Western Regional Air Partnership 

2005 Work Plan 

December 7, 2004 
Table of Contents

I. Introduction ........................................................................................................... 1 

II. Project Summaries ................................................................................. 11 

 A. Initiatives Oversight Committee ....................................................................... 11 

 B. Stationary Sources Joint Forum ....................................................................... 11 

 C. Fire Emissions Joint Forum ............................................................................ 12 

 D. Air Pollution Prevention Forum ..................................................................... 16 

 E. Mobile Source Forum ................................................................................. 17 

 F. Sources In and Near Class I Areas Forum ...................................................... 18 

 G. Economic Analysis Forum ........................................................................... 18 

 H. Air Quality Modeling Forum ........................................................................... 21 

 I. Emission Forum ........................................................................................ 22 

 J. Tribal Data Development Work Group ............................................................... 25 

 K. Dust Emissions Joint Forum ..................................................................... 27 

 L. Ambient Monitoring and Reporting Forum .......................................................... 28 

 M. Attribution of Haze Work Group ...................................................................... 29 

 N. 309 Coordinating Committee ........................................................................... 31 

 O. Air Managers Committee .............................................................................. 31 

 P. Communications Committee .......................................................................... 35 

APPENDIX A: Background 

I. Background....................................................................................... 36 

II. Tribal Options for Implementation Plan Development........................................... 36 

III. WRAP Organization and Structure..................................................................... 37 

A. Membership 

B. Charter and Bylaws 

C. WRAP Organization 

D. Oversight Committees (Initiatives and Technical) 

E. Communications Committee 

F. Stakeholder Involvement 

IV. Project Management ........................................................................................ 39 

A. Setting Priorities 

B. Reconciling Conflicts 

C. Outreach and Peer Review 

D. State and Tribal Coordination 

E. Administration and Staffing 

F. Contract Management 

APPENDIX B: Process Overview for 2005 WRAP Projects – pg.43 

APPENDIX C: WRAP Region, Members, & Federal Class I Areas – pg. 44 

APPENDIX D: Map of Tribal Lands & Tribal Class I Areas in the WRAP Region – pg. 45 

APPENDIX E: WRAP Organizational Chart – pg. 46 
1

I. INTRODUCTION 

This work plan summarizes activities and expenditures planned by the Western Regional Air 

Partnership (WRAP) for calendar year 2005, including activities initiated in earlier years and 

new activities. 

The WRAP is funded through annual grants from the U.S. EPA. This work plan will be 

submitted to EPA as part of the WRAP’s grant application for the federal FY04 funds ($3.08 

million) awarded to the WRAP to support ongoing technical and policy work related to the 

development of state and tribal regional haze plans for the West. 

Table 2 (pages 6 to 8) provides a list of the projects that will be funded in calendar year 2005 by 

the WRAP’s federal FY04 grant. The funding levels for these projects are shown in the last 

column of the table, titled “2005 Request”. 

Table 2 also lists projects funded through previous years’ grants which are currently underway 

(column titled “Projects Underway”) or which are pending initiation in 2005 (column titled 

“Projects Pending”). For those projects underway, the table lists actual “Expenses to Date” as of 

August 31, 2004. 

The completion in December of 2003 of Section 309 regional haze plans by five WRAP states 

and the city of Albuquerque represented a significant accomplishment of the WRAP. The 

WRAP’s principal effort in 2005 will be to build on the work completed through the Section 309 

plans in order to support state and tribal demonstrations of reasonable progress to improve 

visibility at the more than one hundred Class I areas in the WRAP region. 

Recognizing this challenge, the WRAP completed a long-term strategic plan in 2003.1

 Figure 1 

on pages 9 and 10 shows the strategic plan time line and major project milestones. The time line 

and major milestones from the strategic plan provide the overall schedule and objectives for this 

work plan. The Strategic Plan also serves as an instrument of coordination and provides the 

direction and transparency needed to foster stakeholder participation and consensus-based 

decision making, which are key features of the WRAP process. The strategic plan also provides 

guidance to the individual plans of WRAP forums and committees which are included in this 

work plan. 

On a more general level, the WRAP’s planning process must accommodate a unique landscape 

of environmental, social, economic, and political issues. The WRAP region includes 116 (or 

75 percent) of the nation’s 156 mandatory federal Class I areas, half the land mass of the United 

States (not including Alaska), a very large portion of publicly-owned lands, and numerous tribal 

jurisdictions (many with large land areas). It also emits a minority of total U.S. emissions, 

borders both Canada and Mexico, and receives pollution from Asia. Most WRAP members will 

not have to contend with ongoing ozone and particulate matter nonattainment issues, which 

simplifies air quality planning to some extent, but many WRAP members are faced with rapid 

population growth and other challenges to preventing deterioration of air quality. Moreover, the 

 

1

 See http://www.wrapair.org/forums/sp/docs.html
2

WRAP must be sensitive to other regionally-important environmental issues, such as fire and 

drought. This presents a unique and challenging environment for long-term planning which is 

best addressed through a single, well-funded and well-organized institution at the appropriate 

political level. The WRAP, with the appropriate EPA financial support, provides such an 

institution, especially given its co-management structure shared between the Western Governors’ 

Association and the National Tribal Environmental Council. 

Finally, the WRAP’s long-term planning process must be prepared to deal with relevant events 

beyond its control, such as federal multi-pollutant initiatives and the ramifications of legal 

challenges to the RHR. One way the WRAP contends with these events is to have sufficient 

staffing to track the issues and to foster a constructive dialogue among its members. 
3

Table 1: Overview of WRAP 2004 - 2005 Key Deliverables

Time 

Frame Responsible Group/Subject Deliverable (completion target month) 

Emissions Forum 

 Operational version of Emissions Data Management System (EDMS) with 

region. (December) 

 NH3 inventory improvement project complete (October) 

Fire Forum (Phase 2 EI project) Final 2002 complete fire EI – actual 2002 emissions, stored in EDMS. (DecMonitoring Forum (CoHA project) 

 Source apportionment of each state’s major emissions source category impa

report. (December) 

 Descriptive analyses of 2002 monitored impact at Class I areas in AoH repo

Modeling Forum (TSSA project) 

 Source apportionment of each state’s major emissions source category impa

report. (December) 

 Source apportionment of each state’s natural and manmade emissions at Cla

(December) 

 Boundary conditions and new emissions estimates from WRAP Fire Forum

Mexico updated. (September-October) 

Attribution of Haze WG 

 AoH 2004 Draft Report draft complete – Integrated “weight of evidence” so

state’s emissions source category impacts at Class I areas, from TSSA and C2002 “interim” (not EDMS) EIs. (December) 

Tribal Data Development WG  Tribal monitoring data analysis from CoHA project for tribal Class I areas in Stationary Sources Forum 

 List of BART-eligible sources (December) 

 Begin work on oil/gas and point source EI projections. 

Dust Emissions Forum 

 Phase 2 windblown dust emissions inventory model completed, evaluated, a

subsequent modeling analyses. (October) 

 Causes of Dust analysis products from CoHA project. (December) 

 Fugitive dust handbook and website. (December) 

2004 Q4 

Economic Analysis Forum  Complete pilot study / demonstration of economic analysis framework. (Dec
4

Emissions Forum 

 EDMS updated with 2018 base case EI for WRAP region. (April, pending S

below) 

Fire Forum (Phase 3 EI project)  2000-04 baseline period fire EI – for planning purposes, stored in EDMS. (MMonitoring Forum (CoHA project) 

 Continuing development of conceptual models and processing of additional 

Modeling Forum (2002 base case modeling project) 

 Modeling performance evaluation using actual 2002 emissions from EDMS

monitoring data. (March) 

Attribution of Haze WG • AoH 2004 Final Report complete – see draft description above in 2004 Q4. Tribal Data Development WG • Tribal monitoring needs report from CoHA project for tribal Class I areas. (

 Review, improve, project emissions inventories of point and oil/gas sources 

Stationary Sources Forum 

 Review and improve the 2002 point and area source inventory. (February) Begin work on oil/gas and point/area source EI projections. (January)

Mobile Sources Forum  Workshop to initiate offroad retrofit program. (January) Dust Emissions Forum  Establish a preliminary definition of dust and release for public review. 

2005 Q1 

In and Near Forum • Summarize PM10 SIPs for local sources and their transferability to Class I arEmissions Forum 

 Prepare scenarios’ specifications and EIs for 2018 control strategy projectio

in EDMS. (June) 

Fire Emissions Forum (Phase 4 EI project) 

 2018 projection year fire EIs consisting of 2 to 3 scenarios, stored in EDMS

Monitoring Forum (CoHA)  Continuing development of conceptual models and processing of additional Modeling Forum (2018 base case modeling project) 

 Modeling performance evaluation using 2018 base case emissions from EDM

Stationary Sources Forum  Complete work on oil/gas and point source EI projection scenarios. (June) 

2005 Q2 

Dust Emissions Forum 

 Host dust control measures workshop  Complete enhanced ambient data analysis  Establish appropriate size distribution of fine versus coarse dust emissions. 
5

Emissions Forum 

 Continuing emissions analyses for 2018 control strategy scenarios. (Septem

Monitoring Forum (CoHA project) 

 Begin to define work products for reasonable progress tracking for second A

 Define analyses and work products for second AoH report. (August) 

Modeling Forum (2018 control strategy modeling project) 

 Start source apportionment of each state’s 2018 major emissions source cate

areas, associated with control strategy scenarios for second AoH report. (Se

Attribution of Haze WG 

 Start second AoH project - integrated “weight of evidence” source attributio

control strategies, to be complete early 2006. (July) 

Stationary Sources Forum  Continue work on control technology analysis and program development 

2005 Q3 

Dust Emissions Forum  Complete definition of dust Emissions Forum  Continuing emissions analyses for 2018 control strategy scenarios. (NovembMonitoring Forum (CoHA)  Work products to support AoH report. (December) Modeling Forum (2018 control strategy modeling project) 

 Continuing source apportionment of each state’s 2018 major emissions sour

Class I areas, associated with control strategy scenarios. (December) 

 Source apportionment of each state’s natural and manmade emissions at Cla

Attribution of Haze WG 

 Continue work on second AoH project analysis - integrated “weight of evid

each Class I area’s control strategies, to be complete early 2006. (December

Stationary Sources Forum  Continue work on control technology analysis and program development 

2005 Q4 

Dust Emissions Forum  Complete analysis of sources and control options in high-dust areas 
6

Table 2. August 31, 2004 Status Report and 2005 Budget. 

