REGIONAL HAZE STATE IMPLEMENTATION PLAN FOR THE STATE OF ARIZONA Air Quality Division Arizona Department of Environmental Quality December 23, 2003 Acknowledgement Greg Witherspoon (July 4, 1948 – December 24, 2001) Greg Witherspoon committed his professional career to the advancement of balanced environmental policies and programs in Arizona. He worked at the Salt River Project for over 20 years as a Principal Environmental Scientist. In this capacity, he was engaged in numerous environmental matters affecting power utilities and Arizona’s natural resources. Among his many duties at SRP, Greg was actively involved in advancing air quality policies that would protect the public’s enjoyment of the spectacular scenery in Arizona’s national parks and wilderness areas. Greg participated in several technical committees to support the work of the Grand Canyon Visibility Commission in addressing regional haze visibility impairment in the Grand Canyon National Park and other Class I areas on the Colorado Plateau. He worked with other stakeholders throughout the west to advance technical and regulatory policies necessary to achieve long-term reductions of visibility impairing emissions. Greg was a champion of market based emission reductions as the vehicle for achieving air quality goals in the most cost effective manner. Greg was the consummate professional throughout the stakeholder process. He came to meetings thoroughly prepared. He readily shared his expertise and valued the input of others. He sought to build consensus among all the stakeholders throughout the process. Greg was instrumental in helping Arizona decide to base its Regional Haze State Implementation Plan on the program conceived by the Grand Canyon Visibility Commission and developed by its successor organization, the Western Regional Air Partnership. TABLE OF CONTENTS TABLE OF CONTENTS ............................................................................................................................ i LIST OF FIGURES .................................................................................................................................... v LIST OF TABLES ..................................................................................................................................... vi LIST OF APPENDICES .......................................................................................................................... vii EXECUTIVE SUMMARY .................................................................................................................. ES-1 1.1. 1.2. 1.3. 1.4. 1.5. 1.6. 1.7. 1.8. 1.9. 1.10. BACKGROUND ............................................................................................................................ 1 Introduction ................................................................................................................................. 1 Definitions ................................................................................................................................... 1 1977 Clean Air Act...................................................................................................................... 1 Reasonably Attributable Visibility Impairment........................................................................... 2 1990 Clean Air Act...................................................................................................................... 2 Grand Canyon Visibility Transport Commission ........................................................................ 2 Western Regional Air Partnership ............................................................................................... 3 1999 Regional Haze Rule ............................................................................................................ 3 2002 Annex Rule for Stationary Sources of Sulfur Dioxide ....................................................... 3 2003 Rule Change to Mobile Source Requirements for National Strategies .............................. 6 2.1. 2.2. 2.3. PHYSICAL, DEMOGRAPHIC, AND ECONOMIC DESCRIPTIONS OF ARIZONA ........ 7 Climate and Physiography........................................................................................................... 7 Population.................................................................................................................................... 8 Economy.................................................................................................................................... 11 1. 2. 3. 4. MANDATORY CLASS I FEDERAL AREAS ON THE COLORADO PLATEAU............. 15 3.1. Arizona Class I Areas ................................................................................................................ 15 3.1.1. Grand Canyon National Park .................................................................................................. 16 3.1.2. Sycamore Canyon Wilderness................................................................................................. 18 3.1.3. Petrified Forest National Park ................................................................................................. 19 3.1.4. Mt. Baldy Wilderness.............................................................................................................. 20 3.2. Class I Areas Outside Arizona................................................................................................... 