changes were made to any of the other U.S. inventories outside of the WRAP and VISTAS regi ons in simulation PRP18b. In addition to the WRAP and VISTAS updates, new 2018 Mexican inventories in simulation PRP18b.

T he Mexico inventories in simulation PRP18b were updated with the Phase III 2018 inventory produced by ERG, Inc. The Phase III 2018 Me xico inventory replaced the 1999 Mexican inventories used in simulation PRP18a. The Phase III inventories cover the entire country for all emissions sectors. As the 2018 Phase III Mexican inventory did not contain road dust estimates, the same Mexican road dust inventory used in all previous modeling runs were used in the PRP18b scenario . The inventory sources for Canada, as well as the domain

- wide biogenic emissions did not change in simulation

PRP18b.

Overall the WRAP emissions on an annual basis (annual totals for all WRAP states) decreased for all inventory pollutants, with the exception of CO, for simulation PRP18b relative to simulation PRP18a. The largest reductions for the PM pollutants came from the non

- road mobile and fugitive dust/stationary area sectors. Increases in PM emissions from the on

- road mobile and stationary point sectors slightly offset the PM emissions reductions in PRP18b. The NO

x emissions reductions in simulation PRP18b relative to PRP18a were driven by the stationary point sector, with smaller

reductions from non

- road mobile and stationary area. The only sector that exhibited NO

x increases in comparing these two simulations was the on

- road mobile sector. The SO 2 reductions in simulation PRP18b relative to PRP18a were driven primari ly by the stationary point sector with smaller reductions in the stationary area and non

- road mobile sectors. There was a small offsetting increase in

SO 2 emissions from the on

- road mobile sector. Simulation PRP18b included only reductions in NH 3 emission s relative to simulation PRP18a and these were the result of changes primarily in the on

- road

mobile sector. Smaller NH 3 reductions occurred in the stationary point, non

- road mobile, and stationary area sectors. The stationary area sector contributed the only VOC reduction, which was offset by smaller increases in VOC emissions from the on

- road mobile, non

- road mobile, and stationary point sectors. A relatively large increase in CO emissions from non

- road mobile sources was offset by smaller decreases in t he stationary area, stationary point, and on

- road mobile sectors.Page 6

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Relative to simulation Plan02c, the PRP18b WRAP emissions decreased for PM 2.5 , NO

x , SO 2 , NH 3 and CO and increased for PMC, PM 10 , and VOC. The PM 2.5 reductions were driven by the on

- road mob ile,

non

- road mobile, and stationary area sectors and offset by increases in the stationary point, road dust and fugitive dust sectors. The largest increase in PM 2.5 is from the fugitive dust sector and reflects the expanded list of dust sources that we re applied after simulation Plan02c. The NO

x emissions decreased

as a result of the on

- road mobile, non

- road mobile, and stationary point sectors. These decreases were offset slightly by NO

x increases in the stationary area and oil and gas sectors. The SO 2 re ductions were driven by stationary point, on

- road mobile, and non

- road mobile sectors. A large CO reduction in the

on

- road mobile sector was offset by increases in the stationary area, stationary point, non

- road mobile, and oil and gas sectors. PMC and PM 1 0 increased in simulation PRP18b relative to Plan02c primarily because of the fugitive dust and road dust sectors. The only major offset to these increases were

reductions in PMC and PM 10 emissions from stationary area sources. Decreases in NH 3 emissions w ere driven by the on

- road mobile sector. Large increases in VOC emissions from the oil and gas and stationary area sectors were offset by smaller decreases in the on

- road and non

- road mobile sectors.