Project 

Code Project Title Projects Underway 

Expenses 

to Date 

Projects 

Pending 

2005 

Request 

Stationary Sources Joint Forum 

SS1 Identification of BART-Eligible Sources (ERG) 125,811 78,997 

SS4 Technical Support for Emissions and Control 

Technology Analysis 149,000 25,000

SS5 Regional Stationary Source Strategy Development 150,000

Fire Emissions Joint Forum 

FF “C” 

+ 1 

2002 Inventory (Phase I) and Wildland Fire 

Emissions Tradeoff Model Review (Air Sciences) 157,464 92,877 

FF7 2002 National Wildfire EI (inter-RPO project - Air 

Sciences) 100,000 26,500

FF"C" 2002 Inventory - Phase II (Air Sciences) 167,000

FF"D" Sensitivity Runs Phase II: Regional and Mesoscale 100,000

FF”E” Fire Emissions Categorization Guidance - 

Restoration / Maintenance Difference 10,000

FF4 Regional Modeling Center Support 25,000

FF5 Fire Tracking System / EDMS 40,000

FF6+3 Phase III & IV Inventories & Preliminary 

Assessment of Apportionment Methods 170,000

FF8 Methods for Calculating Benefits of ERTs to 

Support AEG Policy 75,000

FF9 Regional Coordination of Smoke Management 

Programs 25,000

FF12 Smoke Mgmt Technical and Policy Workshop 25,000

Air Pollution Prevention Forum 

PP2 Renewable Energy Tracking and Certificates (CEC) 80,000 

PP2 Renewable Energy Tracking and Certificates 100,000

PP5 Displaced Emissions Analysis 15,000

PP6 WGA Clean Energy Initiative 100,000 

Mobile Sources Forum 

MS1 Coordinator to Support Non-Road Demonstration 

Projects - (Emissions Advantage) 144,544 100,000

Sources In and Near Class I Areas Forum 

IN2 In/Near Strategies for Reasonable Progress 

(Review PM-10 SIPs) 50,000 25,000

Economic Analysis Forum 

EA1 Framework Application Test (BBC) 89,980 42,760 

EA1 Mobile Sources (Emissions Advantage) 15,000 11,266 

EA2 Development of Baseline Economic Data 55,000 30,000

EA3 Enhancement of Cost and Benefit Unit Values 80,000

EA4 Screening Tool 40,000

EA6 Economic Assessment Capability 50,000

Air Quality Modeling Forum 

MF1 Regional Modeling Center (UCR) 2,640,599 1,925,935 70,000 430,000
7

Project 

Code Project Title Projects Underway 

Expenses 

to Date 

Projects 

Pending 

2005 

Request 

2004 subtototal = $556,832 plus subtasks below 

for a total of $884,942 

Fire Sensitivity Runs - 42,650 

Training and Outreach Activities- 65,000 

MM5 Runs - 20,000 

Wind Blown Dust - 51,283 

MF2 Alaska Modeling- 200,460 

Tech-Wide Projects (TOC) 

 Co-sponsor March 2004 Organic Aerosols 

Workshop (FLC) 10,000 9,936 

 Geographic Data Display (Pangea) 24,919 22,427 

Emissions Forum 

EF1 EDMS (Pechan) 560,278 432,748 

EF1 2004 EDMS Testing - Phase I (ERG) 25,000 

EF1 2004 EDMS Testing - Phase II 25,000

EF1 2005 EDMS Hosting / Operation 180,000

EF1 2018 Base Case and Control Strategy Point and 

Area Source EI Projections 91,000

EF1 Fire Module Improvements 105,000

EF2 Representative Community EIs - Rural Alaska 

(Sierra Research) 139,888 4,239 

EF3 Update On-road & Non-road Input Data & Generate 

EIs for 2002, 08, 13, 18 125,000

EF7 Alaska Aviation Inventory (RFP) 49,998 

Tribal Data Development Work Group 

 Tribal Inventory Gathering and Analysis 

(ITEP/NAU) - Phase III 316,000 0 

TW1 Emissions Data Development Support 103,000

TW5 Continue Emissions Inventory & TEISS Technical 

Support 98,000

Dust Emissions Joint Forum 

DF1 Common Definition of Dust and Dust Types 45,000

DF2 Enhanced Ambient Data Analysis 50,000

DF3 Fine Fraction of Dust EFs 120,000

DF4 Wind Blown Dust Inventory Improvement 

(Environ) 182,324 156,642 

DF5 Fugitive Dust Handbook, Website (Countess/MRI) 71,327 29,963 20,000

DF7 Dust Control Measures Workshop 10,000

Ambient Monitoring and Reporting Forum 

AMR1 VIEWS Data Base 499,724 406,676 

AMR2 Causes of Haze Report, including $50 K for Dust 

(DF2) & $85 K for Tribal Areas (DRI) 550,000 382,235 225,000

AMR3 Natural Haze Levels Analysis (from OAQPS, 

national project) (Tombach) 85,000 0 
8

Project 

Code Project Title Projects Underway 

Expenses 

to Date 

Projects 

Pending 

2005 

Request 

Attribution of Haze Work Group 

 Report on 2002-04 Organic Aerosols Workshop 

series (T. Richard) 5,000 

AoH1 Contractor Support for Attribution of Haze (ARS) 88,520 75,000

AoH2 WIGIMS Implementation 60,000 107,000

309 Coordinating Committee 

309a Annex Implementation - 2003 Emissions Report 

(Perrin Quarles) 21,855 988 

Air Managers Committee 

AMC1 State Caucus Staff Support (WESTAR) 347,434 283,036 120,000

AMC2 AK Tribal Outreach Coordinator (NTEC) 75,000 0 

AMC3 Health and Environmental Assessment of HazeRelated Improvements 45,000

AMC4 Traditional Tribal Practices and Regional Haze 35,000

AMC5 308 Implementation Work Group Support 

(WESTAR) 18,000 5,394 20,000 38,000

AMC6 Workshops on Effective Collaboration 20,000

 Contractor Assistance 103,580

Communications Committee 

 Outreach Assistance (Pat Murdo) 54,700 35,469 

 Retool Web Site (Cobalt) 28,269 23,977 

CC1 Web Site Maintenance (B. Bissey) 125,000 97,201 23,500

CC6 Graphics for Children’s Handout 8,600 

CC2-5 Public Outreach and Communication 41,400

Subtotal for Contractor Assistance 6,740,234 4,042,764 2,151,980 1,766,000

Travel and Project Management 

WGA 

2005 

Request 

Travel Reimbursements 172,245

Conference Calls 26,024

Meeting Expenses 53,679

Direct Salaries and Benefits 313,490

Overhead & Other Expenses 239,663

Subtotal 805,101

NTEC 

Direct Salaries and Benefits 361,140

Travel Reimbursements 115,400

Overhead & Other Expenses 78,800

2002-2003 Remaining funds for Carryover (45,200)

Subtotal 510,140

Contractor Assistance 1,766,000

Total 3,081,241
9

Figure 1. Strategic Plan Timeline (Updated October 13, 2004). 
10
11

II. PROJECT SUMMARIES 

The following sections provide project summaries for each of the WRAP’s forums, committees 

and work groups. These projects were developed by the forums consistent with the direction 

provided in the strategic plan and by the oversight committees (Initiatives Oversight Committee 

and Technical Oversight Committee). The WRAP Planning Team (oversight committee 

members and forum, committee, and work group co-chairs) finalized the list of projects, and 

funding levels, ultimately included in this work plan and approved by the WRAP Board. 

The IOC provides overall direction and review to the forums evaluating potential emissions 

control strategies for regional haze in the West. The IOC has identified two general areas of 

investigation related to how the work of the individual forums might be aggregated into regional 

haze plans. 

IO1 Reasonable Progress Criteria – The regional haze rule requires states, when establishing 

reasonable progress goals, to consider the following statutory factors: the cost of 

compliance, the time necessary for compliance, the energy and nonair quality 

environmental impacts of compliance, and the remaining useful life of any potentially 

affected source. Furthermore, states must include a demonstration in their SIPs showing 

how these factors were taken into consideration in selecting each goal. The purpose of 

this task is to explore these factors (e.g., how they have been used or interpreted in other 

environmental programs) and to provide further definition and guidance with respect to 

using them in a regional haze SIP demonstration. 

IO2 Process for Identifying Control Strategies – The WRAP strategic plan identifies a 

“navigational challenge” identifying and selecting emission control strategies among the 

large number of those potentially available. It also provides some general ideas on how 

to “narrow the field.” The purpose of this task is to develop a process by which the most 

effective control strategies will be identified and refined. 

This work plan assumes that most BART activities will be undertaken by those jurisdictions 

which choose to implement BART under Section 308(e)(1) of the Regional Haze Rule. Hence, 

the focus of this work plan is on the development of alternative programs (e.g., emission trading 

programs) for SO2 and NOx. Other activities by the SSJF will include working with EPA to 

finalize the proposed BART guidelines and to address any potential expansion of the Clean Air 

Interstate Rule (CAIR) to the West. In the course of its work, the SSJF will assume that the fivestate SO2 milestone and backstop emissions trading program will remain in effect and must be 

preserved in any regional strategy. Finally, NOx and PM emissions must be addressed in such a 

way as to satisfy the SIP revision requirements under Section 309 of the Regional Haze Rule, as 

well as Section 308. 

Initiatives Oversight Committee

Stationary Sources Joint Forum
12

SS4 Technical Support for Emissions and Control Technology Analysis – The purpose of this 

project is to support WRAP activities to address emissions from point and area sources 

by providing WRAP work groups and forums with data, information, and assessments to 

support the development of programs to address the contribution of Western point and 

area sources to regional haze at mandatory Class 1 federal areas. The emissions 

inventory work will include inventory analysis, inventory improvements, and future year 

projections of point and area sources. The control technology analysis will address issues 

such as costs, control efficiencies, and other impacts on the source and environment. For 

SO2, consideration will be given to expansion of the Annex. For NOx, consideration will 

be given to both EGU and non-EGU sources. Other pollutants will be addressed as 

necessary. 

There are several uncertainties that must be factored into the work of the WRAP. These 

include the possibility of federal multi-pollutant initiatives for electric utilities, the final 

federal rule for Best Available Retrofit Technology (BART) due by April 2005, and the 

extent to which WRAP states and tribes choose to implement source-specific BART as 

opposed to an alternative program (i.e., regional emissions trading). As a result, there is a 

need to maintain flexibility in program design and to assess new information as it 

becomes available, including information from ongoing WRAP technical studies which 

will provide more information on the contribution of various sources to regional haze in 

the West. A single contractor or team of contractors will be sought for consistency over 

the course of the project, as developing a point and area source program will likely be an 

iterative process and may require revisiting analyses as assumptions change or new data 

become available. 

SS5 Regional Stationary Source Strategy Development – This project will include activities 

which are needed to (1) further implement alternative programs to BART or (2) address 

sources and/or pollutants which are not included in the alternative programs. Such 

activities may include providing a forum for coordinating the implementation of BART, 

estimating the likely emission reductions from the application of BART, demonstrating 

that an alternative program is better than BART, and addressing trading program design 

issues, such as 2018 and interim milestones; geographic, new source, and tribal 

considerations; monitoring and reporting requirements; enforcement provisions; 

economic impact assessments; and a general method for allowance allocation. 

The FEJF projects identified in the existing 2004 WRAP Work Plan, and the proposed FEJF 

projects for the 2005 WRAP Work Plan, fall into two main categories: 

1) The first category provides analyses of technical and policy information needed for 

further Policy Refinement and Implementation of existing fire policies and programs 

applicable to the needs of §309 and §308 states. 

Fire Emissions Joint Forum
13

2) The second category addresses existing and future Technical Needs, specifically 

emissions inventory development and related modeling analyses, fire tracking and 

emissions data management system, and emission reduction techniques. 

No additional 2005 funding is requested as funding has been reprogrammed from funds allocated 

to FEJF in the 2004 WRAP Work Plan. 

FEJF Policy Refinement and Implementation 

FF1 Wildland Fire Effects Trade-Off Model Review – This project was funded and started in 

2004. As fire management programs evolve, and as directed by the GCVTC, the 

applicability of the Wildland Fire Emissions Trade-off Model (FETM) will be reviewed 

for use in applying existing WRAP policies and guidance pertaining to smoke 

management of fire. Recommendations from this assessment have possible linkage to 

both the Enhanced Smoke Management Program and the Annual Emissions Goal 

policies, both §309 requirements and potentially useful approaches for §308. FETM may 

also be useful in the development of scenarios for future fire emissions inventories. 

FF”E” Fire Emissions Categorization Guidance: Restoration / Maintenance Difference – This 

project was funded in 2003 and started in 2004. Develop further user guidance to support 

the existing WRAP Policy for Categorizing Fire Emissions, to refine differences between 

restoration and maintenance prescribed burns in terms of vegetation structure, fuel 

loading, fuel size classes, ecosystem function and fire resilience. This project directly 

supports the “anthropogenic” / “natural” apportionment for implementation of the FTS 

requirement in §309 as well as similar implementation issues for §308. These 

categorizations will help support natural and anthropogenic differentiation needed for 

upcoming WRAP source apportionment efforts. 

FF9 Regional Coordination of Smoke Management Programs – This project was funded in 

2003 and will be started in 2005. Regional Coordination is a required element within the 

ESMP Policy as coordination of burning activity (ranging from passive to active) is 

critical to avoiding cumulative smoke impacts within and across source types in 

mandatory Class I areas. Methods for this inter-jurisdictional and regional coordination 

will need to be developed for wildland and agricultural prescribed fire smoke 

management programs, information sharing, and public notification. Proposed options 

will be developed, and then presented and reviewed at a facilitated conference, to be held 

in 2005. This project directly supports the implementation of the ESMP requirement in 

§309 as well as similar implementation issues for §308. 

