## 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 Deve lopment 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. 461 

### I. INTRODUCTION

This work plan summarizes activities and e xpenditures planned by the Western Regional Air Partnership (WRAP) for calenda r year 2005, including activities in itiated 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 gran t 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 leve ls for these projects are shown in the last column of the table, titled “2005 Request”.

Table 2 also lists projects funde d through previous years’ grants which are currently underway (column titled “Projects Underway”) or whic h are pending initiation in 2005 (column titled “Projects Pending”). For those projects underway, th e table lists actual “Expenses to Date” as of August 31, 2004.

The completion in December of 2003 of Secti on 309 regional haze plans by five WRAP states and the city of Albuquerque represented a si gnificant accomplishment of the WRAP. The WRAP’s principal effort in 2005 will be to bui ld on the work completed through the Section 309 plans in order to support state and tribal de monstrations of reasonable progress to improve visibility at the more than one hundred Class I areas in the WRAP region.

Recognizing this challenge, the WRAP comp leted 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 stra tegic plan provide the overall sc hedule 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 part icipation and consensus-based decision making, which are key featur es of the WRAP process. Th e strategic plan also provides guidance to the individual plan s 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 politic al issues. The WRAP region includes 116 (or 75 percent) of the nation’s 156 ma ndatory 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 la nd 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 pa rticulate matter nonattainment issues, which simplifies air quality planning to some extent , but many WRAP members are faced with rapid population growth and other challeng es to preventing deterioration of air quality. Moreover, the

1 See http://www.wrapair.org /forums/sp/docs.html2 WRAP must be sensitive to other regionally-impor tant environmental issues, such as fire and drought. This presents a unique and challenging environment fo r long-term planning which is best addressed through a single, well-funded and well-organized institutio n at the appropriate political level. The WRAP, with the appropr iate EPA financial support, provides such an institution, especially given its co-management st ructure shared between the Western Governors’

Association and the National Trib al Environmental Council.

Finally, the WRAP’s long-term pla nning process must be prepared to deal with relevant events beyond its control, such as fede ral multi-pollutant initiatives and the ramifications of legal challenges to the RHR. One way the WRAP conte nds with these events is to have sufficient staffing to track the issues and to foster a constructive dialogue among its members.3Table 1: Overview of WRAP 2004 - 2005 Key DeliverablesTimeFrameResponsible Group/Subject Deliverable (completion target month)Emissions ForumOperational version of EmissionsData Management System (EDMS) with actual 2002 EI for WRAPregion. (December)NH3inventory improvement project complete (October)Fire Forum (Phase 2 EI project) Final 2002 complete fireEI – actual 2002 emissions, stored in EDMS. (December)Monitoring Forum (CoHAproject)Source apportionment of each state’s major emissions source category impacts at Class I areas in AoHreport. (December)Descriptive analyses of 2002 monitored impactat Class I areas in AoH report. (December)Modeling Forum (TSSA project)Source apportionment of each state’s major emissions source category impacts at Class I areas in AoHreport. (December)Source apportionment of each state’s natural andmanmade emissions at Class I areas in AoH report.(December)Boundary conditions and new emissions estimates from WRAP Fire Forum, other RPOs, Canada, andMexico updated. (September-October)Attribution of Haze WGAoH 2004 Draft Reportdraftcomplete – Integrated “weight ofevidence” source attribution for eachstate’s emissions source category impacts at Class I areas, from TSSA and CoHA projects, based on2002 “interim” (not EDMS) EIs. (December)Tribal Data Development WGTribal monitoring data analysis from CoHA projectfor tribal Class I areas in AoH report. (December)Stationary Sources ForumList of BART-eligible sources (December)Begin work on oil/gas and point source EI projections.Dust Emissions ForumPhase 2 windblown dust emissions inventory modelcompleted, evaluated, and EI included insubsequent modeling analyses. (October)Causes of Dust analysis products from CoHA project. (December)Fugitive dust handbook and website. (December)2004 Q4Economic Analysis ForumComplete pilot study / demonstration ofeconomic analysis framework. (December)4Emissions ForumEDMS updated with 2018 base case EI for WRAP region. (April, pending SSJF/TDDWG projectsbelow)Fire Forum (Phase 3 EI project)2000-04 baseline period fire EI – for planning purposes, stored in EDMS. (March)Monitoring Forum (CoHAproject)Continuing development of conceptual modelsand processing of additional data. (March)Modeling Forum (2002 basecase modeling project)Modeling performance evaluation using actual2002 emissions from EDMS, and compared tomonitoring data. (March)Attribution of Haze WG•AoH 2004 Final Report complete – see draftdescription above in 2004 Q4. (January)Tribal Data Development WG•Tribal monitoring needs report from CoHA project for tribal Class I areas. (March)Review, improve, project emissions inventories ofpoint and oil/gas sourceson tribal lands. (March)Stationary Sources ForumReview and improve the 2002 point and area source inventory. (February)Begin work on oil/gas and point/area source EI projections. (January)Mobile Sources ForumWorkshop to initiate offroad retrofit program. (January)Dust Emissions ForumEstablish a preliminary definition of dust and release for public review.2005 Q1In and Near Forum•Summarize PM10SIPs for local sources and their transferability to Class I areas.Emissions ForumPrepare scenarios’ specifications and EIs for 2018 control strategy projections for WRAP region, storedin EDMS. (June)Fire Emissions Forum (Phase 4EI project)2018 projection year fire EIs consisting of 2 to 3 scenarios, stored in EDMS. (May)Monitoring Forum (CoHA)Continuing development of conceptual models and processing of additional data. (June)Modeling Forum (2018 basecase modeling project)Modeling performance evaluation using 2018base case emissions from EDMS. (June)Stationary Sources ForumComplete work on oil/gas and point source EI projection scenarios. (June)2005 Q2Dust Emissions ForumHost dust control measures workshopComplete enhanced ambient data analysisEstablish appropriate size distributionof fine versus coarse dust emissions.5Emissions ForumContinuing emissions analyses for 2018 control strategy scenarios. (September)Monitoring Forum (CoHAproject)Begin to define work products for reasonable progress tracking for second AoH report. (August)Define analyses and work productsfor second AoH report. (August)Modeling Forum (2018 controlstrategy modeling project)Start source apportionment of each state’s 2018 major emissions source category impacts at Class Iareas, associated with control strategy scenarios for second AoH report. (September)Attribution of Haze WGStart second AoH project - integrated “weight of evidence” source attribution for each Class I area’scontrol strategies, to be complete early 2006. (July)Stationary Sources ForumContinue work on control technologyanalysis and program development2005 Q3Dust Emissions ForumComplete definition of dustEmissions ForumContinuing emissions analyses for 2018control strategy scenarios. (November)Monitoring Forum (CoHA)Work products to support AoH report. (December)Modeling Forum (2018 controlstrategy modeling project)Continuing source apportionment of each state’s 2018 major emissions source category impacts atClass I areas, associated with control strategy scenarios. (December)Source apportionment of each state’s natural and manmade emissions at Class I areas. (December)Attribution of Haze WGContinue work on second AoH project analysis - integrated “weight of evidence” source attribution foreach Class I area’s control strategies, to be complete early 2006. (December)Stationary Sources ForumContinue work on control technologyanalysis and program development2005 Q4Dust Emissions ForumComplete analysis of sources andcontrol options in high-dust areas6 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 Calculati ng 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 70,000 430,0007 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 08 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 3,081,2419 Figure 1. Strategic Plan Timeline (Updated October 13, 2004).1011 

