WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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Pollution Prevention Workshop for the Preparation of 

Section 309 SIPs and TIPs 

 

May 20-21, 2003, Portland, OR

Executive Summary 

Background 

The workshop brought together representatives of the energy and air pollution regulatory 

communities in the western states to discuss their approaches to the pollution prevention portion 

of Section 309 of the Regional Haze Rule. The purpose of the workshop was to reach a common 

understanding of what the pollution prevention section of S. 309 requires, discuss how best to 

meet those requirements, and establish a basis for consistency, where appropriate, among 

states/tribes submitting State Implementation Plans (SIPs) under this section of the Regional 

Haze Rule. 

Action Items 

• WRAP will find AP2 Forum language that addresses recognition and beyond–compliance 

programs provisions in Paragraph (ii); 

• Jeff Burks will contact John Nielsen at the Land and Water Fund of the Rockies regarding 

resource atlas documents for each of the states showing renewable energy potential in 

response to Paragraph (iv); 

• Lee Alter from the WRAP will create common language that all the states can use to respond 

to Paragraph (v), (included in the “Key Points” section of this Executive Summary, and also 

in the Workshop Session Notes at the end of the Paragraph (v) discussion); 

• Jeff Burks will develop common language for Paragraph (v) that every state could file with 

the regional modeling results from the ICF study; 

• Scott Manzano will work on developing common language in response to Paragraph (vi) that 

will assist the states in explaining why regional data has been submitted, rather than data 

showing how each state is individually contributing to the regional 10 / 20 goals; 

• WRAP will identify the regional goals established by the ICF Consulting report for 2005 and 

2015 in response to Paragraph (vi); 

• WRAP requested that each of the states provide a draft of their S. 309 submittal before July 

30 to allow them to undertake some consistency analysis on the states’ responses; and 

• The states participating in the workshop requested that WRAP post all relevant background 

documents to the web, including the latest P2 sections of the STIP template, the ICF study 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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summary, presentations and notes from this workshop, and example materials from each of 

the states. 

Key Points 

The group discussed the background and history of the WRAP, the pollution prevention (P2) 

provisions of Section 309 of the Regional Haze rule, and the potential for energy efficiency (EE) 

and renewable energy (RE) to provide solutions to regional haze. 

The workshop featured presentations from ICF Consulting and The Tellus Institute, which had 

performed regional modeling to determine the visibility and economic impacts of states meeting 

the 10/20 goals established by the Grand Canyon Visibility Transport Commission (GCVTC) in 

1996. The participants learned about the latest revisions to the SIP template prepared by 

WESTAR. States provided their interpretations of the best way to address the provisions 

contained in this part of the rule. 

Several overarching themes and guidelines came out of the workshop, which focused on 

developing a baseline of the minimum information necessary for an adequate filing. The group 

noted that, at a minimum, a state’s Section 309 filing could center on energy / electricity. 

However, if a state has information on P2 programs beyond this scope, it can be included for a 

broader P2 filing. 

Key points on the provisions of Section 309 of the regional haze rule, as discussed by workshop 

participants, follow in a paragraph-by-paragraph format. 

Paragraph (i)

• The group discussed that the initial list of P2 programs focus first on EE and RE in states that 

are going the Section 309 (S. 309) route. It is at a state’s discretion to include other kinds of 

P2 programs in this list, but states may also want to consider putting information about nonEERE programs in other appropriate sections in their S. 309 SIP. 

• For purposes of determining what to include in the inventory of all renewable energy 

generation capacity and production in use or planned as of 2002, states discussed using two 

key guidelines:

 Installations that are included in integrated resource plans (IRPs); or

 Installations for which there is money on the table or a permit issued or in process.

• To determine a state’s anticipated contribution toward the 10/20 goals, the states indicated 

that not only could a state include the generation capacity of installations within its 

boundaries, but also that states could interpret that “contribution” could include the amount 

of renewable generation consumption occurring in the state. 

• Listing the programs intended for use as EE as well as all the programs intended for use to 

meet 10 / 20 RE goals coincidentally produces a summary of P2 programs. The group noted 

that off-the-shelf information is preferable to trying to develop new information. In keeping 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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with the discussion of guidelines for renewable energy generation capacity and production, 

Arizona representatives suggested a rule of thumb that considered a project “planned” only if 

money had been expended or a permit issued, in order to reduce the potential for projects in 

their earliest study stages to be included in the SIP, and later abandoned or not developed. 

Paragraph (ii)

• The group noted that “Beyond Compliance” does not necessarily refer to the 10 / 20 goals, 

but could include compliance with other regulations affecting the electricity / energy sector. 

• Two approaches to responding to this paragraph were discussed: 

 Using a cross-reference to Paragraph (i)’s response, using AP2 Forum language that 

WRAP offered to identify. 

 Focusing on programs such as Supplemental Environmental Programs, where available, 

laws that trade regulatory certainty for early compliance, and recognition and awards 

programs, both state-sponsored (such as New Mexico’s Green Zia program) and national 

(such as Energy Star). 

Paragraph (iii)

• States may wish to use standard language for this section. The “best practices” list from AP2 

Forum is a good list of areas to investigate / include in a standard response to this section, 

using the WESTAR STIP template as a basis. A state could supplement this response by 

including additional information and data in the appendices. 

Paragraph (iv)

• States may wish to respond to this paragraph in large part by using maps and supporting 

documentation. Utah, for example, is using maps from the Renewable Potential Atlas 

developed by the Land and Water Fund of the Rockies (LFWR). Jeff Burks will contact 

LWFR for a packet for each of the 5 states participating in the workshop. 

• Generally speaking, states indicated that this paragraph reflects one idea – areas that are 

BOTH off-grid AND cost effective for RE. A general rule of thumb that some of the states 

participating in the workshop use is as follows: If you go farther than 1⁄4 mile from 

transmission system, RE becomes a cost effective alternative to transmission line 

improvements. A reference to this “1⁄4 mile rule of thumb” in the SIP filing may be sufficient 

to apply in addressing this paragraph. 

Paragraph (v)

• The years 2005, 2010, 2015, 2018 are the years used in the in ICF Consulting models, and 

the sense among participants was that these could be good dates to use as guidelines for 

determining “short-term” and “long-term” goals. The states noted that a common 

presentation of the ICF model regional results might be appropriate in responding to this 

paragraph, and pointed out that non-participant states such as CA and NV are doing their part 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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to meet the 10/20 goals through their RPS and other mechanisms. In moving forward, Utah 

representatives said that they would work with the WRAP to draft some common language 

for all the S.309 states to file, potentially liberally excerpting from the ICF modeling study. 

• The initial draft of common language provided by the WRAP at the workshop is as follows: 

"Projections of visibility improvements for the 16 Class I areas on the Colorado Plateau are 

provided in Table 1 [of the SIP template]. These projections include the combined effects of 

all measures in this SIP, including air pollution prevention programs. Although emission 

reductions and visibility improvements from air pollution prevention programs are expected 

at some level, they were not explicitly calculated because the resolution of the regional air 

quality modeling system is not currently sufficient to show any significant visibility changes 

resulting from the marginal nitrogen oxide emission reductions described above for air 

pollution prevention programs." 

Paragraph (vi)

• States noted that providing information based on the regional data from the ICF modeling 

could be an appropriate response to this paragraph. A response to this paragraph could make 

reference to the programs outlined in Paragraph (i)’s response, the LWFR maps, and make 

the case that if all 9 states were to participate in S.309 filings, the state’s contribution to the 

total 10 / 20 goals would be X; however, since 9 states will not participate, the state will 

update the information about its contribution as part of the next SIP update. 

