REGIONAL HAZE 

 STATE IMPLEMENTATION PLAN 

FOR 

THE STATE OF ARIZONA 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Air Quality Division 

Arizona Department of Environmental Quality 

December 23, 2003
Acknowledgement 

 Greg Witherspoon 

(July 4, 1948 – December 24, 2001) 

Greg Witherspoon committed his professional career to the advancement of balanced 

environmental policies and programs in Arizona. He worked at the Salt River Project for 

over 20 years as a Principal Environmental Scientist. In this capacity, he was engaged in 

numerous environmental matters affecting power utilities and Arizona’s natural resources. 

Among his many duties at SRP, Greg was actively involved in advancing air quality 

policies that would protect the public’s enjoyment of the spectacular scenery in Arizona’s 

national parks and wilderness areas. Greg participated in several technical committees to 

support the work of the Grand Canyon Visibility Commission in addressing regional haze 

visibility impairment in the Grand Canyon National Park and other Class I areas on the 

Colorado Plateau. He worked with other stakeholders throughout the west to advance 

technical and regulatory policies necessary to achieve long-term reductions of visibility 

impairing emissions. Greg was a champion of market based emission reductions as the 

vehicle for achieving air quality goals in the most cost effective manner. Greg was the 

consummate professional throughout the stakeholder process. He came to meetings 

thoroughly prepared. He readily shared his expertise and valued the input of others. He 

sought to build consensus among all the stakeholders throughout the process. Greg was 

instrumental in helping Arizona decide to base its Regional Haze State Implementation 

Plan on the program conceived by the Grand Canyon Visibility Commission and developed 

by its successor organization, the Western Regional Air Partnership.
Table of Contents i Arizona Regional Haze SIP

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................................ i

LIST OF FIGURES .................................................................................................................................... v

LIST OF TABLES ..................................................................................................................................... vi

LIST OF APPENDICES ..........................................................................................................................vii

EXECUTIVE SUMMARY ..................................................................................................................ES-1

1. BACKGROUND ............................................................................................................................ 1

1.1. Introduction .................................................................................................................................1

1.2. Definitions ...................................................................................................................................1

1.3. 1977 Clean Air Act......................................................................................................................1

1.4. Reasonably Attributable Visibility Impairment...........................................................................2

1.5. 1990 Clean Air Act......................................................................................................................2

1.6. Grand Canyon Visibility Transport Commission........................................................................2

1.7. Western Regional Air Partnership...............................................................................................3

1.8. 1999 Regional Haze Rule............................................................................................................3

1.9. 2002 Annex Rule for Stationary Sources of Sulfur Dioxide .......................................................3

1.10. 2003 Rule Change to Mobile Source Requirements for National Strategies ..............................6

2. PHYSICAL, DEMOGRAPHIC, AND ECONOMIC DESCRIPTIONS OF ARIZONA........ 7

2.1. Climate and Physiography...........................................................................................................7

2.2. Population....................................................................................................................................8

2.3. Economy....................................................................................................................................11

3. MANDATORY CLASS I FEDERAL AREAS ON THE COLORADO PLATEAU............. 15

3.1. Arizona Class I Areas................................................................................................................15

3.1.1. Grand Canyon National Park .................................................................................................. 16

3.1.2. Sycamore Canyon Wilderness................................................................................................. 18

3.1.3. Petrified Forest National Park ................................................................................................. 19

3.1.4. Mt. Baldy Wilderness.............................................................................................................. 20

3.2. Class I Areas Outside Arizona...................................................................................................21

4. TECHNICAL BASIS FOR REGULATION OF REGIONAL HAZE.................................... 23

4.1. How Do We See? ......................................................................................................................23

4.2. How Particulates and Gases Impair Visibility...........................................................................24

4.3. Types of Particles and Gases Contributing to Visibility Impairment........................................25

4.4. Sources of Particulates and Gases Contributing to Visibility Impairment on the Colorado 

Plateau...................................................................................................................................26

4.5. Visibility Conditions on the Colorado Plateau ..........................................................................26

4.6. State of Arizona Visibility Monitoring Plan and Network........................................................26

5. STRATEGY TO ADDRESS REASONABLY ATTRIBUTABLE VISIBILITY 

IMPAIRMENT (RAVI)............................................................................................................... 29

5.1. Implementation of Control Strategies........................................................................................30
Table of Contents ii Arizona Regional Haze SIP

5.2. Exemptions from Controls.........................................................................................................30

5.3. Identification of Integral Vistas.................................................................................................30

5.4. Monitoring.................................................................................................................................30

5.5. Long-term Strategy Requirements.............................................................................................31

5.6. New Source Review for Visibility Protection ...........................................................................31

6. LONG-TERM STRATEGY FOR THE CLEAN AIR CORRIDOR ...................................... 33

6.1. Regulatory History and Requirements ......................................................................................33

6.2. Identification of Clean Air Corridor; Other Clean Air Corridors..............................................34

6.3. Strategy for Clean Air Corridors ...............................................................................................35

7. LONG-TERM STRATEGY FOR STATIONARY SOURCES.............................................. 37

7.1. Regulatory History and Requirements ......................................................................................37

7.2. Monitoring and Reporting of Stationary Source Sulfur Dioxide Emissions. ............................38

7.3. Report on Assessment of NOx/PM Strategies...........................................................................39

8. SO2 MILESTONES AND BACKSTOP TRADING PROGRAM ........................................... 41

8.1. Milestones and Determination of Program Trigger...................................................................41

8.1.1. Regional SO2 Milestones......................................................................................................... 41

8.1.2. Regional Program Administration........................................................................................... 44

8.1.3. Determination of Program Trigger.......................................................................................... 44

8.1.4. Year 2013 Assessment ............................................................................................................ 49

8.1.5. Special Penalty Provisions for the 2018 Milestone................................................................. 50

8.2. Pre-Trigger Emissions Tracking Requirements.........................................................................51

8.2.1. SO2 Emission Inventory .......................................................................................................... 51

8.2.2. Development of Emission Tracking System ........................................................................... 52

8.2.3. Periodic Audit of Pre-Trigger Emission Tracking Database................................................... 52

8.3. WEB Trading Program Requirements.......................................................................................52

8.3.1. Initial Allocation of SO2 Allowances ...................................................................................... 52

8.3.2. Distribution of Allowances for Future Control Periods. ......................................................... 59

8.3.3. Distribution of the New Source Allocation............................................................................. 60

8.3.4. Regional Tribal Set-aside ........................................................................................................ 61

8.3.5. Opt-in Sources......................................................................................................................... 61

8.3.6. WEB Allowance Tracking System (WEB ATS)..................................................................... 61

8.3.7. Allowance Transfers................................................................................................................ 63

8.3.8. Use of Allowances from a Previous Year ............................................................................... 63

8.3.9. Monitoring/Recordkeeping ..................................................................................................... 65

8.3.10. Compliance and Penalties ..................................................................................................... 66

8.3.11. Periodic Evaluation of the Trading Program......................................................................... 66

8.3.12. Retired Source Exemption .................................................................................................... 68

8.3.13. Integration into Permits......................................................................................................... 68

8.4. 2013 SIP Revision; Backstop for Beginning of Second Planning Period .................................69

8.5 Geographic Enhancement Program ...........................................................................................69

9. LONG-TERM STRATEGY FOR MOBILE SOURCES......................................................... 71

9.1. Regulatory History and Requirements ......................................................................................71

9.2. Inventory of Current and Projected Emissions from Mobile Sources.......................................72

9.3. Other GCVTC Strategies for Mobile Sources...........................................................................73

10. LONG-TERM STRATEGY FOR FIRE PROGRAMS ........................................................... 75

10.1. Regulatory History and Requirements ......................................................................................75
Table of Contents iii Arizona Regional Haze SIP

10.2. Prescribed Fire Program Evaluation..........................................................................................75

10.3. Emission Inventory and Tracking System.................................................................................75

10.4. Strategy for Use of Non-burning Alternatives...........................................................................76

10.5. Enhanced Smoke Management Program...................................................................................76

10.6. Annual Emission Goal...............................................................................................................77

11. AREA SOURCES OF DUST EMISSIONS FROM PAVED AND UNPAVED ROADS ...... 79

11.1. Regulatory History and Requirements ......................................................................................79

11.2. Strategy for Road Dust Sources.................................................................................................79

12. POLLUTION PREVENTION AND RENEWABLE ENERGY PROGRAMS ..................... 81

12.1. Regulatory History and Requirements ......................................................................................81

12.2. Approach to Addressing Requirements Under 40 CFR 51.309(d)(8) .......................................81

12.3. Description of Existing Pollution Prevention Programs in Arizona..........................................82

12.4. Inventory of All Renewable Energy Generation Capacity and Production in Arizona.............98

12.5. Summary of Anticipated Renewable Energy Contribution .......................................................99

12.6. Incentive Programs..................................................................................................................100

12.7. Programs to Preserve and Expand Energy Conservation Efforts ............................................100

12.8. Potential for Renewable Energy ..............................................................................................106

12.9. Projections of Renewable Energy Goals, Energy Efficiency, and Pollution Prevention 

Activities .............................................................................................................................113

12.10. Programs to Achieve GCVTC Renewable Energy Goal.........................................................113

12.11. Future Progress Reports...........................................................................................................113

13. OTHER GCVTC RECOMMENDATIONS............................................................................ 115

13.1. Regulatory History and Requirements ....................................................................................115

13.2. Other Long-term Strategy Components ..................................................................................115

13.3. Sources In and Near GCVTC Class I Areas............................................................................115

13.3.1. Grand Canyon National Park .............................................................................................. 116

13.3.2. Mt. Baldy Wilderness Area................................................................................................. 116

13.3.3. Petrified Forest National Park............................................................................................. 116

13.3.4. Sycamore Canyon Wilderness ............................................................................................ 117

14. PROJECTION OF VISIBILITY IMPROVEMENT ............................................................. 119

14.1. Effect on Emissions of Long-term Strategy Components .......................................................119

14.1.1. Inventory Methodology and Scope ..................................................................................... 119

14.1.2. Projected Changes in Emissions for Arizona...................................................................... 120

14.2. Projected Changes in Visual Air Quality.................................................................................121

14.2.1. Applicable Class I Areas..................................................................................................... 121

14.2.2. Projected visibility improvement ........................................................................................ 121

15. STATE PLANNING/INTERSTATE COORDINATION AND TRIBAL 

IMPLEMENTATION ............................................................................................................... 125

15.1. Participation in Regional Planning and Coordination .............................................................125

15.2. Applicability to Tribal Lands ..................................................................................................125

16. PERIODIC IMPLEMENTATION PLAN REVISION.......................................................... 127

17. DECLARATION OF TREATMENT FOR ADDITIONAL CLASS I AREAS UNDER 

40 CFR 51.309(g)........................................................................................................................ 129
Table of Contents iv Arizona Regional Haze SIP

18. PUBLIC PARTICIPATION AND REVIEW PROCESS ...................................................... 131

18.1. Public Hearing Notice .............................................................................................................131

18.2. Hearing Transcripts .................................................................................................................131

18.3. Written Comments Received...................................................................................................131

18.4. Responsiveness Summary .......................................................................................................131
Table of Contents v Arizona Regional Haze SIP

LIST OF FIGURES

Figure 1-1. Western Regional Air Partnership Region ............................................................................. 5 

Figure 2-1. Class I Areas and Physiography Regions in Arizona............................................................. 7

Figure 2-2. Counties and Class I Areas in Arizona................................................................................... 9 

Figure 2-3. Non-Farm Employment in Arizona: 1990-2001 .................................................................. 12 

Figure 3-1. Colorado Plateau Class I areas ............................................................................................. 15 

Figure 3-2. Arizona Class I Areas........................................................................................................... 16 

Figure 3-3. View From South Rim of The Grand Canyon National Park .............................................. 17 

Figure 3-4. Map of Grand Canyon National Park Area.......................................................................... 17 

Figure 3-5. Map of Sycamore Canyon Wilderness Area ........................................................................ 18 

Figure 3-6. Petrified Forest National Park .............................................................................................. 19 

Figure 3-7. Map of Petrified Forest National Park Area................................................................... .... 19 

Figure 3-8. Map of Mount Baldy Wilderness Area ................................................................................ 20 

Figure 4-1. Interaction of Particles and Gases with Light ...................................................................... 24 

Figure 6-1. Map of the Clean Air Corridor in the Transport Region...................................................... 34 

Figure 7-1. Regional Sulfur Dioxide Emission Milestones .................................................................... 37 

Figure 12-1. Map of Arizona Solar Photovoltaic Resources .................................................................. 107

Figure 12-2. Map of Arizona Concentrating Solar Power Resources..................................................... 108 

Figure 12-3. Map of Arizona Biomass Energy Resources...................................................................... 109

Figure 12-4. Map of Arizona Collocated Gerthermal Energy Resources............................................... 110 

Figure 12-5. Projected Cost of Solar Energy Technologies.................................................................... 111 

Figure 12-6. Projected Cost of Energy from Renewable Energy Technologies - 2000.......................... 112 

Figure 17-1. Arizona Additional non-GCVTC Class I Areas................................................................ 129
Table of Contents vi Arizona Regional Haze SIP

LIST OF TABLES

Table ES-1. Requirements for Reasonably Attributable Visibility Impairment 

 Under 40 CFR 51.302 through 307 ................................................................................... ES-1 

Table ES-2. Summary of Requirements for Regional Haze Visibility Impairment 

 Under 40 CFR 51.309........................................................................................................ ES-2 

Table 2-1. Arizona’s Urbanized Areas: Census 2000............................................................................... 9 

Table 2-2. Growth of Arizona’s Counties: 2000-2002 ........................................................................... 10 

Table 2-3. Population Projections for Selected Arizona MSAs and Counties: 2000-2020 .................... 11 

Table 2-4. Average Number of Non-Farm Employees in Arizona 1990-2001 (10,000s)....................... 12 

Table 2-5. Projected Economic Indicators for Arizona: 2001-2005 ....................................................... 13 

Table 4-1. Light Extinction Efficiencies of Particles.............................................................................. 25 

Table 7-1. State-by-State Comparison of 1990 and 2000 Stationary Sources Sulfur 

 Dioxide Emissions in the 9 GCVTC Transport Region States (tons per year)...................... 38 

Table 8-1. Base Sulfur Dioxide Emissions Milestones (excludes Smelter Set-aside) ............................ 41 

Table 8-2a. (Years 2003-2010) Amounts of SO2 Tons To Be Subtracted from the 

 Base Milestones for States and Tribes That Do Not Have an Approved 

 Implementation Plan under 40 CFR 51.309* .................................................................. .... 42 

Table 8-2b. (Years 2011-2018) Amounts of SO2 To Be Subtracted from the Base Milestones 

 for States and Tribes that do not have an Approved Implementation Plan 

 under 40 CFR 51.309*........................................................................................................... 42 

Table 8-3. Preliminary Smelter-Specific Set Aside ................................................................................ 43 

Table 8-4. Utility/Non utility Split.......................................................................................................... 56 

Table 8-5. New Source Set-Aside Adjustment ....................................................................................... 56 

Table 9-1. Statewide Mobile Source Emissions for Arizona (Tons per Day)......................................... 72 

Table 10-1. Inclusion of ESMP Elements Into Arizona Regulations ....................................................... 77 

Table 12-1. Arizona’s Approach to Address 40 CFR 51.309(d) Requirements ....................................... 82 

Table 12-2. Summary of Renewable Energy Programs Currently in Place in Arizona............................ 82 

Table 12-3. Summary of Energy Efficiency Programs in Place in Arizona ............................................. 86 

Table 12-4. Planned Renewable Energy Capacity at of 2002................................................................... 97

Table 12-5. Summary of Renewable Energy Generation Capacity and Production................................. 99 

Table 12-6. Summary of Arizona’s Total Encergy Generation Capacity and Production........................ 99 

Table 12-7. Summary of Arizona’s Incentive Programs ........................................................................ 100 

Table 12-8. Programs that Preserve and Expand Energy Conservation in Arizona ............................... 100 

Table 12-9. Cost Estimates of Solar Options.......................................................................................... 112 

Table 14-1. Changes in Emissions from 1996 to 2018 for Arizona Sources (Tons per Year)................ 121 

Table 14-2. Changes iin Emissions from 1996 to 2018 for 9 GCVTC States (Tons per Year).............. 121 

Table 14-3. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018 

 on the Average 20% Worst Days, resulting from implementation of 

 “All 309 Control Strategies”................................................................................................ 122 

Table 14-4. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018, 

 on the Average 20% Best Visibility Days, resulting from implementation of 

 “All 309 Control Strategies”................................................................................................ 123
Table of Contents vii Arizona Regional Haze SIP

LIST OF APPENDICES

APPENDIX VOLUME I

APPENDIX A-1. BACKGROUND 

Appendix A-1a. Definitions 

Appendix A-1b. Arizona Department of Environmental Quality – Air Quality Division 

Organization Charts 

APPENDIX A-2. DESCRIPTIONS OF ARIZONA 

Appendix A-2a. Bibliography for Chapter 2 

APPENDIX A-5. ATTRIBUTABLE IMPAIRMENT 

Appendix A-5a. Arizona’s RAVI rule 

Appendix A-5b. Notification letters to FLMS on contact person, and Public Comment Period 

Appendix A-5c. Supporting Documents Related To The Promulgation Of Arizona’s RAVI Rule 

Appendix A-5d. New source review rule-R18-2-410 

APPENDIX A-6. CLEAN AIR CORRIDOR 

Appendix A-6a. WRAP Policy on Clean Air Corridors 

Appendix A-6b. WRAP Emission Tracking System and Assessment Process for the Clean Air 

Corridor 

APPENDIX A-7. STATIONARY SOURCES 

Appendix A-7a. Arizona Draft Western Backstop SO2 Trading Program Rule 

Appendix A-7b. Proposed WRAP 309 Coordinating Committee Charter 

Appendix A-7c. WRAP Report on Assessment of NOx/PM Strategies 

APPENDIX A-8. SO2 MILESTONES/BACKSTOP 

Appendix A-8a. WRAP Market Trading Forum Non-Utility Sector Allocation Final Report from 

the Allocations Working Group (November 2002) 

Appendix A-8b. Western Emissions Backstop (WEB) Emissions & Allowance Tracking Systerm 

(EATS) Analysis 

Appendix A-8c. Recommendations for Making Additional Determinations in the Context of 

Reasonably Attributable BART 

APPENDIX A-9. MOBILE SOURCES 

Appendix A-9a. Arizona Mobile Source Work Group Findings and Recommendations Related to Mobile 

Source Emissions 

APPENDIX VOLUME II

APPENDIX A-10. FIRE PROGRAMS 

Appendix A-10a. WRAP report “Assessing Status of Incorporating Smoke Effects into Fire 

Planning and Operation” 

Appendix A-10b. EPA’s “Interim Air Quality Policy on Wildland and Prescribed Fires” 
Table of Contents viii Arizona Regional Haze SIP

Appendix A-10c. Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest 

and Range Management Burns” 

Appendix A-10d. Supporting Documents Related to the Promulgation of Revised Arizona R18-2-

602, “Unlawful Open Burning” and Article 15, “Forest and Range 

Management Burns” 

Appendix A-10e. WRAP “Policy on Fire Tracking Systems” 

Appendix A-10f. WRAP report “Nonburning Alternatives for Vegetation and Fuel Management” 

Appendix A-10g. WRAP report “Burning Management Alternatives on Agricultural Lands in the 

Western United States” 

Appendix A-10h. WRAP report “Enhanced Smoke Management Programs for Visibility” 

Appendix A-10i. Arizona Revised Statute 49-501 

Appendix A-10j. WRAP report “Annual Emission Goals for Fire” 

APPENDIX VOLUME III

APPENDIX A-12. POLLUTION PREVENTION 

Appendix A-12a. Arizona Pollution Prevention Work Group Review of WRAP Policy on 

Renewable Energy and Energy Conservation 

Appendix A-12b. Details of Renewable Energy Generation and Capacity 

Appendix A-12c. ICF Assessment of Renewable Energy and Energy Conservation Programs 

APPENDIX A-13. OTHER GCVTC OPTIONS 

Appendix A-13a. Arizona’s Assessment of Other Recommendations Of The Grand Canyon 

Visibility Transport Commission 

Appendix A-13b. Summary of Discussions with Federal Land Managers on Emissions In-andNear the Four Arizona GCVTC Class I Areas 

APPENDIX A-14. PROJECTION OF VISIBILITY 

Appendix A-14a. Arizona Technical Review Memoranda of WRAP Emission Inventories and 

Technical Support Document 

Appendix A-14b. Summary of Emission Inventories used in WRAP Modeling 

APPENDIX A-18. PUBLIC PARTICIPATION 

Appendix A-18a. Notices of Public Hearings 

Appendix A-18b. Hearing Agendas, Sign-in Sheets, Transcripts, and Certifications 

Appendix A-18c. Written Comments Received During Comment Period 

Appendix A-18d. Responsiveness Summary 
Executive Summary ES - 1 Arizona Regional Haze SIP

EXECUTIVE SUMMARY

This Arizona State Implementation Plan (SIP) addresses the requirements of Title 40 of the Code 

of Federal Regulations, Part 51, Subpart P – Protection of Visibility (40 CFR 51.300-307, and 309). The 

SIP describes the programs that the State will rely upon to make reasonable progress toward “preventing 

any future and ... remedying any existing impairment of visibility” in the large parks and wilderness areas 

in Arizona and those in other states that may be affected by pollution generated in Arizona (Class I areas). 

The federal regional haze rules require states to develop and submit SIPs for improving visibility through 

the year 2018 that make reasonable progress toward achieving “natural visibility conditions” by the year 

2064. This SIP is designed to adopt the basic visibility program that addresses impairment of visibility 

that can be traced to older major industrial sources and implements recommendations adopted by the 

Grand Canyon Visibility Transport Commission (GCVTC) in its 1996 report to EPA. The Western 

Regional Air Partnership (WRAP) is the successor organization to GCVTC, and, in addition to being 

chartered to implement the GCVTC's recommendations, provides the mechanism for states and tribes to 

coordinate efforts and pool resources to conduct the complex technical analyses necessary to develop the 

science that is part of the foundation of regional haze SIPs. Arizona State government officials and 

employees and a variety of Arizona stakeholders actively participate in WRAP committees and 

workgroups to direct the policy and technical products of the WRAP. As such, this SIP revision relies on 

much of the work conducted by WRAP staff and contractors. 

Chapters 1 through 4 of this SIP include introductory and background information about visibility 

protection and regional haze. Chapter 5 is the plan for implementation of the rules and regulations 

addressing reasonably attributable visibility impairment, in addition to monitoring, planning, and new 

source review requirements under 40 CFR 51.300-307. Chapters 6 through 17 include Arizona’s 

approach to meeting the requirements for developing long-term visibility improvement strategies for 

regional haze under 40 CFR 51.309. Chapter 18 summarizes the public participation process in 

developing this SIP as required under 40 CFR 51.102. 

Table ES-1 summarizes the requirements in 40 CFR 51.302-307 for reasonably attributable 

visibility impairment, the approach taken by the State of Arizona to address the requirements, and the 

chapter in this SIP addressing the requirements. 

Table ES-1. Requirements for Reasonably Attributable Visibility Impairment 

Under 40 CFR 51.302 through 307 

Requirements of Summary of Approach, Content, or Findings 

Chapter 

in SIP 

40 CFR 51.302 

Implementation control 

strategies 

for reasonably 

attributable visibility 

impairment. 

Arizona has promulgated regulations in 2003 to address 

the implementation of controls, as needed, for sources 

subject to the best available retrofit technology 

requirements of the 1977 Clean Air Act for reasonably 

attributable visibility impairment (RAVI). 

5.1 

40 CFR 51.303 

Exemptions from 

control. 

Arizona has incorporated into the Arizona RAVI rule the 

necessary provisions to address the petition of BART 

emissions limits to the EPA Administrator. 

5.2 

40 CFR 51.304 

Identification of 

integral vistas. 

No integral vistas were identified for the Class I areas on 

the Colorado Plateau addressed by this SIP or the other 

Additional Class I areas in Arizona. 

5.3 
Executive Summary ES - 2 Arizona Regional Haze SIP

Requirements of Summary of Approach, Content, or Findings 

Chapter 

in SIP 

40 CFR 51.305 

Monitoring for 

reasonably attributable 

visibility impairment. 

Arizona established a comprehensive visibility 

monitoring program for the Class I areas and other 

transport sites in 1996. Arizona is an associate member 

of the IMPROVE Steering Committee and ensures 

information from the Arizona network is submitted as 

required, and participates in the technical leadership of 

the overall IMPROVE program. 

5.4 

40 CFR 51.306 

Long-term strategy 

requirements 

for reasonably 

attributable 

visibility impairment. 

Arizona has included in the SIP comprehensive long-term 

strategy components to address regional haze visibility 

impairment and RAVI from BART eligible sources. 

5.5 

40 CFR 51.307 

New source review. 

Arizona’s R18-2-410 (Article 4, New Source Review, 

Arizona Administrative Code) address requirements of 

new sources to meet performance standards to assure 

emissions will not have an impact on visibility. 

5.6 

Table ES-2 summarizes the requirements in 40 CFR 51.309 for regional haze, the approach taken 

by the State of Arizona to address the requirements, and the chapter in this SIP addressing the 

requirements. 

Table ES-2. Summary of Requirements for Regional Haze Visibility Impairment 

Under 40 CFR 51.309 

Requirement of 

40 CFR 51.309 Summary of Approach, Content, or Findings 

Chapter 

in SIP 

(d)(1) Time Period 

Covered 

This SIP addresses reasonable progress at the Class I 

areas on the Colorado Plateau from December 31, 2003 

through December 31, 2018. 

1.1 

(d)(2) Projection of 

Visibility Improvement 

Projected emissions and estimated visibility changes for 

each of the Class I areas on the Colorado Plateau were 

performed by the Western Regional Air Partnership 

(WRAP). 

Ch. 14 

(d)(3) Treatment of 

Clean Air Corridors 

The only Clean Air Corridor for the Class I areas on the 

Colorado Plateau does not include any area within 

Arizona. Arizona will include the results of future 

analyses in its periodic plan revisions. 

Ch. 6 

(d)(4), (f), and (h)

Implementation of 

Stationary Source 

Reductions 

General stationary source requirements are contained in 

Chapter 7. Chapter 8 contains a description of the SO2

Milestone and Backstop Trading Program. 

Ch. 7 

(general) 

Ch. 8 

(SO2) 

(d)(5) Mobile Sources Federal programs (such as low sulfur diesel, engine 

standards, etc.) are identified and describe mobile source 

emissions throughout the planning period. 

Ch. 9 
Executive Summary ES - 3 Arizona Regional Haze SIP

Requirement of 

40 CFR 51.309 Summary of Approach, Content, or Findings 

Chapter 

in SIP 

(d)(6) Programs 

Related to Fire 

Arizona revised its open burning and smoke management 

regulations (A.A.C. R18-2-602 and A.A.C R18-2-1501 - 

1515) to address the federal requirements. 

Ch. 10 

(d)(7) Area Sources of 

Dust Emissions From 

Paved and Unpaved 

Roads 

WRAP’s analysis concluded dust emissions from paved 

and unpaged roads are currently not a significant regional 

contributor to visibility impairment within the Colorado 

Plateau 16 Class I areas. Arizona will continue to support 

further research on this issue, as it develops its periodic 

plan revisions under 40 CFR 51.309(d)(10). 

Ch. 11 

(d)(8) Pollution 

Prevention 

Programs and policies within Arizona related to 

renewable energy and energy efficiency are described. 

Ch. 12 

(d)(9) Additional 

Recommendations 

The status of implementation of other strategies and 

options in the Grand Canyon Visibility Transport 

Commission Report are summarized. In addition, an 

overview of sources in and near each Arizona GCVTC 

Class I area is included. 

Ch. 13 

(d)(10) Periodic 

Revisions 

Arizona will submit periodic plan revisions to this SIP in 

2008, 2013 and 2018. 

Ch. 16 

(d)(11) State Planning 

and Interstate 

Coordination 

Arizona has and will continue to participate in the WRAP. 

As periodic plan revisions are done, consultation will also 

be made with states and tribes not implementing 40 CFR 

51.309. 

Ch. 15 

(f)(4) Geographic 

Enhancement 

WRAP has developed a model MOA to be executed by 

Arizona and Federal Land managers to address 

geographic enhancement of the regional haze SO2

Milestone and Backstop Trading Program (Ch. 8) for 

reasonably attributable visibility impairment. 

Ch. 8 in 

8.5 

(g) Reasonable 

Progress for Additional 

Class I Areas 

A supplement to this plan revision to address regional 

haze at the Additional 8 Class I areas in 

Arizona will be developed in accordance with 

40 CFR 51.309(g)(2-3) and submitted by 

December 31, 2008. 

Ch. 17 

While the above tables are organized in the order of the provisions of the regional haze rule, the 

SIP itself is organized according to the logic of pollution control plans. Consequently, the chapters of the 

SIP do not correspond precisely to the order of the requirements in the regional haze rule. 

Finally, the Technical Support Document (TSD) developed by the Western Regional Air 

Partnership (WRAP) is a reference for this SIP (herein referred to as the “WRAP TSD”). 

Chapter 1 – Background - 1 - Arizona Regional Haze SIP

1. BACKGROUND

1.1. Introduction

 Good visibility is important to fully enjoy the experience of visiting the State’s and Country’s 

national parks and wilderness areas. Visibility is how far and how well a person can see, and can be 

reduced or impaired by light scattering and absorption caused by particulate matter and gases in the 

atmosphere that occur from both natural and human-caused activities. Visibility impairing natural 

sources may include rain, wildland fires, volcanic activity, and wind blown dust. Visibility also can be 

impaired by human-caused sources of air pollution such as industrial processes, (utilities, smelters, 

refineries, etc.), mobile sources (cars, trucks, trains, etc.) and area sources (residential wood burning, 

prescribed burning, agricultural activities, wind blown dust from disturbed soils, etc.) 

Congress established a program to protect visibility in the larger national parks and wilderness 

areas which referred to as the mandatory Class I Federal areas (herein referred to as “Class I areas”). The 

State of Arizona is submitting this SIP to address the requirements (40 CFR 51.300-307) for visibility 

protection in the Class I areas and remove the existing Federal Implementation Plan (FIP) (52 FR 45132, 

November 24, 1987). This SIP also fulfills the requirements under 40 CFR 51.309 for Arizona’s 4 

Colorado Plateau Class I areas in addition to the other 12 Class I areas studied by the Grand Canyon 

Visibility Transport Commission (GCVTC). It contains all necessary measures to address reasonably 

attributable visibility impairment and regional haze visibility impairment necessary to ensure the State of 

Arizona makes reasonable progress toward the national goal for visibility contained in 42 U.S.C. 7491 

(Clean Air Act), specifically “...the prevention of any future, and remedying of any existing impairment 

of visibility in mandatory Class I Federal areas, which impairment results from man-made air pollution.” 

The Regional Haze Rule (RHR) defines this goal as achieving natural visibility conditions by 2064. This 

SIP addresses reasonable progress toward the national goal for the planning period from December 31, 

2003 thorough December 31, 2018. 

1.2. Definitions

 This SIP duplicates terms and phrases defined in 40 CFR 51.301, 40 CFR 51.309(b), and other 

terms specific to the programs set forth in this Plan. These definitions are contained in Appendix A-1a of 

this SIP. 

1.3. 1977 Clean Air Act

In the 1977 Clean Air Act (CAA), Congress established requirements for the prevention of 

significant deterioration of air quality in areas within the United States and for the review of pollution 

controls on new sources.1

 Coupled with this, Congress established a visibility protection program and the 

national goal (Section 169A) for larger national parks and wilderness areas.2

 The visibility protection 

program also requires states to address any visibility impairment caused by emissions of air pollutants 

from certain large industrial sources if the source was less than 15 years old as of August 1977, through 

the establishment of emission limits based on best available retrofit technology (BART). Congress also 

 

1

 Clean Air Act Amendments of 1977, United States Congress. 42 U.S.C. 7470-7479. Government Printing 

Office: Washington, D.C. August 7, 1977. 

2

 Clean Air Act Amendments of 1977, Section 169A, United States Congress. 42 U.S.C. 7491. Government 

Printing Office: Washington, D.C. August 7, 1977. 
Chapter 1 – Background - 2 - Arizona Regional Haze SIP

established mandatory criteria for states to use when establishing BART emission limits and developing 

long-term strategies for reasonable progress toward the national goal. 

1.4. Reasonably Attributable Visibility Impairment 

In 1980, the United States Environmental Protection Agency (EPA) issued final regulations to 

address the requirements of the 1977 Clean Air Act, requiring states with Class I areas to submit State 

Implementation Plan (SIP) revisions with new source review plans, monitoring plans, BART 

implementation plans, and long-term strategies to address reasonable progress toward the national 

visibility goal.3

 Arizona did not submit a SIP to address visibility, and in 1987 (52 FR 45132) EPA 

issued a Federal Implementation Plan. 

1.5. 1990 Clean Air Act

Although the 1980 regulations addressed reasonably attributable visibility impairment from 

specific sources, also know as plume blight, it did not adequately address visibility impairment from large 

collections of sources whose emissions are mixed and transported over long distances, creating a uniform 

haze (regional haze). In the 1990 amendments to the Clean Air Act (CAA), Congress established the 

requirements to address regional haze visibility impairment, giving the EPA authority to establish 

visibility transport commissions and promulgate regulations to address regional haze, and requiring the 

establishment of a visibility transport commission to investigate and report on regional haze visibility 

impairment in the Grand Canyon National Park located in northern Arizona.4

The Regional Haze SIP meets the requirements of Section 110, Implementation Plans, of the 

CAA. Demonstration of the public review process can be found in Chapter 18 and its related Appendix. 

Information to satisfy Section 110(a)(2)(E), adequate personnel to carry out such an implementation plan, 

can be found in Appendix A-1b). 

1.6. Grand Canyon Visibility Transport Commission

In response to the 1990 CAA, the Grand Canyon Visibility Transport Commission (GCVTC) was 

established in November 1991. Membership evolved over the approximately four and one-half years of 

its activities. When the GCVTC issued recommendations to EPA in June 1996, membership consisted of 

eight western governors (or their designees), four western tribal leaders, five ex-officio members 

representing federal land management agencies, an ex-officio tribal representative, and EPA. The 

transport region studied by the GCVTC consisted of nine western states: Arizona, California, Colorado, 

Idaho, New Mexico, Nevada, Oregon, Utah, and Wyoming. Arizona’s Governor Symington chaired the 

GCVTC. The GCVTC members agreed to expand the scope of technical and policy studies to include all 

16 of the Class I areas on the Colorado Plateau. The GCVTC elected to use a stakeholder-driven process 

to accomplish its objectives to review current science and policy information and determine what actions, 

if any, were needed to address regional haze visibility impairment at the Class I areas on the Colorado 

Plateau. Ultimately, the organization included over 200 political, policy and technical stakeholders, who 

staffed a variety of committees and subcommittees. The GCVTC was funded by EPA grants and 

contributions from stakeholders, including substantial in-kind labor. The GCVTC submitted its 

recommendations to EPA in June 1996.5

 The major recommendations of the GCVTC included: 

 

3

 40 CFR Part 51 - Protection of Visibility, United States Environmental Protection Agency, 45 FR 80089. 

Government Printing Office: Washington, D.C. December 2, 1980. 4

 Clean Air Act Amendments of 1990, Section 169B, United States Congress. 42 U.S.C. 7492. Government 

Printing Office: Washington, D.C. November 15, 1990. 

5

 Recommendations for Improving Western Vistas, Grand Canyon Visibility Transport Commission; Western 

Governors' Association: Denver, CO, June 10, 1996. 
Chapter 1 – Background - 3 - Arizona Regional Haze SIP

• The need to promote energy conservation, energy efficiency and renewable energy production; 

• The need to track emissions growth that may affect air quality in clean air corridors; 

• The need to manage emissions of stationary sources of sulfur dioxide with a voluntary program 

using emission reduction milestones coupled with a backstop cap-and-trade program that would 

be implemented if emissions reductions milestones were exceeded. 

• The need to cooperate and work with federal land managers to do further studies of sources in 

and adjacent to Class I areas; 

• The need to manage emissions of mobile sources through the implementation of more stringent 

national engine and fuel standards; 

• The need to manage emissions of mobile sources from large urban areas that contribute 

significantly to visibility impairment in any of the 16 GCVTC Class I areas; 

• The need to analyze the contribution of road dust emissions on visibility in the Class I areas; 

• The need to promote programs to encourage emissions reductions in Mexico; 

• The need to manage the visibility impacts resulting from the growth of emissions from prescribed 

fires needed to restore the ecosystem; and, 

• The need to establish a successor organization to the GCVTC to oversee, promote, and support 

the GCVTC’s recommendations. 

1.7. Western Regional Air Partnership

The GCVTC’s successor, the Western Regional Air Partnership (WRAP) was formed in 

September 1997. Though the WRAP's charter allows it to address any air quality issue of interest to 

WRAP members, its current work is focused on developing the policy and technical work products 

needed by states and tribes for regional haze SIPs or Tribal Implementation Plans (TIPs). Figure 1-1 

shows the WRAP region. 

The WRAP Board is composed of representatives from 13 states, 13 tribes, the US Department of 

Agriculture, the US Department of the Interior, and EPA. The WRAP operates on a consensus basis and 

conducts business through stakeholder-based technical and policy groups charged with assisting the 

development of regional haze work products. Additional information about the WRAP can be found at 

http://www.wrapair.org. 

1.8. 1999 Regional Haze Rule

EPA proposed regional haze regulations in 1997.6 The proposed regulations described a national 

program but did not include provisions to address the recommendations of the GCVTC. The Western 

Governors' Association (WGA) subsequently developed a recommendation related to the Colorado 

Plateau area and submitted it to EPA in June 1998.7

 Based on this and other comments, EPA issued the 

final regional haze rule in July 1999. In addition to the national program that could apply to any state or 

tribe and the final rule contained requirements for an optional program relying on the work of the 

GCVTC.8

1.9. 2002 Annex Rule for Stationary Sources of Sulfur Dioxide

One of the requirements of the RHR was the development and submission to EPA of a 

 

6

 40 CFR Part 51 - Regional Haze Regulations; Proposed Rule - 62 FR 41138. United States Environmental 

Protection Agency, Government Printing Office: Washington, D.C. July 31, 1997. 

7

 Leavitt, M. O, Governor of Utah, Letter to EPA Administrator Browner on behalf of the Western 

Governors' Association, June 29, 1998. 

8

 40 CFR Part 51 - Regional Haze Rule; Final Rule, 64 FR 35714. United States Environmental Protection 

Agency, Government Printing Office: Washington, D.C. July 1, 1999. 
Chapter 1 – Background - 4 - Arizona Regional Haze SIP

supplement or Annex to the GCVTC recommendations to define the program for stationary sources of 

sulfur dioxide by October 1, 2000. The WRAP established the Market Trading Forum (MTF) consisting 

of key stakeholders in the region to develop the Annex. The MTF analyzed the technical and policy 

issues surrounding the establishment of the voluntary emission reduction milestones with a backstop 

program to assure emission reductions were achieved and deliberated the content of the Annex. 
Chapter 1 – Background - 5 - Arizona Regional Haze SIP

Figure 1-1. Western Regional Air Partnership Region 
Chapter 1 – Background - 6 - Arizona Regional Haze SIP

The WRAP approved and submitted the Annex to the GCVTC recommendations to define a 

voluntary program of sulfur dioxide emission reduction milestones coupled with a backstop markettrading program to assure emission reductions on September 30, 2000. EPA proposed changes to the 

regional haze rule to incorporate the GCVTC Annex,9

 and the final rule was published in the Federal 

Register on June 5, 2003 (68 FR 33764). 