### II. PROJECT SUMMARIES

The following sections provide project summarie s for each of the WRAP’s forums, committees and work groups. These projects were develope d by the forums consistent with the direction provided in the strategic plan and by the overs ight 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 mi ght be aggregated into regional haze plans.

IO1 Reasonable Progress Criteria – The regional haze rule requi res states, when establishing reasonable progress goals, to consider the following statutory fact ors: the cost of compliance, the time necessary for co mpliance, the energy and nonair quality environmental impacts of compliance, and th e remaining useful lif e of any potentially affected source. Furthermore, states must include a demonstration in their SIPs showing

how these factors were taken into considera tion 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 furt her definition and guida nce 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” identi fying 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 ta sk is to develop a pr ocess by which the most effective control strategies will be identified and refined.

This work plan assumes that most BART activ ities 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 developm ent 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 addr ess any potential expansion of the Clean AirInterstate Rule (CAIR) to the West. In the course of its work, the SSJF will assume that the fivestate SO2 milestone and backstop emissions tradi ng program will remain in effect and must be preserved in any regional strate gy. 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 Oversi g ht Committee

Stationar y Sources Joint Forum12 SS4 Technical Support for Emissions and Control Technology Analysis – The purpose of this project is to support WRAP ac tivities 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 addr ess 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 so urces. The control technology analysis will address issues such as costs, control efficiencies, and othe r impacts on the source and environment. For SO2, consideration will be given to expansi on 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 federa l multi-pollutant initiatives fo r 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 c hoose 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 contribu tion of various sources to regional haze in the West. A single contractor or team of c ontractors 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 an alyses as assumptions change or new data

become available.

SS5 Regional Stationary So urce Strategy Development – This project will include activities which are needed to (1) further implement a lternative programs to BART or (2) address sources and/or pollutants which are not incl uded in the alternative programs. Such activities may include providi ng 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 milestone s; geographic, new source, and tribal considerations; monitoring and reporting requirements; enforcement provisions; economic impact assessments; and a ge neral 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 Pla n, fall into two main categories:

1) The first category provides analyses of t echnical 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 Forum13 2) The second category addresses exis ting and future Technical Needs , specifically emissions inventory development and rela ted 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 polic ies and guidance pertaining to smoke management of fire. Recommendations from this assessment have possible linkage to both the Enhanced Smoke Management Pr ogram and the Annual Emissions Goal policies, both §309 requirements and potentially useful approaches for §308. FETM may also be useful in the development of scenar ios for future fire emissions inventories.

FF”E” Fire Emissions Categorization Guidan ce: 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 pr escribed burns in terms of vegetation structure, fuel loading, fuel size classes, ecosystem function and fire resilience. Th is project directly supports the “anthropogenic” / “natural” appo rtionment for implementation of the FTS requirement in §309 as well as similar implementation issues for §308. These categorizations will help support natural a nd 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 Coordi nation is a required element within the ESMP Policy as coordination of burning activ ity (ranging from passive to active) is critical to avoiding cumulative smoke im pacts within and acro ss source types in mandatory Class I areas. Methods for this inte r-jurisdictional and re gional coordination will need to be developed for wildland and agricultural prescribed fire smoke management programs, information sharing, and public notificati on. Proposed options will be developed, and then presented and review ed 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 a nd SIP implementation and refinement of policy options under §308. This effort will bu ild on the two FEJF workshops held in 2004 to ensure that the needed technical and polic y tools are in place for SIP/TIP development under §308. Reprogramming 2004 fundi ng 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 con tinue 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 rangela nd. Agricultural bur ning 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 jurisdicti ons. Phase I developed an initial emission inventory to allow the RMC to initia lize the 2002 modeling efforts.

