Western Regional Air Partnership 

2008-12 Strategic Plan 

March 2008 
2008-12 WRAP Strategic Plan March 2008

 2

Table of Contents

 Introduction............................................................................................................ 3 

 

I. Background and Status................................................................................................ 5 

II. Organization and Structure.......................................................................................... 9 

III. Technical and Planning Work Activities .............................................................. 10 

A. Post-2007 SIP submittal Regional Haze Analysis and Implementation Support 

B. Support for other Air Quality Management Priorities 

C. Assessing Air Quality Impacts of Changes in Energy Supply and Use and in the 

 Activities of Greenhouse Gas Emissions Sources 

Appendix A: Status of Partners’ Priorities and Findings of the WRAP Board..................... 21 

Appendix B: WRAP Technical Data and Decision Support Systems .............................. 23 

Appendix C: Preliminary 2009-12 Budget............................................................... 24 

Appendix D: Current List of Technical Air Quality Studies Using WRAP data................... 26 

Appendix E: Support of Tribal Air Quality Management Capability and Tribal 

 Implementation Plan (TIP) Development................................................ 27 
2008-12 WRAP Strategic Plan March 2008

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Introduction 

In July 2007, the WRAP reached its 10th anniversary. Over the last 10 years, the WRAP has received 

substantial financial support from the U.S. Environmental Protection Agency (EPA) and has used these 

resources to build state-of-the-art technical data and decision support systems to facilitate regional haze 

planning in the West where 75% of our nation’s Class I airsheds are located. The WRAP’s technical tools 

have also proven to be valuable for evaluating other air quality issues and have been utilized by numerous 

state, tribal, and federal agencies. Western tribes’ participation in the WRAP has greatly improved the 

availability of tribal data and understanding of air quality issues from a tribal perspective. 

 

Through the WRAP, states, tribes, EPA, and Federal Land Managers (FLMs), working with industry and 

environmental organizations, have developed and implemented numerous air quality policies that have 

improved the environment in the Western United States. 

• §309 Annex – Established SO2 emission reduction milestones across the region 

• Low Sulfur Gasoline – WRAP provided early support of the series of EPA mobile source sector 

emissions reductions 

• Smoke Management – Developed enhanced smoke management plans, emissions tracking 

• Diesel Retrofits – Promoted & facilitated development of retrofit programs in several states 

• Renewable Energy and Energy Efficiency – linked programs/standards to haze reduction 

• BART – WRAP supported impact analyses and coordinated development of controls for these 

grandfathered point sources 

• Oil and Gas – Developed new emissions inventories and control technology assessments 

All Western states are currently completing their Regional Haze state implementation plans (SIPs) to 

demonstrate reasonable progress at the 118 Class I areas located in WRAP states, including the 

resubmittal of the §309 plans originally submitted in 2003. Completion and approval of these Regional 

Haze plans is a major milestone for the WRAP. This plan describes the efforts Western states, tribes, and 

FLMs envision for the WRAP over the next five years (2008 through 2012) to build on the success of the 

last 10 years, providing for: 

• Ongoing implementation of the regional haze program; 

• Technical and policy support related to other regional air quality issues, such as the Ozone and PM 

NAAQS, mercury and nitrogen deposition impact on ecosystems, regionally-appropriate 

emissions management strategies; and 

• Technical and policy support on issues related to climate change and energy. 

At the direction of the WRAP Board of Directors, the plan included here was developed through the 

WRAP’s Air Managers Committee, which includes state, tribal, and federal officials and reflects their 

individual and collective priorities for the 2008-12 time period. Summaries of inputs to this plan are 

presented in Appendix A. 

While much of the plan addresses specific planning requirements under the regional haze rule, additional 

and related priorities of states, tribes, EPA, and FLMs are addressed. Priority activities discussed here are 

not likely to occur at a constant level throughout the plan period, but vary and will be adjusted to 

accommodate changing needs. 
2008-12 WRAP Strategic Plan March 2008

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Strategic Goals for 2008-12 

There are three interrelated goals for simultaneous concurrent action between 2008 and 2012. 

1. In 2008-09, coordinate and support the submittal, review, and approval of regional haze 

implementation plans. 

2. In 2009, begin refinement of regional data and development of analysis tools for strategic 

evaluation of ongoing and future control programs for air quality planning focusing on: 

a) Tracking, reporting, and analyzing progress for regional haze; 

b) Regional contributions to Ozone and PM health and welfare standards’ nonattainment issues at 

various scales; 

c) Understanding and analyzing the nature and causes of mercury, acid deposition, and critical 

loads in the West; and 

d) Regionally-appropriate and effective emissions management strategies and programs. 

3. In concert with emerging efforts to manage and adapt to climate change, fully integrate data for 

both energy supply and use as well as activity changes for sources of greenhouse gas emissions 

into air quality analyses. 

Further description of the objectives, activities, and actions to meet these goals is discussed at a 

strategic level in this plan. These require active participation by WRAP member agency staff and 

management, as well as financial support; both are needed to assure continued success in the operation 

and activities of the organization in alignment with technical analysis and control strategy 

development projects. 
2008-12 WRAP Strategic Plan March 2008

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I. Background and Status 

The WRAP has been supporting state and tribal work on regional haze since 1997. The WRAP work 

products are the result of direction and priorities from the Grand Canyon Visibility Transport Commission 

and the WRAP Board are carried out through Committees, Forums, and Workgroups addressing state, 

tribal, FLM, EPA, industry, and environmental groups’ collective needs and air management concerns for 

regional haze planning. The WRAP Charter states: “The purpose of the WRAP is to identify regional or 

common air management issues, develop and implement strategies to address these issues, and formulate 

and advance western regional policy positions on air quality. Included in this purpose is the 

implementation of the Grand Canyon Visibility Transport Commission's recommendations.” 

Work by WRAP Committees, Forums, and Workgroups is accomplished by the staff time contributed by 

state, tribal, FLM, EPA, and environmental, industry, and public representatives, with the support of 

WRAP staffing through WGA and NTEC. WRAP work is also handled through contracts to 

environmental consulting firms, to analyze air pollution data collected by states and tribes in their 

regulatory programs as well as to prepare data and analyses for natural and/or uncontrollable air pollution 

sources. The past 10 years of WRAP work has shown participating state and tribal WRAP members and 

stakeholders the benefits of working together regionally. Efficiencies have been gained in leveraging 

resources, developing technical tools, and problem-solving that better addresses air quality issues of 

regional concern. While the WRAP is meeting its GCVTC-directed objectives, other air quality issues 

have emerged that the WRAP’s collective resources framework is better equipped to address than if states 

and tribes were to work on the issues individually. 

The WRAP has developed a regionally-consistent and comparable body of technical data and analysis 

tools that will be essential to the ongoing work to reduce visibility impairment in the 118 Class I areas 

throughout the West and to address other regional air quality issues. The Regional Haze Rule has a 

nominal 60-year implementation period to reach natural visibility conditions, and requires tracking of 

visibility monitoring and emissions data, and ongoing analyses of source apportionment, projection of 

future visibility conditions, and verification/adjustment of reasonable progress goals to improving 

visibility for each Class I area. 

Most of the technical work needed to support the current regional haze SIPs is complete. These data and 

tools supporting plan development and implementation tracking are provided for use and evaluation 

through a transparent and open network of interrelated data support web systems and a technical decision 

support system (see Appendix B). Considerable advances have been made by a number of tribes on 

emissions inventories, data gathering, and analysis. The related goal of sharing analyses of these data in 

support of coordination between WRAP region states, tribes, FLMs, and EPA has seen a great deal of 

progress through the WRAP systems, and these tools form the basis for even closer collaboration moving 

forward. 

EPA funding for WRAP regional haze analysis and planning has decreased sharply and future EPA 

funding for haze and other regional air quality work is uncertain. Based on the cooperative collaborative 

model for the regional planning effort of the last 10 years, and given the scope of the effort required for 

implementation of the Regional Haze Rule over the next 5 years, a minimum consistent maintenance level 

of EPA funding for WRAP regional efforts is needed (preliminary budget - Appendix C). 