1.10. 2003 Rule Change to Mobile Source Requirements for National 

Strategies

The GCVTC developed long-term projections of emissions in the GCVTC transport region based 

on information available in the early 1990’s. Those emission projections showed that emissions from 

mobile sources were expected to decline through approximately 2005 and then begin to increase through 

2040. As a result, the GCVTC recommendations included recommended actions for national strategies, 

that were out of the control of the GCVTC, and local strategies. The local strategies included the concept 

of capping emissions from mobile sources in large urban areas that contribute significantly to visibility 

impairment in any of the 16 GCVTC Class I areas in the year 2005, or some other year that emissions 

reached its minimum levels. This strategy was adopted in the RHR in 40 CFR 51.309(d)(5)(ii) and (iii). 

After the RHR was adopted, EPA promulgated several new emission and fuel standards for 

mobile sources. Emission projections developed by the WRAP demonstrated emissions from mobile 

sources would decline significantly through the entire planning period from 2003 through 2018, and 

possibly beyond. Each pollutant was expected to decline except for sulfur dioxide from off-road mobile 

sources unless pending rule making for fuel standards were promulgated by EPA. Given the significant 

reduction in emissions, the WRAP determined that the current requirement under 40 CFR 51.309(d)(5)(ii) 

and (iii) were no longer an effective management tool for mobile sources, and developed proposed 

changes to the RHR to address emissions from mobile sources. 

 

 In 2003, the WRAP formally requested that EPA make revisions to the mobile sources section of 

the Regional Haze Rule (40 CFR 51.309(d)(5)) to reflect changes in emissions due to federal programs 

developed since the rule was promulgated in 1999. The basis for the WRAP request was EPA’s adoption 

of more stringent national vehicle emission and fuel standard that result in mobile source emissions 

declining throughout the region during the 2003-2018 planning period covered by plans being submitted 

in December 2003. EPA proposed changes to 40 CFR 51.309(d)(5) on July 3, 2003 (68 FR 39842 and 68 

FR 39888). EPA held a hearing on October 7, 2003, on the proposed change and promulgated the final 

rule on December 22, 2003 (68 FR 71009).

 

9 40 CFR Part 51 - Regional Haze Regulations; Proposed Rule, 67 FR 30418, United States Environmental 

Protection Agency. Government Printing Office: Washington, D.C. May 6, 2002. 
Chapter 2 – Descriptions of Arizona - 7 - Arizona Regional Haze SIP

2. PHYSICAL, DEMOGRAPHIC, AND ECONOMIC 

DESCRIPTIONS OF ARIZONA

This section of the SIP provides an overview of the physical, demographic and economic 

characteristics, along with some history of the formation of the state. Appendix A-2a contains a 

bibliography of sources for the information presented in this chapter. 

2.1. Climate and Physiography

Arizona encompasses nearly 114,000 square miles, ranging in elevation from 70 feet above sea 

level on the Colorado River at the Arizona-Mexico border, to 12,643 feet in the north at Humphreys Peak 

just north of Flagstaff. It contains four desert regions and hundreds of mountains, remnants of state’s past 

volcanic activity. Arizona borders states of California and Nevada on the West, Utah on the North, 

Colorado to the Northeast, New Mexico on the East, and the country of Mexico to the South. 

Figure 2-1. Class I Areas and Physiography Regions in Arizona 
Chapter 2 – Descriptions of Arizona - 8 - Arizona Regional Haze SIP

Arizona has three main topographical areas: 1) a high plateau in the northeast; 2) a mountainous 

region oriented southeast to northwest; and 3) low mountain ranges and desert valleys in the southwestern 

portion of the state. These regions bring a wide range of climate to the state with lows well below zero in 

the high plateau and mountainous regions of central and northern Arizona, while temperatures can exceed 

125°F within the desert areas. 

Precipitation throughout Arizona is governed by elevation and time of year, with the highest 

elevations averaging between 25 to 30 inches of precipitation annually. The desert southwest averages as 

low as three to four inches per year. The average number of days per year with measurable precipitation 

varies from near 70 days in the north (Flagstaff area) to 15 in the southwest (Yuma area). From 

November through March, storm systems from the Pacific Ocean cross the state, some bringing blizzard 

conditions to the high elevations. Summer rainfall begins early in July and usually lasts until midSeptember. The moisture-bearing winds come from either the southwest (Gulf of California) or southeast 

(Gulf of Mexico), and during a wind shift called, “the North American Monsoon,” large thunderstorms 

can occur in the mountainous regions on down through the central and southeastern portion of the state. 

Blowing dust prior to onset of rain can occur during these storms. Flash floods can also occur. 

Approximately 70% of Arizona’s land is owned and managed by the federal government and the 

21 federally recognized Indian tribes. The state owns nearly 13%, leaving about 18% of the state land is 

under private ownership. 

Arizona is host to some of the country’s most spectacular and beloved national parks and 

wilderness areas. Of the 158 national parks and wilderness areas classified as mandatory Class I Federal 

areas, 12 are located in Arizona (40 CFR 81.403). Four of the 12 Arizona Class I areas are on the 

Colorado Plateau, the area of study by the GCVTC. A list of all 16 Class I areas that were part of the 

GCVTC study of Colorado Plateau Class I areas can be found in Chapter 3 of this SIP. Detailed 

information on Arizona’s four Colorado Plateau Class I areas also can also be found in Chapter 3. Figure 

2-2 shows Arizona Class I areas. 

2.2. Population

The Arizona Territory was formed in 1863 from the western part of the New Mexico Territory.10 

As part of the New Mexico Territory in 1860, “Arizona County” had an 1860 population of 6,482. By 

1870, Arizona Territory’s population grew to 9,658 with most of the inhabitants living in Pima County. 

Arizona’s population during the 2000 Census had grown to 5,130,632. 

Arizona has six urbanized areas (i.e., 50,000 people or more), two of which are major urban areas 

(i.e., 250,000 people or more), and three represent newly qualified areas based on the results of the 2000 

Census (see Table 2-1). Two of these urbanized areas, Flagstaff and Prescott, are located in northern 

Arizona. Flagstaff is in Coconino County near two of the four Class I areas: Grand Canyon National 

Park and Sycamore Canyon Wilderness. 

 

10 Arizona was the name given to the territory. The town of Arizona actually was located south of the new border in 

Sonora, Mexico. The old name of the region was ‘Pimería Alta.’ The Treaty of Guadalupe Hidalgo in 1848 ended 

the war between the U.S. and Mexico. The treaty required Mexico to cede hundreds of thousands of square miles of 

land to the U.S. The geographical areas included western New Mexico, Arizona north of the Gila River, California, 

Nevada, Utah, as well as parts of Colorado, Wyoming, Kansas, and Oklahoma. Then, in 1853 with the Gadsden 

Purchase, which added the land south of the Gila River, Arizona formed its present borders. 
Chapter 2 – Descriptions of Arizona - 9 - Arizona Regional Haze SIP

Figure 2-2. Counties and Class I Areas in Arizona

Table 2-1 

 Arizona’s Urbanized Areas: Census 2000 

Urbanized Areas Arizona County Population 

Avondale Maricopa 67,875 

Flagstaff Coconino 57,050 

Phoenix-Mesa Maricopa 2,907,049 

Prescott Yavapai 61,909 

Tucson Pima 720,425 

Yuma (AZ-CA) Yuma 94,950 

 Source: U.S. Bureau of the Census 

Table 2-2 shows Census 2000 county populations as well as 2002 mid-year county population 

estimates for Arizona. According to these data, the state grew 6.7 percent between 2000 and 2002. The 

two largest Metropolitan Statistical Areas (MSAs), Phoenix-Mesa and Tucson, grew at 7.3 percent and 

5.5 percent, respectively, during these two years. The Phoenix-Mesa MSA includes Maricopa and Pinal 

Counties. Pinal County was added to the Phoenix-Mesa MSA in 1993. 
Chapter 2 – Descriptions of Arizona - 10 - Arizona Regional Haze SIP

Table 2-2 

 Growth of Arizona’s Counties: 2000-2002 

County Census 2000 

(April) 

2002 Estimate 

(July) 

Apache 69,423 70,105 

Cochise 117,755 124,040 

Coconino 116,320 125,420 

Gila 51,335 53,015 

Graham 33,489 34,070 

Greenlee 8,547 8,605 

La Paz 19,715 20,365 

Maricopa* 3,072,149 3,296,250 

Mohave 155,032 166,465 

Navajo 97,470 101615 

Pima (Tucson MSA) 843,746 890,545 

Pinal* 179,727 192,395 

Santa Cruz 38,381 39,840 

Yavapai 167,517 180,260 

Yuma 160,026 169,760 

State Total 5,130,632 5,472,750 

 * Part of Phoenix-Mesa Metropolitan Statistical Area 

 Source: U.S. Bureau of the Census; Population Statistics Unit, Research 

 Administration, Department of Economic Security, December 6, 2002. 

The Phoenix-Mesa MSA ranks 14th among all metropolitan areas by total population for 2000. 

However, the Phoenix-Mesa MSA is one of the fastest-growing metropolitan areas in the nation. As a 

county, however, Maricopa County gained the most number of people numerically, ranking it as the 

fourth largest county in the nation. 

Table 2-3 portrays population projections for selected areas in Arizona including the PhoenixMesa MSA and Tucson MSA in five-year increments from 2000 to 2020. The county population 

projections for the four counties where the Arizona Colorado Plateau Class I areas are located and the 

projected state totals also are included for reference. 
Chapter 2 – Descriptions of Arizona - 11 - Arizona Regional Haze SIP

Table 2-3 

 Population Projections for Selected Arizona MSAs and Counties: 2000-2020

Area 2000 2005 2010 2015 2020 

Phoenix-MesaScottsdale MSA 

3,115,787 3,511,048 3,909,281 4,317,999 4,747,319 

Tucson MSA 854,329 943,795 1,031,623 1,119,342 1,206,244 

Apache County 67,925 72,236 76,645 81,173 85,766 

Coconino 

County 

123,329 135,595 147,352 158,753 169,343 

Mohave County 147,529 171,504 194,403 215,988 236,396 

Navajo 

County 

88,898 94,395 99,979 105,843 111,946 

Yavapai County 152,966 175,693 198,052 219,614 240,849 

State Total 4,961,953 5,553,849 6,145,108 6,744,754 7,363,604 

Source: Population Statistics Unit, Research Administration, Department of Economic Security (DES), 

Approved by Director August 1, 1997. 

According to these projections, the state’s population is projected to grow by 48 percent in 20 

years. While these are the official population projections for the State, they are under estimates. The 

2000 projection is 4.2% below the 2000 official U.S. Census count and the decennial growth rates for 

2000 through 2010 and 2010 through 2020 are 20% and 10%, respectively. 

If the average decennial growth rate of 40 percent from 1960 through 2000 is maintained, 

Arizona’s population in 2010 would almost be equivalent to the 2020 DES population projection. 

Carrying the 40 percent decennial growth rate forward to 2020 would mean a state population of about 10 

million compared to the 7.3 million projected in 2020 by DES. 

2.3. Economy

Arizona’s growth in gross state product ranked first in the nation during 1992 through 1999, 

increasing from $85 billion in 1992 to $140 billion in 1999. Contributing to this growth were high-tech 

manufacturing industries, wholesale and retail trade, services, and construction industries.11 

Manufacturing output averaged 13.2 percent annually during this eight-year time period. The other 

sectors grew predominantly as the population of the state grew. 

Table 2-4 shows a time series of civilian non-farm labor force data. The last column shows the 

annual average growth rate in employment between 1990 and 2001. Total non-farm and private 

employment grew at rates over 50%. By contrast the minimum decennial growth rate for 1960 through 

2000 was 35%. Figure 2-3 shows the change in employment from 1990 through 2001. It should be noted 

that reliable data for agricultural employment are not available due to large seasonal fluctuations in 

employment. 

 

11 Based on construction data through the 1990s, it is evident that the single family housing sector was a major force, 

coupled with the commercial sector, behind the state’s construction and real estate industries. 
Chapter 2 – Descriptions of Arizona - 12 - Arizona Regional Haze SIP

Table 2-4 

 Average Number of Non-Farm Employees in Arizona 1990-2001 (10,000s) 

Year 1990 1992 1994 1996 1998 2000 2001 Annual 

Avg. 

Growth 

Goods 27.33 26.22 30.35 34.69 37.30 38.78 38.48 4.1% 

Services 120.98 125.49 138.86 154.54 170.18 185.49 188.01 4.0% 

Total 

Non-Farm 

148.31 151.71 169.20 189.23 207.47 224.27 226.50 3.9% 

Private 122.41 124.03 139.77 157.44 173.32 187.61 188.72 3.2% 

Source: Arizona Department of Economic Security in cooperation with U.S. Department of Labor, 

Bureau of Labor Statistics. 

* Percent change between 1990 and 2001. 

Figure 2-3. Non-Farm Employment in Arizona: 1990-2001 

Non-Farm Employment In Arizona

1990 - 2001

0

500

1000

1500

2000

2500

1990 1992 1994 1996 1998 2000 2001

Total Full-Time 

Employees in 

Thousands

Goods Services Private (Goods & Svcs)

Table 2-5 contains selected economic indicators forecast for Arizona for 2001 through 2005. All 

indicators are forecast to increase except for mining, manufacturing, and TCPU. The forecast largest 

gains are for personal income (27.9%), restaurant and bar sales (26.0%), retail sales (19.8%), food sales 

(17.9%), and services (16.7%). 
Chapter 2 – Descriptions of Arizona - 13 - Arizona Regional Haze SIP

 Table 2-5 

 Projected Economic Indicators for Arizona: 2001-2005 

Economic Indicator 2001 2002 2003 2004 2005 

Personal Income ($millions) 137,313.5 143,291.1 150,549.4 161,338.3 175,570.2 

Retail Sales ($millions) 55,421.2 55,928.2 58,288.5 61,477.6 66,369.8 

Food Sales ($millions) 7,262.7 7,491.3 7,678.3 8,050.4 8,565.3 

Restaurant & Bar Sales 

($millions) 

6,360.6 6,490.3 6,851.4 7,367.4 8,014.0 

Gasoline Sales ($millions) 3,492.3 3,476.4 3,693.4 3,717.5 3,845.0 

Total Employment (10,000s) 226.63 224.74 229.23 238.10 248.87 

Mining (1,000s) 9.6 8.8 8.7 8.5 8.3 

Construction (1,000s) 164.9 159.4 161.6 160.8 166.6 

Manufacturing (1,000s) 210.1 194.0 188.8 193.0 204.4 

TCPU (1,000s)** 110.7 105.6 105.1 107.5 110.4 

Trade (1,000s) 533.2 537.2 547.8 570.8 594.9 

FIRE (1,000s)*** 150.7 149.9 155.1 164.4 173.2 

Services (1,000s) 711.1 707.3 736.8 783.5 829.7 

Government (1,000s) 376.4 385.3 388.6 392.7 401.2 

Unemployment Rate 4.7% 5.7% 5.2% 4.4% 4.1% 

Source: Economic Outlook 03/04. The University of Arizona. Eller College of Business and Public 

Administration, Table 3. 

* Includes bar sales as well 

** Transportation, Communication, and Public Utilities 

*** Finance, Insurance, and Real Estate 
Chapter 2 – Descriptions of Arizona - 14 - Arizona Regional Haze SIP

(This page intentionally blank) 
Chapter 3 – Class I Areas - 15 - Arizona Regional Haze SIP

3. MANDATORY CLASS I FEDERAL AREAS ON THE 

COLORADO PLATEAU

This chapter describes the 16 Class I areas on the Colorado Plateau studied by the Grand Canyon 

Visibility Transport Commission and addressed in this SIP in response to 40 CFR 51.309. Figure 3-1 

shows the location of the national parks and wilderness areas addressed by this SIP. 

Figure 3-1. Colorado Plateau Class I areas 

 

3.1. Arizona Class I Areas

There are a total of 12 mandatory Class I Federal areas in Arizona. Of the four Arizona Class I 

areas addressed by this SIP, two, Grand Canyon National Park and Sycamore Canyon Wilderness are 

located in the northwestern portion of the state. Grand Canyon National Park extends over toward the 

state’s western border with Nevada, and Sycamore Canyon Wilderness Area is located south of Flagstaff. 

The third Class I area, Petrified Forest National Park, occupies land adjacent to and directly south of the 

Navajo Reservation. The fourth, Mt. Baldy Wilderness Area, occupies a comparatively small portion of 

land on the eastern side of the state and is one of the many extinct volcanoes found throughout the state. 

All four of these Arizona Class I areas are part of a larger formation known as the Colorado Plateau. This 

high, semi-arid tableland includes, along with northern Arizona, southeast Utah, northwest New Mexico, 

and western Colorado. 

 
Chapter 3 – Class I Areas - 16 - Arizona Regional Haze SIP

Figure 3-2. Arizona Class I Areas. 

3.1.1. Grand Canyon National Park

The Grand Canyon National Park is on the southwestern Colorado Plateau. Over time, the 

Colorado River and its tributaries cut through the many layers of rock that make up the southwestern 

Colorado Plateau, forming a gorge one-mile deep and several miles wide. This cut into the earth begins 

at Lees Ferry, below Glen Canyon Dam, and extends 277 miles with a variation in width from 10-18 

miles wide to just hundreds of yards in Marble Canyon to the northeast. The western part of the canyon 

extends into the Mohave Desert, while the eastern part reaches into the Great Basin Desert. 

The Park, after being designated a national monument in 1908, became a national park on 

February 26, 1919. The Park is contained within Mohave and Coconino Counties. The Grand Canyon 

was designated a World Heritage Site in 1979. The Grand Canyon is a spectacular example of weathering 

and erosion, featuring unmatched vistas and intriguing landforms comprised of irregular-shaped cliffs and 

valleys caused by differential erosion, buttes, mesas, and rock depositions forming talus cones and aprons. 

Because of these geological spectacles, the Grand Canyon ranks among the world’s greatest attractions 

with on-going erosion revealing much about the earth’s geological history. Every year millons of visitors 

from all over the world visit the Park. 
Chapter 3 – Class I Areas - 17 - Arizona Regional Haze SIP

Figure 3-3. View From South Rim of The Grand Canyon National Park 

Figure 3-4. Map of Grand Canyon National Park Area 
Chapter 3 – Class I Areas - 18 - Arizona Regional Haze SIP

3.1.2. Sycamore Canyon Wilderness

Approximately 40 miles southwest of Flagstaff is the Class I Area known as Sycamore Canyon 

Wilderness. Designated in 1935 as a Primitive Area, Congress formally established the area as a federally 

protected area in 1972. It became a Wilderness Area through the 1977 Arizona Wilderness Act. 

The area, split between Coconino and Yavapai Counties, contains 55,937 acres, beginning with 

pine and fir forests on the Colorado Plateau through part of the Mogollon Rim, ending at the desert mouth 

of the Verde Valley. Sycamore Canyon Wilderness, containing beautiful red rock, buttes, and sheer 

cliffs, is only 15 miles west of Oak Creek Canyon and Sedona area, one of Arizona’s most popular tourist 

destinations. Motorized or mechanized vehicles are not allowed in the area. 

Figure 3-5. Map of Sycamore Canyon Wilderness Area 

 
Chapter 3 – Class I Areas - 19 - Arizona Regional Haze SIP

3.1.3. Petrified Forest National Park

Petrified Forest National Park is located in northeastern Arizona. The Park lies within both 

Navajo and Apache Counties, covering a total of 93,533 acres. It was designated a national monument in 

1906 and a national park in 1962. The southern portion of Petrified Forest National Park contains one of 

the world’s largest concentrations of petrified wood. The northern portion of the Park encompasses the 

badlands of the Chinle Formation that extends along the Little Colorado River valley to the west for about 

125 miles. Known more commonly as “the Painted Desert” with its colored soils ranging from blues and 

reds to yellows and grays, this area includes at its southern tip, the Rainbow Forest 

Figure 3-6. Petrified Forest National Park 

Figure 3-7. Map of Petrified Forest National Park Area 
Chapter 3 – Class I Areas - 20 - Arizona Regional Haze SIP

3.1.4. Mt. Baldy Wilderness

Not to be confused with California’s Mt. Baldy, located in the San Gabriel Mountains, Mt. Baldy 

Wilderness, located in Apache County about 90 miles south of the Petrified Forest National Park. Mt. 

Baldy Wilderness, 7,079 acres, is an ancient volcano and the second highest peak in Arizona. It is located 

in the White Mountains along the southern edge of the Colorado Plateau. The summit of Mt. Baldy is on 

the White Mountain Apache Indian Reservation and is closed to all non-tribal members. This SIP is only 

for the portion of Mt. Baldy under the jurisdiction of the State. 

Figure 3-8. Map of Mount Baldy Wilderness Area 

Four rivers have headwaters on the slopes of Mt. Baldy: the Black, Blue, White, and Little 

Colorado rivers. Fishing and camping are major recreational activities where 25 lakes are scattered 

among the mountains. Livestock grazing is common on the meadows and pine forests of the White 

Mountains. The area has a wide range of weather, with snow at the higher elevations. 

The same conditions and restrictions that pertain to the Sycamore Canyon Wilderness Area also 

pertain to Mt. Baldy Wilderness area – no motorized or mechanized vehicles, no bicycles, and no power 

equipment is allowed. 
Chapter 3 – Class I Areas - 21 - Arizona Regional Haze SIP

3.2. Class I Areas Outside Arizona

The four Class I areas on the Colorado Plateau are joined by 12 other Class I areas to 

make up the total of 16 Class I areas originally examined by the GCVTC. A brief description of each of 

these 12 areas follows.12 

 

Capitol Reef National Park, Utah – Capitol Reef received its name from the barrier created by a 100 mile 

long ridge of rock that was thrust up from the earth millions of years ago. The rock is said to resemble 

the dome-like structures seen on capitol buildings in Washington, D.C. The park is fairly isolated in the 

south central part of Utah, 60 miles south of I-70. 

Bryce Canyon National Park, Utah – Also in southern Utah, Bryce Canyon represents the effect of 

centuries of erosion that has shaped the colorful Claron limestones, sandstones, and mudstones of this 

park into thousands of spires, pinnacles and mazes. The local name for these shapes is “hoodoos,” one of 

which forms a natural amphitheatre along the eastern edge. 

Zion National Park, Utah – On the southern edge of the Colorado Plateau, Zion is known for its highly 

variable weather due to its elevation changes of 3,666 feet at its lowest point in Coalpits Wash to 8,726 

feet at its highest, Horse Range Mountain in the Kolob Canyon section. The variable weather an 

elevations have led to numerous “microenvironments” that range from hanging gardens to isolated mesas. 

Arches National Park, Utah - Arches National Park contains over two thousand natural sandstone arches, 

including the famous Delicate Arch. The park, also known for its balanced rocks and pinnacles, is located 

near Moab, Utah. Protected since 1929, it became a national park in 1971. 

Canyonlands National Park, Utah – Canyonlands preserves one of the last, relatively undisturbed areas of 

the Colorado Plateau. It contains a large portion of the Colorado River and its tributaries, which carve out 

numerous canyons and gorges. The unique desert ecosystem has been visited by different groups of 

settlers for over 10,000 years, in concert with available resources. Its national park designation in 1964 is 

an attempt to maintain its natural beauty while still allowing for continued visitors. 

Mesa Verde National Park, Colorado – Spanish for “green table,” Mesa Verde allows visitors to 

experience both cultural and physical influences on the land. From approximately 600 A.D. through 1300 

A.D., settlements flourished in stone villages throughout the alcoves of the canyon walls. Twenty-four 

tribes in the southwest have ancestral affiliation with the sites at Mesa Verde. The park is 35 miles west 

of Durango in southwestern Colorado, just off US Highway 160. 

Flattops Wilderness Area, Colorado – Flattops has a less friendly history than Mesa Verde, witnessing the 

“Meeker Massacre” of 1879 when federal troops forcibly removed the Ute Indians, who had resided in 

the area for perhaps thousands of years. Originally destined to become a summer home area, it was 

instead recommended for wilderness area designation in 1919. In fact, Flattops became the keystone in 

the establishment of the National Wilderness Preservation System. 

Maroon Bells Wilderness Area, Colorado – Maroon Bells, and its neighboring area, Snowmass, see a 

large amount of visitors every year. There are over 100 miles of trail, and despite peaks that rise above 

14,000 feet, people literally swarm throughout the park’s over 181,000 acres to enjoy some of the most 

beautiful views, some say of wildflowers alone, in the country. The park is named not for a flower, but 

 

12 The State of Arizona thanks the USDA and US Park Service for providing information on the national parks and 

wilderness areas that comprise the Colorado Plateau through its various web sites and literature. 
Chapter 3 – Class I Areas - 22 - Arizona Regional Haze SIP

for Maroon Bells peak, one of the most photographed mountains, especially when it is reflected in 

Maroon Lake. 

West Elk Wilderness Area, Colorado – As busy as Maroon Bells Wilderness Area is with visitors, West 

Elk is fairly devoid of people. Only hunters populate the area in the fall, when elk and deer number in the 

thousands. Long lava flows are found throughout the area, where trails can lead to areas containing 

ridges that the wind and water have carved into formations that resemble the turrets of castles. 

Black Canyon of the Gunnison Wilderness Area, Colorado – The Black Canyon of the Gunnison’s unique 

and spectacular landscape was formed slowly by the action of water and rock scouring down through hard 

Proterozoic crystalline rock. No other canyon in North America combines the narrow opening, sheer 

walls, and startling depths offered by the Black Canyon of the Gunnison. 

Weminuche Wilderness Area, Colorado – Weminuche is Colorado’s largest wilderness area. It contains 

63 high altitude lakes, known for their deep blue color. The area encompasses a total of 488,210 acres 

that include the headwaters of both the Rio Grande and San Juan Rivers. The area also contains the 

Continental Divide Trail and is said to exemplify the mission of the Wilderness Act of 1964 by securing 

the benefits of an enduring resource of wilderness for generations to come. 

San Pedro Parks Wilderness Area, New Mexico – This area, at the same latitude as the Grand Canyon 

National Park where the Colorado Plateau dips into New Mexico and Arizona, has an elevation of 10,000 

feet above sea level. But unlike its counterpart in Arizona, the area has rolling mountaintops and 

meadows with large grassy areas. The area sees frequent rain in late summer and snow by November. Its 

mountain streams are a favorite of local trout anglers. 
Chapter 4 – Technical Background - 23 - Arizona Regional Haze SIP

4. TECHNICAL BASIS FOR REGULATION OF REGIONAL 

HAZE

This chapter provides a brief introduction to the science of visibility and the technical basis for 

the regulation of regional haze. A more detailed presentation of the concepts contained in this chapter can 

be found in the 1999 document entitled Introduction to Visibility by William C. Malm, Ph.D., available 

from CIRA (Cooperative Institute for Research in the Atmosphere) at Colorado State University. 

4.1. How Do We See?

Light waves, like radio waves, are a form of electromagnetic radiation. All electromagnetic 

radiation travels in the form of waves at the speed of light which is approximately 186,000 miles per 

second. Light waves, like radio waves, also have distinct frequencies (the number of times per second the 

wave goes from crest to crest) and a corresponding wave length (the distance between the crest of each 

wave). As an example, when you tune your radio to 550 on the AM dial, your radio receives a signal that 

has a frequency of 550 thousand cycles per second with a corresponding wave length of approximately 

1,800 feet (six football fields). In contrast, blue light has a frequency of about 3.5 trillion cycles per 

second corresponding wave length of 1.5 millionths of an foot. Unlike radio waves that require humans 

to use a radio receiver to capture information, the human eye directly captures information contained in 

light waves. 

Light waves are made up of small energy packets, or photons, that travel through the air. Light 

photons each have a defined energy level that give them a distinct color corresponding to its frequency or 

wave length. Red light waves are at the lowest energy level and the longest wavelength. Blue light 

waves are at the higher energy level and shorter wavelength. White light, like sunlight, is made up of a 

mixture of all of the different wave lengths of light. When white sunlight goes through a prism, or 

through rain drops, the photons can be separated by energy level and generate a rainbow of colors. The 

human eye is a sophisticated receiver of electromagnetic radiation in the form of light. Unlike a radio 

receiver that can only detect and interpret one frequency at a time, the human eye can detect all 

frequencies, or wavelengths, of visible light simultaneously. 

The human eye can distinguish a wide variety of colors and light intensities of objects. In order 

to distinguish an object from its background, there must be a contrast between the object and its 

background. The contrast necessary to distinguish an object from its background varies depending on 

color and texture, but generally, a 2% contrast is necessary in order to be detected by the human eye. 

 When sunlight hits a solid object, the surface absorbs some photons and reflect others. The 

wavelength of the light reflected defines the color that the human eye perceives. For example, the reason 

an apple looks red is that red photons are mostly reflected, and photons in the other color wavelengths are 

mostly absorbed. An egg looks white because the surface absorbs and reflects all of the color components 

of light at about the same level. 

Sunlight reflected from surfaces on the earth, or scattered by particles and gases in the air, 

interfere with the view that would be experienced under ideal conditions. Gases and very small particles 

preferentially scatter blue light in all directions. Large particles tend to scatter all colors of light (white 

light) in the forward direction. This causes a very strong white haze to appear to the eye when looking 

toward the sun, and much lighter haze when looking away from the sun. 
Chapter 4 – Technical Background - 24 - Arizona Regional Haze SIP

4.2. How Particulates and Gases Impair Visibility

As light photons travel through the air, they collide with molecules of gases and particles. This 

collision results in the light photons either being scattered or absorbed. When sunlight travels through 

clear air (i.e., with no particles), light photons corresponding with the higher energy level blue 

wavelengths of light are preferentially scattered, resulting in the human eye perceiving the sky as being 

blue, even though air is a colorless gas. Figure 4-1 shows how particles and gases interact with light. 

Figure 4-1. Interaction of Particles and Gases with Light. 

There is a limit to how far the eye can see. That limit is defined by the rate at which light is 

extinguished (scattered or absorbed) as it travels through the air. The light extinction coefficient defines 

the rate at which light is removed as it travels through the air. In clear air (i.e., with no particles in the 

air), that limit is approximately 350 kilometers and results from Rayleigh scattering caused by light 

encountering molecules of oxygen and nitrogen in clear air. This corresponds to a light extinction 

coefficient of approximately 10 inverse mega-meters (10 Mm-1). 

Particles in the air, which are also referred to as aerosols, also interfere with light as it travels, 

especially particles that are approximately the same size as the wavelength of light. As light travels, light 

photons will be scattered and absorbed by particles in the air. A higher concentration of particles in the 

air will result in a higher light extinction coefficient and more visibility impairment. 

Different types of particles have different effects on visibility. For visibility studies, 

concentrations of particles in the air are expressed in millionths of grams (micrograms) per cubic meter of 

air. Filters are used to collect the particles for laboratory analysis. The equipment used to collect the 
Chapter 4 – Technical Background - 25 - Arizona Regional Haze SIP

filters separate the particles by size. Some filters only collect fine particles that are smaller than 2.5 

microns in diameter, while others collect both fine particles and courser particles smaller than 10 microns 

in diameter. Light extinction efficiencies are used to convert the concentration of particles in the air into 

the impact on the light extinction coefficient. As was noted above, smaller particles are more efficient at 

scattering light than larger particles. 

4.3. Types of Particles and Gases Contributing to Visibility Impairment

There are two distinct categories of particles in the air: primary particulates that are directly 

emitted into the air, and secondary particulates that are formed by the chemical reaction of gases emitted 

into the air. Primary particulates include course soils, fine soils, elemental carbon (soot), and organic 

carbon. Secondary particulates include ammonium sulfate formed from gaseous sulfur dioxide, 

ammonium nitrate formed from gaseous oxides of nitrogen, and also organic carbon particles formed 

from volatile organic carbon gases. An additional factor that effects visibility is that ammonium sulfate 

and ammonium nitrate particles also can absorb moisture in the air causing the particles to grow, which 

increases light extinction. 

For regional haze visibility assessment studies, Table 4-1 summarizes the particles of interest, 

light extinction efficiencies, and the effect of relative humidity on the extinction efficiencies for 

ammonium sulfate and ammonium nitrate particles. 

Table 4-1. Light Extinction Efficiencies of Particles

Type of Particle Light Extinction Efficiency & Effect of Relative Humidity (RH) 

Relative Humidity 30% RH 60% RH 90% RH 

Humidity Dependent 

 Ammonium Sulfate 3.0 4.8 11.4 

 Ammonium Nitrate 3.0 4.8 11.4 

Humidity Independent 

 Organic Carbon 4.0 4.0 4.0 

 Elemental Carbon 10.0 10.0 10.0 

 Fine Soil 1.0 1.0 1.0 

 Coarse Soil 0.6 0.6 0.6 

Source: EPA Visibility Monitoring Guidance EPA-454/R-99-003. Humidity effects derived from Figure 

2-3. Light Extinction Efficiencies are expressed in units of square-meters per gram. 

The key concepts to understand from Table 4-1 are: 

• The extinction efficiency varies widely depending on the type of particle. For instance, 

elemental carbon, which not only scatters light but also absorbs light has 16.7 times the 

influence on visibility than coarse soil. 

• Relative humidity is important if ammonium sulfates or ammonium nitrates are present. 

At high relative humidity the extinction efficiency can be a factor of 4 higher than under 

low relative humidity. 

• Understanding of the composition of the particles present in the atmosphere is necessary 

to accurately characterize the impact on visibility. 
Chapter 4 – Technical Background - 26 - Arizona Regional Haze SIP

4.4. Sources of Particulates and Gases Contributing to Visibility 

Impairment on the Colorado Plateau

Sources of emissions that contribute to the particles in the atmosphere that cause visibility 

impairment fall into two broad classes: natural sources of emissions, and human-caused (or 

anthropogenic) sources of emissions. The GCVTC developed comprehensive emission inventories for 

areas contributing to visibility impairment at the 16 GCVTC Class I areas on the Colorado Plateau. 

Natural sources of emissions include a wide variety of pollutants that are emitted to the 

atmosphere. Wildfire emissions include primarily fine particulates (organic carbon, elemental carbon, 

and fine soils), course soils, oxides of nitrogen, and volatile organic compounds. Volcanic activity 

produces fine and course soils, and in many instances, sulfur dioxide. High winds can create emissions 

from natural undisturbed lands that contain primarily coarse and some fine soils. Achieving visibility 

conditions comparable to those that would be experienced with only natural sources is the long-term goal 

of the regional haze program. 

Human-caused sources of emissions also contribute to visibility impairment. Point sources (such 

as utility boilers, smelters, industrial boilers, and refineries) produce the majority of the sulfur dioxide in 

the GCVTC region, and about 25% of the oxides of nitrogen. Mobile sources (such as cars, trucks, offroad equipment, trains, and planes), produce the majority of the oxides of nitrogen in the GCVTC region 

and half of the human-caused volatile organic carbon emissions. In addition to direct emissions from 

mobile sources, road dust can be an important source of course and fine soil emissions. Prescribed fire on 

wildlands produce emissions similar to natural occurring wildfires. Finally, area sources (which make up 

all the other source types not discussed above) generate a broad range of emissions of all pollutants of 

interest for visibility and can be important especially in large population centers. States are required to 

develop long-term strategies to manage human-caused sources of visibility impairment to make 

reasonable progress toward the national goal of eliminating human-caused visibility impairment. 

4.5. Visibility Conditions on the Colorado Plateau

The Colorado Plateau generally has the best visibility conditions in the country. Unlike the 

eastern United States where ammonium sulfates are the most significant contributor to visibility 

impairment, there is no one type of particle that is the most significant contributor on the Colorado 

Plateau. The GCVTC found that particle based visibility impairment results equally from ammonium 

sulfates, the combination of organic carbon and elemental carbon, and the combination of coarse and fine 

soils. The GCVTC found that ammonium nitrate is a relatively small contributor to visibility impairment 

on the Colorado Plateau. On a day-to-day basis there can be one type of particle that has a more 

pronounced impact on visibility than others. However, all sources of these types of particles must be 

reviewed to develop an effective long-term strategy to make reasonable progress toward the national goal. 

4.6. State of Arizona Visibility Monitoring Plan and Network

The Arizona Department of Environmental Quality (ADEQ), local agencies, and federal land 

managers at Arizona’s 12 Class I areas are cooperatively operating a visibility monitoring network to 

track impairment of visual air quality. The Arizona Class I visibility network consists of visibility 

monitoring equipment provided by the Interagency Monitoring of PROtected Visual Environments 

(IMPROVE) monitoring program and additional equipment provided by ADEQ. The IMPROVE aerosol 

samplers collect particulate matter on filters (both PM2.5 and PM10 fractions) which are routinely analyzed 

for chemical constituents. ADEQ and the National Park Service (NPS) have added optical monitoring 

equipment to measure visibility impairment, and meteorological monitoring equipment at most sites. 
Chapter 4 – Technical Background - 27 - Arizona Regional Haze SIP

Arizona maintains a visibility monitoring operation plan. This visibility monitoring plan is 

updated when necessary to reflect updated IMPROVE and EPA guidance, and specific needs identified 

by ADEQ. ADEQ is an Associate Member of the IMPROVE Steering Committee and participates in the 

technical oversight of the IMPROVE network. 

The chemical constituent data from the IMPROVE samplers are used to identify the chemical 

species and emission sources responsible for existing human-caused visibility impairment. The optical 

data show the visual air quality at a point as a person might experience the view. Nephelometers measure 

light scattering by particles at points collocated with the IMPROVE samplers, and at four areas, 

transmissometers also provide optical data on total light extinction along a path. Meteorological data are 

collected to provide a more complete understanding of the behavior of the atmosphere in general, as well 

as clarifying local air movement. These data are collectively used to track short-term and long-term 

trends, assess source contributions to visibility impairment that are reasonably attributable to a single 

source or group of sources, and determine the causes of regional visibility impairment at a given location. 

The intent of this visibility monitoring operational plan is to characterize long-term trends in all 

Arizona Class I areas as completely as possible using ambient visibility measurements, within constraints 

of an area’s size, terrain, or logistics, for each of the 12 federally-protected Class I areas in Arizona. In 

practical terms, one monitoring site or a group of sites may represent several Class I areas, or multiple 

locations of the same or different types of sites may represent an individual Class I area. This monitoring 

plan is designed to meet the following requirements of 40 CFR 51.305 and 40 CFR 51.308(d)(4): 1) to 

have a long-term monitoring strategy; 2) to track visibility trends at Arizona Class I areas; 3) to assist in 

identifying any attributable visibility impairment; and 4) to provide monitoring data, if necessary, for 

evaluating the impact of new or major modifications of categorical major sources. Arizona’s monitoring 

program began in the spring of 1996, and the monitoring plan was updated in 2002. In addition to the 

state-sponsored IMPROVE monitoring, the National Park Service has maintained IMPROVE monitors 

(transmissometer and particle samplers) in Petrified Forest and Grand Canyon national parks since 1987, 

providing a long baseline of visibility measurements. 