Phase II involves further refinement of th e Phase I inventory with greater QA/QC and state/tribal review of the fire activity estim ates. Data collection to support estimates of private rangeland burning and augmentation of ag ricultural 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 repr ogrammed 2004 funding. This remote sensing approach may also allow for new approaches to the Phase III Baseline inventory. The 2002 emission inventory will include “anthr opogenic” / “natural” apportionment to support the Attribution of H aze initial report. These proj ects directly support the modeling for the §308 SIPs/TIPs and should allo w 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 fulf ill the states’ emissions inventory reporting requirements. This portion of the pr oject was funded by reprogramming 2004 funding

and will be started in 2004.

FF6+3 Phase III & IV Inventories & Prelim inary 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 representa tive emissions inventory. Phase IV is for the 2018 Planning Apportionment and will be a 2018 representativ e inventory. The 2018 inventory may include a range of potentia l control scenarios a nd possible ranges of emissions to reflect the high degree of uncer tainty in this type of forecast. The inventories will be prepared for the conti guous WRAP region for wildfire, prescribed fire, and wildland fire use on wildland a nd rangeland. Agricultural burning is also included. Alaska fire emissions may follow th e lower states in de liverable 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 s upported by the FEJF through development of technical approaches to appor tioning the impact of fire emissions between natural and anthropogenic source categories. These projec ts 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 em issions inventory for wildfire will be15 developed through an inter-RPO effort f unded by EPA, based on a scope of work discussed amongst the RPOs. The FEJF has le ad RPO responsibilities for this project. These projects directly support th e 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 Inventor y (Canada & Mexico), Representative Base Year Inventories (current conditions & 2018), Software Development for Location Conversion (STR to lat./long.), and 2002 Prescribed Fire Inve ntory. 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 dire ctly 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 Re gional 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. Th is 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, variati ons in total net emissions, and other key assumed parameters in the context of the re gional model results. This project directly supports refinement of the m odeling 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 m odeling features chemistry capacity with regional and longer temporal scales. The me soscale modeling features complex terrain capacity with smaller geographic and temporal scales. Together, these two approaches will provide a comprehensive analysis of potentia l de minimus levels to assist states and tribes with maximizing efficiency for fi re tracking, public noti fication and regional coordination. This project di rectly supports the implement ation of the FTS and ESMP requirements in §309 as well as sim ilar implementation issues for §308.

FF5 Fire Tracking System / Emissions Data Management System – Portions of this project were funded prior to 2002 and in 2004 w ith additional 2004 funding being reprogrammed to this project and will be started in 2005. Evaluation of ex isting fire emissions inventory systems to develop a Fire Tracking System within, or bridged to, the WRAP EDMS as identified in the Fire Tracking System polic y to calculate emissions from fire activity data. Develop user guidance to support the FT S policy identifying a specific format for the EDMS, parameters, defaults, structur e and methods of emission calculation for16 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 Em issions Benefits of Emissions Reduction Techniques to Support Implementation of the AEG Policy – This project was funded and

started in 2003 with the co mpletion of an annotated bi bliography 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 vegeta tion/crop type, emission factors, economics,

and emissions averted includi ng identification of new ERTs . Develop user guidance to support the tracking of ERTs (specific form at, 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 Board 2 and on its subsequent manageme nt directive to the IOC and

AP2 Forum. 3

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

work with the Western Governors’ Associ ation to convene a regional meeting of stakeholders to collaboratively develop a “blue pr int” that will define the critical features

needed to:



### ◦ Conduct a needs assessment and develop a si ngle 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 Interconne ction to support establishmen t of a single institution in the West responsible for registering, i ssuing, tracking, and verifying renewable energy certificates; and



### ◦ Create of an independent, regional genera tion tracking system to provide data necessary to substantiate the number of megawatt hours generated from renewable energy sources and to support verifica tion, tracking, and trading of RECs.

PP5 Displaced Emissions Analysis and Ti me-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 coul d be used by states to help energy offices and air quality managers develop credible, st ate-specific estimates of emissions displaced by adopting different renewabl e energy programs and energy e fficiency best practices

2 WRAP Policy: Renewable Energy and Energy Efficiency As Pollution Prev ention Strategies For Regional Haze; April 2003; pg. 1-2.

3 Ibid.; pg 3. Air Pollution Prevention Forum17 found in the AP2 reports. The Forum’s anal ysis, to date, has focused only on regionalscale impacts. Emissions displacement tool s similar to those developed by OTAG for NOx could help individual states establish reporti ng, 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 pa rtial support to the

Western Governors’ Associ ation (WGA) Clean Energy In itiative. The WGA Clean Energy Initiative is described in a WGA policy resolution approved on June 22, 2004. The initiative includes a goal of achie ving 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 stra tegies through state a nd 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 pr ogram is to promote voluntary emission reductions from existing offroa d 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 guida nce, 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 progr am 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 ha s 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., fo r ocean-going vessels and locomotives). Mobile Sources Forum18 IN1 Update Near Inventory and Displays – The goal of this project is to replace the 1996 maps and data currently on the In/Near we bsite 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, af ter the EDMS is operational and other priorities are addressed by the Emissions Fo rum 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 Fo rum will work with the Emissions Forum, EDMS contractor, and as necessary ENVI RON (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 pl an. 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, se asonal, or of such si ze that would not be properly characterized by a regional-scale m odel – 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 PM 10 SIPs, maintenance plans, and natural events action plans in the West focused primarily on local, primary sources of PM. Many of th e existing plans rely on one or two control strategies for the bulk of emi ssion reductions. A subset of thes e 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 th eir 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 Cla ss I area visibility protection (federal land managers, state and lo cal officials, environmental groups, etc.). The result of this project will be a repo rt summarizing the approach, success, and

limitations of the most common PM 10 control measures; their applicability and transferability to Class I areas; and a list of contacts for mo re information. It will include

ambient PM 10 data for the areas studies and summar ies of interviews with officials who implemented and enforce the strategies.