P RP 18cmv

The objective of emissions simulation PRP18_ CMV was to incorporate emissions inventory updates and corrections completed during 2009 by WRAP contractors to create a new future year Pacific Ocean commercial shipping inventory. The changes to commercial marine vessels (CMV) in
simulation PRP18b_ cmv in cluded the addition of a new 2018 inventory for the Pacific Ocean and the correction of units conversion and chemical speciation errors that were present in the previous CMV inventories. The 2018 inventory represents projected activities and emissions fact ors for CMV sources in the Eastern Pacific Ocean for the year 2018. By not accounting for the metric ton units of the CMV inventory and assuming that it was provided in short ton units, these emissions were underestimated in earlier RMC simulations by abou t 10%. T his error was corrected in simulation PRP18_ cmv

. A n error in the VOC speciation of the CMV emissions was also corrected which resulted in a net decrease of the

overall VO C emissions in simulation PRP18

_ cmv

.

With the only diffe rence between sim ulations PRP18

_ cmv and PRP18b occurring in the Pacific shipping emissions, the inventory summaries and emissions plots reflect only differences in this sector. There are no emissions differences over land between these two simulations. The emissions change s in the CMV sector are the result of the inventory update and the corrections to the unit conversion and speciation errors. The overall results of these changes were that all inventory pollutants except VOC increased in the 2018 Pacific CMV inventory rela tive to the 2002 inventory. The VOC decrease in the
PRP18_ cmv emissions resulted from correcting an over prediction of formaldehyde emissions in the 2002 inventory.

Annual anthropogenic emissions for the WRAP states, by source sector are summarized in Ta bles 1

- 3 below which present the Plan02d, PRP18a, PRP18b, respectively, in tons/year. Table 4 summarizes
the difference in annual Pacific Offshore CMV emissions between the PRP18b and PRP18_cmv

emission scenarios. Emission summaries are also displayed gra phically in Figures 1

- 7, for NOx, VOC, CO, SO2, PM10, PM2.5 and NH3.

The spatial distribution of the difference in total (all source sectors) annual emissions between the PRP18a and PRP18b scenarios are displayed in Figure 8, in tons/year. The spatial di stribution of the change in emissions between PRP18_cmv and PRP18b is displayed in Figure 9, in tons/year.Page 7

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Table 1

. Plan02d WRAP total annual emissions by sector (tons/yr)

Sector CO NOX VOC NH3 SO2 PM10 PM2_5

PMC

Fires 8928013 202217 436714 45263 53856 726518 627618 119796

Area 1268874 259990 1331075 24519 85117 213825 190665 23197

Point 533870 897910 260247 780738 780738 147818 60424 105346

Non Road 39 17820 1005930 535025 734 67286 74322 69424 4898

Onroad 12186508 1632549 1028968 55668 30253 50453 38902 11551
Biogenic 2624814 286996 18197340 0 0 0 0 0

WOG 46846 118573 439330 0 1182 0 0 0

Road Dust 0 0 0 0 0 581980 63358 518630 Fugitive

Dust 0 0 0 0 0 915642 146387 769256

Wind

- Blown

Dust 0 0 0 0 0 1962165 431676 1530489

Offshore

Platforms 0 0 0 0 0 0 0 0

Offshore Shipping 40868 524797 367468 149 280561 36352 35220 1132 Ag

Ammonia 0 0 0 817256 0 0 0 0

Total 29547611 4928961 22596168 1724327 12989 93 4709074 1663673 3084295

Table 2 . PRP18a WRAP total annual emissions by sector

Sector CO NOX VOC NH3 SO2 PM10 PM2_5 PMC

Fires 8928013 202217 436714 452 63 53856 726518 627618 119796

Area 1446307 320345 1860528 25430 110772 240738 211012 29765

Point 752028 895549 299700 14031 535055 190862 58607 132255

Non Road 4367813 594397 328247 1409 4074 43367 39320 4047

Onroad 5708505 519090 400626 71408 5933 363 68 23618 12749 Biogenic 2624814 286996 18197340 0 0 0 0 0

WOG 68260 191728 749979 0 89 0 0 0

Road Dust 0 0 0 0 0 689599 72821 616779 Fugitive Dust 0 0 0 0 0 1123032 166125 956919