Pursuant to 40 CFR 51.305 and 40 CFR 51.308(d)(4), the State of Arizona maintains a 

monitoring plan to address visibility impairment. The State of Arizona relies on the IMPROVE program 

for data collection and processing and commits to the reporting of all visibility monitoring data to the 

Administrator at least annually for each Class I area in the State. 
Chapter 4 – Technical Background - 28 - Arizona Regional Haze SIP

(This page intentionally blank) 
Chapter 5 – Attributable Impairment - 29 - Arizona Regional Haze SIP

5. STRATEGY TO ADDRESS REASONABLY ATTRIBUTABLE 

VISIBILITY IMPAIRMENT (RAVI)

Section 169A of the CAA contains the national goal that requires states to remedy existing 

visibility impairment and prevent future visibility impairment in the Class I areas. Initially, states 

containing mandatory Class I Federal areas were required to address the specific type of air pollution 

coming from existing stationary sources that could be anticipated to cause or contribute to visibility 

impairment. This type of pollution was commonly referred to as “plume blight,” or more formally, 

reasonably attributable visibility impairment (RAVI). On December 2, 1980, the EPA determined that 

there were two types of air pollution that reduced or impaired visibility (45 FR 80084). One type was 

described as “smoke, dust, colored gas plumes, or layered haze emitted from stacks,” and the second type 

was “widespread, regionally homogeneous haze from a multitude of sources” (Ibid, p. 80085). 

The existing stationary sources subject to this regulation include any reconstructed source that 

was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the 

potential to emit 250 tons per year of any regulated pollutant. “In existence” is interpreted by the EPA to 

be consistent with the term, “commence construction” found in Prevention of Serious Deterioration (PSD) 

regulations (40 CFR 51.165(a)(1)(xvi) and 40 CFR 52.21(b)(9)). If construction commenced after 

August 7, 1977, the source would be subject to the PSD/NSR (new source review) program. 

The SIPs developed to address visibility impairment from sources that could be reasonably 

anticipated to cause or contribute to visibility impairment in Class I areas had to include four specific 

things: (1) a monitoring plan to assist in the determination of what type of emissions were actually 

occurring in and near the Class I Area; (2) a way to determine what type of technological controls (best 

available retrofit technology or BART) could be used at a source should that source be found to cause or 

contribute – be found attributable – for the air pollution; (3) a process for addressing possible visibility 

impairment from new sources through existing New Source Review regulations, including review of that 

process by the FLMs; and (4) long-term strategies for dealing with existing and any future visibility 

impairment from stationary sources. 

SIPs for 36 states were due to EPA by December 2, 1980. Unable to comply by the deadline, 

Arizona along with several other states, was cited on July 12, 1985, as failing to meet the requirements of 

40 CFR 51.305, monitoring, and 51.307, new source review (50 FR 28545). On November 24, 1987, 

Arizona was cited as failing to meet the requirements of 40 CFR 51.306, long-term strategies, and 51.302, 

control strategies (i.e., BART).13 Failure to meet the requirements in 40 CFR 51.302, 305, 306, and 307 

through a SIP meant EPA imposed a Federal Implementation Plan or FIP (52 FR 45134, November 24, 

1987). Included in the 1987 FIP was FLM certification of three Class I areas in Arizona for visibility 

impairment: Grand Canyon National Park, Petrified Forest National Park, and Saguaro Wilderness. 

 

On September 15, 1988, EPA published its assessment of the Class I areas certified by the FLMs 

that included an assessment of the three Arizona areas named in 1987 (53 FR 35956). By 1991, EPA 

published a final rule that revised Arizona’s FIP to reflect an analysis of the visibility impairment at 

Grand Canyon National Park for an attributable stationary source, Navajo Generating Station (56 FR 

50172). 

For the purpose of addressing the process the State of Arizona could use in the event of future 

certifications, a State rule has been promulgated for reasonably attributable visibility impairment. That 

 

13 Arizona was not cited for failure to meeting 51.304, integral vistas, as no integral vistas have been listed in 

Arizona. Integral vistas are areas outside the boundary of a Class I Area, but visible from within it. 
Chapter 5 – Attributable Impairment - 30 - Arizona Regional Haze SIP

rule, effective December 2, 2003, can be found in Appendix A-5a. The following sections discuss how 

Arizona is now meeting the requirements of 40 CFR 51.302 through 307, which should allow EPA to 

remove the existing FIP. 

5.1. Implementation of Control Strategies

Pursuant to 40 CFR 51.302, states must have a procedure in place to analyze and, if necessary, 

implement control strategies for RAVI, and imposition of best available retrofit technology (BART) for 

any eligible source whose emissions are found to cause or contribute to visibility impairment. Arizona’s 

RAVI rule can be found in Appendix A-5a; a list of the BART-eligible sources is listed in Section 1601 

of the rule. Arizona’s RAVI rule also serves as the authority for the possible implementation of controls 

under “geographical enhancement” for any stationary source found to impair visibility via the WEB 

Trading Program as outlined in Chapter 8 of this SIP. 

 40 CFR 51.302 also requires the state to communicate with the FLMs and provide for 

consultation on any matters pertaining to visibility impairment. A letter notifying the FLMS of the State 

of Arizona’s visibility contact person, as well as the opportunity to review this SIP prior to any public 

hearings, can be found in Appendix A-5b. A subsequent letter notifying the FLMs of the public comment 

period, and locations and dates of public hearings for this SIP can also be found in Appendix A-5b. All 

supporting documents related to the promulgation of Arizona’s RAVI rule can also be found in Appendix 

A-5c. 

5.2. Exemptions from Controls

Pursuant to 40 CFR 51.303, any source found attributable for visibility impairment and required 

to install and operate BART, may request a federal exemption from BART. This federal exemption 

process is incorporated by reference in R18-2-1606 of Arizona’s RAVI rule. At this time, no source in 

the State of Arizona has requested a federal exemption from BART. 

5.3. Identification of Integral Vistas

Pursuant to 40 CFR 51.304, any identified integral vista must be addressed on an equivalent basis 

as for any Class I Area. An integral vista is a specific landmark or panorama located outside the 

boundary of a mandatory Federal Class I Area, but visible from that Class I Area. Therefore, any 

impairment within the Class I Area could possibly impact the integral vista as well. No integral vistas 

have been identified to date for the State of Arizona’s 12 mandatory Class I Federal areas (52 FR 45132, 

November 24, 1987). 

5.4. Monitoring

Pursuant to 40 CFR 51.305, the State of Arizona has developed a monitoring plan for the 12 

Class I areas. The plan, Arizona Class I Area Visibility Monitoring Operational Plan (Monitoring Plan), 

published in 1996 and updated in 2002, includes a commitment to, “characterize long-term trends in all 

Arizona Class I areas as completely as possible using ambient visibility measurements, within constraints 

of an area’s size, terrain, or logistics, for each of the 12 Class I areas in Arizona” (p. 3 Monitoring Plan). 

Arizona’s Monitoring Plan was developed with the full cooperation of the FLMs, other related 

agencies and counties as well as air quality specialists in the field of monitoring, data gathering and 

assessment, and meteorology. The Monitoring Plan is reviewed annually and contains four objectives 

that also serve to meeting the needs of any visibility regulations promulgated by the State of Arizona to 

meet RAVI. The objectives are: (1) long-term monitoring strategy, (2) track visibility trends at Arizona 
Chapter 5 – Attributable Impairment - 31 - Arizona Regional Haze SIP

Class I areas, (3) assist in identifying any reasonably attributable visibility impairment impacts, and (4) 

provide monitoring data if necessary for new or major modifications of categorical major sources. 

Along with providing a network of visibility monitors, the Monitoring Plan also accounts for the 

long-standing IMPROVE monitoring program and integration with EPA’s PM 2.5 monitoring guidance. 

IMPROVE was established in 1985 to coordinate the monitoring of national parks and wilderness areas 

and to ensure sound and consistent scientific methods were being employed. The IMPROVE Steering 

Committee established monitoring protocols for visibility measurement, particulate matter measurement, 

and scientific photography of the Class I areas. IMPROVE monitoring is designed to established 

reference information on visibility conditions and trends to aid in the development of visibility protection 

programs. 

5.5. Long-term Strategy Requirements

Pursuant to 40 CFR 51.306, a long-term strategy for RAVI must be established in the SIP. This 

strategy must cover a 10-15 year period. Arizona’s submittal under 40 CFR 51.309 fulfills the long-term 

strategy requirements for RAVI for stationary sources. Should any source be found attributable for 

visibility impairment and subsequently required to install and operate BART, the State of Arizona 

commits to submitting a SIP revision (as required by R18-2-1605(B)), meeting the review requirements 

for the long-term strategies as outlined in 51.306(e), including any impact resulting from the imposition 

of controls or exemption from controls for BART. 

5.6. New Source Review for Visibility Protection

Pursuant to 51.307, the State of Arizona’s R18-2-410 (Article 4, New Source Review, Arizona 

Administrative Code) addresses the requirements of new sources to meet performance standards to assure 

emissions will not have an impact on visibility in Arizona’s 12 Class I areas. The rule can be found in 

Appendix A-5d. 

 On September 1, 1994, EPA deemed the State of Arizona SIP revision for New Source Review 

(NSR) / Prevention of Significant Deterioration (PSD) and minor NSR source programs complete and is 

awaiting further EPA action. 
Chapter 5 – Attributable Impairment - 32 - Arizona Regional Haze SIP

(This page intentionally blank) 
Chapter 6 – Clean Air Corridor - 33 - Arizona Regional Haze SIP

6. LONG-TERM STRATEGY FOR THE CLEAN AIR 

CORRIDOR

6.1. Regulatory History and Requirements

One of the requirements of the Regional Haze Rule (40 CFR 51.309(d)(3)) is to finalize earlier 

work initiated by the GCVTC to address clean-air corridors. One of the tasks of the GCVTC required by 

CAA 169B was to determine whether any clean-air corridors exist for any of the 16 GCVTC Class I 

areas. A clean-air corridor is a geographic region that contributes clean air to a Class I area on the days 

with best visibility. If clean-air corridor(s) were found to exist, the GCVTC was required to recommend 

whether additional control strategies were needed to manage emissions growth to protect visibility on the 

least impaired days in the Class I areas. For the purpose of its assessment, the GCVTC considered the 

average of the days representing the 20% best visibility conditions to be the least impaired days. EPA 

also used this definition in defining the term in the 1999 Regional Haze Rule (40 CFR 51.308 and 40 

CFR 51.309). 

In 1995, the GCVTC Meteorology Subcommittee completed an analysis of the geographical 

source areas contributing to least impaired days in the 16 GCVTC Class I areas. The analysis, in a report 

entitled, Clean-Air Corridors: A Framework for Identifying Regions that Influence Clean Air on the 

Colorado Plateau,

14 showed that the area north and west of the Grand Canyon National Park does provide 

clean air to the Grand Canyon area primarily due to a combination of favorable meteorological conditions 

and low emissions of pollutants from the sparsely populated area. The GCVTC Public Advisory 

Committee (PAC) reviewed the clean-air corridor analysis and emission projections and determined 

expected emissions growth was less than the amount that would degrade visibility on the least impaired 

days in the 16 Class I areas. Based on this finding, the PAC recommended emissions growth be 

monitored in the future but that no additional control strategies were needed in the identified clean-air 

corridor at that time. The GCVTC adopted this recommendation and included it in its final report to 

EPA, which was integrated into the regional haze rule (40 CFR 51.309(d)(3)). 

The Regional Haze Rule requires states submitting SIPs under 40 CFR 51.309 to determine if 

there were additional areas(s) to be considered as clean-air corridors for emission tracking purposes in the 

GCVTC areas. The successor to the GCVTC, the Western Regional Air Partnership (WRAP), completed 

an economic/technical analysis to validate the growth projections in the clean air corridors. This analysis 

was included as part of a consensus policy adopted by the WRAP Board in November, 2002. A copy of 

this policy, WRAP Policy on Clean Air Corridors, is contained in Appendix A-6a. The WRAP policy 

defined a clean air corridor consistent with the range of optional clean air corridor definitions identified 

by the GCVTC Meteorology Subcommittee. The final clean air corridor included a recognition of 

county-level emissions inventory practices, and an emissions tracking requirement in the clean air 

corridor. The technical studies and findings used as the basis for the WRAP Clean-Air Corridor Policy 

are located in Chapter 3 of the WRAP Technical Support Document. 

The most recent projections of visibility conditions at the 16 GCVTC Class I areas performed by 

WRAP is discussed in Chapter 14. 

 

14 Clean Air Corridors: Framework for Identifying Regions that Influence Clean Air on the Colorado 

Plateau, Meteorology Subcommittee of the Grand Canyon Visibility Transport Commission; Western Governors' 

Association: Denver, CO, July 1995. 
Chapter 6 – Clean Air Corridor - 34 - Arizona Regional Haze SIP

6.2. Identification of Clean Air Corridor; Other Clean Air Corridors

Pursuant to 40 CFR 51.309(d)(3)(i), the State of Arizona concurs that there is an existing cleanair corridor as defined in the WRAP Policy on Clean-Air Corridors. The boundary of the clean-air 

corridor is indicated on the map in Figure 6-1 provided below. No portion of Arizona is inside the 

clean-air corridor. 

Figure 6-1. Map of the Clean Air Corridor in the Transport Region 

This Clean Air Corridor was identified using studies conducted by the Meteorological 

Subcommittee of the Grand Canyon Visibility Transport Commission, and then updated by the WRAP 

based on an assessment described in the WRAP Policy on Clean-Air Corridors, and related technical 

analysis conducted by the WRAP. 

The State of Arizona, pursuant to 40 CFR 51.309(d)(3)(v), has determined, based on the WRAP 

Policy on Clean-Air Corridors and technical analysis, that no other clean-air corridors are identified at 

this time. The State of Arizona commits to participating in a regional effort to review this determination 

as part of periodic plan revisions required under 40 CFR 51.309(d)(10). 
Chapter 6 – Clean Air Corridor - 35 - Arizona Regional Haze SIP

6.3. Strategy for Clean Air Corridors

(a) Comprehensive emissions tracking program. Pursuant to 40 CFR 51.309(d)(3), a 

comprehensive emissions tracking system has been established to track emissions inside and outside the 

clean-air corridor, as specified in (b) below, to ensure that visibility is not degraded on the least-impaired 

days in any of the 16 Class I areas of the Colorado Plateau. This comprehensive emissions tracking 

system was developed by the WRAP to assist the above states in meeting this requirement. Appendix A6b of this SIP describes the WRAP comprehensive emissions tracking system, and the process by which 

the WRAP will summarize annual emission trends in order to identify any significant emissions growth 

that could lead to visibility degradation in the 16 Class I areas. Included in this summary will be an 

assessment of whether any significant emissions growth has occurred within the Clean Air Corridor, in 

accordance with (c) below. The State of Arizona will work cooperatively with states not submitting a 

plan revision under 40 CFR 51.309 that have emissions within or outside the clean-air corridor that could 

affect air quality in the clean-air corridor, to assure the emissions are incorporated into the tracking 

program through inter-state consultation. 

(b) Patterns of growth within the clean-air corridor. Pursuant to 40 CFR 51.309(d)(3)(ii), the 

State of Arizona has determined, based on the WRAP Policy on Clean-Air Corridors and WRAP technical 

analysis, that current projections of emissions changes inside the identified clean-air corridor will not 

contribute to degradation of visibility on the least impaired days in the 16 Class I areas during the 

planning period through 2018. Future emissions growth will be tracked in accordance with the 

comprehensive emissions tracking system noted in (a) above. The WRAP will summarize annual 

emission trends within the clean-air corridor and assess whether any significant emission growth has 

occurred within the corridor as an analysis tool for states. 

(c) Patterns of growth outside the Clean Air Corridor. Pursuant to 40 CFR 51.309(d)(3)(iii), the 

State of Arizona has determined, based on the WRAP Policy on Clean-Air Corridors and technical 

analysis conducted by the WRAP, that outside the Clean Air Corridor identified in Section 6.2, above, 

there is no emissions growth occurring at this time that is contributing to visibility impairment within the 

Clean Air Corridor in any of the 16 Class I areas of the Colorado Plateau As part of the WRAP’s annual 

summary of emission trends within the corridor, an assessment will be made of emission and monitoring 

data trends outside the Clean Air Corridor, in order to determine if significant emissions growth is 

occurring outside the corridor that could be impairing air quality within the corridor, and resulting in 

visibility impairment in the 16 Class I areas. 

(d) Actions if impairment inside or outside the Clean Air Corridor occurs. The State of Arizona, 

in coordination with other transport region states and tribes, will review the WRAP’s annual summary of 

emission trends within the Clear Air Corridor and whether any significant emissions growth was 

identified within the corridor in accordance with (b) above, or was identified outside the corridor, in 

accordance with (c) above. If significant emissions growth is identified, the State of Arizona in 

coordination with other transport region states and tribes, will conduct or seek WRAP assistance in 

conducting an analysis of the effects of this emissions growth in terms of possible impact on air quality 

within the corridor and possible degradation of the least-impaired days in any of the 16 Class I areas of 

the Colorado Plateau. Pursuant to 40 CFR 51.309(d)(3)(iv), if this analysis finds that this growth is 

causing visibility impairment in the 16 Class I areas, the State of Arizona in coordination with other 

transport states and tribes will evaluate the need for additional emission reduction measures, and identify 

an implementation schedule for such measures, if needed. The implementation of any additional emission 

measures shall be coordinated with all appropriate transport region states and tribes, on a mutually agreed 

upon timetable, and reported to EPA in accordance with the periodic progress reports required under 40 

CFR 51.309(d)(10)(i). If the WRAP regional planning process is unable to perform such an analysis for 
Chapter 6 – Clean Air Corridor - 36 - Arizona Regional Haze SIP

the GCVTC Class I areas in Arizona, or come to a consensus on the interpretation of such an analysis, the 

State of Arizona will perform such studies and engage in independent interstate consultation provided for 

under 40 CFR 51.309(d)(11). 
Chapter 7 – Stationary Sources - 37 - Arizona Regional Haze SIP

7. LONG-TERM STRATEGY FOR STATIONARY SOURCES

7.1. Regulatory History and Requirements

The Grand Canyon Visibility Transport Commission (GCVTC) studied the long-term projected 

changes of emissions from stationary sources. It was found that emissions of sulfur dioxide from 

stationary sources would decline by at least 13% between 1990 and 2000. Also, emissions of sulfur 

dioxide would continue to decline through 2040 when only 30% to 50% of the 1990 emission levels 

would remain. This decline was due to the normal turnover of source technology as older sources retire 

and are replaced by newer and cleaner technologies. 

The GCVTC decided that the most effective way to address emissions of sulfur dioxide from 

stationary sources was to establish regional emission milestones and provide for a backstop program to 

achieve necessary emission reductions. If the emission reduction milestones are not achieved, then a 

backstop market trading program will be implemented. 

In Section 309(d)(4)(ii-iv) of the Regional Haze Rule, EPA required the states to complete the 

development of a backstop market trading program for sulfur dioxide. The WRAP submitted the Annex 

to EPA in October 2000.15 On June 5, 2003, EPA approved the program (68 FR 33764). Chapter 8 of 

this SIP contains the regional Sulfur Dioxide Milestones and Backstop Trading Program as required 

under Section 309(h) of the June 5, 2003, revised Regional Haze Rule. To keep the actual program as 

detailed in Chapter 8 intact, what follows here is a summary of the major elements of the program. 

 

• Regional milestones, SO2 emissions tracking requirements, and methodology the State of Arizona 

would use to determine allocations and manage the allowance tracking system should the 

program be “triggered” by the violation of any of the milestones as shown in Figure 7-1. 

Figure 7-1. Regional Sulfur Dioxide Emission Milestones 

510

655

720 715 723

831

625

677 6 82

480

0

10 0

20 0

30 0

40 0

50 0

60 0

70 0

80 0

90 0

1990 2000 2010 2020 2030 2040

GCVTC Region Total Annual SO2 of Tons (000)

w/ S me lt er S et -a s id e w/ o S m elt e rs

52% R e duction

13% R e duction

S O 2 M ilestones

 

15 Western Regional Air Partnership. Voluntary Emissions Reduction Program for Major Industrial Sources of 

Sulfur Dioxide in Nine Western States and a Backstop Market Trading Program, An Annex to the Report of the 

Grand Canyon Visibility Transport Commission. Denver, CO. September 29, 2000. 
Chapter 7 – Stationary Sources - 38 - Arizona Regional Haze SIP

• Description of the regulatory authority for the SO2 Milestones and Backstop Trading Program. 

The Western Backstop SO2 Trading Program Rule establishes the procedures and compliance 

requirements for the participating states, tribes, and affected sources. Appendix A-7a contains the 

State of Arizona’s draft rule based on the Western Backstop SO2 Trading Program Model Rule. 

This draft rule also contains requirements for participating sources under the pre-trigger portion 

of the program found in Section 8.2.1 of the SO2 Milestones and Backstop Trading Program. The 

State of Arizona commits to the promulgation of a State rule for the Western Backstop SO2

Trading Program as expeditiously as practicable. 

• Authority to require major industrial sources of SO2 to submit an annual emissions inventory in 

the pre-trigger phase of the program to measure compliance with the regional SO2 milestones. 

The authority for Arizona to require sources to meet this requirement of Section 8.2.1 of the SO2

Milestones and Backstop Trading Program is contained in the draft rule in Appendix A-7a. 

Again, the State of Arizona commits to the promulgation of a State rule for the Western Backstop 

SO2 Trading Program as expeditiously as practicable. 

• Establishment of a WRAP standing committee to develop the coordination procedures for the 

program. This “309 Coordinating Committee” will be formally proposed at the WRAP Board 

Meeting to be held in October 2003. Appendix A-7b contains the proposal approved by the 

WRAP Board on October 15, 2003 for the establishment of the WRAP 309 Coordinating 

Committee. 

7.2. Monitoring and Reporting of Stationary Source Sulfur Dioxide 

Emissions.

Achievement of Greater Than a 13% Reduction in Sulfur Dioxide by 2000. One item that must be 

included in the first SIP under Section 309(d)(4)(i) is monitoring and reporting of stationary source sulfur 

dioxide (SO2) emissions. This monitoring and reporting data must be sufficient to determine whether a 

13 % reduction in actual stationary source SO2 emissions has occurred between the years 1990 and 2000, 

and whether milestones required by Section 51.309(d)(4)(ii) have been achieved for the transport region. 

As shown in Table 7-1, regional SO2 emission totals show that there has been a 25 percent reduction in 

these emissions from 1990 to 2000.16 Details of the source of emission inventories used for this 

calculation are in the Chapter 4 of the WRAP TSD. 

Table 7-1. State-by-State Comparison of 1990 and 2000 Stationary Source Sulfur Dioxide 

Emissions in the 9 GCVTC Transport Region States (tons per year)

7.3. 

 

16 Year 2000 Point Source SO2 Emissions Analysis - 9 State Western Region Report, E.H. Pechan & Associates, 

Inc. for the Western Governors’ Association; Denver, CO, May 2002.

States 1990 2000

Arizona 185,398 99,133

California 52,832 38,501

Colorado 95,534 99,161

Idaho 24,652 27,763

Nevada 52,775 53,943

New Mexico 177,994 117,344

Oregon 17,705 23,362

Utah 85,567 38,521

Wyoming 136,318 124,110

Totals 828,775 621,838
Chapter 7 – Stationary Sources - 39 - Arizona Regional Haze SIP

Report on Assessment of NOx/PM Strategies

Provisions for Stationary Source NOX and PM. Pursuant to 40 CFR 51.309(d)(4)(v), the State of 

Arizona has included in this SIP a report which assesses emissions control strategies for stationary 

sources of NOx and PM, and the degree of visibility improvement that would result from implementation 

of the identified strategies. The report, Stationary Source NOx and PM Emissions in the WRAP Region: 

An Initial Assessment of Emissions, Controls, and Air Quality Impacts, was prepared by the WRAP and is 

included in Appendix A-7c. The report represents the State of Arizona’s initial assessment of stationary 

source NOx and PM strategies for regional haze. The State of Arizona has determined that NOx and PM 

strategies are not needed at this time. The State of Arizona commits to adopting long-term strategies and 

Best Available Retrofit Technology (BART) requirements for stationary sources of NOx and PM as a SIP 

revision in 2008 if Arizona determines such emission control strategies are needed to demonstrate 

reasonable progress. 
Chapter 7 – Stationary Sources - 40 - Arizona Regional Haze SIP

(This page intentionally blank)
Chapter 8 – SO2 Milestones/Backstop - 41 - Arizona Regional Haze SIP

8. SO 2 MILESTONES AND BACKSTOP TRADING PROGRAM

8.1. Milestones and Determination of Program Trigger

8.1.1. Regional SO2 Milestones

(1) Base Milestone Values. The regional sulfur dioxide base milestones for the years 2003 

through 2018 are provided in Table 8-1. The base milestones will be adjusted annually as described in 

paragraphs 8.1.1(2), (3) and (4) of this plan.

Table 8-1. Base Sulfur Dioxide Emissions Milestones (excludes Smelter Set-aside)

Column 1 Column 2 Column 3 

For the year the base regional sulfur 

dioxide milestone is 

and the annual SO2 emissions for these years will 

determine whether emissions are greater than or less 

than the milestone 

2003 682,000 tons SO2 2003 

2004 682,000 tons SO2 Average of 2003 and 2004 

2005 682,000 tons SO2 Average of 2003, 2004 and 2005 

2006 682,000 tons SO2 Average of 2004, 2005 and 2006 

2007 682,000 tons SO2 Average of 2005, 2006 and 2007 

2008 680,333 tons SO2 Average of 2006, 2007 and 2008 

2009 678,667 tons SO2 Average of 2007, 2008 and 2009 

2010 677,000 tons SO2 Average of 2008, 2009 and 2010 

2011 677,000 tons SO2 Average of 2009, 2010 and 2011 

2012 677,000 tons SO2 Average of 2010, 2011 and 2012 

2013 659,667 tons SO2 Average of 2011, 2012 and 2013 

2014 642,333 tons SO2 Average of 2012, 2013 and 2014 

2015 625,000 tons SO2 Average of 2013, 2014 and 2015 

2016 625,000 tons SO2 Average of 2014, 2015 and 2016 

2017 625,000 tons SO2 Average of 2015, 2016 and 2017 

2018 480,000 tons SO2 Year 2018 only 

2019 forward, 

until replaced by 

an approved SIP 

480,000 tons SO2 Annual; no multiyear averaging 

(2) Adjustments for participation by eligible States and Tribes. The amount provided in 

Table 8-2 below will be subtracted from the milestone in Table 3 for each state and tribe that does not 

have an Implementation Plan approved by the EPA Administrator as meeting the requirements of 40 CFR 

51.309 as of December 31 of the year following the milestone year. The first adjustment to the 2003 

milestone will be made no later than March 31, 2005, and will be based on all states and tribes that do not 

have a federally-approved Implementation Plan as of December 31, 2004. 
Chapter 8 – SO2 Milestones/Backstop - 42 - Arizona Regional Haze SIP

Table 8-2a. (Years 2003-2010) Amounts of SO2 Tons To Be Subtracted from the Base Milestones for 

States and Tribes That Do Not Have an Approved Implementation Plan under 40 CFR 51.309*

State or Tribe 2003 2004 2005 2006 2007 2008 2009 2010 

1. Arizona 117,372 117,372 117,372 117,372 117,372 117,941 118,511 119,080 

2. California 37,343 37,343 37,343 37,343 37,343 36,363 35,382 34,402 

3. Colorado 98,897 98,897 98,897 98,897 98,897 98,443 97,991 97,537 

4. Idaho 18,016 18,016 18,016 18,016 18,016 17,482 16,948 16,414 

5. Nevada 20,187 20,187 20,187 20,187 20,187 20,282 20,379 20,474 

6. New Mexico 84,624 84,624 84,624 84,624 84,624 84,143 83,663 83,182 

7. Oregon 26,268 26,268 26,268 26,268 26,268 26,284 26,300 26,316 

8. Arizona 42,782 42,782 42,782 42,782 42,782 42,795 42,806 42,819 

9. Wyoming 155,858 155,858 155,858 155,858 155,858 155,851 155,843 155,836 

10. Navajo Nation 53,147 53,147 53,147 53,147 53,147 53,240 53,334 53,427 

11. ShoshoneBannock Tribe of 

the Fort Hall 

Reservation 

4,994 4,994 4,994 4,994 4,994 4,994 4,994 4,994 

12. Ute Indian 

Tribe of the 

Uintah and Ouray 

Reservation 

1,129 1,129 1,129 1,129 1,129 1,129 1,129 1,129 

13. Wind River 

Reservation 

1,384 1,384 1,384 1,384 1,384 1,384 1,384 1,384 

*These numbers differ from Annex opt-in/-out tables in that the smelter set-aside is excluded and the new source 

set-aside is included. 

Table 8-2b. (Years 2011-2018) Amounts of SO2 tons to be Subtracted from the Base Milestones for 

States and Tribes that do not have an Approved Implementation Plan under 40 CFR 51.309* 

State or Tribe 2011 2012 2013 2014 2015 2016 2017 2018 

1. Arizona 119,080 119,080 116,053 113,025 109,998 109,998 109,998 82,302 

2. California 34,402 34,402 33,265 32,128 30,991 30,991 30,991 27,491 

3. Colorado 97,537 97,537 94,456 91,375 88,294 88,294 88,294 57,675 

4. Idaho 16,414 16,414 15,805 15,197 14,588 14,588 14,588 13,227 

5. Nevada 20,474 20,474 20,466 20,457 20,449 20,449 20,449 20,232 

6. New Mexico 83,182 83,182 81,682 80,182 78,682 78,682 78,682 70,000 

7. Oregon 26,316 26,316 24,796 23,277 21,757 21,757 21,757 8,281 

8. Utah 42,819 42,819 41,692 40,563 39,436 39,436 39,436 30,746 

9. Wyoming 155,836 155,836 151,232 146,629 142,025 142,025 142,025 97,758 

10. Navajo Nation 53,427 53,427 52,707 51,986 51,266 51,266 51,266 44,772 

11. Shoshone-Bannock 

Tribe of the Fort Hall 

Reservation 

4,994 4,994 4,994 4,994 4,994 4,994 4,994 4,994 

12. Ute Indian Tribe of 

the Uintah and Ouray 

Reservation 

1,135 1,135 1,135 1,135 1,135 1,135 1,135 1,135 

13. Wind River 

Reservation 

1,384 1,384 1,384 1,384 1,384 1,384 1,384 1,384 

*These numbers differ from Annex opt-in/-out tables in that the smelter set-aside is excluded and the new 

source set-aside is included.

(3) Adjustment for Future Operation of Copper Smelters in Arizona and New Mexico. If either 

the BHP San Manuel smelter in Arizona or the Phelps Dodge Hidalgo smelter in New Mexico resumes 
Chapter 8 – SO2 Milestones/Backstop - 43 - Arizona Regional Haze SIP

operation, the milestones will be increased as described below. The adjustment will occur only if the 

respective state has a State Implementation Plan approved by the EPA Administrator under 40 CFR 

51.309. Once the adjustments have been made, the milestones will not be changed due to future 

suspensions or changes in plant operations, except as provided below. If Arizona or New Mexico elect 

not to submit a SIP under 40 CFR 51.309, the emissions for the smelters in the state opting out will be 

subtracted from the smelter set-aside. 

(a) If one or both smelters resume operations under their existing permits, the milestone will be 

adjusted upward for each smelter respectively by the following amounts: 

1. Phelps Dodge Corporation, Hidalgo Smelter: 22,000 tons SO2 

2. BHP, San Manuel Smelter: 16,000 tons SO2

3. For the 2013 through 2018 milestones, the maximum increase will be 30,000 tons SO2. 

(b) If Arizona or New Mexico determines that either smelter will resume operation by operating 

only a portion of the plant, the milestone adjustment in (a) will be reduced by a percentage to 

reflect current conditions. If the smelter resumes normal operations at a later date, the full 

adjustment described in (a) will be applied. 

(c) If one or both smelters resume operations after going through new source review, the 

milestone adjustment will be based on the new permitted level for the source, but in no instance 

may the adjustment to the milestones exceed 22,000 tons SO2 per year for the Hidalgo Smelter or 

16,000 tons SO2 per year for the San Manuel Smelter. 

(d) If one or both smelters do not resume operation, the State of Arizona will determine, based on 

the calculation procedures in section 8.1.3(4) of this plan, the amount of source-specific set aside 

that will be added to the milestone to account for capacity expansion at the remaining smelters. 

This set-aside will only be available for use if sulfur input and emissions from the copper smelters 

are above the baseline level listed in Table 8-3 in any particular year as a result of increased 

capacity. The increase to the milestone will be based on a smelter’s proportional increase above 

its baseline sulfur input. The set-aside will be recalculated every year to reflect actual operations 

of the remaining copper smelters. The set-aside may not be traded under the backstop trading 

program. 

Table 8-3. Preliminary Smelter-Specific Set Aside 

Company/Smelter Baseline 

Sulfur Input 

Baseline 

Allocation 

Smelter-specific Set-aside 

BHP San Manuel 417,200 tons 16,000 tons SO2 1,500 tons SO2

Asarco Hayden 235,000 tons 23,000 tons SO2 3,000 tons SO2

Phelps Dodge Chino 212,800 tons 16,000 tons SO2 3,000 tons SO2

Phelps Dodge Hidalgo 256,800 tons 22,000 tons SO2 4,000 tons SO2

Phelps Dodge Miami 208,700 tons 8,000 tons SO2 2.000 tons SO2

Kennecott Copper 

Corporation, Smelter and 

Refinery 

340,269 tons 1,000 tons SO2 100 tons SO2

TOTAL 1,670,769 tons 86,000 tons SO2 13,600 tons SO2

 (4) Other Milestone Adjustments. 

(a) All other milestone adjustments will require a SIP revision. Section 8.1.3(3) of this plan 

outlines adjustments to be made to the emissions inventory to ensure a consistent comparison to 
Chapter 8 – SO2 Milestones/Backstop - 44 - Arizona Regional Haze SIP

the milestones. These adjustments will be incorporated into the milestones every five years as 

part of the periodic SIP revisions required by 40 CFR 51.309(d)(10). Adjustments to the 

milestones shall be tracked in the annual emissions report in section 8.1.3(3) of this plan. 

(b) Within ninety days of the periodic SIP revision incorporating adjustments based on section 

8.1.3(3) of this plan, the State of Arizona shall provide notice to sources whose records were used 

to calculate the adjustments, including the date of the SIP revision reflecting the milestone 

adjustment to sources whose records were used as the basis for the milestone adjustment and a 

statement that the source needs to retain the record for at least five years from the date of the SIP 

revision, or ten years from the date of establishing the record, whichever is longer. 

8.1.2. Regional Program Administration

(1) Pre-trigger tracking of regional SO2 emissions. The State of Arizona will work cooperatively 

with the states and tribes that are participating in the SO2 Milestones and Backstop Trading Program to 

ensure that an emission tracking system for the regional SO2 inventory is developed and maintained. The 

State of Arizona is responsible for all regional program administration functions as described in this plan. 

The State of Arizona will perform these functions using the Western Regional Air Partnership (WRAP) as 

the State of Arizona’s agent. The WRAP compiled the SO2 emission inventories that were used during the 

development of the Annex, and the WRAP continues to refine and improve the overall tracking system 

for the regional haze. The WRAP will maintain the outlined pre-trigger emissions tracking functions in 

the foreseeable future. If the WRAP is no longer able to fulfill this function, then the State of Arizona 

will ensure that other arrangements are made, either through a different regional organization or through a 

contractor, to maintain the SO2 tracking system that is described in this plan. The WRAP has no authority 

to make regulatory determinations. The WRAP has limited authority under this plan to perform tracking 

and accounting functions, prepare reports, and perform other administrative functions as directed by the 

State of Arizona. The State of Arizona will work expeditiously to correct any problems if the WRAP fails 

to perform any of the functions described in this plan in a timely manner. 

(2) Designation of the Tracking System Administrator. If the backstop trading program is 

triggered due to an exceedance of the SO2 milestones as outlined in section 8.1.3 of this plan, the State of 

Arizona will work cooperatively with the other participating states and tribes to designate one Tracking 

System Administrator (TSA). The TSA will be designated as expeditiously as possible, but no later than 

six months after the program trigger date. In addition, before the TSA is designated, the State of Arizona 

will enter into a binding contract with the TSA that will require the TSA to perform all TSA functions 

described in this plan. The State of Arizona has sufficient authority under State contract law to ensure 

that the functions in this plan are carried out by the TSA.

(3) Information Provided by other States and Tribes. The State of Arizona will accept the 

emission inventory and permitting information provided by the other participating states and tribes in 

order to determine the milestone value and program trigger if such other states and tribes have provided 

proper documentation and followed the public notification process in their federally approved 

implementation plans. 

8.1.3. Determination of Program Trigger

 (1) Until the program has been triggered and source compliance is required, the State of Arizona 

will submit an annual emissions report to the WRAP and all participating states and tribes by September 

30 of each year. The report will document actual sulfur dioxide emissions during the previous calendar 

year for all sources subject to the Sulfur Dioxide Milestone Inventory requirements. The first report for 

calendar year 2003 will be submitted by September 30, 2004. The State of Arizona will prepare the 

supporting documentation that is included with the annual emissions report as noted in (2) and (3) below. 
Chapter 8 – SO2 Milestones/Backstop - 45 - Arizona Regional Haze SIP

 

(2) The annual emissions report for Arizona will include a source emissions change report that 

contains the following information: 

(a) identification of any new sources that were not contained in the previous calendar year’s 

emissions report, and an explanation of why the source is now included in the program; 

(b) identification of any sources that were included in the previous year’s report and are no longer 

included in the program, and an explanation of why this change has occurred; and 

(c) an explanation for increases or decreases of emissions at any applicable source or more than 

twenty percent from the previous year. 

(3) The annual emissions report for Arizona will include the proposed emission 

adjustment as described in (a) through (c) to ensure a consistent comparison to the milestones. 

(a) Changes in flow rate measurement methods. Actual emission inventories for utilities that use 

EPA’s Reference Method 2F, 2G, or 2H to measure stack flow rate will be adjusted to be 

comparable with the flow rate assumptions that were used in 1999, the base year inventory for the 

Annex. The adjustment may be calculated using any of the following three methods, and 

emissions for the year 2018 will not be adjusted. 

(i) Directly determine the difference in flow rate through a side-by-side comparison of 

data collected with the new and old flow reference methods during a relative accuracy 

test audit (RATA) test. 

(ii) Compare the annual average heat rate using Acid Rain heat input data (MMBtu) and 

total generation (MWHrs) as reported to the Federal Energy Information Administration. 

Under this approach, the flow adjustment factor will be calculated using the following 

ratio: 

Heat input/MW for first full year of data using new flow rate method /

Heat input/MW for last full year of data using old flow rate method. 

(iii) Compare the standard CFM per MW before and after the new flow reference method 

based on CEMs data submitted in the Acid Rain Program, as follows: 

SCF/Unit of Generation for first full year of data using new flow rate method

SCF/Unit of Generation for last full year of data using old flow rate method. 

(b) Changes in emission monitoring or calculation methods. Actual emission inventories for 

sources that change the method of monitoring or calculating their emissions will be adjusted to be 

comparable to the emission monitoring or calculation method that was used in the base year 

inventory for the Annex (1999 for utilities and 1998 for all other sources). 

 

(c) Changes due to enforcement actions. 