EA2 Development of Baseline Econom ic 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 part icular challenge within this task will be the continued collection and development of tribal baseline data. The overall baseline

effort will be conducted in close coordinati on 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 Anal y sis Forum19 To date, baseline data have been collected for three states in the WR AP 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 overal l effort to compile baseline data for the remaining WRAP states. Development of th e baseline economic and demographic data

would include careful documentation of bot h the process and sources employed. In addition, that documentation would include easily applied rule sets for both modifications (if needed) and deconfliction as new informa tion 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 base line data and projecti on updates as part of the overall analyses identified in the WRAP Strategic Plan.

In concert with the Emissions Forum, the EA F and its support contractor will work to ensure that consistency is maintained be tween the baseline projections and their subsequent use by the Air Quality Modeling Fo rum. 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 consis tent economic impact and trad eoff 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 reducti on 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 (wheth er full or a “lite” ve rsion”) for reductions attributable to that partic ular 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 expe nse of conducting the needed research and the tremendous uncertainty involved in evaluating “soft” effects. “Tailored” unit benefit values taken from pr evious studies for such areas as health, materials and ecological impacts can provide cr edible “default” or standard coefficients by use of all stakeholders in future economic analyses and regulatory strategy tradeoffs. We recognize, however, that ta ilored values will fall short of the broad set of values needed by the diverse set of st akeholders with WRAP. As with some of the other tasks, the Forum will actively seek partners to co mplete 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 equa tion – that of control costs for the myriad of strategy and technol ogy 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 estimat es, both for the current set of control technologies, and those technologi es 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 (u sually due to inherent uncertainties in20 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 pro cesses 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 reduc tion strategies for the states of AZ, MT and ND and three tribes) employs a fairly comprehensive anal ysis. Along with the comprehensiveness of such analyses comes the commensurate costs – understanding, skill s, 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 seri ous consideration by WRAP stakeholders

As a complement to the study framework ongoing application, the Forum is targeting completion of an initial sc reening tool based on the fr amework (e.g., a light-weight version of the framework) to be applied more routinely and co st-effectively by WRAP stakeholders for assessing and ranking a va riety 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 fi nishing the screening tool, the forum will run through a couple of test cases to see if the tool works and to en sure that the final tool is something useful and meaningful for WRAP. This screening tool has been explicitly identified as a needed capability w ithin 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 condit ions 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 Cl ass I Areas Forum. A critical area of coordination will be with tribal issues (e .g., baseline data, distributional impacts, and alternative values), with requi res 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, es pecially since formal, comprehensive (e.g., both costs and benefits) economic analysis is not typically an ev eryday part of WRAP ember activities. To improve coordination and outreach, the EAF will take advantage of WRAP-wide meetings to host periodic work shops 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 stake holders 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 consultati on, answering questions, and guiding the use of various economic mode ls including both the full WRAP Economic

Framework and its “lite” versi on ($25-50 K). (2) The mid-leve l, or ‘partner’ role would involve partnering with the vari ous stakeholders (principally the states and tribes who are ultimately responsible for 308 and 309 SIP prep aration) in the actual conductance of their respective varying economic anal yses ($40-150K). (3) A third le vel, or role would be for the EAF and its supporting contractors to perf orm 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 comprehensiv e 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 suppo rt 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 a pproval 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 iden tified 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 ou tputs analysis & reports

o Model performance evaluation

 April 2005 - 2002 final base case modeling results report Air Q ualit y Modelin g Forum22  June 2005 - 2018 final base case modeling results report

 August 2005 - 2018 base case final source a pportionment modeli ng results report

 Fall 2005 - Three to five [3-5] 2018 contro l 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 contributi ons 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 tw o tasks: 1) Develop appropriate methods for running MM5 over central Alaska, includi ng Cook Inlet, the Alaska Range, to north of Fairbanks, and 2) Run MM5 for this re gion for several time periods representing different seasonal and meteorological conditi ons and evaluate the meteorological model results. During the Spring of 2005, RMC staff will present the result s of their work to date at a technical meeting in Alaska. Pendi ng more specific direc tion after that meeting, the 2005 Alaska modeling tasks will focus on:

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

2002.

 Then run a Lagrangian model, such as CALP UFF, for the largest point sources in the region (up to about 10) - provi de a modeling results report.

 Run the Lagrangian model [chosen previously ] to evaluate the potential for impacts from the urban areas of Anchorage and Fair banks - provide a mode ling results report.

The Emissions Forum is planning to continue a major project, a nd several specific supplementary projects during 2005. The Emission s 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 Ph ase 2. The Forum also plans specific projects addressing independent testing of the EDMS functions as it b ecomes 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 fede ral 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 th eir computer systems subcontractor, Carolina Environmental Programs. P echan has proposed a budget of $120,000 for operation and administration of the EDMS, in cluding data analysis products, data provider/user assistance , and general oversight. Emissions Forum23 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 Manage ment activity data protocol for data providers to transmit, view, and track on th e 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 Pr ogram policy adopted by WRAP.

