REPORT OF THE 

 GRAND CANYON VISIBILITY TRANSPORT COMMISSION 

 TO THE UNITED STATES 

 ENVIRONMENTAL PROTECTION AGENCY 

 June 1996 
 1

 EXECUTIVE SUMMARY

The Colorado Plateau's national parks and wilderness areas provide a unique, panoramic 

visual experience for people from around the world. This experience depends on 

maintaining high visual air quality in the region, which is threatened by haze resulting from 

projected growth over the next fifty years. Congress has set a national goal of remedying 

existing human-caused visibility impairment, and preventing future impairment, at these 

national parks and wilderness areas. Congress recognized that not all haze is humancaused and that haze is a regional issue. Congress created the Grand Canyon Visibility 

Transport Commission in 1991 to advise the U.S. Environmental Protection Agency on 

strategies for protecting visual air quality at national parks and wilderness areas on the 

Colorado Plateau. The Commission established a Public Advisory Committee (PAC) to 

obtain broad input as it formulated these strategies. 

The Commission conducted an extensive review of scientific, technical, and other 

information with assistance from a range of governmental, business, tribal, and 

environmental interests. It developed more comprehensive databases, and new computer 

modules to analyze these data and model future air quality. The Commission significantly 

advanced understanding of regional haze, but limitations and uncertainties remain. Based 

on that information and its own deliberations, the PAC developed a set of emissions 

management recommendations for the Commission with a full understanding of progress 

and limitations in available knowledge. These recommendations are aimed at protecting 

clear days and reducing dirty days at national parks and wilderness areas on the Colorado 

Plateau. Following a series of public meetings in April 1996, the PAC and Operations 

Committee conducted a final review and approval of these recommendations and 

forwarded them to the Commission for action. The Commission formally considered the 

PAC and Operations Committee reports on June 10, 1996 and approved them as the 

Commissions report to the Environmental Protection Agency. The EPA should use the 

Commission's recommendations as guidance for developing national strategies and/or 

rulemaking. Implementation of all specific program components will remain the 

responsibility of tribes, states and their political subdivisions, and, in some cases, federal 

agencies. 

Some of the Commission's recommendations ask the EPA to take specific actions or 

institute particular programs, in cooperation with the tribes, states and federal agencies as 

implementing bodies. Other recommendations provide a range of potential policy or 

strategy options for consideration by the EPA and implementing entities. As the EPA 

develops policies and takes actions based on this report, this distinction between "actions" 

and "options" should be maintained with diligence. That is, recommendations intended as 

policy options should not become mandated actions or regulatory programs. 

The primary recommendations include: 

·Air Pollution Prevention. Air pollution prevention and reduction of per capita pollution is a 

high priority for the Commission. The Commission recommends policies based on 

energy conservation, increased energy efficiency and promotion of the use of renewable 
 2

resources for energy production. 

·Clean Air Corridors. Clean air corridors are key sources of clear air at Class I areas, and 

the Commission recommends careful tracking of emissions growth that may affect air 

quality in these corridors. 

·Stationary Sources. For stationary sources, the Commission recommends closely 

monitoring the impacts of current requirements under the Clean Air Act and ongoing 

source attribution studies. Regional targets for SO2 emissions from stationary sources 

will be set, starting in 2000. If these targets are exceeded, this would trigger a regulatory 

program, probably including a regional cap and market-based trading. During the next 

year, participants in the Commission's process will develop a detailed plan for an 

emissions cap and market trading program. 

·Areas In And Near Parks. The Commission's research and modeling show that a host of 

identified sources adjacent to parks and wilderness areas, including large urban areas, 

have significant visibility impacts. However, the Commission lacks sufficient data 

regarding the visibility impacts of emissions from some areas in and near parks and 

wilderness areas. In general, the models used by the Commission are not readily 

applicable to such areas. Pending further studies of these areas, the Commission 

recommends that local, state, tribal, federal, and private parties cooperatively develop 

strategies, expand data collection, and improve modeling for reducing or preventing 

visibility impairment in areas within and adjacent to parks and wilderness areas. 

·Mobile Sources. The Commission recognizes that mobile source emissions are projected 

to decrease through about 2005 due to improved control technologies. The Commission 

recommends capping emissions at the lowest level achieved and establishing a regional 

emissions budget, and also endorses national strategies aimed at further reducing 

tailpipe emissions, including the so-called 49-state low emission vehicle, or 49-state 

LEV. 

·Road Dust. The Commission's technical assessment indicates that road dust is a large 

contributor to visibility impairment on the Colorado Plateau. As such, it requires urgent 

attention. However, due to considerable skepticism regarding the modeled contribution 

of road dust to visibility impairment, the Commission recommends further study in order 

to resolve the uncertainties regarding both near-field and distant effects of road dust, 

prior to taking remedial action. Since this emissions source is potentially such a 

significant contributor, the Commission feels that it deserves high priority attention and, if 

warranted, additional emissions management actions. 

·Emissions from Mexico. Mexican sources are also shown to be significant contributors, 

particularly of SO2 emissions. However, data gaps and jurisdictional issues make this a 

difficult issue for the Commission to address directly. The Commission recommendations call for continued binational collaboration to work on this problem, as well as 

additional efforts to complete emissions inventories and increase monitoring capacities. 

These matters should receive high priority for regional and national action. 
 3

·Fire. The Commission recognizes that fire plays a significant role in visibility on the 

Plateau. In fact, land managers propose aggressive prescribed fire programs aimed at 

correcting the buildup of biomass due to decades of fire suppression. Therefore, 

prescribed fire and wildfire levels are projected to increase significantly during the 

studied period. The Commission recommends the implementation of programs to 

minimize emissions and visibility impacts from prescribed fire, as well as to educate the 

public. 

·Future Regional Coordinating Entity. Finally, the Commission believes there is a need 

for an entity like the Commission to oversee, promote, and support many of the 

recommendations in this report. To support that entity, the Commission has developed a 

set of recommendations addressing the future administrative, technical and funding 

needs of the Commission or a new regional entity and has asked the Operations 

Committee to complete detailed plans by September, 1996. The Commission strongly 

urges the EPA and Congress to provide funding for these vital functions and give them a 

priority reflective of the national importance of the Class I areas on the Colorado Plateau. 

To the maximum extent feasible, Commission recommendations calling for additional 

exploration and study, etc. (necessary for filling information gaps and for resolving certain 

policy issues) should be accomplished by the year 2000. Until such time as future 

organizational arrangements have been determined, all tasks which are not assigned to 

any particular existing entity should be performed by or under the auspices of the 

Operations Committee. 

The Commission believes that reasonable progress toward the national visibility goal is 

achieved to the extent that current Clean Air Act requirements, existing laws and 

regulations, and the Commission's recommendations result in a significant near-term 

decrease in emissions that contribute to visibility impairment and ensure long-term 

protection of visibility. For example by 2000-2010, pollutants from stationary and mobile 

sources are expected to be reduced by 30% from the 1990 levels.1

 

 

 1 Sulphur dioxide (SO2) for stationary sources and nitrogen oxides (NOx) and volatile organic 

compounds (VOC) for mobile sources.
 4
 5
 6

 TABLE OF CONTENTS

 

EXECUTIVE SUMMARY ....................................... i 

GLOSSARY ..................................... vii 

SECTION I: INTRODUCTION................................... 1 

SECTION II: PROCESS FOR DEVELOPING PAC RECOMMENDATIONS..... 5 

 

SECTION III: .......................EMISSION MANAGEMENT RECOMMENDATIONS

 Guiding Principles............................. 26 

 Air Pollution Prevention ...................... 28 

 Stationary Sources............................. 32 

 Mobile Sources................................. 38 

 Area Sources................................... 46 

 Clean Air Corridors............................ 51 

 Emissions Within and Near Class I Areas........ 53 

 Transboundary Emissions from Mexico............ 56 

 Future Scientific and Technical Needs ......... 59 

SECTION IV: TRIBAL PERSPECTIVES AND POSITIONS REGARDING 

 RECOMMENDATIONS................................ 66 

SECTION V: FUTURE ADMINISTRATIVE NEEDS.................... 74 

SECTION VI: ANALYSIS OF RECOMMENDATIONS ............... 78 
 7
 8

GLOSSARY OF TERMS USED IN THIS REPORT

Within each definition, terms defined elsewhere in this glossary 

are printed in italics. 

Aerosol: Solid particles or liquid droplets that are small enough to be suspended in the air. 

 Aerosols cause most of the light extinction responsible for haze on the Colorado 

Plateau. 

Area source: Many small sources of air pollution in which the contribution of each source 

is relatively small, but combined may be a significant source of air pollution. A city 

can be an area source (although large facilities within the city could release enough 

air pollution to warrant their analysis individually as a point source). 

BART: Best Available Retrofit Technology, a process under the CAA to evaluate the need 

and, if warranted, install the most effective pollution controls on an already existing 

air pollution source. 

BFS/Baseline Forecast Scenario: A computer model used by the Grand Canyon 

Visibility Transport Commission to estimate future haze-causing pollution and 

economics. The GCVTC based this scenario on current technologies, existing laws, 

and a variety of assumptions about how quickly various kinds of pollution sources 

will be retired and the type of facilities that will replace them. It is an extension of 

current policies, and allows comparisons with other air pollution management 

scenarios the GCVTC may propose. 

CAA/CAAA: The Clean Air Act, and the Clean Air Act Amendments. National air 

pollution control is based on the Clean Air Act, passed in 1970. Congress amended 

the Clean Air Act in 1977 (adding many visibility sections that the GCVTC is 

addressing), and in 1990 (when it required creation of the GCVTC, assigned tribal 

governments power under the CAA similar to those of the states). 

Class I site/area: In 1977, Congress identified 158 national parks, wilderness areas, 

international parks and other areas that were to receive the most stringent 

protection from increases in air pollution. It also set a visibility goal for these areas 

to protect them from future human-caused haze, and to eliminate existing humancaused haze, and required reasonable progress toward that goal. 

Colorado Plateau: A high, semi-arid tableland in southeast Utah, northern Arizona, 

northwest New Mexico, and western Colorado. The unique erosional forms of the 

Plateau are world famous. 

CNG: Compressed Natural Gas, a relatively clean-burning fossil fuel. 
 9

EC/OC: Elemental Carbon (such as soot, often the result of fire and diesel engines) and 

Organic Carbon (carbon combined with other elements to form complex 

compounds, often given off by plants and most human activities). 

Fine mass particulates: Aerosols that are smaller than 2.5 micrometers in diameter. (A 

micrometer is one millionth of a meter, a human hair is about 70 micrometers in 

diameter.) 

GCVTC: The Grand Canyon Visibility Transport Commission, composed of the governors 

of eight western states (AZ, CA, CO, NM, NV, OR, UT, WY), five tribes (Acoma, 

Hopi, Hualapai, Navajo), four federal land managers (Bureau of Land Management, 

U.S. Fish and Wildlife Service, U.S. Forest Service, National Park Service), the 

Columbia River Inter-Tribal Fish Commission, and the Environmental Protection 

Agency. The states and tribes vote, the other GCVTC members do not. The 

Commission was established to recommend methods to preserve and improve 

visibility on the Colorado Plateau. Congress required establishment of the GCVTC 

through the Clean Air Act Amendments of 1990. 

HC: Hydrocarbons. A group of chemicals containing hydrogen and carbon that often 

contribute to air pollution as OC's or VOC's. They are involved in forming ozone, 

and some hydrocarbons are toxic. Term often used interchangeably with VOCs. 

Hopi Point: An important air quality monitoring site on the South Rim of the Grand 

Canyon in Grand Canyon National Park. 

IAS: Integrated Assessment System, a computer model created by the GCVTC to 

generate information about future visibility and economic trends under a variety of 

pollution control scenarios. 

IMPROVE: Interagency Monitoring of Protected Visual Environments, a group of federal 

agencies using a common set of standards to monitor visibility across the United 

States. Other nations have also adopted portions or all of the IMPROVE monitoring 

techniques. 

Inverse megameters, Mm-1: A measurement unit used for light extinction, the higher the 

value, the hazier the air is. 

LEV/ZEV: Low Emission Vehicle/Zero Emission Vehicle, motor vehicle classifications 

referring to their tailpipe release of air pollution. Today's ZEV's are generally 

battery-powered, but may use hydrogen fuel cells and other energy sources in the 

future. 

Light extinction: The "loss" of light as it travels through the air. Light can be truly lost by 

being absorbed by gases and aerosols in the air. Light can also be "lost" as it 

scatters off gases and aerosols. 
 10

LNG: Liquefied Natural Gas, a relatively clean-burning fossil fuel. 

LPG: Liquefied Petroleum Gas, a relatively clean-burning fossil fuel such as propane. 

Mm-1: Inverse megameters, a measurement unit used for light extinction, the higher the 

value, the hazier the air is. 

MMA: Maximum Management Alternative, an IAS computer model used to estimate the 

maximum visibility improvements possible regardless of the cost of the pollution 

controls used. The MMA was used for comparisons, rather than as a policy option. 

Mobile source: A pollution source that moves. Mobile sources are often divided into road 

sources, including cars, trucks, buses, and motorcycles, and non-road sources like 

trains, planes, boats, lawnmowers, etc. 

Modeling: The use of a computer to mimic reality and predict the future behavior of the 

subject under study. Models of complex subjects like visibility are often limited by 

the raw data available and the capacity of the computer itself. The GCVTC's IAS is 

a computer model of regional air quality for the Colorado Plateau and uses 

information from throughout western North America. 

NAAQS: National Ambient Air Quality Standards, levels of air pollution set by the U.S. 

Environmental Protection Agency to protect public health and welfare. Standards 

are set for ozone (O3), carbon monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide 

(NO2), lead (Pb), and particulates (solid aerosols). 

Non-attainment area: A geographic region where concentrations of a particular air 

pollutant exceed the NAAQS. A particular location may be non-attainment for more 

than one pollutant. 

NOx: A mixture of nitrogen dioxide and other nitrogen oxide gases. Nitrogen is the most 

common gas in the atmosphere. In high temperature and/or high pressure burning 

(as in an engine), the air's nitrogen is broken down and combined with oxygen, 

forming unstable or reactive NOx gases. Nitrogen dioxide (NO2) is yellowish brown, 

and thus contributes directly to haze. All the NOx gases react in the air to form 

haze-causing aerosols and smog. 

NPS: National Park Service, a federal agency charged with protecting the natural and 

cultural resources and the processes that create and sustain them, in the National 

Park System. 

New Source Review: A review of a new facility that has the potential to emit air pollutants 

in amounts specified by law. The review is done to establish the impact of the 

pollution, and the options available to control that pollution. 
 11

OC: Organic Carbon, complex carbon-containing compounds often emitted by plants and 

many human activities. OC2.5 is organic carbon of 2.5 micrometers of less. 

PAC: Public Advisory Committee, established by the GCVTC to represent a broad range 

of public interests. Members are drawn from all levels of government, business, 

industry, environmental organizations, academia, and private citizens. The GCVTC

Commissioners charged the PAC with developing consensus recommendations for 

managing visibility. 

Particulates: Solid material small enough to remain suspended in the air. 

PM2.5: Aerosols with a diameter smaller than 2.5 micrometers, the most effective size 

range to create haze (a micrometer, or micron, is one millionth of a meter, an inch is 

25,400 micrometers long). 

PM10: Aerosols with a diameter smaller than 10 micrometers, on which the EPA has 

based current NAAQS. Larger aerosols in this size range (larger than 2.5 

micrometers) are less effective in creating haze than the smaller ones. In addition 

to creating haze, higher concentrations of PM10 can also cause irritation of the throat 

and lungs, cancers, and early death. 

Point source: A specific source of air pollution. 

Prescribed fire: Fires in wildland areas that are allowed to burn under prescribed 

conditions. The "prescription" reflects ecosystem management goals, ability to 

control the fire, and air quality concerns. 

Prescribed natural fire: A fire started by natural processes (usually lightning) and allowed 

to burn as long as it meets prescribed fire conditions. 

PSD: Prevention of Significant Deterioration. A program established under the Clean Air 

Act Amendments of 1977, whose goal is to prevent major increases in air pollution 

in areas with cleaner air. The program sets the tightest limits on pollution increases 

from large point sources in Class I areas. 

Rayleigh or Rayleigh Scattering: The natural scattering of light caused by nitrogen and 

oxygen in the atmosphere which makes the sky look blue. Also called "blue sky." 
 12

Reasonable progress: Reasonable progress refers to progress in reducing humancaused haze in Class I areas under the national visibility goal. The Clean Air Act

indicates that "reasonable" should consider the cost of reducing air pollution 

emissions, the time necessary, the energy and non-air quality environmental 

impacts of reducing emissions, and the remaining useful life of any existing air 

pollution source considered for these reductions. The GCVTC Public Advisory 

Committee has developed the following definition: "Reasonable progress towards 

the national visibility goal is achieving continuous emission reductions necessary to 

reduce existing impairment and attain steady improvement of visibility in mandatory 

Class I areas, and managing emissions growth so as to prevent perceptible 

degradation of clean air days." 

Re-entrained dust/road dust: Fine and coarse dust stirred up from paved or dirt surfaces 

by the passage of vehicles. The dust may include soil particles, tire rubber, soot, 

and other materials. 

Regional cap: A limit on the amount of specific air pollutants that can be released in a 

defined geographic area, or a limit on the amount of a specific air pollutant that is 

allowed to be in the air in a defined geographic area. 

ROG: Reactive Organic Gases, typically hydrocarbons (HC), but include oxygenated 

hydrocarbons. 

SIP/TIP: State Implementation Plan/Tribal Implementation Plan, plans devised by states 

and tribes to carry out their responsibilities under the Clean Air Act. SIP's and TIP's 

must be approved by the U.S. Environmental Protection Agency and include public 

review. 

SO2, SOx, sulfates: Compounds composed of oxygen and sulfur. Burning fuels, 

manufacturing paper, or smelting rock containing sulfur produces sulfur dioxide gas 

(SO2) which is converted in the air to other sulfur oxides (SOx) or haze-causing 

aerosols (sulfates). 

Source: Where air pollutants are released. Sources are usually classified as point, 

mobile, or area sources. 

Source attribution: Determining how much a single source contributes to air pollution. 

Stationary source: An air pollution source that remains in one place (generally a 

business or industrial facility). 

Species: A term used to refer to types of pollutants. 

TIP/SIP: Tribal Implementation Plan/State Implementation Plan, plans devised by states 

and tribes to meet requirements of the Clean Air Act as defined by the U.S. 

Environmental Protection Agency. 
 13

Trading program: In air quality management, a plan under which some limit is set on the 

amount of an air pollutant that can be released into the air. If a facility releases less 

than its limit, it may trade or sell the ability to release "unused" amount of air 

pollutant to another facility, so the second facility can release more than the limit. 

Transfer coefficient: In computer modeling of air quality, a geographic area is divided 

into "cells." Transfer coefficients are mathematical formulas that tell the computer 

how much air pollution to "move" from one cell to another. Determining a transfer 

coefficient requires the computer model designer to consider wind directions, 

chemical changes to the air pollutants as they travel, loss of pollutants from the air, 

and other factors. 

Transmissometer: A device that measures light extinction by shining a light beam of 

known brightness through the air and measuring how much is lost when the beam 

reaches a receiver, usually about 4 miles away. 

Urban plume/plume blight: An urban plume is the "cloud" (either visible or invisible) of air 

pollution blown downwind of an urban area. Plume blight is a distinct band or layer 

of visible air pollution, often from a single pollution source. 

Visibility impairment: The loss of clarity in the air that results when gases or aerosols

scatter and absorb light. We usually see visibility impairment as a general haze or a 

distinct plume. 

VMT: Vehicle Miles Traveled. This number is a measure of vehicle usage and is used to 

calculate the air pollution produced by mobile sources, such as passenger cars, 

tailpipe emissions and or road dust. 

VOC: Volatile Organic Compound. A carbon-containing material that evaporates, such as 

gasoline, some paints, solvents, dry cleaning fluids, and the like. VOC's contribute 

to ozone formation and may form OC aerosols. 
 1

 I. INTRODUCTION

The Colorado Plateau is a spectacular landscape of massive landforms, unique geology, 

and vivid colors. People from around the world have experienced these wonders at Grand 

Canyon, Canyonlands, Bryce Canyon, Zion, and other national parks and wilderness areas 

on the Plateau. The panorama is a visual experience, and air quality is the key to full 

enjoyment. On hazy days, when visibility is reduced, the human eye perceives a loss of 

color, contrast, and detail in the landscape. That loss of visibility diminishes the unique 

experience of nature's work on the Plateau. (See pictures at the end of this Section which 

illustrate variations in visibility at selected sites.) 

Visibility and visual air quality are daily issues for the inhabitants of the Colorado Plateau, 

including Indian tribes. They experience, on an almost daily basis, the variations in visibility 

at national parks on the Plateau. The Colorado Plateau has some of the best visual air 

quality in the United States. Paradoxically, this means that reduced visual air quality that 

might go unnoticed in other parts of the United States is starkly apparent on the Plateau. 

Visual air quality in the West is quite sensitive to relatively small increases in pollutants. 