 
2008-12 WRAP Strategic Plan March 2008

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The next phase of the WRAP’s technical work for regional haze will focus on: 1) issue resolution and 

analyses needed as EPA conducts SIP review and approval; 2) assistance for states in implementing 

regional haze SIP strategies; 3) assistance for tribes preparing TIPs and/or working with EPA on FIPs; 4) 

tracking reasonable progress; and 5) preparing for the 5-year regional haze implementation plans’ review 

and required revision. 

Status of Regional Haze Emissions Analysis and Controls 

• Mobile Sources – New EPA standards for land-based engines and fuel will greatly reduce 

emissions from mobile sources. Mobile sources are the largest source of nitrogen oxide 

emissions in the West. These new standards will reduce mobile source emissions of nitrogen 

oxides by 70% over the next 15 years, even as the West continues to grow. 

o In contrast to other mobile engines, offshore marine shipping emissions are increasing, 

perhaps doubling by 2018 across the eastern Pacific Ocean. While held constant to date 

for modeling as the uncertainty of 2018 estimates was not known, the 2018 shipping 

emissions projections now appear to be generally accepted and will be applied in future 

analyses. Potential emission controls may dampen growth, but analysis and 

implementation of sufficient controls to assure reasonable progress will require concerted 

and coordinated state and federal efforts and resources. 

 WRAP Region NOx emissions by source category 

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

On Road Off Road Point Area Area O&G Fires Offshore

Shipping

Biogenic

NOx (tons/yea r

2002 2018 Base Case 
2008-12 WRAP Strategic Plan March 2008

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• EGUs and BART – Through BART implementation and other efforts to reduce stationary 

source emissions of SO2 and NOx beyond those completed by 2006, the Regional Haze Plans 

will address the long-standing issue of emissions from grandfathered sources, including coalfired power plants. 

Western State Power Plant Emissions (1995-2006)

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

550,000

600,000

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

SO2 (tpy)

NOx (tpy)

CO2/1000 (tpy)
2008-12 WRAP Strategic Plan March 2008

 8

• Prescribed Burning and Smoke Management – Western states/tribes/FLMs are improving 

their smoke management programs to ensure that air quality impacts are minimized when 

prescribed burns are necessary on public and private land. 

o The WRAP is implementing a fire tracking system to help land managers and air quality 

planners manage controllable smoke impacts on a regional basis. 

o While smoke management programs for prescribed fire and fire emissions tracking are in 

place, substantial additional study and resources are needed to quantify the chemical 

signature and deposition of haze pollutants generated by fire emissions and to develop a 

method to routinely evaluate the contribution of wildfire to natural haze conditions. Fire 

emissions in general and wildfire in particular are the primary drivers of the temporal 

occurrence of measured worst visibility days at many sites in the West, while varying 

significantly by Class I area from year to year. Emission controls are not possible for 

wildfire, but analysis to provide source apportionment for biogenic burning will improve 

understanding of haze caused by natural fire. 

WRAP Region Fire PM2.5 Emissions Scenarios (tpy)

0

500,000

1,000,000

1,500,000

2,000,000

Prescribed Fire 71,421 72,218 64,170 195,020 97,347 376,206

Wildland Fire Use 81,505 41,171 41,171 659,594 1,319,189 659,594

Wildfire 1,489,886 971,453 971,453 504,654 504,654 504,654

Agricultural Fire 34,571 34,590 34,590 34,590 34,590 34,590

N-F Rangeland Fire 15,454 15,454 15,454 18,643 18,643 18,643

2002 Actual 2000-04 Baseline 

Average

2018 Planning - 

Baseline Average 

with ERTs

2018 Projection A - 

FLM-proposed 

activities

2018 Projection B - 

Climate conditions/ 

resource limited

2018 Projection C - 

Max. application of 

Prescribed Fire

• Other Source Categories – Ongoing Support: 

o Phases I and II of a regional inventory of haze-causing emissions from oil and gas sources 

have been completed, including a preliminary analysis of potential control options. The 

Phase III study is now underway. 

o The WRAP is providing direct assistance to state and local governments and fleet owners 

in an effort to reduce diesel emissions through retrofit programs. 

o The WRAP has assisted several sub-regional air quality studies and air management efforts 

with data and technical support (see Appendix D). 
2008-12 WRAP Strategic Plan March 2008

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II. WRAP Organization and Structure 

For the continued successful operations of the WRAP organization, three objectives are identified to 

support the strategic goals for WRAP: 

1. Maintain the WRAP process (organization, staffing, and operations) at a level sufficient for continued 

support of successful regional planning. 

2. Continue support for tribal capacity, including: 

a) Improving the ability of Tribes to assess their air quality conditions and to develop strategies to 

address air quality issues as part of the larger regional planning process; and 

b) Increasing the ability of Tribes to protect and manage their natural resources and communities. 

3. Maximize coordination within WRAP and with other related partner organizations (the FLMs, EPA, 

multi-jurisdictional organizations such as RPOs and WESTAR, NTEC, NTAA, NOAA, as well as 

other federal agencies). 

The overall WRAP organization and structure is proposed to remain as is for the purposes of preparing 

this workplan. Needed changes to Committees, Forums, and Workgroups will be identified in 2008. The 

general approach to revising the missions, responsibilities, and operations of the WRAP organization will 

address the following: 

• Improving economies of WRAP operations throughout, and enhancing effectiveness of technical 

capabilities in place; 

• When efficiencies can be gained, continuing the effort to combine existing Forums and Workgroups 

to cover a broader range of subjects within a lesser number of groups, such as combining emissions 

inventory work rather than separating into Fire, Dust, and Point sources – while still maintaining 

technical expertise in these varieties of emissions categories; 

• Evolving the focus of periodic technical meetings to address broader interrelated topics, such as 

regional modeling analysis of PM, haze, and ozone simultaneously; 

• Continuing the trend of less frequent but highly coordinated meetings supported by conference calls 

and web-based meetings to provide maximum benefit to attendees; 

• Focusing on resetting the missions of the Committees, Forums, and Workgroups to address these 

broader topics, such as emphasizing partnership and providing technical and planning support to subregional air quality management initiatives between states, tribes, and FLMs; and 

• Building closer working relationships with partner organizations, the FLMs, EPA, multi-jurisdictional 

organizations such as RPOs and WESTAR, NTEC, NTAA, NOAA, as well as other federal agencies. 

The approach to the ongoing effort to evolve the WRAP organization is and will be based on tribal, state, 

FLM, and WRAP Board priorities, and on the use and benefit of the successful regional analysis and 

planning efforts. As noted in Appendix B, proposed funding for the WRAP project through WGA is a 

level of effort consistent with the average grant amount for regional haze of the last 3 grant years (FFYs 

2004, 05, 06), which are then used in calendar years 2005, 06, and 07. WRAP staff work for the entire 

organization, by supporting activities of Committees, Forums, and Workgroups, as well as managing 

contracts and operations of data support centers and the technical decision support system. Proposed 

additional staffing and projects to assist tribes are also to be provided through NTEC (see Appendix E). 

The entire WRAP staff effort is also focused on ensuring the maximum opportunity for coordination and 

communication between the WRAP members as well as their umbrella organizations. 
2008-12 WRAP Strategic Plan March 2008

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III. Technical and Planning Work Activities 

The technical and planning work activities by WRAP will address the areas shown in Figure 1. Regional 

Haze implementation and air program support activities are well-developed and mature, based on the 

work of the past 10 years, and the web-based systems already in operation. Ozone and PM NAAQS 

analysis activities are to focus on defining the regional source contributions to violations and degrading 

trends in ozone and PM air quality in the West. The studies of ozone and PM issues benefit from the 

comprehensive and consistent regional databases and tools already developed for haze, which will be 

adapted with minor effort, and improved to evaluate regionally-consistent control measures and strategies 

to improve ozone, PM and haze simultaneously. Finally, the WRAP will develop and analyze the 

information about deposition, critical loads, greenhouse gas emissions, and energy supply to assist WRAP 

members in crafting appropriate air quality management responses for these interconnected issues. 