2) With review and approval by the EDMS Steering Committee, specify and implement an EDMS protocol to accept/use/display stat e/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 s upport the fire emissions tracking elements in §309 smoke management programs committed to by OR, WY, UT, AZ, and NM.

This subtask would create emissions invent ories 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 re gulatory tracking purposes, and would be separate from the fire emissions inventorie s 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 tool s and procedures to use in estimating emissions changes from annual emissions goals and regiona l control strategy

scenarios. This subtask would create emissions adjustment factors which smoke management program operators could us e to modify their regulatory tracking emissions inventories (from #2 or #4, above ) for planning purposes, as well as to separately modify the fire emissions i nventories 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 ar e needed to verify proper operation at the

time the EDMS comes on-line in late 2004. Tw o 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 correc tions 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 inventorie s, 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 sta ndard point and area source emissions projection models and tec hniques in common use. These WRAPdesignated economic and other data types a nd the associated mode ls 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 invent ory 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 need ed for this project toward the SS4 project, reserving 10 to 15% to insure that the emi ssions 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-ro ad and non-road activity data as inputs to the EPA mobile emissions models with limited surveys, a nd then generate Emi ssions 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 ta ken in the §309 SIP updates as well as in the §308 plans. This project would use the i nput and default information from the §309 mobile source EI work as a starting point, a nd send those data to states, locals, and/or metropolitan planning organizations for veri fication and updating (i.e., with 2000 census data). The mobile source inventories woul d capture all regulations on the books as of September 2004 for use in preparing th e 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 en d of 2004 to analyze tr ibal monitoring data through a subproject of the Causes of Haze Assess ment project, as well as continuing training and support for TEISS implementation. Also, th e TDDWG has reprogrammed resources from their 2004 budget to have ITEP facilitate develo pment of actual 2002 emissions inventories for:

• SOx and NOx point sources on trib al lands with emissions great er than 50 tons/year; and

• Oil and gas production/distri bution 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 implementati on and training on TEISS, and training on the software before making it available to the Tr ibes to compile their respective emissions inventory data. Also, training sessions will be offered for the Tribal Professional by

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

• TEISS Software Support (software distribut ion 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 pr ovide voice and electronic support, for the use of TEISS in Alaska);

• TEISS Software User Workshops (Two work shops, designed for both new [3.5 days] and experienced [2.5 days] TEISS users, wi ll be developed and conducted at the Tribal Air Monitoring Support (TAMS) Cente r’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 th at piggybacks with another meeting and conference with tribes funding their own travel or using th e 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 gui dance documents and assistance;

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

• Information about contractors who have wo rked 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 Develo p ment Work Grou p26 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 t echnical 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 deve loped 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 work ing 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 re servations and provide assistance on a one-onone basis is requested. Due to travel related costs, request s for assistance from Alaskan tribes must be considered carefully and needs met in such a way that the maximum

number of Alaskan tribal co mmunities will be served. Thes e needs could be met through mini-workshops in Alaska, with Alaskans pr oviding their own travel funding to a central location in Alaska. ITEP would help facili tate the information distributed at these workshops – but no funding is requested in th is proposal for ITEP staff or instructor

travel to the state.

Funds are requested to allow those trained in the initial train-th e-trainer workshop, or other tribal staff knowledgeable in EI techniques and methods, to travel to another tribe’s reservation and provide assist ance in planning EI work, colle cting data, using TEISS, and completing and reporting EI results. These f unds could also be used to fund travel for tribal trainers to assist with the TEISS workshops.

Funds will also be used as needed to mainta in 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 mainta in the geographic information system (GIS) tribal coverage for the WRAP region. The GI S Specialist would cont inue the outreach to tribes and updating of the GIS coverage de veloped 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 S ources 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 trai ning 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 fo r 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 communi ty 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 comm on definition of dust and to de velop a policy for categorizing dust emissions as either natural or anthropogenic. The common definition and categorization policy could then be used to consistently track dus t emissions and theircontributions to regional haze. In 2004, the DEJF started the process of a consensusbased definition of dust. A draft definiti on 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 activ ities, such as those of the Attribution of Haze Work Group. The DEJF anticipates using a facili tator and one or two public workshops to

finalize the definition an d categorization policy.

DF2 Enhanced Ambient Data Analysis – In 2004, the DEJF funded a project (DF2) to identify the 20 percent worst visibility days dominate d by dust at all West ern IMPROVE sites for the years 2000-2002, and to place these events into one of se veral categories (e.g., local, regional, Mexican, Asian, fire-related, uncertai n, 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 a bout the precise sources of dust (e.g., are local events hi ghly localized, or on the scale of tens of miles? is the local

dust associated with human activ ity? if so, what activities, wh ere, and when? what are the

trends in dust concentrations a nd 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 IM PROVE 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 hi gh-dust areas). An additional reason for continuing ambient data an alysis of dust is the uncertainty regarding the quality and usefulness of the 2002 wi ndblown 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 devel oped in 2004) to keep them as relevant and useful as possible to WR AP members throughout the SI P development process (i.e., 2005-2007). New information will be includ ed in the handbook and website as it Dust Emissions Joint Forum28 becomes available from other WRAP projec ts (e.g., the Dust Control Measure Workshop described below) and from other dust-rela ted efforts (e.g., dust control programs in various western jurisdictions).