Wind

- Blown

Dust 0 0 0 0 0 1962165 431676 1530489

Offshore

Platforms 0 0 0 0 0 0 0 0

Offshore Shipping 40868 524797 367468 149 280561 36352 35220 1132 Ag Ammonia 0 0 0 817256 0 0 0 0

Total 23936606 3535119 22640603 974946 990341 5049001 1666017 3403931

Table 3

. PRP18b WRAP total annual emissions by sector (tons/yr)

Sector CO NOX VOC NH3 SO2 PM10 PM2_5 PMC

Fires 8928013 202217 436714 45263 53856 726518 627618 119796

Area 1386853 290874 1830236 25387 108274 233469 205202 283 06

Point 714163 811324 300509 11564 512467 196677 59046 147229

Non Road 4520104 557423 332659 922 3186 35095 31673 3442

Onroad 5706430 533287 410149 43339 6116 38603 25509 13094
Biogenic 2624814 286996 18197340 0 0 0 0 0

WOG 68260 191728 749979 0 89 0 0 0

Road Dust 0 0 0 0 0 689599 72821 616779Page 8

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Fugitive Dust 0 0 0 0 0 1099367 166474 932901

Wind

- Blown

Dust 0 0 0 0 0 1962165 431676 1530489

Offshore

Platforms 0 0 0 0 0 0 0 0

Offshore Shipping 40868 524797 367468 149 280561 36352 35220 1132

Table 4

. 2018

– 2002 Pacific commercial marine shipping emissions difference (tons/yr)

Sector CO NOX VOC NH3 SO2 PM10 PM2_5 PMC

Pacific Shipping 38657 380360

- 3301 55 107 247607 99836 98354 1481

Figure 1. Anthropogenic NOx emissions for the WRAP states, by source sector (tons/year)

Figure 2. Anthropogenic VOC emissions for the WRAP states, by source sector (tons/year)Page 9

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 3. Anthropogenic CO emission s for the WRAP states, by source sector (tons/year)

Figure 4. Anthropogenic SO2 emissions for the WRAP states, by source sector (tons/year)Page 10

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 5. Anthropogenic PM10 emissions for the WRAP states, by source sector (tons/year)

Figure 6. Anthr opogenic PM2.5 emissions for the WRAP states, by source sector (tons/year)Page 11

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 7. Anthropogenic NH3 emissions for the WRAP states, by source sector (tons/year)Page 12

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 8. Annual difference in emissions between PRP18a and PRP18b

– All source sectors (tons/year)Page 13

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.comPage 14

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 9. Annual difference in emissions between PRP18 _cmv and PRP18b

– All source sectors (tons/year)

CMAQ MODELING RESULT S

The PRP18b and PRP18_cmv emission scenarios were used in annual regional CMAQ modeling to

estima te the 2018 future year air quality and regional visibility across the WRAP region. A discussion of the results of these simulations is provided below.

PRP 18b

To evaluate seasonal differences in the comparison of PRP18b to PRP18a , plots of monthly aver age changes in concentrations for each of the PM species were prepared and evaluated

. Although displays for all 12 months are available on the RMC webpage ( link )

, we present summary results here for the months of January and July. These months were select ed because the largest variation in model results is typically between the winter and summer months. Figures 1 0 through 1 4 show the monthly average model concentrations of the PM species for the PRP18b case relative to the PRP18a case . There were

s ignific ant reductions in predicted nitrate concentrations in winter in the San Francisco Bay Area and Southern California with slight increases in the Central Valley of California as well as in the eastern portion of the WRAP regions and in central Washington Sta te. Additionally, a large increase in nitrate is seen in the El Paso area of western Texas. In the summer months, small reductions are seen in the urban areas of California. Particulate sulfate concentrations are reduced slightly in winter in Southern

C alifornia and along the western coast of the Mexican mainland and in the Seattle area during the summer months. Large increases in sulfate concentrations from the PRP18b case relative to the

