ESSENTIAL WRAP AND STATE ACTIVITIES

FOR 308 REGIONAL HAZE PLANNING

Bob Saunders, Washington

Who Are Western 308 States

Not a Grand Canyon transport state:

§  Washington
§  Montana
§  North Dakota / §  South Dakota
§  Alaska
§  Hawaii

Grand Canyon transport states choosing to use 308

§  Nevada

§  California

§  ?? for Colorado, Wyoming, Idaho

What Is In a 308 SIP – Summary

  1. Determination of how much improvement is needed at each class I area affected.
  2. Determination of what states/areas are responsible to what extent for those impacts.
  3. Development and implementation of a long-term strategy to achieve the emission reductions needed to meet the first period improvement goal.
  4. Documentation that states considered 7 factors and taken them into account:
  5. Effect of current control strategies
  6. Construction activity impacts
  7. Additional control strategies above and beyond a., if needed
  8. Source retirement and replacement schedules
  9. Smoke management programs
  10. Enforceability of the measures relied upon
  11. Documentation of the technical analysis:
  12. Rationale for determining what “natural” is.
  13. Monitoring data to calculate the impairment and uniform rate of reasonable progress.
  14. Emission inventory info for control strategy assessment and modeling.
  15. Model runs to assess effects of existing controls and possible new strategies.
  16. Speciation analysis if used to support the strategy.

Critical WRAP efforts for 308 are:

1.  Preparing the inventory information for use in the WRAP models.

2.  Making sure problematic inventories are improved and available on time, e.g. dust emissions, ammonia.

3.  Making sure the model is operating the best that it can.

4.  Making every effort to meet state/tribal modeling needs or substantially assist states if they can’t. Especially providing for:

  smaller grids or nested grids

  capacity to do sensitivity and “what if” strategy runs.

  handling difficult modeling problems like dust emissions, chemistry, ammonia , etc.

5.  Major assistance to states in calculating pollutant mass and the degree of impairment (deciview level) at each class I area.

6.  Major assistance to states on the analysis and interpretation of speciated data -- through the “Causes of Haze” report.

7.  Making sure the resources are substantially shifted to 308 over the next few years.

8.  Providing documentation of the technical work they have done.

Critical state efforts for 308 are:

1.  Making sure state needs are identified and communicated to WRAP participants. WRAP can’t meet needs that are not identified early enough.

2.  Ongoing input and participation into the WRAP to help with the work and ensure it gets completed on time. Especially providing the inventories in a timely fashion and in the format needed to facilitate WRAP work.

3.  Designing any needed what if runs or sensitivity model runs.

4.  Reviewing, evaluating and drawing conclusions, especially with respect to control strategy implications, from WRAP inventories, modeling results and the Causes of Haze reports.

5.  Working with local stakeholders

6.  Determining any needed control strategies and implementing them

7.  Preparing the actual SIP documents.

A possible schedule (illustrative, WRAP should finalize):

Emission inventory year / 2002
Model Evaluation / Jan 2003 to Mar 2005
Emission inventories turned into EPA / Jun 2004
EPA releases NEI (with one state review incorporated), WRAP uses Oct NEI / Oct 2004
WRAP does Q/A, formatting for modeling, and updated projections (18 mo) / Feb 2006
2002 and 2018 base modeling done (4 mo) / Jun 2006
Deadline for states to request other modeling, e.g. sensitivity runs and “what if” runs (3mo) / Sep 2006
Iterative analysis between initial modeling and inventory occurs (6 mo) / Jun to Dec 2006
WRAP modeling completed / Jun 2007
308 SIPs completed—rules, etc. as needed (18 mo) / Dec 2008

Issues:

§  This schedule, while technically desirable, essentially ignores the risk of imposition of an early deadline. Just in case, WRAP should consider options for faster completion.

§  Currently no one knows when EPA will designate PM 2.5 Nonattainment areas. They have a statutory deadline of 12/31/05, but are under pressure to act earlier, maybe 2004.

§  The court has questioned the validity of the haze rule that gives attainment states that are part of a planning organization three years instead of one.

§  EPA has indicated they will try to get Congress to establish a uniform due date of 2008 (in TEA21 reauthorization), but the success of that won’t be known until fall 2003 at the earliest.