DF6 Analysis of Sources a nd Control Options in High-Dust Areas – The purpose of this project is to test and de monstrate how the various pr oducts of the Forum can be integrated to address the cont ribution of dust to regional ha ze at one or a small group of Class I areas. This “pilot study” will us e 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 opti ons, costs, and benefits in a real-world setting. Shortcomings of the process a nd/or WRAP products will be identified and refined to the extent possibl e 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 significan ce of dust sources to the 20 percent worst visibility days and on the avai lability of data and (in ki nd) 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 ha ze 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 emissi on and control measure reductions, developing dust ordinances and regulations, enforcemen t issues, and the politics behind adopting dust control measures. Collaboration / co-spons orship will be sought from the California Air Resources Board, which is in the proce ss 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 Attributi on 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 expect ed from this project in late Spring 2005.

Funding is requested for two projects in 2005: Ambient Monitorin g and Re p ortin g Forum29 AMR1 VIEWS Data Base a nd 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 r eceived joint, annual funding by all 5 RPOs, each contributing $50,000, through a WGA cont ract. A Steering Committee composed of RPO representatives, EPA, and Federal La nd Managers oversees the operation of the database and website, and tracks deliverables from the annual VIEWS work plan. The funding mechanism for VIEWS was transfer red 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 RP Os 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 specie s 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 projec t 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 Matr ix Factorization (PMF) – to identify source impacts at Class I areas with an adequate monitoring record.

These analytical results will di rectly support Phase 2 of the A ttribution 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 Initia tives 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 analys es and discussions among the TO C, IOC, the Air Managers Committee, all Forums and Workgroups, and the WRAP Board are planned. The AoH Workgroup plans a “Phase 2” project, anticipat ed to begin in mid-Summer 2005, to analyze improvements in haze between the final/revise d 2002 emissions estimates available early in 2005, and the emissions estimates for the 2018 base and control strategy scenarios’ cases. Attribution of Haze Work Grou p30 AoH1 Attribution of Haze – Phase 2 Contractor Support – The AoH Workgroup requests funding for contractor support to execute the Phase 2 AoH proj ect 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 need ed in the Phase 2 project, but funds are requested to ensure that tec hnical 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 pr oject, or not used by the AoH workgroup. If needed, similar to the Phase 1 AoH Technica l Support project during 2004, the contractor

will:

 Attend AoH Workgroup meetings and disti ll members’ opinions and results of discussions into a schedule and methodology to accomplish the Phase 2 tasks;

 Possibly subcontract with independe nt experts for analytical work;

 Gather and format the resulting inform ation and data from WRAP Forums, independent experts, and ot her related air quality anal yses, all for review by the Workgroup;

 Draft a “Phase 2 Attribut ion of Haze Report” for review and comment by the Workgroup; and

 Complete and publish a “Final Phas e 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 Ma nagement Strategy (WIGIMS) report: ( http://wrapair.org/forums/toc/documents/w igims/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 structur e for data and information management of monitoring data/analyses, emissions informa tion, 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 tec hnical 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 doc ument into a phased approach, resulting in a scope of work for contractor support to build and operate a t echnical 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 flexib le 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 subseque nt data query and analysis for interested parties, so “weight of evidence” demonstrati ons 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 GI S data makes preparing the “weight of evidence” analyses descri bed 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 commen t, 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 am ong 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 Secti on 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 mile stones) and periodic audits of emissions tracking, (b) addressing any remaining or ne w 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 th e 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 ha ze 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 Mana g ers Committee 309 Coordinatin g Committee32 AMC1 Staff Support for the State and Tribal Caucuses – Two coordinators, one for each caucus, are positions under the Air Manager’s Committ ee. The State Caucus Coordinator position is filled through a services contract betw een 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 a nd state air directors with continual tracking and reporting of WRAP activities, issue identification and communication among the WRAP partners, recr uitment of WRAP participants from states and tribes, facil itation 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 Alas ka. A number of activities, in addition to those typically associated w ith 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 se nt 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 s ought with Alaskan Native organi zations 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 he alth benefits of haze controls could be gleaned from on-going WRAP activities, such as those related to air quality modeling, ambient monitoring, and socioeconomic analys is. Distilling health -related information from WRAP activities will provide added va lue to WRAP members and may generate

further interest from individua ls and organizations that ma y 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 ar ea of air quality and h ealth to draft a report which (a) summarizes what the available litera ture implies about the health significance of various PM constituents and PM precursor s 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 (particula rly on tribal lands) which c ould 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 contro ls. 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 ad dition to providing some additional insights – and discuss next steps for the WRAP w ith respect to regional haze and health.33 AMC4 Traditional Tribal Practices and Regional Haze – Tribal traditi onal practices (e.g., ceremonial, cultural, religious) are regularly affected by regional haze or the policies

intended to curb such haze. On the one ha nd, tribes are concerned with protecting their traditional practices from the air pollutants th at obscure visibility. For instance, some tribal members have noted the importance of being able to see near by 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 pr oduced 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 WR AP region and how these practic es 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 eff ective policies on regional haze.