PRP18a case are seen in southern and eastern New Mexico and thro ughout northern Mexico extending into eastern and central Texas during both summer and winter months. Concentrations of OC and EC

are predicted to increase for PRP18b relative to PRP18a, in the Seattle area with small reductions in eastern Washington Stat e in both January and July. Reductions in pr e dicted EC concentrations are also

seen in the urban areas of California for both the winter and summer seasons. Increases in both OC and EC are seen throughout Mexico.Page 15

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 10. Difference in predicted particulate nitrate concentrations: PRP18b

– PRP18a. Left

– January; right

- July

Figure 11. Difference in predicted particulate sulfate concentrations: PRP18b

– PRP18a. Left

– January; right

- JulyPage 16

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 12. Difference in predicted elemental carbon concentrations: PRP18b

– PRP18a. Left

– January; right

- July

Figure 13. Difference in predicted organic carbon concentrations: PRP18b

– PRP18a. Left

– January; right

- JulyPage 17

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Fig ure 14. Difference in predicted PM2.5 concentrations: PRP18b

– PRP18a. Left

– January; right

- July

To evaluate seasonal differences in the comparison of PRP18b to Plan02d, plots of monthly average changes in concentrations for each of the PM species we re prepared and evaluated. W e present summary results here for the months of January and July ; displays for all 12 months are available on the RMC webpage ( link )

. Figures 15 through 22 show the monthly average model concentrations of

ozone and PM species for the PRP18b case relative to the Plan02d case . There were small reductions

in sulfate in PRP1 8b in the winter months and larger reductions in nitrate, ammonium and elemental carbon throughout large regions in the WRAP states. Figure 18 shows that ther e were small reductions in ozone of about 1 to 3 ppb though much of the WRAP domain, excluding some major urban areas were low ozone levels increased because of reduced NOx emissions and reduced titration of ozone by

NO.

Figure 15 shows the changes in s ulfate for January and July. The largest change was caused by updates to the Mexican SOx emissions inventory, with large reductions in sulfate in the Baja California area and large increases in sulfate in northern Mexico and southern Texas. Overall, ther e was a mixed response in sulfate concentration in the WRAP states in January, and there was a reduction in sulfate in the WRAP states in July.

Figure 16 shows the change in nitrate for January and July. There were reductions in nitrate in most of

the W RAP region throughout the year, due largely to large reductions in NOx emissions in the PRP18b mobile source inventory

. The PRP18b point inventory had reductions in NOx emissions in some areas and increases in other areas, and Figure 16 shows small increa ses for PRP18b compared to Plan02d nitrate in parts of Nevada and Arizona in January. The reductions in nitrate in PRP18b were largest in the winter months because nitrate concentrations are much larger in the winter than in the summer

months.

Figure 17 s hows that there were mostly reductions in ammonium concentrations in PRP18b compared to Plan02d, consistent with the large reductions in nitrate. There were some areas, mostly in MexicoPage 18

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com and Texas, where ammonium increased in PRP18b because of the increases in sulfate in PRP18b compared to Plan02d.

Figure 18 shows the change in ozone in PRP18b compared to Plan02d for January and July. During January, PRP18b had higher ozone concentration in urban influenced areas because of the reduced

NOx emissions in PRP1 8b. During winter months, high NOx concentrations mostly act to titrate

ozone , so reductions in NOx causes increases in ozone in winter months. However, the ozone concentrations are usually low during the winter and exceedances of the ozone NAAQS are rare

. During July, the PRP18b NOx reductions cause significant reductions of ozone in the WRAP region with the largest reductions, up to 8 ppb for the monthly average, occurring in California’s central valley.

Figure 19 shows the change in elemental carbon ( EC) in PRP18b compared to Plan02d for January and July. EC concentrations were reduced in the WRAP region throughout the year in PRP18b, in part due to reductions in mobile source emissions. Reductions were larger in the winter months, as much a 2 ug/m3 i n December compared with smaller reductions of up to 1 ug/m3 in July, because of less vertical mixing in the winter months. Figure 20 shows changes in organic carbon (OC) in PRP18b compared to Plan02d for January and July. There were mostly reductions in OC in PROP18b compared to Plan02d, with the exception of increases in OC in both the Seattle and Phoenix areas in PRP18b.