(i) Adjustments due to enforcement actions arising from settlements. Adjustments to the 

milestones shall be made, as specified in section 8.1.3(3) and (4), if: 
Chapter 8 – SO2 Milestones/Backstop - 46 - Arizona Regional Haze SIP

(A) an agreement to settle an action, arising from allegations of a failure of an 

owner or operator of an emissions unit at a source in the program to comply with 

applicable regulations which were in effect during the base year, is reached 

between the parties to the action; 

(B) the alleged failure to comply with applicable regulations affects the 

assumptions that were used in calculating the source’s base year and forecasted 

sulfur dioxide emissions; and 

(C) the settlement includes or recommends an adjustment to the milestones. 

(ii) Adjustments due to enforcement actions arising from administrative or judicial 

orders. Adjustments to the milestones shall be made as directed by any final 

administrative or judicial order, as specified in section 8.1.3(3) and (4). Where the final 

administrative or judicial order does not include a reforecast of the source's baseline, the 

State of Arizona shall evaluate whether a reforecast of the source's baseline emissions is 

appropriate. 

(iii) Adjustments method and effective dates. Based on section 8.1.3(3) and (4), the 

milestone must be decreased by an appropriate amount based on a reforecast of the 

source’s decreased sulfur dioxide emissions. The adjustments do not become effective 

until after the source has reduced its sulfur dioxide emissions as required in the settlement 

agreement, or administrative or judicial order. All adjustments based upon enforcement 

actions must be made in the form of an SIP revision that complies with the procedural 

requirements of 40 CFR 51.102 and 51.103. 

(iv) Documentation of adjustments for enforcement actions. In the periodic plan revision 

required under 40 CFR 51.309(d)(10), the State of Arizona shall include the following 

documentation of any adjustment due to an enforcement action: 

(A) identification of each source under the State of Arizona 's jurisdiction that 

has reduced sulfur dioxide emissions pursuant to a settlement agreement or an 

administrative or judicial order; 

(B) for each source identified, a statement indicating whether the milestones were 

adjusted in response to the enforcement action; 

(C) discussion of the rationale for the State of Arizona 's decision to adjust or not 

to adjust the milestones; and 

(D) if SO2 emissions reductions over and above those reductions needed for 

compliance with the applicable regulations were part of an agreement to settle an 

action, a statement indicating whether such reductions resulted in any adjustment 

to the milestones or allowance allocations, and a discussion of the rationale for 

the State of Arizona 's decision on any such adjustment. 

(4) The annual sulfur dioxide milestone and emissions report for Arizona will document any 

adjustments that should be made to the milestone for the previous year as follows. 
Chapter 8 – SO2 Milestones/Backstop - 47 - Arizona Regional Haze SIP

(a) The State of Arizona will document the submittal date of this Implementation Plan to 

implement the regional WEB Trading Program, and the approval date by the EPA Administrator, 

if applicable. 

(b) If actual emissions and sulfur input are greater than the baseline level in Table 3, and either 

the BHP San Manuel smelter in Arizona or the Phelps Dodge smelter in New Mexico have not 

resumed operation, the State of Arizona will determine the milestone adjustment for all copper 

smelters in Arizona by determining the increase in the milestone based on the proportional 

increase in sulfur input over baseline levels. For each smelter, the adjustment will not exceed the 

smelter-specific set-aside listed in Table 8-3. 

(c) Arizona shall determine the status of BHP San Manuel copper smelter during the previous 

year. If the smelter resumed operation during the milestone year, the report shall include: 

 (i) the date the smelter resumed operation; 

 

 (ii) a determination by Arizona that either, 

 (A) the smelter resumed production consistent with past operations, 

 (B) the smelter was required to go through new source review, in which case 

 Arizona shall include the new SO2 permitted limit for BHP San Manuel in the 

 report, or 

 (C) the smelter resumed operations in a substantially different manner such that 

 emissions will be less than for past operations, in which case Arizona shall 

 determine expected emissions from the operations. 

(d) a proposed adjustment to the sulfur dioxide milestone to account for the operation of the BHP 

San Manuel smelter. 

(e) Comparison of actual emissions from all smelters in [state] to the baseline emissions level for 

that smelter listed in Table 3. If actual emissions and sulfur input are greater than the baseline 

levels in Table 3, and either the BHP San Manuel smelter in Arizona or the Phelps Dodge smelter 

in New Mexico have not resumed operation, [state] shall determine the milestone adjustment by 

determining the increase in the milestone based on the proportional increase in sulfur input over 

baseline levels. For each smelter, the adjustment shall not exceed the smelter-specific set-aside 

listed in Table 3. 

The following example is for illustrative purposes: 

Asarco’s baseline SO2 emissions are 23,000 tons 

Asarco’s baseline sulfur input is 235,000 tons 

For example, in 2005: 

Asarco’s S02 emissions were 25,000 tons 

Asarco’s sulfur input was 250,000 tons. 

Because Asarco’s 2005 emissions and sulfur input exceeded it’s baseline emissions and 

sulfur input: need to calculate the percent increase in sulfur input in the year 2005 

= [(2005 sulfur input) - (baseline sulfur input)] ÷ [baseline sulfur input] 

= [250,000 - 235,000] ÷ [235,000] 
Chapter 8 – SO2 Milestones/Backstop - 48 - Arizona Regional Haze SIP

= [15,000] ÷ [235,000] 

= 0.0638 

= 6.38% 

The adjustment to the milestone based on Asarco’s increase in production is to increase 

the milestone by 1,564 tons of SO2 (which is ok, since it is less than the maximum of 

3,000 tons in Table 3 for Asarco). 

adjustment = 6.38% x baseline emissions 

adjustment = 6.38% x 23,000 

 

(5) Compilation of Reports. 

(a) The WRAP will compile the annual emissions reports submitted by all participating states and 

tribes into a draft regional emission report for sulfur dioxide. The WRAP will follow additional 

quality assurance procedures developed by states and tribes to identify possible errors in the 

emissions data, including screening for missing or added sources, name changes, and significant 

changes in reported emissions. Any questions or anomalies regarding Arizona’s report will be 

resolved by the State of Arizona for resolution prior to the submission of the draft regional 

emission report. 

(b) By December 31 of each year, the WRAP will submit the draft regional emission and 

milestone report to the State of Arizona and all participating states and tribes and will post the 

report on the WRAP’s web page. The report will include the following information for all states 

and tribes that have an implementation plan that has been approved by the EPA Administrator 

under 40 CFR 51.309(h): 

 (i) Actual regional sulfur dioxide emissions in tons per year, 

 (ii) Adjustments to account for: 

 (A) changes in flow rate measurement methods, 

(B) changes in emission monitoring or calculation methods, and 

(C) enforcement actions or settlement agreements as a result of 

enforcement actions; 

(iii) average adjusted emissions for the last three years for comparison to the 

regional milestone, if adjustments were made. 

(iv) regional milestone adjustments to account for participation by eligible states 

and tribes and the future operation of smelters in Arizona and New Mexico. A 

separate report that includes additional states and tribes that have submitted 

implementation plans that are still under review by the Environmental Protection 

Agency will also be prepared for information purposes. 

(6) The State of Arizona will evaluate the draft regional emissions report and will propose a draft 

determination that the sulfur dioxide milestone has either been met in the region, or has been exceeded. In 

the event that the TSA has not submitted a draft regional emissions and milestone report to the State of 

Arizona by the December 31 deadline for any year, the State of Arizona will prepare the report for that 

year based upon the annual emissions reports submitted by all participating states and tribes to the WRAP 

for that year. The State of Arizona will modify the data in these annual emissions reports, or use data 

where such report(s) have not been submitted, based upon direction received from the Environmental 

Protection Agency. 

(7) The State of Arizona will advertise availability of the draft regional emissions report and will 

notify the public of the draft determination by publishing a notice in newspapers of general circulation 
Chapter 8 – SO2 Milestones/Backstop - 49 - Arizona Regional Haze SIP

throughout Arizona. A 30-day public comment period will be established, and a public hearing will be 

held during the public comment period. The State of Arizona will also submit the draft determination to 

EPA for review and comment concurrently. 

(8) The State of Arizona will consider any comments received during the comment period, and 

will submit a copy of all comments to the WRAP and to all participating states and tribes along with a 

response that addresses the comments. 

(9) The WRAP will compile the comments and responses from all participating states and tribes 

and prepare a draft final regional emissions report. The report will be submitted to the states and tribes 

that are participating in the program and, if necessary, the report will propose a common program trigger 

date. 

 

(10) The State of Arizona will review and approve the final regional emissions report. The State 

of Arizona will then submit this report to the Environmental Protection Agency along with a final 

determination that the milestone either has been met in the region, or that the milestone has been 

exceeded and the WEB Trading Program has been triggered in Arizona. This determination will be 

submitted to the Environmental Protection Agency by the end of March, fifteen months following the 

milestone year. The first determination will be submitted by March 31, 2005, for the 2003 milestone. If 

the milestone has been exceeded, the common trigger date proposed in the regional report will become 

the program trigger date for purposes of implementing the WEB Trading Program. In the event that the 

program trigger date must be established by the State of Arizona in the absence of a regional emissions 

and milestone report prepared by the WRAP, the program trigger date will be March 31 of the applicable 

year. 

(11) The State of Arizona will publish a notice of the final determination in newspapers of 

general circulation throughout the state of Arizona. This notice will include the milestone and the final 

annual regional SO2 emissions for that year. If the milestone has been exceeded, the notice will specify 

the program trigger date and the first year that WEB sources must be in compliance with the WEB 

Trading Program provisions. 

8.1.4. Year 2013 Assessment

(1) Initial Assessment in 2013 Periodic SIP Review. 

(a) The State of Arizona will work cooperatively through the WRAP with other participating states 

and tribes to develop a projected emission inventory for SO2 through the year 2018, using the 2010 

regional inventory as a baseline. This projected inventory will be included in the 2010 annual 

emission and milestone report that will be completed in March 2012 as outlined in section 8.1.3 of 

this plan. 

(b) The State of Arizona will evaluate the projected inventory, and based upon this information 

will make an assessment of the likelihood of meeting the regional milestone for the year 2018. The 

State of Arizona will include this assessment as part of Arizona’s progress report that must be 

submitted by December 31, 2013, as required by 40 CFR 51.309(d)(10). 

(2) Regional Emissions Report for 2012. 

(a) The State of Arizona will prepare an SO2 emission report for the year 2012 by September 30, 

2013, as described in section 8.1.3(1) of this plan. The State of Arizona will include a list of all 

known or anticipated sources in Arizona that are anticipated to affect total SO2 emissions in 2018. 
Chapter 8 – SO2 Milestones/Backstop - 50 - Arizona Regional Haze SIP

This may include permitted sources, projects that are still in the planning stage, or projections 

from the affected sources of anticipated emissions in 2018. The status of these projects will be 

described to provide a better understanding of the degree of certainty that individual projects will 

be completed by 2018. 

(b) The WRAP will compile the information from all participating states and tribes, prepare draft 

SO2 inventory projections for the year 2018, and estimate the effect of known future sources on 

SO2 emissions. Projected 2018 emissions will be compared to the 2018 milestone. This 

information will be included in the draft regional emissions report for 2012 that will be submitted 

to the State of Arizona by December 31, 2013, as outlined in section 8.1.3(5) of this plan.

(3) Consensus Decision. The State of Arizona commits to meet with the participating states and 

tribes in March 2014 to discuss any comments received on the 2018 emission projections in the draft 

report. The participating states and tribes will decide, through a consensus process, whether it is necessary 

to trigger the WEB trading program early in order to meet the SO2 emission reduction goals in 2018.

(4) Early Trigger: Timing. If the participating states and tribes unanimously decide in the March 

2014 meeting that an early trigger of the backstop trading program is necessary, the State of Arizona will 

trigger the WEB Trading Program and the timing of the program elements will be adjusted as follows to 

ensure that the WEB Trading Program is in place in 2018. 

(a) The date of the consensus decision by the participating states and tribes to voluntarily trigger 

the WEB trading program will become the program trigger date. 

(b) Allowances for 2018 will be distributed to WEB sources by January 1, 2015.

(c) The first control period will be the year 2018. WEB sources will need to demonstrate at the 

end of the first control period that they have enough allowances to cover their 2018 SO2 

emissions. 

(5) Public Notification. The State of Arizona will publish notice of the decision in newspapers of 

general circulation in Arizona. If applicable, the notice will include a statement that the WEB Trading 

Program is in effect and will specify the program trigger date. 

8.1.5. Special Penalty Provisions for the 2018 Milestone

If the WEB Trading Program is triggered as outlined in the section 8.1 of this plan, and the first 

control period will not occur until after the year 2018, a special penalty shall be assessed for the 

exceedance of the 2018 milestone. 

(1) The State of Arizona will allocate allowances to all WEB sources using the methods 

established in the 2013 SIP revision described in section 8.4 of this plan. WEB sources will have the 

option to buy and sell allowances during a two-month allowance transfer period. 

(2) At the end of this two-month allowance transfer period, compliance with the allowance 

limitation will be determined. Penalties will be assessed for SO2 emissions that are greater than the 

allowance limitation for each WEB source. However, SO2 emissions in the year 2018 for each WEB 

source will be determined in accordance with the Sulfur Dioxide Milestone Inventory requirements. 

(3) The 2018 special penalty provision shall continue to be applied each year after 2018 until the 

2018 milestones have been achieved.
Chapter 8 – SO2 Milestones/Backstop - 51 - Arizona Regional Haze SIP

8.2. Pre-Trigger Emissions Tracking Requirements 

8.2.1. SO2 Emission Inventory

40 CFR 51.309 sets forth emissions inventory requirements for tracking compliance with the SO2 

milestones. Arizona’s Article 3 (Permits and Permit Requirements) and Article 7 (Existing Stationary 

Source Performance Standards) in addition to the requirements of the state-specific WEB Trading 

Program rule, contain the inventory requirements to satisfy the needs of this program. 

(1) Applicability. The sulfur dioxide milestone inventory requirements of R18-2-306 require all 

stationary sources with actual emissions of 100 tons per year or more of SO2 in the year 2000, or in any 

subsequent year, to submit an annual inventory of SO2 emissions, beginning with the 2003 emission 

inventory. A source that meets these criteria and then emits less than 100 tons per year in a later year must 

continue to submit an SO2 inventory for tracking compliance with the regional SO2 milestones until 2018 

or until the WEB Trading Program has been fully implemented and emission tracking is occurring under 

the state-specific rule, whichever is earlier. 

(2) Enforceable requirements for WEB sources as found in the state-specific rule. 

(a) Each source shall submit an annual inventory of SO2 emissions and smelters also must submit 

an annual report of sulfur input in tons per year. 

(b) Each source shall use appropriate emission factors and estimating techniques and document 

the emissions monitoring or estimation methodology used. 

(c) Each source shall include emissions from start up, shut down, and upset conditions in the 

annual total inventory. 

(d) Each source subject to the federal acid rain program shall use methods from 40 CFR Part 75 

to report emissions from all sources. 

(e) Each source shall include the rate and period of emissions, the specific installation that is the 

source of the air pollution, composition of air contaminant, type and efficiency of the air pollution 

control equipment and other information necessary to quantify operation and emissions, and to 

evaluate pollution control. 

(f) Each source shall retain records for a minimum of 10 years from the date of their creation, or 

if the record was the basis for an adjustment to a milestone, 5 years from the date of a SIP 

revision, whichever is longer. 

(3) The State of Arizona will quality-assure the submitted inventory data as outlined in the 

Inventory Preparation Plan. The State of Arizona will screen the inventories to identify changes in 

emission measurement techniques that would require an inventory and milestone adjustment as outlined 

in section 8.1 of this plan. 

 

(4) The State of Arizona will retain historical emission inventory records for non-utilities from 1996 and 

1998 that may affect milestone calculations under section 8.1 of this plan and allocation decisions under 

section 8.1 of this plan until the year 2018 to ensure that changes in emissions monitoring techniques can 

be tracked. 
Chapter 8 – SO2 Milestones/Backstop - 52 - Arizona Regional Haze SIP

8.2.2. Development of Emission Tracking System

The State of Arizona will work cooperatively with the states and tribes that are participating in 

the WEB Trading Program to ensure that an emission tracking system for the regional SO2 inventory is 

developed and maintained. 

8.2.3. Periodic Audit of Pre-Trigger Emission Tracking Database

(1) During the pre-trigger phase when the State of Arizona is tracking compliance with the 

regional SO2 milestones, the State of Arizona will work cooperatively with the participating states and 

tribes to ensure that an independent audit of the tracking database is conducted to make sure that the 

WRAP is accurately compiling the regional emissions report. 

(a) The first audit will occur during the year 2006 and will review data collected during the first 

two years of the program. 

(b) Subsequent audits will occur in 2011, which will cover emissions years 2005-2009, and 2016, 

which will cover emissions years 2010-2014. 

(2) The primary focus of the audit will be the process that is used to compile the regional 

inventory from the data provided by each state and tribe, and the tracking of accumulated changes during 

the period between SIP revisions. The audit will also review the accuracy and integrity of the regional 

reports that are used to determine compliance with the milestones. The audit will not be a full review of 

Arizona’s process for compiling and reporting SO2 emissions, but will include a broad review of 

Arizona’s inventory management and quality assurance systems, including the presence and exercise of 

systems to assure data quality and integrity. 

(3) The audit will discuss the uncertainty of emissions calculations, and whether this uncertainty 

is likely to affect the annual determination of whether the milestone is exceeded. It will identify any 

recommended changes to emissions monitoring or calculation methods or data quality assurance systems. 

It will also review and recommend any changes to improve the administrative process of collecting the 

annual emissions data at the state and tribal level, compiling a regional emission inventory, and making 

the annual determination of whether the WEB Trading Program has been triggered. 

(4) Changes to the WEB trading program, including any changes to the milestones due to the 

results of these periodic audits, will be submitted to EPA as a SIP revision as part of the five-year SIP 

review required by 40 CFR 51.309(d)(10). 

(5) The State of Arizona will advertise the availability of the draft audit report by publishing a notice in 

newspapers of general circulation in Arizona. A 30-day public comment period will be established, and a 

hearing will be held during the public comment period. The State of Arizona will respond to comments 

and provide notice of the availability of the final audit report. The State of Arizona will submit the final 

audit report to the EPA regional office. 

8.3. WEB Trading Program Requirements

8.3.1. Initial Allocation of SO2 Allowances

 (1) Draft Allocation Report. Within six months of the program trigger date, as outlined in 

section 8.1.3(11) of this plan, the State of Arizona will submit a draft allocation report to all participating 

states and tribes and to the TSA. This report will contain the following information: 
Chapter 8 – SO2 Milestones/Backstop - 53 - Arizona Regional Haze SIP

(a) A list of all WEB sources in Arizona as defined in the state-specific rule. Those sources are 

grouped into two categories: 

(i) Category 1: WEB sources that commenced operation prior to January 1, 2003. These 

sources will receive a floor allocation and will be eligible for the reducible portion of the 

allocation. 

(ii) Category 2: WEB sources that commenced operation on January 1, 2003 or a later 

date. These sources will receive a floor allocation, but will not be eligible for the 

reducible allocation. The floor allocation for Category 2 sources will be deducted from 

the new source set-aside. 

WEB sources that have received a retired source exemption will be included in the allocation 

process in the same manner as WEB sources that are currently operating. However, sources that were 

permanently shut down prior to the program trigger date are not considered WEB sources and would 

therefore not be included in the allocation process. 

(b) The floor allocation for all WEB sources in Arizona. 

(i) For non-utility category 1 WEB sources, the floor allocation shall be as established in the E.H. 

Pechan Report, Market Trading Forum Non-Utility Sector Allocation Final Report from the 

Allocations Working Group (November 2002). The Pechan Report can be found in Appendix A8a. If any additional category 1 sources are identified, the State of Arizona shall calculate a floor 

allocation using the methodology outlined in the E.H. Pechan Report. 

(ii) For utility category 1 WEB sources, the floor will be calculated by first assigning a “clean 

unit” emission rate to each unit. The clean unit emission rate will then be multiplied by an annual 

heat input (MMBtu) that represents a realistic upper bound for the unit. 

[Note: The floor level approach described above is designed to address equity issues regarding 

the allocation process for utilities. The State of Arizona is participating in ongoing discussions 

with the other participating states, tribes and regional stakeholders to ensure that all equity issues 

have been addressed. ] 

Principles 

• Each unit will have enough allowances to operate as a clean source and at an operating rate 

(capacity factor) that is a realistic upper bound for the unit. 

• There will not be significant winners and losers in this process. 

• The focus is on a fair approach that is applied equally to all sources rather than on state and 

tribal budgets. 

• The allocation process will use data that reflect current conditions, including current 

monitoring methodologies. 

Equity Issues 

• Sources that are currently burning very low sulfur coal may see changes in their supply in 

the future. Historic actual emissions may not reflect future operations. 
Chapter 8 – SO2 Milestones/Backstop - 54 - Arizona Regional Haze SIP

• Sources that are currently operating at a low utilization may not reach full capacity in the 

future. Assumptions about growth that are realistic on the regional level may provide a 

windfall to some sources, and not provide adequate allowances for other sources. 

• There are some utility units in the region that are not BART-eligible and are operating at 

a low level of control for SO2. The relative responsibility of BART-eligible vs. nonBART-eligible is a consideration in the process. 

• Sources that are operating at a high level of control are already bearing the cost of control 

and this affects their ability to compete in the market. 

• Sources that have no SO2 controls are facing a large expense that could affect their ability 

to continue to operate. 

• Emission rate disparities exist throughout the region. 

(iii) For Category 2 WEB sources the floor allocation shall be the lower of the permitted SO2

annual emissions for the WEB source, or SO2 annual emissions calculated based on a level of 

control equivalent to BACT and assuming 100% utilization of the WEB source. 

(c) A list of certified early reductions, expressed as tons of SO2. Early reductions will be 

calculated and certified as follows: 

(i) Any WEB source that installs control technology and accepts new permit emissions 

limits that are, for a non-utility source, below its floor as established in this section, or, 

for a utility source, below BACT, may apply for an early reduction credit. The 

application must show that the floor was calculated in a manner that is consistent with the 

monitoring requirements and the new permit must contain monitoring requirements that 

are consistent with the state-specific rule. The credits accumulate from the time the new 

controls come on line until the program trigger date and will be allocated to the WEB 

source over a 10 year period. The use of early reduction credits in any control period is 

limited to no more than five percent, system-wide, of the existing available allowances, 

as provided in section 8.1.3(2)(f) of this plan. 

(ii) The State of Arizona will review the application and will certify early reductions for 

each full year between 2003 and the program trigger year that meet the requirements of 

the state-specific rule and this plan. 

(iii) A source’s certified early reductions for all years will be added together to obtain the 

total certified early reductions for that source. 

(d) A list of all renewable energy plants and sources in Arizona that began operation after 

October 1, 2000, and the MW of installed nameplate capacity for each of these resources. 

Renewable energy credits will be granted at a rate of 2.5 tons per MW, and will accumulate from 

the beginning of the facility’s operation. Their use in any control period is limited to no more 

than five percent, system-wide, of the existing available allowances, as provided in section 

8.1.3(2)(g) of this plan. 
Chapter 8 – SO2 Milestones/Backstop - 55 - Arizona Regional Haze SIP

(e) Historical SO2 emissions data for all Category 1 sources for the purposes of calculating the 

reducible allocation. 

(i) For utilities, the average of the years 2000 – 2002. Another time period may be used 

for individual emission units, if needed, to be representative of normal operating 

conditions. 

(ii) For non-utilities, the average of annual SO2 emissions for the years 1996 and 1998. 

 

(f) Changes due to enforcement actions or settlement agreements as a result of enforcement 

actions. The adjustment shall be determined in accordance with section 8.1.3 of this SIP. The 

difference between the WEB source’s allocations prior to enforcement and after the enforcement 

action shall be removed from the allocation pool.

(2) Compiled Allocation Report. 

The TSA will compile the information provided by all participating states and tribes into a draft 

regional allocation report, and will submit this draft regional report to the State of Arizona and all 

participating states and tribes for review and comment thirty days after receiving the preliminary 

allocation reports. The draft regional allocation report will include a proposed budget for each state and 

tribe and the proposed allocation for each WEB source in Arizona. 

The following methodology for calculating the proposed regional allocation for utilities and nonutilities is based on the assumption that the states of Arizona, Oregon, New Mexico, Utah and Wyoming 

are the only participating states in the WEB Trading Program. These 5 states are actively pursuing a SIP 

under section 309 of the Regional Haze Rule and it is unlikely that any other states will be able to develop 

a SIP under section 309 by the deadline of December 31, 2003. The State of Arizona will work closely 

with the other four states that are developing 309 SIPs to ensure that the regional allocation is distributed 

consistently and fairly and to address any change in status that may affect this process. Tribal nations 

may participate in the program at a later date under the provisions of the Tribal Authority Rule. There are 

currently four category 1 sources operating on tribal lands under the jurisdiction of three tribal nations. 

The following methodology will remain unchanged if any of these tribal nations opt in to the program at a 

later date because the allocation for any of the four existing tribal sources will be covered by the opt-in 

adjustment for the tribe, and the allocation for any new sources will be covered by the regional newsource set-aside. 

(a) Table 8-4 shows the calculation of the available allocation for existing sources. The base 

milestone for the 5-state region (i.e., those states currently committed to a SIP under Section 309; 

namely: Arizona, New Mexico, Oregon, Utah, and Wyoming) calculated in accordance with 

section 8.1 of this plan is the starting point. The base milestone does not include the smelter setaside. 20,000 tons of SO2 is then subtracted for a tribal set-aside. 
Chapter 8 – SO2 Milestones/Backstop - 56 - Arizona Regional Haze SIP

Table 8-4. Utility/Non-utility Split. 

 Base 

Milestone 

from Table 2 

Tribal SetAside New Source 

Set-aside 

Remaining 

Allocation 

Utility 

Portion 

Non-utility 

portion 

2003 446,904 20,000 6,390 420,514 275,027 145,488 

2004 446,904 20,000 6,390 420,514 275,027 145,488 

2005 446,904 20,000 6,390 420,514 275,027 145,488 

2006 446,904 20,000 6,390 420,514 275,027 145,488 

2007 446,904 20,000 6,390 420,514 275,027 145,488 

2008 447,014 20,000 12,902 414,112 275,636 138,476 

2009 447,123 20,000 12,902 414,221 275,708 138,513 

2010 447,333 20,000 12,902 414,331 275,782 138,549 

2011 447,333 20,000 12,902 414,331 275,782 138,549 

2012 447,333 20,000 12,902 414,331 275,782 138,549 

2013 435,455 20,000 19,370 396,085 259,171 136,914 

2014 423,676 20,000 19,370 384,306 251,463 132,843 

2015 411,898 20,000 19,370 372,528 243,757 128,771 

2016 411,898 20,000 19,370 372,528 243,757 128,771 

2017 411,898 20,000 19,370 372,528 243,757 128,771 

2018 309,087 20,000 19,370 269,717 155,367 114,350 

(b) Table 8-5 shows the new source set-aside for the 5-state region. 

(i) The new source set-aside is calculated by subtracting the new source set-aside 

adjustment listed in Table 8-5 for all states and tribes that do not have a federally 

approved Implementation Plan for the WEB trading program under 40 CFR 51.309 as of 

the program trigger date from the maximum possible set-aside for each of the first five 

years of the trading program. 

Table 8-5. New Source Set-Aside Adjustment

2003 - 2007 2008 - 2012 2013 - 2018 

Maximum 

Possible SetAside 

9,000 18,000 27,000 

State or Tribe Adjustment 

(tons/yr SO2) 

1. Arizona 1,757 3,596 5,437 

2. California 559 1,039 1,532 

3. Colorado 1,480 2,945 4,364 

4. Idaho 270 496 721 

5. Nevada 302 618 1,011 

6. New Mexico 1,267 2,512 3,889 

7. Oregon 393 795 1,075 

8. Arizona 640 1,293 1,949 

9. Wyoming 2,333 4,706 7,020 

10. Tribes No 

adjustment 

needed 

No 

adjustment 

needed 

No 

adjustment 

needed 
Chapter 8 – SO2 Milestones/Backstop - 57 - Arizona Regional Haze SIP

(ii) Subtract the floor allocation for all WEB sources in the region that were identified as 

Category 2 from the new source set-aside for the 5-state region to determine the available 

allocation for new sources that begin operation after the program trigger date. The allocation 

process for these new sources is described in section 8.3.3 of this plan. 

Example calculation of the new source set-aside. 

The example uses the following assumptions: 

(i) Emissions exceed the milestones based on an average of the years 2003-2005. 

(ii) The program trigger date is March 31, 2007. 

(iii) The first 5 years of the program are 2011-2015. 

(iii) Five states are participating in the program (AZ, NM, OR, UT, WY). 

(iv) New sources that commenced operation between January 1, 2003 and the program trigger date have a 

total floor allocation of 6,000. 

2011 2012 2013 2014 2015 

Maximum Possible Set-Aside 18,000 18,000 27,000 27,000 27,000

5-State Adjustment - 5,098 -5,098 -7,628 -7,628 -7,628

Floor for Category 2 Sources -6,000 -6,000 -6,000 -6,000 -6,000

Remaining New Source Setaside 6,902 6,902 13,372 13,372 13,372

 

(c) The remaining allocation shown in Table 8-5 is available for distribution to category 1 

sources. The final two columns in Table 8-5 split this remaining allocation into a utility allocation 

and a non-utility allocation. Apply any milestone adjustments due to the smelter set-aside as 

outlined in section 8.1 of this plan to the non-utility allocation listed in Table 8-5. 

(d) Subtract the floor allocations for all category 1 utility and non-utility sources in the region 

from the utility allocation or the non-utility allocation. 

(e) Calculate the early reduction allocation. 

(i) Divide the number of certified early reduction credits for all WEB sources in the 

region by ten. 

(ii) Add the utility allocation for 2018 to the non-utility allocation for 2018 and then 

multiply this total by 0.05. 

(iii) If the product of paragraph (i) is no more than the product of paragraph (ii), the 

product of paragraph (i) is the early reduction allocation, and each source is allocated ten 

percent of its early reduction credits. 

(iv) If the product of paragraph (i) is more than the product of paragraph (ii), the early 

reduction allocation for the region is the product of paragraph (ii). To determine a 

source’s allocation, divide the product of paragraph (ii) by 0.10 times the total number of 

early reduction credits and apply that ratio to the early reduction credits claimed by the 

source. 
Chapter 8 – SO2 Milestones/Backstop - 58 - Arizona Regional Haze SIP

(v) Split the regional early reduction allocation based on the ratio of utility to non-utility 

allocations in 2018 and subtract the early reduction allocation from the utility and nonutility allocation totals. 

(vi) The early reduction allocation will be calculated in a similar manner for the second 

five-year allocation period under this program, and will then be discontinued for any 

future allocation periods. 

(g) Calculate the regional renewable energy allocation. 

(i) Add together the reported MW of installed nameplate capacity for renewable energy 

facilities reported by the participating states and tribes, and then multiply this number by 

2.5. 

(ii) Add the utility allocation for 2018 to the non-utility allocation for 2018 and then 

multiply this total by 0.05. 

(iii) If the product of paragraph (i) is no more than the product of paragraph (ii), the 

product of paragraph (i) is the renewable energy allocation. 

(iv) If the product of paragraph (i) is greater than or equal to the product of paragraph 

(ii), the renewable energy allocation for the region is the product of paragraph (ii). To 

determine a source’s allocation, divide the product of paragraph (ii) by the total number 

of renewable energy credits and apply that ratio to the early reduction credits claimed by 

the source. 

(v) Split the regional renewable energy allocation based on the ratio of utility to nonutility allocations in 2018 and subtract the renewable energy allocation from the utility 

and non-utility allocation totals. 

(h) Any remaining allowances in the utility allocation or the non-utility allocation after 

subtraction of the early reduction allocation and the renewable energy allocation is considered the 

reducible allocation and will be assigned to Category 1 sources. 

(i) For non-utility sources, add together the historic SO2 emissions in accordance with 

section 8.1.3(1)(e) of this plan for all Category 1 non-utility sources in the region to 

determine an historic emission total. Determine a percent contribution of SO2 emissions 

for each WEB source to the historic emission total. Multiply the non-utility reducible 

allocation calculated in paragraph ((i)) below by the percent contribution for each WEB 

source to determine a reducible allocation for each WEB source. 

(ii) For utility sources, the reducible allocation will be distributed to sources that emitted 

above their floor in the baseline period (2000 through 2002) based on their percentage of 

total floor emissions for sources emitting above the floor times the number of reducible 

allowances available for the first five years of the WEB Trading Program. The number 

of allowances for any source receiving a reducible allocation shall not exceed a recent 

historic emission rate times a heat input that represents a realistic upper bound for the 

unit. 
Chapter 8 – SO2 Milestones/Backstop - 59 - Arizona Regional Haze SIP

[Note: The approach for distributing the reducible utility allocation described above is designed 

to address equity issues regarding the allocation process for utilities. The State of Arizona is 

participating in ongoing discussions with the other participating states, tribes and regional 

stakeholders to ensure that all equity issues have been addressed. The principles and equity 

issues that are under discussion are listed in section 8.1 of this plan.] 

(i) Add together the floor allocation, early reduction allocation, renewable energy resource 

allocation, and reducible allocation for each WEB source and each renewable energy source to 

determine the proposed allocations for the first five years of the WEB Trading Program. 

(j) Add together the proposed allocations for all of the WEB sources in the jurisdiction of each 

participating state and tribe to determine a draft SO2 allowance budget for each state and tribe. 

(3) Public Comment Period. The State of Arizona will publish notice of availability of the draft 

regional allocation report in newspapers of general circulation throughout Arizona. A 30-day public 

comment period will be established, and a hearing will be held during the comment period. The State of 

Arizona will consider the comments, and will revise the draft report as needed.

(4) Proposed Changes Submitted to Tracking System Administrator. The State of Arizona will 

submit proposed changes to the budget and source allocations to the TSA within sixty days of receipt of 

the draft regional allocation report. 

(5) Compilation of Changes. The TSA will compile the proposed changes and will submit a final 

draft regional allocation report to the State of Arizona for approval within 30 days of receipt of the 

recommended changes. 

(6) Final Regional Allocation Report. The State of Arizona will review the final regional 

allocation report and will determine the budget for Arizona and allocations for WEB sources within 

Arizona in accordance with the provisions of this plan within thirty days of receipt of the final draft 

allocation report. The State of Arizona will submit the budget and allocations for all WEB sources in 

Arizona to EPA, and will notify the TSA that the WEB source allocations should be recorded in the 

allowance tracking system. 

(7) The State of Arizona will notify all WEB sources within Arizona of the number of allowances 

that have been recorded in their compliance account. The notice will include a warning to the WEB 

sources that reported annual sulfur dioxide emissions may change due to the implementation of new 

monitoring methods. Allocations for the first five years of the program will not be adjusted to account for 

changes due to the new monitoring method. However, allocations during the next five-year distribution 

will be adjusted as needed to account for paper changes in emissions due to changes in monitoring 

methodology. 

8.3.2. Distribution of Allowances for Future Control Periods. 

By December 1 of the year five years after the initial allocation, the State of Arizona will follow 

the process outlined in section 8.1 of this plan to distribute allowances for the next five-year period. This 

process will continue every five years until allowances have been allocated through the year 2018. 
Chapter 8 – SO2 Milestones/Backstop - 60 - Arizona Regional Haze SIP

8.3.3. Distribution of the New Source Allocation

(1) The new source set-aside will be available for two categories of sources. 

(a) A new WEB source is eligible to receive an annual allocation equal to the annual sulfur 

dioxide limit in the source’s approval order, beginning with the first full year of operation and in 

accordance with the provisions of the state-specific rule.

(b) An existing WEB source that has increased production capacity by first obtaining a new 

approval order is eligible to receive an allocation from the new source set-aside equal to: 

 

(i) the permitted annual sulfur dioxide emission limit for a new unit; or 

(ii) the permitted annual SO2 emission increase for the WEB source due to the 

replacement of an existing unit with a new unit or the modification of an existing unit that 

increased the production capacity of the WEB source. 

The allocation from the new source set-aside in the first year of operation will be adjusted to 

account for the number of days that the source is operating in that first year. 

EXAMPLE. A new unit with a nameplate capacity of 400 MW is constructed at a power plant with two 

existing units with nameplate capacities of 400 MW and 300 MW. The two existing units install SO2

controls and reduce emissions to meet PSD requirements for the construction of the new unit. In this 

example, the source would continue to receive a floor and a reducible allocation for each of the existing 

units, and would also be eligible to receive an allocation from the new source set-aside for the new unit. 

Even though total SO2 emissions will decrease at this plant due to the construction of the new unit, the 

allowances allocated to the source will increase to reflect the increase in production capacity of 400 MW 

of electricity. If the new unit comes on line on July 1 the allocation for the first year will be reduced by 50 

percent because the unit was operational for half of the year. 

(2) Allocations from the new source set-aside will remain constant for the applicable WEB source 

and will be made on an annual basis by March 31 of each year for the current control period. When the 

next five-year allocation block is distributed as outlined in section 8.1 of this plan, all sources with an 

allocation under the new source set-aside will receive a five-year allocation block from the new source 

set-aside, and will continue to receive this allocation in future five-year allocation blocks. 

(3) Owners or operators of new WEB sources or modified WEB sources that meet the eligibility 

requirements of (1) may apply for an allocation from the new source set-aside by submitting a written 

request to the State of Arizona. 

(4) The State of Arizona will review the application for an allocation for accuracy and 

completeness, and will notify the source of intent to distribute allocations from the regional new source 

set-aside pending verification that allowances are available in the new source set-aside account. The State 

of Arizona will then forward the request to the TSA. 

(5) The TSA will document the date that the request is received by the TSA. Requests for 

allocation of allowances from the new source set-aside will be processed in the order received. The TSA 

will deduct the number of allowances requested from the regional new source set-aside that was 

established by the participating states and tribes, and will then record an equal number of allowances in 

the source’s compliance account for each remaining year of the five-year period. The TSA will then send 
Chapter 8 – SO2 Milestones/Backstop - 61 - Arizona Regional Haze SIP

written notification to the source and to the State of Arizona that the allowances have been recorded in the 

source’s compliance account. 

(6) If there are insufficient allowances remaining in the new source set-aside to fulfill the request, 

the source must to purchase the allowances required to demonstrate compliance. Any eligible WEB 

source that does not receive an allocation from the new source set-aside because the set-aside was 

depleted will be first in line to receive an allocation when the new source set-aside is increased in the next 

five-year period as outlined in Table 8-5 of this plan. If there is more than one such source, their 

allocation requests will be processed in the order they were received by the TSA. 

(7) A source that has received a retired source exemption and continues to receive an allocation as 

a retired WEB source is not eligible to receive an allocation from the new source set-aside. 

8.3.4. Regional Tribal Set-aside

 (1) Each year after the program is triggered, 20,000 allowances will exist as a tribal set-aside. 

(2) The tribal caucus of the WRAP has stated its intent to determine the means for distributing the 

allowances among the tribes within one year after the program trigger date. The State of Arizona 

understands that there will be a process that will meet the tracking and data security requirements of the 

allowance tracking system by which a tribe will move its set-aside allowances into the trading program 

for the purposes of trading. 