• Each filing may need to include language to address why this is not parsed out on a state-bystate basis. Oregon offered to develop a draft of such language. 

• Currently, there is no coordinated effort working on adding up 309 states’ contribution and 

the estimated contributions from non-309 states to determine whether the 10/20 goals are 

being met regionally. States suggested that this might be a function for the WRAP. 

Next Steps 

WRAP requested that states share drafts of their S. 309 filings in order for some consistency 

review to occur prior to the final submission deadline. This was suggested as a way to facilitate 

a smooth review process with EPA. States participating in the workshop indicated they would 

provide their draft S. 309 filings to the WRAP before July 30, 2003. 

More complete discussion notes from the workshop, action items, and information on approaches 

states may want to consider regarding S. 309 are included in the attached meeting notes. In 

addition, there is a possibility that the WRAP may convene one or more conference calls to 

facilitate an ongoing dialogue to follow up on issues and discussions from this workshop. 

Attachments

Workshop Agenda 

Workshop Session Notes 

Workshop Attendee List 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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Attachment 1: Agenda

Pollution Prevention Workshop for the Preparation of Section 309 SIPs and TIPs 

May 20-21, 2003; Portland, OR 

Tuesday, May 20

1:00 Workshop Overview and Introductions 

1:15 Summary of WRAP Products, and Workshop Material 

History of AP2 work (Jeff Burks) – 15 minutes 

Development of renewable energy options (Jeff Burks) – 10 minutes 

Development of energy efficiency options (David Von Hippel) – 15 minutes 

ICF report (Bishal Thapa) – 30 minutes 

SIP template (Brian Finneran) – 10 minutes 

Summary of Utah process/approach (Van Jamison) – 10 minutes 

2:45 Break 

The workshop is organized according to the paragraphs in Section 309 pertaining to air 

pollution prevention. Through a series of facilitated roundtable discussions on each 

paragraph, participants will address the following questions: 

What does the paragraph mean and what is required? 

What have states done so far? 

How can states and tribes use WRAP products and other information sources? 

What additional assistance might states/tribes need to complete SIPs/TIPs? 

How important is inter-state/tribe consistency, and how do we best achieve it? 

What issues deserve follow-up with EPA and/or others? 

3:15 Summary of 309(d)(8) Requirements (Bruce Polkowsky) 

3:30 Section 309(d)(8)(i) 

5:00 Adjourn 

Wednesday, May 21

8:00 Section 309(d)(8)(ii) 

8:30 Section 309(d)(8)(iii) 

9:00 Section 309(d)(8)(iv) 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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10:00 Break 

10:30 Section 309(d)(8)(v) 

12:00 Lunch provided 

12:30 Section 309(d)(8)(vi) 

2:00 Next steps 

2:30 Adjourn 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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Attachment 2: Workshop Session Notes 

Agenda Topic 1. History of AP2 Work 

Pollution prevention can refer to several waste streams. In this context, the AP2 Forum has 

interpreted it to focus on measures that affect air quality and specifically to regional haze. 

The language arises out of work of Grand Canyon Visibility Transport Commission. 

GCVTC concluded that EERE strategies provide real benefits toward achieving visibility 

improvements, and developed the 10 / 20 goals: 10% RE in regional portfolio by 2005, 20% 

by 2015. 

(See Jeff Burks’ slides for more detail) 

Agenda Topic 2. Development of Renewable Energy Options 

(see J. Burks’ slides for more detail) 

Agenda Topic 3. Development of Energy Efficiency Options 

(see J. Burks’ slides for more detail) 

Agenda Topic 4. ICF Report 

David von Hippel 

David Von Hippel made a presentation on the study performed by ICF and Tellus that 

examined the economic impacts of 10 / 20 goals for two regions: West Interior and Oregon / 

W. Idaho. The model predicted the incremental effects of measures that would need to be 

taken to meet the WRAP’s 10 / 20 renewable energy goals with, and without, investments in 

energy efficiency. 

The evaluation method used took four steps: 

• Grouped measures by type 

• Estimated market 

• Estimated penetration 

• Estimated administration costs 

Programs assessed included cooling, residential systems, lighting, eating, appliance 

efficiency, green buildings, refrigeration, fuel switching, miscellaneous device efficiency, 

“retro-commissioning” follow-up, transformer efficiency, motors, CHP, etc., for residential, 

commercial, industrial sectors. 

CHP was removed for the resulting modeling because of anomalies in the model. 

Modeling results: Regarding annual energy savings, large contributions were made from 

commercial lighting and cooling efficiency. Summer peak, cost, etc, were modeled. Savings 

were calculated and used to develop “measure cost curves”. Costs were estimated based on 

electricity sales. 
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The outputs of the initial ICF modeling run included regional annual energy and peak 

savings; net costs; net annual costs; and cost effectiveness. The results of this modeling 

were input into REMI modeling software to determine the economic impact. This modeling 

considered investments made before 2018 (the horizon for Regional Haze SIP planning) for 

improvements going until 2023. 

(See presentation slides for more detail) 

Bishal Thapa, ICF Consulting 

This presentation focused on a study that Bishal Thapa had performed that compared a 

“business as usual” case with what would occur if states met 10 / 20 goals. His study does 

not look at how incentives lead to targets, but looks at what economic impacts result from 

trying to meet a set of targets. 

ICF based the study’s assumptions on another previous market trading forum report that had 

assumptions that could, in large part, be used again for this purpose. The AP2 Forum 

reviewed these assumptions, discarding or modifying those that were not applicable. The 

remaining assumptions were plugged into the integrated planning model. The IPM model 

figures out how electricity markets adapt to exogenously produced goals. IPM looks 

regionally, and this complicates derivation of state-level results. The steps taken in this 

modeling were: 

• Modelers derived the state- / tribal-level cost impacts 

• Plugged the results of this analysis into regional economic impact model (REMI) analysis 

• REMI produced the regional economic model 

The first scenario modeled was for “business as usual”: 

• Provided a basis for comparison with alternate futures to determine level of impacts; 

• Includes the SO2 trading program; 

• No additional efforts to promote EERE were included in the assumptions; 

• No improvements in the cost of renewable energy technologies; and 

• For wind, specifically, there is no significant new penetration, even though there is slight 

increase in the amount of wind being deployed. 

ICF then modeled scenarios based on regional RE targets, with and without EE strategies. 

The adoption of a regional target in the model means that no state-level specific targets were 

developed. To be included in the modeling, a system must be within the transmission 

system, within GCVTC region, and fit cost-effectiveness criteria. 

The modelers took RE targets and reduced demand for model purposes: anything under 5.1 

c/kW was deemed cost effective. Grid load served by RE is assumed to grow to 8% by 2018. 

Cost modeling included assumptions for avoided T&D improvements, new generation. 

Electricity System Impacts

The model results for RE only show that meeting the 10 / 20 goals will increase production 

costs from $17.4B under BAU to 17.7B for compliance purposes (about 2% of the total). 

With RE improvements added to the model, the costs increase $900 M by 2018. 
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Based on generation dispatch, the displacement of fossil fuels by RE by 2018 will take form 

as follows: 

• Existing coal persists; expansion of coal is affected somewhat; 

• Fuel most displaced is new and existing oil and gas; 

• Hypothetical scenario excludes EE and some potential unknown effects; 

• Potential gremlins include Clear Skies, mercury provisions, and future carbon 

regulations. 

The model indicates that new RE that is developed will be predominantly wind; smaller 

levels of geothermal, small amount of landfill gas. Solar and biomass / gasification projects 

were not heavily featured. 