Figure 21 shows the change in total PM2.5 in PRP18b compared to Plan02d for January and July. PM2.5 represents the sum of the chan ges in the speciated PM results shown in Figure 15 through 20. The largest reductions in PM2.5 were in January in California, as large as 6 ug/m3, because of large reductions there in nitrate, ammonium and EC from the updated mobile source inventory in P RP18b. The magnitude of the reductions in PM2.5 for PRP18b were smaller in the summer months in California, but reduction extended over a much larger area, including the mountain states, because of reductions in sulfate, ammonium and EC in those areas fo r the PRP18b simulation. Figure 22 shows the change in total coarse matter (CM) in PRP18b compared to Plan02d for January and July. There were mostly increases in CM associated with urban areas in PRP18b, with the exception of Clark County, NV, were ther e were large reductions in CM.Page 19

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 15. Difference in monthly average sulfate concentrations for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).

Figure 16. Difference in monthly average nitrate conc entrations for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).Page 20

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 17. Difference in monthly average ammonium (NH4) concentrations for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).

Figure 18. Difference in monthly average ozone (O3) concentrations for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).

.Page 21

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 19. Difference in monthly average elemental carbon (EC) concentration for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).

Figure 20

. Difference in monthly average organic carbon (OC) concentrations for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).Page 22

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 21. Difference in monthly average total PM2.5 concentrations for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).

Figure 22. Difference in monthly average total Coarse P M (PMC) concentrations for the PRP18b compared to the Plan02d CMAQ simulations for January (left) and July (right).Page 23

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com PRP18_cmv

To evaluate seasonal differences in the comparison of PRP18cmv to PRP18b, we prepared plots of monthly average changes in con centrations for ozone and each of the PM species. Plots for all 12 months are available on the RMC webpage ( link ) but we present summary results here for the months of January and July as the largest variation in model results is typically between the wint er and

summer months. Figures 23 through 29 display the monthly average model concentrations of ozone and PM species for the PRP18cmv case relative to the PRP18b case

. As expected, Figure 23 shows that the largest effect of the updated shipping emissions was an increase in SOx emissions offshore and

an increase in sulfate concentration over the eastern Pacific

. The increased sulfate extended over some coastal areas, including Washington, Oregon, northern CA and Baja California. There were significant re ductions in sulfate in the Los Angeles area because SOx emission were reduced in the LA port and increased offshore. The pattern of sulfate reduction was similar throughout the year with larger sulfate changes in the summer months.

Figure 24 shows no cha nge in nitrate concentrations, except for the Los Angeles area, where nitrate increased during all months for the PRP18cmv case. The increase in nitrate is a direct result of the reduced sulfate concentrations in the Los Angeles area in PRP18cmv. The lowe r sulfate concentrations result in greater availability of gas phase ammonia and increased formation of ammonium nitrate in the Los Angeles area.

Figure 2 5 shows that the changes in ammonium aerosol are consistent with the sulfate and nitrate

results. In creased sulfate in coastal Washington, Oregon and Baja California in the PRP18cmv case resulted in higher ammonium concentrations in those areas, especially in the winter months. The PRP18cmv case had lower ammonium concentrations in the Los Angeles area because of the reduction

in ammonium sulfate.

Figure 2 6 shows small increases in ozone concentrations during July in the PRP18cmv case, from 1 to

5 ppb, over the eastern Pacific as a result of the increased shipping activity in those areas.

Figure 27 sh ows reductions in elemental carbon (EC) for the PRP 18 cmv case in the Los Angeles and San Francisco areas because of reduced shipping emissions in the ports in those cities. The monthly average reduction in EC was a pproximately 0.2 ug/m 3

, for both January a nd July , in the port areas

. Essentially no change was predicted for OC concentrations as illustrated in Figure 28.