FF12 Smoke Management Technical and Policy Workshop – Three-day workshop in 2005 to 

assess technical work to date, §309 policy and SIP implementation and refinement of 

policy options under §308. This effort will build on the two FEJF workshops held in 2004 

to ensure that the needed technical and policy tools are in place for SIP/TIP development 

under §308. Reprogramming 2004 funding funded this project. 
14

FEJF Technical Projects 

FF”C” 2002 Inventory of Wildfire and Prescribed Fire: Phase I & Phase II – This project was 

funded and started in 2003 and will continue into late 2004. The 2002 base year 

inventories will be prepared for the contiguous WRAP region for wildfire, prescribed fire, 

and wildland fire use on wildland and rangeland. Agricultural burning is also included. 

Alaska fire emissions may follow the lower states in deliverable schedule due to a 

different modeling plan as compared to the other WRAP jurisdictions. Phase I developed 

an initial emission inventory to allow the RMC to initialize the 2002 modeling efforts. 

Phase II involves further refinement of the Phase I inventory with greater QA/QC and 

state/tribal review of the fire activity estimates. Data collection to support estimates of 

private rangeland burning and augmentation of agricultural burning will occur in Phase II. 

The use of remote sensing in both the QA/QC and augmentation steps of Phase II will be 

assessed and is now included with reprogrammed 2004 funding. This remote sensing 

approach may also allow for new approaches to the Phase III Baseline inventory. The 

2002 emission inventory will include “anthropogenic” / “natural” apportionment to 

support the Attribution of Haze initial report. These projects directly support the 

modeling for the §308 SIPs/TIPs and should allow for assessment of remote sensing for 

future inventory development. 

At the request of WRAP states, statewide CERR Reports for US EPA will be developed 

for the Phase II inventory for all fire sources. This will allow WRAP states to submit to 

US EPA reports, which will partially fulfill the states’ emissions inventory reporting 

requirements. This portion of the project was funded by reprogramming 2004 funding 

and will be started in 2004. 

FF6+3 Phase III & IV Inventories & Preliminary Assessment of Apportionment Methods – This 

project was funded and will be started in 2004. Phase III is for the Baseline Planning 

Apportionment and create a 2000-2004 representative emissions inventory. Phase IV is 

for the 2018 Planning Apportionment and will be a 2018 representative inventory. The 

2018 inventory may include a range of potential control scenarios and possible ranges of 

emissions to reflect the high degree of uncertainty in this type of forecast. The 

inventories will be prepared for the contiguous WRAP region for wildfire, prescribed 

fire, and wildland fire use on wildland and rangeland. Agricultural burning is also 

included. Alaska fire emissions may follow the lower states in deliverable schedule due 

to a different modeling plan as compared to the other WRAP jurisdictions. This effort 

also includes categorization of “natural” and “anthropogenic” fire sources. The 

Attribution of Haze project will be supported by the FEJF through development of 

technical approaches to apportioning the impact of fire emissions between natural and 

anthropogenic source categories. These projects directly support the modeling for the 

§308 SIPs/TIPs. 

FF7 2002 National Wildfire Emissions Inventory (includes separate $100,000 contributed 

from OAQPS, national project, WRAP has lead RPO responsibility) – This project was 

funded and will be started in 2004. The 2002 emissions inventory for wildfire will be 
15

developed through an inter-RPO effort funded by EPA, based on a scope of work 

discussed amongst the RPOs. The FEJF has lead RPO responsibilities for this project. 

These projects directly support the modeling for the §308 SIPs/TIPs. 

Included in the RFP was a list of optional tasks that may allow for inter-RPO 

collaboration such as 2002 Wildfire Inventory (Canada & Mexico), Representative Base 

Year Inventories (current conditions & 2018), Software Development for Location 

Conversion (STR to lat./long.), and 2002 Prescribed Fire Inventory. This list of optional 

projects that the FEJF may contribute to was funded by reprogramming 2004 funding and 

will be started in 2004. These projects directly support the modeling needs for the §308 

SIPs/TIPs. 

FF4 Regional Modeling Center Support – This project was funded in 2004 and will be utilized 

as the need arises. Provide support to the Regional Modeling Center to assess the impact 

of various fire emissions scenarios, using modeling runs conducted by the RMC. Support 

may also be required for fire emissions QA and troubleshooting, which has historically 

been absorbed by other FEJF projects. This project directly supports the model 

assessment / sensitivity runs resulting in refinement of the modeling for the §308 

SIPs/TIPs. 

FF”B” Model Assessment / Sensitivity Runs – This project was funded in 2003 and will be 

started in 2004. Independent assessment of fire emissions sensitivity runs to be conducted 

by the RMC. The assessment will address emissions inventory issues, pollutant 

speciation, plume height approach, variations in total net emissions, and other key 

assumed parameters in the context of the regional model results. This project directly 

supports refinement of the modeling for the §308 SIPs/TIPs. 

FF”D” Sensitivity Runs Phase II: Regional & Mesoscale – This project was funded in 2003 and 

will be started after completion of the initial Model Assessment / Sensitivity Runs are 

complete. Conduct an air quality source/impact analysis with two scales of modeling: 

regional and mesoscale. The regional-scale modeling features chemistry capacity with 

regional and longer temporal scales. The mesoscale modeling features complex terrain 

capacity with smaller geographic and temporal scales. Together, these two approaches 

will provide a comprehensive analysis of potential de minimus levels to assist states and 

tribes with maximizing efficiency for fire tracking, public notification and regional 

coordination. This project directly supports the implementation of the FTS and ESMP 

requirements in §309 as well as similar implementation issues for §308. 

FF5 Fire Tracking System / Emissions Data Management System – Portions of this project 

were funded prior to 2002 and in 2004 with additional 2004 funding being reprogrammed 

to this project and will be started in 2005. Evaluation of existing fire emissions inventory 

systems to develop a Fire Tracking System within, or bridged to, the WRAP EDMS as 

identified in the Fire Tracking System policy to calculate emissions from fire activity 

data. Develop user guidance to support the FTS policy identifying a specific format for 

the EDMS, parameters, defaults, structure and methods of emission calculation for 
16

required and optional FTS elements. This project directly supports the implementation of 

the FTS requirements in §309 as well as similar implementation issues for §308. 

FF8 Quantitative Methods for Calculating Emissions Benefits of Emissions Reduction 

Techniques to Support Implementation of the AEG Policy – This project was funded and 

started in 2003 with the completion of an annotated bibliography on emission reduction 

techniques completed in 2004. This project will continue in 2004 and 2005. Develop 

technical guidance on ERTs applicable for wildland, rangeland, and agricultural burning 

for use in the establishment and support of AEGs. The guidance will include applicability 

criteria and calculation techniques by vegetation/crop type, emission factors, economics, 

and emissions averted including identification of new ERTs. Develop user guidance to 

support the tracking of ERTs (specific format, parameters, structure), which is an 

optional FTS Policy element. These projects directly support the Annual Emissions Goal 

reporting requirement in §309 as well as similar implementation issues for §308. 

The AP2 Forum’s work plan is based largely on the renewable energy and energy efficiency 

policy adopted by the WRAP Board2

 and on its subsequent management directive to the IOC and 

AP2 Forum.3

PP2 Renewable Energy Tracking and Certificates Project – Under this task, the Forum will 

work with the Western Governors’ Association to convene a regional meeting of 

stakeholders to collaboratively develop a “blue print” that will define the critical features 

needed to: 

◦ Conduct a needs assessment and develop a single set of functional requirements for a 

certificates-based renewable generation tracking and accounting system in the 

Western Interconnect; 

◦ Develop a standard set of market design and operating guidelines for trading RECs 

within the Western Interconnection to support establishment of a single institution in 

the West responsible for registering, issuing, tracking, and verifying renewable 

energy certificates; and 

◦ Create of an independent, regional generation tracking system to provide data 

necessary to substantiate the number of megawatt hours generated from renewable 

energy sources and to support verification, tracking, and trading of RECs. 

PP5 Displaced Emissions Analysis and Time-Specific Marginal Emissions Rates – The Forum 

will host a series of meetings with experts to identify renewable energy and energy 

efficiency data collection and measurement protocols in western states and evaluate 

available emissions displacement tools that could be used by states to help energy offices 

and air quality managers develop credible, state-specific estimates of emissions displaced 

by adopting different renewable energy programs and energy efficiency best practices 

 

2 WRAP Policy: Renewable Energy and Energy Efficiency As Pollution Prevention Strategies For Regional Haze; 

April 2003; pg. 1-2. 

3

 Ibid.; pg 3.

Air Pollution Prevention Forum
17

found in the AP2 reports. The Forum’s analysis, to date, has focused only on regionalscale impacts. Emissions displacement tools similar to those developed by OTAG for 

NOx could help individual states establish reporting, monitoring, evaluation, and 

modeling protocols that would enable them to meet potentially higher verification 

standards required by EPA for Section 308 SIPs and other types of SIPs 

PP6 Clean Energy Initiative Consistent with the WRAP’s definitions and policies related to 

renewable energy and energy efficiency, the WRAP will provide partial support to the 

Western Governors’ Association (WGA) Clean Energy Initiative. The WGA Clean 

Energy Initiative is described in a WGA policy resolution approved on June 22, 2004. 

The initiative includes a goal of achieving 30,000 megawatts of clean energy from 

sources such as wind, solar, geothermal, biomass, clean coal, and advanced gas 

technologies by 2015. It also includes a goal of increasing energy efficiency by 

20 percent by 2020. These goals will help achieve the WRAP’s renewable energy and 

energy efficiency goals for the Section 309 plans and support the potential expansion of 

renewable energy and energy efficiency strategies through state and tribal Section 308 

regional haze plans. 

 

MS1 WRAP Offroad Retrofit Program – This project was formerly named “Support of 

Nonroad Demonstration Project” and has been expanded in concept. Initiated in the 

summer of 2004, the goal of the retrofit program is to promote voluntary emission 

reductions from existing offroad vehicles and equipment in the WRAP region. In 2005, 

the MSF, with contractor support, will continue to provide WRAP members and 

vehicle/equipment owners with written guidance, technical support, outreach services, 

identification of incentives and public policy options, and examples of successful efforts 

and reduction opportunities. 

MS2 Offroad Retrofit Credits – The MSF will work with the EPA and other stakeholders to 

develop and implement, if appropriate, a program that uses retrofits of existing offroad 

sources to generate credits for compliance with new engine emission standards under the 

Tier IV nonroad diesel regulations. EPA has indicated an interest in working with 

stakeholders during 2004 – 2005 to examine the feasibility of this compliance option and 

implement it if appropriate. Other uses of offroad retrofit credits (e.g., for use in SIPs 

and TIPs) will be addressed by the Forum as needed. 

MS3 Review of EPA Analyses and Proposals – The MSF will review and where appropriate 

recommend WRAP comments on EPA technical analyses (e.g., for small nonroad diesel 

engines) and regulatory proposals (e.g., for ocean-going vessels and locomotives). 

Mobile Sources Forum
18

IN1 Update Near Inventory and Displays – The goal of this project is to replace the 1996 

maps and data currently on the In/Near website with 2002 maps and data, and to add 

some additional features. Originally, this was scheduled to occur in the fourth quarter of 

2004, but will have to occur in early 2005, after the EDMS is operational and other 

priorities are addressed by the Emissions Forum and EDMS contractor. Furthermore, the 

in/near maps and data will be a product of the EDMS, as opposed to a stand-alone, static 

website, as is currently the case. The Forum will work with the Emissions Forum, 

EDMS contractor, and as necessary ENVIRON (the developer of the 1996 maps and 

data) to transfer the emission estimation procedures and display methods carefully 

developed for the 1996 data into the EDMS. 

IN2 In/Near Strategies for Reasonable Progress – The scope of this project is being expanded 

from what was described in the 2004 work plan. In addition to addressing how in/near 

strategies might be included in a reasonable progress demonstration – given that some of 

these strategies may be voluntary, episodic, seasonal, or of such size that would not be 

properly characterized by a regional-scale model – this project will also identify which 

control strategies may be most effective at addressing local sources of visibility 

impairment. As a first step, the Forum will hire a contractor to identify all the PM10

SIPs, maintenance plans, and natural events action plans in the West focused primarily 

on local, primary sources of PM. Many of the existing plans rely on one or two control 

strategies for the bulk of emission reductions. A subset of these plans will be selected for 

further review. The plans selected, in total, will cover a variety of control strategy types. 