21 TECHNICAL BASIS FOR REGULATION OF REGIONAL HAZE.................................... 23 How Do We See? ...................................................................................................................... 23 How Particulates and Gases Impair Visibility........................................................................... 24 Types of Particles and Gases Contributing to Visibility Impairment........................................ 25 Sources of Particulates and Gases Contributing to Visibility Impairment on the Colorado Plateau ................................................................................................................................... 26 4.5. Visibility Conditions on the Colorado Plateau .......................................................................... 26 4.6. State of Arizona Visibility Monitoring Plan and Network ........................................................ 26 4.1. 4.2. 4.3. 4.4. 5. STRATEGY TO ADDRESS REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT (RAVI)............................................................................................................... 29 5.1. Implementation of Control Strategies........................................................................................ 30 Table of Contents i Arizona Regional Haze SIP 5.2. 5.3. 5.4. 5.5. 5.6. Exemptions from Controls......................................................................................................... 30 Identification of Integral Vistas................................................................................................. 30 Monitoring................................................................................................................................. 30 Long-term Strategy Requirements............................................................................................. 31 New Source Review for Visibility Protection ........................................................................... 31 6.1. 6.2. 6.3. LONG-TERM STRATEGY FOR THE CLEAN AIR CORRIDOR ...................................... 33 Regulatory History and Requirements ...................................................................................... 33 Identification of Clean Air Corridor; Other Clean Air Corridors.............................................. 34 Strategy for Clean Air Corridors ............................................................................................... 35 7.1. 7.2. 7.3. LONG-TERM STRATEGY FOR STATIONARY SOURCES.............................................. 37 Regulatory History and Requirements ...................................................................................... 37 Monitoring and Reporting of Stationary Source Sulfur Dioxide Emissions. ............................ 38 Report on Assessment of NOx/PM Strategies........................................................................... 39 6. 7. 8. SO2 MILESTONES AND BACKSTOP TRADING PROGRAM ........................................... 41 8.1. Milestones and Determination of Program Trigger................................................................... 41 8.1.1. Regional SO2 Milestones......................................................................................................... 41 8.1.2. Regional Program Administration........................................................................................... 44 8.1.3. Determination of Program Trigger.......................................................................................... 44 8.1.4. Year 2013 Assessment ............................................................................................................ 49 8.1.5. Special Penalty Provisions for the 2018 Milestone ................................................................. 50 8.2. Pre-Trigger Emissions Tracking Requirements......................................................................... 51 8.2.1. SO2 Emission Inventory .......................................................................................................... 51 8.2.2. Development of Emission Tracking System ........................................................................... 52 8.2.3. Periodic Audit of Pre-Trigger Emission Tracking Database................................................... 52 8.3. WEB Trading Program Requirements....................................................................................... 52 8.3.1. Initial Allocation of SO2 Allowances ...................................................................................... 52 8.3.2. Distribution of Allowances for Future Control Periods. ......................................................... 59 8.3.3. Distribution of the New Source Allocation ............................................................................. 60 8.3.4. Regional Tribal Set-aside ........................................................................................................ 61 8.3.5. Opt-in Sources......................................................................................................................... 61 8.3.6. WEB Allowance Tracking System (WEB ATS)..................................................................... 61 8.3.7. Allowance Transfers................................................................................................................ 63 8.3.8. Use of Allowances from a Previous Year ............................................................................... 63 8.3.9. Monitoring/Recordkeeping ..................................................................................................... 