Figure 1. WRAP 2008-12 Technical and Planning Work Activities related to regional air quality 

WRAP support to members: Now + Future

Regional Haze 

Implementation 

PM NAAQS 

(primary & 

secondary) 

Mercury & Nitrogen 

Deposition/Critical Loads 

Climate Change, GHG 

Emissions, & Energy Supply 

Ozone NAAQS 

(primary & 

secondary) 

Air Program Support 

(data resources, peer-topeer contact + training) 

Regional Air 

Quality Analysis 

(Technical & 

Planning/Policy) 

For the technical work activities of the WRAP organization, five objectives are identified to support the 

strategic goals for WRAP: 

1. Support and provide coordination for WRAP members (States, Tribes, FLMs, EPA) during EPA’s 

review and approval process for regional haze implementation plans (2008-09). 

2. Provide support and coordination in implementing emissions reductions in the haze plans, and track 

Class I visibility improvement resulting from regional haze strategies (2008 and onward). 

3. Maintain and update technical capabilities for haze, including databases, regional analysis functions, 

data and decision support systems (2008 and onward). 

4. Provide analysis and data needed for 2012 progress report and SIPs/TIPs/FIPs (2009-12). 

5. Provide technical and policy support to address other priority issues for air quality and climate change 

(2009-12). 

Specific work activities for haze implementation and effort to provide regional technical and policy 

support to address other priority air quality issues are discussed in Sections A, B, and C, respectively. 
2008-12 WRAP Strategic Plan March 2008

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A. Post-2007 SIP submittal Regional Haze Analysis and Implementation Support

The WRAP proposes to have 5 primary technical activities to support the implementation of the 

regional haze plans during the 2008-12 time period. Those are: 

1. Support states during EPA’s regional haze SIP review and approval process (2008-09); 

2. Assist tribes preparing TIPs and/or working with EPA on FIPs (2008 and onward); 

3. Support and provide coordination in implementing emissions reductions in regional haze plans, 

and track Class I area visibility improvement resulting from regional haze strategies (2008 and 

onward); 

4. Maintain and update technical capabilities for haze (databases, regional analysis functions, data 

and decision support systems – 2008 and onward); and 

5. Provide analysis and data needed for 2012 progress report and SIP revisions (2009-12). 

These activities are illustrated in Figure 2, depicting how the regional haze SIPs will receive ongoing 

review and be adapted over the next 10 years. The reasonable progress requirement of the RHR is 

fundamentally different than the SIP requirements for the National Ambient Air Quality Standards 

(NAAQS). The haze SIPs are ongoing management plans, which accumulate control strategies from 

other air quality management programs over time, require consultation with upwind and downwind 

jurisdictions, and determine how natural and/or uncontrollable emissions are affecting reasonable 

progress toward natural visibility conditions in 60 years. 

Proposed annual funding described in Appendix C for the technical support effort for haze 

implementation for 2009-12 is a level of effort generally consistent with the 2005-07 average. It is 

important to note that the funding currently available for 2008 technical work is at a “bare bones” 

level due to EPA funding cuts. The funding currently available and the amount of associated 

technical work in 2008 are expected to possibly be adequate, but not at all comparable with historic 

efforts by WRAP. 

 
March 2008

12

* – This analysis for the 2012 SIP check will establish accountability for emissions reductions/management strategies for that state identified in each 200

track as anticipated? The 2007 SIP should require the state to complete a review of its emissions and spell out the circumstances of how a SIP revision p

triggered. If things have changed enough, that State needs to re-do the projections based on its changed emissions and either re-affirm that it will be on tmake the needed changes to emissions strategies and / or the SIP RP goals written into each state’s 2007 SIP. 

Actions needed for 2012 SIP revision toward ne

Figure 2. 2007 to 2012 Regional Haze Implementation Activities leading to 2018 Haze Plan milestone 

2007 Haze SIP

Narrative

Measures

Visibility conditions (2000-04 baseline) 

Current 

 Natural 

Emissions (mostly 2002)

Point 

 Area  Mobile  Fire, Dust, et cetera  International 

2018 Emissions Projections 2018 Visibility Reasonable  Progress Goals 2012 SIP Revision Approach  Monitoring Data Trends  Emissions Trends  In-state* All contributing states

On-The-Books Specific to RHR 

BART 

 Other point ? Area ? Smoke Management ? 

Same categories as 2002, based on Federal Programs, othState rules, plus BART and any additional measures (groprojections for some categories, others held constant) 

Review completeness and trends in monitoring data Based on latest & best regional emissions inventories: 

1) Examine how trends in various emissions types and scales com

narrative prepared for SIP submittal*

 2) Examine what is “now” On-The-Books and re-project 2018  3) Adjust SIP (measures and / or goal) 

Estimated using modeling of the “Reasonable Progress” for most and least impaired days, then adjusted using moRelative Response Factors – review of progress toward vgoals selected in SIP by each stateIdentify needs for comprehensive regional emissions tracand complete/representative Class I area monitoring dataAssess post-2012 need for additional regional analysis aplanning to begin now for 2018 SIP submittal

⎬ These measures may include non-BART emissions limits

limits on source categories, and modification to smoke mplans, et cetera.

⎬

2008-12 WRAP Strategic Plan
2008-12 WRAP Strategic Plan March 2008

 13

The review and approval by EPA of the haze plans in the WRAP region is expected to take up to 2 

years, well into 2009, followed by analysis and preparation for a 2012 SIP revision. During the EPA 

review process for the individual state haze plans, which are based on the collective regional databases 

and analytical work products, questions about the impacts of some source categories and source 

regions are likely to occur. The WRAP regional haze data, developed by consensus technical efforts 

and regional technical analysis capabilities will need to be applied to answer those questions. The 

proposed WRAP staff effort, as well as existing and proposed funding for broad workplan topics for 

the 2008-12 time period are shown in Figure 3 and 4. 

Figure 3. Conceptual WRAP Staff Effort Distribution on only Regional Haze tasks [based on 

Limited Current Known Funding (2008) & Proposed Future Funding (2009-12)]

2008 2009 2010 2011 2012

WRAP staff effort

SIP Review/Approval Haze SIP Implementation

Technical Analyses Continue successful process

Figure 4. Distribution of Limited Current Known Funding (2008) & Proposed Future 

Funding (2009-12) for all technical work activities and staff support

$0

$200,000

$400,000

$600,000

$800,000

$1,000,000

$1,200,000

$1,400,000

2008 2009 2010 2011 2012

Costs

Technical Support System Regional Modeling Center

Emissions Data Management System Emissions Projects1

Monitoring Data Analysis1 Staff + Project Management

Technical Data/Analysis Support subtotal

1- the costs and effort to be applied to the Emissions and Monitoring projects are scaleable for any particular year; 

usually these are done early in the multi-year analysis sequence leading to the 2012 SIP revision. 
2008-12 WRAP Strategic Plan March 2008

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Key project activities in 2008 for support of the regional haze SIP review and approval process with 

the limited funding currently available to WRAP include: 

• Collection, storage, tracking, display, and analysis of emissions and visibility monitoring trend 

data as they are reported to WRAP data and decision support centers. 

• Emissions analysis and modeling simulation of the regional “2018 Final Reasonable Progress” 

scenario, which is to include: 

o Permitted/controlled emissions rates for the sources states and EPA have determined to be 

“subject-to-BART” – this information will be provided by individual states and EPA for 

processing into a single regional emissions analysis and modeling simulation effort; and 

o Correction of the limited number of remaining errors in the 2018 emissions projection data. 

• A limited number of regional modeling sensitivity analyses, for example, international transport, 

marine shipping inventory improvements, et cetera. 

• Respond to regional analytical needs as resources allow for topics such as fire emissions 

contributions to 2000-04 baseline conditions and the implied contribution to 2064 natural 

conditions targets. 

Beginning in 2009, the WRAP proposes to coordinate the implementation of the Regional Haze SIP 

strategies and provide analyses and tracking of Reasonable Progress, laying the groundwork for a 

comprehensive and rigorous analysis supporting the 2012 SIP revisions. The work will include 

collecting and analyzing data for monitoring and emissions trends, performing selected modeling 

studies to address source and source region impacts, and conducting regional analyses to support 

control strategy development. 