Annual savings with EE were also modeled to determine the annual savings with EE / RE 

with 10 / 20 goals. EE saves $1 billion even after taking implementation cost into account. 

Satisfying 10/20 goals increases the costs, but overall the savings are approximately $700 

million annually. 

Emissions Reductions

With regard to emissions reductions, there is a 1-2% reduction in NOx in the scenario 

including EE strategies. This occurs in the model because although the model assumptions 

include cleanest new additions, there is no guarantee that SCR will be on all systems, nor that 

gas will predominate future siting. The model assumes a 65-year lifetime for existing coal 

facilities – few leave the system in the lifetime of the model. Therefore modeling reflects 

that the RE strategies provide a “hedge” against high-emissions capacity additions. 

When EE is added to meeting the 10/20 goal assumptions in the model, the total electricity 

generated is less than it would have been without EE. Because the total electricity generated 

is lower, the 10% and 20% RE contribution goals are lower as well: 10% and 20% of total 

grid electricity is less in absolute terms because total grid electricity generation is reduced by 

the implementation of EE. 

The model also shows that meeting the 10/20 goals with EE will result in 10% – 15% 

reductions in CO2. The Regional Haze Rule asks for “secondary environmental benefits”, 

and this is a good example of a secondary environmental benefit that can be included in a 

state’s filing. 

The model shows that SO2 emissions will be unaffected because of a hard cap that is 

assumed on SO2 as part of the emissions trading program. Bringing in EE / RE lowers grid 

demand, but reducing demand under the cap will allow another producer to emit more, as 

long as the total emissions remain within the cap limits. Therefore, meeting the 10 / 20 goals 

reduces the price of allowances since fossil generation does not need as many allowances to 

meet the cap, which reduces demand for emissions allowances and consequently reduces the 

allowance price. Combining EE with the 10 / 20 level RE also reduces the need for 
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investments in scrubbers by 1200 to 1700 MW (this is confusing). If a wind supplier retires 

their SO2 credits, then the cap is effectively lowered, and the cost of the remaining 

allowances will increase. If wind and other RE generators sell their allowances to recoup 

differential costs, the level of the cap remains the same, and prices for allowances decrease. 

Economic Impacts

The modeling results for meeting the 10/20 goals show that the economic impacts are small; 

less than 1⁄2 percent regionally. Two states have negative employment impacts, but regionally, 

employment improves. The increased cost of electricity impacts the economy by reducing 

disposable income (since more will need to go to electricity), but regionally, disposable 

income increases. Gross regional product is affected negatively because cost of one raw 

material – electricity – increases, raising costs for manufacturers. In a local context, changes 

can be large-scale; but regionally changes are small but positive. Overall costs to electric 

power sector are 1 – 5 percent. 

Agenda Topic 5. SIP Template 

Brian Finneran – OR DEQ 

Brian Finneran provided information on a draft template that outlines a potential S.309 filing. 

The idea for a template to provide some guidance for states came from WRAP Air Managers 

Committee. The goal of producing this document is to help States and tribes write their first 

309 SIP filing. Rosanne Sanchez, NM, is developing a SIP template for Tribes. 

All the chapters in the template follow the same format: 

• Section 1: verbatim regulatory language 

• Section 2: Discussion of requirements 

• Section 3: suggested SIP language 

• Section 4: summary of available policy and technical documentation. 

Imminent compliance deadlines are driving the speedy development of a final template. The 

template will be finalized soon and posted online at http://www.wrapair.org

The Technical Support Document (TSD) included with the SIP template summarizes all the 

technical documents put together to date for SIPs. For states moving forward, the Draft 309 

STIP template is one alternative, and it might be useful to compare with Utah’s template. 

Questions that the group felt warranted consideration when discussing the SIP Template 

included: 

• What are the basic requirements for the filing? 

• What similarity/consensus is needed among different state SIP submissions? 

• What is EPA going to be looking for? 

The group generally concurred that the advantage of a consensus document is that greater 

uniformity increases the chances that EPA will approve the filings. It does no good for EPA 

to approve states’ SIPs piecemeal because of the trading program, and EPA is aware of this. 
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If all of the five states considering filing S. 309 filings (UT, OR, AZ, NM, and WY) proceed 

in this direction, four different EPA regions will be involved in reviewing and approving 

these filings. 

Agenda Topic 6. Summary of Utah Process/Approach 

Van Jamison 

States that decide to file Section 309 will likely face similar “hoops,” so Van Jamison 

provided information concerning how Utah has interpreted each section as a basis for 

discussion. 

Utah tried to sort paragraphs of S. 309 (d) (8) into basic components to determine what 

information they were supposed to supply. Utah began by developing of a matrix of required 

elements, used this to develop a workplan. They then developed / gathered / synthesized 

information to satisfy requirements. One of the main lessons learned is that there is no onestop shop for perfect information – but the rule requires reasonable information with a 

rational basis for using it, not perfect information. 

For example, to determine renewable capacity in Utah, Van Jamison started with information 

available from the DOE’s EIA. This program has info for 10MW+; Utah has information 

from net metering, installed credit; etc. Information on renewables that were too small to be 

significant against the total Utah generating capacity was not included. Utah did run a survey 

to find information from some smaller systems that, when aggregated, offered capacity of 

enough significance to be included. This information was carefully parsed through to avoid 

double-counting in the filing. 

For EERE program descriptions, the Utah Energy Office began by developing list of 

potential information sources. Information gathering was followed by development of 

program descriptions in a template. This template is a standard reporting format for EERE 

programs that considers “programs” broadly speaking, and considers the “components” of 

these programs individually where necessary. 

(Note: “Program” means different things to someone with an Energy perspective than to 

someone with an Air Quality perspective; the latter might look for enforceability. This is 

reflected in Van Jamison’s approach to filling in Utah’s Component and Program templates, 

although not all programs included are enforceable.) 

The Utah Energy Office has been filling in the data-gathering templates and has created an 

outline of all the chapters that are outlined in S.309. Each chapter is being fleshed out by the 

data from the data-gathering templates. These chapters, including data modeled after the 

WESTAR template, form the basis for the current version of Utah’s draft filing. The next 

steps for developing Utah’s SIP filing include review and input by stakeholders. 

Discussion

The question was raised about balancing perfect information with using “rational basis” for 

actions - how does that interpretation sit with EPA? Van Jamison’s response was that S. 309, 
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once implemented, includes a process for periodic updates, so future filings do not need to 

reinvent the wheel. The idea is documentation with reasonable support. 

Another topic for discussion at the meeting focused on whether the inventory of pollution 

prevention (P2) in Paragraph (i) refers to a wide spectrum of P2 activity, or is intended to 

focus on energy / electricity. The group decided that the focus is on energy / electricity, but 

if there is information that can be surveyed outside this area, it is includable. The rule 

language calls for “an initial summary”. The goal is a SIP that is readable, so filers could put 

highly technical support information into appendices. Utah’s current draft includes some of 

this – future drafts will move some technical information to appendices. Support 

documentation (such as the PacifiCorp IRP) will be included in the SIP TSD. 

(A suggestion from the group was to follow the example of the AP2 Forum, which passed 

transportation information to the Mobile Sources Forum, rather than dealing with it in the 

context of the Pollution Prevention Forum. Similarly, mobile source reductions could be 

addressed in the mobile sources section of the SIP instead of the P2 section.) 

The group noted that one potential outcome of this workshop is agreement among the states 

to develop a common format that meets all of their needs. 

Agenda Topic 7. S. 309 (d) (8) overview 

Bruce Polkowsky, NPS 

Bruce Polkowsky began his remarks by noting that he had played a role in putting together 

the rule language, and that although it had been some time since he was with the relevant 

EPA office, he would try to detail some of the origins and original intent of the language in 

the rule. 