They will also be selected on the basis of their historical record – that is, they should 

provide a sufficient history of ambient data and implementation and enforcement 

experience to offer lessons and insights to groups involved in Class I area visibility 

protection (federal land managers, state and local officials, environmental groups, etc.). 

The result of this project will be a report summarizing the approach, success, and 

limitations of the most common PM10 control measures; their applicability and 

transferability to Class I areas; and a list of contacts for more information. It will include 

ambient PM10 data for the areas studies and summaries of interviews with officials who 

implemented and enforce the strategies. 

EA2 Development of Baseline Economic Data for States and Tribes – Baseline economic and 

demographic data (2002 and 2018) are required by the WRAP, selected Forums, and the 

states and tribes to assess the potential economic impacts of proposed haze reduction 

strategies on the states, tribes and other stakeholders. These data need to be collected for 

each state, sub-state regions, and tribes. A particular challenge within this task will be 

the continued collection and development of tribal baseline data. The overall baseline 

effort will be conducted in close coordination with tribal partners and the Emissions 

Forum, since its emissions baseline should be predicated on similar, if not identical 

economic and demographic data as employed in economic assessments. 

Sources In and Near Class I Areas Forum

Economic Analysis Forum
19

To date, baseline data have been collected for three states in the WRAP region at both the 

state and sub-state level as part of its Framework Test Application. The EAF will 

continue its management role in the overall effort to compile baseline data for the 

remaining WRAP states. Development of the baseline economic and demographic data 

would include careful documentation of both the process and sources employed. In 

addition, that documentation would include easily applied rule sets for both modifications 

(if needed) and deconfliction as new information becomes available over next 2-4 years. 

The EAF and its contractor would provide assistance to WRAP and its respective 

stakeholders in generating those required baseline data and projection updates as part of 

the overall analyses identified in the WRAP Strategic Plan. 

In concert with the Emissions Forum, the EAF and its support contractor will work to 

ensure that consistency is maintained between the baseline projections and their 

subsequent use by the Air Quality Modeling Forum. The Tribal Data Development Work 

Group (TDDWG) is working toward a standard data “template” which is designed to 

formally and effectively develop the needed demographic and economic data and data 

sets required to support consistent economic impact and tradeoff analysis by tribes and 

other stakeholders. The tribal baseline work will implement that template as it works 

toward a complete picture of tribal conditions, and forecasts, in the WRAP region. 

EA3 Enhancement of Cost and Benefit Unit Values Used in WRAP Economic Analysis – The 

net benefit calculated for any haze reduction strategy will depend heavily on both the unit 

cost values (e.g., $/ton) and the unit benefit values (e.g., $/deciview and $/life saved) 

applied within an economic framework (whether full or a “lite” version”) for reductions 

attributable to that particular strategy. As was documented in the initial Economic 

Framework study, and is being borne out in its current application to the off-road strategy 

comparisons in AZ, MT and ND, these values are often available from only a limited 

number of existing studies – often due to the rather large expense of conducting the 

needed research and the tremendous uncertainty involved in evaluating “soft” effects. 

“Tailored” unit benefit values taken from previous studies for such areas as health, 

materials and ecological impacts can provide credible “default” or standard coefficients 

by use of all stakeholders in future economic analyses and regulatory strategy tradeoffs. 

We recognize, however, that tailored values will fall short of the broad set of values 

needed by the diverse set of stakeholders with WRAP. As with some of the other tasks, 

the Forum will actively seek partners to complete the effort of improving existing air 

quality unit cost and benefit values. 

The Forum has yet to address the other side of the cost/benefit equation – that of control 

costs for the myriad of strategy and technology options that may (should) be considered 

over the next few years as both the 308 path comes to completion and the 309 path is 

evaluated for effectiveness. The Forum and its supporting contractor(s) will focus on reestablishing standard benchmark cost estimates, both for the current set of control 

technologies, and those technologies that may be available in the future. Existing values 

used are out-of-date. As with the unit benefit values, documentation will include rule sets 

for making good choices when alternative value (usually due to inherent uncertainties in 
20

any forecast) selection and application need to be offered for both credibility and 

completeness. Care will be taken to include the “softer” technologies that may be more 

focused on operating options within production processes themselves as part of this cost 

side of the equation. 

On the benefit side the three principal categories (outside of haze reduction itself) of 

health, materials damage and ecological quality will remain the focus. On the cost side, 

both technological options and changes in operating processes and practices will be 

included. 

EA4 Screening Tool – The current economic analysis framework (study application ongoing 

for off-road mobile source reduction strategies for the states of AZ, MT and ND and three 

tribes) employs a fairly comprehensive analysis. Along with the comprehensiveness of 

such analyses comes the commensurate costs – understanding, skills, dollar costs and 

time. These considerations make it highly likely that its next set of applications will be 

used only an occasional basis to assess “packages” of control strategies that have either 

been well defined and/or are nearing serious consideration by WRAP stakeholders 

As a complement to the study framework ongoing application, the Forum is targeting 

completion of an initial screening tool based on the framework (e.g., a light-weight 

version of the framework) to be applied more routinely and cost-effectively by WRAP 

stakeholders for assessing and ranking a variety and number of individual potential 

control strategies. Two products from this task would be a template and a cookbook of 

screening various control strategies. After finishing the screening tool, the forum will run 

through a couple of test cases to see if the tool works and to ensure that the final tool is 

something useful and meaningful for WRAP. This screening tool has been explicitly 

identified as a needed capability within the WRAP Strategic Plan for 2003-2008. 

EA5 Coordination and Outreach – An ongoing and inherent task of the Forum will be the 

coordination with other Forums. As noted above, the Emissions Forum and Economic 

Analysis Forum would co-develop and share a common set of economic and 

demographic baseline data, both current conditions and future projections. In addition, 

because economic analysis is dependent upon results from air quality modeling, the EAF 

would work very closely with the Air Quality Modeling Forum to fully and in a timely 

manner capture results from their sets of runs. Also, the EAF and its supporting 

contractors will be making more extensive use of GIS data, and would be working 

closely with the Areas Within and Near Class I Areas Forum. A critical area of 

coordination will be with tribal issues (e.g., baseline data, distributional impacts, and 

alternative values), with requires a close working relationship, if not partnership, with the 

Tribal Data Development Work Group. Finally, outreach to other WRAP Forums and 

stakeholders (including the public) is important to ensure proper use and understanding of 

economic principles and analytical results, especially since formal, comprehensive (e.g., 

both costs and benefits) economic analysis is not typically an everyday part of WRAP 

ember activities. To improve coordination and outreach, the EAF will take advantage of 

WRAP-wide meetings to host periodic workshops on the application of the tools and 

interpretation of results of the Forum’s analyses framework and supporting data sets. 
21

EA6 Economic Assessment Capability – The Forum, and its supporting contractor(s) will 

provide WRAP and its stakeholders with some level of on-going economic assessment 

capability, depending (in part) on what stakeholders need and the varying role of 

economic analyses to be conducted for the 308 submittals and 309 reviews. We envision 

three alternative levels of that support capability -- each with a differing funding 

requirement: (1) The simplest role would be that of consultation, answering questions, 

and guiding the use of various economic models including both the full WRAP Economic 

Framework and its “lite” version ($25-50 K). (2) The mid-level, or ‘partner’ role would 

involve partnering with the various stakeholders (principally the states and tribes who are 

ultimately responsible for 308 and 309 SIP preparation) in the actual conductance of their 

respective varying economic analyses ($40-150K). (3) A third level, or role would be for 

the EAF and its supporting contractors to perform most, if not almost all of the ensuing 

economic analyses conducted within WRAP, both for WRAP as a whole and for each of 

its constituent members. Under all three levels, the Forum would house one or more 

economic models, such as IMPLAN or REMI for both total impact and distributional 

analysis, to assist in the comprehensive economic analyses conducted within WRAP. 

MF1 Regional Modeling Center – The Modeling Forum plans to continue operation of the 

Regional Modeling Center (RMC) with the same team of contractors as their single major 

project, including modeling of Alaska regional haze. The RMC will continue to provide 

documentation of their ongoing analysis work (including support of the Attribution of 

Haze Workgroup), protocols and technical support documents for the various analyses 

and work products, and disseminating this information through biweekly Modeling 

Forum conference calls, the RMC E-Mail listserv, and periodic meetings. 

The proposed 2005 work plan for the RMC will primarily focus on completing emissions 

processing and air quality modeling evaluations of revised and final 2002 emissions and 

2018 emissions projections. The RMC will prepare a specific 2005 cost proposal and 

work plan for Modeling Forum review and approval in late 2004, and the RMC contract 

will be amended to reflect this work plan in January 2005. Below, in no particular order 

of priority, is a list of RMC activities for the 2005 calendar year contract. These tasks 

continue work begun in 2004, and are identified in the WRAP Strategic Plan. 

 Process revised 2002 emissions and 2018 emissions projections 

 Update new model codes for SMOKE, MCIP, and CMAQ as needed 

 Continue to update post-production displays 

 Run CMAQ model with 2002 and 2018 inputs 

 Conduct source apportionment/sensitivity model runs 

 QA/QC: 

o Implement version control mechanism 

o EI data file to SMOKE outputs analysis & reports 

o Model performance evaluation 

 April 2005 - 2002 final base case modeling results report 

Air Quality Modeling Forum
22

 June 2005 - 2018 final base case modeling results report 

 August 2005 - 2018 base case final source apportionment modeling results report 

 Fall 2005 - Three to five [3-5] 2018 control strategy sensitivity modeling results 

reports 

MF2 Alaska Region Modeling – This portion of the RMC work is aimed at providing a 

credible evaluation of the potential contributions to regional haze in the Class I areas of 

Alaska that are more likely to be affected by in-state emissions, namely Tuxedni and 

Denali. During 2004, the RMC is completing two tasks: 1) Develop appropriate methods 

for running MM5 over central Alaska, including Cook Inlet, the Alaska Range, to north 

of Fairbanks, and 2) Run MM5 for this region for several time periods representing 

different seasonal and meteorological conditions and evaluate the meteorological model 

results. During the Spring of 2005, RMC staff will present the results of their work to 

date at a technical meeting in Alaska. Pending more specific direction after that meeting, 

the 2005 Alaska modeling tasks will focus on: 

 Assuming the MM5 model test period runs are credible, run the MM5 model for all of 

2002. 

 Then run a Lagrangian model, such as CALPUFF, for the largest point sources in the 

region (up to about 10) - provide a modeling results report. 

 Run the Lagrangian model [chosen previously] to evaluate the potential for impacts 

from the urban areas of Anchorage and Fairbanks - provide a modeling results report. 

The Emissions Forum is planning to continue a major project, and several specific 

supplementary projects during 2005. The Emissions Data Management System (EDMS) is the 

major project of the Forum, as an ongoing data center and repository. During 2005, an EDMS 

operation and maintenance task is planned, and a related enhancement task for the Fire Module 

of the EDMS is planned, referred to as EDMS Phase 2. The Forum also plans specific projects 

addressing independent testing of the EDMS functions as it becomes operational in Winter 2004-

05, projecting 2018 emissions of point and areas sources for base and control scenarios in 

coordination with the SSJF and TDDWG, as well as preparing updated regional base and 2018 

projection years’ on-road and non-road mobile source emissions that fully account for state, 

tribal, local, and federal mobile source control programs. 

EF1 EDMS Hosting / Operation – This project supports ongoing operation, maintenance, 

standard software and hardware upgrades, and computer system hosting for the EDMS 

during 2005. E.H. Pechan, the WRAP EDMS contractor has proposed a budget of 

$60,000 for hosting and hardware support by their computer systems subcontractor, 

Carolina Environmental Programs. Pechan has proposed a budget of $120,000 for 

operation and administration of the EDMS, including data analysis products, data 

provider/user assistance, and general oversight. 