Figure 29 shows the change in monthly average PM2.5 for the PRP18cmv case for January and July. Changes in sulfate were the largest compone nt of the changes in PM2.5, and the plots for PM2.5 are similar to the sulfate results in Figure 23 . Note that the scale is different in the two plots.Page 24

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 23. Difference in monthly average sulfate concentrations for the PRP18cmv compared to th e PRP18b CMAQ simulations for January (left) and July (right).

Figure 24

. Difference in monthly average nitrate concentrations for the PRP18cmv compared to the PRP18b CMAQ simulations for January (left) and July (right).Page 25

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 2 5. Difference i n monthly average ammonium (NH4) concentrations for the PRP18cmv compared to the PRP18b CMAQ simulations for January (left) and July (right).

Figure 26. Difference in monthly average ozone (O3) concentrations for the PRP18cmv compared to the

PRP18b CMAQ simulations for January (left) and July (right).Page 26

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 27. Difference in monthly average elemental carbon (EC) concentration for the PRP18cmv compared to the PRP18b CMAQ simulations for January (left) and July (right).

Figure 28

. Differe nce in monthly average elemental carbon (OC) concentrations for the PRP18cmv compared to the PRP18b CMAQ simulations for January (left) and July (right).Page 27

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 29

. Difference in monthly average total PM2.5 concentrations for the PRP18cmv compared to the PRP18b CMAQ simulations for January (left) and July (right).

VISIBILITY PROJECTIO NS

The impacts of the PRP18b and PRP18_cmv model simulations on the predicted visibility at Class I Areas were evaluated with respect to the rate of progress in ach ieving the goals of the Regional Haze

Rule. As seen in Figures 10 and 11, compared to the PRP18a case, relatively minor decreases in the predicted nitrate and sulfate concentrations throughout most of the WRAP region are realized for the

PRP18b case and t herefore only minimal impacts on visibility are expected with the exception of the increased sulfate concentrations in southern Arizona and New Mexico, as well as the Central Valley of

California.

Visibility Impacts Due to the PRP18b Scenario

A revie w of the 2018 visibility conditions at several Class I Areas throughout New Mexico was conducted to evaluate these impacts. The evaluations presented herein are based on various tools available on the WRAP Technical Support System (TSS) website. Figures 30 through 3 4 display potential emission source sectors and regions impacting the visibility on the 20% worst visibility days at GUMO, SACR, WHIT, GICL and CHIR IMPROVE monitor locations. These displays indicate that for the PRP18b scenario, large potenti al increased impacts from point and area source SOx and NOx emissions from Mexico in comparison with the PRP18a scenario likely contribute to visibility degradation at these Class I Areas.Page 28

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 30. Potential emission sources and region s impacting visibility at GUMO for the

PRP 18a scenario (top) and the PRP18b scenario (bottom)

Figure 31. Potential emission sources and regions impacting visibility at SACR for the PRP18a scenario (top) and the PRP18b scenario (bottom)Page 29

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 32. Potential emission sources and regions impacting visibility at WHIT for the PRP18a scenario (top) and the PRP18b scenario (bottom)

Figure 33. Potential emission sources and regions impacting visibility at GICL for the PRP18a scenario (top) and the PRP18b scenario (bottom)Page 30

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 34. Potential emission sources and regions impacting visibility at CHIR for the PRP18a scenario (top) and the PRP18b scenario ( bottom)

A review of the point and are a source emission inventories for Mexico comparing the PRP18a and PRP18b scenarios show considerable changes from 18a to 18b for these source sectors primarily in the

states of Chihuahua and Coahuila. The developmen t of the 2018 projected emission inventories for Mexico, as used in the PRP18b scenario, is described in ERG, 2009 3

. Figure s 35 and 36 display the

total state

- level point and area source NOx and SO2 emissions for Mexico, respectively for both

PRP18a and P RP18b. Relative to PRP18a, the stationary source SO2 and NOx emissions in