He noted that this section is new to EPA as well as to states, so states have an opportunity to 

help define what satisfies the rule’s requirements. Furthermore, EPA’s attention may focus 

on the command-and-control market piece, and not deal with the P2 section as thoroughly. 

Paragraph (i) focuses on documenting programs that are in your state. 

Paragraph (ii) deals with incentives for actions that take a state beyond compliance. The 

difficulty arises for states that do not have existing programs that go beyond compliance: do 

you need to have such programs to satisfy the rule requirements? 

Paragraph (iii) asks for programs that “preserve and expand energy conservation”. There has 

been an emphasis on market-driven initiatives since deregulation and restructuring occurred 

in many states. The concern at the time the rule was written was that rate-based sponsors of 

demand side management (DSM) would be taken out of the picture under restructured 

market-based electricity systems. This section focuses on how states can preserve DSM 

programs in the face of deregulation. 
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Paragraph (iv) was focused on tribes, to encourage states to look for areas where capacity 

additions could be served by renewables. More generally, Paragraph (iv) looks for ways to 

develop RE in off-grid areas. 

Paragraph (v) allows states to turn to work done by groups like WRAP to provide 

information for SIP at the state level. A question raised during discussion was whether or not 

this could be sufficient. States may or may not have to justify their own portion of the 

model results with regards to their contributions to the regional goals. EPA may accept 

regional-based TSD information for Paragraphs (v) and (vi). 

Upon completion of the introductory presentations and remarks, workshop participants 

engaged in a paragraph-by-paragraph discussion of the meaning and requirements of the 

Section 309 rule language. 

Agenda Topic 8. Paragraph-By-Paragraph Review 

Paragraph (i): An initial summary of all pollution prevention programs currently in place, 

an inventory of all renewable energy generation capacity and production in use, or 

planned as of the year 2002 (expressed in megawatts and megawatt-hours), the total 

energy generation capacity and production for the State, the percent of the total that is 

renewable energy, and the State’s anticipated contribution toward the renewable energy 

goals for 2005 and 2015, as provided in §51.309(d)(8)(vi). 

Discussion Notes

The group discussed whether it made sense to first examine “an initial summary of all 

pollution prevention programs currently in place”, and get any interpretations from states. 

The group noted that the rule’s authors intended for there to be a difference between EE, RE 

and P2 programs. Consequently it may be aimed at more traditional energy sources, as well 

as a broader range of activities that result in pollution prevention (example: solvent 

substitution) 

One comment was that the authors wanted as broad a set of included programs as possible. 

Therefore it might be worthwhile to prioritize programs based on effectiveness at reducing 

regional haze. One direction would be to approach EPA with prioritized list. 

The group was informed that Arizona focused on EE and RE programs, and not on broader 

P2 programs. Representatives from Utah said that a potential approach would be to prioritize 

those that have greatest impact on Class 1 areas. The group noted that if you claim credit for 

mobile and area source P2 in the mobile and area source sections, rather than here, it is 

reasonable to think EPA will allow you to focus on energy in section 309 d 8. 

The group discussed whether listing the programs intended for use as EE, and all the 

programs intended for use to meet 10 / 20 goals, coincidentally produces a summary of P2 

programs. The group observed that this could create a common minimum to satisfy the filing, 
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although some states could do more if they chose to. States considering going beyond energy 

/ electric generation P2 could do so, but the focus for this workshop was on developing the 

baseline for an adequate filing, the “Volkswagen” model for a SIP filing, not the “Cadillac.” 

Next item: “inventory of RE generation capacity and production numbers in use, or 

planned as of the year 2002 (expressed in megawatts and megawatt-hours)” 

In the definition of RE, the AP2 Forum recommends including only hydroelectric power 

(hydro) meeting Hydro Institute’s renewable certification requirements. Utah has no 

certified facilities, so for now, is not counting hydro in SIP as renewable; leaving open the 

possibility of future-certified facilities in future SIP filings. Small capacity systems were 

surveyed at a “reasonable” level by contacting vendors, looking at PSC records for netmetering tariff. Basic intent was to provide basis for claim that policies exist to encourage 

RE. Oregon representatives noted that this state’s Public Service Commission tracks 

renewables for solar, wind, etc. at a low nameplate capacity level. 

The group observed that off-the-shelf information is preferable to trying to develop new 

information. Record-keeping may vary by state. It may require polling more than one office 

– energy office, PSC, etc. Some states may choose to provide web-based information as 

well. 

Utah representatives noted that if the region were to consider hydro as renewable, then the 10 

/ 20 goals have already been met. The question is whether the rule’s intent was to encourage 

the AP2 Forum definition of “renewable” – excluding hydropower with substantive impacts 

to river ecosystems - or not. Utah representatives noted that they will provide two types of 

data, one which will report two data types, separating the capacity of the state’s “non-hydro 

renewable” resources from the amount of “renewable with hydro” in its tables. 

The group discussed what the potential definitions for “planned” were, based on the 

intentions of the rule writers. Arizona representatives suggested a rule of thumb that 

considered a project “planned” only if money had been expended or a permit issued, in order 

to reduce the potential for projects in their earliest study stages to be included in the SIP, and 

later abandoned or not developed. 

Utah representatives noted that they planned to identify anything that has gone through a 

regulated planning process that identifies RE, such as PacifiCorp’s IRP. (In PacifiCorp’s 

case, RE and EE are a risk management tool, and they include EE and RE programs in their 

planning filings to the state). 

The group discussed how this affects states that do not require IRP filings. (Oregon, Utah, 

Wyoming, New Mexico, Idaho require these). Arizona’s standard - money on the table or 

permit in hand – may serve as a good criterion when looking at situations with merchant 

plants or other situations were development is outside the PUC’s jurisdiction. Rural co-ops 

and others who purchase from WAPA and BPA need to file IRPs, so this might be another 

source of “planning” information. 
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Annual Energy Outlook from EIA might be another source of “planned” RE capacity 

expansion. Tom Petersic (sp?) at EIA puts this information together. The group could think 

about the difference in the definition between “proposed” and “planned” 

The California Energy Commission’s (CEC) energy generation tracking website may have 

good regional information. Their website URL is: 

http://www.energy.ca.gov/electricity/wscc_proposed_generation.html 

Utah is looking at installed capacity. They noted that progress could be measured by 

determining: 

Total amount of RE consumed in your state / Total consumption within your state. 

Utah representatives explained that their rationale is that if you contribute to RE consumption 

in another state (by paying for it), you should get credit for it. States must demonstrate their 

contribution of the regional goal, not simply meeting an in-state goal. It is important to avoid 

double-counting, and it is possible that EPA will look at generation state-by state to 

determine regional progress towards achieving the regional goal. However, for purposes of 

states trying to demonstrate their contribution to the regional goals, they should report 

consumption. Although tracking electrons is difficult, tracking investments is easier. 

Two metrics are required: 

 Inventory of all RE generation in-state (for reporting all planned / installed RE) 

 Tracking of RE consumption in state (for reporting contribution to 10 / 20 goal) 

The minimum for addressing paragraph (i) would be to include EE / RE in this section; look 

at including mobile P2 in the mobile section, and the area-source P2 in area-source section. 

A question for EPA: should P2 consideration be limited to electricity / energy? One 

suggestion was to check with John Nielsen before proceeding. The group observed that it 

might make more sense to proceed, focusing on the most credible information, and focusing 

on “the big rocks” – programs and components that have significant impacts and directing 

research and energy in that direction. 