(3) The State of Arizona recognizes that the tribal set-aside allowances are bonus allowances for 

the tribes and, as such, are separate and additional to any allowances included in a tribal budget or the 

new source set-aside as outlined in the allocation report that is prepared in accordance with section 

8.1.3(6) of this plan. 

8.3.5. Opt-in Sources.

The WRAP Market Trading Forum has recommended including provisions in this plan that 

would allow smaller sources to opt in to the program. Opt-in sources may provide a more cost-effective 

way to reduce overall regional SO2 emissions, and therefore may strengthen the market incentives of this 

program. While the benefits of allowing sources to opt in to the program are important, the program must 

also provide safeguards to ensure that the integrity of the program is not affected. For example, it would 

be counterproductive to allow sources that were already planning to shut down to opt in to the program 

and then sell allowances to an existing source. In this example, regional emissions could slowly creep 

upward in a manner that is not consistent with the goals of the SO2 milestones. 

The State of Arizona is deferring inclusion of provisions for opt-in sources until a future SIP 

revision to allow time to thoroughly consider how to provide the flexibility and potential benefits to the 

market by expanding the program while also ensuring that the SO2 emission reduction goals are 

maintained.

8.3.6. WEB Allowance Tracking System (WEB ATS)

Section 40 CFR 51.309(h)(4)(v) requires a centralized system for the tracking of allowances and 

emissions. The centralized system will be referred to as the WEB Allowance Tracking System (WEB 

ATS or ATS). The WEB ATS must provide that all necessary information regarding emissions, 

allowances, and transactions is publicly available in a secure, centralized database. The ATS must ensure 

that each allowance is uniquely identified, allow for frequent updates, and include enforceable procedures 

for recording data. 
Chapter 8 – SO2 Milestones/Backstop - 62 - Arizona Regional Haze SIP

The State of Arizona will work cooperatively with other states and tribes participating in the 

WEB Trading Program to designate this system. The State of Arizona will be responsible for ensuring 

that all the ATS provisions are completed as described in this plan. 

The ATS will not exist unless the program is triggered. Prior to the implementation of the WEB 

Trading Program, a separate emissions tracking database will be employed to track the ongoing emissions 

of sources emitting SO2 at amounts equal to or greater than 100 tons per year. The emissions tracking 

database, which was used to track and measure SO2 emissions against the milestones, will still exist once 

the WEB Trading Program is triggered; however, it will become incorporated into the SO2 Allowance 

Tracking System. Both the emissions tracking database and the ATS will be centralized systems and data 

will be posted in an electronic, Web-based program and available to all persons. 

The participating states and tribes will contract with a common TSA to service and maintain the 

WEB ATS. It is envisioned that the ATS will require the use of a contracted consultant or database design 

engineer to create a secure, efficient and transparent tracking system. Because the ATS will be utilized by 

all states and tribes participating in the program, the design will require a uniform approach and level of 

security that will satisfy regional needs and concerns as well as meet the electronic, Web-based, access 

needs and security provisions. Due to the dynamic needs of the marketplace, the ATS will require a 

database that will reflect the current status of allowances and allowance transactions. The ATS will be 

operational within one year after the program trigger date. 

Specifications of the WEB ATS such as emissions tracking, the recording of allowance 

transactions, account management, system integrity and transparency are outlined in Appendix A-8b to 

this Plan. Appendix A-8b and requirements found in the state-specific rule detail how a WEB source will 

register for the ATS and how the source will, through an account representative, establish accounts, 

transfer allowances, and track unused allowances from a previous year. The account representative will 

also look to Appendix A-8b to determine the appropriate interface with the ATS. 

Neither the State of Arizona nor the TSA will adjudicate any dispute between the parties 

concerning the authorization of any account representative with regard to any representation, action, 

inaction, or submission of the account representative. 

As an example of how the WEB ATS will generally function, once the WEB Trading Program is 

triggered, a WEB source will have its allowance allocation determined. At the same time, the WEB 

source’s account representative will register for the ATS, and a compliance account will be established. 

Each allowance will be assigned a serial number. The allowance serial number will be used by the WEB 

ATS to track allowance allocations, transfers, and deductions, and to account for any unused allowances 

from a previous year. The serial number also will be assigned to each allowance recorded in a general 

account, which is an account for allowances that are not held to meet program compliance requirements. 

Furthermore, the ATS will track tribal allowance set-asides and new source allowance set-asides not yet 

assigned to either a compliance or general account. 

It is important to note that while this plan has provided a design for and an operational 

understanding of the ATS, the components of the ATS will need to be examined and possibly altered 

upon each required SIP revision. 
Chapter 8 – SO2 Milestones/Backstop - 63 - Arizona Regional Haze SIP

8.3.7. Allowance Transfers

(1) 40 CFR 51.309(h)(4)(viii) requires the Plan to include provisions detailing the process for 

transferring allowances between parties. Transfers are defined as the conveyance from one account to 

another account (compliance account or general account) of one or more allowances by whatever means, 

including but not limited to purchase, trade, or gift in accordance with the procedures established in the 

state-specific rule. This includes the transfer of allowances for the purpose of retirement. Once an 

allowance is retired, it is no longer available for transfer to or from any account. Allowances may be 

purchased by any person for the purpose of retirement. 

(2) The TSA will have specific recording duties involving transfers. These required procedures 

will be detailed in the service contract and will include the following activities. 

(a) Recording of Allowance Transfers. 

(i) Within five business days of receiving an allowance transfer, except when the transfer 

does not meet the requirements of the state-specific rule, the TSA will record an 

allowance transfer by moving each allowance from the transferor account to the 

transferee account as specified by the request, provided that the transfer is correctly 

submitted and that the transferor account includes each allowance identified in the 

transfer. 

(ii) Any allowance transfer that is submitted for recording following the allowance 

transfer deadline and that includes any allowances allocated for a control period prior to 

or the same as the control period to which the allowance transfer deadline applies will not 

be recorded until after completion of the compliance account reconciliation.

(iii) Where an allowance transfer submitted for allowance transfer recording fails to meet 

the requirements of the state-specific rule, the TSA will not record the transfer. 

(2) Notification of the Recording of Allowance Transfers. The TSA has specific responsibilities 

involving the notification of the recording of any transferred allowances, including the failure to 

record any transfer of allowances. Again, these required procedures will be outlined in the service 

contract, but include the following. 

(a) Within five business days of the recording of an allowance transfer, the TSA will 

notify the transferor’s and transferee’s account representatives of both accounts, and 

make the transfer information publicly available on the Internet. 

(b) Within five business days of receipt of an allowance transfer that fails to meet the 

requirements of the state-specific rule, the TSA will notify the account representatives of 

both accounts of the decision not to record the transfer, and the reasons for not recording 

the transfer. 

8.3.8. Use of Allowances from a Previous Year 

(1) Background. 40 CFR 51.309(h)(4)(ix) allows states to include in the plan provisions for the 

accounting of unused allowances from a previous year. The unused allowances may be kept for use in 

future years and there are restrictions on the use of the allowances in accordance with the state-specific 

rule. The federal rule also requires that allowances kept for use in future years may be used in calendar 

year 2018 only to the extent that the plan guarantees that such allowances will not interfere with the 

achievement of the 2018 milestone as outlined in Table 3 of this plan, adjusted according to the provision 
Chapter 8 – SO2 Milestones/Backstop - 64 - Arizona Regional Haze SIP

of sections 8.1.3(2) (3) and (4) of this plan. The state-specific rule addresses this by prohibiting the use 

after the year 2017 of allowances allocated for the years 2003 – 2017. This provision ensures that actual 

emissions will be less than the 2018 milestone because only allowances allocated for the year 2018 could 

be used to show compliance in that year. The provision also maintains flexibility by resetting the baseline 

to the year 2018 and then allowing sources to once again use extra allowances to show compliance in any 

future year. This flexibility is important for sources that have variable operations because the source may 

build up a reserve of unused allowances for use in a high production year. 

The Annex explains the benefits of allowing the WEB source to use unused allowances from 

previous years, including increased flexibility and early reduction stimulus. The risk in allowing the use 

of allowances carried from a previous year could be an increase in emissions in later years as the unused 

allowances are withdrawn for compliance. 

Because the regional haze SIP is based on reasonable progress requirements related to the 

remedying or prevention of any future visibility impairment, it is important to assure the use of these 

allowances will not interfere with attainment or maintenance of any reasonable progress goals. The 

safeguard employed here to mitigate this type of risk is termed, “flow control”, and is described in 

paragraph (2) below. 

(2) Flow Control Provisions. 

(a) At the end of each control period, WEB sources may transfer allowances in and out of their 

compliance account for a period of 60 days to ensure that the account will contain enough 

allowances to cover sulfur dioxide emissions during the previous year. At the end of the sixty-day 

transfer period, allowances shall be deducted from the compliance account of each WEB sources 

in an amount equal to the sulfur dioxide emissions of that source during the control period. 

(b) After the deductions have been completed, the Tracking System Administrator shall perform 

the following calculations and prepare a report according to 8.1.5 of this plan. 

(i) Determine the total number of allowances remaining in the allowance tracking system 

that were allocated for the just completed control period and all previous control periods. 

(ii) If the number calculated in (i) exceeds 10 percent of the milestone for the next control 

period, then the flow control procedures found in the state-specific rule shall be triggered 

for that next control period. These flow control provisions will discourage the excessive 

use of allowances that were allocated for an earlier control period without establishing an 

absolute limit on their use. WEB sources will maintain the option to use allowances 

allocated for an earlier control period, but will be required to use two allowances for each 

ton of SO2 emissions. Flow Control operates as follows. 

(A) The flow control ratio shall be calculated by multiplying 0.1 times the 

milestone for the next control period, divided by the total number of unused 

allowances remaining in the system. 

(B) To calculate the number of prior-year allowances that can be used without 

restriction by a source for the next control period, the TSA shall multiply the 

prior-year allowances by the flow control ratio. The resulting number of 

allowances may be used on a one-to-one ratio to show compliance with the 

source’s emission limitation. 
Chapter 8 – SO2 Milestones/Backstop - 65 - Arizona Regional Haze SIP

(C) The remaining prior-year allowances may be used on a two-to-one ratio to 

show compliance. Thus, WEB sources will maintain the option to use allowances 

allocated for an earlier control period, but will be required to use two of those 

allowances for each ton of SO2 emissions.

Example: On March 1, 2010 (the compliance transfer deadline for the 2009 control period) the Tracking 

System Administrator deducts allowances from the compliance account for each WEB source to cover 

2009 SO2 emissions from that source. After completing these deductions, the TSA reports the following 

information: 

Total number of allowances still in the system 

for the years 2003 – 2009 = 75,000 

2010 milestone (5-state, no smelter) = 508,223 

Percent of milestone = 14.75 % 

Because the number of allowances not used in previous control periods is greater than 10% of the 

milestone, flow control procedures are triggered. In the annual report required in XX.E.3.j(1)(6) the TSA 

will then calculate the flow control ratio for 2010: 

 0.1 x 2010 Milestone ÷ prior year allowances = flow control ratio 

 0.1 x 508,223 ÷ 75,000 = 0.67 

On March 1, 2011 (the compliance transfer deadline for the 2010 control period) the TSA will apply the 

2010 flow control ratio before deducting allowances from each WEB source’s compliance account 

WEB Source A 

2010 Allowances = 1,000 

Remaining Prior Year Allowances = 500 

2010 Emissions = 1,400 

In this example, the TSA would multiply the prior year allowances by 0.67 to determine the number of 

prior year allowances that could be used without restriction, at a one-to-one ratio. This would equal 335. 

The remaining prior year allowances would then be used at a 2:1 ratio. 130 allowances would be needed 

to cover the remaining 65 tons of SO2 emissions. The TSA would therefore deduct a total of 1,465 

allowances (1,000 + 335 + 130) to cover 1,400 tons of SO2 emissions. 

8.3.9. Monitoring/Recordkeeping

(1) For WEB sources subject to 40 CFR Part 75, the TSA shall use data that has been quality 

assured and finalized by the EPA. For WEB sources subject to a state-specific monitoring protocol, the 

State of Arizona will quality assure and finalize the data in accordance with these provisions for 

submission to the TSA. 

 

(2) The data will be verified and submitted to the emissions tracking database as soon as reasonably 

feasible after annual emissions are reported by the WEB sources. These timelines will be modified, as 

necessary, according to the monitoring protocols. 
Chapter 8 – SO2 Milestones/Backstop - 66 - Arizona Regional Haze SIP

8.3.10. Compliance and Penalties

(1) Compliance. When a WEB source exceeds its allowance limitation, the State of Arizona will 

require the TSA to deduct allowances from the following year’s allocation in an amount equal to two 

times the WEB source’s emissions of SO2 in excess of its allowance limitation. This deduction will be 

made from the WEB source’s compliance account after deductions for compliance are made. If sufficient 

allowances do not exist in the compliance account for the next control period to cover this amount, the 

State of Arizona will require the TSA to deduct the required number of allowances, regardless of the 

control period for which they were allocated, whenever the allowances are recorded in the account. 

(2) Penalties. The amount of the financial penalty shall be evaluated at each five-year SIP 

review, and adjusted to ensure that penalties per ton exceed the expected cost of allowances to ensure that 

this remains a stringent penalty. The state-specific rule establishes a penalty of $5,000 per ton for each 

ton of emissions above the source’s allowance limitation. This amount is in addition to the two 

allowances from the next year’s allocation to be deducted from the account for each one allowance of 

exceedance. For a violation of any provision of the market trading program, each day of the control 

period is a separate violation under Arizona’s rule, and each ton of excess emissions is a separate 

violation. 

8.3.11. Periodic Evaluation of the Trading Program.

(1) Annual Report. 

(a) Beginning one year after compliance with the trading program is required, the State of 

Arizona will obtain from the TSA an annual report that contains the following information: 

(i) the level of compliance program-wide; 

(ii) a summary of the use and transfer of allowances, both geographically and temporally; 

(iii) a source-by-source accounting of allocations compared to emissions; 

(iv) a report on the use of unused allowances from a previous year, in order to determine 

whether these emissions have or have not contributed to emissions in excess of the cap; 

and 

(v) the total number of WEB sources participating in the trading program and any 

changes to eligible sources, such as retired sources, or sources that emit more than 100 

tons of SO2 after the program trigger date. 

(b) Within 10 months after the allowance transfer deadline for each control period when 

compliance with the trading program is required, the TSA will prepare a draft report that lists: 

(i) the total number of allowances deducted for the control period, 

(ii) the total number of allowances remaining in the Allowance Tracking System 

allocated for that control period and any earlier control period, 

(iii) a proposed determination that flow control procedures have either been triggered or 

have not been triggered for the next control period, and 
Chapter 8 – SO2 Milestones/Backstop - 67 - Arizona Regional Haze SIP

(iv) if flow control procedures have been triggered, a draft flow control ratio calculated 

according to 8.3.8(2). 

(c) The State of Arizona will evaluate the draft report, and will propose a determination that flow 

control procedures either have been triggered or have not been triggered for the next control 

period. 

(d) The State of Arizona will publish a notice of availability of the draft report in newspapers of 

general circulation in Arizona, and will hold a 30-day public comment period. 

(e) After the comment period the State of Arizona will make a final determination that the flow 

control procedures either have been triggered or have not been triggered for the next control 

period. If the flow control procedures have been triggered, the State of Arizona will notify all 

WEB sources in Arizona that flow control procedures will be in effect during the next control 

period. 

(2) Five-year Evaluation. 

(a) The State of Arizona will work cooperatively with other participating states and tribes to 

conduct an audit of the WEB Trading Program no later than three years following the first full 

year of the trading program, and at least every five years thereafter. This evaluation does not 

replace the Plan assessments in 2008, 2013, and 2018. The evaluation will be conducted by an 

independent third party and include an analysis of: 

(i) whether the total actual emissions could exceed the values in Table 3 of this 

Implementation Plan of the WEB Trading Program even though sources comply with 

their allowances; 

(ii) whether the program achieved the overall emission milestone it was intended to 

reach; 

(iii) the effectiveness of the compliance, enforcement and penalty provisions; 

(iv) a discussion of whether states and tribes have enough resources to implement the 

WEB Trading Program; 

(v) whether the trading program resulted in any unexpected beneficial effects, or any 

unintended detrimental effects; 

(vi) whether the actions taken to reduce sulfur dioxide have led to any unintended 

increases in other pollutants; 

(vii) whether there are any changes needed in emissions monitoring and reporting 

protocols, or in the administrative procedures for program administration and tracking; 

(viii) the effectiveness of the provisions for interstate trading, and whether there are any 

procedural changes needed to make the interstate nature of the program more effective; 

and 

 

(ix) the integrity of the emissions and allowance tracking system, including whether the 

procedures for recording transactions are adequate, whether the procedures are being 
Chapter 8 – SO2 Milestones/Backstop - 68 - Arizona Regional Haze SIP

followed and in a timely manner, whether the information on sources’ emissions are 

accurately recorded, whether the emissions and allowance tracking system has 

procedures in place to ensure that the transactions are valid, and whether back-up systems 

are in place to account for problems with loss of data. 

(b) The public will have an opportunity to participate in this trading program evaluation. 

(c) In the event that any audit results in recommendations for program revisions, the State of 

Arizona, in consultation with the WRAP, will make appropriate modifications to this Plan. The 

State of Arizona will revise this Plan if the program is not meeting its emission reduction goals. 

(d) The State of Arizona will submit a copy of the report to the EPA regional office. 

8.3.12. Retired Source Exemption

The state-specific rule outlines the procedure that a WEB source must follow to receive a retired 

source exemption. The exemption would allow the source to continue to receive an allocation, but would 

exempt the source from monitoring and recordkeeping requirements that would serve no useful function 

for a source that has ceased operations. The State of Arizona (i.e., the Director) will notify the source of 

its obligation to apply for a retired source exemption upon the cancellation or relinquishment of a permit. 

To receive a retired source exemption, the source must submit a request for the exemption to the 

State of Arizona. The State of Arizona will review this request, and within 60 days of receipt of the 

request will notify the source that the retired source exemption has been granted or has been rejected. If 

the exemption has been rejected, the notification will contain an explanation of the reasons for rejecting 

the request. 

The TSA will record an allocation to a WEB source that has received a retired source exemption. 

However, the allowances will be recorded in a general account rather than a compliance account for the 

source. 

A WEB source that is permanently retired and that does not request a retired source exemption 

will forfeit all abandoned allowances in that source’s compliance account. The forfeited allowances will 

not be redistributed to other sources, and will be permanently retired from the Allowance Tracking 

System. During the next five-year allowance distribution period the retired source will not receive an 

allocation, and the allowances that would have been distributed to that source will be added to the new 

source set-aside. 

8.3.13. Integration into Permits

40 CFR 51.309 requires that the requirements for emissions reporting and for the trading program 

be incorporated into a permit that is enforceable as a practical matter by EPA and by citizens to the extent 

permitted by the Act. It is expected that all WEB sources will at least initially be subject to Arizona’s 

Title V permitting requirements. Arizona’s delegated Title V permitting program, the pre- and posttrigger requirements of the market trading program fall under the definition of “applicable requirements”, 

and will be incorporated into each source’s Title V permit. As found in the state-specific rule, any source 

that for any reason and at any time is not required to have a permit under the requirements of the statespecific rule, must obtain a New Source Review permit that incorporates the same requirements. Both 

types of permits are enforceable both federally and by citizens pursuant to Arizona’s SIP. 
Chapter 8 – SO2 Milestones/Backstop - 69 - Arizona Regional Haze SIP

8.4. 2013 SIP Revision; Backstop for Beginning of Second Planning Period

In addition to the requirements of 40 CFR 51.309(d)(10), the periodic SIP revision due in 2013 

will include the following information: 

a. Source specific allocations for all WEB sources in Arizona for the year 2018; and 

b. Either the provisions of a program designed to achieve reasonable progress for stationary 

sources of SO2 beyond 2018 or a commitment to submit a SIP revision containing the provisions of such a 

program no later than December 31, 2016. The program will ensure that the requirements of 40 CFR 

51.309 for the first planning period, including requirements that cannot be measured until after 2018, such 

as the determination of compliance with the 2018 milestone. 

This 2013 SIP revision will provide certainty to sources regarding their potential liability under 

the special penalty provisions for the year 2018 outlined in section 8.1.5 of this plan. The calculation of 

these allocations is delayed until 2013 to provide certainty about the number of sources that will qualify 

as WEB sources at that time; the allocations needed for new sources in the region, and the magnitude of 

renewable energy development and early reductions that will be included in the allocation process. It is 

difficult to estimate the impact of these factors in 2003 because circumstances may change during the 

next 10 years. 

If the 2018 milestone is not met, the starting point for the next planning period shall be the 2018 

milestones, not actual emissions in 2018. 

8.5 Geographic Enhancement Program

The requirements for geographic enhancement are discussed on page 35757 in the Preamble to 

the RHR (64 FR 35714, July 1, 1999). These requirements are related to Section 51.309(f)(1) which 

describes requirements for the Annex. The Annex allows states to submit a SIP, or tribes a TIP, which 

adopts an alternative measure to regional haze BART. Geographic enhancement is a voluntary approach 

that can be included in the Annex for addressing reasonably attributable visibility impairment (RAVI) for 

stationary sources, under the provisions of Section 51.302(c). RAVI is different from regional haze in 

that it addresses “hot spots” or situations where visibility impairment in a Class I area is reasonably 

attributable to a single source or small group of sources in relatively close proximity to the Class I area. 

The geographic enhancement approach would allow states or tribes to use the efficiencies and reduced 

cost provided by the market trading program in the Annex to accommodate situations where RAVI needs 

to be addressed. Additional information is contained in the WESTAR report, Recommendations for 

Making Attribution Determinations in the Context of Reasonably Attributable BART,

17 contained in 

Appendix A-8c. 

(a) Procedure for addressing Reasonably Attributable Visibility Impairment under the Regional 

Haze Rule. Pursuant to 40 CFR 51.309(f)(4), the State of Arizona shall use the following process 

to address reasonably attributable impairment (RAVI) in any Class I area, and the potential need 

for Best Available Retrofit Technology (BART), as specified in 40 CFR 302(c): 

(1) The State of Arizona will work with the National Park Service of the Department of Interior, 

and the U.S. Forest Service of the Department of Agriculture, on the agreed upon principles that 

will be followed for addressing RAVI within the context of regional SO2 milestones and a 

backstop emission trading program that have been developed to address regional haze. As part of 

 

17 WESTAR , “Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable 

BART”, report to WRAP, [Date] 
Chapter 8 – SO2 Milestones/Backstop - 70 - Arizona Regional Haze SIP

the Federal Land Managers’ obligation to protect the visibility in the areas that Congress has 

designated as mandatory Class I Federal areas, in the course of certifying impairment, the 

National Park Service or U.S. Forest Service may make recommendations to the State of Arizona 

regarding a source or sources to which impairment may be reasonably attributable. Within the 

context of established regional milestones for SO2 and a backstop trading program, the National 

Park Service and U.S. Forest Service will use the following screening process in making these 

recommendations as part of the certification process: 

(i) The National Park Service or U.S. Forest Service determines that sulfate concentrations are not 

decreasing since the year 2000, based on ambient monitoring, and 

(ii) There are BART-eligible sources of sulfur dioxide within 150 km of the mandatory Federal 

Class I area, and 

(iii) The BART-eligible sources have not installed control technology to reduce sulfur dioxide 

emissions at a rate equivalent to capture of 85% of potential annual emissions. 

(2) In approximately 2009 to 2010, but no later than December 2010, the State of Arizona will 

conduct a public meeting to facilitate the exchange of information regarding current visibility 

monitoring data at Class I areas in Arizona or in nearby states within 100 miles of any BARTeligible sources located in Arizona. The purpose of the meeting will be to provide as much 

information as possible to all interested parties about the potential for a certification to occur. 

The information will include visibility trends, as well as the type of impairment that is occurring 

at individual areas (e.g., haze, episodic impairment, and other types of screening criteria). The 

goal of this meeting is to provide information to sources and to the trading market so that 

potential problems could be addressed in the most cost-effective manner. 

(3) If the National Park Service or U.S. Forest Service certifies impairment, the State of Arizona 

will fulfill its obligation to determine attribution and if necessary determine BART for the 

applicable source or group of sources in accordance with Arizona's SIP for visibility protection 

submitted to EPA in Chapter 5 of this Implementation Plan. 

(i) The WESTAR report titled Recommendations for Making Attribution Determinations in the 

Context of Reasonably Attributable BART, contained in Appendix A-8c, periodically augmented 

by new techniques and information available at the time of review, will be used to provide a 

toolbox of appropriate technical criteria and techniques for determining attribution. 

(ii) If attribution is determined, then the following alternative remedy solutions will be considered 

when determining BART for the applicable source: 

(A) BART-level controls could be installed on the attributed source or group of sources; 

(B) SO2 emission reductions that may be more cost-effective or have other air quality benefits 

could be required at nearby sources in lieu of, or in combination with controlling the attributed 

source to achieve greater visibility improvements that the application of BART. 
Chapter 9 – Mobile Sources - 71 - Arizona Regional Haze SIP

9. LONG-TERM STRATEGY FOR MOBILE SOURCES

9.1. Regulatory History and Requirements

In its June 1996 Report, the GCVTC recommended EPA move forward on new national vehicle 

emission and fuel standards to reduce emissions from mobile sources. The GCVTC also recommended 

other regional and local strategies be considered to manage mobile source emissions. One of the local 

strategies was to establish emission budgets for those pollutants in urban areas shown to significantly 

contribute to visibility impairment in any of the 16 GCVTC Class I areas. The budget caps were to be set 

at the 2005 emission levels. 

When EPA finalized the RHR in July 1999, the rule acknowledged the GCVTC recommendations 

related to national vehicle emission and fuel standards. EPA included a status of planned actions on those 

recommendations as of July 1999 (Preamble to the regional haze rule, 64 FR 35753). EPA noted these 

new measures were over and above those included in the RHR for mobile sources that simply required a 

cap on emissions in significantly contributing urban areas at the 2005 level. EPA also indicated that 

emission reductions resulting from new standards adopted after the RHR was approved would be 

creditable toward reasonable progress. EPA also committed to work with the states if new national 

standards impacted the efficacy of regional or local strategies. 

After the RHR rule was finalized, EPA established new standards for on-road vehicle emission 

and fuel standards (65 FR 6698). As a result, current mobile source emission projections developed by 

WRAP for the GCVTC Transport Region indicate overall mobile source emissions will decline 

continuously from 2003 through the end of the SIP planning period in 2018, which exceeds the level of 

emission reductions that EPA approved as meeting reasonable progress; i.e., holding mobile source 

emissions from major urban areas to their lowest level during the planning period. In addition, new 

standards for non-road vehicles were proposed by EPA on April 15, 2003, and are expected to be 

finalized in the near future. These new standards for non-road vehicles will further reduce overall mobile 

source emissions. 

At the April 2003 WRAP Board meeting, the WRAP approved a recommendation that EPA 

modify the RHR eliminating the current requirements related to mobile source emission significance 

determination and budgets for urban areas (40 CFR 309(d)(5)), and replace those requirements with a new 

requirement focused on tracking mobile source emission reductions resulting from national standards to 

assure reasonable progress. This action was based on the finding that emissions of all pollutants from onroad and non-road mobile sources, except for sulfur dioxide from non-road engines, are expected to 

decline significantly through 2018. The overall emission trends for mobile sources are summarized in 

Table 9-1 contained in Section 9.2, below, with additional details contained in Chapter 5 of the WRAP 

TSD. If EPA adopts new low-sulfur standards for non-road mobile sources, then non-road mobile source 

sulfur dioxide emissions would also decline dramatically through 2013 with a very small increase 

expected through 2018. 

On July 3, 2003, EPA issued a proposed rule (68 FR 39888) and a direct final rule (68 FR 39842) 

to amend the mobile sources provision of the Regional Haze Rule consistent with the recommendations of 

the WRAP. One adverse comment was received, so the direct final rule was withdrawn. On December 

22, 2003, EPA promulgated the final rule (68 FR 71009) changing the mobile source requirements in 40 

CFR 51.309. The revisions changed the requirements under 40 CFR 51.309(d)(5)(i) and eliminated the 

previous requirements under 40 CFR 51.309(d)(5)(ii & iii) for setting mobile sources emissions budgets 

using the lowest projected level as a planning objective and performance indicator for each urban area. 
Chapter 9 – Mobile Sources - 72 - Arizona Regional Haze SIP

The former 40 CFR 51.309(d)(5)(iv), which addresses the other GCVTC mobile source 

recommendations, was retained as 40 CFR 51.309(d)(5)(ii). The new Section 51.309(d)(5)(i)(A) requires 

statewide inventories of mobile source emissions, for each 5-year implementation plan reporting period 

required under 40 CFR 51.309(d)(10), to be reviewed to demonstrate a continuous decline in emissions of 

each pollutant of concern over the planning period through 2018. Should mobile source emission not 

decline as expected, the State of Arizona will review control options for mobile sources and determine if 

additional controls are needed, consistent with the criteria for reasonable progress. If the State of Arizona 

determines that additional controls are needed, Arizona will prepare a revision to the implementation plan 

within one year after the progress report is due under 40 CFR 51.309(d)(10)(i), as required under 40 CFR 

51.309(d)(10)(ii)(D). 

In addition to the new revisions to 40 CFR 51.309(d)(5)(i) and the elimination of the former 

Sections 51.309(d)(5)(ii) and (iii), a backstop provision as outlined by the WRAP was added. The new 

40 CFR 51.309(d)(5)(i)(B), requires the State of Arizona to assess the need for any long-term strategies to 

address SO2 from non-road mobile sources by no later than December 31, 2008. Under this provision, 

Arizona will determine if a SIP revision is necessary to address SO2 from mobile sources by considering 

whether the emission reductions anticipated or achieved by any Federal standards in place addressing fuel 

sulfur content for non-road engines are sufficient to meet reasonable progress. 

 

To assist in the investigative and deliberative process related to mobile source emissions and their 

significance, ADEQ established a Mobile Source Work Group (MSWG) made up of a wide range of 

Arizona stakeholders including industry, environmental, metropolitan planning organization 

representatives, and regulators. The MSWG monitored the WRAP Mobile Source Forum process and 

work products. In addition, the MSWG collected and analyzed data to assist in the deliberative process. 

The MSWG provided ADEQ tabular information on projected emissions in addition to recommendations 

for the mobile source regional haze SIP component. The MSWG issued a final memoranda summarizing 

findings and recommendations to ADEQ that are contained in Appendix A-9a, entitled “Arizona Mobile 

Source Work Group Findings and Recommendations Related to Mobile Source Emissions.” 

9.2. Inventory of Current and Projected Emissions from Mobile Sources

(a) Inventory of Current and Projected Emissions from Mobile Sources. Pursuant to 40 CFR 

51.309(d)(5)(i)(A), the State of Arizona, in collaboration with the WRAP, assembled a comprehensive 

statewide inventory of mobile source emissions. This is summarized in Table 9-1, and is described in 

detail in the WRAP TSD in Chapter 1 and Chapter 5. This emission inventory showed the year with the 

lowest level of emissions would be at the end of the SIP planning period in 2018 instead of 2005 as 

anticipated by the GCVTC. The substantial reduction of projected mobile source emissions from 2003 to 

2018 is due to the adoption of new on-road vehicle emission and fuel standards by EPA. The figures in 

Table 9-1 do not include the anticipated reduction from the pending proposal to reduce sulfur content of 

non-road sources. 

Table 9-1. Statewide Mobile Source Emissions for Arizona (Tons per Day) 

Year VOC NOx PM2.5 SO2 Total 

1996 553.2 655.0 37.2 33.3 1,278.7

2003 448.7 496.5 23.0 20.9 989.1

2008 319.9 381.2 22.0 10.0 733.1

2013 256.9 296.7 19.1 9.5 582.2

2018 222.0 237.3 18.0 18.6 495.9

Source: 1996 from WRAP 1996 Base Emission Inventory 

 2003-2018 from WRAP Mobile Source Worksheets 
Chapter 9 – Mobile Sources - 73 - Arizona Regional Haze SIP

(b) Program to assure continuous decline in mobile source emissions. Pursuant to 40 CFR 

51.309(d)(5)(i)(A), the State of Arizona commits to monitoring the emissions from mobile sources to 

assure a continuous decline in emissions as defined in 40 CFR 51.309(b)(6). If Arizona determines that a 

continuous decline in emissions is not being achieved, additional control measures will be reviewed to 

determine if they are needed to demonstrate reasonable progress. If Arizona determines such measures 

are needed, Arizona will submit an SIP revision to address the identified control measures. 

(c) Backstop provision to address potential increase in non-road emissions in the event proposed 

Federal standards are not finalized. Pursuant to 40 CFR 51.309(d)(5)(i)(B), the State of Arizona 

commits to provide for a SIP revision no later than December 31, 2008, containing long-term strategies 

necessary to reduce emission of SO2 from non-road mobile sources consistent with the goal of reasonable 

progress. The need for a SIP revision will be determined by a consideration of the emission reductions 

achieved or anticipated to be achieved by proposed Federal standards should those standards addressing 

fuel sulfur content for non-road engines not be in place. 

9.3. Other GCVTC Strategies for Mobile Sources

Pursuant to 40 CFR 51.309(d)(5)(ii), the State of Arizona has reviewed the other mobile source 

recommendations contained in the GCVTC report. The results of that review are included in Chapter 13 

of this SIP that addresses all recommendation of the GCVTC report, including mobile source 

recommendations. 
Chapter 9 – Mobile Sources - 74 - Arizona Regional Haze SIP

(This page intentionally blank) 

 
Chapter 10 – Fire Programs - 75 - Arizona Regional Haze SIP

10. LONG-TERM STRATEGY FOR FIRE PROGRAMS

10.1. Regulatory History and Requirements

In its 1996 final report, the GCVTC recognized that past land management practices, including 

decades of fire suppression, have led to an increase of accumulated forest fuels. Wildfires are becoming 

larger in size, unnaturally destructive, and more dangerous and costly to control. Fire, however, is a 

component of most natural ecosystems in the West and therefore must be a component of processes to 

meet land management, human health and visibility objectives. The GCVTC recognized that prescribed 

fire and wildfire levels are projected to increase significantly for decades to come, and that programs to 

minimize emissions and visibility impacts, and to educate the public, should be implemented. 

The Regional Haze Rule (40 CFR 51.309(d)(6)) requires documentation that all federal, state and 

private prescribed fire programs in the state evaluate and address the degree of visibility impairment from 

smoke. In addition, a statewide inventory and emissions tracking system must be established for volatile 

organic compounds, nitrogen oxides, elemental and organic carbon, and fine particle emissions from fire. 

Any administrative barriers to the use of alternatives to burning should be identified and removed where 

possible along with an enhanced smoke management program based on specific criteria that addresses 

visibility as well as health and nuisance objectives. Finally, annual emission goals for fire shall be 

established, in cooperation with states, tribes, federal land managers and private entities, to minimize 

emissions increases from fire to the maximum extent feasible. 

The WRAP's effort to document and understand the incidence of fire and its effect on visibility in Class I 

areas has been extensive and productive. Chapter 6 of the WRAP TSD, “Assessment of Fire Programs,” 

details the results of WRAP’s analyses of fire on visibility to date. Different emission reduction scenarios 

for the 2018 projected inventories were the basis for the analyses. WRAP modeling shows that emissions 

from fire will continue to affect visibility for some time on an episodic basis. 

10.2. Prescribed Fire Program Evaluation

Pursuant to 40 CFR 51.309(d)(6)(i), the State of Arizona evaluated the State’s Enhanced Smoke 

Management Plan and all Federal, State, and private prescribed fire smoke management programs in the 

State, based on the potential to contribute to visibility impairment in the 16 Class I areas of the Colorado 

Plateau, and how visibility protection from smoke is addressed in planning and operation. The State of 

Arizona relied upon the WRAP report Assessing Status of Incorporating Smoke Effects into Fire Planning 

and Operations (see Appendix A-10a) as well as EPA’s Interim Air Quality Policy on Wildland and 

Prescribed Fires (see Appendix A-10b) as a guides for making this evaluation along with input from a 

stakeholder-based work group familiar with the policies and regulations related to fire and land 

management within the State. The State of Arizona also evaluated whether the State’s existing fire 

regulations as part of an Enhanced Smoke Management Plan contained the following elements: actions to 

minimize emissions; evaluation of smoke dispersion; alternatives to fire; public notification; air quality 

monitoring; surveillance and enforcement; and program evaluation. The result of this evaluation process 

was the determination that revisions to Arizona’s existing fire regulations, R18-2-602, “Unlawful Open 

Burning,” and Article 15, “Forest and Range Management Burns,” would be necessary. 

10.3. Emission Inventory and Tracking System

The State of Arizona has made revisions to R18-2-602, “Unlawful Open Burning,” and Article 

15, “Forest and Range Management Burns,” to allow for the tracking of all types of fire in the State. 
Chapter 10 – Fire Programs - 76 - Arizona Regional Haze SIP

These state-approved rules along with the related public participation and review process, can be found in 

Appendix A-10c, with Appendix A-10d containing supporting information related to the promulgation of 

these rules. Most of the changes made to Article 15 relate directly to the requirement of Section 

309(d)(6), including to the collection and recording of burn data. Changes to R18-2-602 allow Arizona to 

meet the tracking requirements in 12 counties throughout the state. The three remaining counties, 

Maricopa, Pima and Pinal, have their own fire rules (Maricopa County Rule 341; Pima County Rule 

17.12.480, et seq.; and Pinal County Rule 3-8-700 and 3-8-710.). The three counties will revise their 

existing rules to comply the requirements of R18-2-602. The State of Arizona commits to submit updated 

county rules based on the revised Arizona rules in a SIP revision by December 31, 2004. 

In addition to its own emissions tracking, the State of Arizona will review the WRAP data on 

post-burn activity and utilize the WRAP’s regional emission tracking system. In addition, fire emission 

inventory updates will be provided in future progress reports, as part of the periodic SIP revisions, 

pursuant to 40 CFR 51.309(d)(10). See Appendix A-10e, entitled, Policy on Fire Tracking Systems for 

further information on the emissions inventory and tracking system to be utilized by Arizona. 

10.4. Strategy for Use of Non-burning Alternatives

The State of Arizona is continuing to develop a process with key public and private entities, 

including the State Department of Agriculture, State Land Department, Federal Land Managers’, farming 

and forestry associations, etc. to identify and remove administrative barriers to the use of non-burning 

alternatives to prescribed fire on federal, state, and private lands, pursuant to 40 CFR 51.309(d)(6)(iii). 

The process is collaborative and provides for continuing identification and removal of administrative 

barriers, and considers economic, safety, technical and environmental feasibility criteria, and land 

management objectives. This process is outlined in the related sections of the Arizona fire rules (see 

Table 10.1, “Alternative to fire”). In developing this process, the State of Arizona will rely on two 

documents: (1) Nonburning Alternatives for Vegetation and Fuel Management (see Appendix A-10f), and 

(2) Burning Management Alternatives on Agricultural Lands in the Western United States (see Appendix 

A-10g), prepared by the WRAP that describe a variety of non-burning alternatives and methods of 

assessing their potential applicability. 

 

10.5. Enhanced Smoke Management Program

Pursuant to 40 CFR 51.309(d)(6)(iv), the smoke management programs that operate within 

Arizona are consistent with the WRAP Enhanced Smoke Management Programs for Visibility (see 

Appendix A-10h). This approach calls for programs to be based on the criteria of efficiency, economics, 

law, emission reduction opportunities, land management objectives, and reduction of visibility impacts. 