Emissions Forum
23

EF1 EDMS Phase 2 Work Plan - Fire Module Improvements – Up to five (5) EDMS fire 

module subtasks, presented next in priority order as identified FEJF EDMS Steering 

Committee representatives, are planned for completion during 2005. Brief task 

descriptions and costs for each are shown separately. 

1) With review and approval by the Fire Emissions Forum and the EDMS Steering 

Committee, implement a daily Smoke Management activity data protocol for data 

providers to transmit, view, and track on the EDMS. Work with the Fire Emissions 

Forum and the EDMS Steering Committee to determine the frequency of data upload 

and display updates. This subtask supports the regional coordination element of the 

Enhanced Smoke Management Program policy adopted by WRAP. 

2) With review and approval by the EDMS Steering Committee, specify and implement 

an EDMS protocol to accept/use/display state/tribal-reported fire emissions data with 

supporting activity data. These data would be stored to satisfy the Fire Tracking 

System policy adopted by WRAP, and to support the fire emissions tracking elements 

in §309 smoke management programs committed to by OR, WY, UT, AZ, and NM. 

This subtask would create emissions inventories for regulatory tracking purposes, and 

would be separate from the fire emissions inventories provided to Pechan by the Fire 

Emissions Forum for regional modeling and analysis purposes. 

3) With review and approval by the EDMS Steering Committee, incorporate an FEJFspecified fire emissions model into the EDMS, to ensure regionally-consistent 

emissions estimates from the data reported in #4 below, including recently available 

improved base data layers. This subtask entails determining the appropriate model 

(Consume, FOFEM, others) to incorporate into the EDMS, and applying the results of 

the analysis. 

4) With review and approval by the Fire Emissions Forum and the EDMS Steering 

Committee, specify and implement EDMS fire activity data reporting format(s) based 

on inputs to FEJF-specified fire emissions model. This subtask would allow the 

creation of emissions inventories for regulatory tracking purposes, and would be 

separate from the fire emissions inventories provided to Pechan by the Fire Emissions 

Forum for regional modeling and analysis purposes. 

5) With review and approval by the Fire Emissions Forum and the EDMS Steering 

Committee, develop and implement EDMS tools and procedures to use in estimating 

emissions changes from annual emissions goals and regional control strategy 

scenarios. This subtask would create emissions adjustment factors which smoke 

management program operators could use to modify their regulatory tracking 

emissions inventories (from #2 or #4, above) for planning purposes, as well as to 

separately modify the fire emissions inventories provided to Pechan by the Fire 

Emissions Forum for regional modeling and analysis purposes. 
24

EF1 Independent Review/Testing of the EDMS – Two (2) independent contractor tests of the 

EDMS functions, calculators, and displays are needed to verify proper operation at the 

time the EDMS comes on-line in late 2004. Two separate contracts would be awarded, 

with reports from each to list all problems encountered, non-functional tools, and 

suggestions for improved operation and ease of use. This task would be completed by 

January 2005, so that corrections could be implemented during the first half of 2005. 

EF1 2018 Base Case & Control Strategy Point & Area Source EI Projections – The project 

would fund the projection of 2018 emissions base case and control strategy scenarios 

based on 2002 emission inventories, for point and area sources. This project will be done 

in coordination with the SSJF and TDDWG, using recommendations from the Economic 

Analysis Forum about economic and demographic data inputs to standard point and area 

source emissions projection models and techniques in common use. These WRAPdesignated economic and other data types and the associated models will be accessed by 

a contractor for the purpose of projecting changes in emissions in future years. The 

resulting emissions projection data will be stored in the EDMS, covering 5 to 10 

combinations of numbers of years and inventory types. These data will be used for 

modeling purposes by the WRAP Regional Modeling Center. The Emissions Forum 

plans to apply the bulk of the funding for the contractor support needed for this project 

toward the SS4 project, reserving 10 to 15% to insure that the emissions projections data 

are successfully imported and displayed in the EDMS. The Emissions, Stationary 

Source, Economic Analysis, TDDWG, and other WRAP forums and committees will 

need to coordinate on this project, led by the SSJF. 

EF3 Mobile Source Base and Projection EI Update – This project was originally proposed in 

the 2004 work plan, but the scope and budget have been expanded in 2005. The purpose 

of this project is update on-road and non-road activity data as inputs to the EPA mobile 

emissions models with limited surveys, and then generate Emissions Inventories for 

2002, 08, 13, and 18. With the bulk of expected mobile source (on-road and non-road) 

federal emissions reduction programs adopted in rule, to be implemented over the next 

10 years, updates to the mobile emissions inventories are needed for the §309 plans 

revisions, so that proper credit can be taken in the §309 SIP updates as well as in the 

§308 plans. This project would use the input and default information from the §309 

mobile source EI work as a starting point, and send those data to states, locals, and/or 

metropolitan planning organizations for verification and updating (i.e., with 2000 census 

data). The mobile source inventories would capture all regulations on the books as of 

September 2004 for use in preparing the emissions data. The Mobile6 and 

NONROAD2004 models would then be used to estimate mobile source emissions for 

the WRAP region, including Alaska. This project would be complete in early 2005. 
25

The TDDWG is completing projects near the end of 2004 to analyze tribal monitoring data 

through a subproject of the Causes of Haze Assessment project, as well as continuing training 

and support for TEISS implementation. Also, the TDDWG has reprogrammed resources from 

their 2004 budget to have ITEP facilitate development of actual 2002 emissions inventories for: 

• SOx and NOx point sources on tribal lands with emissions greater than 50 tons/year; and 

• Oil and gas production/distribution on tribal lands. 

For 2005, the TDDWG plans the following projects. 

TW1 Emissions Data Development Support – In 2005 the TDDWG is proposing to continue 

the contract with ITEP for the implementation and training on TEISS, and training on the 

software before making it available to the Tribes to compile their respective emissions 

inventory data. Also, training sessions will be offered for the Tribal Professional by 

ITEP. Some of the elements of this task will be done by the TDDWG. 

• TEISS Software Support (software distribution to interested tribes, promotion, 

technical assistance by phone and E-Mail); 

• Alaska tribal support (ITEP will work the state of Alaska, and interested Alaskan 

Native Corporations to distribute, and provide voice and electronic support, for the 

use of TEISS in Alaska); 

• TEISS Software User Workshops (Two workshops, designed for both new [3.5 days] 

and experienced [2.5 days] TEISS users, will be developed and conducted at the 

Tribal Air Monitoring Support (TAMS) Center’s training facility in Las Vegas, NV 

or at an EPA facility that can provide a computer lab free of cost for the training); 

• Contractor support for tribal data needed by the Emissions Forum; 

• Provide at least one TEISS training that piggybacks with another meeting and 

conference with tribes funding their own travel or using the travel funding from the 

travel funds available through WRAP; and 

• ITEP offer 2 trainings during conferences or meetings where primary travel expenses 

are by the participant. 

TW5 Continue Emissions Inventory & TEISS Technical Support – ITEP will maintain a 

comprehensive website to provide information on the technical aspects of EI work that is 

unique to tribes. The information that will be easily accessible on this website will 

comprise sections covering: 

• Summaries and URL links to EPA guidance documents and assistance; 

• Steps, procedures and documentation requirements for constructing a tribal EI; 

• Information about contractors who have worked with tribes on EI issues; and 

• A tracking system for QA/QC concerns and issues derived from tribal experiences 

with the EI process. 

Tribal Data Development Work Group
26

ITEP’s Tribal Environmental Resource Center will facilitate networking between tribes 

working on EIs through our Tribal Air Mentor Network. Tribes desiring specific kinds of 

assistance will be linked with ITEP’s existing Professional Exchange program to get the 

training and knowledge they need, whether from another tribal air program or from EPA. 

ITEP staff will be available to provide technical assistance on a one-on-one basis on all 

aspects of EI work on tribal lands in the lower 48 United States. Due to the limited 

nature of this service, ITEP staff will consider each tribes request for one-on-one 

assistance in a formal process (to be developed with the TDDWG), and deliver this 

resource on a needs basis. 

As part of this task ITEP staff will also be available to provide information and contact 

data on tribes for other forums and groups working with the WRAP. This service will be 

limited to providing focused contact lists in response to specific requests. 

Funding to allow ITEP staff to travel to reservations and provide assistance on a one-onone basis is requested. Due to travel related costs, requests for assistance from Alaskan 

tribes must be considered carefully and needs met in such a way that the maximum 

number of Alaskan tribal communities will be served. These needs could be met through 

mini-workshops in Alaska, with Alaskans providing their own travel funding to a central 

location in Alaska. ITEP would help facilitate the information distributed at these 

workshops – but no funding is requested in this proposal for ITEP staff or instructor 

travel to the state. 

Funds are requested to allow those trained in the initial train-the-trainer workshop, or 

other tribal staff knowledgeable in EI techniques and methods, to travel to another tribe’s 

reservation and provide assistance in planning EI work, collecting data, using TEISS, and 

completing and reporting EI results. These funds could also be used to fund travel for 

tribal trainers to assist with the TEISS workshops. 

Funds will also be used as needed to maintain and provide information on tribal data and 

GIS coverages for use by other WRAP forums and committees. Time is requested for a 

GIS Specialist whose task would be to maintain the geographic information system (GIS) 

tribal coverage for the WRAP region. The GIS Specialist would continue the outreach to 

tribes and updating of the GIS coverage developed under the 2003 work plan, to ensure 

that the tribal boundaries used in all WRAP projects are correct. A Specialist would 

provide maps and geographic analysis related to tribes to WRAP forums and committees 

upon request. 

TW6 EI with of Point Sources on Tribal Lands (collaborative project with SSJF and EF) – A 

collaborative project with the Stationary Sources Joint Forum and the Emissions Forum is 

planned, to focus on developing a complete actual 2002 point source emissions inventory 

develop basic and intermediate modeling training that is tribal specific for WRAP 

Regional modeling. 
27

The mission of the Dust Emissions Joint Forum (DEJF) is to (1) improve the WRAP’s dust 

emissions inventory, including the magnitude and spatial, temporal, and particle size distribution 

of dust emissions; (2) coordinate interpretation of modeling and monitoring results with respect 

to dust, including the apportionment of haze to natural and anthropogenic sources of dust; and 

(3) identify the most appropriate strategies for reducing anthropogenic sources of dust affecting 

Class I areas. At its discretion, the DEJF may also develop a research agenda to guide and 

coordinate efforts within the air quality community and may evaluate the usefulness of existing 

monitoring and modeling techniques for quantifying the contribution of dust to haze in Class I 

areas. 

DF1 Establish a Common Definition of Dust and Dust Emission Types – The goal of this 

project is to develop a common definition of dust and to develop a policy for categorizing 

dust emissions as either natural or anthropogenic. The common definition and 

categorization policy could then be used to consistently track dust emissions and their 

contributions to regional haze. In 2004, the DEJF started the process of a consensusbased definition of dust. A draft definition and examples of natural and anthropogenic 

dust were reviewed by the DEJF and the Implementation Work Group (IWG) and will be 

further developed when vital information is available in early 2005 from other DEJF 

projects and other WRAP activities, such as those of the Attribution of Haze Work 

Group. The DEJF anticipates using a facilitator and one or two public workshops to 

finalize the definition and categorization policy. 

DF2 Enhanced Ambient Data Analysis – In 2004, the DEJF funded a project (DF2) to identify 

the 20 percent worst visibility days dominated by dust at all Western IMPROVE sites for 

the years 2000-2002, and to place these events into one of several categories (e.g., local, 

regional, Mexican, Asian, fire-related, uncertain, etc.). The purpose of this project (DF6) 

is to conduct further, “enhanced” analysis of ambient data to improve the categorization 

of any “uncertain events” and/or to address additional questions about the precise sources 

of dust (e.g., are local events highly localized, or on the scale of tens of miles? is the local 

dust associated with human activity? if so, what activities, where, and when? what are the 

trends in dust concentrations and are they related to trends in climate, land use, etc?). 

Given the more intensive types of analyses needed to answer these questions, the 

enhanced analysis will probably be limited to a subset of the IMPROVE sites (e.g., those 

with significant and/or variable dust sources). The selection of sites will be coordinated 

with project DF7 (analysis of sources and control options in high-dust areas). An 

additional reason for continuing ambient data analysis of dust is the uncertainty regarding 

the quality and usefulness of the 2002 windblown dust emissions inventory currently 

under development. It is therefore important to maintain an alternative (e.g., ambient) 

method for assessing the impacts and causes of windblown dust. 