Summary of Discussion on Paragraph (i): 

The group discussed that the initial list of P2 programs focus first on EE and RE in states that 

are going the S. 309 route. It is at the state’s discretion to include other kinds of P2 programs 

in this list, but states may also want to consider putting information about non-EERE 

programs in other appropriate sections in their S. 309 SIP. 

For purposes of determining what to include in the inventory of all renewable energy 

generation capacity and production in use or planned as of 2002, states discussed using two 

key guidelines: 

o Installations that are included in integrated resource plans (IRPs); or
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o Installations for which there is money on the table or a permit issued or in 

process.

To determine a state’s anticipated contribution toward the 10/20 goals, the states indicated 

that not only could a state include the generation capacity of installations within its 

boundaries, but also that for purposes of addressing this paragraph, states could interpret that 

“contribution” could include the amount of renewable generation consumption occurring in 

the state. 

Listing the programs intended for use as EE as well as all the programs intended for use to 

meet 10 / 20 RE goals coincidentally produces a summary of P2 programs. The group noted 

that off-the-shelf information is preferable to trying to develop new information. Arizona 

representatives suggested a rule of thumb that considered a project “planned” only if money 

had been expended or a permit issued, in order to reduce the potential for projects in their 

earliest study stages to be included in the SIP, and later abandoned or not developed. 

Paragraph (ii): Programs to provide incentives that reward efforts that go beyond 

compliance and/or achieve early compliance with air-pollution related requirements. 

Discussion Notes

Utah representatives noted that one potential program to satisfy this section were 

Supplemental Environmental Programs (SEPs). In Utah, an emphasis on green power 

purchases in SEPs is complicated by general fund issues. The group discussed how the 

decision to include this type of program was affected by the fact that this is a compliance 

penalty-related program). 

AZ has a trading program that provides additional rewards for renewable energy generation. 

The resulting reward is an allowance in an SO2 program. 

The group noted that “Beyond Compliance” is not necessarily referring to the 10 / 20 goals, 

but could also include compliance with other regulations affecting the electricity / energy 

sector. 

The group discussed whether there is a place in this section for financial mechanisms such as 

SBC, possibly through a cross-reference to another paragraph’s section (such as Paragraph 

(i). The ICF modeling showed that a credible RPS resulted in early implementation of RE – 

sometimes it makes economic sense to have your RE come on line prior to compliance date. 

One potential solution to responding to the section that was suggested would be to simply 

ignore it, possibly by responding with language such as “See Paragraph (vi)”. One opinion 

was that states should commit to making programs credible, by referring to regional 

modeling showing that there is potential to have RE come online early, and by demonstrating 

that the state is serious about achieving objectives discussed under Paragraph (i). 

Another approach suggested was to list voluntary / beyond compliance programs where they 

exist, such as an AZ program that rewards RE in emissions trading. Unexpected funds or 
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efforts towards EE / RE could potentially result in contributions to 10 / 20 goals, and where 

data for these programs exist, they could be included. For example, language could be 

included such as: “the state will look at using SEPs as a mechanism that could potentially 

help achieve the goals earlier”. 

Of all the provisions in the rule, this might be the one that is least directly linked to RE. One 

solution would be to discuss the authority to take actions such as SEPs, without discussing it 

in too much detail. Another example is a Colorado law that provides regulatory certainty in 

exchange for voluntary beyond-compliance actions. 

Where Paragraph (i) was focused on EERE, this section might be interpreted as any P2 effort 

that goes beyond compliance and results in air-pollution-related improvements. NM has a 

voluntary program (“Green Zia”) that recognizes pollution prevention activities with an 

award – the sole reward here is recognition. CO has a similar program. This might fit the 

requirements for this section. There is language in the AP2 Forum’s RE recommendations 

policy that is consistent with this approach, and this language might be useful for states to 

reference. 

The group discussed whether states need programs if they do no have them already. If you 

are signing up for 309, you already have the market trading provision. States may also have 

the SEP authority (but the filing should point to language that provides this authority), and 

recognition programs (including national programs such as Energy Star etc. that are being 

implemented in your state) can be included. 

Summary of Discussion on Paragraph (ii): 

The group noted that “Beyond Compliance” does not necessarily refer to the 10 / 20 goals, 

but could also include compliance with other regulations affecting the electricity / energy 

sector. 

Two approaches to responding to this paragraph were discussed: 

1. Using a cross-reference to Paragraph (1)’s response; and 

2. Focusing on programs such as Supplemental Environmental Programs, where 

available, laws that trade regulatory certainty for early compliance, and recognition 

and awards programs, both state-sponsored (such as New Mexico’s Green Zia 

program) and national (such as Energy Star). 

ACTION ITEM: There is language in the AP2 Forum’s RE recommendations policy that is 

consistent with this approach, and this language might be useful for states to reference. 

Paragraph (iii): Programs to preserve and expand energy conservation efforts.

Discussion Notes

Oregon has had utility and state programs since the 1970s to meet this requirement. For 

states without formal programs, there is the menu of options from the AP2 Forum 

(residential, commercial, industrial) programs. 
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PacifiCorp and other utilities have PSC-mandated efforts, in some areas there are countylevel building codes; many states have state buildings programs. 

 Preserve = ongoing programs that are already in place 

 Expand = programs such as PacifiCorp IRP that are planned or proposed (and 

documented) 

Utah’s representatives noted that the “best practices” list from AP2 Forum is a good list of 

areas to investigate / include in this section. 

While the formatting of the Utah filing does not distinguish between “preserve” and 

“expand”, they did use this as a guideline for excluding programs that will not be ongoing. Is 

it important that states characterize the programs as existing / ongoing, and planned? How 

much consistency is needed between states? (For Utah, existing program benefits were 

documentable using available information, and they are moving towards improving 

information for future compliance). 

The rule language comes from 1996, during the height of interest in electric industry 

restructuring, and it was included as a way to keep incentives for demand management in the 

wake of the expected deregulated environment. Restructuring has not gone forward to the 

degree that was expected – MT and CA are moving reconsidering their moves toward 

deregulation, and most western states continue to require resource planning. 

Oregon’s representatives commented that their state’s programs can deal with both energy 

and electricity. Does this play a role in the filing? If so, where? Does this section focus on 

electricity generation alone? Utah commented that in their state’s case, they had passed the 

mobile P2 information to the mobile section. Utah also does not include fossil fuel 

conservation programs in its current draft filing. This has an effect on weatherization and 

other building programs. AP2 Forum’s recommendation is to focus on electricity generation, 

and not on direct energy use. 

One comment was to keep in mind the effectiveness of programs relative to visibility 

improvements for Class 1 areas – use this to prioritize programs included. Utilities 

incorporate energy and electricity – if the program information exists, there is no harm in its 

inclusion. 

One area that the group felt was logical was that since states have several programs that they 

are all involved in, they can try to use standard language for these sections. The group could 

develop language that all states filing / considering filing under S. 309 can use. 

The group reviewed the PacifiCorp IRP vs. Arizona P2 programs as a model - AZ’s program 

is simpler. Participants noted that the rule language is looking for a list. Scott: a link to a 

website is a good way to refer to a program without filling up the document. The group 

noted that a list is an appropriate approach, supported with appendices. 
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An option is for states to list the programs they will need to create the projections in 

Paragraph (v). One participant noted that taking the right approach will be important since 

the SIP documents are enforceable, but readability is an issue as well, especially in light of 

the fact that S.309 filings are based on contributions to the 10 / 20 goals, among other things. 

The 10 / 20 goals are not enforceable, for example, so listing the programs could be 

satisfactory. The supporting data needs to be included, but to help with readability, possibly 

in appendices. 