The kinds of sources and geographic regions to be studied and assessed for controls or improved 

management include: 

• Non-BART point and stationary area sources; 

• §309 SO2 Annex Backstop Cap and Trade Program sources; 

• Concentrated geographic groups of sources proximate to Class I areas; 

• Oil and Gas production and distribution; 

• Dust emissions; 

• Fire emissions; 

• Secondary aerosol precursor emissions such as ammonia and volatile organic compounds; and 

• Sources outside the WRAP region, international transport, and/or beyond the states’ control. 

This work would involve monitoring data analysis and emissions inventory studies, and include 

applying the regional air quality modeling tools to assess changes in cumulative visibility impacts at 

each Class I area. This work could be done efficiently and effectively within the WRAP 

organizational structure using existing regional technical tools and capabilities, allowing assessment 

of sources common to all states and air regulatory agencies as well as to explore the impacts and 

management of sub-regional groupings of all kinds of sources. 

To achieve these goals, WRAP proposes to conduct the following activities: 

• Refine and improve data and tools to improve the ability of states, tribes, FLMs, and EPA to 

predict regional haze impacts and attribute sources. 
2008-12 WRAP Strategic Plan March 2008

 15

o Apply these data and tools to help states, tribes, FLMs, and EPA be more strategic in securing 

future emissions reductions, meet or exceed reasonable progress goals, and make mid-course 

corrections as needed. 

• Maintain and update technical capabilities for regional haze related to visualization, tracking, and 

analysis of data and analytical results - data and decision support systems: 

o Technical Support System (TSS - decision support) is the regional haze plan technical data 

resource, and includes: 

 VIEWS (IMPROVE visibility monitoring data, analysis tools); 

 CoHA (analysis of historical meteorological and particulate monitoring data); and 

 FETS (fire activity/emissions data, prescribed fire regional coordination, analysis tools). 

o Emissions Data Management System (EDMS - tracking of all emissions inventory data, 

analysis); and 

o Regional Modeling Center (RMC - comprehensive photochemical aerosol modeling studies, 

testing of source category and source region impacts, training, technical data file transfer, and 

user support). 

Deliverables and Timeline: 

• As noted above, support for the states, tribes, FLMs, and EPA during review and approval of the 

haze SIPs will begin in 2008 and likely continue through 2009. Beginning in 2009, work 

identified by WRAP Committees, Forums, and Workgroups will begin on the implementation for 

the Haze SIPs, becoming the major focus for 2010 through 2012, the due date for Haze SIP 

revisions confirming progress or making mid-course adjustments to improve progress toward the 

2018 Reasonable Progress Goals. It is expected that the need for collection, preparation, and 

dissemination of technical data and analytical results will need to continue at least at the average 

of the 2005 through 2007 levels of WRAP effort, to support both these efforts across the 2008 

through 2012 time period. The process support will need to continue at 2005 through 2007 levels 

as well. The funding presently available for technical data and analyses for use during 2008 is 

limited, but will need to return to pre-2006 levels to support haze SIP review, approval, and 

implementation leading to the 2012 haze SIP revision. 
2008-12 WRAP Strategic Plan March 2008

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B. Support for other Air Quality Management Priorities 

As directed by the U.S. Congress, the National Research Council (NRC) of the National Academy of 

Science published Air Quality Management in the United States in 2004. Figure 5 (below) from that 

report illustrates the interconnected nature of regional air pollution impacts, emissions control, and air 

quality management. More recently, EPA senior technical management staff published The Rationale 

for a Multipollutant, Multimedia Air Quality Management Framework in the May 2007 edition of the 

Environmental Manager magazine of the Air & Waste Management Association. Both the research 

community in the NRC report and now the EPA have articulated the need for one-atmosphere analysis 

approach regarding state and tribal emissions control decisions to achieve health and welfare 

standards as well as aesthetic goals codified in the federal Clean Air Act. 

With incremental additional funding, the WRAP proposes to conduct regional technical analyses and 

coordinate emissions control assessments on a value-added basis beyond regional haze 

implementation, primarily for the Ozone and Particulate Matter (PM) NAAQS. This work would be 

of benefit to WRAP members and affected groups across the West, as noted in the priorities identified 

in Section II above, Organization and Structure. The primary reasoning for proposing this valueadded effort is the ongoing success of regional haze analysis and planning work, the cost-effectiveness 

of applying existing data and analytical tools from regional haze to other pollutants in, and impacts 

from, the same atmosphere, and the experience of the WRAP in coordinating the analysis and 

reduction of haze emissions over the past 10 years. Opportunities for making assessment of impacts 

and effects of controls on climate change adaptation strategies, mercury and acid deposition, and other 

air quality management issues would also be possible. 

As with regional haze implementation, this work would involve monitoring data analysis and 

emissions inventory studies, and would apply the regional air quality modeling tools to assess changes 

in cumulative air pollution impacts at Class I areas, urban areas, and more rural locations such as 

tribal lands. This work could be done efficiently and effectively within the WRAP organizational 

structure using existing regional technical tools, allowing assessment of sources common to all states 

and air regulatory agencies as well as to explore sub-regional groupings of all kinds of sources. These 

technical tools and methods could also be applied in combination or sequentially, and would look at 

the PM and Ozone NAAQS and other issues simultaneously. 

States, tribes, FLMs, and EPA are already using WRAP data and analytical results in sub-regional 

studies to assess attainment, protection, and maintenance of health and welfare air quality standards 

(see Appendix D). These efforts have received no consistent WRAP-wide assessment as with the 

regional haze analyses, and suffer from funding shortages to recreate and reanalyze results for subregional issues. 
March 2008

17

Scientific and

Technical Foundation

Monitoring

• Emissions• Ambient air quality• Health and exposure• Ecosystems

Analysis

• Models (e.g. air quality,

emissions)

• Economics• Health and ecological

risk assessment

Research

• Public health and

ecosystem studies

• Laboratory studies

(e.g., air chemistry,

toxicology)

Development

• Source control technology• Monitoring technology

2.) Designing and Implementing Control Strategies

3.) Assessing Status and Measuring Progress

• Emissions trends • Air quality trends • Health effects trends• Ecosystem trends • Institutional accountability

• Emissions standards • Ambient air quality standards• Reducing acid deposition • Reducing regional pollution • Protecting visibility

• Source control technology requirements • Emissions caps and trading • Voluntary or incentive-based programs • Energy efficiency• Pollution prevention (e.g., product substitution and process alteration) • Compliance assurance

1.) Setting Standards and Objec

Figure 5. National Research Council Air Quality Management Schematic

Source: National Academy of http://www.nap.edu/books/03

2008-12 WRAP Strategic Plan
2008-12 WRAP Strategic Plan March 2008

 18

Future air program analysis priorities under this incremental regional technical analysis effort would 

be better coordinated and address a variety of dimensions, for example: 

• Simultaneously assess regional haze implementation, Ozone and PM NAAQS issues, mercury 

and acid deposition problems, air quality impact of greenhouse gases reductions and energy 

development in an integrated fashion. 

• Determine the regional contribution to locally-oriented NAAQS problems such as exceeding the 

24-hour PM standard along the Wasatch Front or other populated areas; 

• Assist well-organized and substantial sub-regional analysis and planning efforts such as those 

listed in Appendix D; and 

• To protect health and welfare standards, analysis is needed to understand the regional response to 

emissions control and management programs over time. 

Proposed annual funding (see Appendix B) for this incremental additional regional technical analysis 

effort for 2009 through 2012 assumes that the haze implementation resources identified earlier are 

provided as a foundation. The WRAP is not currently funded for this additional work, so no resources 

are currently available in 2008. No funding for additional WRAP staff or operations is requested for 

this additional effort 2008 through 2012. Planning by WRAP Committees, Forums, and Workgroups 

during 2008 is needed to make the fullest use of these incremental value-added funds, should they be 

provided for the 2009 through 2012 time period. The re-focusing of the missions and responsibilities 

of WRAP Committees, Forums, and Workgroup described above in Section II, Organization and 

Structure, would adapt to these priorities as incremental funding is provided. 