The WRAP Enhanced Smoke Management Programs for Visibility lists the previously identified elements 

under 40 CFR 51.309(d)(6)(i) as well as adding “burn authorization” and “regional coordination” 

elements to ensure visibility protection and to meet the designation of “enhanced.” 

An Enhanced Smoke Management Plan (ESMP) comprises a series of key policies and 

management practices. In general the ESMP must specifically address visibility effects and apply to all 

fire sources as do all smoke management plans in the State of Arizona. The ESMP should also apply 

uniformly to source sectors or be tailored to source sectors and/or geographical areas. In addition, the 

ESMP must provide the opportunity to work collaboratively with state, tribal, local, and federal agencies, 

and private parties while considering the criteria of efficiency, economics, law, emission reduction 

opportunities, land management objectives, and reduction of visibility impact. The State of Arizona 
Chapter 10 – Fire Programs - 77 - Arizona Regional Haze SIP

ESMP meets all of these requirements. The State of Arizona will conduct annual meetings of all affected 

parties to discuss smoke management issues and objectives. 

Arizona’s Article 15 (R18-2-1501-1515), Forest and Range Management Burns, and R18-2-602 

(Section 602), Unlawful Open Burning, upon revision now includes the following specific elements 

required of an ESMP, and are enumerated in the Table 10-1. 

Table 10-1. Inclusion of ESMP Elements Into Arizona Regulations 

Enhanced Smoke Management Plan Element Rule Citation 

Actions to minimize emission from fire R18-2-1509 

R18-2-602(D)(3)(e) 

Evaluation of smoke dispersion R18-2-1506 and 1510 

R18-2-602(D)(3)(m) and (o) 

R18-2-602(B)(3)(d) 

Alternative to fire R18-2-1503(C)(8), 1503(D) and 

1503(G) 

R18-2-602(H)* 

Public notification of burning R18-2-1513 

R18-2-602(D)(3)(g) 

Air quality monitoring R18-2-1508 and 1511 

R18-2-602(H)* 

Surveillance and enforcement R18-2-1514 

R18-2-602** 

Program evaluation R18-2-1503 

R18-2-602(H)* 

Burn Authorization R18-2-1505 and 1508 

R18-2-602(D)(3)(g) 

Regional Coordination R18-2-1513 and 1515 

R18-2-602(H)* 

* R18-2-602(H) allows the State of Arizona to examine at its annual meeting any need 

 to address monitoring, regional coordination, or alternatives to burning as they arise 

 in an overall discussion of program evaluation for unlawful opening burning. Issues 

 that could arise in these areas are difficult to determine ahead of time, and are driven 

 by proximity and volume. 

** Any violations under R18-2-602 have penalty authority under Arizona Revised 

 Statute 49-501. A copy of ARS 49-501 can be found in Appendix A-10i. 

10.6. Annual Emission Goal

Pursuant to 40 CFR 51.309(d)(6)(v), efforts will be made within the State of Arizona to minimize 

emission increases in fire, excluding wildfire, to the maximum extent feasible, through the use of annual 

emission goals, in accordance with the WRAP Annual Emission Goals for Fire (see Appendix A-10j). 

 The Annual Emission Goals for Fire recognizes that Emission Reduction Techniques (ERTs) can 

be used to minimize emissions from fire. The State of Arizona commits to the establishment of a 

collaborative mechanism for setting annual emission goals, and development of a process for tracking 

their attainment on a yearly basis. The authority to proceed with this commitment can be found in 

Arizona’s revised Article 15, subsection 1503 and 1509. It can also be found in the tracking timeline 
Chapter 10 – Fire Programs - 78 - Arizona Regional Haze SIP

contained within Arizona’s revised R18-2-602 rule. A list of current ERTs is contained in the rule 

appendix to R18-2-602. 

 The projection and tracking of ERT use is a minimum element of the quantifiable annual 

emission goal. The Annual Emissions Goal will utilize the projection of total emissions inventory for 

prescribed fire and agricultural burning, as provided by the emissions inventory and tracking systems 

outlined in Section 10.3 of this chapter, such that the effect of projected emission reduction techniques or 

percentage of ERT use is shown in relation to projected total emissions. Should projected annual 

emissions not be available, the State commits to submit a timeline to develop the necessary inventory. 

Where ERT use or other emission reduction methods cannot be quantified with confidence due to the 

current state of the science (such as for agricultural burning), the State of Arizona commits to participate 

in the development of further refinements in emission reduction or emissions averted calculation 

methodologies. 

The use of ERTs to meet the 51.309(d)(6)(iv) requirement, as with the ESMP, is subject to 

economic, safety, technical and environmental feasibility, and land management objectives. 
Chapter 11 – Road Dust - 79 - Arizona Regional Haze SIP

11. AREA SOURCES OF DUST EMISSIONS FROM PAVED 

AND UNPAVED ROADS

11.1. Regulatory History and Requirements

In its 1996 report to EPA Recommendations for Improving Western Vistas the GCVTC stated that 

dust emissions from vehicles traveling on paved and unpaved roads are generally near-field transport 

issues rather than long-range transport issues, especially with respect to larger, coarse materials that settle 

out of the atmosphere before being transported long distances. Due to considerable uncertainty regarding 

the ability of emission and air quality models to accurately characterize the contribution of road dust to 

visibility impairment, the GCVTC also recommended further analysis to resolve the uncertainties 

regarding both near-field and distant effects of road dust prior to recommending any remedial actions. 

As a result, the Regional Haze Rule (40 CFR 51.309(d)(7)) requires states to assess the impact of 

dust emissions from paved and unpaved roads on regional haze in the 16 Class I areas located on the 

Colorado Plateau in the SIPs due by December 31, 2003. The WRAP, the GCVTC’s successor 

organization, analyzed this issue, including efforts to improve methods for estimating road dust emission 

inventories as applied to regional scale modeling and characterization of transport and deposition. The 

WRAP’s modeling work demonstrated road dust is not a measurable contributor on a regional level to 

visibility impairment in the 16 Class I areas. Due to this finding, no additional road dust control 

strategies are needed in the current SIP. The State of Arizona, in consultation with the WRAP, will 

perform further assessments of road dust impacts on visibility in the 16 GCVTC Class I areas in the 

progress updates and status reports due in 2008, 2013 and 2018. Based on these assessments, if road dust 

emissions are determined to be a significant contributor to visibility impairment, the State of Arizona 

commits to implement emissions management strategies to address the impact as necessary and 

appropriate to demonstrate reasonable progress. 

11.2. Strategy for Road Dust Sources

Impact of paved and unpaved road dust emissions and contribution to visibility impairment 

finding. Pursuant to 40 CFR 51.309(d)(7), a regional scale assessment was made by the WRAP of the 

impact of dust emissions from paved and unpaved roads from transport region states on the 16 Class I 

areas of the Colorado Plateau. Chapter 7 of the WRAP TSD contains the results of the following 

technical work: (1) a summary of 1996 and 2018 emission inventories for re-entrained road dust from 

paved and unpaved roads; (2) a description of the definition of significance for road dust in the 16 Class I 

areas; (3) road dust modeling results – regional versus localized air quality impacts; and (4) a discussion 

of WRAP’s finding of no measurable contribution to regional haze. Based on these findings, no emission 

management strategies have been identified at this time. 

Tracking of Road Dust Emissions. The State of Arizona commits to track road dust emissions 

with the assistance of the WRAP, and provide an update on paved and unpaved road dust emission trends, 

including any modeling or monitoring information regarding the impact of these emissions on visibility in 

the Colorado Plateau 16 Class I areas. These updates shall include a re-evaluation of whether road dust is 

a measurable contributor to visibility impairment. These updates shall be part of the periodic SIP 

revisions, pursuant to 40 CFR 51.309(d)(10). 
Chapter 11 – Road Dust - 80 - Arizona Regional Haze SIP

(This page intentionally blank) 
Chapter 12 – Pollution Prevention - 81 - Arizona Regional Haze SIP

12. POLLUTION PREVENTION AND RENEWABLE ENERGY 

PROGRAMS

12.1. Regulatory History and Requirements

In its 1996 Report, the GCVTC recommended several pollution prevention strategies from 

education to supporting development of renewable energy sources. The GCVTC also identified regional 

goals of renewable energy usage of 10% by 2005 and 20% by 2015. These are referred to below as the 

“10/20 goals.” The GCVTC also recommended that progress towards this goal should be evaluated every 

five years, in conjunction with regular reviews of emissions reductions and progress toward the national 

visibility goal.18 40 CFR 51.309(d)(8) includes the regulatory language for the GCVTC’s 

recommendations. 

 

The Air Pollution Prevention (AP2) Forum was created in September, 1998 by WRAP to study 

the issues related to pollution prevention required in 40 CFR 51.309(d)(8), and to develop work products 

the states and tribes could rely on when developing SIPs. The AP2 Forum’s documents may be found at 

www.wrapair.org. These include information related to identifying barriers and policies that could lead to 

increased investment in renewable energy and energy efficiency in the Grand Canyon Visibility Transport 

Region. The Forum also performed an analysis related to potential emissions reductions, energy cost 

savings, and secondary environmental and economic benefits of meeting the GCVTC’s 10/20 goals. 

The Arizona Department of Environmental Quality established a Pollution Prevention Work 

Group (P2WG) to assist in developing the material necessary for this SIP. The P2WG included 

representatives from utilities, environmentalists, state energy regulators, and local regulators. The P2WG 

work products relied upon the work of the WRAP AP2 Forum, and independent research necessary to 

assemble the materials in this chapter. 

Arizona's P2WG reviewed WRAP's policy on renewable energy and energy efficiency. 

Appendix A-12a entitled “Arizona Pollution Prevention Work Group Review of WRAP Policy on 

Renewable Energy and Energy Conservation” contains a copy of a comment letter sent to WRAP's Air 

Pollution and Prevention Forum (AP2 Forum) along with a copy of the WRAP Policy entitled, 

"Renewable Energy and Energy Efficiency As Pollutuion Prevention Strategies For Regional Haze." 

12.2. Approach to Addressing Requirements Under 40 CFR 51.309(d)(8)

Pursuant to 40 CFR 51.309(d)(8), the following sections, (1) identify, describe and/or inventory 

programs being implemented by various companies, organizations and agencies in the State of Arizona, 

including renewable energy programs, incentive programs, programs to preserve and expand energy 

conservation efforts, and programs to demonstrate progress towards renewable energy goals; and (2) 

project emission reductions, visibility improvements and other impacts anticipated to result from such 

programs. Arizona’s approach to address the specific requirements of 40 CFR 51.309(d)(8) are 

summarized in Table 12-1. 

 

18 Recommendations for Improving Western Vistas, Grand Canyon Visibility Transport Commission; Western 

Governors' Association: Denver, CO, June 10, 1996, page 30. 
Chapter 12 – Pollution Prevention - 82 - Arizona Regional Haze SIP

Table 12-1. Arizona’s Approach to Address 40 CFR 51.309(d) Requirements 

Citation in 

40 CFR 51.309(d) 

Description of 

Requirement 

Addressed 

in Section 

(d)(i) Description of Existing Pollution Prevention Programs 12.3 

(d)(i) Renewable Energy Generation Capacity and Production 12.4 

(d)(i) Summary of Anticipated Renewable Energy Contribution 12.5 

(d)(ii) Incentive Programs 12.6 

(d)(iii) Programs to Preserve and Expand Energy Conservation 12.7 

(d)(iv) Potential for Renewable Energy 12.8 

(d)(v) Projection of Pollution Prevention Programs on Visibility 12.9 

(d)(vi) Programs Relied on to Achieve GCVTC Renewable Goals 12.10 

(d)(vi) Future Progress Reports 12.11 

The inclusion in the SIP of these programs and estimated emission reductions and impacts shall 

not render such programs and estimates mandatory and/or federally enforceable, nor are such programs or 

estimates relied on for purposes of meeting the visibility goals established as part of the SIP planning 

process. These programs are voluntary or state programs that were never intended to be federally 

enforceable, and the projected emission reductions are estimates only. It is expected that these programs 

and the associated emissions impacts will change over time and will be reflected in the progress reports 

for 2008, 2013, and 2018 required under 40 CFR 51.309(d)(10). 

12.3. Description of Existing Pollution Prevention Programs in Arizona

Pursuant to 40 CFR 51.309(d)(8)(i), Tables 12-2 and 12-3 summarizes all pollution prevention 

programs currently in place in Arizona. Table 12-2 summarizes the renewable energy programs currently 

in place. Table 12-3 summarizes the energy efficiency programs currently in place for Arizona. Table 

12-4 summarizes planned renewable energy projects as of 2002. 

Table 12-2. Summary of Renewable Energy Programs Currently in Place in Arizona 

Program Title Program Description 

Environmental 

Portfolio 

Standard 

The Arizona Corporation Commission (ACC) approved rules implementing the Environmental 

Portfolio Standard, in March 2002 (ACC R14-2-1618). The standard requires a minimum percentage 

of retail electricity sales to be from eligible solar electric or “environmentally friendly renewable 

electricity technologies.” Technologies included are: photovoltaics, solar thermal resources that 

generate electricity, solar water heaters, solar air conditioning systems, in-state landfill gas generators, 

wind generators, and biomass generators. The standard began with 0.2% in 2001, rises to 1.1% in 

2007, and then remains stable until 2012. 

2001 0.2% 

2002 0.4% 

2003 0.6% 

2004 0.8% 

2005 1.0% 

2006 1.05% 

2007-12 1.1% 

At least 50% of the portfolio standard must be solar electric in early years, increasing to 60% solar 

electric in 2004. The portfolio includes incentives or “extra credit multipliers” for early installation, 

for installation in Arizona, for using equipment manufacturers in Arizona, for use in “distributed” 
Chapter 12 – Pollution Prevention - 83 - Arizona Regional Haze SIP

Program Title Program Description 

applications or various programs including green pricing, net metering, solar leasing, or customersited systems. This standard only applies to electric suppliers who are regulated by the Arizona 

Corporation Commission. It does not apply to municipal utilities, irrigation districts, electrical district, 

and other quasi-governmental utilities. Further information can be found at the Arizona Corporation 

Commission website, http://www.cc.state.az.us/utility/electric/R14-2-1618.htm

 2001/2002Arizona Environmental Portfolio Standard Results (in kWh Credits1) 

 2001 2002 

Arizona Public Service 

Solar Electricity (Utility) 17,237,202 9,126,664 

Solar Hot Water 6,541,328 2,208,334 

Solar Air Conditioning --- --- 

Landfill Gas 11,307,931 44,938,574 

Biomass --- --- 

Wind --- --- 

Total 34,786,461 56,273,572 

 (99.1% of requirement) (59.68% of requirement) 

 

Tucson Electric Power 

Solar Electricity (Utility) 2,990,538 9,006,169 

Solar Hot Water --- --- 

Solar Air Conditioning --- --- 

Landfill Gas 6,884,068 16,024,836 

Biomass --- --- 

Wind --- 388,070 

Total 9,874,606 25,419,075 

 (71.7% of requirement) (79.31% of requirement) 

 

Citizens Communications 

Solar Electricity 152,000 39,000 

Total 152,000 39,000 

 (6% of requirement) (1% of requirement) 

 

Navopache Electric 

Landfill Gas 150,000 644,377 

Total 150,000 644,377 

 (50% or requirement) (50% or requirement) 

 

1 The portfolio includes incentives or “extra credit multipliers” for early installation, for installation in 

Arizona, for using equipment manufacturers in Arizona, for use in “distributed” applications or 

various programs including green pricing, net metering, solar leasing, or customer-sited systems. 

Therefore the Total number of actual kWh achieved is less than the kWh credits shown in the table 

above. Further information can be found at http://www.cc.state.az.us/utility/electric/R14-2-1618.htm. 

The lead agency in implementing this strategy is the Arizona Corporation Commission.

Regulated 

Utility 

Customer 

Funding or 

System Benefit 

Charge Funding 

for Renewables 

Regulated utilities in Arizona have utility customer funding or system benefit charge (SBC) funding to 

support low income, demand-side management (DSM), environment, renewables, and other programs 

beneficial to society. A portion of the funds is targeted to the development of renewable energy, 

including the support of the Environmental Portfolio Standard. System benefit charges (SBC) are 

funds approved by the state’s regulatory oversight body, the Arizona Corporation Commission. 

Further information can be found at: http://www.cc.state.az.us/utility/electric/rules-electric.htm

Arizona Public Service: 2002 -- $7 million in approved spending, of which $6 million was used for 

renewable energy programs and technology development, and $1 million for low-income customer 
Chapter 12 – Pollution Prevention - 84 - Arizona Regional Haze SIP

Program Title Program Description 

support. In addition, under the EPS program, APS collected an additional$6,571,745 for renewable 

energy programs in 2002.

Tucson Electric Power: 2002 --$3 million in approved SBC spending, of which $2 million was for 

renewable energy programs and $1 Million for low income and energy efficiency programs. In 

addition, the EPS surcharge collected $2.4 million for renewables. 

Salt River 

Project 

Customer 

Funding 

Salt River Project (SRP) has a SBC that supports customer assistance programs, renewable energy 

development and maintenance, and other programs. Since December 31, 1998, the SBC has generated 

approximately $123 million. In 2002, this generated $3.8 million in funding for renewable resources. 

In addition, SRP designated additional program funding each year and plans to continue this funding 

in future years. SRP customers support renewable energy programs through the SRP EarthWise 

Energy green pricing program. Revenues received from these premiums are used to build new 

renewable energy projects in the community. 

Government 

Purchase 

Requirements 

ARS 34-452 Arizona law requires that new state building projects over six thousand square feet follow 

prescribed solar design standards and that solar improvements be evaluated on the basis of life cycle 

costing. Such new buildings include state office buildings, school districts, community college 

districts and universities. These projects must include evaluation of (a) proper site orientation, (b) 

active and passive solar energy systems for space heating, (c) solar water heating, and (d) use of solar 

day-lighting devices. The life cycle costing requirements state that solar energy and energy 

conservation design, equipment and materials shall be used if the simple payback in energy savings is 

eight years or less. http://www.azleg.state.az.us/ars/34/00452.htm

Consumer 

Education and 

Information 

Million Solar Roofs program – educates consumers on solar products and encourages them to install 

photovoltaics on homes and businesses. 

The major utilities in the state operate programs to market the renewable energy they produce. 

APS – Solar Partners 

SRP- EarthWise Energy 

TEP-Greenwatts 

APS has programs to educate customers about renewable energy and energy efficiency. Examples 

include: Project SOL (http//:projectsol.aps.com) where customers can learn about solar power and see 

how they can be used to generate electricity; the APS Solar Test and Research Center 

(www.aps.com/solar) where customers and students are provided tours of one of the leading solar 

research center in the world to see and learn about the latest in solar technology; and the APS web site 

www.aps.com where anyone with access to the web can keep abreast of APS’ many renewable and 

energy efficiency programs including home energy audits and energy savings and conservation 

information. 

SRP also has a Customer Support Group that helps with program development and evaluation, and to 

assist in communicating program messages to the community. 

The Arizona Solar Energy Industries Association operated the Solar Options in Arizona program 

through their hotline for consumer education. They also have homeowners’ association education 

program on installation of solar hot water systems. 

Arizona Solar Center is a website run by a non-profit offering a variety of information for consumers. 

Tucson Coalition for Solar – conducts an annual home tour and ongoing education on renewable 

energy. 

Net Metering In 1981, the ACC adopted a net metering rule (Decision No. 52345) requiring the state’s regulated 

utilizes to offer net metering for renewable and cogeneration resources with the capacity of 100 

kilowatts or less. Excess electricity generated by the system is purchased at each utility’s avoided 

cost. Further information can be found on the net metering rule at: 

http://www.eren.doe.gov/greenpower/netmetering/index.shtml#AZ

Arizona Public Service (APS) company filed in 1994 to allow net billing of all renewable energy 

generators under 10kW. Net excess generation under the APS tariff is purchased at the utility’s 

avoided cost. 
Chapter 12 – Pollution Prevention - 85 - Arizona Regional Haze SIP

Program Title Program Description 

Tucson Electric Power Company (TEP) filed two net metering tariffs in 1996 that were revised in 

2003. The first is Tariff 101which applies to all qualifying non-firm customers, and Tariff 102 applies 

to all qualifying firm customers. Under both tariffs, net metering is allowed for QFs whose maximum 

monthly usage is 100 kW or less. These tariffs are for customers who have installed either a single 

solar to electricity or wind to electricity conversion system of AC electrical peak capability of 10 kW 

or less, and meet all TEP qualifications. Excess net generation is credited to the customer’s account 

each billing month (when applicable), and credits may be applied throughout the calendar year. 

However, each January any remaining credit to the customer’s account will be zeroed out.

Information 

Disclosure 

1996 Arizona Corporation Commission Rule R14-2-1617 

ACC adopted disclosure provisions as part of the 1996 Retail Electric Competition Rules. Under the 

disclosure provision, all retail suppliers of electricity must disclose composition, fuel mix, and 

emissions characteristics upon request. http://www.cc.state.az.us/utility/electric/rules-electric.htm

Green Pricing Arizona Public Service Solar Partners APS was the first utility in the state to develop a green energy 

option for its customers in 1996 with the APS Solar Partner Program. APS customers have the option 

to support the development of solar power in APS service territory by purchasing 15kWh of 100% 

solar power for $2.64 though the APS Solar Partner Program. Customers may choose as many 15 kWh 

blocks of solar power as they wish. The funds raised go towards the development of additional new 

solar power plants for APS Solar Partners. APS has installed a combination of fixed, tracking and 

concentrating solar technologies and will continue to install new solar power plants that are the most 

cost effective for our customers. www.aps.com/solarpartners

Salt River Project: SRP provides a solar energy purchase option to its customers. Dubbed EarthWise 

Energy, SRP customers can purchase 100-watt block of solar power capacity for $3.00 per month. For 

more details see http://www.eren.doe.gov/greenpower/gp_munipu.html#srp

TEP Green Watts: Launched in January 2000, Green Watts is a TEP program that enables supporters 

to invest directly in the creation of “green” power. For each Green Watt that a customer adopts, TEP 

will generate 20-kilowatt hours per moth from renewable energy resources. The first Green Watt is 

$2.00 and each additional Green Watt is $1.50. This amount appears as a line item on a customer’s 

monthly statement. Every ten Green Watts that are adopted save a ton of coal per year from being 

used and encourages environmental conservation in Southern Arizona. 100% of the dollars raised go 

directly to building and maintaining renewable facilities in Arizona. 

http://greenwatts.com/gw_pages/gw_Home.html

Economic 

Incentive for 

Renewable 

Manufacturers 

Arizona’s Environmental Portfolio Standard provides extra credit for Arizona solar-electric capacity 

that incorporates Arizona-built components. From the rules (C.2.b): In-State Manufacturing and 

Installation Content Extra Credit Multiplier: Solar electric power plants shall receive up to a .5 extra 

credit multiplier related to the manufacturing and installation content that comes from Arizona. The 

percentage of Arizona content of the total installed plant cost shall be multiplied by .5 to determine the 

appropriate extra credit multiplier. So, for instance, if a solar installation included 80% Arizona 

content, the resulting extra credit multiplier would be .4 (which is .8 X .5). 

Financial 

Incentives 

Environmental Technology Facility Credit – Allows a personal or corporate income tax credit of 10% 

of the cost of construction of a qualified environmental technology manufacturing, producing or 

processing facility. (Source: DSIRE Database http://www.ncsc.ncsu.edu) 

Solar and Wind Energy System Tax Credit- ARS-43-1083, ACC R14-2-1618, Provides a personal 

income tax credit of 25% of the cost of a solar or wind energy device. (Source: DSIRE Database 

http://www.ncsc.ncsu.edu) 

Solar and Energy Equipment Tax Exemption – Provides a retail sales tax exemption of up to $5000 for 

solar and wind energy equipment. Legislation http://www-solar.mck.edu/finance/AZ08.htm (Source: 

DSIRE Database http://www.ncsc.ncsu.edu/dsire.htm) 

APS offers the APS EPS Credit Purchase program. This program provides a financial incentive to 

APS customers for the installation of solar electric and solar water heating systems on customer 
Chapter 12 – Pollution Prevention - 86 - Arizona Regional Haze SIP

Program Title Program Description 

homes. Customers that choose to include Photovoltaic systems on their homes or businesses can 

receive $2.00 per watt-dc for the installation of systems up to 5 kW. In addition, APS also provides an 

incentive to customers that replace or supplement electric water heaters with solar water heating. 

Customers receive $350 for the professional installation of a new solar water heating system. APS 

pays these customers for opportunity to use the environmental benefits from these systems to meet its 

own EPS goals. Once the system is professionally installed, the customer submits the application to 

APS and APS pays the customer directly. http://www.aps.com/my_community/Solar/eps.html

TEP SunShare: Launched in 2002, TEP’s SunShare program is designed to encourage customers to 

install new photovoltaic equipment at their residence or business. TEP currently offers two options for 

those who are interested in investing in solar. SunShare, option #1, requires that customers provide 

their own photovoltaic equipment while SunShare Kit, option #2, requires that customers purchase the 

solar equipment from TEP. Under the SunShare programs, systems of 1kW to 5kW are eligible. The 

customer may either purchase a qualifying system, 1kW thru 5kW, from a third party or may purchase 

one to five 1-kW system kits from TEP. Under SunShare, option #1, TEP will credit the customer 

$2,000 per AC kW of proven, installed solar generating capacity. Under the SunShare Kit, option #2, 

TEP will credit the customer $2,000 for each 1kW system, up to $10,000 for five systems. The kit 

includes panels, inverter, supports, meter, and meter socket. The retail cost for a 1 kW solar kit is 

approximately $9,000 plus installation costs. However, a kit purchased from TEP will cost $4000 after 

the $2000 credit. TEP also offers a net metering option which credits the customer with the energy 

sent into the grid on a kWh basis. http://greenwatts.com/gw_pages/gw_sunshare.html

Table 12-3 summarizes the energy efficiency programs currently in place for Arizona. There is a 

long list of energy efficiency programs, including programs offered by the State Energy Office and the 

utilities. Summaries of the programs are provided. A few programs have listed quantification 

information in terms of energy savings or program expenditures; many are not quantified because this 

type of information is currently not available. 

Table 12-3. Summary of Energy Efficiency Programs in Place in Arizona 

Program Title Program Description 2002 Status Ref. 

Arizona Energy 

Office, Arizona 

Dept of 

Commerce 

The Energy Office’s $2.3 million annual budget is 

funded through a combination of federal funds and 

Petroleum Violation Escrow funds. 

Director: Craig Marks 

(602) 771-1139 

craigm@azcomerce.com

http://www.azcommerce.com?energy/default.asp

The Energy Office’s mission is to encourage 

energy efficiency and renewable-energy 

usage, provide energy education and 

community outreach, offer policy advise to 

the Executive and Legislative branches, and 

help Arizona low-income residents to reduce 

their utility bills and improve their comfort 

and safety. 

3,4 

Low Income 

Weatherization 

The Energy Office administers Arizona’s $3 annual 

million (federal and private funds), low-income, 

weatherization program. The primary mission of 

this program is to reduce the energy required for 

space heating and cooling for income eligible 

households applying for assistance through one of 

ten sub-grantees, statewide. This program receives 

its primary funding from the U.S. Department of 

Energy and the U.S. Department of Health and 

Human Services. The program also leverages 

additional funds through partnership with utilities, 

17,000 homes weatherized to date. 

In 2002, 695 homes were weatherized 

statewide, with present- value utility savings 

of three million dollars. 

In addition to approximately $2.2 million in 

federal funds, the utilities provided the 

following: 

2002 Utility Funding: 

3 
Chapter 12 – Pollution Prevention - 87 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

and other federal and state housing programs. 

Many aspects of the Residential Training and 

Technical Assistance Programs are now 

incorporated into the training of Weatherization 

sub-grantees, which assures that savings are 

maximized. 

The following are done under the program: 

• Adding thermal insulation to the 

residential building envelope, most 

typically attic insulation. Shading sunexposed windows, primarily for houses 

using central refrigeration cooling. 

• Implementing air leak control measures to 

reduce excessive infiltration of outside air. 

• Testing, tuning and maintaining heating 

and cooling equipment. 

• Reducing duct leakage where heating and 

central refrigerated air is distributed by a 

forced air system. 

• Installing low-flow showerheads and other 

general energy and water efficiency 

measures. 

• Other energy conservation improvements 

as identified by the home energy auditor. 

SW Gas $350,000 

APS $302,397 

TEP $180,000 

Citizens $68,885 

Co-ops $4,500 

Total $905,782 

Special Project 

Grants 

The Energy Office administers the State Energy 

Project – Special Project Grants. Each year states 

submit proposals in response to a DOE solicitation 

identifying how specific technologies could be 

implemented in their region of the country. DOE 

then selects the projects that best meet national 

energy goals. The Energy Office publicizes grant 

availability, helps prepare grant applications, and 

administers grants. The Energy Office is currently 

administering $2,865,375 SEP Special Project 

funds. 

2002 Special Project Awards

$800,000 to Pinnacle West for Hydrogen 

Power Park 

$75,000 to Tucson USD for Tucson Solar 

Schools 

$100,000 for Teaching Energy Conservation

Supports Implementation of Energy Codes in 

Tucson Metro Area and Southern Arizona 

Communities 

$25,000 for Tucson Regional Clean Cities 

Coordinator 

$48,808 to AZ Energy Office to Film New 

Solar in Arizona Documentary 

$45,000 to Energy Office for State Industries 

of the Future Program 

Federal IOF – 9 Industries Targeted to 

Improve Energy Efficiency and Productivity, 

and to Manage Waste Streams 

AZ IOF Chapter Will Target 4 of the Federal 

IOFs – Agriculture, Aluminum, Forest 

Products, and Mining 

Goal – Establish Industry, Government, 

University Partnerships, With MOU Executed 

by 2004. 
Chapter 12 – Pollution Prevention - 88 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

ResidentialMarket Training 

and Technical 

Transfer 

Over 30,000 new homes are built each year in 

metro-Phoenix, making it one of the largest new 

home markets in the United States. Thousands 

more homes are built each year in other fastgrowing Arizona communities. Improving the 

energy efficiency of new homes has an enormous 

impact on Arizona’s energy usage. 

The Energy Office has long partnered with Arizona 

utilities to provided technical assistance and 

training for the building trades on the latest energy 

efficiency technologies and techniques, including: 

Infrared imaging to analyze insulation 

performance; 

Smoke generation to show duct leakage; and 

Using pressure diagnostics, such as the blower door 

testing, duct blasters, and digital monometers, to 

confirm envelope integrity. 

Overall the goal is to encourage builders and 

subcontractors to take a scientific systems approach 

to home construction and incorporate energyefficient techniques into the building process. 

Arizona’s largest HVAC contractor now seals 

all ductwork, which has saved Arizonans over 

$27 million in energy bills since 1997. 

Over the past year, in partnership with the 

home-building industry and Arizona utilities, 

the Arizona Energy Office provided 23 days 

of training to over 2,500 attendees from the 

building-trades industry. 

Because of the innovations and techniques 

brought to the market, builders have helped 

develop and introduce Energy Star-certified 

homes into the Arizona market. Energy Star 

is a joint program offered by the U. S. 

Environmental Protection Agency and the U. 

S. Department of Energy. Energy Star 

certification requires a home to be 30% more 

efficient than the 1995 Model Energy Code, 

which saves the average homebuyer 

approximately $400 a year. Of the 34,000 

Energy Star homes built nationally in 2001, 

over 8,000 were built in Arizona. 

Arizona homebuilders are also national 

leaders in offering guaranteed heating and 

cooling costs. These homes are typically 40% 

to 50% more efficient than required by the 

1995 Code, and have guaranteed annual 

heating and cooling costs of approximately $ 

.30 per square foot. Regional and national 

homebuilders now market entire subdivisions 

where each home comes with guaranteed 

energy bills. 

Municipal Energy 

Management 

Program 

The MEMP (Municipal Energy Management 

Program) encourages and assists in the 

development and implementation of energy 

management programs by facilitating the planning 

process and providing the necessary basic tools, 

staff training and technical assistance. As part of 

MEMP, the Energy Office makes funds available 

for energy saving projects. Those eligible to apply 

include incorporated Arizona cities, towns, 

counties, improvement districts, and Indian tribes 

with populations under 70,000. 

 

The MEMP approach to energy conservation is a 

simple and direct step-by-step approach. The first 

step is to understand where energy is being 

consumed and how much it costs, based on the 

utility bill analysis and audits. The second step 

identifies strategies for lowering energy costs. The 

third step assists in incorporating energy 

management into future development through an 

energy management plan. 

$150,000 awarded to Arizona communities in 

2002 
Chapter 12 – Pollution Prevention - 89 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

Federal Energy 

Management 

Program 

Goal: reduce the cost and environmental impact of 

the federal government by advancing energy 

efficiency and water conservation, promoting the 

use of distributed and renewable energy, and 

improving utility management decisions at federal 

sites. 

Funds are occasionally available to the Arizona 

Energy Office to partner with Indian communities 

and military bases or other federally-owned 

facilities 

Ak Chin Community. This outreach was 

funded by thee Western Area Power 

Administration and FEMP. The Energy 

Office performed the following services for 

the Community: 

Residential Energy Audits 

Weatherization 

Training

Market Design 

Initiatives 

Salt River Project’s M-Power is a residential 

prepayment program, which uses a special electric 

meter located outside the home, a small display 

unit located inside the home and smart cards, which 

work in a way similar to prepaid telephone calling 

cards. The SRP M-Power display shows how 

much energy is used daily and hourly, and when to 

buy more energy via the smart cards. With actual 

information on cost of consumption, customers 

conserve and can save as much as 10% on electric 

bills. At the same time, SRP reduces turn-off and 

turn-on costs, while improving customer 

satisfaction. 

 

Regulated 

Utility Customer 

Funding or 

System Benefit 

Charge Funding 

for Energy 

Efficiency 

Tucson Electric Power: 2002 --$3 million in 

approved SBC spending, of which $2 million was 

for renewable energy programs and $1 million for 

low income and energy efficiency programs. 

Arizona Public Service: 2002 - $7 million in 

approved spending, of which $6 million was used 

for renewable energy programs and technology 

development, and $1 million for low-income 

customer support and other programs. In addition, 

under the EPS program, APS collected an 

additional $6,571,745 for renewable energy 

programs in 2002. 

See also the listing in Table 12-2 under the heading 

Regulated Utility Customer Funding or System 

Benefit Charge Funding for Renewable Energy. 

 

Residential New 

Construction and 

New Home 

Guarantee 

Programs 

To help promote the value of energy efficient 

residential construction, APS works with builders 

and building material vendors to provide buyers 

with a heating and cooling guarantee. All 

participating builders must offer their homebuyers 

a 2-year guarantee that the monthly costs to heat 

and cool their home will be less than a specified 

amount. APS has promoted the concept of 

guaranteed heating and cooling bills through a 

multi-media campaign including TV, print, on-line, 

and point-of-sale materials. 

In 1997, TEP designed and implemented the first 

utility operated new home guarantee program in the 

nation. The program philosophy addresses the 

Currently four of the top ten production 

builders in the Phoenix metro area are 

participating in the program and over 3500 

home lots have been committed. 

Since inception to December 2002, there were 

5590 homes either completed, in some 

progress of completion or waiting for 
Chapter 12 – Pollution Prevention - 90 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

issues of affordability, durability, comfort, health 

and safety using scientific laws of airflow, 

moisture-flow and pressure management within a 

home. Homes are constructed to high standards set 

by TEP and include on-site inspections of framing 

areas related to energy performance, insulation 

installation, and HVAC system design and 

installation. On-site testing is also provided to 

measure duct leakage, whole-house infiltration and 

pressure management within the home under 

various operating conditions. If a home passes all 

inspection and testing criteria, the homeowner 

receives a guarantee from TEP that heating and 

cooling costs will not exceed a predetermined 

average cost per day (calculated on each separate 

model home) and a guarantee for comfort for a preset time period. Homes permitted prior to February 

20, 2003 receive a 3-year guarantee and homes 

permitted after February 20, 2003 receive a 5-year 

guarantee. Homeowners who purchase a TEP 

Guarantee home qualify for a specially designed 

rate-tariff that reduces the cost of all electricity 

used in the home by 12% annually compared to the 

standard residential electric rate. The homeowners 

also have the option to increase this electric rate 

savings to either 18% or 22% depending on their 

selection of TOU and/or the installation of solar 

water heating systems. 

construction to begin. The program is 

operated within the utility structure with 

quality control provisions and the guarantee 

provided by a utility. All TEP Guarantee 

Homes qualify for ENERGY STAR since the 

qualifications from TEP are more stringent 

than ENERGY STAR. TEP provides the 

DOE/EPA program documents to customers 

along with the Guarantee certification. 

New 

Construction 

Energy 

Efficiency 

Research and 

Training

In partnership with the Arizona Energy Office, 

APS has conducted extensive research and testing 

on new residential construction with blower doors, 

duct blasters, infrared cameras, and other 

diagnostic tools. The result of these tests is a list of 

building construction details that need the most 

focus to improve home performance. In 1998, APS 

and the Arizona Energy Office began offering 

Building Science training for residential builders. 

TEP hosts quarterly education programs to target 

audiences of builders, sub-contractors, and 

city/county code officials, architects and 

consumers. These programs are designed to 

educate all audiences on the scientific approach of 

building new homes or retrofitting existing homes 

to gain the maximum benefit in affordability, 

durability, comfort and health and safety. TEP also 

adds matching funds for grants provided to the City 

of Tucson ‘Teaching Energy Conservation’ project 

which educates consumers, builders, contractors, 

consumers and code officials on various 

conservation related issues. 

The SRP-Certified Home (SCH) program was 

introduced in May 1995. For a subdivision to be 

In 1998, APS and the Arizona Energy Office 

began offering Building Science training for 

residential builders. To date, over 2000 

building industry members have attended. 

Coupled with the heating/cooling guarantee 

program, this has resulted in substantial 

improvements in the real world performance 

of residential new construction as confirmed 

through field studies by the Arizona Energy 

Office. 

Between 1999 and 2002, approximately 
Chapter 12 – Pollution Prevention - 91 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

SRP certified, SRP works directly with the builder 

to ensure that each home design meets our energyefficiency standards. SRP certification means the 

home design includes certain energy-efficient 

features. Certification is based on the SRPCertified Homes Point Sheet that primarily is a 

construction specification trade-off system. With 

the system, one design feature may be substituted 

for another if the overall design complies with the 

SRP-Certified Home energy consumption 

standard. Between 1999 and 2002, approximately 

21,000 SCH contracts were signed. 

In 2002 SRP announced a new addition to the SRPCertified Home program. Energy Code 

Compliance certification is now available upon 

request. SRP can provide REM/Design compliance 

reports for 1998/2000 International Energy 

Conservation Codes (IECC), CABO Model Energy 

Code (MEC), and ASHRAE 90.2 By adding the 

new "Code Compliance" feature to the program we 

can now assist builders in meeting the energy 

efficiency codes required by the various 

municipalities. 

21,000 SCH contracts were signed. 

Qualified 

Contractor 

Program

APS offers referrals to customers seeking qualified, 

professional HVAC contractors for service or 

replacement of their existing AC/heat pumps. To 

qualify for the program, residential HVAC 

contractors are required to meet stringent 

requirements and complete ongoing rigorous APS 

education courses for their service technicians. 