Research shows that visual air quality in the West experienced a significant decline due to 

emissions from industrial activity from the 1940s to the 1970s. Visibility-impairing emissions 

began to decline in the 1970s following enactment of the federal Clear Air Act. Visual air 

quality at national parks and wilderness areas on the Colorado Plateau has not appeared 

to change since reliable monitoring data became available in the 1980s. However, all the 

projections point to continued population and economic growth in the region into the next 

century. This growth is a potential threat to air quality, and poses a challenge to states, 

tribes, and the federal government. 

The National Visibility Goal Under Federal Law

Congress set a national goal of remedying existing visibility impairment, and preventing 

future impairment, from manmade pollution at 158 national parks and wilderness areas 

across the United States as part of the Clean Air Act Amendments in 1977. This group 

includes sixteen parks and wilderness areas on the Colorado Plateau, as well as others in 

the Western United States. 

Congress adopted two main strategies to make progress towards the national visibility 

goal: Prevention of Significant Deterioration (PSD), which focuses on new or modified

major sources that exceed specified emission thresholds; and a Visibility Protection 

Program directed at existing sources of emissions that impair visibility. 
 2

1. The PSD Program

The PSD program designates three classes of areas, with those designated Class I having 

the most pristine air and receiving the greatest protection under the federal statute. 

Mandatory federal Class I areas include all national parks, all national wilderness areas 

and national memorial parks over 5,000 acres, and all national parks over 6,000 acres in 

existence in 1977. In addition, states and tribes can designate Class I areas. Most Class I 

areas are located west of the Mississippi River. 

Prior to either construction of a major new source or major modification of an existing 

source, the PSD program requires application to the Environmental Protection Agency 

(EPA) or the state for a permit. The permit is issued only if emissions from the new or 

modified major source will not exceed, or contribute to the exceeding of, maximum 

allowable increments under the CAA. 

2. The Visibility Protection Program

Under the Visibility Protection Program, states and tribes must demonstrate to the EPA in 

their State/Tribal Implementation Plans (SIPs/TIPs) that they will make "reasonable 

progress" toward achieving the national visibility goal established by Congress in 1977. 

The EPA issued its first regulations under the program in 1980. These regulations did not 

include a tribal component. The first explicit consideration of tribal lands with respect to air 

quality regulations occurred in the 1990 Amendments to the CAA. These regulations are 

known as plume blight regulations and focus on a source or small group of sources to 

which visibility impairment at a Class I area can be "reasonably attributed." The EPA 

regulations require such sources to adopt the best available retrofit technology, or BART, 

to reduce emissions reasonably attributed to them. 

The next phase of the EPA's regulations under the Visibility Protection Program focuses on 

widespread, regionally homogeneous haze from a multitude of sources that impairs 

visibility over a large area. These regulations are still under development. 

Regional Haze

Haze and visibility problems do not respect state and tribal boundaries. Congress 

addressed this issue when it amended the CAA again in 1990 and authorized the EPA to 

establish visibility transport regions as a way to combat regional haze. Congress also 

specifically ordered the EPA to establish a visibility transport region for Grand Canyon 

National Park, and to create a Grand Canyon Visibility Transport Commission (hereafter 

referred to as the GCVTC or the Commission). The EPA established the Commission in 

November 1991. 

Tribal Authority Under the Clean Air Act

Tribes have always had the inherent right to regulate air quality on tribal lands. Under the 

1990 Clean Air Act Amendments (CAAA), the EPA may delegate authority to Indian tribes 
 3

to regulate air quality. For example, tribes, like states, can prepare permitting programs 

under Title V of the CAAA, and establish Tribal Implementation Plans (TIPs) and submit 

those programs to the EPA for approval. Tribal regulation of air quality on the Colorado 

Plateau and across the Transport Region requires full consideration of tribal interests and 

the active participation of Indian tribes on the GCVTC. 
 4

The Commission's Mandate and Structure

The Grand Canyon visibility Transport Region includes nine states and 211 tribal lands2

. 

The states are: Arizona, California, Colorado, Idaho, Nevada, New 

Mexico, Oregon, Utah, and Wyoming. Idaho has chosen not to 

participate in the Commission. The GCVTC comprises: 

· The Governors or their designees of each of the states in the 

Transport Region (with the exception of Idaho); 

· The leaders of four Indian tribes (Navajo, Hopi, Hualapai, and 

Acoma Pueblo) or their designees; and 

· The EPA and federal land managers from the National Park 

Service, Bureau of Land Management, Fish & Wildlife Service, and 

Forest Service, and the Columbia River Inter-Tribal Fish 

Commission, as ex officio members. 

Congress specified that the GCVTC should assess scientific, 

technical, and other information related to adverse visual air 

quality impacts from potential or projected emissions growth from 

sources located in the Transport Region. The Commission adopted a 

work plan and created a committee structure in order to carry out 

its tasks. Technical committees drew upon expert resources in 

government, private industry, academia, and environmental groups. 

The Commission's broad task is to report to the EPA on what 

measures, if any, are appropriate to address visual air quality on 

the Colorado Plateau. This report must address three areas: 

1. The establishment of "clean air corridors" and whether 

additional restrictions on emissions in these corridors are 

appropriate to protect visibility at Class I areas on the 

Colorado Plateau. 

2. The imposition of CAA requirements affecting construction of 

new, major stationary sources or major modifications to existing 

sources in clean air corridors. 

3. Regulations to address long-range strategies for regional haze 

that impairs visibility in Class I areas on the Colorado 

Plateau. 

The Commission created structures based on principles of broad 

public input and consensus in order to carry out its mandate, 

including establishment of a Public Advisory Committee (PAC). PAC 

members were drawn from government at the federal, tribal, state, 

and local levels; business and industry; educational institutions; 

and environmental advocacy groups. 

 

 2 A list of federally recognized tribes, organized by geographic area, is included as available from the 

Bureau of Indian Affairs or the National Tribal Environmental Council.
 5

Each Commissioner appointed up to five members to the PAC 

representing a broad range of the public, including government, 

business, industry, environmental organizations, academia and 

private citizens. The PAC's tasks were to develop consensus 

recommendations for the Commission, to serve as a sounding board 

for the Commission for social and economic issues affecting 

visibility, and to provide a balanced representation of views on 

the value and impacts of protecting visibility on the Colorado 

Plateau. The PAC relied on the extensive scientific and technical 

work of the other GCVTC committees to prepare its recommendations. 

These other committees include the Operations Committee and 

committees which report to it: the Alternatives Assessment 

Committee, the Technical Committee, and the Communications 

Committee. 

Following a series of public meetings in April 1996, the PAC and 

Operations Committee conducted a final review and approval of 

these recommendations in May. The Commission formally considered 

the PAC and Operations Committee reports on June 10, 1996 and 

approved the recommendations to be forwarded to the EPA for 

action. Tribal perspectives on the Commission process and 

recommendations are elaborated in Section IV of this report. 

Photographic Illustration of the Problem

The following four pages contain color photographs which 

illustrate the appearance of the average 20% best and worst days 

and an average day at four of the National Parks and Wilderness 

areas on the Colorado Plateau. A depiction of the average of the 

20% worst or best days means that 10% of the days of the year can 

be expected to be worse or better, respectively. Please be aware 

of the limitations of reproduced photographs. They do not 

completely capture the detail and color of the originals. Note 

that the identification is incorrect for the location of the Grand 

Canyon photographs; the photographs were taken from Desert View. 
 6

 II. PROCESS FOR DEVELOPING EMISSIONS MANAGEMENT 

 RECOMMENDATIONS

STAGES IN THE COMMISSION'S STUDY PROCESS

An understanding of the Commission's research and modeling process 

provides the context for its recommendations. There were six 

phases of the Commission's work: 

 1. Development of an emissions inventory for the Transport 

Region. 

2. Development of a technical basis for assessing visibility 

impacts from changes in emissions. 

3. Development of criteria to evaluate options. 

4. Development of emission management options. 

5. Development of scenarios based on varying levels of emission 

management options, including a baseline or "current law" 

scenario. 

6. Development of a computer-based Integrated Assessment System 

(IAS) to compare/evaluate costs and visibility impacts of 

different scenarios. 

The first step in the process was creating an inventory of 

emissions for each state on the Commission, neighboring states 

(Idaho, Montana, Washington, and Texas), northern Mexico and 

western Canada. This inventory uses 1990 as its base year, and 

includes all major stationary sources throughout the Transport 

Region, and mobile and area sources summarized at a county level. 

It covers key gaseous (sulfur dioxide, nitrogen oxides, and 

reactive organic gases/ROG) and aerosol (organic carbon, elemental 

carbon, and fine and coarse particles) emissions. Data specific to 

tribal lands have not been checked for adequacy or accuracy. 

Figure II-1 provides a graphic presentation of key elements of the 

emissions inventory. 
 7

Based on this inventory, the Commission then developed a series of 

emission management scenarios and a method for assessing the 

visibility and cost impacts of those scenarios. The Commission 

used three main emission management frameworks: a regional 

emission cap; a visibility standard for the Colorado Plateau; and 

standardized control technology and process requirements. These 

frameworks were refined into a series of scenarios that were 

evaluated under the Integrated Assessment System, or IAS. The 

scenarios included a baseline or lower bound, which projected 

effects of applying existing laws and regulatory programs; an 

upper bound which included maximum application of controls on 

emissions irrespective of costs; and several different 

intermediate goals. Each scenario reflected different combinations 

of options and goals for improving visibility. 
 8

 Figure II-1: Emissions Inventory 
 9

The Commission's committees also developed technical tools for 

understanding the effect of different emission sources on 

visibility at Class I sites, principally the Grand Canyon. These 

tools include transfer coefficients that explain the relationship 

between pollution sources in various locations and visibility at 

specific Class I sites. These coefficients have been refined 

continuously to assist the Commission in its understanding of 

visibility impacts. 

VISIBILITY ON THE COLORADO PLATEAU

The starting point for understanding the Commission's analytical 

process is visibility. In simple terms, visibility depends on 

three factors: Rayleigh scattering, other natural impairment, and 

human-caused impairment. Nitrogen and oxygen in the atmosphere 

cause the sky to look blue; this is Rayleigh scattering. Other 

natural sources, such as volcanoes, wind-blown dust, smoke from 

wildfires, and emissions from trees and plants also cause 

visibility impacts by scattering and absorbing sunlight. Human 

activities, from industrial manufacturing to farming, also impair 

visibility. Visibility varies depending on natural effects 

(including weather) and their interactions with human-caused 

emissions. 

Note: All of the figures which follow in this section have been 

generated using the Commission's Integrated Assessment System 

(IAS). These figures all include future projections. Projections 

for 2040 are less reliable than projections for 2000. 

Figure II-6 shows the relative visibility impairment from natural 

and human causes at four Class I areas on the Colorado Plateau: 

Hopi Point, Mesa Verde, Bryce Canyon, and Canyonlands. Values are 

shown as an annual average beginning in 1990 and continuing to 

2040, and also as an average for the 20% of days during the year 

when visibility is worst. Visibility impairment or light 

extinction caused by light scattering and absorption that impairs 

visibility is stated in "inverse megameters," represented as "Mm1

." Figure II-6 shows that natural causes account for approximately 

15 Mm-1 to 17 Mm-1 of visibility impairment at these four areas on 

average. The remaining visibility impairment at each area is 

caused by human activities. This portion of total visibility 

impairment is considered manageable by the Commission, and is the 

focus for its recommendations. 

For ease of comparison, light extinction can be converted to the 

theoretical distance at which a human eye could see a large dark 

horizon feature, such as a tree-covered mountain. As extinction 

increases, the distance one can see decreases. For example, if 

there is only blue sky or Rayleigh scattering (10 Mm-1), one could 

theoretically see a horizon feature 245 miles distant. If light 

extinction is doubled to 20 Mm-1 due to natural and/or human caused 

aerosols, visibility would be reduced to about 120 miles. 
 10

Figure II-2

Figure II-2 shows annual average light extinction for one Class I 

area: Hopi Point in Grand Canyon National Park for 1990, 2000, 

2010, and 2040. The dark portion of each vertical bar is the 

portion of light extinction caused by Rayleigh scattering or blue 

sky. This totals approximately 10 Mm-1. The remaining portion of 

light extinction is caused by natural and human-caused aerosols. 

This total ranges from 24 Mm-1 to 25 Mm-1. The corresponding 

distance for visibility is only about 90 miles. Figure II-2 shows 

that natural and human-caused particles account for the majority 

of light extinction at Hopi Point. 

Figure II-3

Figure II-3 shows the relative contributions of natural and humancaused particles to visibility impairment at Hopi Point. For a 

complete discussion of the development of the data underlying 

these figures, please refer to the GCVTC Report, Options for 

Western Vistas. Note that the sources identified have not been 

distinguished by location. Specifically, the relative contribution 

to visibility impairment from "local" versus "regional" sources 

has not been identified. Natural particles account for 

approximately 5.4 Mm-1 of light extinction on an annual average 

basis from 1990 through 2040. Human-caused particles are 

responsible for approximately 9 Mm-1 of light extinction at Hopi 

Point, roughly double the amount caused by natural particles. In 

terms of visible distance, human-caused particles reduce 

visibility at Hopi Point by about 66 miles on an annual average 

basis. 

Figure II-4

Using its emissions inventory and other data, the Commission has 

identified the major sources of human-caused light extinction at 

Hopi Point. This information is shown in Figure II-4 for the 

period 1990 to 2040, on an annual average basis. Each source of 

emissions is listed on the right side of Figure II-4, along with 

its corresponding pattern shown in the vertical bars. Figure II-4 

shows that light extinction caused by emissions from utilities is 

projected to decline by approximately 1 Mm-1. This decline is due 

to emissions reductions. Light extinction caused by mobile sources 

is projected to decline until approximately 2005, and then 

increase through 2040. The same is true for road dust. However, 

as noted on page 46, there is considerable uncertainty surrounding 

the predictions about road dust. 

Figure II-5

Visibility varies from day to day at Class I sites on the Colorado 

Plateau. Figure II-5 shows the relative contributions of different 

human-caused particles to light extinction on the 20% of "worst" 

days at Hopi Point. 
 11

A comparison of Figure II-5 with Figure II-4 indicates that there 

is approximately 60% more light extinction caused by human sources 

on the average of "worst" days (approximately 17 Mm-1) than the 

annual average (approximately 9 Mm-1). 

Figure II-6 (4 pages)

Figure II-6 compares light extinction from natural and human 

causes at four Class I areas on the Colorado Plateau: Hopi Point, 

Mesa Verde, Bryce Canyon, and Canyonlands. Values are shown as an 

annual average beginning in 1990 and continuing to 2040, and also 

as an average for the 20% of days during the year (71 days) when 

visibility is worst. On each graph, the bottom layer represents 

Rayleigh scattering and other natural causes of light extinction. 

The additional layers represent light extinction caused by various 

human sources: stationary, area, mobile, and Mexico. The scale on 

the right of each graph shows visibility in distance. 

Figure II-6 shows that natural causes account for approximately 15 

Mm-1 to 17 Mm-1 of visibility impairment at these four areas on 

average. The remaining visibility impairment at each area is 

caused by humans. This portion of total visibility impairment is 

considered manageable by the Commission, and is the focus for its 

recommendations. 

THE BASELINE FORECAST SCENARIO, BASED ON CURRENT LAW

The Commission needed a way to evaluate how its recommendations 

would affect visibility beyond current law and programs, and 

developed a baseline or "current law" scenario to meet that need. 

The Commission refers to this scenario as the Baseline Forecast 

Scenario (BFS). 

The Baseline Forecast Scenario is the best possible estimate of 

future visibility impairment at Class I areas on the Colorado 

Plateau, assuming current law is enforced, with no additional 

actions to protect visibility. 

The Baseline Forecast Scenario is built on the following assumptions: 

· Emissions growth or decline is based on changes in economic 

demand in the region 

· Sources retire at a specific age 

· New sources are a mixture of new technology and assumed control 

levels 

· State Implementation Plans under the Clean Air Act for 

attainment by 2010 are included, and emissions growth is 

permitted after that time based on economic growth 

· There is no growth in unpaved road dust beyond 1990 
 12

· Emissions from Mexico are held constant 

Because visibility is highly variable, the Baseline Forecast 

Scenario analyzes the average of the "best" and "worst" 20% of 

days, as well as annual averages. 
 13
 14
 15
 16
 17

 Figure II-6
 18

 Figure II-6
 19

 Figure II-6
 20

 Figure II-6
 21

 Figure II-7
 22

 Figure II-7
 23

Figure II-7

Figure II-7 shows current and predicted visibility impairment 

through 2040 under the Baseline Forecast Scenario at the same four 

Class I areas discussed above: Hopi Point, Mesa Verde, Bryce 

Canyon, and Canyonlands. For each of the four areas, the top line 

shows visibility on the "worst" days, the middle line shows the 

annual average visibility; and the bottom line shows visibility on 

the "best" days. 

Figure II-7 shows the wide difference in air quality on the "best" 

and "worst" days. There is virtually no human-caused impairment on 

the "best" days at these four parks through 2040. On the "worst" 

days, visibility impairment is more than doubled, and most of that 

increase is caused by human sources. This is particularly 

significant because the human eye is more sensitive to changes in 

the "worst" visibility conditions than the "best" conditions. 

PAC INTERACTIONS IN DEVELOPING CONSENSUS RECOMMENDATIONS

Members of the PAC represented diverse interests from throughout 

the West. Given the divergent perspectives and concrete interests, 

the struggle to consensus was difficult at times, but PAC members 

maintained a cordial atmosphere of collaboration in their search 

for good policy. The resulting policy recommendations do not 

represent what any one group would have advocated on its own. The 

recommendations embody concessions, compromises and creative 

solutions which all members of the PAC support. 

The PAC assisted in gathering public input at different phases of 

this process to refine emission management options and evaluation 

criteria. In November 1995, the PAC received a contractor's report 

entitled Options for Improving Western Vistas. That report 

summarized the work of the Commission's committees to that point 

and discussed the results of Integrated Assessment System 

modeling. Based on that report and other technical information, 

and with continuing input from the Commission's committees and the 

general public, the PAC developed consensus recommendations for 

consideration by the Commission. It should be noted that there is 

a significant divergence among the scenarios analyzed in the 

technical assessment process and the recommendations included 

herein. To the extent that the recommendations diverge from the 

Commission's analyses, they reflect the input from the public and 

deliberations of the PAC. 

The Commission sought broad public input to develop its emission 

management options and evaluation criteria. Beginning in April 

1993 and continuing until November 1995, the Commission held 

several series of public workshops and meetings across the 

Transport Region to provide information and receive feedback. 

Public comments were discussed at PAC meetings and incorporated 

into the PAC's recommendations to the Commission. 
 24

CRITERIA FOR ASSESSMENT OF EMISSIONS MANAGEMENT OPTIONS

The Commission developed six criteria for assessing different 

emission management strategies: 

1. effectiveness in achieving visibility goals 

2. economic effects 

3. social effects 

4. environmental effects in addition to visibility 

5. equity, and 

6. administrative ease and effectiveness 

The purpose of these criteria is to ensure that all significant 

impacts of different emission management strategies are considered 

in making recommendations for the future. 

Most of the available scientific and technical information—

emissions budgets, emission management options, scenarios, 

criteria, and transfer coefficients—is brought together in the 

Integrated Assessment System (IAS). The Commission's goal in 

designing the IAS was to enable a user to select different 

combinations of emission reduction strategies applied to sources 

within the Transport Region to yield desired visibility conditions 

at any one of sixteen Class I sites on the Colorado Plateau over 

the next forty years (2000, 2010, 2020, 2030, and 2040). 

Development of the IAS was a major task, and work continues to 

expand its capabilities. Most of the modeling output to date is 

based on visibility at a single Class I site, Hopi Point in Grand 

Canyon National Park. 

TECHNICAL FOUNDATION FOR THE COMMISSION'S RECOMMENDATIONS

Introduction

In order to fulfill its mandate, the Commission needed a reliable 

picture of the impacts of regional haze on visibility at sixteen 

Class I areas on the Colorado Plateau, and a way to assess the 

changes in visibility and costs associated with different options 

for managing emissions. Meeting these needs was not simply a 

matter of gathering existing data and running it through a basic 

computer model. The Commission needed new information and new 

analytical tools, and its technical committees and outside 

consultants have done groundbreaking work to meet these needs in 

only a few years. This work has significantly improved 

understanding of visibility impairment in the Transport Region, 

and provides the technical foundation for the Commission's 

recommendations. 
 25

It is important to understand that this technical work, while 

representing a significant advance in knowledge, is not yet 

complete. The large size and complex terrain of the Transport 

Region, the time, funding, and other resources available for work, 

significant data gaps, and the amount of information that could be 

modeled with current technology were important limiting factors. 

As a result, the Commission's technical data and findings, 

discussed below, are characterized by varying degrees of 

uncertainty. In particular, the modeling has, to date, given a 

limited picture of the regional, and particularly sub-regional, 

including tribal, dynamics of both emissions and economics. 

Nevertheless, the Commission has sufficient confidence in its 

overall understanding of the causes of regional haze and its 

effects on visibility to make the recommendations presented in 

Section III. 