As funding for the technical projects and analyses beyond haze implementation is provided, there will 

be a process for project selection and prioritization. Meetings will be held to develop and review 

conceptual descriptions of projects and evaluation criteria. These will then be used to develop more 

detailed annual workplans (2009, 10, 11, 12) for Board approval and action by Committees, Forums, 

and Workgroups. The incremental regional technical analysis effort supporting planning and policy 

in the WRAP region will address the following topics: 

• Refine emissions and air quality analysis data and tools to support nested studies within the 

WRAP region of the contributing sources and regions for Ozone NAAQS monitors across the 

West, and specifically nonattainment areas. 

o Develop or adapt existing tools for states to use in ozone modeling, nested within regional 

analysis tools, and provide technical assistance to agencies in developing regional approaches 

to ozone control programs. 

• Refine emissions and air quality analysis data and tools to support nested studies within the 

WRAP region of the contributing sources and regions for PM NAAQS monitors across the West, 

and specifically nonattainment areas. 

• Conduct the control strategy analyses for these regional and nested studies to improve the 

evaluation of control strategies to continue reasonable progress for regional haze in concert with 

attainment of the ozone and PM health standards. 

• Regional analysis of the contributing sources and regions for mercury and acid deposition (Critical 

Loads) issues in the WRAP region. 

o Develop the capability to determine the transport and regional fate of Mercury emissions. 
2008-12 WRAP Strategic Plan March 2008

 19

o Develop tools, data, and methods to routinely evaluate regional contributions to atmospheric 

deposition in Class I areas. 

o Regional data collection and storage, as well as regional analysis of emissions resulting from 

New Source Review permitting processes. 

• Climate change-related activities: 

o Mitigation and adaptation strategies; 

o Energy supply and use; and 

o Greenhouse gas emissions tracking, analysis, and management. 

Deliverables and Timeline 

The distribution of the effort for the incremental regional technical analysis efforts is depicted in 

Figure 6. As an example of deliverables over time for the regional contribution to Ozone and PM 

NAAQS problems: 

Technical Issue: Evaluate regional and international sources of Ozone/PM precursors and PM 

emissions, and the resulting formation and transport of Ozone and PM impacts 

across the West. 

Activities: 2008 – hold workshops, assess efforts underway, identify gaps, and develop specific 

annual workplan(s) and analysis schedule/deliverables; 

2009 - improve and/or develop emissions data, conduct monitoring data analysis, and 

begin meteorological, emissions, and air quality modeling preparations; 

2010 - assess model performance, refine base year and projection base case inventories; 

2011 - test emissions control scenarios, assess and begin SIP process; and 

2012 - provide regional technical support for adopting controls in individual SIPs. 

Figure 6. Distribution of Proposed Future Funding Needs (2009-12) for regional technical 

analyses for NAAQS, mercury, deposition, and climate issues.

$0

$100,000

$200,000

$300,000

$400,000

$500,000

$600,000

$700,000

$800,000

$900,000

2008 2009 2010 2011 2012

Costs

Technical Support System Regional Modeling Center

Emissions Data Management System Emissions Projects1

Monitoring Data Analysis1 Staff + Project Management

Technical Data/Analysis Support subtotal

1- the costs and effort to be applied to the Emissions and Monitoring projects are scaleable for any particular year; usually these are done earlier in 

the multi-year sequence to support emissions and air quality modeling for Ozone and PM NAAQS, Mercury, and other pollutants. 
2008-12 WRAP Strategic Plan March 2008

 20

C. Assessing air quality impacts of changes in energy supply and use and in the activities of 

 sources of greenhouse gas emissions 

Climate change management and adaptation activities continue at a rapid pace in the West. The 

WRAP Board has directed the development of greenhouse gas emissions inventories for the WRAP 

region, available at: http://wrapair.org/WRAP/ClimateChange/index.html. Members of The Climate 

Registry currently include 39 states in the U.S., 3 tribes, 2 states in Mexico, and 7 provinces in 

Canada; The Climate Registry provides standard protocols for participants to use in reporting and 

tracking greenhouse gas emissions. The Western Climate Initiative is developing emissions reduction 

targets for its members. Employing the one-atmosphere analysis approach suggested in the previous 

section to support state and tribal air pollution emissions control decisions to achieve health and 

welfare standards as well as aesthetic goals codified in the federal Clean Air Act, will require 

integration of the efforts to mitigate and adapt to the effects of climate change.

The air pollution emissions inventory data collection and reporting projects for 2009-12 will assess 

the following effects on air pollution emissions related to climate change: 

• Changes in the fuels used to generate electricity and power the transportation sector; 

• Modifications to emissions rates from air pollution sources; 

• New and modified operating protocols for air pollution sources; 

• Mitigation strategies to reduce greenhouse gas emissions; 

• Adaptation strategies related to air pollution sources affecting air quality in the West; and 

• International sources of air pollution. 

The regional air quality modeling and data analysis projects for 2009-12 will assess the following 

effects on air pollution impacts related to climate change: 

• Effects on implementation of controls and reasonable progress goals for regional haze; 

• Changes in the understanding of the source types and regions contributing to regional haze, Ozone 

and PM NAAQS attainment, and critical loads related to mercury and nitrogen deposition; 

• Contributions from new electrical energy generation and transportation fuels sources; 

• Contributions from modified operations of existing air pollution sources; 

• Mitigation strategies to reduce greenhouse gas emissions; 

• Adaptation strategies related to air pollution sources affecting air quality in the West; 

• International and intercontinental transport of air pollution; and 

• Changes in the climate for future air quality projections. 
2008-12 WRAP Strategic Plan March 2008

 21

Appendix A: Status of Partners’ Priorities and Findings of the WRAP Board 

Tribal Caucus findings and priorities - September 2006 WRAP Board Meeting 

Perspective on Partnership

• The WRAP partners have facilitated many successful dialogues on air quality issues important 

to Western tribes. 

• Shared experiences and exchange of cultural values have enhanced air quality efforts by states 

and tribes to develop regulatory programs and strategies that benefit the environment and solve 

problems for both tribes and states 

Needed Technical Studies 

• Transport/characterization/impacts of PM in rural communities 

• PM health impacts and risk analysis 

• Dust emissions and air quality modeling 

• Climate change – emissions inventories 

• Oil and gas development and production emissions 

• Atmospheric deposition – mercury and sulfur/nitrogen 

• PSD consumption – systematic tracking and management 

• Tribal emissions and air quality data 

• Ozone – especially rural areas 

National Park Service priorities and findings - March 2007 WRAP Board meeting

 

• Ongoing technical support to assist in regional haze program implementation (IMPROVE 

reasonable progress monitoring and tracking) 

• Rural ozone 

• Critical Loads for air, water, soil, and ecosystems: 

o Nitrate deposition 

o Ammonia emissions and sources 

• International transport (especially toxic and heavy metal pollutants from Asia) 

• Trust and cooperation among the WRAP members and stakeholders and with the WRAP 

process is well-established 

State Caucus/WESTAR Survey findings and priorities - June 2007 

Regional Haze Implementation Support: 

• Provide emissions and modeling analyses support for SIP Reasonable Progress Goals

• Facilitate issue resolution from EPA review of submitted SIPs

• Provide venues for and facilitate interstate communications and meetings as needed

• Provide technical support for qualified users of TSS and the data nodes (EDMS, VIEWS, 

FETS CoHA, RMC, etc.)

• Compile updated emissions, monitoring data for tracking reasonable progress

• Test and refine fire tracking system
2008-12 WRAP Strategic Plan March 2008

 22

• Maintain minimum capability for supplemental analyses needed for SIP issue resolution and 

TSS maintenance, including contract support

• Continue to manage annual SO2 milestone reports for §309 states

• Develop technical framework for 5-year review-including status of control strategy 

implementations

Analyses for other air program management priorities:

• Identify gaps in technical understanding of pollutant transport in the west-as needed to meet 

planning and regulatory requirements

• Provide venues for and facilitate peer-to-peer and stakeholder communications and meetings 

to prioritize issues and develop regional approaches

• Within resource availability, develop or adapt existing WRAP tools to raise level of 

understanding for application to planning and regulatory requirements

• Undertake joint project with other organizations to assess opportunities for improving 

efficiencies of (state, tribal) staff and avoiding duplicative efforts

WRAP Board findings - March 2007 meeting 

• Board strongly supports the continuation of WRAP technical and planning support and 

broadening work beyond haze to include climate change and other regional air quality issues. 