To date, APS has subsidized technical training 

for over 6000 service technicians. APS 

currently provides free contractor referrals to 

approximately 4000 customers each year, 

ensuring that units are properly serviced and 

installed. 

High Efficiency 

Appliance 

Programs 

APS High Efficiency Air Conditioners Program 

For several years APS has worked with the air 

conditioner contractor community. This 

partnership has been instrumental in moving the 

market for resale air conditioners and heat pumps 

to high efficiency equipment. Evidence suggests 

that the resale market is about 90% 12 SEER, 

which is 15% more efficient than standard 

equipment, reducing demand and energy 

consumption. 

SRP Rebates on Highly-Efficient Refrigerators and 

Heat Pumps – Over the last several years, SRP has 

independently offered customers rebates on highly 

efficient refrigerators and heat pumps. 

Since 1998, APS and contractors have 

distributed over 20,000 copies of the 

Consumer’s Guide to an Energy Efficient Air 

Conditioning System as an education tool for 

customers. 

SRP has issued more than 8,500 rebates on 

refrigerators labeled by ENERGY STAR® as 

exceeding federal standards and more than 

1,000 rebates on heat-pumps with a 13-SEER 

rating that also meet additional strict criteria. 

Time of use rates APS Time of use rates - Approximately 40% of all 

residential customers are on a time of use rate. It is 

one of the highest penetrations of TOU rates in the 

country. APS is one of the only utilities nationwide 

to offer a demand rate for residential customers. 

Most new APS customers apply for one of the two 

 
Chapter 12 – Pollution Prevention - 92 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

TOU rates. Evidence suggests it reduces demand 

and shifts load. A recent survey of customers 

indicates that over 75% of TOU customers do shift 

some of their energy use to off-peak time periods. 

Customers feel it gives them control over their 

electric bill and helps conserve peak energy. 

SRP has approximately 140,000 customers on our 

peak-load shifting program, Time-of-Use (TOU). 

Residential TOU customers average 75% off-peak 

usage annually, while non-TOU residential 

customers average 72% - 73% off-peak usage 

annually. The result of TOU is that SRP has been 

successful in shifting 2%-3% of our average annual 

energy consumption to off-peak. 

Peak Reduction 

Campaign 

Commercial Peak Reduction Campaign -- Since the 

summer of 2001, APS has promoted a voluntary 

summer peak energy management initiative with 

commercial customers. Participating customers 

pledge to save energy on extreme summer days 

when temperatures exceed 110 degrees in Phoenix. 

Customers receive an email on “Peak Power Days” 

asking them to turn thermostats up two degrees, 

turn off unnecessary lights and equipment, and 

adjust the schedule of energy-intensive processes. 

The campaign has helped shave peak consumption 

and heightened awareness of the need to save 

energy on extreme summer days. 

 

Shade Trees 

Campaign 

The TEP Trees Program promotes energy 

conservation and the environmental benefits 

associated with planting low-water usage trees and 

other vegetation. Desert-adapted trees have been 

provided to residential neighborhoods, low-income 

families, public areas and schools by TEP. The 

residential trees are to be located on the south, west 

and east sides of homes in the TEP service area 

with the objective of continuing positive 

community service as well as providing DemandSide Management (“DSM”) benefits. 

Residential Program: There were 3,000 trees 

distributed to roughly 1,500 homes for the period 

January 1, 2002 through December 31, 2002. 

School and Community Programs: For the period 

January 1, 2002 through December 31, 2002, this 

program provided 105 fifteen-gallon-sized and 41 

five-gallon-sized trees to 43 schools. In addition, 

63 community projects received 115 fifteen-gallonsized and 111 five-gallon-sized trees. 

 
Chapter 12 – Pollution Prevention - 93 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

Energy 

Efficiency 

Education 

APS provides a free on line energy analysis on 

aps.com. It allows customers and prospective 

customers to analyze their home and business 

energy use and identify customized energy efficient 

measures. APS provides seasonal energy savings 

tips online and in customer bill inserts. 

SRP Energy Savings Solutions Campaign 

Energy Savings Solutions (ESS) is a multi-media 

campaign, which runs from May through 

September. The goal of ESS is to educate 

customers about effective energy management. 

ESS provides customers with useful and easy ways 

to lower their energy usage and enables customers 

to make informed decisions everyday by 

demonstrating how home energy conservation 

efforts can help reduce energy costs. 

TEP provides free class sets of booklets to schools 

in its area, including, "Learning to Save Energy", 

which is geared to grades 3-5. TEP also offers 

teacher training and back up materials for two 

hands-on activities: The Insulation Station (which 

deals with residential energy issues) and The 

Energy Patrol (where a class or group of students 

learn about energy efficiency, and then try to 

"patrol" their school, helping remind others how to 

save energy). TEP also provides seasonal energy 

tips on-line and in mailings to customers and 

handouts at presentations.

 

Energy Star Customer Education on Purchasing Decisions 

SRP has been an ENERGY STAR® partner since 

1999. This DOE/EPA program establishes stricter 

efficiency criteria for new products. As a partner, 

SRP has been able to not only increase awareness 

of ENERGY STAR, but also to provide 

information for customers so that they can make 

informed purchase decisions. This information has 

been incorporated into our monthly newsletters and 

our Energy Savings Solutions campaign and has 

also been heavily featured in on-going publications 

to both residential and commercial customers via 

Powerful Solutions and eNews.

 

Energy 

Efficiency Audits 

For approximately the last two years, SRP has been 

working with third party contractors and other 

entities such as the Arizona Department of 

Commerce to provide free or low cost energy 

efficiency audits and educational programs to 

energy consumers in the commercial, industrial and 

government sectors. The focus of the programs to 

date has been on high-efficiency lighting retrofits, 

energy information services, and improvements to 

compressed air systems. 

 
Chapter 12 – Pollution Prevention - 94 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

TEP offers the Energy Advisor, a quick, free, 

online analysis of a home's or business's monthly 

energy use, as well as suggestions on how to reduce 

energy costs.

State Energy 

Efficiency 

Demonstration 

Program 

Working with the Department of Administration 

and agency facility managers, the Energy Office 

provides training, technical assistance and funding 

to implement energy savings and demand-reduction 

measures in state-controlled facilities. Matching 

grant program. 

Ongoing. 

State Facility 

Managers 

Training Program 

Based on results of the forensic audits and utility 

tracking, the Energy Office provides training and 

technical assistance to state facility management 

staff with the goal of identifying actions that may 

be taken to decrease electricity consumption in 

state facilities. This training will assist facility 

managers in performing diagnostics on their 

facilities, complete retrofits on equipment and 

buildings, and track energy consumption. 

Ongoing. 

Energy Efficient 

Schools 

Energy Office partnership with School Facilities 

Board. A jointly funded engineer works with 

architects and vendors to incorporate cost-effective, 

energy-efficient designs and equipment.

Energy audits of existing facilities are also 

available. 

Significant opportunities have been found in 

replacement of HVAC package units, lighting 

retrofits, and central heating and cooling 

systems, for a total avoided energy costs of 

$8,916,197 per year. 

State Energy 

Code 

HB 2541 (2001) Is a voluntary model energy code 

(AZ=home rule). This bill designates the State 

Energy Code as a legislative tool to create 

incentives for the use of energy saving devices and 

practices. It established a State Energy Code 

Advisory Commission to review and recommend 

changes to the State Energy Code. 

http://www.azleg.state.az.us/legtext/44leg/2r/bills/h

b2451p/pdf

Energy Code Advisory Commission. Code 

Advisory Commission members were 

appointed. First meetings held by the 

Energy Office to provide technical support to 

Arizona municipalities 

In 2001, the Energy Office applied for and 

received a $100,000 grant from the U. S. 

Department of Energy to build on the 

legislative initiative and to initiate an outreach 

and training program for municipalities, 

governmental entities, code officials, and the 

building industry on codes and the impact on 

Arizona’s energy consumption. In 2002, 

Energy Office efforts on codes are being 

concentrated in the areas of 1) codes adoption, 

and 2) training provided to the building 

industry designed to help insure that structures 

designed to code will also perform as 

designed. 

1 

Governor’s 

Awards for 

Energy 

Efficiency 

The Energy Office recognizes local governments, 

state agencies, and educational institutions for 

exceptional energy-conservation accomplishments. 

The 2002 Governor's Awards for Energy 

Efficiency were presented to Arizona cities, 

educational institutions and state government 

agencies in recognition of successful energy 

conservation programs. 

 

Awards of Excellence, the highest honor, went 

to the City of Bullhead City, Arizona School 

Facilities Board, Mesa Unified School District 

and the Tucson Unified School District. 
Chapter 12 – Pollution Prevention - 95 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

The City of Tucson received Awards of Merit 

for two energy-saving projects. Awards of 

Merit were also given to the City of Coolidge, 

Arizona Department of Administration, 

Arizona Department of Public Safety and the 

Arizona Department of Game and Fish. The 

Arizona Department of Emergency and 

Military Affairs received Awards of Merit for 

two energy-conservation projects. 

In addition, Awards of Special Recognition 

were bestowed on the City of Tucson, Arizona 

Department of Administration, Arizona 

Department of Emergency and Military 

Affairs, Isaac Elementary School District and 

the Scottsdale Unified School District. The 

City of Mesa and the City of Phoenix both 

received Awards of Special Recognition for 

two energy-saving projects. 

http://www.azcommerce.com/Energy/eaward.

htm

Rebuild America U.S. D.O.E. Program supported by Arizona Energy 

Office. - Helps businesses and communities reduce 

energy use in buildings. 

Ongoing. Energy-efficiency seminar 

presented to Arizona school officials in 

September 2002. 

1 

Green Buildings Green buildings are use design and construction 

practices that significantly reduce or eliminate the 

negative impact of buildings on the environment 

The concept includes: 

- Sustainable site planning 

- Safeguarding water and water efficiency 

- Energy efficiency and renewable energy 

- Conservation of materials and resources 

- Indoor environmental quality 

City of Scottsdale Green Building Program. 

This is weighted rating checklist that 

emphasizes a system’s approach by requiring 

26 prerequisites. Established in 1998, 47 

builders, 129 homes constructed by 2002. 

http://www.ci.scottsdale.az.us/greenbuilding/

Southern Arizona Green Building Alliance (in 

progress) This green building program is in its 

infancy and details are still being determined 

Contact Loretta Ishida, The Development 

Center of Appropriate Technology (520) 624-

6628 Loretta@dcat.net, http://www.dcat.net

2 

Leadership in 

Energy & 

Environmental 

Design (LEED) 

This program facilitates positive results for the 

environment, occupant health and financial return. 

It defines “green” by providing a standard for 

measurement, prevents false or exaggerated claims, 

and promotes whole-building, and integrated 

design process. LEEDS evaluated and recognizes 

performance in accepted green design categories, 

existing and proven technologies. There are four 

levels of certification. 

April Green Building Forum – sponsored by 

Phoenix, Scottsdale and Surprise. 

New capital mall buildings including Arizona 

Department of Environmental Quality and 

Department of Administration buildings built 

in 2002. 

1 

Utility Tracking Developed by the Energy Office for entities with 

multiple accounts (e.g., schools, municipalities, 

large businesses). Uses Microsoft Excel to track 

utility usage by meter. Captures data from utility’s 

web site. The program identifies problems, and 

raises questions. 

Ongoing. 1 
Chapter 12 – Pollution Prevention - 96 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

National 

Industries of the 

Future 

Administered by Department of Energy – Office of 

Industrial Technologies 

9 Industries targeted that together supply 90% of 

the materials vital to US economy. 

The 9 industries are: agriculture, aluminum, 

chemicals, forest products, glass, metal casting, 

mining, petroleum, and steel. 

Goal: Promote energy efficiency and manage waste 

streams. 

Arizona Industries of the Future being 

developed by Energy Office with D.O.E grant. 

4 industries targeted 

- Agriculture 

- Aluminum 

- Forest Products 

- Mining 

1 

Industrial 

Assessment 

Centers 

Administered by DOE, OIT 

Enables eligible small and medium-sized 

manufacturers to have comprehensive industrial 

assessments performed at no cost to the 

manufacturers. 

Teams of engineering faculty and students from the 

center, located at 26 universities around the 

country, conduct energy audits, or industrial 

assessment and provide recommendations to 

manufacturers to help them identify opportunities 

to improve productivity, reduce waste, and save 

energy. 

Recommendations from industrial 

assessments have averaged about $55,000 in 

potential annual savings for each 

manufacturer 

ASU operates one of the 28 National Centers 

Director: Dr. Patrick E. Phelan 

(480) 965-1625 

phelan@asu.edu 

1 

Income 

Subtraction for 

Construction of 

an Energy 

Efficient 

Residence

For taxable years beginning from and after 

December 31, 2001, through December 31, 2010, 

Arizona law (A.R.S. 43-1031) allows a subtraction 

for a residence that is 50% more efficient than the 

1995 Model Energy Code (MEC). The subtraction 

is allowed for selling one or more new energy 

efficient residences located in Arizona. The 

subtraction is equal to 5% of the sales price 

excluding commissions, taxes, interest, points, and 

other brokerage, finance and escrow charges. The 

subtraction cannot exceed $5,000 for each new 

qualifying residence. 

A home’s energy efficiency must be demonstrated 

by a score of at least 90 points (indicating that the 

home is 50% better than the MEC threshold) on a 

home energy rating. A Certified Home Energy 

Rater must provide the home energy rating. 

Ongoing 4 

Building America Building America is a private/public partnership 

that provides energy solutions for production 

housing. The Energy Office assists in 

disseminating the results of this effort to the 

Arizona market place. 

Ongoing 4 

Governor’s Smart 

Energy Usage 

Program 

"Conservation saves money, which makes sense 

during tight budget times. And decreased energy 

production saves water, which makes sense during 

a drought. These two reasons provide more-thanenough motivation to conserve this summer," 

Arizona Governor Jane Dee Hull said when 

announcing the Smart Energy: Phase II program for 

summer 2002. 

 

As a result of the success of the 2001 campaign, 

Governor Hull ordered all agencies under her 

The Smart Energy campaigns of 2001 and 

2002 require state agencies to set thermostats 

up two degrees to save energy. As a result it is 

estimated that these conservation efforts 

reduced energy usage from 7 to 10 percent 

and saved the state $115,000 in utility bills 

during the summer of 2001 The campaign also 

called upon Arizonans to do their part. "Two 

Degrees - No Sweat” encouraged Arizonans to 

save energy by raising thermostats two 

degrees. 

4 
Chapter 12 – Pollution Prevention - 97 - Arizona Regional Haze SIP

Program Title Program Description 2002 Status Ref. 

jurisdiction to take a number of energy-saving steps 

for the second summer in a row. The Governor also 

asked that state residents voluntarily comply with 

the "Arizona Smart Energy: Phase II" program. 

 

As part of the Smart Energy: Phase II program, the 

Governor asked all state employees to implement 

the following energy saving measures: 

• Every agency will use power management 

tools like Energy Star to keep computers, 

monitors and other devices in stand-by 

mode when not in use. 

• Employees will turn off lights and office 

equipment, as much as possible, when 

they expect to be out of the office for more 

than one hour. 

• Agencies will reduce all lighting that does 

not affect productivity, health or safety. 

• Thermostats in all state-controlled 

facilities, will be increased during the 

months of June through September by two 

degrees or brought within the 76-79 

degrees F range, whichever is greater. 

• Agencies will implement a professional, 

casual-dress policy from June through 

September, consistent with the type of 

work being performed.

1 Presentation by Craig Marks, of the Arizona Energy Office, Department of Commerce, to the Pollution 

Prevention Workgroup, July 26, 2002. 

2 “Summary of Green Building Programs,” Prepared for National Renewable Energy Laboratory, by 

National Association of Home Builders Research Center, Second Edition, August 2002. 

3 U.S Department of Energy, Office of Building, Technology, State & Community Projects, 

http://www.eere.energy.gov/buildings/state_energy/

4 Arizona Department of Commerce, Energy Office, http://www.azcommerce.com/Energy/default.asp

The regional haze rule and the 10/20 goals look ahead to future years. While not specifically 

required, Arizona is providing the following Table 12-4 on renewable energy capacity that is planned as 

of 2002 to provide information on projects that are in the planning stages and have the potential to 

provide additional renewable energy capacity in the future. 

 

Table 12-4. Planned Renewable Energy Capacity as of 2002 

Program Title Program Description Ref. 

Land fill Gas 

Pipeline Project 

This is a partnership with Salt River Project, Detroit Edison and Salt River Pima Maricopa Indian 

Community. The pipeline is between Salt River and Tri-Cities Landfills. It extends the fuel supply to 

the Tri-Cities Landfill Gas Generation Plant. Facility is expected to be commissioned in the second 

quarter of 2004 

1 

Arizona Falls 

Project 

This SRP sponsored project will generate 750 kW. It has roof mounted solar placed on the turbine 

building. Facility is to be commissioned in second quarter of 2003. 

1 
Chapter 12 – Pollution Prevention - 98 - Arizona Regional Haze SIP

Program Title Program Description Ref. 

Mesa City 

Library 

Photovoltaic 

Parking 

This is a 25kW system with covered parking for 34 spaces. Provides green energy for SRP Earthwise 

Energy customers. Project is expected to be completed May 2003. 

1 

SRP 

Park & Ride 

Photovoltaic 

This SRP sponsored project is for a 100kW PV system on parking structures. The PV system is 

expected to be complete in July 2003. It also has a goal to increase public awareness of renewable 

energy. 

1 

APS Prescott 

Airport Solar 

Power Plant 

APS Prescott Airport Solar Power Plant - Prescott – 5 MW projected in 3 yrs (possibly expandable to 

10 MW), This is currently the largest single axis tracking system in the state and is expected to 

become the largest PV site in the country consisting of both single axis tracking and concentrating PV 

technologies. 

2 

APS Solar 

Trough 

APS is building a 1MW demonstration solar thermal trough project that will be tested for performance 

compared to photovoltaic technologies. 

2 

APS Dish 

Stirling tests 

10 Units ordered for test once the technology demonstrates performance and price characteristics that 

exceed photovoltaics. 

2 

APS Landfill 

Gas to Energy 

There a two 3 MW and one 70 kW landfill gas opportunities being explored by APS. Additionally, 

new technologies including for generating electricity from methane are being explored including 

reciprocating engines and micro turbines. 

2 

APS Wind APS is exploring wind opportunities as they become available and demonstrate financial viability. 2 

APS Biogas Biogas - Possible opportunities being explored by APS include Water Treatment Plant (6 MW) and 

Bovine Power (2 MW) using an anaerobic digestion process to convert animal waste into biogas 

which can the be used to generate electricity. 

2 

APS 

Geothermal 

APS is beginning evaluation of technology for potential future installation in SE AZ (10 MW). 2 

APS Biomass APS is Exploring the development of Plasma gasification, waste wood (3 MW) biomass opportunities 

to extract energy from the waste wood resulting from forest management processes due to the State’s 

extended draught and the bark beetle infestation. 

2 

Springerville 

Solar 

Generating 

Station 

As of December 2002, TEP has 2.4 MW solar capacity installed at the Springerville Generating 

Station in Eastern Arizona. By the end of 2003, the Springerville facility will have 3.5MW of capacity 

and TEP will have 4MW of capacity overall.

3 

1 “Overview of SRP’s Renewable Energy Program,” Presentation by Herjinder Hawkins to PPWG on March 24, 

2003. 

2 “Renewable Energy Opportunities in Arizona,” Presentation by Cassius McChesney to PPWG on June 2002. 

3 “Statewide Economic Study 2002 – Arizona’s Energy Infrastructure,” Prepared for the Arizona’s Department of 

Commerce by Rebecca Holmes, SRP, and Craig Marks, ACC, September 2002, p. 13. 

12.4. Inventory of All Renewable Energy Generation Capacity and 

Production in Arizona

Pursuant to 40CFR 51.309 (d)(8)(i), Table 12-5 summarizes all renewable energy generation 

capacity and production in use or planned as of 2002 (expressed in MW and MWh). Appendix A-12b 

entitled Details of Renewable Energy Generation and Capacity contains a detailed inventory of existing 

and currently planned renewable energy production projects and their references. 
Chapter 12 – Pollution Prevention - 99 - Arizona Regional Haze SIP

Table 12-5. Summary of Renewable Energy Generation Capacity and Production 

Categories Existing Capacity 

 in 2002 

 (MW) 

Existing & Planned 

 Capacity as of 2002 

(MW) 

Total Production 

in 2002 

(MWh) 

Solar 6.222 6.733 10,579.764

Methane 9.500 9.570 63,715.000

Wind 0 0 0

Wood Chips 0 3.000 0

Low-Impact Hydro 0 0.750 0

TOTAL 15.722 20.053 74,294.764

The total electric-energy production in the State of Arizona for 2000 was 89,101,000 megawatthours. (Energy Information Administration). The approximate percentage of renewable electric energy 

generated in 2002 was 0.08%. Generation capacity as of 2002 is summarized in Table 12-6. 

Table 12-6. Summary of Arizona’s Total Energy Generation Capacity and Production19

Rank Operator Plant Name Fuel MW Percent

1 Arizona Public Service Company Palo Verde Uranium 3,730 19.2%

2 Salt River Project Navajo (SRP)20 Coal 2,255 11.6%

3 U.S. Bureau of Reclamation Glen Canyon Water 1,300 6.7%

4 Pinnacle West Redhawk Units 1 and 2 Gas 1,060 5.4%

5 U.S. Bureau of Reclamation Hoover AZ Water 1,042 5.4%

6 Arizona Public Service Company Cholla Coal 995 5.1%

7 Tucson Electric Power Co Springerville Coal 800 4.1%

8 Salt River Project Coronado Coal 760 3.9%

9 Duke Energy North America Griffith Energy Project Gas 620 3.2%

10 Salt River Project Agua Fria Gas 619 3.2%

11 Duke Energy North America Arlington Valley Gas 570 2.9%

12 Arizona Electric Power Cooperative Apache Coal/Gas 560 2.9%

13 Reliant Energy Power Gene Desert Basin Gas 560 2.9%

Total, Top 13 Plants 14,871 76%

Balance of State 4,581

Arizona Total 19,412 MW

Sources: 

Statewide Economic Study 2002, Arizona Energy Infrastructure, Prepared for the Arizona Department of 

Commerce, September 2002, pg. 7. 

Second Biennial Transmission Assessment, 2002-2011, Arizona Corporation Commission, P Plus 

Corporation, December 2002, pg. 107-124

12.5. Summary of Anticipated Renewable Energy Contribution

The approximate percentage of renewable electric energy generated in Arizona for 2002 was 

0.08%. Generation capacity as of 2002 is summarized in Table 12-6 above. Pursuant to 40CFR 51.309 

(d)(8)(i), Appendix A-12b entitled of this SIP summarizes the State of Arizona’s anticipated contribution 

toward meeting the GCVTC renewable energy goals for 2005 and 2015. Also see Section 12.10, below. 

 

19 Based on summertime generating capacity. 

20 This facility is on tribal lands (Navajo Nation). 
Chapter 12 – Pollution Prevention - 100 - Arizona Regional Haze SIP

12.6. Incentive Programs

Pursuant to 40CFR 51.309 (d)(8)(ii), Table 12-7 below identifies incentive programs in the State 

of Arizona that reward efforts to go beyond compliance and/or achieve early compliance with air 

pollution related requirements. 

Table 12-7. Summary of Arizona’s Incentive Programs 

Program Title Program Description 

Market Trading Arizona has opted into the Section 309 regional SO2 “cap-and-trade program”, as outlined 

in the Annex, under the Regional Haze Rule. 

Western Backstop SO2

Trading Program Early 

Reduction Credits 

As further described in Section C1.1 of the stationary source provisions of this plan, 

industrial sources of SO2 subject to the trading program which, upon verification by the 

State, reduce emissions to levels below their floor amount prior to the program trigger date 

shall receive additional emission allowances. Such allowances may be used by the source 

for compliance purposes or may be sold to other parties, hence, providing an incentive for 

sources to go beyond compliance (i.e., their floor) or to achieve early compliance (i.e., 

reductions prior to the program trigger date). 

Western Backstop SO2

Trading Program 

Renewable Energy 

Credits 

As further described in Section C1.1 of the stationary source provisions of this plan, 

allowances shall be provided to the owners of renewable energy facilities installed since 

October 1, 2000. Such allowances will hold a market value and therefore provide an 

incentive for power suppliers to invest in renewable energy facilities with zero or very low 

air pollutant emissions. 

12.7. Programs to Preserve and Expand Energy Conservation Efforts

Pursuant to 40 CFR 51.309 (d)(8)(iii), Table 12-8 identifies programs in Arizona that preserve 

and expand energy conservation efforts. 

Table 12-8. Programs that Preserve and Expand Energy Conservation in Arizona 

Program Title Program Description 

Energy 

Conservation in 

State Buildings

Legislation passed in 2003 requires that state agencies (the Department of Administration and 

Transportation and the Board of Regents) reduce energy use by 10 percent by July 1, 2008 and 15 

percent by July 1, 2011. 

Preserve and Expansion Description: This program will expand energy efficiency activities of state 

agencies. Industry projections for savings from implementation of this measure are projected to be 

$11 million per year by 2011, with $90 million of cumulative energy efficiency savings over the 

period 2004-2015. 

Purchase of 

Energy Star 

Projects by 

State Agencies

Legislation passed in 2003 requires all state agencies to purchase products certified as Energy Star or 

certified under FEMP in all categories unless the products is shown not to be cost effective on a life 

cycle cost basis. 

Preserve and Expansion Description: State agencies already purchase some products that are Energy 

Star certified. This program will expand existing energy efficient equipment purchase and have a 

long-term effect on energy use by state agencies. School districts and all political subdivisions can 

also purchase these energy star products off of the state contacts, which could further increase the 

impact of this program. 
Chapter 12 – Pollution Prevention - 101 - Arizona Regional Haze SIP

Program Title Program Description 

Regulated 

Utility 

Customer 

Funding or 

System Benefit 

Charge Funding 

for Energy 

Efficiency 

Tucson Electric Power: 2002 --$3 million in approved SBC spending, of which $2 million was for 

renewable energy programs and $1 million for low income and energy efficiency programs. 

Arizona Public Service: 2002 - $7 million in approved spending, of which $6 million was used for 

renewable energy programs and technology development, and $1 million for low-income customer 

support and other programs. In addition, under the EPS program, APS collected an additional 

$6,571,745 for renewable energy programs in 2002. 

See also the listing in Table 12-2 under the heading Regulated Utility Customer Funding or System 

Benefit Charge Funding for Renewable Energy. 

Residential New 

Construction 

and New Home 

Guarantee 

Programs 

To help promote the value of energy efficient residential construction, APS works with builders and 

building material vendors to provide buyers with a heating and cooling guarantee. All participating 

builders must offer their homebuyers a 2-year guarantee that the monthly costs to heat and cool their 

home will be less than a specified amount. Currently four of the top ten production builders in the 

Phoenix metro area are participating in the program and over 3500 home lots have been committed. 

APS has promoted the concept of guaranteed heating and cooling bills through a multi-media 

campaign including TV, print, on-line, and point-of-sale materials. 

In 1997 TEP designed and implemented the first utility operated new home guarantee program in the 

nation. The program philosophy addresses all of the issues of affordability, durability, comfort, health 

and safety using scientific laws of airflow, moisture-flow and pressure management within a home. 

Homes are constructed to high standards set by TEP and include on-site inspections of framing areas 

related to energy performance, insulation installation, and HVAC system design and installation. Onsite testing is also provided to measure duct leakage, whole-house infiltration and pressure 

management within the home under various operating conditions. If a home passes all inspection and 

testing criteria, the homeowner receives a Guarantee from TEP that heating and cooling costs will not 

exceed a predetermined average cost per day (calculated on each separate model home) and a 

guarantee for comfort for a pre-set time period. Homes permitted prior to February 20, 2003 receive a 

3-year guarantee and homes permitted after February 20, 2003 receive a 5-year guarantee. 

Homeowners who purchase a TEP Guarantee home qualify for a specially designed rate-tariff that 

reduces the cost of all electricity used in the home by 12% annually compared to the standard 

residential electric rate. The homeowners also have the option to increase this electric rate savings to 

either 18% or 22% depending on their selection of TOU and/or the installation of solar water heating 

systems. There are currently over 5500 homes either completed, in some progress of completion or 

waiting for construction to begin. The program is operated within the utility structure with quality 

control provisions and the guarantee provided by a utility. All TEP Guarantee Homes qualify for 

ENERGY STAR since the qualifications from TEP are more stringent than ENERGY STAR. TEP 

provides this DOE/EPA program documents to customers along with the Guarantee certification. 

The SRP-Certified Home (SCH) program was introduced in May 1995. For a subdivision to be SRP 

certified, SRP works directly with the builder to ensure that each home design meets our energyefficiency standards. SRP certification means the home design includes certain energy-efficient 

features. Certification is based on the SRP-Certified Homes Point Sheet that primarily is a 

construction specification trade-off system. With the system, one design feature may be substituted 

for another if the overall design complies with the SRP-Certified Home energy consumption standard. 

Between 1999 and 2002, approximately 21,000 SCH contracts were signed. 

In 2002 SRP announced a new addition to the SRP-Certified Home program. Energy Code 

Compliance certification is now available upon request. SRP can provide REM/Design compliance 

reports for 1998/2000 International Energy Conservation Codes (IECC), CABO Model Energy Code 

(MEC), and ASHRAE 90.2 By adding the new "Code Compliance" feature to the program we can 

now assist builders in meeting the energy efficiency codes required by the various municipalities. 

New 

Construction 

Energy 

Efficiency 

In partnership with the Arizona Energy Office, APS has conducted extensive research and testing on 

new residential construction with blower doors, duct blasters, infrared cameras, and other diagnostic 

tools. The result of these tests is a list of building construction details that need the most focus to 

improve home performance. In 1998, APS and the Arizona Energy Office began offering Building 
Chapter 12 – Pollution Prevention - 102 - Arizona Regional Haze SIP

Program Title Program Description 

Research and 

Training

Science training for residential builders. To date, over 2000 building industry members have attended. 

Coupled with the heating/cooling guarantee program, this has resulted in substantial improvements in 

the real world performance of residential new construction as confirmed through field studies by the 

Arizona Energy Office. 

TEP hosts quarterly education programs to target audiences of builders, sub-contractors, and 

city/county code officials, architects and consumers. These programs are designed to educate all 

audiences on the scientific approach of building new homes or retrofitting existing homes to gain the 

maximum benefit in affordability, durability, comfort and health and safety. TEP also adds matching 

funds for grants provided to the City of Tucson ‘Teaching Energy Conservation’ project which 

educates consumers, builders, contractors, consumers and code officials on various conservation 

related issues. 

Qualified 

Contractor 

Program

APS offers referrals to customers seeking qualified, professional HVAC contractors for service or 

replacement of their existing AC/heat pumps. To qualify for the program, residential HVAC 

contractors are required to meet stringent requirements and complete ongoing rigorous APS education 

courses for their service technicians. To date, APS has subsidized technical training for over 6000 

service technicians. APS currently provides free contractor referrals to approximately 4000 customers 

each year, ensuring that units are properly serviced and installed. 

High Efficiency 

Appliance 

Programs 

APS High Efficiency Air Conditioners Program 

For several years APS has worked with the air conditioner contractor community. This partnership 

has been instrumental in moving the market for resale air conditioners and heat pumps to high 

efficiency equipment. Evidence suggests that the resale market is about 90% 12 SEER, which is 15% 

more efficient than standard equipment, reducing demand and energy consumption. Since 1998, APS 

and contractors have distributed over 20,000 copies of the Consumer’s Guide to an Energy Efficient 

Air Conditioning System as an education tool for customers. 

SRP Rebates on Highly-Efficient Refrigerators and Heat Pumps – Over the last several years, SRP has 

independently offered customers rebates on highly efficient refrigerators and heat pumps. SRP has 

issued more than 8,500 rebates on refrigerators labeled by ENERGY STAR® as exceeding federal 

standards and more than 1,000 rebates on heat-pumps with a 13-SEER rating that also meet additional 

strict criteria. 

Time of use 

rates

APS Time of use rates - Approximately 40% of all residential customers are on a time of use rate. It is 

one of the highest penetrations of TOU rates in the country. APS is one of the only utilities nationwide 

to offer a demand rate for residential customers. Most new APS customers apply for one of the two 

TOU rates. Evidence suggests it reduces demand and shifts load. A recent survey of customers 

indicates that over 75% of TOU customers do shift some of their energy use to off-peak time periods. 

Customers feel it gives them control over their electric bill and helps conserve peak energy. 

SRP has approximately 140,000 customers on our peak-load shifting program, Time-of-Use (TOU). 

Residential TOU customers average 75% off-peak usage annually, while non-TOU residential 

customers average 72% - 73% off-peak usage annually. The result of TOU is that SRP has been 

successful in shifting 2%-3% of our average annual energy consumption to off-peak. 

TEP has approximately 7,700 customers on our peak-load shifting program, Time-of-Use (TOU). 

Residential TOU customers average 80% off-peak usage annually, while non-TOU residential 

customers average 77% - 78% off-peak usage annually. The result of TOU is that TEP has been 

successful in shifting 2%-3% of our average annual energy consumption to off-peak. 

Peak Reduction 

Campaign 

Commercial Peak Reduction Campaign -- Since the summer of 2001, APS has promoted a voluntary 

summer peak energy management initiative with commercial customers. Participating customers 

pledge to save energy on extreme summer days when temperatures exceed 110 degrees in Phoenix. 

Customers receive an email on “Peak Power Days” asking them to turn thermostats up two degrees, 

turn off unnecessary lights and equipment, and adjust the schedule of energy-intensive processes. The 

campaign has helped shave peak consumption and heightened awareness of the need to save energy on 

extreme summer days. 
Chapter 12 – Pollution Prevention - 103 - Arizona Regional Haze SIP

Program Title Program Description 

Shade Trees 

Campaign 

The TEP Trees Program promotes energy conservation and the environmental benefits associated with 

planting low-water usage trees and other vegetation. Desert-adapted trees have been provided to 

residential neighborhoods, low-income families, public areas and schools by TEP. The residential 

trees are to be located on the south, west and east sides of homes in the TEP service area with the 

objective of continuing positive community service as well as providing Demand-Side Management 

(“DSM”) benefits. 

Residential Program: There were 3,000 trees distributed to roughly 1,500 homes for the period January 

1, 2002 through December 31, 2002. 

School and Community Programs: For the period January 1, 2002 through December 31, 2002, this 

program provided 105 fifteen-gallon-sized and 41 five-gallon-sized trees to 43 schools. In addition, 

63 community projects received 115 fifteen-gallon-sized and 111 five-gallon-sized trees. 

Energy 

Efficiency 

Education 

APS provides a free on line energy analysis on aps.com. It allows customers and prospective 

customers to analyze their home and business energy use and identify customized energy efficient 

measures. Approximately 30,000 customers have used this service since 2001. APS offers an energy 

answer line service to answer questions about home energy efficiency. This service receives about 

6000 calls per year. APS provides seasonal energy savings tips online and in customer bill inserts. 

SRP Energy Savings Solutions Campaign 

Energy Savings Solutions (ESS) is a multi-media campaign, which runs from May through September. 

The goal of ESS is to educate customers about effective energy management. ESS provides customers 

with useful and easy ways to lower their energy usage and enables customers to make informed 

decisions everyday by demonstrating how home energy conservation efforts can help reduce energy 

costs. 

TEP provides free class sets of booklets to schools in its area, including, "Learning to Save Energy", 

which is geared to grades 3-5. TEP also offers teacher training and back up materials for two handson activities: The Insulation Station (which deals with residential energy issues) and The Energy 

Patrol (where a class or group of students learn about energy efficiency, and then try to "patrol" their 

school, helping remind others how to save energy). TEP also provides seasonal energy tips on-line 

and in mailings to customers and handouts at presentations.

Energy Star Customer Education on Purchasing Decisions 

SRP has been an ENERGY STAR® partner since 1999. This DOE/EPA program establishes stricter 

efficiency criteria for new products. As a partner, SRP has been able to not only increase awareness of 

ENERGY STAR, but also to provide information for customers so that they can make informed 

purchase decisions. This information has been incorporated into our monthly newsletters and our 

Energy Savings Solutions campaign and has also been heavily featured in on-going publications to 

both residential and commercial customers via Powerful Solutions and eNews.

Energy 

Efficiency 

Audits 

For approximately the last two years, SRP has been working with third party contractors and other 

entities such as the Arizona Department of Commerce to provide free or low cost energy efficiency 

audits and educational programs to energy consumers in the commercial, industrial and government 

sectors. The focus of the programs to date has been on high-efficiency lighting retrofits, energy 

information services, and improvements to compressed air systems. 

TEP offers the Energy Advisor, a quick, free, online analysis of a home's or business's monthly energy 

use, as well as suggestions on how to reduce energy costs.

Pre-Pay 

Program

SRP has approximately 31,000 customers on our pre-pay program, M-Power. M-Power customers 

have reduced their energy consumption by 10% on average. This energy conservation is due to the 

intensive educational information provided by the program and the discipline required from the 

customer. M-Power is the largest program of its kind in North America.

Arizona Energy 

Office, Arizona 

Dept of 

Commerce 

The Energy Office’s $2.3 million annual budget is funded through a combination of federal funds and 

Petroleum Violation Escrow funds. 

Director: Craig Marks 

(602) 771-1139 

craigm@azcomerce.com
Chapter 12 – Pollution Prevention - 104 - Arizona Regional Haze SIP

Program Title Program Description 

http://www.azcommerce.com?energy/default.asp

Low Income 

Weatherization 

The Energy Office administers Arizona’s $3 annual million (federal and private funds), low-income, 

weatherization program The primary mission of this program is to reduce the energy required for 

space heating and cooling for income eligible households applying for assistance through one of ten 

sub-grantees, statewide. This program receives its primary funding from the U.S. Department of 

Energy and the U.S. Department of Health and Human Services. The program also leverages 

additional funds through partnership with utilities, and other federal and state housing programs. 

Many aspects of the Residential Training and Technical Assistance Programs are now incorporated 

into the training of weatherization sub-grantees, which assures that savings are maximized. 

Special Project 

Grants 

The Energy Office administers the State Energy Project – Special Project Grants. Each year states 

submit proposals in response to a DOE solicitation identifying how specific technologies could be 

implemented in their region of the country. DOE then selects the projects that best meet national 

energy goals. The Energy Office publicizes grant availability, helps prepare grant applications, and 

administers grants. The Energy Office is currently administering $2,865,375 SEP Special Project 

funds. 

ResidentialMarket Training 

and Technical

Transfer

Over 30,000 new homes are built each year in the harsh desert environment of metro-Phoenix, making 

it one of the largest new home markets in the United States. Thousands more homes are built each 

year in other fast-growing Arizona communities. Improving the energy efficiency of new homes has 

an enormous impact on Arizona’s energy usage. 

The Energy Office has long partnered with Arizona utilities to provided technical assistance and 

training for the building trades on the latest energy efficiency technologies and techniques, including: 

Infrared imaging to analyze insulation performance; 

Smoke generation to show duct leakage; and 

Using pressure diagnostics, such as the blower door testing, duct blasters, and digital monometers, to 

confirm envelope integrity. 

Overall the goal is to encourage builders and subcontractors to take a scientific systems approach to 

home construction and incorporate energy-efficient techniques into the building process. 