Important Technical Data Findings

The following are some of the results and technical findings from 

the Commission's work to date which form a basis for policy 

recommendations. 

· The most comprehensive inventory to date of emissions across 

the Transport Region. The Commission gathered 1990 data from a 

variety of sources to create the most comprehensive inventory 

yet of emissions for the Transport Region. This inventory is 

the cornerstone for most emissions forecasting by the 

Integrated Assessment System model. 

· The Commission's current modeling shows improvements in 

visibility, under existing regulations and programs, through 

the year 2000. After that, predicted gains in visibility are 

offset by increases in economic activity related to population 

increases. 

· Regional phenomena can contribute to visibility impairment. The 

Commission's air quality monitoring data and modeling show that 

a part of the haze problem can be caused by long-range 

transport of emissions. Visibility at Class I sites on the 

Colorado Plateau is affected by pollutants that have travelled 

long distances, i.e., more than approximately 100 miles. These 

pollutants often cross the boundaries of several states within 

the Transport Region. Some centrally located emission sources 

are frequent contributors to visibility impairment at multiple 

receptor sites across the Transport Region, regardless of wind 

direction. In addition, Clean Air Corridors are a regional 

phenomenon of clear air transport from low emission areas 

located to the north. 
 26

· There is also a local aspect to the haze problem on the 

Colorado Plateau. Emissions from sources located roughly under 

100 miles away can affect visibility at Class I sites. These 

local-source emissions are less diluted than emissions that 

travel long distances. The Commission has an improved understanding of the conditions that lead to local source impacts on 

visibility. For example, local emissions can build up during 

windless periods, and are subject to being trapped above lowlying terrain during temperature inversions. Also, urban areas 

(Las Vegas and Salt Lake City) have been studied and may have 

significant3 impacts on visibility at the Grand Canyon and 

Canyonlands, respectively. 

The Commission's current analyses suggest that visibility 

impairment caused by local sources may be much greater than 

predicted by prior studies. If correct, these new analyses have 

significant implications for reducing current visibility 

impairment. In light of their conflict with prior studies, the 

Commission's results should be treated with caution. Years of 

technical work may be necessary before the relative visibility 

impacts of local sources can be confirmed. 

· The relative visibility effects of regional and local emissions 

are variable, but local emissions have a greater impact per ton 

emitted. Seasons, weather conditions, and terrain elevations 

influence the relative visibility impacts of regional and local 

emissions. Both emission types contribute to visibility 

impairment much of the year, and either type can be the 

dominant cause of impairment on any particular day regardless 

of the season or the location of a receptor. There is little 

doubt, however, that local emissions have a greater visibility 

impact per ton emitted than emissions from distant sources. 

· Wildfire and prescribed fire play an important role in 

visibility on the Colorado Plateau. During coming years, land 

managers are projecting significant increases in prescribed 

fire in order to reduce the effects of wildfire resulting from 

past decades of fire suppression. Therefore, prescribed fire 

has the potential for outweighing visibility improvements on an 

episodic basis. 

· Emissions from Mexico are significant and growing, particularly 

contributing to the SO2 emission budget. Without control 

strategies for Mexican sources, they will have continuing and 

growing adverse visibility effects. 

 

 3 In numerous places, this report refers to "significant" contributions to visibility impairment and 

"significant" decreases or increases in emissions, but "significant" is not defined. "Significant" will be defined 

in the context of developing implementation plans with full participation by the affected parties. 
 27

· Visibility effects are a combination of emissions and 

meteorology and other uncontrollable factors, such as wildfire.

Meteorology and wildfire can vary significantly from year to 

year. Therefore, in assessing the visibility gains from an 

emissions management strategy, measurements of visibility from 

any one year may not show improvements. Data trends from 

multiple years are needed. In the short term, gains or losses 

in visibility may be better represented by the emissions 

inventory than from monitoring data at Class I sites. 

· Source areas with large transfer coefficients merit particular 

attention. The Commission developed transfer coefficients for 

95 source areas across the Transport Region as a tool to model 

changes in visibility. In the simplest sense, each source 

area's transfer coefficients represent the mathematical 

relationship between emissions in that source area and aerosol 

concentrations at a specific Class I receptor. The Integrated 

Assessment System model indicates that emissions reductions 

will yield the greatest visibility improvements if they occur 

in source areas having "large" transfer coefficients and large 

emissions. Source areas having large transfer coefficients but 

low emissions merit increased attention in emissions planning. 

Finally, for any specific reduction in emissions, source areas 

with large transfer coefficients will yield the largest 

improvements in visibility at Class I sites. 

Summary of Data and Model Limitations

The Commission's technical models are designed primarily to assess 

the regional impacts of pollutant transport, i.e., to give a 

picture of how pollutants travel across the nine-state Transport 

Region. The meteorological and air quality models simulate 

regional scale phenomena—such as wind—reasonably well. The models 

are best at demonstrating the relative effects of regional 

emissions on visibility. As a result, the Commission has a 

reliable understanding of the relative significance of most 

regional sources. For example, information shows that Southern 

California is the largest regional source of visibility-impairing 

particles in the Transport Region. 

Because the Integrated Assessment System models were designed with 

a regional transport focus, they offer only limited insights into 

(1) the absolute contributions to visibility impairment from 

"local" sources located under approximately 100 miles of Class I 

sites, and (2) the visibility impacts of local sources relative to 

regional sources. The Integrated Assessment System permits 

qualitative understanding of local source influences, but does not 

permit quantitative understanding. In particular, the Integrated 

Assessment System model is not designed to be used for local 

source attribution. Accordingly, further study on local sources 

should be undertaken prior to enactment of recommendations for 

emissions controls on specific local sources. 
 28

There are several reasons for the limitations in the Integrated 

Assessment System model concerning local source impacts on 

visibility. 

· Most of the modeling was done using coarse grid cells measuring 

thirty miles on each side. Modeling the transport and dispersion of pollutants between adjacent cells did not reflect the 

actual physics of such activity. The Commission used a fine 

grid (six mile) for several major sources for a limited period 

of the modeled year. While this approach should improve the 

model's performance, data and time limitations made it 

impractical as a substitute for all of the coarse-grid 

analysis. 

· While the Commission's model reliably simulates the effects of 

meteorological factors on pollutant transport, it does not 

simulate effects caused by "smaller" terrain features such as 

the Grand Canyon. 

· The model's projected visibility impacts are scaled to reflect 

actual measurements. This means that an inaccurate projection 

of local influence on visibility causes a distortion of the 

regional influence. 

· The model's projections of pollutant concentrations at Class I 

areas are generally in the form of seasonal and annual 

averages, and the 20% best and worst days. Day-to-day 

variations in pollutant concentrations are not projected. This 

is a significant limitation because visibility changes are 

instantaneous, occurring within hours depending on meteorology. 

· In addition, uncertainties in the emission inventory, 

meteorology, atmospheric chemistry and transport modeling 

methods, and background assumptions contribute to uncertainties 

in the modeled relative contributions of sources in the region. 

 Although these have not been quantified, they could have a 

significant effect on the model results. 

One other important limitation involves the number of receptors 

where pollution data were available. The Commission collected data 

from only six receptors, and ultimately scaled its modeling for 

only four of these: Hopi Point, Mesa Verde, Canyonlands, and Bryce 

Canyon. The most detailed information came from one receptor, Hopi 

Point in Grand Canyon National Park. As a result, the Commission 

has a reliable understanding of visibility impacts at Hopi Point. 

However, this single receptor does not provide a comprehensive 

picture for the entire Grand Canyon, let alone the other 15 Class 

I sites on the Colorado Plateau. 

Even with these limitations, however, the Commission's models and 

its technical data and findings provide an adequate foundation for 

the recommendations presented in the next section. 
 29

 SECTION III: EMISSIONS MANAGEMENT RECOMMENDATIONS 

GUIDING PRINCIPLES

In developing the set of recommendations that follow, the 

Commission has been guided by several general principles. 

Achieve Reasonable Progress Toward the National Visibility Goal

The overall goal of the Commission's recommendations is to improve 

visibility on the worst days and to preserve existing visibility 

on the best days, at Class I areas on the Colorado Plateau. 

Reasonable progress towards the national visibility goal is 

achieving continuous emission reductions necessary to reduce 

existing impairment and attain steady improvement of visibility in 

mandatory Class I areas and managing emissions growth so as to 

prevent perceptible degradation of clean air days. 

Address All Important Sources of Visibility Impairing Emissions 

The recommendations are designed to address all important sources 

of visibility impairing emissions. 

Apply Emissions Control Measures Equitably

The Commission has sought to distribute the burden of improving 

visibility in an equitable manner. No single source or geographic 

region should be unfairly required to bear costs or limit 

expansion while others are not. The Commission recognizes that 

equity considerations require that past emissions reductions, 

current levels of control, technical feasibility, cost of 

controls, the time necessary for compliance, the energy and nonair quality environmental impacts, the remaining useful life of 

existing emissions sources, and other relevant equity factors must 

be considered in achieving reasonable progress. 

Prevent Future Visibility Impairment by Protecting Clear Days

Key strategies, imbedded in many of the recommendations, are aimed 

at protecting the present sources of clear days at Class I sites 

on the Colorado Plateau. 

Remedy Existing Impairment by Reducing Present Levels of Emissions

Present emissions that cause visibility impairment must be reduced 

significantly in order to improve visibility. 

Take a Regional Approach
 30

Strategies for both preventing future impairment and remedying 

existing impairment demand regional approaches that can be 

applied, in a coordinated manner, by tribes, states, and federal 

authorities throughout the Transport Region. Such strategies 

should be developed in concert with existing cooperative efforts 

to assess and manage air quality within the region. 

Assume that Existing Federal, Tribal and State Laws Will Remain in 

Force

The recommendations assume that state, tribal and federal air 

quality laws, programs, and regulations will remain in force for 

the foreseeable future. 

Consider Costs and Benefits of Emission Control Measures

The Commission has been guided in most cases by estimates of the 

costs and improvements to visibility associated with various 

strategies for controlling emissions. 

Develop Action Plans for All Recommendations

The responsible entities should develop detailed plans for 

implementing Commission recommendations. 

Provide Funding

Specific funding sources should be identified for implementing the 

Commission's recommendations. 

Consider Social, Cultural and Environmental Factors

In analyzing the potential impacts of recommendations, social, 

cultural and environmental costs and benefits should be 

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 33

 AIR POLLUTION PREVENTION 

Background: Pollution Prevention as Key to Protection of Western 

Vistas 

The spectacular scenery of national parks and wilderness area on 

the Colorado Plateau is an important part of our Nation's natural 

heritage. We have a legal and moral obligation to protect this 

national resource for future generations. Visibility in this 

region is extremely sensitive to even small increases and 

decreases in air pollution. 

As the population and economy of the West grow, the only way to 

prevent further degradation of this national resource—as well as 

the air we share generally throughout the West—is to combine costeffective pollution control strategies with a greater emphasis on 

air pollution prevention, including low or zero emissions 

technologies and energy conservation. Because so much of the 

Transport Region is relatively undeveloped, including tribal 

lands, regional stakeholders have the opportunity to take a 

proactive approach to pollution prevention. In fact, given 

expected growth in the Transport Region, it provides an excellent 

place to experiment with an incentive-based approach to managing 

not only air quality but other environmental effects of growth. 

As demand for more power increases, and the region's power 

production base evolves, there is a tremendous opportunity to 

realize substantial benefits from energy efficiency, as well as to 

integrate cleaner, sustainable energy technologies into all 

aspects of our society. The West enjoys high potential for 

renewable energy production, especially electrical energy 

generation employing solar and wind power. The relative cost of 

renewables is declining over time. Based on forecasts of 

electrical energy consumption in the Transport Region by the 

Western Systems Coordinating Council, renewables could supply 

18,000 gigawatt hours of energy annually by 2002. Others have 

suggested that this potential could be much higher (approaching 

50,000 gigawatt hours annually) from renewables (geothermal, solar 

and wind) by 2002. These latter targets would still only comprise 

approximately 10% of region-wide power consumption. A recent 

study by the Land and Water Fund of the Rockies (How the West Can 

Win, 1996) suggests that renewable energy could comprise 19% of 

regional power needs, by adding additional capacity by 2015. The 

study also concludes that as much as 40% of projected power needs 

in 2015 could be met by improved energy efficiency alone.. 

Based on estimates of renewable energy potential, achieving the 

above goals for renewables and efficiency could result in 
 34

substantial emissions reductions, which could translate into 

visibility improvements, as well as secondary environmental and 

economic benefits. Although the Commission did not have the 

resources necessary to model or completely quantify the effects of 

its recommendations in this area, it is convinced that, if 

implemented, they have the potential to become some of the most 

successful and cost-effective contributions to improved 

visibility. 

Hastening the utilization of renewables requires new and increased 

investments, assisted by economic incentives. Huge economic and 

environmental benefits from improving energy efficiency gains are 

also possible with adequate commitment and investment, since 

investment in energy efficiency is the most cost-effective 

resource option. 

 RECOMMENDATIONS REGARDING AIR POLLUTION PREVENTION

 1. Place a high priority on pollution prevention.

Supporting pollution prevention, education about pollution 

prevention, and innovative ways of reducing per capita 

pollution is one of the Commission's highest priorities. 

2. Model the effects of renewable energy and pollution 

prevention.

Potential emissions reductions, visibility improvements, cost 

savings, and secondary benefits associated with renewables, 

energy efficiency, and pollution prevention should be part of 

future modeling work. 

3. Develop economic incentives for pollution prevention efforts.

Economic incentives are a powerful tool for effecting change. 

The Commission supports creation of incentives that encourage 

low-emission industries to locate in the Transport Region, 

retooling of industries to reduce emissions and increase their 

efficient use of energy, the development of energy production 

based on renewable resources, and providing consumers with 

opportunities to reduce their individual contributions to air 

pollution. The Commission recommends that federal power 

management suppliers be given incentives to increase renewable 

energy generation and pollution prevention actions, and that 

public utility commissions continue to influence retail power 

markets to encourage efficiency and investments in renewables. 
 35

4. Encourage zero and near-zero emitting technologies.

The Commission encourages zero and near-zero emitting 

technologies through incentives, education and information exchange, such as a clearinghouse. Opportunities should be 

explored to promote economic development and job creation 

through the development and deployment of such technologies. 

5. Provide incentives for actions beyond compliance.

Incentives should also be provided to reward efforts that go 

beyond compliance and/or achieve early compliance with air 

pollution-related requirements. 

 6. Consider charging emission fees.

A variety of market approaches should be analyzed. Emission fees 

could be charged for pollution emitted into the air to 

encourage people and industry to reduce pollution in the most 

efficient manner possible. Revenues could be used to substitute 

for taxes on property or income or to provide financial assistance to those industries or communities wishing to implement 

pollution prevention projects. Emission fee caps that exist in 

some states should be analyzed. 

 7. Support development of renewable energy sources.

The Commission promotes the transition to power production based 

on renewable resources such as wind, solar, biomass, and 

geothermal resources and supports the establishment and 

tracking of annual goals for increases in renewable power 

generation in the Transport Region that fosters the sustained, 

orderly development of renewables in the region. Specific 

areas should be identified where renewables have the potential 

to supply power where it is now lacking and where renewables 

are most cost-effective. Encouraging development of renewables 

has particularly high potential for tribal lands (see page 69). 

 The goal of the states in the Transport Region should be to 

achieve annual additions in order that renewables will comprise 

10% of the regional power needs by 2005 and 20% by 2015. 

Progress towards this goal should be evaluated every five years, 

in conjunction with regular reviews of emissions reductions and 

progress toward the national visibility goal. Incentives 

provided by tribal, state and federal governments may be 

necessary to achieve this goal. In the interests of equity, the 

Commission recommends that spending and investment in energy 

research and development should be equalized among fossil fuelbased and renewable energy programs. The EPA should coordinate 

with the Department of Energy to achieve funding for the range 

of pollution prevention programs authorized by the Energy 

Policy Act and administered by the Department of Energy's 

Center of Excellence for Sustainable Development. All new power 

generation projects should include a percentage of renewables 
 36

associated with them, in order to help achieve regional 

renewable energy portfolio goals. 

8. Promote energy conservation.

The Commission supports the continued development and 

implementation of national energy efficiency standards for 

motors, appliances and lighting and recommends the national 

adoption of California energy efficiency standards. The 

Commission also supports the construction of energy efficient 

buildings, both residential and commercial, and proposes the 

reinstatement of incentives for building energy efficient 

structures similar to those in place during the early 1970s. 

The Commission also suggests the continuation of demand-side 

management programs, despite current funding restrictions. The 

Commission recommends that continuing attention be paid to 

maintaining the role of energy conservation within the changing 

electric power industry markets. Energy conservation programs 

should be preserved and expanded through such mechanisms as 

"system benefit charges" paid at the distribution level, rather 

than in the commodity electricity rate. This approach would be 

equitable and would not disadvantage utilities in relation to 

their competitors. 

9. Promote education and public outreach efforts on preventing 

pollution. 

The Commission encourages the integration of pollutionprevention and renewable energy concepts in elementary, 

secondary, higher and continuing education programs and in 

public environmental education efforts. Teaching by first-hand 

example, through the incorporation of energy efficient 

technologies at school facilities is encouraged. 

10. Introduce product labeling.

The Commission recommends a market-based approach to pollution 

prevention and energy conservation and efficiency through 

"green pricing." The EPA, the Federal Energy Regulatory 

Commission and the states should institute labeling, on a 

voluntary basis at first, but potentially based on national 

standards, that provides consumers with information about the 

pollution potential, energy requirements and relative 

efficiency of products. Voluntary product labeling can be 

beneficial to businesses by providing more consumer information 

and improving product attractiveness in the marketplace. Such 

approaches could begin with a limited scope, such as providing 

information to consumers about the characteristics of their 

sources of electric power generation. 

11. Promote the use of clean fuels.

The Commission also supports the regional use of cleaner-burning 

fuels, including reformulated gasoline and diesel and extending 
 37

towards natural gas, electricity and hydrogen. 
 38

 STATIONARY SOURCES

Background 

Emissions from stationary sources throughout the Transport Region 

contribute in varying degrees to light extinction in Class I 

Areas. The extent to which these sources produce pollutants that 

impair visibility is a function of the size of the source and its 

location in relation to the protected areas. The GCVTC analytical 

work addressed three species of pollutants that are significantly 

produced by stationary sources: sulfates, nitrates and organic 

compounds. This section of the recommendations proposes a program 

to deal with all species, but focuses on sulfates, which are the 

most significant contributor to visibility impairment of the 

three. 

Because of the significance of the role sulfates have played in 

the Commission's studies and analyses related to visibility, more 

information is available related to sulfates and their 

relationship to light extinction. Additionally, because SO2, the 

dominant precursor to sulfates, is associated with a relatively 

small number of large sources, trends in emissions can be 

forecasted with a relatively high degree of certainty. Moreover, 

the Commission is aware of efforts to restructure the utility 

industry and should monitor its impact on regional visibility. 

The stationary source proposal envisions relying on the 

implementation of current programs through the year 2000 before 

the implementation of a new regulatory program. Current programs 

include those mandated by the federal Clean Air Act and by states 

and tribes that have resulted in or are expected to result in the 

installation of significant emission control technologies with 

associated emission reductions. The Baseline Forecast Scenario 

conservatively estimated only a 6% reduction (13% in the Transport 

Region) in the emissions of sulphur dioxide (SO2) through the year 

2000. However, implementation of current programs could result in 

greater reductions in SO2 emissions in the short term. In 

particular, a number of open issues with a bearing on the 

visibility problem could be resolved prior to 2000. These include 

the “source attribution” studies at the Centralia, Mohave and 

Hayden power plants, greater than expected emission reductions in 

the copper smelting industry, and the imposition of lower fuel 

sulfur standards. With these additional reductions not anticipated 

by the Baseline Forecast Scenario, it is estimated that actual SO2

reductions could be closer to 20-30%. 

A major component of this proposal is that, if a regulatory 

program is deemed necessary, it may be an incentive-based trading 

program (e.g., including, but not limited to, a market-trading 
 39

program.) It is the intent of this recommendation that any 

trading program include as many source categories and species of 

pollutants as is feasible and technically defensible. This 

preference for a “comprehensive” market is based upon the 

expectation that a comprehensive program would be more effective 

at improving visibility and would yield more cost-effective 

emission reduction strategies for the region as a whole. However, 

the Commission recognizes that the inclusion of multiple 

pollutants and sources, as well as inter-pollutant/sector trading, 

raises a number of complex issues (e.g., emission inventories, 

validity of reductions, etc.) that would need to be addressed 

before multiple sources or pollutants could be included. 

The Commission also recommends that any incentive program contain 

specific provisions to encourage and reward early emission 

reductions, including reductions achieved before 2000. The 

Commission recognizes the potential impact this will have on lessdeveloped areas, including Indian lands. Also, the program should 

include incentives for emission reduction measures that go beyond 

pollution controls (e.g., investment in renewable energy and 

energy conservation measures.) 