• Sufficient funds in hand to maintain essential services and support of haze plan 

implementation through 2008. 

• Anticipate some FY08 EPA funding (for 2009 work). 

• WRAP Board as a whole shares concerns and priorities articulated by tribes and FLMs, with 

an emphasis on health effects from PM. 
2008-12 WRAP Strategic Plan March 2008

 23

Appendix B: WRAP Technical Data and Decision Support Systems 

Technical Data Support Centers 

Visibility Information Exchange Web System: VIEWS provides on-line access to monitoring 

data, research results and special studies related to visibility. 

Causes of Haze Assessment: A detailed analysis of ambient monitoring data for regional haze in 

the WRAP region. 

Fire Emissions Tracking System: FETS is a database with a web interface for tracking and 

managing planned and unplanned fire events. Users can view fire data on-screen with a mapping 

tool and query the database for downloads of data. 

Regional Modeling Center: The WRAP’s Regional Modeling Center at the University of 

California Riverside provides state and tribal agencies with sophisticated modeling of regional 

haze and other air quality parameters in the Western United States. 

Emissions Data Management System: An emission inventory data warehouse for states and 

tribes. The system provides a consistent, complete and regional approach to emissions data 

management and tracking. 

Technical Decision Support System 

The Technical Support System integrates a number of different data support resources under one 

web-based decision support umbrella for regional haze planning and implementation, with planned 

extension to other pollutants/air management issues. 
2008-12 WRAP Strategic Plan March 2008

 24

Appendix C: Preliminary 2009-12 Budget (no additional CY08 funds are anticipated) 

Cost estimates are presented for the 5 major work areas and staffing/meetings/project operations for a 

“Basic Effort” – implementing the regional haze plans, and a “Value-added Effort” – additional data 

collection, analysis, and studies for assessing the regional contribution to the Ozone and PM NAAQS, 

mercury and acid deposition, and other topics as resources allow. 

WRAP Annual Costs* 

Major Work Areas 

Basic Effort – 

Costs to Implement 

Haze Plans 

Value-added Effort – 

Incremental Costs 

Beyond Haze to Address 

Regional Air Quality 

Analysis Priorities 

Comprehensive 

Regional Effort 

Technical Support System (haze 

implementation, includes IMPROVE 

monitoring data [VIEWS] and fire 

emissions tracking [FETS]) 

375,000 200,000 

Regional Modeling Center (followup 

haze questions and studies of other 

pollutants) 

350,000 250,000 

Emissions Data Management System

(tracking for all pollutants reported by 

states and tribes) 

200,000 125,000 

Emissions Projects (studies to fix 

incomplete data) 250,000 200,000 

Monitoring Data Analysis (haze and 

beyond in concert with RMC studies) 150,000 175,000 

Enables support 

for sub-regional 

and local studies to 

be available on a 

prioritized basis

Technical Data/Analysis Support subtotal 1,325,000 950,000 

Staff + Project Management (travel, 

meetings, overhead, etc.) 650,000 ----0---- 

Total $1,975,000 $950,000 $2,925,000

* NTEC funding proposal separate, see Appendix E 

Technical Support System

• Basic effort - annual cost estimate $375,000 – continue haze implementation support through 

technical decision support work 

– Analysis/display of answers to EPA questions for plan approval 

– Display/storage of analyses/results from haze planning 

– Ongoing monitoring data from IMPROVE 

– Periodic EI summary and analysis for SIP trends using data from states (2005, 2008, 

2011), as well as display of regional EI trends for natural and uncontrollable emissions 

• Value-added effort – further analysis of haze technical data and analysis/display of data for other 

air quality issues, $200,000 if funded 
2008-12 WRAP Strategic Plan March 2008

 25

Regional Modeling Center

• Basic effort - annual cost estimate $350,000 – continue haze implementation support through 

regional modeling studies 

– Emissions/modeling analysis of EPA questions for plan approval 

– Modeling sensitivity studies for potential additional control strategies and source 

apportionment studies for potential additional control strategies for reasonable progress 

– Modeling studies and ana states/tribes (2005, 2008, 2011) 

– Preparation/training/transfer of modeling data te/tribal/FLM use 

• Value-added effort - emissions/mo of re to O

NAAQS issues and modeling st f

lysis of periodic EIs from

 inputs/results for sta

gional contribution

uality issues, $250,000 i

deling studies 

udies for other air q

zone and PM 

 funded 

Emissions Data Management System

• Basic effort - annual cost es

analysis 

timate $200,000 – continue haze emissions data tracking, storage, and 

nd analysis - periodic EIs from states/tribes (2005, 2008, 2011) 

nswers to EPA ns for plan appr

ue-added effort - further analysis of haze emissions data for other air qua

 study of other pollutants, $125,000 if funded

rojects

– Emissions tracking/tre

– Analysis/display of a

• Val

 questio oval 

lity issues and 

identify gaps in emissions for

Emissions P

• Basic effort - annual cost estimate $250,00 ent, and 

EPA questions approval 

Studies to correct incomplete/inaccurate data 

rollable s to support tren 

 gaps in EIs fo ir quality studie dy of other related 

000 annually if funded 

0 – continue haze EI improvement, developm

analysis 

– Develop answers to 

–

 for plan

– Augment natural/uncont ources EIs d analysis

• Value-added effort - address

pollutants, $200,

r other a s and stu

Monitoring Data Analysis

• Basic effort - annual cost estimate $150,000 – continue haze monitoring data analysis 

of answers to EPA questions for plan approval 

PROVE monitoring data and network adequacy 

n 

– Analysis/display 

– Assess ongoing IM

• Value-added effort - further analysis of haze technical data for other air quality issues and begi

new analysis of monitoring data for other air quality issues, $175,000 annually if funded 
2008-12 WRAP Strategic Plan March 2008

 26

Appendix D: Current List of Technical Air Quality Studies Using WRAP Data 

• Rocky Mountain National Park Sulfur and Nitrogen Study (RoMANS) – National Park Service

and State of Colorado 

• Rur O study 

• Rur O

Wyom

• s WG 

 4 Corners region – 4CAQTF Mitigation Modeling group 

•

Dak

sible data for permit analyses by WRAP members, sources, and consulting firms 

al zone Impacts from Oil & Gas emissions in the 4 Corners Region – NPS modeling

al zone Impacts from Oil & Gas in northeast UT/southwest WY – States of Utah and 

ing 

Emissions reductions options analysis – 4 Corners AQ Task Force Cumulative Effect

• Sub-regional air quality modeling in

• Pilot Dust Regional Haze SIP for Salt Creek Wilderness – State of New Mexico 

Nested BART CalPuff modeling using regional modeling data as background – State of North

ota 

• 2018 emissions projections as basis for Columbia Gorge air quality planning 

• Consistent, acces
2008-12 WRAP Strategic Plan March 2008

 27

 Tribal Implementation Plan (TIP) Development 

Appendix E: Support of Tribal Air Quality Management Capability and 

++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ 

National Tribal Environmental Council Workplan Proposal 

Continued Support for Tribal Participation in the Western Regional Air Partnership 

January 1, 2009 – December 31, 2012 

4-year budget proposal total $1,986,346 for 2009 through 2012 

Introduction/Background

The National Tribal Environmental Council (NTEC) was established in 1991 as a membership 

organization dedicated to assisting tribes in the protection and preservation of their homelands. NTEC 

supports tribal governments in their efforts to protect, regulate and manage their resources according to 

their respective priorities and values. NTEC has grown from its seven founding tribes to a current 

membership of more than one hundred eighty tribes. 

In accordance with this mission, and the included goal of assisting tribes in working with federal and state 

environmental agencies, NTEC has facilitated tribal participation in the Western Regional Air Partnership 

(WRAP), and its predecessor, the Grand Canyon Visibility Transport Commission (GCVTC), since 1994. 