The participants concurred that one approach would be to include a standard-format program 

description in the body of the filing, with additional details and data put into appendices 

whose contents would be at the discretion of the state. The group concurred that the STIP 

template could be a basis for a standard format. 

Summary of Discussion on Paragraph (iii): 

States may wish to use standard language for this section. The “best practices” list from AP2 

Forum is a good list of areas to investigate / include in a standard response to this section, 

which could be based on the WESTAR STIP template. This response could be supplemented 

with data included in the appendices. 

Paragraph (iv): The identification of specific areas where renewable energy has the 

potential to supply power where it is now lacking and where renewable energy is most costeffective. 

Discussion Notes

During the previous day’s discussion of Paragraph (i), it was suggested that this paragraph’s 

language was included to encourage off-grid RE development. Utah representatives 

explained that they had interpreted this paragraph’s language to mean a map. NREL has 

done work on resource availability, and this is language intended to merge resource 

availability with grid maps. Some states, such as Oregon, reported that their off-grid areas 

are unpopulated and consequently have no electric demand. States also do not necessarily 

have the resources to catalogue state renewable potential. The Land and Water Fund of the 

Rockies (LWFR) has a renewable potential atlas that Utah has used in its filings. Programs 

to electrify areas under the jurisdiction of the National Park Service (NPS) and other park 

sites with RE are good opportunities that might be listed, as well as tribal areas, because they 

have not yet been electrified to the same extent as other areas. To the extent that you have 

programs to support those types of projects, this is the place to list them. 

There was discussion among the group about whether tribal lands are will be included in 

SIPs. States and tribes need to communicate to avoid double-counting. One option for 

dealing with RE projects on Tribal lands is to take a “hands off” approach unless it is statefunded, along with a recognition that it is occurring on tribal lands. 

States are likely to use LWFR maps in common: contact is John Nielson (303) 444 1188 ext. 

232. Jeff Burks will contact John for a packet for each of the five states. 
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The maps provided by LWFR should not be expected to provide high-resolution data; Utah 

has supported the maps with statements that provide, generally speaking, information on cost 

effectiveness of resource, broad description of activities underway to identify areas of cost 

effectiveness. 

In terms of including this information, participants discussed whether they might be a way to 

account for potential improvements in technology / cost in the future. They were also 

interested in whether there might be a standard number available to express a point of costeffectiveness, and whether each state has information for potential utility customers to 

determine cost effectiveness. 

One direction forward for responding to this paragraph would be to express the resource 

availability, then make a statement about cost effectiveness (based on state or other 

guidelines or information such as NPS), broadly speaking, in the areas that these maps 

identify as having resource potential that are off-grid. NPS has guidelines for incorporating 

environmental externalities in cost-effectiveness in evaluation of projects. “Cost 

effectiveness” means lowest cost way to reach goals – goals are broader than just “getting 

electricity”, can also include meeting air quality goals. 

Note – does the cost-effectiveness question refer only to areas that lack grid connectivity? 

The group discussed whether “remote” areas are the ones to be addressed in this section. 

Consistency in state interpretation of this section will be important. Generally speaking, this 

paragraph should be read as one idea – areas that are BOTH off-grid AND cost effective for 

RE. Rule of thumb: If you go farther than 1⁄4 mile from transmission system, RE 

becomes cost effective. Maps exist for 50 kV system overlaid with the resource potential 

maps for some states, but not all, and even this does not provide a high-resolution view of 

areas without grid interconnection. 

In the “Volkswagen” version of a state filing, a reference to the “1⁄4 mile rule of thumb” in the 

SIP might be enough. Potential language might read: “Areas located more than 1⁄4 mile from 

transmission might consider RE as a cost-effective approach” 

(Note – another model is being developed by Walter Short at NREL that determines RE 

resource cost effectiveness, this might be the direction to explore for a “Cadillac” version) 

The group discussed the validity of web-based material in the filings. The participants noted 

that since URLs change, filings can use the URL, but also provide a contact, and make a 

paper copy available for state files in the air quality offices for future reference if needed. 

Summary of Discussion on Paragraph (vi): 

This paragraph can be largely responded to by using maps and supporting documentation. 

States are likely to use maps from the Renewable Potential Atlas developed by the Land and 

Water Fund of the Rockies. Jeff Burks will contact LWFR for a packet for each of the five 

states. Generally speaking, this paragraph should be read as one idea – areas that are BOTH 

off-grid AND cost effective for RE. There is a rule of thumb: If you go farther than 1⁄4 mile 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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from transmission system, RE becomes a cost effective alternative to transmission line 

improvements. A reference to this “1⁄4 mile rule of thumb” in the SIP filing might be enough 

for a state to provide in responding to this paragraph. 

Paragraph (v) Projections of the short- and long-term emissions reductions, visibility 

improvements, cost savings, and secondary benefits associated with the renewable energy 

goals, energy efficiency and pollution prevention activities.

is the group tried to come to a definition for what the rule language meant by “Long-Term.” 

For Utah, the end-point of “long term” is 2018, the end-point for compliance in the rule. The 

first report date, 2008, is the end-point for short-term actions (compared to a baseline of 1990 

– 2003). The years 2005, 2010, 2015, 2018 are the years in ICF models, and the group 

discussed this as another option, ultimately agreeing to try to be consistent using the ICF 

dates where necessary. 

The ICF modeling “forced” nine states to adopt 10 / 20 goals, and the group discussed their 

concern that using the results of this modeling would be affected by only having four or five 

states file S.309 filings. Year-by-year estimates can be summarized from data that is 

available from ICF report. 

WRAP did a state-by-state emissions analysis comparing the results from 10 / 20 + EE in 

2018 with the “business as usual” case. The results can be summarized as: 

State NOx emissions (tpy) SO2 reductions (tpy) 

AZ 3267 +5558 

CO -1370 -1119 

NV -430 -307 

NM -7053 -5135 

UT -780 -595 

WY -1374 +1598 

Total -14274 0 (because of cap) 

In the context of the overall cap, the NOx reductions are very small, but they are reductions 

nonetheless. 

Overall, with regard to visibility improvements, the 10 / 20 goals will also have a positive 

impact, but initially will not, by themselves, result in sufficient improvements. Natural 

conditions = 7.5 deciviews, and WRAP is doing some simple calculations to determine 

visibility improvements as well. The rule does not say you need to project improvements for 

each policy – just progress towards improving visibility overall though a package of 

strategies. There has not been analysis of how the shifting of pollutants from one area to 

another affects specific Class 1 areas. 
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A question for EPA: is analysis that focuses on the full package satisfactory for the SIP 

filing? The group discussed whether visibility improvements on this small a scale are useful 

for inclusion in the model, since they are lost in the “noise” of the model. 

One suggestion was to submit the entire ICF model, with regional data and not state-specific 

data. This submission could be supplemented with a statement explaining that the EERE 

effects on visibility are small and lost within the noise of the model. There will be no 

detriment to visibility from NOx (a slight improvement overall) and no effect on SO2 

because of the cap. The argument to be made is that compliance is met at lower cost. If this 

were the route taken, there would not be not any way for a state to draft something 

quantitative beyond this. 

ACTION ITEM: 

Lee Alter will draft text for the above approach. This text is included at the end of the notes 

for Paragraph (v), below. 

Oregon’s representatives noted that the cost for gas is higher now and continuing to be high, 

this could be an ongoing gremlin in the model that affects the cost-effectiveness of EERE P2 

measures. 

Cost savings: 

• Outputs of the model are focused on electricity production costs (avoided energy use and 

avoided capacity additions). 

• The regional market makes it difficult to predict savings on a state-by-state basis. 