Municipal 

Energy 

Management 

Program 

The MEMP (Municipal Energy Management Program) encourages and assists in the development and 

implementation of energy management programs by facilitating the planning process and providing 

the necessary basic tools, staff training and technical assistance. As part of MEMP, the Energy Office 

makes funds available for energy saving projects. Those eligible to apply include incorporated 

Arizona cities, towns, counties, improvement districts, and Indian tribes with populations under 

70,000. 

 

The MEMP approach to energy conservation is a simple and direct step-by-step approach. The first 

step is to understand where energy is being consumed and how much it costs, based on the utility bill 

analysis and audits. The second step identifies strategies for lowering energy costs. The third step 

assists in incorporating energy management into future development through an energy management 

plan. 

Federal Energy 

Management 

Program 

Goal: reduce the cost and environmental impact of the federal government by advancing energy 

efficiency and water conservation, promoting the use of distributed and renewable energy, and 

improving utility management decisions at federal sites. 

Funds are occasionally available to the Arizona Energy Office to partner with Indian communities and 

military bases or other federally-owned facilities 

State Energy 

Efficiency 

Demonstration 

Program 

Working with the Department of Administration and agency facility managers, the Energy Office 

provides training, technical assistance and funding to implement energy savings and demand-reduction 

measures in state-controlled facilities. Matching grant program. 

State Facility 

Managers 

Training 

Program 

Based on results of the forensic audits and utility tracking, the Energy Office provides training and 

technical assistance to state facility management staff with the goal of identifying actions that may be 

taken to decrease electricity consumption in state facilities. This training will assist facility managers 

in performing diagnostics on their facilities, complete retrofits on equipment and buildings, and track 
Chapter 12 – Pollution Prevention - 105 - Arizona Regional Haze SIP

Program Title Program Description 

energy consumption. 

Energy Efficient 

Schools 

Energy Office partnership with School Facilities Board. A jointly funded engineer works with 

architects and vendors to incorporate cost-effective, energy-efficient designs and equipment.

Energy audits of existing facilities are also available. 

State Energy 

Code 

HB 2541 (2001) Is a voluntary model energy code (AZ=home rule). This bill designates the State 

Energy Code as a legislative tool to create incentives for the use of energy saving devices and 

practices. It established a State Energy Code Advisory Commission to review and recommend 

changes to the State Energy Code. 

Governor’s 

Awards 

The Energy Office recognizes local governments, state agencies, and educational institutions for 

exceptional energy-conservation accomplishments. 

Rebuild 

America 

U.S. D.O.E. Program supported by Arizona Energy Office help businesses and communities reduce 

energy use in buildings. 

Green Buildings Green buildings are use design and construction practices that significantly reduce or eliminate the 

negative impact of buildings on the environment The concept includes: 

- Sustainable site planning 

- Safeguarding water and water efficiency 

- Energy efficiency and renewable energy 

- Conservation of materials and resources 

- Indoor environmental quality 

Leadership in 

Energy & 

Environmental 

Design (LEED) 

This program facilitates positive results for the environment, occupant health and financial return. It 

defines “green” by providing a standard for measurement, prevents false or exaggerated claims, and 

promotes whole-building, and integrated design process. LEEDS evaluated and recognizes 

performance in accepted green design categories, existing and proven technologies. There are four 

levels of certification. 

Utility Tracking Developed by the Energy Office for entities with multiple accounts (e.g., schools, municipalities, large 

businesses). Uses Microsoft Excel to track utility usage by meter. Captures data from utility’s web 

site. The program identifies problems, and raises questions. 

National 

Industries of the 

Future 

Administered by Department of Energy – Office of Industrial Technologies 

Nine industries targeted that together supply 90% of the materials vital to US economy. 

The 9 industries are: agriculture, aluminum, chemicals, forest products, glass, metal casting, mining, 

petroleum, and steel. 

Goal: Promote energy efficiency and manage waste streams. 

Industrial 

Assessment 

Centers 

Administered by DOE, OIT 

Enables eligible small and medium-sized manufacturers to have comprehensive industrial assessments 

performed at no cost to the manufacturers. 

Teams of engineering faculty and students from the center, located at 26 universities around the 

country, conduct energy audits, or industrial assessment and provide recommendations to 

manufacturers to help them identify opportunities to improve productivity, reduce waste, and save 

energy. 

Income 

Subtraction for 

Construction of 

an Energy 

Efficient 

Residence 

For taxable years beginning from and after December 31, 2001, through December 31, 2010, Arizona 

law (A.R.S. 43-1031) allows a subtraction for a residence that is 50% more efficient than the 1995 

Model Energy Code (MEC). The subtraction is allowed for selling one or more new energy efficient 

residences located in Arizona. The subtraction is equal to 5% of the sales price excluding 

commissions, taxes, interest, points, and other brokerage, finance and escrow charges. The subtraction 

cannot exceed $5,000 for each new qualifying residence. 

A home’s energy efficiency must be demonstrated by a score of at least 90 points (indicating that the 

home is 50% better than the MEC threshold) on a home energy rating. A Certified Home Energy 

Rater must provide the home energy rating. 

Building 

America 

Building America is a private/public partnership that provides energy solutions for production 

housing. The Energy Office assists in disseminating the results of this effort to the Arizona market 

place. 
Chapter 12 – Pollution Prevention - 106 - Arizona Regional Haze SIP

Program Title Program Description 

Governor’s 

Smart Energy 

Usage Program 

"Conservation saves money, which makes sense during tight budget times. And decreased energy 

production saves water, which makes sense during a drought. These two reasons provide more-thanenough motivation to conserve this summer," Arizona Governor Jane Dee Hull said when announcing 

the Smart Energy: Phase II program for summer 2002. 

 

As a result of the success of the 2001 campaign, Governor Hull ordered all agencies under her 

jurisdiction to take a number of energy-saving steps for the second summer in a row. The Governor 

also asked that state residents voluntarily comply with the "Arizona Smart Energy: Phase II" program. 

 

As part of the Smart Energy: Phase II program, the Governor asked all state employees to implement 

the following energy saving measures: 

- Every agency will use power management tools like Energy Star to keep computers, monitors and 

other devices in stand-by mode when not in use. 

- Employees will turn off lights and office equipment, as much as possible, when they expect to be out 

of the office for more than one hour. 

- Agencies will reduce all lighting that does not affect productivity, health or safety. 

- Thermostats in all state-controlled facilities will be increased during the months of June though 

September by two degrees or brought within the 76-79 degree range whichever is greater. 

- Agencies will implement a professional, casual-dress policy from June through September, 

consistent with the type of work being performed. 

12.8. Potential for Renewable Energy

Pursuant to 40CFR 51.309 (d)(8)(iv), the State of Arizona has made an assessment of areas where 

there is the potential for renewable energy to supply power in a cost-effective manner. This section 

summarizes the findings of this assessment beginning with a review of the geographic distribution of 

renewable energy potential contained in Figures 12-1 through 12-4.
Chapter 12 – Pollution Prevention - 107 - Arizona Regional Haze SIP

Figure 12-1. Map of Arizona Solar Photovoltaic Resources 
Chapter 12 – Pollution Prevention - 108 - Arizona Regional Haze SIP

 Figure 12-2. Map of Arizona Concentrating Solar Power Resources 
Chapter 12 – Pollution Prevention - 109 - Arizona Regional Haze SIP

 Figure 12-3. Map of Arizona Biomass Energy Resources 

 
Chapter 12 – Pollution Prevention - 110 - Arizona Regional Haze SIP

Figure 12-4. Map of Arizona Collocated Geothermal Energy Resources 
Chapter 12 – Pollution Prevention - 111 - Arizona Regional Haze SIP

Arizona is not blessed to the same degree with wind resources as Montana, geothermal resources 

as Nevada, or the hydroelectric resources of the northwest. However, Arizona has renewable energy 

resources that have yet to be tapped. A consortium of business, government and academic institutions are 

actively evaluating the state’s wind resources. Initial data suggest that commercial-scale wind resources 

may exist in the state on developable lands. The cost of utility scale wind installations has dropped 

dramatically in the past decade resulting in a robust new wind industry. Between 2000 and 2001, wind 

generated installations doubled in capacity and in 2001 alone, 1,700 MW of wind were installed in the 

U.S. Depending on the wind resource and local, state and federal subsidies, costs are equal to or nearing 

the cost of generating electricity with conventional fuels. 

Projects are underway to evaluate or develop electricity generation projects in two areas of the 

state. In addition, large reserves of geothermal resources are available for direct use, hot water 

applications. Renewable resource development is site specific, dependent on access, and availability of 

transmission, land ownership issues and economics of developing the known resource. 

In terms of renewable energy resources, Arizona leads the nation in potential solar-energy 

resources. Solar electric generating plants cost much more than plants that employ conventional 

technologies. Large natural gas-fired, combined-cycle plants can be built for approximately six-hundred 

dollars per kilowatt, while the best solar technologies are still estimated to cost at least six to ten times as 

much. 

Figure 12-5. Projected Cost of Solar Energy Technologies 

Projected Cost of Energy from

Solar Energy Technologies - 2000

Source: DOE/EPRI

Central Receiver

Trough

Dish - Hybrid

PV - Residential

Utility Thin Film

Concentrator

5

10

15

20

25

30

35

40

c/kWh ($1997 - levelized)

Source: WRAP AP2 Renewables, “Recommendations of the Air Pollution Prevention Forum to Increase 

Generation of Electricity from Renewable Energy Resources,” p. I-13. 
Chapter 12 – Pollution Prevention - 112 - Arizona Regional Haze SIP

Table 12-9. Cost Estimates of Solar Options 

Technology Plant Size (MW) Cost ($Million) Cost per kilowatt 

Parabolic Trough 50 200 4,000 

Power Tower 15 60 4,000 

Dish Engine 1 6 6,000 

Photovoltaic 1 6 6,000 

Concentrating Photovoltaic 1 6 6,000 

Organic Rankine Cycle Trough 1 <5 <5,000 

Source: Presentation by Dr. Peter Johnson, Arizona Public Service Company, June 2002 

Balanced against the higher capital costs of solar technologies are lower operation and 

maintenance costs. Fuel is the most expensive component of conventional power generation; sunlight is 

free. However, a conventional plant can be called on (dispatched) at any time, while solar plants can 

operate only while the sun is out and generation will be reduced on cloudy days. Because electricity 

cannot be stored cost effectively, the inability to dispatch the plant is a significant drawback to solar and 

wind-powered generation. Overall, solar electric generation cannot compete yet with conventional plants 

on pure economics. But solar generation requires no imported fuel, produces no air emissions, and 

consumes no water. Further, like any newer technology, it is expected that costs will come down as 

economies of scale are realized and production techniques improve. 

Finally, solar and other renewable generation have cost-effective applications in remote areas 

where it may be too expensive to extend a power line. For example, solar energy is being used to provide 

electricity for landfills, ranches, rural streetlights, emergency phones, and entire homes. Solar water 

heating can be cost effective even in urban areas, particularly in competition with electric water heating. 

Overall, the next ten years should see substantially increased penetration of solar and other renewable 

resources into Arizona’s generation mix. 

Figure 12-5. Projected Cost of Renewable Energy Technologies

Projected Cost of Energy from

Renewable Energy Technologies - 2000

Conv. Biomass

Adv. Biomass

Wind (Class 4)

Wind (Class 6)

Flash Geothermal

Binary Geothermal

1

2

3

4

5

6

7

8

9

c/kWh ($1997 - levelized)

Source: WRAP AP2 Renewables, “Recommendations of the Air Pollution Prevention Forum 

to Increase Generation of Electricity from Renewable Energy Resources,” p. I-13. 
Chapter 12 – Pollution Prevention - 113 - Arizona Regional Haze SIP

12.9. Projections of Renewable Energy Goals, Energy Efficiency, and 

Pollution Prevention Activities

Pursuant to 40CFR 51.309 (d)(8)(v), projections have been made by the WRAP of the short and 

long term emissions reductions, visibility improvements, cost savings, and secondary benefits associated 

with “renewable energy goals, energy efficiency and pollution prevention activities.” A complete 

description of the WRAP projections is contained in the report ICF Assessment of Renewable Energy and 

Energy Efficiency Programs included as Appendix A-12c. Projections of visibility improvements for the 

16 Class I areas on the Colorado Plateau are provide in Section 14.2. These projections include the 

combined effects of all measures in this SIP, including air pollution prevention programs. Although 

emission reductions and visibility improvements from air pollution prevention programs are expected at 

some level, they were not explicitly calculated because the resolution of the regional air quality modeling 

system is not currently sufficient to show any significant visibility changes resulting from the marginal 

nitrogen oxide emission reduction described above for air pollution prevention programs. Details of the 

modeling methodology are contained in the WRAP TSD in Chapter 8 entitled, “Assessment of Pollution 

Prevention.” 

12.10. Programs to Achieve GCVTC Renewable Energy Goal

Pursuant to 40 CFR 51.309 (d)(8)(vi), the programs relied upon by the State of Arizona to 

demonstrate progress in achieving the renewable energy goal of the GCVTC that renewable energy 

comprise 10 percent of the regional power needs by 2005 and 20 percent by 2015 are the environmental 

portfolio standard, and the utility customer funding or system benefit charge funding for renewables in 

addition to the other programs that are listed in Table 12-2. The approximate percentage of renewable 

electric energy generated in Arizona for 2002 was 0.08%. Generation capacity as of 2002 is summarized 

in Table 12-6 above. 

Appendix A-12b entitled Details of Renewable Energy Generation and Capacity provides 

additional information on the programs relied upon by Arizona to meeting the 10/20 regional goals. 

Appendix A-12c entitled ICF Assessment of Renewable Energy and Energy Efficiency Program, contains 

the regional modeling assessment performed by WRAP on the potential economic and visibility impacts 

associated with achieving the 10/20 regional goals. Section 12.8, above, contains an assessment of the 

potential for renewable energy resources. 

12.11. Future Progress Reports

Pursuant to 40 CFR 51.309 (d)(8)(vi), the State of Arizona commits to submit progress reports in 

2008, 2013 and 2018, describing the State’s contribution toward meeting the GCVTC renewable energy 

goals. This description will be consistent with Section 12.9 above. To the extent that is not feasible for 

the State to meet its contribution to these goals, the State commits to identify measures that were 

implemented to achieve its contribution, and explain why meeting its contribution was not feasible. 
Chapter 12 – Pollution Prevention - 114 - Arizona Regional Haze SIP

(This page intentionally blank) 
Chapter 13 – Other GCVTC Options - 115 - Arizona Regional Haze SIP

13. OTHER GCVTC RECOMMENDATIONS

13.1. Regulatory History and Requirements

The recommendations of the GCVTC are presented throughout the June 1996 final report with 

varying degrees of specificity. Not all are included in the Regional Haze Rule. However, some of the 

recommendations were intended as a menu of options, with no expectation that any geographic area 

would implement all of them. The GCVTC pointed out in its final report that: 

 Some of the Commission's recommendations ask the EPA to take specific actions or 

institute particular programs, in cooperation with the tribes, states and federal agencies 

as implementing bodies. Other recommendations provide a range of potential policy or 

strategy options for consideration by the EPA and implementing entities. As the EPA 

develops policies and takes actions based on this report, this distinction between 

"actions" and "options" should be maintained with diligence. That is, recommendations 

intended as policy options should not become mandated actions or regulatory programs. 

[BOLD emphasis in original] 

13.2. Other Long-term Strategy Components

 (a) Evaluation of additional Grand Canyon Visibility Transport Commission recommendations. 

Pursuant to 40 CFR 51.309(d)(9), the State of Arizona has evaluated the “additional” recommendations of 

the Grand Canyon Visibility Transport Commission, to determine if any of these recommendations can be 

practicably included in this SIP. The State of Arizona reviewed the Commission's 1996 report, 

Recommendations for Improving Western Vistas, to identify those recommendations that were not 

incorporated into Section 309 of the Regional Haze Rule. This evaluation is described in Appendix A13a of this SIP. 

(b) Implementation of Additional Recommendations. The State of Arizona has identified those 

additional strategies that have been implemented at the national, regional, state, and local levels. Based 

on the evaluation made by the State of Arizona, as described in Appendix A-13a, no additional measures 

have been identified as being practicable or necessary to demonstrate reasonable progress at this time. 

The State of Arizona will re-evaluate the status of implementation of additional recommendation in future 

plan revisions required under 40 CFR 51.309(d)(10). 

13.3. Sources In and Near GCVTC Class I Areas

Pursuant to 40 CFR 51.309(d)(9), the SIP must provide for implementation of all other 

recommendations in the Commission report that can be practicably included as enforceable emission 

limits, schedules of compliance or other enforceable measure to make reasonable progress toward 

remedying existing and preventing future regional haze in the GCVTC Class I areas. The GCVTC report 

also recognizes the importance of visibility issues related to emission sources in and near Class I areas 

and includes recommendations regarding emissions within and near these areas. In addition, the GCVTC 

recommendations for road dust include actions contained in the “In and Near” section of the report to 

address the control or reduction of emissions related to road dust. 

The State of Arizona has in place existing strategies to address the requirements of 40 CFR 

51.309(d)(9) for area sources of dust. The State of Arizona commits to the evaluation of sources of dust 

in and near the GCVTC Class I areas and will develop and implement controls as necessary to 
Chapter 13 – Other GCVTC Options - 116 - Arizona Regional Haze SIP

demonstrate reasonable progress toward the national goal in future SIP revisions as required under 40 

CFR 51.309(d)(10). 

The State of Arizona continues to address the impact of road dust and other dust sources at the 

Colorado Plateau Class I areas and has reviewed, with the help of Federal Land Managers (FLMs) with 

knowledge of the Grand Canyon National Park, Mt. Baldy Wilderness Area, Petrified Forest National 

Park, and Sycamore Canyon Wilderness Area, the type of localized sources of dust that may affect 

visibility in and near these four areas. Descriptions of the Class I areas and summaries of the 

observational and quantitative information provided by the Federal Land Managers to the Arizona 

Regional Haze SIP Dust Management Work Group are found below and in Appendix A-13b, Tables 1 

through 4. 

In addition, in-and-near micro-inventories are being developed by the WRAP for the four Arizona 

Class I areas within the 16 GCVTC Class I areas. Further, the Dust Emissions Joint Forum is 

endeavoring to determine the affects of both regionally and near-field wind-blown dust. This work 

fulfills the need identified by the GCVTC to develop accurate emission inventories and air quality 

modeling to determine appropriate emission control strategies from road dust and other dust sources for 

each Class I area. 

13.3.1. Grand Canyon National Park

The Grand Canyon National Park encompasses 1,218,375 acres of the Colorado River canyon 

and adjacent uplands. This natural preserve is under the jurisdiction of the U.S. National Park Service. 

Intensive visitor use is confined to relatively small areas on the North and South rims, while most of the 

park is remote and primitive. Large areas of Forest Service, Tribal, and private lands surround the Park. 

A summary of emission information for sources of dust within and near the Grand Canyon area is 

contained in Appendix A-13b, Table 1, including information for paved and unpaved roads and wind 

generated emissions. 

13.3.2. Mt. Baldy Wilderness Area

The Mt. Baldy Wilderness is located in the White Mountains along the southern edge of the 

Colorado Plateau and comprises 7,079 acres pine and fir forest on the northeastern flank of Mt. Baldy. 

The Wilderness and areas to the east are primarily under the jurisdiction of the Apache-Sitgreaves 

National Forest. Tracts of State and private land are also included in this multi-use region. Areas to the 

west are under the jurisdiction of the Fort Apache Indian Reservation. The FLM survey of dust sources 

includes information on seasonal recreational access roads. A summary of emission information for the 

Mt. Baldy area is found in Appendix A-13b, Table 2. 

13.3.3. Petrified Forest National Park

The Petrified Forest National Park covers 93,533 acres of grasslands and high desert plateau. 

State, Tribal, and private land are adjacent to the Park. The FLM survey of potential sources of dust in 

this popular preserve includes information on wind generated emissions. A summary of emission 

information for the Petrified Forest area is found in Appendix A-13b, Table 3. 
Chapter 13 – Other GCVTC Options - 117 - Arizona Regional Haze SIP

13.3.4. Sycamore Canyon Wilderness

The Sycamore Canyon Wilderness area comprises 55,937 acres of pine and fir forest on the 

Colorado Plateau and extends southwest, ending at the desert mouth of sycamore creek in the Verde 

Valley. The wilderness and surrounding area is primarily under the jurisdiction of the Prescott, Coconino, 

and Kaibab National Forests. Areas of State, Tribal, and private lands are also located near the 

Wilderness. The FLM survey of potential sources of dust in this recreational area includes information on 

wind generated emissions. A summary of emission information for the Sycamore Canyon area is found 

in Appendix A-13b, Table 4. 
Chapter 13 – Other GCVTC Options - 118 - Arizona Regional Haze SIP

(This page intentionally blank)
Chapter 14 – Projection of Visibility - 119 - Arizona Regional Haze SIP

14. PROJECTION OF VISIBILITY IMPROVEMENT 

The Western Regional Air Partnership (WRAP) performed extensive data gathering and 

modeling to determine the impact of the regional haze program on visibility at the 16 GCVTC Class I 

areas on the Colorado Plateau. The WRAP work effort began with development of a regional 

comprehensive inventory of emissions for all categories of sources. In addition, econometric models and 

new technology profiles were used to project changes in emissions over time expected from 

implementation of current requirements under the Clean Air Act (CAA). The WRAP also estimated 

emission changes resulting from the programs contained in the long-term strategy for regional haze under 

40 CFR 51.309. 

The emission inventories and projections were then used by the WRAP Regional Modeling 

Center to estimate aerosol concentrations and visibility changes at each of the 16 Class I areas using the 

Community Multi-scale Air Quality (CMAQ) model to estimate aerosol concentrations from the emission 

inventories and projections. 

The WRAP results are contained in the WRAP Technical Support Document (WRAP TSD) and 

include detailed descriptions of the emission inventory and projection methods, as well as the air quality 

modeling techniques and results (see WRAP TSD Chapter 1). The projection of expected visibility 

changes are contained in Chapter 2 of the WRAP TSD. The following sections contain an overview of 

the resultant projected changes in emissions and visibility resulting from the implementation of the 

Regional Haze Rule. 

14.1. Effect on Emissions of Long-term Strategy Components

14.1.1. Inventory Methodology and Scope

The WRAP 1996 base emission inventories used for assessment of visibility included the 

following pollutants: 

• Volatile Organic Compounds (VOCs); 

• Oxides of Nitrogen (NOX); 

• Carbon Monoxide (CO); 

• Sulfur Dioxide (SO2); 

• Particulate Matter smaller than 10 microns (PM10); 

• Particulate Matter smaller than 2.5 microns (PM2.5); and, 

• Ammonia (NH3). 

For visibility modeling, the PM2.5 emission inventory was broken down into components, or species, 

representing the key visibility impairing species of interest. Breaking down the PM2.5 into its components 

is necessary since each component has a different effect on visibility. These PM2.5 species are organic 

carbon particles, elemental carbon particles, and other fine material (soils and dusts). The factors used to 

allocate PM2.5 into its components are based on source-specific speciation factors. In addition, the coarse 

material (CM) fraction of PM10 (i.e., PM10 minus PM2.5) was also computed, since course particulate 

matter has a different effect on visibility than fine particulate matter. 

The geographic domain for the inventory included the 22 states west of the Mississippi River, and 

portions of Mexico and Canada. The inventory included emissions from the following categories of 

sources: 

• Area Sources; 

• Stationary Point Sources; 
Chapter 14 – Projection of Visibility - 120 - Arizona Regional Haze SIP

• Mobile Sources (both on-road and non-road); 

• Road Dust (both from paved and unpaved road surfaces); 

• Fire Emissions (agricultural burning, prescribed fire, and wildfire); 

• and, Biogenic Sources. 

In addition to the 1996 base year emission inventory used for model validation, a projected base 

year emission inventory for the year 2018 was developed from the base 1996 inventory and other 

information related to growth and technology issues, but excluding expected changes from control 

strategies required by the Regional Haze Rule. This 2018 base case emission inventory was then 

modified to reflect the impact of the control strategies required by the Regional Haze Rule. This is 

referred to as “Scenario 2” in the WRAP TSD, and are referred to as “2018 w/309” in the tables below. 

The ADEQ established an Emission Inventory Work Group (EIWG) made up of key Arizona 

stakeholders to assist with the review of WRAP’s emission inventory for Arizona’s SIP sources. This 

review was performed in two parts. 

First, the EIWG reviewed the WRAP’s 1996 base emission inventory, comparing estimates with 

other Arizona reference inventories used for non-attainment SIPs. The EIWG’s findings were 

summarized in a memorandum to WRAP (see Appendix A-14a). The EIWG concluded that the 1996 

inventory was adequate for current Regional Haze SIP modeling, but identified several areas that should 

be addressed in future WRAP emission inventory improvement projects. 

Second, the EIWG reviewed the 2018 emission growth/projection factors used to develop the 

2018 inventory. This review included an analysis of accuracy of earlier projections, such as the growth 

factors used in the GCVTC Integrated Assessment System, and more recent projections performed by the 

Arizona Department of Economic Security, U.S. Census Bureau data, and forecasts prepared by the 

metropolitan planning organizations. Although differences were found, the EIWG concluded that the 

long-range forecast factors were within the level of uncertainty in any long-range economic forecast. 

Areas for future improvement of the WRAP inventory projections were summarized in a memorandum to 

WRAP (also in Appendix A-14a). 

In addition to the EIWG, ADEQ also established the Technical Assessment Work Group 

(TAWG) to review the assessment and modeling methodologies used by the WRAP. The TAWG 

reviewed the WRAP TSD and identified areas for future improvements in a memorandum to WRAP (also 

in Appendix A-14a). 

14.1.2. Projected Changes in Emissions for Arizona

The projected change in emissions for the State of Arizona are summarized in Table 14-1. As 

shown, emissions of sulfur dioxide are expected to decrease by 36% by 2018. In addition, by 2018 

emissions of oxides of nitrogen and volatile organic compounds are expected to decline by 16% and 25%, 

respectively. Table 14-2 shows similar emission reductions for the nine-state GCVTC Transport Region. 

Appendix A-14b, Tables 1 through 3, provide more detailed summaries of emissions by source category, 

including emissions estimates for the 2018 WRAP Base Case. Also, Appendix A-14b, Table 4, 

summarizes the detailed county-level emission for Arizona. Information in Appendix A-14b were 

derived from WRAP county-level emission inventories contained in the WRAP TSD emission 

appendices. 
Chapter 14 – Projection of Visibility - 121 - Arizona Regional Haze SIP

Table 14-1. Changes in Emissions from 1996 to 2018 for Arizona Sources 

(Tons per Year) 

Year PM2.5

* CM SO2 NOx VOC 

1996 147.9 98.8 217.9 454.0 372.3 

2018 w/309 143.3 103.6 139.3 383.2 277.8 

% Change -3% 5% -36% -16% -25%

* PM2.5 includes organic carbon, elemental carbon, and fine soils/dusts. 

Table 14.2. Changes in Emissions from 1996 to 2018 for 9 GCVTC States 

(Tons per Year) 

Year PM2.5*

 CM SO2 NOx VOC 

1996 1,196.7 1,170.6 1,036.3 3,952.1 3,325.3 

2018 w/309 1,228.3 1,198.4 808.9 2,691.8 2,339.2 

% Change 3% 2% -22% -32% -30%

* PM2.5 includes organic carbon, elemental carbon, and fine soils/dusts. 

14.2. Projected Changes in Visual Air Quality

14.2.1. Applicable Class I Areas

This projection of visibility improvement addresses the 16 Class I areas of the Colorado Plateau, 

as defined in 40 CFR 51.309(b)(1) that are described in Chapter 3 of the WRAP TSD. 

14.2.2. Projected visibility improvement

Pursuant to 40 CFR 51. 309(d)(2), Tables 14-3 and 14-4 indicate the projected visibility 

conditions in deciviews for each of the 16 Class I areas, from the baseline emission projection year of 

1996 through December 31, 2018. These projections were made for the 20% worst days and 20% best 

days, and are expressed in deciviews (dV). The first column represents the best estimate of actual 

visibility conditions in 1996. Because the IMPROVE monitoring network was significant expanded from 

1999 through 2001, the actual visual air quality values in the first column represent the most recent and 

representative five years of monitoring data from 1997 through 2001. The second column represents the 

expected conditions in 2018 without the implementation of the strategies and programs contained in this 

SIP. The final column represents the expected conditions in 2018 with the implementation of this SIP 

strategies and programs. Chapter 2 and Appendix A of the WRAP TSD describe the control strategies 

included in the air quality modeling projections. 
Chapter 14 – Projection of Visibility - 122 - Arizona Regional Haze SIP

Table 14-3. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018 on 

the Average 20% Worst Days, resulting from implementation of “All 309 Control Strategies”. 

Colorado Plateau 

Class I Area State 

1996 - 20% Worst 

Days’ Visibility 

(dV) 

(Base Case) 

2018 - 20% Worst 

Days’ Visibility (dV) 

(Base Case - all 

controls “on the 

books” as of 2002) 

2018 - 20% Worst Days’ 

Visibility (dV) 

(All §309 Control 

Strategies including 

Optimal Smoke 

Management) 

Grand Canyon National 

Park AZ 12.30 11.62 11.51 

Mount Baldy 

Wilderness AZ 14.30 12.22 11.96 

Petrified Forest 

National Park AZ 13.00 11.99 11.74 

Sycamore Canyon 

Wilderness AZ 15.40 11.63 11.48 

Black Canyon of the 

Gunnison NP 

Wilderness 

CO 11.30 10.90 10.60 

Flat Tops Wilderness CO 10.50 11.04 10.73 

Maroon Bells 

Wilderness CO 10.60 11.15 10.84 

Mesa Verde National 

Park CO 13.10 12.24 11.84 

Weminuche Wilderness CO 10.60 11.19 10.84 

West Elk Wilderness CO 11.30 11.08 10.72 

San Pedro Parks 

Wilderness NM 10.70 12.33 11.71 

Arches National Park UT 12.10 12.41 12.15 

Bryce Canyon National 

Park UT 11.80 12.26 11.95 

Canyonlands National 

Park UT 12.10 12.41 12.18 

Capitol Reef National 

Park UT 12.10 12.51 12.36 

Zion National Park UT 13.60 12.13 12.03 
Chapter 14 – Projection of Visibility - 123 - Arizona Regional Haze SIP

Table 14-4. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018, on 

the Average 20% Best Visibility Days, resulting from implementation of “All 309 Control 

Strategies”. 

Colorado Plateau 

Class I Area State 

1996 - 20% Best Days’ 

Visibility (dV) 

(Base Case) 

2018 - 20% Best Days’ 

Visibility (dV) 

(Base Case - all 

controls “on the 

books” as of 2002) 

2018 - 20% Best Days’ 

Visibility (dV) 

(All §309 Control 

Strategies including 

Optimal Smoke 

Management) 

Grand Canyon National 

Park AZ 4.80 4.76 4.64 

Mount Baldy 

Wilderness AZ 5.50 5.49 5.36 

Petrified Forest 

National Park AZ 6.50 5.18 5.10 

Sycamore Canyon 

Wilderness AZ 6.30 4.85 4.75 

Black Canyon of the 

Gunnison NP 

Wilderness 

CO 4.60 3.89 3.75 

Flat Tops Wilderness CO 3.10 3.96 3.81 

Maroon Bells 

Wilderness CO 3.10 3.90 3.80 

Mesa Verde National 

Park CO 5.50 4.40 4.33 

Weminuche Wilderness CO 3.10 3.89 3.74 

West Elk Wilderness CO 4.60 3.97 3.82 

San Pedro Parks 

Wilderness NM 4.00 5.59 5.36 

Arches National Park UT 5.50 4.85 4.61 

Bryce Canyon National 

Park UT 4.30 3.91 3.89 

Canyonlands National 

Park UT 5.60 4.87 4.67 

Capitol Reef National 

Park UT 5.60 4.85 4.75 

Zion National Park UT 5.90 3.81 3.75 
Chapter 14 – Projection of Visibility - 124 - Arizona Regional Haze SIP

(This page intentionally blank)
Chapter 15 – Coordination - 125 - Arizona Regional Haze SIP

15. STATE PLANNING/INTERSTATE COORDINATION AND 

TRIBAL IMPLEMENTATION

15.1. Participation in Regional Planning and Coordination

Pursuant to 40 CFR 51.309(d)(11), the State of Arizona has participated in regional planning and 

coordination with other states in developing its emission reduction strategies under 40 CFR 51.309, 

related to protecting the 16 Class I areas of the Colorado Plateau. This participation was through 

Arizona’s leadership of the Grand Canyon Visibility Transport Commission (GCVTC) and participation 

in the Western Regional Air Partnership (WRAP). The State of Arizona has provided staff in leadership 

positions of many of the WRAP committees and forums, and encourages participation of Arizona 

stakeholders in the WRAP process. The State of Arizona has been nominated to assume the position of 

Co-chair of the WRAP and will continue to participate actively in WRAP activities. 

In order to coordinate implementation issues associated with this SIP, the State of Arizona will 

serve on the recently established “309 Coordinating Committee” of the WRAP. This standing committee 

is chartered to perform the necessary implementation tracking for the states and tribes submitting SIPs 

and TIPs to address the requirements of 40 CFR 51.309. 

15.2. Applicability to Tribal Lands

Pursuant to 40 CFR 51.309(d)(12), and in accordance with the Tribal Authority Rule (63 FR 

7253, February 12, 1998), all Tribes have the option to develop a regional haze Tribal Implementation 

Plan (TIP) for their lands to assure reasonable progress in the 16 Class I areas of the Colorado Plateau. 

As such, no provisions of this SIP are applicable to tribal lands. 
Chapter 15 – Coordination - 126 - Arizona Regional Haze SIP

(This page intentionally blank) 
Chapter 16 – Plan Revisions - 127 - Arizona Regional Haze SIP

16. PERIODIC IMPLEMENTATION PLAN REVISION

(a) Periodic Progress Reports for demonstrating Reasonable Progress. Pursuant to 40 CFR 

51.309(d)(10)(i), the State of Arizona commits to submit to EPA periodic progress reports for the years 

2008, 2013 and 2018. The demonstration may be conducted by the WRAP, with assistance from 

Arizona, and shall address the elements listed under 40 CFR 51.309(d)(10)(i)(A) through (G) for the 

Colorado Plateau areas: 

1. Implementation status of this SIP’s measures; 

2. Summary of emissions reductions; 

3. Assessment of the 20% most/least impaired days; 

4. Analysis of emission reductions by pollutant; 

5. Analysis of significant changes in anthropogenic emissions; 

6. Assessment of this SIP’s adequacy; and 

7. Assessment of visibility monitoring strategy. 

(b) Actions to be taken concurrent with Periodic Progress Reports. Pursuant to 40 CFR 

51.309(d)(10)(ii), the State of Arizona commits to take one of the following actions based upon 

information contained in each periodic progress report: 

1. Provide a negative declaration statement to EPA saying that no SIP revision is needed if 

reasonable progress is being made, in accordance with section (a) above; 

2. If the State finds that the SIP is inadequate to ensure reasonable progress due to emissions from 

outside the State, the State of Arizona commits to notify EPA and the other contributing state(s), 

and initiate efforts through a regional planning process to address the emissions in question. The 

State of Arizona commits to identify in the next progress report the outcome of this regional 

planning effort, including any additional strategies that were developed to address the plan’s 

deficiencies; 

3. If the State finds that the SIP is inadequate to ensure reasonable progress due to emissions from 

another country, the State of Arizona commits to notify EPA and provide information on the 

impairment being caused by these emissions; or 

4. If the State finds that the SIP is inadequate to ensure reasonable progress due to emissions from 

within Arizona, the State of Arizona commits to develop additional strategies to address the plan 

deficiencies and revise the SIP no later than one year from the date that the progress report was 

due. 
Chapter 16 – Plan Revisions - 128 - Arizona Regional Haze SIP

(This page intentionally blank)
Chapter 17 – Additional Class I Areas - 129 - Arizona Regional Haze SIP

17. DECLARATION OF TREATMENT FOR ADDITIONAL 

CLASS I AREAS UNDER 40 CFR 51.309(g)

The requirements for reasonable progress for Additional Class I areas are discussed on page 

35758 in the Preamble to the RHR. Section 309 of the RHR requires that the first SIP due by December 

31, 2003 address the 16 Class I areas of the Colorado Plateau. Additional Class I areas do not need to be 

addressed until December 31, 2008. 40 CFR 51.309(g)(1) requires states to declare in the SIP due by 

December 31, 2003 whether the Additional Class I areas will be addressed under 40 CFR 51.308, or 

under 40 CFR 51.309(g). 

 

a. Declaration for Additional Class I areas. Pursuant to 40 CFR 51.309(g)(1), the State of 

Arizona commits to submittal of a SIP supplement under 40 CFR 51.309(g) for the eight 

Additional Class I areas in the State of Arizona. Arizona shall submit the SIP revision 

for the eight Additional Class I areas as early as practicable, but no later than December 

31, 2008. The eight Additional Class I areas in Arizona that will be addressed under 40 

CFR 51.309(g) include: Chiricahua National Monument and Chiricahua, Galiuro, 

Mazatzal, Pine Mountain, Saguaro, Sierra Ancha, and Superstition Wilderness Areas. 

These Additional Class I areas are shown in Figure 17-1. 

Figure 17-1 Arizona Additional non-GCVTC Class I Areas. 
Chapter 17 – Additional Class I Areas - 130 - Arizona Regional Haze SIP

The State of Arizona, if necessary to address reasonable progress for non-GCVTC Additional 

Class I areas outside of Arizona, will rely the procedures under 40 CFR 51.309(g)(2) and (3) and submit a 

SIP revision by December 31, 2008, to address reasonable progress for any such areas. 
Chapter 18 - Public Participation - 131 - Arizona Regional Haze SIP

18. PUBLIC PARTICIPATION AND REVIEW PROCESS

Public participation and review process documents for the rulemakings described in this SIP can 

be located in the appendix for the related chapter in which those rules are references (e.g., for the RAVI 

rule see Chapter 5; for WEB trading program rule see Chapter 7; and, for the fire rules see Chapter 10). 

This chapter contains the public participation and review process documents associated with the SIP only. 

18.1. Public Hearing Notice

Notices of the public hearings were published in The Arizona Republic (Phoenix and statewide), 

The Arizona Daily Star and Tucson Citizen (Tucson Newspapers), and the Arizona Daily Sun (Coconino 

County/Flagstaff) on October 24, 2003. Copies of the notices are contained in Appendix A-18a. 

18.2. Hearing Transcripts

Agendas, sign-in sheets, transcripts and hearing officer certifications for the public hearings held 

on November 24, 2003 in Phoenix, Arizona, and Flagstaff, Arizona, are contained in Appendix A-18b. 

18.3. Written Comments Received

Several written comments were received by ADEQ before the end of the comment period 

(December 3, 2003). These were utilized in finalizing revisions to this SIP and are contained in Appendix 

A-18c. 

18.4. Responsiveness Summary

Based on the oral comments received at the public hearings, and written comments received by 

the close of the comment period, the State of Arizona made appropriate revisions the Public Review Draft 

of the SIP released on October 24, 2003. Appendix A-18d contains the response to comments developed 

by the State of Arizona addressing the requirements under 40 CFR 51.102. 
Chapter 18 - Public Participation - 132 - Arizona Regional Haze SIP

(This page intentionally blank)