 RECOMMENDATIONS REGARDING STATIONARY SOURCES

The objectives of the approach outlined below are: 

· to achieve significant reductions in sulfur dioxide emissions 

in the near term; 

· to ensure reasonable progress toward the national goal through 

continuing decreases in sulfur dioxide emissions over the long 

term; and 

 · to avoid increases of other visibility-reducing pollutants 

within the Transport Region as a whole from stationary sources. 

The Commission believes these objectives are best achieved by 

relying on diligent implementation of current regulatory 

requirements in the short term while working to develop an 

incentive-based approach to ensure long-term protection. 

The following specific recommendations are presented with the 

recognition that the tribal participants support these 

recommendations and have offered additional concerns and 

recommendations in Section IV of this report. 

1. Implement existing Clean Air Act requirements through the year 

2000.

Implementation of existing Clean Air Act requirements is 

expected to result in a significant decrease in sulfur dioxide 
 40

emissions and their contribution to light extinction in the 

short term (1990-2000). Because some of these reductions are 

associated with the installation of SO2 control equipment 

currently under construction, they can be projected with a very 

high degree of confidence (e.g., a 6% reduction in the total 

SO2 emissions inventory resulting from emissions reductions at 

the Navajo Generating Station). In addition to these known 

reductions, the rate of SO2 emissions decline will be 

influenced by ongoing source attribution studies and decisions 

similar to "best available retrofit technology" in the 

Transport Region, as well as other factors mentioned above. By 

the year 2000, the amount of SO2 emissions reductions achieved 

(or represented by enforceable commitments) could be in the 

range of 20-30%. These pending matters may also affect the 

amount and rate of SO2 emission reductions that will occur 

after the year 2000. States and tribes are encouraged to review 

the visibility impacts at Class I sites on the Colorado Plateau 

of uncontrolled pollution sources and make expeditious 

determinations regarding the need for additional pollution 

controls pursuant to the Clean Air Act. To the extent 

decisions are made to require additional emission reductions at 

existing facilities, the Commission supports the adoption of 

the best, most cost-effective strategies. 

22. Establish stationary source emission targets4

 as regulatory 

triggers.

a) An SO2 emissions target for stationary sources will be established effective in the year 2000. The level of the target 

would be calculated by (1) determining the amount of emission 

reductions that has actually been achieved (or legally 

committed to) between 1990 and 2000; (2) comparing the actual 

reduction to the 13% reduction from 1990 actual emission levels 

that was projected by the Baseline Forecast Scenario; (3) 

assuming the actual reduction is higher than the projected 

reduction, set the emissions target at a level midway between 

the projected and actual, unless any affected party convinces 

the Commission or its successor that a different distribution 

is needed (e.g., emissions growth in undeveloped areas, 

operational flexibility needs, deteriorating visibility). As 

part of this calculation, the 1990 emissions inventory will be 

compared to the reported emissions to 1995/1996 data now 

available from sources (all utilities and many stationary 

sources have Continuous Emission Monitors). 

b) An ultimate SO2 emissions target for the visibility Transport 

Region will be established for the year 2040 that locks in the 

50-70% reduction in SO2 emissions projected by the Baseline 

 

 4 These "targets" are intended as firm limitations on emissions and have the same effect as a 

"cap." However, we are reserving the term "cap" to refer to the limits set under a regulatory 

program which would be triggered if the "targets" are exceeded. 
 41

Forecast Scenario.5 Interim targets may also be needed to 

ensure steady and continuing emission reductions and to promote 

investment in pollution prevention (in accordance with five 

year review periods as described in #4 below). 

c) Various emissions management options for stationary source 

NOx and PM will be explored, including considering the 

establishment of emission targets, in order to avoid any net 

increase in these pollutants from stationary sources within the 

region as a whole and to provide a foundation for future 

incorporation into a multi-pollutant and possibly multi-source 

market-based program. 

3. Develop a plan for allocating trading credits under a 

regulatory program emissions cap.

a) Development of an equitable plan for allocating the trading 

credits among existing and future sources will be accelerated. 

 The Commission expects that the targets will be met based on 

existing commitments and other actions that are likely to be 

required because of ongoing source attribution studies. 

However, in order to create economic incentives for early 

reductions as well as to provide flexibility and certainty to 

sources in planning future actions, participants in the 

Commission's process are committed to designing the plan before 

the EPA takes final action on the Commission’s recommendations 

so that the elements of that program can be incorporated into 

the federal regulatory program. (The estimated date for 

completing development of the program is June, 1997). A number 

of factors will be considered in developing the program, 

including measures to: 

· prevent new sources from causing the target to be exceeded; 

· account for sources which achieve emission reductions early or 

have achieved maximum control efficiency; 

· ensure that all allocations to tribal lands, rural areas and 

relatively undeveloped areas (e.g., clean air corridors) are of 

practical benefit; and 

· account for the effects of increases or decreases of emissions 

on visibility. 

b) In order to generate information for development and implementation of the incentive-based program, owners and operators 

 

 5 For example, the utility industry is committed to achieving the current baseline projections of 73% 

reductions in SO2 emissions from utility sources by 2040. All projected percentage reductions in SO2

emissions within the Transport Region will need to be verified by an updated assessment of the Baseline 

Forecast Scenario in the year 2000. Some stationary source categories require additional detailed analysis 

in order to produce more reliable projections. For this reason, the percentage reductions in stationary 

sources as a whole are expressed here as a range. 
 42

of existing facilities located within the Transport Region 

should: (1) by 1997, notify states and tribes of existing or 

planned pollution control or prevention measures; and (2) 

report biannually on efforts that are being made to manage 

their emissions or engage in other transactions to voluntarily 

meet their emissions reductions responsibility per the trading 

credit allocation scheme. These plans would not be 

incorporated as enforceable permit conditions or SIP revisions 

except as noted below. 

4. Review compliance with targets and establish incentives. 

Progress in complying with the emissions target(s) would be 

assessed in the year 2000 and at five-year intervals 

thereafter. 

a) In 2000, or any subsequent five-year review period, if the 

regional target in effect at that period has not been exceeded 

no additional regulatory program will be required.6 Any source 

that has contributed significantly to achieving the needed 

reductions by going beyond compliance or achieving early 

reductions will be rewarded. For instance, the following 

rewards could be included: 

· an exemption from any interim target requirements that might be 

established; 

· streamlined treatment in the permitting process; 

· ability to bank emissions; or 

· bonus allowances if credits are used to achieve development on 

tribal lands or other areas that are relatively undeveloped. 

Incentives will be further developed and included in the design 

of the program. 

b) In 2000, or at any subsequent five-year review period, if the 

regional emissions target has been exceeded7, a regulatory program (most likely an emissions cap and incentive-based market 

trading program) will be implemented. Any source that is 

exceeding the emission allocation presented in the plan will 

have no more than five years to come into compliance and any 

reductions achieved will be discounted. Other disincentives 

will be developed and included in the design of the program. 

 

 6 Reductions actually achieved or subject to legally enforceable commitments will be included in 

determining whether the cap has been exceeded. 

 7 See footnote above.
 43

 5. Complete source attribution studies.

The Commission strongly encourages the EPA to complete, within 

one year, the source attribution study currently underway at 

the Mohave Power Project. Further, the Commission strongly 

encourages the EPA to take action consistent with the results 

of that study within twelve months of its completion. The 

Commission supports the commitment by the Mohave Power Project 

to maintain voluntarily its emissions at or below current 

levels (e.g., an average of the past two year's emission 

levels). 

 6. Develop an improved monitoring and accounting system.

A major deficiency in the technical analysis associated with the 

GCVTC activities has been the lack of adequate and reliable 

monitoring data. In order for any visibility policy to be 

effective, there must be an adequate benchmark of existing 

conditions against which to measure progress. To obtain a 

better understanding of visibility throughout the Colorado 

Plateau, Class I areas other than Hopi Point in the Grand 

Canyon need to be included as receptors in visibility modeling 

and additional monitoring sites should be established. 

Emissions in the Transport Region provide another benchmark 

against which to measure progress. An accurate and credible 

emissions accounting method will be essential in determining 

compliance with the emissions targets or caps. Shortcomings in 

the emissions inventory need to be remedied, and a method for 

routinely tracking emissions needs to be developed. 

It is critical that the emissions monitoring and tracking system 

be developed quickly so that emission reductions achieved 

between now and the year 2000 can be recorded and so that those 

areas that are presently lower-emitting can receive appropriate 

credit. If an incentive-based regulatory program is implemented 

after the year 2000, early emission reductions achieved before 

the year 2000 should be awarded credit, provided established 

criteria are satisfied. 
 44

 MOBILE SOURCES

Background: 

Emissions from mobile sources—including both light- and heavy-duty 

vehicles, marine vessels, trains, and airplanes—contribute to 

visibility degradation on the Colorado Plateau. Although the 

relative contribution of mobile source emissions is generally not 

as large as the contributions of some other sources, direct 

emissions and re-entrained road dust from motor vehicles 

contribute significantly to urban plumes that are transported 

across the Colorado Plateau. Emissions from an automobile 

manufactured today are substantially lower—better than 90% lower, 

on a per-vehicle-mile traveled basis—than emissions from one 

manufactured thirty years ago, in large part due to the Federal 

Motor Vehicle Emission Control Program in the Clean Air Act and 

the California motor vehicle emissions control program. However, 

the number of vehicles and the total vehicle miles traveled have 

increased dramatically. This trend is expected to continue. And 

while NOx and PM emissions from heavy-duty on-road diesel engines 

have been reduced 70% and 95%, respectively, since the early 

1970's, emissions from interstate and cross-border truck traffic 

and urban delivery and transportation vehicles continue to 

contribute significantly to total emissions. 

 

Reducing total mobile source emissions is an essential part of any 

long-term emissions management program to protect visibility in 

the western United States generally and on the Colorado Plateau 

specifically. Further reductions can be achieved through a 

combination of national, regional and local actions. 

 RECOMMENDATIONS REGARDING MOBILE SOURCES

1. Adopt an emission management objective and establish a 

regional emissions budget.

The objective of the recommended strategies described below is 

to reduce emissions of VOC, NOx, elemental carbon, and fine 

particulates from the mobile source sector and then hold them 

constant. To the extent that mobile source emissions contribute 

significantly to visibility impairment in the Class I areas of 

the Colorado Plateau, an emissions budget should be established 

for any area with a significant contribution, beginning in the 

approximate year in which emissions are projected to reach a 

minimum, or 2005. The emissions budget should serve as a 

regional planning objective and performance indicator. 
 45

2. Develop a system for tracking emissions.

In order to periodically assess progress, a system for tracking 

emissions will need to be developed. That protocol should take 

into account the relatively rural nature of much of the area 

within the Transport Region and not impose unnecessary burdens 

on small communities, including tribal lands, with air quality 

better than national ambient air quality standards. National 

and regional initiatives should ensure compliance with the 

regional emissions budget. 

3. Suggest targeted local actions.

In addition to national and regional strategies, targeted local 

actions are needed to reduce mobile source emissions within the 

Colorado Plateau's Class I areas, in adjacent communities, and 

in major urban areas that contribute significantly to 

visibility impairment. If the strategies described below and 

elsewhere in this report do not keep emissions within the 

emissions budget, options for expanding and increasing the 

accountability of the relevant authorities will need to be 

considered and implemented. 

 Recommended National Strategies

Introduction to Recommended National Strategies

Most of the mobile source-related emissions reductions achieved 

to date have been brought about by increasingly stringent 

tailpipe and evaporative emissions standards. Further progress 

in reducing mobile source emissions outside of California can 

only be achieved through action on a national level. Although 

it would be difficult to justify a national-scale program based 

strictly on the impact on the Colorado Plateau, there are 

numerous initiatives and proposals to address urban ozone nonattainment problems already being considered for national 

implementation that would benefit air quality in the Colorado 

Plateau's Class I areas. The EPA should ensure the coordination 

of the Commission's efforts related to national standards and 

programs with other regional organizations (e.g., Ozone 

Transport Commission/Ozone Transport Assessment Group), because 

there may be synergies or conflicts among technologies or fuels 

aimed at different air quality goals. 

The Commission promotes the following initiatives on a national 

level: 

1. Adopt 49-state LEV standards.

The Commission supports adoption of the nationwide Low Emission 
 46

Vehicle standards (49-state LEV), beginning in 2001, and 

adoption of federal Tier II standards in 20048, if determined 

to be more effective. In the time frame to 2040, the Commission 

supports the promotion of ultra-low and zero-emission vehicles. 

2. Support development of heavy-duty vehicle standards.

The Commission supports the EPA's current proposal to further 

reduce NOx and particulate emissions from new on-road, heavyduty vehicles by at least 50%, compared to the 1998 

requirements contained in the 1990 Clean Air Act Amendments, 

while maintaining current stringent PM emission limits.9 The 

Commission requests the EPA to pursue additional PM reductions 

from on-road vehicles. 

3. Negotiate and adopt off-road vehicle standards.

The Commission requests that the EPA continue to pursue the 

adoption of additional engine emission standards for new 

off-road vehicles (heavy-duty, construction-type) that provide 

reasonably achievable reductions. 

4. Promote broader application of cleaner fuels.

The Commission requests that the EPA explore broader application 

of and additional reductions in the sulfur content of both 

gasoline and diesel fuel. The Commission also supports the 

promotion of cleaner burning fuels as discussed in 

Recommendation #11 on page 31. 

5. Pursue strategies for diesel locomotives, boats, airplanes 

and federal vehicles.

The Commission requests that the EPA pursue fuel standards and 

control strategies for diesel locomotives, marine 

vessels/pleasure craft, airplanes and federal vehicles. States 

and tribes are preempted from controlling most emissions from 

these sources. Emissions from these categories are relatively 

uncontrolled compared to other mobile sources (e.g., light-duty 

cars and trucks) and will continue to increase with population 

and economic growth. In particular, the EPA should: 

a) promulgate national NOx, HC and PM standards for "captive 

fleet" marine vessels and work with the International Maritime 

Organization to reduce emissions through international 

 8 In March 1996, the California Air Resources Board confirmed an agreement with the largest 

automobile manufacturers to sell nationwide only cars and light trucks which meet standards equivalent to 

California's Low Emission Vehicle (LEV) standards, beginning in 2001. This action was part of a larger 

agreement in which these manufacturers were given greater flexibility in introducing Zero Emission Vehicles 

(ZEVs) prior to 2003 in California. 9 The heavy duty engine manufacturers, the U.S. EPA and the California ARB signed a statement of 

principles in July 1995, committing to the introduction of a NOx standard of 2.0 grams per brake-horsepower 

hour by 2004, compared to the 1998 CAAA requirement of 4.0.
 47

standards; 

b) finalize the proposed HC standards for recreational boats and 

personal watercraft; 

c) adopt NOx standards for new and remanufactured diesel locomotive engines; 

d) strengthen existing national HC standards for aircraft 

engines; 

 

e) adopt stringent national NOx standards for aircraft engines; 

and 

f) pursue emission control strategies, such as alternative 

clean fuels, for all federal fleets. 

6. Support improved control of evaporative emissions

The Commission supports requirements for effective refueling 

vapor recovery systems that capture evaporative emissions. 

 Recommended Regional Strategies

 Introduction to Recommended Regional Strategies

To the extent that mobile source emissions from certain areas 

are found to contribute significantly to visibility impairment 

in the Class I areas of the Colorado Plateau, an emissions 

budget should be established, beginning in the approximate year 

in which emissions are projected to reach a minimum, or 2005. 

As mentioned above, a protocol for inventorying and tracking 

emissions will need to be developed. The adoption of more 

stringent national standards as noted above would help maintain 

compliance with the regional mobile source budget. In addition, 

the Commissioners promote incentives for the use of clean fuels 

on a wide basis. Economic pricing strategies should also be 

analyzed for implementation on a regional scale. The analysis 

should include an examination of the extent to which certain 

populations (for instance, rural communities, low-income groups 

or tribes) may be disproportionately affected. In the event 

that inequities are identified, alternative strategies should 

be developed to address the particular needs of those 

populations. The initiatives which follow should be pursued. 
 48

1. Establish clean fuel demonstration zones.

The feasibility of providing incentives for clean fuel 

demonstration zones or corridors for heavy-duty trucks and 

buses should be assessed by 1998. For example, and at a 

minimum, incentives for converting vehicles used for mass 

transportation and delivery within national parks on the 

Colorado Plateau, as well as in nearby urban areas, to CNG, 

LNG, LPG or alcohol-based fuels should be provided. In 

addition, the Western states should cooperatively: 

a) explore the feasibility of establishing alternative fuel 

corridors in urban areas and along major trucking routes (e.g., 

I-15, I-5, I-80, and I-40);10 and 

b) conduct an analysis comparing the relative emissions from 

trucks and trains (including tailpipe/stack emissions as well 

as road dust, tire wear, etc.). 

2. Analyze pricing and incentive approaches.

A regional analysis of economic pricing and incentive approaches 

should be conducted by 1998, including an analysis of equity 

effects of such approaches, that could be used to reduce 

reliance on vehicle use and better internalize the true cost of 

operating motor vehicles. If such programs were implemented and 

generated revenue, these funds could be rebated to drivers (for 

instance, as a credit against state income or property taxes), 

used to develop multi-modal transportation options, or used to 

help maintain the existing highway infrastructure. The 

Commission supports states that are implementing programs to 

curtail visible emissions and encourage region-wide adoption of 

these programs. 

3. Explore an inspection program for heavy-duty vehicles.

Truck traffic contributes to regional visibility impairment, 

including haze in the Class I areas in the Colorado Plateau. 

The Commission supports development of options and 

opportunities for implementing an emissions inspection programs 

for heavy-duty, on-road vehicles that routinely travel the 

highways in the Transport Region. Within the limitations of 

existing interstate commerce regulations and the North American 

Free Trade Agreement, the states and tribes could explore 

programs to assure compliance with in-use emission 

 10 A privately-initiated effort is already under way to establish LNG fuel stations along the I-15 

corridor from Salt Lake City to St. George, Utah and along the I-15, I-5 and I-80 corridors between Salt Lake 

City, Los Angeles and Sacramento. Efforts are also under way in Southern California for electric vehicles 

and hydrogen corridors. The Commission supports these and similar efforts. If the establishment of a 

regional mobile source emissions budget leads to development of a market-based program, the 

Commission should support the awarding of emissions reduction credits to private entities involved in these 

types of efforts.
 49

requirements, including vehicles involved in cross-border 

transport. 

 

 4. Promote vehicle maintenance.

The Commission also encourages local authorities to mount public 

education campaigns to inform citizens of the air quality 

advantages of maintaining their vehicles properly. It is 

critical for control of mobile source emissions that all 

components of a vehicle's emissions control system be 

maintained according to the manufacturer's specifications as 

detailed in the owner's manual. Such a public education effort 

could be coupled with implementation of a mechanics' training 

and certification program and state-of-the-art vehicle 

inspection and maintenance programs. 

 Recommended Local Strategies

 Introduction to Recommended Local Strategies

Decisions as to how to achieve emissions objectives are best 

made at the local or metropolitan level. However, the 

Commission recognizes that mobile source emissions from some 

areas have a disproportionate impact on visibility in the 

Colorado Plateau Class I areas. Strategies for addressing 

mobile source emissions within Class I areas and in adjacent 

communities are discussed elsewhere in this report. In 

addition, major metropolitan areas located near the Colorado 

Plateau must be encouraged to take actions to reduce in-use 

vehicle emissions. The types of programs described below would 

be targeted initially at these areas, but consideration should 

be given to extending their application on a broader scale to 

achieve regional air quality objectives. Any such extension 

would be preceded by an analysis of the equity effects 

associated with these types of programs in non-urban areas. 

1. Promote incentives for innovative and effective approaches.

The Commission challenges states and tribes with major urban 

areas to develop funding and other incentive-based schemes that 

give priority to allocating discretionary funding to 

transportation projects that are consistent with the goal of 

reducing reliance on single-occupant vehicles. For example, 

governors could exercise fiscal discretion (e.g., preferential 

allocation of state highway/transit, open space, economic 

development/enterprise zone funds or rebates of state fees) to 

reward communities that find appropriate or innovative ways of 

reducing reliance on single-occupant vehicles. Examples include 

land use ordinances that favor development in existing 

transit/transportation corridors, high density development 

needed to ensure the viability of mass transit, and co-located 

residential, business and commercial development to support 
 50

non-vehicular modes of transportation. If possible, this 

incentive-based approach with state funds could be coupled with 

a similar preferential allocation of discretionary federal 

funding to states and tribes that develop appropriate 

approaches. 

2. Encourage better integration of transportation, land use and 

air quality planning. 

In order to avoid incremental degradation of visual air quality 

as the population and economy of the West continue to grow, the 

Commission encourages sustainable community and economic 

development by: 

a) promoting multi-modal transportation options through both 

public and private investments; 

b) encouraging local, state and tribal governments to reduce or 

eliminate entry and rate regulations in the transit industry as 

a means of fostering greater competition; 

c) establishing a clearinghouse for information about sustainable communities and methods for integrating multi-modal 

transportation systems with land use planning; and 

d) sponsoring conferences on transportation, land and air 

quality issues generally (e.g., to showcase various 

communities' efforts), and transportation alternatives within 

and between Class I areas in the Colorado Plateau specifically. 