The first document will describe why tribes n eed to be concerned with regional haze and

how their involvement in the WRAP serves to reduce the haze that in terferes with their traditional practices. This document, among other things, will highlight some of the traditional tribal practices that are a ffected 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 understa nd 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 t ools for WRAP participants (and members of other regional planning organi zations) who regularly work wi th and/or live near tribal lands. These documents will be a compila tion of published and unpublished information about tribal practices and cu ltural 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 audience s, such as other tribes and non-tribal audiences. It is anticipated that the documents will be professionally developed into a bound document fo r distribution to WR AP 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 assi st 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 ongoing34 communication with the other forums as n eeded, prompting timely information from states and tribes, and in turn providing feedback to the forums to ensure they are focused on the critical planning ques tions. WESTAR provides dire ct staff assistance under a

services contract with WGA. This staff s upport 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 Ne w Mexico provided contract st aff to complete the 309 work in 2004 and has agreed to provide contract st aff to address the speci fic 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 se veral 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 collaborat ion 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 subjec t to these deadlines. There is strong opinion among some of the tribes that they are included in WRAP wo rk when it is convenient or in name only. Some states have little to no working relationship w ith tribes in their respective states. Tribal emissions and air qua lity data are almost non-existent. A number

of tribes are reluctant to rel ease tribal information because th ey are distrustful of state and federal regulators.

This task would begin to strengthen working relationships between st ates and tribes that is essential in order to fulfill the requiremen ts of the regional haze planning process and the Regional Haze Rule. EPA’s Regional Haze Ru le explicitly addresses state-tribal relationships and directs them to work collabo ratively with each other and in “partnership with other interested stakeholders,” but provide s little guidance in th is regard. The goal of these workshops is to facilitate improvement s in working relationships within WRAP and among individual states, tribes and federal ag encies, by enhancing the understandings of leadership and staffs of these entities a bout how each of them functions within their organizations, their various operati onal protocols and traditions.

In general, the form of this project is a se ries of sub-regional workshops at selected locations within the WRAP region to instru ct 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 st ructures, environmental priorities and their

efforts toward collaboration. The focus woul d include identification of barriers to collaboration and ways to overcome them. Inte rested 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 Oper ations/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 Th e WRAP Sheet to selected recipients; and

• Produce brochures, fact sheets, and other ha ndout materials for c onferences, exhibits, and public meetings.

CC3 Update Presentation Materi als to Tell the WRAP Story :

• Tailor the WRAP 301A, 401 and Tribal vers ion presentations to meet needs of various forums/committees; and

• Convert presentations to va rious video formats (CD, VHS, 35mm, etc.) and make copies for multiple venues.

CC4 Expand Speakers' Bureau – Assure exposure of WRAP stor y to state and tribal general audiences throughout the WRAP region. Tailor to individual audien ces as appropriate:

• Develop and maintain data ba se of prospective audiences;

• Work with state and tribal air director s/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 part nering 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 Committee36 Appendix A: Background

I. Background

The 1990 Amendments to the Clean Air Act esta blished the GCVTC, which in June of 1996 completed its original mission to recommend stra tegies for improving visibility in the Grand Canyon and other Class I areas on the Colorado Plat eau. Recognizing the ne ed 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 opera tes in conjunction with regional organizations such as WESTAR, the Western Governors' Association, and the Na tional Tribal Environmen tal Council. The work products of the WRAP are used by states and tr ibes in the preparati on 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 planni ng 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 th e Tribal Authority Rule (TAR) (40 CFR 49.1– 49.11) and the regional haze rule, tribal implemen tation 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 preambl e 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 th at any tribe in the GCVTC transport region may implemen t §308 or §309 in whole or in part.

The policy and technical work of the WRAP to a ssist 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 need s may be different. As these differences are identified, project tasks and wo rk plans will be updated to re flect the improved understanding of

tribal needs.

To ensure that tribal needs are addressed, the acti ve participation of trib al 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 par ticipation 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 WR AP, 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 provides37 assistance and staff through the Tr ibal Data Development Working Group to address a key tribal need – the acquisition of data necessar y to make informed policy decisions.

Finally, it should be noted that the WRAP organizational struct ure 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 re presentatives on all standing comm ittees, forums, and work groups. Public workshops for WRAP work products and tr avel support from the WRAP ensure that the broader tribal community has an opportunity to participat e 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. Th e WRAP established oversight committees and forums charged with developing work plans to implement the GCVTC recommendations and to facilitate development of impl ementation plans under the RHR.

A. Membership

The WRAP membership currently includes the Gove rnor 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 ba sic operating goals, prin ciples, 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 foru ms, committees, and work groups. These suborganizations and their relationships are show n in the organization chart in the Executive Summary. All the suborganizations include part icipation from the WRAP membership (states, tribes, and federal agencies) and interested stak eholders (industry, envi ronmental groups, local governments, academia, etc.). Guidelines fo r 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 co ordination and development of air quality strategies necessary to promote the implementation of federal visibility rules. The TOC provides general oversight of the technica l activities of the WRAP. IO C and TOC members are appointed by the WRAP Board, which strives to manage a ba lance among tribes, states, federal agencies, the environmental community, and the industr ial community. In turn, the IOC and TOC establish forums and work groups and appoint their co-c hairs 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 Sour ces 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 Fo rum, and Stationary Sources Joint Forum are overseen by both the IOC and the TOC, as they address both techni cal and policy issues.

E. Communications Committee

The Communications Committee addresses co mmunication 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 par ticipation from industry, environm ental groups, and other affected parties. The following categories of representatives are regularly considered for membership in committees, forums, and work groups: · Industry · Small Busi ness (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 re present and communicate with their agencies and constituents. Forum and committee members are responsible for establishing mechanisms39 that will ensure this communication occurs. These mechanisms may involve working through trade groups, state and tribal organizations su ch as the Western States Air Resource Council (WESTAR Council), the Na tional Tribal Environmental Counc il (NTEC), and intra- and interagency forums.