Through these efforts, NTEC has helped western tribes establish the WRAP as a unique and innovative 

approach to state, tribal, federal and stakeholder collaboration to meet environmental objectives. 
2008-12 WRAP Strategic Plan March 2008

 28

The WRAP co ample for 

tribal participation. The W cal issues as they relate to 

the development and submission of regional haze implementation plans. To advance this effort and 

provide the necessary management and resources to tribes, NTEC relies on the following professional and 

competent team of individuals whose time is either partially or wholly devoted to the WRAP: WRAP CoDirector, Tribal Caucus Coordinator, Senior Policy Analyst, and an Administrative Assistant. NTEC also 

provides for travel assistance for tribal involvement at WRAP-related meetings, trainings and 

conferences. 

The Confederated Salish and Kootenai Tribes and its designated representative, Councilman Lloyd Irvine 

currently serves as Tribal Co-Chair of the WRAP. With its present staffing, NTEC manages its WRAP 

efforts with oversight and direction from the WRAP Tribal Caucus and as presented to the WRAP Board. 

The WRAP Board has determined that those issues identified by the Tribal partners (Tribal Caucus) will 

be incorporated into the WRAP mission and the scope of the future workplan. The tribes within the 

WRAP region continue to be committed to the organization’s efforts to expand the scope of the WRAP 

and will work closely with NTEC to assure that Tribal Implementation Plan (TIP) development and the 

tools which support such development remain a priority of the organization. 

This proposal is for a continuation of NTEC’s efforts to facilitate tribal participation in the WRAP. The 

proposal is organized by position functions (WRAP Co-Director, Tribal Caucus Coordinator, Senior 

Policy Analyst, and Administrative Assistant) and a distinct section for travel. Under each position 

function is a series of target periods for holding meetings and completing documents that fall within the 

purview of NTEC staff to complete in a timely and professional manner. 

I. WRAP Co-Director (Lewis McLeod)

ntinues to lead the nation in regional haze planning efforts, and in setting an ex

RAP continues to move forward on policy and techni

 

 A. Description 

NTEC is identified in the WRAP By-Laws and workplans as co-manager of the WRAP project, 

administrative

• Providing appropriate signed to the WRAP grant at 

NTEC (e

tual work associated with the WRAP grant such as that associated with ITEP 

issions Inventory Software Solution Project; 

from the 

along with the Western Governors’ Association (WGA). This co-management role at NTEC is 

accomplished through the efforts of a WRAP Co-Director who handles the day-to-day 

 tasks associated with the WRAP grant such as: 

 supervisory support to staff members as

.g., Tribal Caucus Coordinator, Administrative Assistant); 

• Managing contrac

and the Tribal Em

• Overseeing the WRAP grant, budget, and workplan for NTEC, gathering comments 

Tribal Caucus as necessary and incorporating them into NTEC projects and deliverables as 

appropriate; 

• Engaging in WRAP grant management activities such as grant analysis, ensuring compliance

with relevant grant provisions and regulations, submitting progress reports, and meeting 

reporting deadlines; 

• Working collaboratively with tribal leaders and representatives regarding air quality issues 

related to regional haze and other issues deemed appropriate by the WRAP Board and helping 

these members come to consensus on matters of concern; and 

• Utilizing existing research and analysis to draft position papers on a vast range of regional 

haze, and air quality issues. 
2008-12 WRAP Strategic Plan March 2008

 29

ect 

gular participation in committee, forum and workgroup meetings; 

• Assist in agenda development for WRAP annual/mid-year, planning team, and other key 

ment Work Group 

meeting with NTEC WRAP staff to discuss relevant 

d schedule, at the pleasure of the WRAP Tribal Co-Chair and Tribal Caucus,

letter as 

Eff

Up

con

c

While the WGA administers the majority of WRAP funds in support of states and stakeholders, 

and handles most logistical functions for these entities, NTEC works closely with WGA and 

facilitates all travel of tribal representatives to insure tribal participation is equal in every resp

as noted below: 

• Coordinate tribal participation in WRAP budget development for Calendar Years 2009 and 

beyond; 

• Re

meetings; 

• Coordinate tribal participation in WRAP entities; 

• Assist in matching interested individuals with appropriate committees, forums and 

workgroups; 

• Facilitate communication between the Tribal Caucus and tribal participants on various 

committees, forums and workgroups; and 

• Provide specialized assistance to the WRAP Board, Initiatives and Technical Oversight 

Committees, Technical Advisory Forum, the Tribal Data Develop

(TDDWG), and joint forums of the organization. 

 B. Regular Deliverables and/or Products 

In addition to the aforementioned activities, the WRAP Co-Director shall provide the specific 

deliverables and/or products on a regular basis: 

• Coordinate and schedule a monthly 

issues; 

• Coordinate an

conference calls with tribal leaders of the WRAP Board or their representatives, and record 

and distribute meeting minutes within two weeks of a meeting; 

• Draft and submit news pieces for the monthly WRAP Tribal News; 

• Draft and submit a WRAP article for the NTEC newsletter or NTEC Insights News

requested; and 

• Complete an annual report regarding WRAP activities undertaken, to be submitted to the 

WRAP project officer located in the Region 9 U.S. Environmental Protection Agency (EPA) 

Office. 

C. Contract Management 

ective July 1, 2006, the WRAP Co-Director assumed contract management oversight of 

projects initiated by the TDDWG in accordance with federal rules, regulations and guidelines; 

NTEC internal guidelines; and additional oversight provided by NTEC’s Business Manager. 

on completion of a scope of work by members of the TDDWG, NTEC will develop and 

distribute Request for Proposals (RFPs) to appropriate entities, oversee the bidding and review 

process, work closely with members of the TDDWG in negotiating contracts with selected 

tractors, and pay invoices to contractors as contract deliverables are met properly and timely in 

ac ordance with the signed contracts between NTEC and said contractors, and based on a 

determination made by TDDWG members. Anticipated projects are as follows: 
2008-12 WRAP Strategic Plan March 2008

 30

 maintain a tribal air emissions inventory database for tribes to access for 

evaluating impacts to tribal lands as a result of State Implementation Plans (SIPs), 

tabase thereby insuring 

 to tribal air quality organizations and other 

ds. 

Ob ng 

 specific information that a tribe can use to 

ting them, as the technical basis for a TIP, or as 

 negotiating a FIP with the EPA. 

in 

ons involved in producing oil and gas on tribal 

on 

Go e to encourage tribes to gather their emissions inventory data to include 

System (EDMS) and modeling tools. 

imary objectives: 

l 

TW 1: Provide the avenue to maintain the TEISS License through the Institute for 

Tribal Environmental Professionals (ITEP)

 

Goal: To

Federal Implementation Plans (FIPs) or Tribal Implementation Plans (TIPs). 

Objective: To increase the number of tribes with information in the da

that tribal data gaps are minimized. 

Deliverables: The continued availability of the TEISS

authorized entities. 

TW2: An Oil & Gas Project to fully explore Tribal analysis 

Goal: To provide a more comprehensive database of oil & gas activities on tribal lan

jective: To assist tribes in accessing the updated emissions inventories and modeli

results, the contractor will be providing

identify sources that may be impac

part of their knowledge base when

Deliverables: Reports on the results of the project which will produce a list of tribes involved 

oil and gas activity and the emissi

lands. 

Contractor will include findings on limitations of the data and also suggest 

improvements in the models and data that will better serve tribes. This informati

will be summarized in quarterly reports and a comprehensive final report. 

TW3: Tribal Emissions Inventory Project

al: To continu

other emissions not considered criteria pollutants, i.e., carbon dioxide, Ammonia 

and to make that data available for the WRAP’s Emissions Data Management 

Objective: This project has 4 pr

1. Keep Tribal Emissions Inventory Software Solution (TEISS) license current 

2. Provide TEISS training for tribal representatives, both new and advanced users 

3. Provide technical assistance for TEISS users 

4. Reconcile the tribal data with state and county data to ensure accurate regiona

emissions inventories 

Deliverables: One training and continued technical support as tribes deem necessary. 