 

DF5 Fugitive Dust Handbook and Website – The purpose of this project is to periodically 

update the handbook and website (originally developed in 2004) to keep them as relevant 

and useful as possible to WRAP members throughout the SIP development process (i.e., 

2005-2007). New information will be included in the handbook and website as it 

Dust Emissions Joint Forum
28

becomes available from other WRAP projects (e.g., the Dust Control Measure Workshop 

described below) and from other dust-related efforts (e.g., dust control programs in 

various western jurisdictions). 

DF6 Analysis of Sources and Control Options in High-Dust Areas – The purpose of this 

project is to test and demonstrate how the various products of the Forum can be 

integrated to address the contribution of dust to regional haze at one or a small group of 

Class I areas. This “pilot study” will use the results of the WRAP dust emissions 

inventory, ambient data analysis, air quality modeling, dust definitions, and fugitive dust 

handbook to identify reasonable dust control options, costs, and benefits in a real-world 

setting. Shortcomings of the process and/or WRAP products will be identified and 

refined to the extent possible prior to 2006, when most of the selection and design of 

emission control strategies is expected to occur. Selection of the Class I area(s) for use in 

the pilot study will be based on the significance of dust sources to the 20 percent worst 

visibility days and on the availability of data and (in kind) local expertise and support 

(e.g., from stakeholders and relevant government agencies). Participation will also be 

sought from EPA regional representatives to facilitate federal approval of any dust 

control measures included in the regional haze SIPs and TIPs. The pilot study will be a 

key topic at the workshop discussed below. 

DF7 Dust Control Measures Workshop – The purpose of this one or two-day workshop is to 

discuss the success and limitations of current dust control strategies and to share thoughts 

on new and improved strategies, especially as they may pertain to regional haze. Results 

will be presented from various DEJF and other dust-related WRAP projects. Other 

workshop topics may include how to identify dust control strategies appropriate for 

individual Class I areas, quantifying emission and control measure reductions, developing 

dust ordinances and regulations, enforcement issues, and the politics behind adopting 

dust control measures. Collaboration / co-sponsorship will be sought from the California 

Air Resources Board, which is in the process of identifying and characterizing best 

available PM control measures. 

During 2004, the Ambient Monitoring & Reporting Forum continued to provide access to 

regional haze monitoring data through operation of the inter-RPO VIEWS website. The Forum 

is also completing the first phase of the comprehensive, multi-year Causes of Haze Assessment 

project, with deliverables to the Attribution of Haze project. Both the VIEWS and CoHA 

projects are ongoing. Also, the Forum has let a contract on behalf of all 5 RPOs to better 

understand the accuracy of the EPA’s estimates of natural conditions and their sensitivity to 

specific assumptions. Deliverables are expected from this project in late Spring 2005. 

Funding is requested for two projects in 2005: 

Ambient Monitoring and Reporting Forum
29

AMR1 VIEWS Data Base and Website 2005 Operations – The Visibility Information Exchange 

Web Site (VIEWS) began operation in 2002, building from the earlier WRAP Ambient 

Monitoring Database. To date, VIEWS has received joint, annual funding by all 5 RPOs, 

each contributing $50,000, through a WGA contract. A Steering Committee composed 

of RPO representatives, EPA, and Federal Land Managers oversees the operation of the 

database and website, and tracks deliverables from the annual VIEWS work plan. The 

funding mechanism for VIEWS was transferred from the WGA contract into the 

IMPROVE grant from EPA during 2004, saving on overhead costs. 2005 will be the 

final year of RPO funding for VIEWS; the RPOs have asked EPA to fund the database 

and website directly at the same resource level to complement IMPROVE operations. 

IMPROVE and a wide variety of other visibility-related data are displayed and available 

for analysis and/or downloading at: http://vista.cira.colostate.edu/views/. 

AMR2 Causes of Haze Assessment Project – The Causes of Haze Assessment project began in 

early 2003, and is designed to provide as much as information as can be estimated using 

monitoring data concerning the aerosol species and source categories that contribute to 

haze. These reports will also document the use of spatial and meteorological analysis 

methods to estimate the impacts from within and outside the WRAP region. Deliverables 

from the first phase of this analysis project will be completed in late 2004, directly 

supporting the Attribution of Haze project. The second phase of the CoHA project will 

begin in early 2005. This phase will include, but not be limited to the following: 

• Meteorological analyses to determine the representativeness of 2002 relative to the 

2000-2004 baseline period for each site; and 

• Receptor modeling – e.g., using Positive Matrix Factorization (PMF) – to identify 

source impacts at Class I areas with an adequate monitoring record. 

These analytical results will directly support Phase 2 of the Attribution of Haze project. 

After the CoHA analyses are completed in 2006, it is anticipated that the CoHA website 

will be maintained, with lesser ongoing efforts directed at continuing analyses of new 

monitoring data. 

In support of the activities described in the WRAP Strategic Plan, the Technical Oversight 

Committee (TOC) established an Attribution of Haze Workgroup in early 2004. This “Phase 1” 

Attribution analysis and report for all Class I areas in the WRAP region will be published in 

January 2005. This project report will be the first step in a process that will be complemented by 

2005 analysis activities continuing by the Initiatives Oversight Committee (IOC), the TOC, and 

the various Forums and Workgroups. During the second half of 2005 and the first half of 2006, 

significant collaborative analyses and discussions among the TOC, IOC, the Air Managers 

Committee, all Forums and Workgroups, and the WRAP Board are planned. The AoH 

Workgroup plans a “Phase 2” project, anticipated to begin in mid-Summer 2005, to analyze 

improvements in haze between the final/revised 2002 emissions estimates available early in 

2005, and the emissions estimates for the 2018 base and control strategy scenarios’ cases. 

Attribution of Haze Work Group
30

AoH1 Attribution of Haze – Phase 2 Contractor Support – The AoH Workgroup requests 

funding for contractor support to execute the Phase 2 AoH project described above. It is 

planned that the Technical Data Portal project listed next will accomplish most, if not all, 

of the reporting formats and capabilities needed in the Phase 2 project, but funds are 

requested to ensure that technical support and preparation work can be completed in a 

timely manner. If the Technical Data Portal project is moving ahead on schedule, then 

these funds may be redirected to that project, or not used by the AoH workgroup. If 

needed, similar to the Phase 1 AoH Technical Support project during 2004, the contractor 

will: 

 Attend AoH Workgroup meetings and distill members’ opinions and results of 

discussions into a schedule and methodology to accomplish the Phase 2 tasks; 

 Possibly subcontract with independent experts for analytical work; 

 Gather and format the resulting information and data from WRAP Forums, 

independent experts, and other related air quality analyses, all for review by the 

Workgroup; 

 Draft a “Phase 2 Attribution of Haze Report” for review and comment by the 

Workgroup; and 

 Complete and publish a “Final Phase 2 Attribution of Haze Report”. 

AoH2 Technical Data Portal Project – At the direction of the TOC during 2004, Pangaea 

Information Technologies prepared a series of 3 white papers comprising the WRAP 

Integrated Geospatial Information Management Strategy (WIGIMS) report: 

(http://wrapair.org/forums/toc/documents/wigims/WIGIMS_Strategy_Report-final.pdf ). 

These papers document a progression from a needs assessment to a resource inventory 

and a final strategy document. The strategy document lays out a range of options and a 

recommended approach to create a structure for data and information management of 

monitoring data/analyses, emissions information, air quality modeling simulation results, 

and ancillary data. The concept is to allow WRAP users and interested parties to access 

these data through a single web-based technical data portal (TDP) using web-based 

Geographic Information System[s] (GIS) tools to view and analyze the data used in 

WRAP regional haze planning work. Implementing the WIGIMS recommendations and 

strategies through a WRAP TDP project will incorporate suggestions and 

recommendations from the Pangaea strategy document into a phased approach, resulting 

in a scope of work for contractor support to build and operate a technical data portal for 

the WRAP region. 

While still under development, the scope of work for this approach to the WRAP TDP 

project would likely consist of three components and provide access to data that could be 

used for a wide variety of analyses. At a minimum, this RFP would need to list: 

1. Examples of the specific analytical products and “canned” regional technical 

documentation and displays needed for the §308 regional haze implementation plans 

(SIPs and TIPs); 
31

2. A description of a structure(s) for a flexible data access structure for more detailed 

analyses needed for individual SIPs and TIPs (borrowing options from the Pangaea 

reports); and 

3. Flexibility for ad hoc storage, and subsequent data query and analysis for interested 

parties, so “weight of evidence” demonstrations used in individual SIPs and TIPs can 

be reviewed. 

The ability to combine air quality observations/analyses, modeling results, emission 

inventory estimates, and any ancillary GIS data makes preparing the “weight of 

evidence” analyses described in #2 and #3 possible. 

The purpose of this committee is to coordinate the post-submittal implementation of Section 309 

SIPs and TIPs, if applicable. This includes tracking emissions for the backstop SO2 trading 

program and addressing issues related to that program (e.g., expansion to other states under 

Section 308). After the SIPs are submitted (by December 31, 2003), the EPA expects to conduct 

a six-month completeness review, followed by an 18-month process to review the substance of 

the SIPs, propose approval, take public comment, and take final action. This process may 

require interactions between the EPA and the 309 states, potential revisions/updates to certain 

SIP elements, and coordination among the 309 states themselves. All these activities would be 

conducted under the purview of the 309 Coordinating Committee. Committee members will be 

comprised primarily of states submitting Section 309 SIPs and tribes interested in submitting 

Section 309 TIPs. 

309a Annex Implementation – The Committee will be responsible for (a) the annual regional 

emissions report (for comparison to the milestones) and periodic audits of emissions 

tracking, (b) addressing any remaining or new issues related to the backstop trading 

program (e.g., tracking and supporting state rule adoptions, consideration of allowance 

price disclosure, etc.), and (c) addressing issues related to other states or tribes interested 

in opting into the program. 

309b 309 Follow-Up – As the EPA reviews and takes action on submitted SIPs, issues are 

likely to arise that will require some ongoing effort by the WRAP to help resolve in a 

coordinated fashion. 

2005 will be the second year of the current strategic plan. It is the year in which we transition 

from “phase I,” to “phase II.” The Attribution of Haze report will be out and serious discussions 

will be had about what pollutants are causing haze in which Class I area, where the pollutants 

originate, and what each state and tribe should do to take care of its share of the problem. 

Air Managers Committee

309 Coordinating Committee
32

AMC1 Staff Support for the State and Tribal Caucuses – Two coordinators, one for each caucus, 

are positions under the Air Manager’s Committee. The State Caucus Coordinator position 

is filled through a services contract between WGA and WESTAR. The Tribal Caucus 

Coordinator position is funded directly through NTEC, and is included in the NTEC line 

item of the WRAP budget. The staff support provides the tribal and state air directors 

with continual tracking and reporting of WRAP activities, issue identification and 

communication among the WRAP partners, recruitment of WRAP participants from 

states and tribes, facilitation of issue resolution. 

AMC2 Alaska Tribal Outreach Coordinator Position – An individual will be hired to conduct a 

variety of outreach activities for the 229 tribes located in Alaska. A number of activities, 

in addition to those typically associated with employee recruitment, will be conducted as 

part of this hiring process to assure long-term success of the position. First, an 

assessment tool (e.g., questionnaire) will be sent to Alaskan Natives and to determine 

what role the Coordinator should be playing. For example, there are jurisdictional issues 

that are of concern to Alaskan Natives due to the Alaskan Native Settlement Claims Act 

(1971) and the Alaska National Interest Lands Conservation Act (1980). Because of such 

issues, not all Alaskan Natives are sure of what areas that they have jurisdiction over. 

Second, collaboration will be sought with Alaskan Native organizations to build a pool of 

individuals who can advise and participate in the hiring and management process of the 

Coordinator. Third, Native Village visits will be important to give a firsthand look at the 

issues facing Alaskan Natives. 