3. Establish mobile source emissions budgets for selected major 

urban areas.

 

To the extent that mobile source emissions from certain major 

urban areas are found to contribute significantly to visibility 

impairment in the Colorado Plateau's Class I areas, the Commission requests that local emissions budgets be developed 

specifically for mobile sources. (Most areas are already 

required to do this under the CAAA for purposes of assuring 

conformity of transportation plans and programs.) Methods for 

managing mobile source emissions budgets need to be explored 

further. Regardless of which approach is taken, there must be 

developed a credible and replicable way of inventorying, 

tracking and reporting emissions. 

a) Develop analytical criteria and accounting methods for implementing emission budgets.

If the proposed emission budgets allow an increase in current 

emission levels, an analysis will be needed to assess whether 

the budgets ensure protection of NAAQS, PSD increments, and 

visibility in downwind Class I areas. In this event, the 

Commission would develop criteria and an analytical method for 

conducting such an analysis, and establish requirements for 
 51

adjusting urban emission budgets found to be inadequate to 

protect downwind areas, as well as accounting and enforcement 

mechanisms. 

b) Consider use of pricing strategies.

The economic pricing analysis called for above may indicate that 

the most efficient method of complying with emissions budgets 

would be to institute pricing strategies for use of roadways 

that internalize the cost of operating motor vehicles so that 

individuals have an incentive to modify their travel behavior. 

The consideration of such pricing strategies should take into 

account the possibility that incremental changes in price, in 

absolute dollar terms, will have a larger effect on rural areas 

and lower-income populations. 

c) Develop an accounting system for market-based programs.

If some sort of market-based program is deemed appropriate, 

accountability for complying with the emissions budget must be 

clearly assigned, with consequences attached to failure to 

maintain emission levels consistent with the budget. For 

example, emissions from mobile sources could be aggregated and 

responsibility for managing them delegated to a private or 

public "broker", or assigned to a local/ regional governmental 

entity. Alternatively, individuals (including businesses, 

government agencies, etc.) could be given responsibility for 

managing emissions from vehicles they own or control. In any 

event, if emissions trading were allowed, credible methods 

would be needed for certifying the validity and value of 

emissions reductions at the start of the program and ensuring 

their permanence over time. 

4. Suggest retiring high-emitting vehicles.

The Commission suggests that local authorities consider the 

advantages of retiring higher polluting vehicles and develop 

incentives for citizens to upgrade to newer, less polluting 

cars and trucks. 
 52

 AREA SOURCES

 DUST FROM PAVED AND UNPAVED ROADS

Background:

Chapter II of the Commissions November 1995 report, Options for 

Western Vistas, discussed the limitations of the Integrated 

Assessment System results with respect to paved and unpaved road 

dust. More recent modeling has shown that local sources of road 

dust play a more important role than distant sources. The 

Commission has considered this issue and has concluded that there 

are good reasons to discount the Integrated Assessment System's 

predictions about the regional importance of this source of 

emissions until more study is completed. For example, the large 

magnitude of emissions projected for this source are tied to 

projections of future growth in population and vehicle-milestraveled, whereas road dust effects on visibility are generally 

localized, especially with respect to large, coarse material which 

settles out of the air relatively close to roadways. 

 RECOMMENDATIONS REGARDING DUST FROM 

 PAVED AND UNPAVED ROADS

Actions to address the control or reduction of emissions related 

to road dust are found in the recommendations regarding 

emissions "In and Near Class I Areas." The Commission further 

recommends that voluntary measures be taken in local areas in 

and near Class I areas to control emissions of dust from paved 

and unpaved roads. Consistent with other Commission recommendations, there is also a recognized need to develop an accurate 

emissions inventory and an improved air quality model for 

controlling or managing this specific source sector. Finally, 

if visibility impacts are validated, the Commission recommends 

that performance standards for road dust emissions be 

developed. 

Due to considerable skepticism regarding the modeled 

contribution of road dust to visibility impairment, the 

Commission recommends further study in order to resolve the 

uncertainties regarding both near-field and distant effects of 

road dust, prior to taking remedial action. Since this 

emissions source is potentially such a significant contributor, 

the Commission feels that it deserves high priority attention 

and, if warranted, additional emissions management actions. 
 53

 FIRE

Background: Fire Emissions and Visibility

Fire has played a major role in the development and maintenance of 

most ecosystems in the West. The long-term future of the West is 

dependent on healthy ecosystems that are capable of sustaining 

natural processes and human uses. 

An increase of accumulated forest fuels in the West has occurred 

because of past land management practices, including decades of 

fire suppression. Evident ecosystem changes include increasing 

tree densities, disrupted nutrient cycling, and altered forest 

structure. As a result, wildfires are becoming larger in size, 

unnaturally destructive, and more dangerous and costly to control. 

In 1994, wildfire burned 3.1 million acres in the West and cost $1 

billion dollars in direct suppression costs while causing 

firefighter deaths and serious human health impacts. Rectifying 

this problem will take years and is a basic responsibility of wise 

land stewardship. Fire is an essential component of most natural 

systems, and perpetuation of fire at a level required to maintain 

ecosystem processes is necessary. The natural role of fire in the 

wildland/urban interface must also be addressed to protect life 

and property. A substitute for fire and its natural role has not 

been found in many ecosystems. The objective of future prescribed 

fire programs is to cooperatively meet land management, human 

health and visibility objectives. 

Emissions from fire (wildfire and prescribed fire) are an 

important episodic contributor to visibility-impairing aerosols, 

including organic carbon, elemental carbon, and particulate matter 

(PM2.5). Agricultural burning emissions and their effects have been 

identified as a concern of the GCVTC but have not been quantified 

due to a lack of data. All types of fire (prescribed fire and 

agricultural burning) must be addressed equitably as part of a 

visibility protection strategy. This may require state legislation 

in some cases. 

Discussion of Management Alternatives

Wildfire impacts are increasingly uncontrollable or unmanageable, 

due to excessive fuel loads, except through the application of 

prescribed fire and/or mechanical means, such as brush removal and 

logging. Field experience has shown that prescribed fire can 

reduce the size, frequency, and intensity of wildfires. Areas that 

have been treated with prescribed fire demonstrate much less 

burning in the tops of trees and a slowing of wildfire spread. 

Prescribed fire therefore promotes better fire control, 

predictable fire effects and allows for management of emissions as 

compared to wildfire. 
 54

The future use of prescribed fire and the restoration of fire in 

its natural role with natural fuel loadings will provide 

sustainable ecosystems where environmental and human health 

impacts can be managed. This future desired situation contrasts 

with the current adverse public health impacts and permanent 

damage to natural resources and property from wildfires. Wildfires 

are causing exceedances of ambient air quality standards and air 

quality-triggered community evacuations with greater frequency. 

Prescribed fire programs will influence future wildfire in many 

locations of the West. However, infrequent large-scale forest 

replacement wildfire will still occur naturally in some vegetation 

types. 

Land managers employ emission reduction and smoke management 

techniques to reduce air quality impacts of prescribed fire. 

Current smoke management techniques take into account the timing 

and location of burns so that impacts on human health are reduced. 

These techniques can be expanded to reduce current and future 

impacts on visibility. Emission reduction techniques can also be 

utilized to reduce the quantity of emissions from a prescribed 

burn. The appropriateness and effectiveness of emission reduction 

techniques vary based on vegetation type, burn objectives, 

location, other environmental constraints such as water quality, 

and funding. Effective agricultural smoke management programs have 

been developed in some states using similar measures. 

Utilization of mechanical treatments such as logging or firewood 

sales to remove fuels will be necessary in some areas prior to 

prescribed burning. The potential use of mechanical treatments is 

limited, however, since large areas of the West are not physically 

available due to inaccessibility, slope or soil sensitivity. 

Significant emission reductions from mechanical treatment would 

only occur in timber areas. Administrative constraints, such as 

wilderness or habitat protection, also impose limitations. 

Approximately 30% of the total timber area has the potential to be 

treated using mechanical methods. In areas where mechanical 

treatments are used alone, some level of prescribed fire treatment 

may still be necessary. Mechanical treatment cannot replace the 

natural role of fire in ecosystem health and sustainability 

processes. 

 

In order to address the fuels problem and ensure adequate 

protection of visibility in the West, funds will need to be 

greatly increased. With the development of increased prescribed 

fire programs, it is crucial to fund smoke management programs 

that protect public health and visibility, while meeting the 

underlying land management objectives. 

 RECOMMENDATIONS REGARDING FIRE

1. Plan for the visibility impacts of smoke.
 55

The Commission recommends that the EPA require all federal, 

state, tribal, and private prescribed fire programs to 

incorporate smoke effects in planning and application by the 

year 2000. 

2. Implement an emissions tracking system for all fire 

activities.

A consistent emissions tracking system for prescribed fire, 

wildfire, and agricultural burning should be implemented 

region-wide. 

3. Improve integrated assessment of emissions.

Federal, state, tribal and private land managers, in conjunction 

with relevant regulatory agencies and interested parties, 

should improve the current integrated assessment of emissions 

from prescribed fire, wildfire and agricultural burning by 

1999. The assessment should: 

a) identify specific areas where fire activities have or could 

have an adverse impact on health and visibility; 

 

b) identify areas where mechanical treatments could substantially reduce emissions and subsequent impacts on health and welfare; 
 56

c) in the areas identified, assess the feasibility of biomass 

utilization (woody material use), market development, and nonstatutory administrative barriers11; and 

d) assess meteorological information needs, air quality monitoring needs, smoke dispersion model needs, interstate planning 

needs, wildfire/prescribed fire trade-offs (economics, air 

quality and other resource effects), and emission factor 

research (vegetation/fuels and effects of emission reduction 

techniques). 

4. Enhance smoke management programs.

The Commission recommends the development and implementation of 

criteria and requirements for the use of enhanced smoke 

management programs (including alternative management 

practices) and emission reduction strategies in the identified 

areas. Such programs should consider factors of efficiency, 

economics, law, land management objectives, and reduction of 

visibility impacts. States, tribes, state and federal land 

management agencies and private parties should create and 

implement smoke management programs that address public health, 

visibility and land management objectives by the year 2000, 

using the results of the assessment listed in Recommendation 

#3. 

 5. Develop cooperative funding mechanisms.

The Commission promotes the development of cooperative funding 

mechanisms between burners and regulatory agencies to implement 

increased smoke management programs and integrated assessment 

costs. 

 6. Promote public education programs.

The Commission supports the creation of a public education 

program regarding the role of fire in air quality, to be 

undertaken by land managers and other interested governmental 

and private groups. 

7. Establish annual emission goals for fire programs. 

The Commission recommends that annual emission goals for all 

fire programs, where appropriate, be established by the year 

2000. These goals will be set to minimize emission increases 

from such programs to the maximum extent feasible. The goals 

will be established cooperatively by states, tribes, state and 

federal land management agencies and their private sector 

counterparts. 

 11 In identifying areas where alternatives to burning are appropriate, it is not the intent of the 

Commission to require actions that are inconsistent with applicable laws or regulations.
 57

8. Remove administrative barriers to the use of alternatives to 

burning. 

The Commission recommends that the federal land management 

agencies and their state, tribal, local and private 

counterparts identify and remove non-statutory administrative 

barriers to emission reduction strategies by the year 2000, to 

the maximum extent feasible. In removing such barriers, the 

Commission intends that subsequent actions will be undertaken 

consistent with applicable laws and regulations. 
 58

 CLEAN AIR CORRIDORS 

Background 

One finding of the Commission's process is that clean air 

corridors exist. One such source of clean air studied by the 

Commission covers major portions of Nevada, southern Utah, eastern 

Oregon and southwestern Idaho. This area provides clean air days 

at Grand Canyon National Park. Projected emissions growth through 

2040 within the studied clean air corridor is not expected to have 

a perceptible negative effect on visibility at Class I sites. 

Clean air corridors also influence visibility at other Class I 

sites in the Colorado Plateau, although the precise relationships 

have not been fully established at this time. In order to ensure 

that sources of clear air for all Class I sites on the Colorado 

Plateau are protected, additional data collection and analysis 

will be needed. 

 RECOMMENDATIONS REGARDING CLEAN AIR CORRIDORS

 1. Do not establish special targeted programs at present.

The Commission considered whether special programs or regulations were needed in clean air corridors in order to protect 

the clean air provided to Class I sites on the Colorado 

Plateau. Given the Commission's findings, there is no present 

need for special targeted policies or regulatory programs to 

control emissions growth within clean air corridors beyond 

existing laws and programs. In addition, clean air corridors 

will be covered by other regional initiatives recommended 

elsewhere in this report. 

 2. Improve regional tracking and monitoring.
 59

Because uncertainties in data and forward projections exist, a 

regional tracking and accounting system is needed to make sure 

that the frequency of clear days increases or does not decrease 

at Class I sites and that the Commission's present assumptions 

regarding population and economic growth and the resulting 

effects on increased emissions prove reliable. In addition to 

these concerns, a regional tracking and accounting system 

should: 

a) within areas that are sources of clear air, identify patterns 

of growth or specific sites of growth that cause significant 

emissions increases having a negative impact on visibility at 

one or more Class I sites on the Colorado Plateau; 

b) in areas outside of clean air corridors, identify significant 

emissions growth that begins to impair the quality of air in 

the corridor and thereby reduce the frequency of clean air days 

at Class I sites; and 

c) continue technical studies to see whether other sources of 

clear air exist and take measures, if needed, to protect 

against future degradation of air quality in these areas. 

 3. Establish triggers for additional action.

The occurrence of any of the conditions described in paragraph 

#2 above should trigger analysis of the effects of increased 

emissions and the implementation of additional measures to 

protect clean air days, if necessary. 
 60

 EMISSIONS WITHIN AND NEAR CLASS I AREAS

Background

Emissions from within and near Class I areas contribute to 

impaired visibility. Transportation-related emissions and other 

emissions from energy use are of particular concern. Prescribed 

fire emissions are also a concern since land managers plan to 

increase necessary prescribed fire activities in order to restore 

natural fire cycles and preserve natural ecosystems. 

National park general management plans and forest land management 

plans are appropriate ways to address some contributions to 

visibility impairment at Class I areas. National Park Service 

(NPS) nation-wide policy is to mitigate visibility impairment and 

other air quality effects from in-park sources by reducing 

emissions and incorporating sustainability concepts into all plans 

and management decisions. The NPS has already implemented several 

innovative approaches to pollution prevention in many Colorado 

Plateau parks and intends to do more. These actions include more 

in-park transportation systems (such as low-emission shuttles), 

conversion of park vehicle fleets to cleaner fuels, increasing 

energy efficiency, and taking other steps at parks on the Colorado 

Plateau. 

The Commission recognizes the importance of visibility issues 

related to emission sources in and near Class I areas, and 

supports funding for these transportation, energy, and other 

programs that help improve visibility. 

 RECOMMENDATIONS REGARDING EMISSIONS 

 WITHIN AND NEAR CLASS I AREAS

1. Implement park and wilderness planning processes.

Federal land managers, through their planning processes, should 

strive to limit and reduce visibility impairing emissions 

within Class I areas. Land managers should also use existing 

opportunities, such as the states’ required consultation 

process with federal land managers in the review of state 

visibility protection plans (discussed below), to inform the 

appropriate regulatory authority regarding agency actions and 

strategies taken or planned within Colorado Plateau Class I 

areas to prevent or reduce pollution emissions that affect 

visibility. 

 Specifically, such plans or actions would assure that: 
 61

a) emissions growth from human-caused sources within the Class I 

area does not cause visibility to deteriorate; 

b) human-caused sources within the Class I area (or that result 

from activities within the area) that contribute to existing 

visibility impairment are mitigated; and 

c) prescribed fire programs (excluded from 1a. and b. above), 

after considering and applying non-fire alternatives whenever 

possible, seek to minimize emissions and visibility impacts 

through smoke management and emissions reduction measures. 

2. Develop strategies for nearby communities and activities.

All significant sources or combinations of sources near each 

Class I area must be examined and cooperative, enforceable 

management strategies developed and implemented among tribal, 

local, state, federal, and private interests, as necessary, to 

assure reasonable progress toward no human-caused impact on 

visibility (the national visibility goal). The development of 

management strategies must take into account such equityrelated concerns as relative contribution to visibility 

impairment and whether any one population (such as lower-income 

groups) is unfairly burdened by the strategies. Regulatory and 

planning authorities have a pivotal role in assuring that 

sources near Class I areas are inventoried and assessed, and 

that their emissions are mitigated with regard to visibility 

impacts on these areas. Existing planning and regulatory 

mechanisms should be strengthened and funded to create a 

systematic approach to address this issue. For example, 

existing regulatory requirements for long-term visibility 

strategies and their review and revision no less than every 

three years should be enforced. 

 To this end, all land managers should: 

a) be vigilant and aggressively pursue opportunities to 

participate in external planning arenas where decision-making 

could have effects on visibility in nearby Class I areas; 

b) review permit applications for new or modified stationary 

sources proposed for construction and operation near Class I 

areas; and 

c) request that the appropriate regulatory authority (or 

authorities) propose emissions reduction strategies for nearby 

sources that contribute to existing visibility impairment, 

either during development of the visibility protection plans or 

during the required periodic review of such plans. 

Regulatory programs should provide exemptions for tribal 

ceremonial practices and for people who are dependent on a 

single source (wood or coal) of heating and cooking. 
 62

 3. Apply existing regulatory requirements.

Regulatory and planning authorities are already required to 

develop, maintain, and enforce visibility protection plans for 

mitigating nearby source impacts on the Class I areas. 

Regulatory agencies should develop criteria for these plans 

that are consistent across the Transport Region. An important 

element of this activity is the development and maintenance of 

an emissions inventory, tracking, and reporting program for 

each Class I area. The authorities must consult and actively 

involve the respective Class I area land manager(s) throughout 

the process. 

 4. Utilize other planning processes.

Federal land managers and authorities in local political 

subdivisions and on tribal lands should perform analyses of 

potential visibility impacts to Class I areas on the Colorado 

Plateau and include them in land management plans for lands 

located near these areas. 
 63

 TRANSBOUNDARY EMISSIONS FROM MEXICO

Background

Pollution from stationary, mobile and area-wide emission sources 

in Mexico contributes to visibility degradation in the Colorado 

Plateau's Class I areas. Expected economic development in the 

border region will likely exacerbate transboundary pollution 

transport unless steps are taken to reduce and prevent pollution. 

The Commission lacks the authority to address these transboundary 

pollution problems directly, but should support several ongoing 

efforts to develop emissions inventories, establish binational 

institutions and bilateral agreements to facilitate cooperation, 

and create incentives for implementation of cost-effective air 

pollution abatement strategies. 

 RECOMMENDATIONS REGARDING EMISSIONS FROM MEXICO

Mexican sources are a significant contributor, particularly of 

SO2 emissions. However, data gaps and jurisdictional issues 

make this a difficult issue for the Commission to address 

directly. The recommendations below call for continued 

binational collaboration to work on this problem, as well as 

additional efforts to complete emissions inventories and 

increase monitoring capacities. The Commission feels that they 

should receive high priority for regional and national action. 

 1. Develop a comprehensive emissions inventory. 

Characterizing and quantifying emissions from sources in Mexico 

provide a necessary foundation for developing emissions management options. Some data exist as a result of past or ongoing 

governmental efforts. In addition, the Western Governors' 

Association, in cooperation with Mexican government officials, 

is developing methodologies for preparing an emissions 

inventory for the entire border region. The Commission supports 

these efforts. 

2. Establish binational institutions and agreements. 

The Commission urges the EPA, the U.S. State Department, and 

affected states to make effective use of opportunities provided 

by existing binational treaties and agreements. For example, 

Annex V to the 1983 La Paz Agreement directs the EPA and INE 

(the National Institute of Ecology of Mexico) to assess the 

causes of, and develop solutions to, air quality problems in 
 64

border sister cities. As a result, the U.S. and Mexican governments have developed an environmental plan for the border that 

is periodically revised (next revision: summer 1996); the 

National Coordinators meet regularly to discuss progress; and 

working groups composed of federal and state officials (e.g., 

the Border Air Working Group) have been established to address 

pollution problems in various media. The Border Governors' 

Association also examines environmental problems in the border 

region. The Commission supports these activities and is 

prepared to work cooperatively with these groups as necessary/-

appropriate. 

3. Develop community mechanisms for cooperative transboundary 

planning.

While pollution transport from Mexico affects the West generally, local communities in the border region are most severely 

affected and have the greatest need to develop cooperative, 

creative approaches. Greater local involvement in decision 

making will likely lead to more effective and expeditious 

pollution abatement strategies. The Commission supports the 

designation of international air quality management districts 

in border cities and the establishment of community-based 

binational committees charged with developing air quality 

management plans. The U.S. and Mexican governments are 

currently negotiating an international agreement to 

institutionalize such an approach in the "Paso del Norte" 

region (El Paso, Texas; Dona Ana County, New Mexico; and Ciudad 

Juarez, Chihuahua). The Commission supports this effort and 

recommends that the respective federal governments consider 

expanding this type of approach to other border communities. 