65 8.3.10. Compliance and Penalties ..................................................................................................... 66 8.3.11. Periodic Evaluation of the Trading Program......................................................................... 66 8.3.12. Retired Source Exemption .................................................................................................... 68 8.3.13. Integration into Permits......................................................................................................... 68 8.4. 2013 SIP Revision; Backstop for Beginning of Second Planning Period ................................. 69 8.5 Geographic Enhancement Program ........................................................................................... 69 9. 9.1. 9.2. 9.3. LONG-TERM STRATEGY FOR MOBILE SOURCES......................................................... 71 Regulatory History and Requirements ...................................................................................... 71 Inventory of Current and Projected Emissions from Mobile Sources ....................................... 72 Other GCVTC Strategies for Mobile Sources ........................................................................... 73 LONG-TERM STRATEGY FOR FIRE PROGRAMS ........................................................... 75 10. 10.1. Regulatory History and Requirements ...................................................................................... 75 Table of Contents ii Arizona Regional Haze SIP 10.2. 10.3. 10.4. 10.5. 10.6. Prescribed Fire Program Evaluation.......................................................................................... 75 Emission Inventory and Tracking System................................................................................. 75 Strategy for Use of Non-burning Alternatives........................................................................... 76 Enhanced Smoke Management Program................................................................................... 76 Annual Emission Goal............................................................................................................... 77 11. AREA SOURCES OF DUST EMISSIONS FROM PAVED AND UNPAVED ROADS ...... 79 11.1. Regulatory History and Requirements ...................................................................................... 79 11.2. Strategy for Road Dust Sources................................................................................................. 79 12. POLLUTION PREVENTION AND RENEWABLE ENERGY PROGRAMS ..................... 81 12.1. Regulatory History and Requirements ...................................................................................... 81 12.2. Approach to Addressing Requirements Under 40 CFR 51.309(d)(8) ....................................... 81 12.3. Description of Existing Pollution Prevention Programs in Arizona.......................................... 82 12.4. Inventory of All Renewable Energy Generation Capacity and Production in Arizona............. 98 12.5. Summary of Anticipated Renewable Energy Contribution ....................................................... 99 12.6. Incentive Programs .................................................................................................................. 100 12.7. Programs to Preserve and Expand Energy Conservation Efforts ............................................ 100 12.8. Potential for Renewable Energy .............................................................................................. 106 12.9. Projections of Renewable Energy Goals, Energy Efficiency, and Pollution Prevention Activities ............................................................................................................................. 113 12.10. Programs to Achieve GCVTC Renewable Energy Goal ......................................................... 113 12.11. Future Progress Reports........................................................................................................... 113 13. OTHER GCVTC RECOMMENDATIONS............................................................................ 115 13.1. Regulatory History and Requirements .................................................................................... 115 13.2. Other Long-term Strategy Components .................................................................................. 115 13.3. Sources In and Near GCVTC Class I Areas............................................................................ 115 13.3.1. Grand Canyon National Park .............................................................................................. 116 13.3.2. Mt. Baldy Wilderness Area................................................................................................. 116 13.3.3. Petrified Forest National Park ............................................................................................. 116 13.3.4. Sycamore Canyon Wilderness ............................................................................................ 117 PROJECTION OF VISIBILITY IMPROVEMENT ............................................................. 119 14. 14.1. Effect on Emissions of Long-term Strategy Components ....................................................... 119 14.1.1. Inventory Methodology and Scope ..................................................................................... 119 14.1.2. Projected Changes in Emissions for Arizona ...................................................................... 