AMC3 Health-Based Effects of Regional Haze – Within the WRAP, little attention has been 

given to the health effects of air pollutants associated with haze, yet information on the 

health consequences of haze pollution and the health benefits of haze controls could be 

gleaned from on-going WRAP activities, such as those related to air quality modeling, 

ambient monitoring, and socioeconomic analysis. Distilling health-related information 

from WRAP activities will provide added value to WRAP members and may generate 

further interest from individuals and organizations that may not otherwise be compelled 

to participate, such as some public interest groups, tribes, and members of the general 

public. 

The AMC will attempt to boost the health-relevance of the WRAP’s haze-related 

activities by first recruiting an expert in the area of air quality and health to draft a report 

which (a) summarizes what the available literature implies about the health significance 

of various PM constituents and PM precursors which may pose a health risk in the West 

(b) identifies WRAP data that can be used to assess health effects, (c) identifies data gaps 

in the WRAP region (particularly on tribal lands) which could provide significantly more 

health-related information, and (d) recommends ways in which the WRAP can use its 

current and forthcoming data (including filled data gaps) to estimate the health effects of 

haze and the health benefits of haze controls. Next, WRAP staff will conduct a workshop 

to disseminate the information in the report – a group of speakers will be on hand to offer 

their own interpretation of the material in addition to providing some additional insights – 

and discuss next steps for the WRAP with respect to regional haze and health. 

 
33

AMC4 Traditional Tribal Practices and Regional Haze – Tribal traditional practices (e.g., 

ceremonial, cultural, religious) are regularly affected by regional haze or the policies 

intended to curb such haze. On the one hand, tribes are concerned with protecting their 

traditional practices from the air pollutants that obscure visibility. For instance, some 

tribal members have noted the importance of being able to see nearby icons for religious 

purposes. On the other hand, tribes engage in traditional practices that involve such 

activities as burning. In some cases, the WRAP has acknowledged these practices and 

exempted them from policies adopted by the organization (see, for example, “Enhanced 

Smoke Management Plan” policy document produced by the Fire Emissions Joint Forum 

and adopted by the WRAP Board). 

No comprehensive documents currently exist that address the traditional practices of 

Indian tribes throughout the WRAP region and how these practices interact with regional 

haze and the policies adopted to address such haze. Documents that address these issues 

will serve to meet the needs and concerns of the tribes within the WRAP region and also 

help the organization develop effective policies on regional haze. 

The first document will describe why tribes need to be concerned with regional haze and 

how their involvement in the WRAP serves to reduce the haze that interferes with their 

traditional practices. This document, among other things, will highlight some of the 

traditional tribal practices that are affected by visibility in the west. 

The second document will discern what some of the traditional tribal practices are that 

utilize fire and other activities which may contribute to regional haze. This document 

will help WRAP participants to understand these traditional practices and their 

importance to tribes. In understanding the importance of such practices, WRAP 

participants will be better equipped to draft policies that meet the need and concerns of 

all involved with the process of addressing regional haze. 

Both documents will serve as educational tools for WRAP participants (and members of 

other regional planning organizations) who regularly work with and/or live near tribal 

lands. These documents will be a compilation of published and unpublished information 

about tribal practices and cultural values. Inclusion of unpublished information in the 

documents will necessitate tribal review and approval. In addition to the two documents, 

there could be additional versions, directed at specific audiences, such as other tribes and 

non-tribal audiences. It is anticipated that the documents will be professionally 

developed into a bound document for distribution to WRAP participants and others in the 

WRAP region. 

AMC5 Implementation Work Group (308 Template Development) – In 2004, the AMC formed 

the Implementation Work Group (IWG) of state, tribal and federal planners to develop 

one or more “templates” or “roadmaps” to assist states and tribes in writing their 308 and 

309(g) plans. Tribes are not subject to specific deadlines to submit TIPs, but it is 

expected that the work of the Implementation Work Group will include developing 

parallel material for 308 TIPs. In addition further work is needed to complete the 

template for the 309 TIPs. Closely related to this, the IWG will maintain ongoing 
34

communication with the other forums as needed, prompting timely information from 

states and tribes, and in turn providing feedback to the forums to ensure they are focused 

on the critical planning questions. WESTAR provides direct staff assistance under a 

services contract with WGA. This staff support brings to bear the WESTAR experience 

of preparing templates and model rules the states and tribes can fit to their own formats as 

appropriate. The State of New Mexico provided contract staff to complete the 309 work 

in 2004 and has agreed to provide contract staff to address the specific planning needs of 

tribes for 308 in 2005. 

AMC6 Workshops on Effective Collaboration – In the last year, during discussions among states 

and among tribes, reference has been made several times, along the lines, “The Tribes 

won’t talk to us.” or “State (agency) is making assumptions we don’t agree with.” 

Although there are examples of collaboration among states and tribes on specific 

projects, states in general have more mature air programs than most tribes and they must 

meet certain deadlines. Tribes are not subject to these deadlines. There is strong opinion 

among some of the tribes that they are included in WRAP work when it is convenient or 

in name only. Some states have little to no working relationship with tribes in their 

respective states. Tribal emissions and air quality data are almost non-existent. A number 

of tribes are reluctant to release tribal information because they are distrustful of state and 

federal regulators. 

This task would begin to strengthen working relationships between states and tribes that 

is essential in order to fulfill the requirements of the regional haze planning process and 

the Regional Haze Rule. EPA’s Regional Haze Rule explicitly addresses state-tribal 

relationships and directs them to work collaboratively with each other and in “partnership 

with other interested stakeholders,” but provides little guidance in this regard. The goal of 

these workshops is to facilitate improvements in working relationships within WRAP and 

among individual states, tribes and federal agencies, by enhancing the understandings of 

leadership and staffs of these entities about how each of them functions within their 

organizations, their various operational protocols and traditions. 

 

In general, the form of this project is a series of sub-regional workshops at selected 

locations within the WRAP region to instruct state and tribal WRAP partners in 

tribal/state protocols. Tribal and state leaders would address in turn their procedures and 

expectations of consultation, their governing structures, environmental priorities and their 

efforts toward collaboration. The focus would include identification of barriers to 

collaboration and ways to overcome them. Interested stakeholders would be invited to 

give insight into their organizational structures and collaborative efforts. 
35

CC1 Web Site Maintenance - primary communications tool for the WRAP. Consider 

additional funding for transition to new Operations/Maintenance Contract for improved 

performance. 

CC2 Continue and Expand Publications – This work is intended for both internal and external 

audiences and includes the following: 

• Collect inputs, draft and publish The WRAP Sheet on the Web site; 

• Print, mail, and/or fax hard copies of The WRAP Sheet to selected recipients; and 

• Produce brochures, fact sheets, and other handout materials for conferences, exhibits, 

and public meetings. 

CC3 Update Presentation Materials to Tell the WRAP Story: 

• Tailor the WRAP 301A, 401 and Tribal version presentations to meet needs of 

various forums/committees; and 

• Convert presentations to various video formats (CD, VHS, 35mm, etc.) and make 

copies for multiple venues. 

CC4 Expand Speakers' Bureau – Assure exposure of WRAP story to state and tribal general 

audiences throughout the WRAP region. Tailor to individual audiences as appropriate: 

• Develop and maintain data base of prospective audiences; 

• Work with state and tribal air directors/forum and committee chairs and follow up on 

contacts to schedule presentations; and 

• Coordinate presentation and support materials for all scheduled events. 

CC5 Support WRAP Forums and Committees in Conducting Public Meetings – Inform and 

obtain public input on WRAP products and related SIP/TIP development efforts: 

• Assist with arrangements for meeting venues; and 

• Coordinate presentation and support materials for all scheduled events. 

CC6 Other Outreach Efforts to Reach Wider Audience - Investigate partnering with other 

agencies/programs with shared goals – e.g., Pollution Prevention Roundtable for AP2 

presentation: 

• Identify potential partnerships and follow up to develop cooperative ventures; and 

• Participate in joint ventures with mutual benefit. 

Communications Committee
36

Appendix A: Background 

I. Background 

The 1990 Amendments to the Clean Air Act established the GCVTC, which in June of 1996 

completed its original mission to recommend strategies for improving visibility in the Grand 

Canyon and other Class I areas on the Colorado Plateau. Recognizing the need for a process to 

monitor and coordinate the implementation of its final recommendations, the GCVTC members 

created the WRAP. The WRAP includes participants from industry, environmental groups, and 

other affected parties and operates in conjunction with regional organizations such as WESTAR, 

the Western Governors' Association, and the National Tribal Environmental Council. The work 

products of the WRAP are used by states and tribes in the preparation of their individual 

implementation plans to meet the requirements of the federal regional haze rule promulgated by 

the U.S. Environmental Protection Agency (EPA) in 1999. 

While the initial focus of the WRAP was to implement the recommendations of the GCVTC in 

conjunction with federal visibility rules, the requirements of these rules also highlighted the need 

to implement other regional planning processes to improve visibility in all western Class I areas. 

In March 1999, the WRAP expanded its charter to address all regional air quality issues. 

II. Tribal Options for Implementation Plan Development 

Under the regulatory framework provided by the Tribal Authority Rule (TAR) (40 CFR 49.1– 

49.11) and the regional haze rule, tribal implementation of visibility programs through Tribal 

Implementation Plans (TIPs) is optional. The TAR authorizes but does not require tribes to 

receive delegation of authority to implement any program, or “reasonably severable elements” of 

a program, under the Clean Air Act. The preamble to the regional haze rule explains that “a 

tribal visibility program is not dependent on strategies selected by the State or States in which the 

tribe is located.” (64 Fed. Reg. 35714, 35756, July 1, 1999) The net result is that any tribe in the 

GCVTC transport region may implement §308 or §309 in whole or in part. 

The policy and technical work of the WRAP to assist states will simultaneously be designed to 

assist tribes in the same way. Tribal concerns are being addressed at every level within the 

WRAP. Tribal and state implementation plan needs may be different. As these differences are 

identified, project tasks and work plans will be updated to reflect the improved understanding of 

tribal needs. 

To ensure that tribal needs are addressed, the active participation of tribal representatives on all 

forums has been and will continue to be sought and encouraged. The National Tribal 

Environmental Council (NTEC) is responsible for coordinating tribal participation in the WRAP 

and receives funds from EPA for this purpose. Since some tribes do not have the resources or 

expertise to participate in the WRAP, NTEC provides tribes with analyses and synopses of issues 

emanating from the WRAP forums and work groups and from sources outside the WRAP. 

NTEC also facilitates consensus building within the WRAP tribal caucus. The Institute for 

Tribal Environmental Professionals (ITEP) at Northern Arizona University also provides 
37

assistance and staff through the Tribal Data Development Working Group to address a key tribal 

need – the acquisition of data necessary to make informed policy decisions. 

Finally, it should be noted that the WRAP organizational structure provides several checkpoints 

for tribal input. First and foremost, the WRAP has established equal representation for tribes and 

states within its management structure, including a tribal Co-Chair of the WRAP. Key positions 

are also reserved for tribal representatives on all standing committees, forums, and work groups. 

Public workshops for WRAP work products and travel support from the WRAP ensure that the 

broader tribal community has an opportunity to participate in the WRAP process. 

III. WRAP Organization and Structure 

In September 1997 the WRAP was formed with a membership including states and tribes both 

within and outside of the GCVTC region. The WRAP established oversight committees and 

forums charged with developing work plans to implement the GCVTC recommendations and to 

facilitate development of implementation plans under the RHR. 