 4. Finance air pollution control projects.

The Commission recommends that the governments of the U.S. and 

Mexico utilize several new institutions established by the 

North American Free Trade Agreement to improve air quality. 

Although there are critical needs in the areas of water supply 

and treatment, the Commission urges the Border Environmental 

Cooperation Commission (BECC) and the North American 

Development Bank (NADBANK) to apply available capital for 

border infrastructure projects to high priority air pollution 

problems whose resolution will have marked effects on regional 

air quality (e.g., emission control technology on major 

industrial or electricity-generating facilities). 

5. Provide incentives for transboundary investment in pollution 

control.

The Commission encourages the EPA to explore the feasibility of 

allowing U.S. industries to earn emission reduction credits for 

investment in pollution control and prevention projects in 

Mexico. These might be applied to existing Clean Air Act 

programs for nonattainment areas or as part of a western 
 65

regional emissions management program implemented to protect 

visibility. Criteria and procedures for awarding appropriate 

credits should be developed to provide an incentive for 

investment in transboundary pollution control projects that 

would have a beneficial impact on air quality in border 

communities and throughout the western United States. The 

ongoing international negotiations directed at the Paso del 

Norte region mentioned above include consideration of 

conducting a feasibility analysis for an international 

emissions trading program. The Commission should support this 

effort. Conversely, the Commission supports disincentives to 

discourage U.S. companies from investing in facilities in 

Mexico that do not achieve pollution control levels comparable 

to those required in the United States. 

6. Pursue pollution control projects at specific major sources 

in Mexico. 

The construction and operation of major stationary sources in 

Mexico may be a significant cause of long-distance pollution of 

Class I areas on the Colorado Plateau. The Commission 

encourages the respective federal governments to pursue, 

through international negotiations and agreements, implementation of pollution reduction strategies aimed at specific 

facilities that may be found to have identifiable impacts on 

the Colorado Plateau. 
 66

 FUTURE SCIENTIFIC AND TECHNICAL NEEDS

Introduction12

Many of the recommendations in this report call directly for 

continued, expanded or improved collection of technical 

information in order to provide the basis for future regional 

policy recommendations and development of appropriate 

implementation strategies by tribes, states and federal agencies. 

In order to implement some of the recommended programs, additional 

technical data will have to be collected, interpreted and modeled 

on an ongoing and regional basis. 

The following sections of this report and related recommendations 

include reference to technical needs: 

Stationary Sources: In order to track emissions targets and/or 

to implement a regional cap and trading program, an improved 

emissions monitoring and accounting system will be needed. 

Mobile Sources: The recommendations call for establishing mobile 

source emissions budgets for selected major urban areas, which 

will require accurate data collection. 

Area Sources: The recommendations call for improved modeling of 

road dust effects, setting up an emissions tracking system for 

all fire activities, and improved integrated assessment of 

emissions. 

Clean Air Corridors: Regional tracking and monitoring of 

emissions is needed in order to make sure that the Commission's 

projections regarding the relative insensitivity of sources of 

clear air prove correct. 

Transboundary Emissions from Mexico: Cooperative work with 

Mexican officials and corporations requires an accurate 

emissions inventory. 

Air Quality on Tribal Lands: There is a need for more 

comprehensive emissions inventories for areas on and near 

tribal areas as well as monitoring of air quality on tribal 

lands. The limitations of present models do not permit modeling 

of impacts on tribal lands. 

In general, four types of initiatives are required to meet the 

 12 For a more comprehensive discussion of technical and scientific needs, see "Subcommittee 

Report on the Future Needs of the Commission," November 6, 1995, developed by a subcommittee of the 

Public Advisory Committee. 
 67

technical needs of future programs: improved emissions 

inventories, expanded monitoring of visual air quality, refined 

modeling capacities, and improved assessment information and 

methods. 

Emissions Inventory

The emissions inventory developed by the Commission represents all 

known emissions of visibility-impairing pollutants from all known 

sources. Programs which call for assessment of reasonable progress 

toward the national air quality goal based on targeted emission 

reductions, or on model-projected estimates of improvements, will 

require an accurate and complete emissions inventory. The current 

GCVTC emissions inventory represents cooperative work among many 

in the region and an advance in comprehensive data collection, but 

the emissions inventory process can and should be improved. 

A substantial effort will be needed to coordinate and update 

continuously the emissions inventory to reflect actual emissions 

in the region on a year-by-year basis. In addition, any disparity 

in methods for developing emission estimates by any entity, 

whether federal, state or tribal, must be adjusted or equalized in 

order to assure a consistent inventory. This will be particularly 

critical if a regional trading program is implemented where tons 

of emissions from one state or tribal land may be traded for tons 

of emissions from another. If the emissions inventory 

methodologies are different, then it will be difficult to assess 

the true impact of trading programs among various jurisdictions. 

Air Quality Monitoring

Now that the Commission has completed these recommendations to the 

EPA, it will be necessary to measure and report on reasonable 

progress toward the goal of remedying existing and preventing 

future impairment of visibility in mandatory Class I areas. This 

implies that federal, state, tribal, and local air quality 

agencies must be committed to a long-term monitoring program. 

The current federal visibility monitoring program (IMPROVE) 

distributed monitoring sites to address national needs at Class I 

areas throughout the country. IMPROVE has led to limited visual 

air quality data collection in the GCVTC region. There are sixteen 

Class I areas on the Colorado Plateau that have been selected as 

requiring visibility protection. Of these sixteen sites, limited 

monitoring is currently being done at only six sites: 

· Bryce Canyon National Park 

· Canyonlands National Park 

· Grand Canyon National Park 

· Mesa Verde National Park 

· Petrified Forest National Park 

· Weminuche National Wilderness Area 

While these sites are reasonably representative of visual air 
 68

quality conditions on the central Colorado Plateau, existing 

visibility in the vast majority of the region, especially on 

tribal lands, has only been inferred from the current IMPROVE data 

set. 
 69

Modeling

In general terms, air quality models are needed to convert 

emissions from all sources and areas into an estimate of 

visibility impairment at the key receptors (Class I sites) on the 

Colorado Plateau. The Commission's committees and contractors have 

developed a model that roughly approximates how weather and 

emissions result in air quality at Class I sites.13 Further 

development of regional models is needed to more accurately show 

the relationships among emissions sources and effects at specific 

Class I sites under specific conditions, in order to resolve the 

limitations of the present model. Further, future modeling efforts 

should assess expected wide-reaching effects from electric utility 

industry restructuring. 

Assessment Information and Methods

The key inputs to the IAS include, in addition to technical inputs 

described above, information related to the current levels of 

controls and installed technologies on sources, the control 

options that are available for sources (including costs and 

efficiencies), and methods to project changes in the future. 

These need to be significantly improved to reduce uncertainties in 

assessing or forecasting the effects of emissions management 

options. In addition, the methods for evaluating overall economic 

effects and other secondary assessment criteria must be improved. 

 RECOMMENDATIONS REGARDING FUTURE 

 SCIENTIFIC AND TECHNICAL NEEDS

The Commission foresees that the following regional scientific 

and technical work will need to be done. The tasks may be 

performed by a combination of state, tribal, and federal 

organizations, with coordination by a regional body. 

 EMISSIONS INVENTORY

 1. Secure adequate long-term funding.

Emissions inventories require significant human and financial 

resources. Enough resources must be allocated to the task from 

state and federal sources. 

2. Develop and update a regional emissions inventory. 

A quality inventory must be completed and then updated on a 

regular basis. A complete plan should be developed prior to the 

start of data collection. All states, tribes, and federal 

agencies should follow this plan, so that data collection 

methods are compatible for all areas and sources. 

 13 The accomplishments and limitations of the present model are discussed in Section II.
 70

3. Standardize comprehensive data collection.

Inconsistencies and gaps in the emissions inventory should be 

addressed, including the following: 

a) current inconsistencies in the ways states collect and 

quantify emissions data; 

b) emissions inventory information for agricultural activities; 

c) all data collection for a single calendar year; 

d) a mechanism to accept/reject/determine factors to fill in data 

gaps; 

e) information regarding current levels of controls; and 

f) emissions inventory data specific to tribal lands. 

4. Develop agreements on how data will be used.

Agreement should be reached on how and for what purposes the 

data will be used. For instance, states, tribes and federal 

agencies should determine whether inventories and analyses 

developed for regional programs and policy development can or 

should be incorporated into national databases. 

5. Develop adequate trained human resources.

Agencies should be staffed to conduct and maintain emissions 

inventories. In the past, the EPA has not placed a high 

priority on emissions inventories even though they provide the 

basis for state or tribal implementation plans, rulemaking and 

application of Section 169B of the Clean Air Act. 

6. Address the need for micro-inventories.

A greater emphasis should be placed on micro-inventories of 

emissions for areas in and near Class I Areas and other areas 

of concern, such as tribal lands. Modeling indicates that 

nearby sources may have a greater impact on visibility than 

sources at a greater distance on a per ton basis. As such, 

comprehensive micro-inventories are needed for the near-field 

around Class I areas. Without them, it will be impossible to 

reliably identify that portion of the contribution to 

visibility impairment caused by long-range transport of 

regional haze. 
 71

 7. Agree on an emissions forecasting methodology. 

Agreement should be reached on the source of information and 

methods to be used to forecast future emission changes related 

to economic growth and anticipated effects from control 

programs. 

 AIR QUALITY MONITORING

1. Continue and expand the number of monitoring sites and 

frequency of sampling.

The current IMPROVE monitoring network only measures aerosol 

samples twice a week and at only a few Class I sites. Thus, 

five-sevenths of the time, the chemical make-up of the 

particulates contributing to visibility impairment is unknown. 

Consideration should be given to expanding the coverage or 

redeployment of resources in the IMPROVE network to enhance 

completeness of the data set, including on tribal lands. In 

addition, background surveillance sites could be established at 

intermediate locations between the Class I areas and large 

regional sources (metropolitan areas) to provide a better 

understanding of the intermediate course of atmospheric 

chemistry and transport. Monitoring should be maintained at 

existing sites in order to allow for long-term trend analysis. 

 2. Establish three essential components.

The three fundamental components of a future visibility 

monitoring program should be: 1) light extinction measurements 

from transmissometers; 2) aerosol chemistry measurements from 

fine/coarse-mass-particulate samplers; and 3) meteorological 

measurements of wind speed, direction, temperature, and 

humidity. Tribal lands would be particularly appropriate sites 

for tracking and monitoring case studies. 

 MODELING

Both sophisticated and reduced form models are needed. Once 

these methods and data are in hand, any simulation can be 

prepared. In other words, the two types of issues placed before 

the GCVTC of subregional or region-wide issues can be assessed 

with equal facility. 

1. Develop a comprehensive, sophisticated model.

A comprehensive model must be able to match its predictions of 

air pollution and visual air quality with actual observations

of both factors. This model should generate output at least on 

a twelve-hour basis using emissions and meteorological 

observations on this time scale. To reproduce the observations 

on a space and time basis, there is a need for accurate 
 72

emissions data over the entire modeling area, reliable wind 

fields, cloud and other climatological data, and samplings of 

pollutants and visual air quality, as well as dependable 

algorithms for the physics and chemistry of transport and the 

transformation of pollutants during transport and deposition. 

This model is likely to be sufficiently complicated that it 

would have to be run on a sophisticated computer. To the extent 

that interpretation of fine grid geography or of urban plumes 

is necessary to match the data, this capability should be 

included. The model must also be able to accurately model both 

near-field (within about 30 miles) and far-field effects. 

2. Develop a "Reduced Form Model."

A second type of model will be needed for assessing the effects 

of control options on emissions and visual air quality. This 

would be a reduced form model (RFM) that can be installed on a 

personal computer and run in seconds to minutes to convert 

emissions into estimates of ambient fine particle loadings and 

visual air quality. This model should relate emissions of 

various species from the source regions of the entire study 

area to data collected at receptor sites in the Class I areas 

of interest. 

The RFM needs to be able to replicate the predictions of the 

more comprehensive model. Therefore, the transfer coefficients 

should be constructed by the comprehensive model for use in the 

RFM. 

 3. Assess impacts of new sources. 

The existing visibility protection program requires a review of 

visibility impairment from new or modified major stationary 

sources to prevent adverse impact on visibility in nearby Class 

I areas as part of the source permitting process. This is 

currently done following guidance issued by the Inter-Agency 

Workgroup for Air Quality Modeling. This review is needed to 

prevent future attributable impairment. To assess regional 

impacts, new sources should be incorporated as part of the 

process to address "reasonable progress." As noted above, EPA 

should develop appropriate guidance on new, large-scale 

regional models which will be able to incorporate all source 

impacts. 

4. Obtain improved meteorological data.

Large-scale regional models are highly dependent on input of 

meteorological data. The wide separation between locations that 

measure winds aloft (i.e., National Weather Service balloon 

stations) contributes a high degree of uncertainty to the 

results of the modeling. Consideration should be given to 

expanding the network of sites that collect upper air 

soundings. In addition, local meteorological data at the Class 

I areas are needed to identify potential local source impacts. 
 73

The coordination of region-wide intermittent control systems 

(such as region-wide smoke management) will necessitate an 

expansion in the meteorological data collection network in 

order for such a system to be effective. 

 ASSESSMENT TOOLS AND METHODOLOGY

1. Undertake more detailed economic studies.

More detailed economic studies are needed in order to determine 

more accurately the costs of controls and, of more importance, 

to understand the effects, both positive and negative, past and 

future, that these costs have on the local and regional 

economies and their growth. Potential economic effects needing 

more study include: economic benefits of cleaner air (such as 

to tourism), impacts of costs on companies and individuals that 

pay them (for instance, effects on profits, competitiveness and 

disposable income), and the feedback of control expenditures 

into other industries in the region (such as pollution 

controls, parts and services and electricity production to 

operate controls). 

 2. Develop better assessment tools and methods. 

In order to provide an objective analysis of the effects of 

emissions management strategies for regional haze, specific 

components of research and development are needed, including: 

a) expanded and improved inventory of control options and costs 

for use in assessments; 

b) establishment of a mechanism to aggregate sources into 

assessment groups consistent with the spacial distribution of 

air quality modeling and economic assessment regions; 

c) improved econometric analysis tools and techniques to 

characterize more accurately subregional, including tribal, 

impacts; and 

d) upgraded methodological approaches for performing secondary 

assessments. 
 74

 SECTION IV: TRIBAL PERSPECTIVES 

 AND POSITION REGARDING RECOMMENDATIONS 

Introduction

The following section provides background regarding tribal 

participation in the Commission process and the legal framework 

for tribal relationships with states and the federal government. 

Tribal participants in the process have also provided their unique 

perspectives on the Commission's recommendations, commenting on 

how those recommendations may affect tribal lands and peoples. 

In large part, the tribal participants support the guiding 

principles set forth in Section III of this report and agree with 

the Commission's recommendations, as discussed in more detail 

below. In some instances, however, the tribal participants wish 

to highlight certain points made in this report or provide a 

distinct perspective and emphasis arising from tribal experience. 

These views are also set forth in this section. 

The Tribal Environment

It is the philosophy of most Indian tribes that the quality of 

life of their members is intimately related to the quality of 

their environment, and that people and nature should be in harmony 

and balance. Vistas are important to tribes in spiritual and 

cultural ways but they are also important for economic reasons. 

The pristine and visible beauty of their homelands are often the 

reason for tourist visitations. These visitations support tourism 

and many cottage industries on the reservations and provide 

revenue for tribal governments. 

As "harmony" requires, tribes also recognize that tribal 

populations are increasing and tribal governments must address the 

needs of their developing nations. Tribes are working to develop 

their economic infrastructure so that they can achieve selfsufficiency and provide for their people, including revenues for 

tribal governments. Tribal governments provide community services, 

such as road maintenance, water, environmental protection, 

education, health care, day care and other social services. As in 

any community, the demand for these services is expected to grow 

with the population, and tribes desire to grow economically to 

support these demands. 

In order to achieve these goals, tribes cannot be unfairly 

burdened by regional or federal regulations. Any recommendations 

must ensure that emission control burdens do not fall 

disproportionately upon tribes. It must be remembered that tribes, 
 75

by and large, have not contributed to the visibility problem in 

the region, precisely because of the lack of economic development 

in Indian country. Therefore, what is fair for states may not 

necessarily be fair for tribes. Tribal economies are much less 

developed than those of states, and tribes must have the 

opportunity to progress to reach some degree of parity with states 

in this regard. Further, economic and cultural differences may 

magnify the effects of recommended emission controls. 

Acknowledgements

Tribal government approval and support of the Commission's recommendations is 

reserved to individual tribal government discretion. This reservation is not intended to 

represent rejection of efforts to arrive at consensus-based policy recommendations. 

Rather, it is based upon the legal and historic status of tribes as individual tribal nations; as 

sovereigns, tribal governments have the prerogative to deal directly with the federal 

government and may choose to do so in regard to western visibility protection and 

improvement. Whatever actions tribal governments ultimately choose to direct or pursue, 

they nevertheless have found value in working within the GCVTC process and have 

directed tribal representatives to learn from the GCVTC deliberations and contribute to the 

best of their abilities toward achieving a good that will benefit all people in the West. 

A number of tribes have been represented on the Commission and on the various 

committees established by the Commission. Although these "tribal participants," as they 

are called in this report, do not represent all 211 tribes in the Transport Region, as 

individual participants in the GCVTC process they have joined together and reached 

consensus on a number of issues, as reflected in this report. When this report presents 

tribal positions on the Commission's recommendations, therefore, it is presenting the views 

of these tribal participants. 

Co-Management Principles 

The Grand Canyon Visibility Transport Region, as defined by the EPA, includes 211 tribes. 

Therefore, visibility improvement and protection strategies ultimately adopted by the EPA 

must be selected and implemented not only in light of statutory requirements of reasonable 

progress toward visibility, but also in light of certain basic principles of Indian law. The 

GCVTC recognizes and respects that the federal and tribal governments have a unique 

government-to-government relationship that is built on historic legal principles. The 

Commission's recommendations must be considered, not in terms of a federal-state 

framework, but in terms of a federal-state-tribal framework. These principles of Indian law 

and their ramifications for the Commission are set forth below. 

 Tribal Sovereignty 

It is a basic principle of Indian law that tribes have inherent sovereignty over tribal lands, 

or "Indian country." Moreover, if a tribe does not assert its jurisdiction in a particular 

instance, then the federal government may have jurisdiction in the tribe’s place, but a 
 76

state government could not. As a result, emission management strategies will be 

implemented within Indian country by tribal governments or, failing that, by the federal 

government, but not by state governments. 

 Federal Trust Responsibility

The Courts have found that the federal government bears a trust responsibility toward 

American Indian tribes. This imposes fiduciary duties on the conduct of federal 

agencies toward Indian tribes and their natural resources. The trust relationship 

therefore presents a second basis, in addition to the principle of tribal sovereignty, for 

the EPA and other federal agencies involved in the GCVTC process to ensure that 

tribal interests are protected in any regulatory scheme. 

Tribal Self-Determination

As acknowledged by Congress in the Indian Self-Determination and Education 

Assistance Act, there must be "effective and meaningful participation by the Indian 

people in the planning, conduct and administration" of programs affecting Indian 

people [25 U.S.C. § 450a(b)]. These principles are also embedded in the EPA policy 

for the Administration of Environmental Programs on Indian Reservations (November 

8, 1984) in which the EPA states that it will "view Tribal Governments as the 

appropriate non-Federal parties for making decisions and carrying out program 

responsibilities affecting Indian reservations, their environments, and the health and 

welfare of the reservation populace." Each tribe is the decision-maker for its own 

future and is responsible for ensuring that the needs and rights of its people are met 

and protected. Tribal concerns must be taken into account in formulating recommendations. 

Tribal Impacts Reports and Studies

Tribal participants feel that the report Impact Projections of Emission Management 

Scenarios on Western Tribal Lands (January 1996), was inadequate and provided only 

very general conclusions. The various other studies undertaken by the Commission did not 

adequately evaluate and describe the unique economic structures and demographic 

patterns of Indian tribes, nor their unique cultures and aspirations. Also, the studies very 

narrowly focused on straight line economic cost/benefit analysis. Other values are 

important to tribes: quality of life, freedom of religion and choice in lifestyle, to name a few. 

Future studies should address these important areas of concerns so that the tribes, and 

those concerned about impacts on tribes, will be able to more fully evaluate management 

option impacts. 

Tribes were greatly disappointed that secondary assessment studies were not fully carried 

out. Little or no work was done to identify impacts on health and welfare, land and water 

uses, solid and hazardous waste disposal, threatened and endangered species, and 

terrestrial and aquatic ecosystems. This information would have been of great interest to 

the tribes and probably many others. 
 77

Program Implementation

Tribal governments have the responsibility to develop, implement, and manage programs 

within Indian country. If a tribe chooses not to establish a program, then the federal 

government has the trust responsibility to establish a program. Thus if the EPA 

promulgates a rule based on a control technology scenario, for example, tribes must have 

the option of implementing the rule within Indian country or prompting federal implementation of the rule within Indian country. Similarly, a market trading scenario in which there was 

separate tribal participation or federal participation on behalf of the tribes could be 

legitimate. 