Chihuahua and Coahuila states are almost double in the PRP18b scenario. Note that the state of Nuevo Leon also shows considerable increases in emission from these source sectors, although their impacts on Class I Area in the WRAP region are likely not as important, impacting regions in eastern Texas

more than in the Western States. Figures 37 and 38 display municipality

- level point source SO2

emissions in Chihuahua and Coahuila s tates, respectively. Although a large decrease in SO2 point source emissions is seen in the municipality of Delicias in Chihuahua state, the increase in SO2 emissions in the city of Chihuahua likely has more impact on the WRAP region as it is located clos er to the US

- Mexico border. However, Figure 38 shows a more than doubling of SO2 point source emissions from Nava municipality in Coahuila state and is probably the more likely source impacting visibility throughout New Mexico.

3 ERG, 2009. Mexico 2018 Emi ssions Projections for Point, Area, On

- Road Motor Vehicle and Nonroad Mobile Sources. Technical Memorandum prepared for Lee Gribovicz and Tom Moore, WRAP. April 27.Page 31

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 35

. State

- l evel stationary source NOx emissions for Mexico for scenarios PRP18a and

PRP18b

Figure 36

. State

- level stationary source SOx emissions for Mexico for scenarios PRP18a and

PRP18bPage 32

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 37

. Municipality

- level point source SO2 emissions for Chihuahu a, Mexico for scenarios

PRP18a and PRP18b

Figure 38

. Municipality

- level point source SO2 emissions for Coahuila, Mexico for scenarios

PRP18a and PRP18b

The 2018 predicted visibility resulting from the PRP18a and PRP18b scenarios were reviewed for

se veral sites in New Mexico which are impacted by these emission changes in the Mexico inventories. Note that, in addition to the results at the IMPROVE sites presented below, corresponding results for

all other sites can be reviewed on the TSS. The sites presented here are those with the largest predictedPage 33

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com impacts on visibility, although others may also show some slight degradation in visibility conditions. Figure 35 through 40 present the 2018 projected visibility conditions on the 20% worst visibility da ys for several Class I Areas in the Southwest in terms of the Glide Slope showing progress towards achieving the Regional Haze Rule goals. As seen in these figures, for most of the sites evaluated visibility degradations are relatively small, on the orde r of 0.2 to 0.6 dV, with the largest change occurring for the GUMO monitor, and are generally the result of increased sulfate extinction

associated with the increased SO2 emissions in Northern Mexico.

Figure 35. Visibility Glide Slope for GUMO for the PRP18a scenario (top) and th e PRP18b scenario (bottom)Page 34

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 36. Visibility Glide Slope for GUMO for the PRP18a scenario (top) and the PRP18b scenario (bottom)

Figure 37. Visibility Glide Slope for SACR for the PRP18a scenario (top) and the PRP18b scenario (bottom)Page 35

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 38. Visibility Glide Slope for WHIT for the PRP18a scenario (top) and the PRP18b

scenari o (bottom)

Figure 39. Visi bility Glide Slope for GICL for the PRP18a scenario (top) and the PRP18b scenario (bottom)Page 36

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 40. Visibility Glide Slope for BOAP for the PRP18a scenario (top) and the PRP18b scenario (bottom)

Visibility Impacts Due to the PRP18 _cmv Scenario

A review of Figures 23 through 29 indicate the impacts of the PRP18_cmv scenario on predicted visibility affect primarily only the coastal regions of Washington, Oregon and California, as well as large regions of Baja California, as expected. In general the predicted changes in the par ticulate matter species affecting regional visibility are increases relative to the PRP18a scenario, with the exception of the urban areas in Southern California for which decreases are predicted with this emission scenario.