The group was asked if, assuming that the regional model does not provide enough for a 

state-specific evaluation, will providing regional data satisfy the state’s SIP process? 

New Mexico’s representatives noted that the rule language does not specifically ask for a 

state-by-state basis for response to this paragraph (it does as for state-based results in other 

paragraphs, notably, Paragraph (i)). 

The modelers suggested that states could apply parameterized results to state / tribal targets 

and report on a state-by-state basis. The targets could be related to a basic unit (i.e. each 

state’s load share). The key assumption to this approach would be that there is some 

consistency in cost. In this model, the State data comes from total compliance cost averaged 

out over a state-specific emissions factor. 

Using the ICF model, to obtain results under the three scenarios (the 10 / 20 goals; only EE; 

and EE+10/20 goals), states would need to find data for the following metrics: 

• Compliance cost ($/MWh) 

• Emissions (lbs/MWh) 

• Employment (jobs/GWh) 

• GRP ($/MWh) 

• Disposable income ($/MWh) 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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Since the SIP is looking at the effects on a regional level – regional haze –a regional response 

for visibility might be appropriate. 

Although only 3 to 5 of the nine states could be going with S.308 filings, some states outside 

the 5 (i.e. Nevada) have an RPS, and their contribution through non-S.309 methods are 

nonetheless contributions towards visibility goals. Therefore, even though only five states (at 

most) might file S.309 filings, a regional response could be appropriate. Participants noted 

that some sort of improvement data must be filed because EPA is unlikely to take “the 

presumption of improvement” to mean that no data needs to be supplied. 

Another potential solution is to do both: use regional data, then extrapolate based on this data 

to a state-by-state level of analysis through parameterization. Filers could provide statespecific information where addressing areas outside of the model projections. This might be 

important because many states lack the resources to model visibility etc. on an individual 

basis. In addition, this only makes a compelling case for states with positive results 

regarding net emission reductions and job increases. Arizona has a focus on solar (rather 

than wind, which in many areas is more cost-competitive), consequently some of the figures 

for “least cost” RE might not be as applicable to this state. Furthermore, the emission 

benefits of investments in RE may not occur in the state making the RE investment – a solar 

investment in AZ might displace a fossil plant in CO or elsewhere, so although for some 

states, the translation from investment to in-state emissions reductions may not be perfect, 

these investments should result in regional emissions reduction. 

Oregon’s representatives noted that costs are not as big a concern in the SIP filing – there 

may not be cost savings... so what? They are leaning towards parameterization. 

One parameter that could be used: RE consumption within the state over total consumption, 

not simply based on generation. Once your target is set (determining the state-specific target 

is for elsewhere – makes an assumption that the target is linear, averaged across the states) 

then apply parameters. Compare your state’s targets to ICF’s average parameterized factors. 

Reporting on the state impacts of a regional problem requires reporting: 

• Visibility improvements on a regional basis 

• Economic (costs, secondary benefits) on a state by state basis 

One difficulty is that the five states can detail their contribution to the nine state goal, but 

what about the other four? Paragraph (v) asks “what do you think your slice of regional 

program’s visibility, cost, and economic impacts are?” Paragraph (vi) asks for the update – 

“are we making the goals?” 

Since the parameters are regional, SIP filers are only finding out the state’s slice of a regional 

number – not a state-specific number. The benefits within that slice may not actually be 

tangible benefits in the state. One solution would be to multiply GWh by parameters. Where 

does the GWh number come from? The results are not additive, so if each state multiplies by 

its own number, the numbers will not add up to the same data that the ICF model has. 
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State filers are presented with two choices: 

• Either present bulk regional numbers, note that CA and NV are doing their part through 

RPS, and that’s our best guess; or 

• Say “here is the total, here is our slice through the ICF parameters” 

State participants were polled as to their preferences, and one approach recommended by 

some workshop participants was to provide regional data, rather than splitting the data by 

state using parameterization. The participants noted that the 10/20 goal itself is not something 

that all 9 states in the region are required to meet, by regulation or other formal agreement. 

As such, states filing regional data can make the case that they are presenting a picture of the 

results if the states participating in filing under S.309 and the non-participants collectively 

reach the 10/20 goal. This is will allow them to take credit for EE and RE and P2 activities 

that are happening anyway. 

In moving forward, Utah offered to work with the WRAP and look at drafting some common 

language for all the S.309 states to file, potentially liberally excerpting from the ICF 

modeling study. 

Inserted Text from WRAP: 

"Projections of visibility improvements for the 16 Class I areas on the Colorado Plateau 

are provided in Table 1 [of the SIP template]. These projections include the combined 

effects of all measures in this SIP, including air pollution prevention programs. Although 

emission reductions and visibility improvements from air pollution prevention programs 

are expected at some level, they were not explicitly calculated because the resolution of the 

regional air quality modeling system is not currently sufficient to show any significant 

visibility changes resulting from the marginal nitrogen oxide emission reductions 

described above for air pollution prevention programs." 

WRAP’s Note: For the projections of short- and long-term emissions reductions, we 

agreed to use the data presented for 2005, 2010, 2015, and 2018 in ICF's Executive 

Summary (and in the body) on the regional emission change in NOx.

Summary of Discussion on Paragraph (v): 

The years 2005, 2010, 2015, 2018 are the milestone years in ICF models, and the workshop 

participants remarked that these might be good dates to use as guidelines for determining 

“short-term” and “long-term” goals. The participants stated that a common presentation of 

the ICF model regional results might be appropriate in responding to this paragraph, noting 

that non-participant states such as CA and NV are doing their part to meet the 10/20 goals 

through their RPS and other mechanisms. In moving forward, Utah offered to look at 

drafting some common language for all the S.309 states to file, potentially liberally 

excerpting from the ICF modeling study. 

Paragraph (vi): A description of the programs relied on to achieve the State's 

contribution toward the Commission's goal that renewable energy will comprise 10 percent 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

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of the regional power needs by 2005 and 20 percent by 2015, and a demonstration of the 

progress toward achievement of the renewable energy goals in the years 2003, 2008, 2013, 

and 2018. This description must include documentation of the potential for renewable 

energy resources, the percentage of renewable energy associated with new power 

generation projects implemented or planned, and the renewable energy generation 

capacity and production in use and planned in the State. To the extent that it is not feasible 

for a State to meet its contribution to the regional renewable energy goals, the State must 

identify in the progress reports the measures implemented to achieve its contribution and 

explain why meeting the State's contribution was not feasible. 

There is potential here for inclusion of a summary, reference, or referral to Paragraph (i) 

response. Paragraph (i) might not get at the underlying programs, instead focusing on the 

specific RE programs. As with Paragraph (i), the response to this Paragraph in the SIP could 

look like a list, potentially with more descriptive detail. One approach would be to use the 

same list. 

Overlap comes up again as a concern in this section: WGA is working on a tradable regional 

REC system, which might be a solution in the long term. In the short term, the earlier 

generally-accepted “the funding state gets the credit” principle could be a way forward. 

Documentation will need to be provided with the filing anyway, potentially in this 

paragraph’s response or potentially in the appendix. 

For the PacifiCorp states, there could be a mention (as in Paragraph (i)) that there are planned 

additions through the regulated resource planning process. 

The group noted that Paragraph (i) requires an aggregated response and discussed whether 

Paragraph (vi) requires a more explicit program breakdown. It appears that aggregated 

approach is more effective: 

 Does the “potential for renewable power” require a consideration of cost 

effectiveness? Since the language does not indicate that this is required, potentially 

include the LWFR maps in response. 

 In compiling information, balance being effective in identifying projected potential 

program results with being overly exhaustive. “Focus on the big rocks” – for Utah, 

PacifiCorp IRP. 