TW4 Other projects to parallel WRAP Projects as needed. 
2008-12 WRAP Strategic Plan March 2008

 31

DDWG will evaluate/analyze 

 the Tribal Caucus what tribal projects should be 

II. Tribal Caucu

 The goals, objectives and deliverables of this task cannot be defined at this 

time. As WRAP Projects are developed the T

them and determine through

undertaken. 

s Coordinator (Ken Cronin)

he Tribal Caucus Coordinator will work to ensure that tribal participants in the WRAP are 

decisions of th , rums and workgroups. 

ct development on a 

ontinual basis through: 

Regular participation in committee, forum and workgroup meetings, or similar participation on 

• Ongoing co

Coordinato

• Communic tribal 

• Monitoring

work perfo the committees, forums and workgroups themselves. 

 

The Tribal Cau

issues of poten

appropriate me

ations, o

l Cau

ction

meeting. Thro

Caucus Coordi nd 

on-visibility i the WRAP.

Identify a

Provide a ucus on a monthly basis concerning activities of WRAP 

tribute 

ft and

A. Description 

T

continuously informed of the processes, schedules, issues, budgets, proposals, work products and 

e WRAP committees fo

The Tribal Caucus Coordinator will track WRAP issues and work produ

c

•

conference calls of such entities; 

mmunication with the WRAP staff including such individuals as the State Caucus 

r and Technical Coordinator; 

ation as necessary with committee, forum and workgroup co-chairs, 

participants, and other people involved with the WRAP; and 

 of forum progress, including RFP development, contracted work products, and 

rmed by

cus Coordinator will synthesize and summarize the information obtained, highlight 

tial concern to tribes, and disseminate this information to the Tribal Caucus through 

ans such as conference calls, newsletters, e-mail, memoranda, in-person 

present r other mechanisms as appropriate. 

The Triba cus Coordinator will also arrange, plan and facilitate face-to-face meetings, either 

in conjun with meetings of the Air Managers Committee, WRAP Board, or as a stand-alone 

ugh meetings such as this along with other means of communication, the Tribal 

nator will assist the Tribal Caucus in identifying and developing any visibility a

n ssues the Caucus may wish to bring to

B. Regular Deliverables and/or Products 

In addition to the aforementioned activities, the Tribal Caucus Coordinator will provide the 

specific deliverables and/or products on a regular basis: 

• nd use existing communication and dissemination outlets on a bi-weekly basis;

• report to the Tribal Ca

committees, forums and workgroups as activities warrant;

• Schedule and conduct monthly Tribal Caucus conference calls, and record and dis

meeting minutes within one week of the meeting; 

• Dra produce the WRAP Tribal Newsletter monthly; 
2008-12 WRAP Strategic Plan March 2008

 32

Attend q o 

weeks of

• Organize

concerning WRAP activities and other outdoor air-related issues. 

bles and/or Products for 2009-2012 

tor will be engaged in the following activities during the specified 

period that will lead to the following deliverables and/or products: 

Tribal involvement within the WRAP activities has been sporadic due to a number of reasons such 

t 

essarily a priority for tribes, etc. With the new direction of WRAP, a new 

effort by the Tribal Caucus Coordinator will develop a new recruitment strategy document that 

mo tatives as a whole. 

2. Workshop (To Be Held During May - August of 

The dule a tribal policy and technical 

e

nce of Visibility; 

• Monitoring; 

re than 50 tribal representatives attending. 

 those previously in attendance during the 

III. 

• uarterly TDDWG meetings, and record and distribute meeting minutes within tw

 the meeting; and 

, coordinate and oversee a yearly meeting and/or workshop for WRAP Tribes 

C. Specific Calendar Year for Delivera

The Tribal Caucus Coordina

1. Recruitment Strategy Document 

as other priorities facing tribes, lack of resources available to attend meetings, and the fact tha

Regional Haze is not nec

will be used as both a means to attract tribal representatives to the activities of the WRAP and to 

nitor involvement of such represen

WRAP Tribal Policy and Technical

each calendar year) 

 Tribal Caucus Coordinator will develop, coordinate, and sche

me ting that covers some of the following topics: 

• Scie

• Connection between Science of Visibility and Climate Change; 

• Road and Windblown Dust; 

• Emission Inventories; 

• Modeling; 

• Tribally-focused WRAP products; 

• Tribal-specific issues (e.g., severability); 

• Special topics related to regional haze, rural ozone, etc; and 

• Specific WRAP Forum Products. 

 

A workshop was held during fall of 2006 with mo

NTEC staff hopes to attract a number greater than

upcoming calendar years.

Senior Policy Analyst (Bob Gruenig)

 

e

y 

aly m time to time through such 

other issues for which NTEC can 

A. Description 

Som issues originating in the WRAP require more detailed analysis and research, in addition to 

summarization. A number of these issues come up during the course of the year for which polic

an sis must be conducted reactively and will be mentioned fro

communication venues as the WRAP Tribal News, but there are 
2008-12 WRAP Strategic Plan March 2008

 33

while ess other issues as they arise. 

IV. Adm

address proactively. NTEC therefore proposes that it will devote its attention to policy issues 

 still being prepared to addr

inistrative Assistant

ge of attendance at a variety of 

meetings and conferences to advertise and recruit for the WRAP, and conducts e-mail and 

ruiting and input (tribal comment) needs.

re 

The Administrative Assistant will provide the specific deliverables and/or products on a regular 

is: 

Send out a monthly e-mail and/or fax message concerning upcoming WRAP meetings and 

 when appropriate) information pieces over the 

WRAP list

ly basis the WRAP Tribal News, a publication dedicated to keeping 

t are relevant to tribes; 

staff for involvement on air quality initiatives by conducting 

ublish and distribute new WRAP recruitment handouts as they are developed by 

ther staff;

s fact sheets and brochures; 

rector; and 

 A. Description 

To a significant degree, outreach is an inherent part of all NTEC staff activities related to the 

WRAP. Staff including the Administrative Assistant takes advanta

telephone outreach on a regular basis to meet rec

Because of the breadth and complexity of WRAP issues, and the time and effort required of staff 

to keep up with issues internally, there is a continued need for assistance in order to provide mo

continuous, systematic and persistent outreach to tribes throughout the region. 

B. Regular Deliverables and/or Products 

bas

•

whom to contact; 

• Work with the WGA in providing monthly (or

serv; 

• Distribute on a month

tribes updated about activities taking place within the WRAP tha

• Recruit tribal environmental 

targeted outreach; 

• Redesign, p

the Co-Director or o

• Distribute promotional items such a

• Attend meetings as assigned by the Co-Di

• Staff exhibit booths at regional and national conferences. 

V. Travel

Travel support is an integral element of NTEC’s workplan that allows staff members and tribal 

RAP-related activities. Due to this, the following trips 

gement: 

A. Description 

representatives to effectively engage in W

are expected in order to enable this effective enga

 B. Staff 

This item is to cover staff travel to WRAP meetings and other regional haze related meetings. See

attached budget for funding details.
2008-12 WRAP Strategic Plan March 2008

 34

enior Policy Analyst 12 trips 

 12 trips 

ives 

p 

ecame 

ee 

attached budget for funding details. 

D. Regional Haze and other WRAP-Related Travel 

From time to time, meetings come up whose subject matter is related to regional haze and other 

le has been the Prevention of Significant Deterioration meetings previously held and 

expected to be held once again by the Western States Air Resources Council. In addition, some 

acc vel to such meetings, a portion of the NTEC grant will be set-aside for such 

WRAP Co-Director 60 trips 

Tribal Caucus Coordinator 52 trips 

S

Administrative Assistant 

 

 C. Tribal Representat

This item is to cover travel of tribal representatives attending committee, forum, and workgrou

meetings. This item also supports speakers who present on regional haze and other WRAP related 

issues at NTEC’s annual conference and similar meetings. Effective July 1, 2006, NTEC b

responsible for reimbursing all such expenses associated with tribal representative travel. S

Tribal Travel 200 trips 

WRAP-related issues necessitate tribal participation in order to protect tribal interests. One 

examp

travel resources may be needed for upcoming Inter-RPO Tribal Workgroup meetings. To 

ommodate tribal tra

a purpose. See attached budget for funding details. 

Related Travel for Tribal Staff 30 trips