As with the PRP18b scenario, several Class I Areas were evaluated to determine the specific impacts due to the inclusion of updated calendar year 2018 CMV emission in the Eastern Pacific. Figures 41 through 4 3 display the visibility Glide Slopes for se lected sites along the coast of Washington State. Figure 41 display s the predicted visibility, as deciview and particle extinction, for Mount Rainier (MORA ) . Displayed are the Glide Slopes of the PRP18a, PRP18b and PRP18_CMV scenarios. At this site, visibility is seen to be degraded fr om PP18a to PRP18b and further degraded based on the PRP18_CMV scenarios. By contrast, visibility at the North Cascades (NOCA) and Olympic NP (OLYM) sites (Figures 42 and 43) is seen to improve slightly from PRP18a to PRP18b, and then slightly deteriorate with the PRP18_CMV case. In all these cases, changes in visibility are driven by associated changes in the sulfate and OC extinction. Similar results are seen in other Class I Areas throughout Washington and the State of Oregon, although to a somewhat l esser degrees as the area are

further inland from the coast.Page 37

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 41. Visibility Glide Slopes for MORA for the PRP18a scenario (top), the PRP18b scenario (middle) an d the PRP18_cmv scenario (bottom)Page 38

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 42. Visibility Glide Slopes for OLYM for the PRP18a scenario (top), the PRP18b scenario (middle) and the PRP18_cmv scenario (b ottom)Page 39

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 43. Visibility Glide Slopes for NOCA for the PRP18a scenario (top), the PRP18b scenario (middle) and the PRP18_cmv scenario (bottom)

Visibility results for Class I Areas along the California coast were also evaluated with respect to the changes in the PRP18a, PRP18b and PRP18_cmv emission scenarios. Figure 44 displays these results

for Redwoods NP on the Northern California coast. A t this site, a lthough the total deciview is basically unchanged between the OPROP18a and PRP18b scenarios, sulfate extinction increases slightly, offset by a decrease in the nitrate extinction. In the PRP18_cmv scenario, the visibility, as measured by deciview is degraded con siderably compared to both the PRP18a and PRP18b cases,

dr ive n by increases in both the sulfate and nitrate extinction. Results for Pinnacles NM and Ventana Wilderness (PINN), in Central California are displayed in Figure 45 . At this site, visibility improvements are realized with the PRP18b scenario over the PRP18a scenario with visibilityPage 40

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com degradations seen in the PRP18_cmv scenario, although the total deciview is still slightly lower than

for the PRP18a scenario.

Figure 4 4

. Visibility Glide Slopes for REDW for the PRP18a scenario (top), the PRP18b scenario (middle) and the PRP18_cmv scenario (bottom)Page 41

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 4 5

. Visibility Glide Slopes for PINN for the PRP18a scenario (top), the PRP18b scenario (middle) and the PRP18_cmv scenario (bottom)

In contrast to Class I Areas along the northern coast of the Western US, a number o f sites in Southern California exhibit visibility improvements under the PRP18_cmv scenario. Figure 4 6 displays the visibility projections for the San Gabriel and Cucamonga Wilderness areas (SAGA). Visibility improvements at this sight are seen from PRP1 8a to PRP18b and again for PRP18_cmv, driven primarily by reductions in the nitrate extinction. Figure 4 7 displays similar results for Agua Tibia (AGTI). In this case, visibility improvements are driven by significant decreases in the sulfate

extinction related to emissions reductions at the ports along the Southern California coast.

While only a select number of Class I Areas were reviewed and evaluated for this Technical Memorandum, the results for all Class I Areas across the WRAP region, for all emis sion scenarios can

be found on the WRAP TSS.Page 42

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 4 6

. Visibility Glide Slopes for SAGA for the PRP18a scenario (top), the PRP18b scenario (middle) and the PRP18_cmv s cenario (bottom)Page 43

773 San Marin Drive, Suite 2115 ● Novato, California 94998 USA

(Tel): 415

- 899

- 0700  (Fax): 415

- 899

- 0707  www.environcorp.com Figure 4 7

. Visibility Glide Slopes for SAGA for the PRP18a scenario (top), the PRP18b scenario (middle) and the PRP18_cmv scenario (bottom)