A. Membership 

The WRAP membership currently includes the Governor or his/her designee from 13 states and 

11 tribes, two U.S. Cabinet Secretaries and the Administrator of the EPA or their designees: 

States Tribes 

Alaska Campo Band of Kumeyaay Indians 

Arizona Cortina Indian Rancheria 

California Hopi Tribe 

Colorado Hualapai Nation of the Grand Canyon 

Idaho Native Village of Shungnak 

Montana Nez Perce Tribe 

New Mexico Northern Cheyenne Tribe 

North Dakota Pueblo of Acoma 

Oregon Pueblo of San Felipe 

South Dakota Confederated Tribes of Salish and Kootenai 

Utah Shoshone-Bannock Tribes of Fort Hall 

Washington 

Wyoming Federal Agencies 

 Department of the Interior 

 Department of Agriculture 

 Environmental Protection Agency 

B. Charter and Bylaws 

The WRAP Charter and Bylaws set forth the basic operating goals, principles, and operating 

procedures and are posted on the WRAP website at http://www.wrapair.org/about/index.html. 
38

C. WRAP Organization 

The WRAP is composed of several forums, committees, and work groups. These 

suborganizations and their relationships are shown in the organization chart in the Executive 

Summary. All the suborganizations include participation from the WRAP membership (states, 

tribes, and federal agencies) and interested stakeholders (industry, environmental groups, local 

governments, academia, etc.). Guidelines for forum procedures (creation, membership, 

processes, etc.) are posted on the WRAP Web site at 

http://www.wrapair.org/about/forumguide.htm. 

D. Initiatives Oversight Committee (IOC) and Technical Oversight Committee (TOC) 

The IOC provides general oversight for the coordination and development of air quality 

strategies necessary to promote the implementation of federal visibility rules. The TOC provides 

general oversight of the technical activities of the WRAP. IOC and TOC members are appointed 

by the WRAP Board, which strives to manage a balance among tribes, states, federal agencies, 

the environmental community, and the industrial community. In turn, the IOC and TOC 

establish forums and work groups and appoint their co-chairs to conduct the specific work of the 

WRAP. 

Presently, there are 13 forums and work groups. The IOC oversees the Air Pollution Prevention 

Forum, Economic Analysis Forum, Mobile Sources Forum, and Sources In and Near Class I 

Areas Forum. The TOC oversees the Emissions Forum, Air Quality Modeling Forum, Ambient 

Monitoring and Reporting Forum, and Tribal Data Development Work Group. The Fire 

Emissions Joint Forum, Dust Emissions Joint Forum, and Stationary Sources Joint Forum are 

overseen by both the IOC and the TOC, as they address both technical and policy issues. 

E. Communications Committee 

The Communications Committee addresses communication among the members and groups of 

the WRAP as well as outreach and education of the public and interested groups on air quality 

issues. 

F. Stakeholder Involvement 

The WRAP includes participation from industry, environmental groups, and other affected 

parties. The following categories of representatives are regularly considered for membership in 

committees, forums, and work groups: 

· Industry · Small Business (including “green industry”) 

· Mobile Sources · Federal Government 

· Tribal Governments · State Governments 

· Local Governments · Academia 

 · General Public · Environmental Groups 

Committee and forum members are expected to represent and communicate with their agencies 

and constituents. Forum and committee members are responsible for establishing mechanisms 
39

that will ensure this communication occurs. These mechanisms may involve working through 

trade groups, state and tribal organizations such as the Western States Air Resource Council 

(WESTAR Council), the National Tribal Environmental Council (NTEC), and intra- and interagency forums. 

IV. Project Management 

A. Setting Priorities

The WRAP members establish the strategic direction of the organization, setting overall 

priorities for action. Once the WRAP agrees on a direction, issues are further developed and 

priorities refined by the following process: 

• The WRAP identifies issues and requests that one or more oversight committees address 

them, or asks that the oversight committees develop issues and work plans for review by 

the WRAP. 

• Oversight committees examine the management and technical issues associated with the 

strategic direction and identify the major deliverables, skills required, and stakeholders 

most affected. 

• Based on this examination, oversight committees may refer issues to existing forums or 

work groups or create forums and work groups to generate the deliverables. Oversight 

committees appoint co-chairs of forums and work groups and work with the co-chairs to 

develop a written charge, including objectives, expectations, and time frames for 

deliverables. 

• Co-chairs of forums and work groups appoint members, taking into consideration 

stakeholder balance and the charge from the oversight committee(s). 

• Each forum and work group is responsible for developing a detailed work plan to meet 

the work product and process guidance from its oversight committee(s) and they should 

issue bi-monthly reports to their oversight committee(s). 

• Oversight committees review and approve detailed work plans to ensure that all WRAP 

time lines and process needs are addressed. 

• Depending on the nature of the process, each forum and work group works with its 

oversight committee(s) to resolve deadline or budgetary conflicts that may arise in the 

plan development process. 

B. Reconciling Conflicts

If an issue arises on which a forum or work group can not reach consensus, the issue is referred 

to the oversight committee(s). If the oversight committee(s) can reach consensus on the issue, 

that decision is referred to the forum or work group for integration with the forum or work 
40

group’s decisions on other issues. If the oversight committee(s) can not reach consensus, the 

issue may be referred to the WRAP Board for resolution, or it may be referred back to the forum 

for further debate. When conflicts over priorities and budgets can not be resolved by the 

individual forum, work group or committee, the issue may be referred to the WRAP Board. 

C. Outreach and Peer Review

The WRAP Communications Manual sets forth the process for reviewing work products and 

policy decisions. At each stage of review, relevant material will be posted on the WRAP Web 

site and comments will be solicited. 

Work products must be presented to the appropriate oversight committees before being presented 

to the WRAP. The oversight committees may provide feedback to the forums or work groups; 

the forum or work group has the responsibility to decide whether or not to make changes. 

Changes the forums or work groups make to work products should be communicated to the 

oversight committees so recommendations from these groups to the WRAP can be fully 

informed. 

Major work products are subject to public review through workshops and formal public 

comment periods. The forums and work groups are responsible for acknowledging public and 

peer reviewer feedback in the final presentation to the WRAP. 

D. State and Tribal Coordination

In addition to the extensive and ongoing communication and coordination that occurs directly 

between WRAP participants, the WRAP will work with the Western States Air Resources 

Council (WESTAR) and the National Tribal Environmental Council (NTEC) as important 

coordination points to ensure that state and tribal regional haze needs are clearly identified and 

addressed by the WRAP. 

E. Administration and Staffing

Members of committees and forums perform much of the work of the WRAP. The oversight 

committees monitor forum and work group activities to ensure that work products are developed 

in a timely manner and that stakeholder participation remains representative, balanced, and fair. 

Contractors hired with EPA grant funds are relied upon to expand the resources of the WRAP. 

Committees and forums direct the work of contractors. 

Support services to the line functions of the WRAP come from the Communications Committee, 

the National Tribal Environmental Council (NTEC) and the Western Governors’ Association 

(WGA). The Communications Committee has developed a Communications Manual for the 

WRAP’s internal and external communications and assists committees and forums with outreach 

strategies for specific products and activities. 

WGA and NTEC staff provides overall project management for the WRAP. WGA provides 

much of the basic logistical support for the WRAP by preparing and managing grant 
41

applications, funds, requests for proposals (RFPs), contracts, travel reimbursements, meetings, 

conference calls, public and media inquiries, press releases, Web sites, requests to participate in 

the WRAP, and report publications. Staff assistance includes providing a “sounding board” for 

stakeholders having concerns with the WRAP processes and relating concerns to forum cochairs, oversight committees, committee co-chairs, facilitators, and the WRAP co-chairs. 

Additionally, WGA and NTEC staff routinely attend the meetings of the various committees and 

forums. WGA and NTEC jointly or separately perform tasks related to WRAP and serve as 

primary contact points by responding to media and public inquiries. 

Under a separate EPA grant, NTEC assists tribal participation in the WRAP by arranging and 

facilitating Tribal Caucus meetings; providing coordination among tribal representatives of 

various committees and forums; performing legal, policy and technical analyses on various 

WRAP issues; and securing contractor assistance for additional policy and technical analysis. 

This includes providing staff support to the Tribal Caucus within the WRAP. 

Staff positions include the WRAP Co-Directors (WGA and NTEC) who oversee other staff, 

share general management responsibilities, work with stakeholders to ensure the WRAP's 

processes are fair an equitable, and serve as the primary points of contact for EPA, the media, 

and the general public. Funding for one of the co-directors is under the WGA line item, while 

funding for the other is under the NTEC line item. There are state and tribal caucus coordinators 

hired through WESTAR and NTEC respectively. 

WGA also employs a technical coordinator and policy analyst to support the oversight 

committees, forums, and work groups. NTEC employs a tribal communications specialist who 

works closely with the WRAP's Communications Committee and who is available to other 

committees and forums to ensure that communications with and for the tribes are properly being 

carried out. NTEC also employs a tribal policy analyst to address the unique circumstances of 

tribes with respect to the Clean Air Act and other related issues. 

F. Contract Management 

WGA and forums jointly manage WRAP contracts. WGA, as the receiver of WRAP grants, 

retains the legal responsibility for signing and administering contracts and ensuring that work 

products are completed. These responsibilities are met with input from forums and work groups. 

Forums and work groups may create balanced subgroups for purposes of contract management. 

It is the responsibility of the forums and work groups and their respective oversight committees 

to develop the scope of work for each contract. All contracts are to be developed in accordance 

with the work plans approved by the WRAP and submitted to the EPA. Once the scope of work 

has been properly developed, it is transmitted to WGA. WGA is responsible for developing an 

RFP or sole source justification. All RFPs are sent to appropriate contractors known to the 

WRAP, posted on the WRAP Web site, and published in the Federal Business Opportunities 

publication as appropriate. Unless time is otherwise a constraint, bidders are provided 30 days to 

respond. 
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A review team is established for the evaluation of proposals. The review team is responsible for 

scoring each proposal. Scoring is documented and retained by WGA to substantiate any 

selection. Once the team has agreed upon selection of a potential contractor, a memorandum is 

transmitted to the WGA Executive Director along with any necessary supporting materials. The 

Executive Director makes the final contractor selection. The winning contractor and all losing 

bidders are notified in writing of Executive Director’s decision. 

Subsequent to contractor selection, WGA staff and the appropriate forum, work group, or 

committee negotiates a final contract with the winning bidder. All contracting is done in 

accordance with established federal guidelines. The standard contract form includes provisions 

for record keeping and audit requirements in accordance with OMB Circular 110. 

It is the responsibility of the forum, work group, or committee to monitor the work of the 

contractor and to determine whether all work requirements are being met. When a bill is 

received, WGA will examine the invoice to match invoice items to requirements outlined in the 

contract. WGA requires documentation from the contractor regarding hours spent and expenses 

incurred. WGA also requires copies of any deliverables prior to rendering payment. If there is 

any question regarding whether the contractor has met the requirements in the scope of work, it 

is negotiated between the contractor, WGA, and the appropriate co-chairs. Once it has been 

agreed that all work has been completed in accordance with the requirements of the contract, 

payment is rendered by WGA. 

WGA is responsible for maintaining all records and does so in accordance with all federal 

requirements. This includes submittal of quarterly status reports to EPA. As noted in the 

previous section, NTEC lets contracts for work done in support of tribal participation. These 

contracts are funded by a grant separate from the general WRAP grant, and are subject to the 

requirements of the single audit act and related compliance supplements. 
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APPENDIX B: Process Overview for 2005 WRAP Projects. 

Stationary Sources – SS4 Dust Emissions – DF3, DF4 Emissions – EF1, EF5 Fire Emissions – FF5, FF7, FF”C” Tribal Data Development – TW1, TW2 Economic Analysis – EA2, EA3 Air Monitoring & Reporting – AMR1, AMR2 Air Quality Modeling – MF1

Stationary Sources – SS5 Dust Emissions – DF1, DF2, DF6 Emissions – EF2, EF3, EF4 Fire Emissions – FF1, FF4, FF6+3, FF8, FF”B”, FF”D” Mobile Sources – MS1, MS2, MS3 Air Managers – AMC3, AMC4 Tribal Data Development – TW3 Economic Analysis – EA4 Air Monitoring & Reporting – AMR3 Attribution of Haze – AoH1 Air Quality Modeling – MF1, MF2

StationDust EFire EmFF”E” Air MaEconomAttribuAir Qu

Ongoing Collection and 

Reporting of Basic Data

Analyzing and Refining Data and Policies 

We

Wor
44

APP. C: WRAP Region, Members, and Federal Areas Covered by the Regional Haze Rule 
45

APPENDIX D: Map of Tribal Lands and Tribal Class I Areas in the WRAP Region 
46

APPENDIX E: WRAP Organizational Chart. 

Website 

Progress 

Reports, 

Stationary 

Sources – 

SS45 

Stationary

Reportin

g of 

Basic 

Data