120 14.2. Projected Changes in Visual Air Quality................................................................................. 121 14.2.1. Applicable Class I Areas ..................................................................................................... 121 14.2.2. Projected visibility improvement ........................................................................................ 121 15. STATE PLANNING/INTERSTATE COORDINATION AND TRIBAL IMPLEMENTATION ............................................................................................................... 125 15.1. Participation in Regional Planning and Coordination ............................................................. 125 15.2. Applicability to Tribal Lands .................................................................................................. 125 16. PERIODIC IMPLEMENTATION PLAN REVISION.......................................................... 127 17. DECLARATION OF TREATMENT FOR ADDITIONAL CLASS I AREAS UNDER 40 CFR 51.309(g)........................................................................................................................ 129 Table of Contents iii Arizona Regional Haze SIP 18. PUBLIC PARTICIPATION AND REVIEW PROCESS ...................................................... 131 18.1. Public Hearing Notice ............................................................................................................. 131 18.2. Hearing Transcripts ................................................................................................................. 131 18.3. Written Comments Received................................................................................................... 131 18.4. Responsiveness Summary ....................................................................................................... 131 Table of Contents iv Arizona Regional Haze SIP LIST OF FIGURES Figure 1-1. Figure 2-1. Figure 2-2. Figure 2-3. Figure 3-1. Figure 3-2. Figure 3-3. Figure 3-4. Figure 3-5. Figure 3-6. Figure 3-7. Figure 3-8. Figure 4-1. Figure 6-1. Figure 7-1. Figure 12-1. Figure 12-2. Figure 12-3. Figure 12-4. Figure 12-5. Figure 12-6. Figure 17-1. Western Regional Air Partnership Region ............................................................................. 5 Class I Areas and Physiography Regions in Arizona............................................................. 7 Counties and Class I Areas in Arizona................................................................................... 9 Non-Farm Employment in Arizona: 1990-2001 .................................................................. 12 Colorado Plateau Class I areas ............................................................................................. 15 Arizona Class I Areas........................................................................................................... 16 View From South Rim of The Grand Canyon National Park .............................................. 17 Map of Grand Canyon National Park Area .......................................................................... 17 Map of Sycamore Canyon Wilderness Area ........................................................................ 18 Petrified Forest National Park .............................................................................................. 19 Map of Petrified Forest National Park Area................................................................... …. 19 Map of Mount Baldy Wilderness Area ................................................................................ 20 Interaction of Particles and Gases with Light ...................................................................... 24 Map of the Clean Air Corridor in the Transport Region ...................................................... 34 Regional Sulfur Dioxide Emission Milestones .................................................................... 37 Map of Arizona Solar Photovoltaic Resources .................................................................. 107 Map of Arizona Concentrating Solar Power Resources..................................................... 108 Map of Arizona Biomass Energy Resources...................................................................... 109 Map of Arizona Collocated Gerthermal Energy Resources ............................................... 110 Projected Cost of Solar Energy Technologies.................................................................... 111 Projected Cost of Energy from Renewable Energy Technologies - 2000.......................... 112 Arizona Additional non-GCVTC Class I Areas................................................................ 129 Table of Contents v Arizona Regional Haze SIP LIST OF TABLES Table ES-1. Requirements for Reasonably Attributable Visibility Impairment Under 40 CFR 51.302 through 307 ................................................................................... ES-1 Table ES-2. Summary of Requirements for Regional Haze Visibility Impairment Under 40 CFR 51.309........................................................................................................ ES-2 Table 2-1. Arizona’s Urbanized Areas: Census 2000............................................................................... 9 Table 2-2. Growth of Arizona’s Counties: 2000-2002 ........................................................................... 10 Table 2-3. Population Projections for Selected Arizona MSAs and Counties: 2000-2020 .................... 