IV. Project Management

A. Setting Priorities

The WRAP members establish the strategic di rection of the organi zation, setting overall priorities for action. Once the WRAP agrees on a direction, issues ar e further developed and priorities refined by the following process:

• The WRAP identifies issues and requests th at 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 identif y the major deliverables, ski lls 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 wo rk groups and work with the co-chairs to develop a written charge, including object ives, expectations, and time frames for

deliverables.

• Co-chairs of forums and work groups appoi nt 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 a nd 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 grou p can not reach consensus, the issue is referred to the oversight committee(s). If the oversight committee(s) ca n reach consensus on the issue,

that decision is referred to the forum or work group for integration with the forum or work40 group’s decisions on other issues. If the oversig ht committee(s) can not reach consensus, the issue may be referred to the WRAP Board for reso lution, or it may be referred back to the forum for further debate. When conflicts over pr iorities and budgets can not be resolved by the individual forum, work group or committee, th e 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, rele vant material will be posted on the WRAP Web

site and comments will be solicited.

Work products must be presented to the appropri ate 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 communi cation and coordination th at occurs directly between WRAP participants, the WRAP will wo rk with the Western States Air Resources Council (WESTAR) and the National Tribal En vironmental 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 participa tion remains representative , balanced, and fair. Contractors hired with EPA gran t funds are relied upon to expand the resources of the WRAP.

Committees and forums direct the work of contractors.

Support services to the line f unctions of the WRAP come from the Communications Committee, the National Tribal Environmental Council (NTEC ) and the Western Governors’ Association (WGA). The Communications Committee has de veloped a Communications Manual for the

WRAP’s internal and external communications and assists committ ees 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 grant41 applications, funds, requests for proposals (RFPs), contracts, travel re imbursements, meetings, conference calls, public and media in quiries, press releases, Web site s, requests to participate in the WRAP, and report publications. Staff a ssistance includes providi ng a “sounding board” for stakeholders having concerns w ith the WRAP processes and re lating 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 respondi ng to media and public inquiries.

Under a separate EPA grant, NTEC assists trib al participation in the WRAP by arranging and facilitating Tribal Caucus m eetings; providing coordination am ong tribal representatives of various committees and forums; performing lega l, 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 respons ibilities, work with stakeholders to ensure the WRAP's processes are fair an equitable, and serve as th e 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 a nd NTEC respectively.

WGA also employs a technical coordinator and policy anal yst to support the oversight committees, forums, and work groups. NTEC em ploys 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 communicati ons with and for the trib es 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 receiv er of WRAP grants, retains the legal responsibility for signing and administering contracts and ensuring that work products are completed. These responsibilities ar e met with input from forums and work groups. Forums and work groups may creat e 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 justificati on. All RFPs are sent to appr opriate contractors known to the WRAP, posted on the WRAP Web site, and publis hed in the Federal Bu siness Opportunities publication as appropriate. Unless time is otherwise a constraint, bidders are provided 30 days to respond.42 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 select ion 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 se lection. The winning cont ractor and all losing bidders are notified in writing of Executive Director’s decision.

Subsequent to contractor se lection, WGA staff and the appr opriate forum, work group, or committee negotiates a final contract with the winning bidder. All c ontracting 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 th e forum, work group, or committee to monitor the work of the

contractor and to determine whet her 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 c ontractor regarding hour s spent and expenses incurred. WGA also requires copies of any deliv erables prior to rendering payment. If there is any question regarding whether the contractor ha s met the requirements in the scope of work, it is negotiated between the contra ctor, WGA, and the appropriate co-chairs. Once it has been agreed that all work has been completed in a ccordance with the requirements of the contract, payment is rendered by WGA.

WGA is responsible for maintaining all record s 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 th e general WRAP grant, and are subject to the requirements of the single audit act and related compliance supplements.43APPENDIX B: Process Overview for 2005 WRAP Projects.Stationary Sources – SS4Dust Emissions – DF3, DF4Emissions – EF1, EF5Fire Emissions – FF5, FF7, FF”C”Tribal Data Development – TW1,TW2Economic Analysis – EA2, EA3Air Monitoring & Reporting –AMR1, AMR2Air Quality Modeling – MF1Stationary Sources – SS5Dust Emissions – DF1, DF2, DF6Emissions – EF2, EF3, EF4Fire Emissions – FF1, FF4, FF6+3,FF8, FF”B”, FF”D”Mobile Sources – MS1, MS2, MS3Air Managers – AMC3, AMC4Tribal Data Development – TW3Economic Analysis – EA4Air Monitoring & Reporting –AMR3Attribution of Haze – AoH1Air Quality Modeling – MF1, MF2Stationary Sources – SS7Dust Emissions – DF5, DF8Fire Emissions – FF9, FF12,FF”E”Air Managers – AMC5, AMC6Economic Analysis – EA6Attribution of Haze – AoH1, AoH2Air Quality Modeling – MF1, MF2Ongoing Collection andReporting of Basic DataAnalyzing and RefiningData and PoliciesWebsite Progress Reports,Workshops, & Conclusions44 APP. C: WRAP Region, Members, and Federal Areas Covered by the Regional Haze Rule45 APPENDIX D: Map of Tribal Lands and Tr ibal Class I Areas in the WRAP Region46 APPENDIX E: WRAP Organizational Chart. 

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