Many tribes are just beginning to develop environmental programs, and these programs 

receive very minimal funding from the EPA, if any. Tribal governments also lack the tax 

base available to states to help fund environmental programs independently. Therefore, 

tribal implementation of visibility programs will require policy development support, 

technical assistance, and program funding. 

In the implementation of an emissions trading program, special consideration for tribes is 

necessary. Given that many tribal lands are "underdeveloped," tribes should be allocated 

some additional share of trading credits to allow for future development, much as "clean" 

states were under the acid rain trading program. 

Tribes, states, local governments and federal agencies must find innovative ways to 

support implementation of regional haze programs. Memoranda of Understanding or 

Memoranda of Agreement, and/or other state/tribal/federal agreements, could be utilized to 

share resources, expertise and responsibility. 

TRIBAL PARTICIPANTS' POSITIONS ON COMMISSION RECOMMENDATIONS

As discussed above, the tribal participants for the most part concur in the Commission's 

recommendations set forth in this report. Specifically, the tribal participants agree with all 

six of the assessment criteria listed on page 20-21 of this report, although the tribal 

participants feel that the criteria were not uniformly applied. The tribal participants also 

have certain additional recommendations and perspectives which are presented below. 

Air Pollution Prevention

Some of the most pristine, and yet the most threatened, ecosystems are found within the 

lands of indigenous peoples. The lack of many basic necessities, such as sustainable 

employment and adequate housing, creates the need for immediate economic 

development. Coupled with this is the lack of environmental protection infrastructure to 

manage and check efforts to develop economic opportunities which are proceeding without 

consideration for the traditional Indian commitment to resource conservation. Tribal 

communities, like others in the Transport Region, have the opportunity to take a proactive 

approach to pollution prevention and to avoid the mistakes of the past which have resulted 
 78

in environmental degradation. Future initiatives should make sure that growth planning and 

development is coupled with environmental mitigation. 

In the first subsection of Section III of this report, various pollution prevention 

recommendations are offered, including economic incentives for pollution prevention 

efforts, encouragement of zero and near-zero emitting technologies, and development of 

alternative (i.e., renewable) power sources. The importance of these recommendations is 

indicated by the prominence they receive in the Executive Summary of this report (they are 

listed as the first recommendation). Tribal participants support this recommendation 

wholeheartedly. However, the extent to which deployment of renewable energy will 

improve visibility is not, nor can it be, stated with certainty, based on the modeling outputs 

available. 

The modeling of renewable energy control scenarios is of paramount importance, 

particularly to western tribes. A significant number of tribes (33) are actively pursuing 

development of renewable energy and end-use efficiency technology applications. These 

development options involve remote electrification, bulk power generation, improving 

reservation economic conditions and reducing the emissions associated with fossil fuel 

generation. The Energy Policy Act of 1992 has intensified tribal interest in renewables by 

authorizing the Department of Energy to provide grants to tribes to evaluate the feasibility 

of renewable energy development. 

The fact that western reservations are prominent within prime solar and wind energy 

resource areas and a number are situated in major electricity transmission corridors has 

focussed Congressional and tribal attention on joint ventures and other strategies for 

securing investment capital to build and operate bulk renewable electric generation 

capacity. Clearly, apart from the income obtained through wholesale power sales, 

renewable energy development will have great added value to tribal governments in the 

form of revenues from payments for accrued "air credits," and wages from jobs in a 

vertically integrated electric power industry. 

Tribal participants support the recommendations to establish goals for bringing renewable 

power on line, but modeling efforts clearly need to be expanded to include the impacts of 

this recommendation. More specific details should underlie this recommendation, including 

goals, incentives and a timeline for adding renewables to the resource mix. 
 79

Stationary Sources

Tribal participants are concerned that PSD and the current visibility program (§ 169A) 

under the Clean Air Act insufficiently address the national goals of preventing and 

remedying visibility impairment in Class I areas caused by human-induced air pollution. 

Government Accounting Office estimates indicate that sources accounting for up to 90% of 

pollutants emitted near five Class I areas are exempt from PSD requirements, which apply 

only to new sources. Existing sources and small new sources are ignored by PSD. In 

addition, § 169A (existing sources) concentrates only on visible plumes, rather than 

regional haze, and very few existing sources have been required to implement BART 

controls. 

Tribal participants in the Commission process support the stationary source recommendations presented in Section III of this report with the following additional concerns and 

recommendations: 

1. All uncontrolled and undercontrolled stationary sources should be subject to equivalent 

emission standards as controlled sources. 

2. An emissions cap should be set for SO2. 

3. A better inventory and better modeling should be developed for PM. 

4. If a cap is established for a particular pollutants, minor sources on tribal lands should 

be inventoried since they may not currently appear in state inventories. 

5. Data from the Federal Energy Regulatory Commission should be used as a basis for 

forecasts of future electric utility emissions and for recommendations regarding 

emission reduction goals. This will also enable the Commission to identify 

opportunities for early retirement of high-emitting facilities. 

6. The effects of increased wholesale and retail competition in the utility industry must be 

taken into account in predicting future emission levels. 

Moreover, if an emission trading strategy is adopted, tribal participants recommend the 

following: 

1. Tribes must be involved in the development of the trading scenario. 

2. Credits should not be based on historical emissions, but should be based on equitable 

factors, including the need to preserve opportunities for economic development on 

tribal lands. In general, these lands are currently lacking in economic bases and have 

not contributed to the visibility problems. 

3. Whatever body administers the trading program must be representative of all of the 

groups involved. 
 80

4. The cap should be defined by region, not by state. 

Mobile Source Controls

As programs are initiated, participating governments should receive compliance assurance 

assistance and equitable funding to administer their respective programs. In addition, tribal 

communities would benefit immensely from educational programs explaining the need for 

controls and demonstrating vehicle maintenance methods for minimizing vehicle 

emissions. 

Tribal participants are concerned about mobile source emissions from federal vehicles on 

or near Indian lands, especially sites run by the Departments of Defense and Energy. 

Federal air traffic in these areas is of particular concern. 

Area Sources

There are major gaps in delineating accurately the contribution of tribal land sources to 

visibility impairment. Very few air quality monitoring programs have been placed in or near 

tribal lands. To more accurately inventory emissions sources, monitoring capability should 

be significantly improved on and near tribal lands. 

 Wood Burning 

Many rural Indian homes rely on wood-burning stoves as the sole source for cooking and 

residential heating. Programs should include a sole-source heating/cooking and 

ceremonial burning exemption from visibility and other air quality regulations on tribal 

lands. 

 Dirt Roads

There are numerous dirt roads within Indian country. If paving is required as a visibility 

protection measure, financial assistance will be needed. In addition, non-paving options 

should be considered. 

Forest Management Practices

Many tribal lands include forest lands which the tribes often manage with prescribed fire. 

Although fire can contribute significantly to visibility impairment, tribal participants 

recognize that fire is an important management tool. Tribal participants recommend 

that the various jurisdictions (federal, tribal, state, etc.) develop and implement time, 

place and manner constraints that minimize visibility impairments. 

In addition, forest land managers need to take into consideration the needs of tribal 

communities in their practice of religion and traditional cultural activities. Some of 

these activities may be protected under the provisions of the American Indian 

Religious Freedom Act. The availability of and access to areas where traditional 

medicines and spiritual foods are located should not be diminished by fire management practices. 
 81

Clean Air Corridor Controls

Tribes should not be penalized for having clean air and little economic development. 

Therefore, no inequitable restrictions should be imposed on tribal and other corridor 

residents and/or economic growth. 

Future Scientific and Technical Needs 

There is a need for the development of comprehensive emission inventories on and near 

tribal lands. These inventories may be used to provide more accurate data for future 

studies, and to prioritize regulatory development. Tribal participants recommend that the 

EPA assist tribes in this effort. In future tribal population and socio-economic studies, the 

data collection process should be designed to work more closely with tribes. 

Future modeling tools need to be able to accommodate political subdivisions smaller than 

large counties. The economic modelling system needs to be adapted to tribal situations. 

The distinctive characteristics of tribal lands deserve special attention. Given the diversity 

of tribal populations and land bases, the broad-based regional and state level impact 

analyses do not provide sufficient and accurate data. Also, the unique economic structure 

and demographics of tribal peoples may be missed in the broader regional analysis. 

Tribes need to be meaningfully involved in the development and implementation of future 

technical studies and in accommodating the special needs of tribes in various study 

methods and tools. Tribes will need the services of their own experts to help with these 

efforts, and will need financial assistance to obtain such experts. 

Future Administrative Needs

Indian tribes have rarely been asked to participate in region-wide policy development such 

as that undertaken by the Commission. Although not all tribes have been involved, the 

tribal participants agree in principle that the work of an administrative body on air quality 

issues should continue. 

 

 

 
 82

 SECTION V. FUTURE ADMINISTRATIVE NEEDS

Background

The Grand Canyon Visibility Transport Commission represents an experiment in regional 

policy development through cooperative partnership among state, tribal and federal 

governmental entities. The Commission has also engaged a broad range of interested 

parties from industry, environmental organizations, academics, technical experts, elected 

officials, and various citizens' organizations. Throughout this process, the Commission has 

provided a means for cooperative development of improved scientific information and for 

intergovernmental consideration of policy recommendations. The following recommendations regarding future administrative needs draw on this experience. 

 RECOMMENDATIONS FOR FUTURE ADMINISTRATIVE STRUCTURES

 1. Continue a regional air quality entity, similar to the Commission.

The implementation and ongoing review of regional haze management strategies will 

require the work of an entity similar to the present Commission, most likely in a 

streamlined structure, based on the evaluation performed in recommendation #4 

below. The Commission therefore recommends that the functions of the GCVTC 

should continue, in order to further develop this important partnership and perform vital 

policy and implementation functions as outlined in #3 below. 

The name GCVTC focuses disproportionately on the Grand Canyon and should be 

changed to reflect the larger geographic entity it serves. The primary role of the 

Commission, or its successor, will continue to be coordination and monitoring in order 

to recommend policies to the appropriate entities. States, tribes and federal agencies 

will undertake implementation actions. 

An equitable body of state, tribal and federal representatives should convene, as 

necessary but at least annually, for the purpose of: discussing visibility and other air 

quality issues, including public health concerns, and coordinating data collection 

efforts, and making recommendations to the EPA on reasonable progress and other 

air quality issues. 
 83

2. Integrate efforts of an administrative body with other regional air quality needs 

and planning efforts.

It is expected that the EPA will soon undertake new air quality initiatives that also require 

regional approaches. The participating entities should explore expanding the scope 

and structure of a successor body to address regional haze and other fine particulate 

impacts on visibility and health throughout the Western United States. (If the mandate 

is expanded the name of the successor body should reflect the new mission.) 

 3. Establish functions of a successor entity.

After it makes its initial recommendations to the EPA, the Commission or its successor 

should, through its subgroups, perform functions including, but not limited to, the 

following: 

a) tracking and providing feedback to the EPA on EPA's interpretation and implementation of Commission recommendations; 

b) coordinating implementation of inter-jurisdictional mechanisms for addressing regional 

haze, including monitoring activities; 

c) tracking implementation of programs for addressing regional haze to ensure equity; 

d) assessing emissions and visibility data to determine if reasonable progress is being 

made towards the national visibility goal, and recommending adjustments to regional 

haze management strategies, as necessary; 

e) promoting the development of innovative, cost-effective mechanisms for addressing 

regional haze; 

f) coordinating research and development efforts on visibility and airborne particulate 

assessment methodologies in the West to ensure that such efforts are focussed on 

concerns relevant to policy formulationi

; 

g) providing a forum for interested parties to offer input on 

the development of regional haze policies; 

h) promoting and supporting educational programs furthering 

visibility (or expanded air quality) goals, in public schools, 

in higher education and to the general public; 

i) supporting energy-conservation measures; and 

j) promoting outreach and communications programs for tribal 

communities in order to address the remoteness and educational 

needs of most Indian reservations. 
 84

 4. Evaluate and review Commission structures.

In order to create efficient, effective and sustainable longterm structures, an evaluation of the Commission's present and 

past functioning should be conducted. Such a review should 

examine the composition of the Commission, operational structures, and management arrangements, and should generate 

recommendations regarding future functional arrangements. To 

ensure neutrality in the evaluation, the review should be 

conducted by an independent outside source. Following such an 

evaluation, each participating governmental entity will be 

consulted about whether and how it will take part in future 

activities. 

During the period through its report to the EPA in the spring of 

1996, the Commission has functioned with governors or other 

high-level state, tribal and federal leaders serving as 

Commissioners. If the Commission becomes an ongoing body, 

consideration should be given to whether other federal, state 

and tribal officials may be the most appropriate appointees as 

Commissioners. Any future management or administrative 

structures should consist of an equitable body of federal, 

state and tribal representatives. Public participation in 

future efforts should be ensured through the use and creation 

of publicly accessible working groups. 

5. Develop ongoing funding mechanisms.

In order to estimate the resources, human and financial, that 

will be necessary to sustain this work (e.g., basic 

administrative functions, specific research and monitoring 

activities), a projected five-year budget should be developed 

in conjunction with development of a comprehensive plan for 

future operations. 

The EPA should provide ongoing financial support for the basic 

administrative functions of the Commission or its successor. 

Work should continue in cooperation with the EPA to support 

efforts to secure such funding. In the course of evaluating all 

current Commission functions (see #4 above), the benefits and 

feasibility of additional sources of funds for specific 

activities should be explored, including: 

a) visibility surcharges on entrance fees for Class I areas 

within the Colorado Plateau; 

b) dedicated air permit or emission fees; and 

c) redistribution of existing air pollution control funds. 

Equitable funding should be made available to tribal, state and 

federal officials to support participation in ongoing data 

collections and modeling efforts. 
 85

6. Planning process for future functions.

The Commission is convinced that its functions must continue in 

some form in order to ensure that regional haze management 

strategies which are implemented meet with regional approval. 

In order to continue the functions of the Commission without 

any hiatus, the Commission directs the Operations Committee to: 

a) Follow up on the Commission’s recommendations, monitor 

interpretation by EPA of the Commission’s recommendations, seek 

funds for future operations, and perform needed interim tasks; 

b) Prepare a comprehensive set of recommendations regarding how 

and in what form to continue the Commission by early September 

1996, building on the recommendations in this section above. 

These recommendations will include provisions regarding: 

· the structure of the Commission and any subsidiary bodies; 

· the participation of states, tribes, and federal agencies on 

the Commission; 

· involvement of stakeholder representatives in Commission processes; 

· administrative arrangements; 

· the scope of Commission activities; and 

· changes in the Commission’s by-laws needed to implement a 

reconstituted Commission. 

By mid-September 1996, the Operations Committee will distribute 

its detailed recommendations as above to the Commissioners by 

mailed ballot for action. 

Note: For tribal perspectives and commentary on these 

recommendations, see Section IV. 
 86

 SECTION VI: ANALYSIS OF THE COMMISSION'S RECOMMENDATIONS

Introduction

This section presents the Commission's analysis of the likely 

effects associated with its recommendations. The analysis attempts 

to address these key questions: 

1. How will the Commission's recommendations affect visibility at 

Class I sites in the Transport Region? 

2. What are the likely economic effects, both direct and indirect, 

of the Commission's recommendations? 

3. What are the likely environmental, social, equity, and 

administrative effects of the Commission's recommendations? 

The analysis is divided into two main parts. The first is a 

summary, using graphs, of likely visibility effects associated 

with the Commission's recommendations, where effects are known. 

Such effects are not, in all cases, known. The second part is a 

detailed discussion of the Commission's recommendations in light 

of the evaluation criteria identified in Section II of this report 

(page 20-21). 

Visibility Gains from the Commission's Recommendations

The overall goal of the Commission's recommendations is to improve 

visibility on the worst days and to preserve existing visibility 

on the best days, at Class I areas on the Colorado Plateau. The 

recommendations focus on reducing emissions from sources that 

presently contribute to visibility impairment and are likely to do 

so in the future. 

The Baseline Forecast Scenario described in Section II (page 9) 

projects the way in which current federal, state, and tribal laws 

and programs are likely to affect visibility at Class I areas on 

the Colorado Plateau through 2040. The Commission used this 

"current law" scenario to evaluate the additional improvements in 

visibility that its recommendations are likely to achieve in order 

to meet the national visibility goal. 

Figure VI-1 consists of two graphs. The first, labeled Figure VI1A: "Visibility Range Determined by the Integrated Assessment 

System", represents the range of estimated visibility conditions 

between the baseline forecast assumptions and a maximum emissions 
 87

management alternative in the Integrated Assessment System. The 

darkly shaded area on the graph represents the difference between 

the estimated visibility conditions resulting from current air 

quality programs and the maximum improvement from emissions 

control actions that were included within the Integrated 

Assessment System. 

One limitation of the Integrated Assessment System is that several 

source categories were not characterized as incorporating cleaner 

emissions technologies over time as is likely under current and 

future air quality management programs. To address this 

shortcoming, the Commission developed a "bounding" estimate of the 

upper limit visibility conditions that could result from making 

adjustments to the Integrated Assessment System baseline 

assumptions for both growth of certain sources and future 

controlled emissions from certain sources. 

The second graph labeled Figure VI-1B: "Visibility Range Expected 

from Recommendations", reflects this approach. The darkly shaded 

area of this graph represents the difference between holding 

visibility constant from the year 2000 to a maximum potential 

improvement from changes in the Integrated Assessment System 

baseline assumptions and future source control levels. To define 

the maximum source control, certain source categories were assumed 

to reduce their contribution to extinction over time in a way 

similar to Integrated Assessment System source categories that had 

technological improvements of approximately 74% reduction from 

1990 levels of impact. This probably results in an overprediction 

of the likely effect, however it is a reasonable estimate of the 

maximum effect for this bounding exercise. 

The Integrated Assessment System source categories that were 

adjusted for this estimate are: industrial/commercial fuels, 

non-road diesel, industrial processes, solvent use, a portion of 

other point sources, and other area sources. The estimate also 

reflects a change in the baseline assumptions for paved road dust 

in the Integrated Assessment System. This graph assumes small 

growth in paved road dust from increased vehicle miles traveled to 

the year 2000 and then a leveling off. This was based on 

uncertainty of the current contribution of road dust to light 

extinction. Overall, the graph demonstrates the Commission's 

belief that, under its definition of "reasonable progress," most 

source categories will improve efficiency and reduce emissions 

over time. The emissions reductions and associated visibility 

change plotted in this graph would be tracked and checked by 

monitoring long-term trends. 

The lightly shaded region on the bottom of both graphs in Figure 

VI-1 represents the "background" light extinction from natural 

causes (e.g., windblown dust). On average, this amount of 

extinction represents the best annual average extinction possible 

if all the effects of human-caused impairment are addressed. 

Currently approximately 20% of the days have this visibility 

level. This is approximately equivalent to the best visibility 
 88

conditions pictured in the Introduction and plotted in Figure 

II-7. Human activities that were not included in the Integrated 

Assessment System options for control are approximately 2 Mm-1

above this "background" level. While the improvement in 

extinction associated with the recommendations in the second graph 

in Figure VI-1 may appear small, they will correspond to much 

larger changes on some days. While these graphs show effects only 

at Hopi Point, the Commission's recommendations are likely to 

result in approximately the same range of visibility benefits at 

other Class I areas. 
 89

 Figure VI-1A
 90

 Figure VI-1B
 91

ANALYSIS OF SPECIFIC COMMISSION RECOMMENDATIONS

Introduction

This section reviews in greater detail the likely effects of the 

Commission's recommendations in light of the evaluation criteria 

described in Section II. The Commission has divided its six 

criteria into two groups: visibility benefits and economic effects 

in one group, and social, environmental, equity, and 

administrative effects in another. The first part of this section 

is an overview of the Commission's efforts to develop rough cost 

estimates for its recommendations. The second part of this section 

discusses specific Commission recommendations. Visibility and 

costs are addressed in connection with each set of 

recommendations. The remaining four criteria are discussed as a 

separate group. 

The Commission's recommendations reflect, but are substantially 

different from the scenarios developed initially by its technical 

committees. The Commission represents a range of interests, and 

its recommendations exhibit the real world of give and take among 

these interests. The Commission could not simply decide to adopt 

one of its earlier scenarios because Commission members needed to 

address a range of concerns not reflected in those scenarios. One 

such example is recommendations supporting pollution prevention 

and renewable energy. In addition, the Commission's early 

scenarios could not have anticipated all the different 

combinations of controls that would be considered. 

As a result, there is not a perfect fit among the Commission's 

recommendations, the early scenarios used in modeling, and prior 

reports to the Commission. Where some or all of a recommendation 

is not part of an earlier scenario, it is possible only to 

estimate its visibility benefits or economic costs at this time. 

An examination of the Commission's recommendations requires a 

synthesis of its earlier analytical work and new analyses that 

reflect the control choices recommended by the Commission. The 

results of the work of the Commission's technical committees are 

discussed below. 

Certain points should be kept in mind when looking at modeling 

results that show visibility effects. One is that data about 

visibility effects often are stated in terms of an annual average. 