 States with RPS can potentially count this in their estimation of future RE. 

For 2003, data to be provided would focus on base case (2003), and where some future info 

is available (from IRPs, RPS), states should make that info available. Utah has identified 

planned additions as part of its program description; including caveat language that the 

program might be subject to revision by the time revision occurs. Because it is the same set 

of programs, the same definition of “planned” applies – funded or committed subject to 

regulatory oversight. 
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States noted that they could include language anticipating updated information at the 

milestone dates for SIP revision, such as “in 2008, state will file information that updates 

progress.” 

Feasibility for 2003 programs could include language indicating that in the future (2008) the 

state will report on success of these 2003 programs in meeting goals. 

One approach for 2008: Each state could use an in-state guideline of 10% and 20% (or the 

goal set out in Paragraph (i), and if your state does not meet the in-state guideline, explain 

(i.e. EE efforts, other state’s efforts, and relative success versus the contribution identified in 

Paragraph (i)) 

 Utah is planning to use current programs to project what future RE is going to be, 

estimate what this contribution will be towards 10 / 20 goals. Using this, Utah will 

have data for the anticipated contributions for 2005, 2015. This provides a “bottomup assessment”, regardless of whether it provides 10%. 

 Arizona could use projections of growth compared to RPS. Another possible addition 

is to determine historical participation in green pricing programs and analyzing this 

relative to projected consumption growth. 

 New Mexico has an RPS in the works, and is comfortable with the idea of finding the 

data in-state to meet its own in-state goals. 

 There is no need to explain how your state’s goals will make the regional goals 

achievable in the first reporting period. 

A second approach would be to file language that reads along the lines of: “if all 9 states 

were to participate in S.309 filings, our state’s contribution would be X; however, since 9 

states will not participate, our state will update as this information becomes available”. 

A third approach would be to use 2003 data based on information developed in Paragraph (i), 

and explain that this information will be updated in 2008. 

(For 2003 filing, states can add language about their energy efficiency at their discretion, i.e. 

“efforts with EE make it easier to reach RE goal”. However, there is no language mandating 

a description of EE programs in Paragraph (vi)) 

Language from the WRAP’s STIP template language might be useful in this section, 

potentially reading: “As information becomes available between revisions, State will 

continue to work with WRAP to determine progress towards regional goals”. The WRAP 

AP2 Forum will continue to investigate ways to help States respond to the SIP. 

The group discussed whether it was worthwhile to have information compiled to predict 

whether states are on track to reaching regional goal. Currently, there is no coordinated 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

27

effort working on adding up 309 states’ contribution and the estimated contributions from 

non-309 states to determine whether the 10/20 goals are being met regionally. This might be 

a function for the WRAP. 

One solution of the problem is to follow a 10 / 20 goal per state. Proposed language: “Until a 

capturing mechanism is in place, state will not report on regional accounting that does not 

exist yet.” 

Each filing may need language to address why the state not looking at the allocation parsed 

out among states – Oregon will work to develop a draft of this language. WRAP will find 

the 2005 and 2015 goals included in the ICF Consulting report for future analysis to see if 

states are on track to meet the 10/20 goals. 

Summary of Discussion on Paragraph (vi): 

 States noted that providing information based on the regional data from the ICF modeling 

could be an appropriate response to this paragraph. A response to this paragraph could make 

reference to the programs outlined in Paragraph (i)’s response, the LWFR maps, and argue 

that if all 9 states were to participate in S.309 filings, the state’s contribution to the total 10 / 

20 goals would be X; however, since 9 states will not participate, the state will update the 

information about its contribution as part of the next SIP update. 

While there is currently no coordinated effort to compile information that could help to 

predict whether states are on track to reaching regional goal, this may be a function for the 

WRAP to consider taking on in the future. 

 

Wrap Up and Next Steps 

The WRAP requested that the states email Lee Alter a copy of their draft submittals for 

comparison with other states. The states discussed their internal deadlines, and each will try 

to accomplish putting a draft together for review by the other states prior to each state’s 

public comment period. 

There may be a possibility that some technical support could be provided to the states. In 

addition, the states discussed the possibility of having an external group such as GETF 

provide some consistency analysis. 

The states have an opportunity to provide a draft of their submittal before July 30. GETF, 

WRAP, and other interested parties will discuss the possibility of preparing a comparison 

matrix for those in the states responsible for producing and filing the SIPs. 

Currently, there is no coordinated effort working on adding up 309 states’ contribution and 

the estimated contributions from non-309 states to determine whether the 10/20 goals are 

being met regionally. This might be a function for the WRAP. There may also be a role for 

a third party to provide some consistency review prior to the filing deadline in order to help 

states provide EPA with consistent filings. 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

28

GETF agreed to provide the summary and action items from this meeting in a timely manner 

to the state participants. The group discussed the possibility of having some follow-up 

dialogue from the workshop, in the form of a conference call or other communication. 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

29

Attachment 3: Workshop Attendees List 

Lee Alter 

Western Governors’ Association 

lalter@westgov.org 

(520) 628-3173 

Don Arkell 

WESTAR 

darkell@westar.org

(541) 895-3664 

Neil Butt 

Air Quality Division, City of Albuquerque 

NButt@cabq.gov 

(505)768-2660 

Jeff Burks 

Utah Energy Office 

jeffburks@utah.gov

(801) 538-5414 

Phillip H. Carver 

Oregon Department of Energy 

Philip.h.carver@state.or.us

503-373-6874 

Brian Finneran 

Oregon Department of Environmental Quality 

finneran.brian@deq.state.or.us 

(503) 229-6278 

Anna Garcia 

GETF 

agarcia@getf.org

(703) 750-6401 

Van Jamison 

GETF 

wakanpowair@msn.com

(406) 443-0815 

Chris Janick

Salt River Project 

crjanick@srpnet.com 

(602) 236-5374 

Miles Keogh 

GETF 

mkeogh@getf.org

(703) 750-6401 

Jerry Kotas 

US DOE, Denver Regional Office 

jerry.kotas@ee.doe.gov 

(303) 275-4850 

Bob Lebens 

WESTAR 

blebens@westar.org 

(503) 387-1660 ext. 6 

Scott Manzano 

Oregon Department of Environmental Quality 

MANZANO.Scott@deq.state.or.us

(503) 229-6480 

Louise Martinez 

New Mexico Energy Office 

lnmartinez@state.nm.us

(505) 476-3310 

Jan Miller 

Utah Department of Environmental Quality 

janmiller@utah.gov 

(801) 536-4042 

Dave Nichols 

Tellus Insitute 

d.nichols@earthlink.net

(617) 277-7950 

Bruce Polkowski 

National Park Service 

bruce_polkowsky@nps.gov 

(303) 987-6944 

Theresa Rigney 

Arizona Department of Environmental Quality 

rigney.theresa@ev.state.az.us 

602-771-2349 

Steve Roseberry 

Wyoming Department of Environmental Quality 

SROSEB@state.wy.us 

307-777-6105 

Bishal Thapa 

ICF Consulting 

bthapa@icfconsulting.com 

(703) 934-3904 
WRAP • Pollution Prevention Workshop for Section 309 SIPs and TIPs • May 20-21, 2003, Portland, Oregon

30

Rita Trujillo 

New Mexico Air Quality Bureau 

rita_trujillo@nmenv.state.nm.us 

(505) 827-1494 

David Von Hippel 

Tellus Institute 

dvonhip@igc.org

(541) 687-9275 

Lisa Yoder 

Utah Energy Office 

lisayoder@utah.gov

801-538-4761