This average includes effects for "clear" days as well as "dirty" 

days. Most emissions reductions, however, are directed at 

improving air quality on dirty days, and using an annual average 

understates their short-term effect. For example, the effects of 

emissions reductions achieved in Los Angeles will only be observed 

25% of the time on the Colorado Plateau, due to wind patterns. On 

days when those improvements are observed, they will be much 

greater than the annual average. 

Another important point is that most of the modeling to date 

addresses visibility effects at only one receptor: Hopi Point in 
 92

Grand Canyon National Park. This receptor is not necessarily 

representative of all Class I sites, but it offered a substantial 

amount of high-quality data. Hopi Point may have unique localized 

influences, and it is also influenced by emissions from a 

combination of directions that may not occur at other Class I 

areas. To address these potential limitations, the Commission has 

analyzed three other Class I areas. This broader approach makes 

more emission source regions relevant to the analysis, but is not 

a complete substitute for modeling all Class I areas. 

Preliminary Cost Scenario

It is not possible to estimate reliably the economic costs and 

benefits of the Commission's recommendations at this time. The 

recommendations are largely conceptual in nature, and the direct 

and indirect costs and benefits will vary depending on when and 

how specific strategies are implemented.

The Commission has developed preliminary rough projections of the 

direct and indirect costs of achieving visibility improvements at 

Class I areas on the Colorado Plateau. Direct costs are the costs 

of imposing emission controls to improve visibility. Indirect 

costs are the additional effects on the region's economy from 

imposing those controls, including wages, employment, and 

"feedback" of expenditures into the regional economy. 

Sources of emissions in the West previously have incurred costs in 

order to comply with requirements of the federal Clean Air Act, 

and state and tribal programs covering all aspects of air quality. 

These costs will continue. The Commission's focus is on any 

additional costs, beyond those resulting from compliance with 

current law, that may be associated with improving visibility at 

Class I areas on the Colorado Plateau. 

As a first step, the Commission has developed rough estimates of 

some of the potential costs and benefits associated with emission 

management options that bear some similarity to its 

recommendations. These emission management options were designed 

early in the Commission's process, and do not match the 

Commission's recommendations. The Commission's rough estimates 

using these early options show the following: 

1. There will be no significant incremental cost associated with 

the Commission's recommendations in the short term because they 

reflect diligent implementation of existing programs and new 

programs likely to be implemented for other reasons. 

2. If the full set of recommendations is implemented, including a 

market-based emissions cap and trading program, the potential 

range of costs after 2010 under the Commission's preliminary 

rough estimate is from $500 million to $1.8 billion per year. 

(These cost estimates were generated by the IAS based on 

optimization runs for 25% and 80% of the Maximum Management 

Alternative.) This translates roughly into a 0.1% decrease in 
 93

gross regional product in peak years, or approximately $10 per 

person, and an overall increase of jobs in the region of 

approximately 0.5% through 2040. 

These rough estimates are only the first step in developing an 

estimate of costs associated with the Commission's 

recommendations. They do not reflect any cost savings or economic 

benefits that may be associated with these emission reductions, 

such as health care savings and enhanced property values. 

Analysis of Air Pollution Prevention Recommendations

Visibility and Cost Effects

There currently is no quantitative assessment of the visibility 

improvements that might result from the Commission's 

recommendations in this area, or of their likely economic effects. 

Intuitively, substituting non-emitting or lower emitting 

technologies likely will result in improved visibility. This 

includes encouraging "clean" sources of energy in new industries. 

Several recommendations will probably have direct economic 

effects. One example is recommendation #3, which supports economic 

incentives to promote industrial retooling that reduces emissions. 

Another example is recommendation #6, which suggests the 

possibility of charging emission fees for air pollution. 

Analysis of Stationary Source Recommendations

Visibility and Cost Effects

The recommendations regarding stationary sources involves 

establishing emission reduction targets for sulfur dioxide 

consistent with those anticipated under the Baseline Forecast 

Scenario, which was designed to reflect requirements under current 

regulations. It is anticipated that the emission reduction 

targets will be achieved through compliance with current 

regulations and voluntary and economically driven decision making 

of sources. Therefore, no additional costs would be incurred to 

impose controls if the targets are met. The only cost of the 

program would be the administrative aspects of collecting and 

analyzing information on emission trends in the Transport Region. 

If emission reductions are not achieved through compliance with 

current regulations and voluntary and economically driven decision 

making, then a program would be established to enforce more rigid 

reductions. Earlier studies showed that a regional emissions cap 

and market trading program is the most cost-effective approach to 

deal with regional haze. However, equity and administrative 

issues associated with this type of program are complex and need 

to be dealt with thoroughly in developing a detailed implementation plan. Under this "back stop" program, some costs of controls 

may be expected, but cannot be quantified at this time. 

The incorporation of other pollutant species into the stationary 

source program will have similar emission reduction effects. To 

the extent that long range targets are established on the basis of 
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expectations under current regulatory requirements, then no 

additional costs associated with the visibility program would be 

incurred, other than monitoring and assessment. It is anticipated 

that annual average light extinction from 1990 through 2040 at 

Hopi Point would be improved between 0.8 and 1.0 Mm-1, depending on 

the actual control levels achieved for those stationary sources 

sectors which have not been analyzed in detail. 

Analysis of Mobile Source Recommendations

Visibility and Cost Effects

The Commission's recommendations incorporate national, regional, 

and local strategies for addressing mobile source emissions. In 

reviewing these recommendations and their projected effects, it is 

important to bear in mind that the Commission's model appears to 

understate urban effects and that mobile sources are a significant 

part of urban emissions. As a result, it is likely that the model 

underpredicts mobile source impacts on visibility, primarily from 

tailpipe emissions. 

Current modeling shows that approximately 30% (3.5 Mm-1) of the 

annual human-caused light extinction at Hopi Point in the year 

2000 is caused by mobile sources (roads, on-road vehicles, offroad vehicles, aviation, marine, and locomotives). Most of this 

impact (2.5 Mm-1) is attributed to road dust under current 

modeling; the balance (1 Mm-1) comes from tailpipe emissions. 

As part of a national strategy, the Commission recommends 

supporting the 49-state LEV. A recent study by the AAMA shows that 

the 49-state LEV is likely to reduce emissions of NOx and VOC from 

on-road vehicles below the BFS by at least 35% by 2020. According 

to the Commission's model, this would translate into only a small 

annual visibility improvement at Hopi Point. However, more work is 

required to determine whether the model underestimates this 

impact. 

Potential visibility benefits from all other mobile source 

categories (off-road vehicles, boats, airplanes, locomotives) are 

approximately 11% of the total mobile source contribution based on 

current modeling. 

The Commission has not modeled the visibility effects of its 

proposed regional and local mobile source initiatives. The same 

limitation applies to estimates of the costs associated with 

imposing mobile source controls. Depending on the costs associated 

with different categories, it may be cost-effective to achieve the 

relatively small visibility benefits associated with different 

national strategies noted above. Additional work is required to 

develop this information. 

Analysis of Area Sources/Fire Recommendations

Visibility and Cost Effects

Millions of wildland acres in the Transport Region are at risk 
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from catastrophic wildfire. These areas will burn eventually, and 

the fires will impair visibility at Class I areas on the Colorado 

Plateau. The Commission's models indicate that emissions from 

fire, both wildfire and prescribed fire, is likely to have the 

single greatest impact on visibility at Class I areas through 

2040. Current modeling indicates that, at certain times, increased 

visibility impairment from fire is likely to exceed the potential 

visibility improvements associated with other Commission 

recommendations. 

The Fire Emissions Project of the Commission found that, 

historically, fire occurred on approximately 35 million acres 

annually. This corresponds to an annual visibility impact of 8-13 

Mm-1. Current prescribed fire programs across the Transport Region 

cover approximately 1.2 million acres annually. In 1995, PM2.5

emissions from prescribed fire were estimated to be approximately 

75,000 tons per year, less than 1% of total PM2.5 emissions from 

all sources in the Transport Region. The proposed future 

prescribed fire programs of land managers would treat 

approximately 6 million acres annually by the year 2040, 

increasing the relative contribution to 3% of total PM2.5 emissions 

in the Transport Region. This projected target is consistent with 

current land management agency fire policies, but is dependent on 

available resources and funding. Significant increases in fire on 

all wildlands will occur, whether by managed prescribed fire or by 

uncontrolled wildfire, if proposed prescribed fire programs are 

not implemented. 

Fire has seasonal impacts on visibility; it is not a constant 

influence. During certain periods (days or weeks) of intense fire 

activity, the visibility impacts of prescribed fire may be much 

greater than the average annual impacts. Most wildfires occur in 

the summer and fall; prescribed fires are used in the spring, 

summer, and fall. The clearest days on the Colorado Plateau occur 

during the winter. As a result, increased fire emissions are 

likely to make the worst 20% of days even worse, rather than 

impair visibility on clear days. Both prescribed fire and wildfire 

activity are dependent on weather conditions, resulting in 

visibility effects that can fluctuate widely from year to year. 

Table VI-1 shows the range of visibility impacts that are 

projected to occur from the use of prescribed fire and wildfire. 
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 TABLE VI-1 

Annual Average1 Prescribed Fire/Wildfire Visibility Impacts in Mm-1

 Year Prescribed 

Fire Baseline2

Prescribed 

Fire 

with Maximum 

Controls3

 Wildfire4

 1990-2000 0.3 - 0.5 NA 0.1 - 1.0 

 2010 1.5 - 2.0 1.4 - 1.7 0.1 - 1.0 

 2040 1.6 - 2.2 1.4 - 1.9 0.1 - 1.0 

1

 Seasonal impacts may be 2-3 times higher than the annual average.

2

 Baseline projections in 2010 and 2040 reflect projected prescribed fire programs under current land 

management policies. Emissions may be overestimated due to fiscal and personnel constraints and National 

Ambient Air Quality Standards requirements.

3

 Prescribed fire emissions can be reduced through smoke reduction measures (mechanical treatment, etc.). 

These impacts may be further mitigated by managing the timing of burning based on meteorology.

4

 Although the Commission believes that increased use of prescribed fire activity will result in long-term 

reductions of wildfire emissions, the Commission has been unable to quantify this benefit.

The Commission's recommendations focused on ways to limit the increased visibility 

impairment from fire that could occur through 2040. Since land managers will be increasing 

their use of prescribed fire techniques to reduce wildfires, there is an opportunity to reduce 

the growth in visibility impairment projected to occur. 

It is important to bear in mind that fire has highly variable effects on visibility, even on a 

daily basis. The Commission's model cannot reflect this variability. 

Even using "optimal" smoke management measures, prescribed fire's contribution to 

annual visibility impairment at Hopi Point could increase by 400% between 1995 and 2040. 

The Commission's fire modeling projects that use of optimal smoke management 

measures could decrease fine particle (PM2.5) emissions from prescribed fires by 

approximately 15-20%. This would limit the increased visibility impairment at Class I areas 

that likely will be caused by prescribed fires through 2040. In practice, land managers 

consider daily weather conditions to minimize effects from prescribed burning. The 

Commission's model does not permit an analysis of how these decisions, based on 

weather conditions, influence smoke impacts. 
 97

Using "optimal" smoke management and emission reduction measures is projected to cost 

approximately $500-$2,000 per ton of PM2.5 reduction. Reducing PM2.5 emissions by 15-

20% over projected increases is estimated to cost approximately $65-$75 million annually. 

Analysis of Clean Air Corridors Recommendations

The Commission is not recommending any special programs or regulations for clean air 

corridors beyond existing law. The basis for this approach is model results showing that 

projected emissions growth in the studied clean air corridor is not expected to have a 

perceptible impact on visibility at Class I sites. 

Analysis of Recommendations Regarding Emissions Within and Near Class I Areas 

Visibility and Cost Impacts 

The Commission's recommendations address a range of transportation and energy-related 

emissions, as well as emissions from prescribed fire, that occur both within and near Class 

I areas. 

Particle emissions in and near Class I areas deserve particular attention because they 

have potential immediate consequences for visibility. Approximately two-thirds of particles 

measured at Hopi Point consist of fine soil and coarse material (PM2.5 and PM10). Fine soil 

from sources near and distant from Class I areas accounts for about one-third of the 

visibility impairment caused by particles. Sources of coarse material have relatively small 

spheres of influence, i.e., coarse material generally doesn't travel far. As a result, the data 

from Hopi Point indicate that sources of coarse material located close to Class I areas, 

such as unpaved roads, are likely to be more important to visual air quality than regional 

sources. Forest fires burning close to or within Class I areas can also be expected to have 

significant impacts on visibility, since they emit coarse and fine dust as well as elemental 

and organic carbon. 

The Commission recommends improved planning to reduce visibility effects from sources 

of coarse material and fine dust both within and near Class I areas. The Commission's 

model does not allow modeling of the potential visibility impacts of this recommendation. 

The same modeling limitation applies to the recommendation that strategies be developed 

to limit emissions from local sources. 

The Commission has not quantified the visibility benefits associated with its recommendations concerning other transportation and energy-related emissions. The Commission 

has not developed any cost analysis for these recommendations. 
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Analysis of Transboundary Emissions Recommendations

Visibility and Cost Effects

The Commission's model presently shows that emissions from Mexico result in annual 

average visibility impacts at Hopi Point of approximately 1.68 Mm-1. Of this amount, 

approximately 1 Mm-1 is attributed to industrial and residential sources near the U.S.-

Mexico border. Of the remainder, approximately half is attributed to specific stationary 

sources; the remainder to off-shore shipping emissions that travel across Mexico to the 

United States. This is approximately 17% of manageable visibility impairment at Hopi Point 

on an annual average basis. Using an annual average likely understates the impact of 

these emissions on a given day, because meteorological conditions limit their influence to 

approximately 25% of the year. It is likely that on certain days the light extinction is much 

greater. The Commission has not modeled visibility impacts at other Class I areas. 

Most of the transboundary emissions (about 60%) are SOx, and most come from area 

sources within Mexico. At least one smelter located within Mexico is projected to be 

responsible for approximately 14% (0.24 Mm-1) of the annual total transboundary light 

extinction at Hopi Point. The Commission is aware of reports that this source is scheduled 

to be shut down within the next few years. 

A comprehensive emissions inventory will give a clearer picture of the different sources of 

transboundary emissions. Programs to finance air pollution control projects, to provide 

incentives for transboundary investment in pollution control, and to retire major emitting 

sources are likely to have visibility benefits at Hopi Point. However, more work is required 

on the emissions inventory before these benefits can be quantified. 

One important issue associated with these emissions is whether they are "manageable" in 

the same way that emissions from sources located within the United States are 

manageable. 

The Commission is unable at this time to estimate the potential costs associated with its 

recommendations. 

Analysis of Scientific and Technical Needs Recommendations

The Commission has made a number of recommendations that include additional 

monitoring, data collection and reporting. These activities are the key to implementing 

many of its other recommendations. It is not practical at this time to estimate the costs 

associated with these activities. 
 99

Discussion of Environmental, Social, Equity, and Administrative Effects

The Commission's recommendations are a mix of the specific and the general. While 

analysis of the economic, social, environmental, equity, and administrative impacts of 

specific recommendations can yield robust conclusions, predicting the effects of general

recommendations is at best an uncertain process. This is particularly true for the 211 

Indian tribes located on the Colorado Plateau, whose peoples have unique economies and 

lifestyles. These issues are addressed more fully in Section IV on "Tribal Perspectives" in 

this report. The Commission's economic model also has certain limitations. The process for 

evaluating criteria other than costs relies primarily on data from the economic model, which 

present impacts at the level of a large county. The economic model is not designed to 

address rural areas with small populations, or Indian tribes, and its output has limited utility 

at best in assessing impacts for these groups. 

The Commission's equity concerns include addressing the following questions: Are the 

sources causing the problem paying for/contributing fairly to the solution? Are sources 

causing the problem paying for the solution in proportion to their current contribution and 

current control levels? The Commission's formal assessments have not analyzed whether 

some income groups will be affected more than others or whether there are ethnic patterns 

to the outcomes of the recommendations. These issues are of particular concern to areas 

which are relatively underdeveloped within the Transport Region. 

With respect to equity for rural and underdeveloped areas, including most tribal lands, it is 

important to note that such areas have not contributed significantly to the regional haze 

problem. One method for measuring equity is to ensure that all groups contribute fairly to 

solutions, relative to their role as an emissions source and their economic position (that is, 

in proportion to the ability to pay). 

While the Commission has sought to distribute the burden of its recommendation equitably, 

inadequacies in the primary and secondary assessment process (e.g., lack of emissions 

data for tribal lands, inability of the economic model to analyze areas smaller than a county, 

and lack of tribal data inputs to economic modeling) require continued vigilance to 

guarantee strong application of the equity criterion in all implementation plans and in 

monitoring the impacts of the Commission's recommendations. 

With these limitations in mind, the Commission offers its perspective on the so-called 

"secondary" impacts associated with its recommendations. 

Tourism. One issue relevant to all the Commission's recommendations is tourism in the 

region. Research conducted for the Commission shows that national parks in the West are 

important contributors to the economy as well as the quality of life. National parks in the 

study generated over 100,000 jobs and almost $5 billion in gross regional product in 1994. 

Most park visitors come to enjoy the scenery. Any noticeable impairment of visibility could 

significantly affect park visits and, as a result, the regional economy. However, there 

currently are no studies that assess the link between air quality and park visits, so stronger 

conclusions cannot be drawn. 
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Air Pollution Prevention. The Commission's recommendations concerning air pollution 

prevention illustrate the limitations of projecting effects at this time. The recommendations 

themselves are general in nature. Because they were not modeled, there presently is no 

information about the costs and benefits. Nevertheless, there is reason to believe that 

promoting alternative energy sources would have some economic benefits, in the form of 

increased investment in alternative technologies and increased employment in the 

alternative technology sector. Some Indian tribes have invested significant resources in this 

area, and could benefit economically from expansion of alternative energy technologies 

and creation of incentives for their use. To the extent there are economic benefits to Indian 

tribes investing in these technologies, it is reasonable to expect some social benefits. 

"Clean" technologies would likely have an overall positive impact on the environment of the 

region. However, a more specific conclusion would require knowledge of the specific 

technologies under consideration. 

Stationary Sources. Turning to the recommendations about stationary sources, there are 

some important concerns. Under a regional cap/trading program, there are fundamental 

questions about how initial credits will be allocated and how reductions would be timed. If 

credits are allocated simply on the basis of historical emissions, there are potential equity 

issues for new emissions sources. This concern has been raised specifically by Indian 

tribes. There also are significant equity and other issues about how such a program affects 

sub-regions where companies may sell their credits and move away, or conversely how it 

would affect areas where industries that acquire pollution credits are located. 

Mobile Sources. To the extent that national strategies, such as the 49-state LEV or low 

sulfur fuels, are adopted, the average costs of implementation will decrease because they 

are spread over a large area and population. 

The Commission is aware of the potential equity impacts associated with some of its 

mobile source recommendations. One example is retiring high-emitting vehicles. These 

vehicles tend to be owned by persons without the economic means to acquire newer, lowemitting vehicles. This recommendation also poses potential equity issues for Indian tribes. 

Another example is enhanced inspection and maintenance programs. These can have 

differential impacts on lower income groups, and raise equity concerns. 

Area Sources/Fire. The use of prescribed fire has clear significance for the health of 

ecosystems throughout the West. A better understanding of fire's role in ecosystem health 

underlies the recommendation supporting the increased use of prescribed fire, along with 

smoke management techniques. In the long run, this recommendation will result in 

environmental benefits in the Transport Region. 

Mechanical treatment will be labor-intensive and may provide significant employment 

opportunities. Substantial subsidies may be required for some use of the biomass resulting 

from mechanical treatment programs. Biomass utilization may be possible in some energy 

markets, and the development of other woody material markets is also possible. 
 101

There are social and equity issues associated with fire policy. One of these involves Indian 

tribes that conduct their own timber, agriculture, and habitat management operations. Any 

policy that restricts the ability of these tribes to develop these operations could have an 

impact disproportionate to that felt by other groups, such as federal land managers. This 

issue is discussed further in the section on "Tribal Perspectives." 

Emissions Within and Near Class I Areas. The Commission's recommendations are likely 

to affect communities located "within and near" Class I areas. These could be major urban 

centers, smaller rural communities, or Indian tribes. One potential emissions source in 

these communities is unpaved roads. Measures to reduce dust could have 

disproportionate impacts on these communities, and on groups within each community. 

Paving roads can increase use, thereby causing a range of economic and social impacts. 

Depending on who paid to pave roads, there could be significant equity impacts as well. 

Pollutant "plumes" from urban areas also raise equity issues involving who should bear the 

cost of addressing mobile and area source emissions that are part of these plumes. 

Transboundary Emissions. Communities located close to the border may be bearing a 

disproportionate share of the impact from transborder emissions. These same communities 

probably would reap the greatest benefit from emissions reductions, but may be unable to 

contribute financially to emission reduction strategies. This issue is also addressed in the 

section on "Tribal Perspectives." 

 i. See Section III, Future Scientific and Technical Needs.