11 Table 2-4. Average Number of Non-Farm Employees in Arizona 1990-2001 (10,000s)....................... 12 Table 2-5. Projected Economic Indicators for Arizona: 2001-2005 ....................................................... 13 Table 4-1. Light Extinction Efficiencies of Particles.............................................................................. 25 Table 7-1. State-by-State Comparison of 1990 and 2000 Stationary Sources Sulfur Dioxide Emissions in the 9 GCVTC Transport Region States (tons per year)...................... 38 Table 8-1. Base Sulfur Dioxide Emissions Milestones (excludes Smelter Set-aside) ............................ 41 Table 8-2a. (Years 2003-2010) Amounts of SO2 Tons To Be Subtracted from the Base Milestones for States and Tribes That Do Not Have an Approved Implementation Plan under 40 CFR 51.309* .................................................................. …. 42 Table 8-2b. (Years 2011-2018) Amounts of SO2 To Be Subtracted from the Base Milestones for States and Tribes that do not have an Approved Implementation Plan under 40 CFR 51.309*........................................................................................................... 42 Table 8-3. Preliminary Smelter-Specific Set Aside ................................................................................ 43 Table 8-4. Utility/Non utility Split.......................................................................................................... 56 Table 8-5. New Source Set-Aside Adjustment ....................................................................................... 56 Table 9-1. Statewide Mobile Source Emissions for Arizona (Tons per Day)......................................... 72 Table 10-1. Inclusion of ESMP Elements Into Arizona Regulations ....................................................... 77 Table 12-1. Arizona’s Approach to Address 40 CFR 51.309(d) Requirements ....................................... 82 Table 12-2. Summary of Renewable Energy Programs Currently in Place in Arizona............................ 82 Table 12-3. Summary of Energy Efficiency Programs in Place in Arizona ............................................. 86 Table 12-4. Planned Renewable Energy Capacity at of 2002................................................................... 97 Table 12-5. Summary of Renewable Energy Generation Capacity and Production ................................. 99 Table 12-6. Summary of Arizona’s Total Encergy Generation Capacity and Production........................ 99 Table 12-7. Summary of Arizona’s Incentive Programs ........................................................................ 100 Table 12-8. Programs that Preserve and Expand Energy Conservation in Arizona ............................... 100 Table 12-9. Cost Estimates of Solar Options.......................................................................................... 112 Table 14-1. Changes in Emissions from 1996 to 2018 for Arizona Sources (Tons per Year)................ 121 Table 14-2. Changes iin Emissions from 1996 to 2018 for 9 GCVTC States (Tons per Year).............. 121 Table 14-3. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018 on the Average 20% Worst Days, resulting from implementation of “All 309 Control Strategies”................................................................................................ 122 Table 14-4. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018, on the Average 20% Best Visibility Days, resulting from implementation of “All 309 Control Strategies”................................................................................................ 123 Table of Contents vi Arizona Regional Haze SIP LIST OF APPENDICES APPENDIX VOLUME I APPENDIX A-1. BACKGROUND Appendix A-1a. Definitions Appendix A-1b. Arizona Department of Environmental Quality – Air Quality Division Organization Charts APPENDIX A-2. DESCRIPTIONS OF ARIZONA Appendix A-2a. Bibliography for Chapter 2 APPENDIX A-5. ATTRIBUTABLE IMPAIRMENT Appendix A-5a. Arizona’s RAVI rule Appendix A-5b. Notification letters to FLMS on contact person, and Public Comment Period Appendix A-5c. Supporting Documents Related To The Promulgation Of Arizona’s RAVI Rule Appendix A-5d. New source review rule-R18-2-410 APPENDIX A-6. CLEAN AIR CORRIDOR Appendix A-6a. WRAP Policy on Clean Air Corridors Appendix A-6b. WRAP Emission Tracking System and Assessment Process for the Clean Air Corridor APPENDIX A-7. STATIONARY SOURCES Appendix A-7a. Arizona Draft Western Backstop SO2 Trading Program Rule Appendix A-7b. Proposed WRAP 309 Coordinating Committee Charter Appendix A-7c. WRAP Report on Assessment of NOx/PM Strategies APPENDIX A-8. SO2 MILESTONES/BACKSTOP Appendix A-8a. WRAP Market Trading Forum Non-Utility Sector Allocation Final Report from the Allocations Working Group (November 2002) Appendix A-8b. Western Emissions Backstop (WEB) Emissions & Allowance Tracking Systerm (EATS) Analysis Appendix A-8c. Recommendations for Making Additional Determinations in the Context of Reasonably Attributable BART APPENDIX A-9. MOBILE SOURCES Appendix A-9a. Arizona Mobile Source Work Group Findings and Recommendations Related to Mobile Source Emissions APPENDIX VOLUME II APPENDIX A-10. FIRE PROGRAMS Appendix A-10a. WRAP report “Assessing Status of Incorporating Smoke Effects into Fire Planning and Operation” Appendix A-10b. EPA’s “Interim Air Quality Policy on Wildland and Prescribed Fires” Table of Contents vii Arizona Regional Haze SIP Appendix A-10c. Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10d. Supporting Documents Related to the Promulgation of Revised Arizona R18-2602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10e. WRAP “Policy on Fire Tracking Systems” Appendix A-10f. WRAP report “Nonburning Alternatives for Vegetation and Fuel Management” Appendix A-10g. WRAP report “Burning Management Alternatives on Agricultural Lands in the Western United States” Appendix A-10h. WRAP report “Enhanced Smoke Management Programs for Visibility” Appendix A-10i. Arizona Revised Statute 49-501 Appendix A-10j. WRAP report “Annual Emission Goals for Fire” APPENDIX VOLUME III APPENDIX A-12. POLLUTION PREVENTION Appendix A-12a. Arizona Pollution Prevention Work Group Review of WRAP Policy on Renewable Energy and Energy Conservation Appendix A-12b. Details of Renewable Energy Generation and Capacity Appendix A-12c. ICF Assessment of Renewable Energy and Energy Conservation Programs APPENDIX A-13. OTHER GCVTC OPTIONS Appendix A-13a. Arizona’s Assessment of Other Recommendations Of The Grand Canyon Visibility Transport Commission Appendix A-13b. Summary of Discussions with Federal Land Managers on Emissions In-andNear the Four Arizona GCVTC Class I Areas APPENDIX A-14. PROJECTION OF VISIBILITY Appendix A-14a. Arizona Technical Review Memoranda of WRAP Emission Inventories and Technical Support Document Appendix A-14b. Summary of Emission Inventories used in WRAP Modeling APPENDIX A-18. PUBLIC PARTICIPATION Appendix A-18a. Notices of Public Hearings Appendix A-18b. Hearing Agendas, Sign-in Sheets, Transcripts, and Certifications Appendix A-18c. Written Comments Received During Comment Period Appendix A-18d. Responsiveness Summary Table of Contents viii Arizona Regional Haze SIP EXECUTIVE SUMMARY This Arizona State Implementation Plan (SIP) addresses the requirements of Title 40 of the Code of Federal Regulations, Part 51, Subpart P – Protection of Visibility (40 CFR 51.300-307, and 309). The SIP describes the programs that the State will rely upon to make reasonable progress toward “preventing any future and … remedying any existing impairment of visibility” in the large parks and wilderness areas in Arizona and those in other states that may be affected by pollution generated in Arizona (Class I areas). The federal regional haze rules require states to develop and submit SIPs for improving visibility through the year 2018 that make reasonable progress toward achieving “natural visibility conditions” by the year 2064. This SIP is designed to adopt the basic visibility program that addresses impairment of visibility that can be traced to older major industrial sources and implements recommendations adopted by the Grand Canyon Visibility Transport Commission (GCVTC) in its 1996 report to EPA. The Western Regional Air Partnership (WRAP) is the successor organization to GCVTC, and, in addition to being chartered to implement the GCVTC's recommendations, provides the mechanism for states and tribes to coordinate efforts and pool resources to conduct the complex technical analyses necessary to develop the science that is part of the foundation of regional haze SIPs. Arizona State government officials and employees and a variety of Arizona stakeholders actively participate in WRAP committees and workgroups to direct the policy and technical products of the WRAP. As such, this SIP revision relies on much of the work conducted by WRAP staff and contractors. Chapters 1 through 4 of this SIP include introductory and background information about visibility protection and regional haze. Chapter 5 is the plan for implementation of the rules and regulations addressing reasonably attributable visibility impairment, in addition to monitoring, planning, and new source review requirements under 40 CFR 51.300-307. Chapters 6 through 17 include Arizona’s approach to meeting the requirements for developing long-term visibility improvement strategies for regional haze under 40 CFR 51.309. Chapter 18 summarizes the public participation process in developing this SIP as required under 40 CFR 51.102. Table ES-1 summarizes the requirements in 40 CFR 51.302-307 for reasonably attributable visibility impairment, the approach taken by the State of Arizona to address the requirements, and the chapter in this SIP addressing the requirements. Table ES-1. Requirements for Reasonably Attributable Visibility Impairment Under 40 CFR 51.302 through 307 Requirements of 40 CFR 51.302 Implementation control strategies for reasonably attributable visibility impairment. 40 CFR 51.303 Exemptions from control. 40 CFR 51.304 Identification of integral vistas. Executive Summary Summary of Approach, Content, or Findings Arizona has promulgated regulations in 2003 to address the implementation of controls, as needed, for sources subject to the best available retrofit technology requirements of the 1977 Clean Air Act for reasonably attributable visibility impairment (RAVI). Arizona has incorporated into the Arizona RAVI rule the necessary provisions to address the petition of BART emissions limits to the EPA Administrator. No integral vistas were identified for the Class I areas on the Colorado Plateau addressed by this SIP or the other Additional Class I areas in Arizona. ES - 1 Chapter in SIP 5.1 5.2 5.3 Arizona Regional Haze SIP Requirements of 40 CFR 51.305 Monitoring for reasonably attributable visibility impairment. 40 CFR 51.306 Long-term strategy requirements for reasonably attributable visibility impairment. 40 CFR 51.307 New source review. Summary of Approach, Content, or Findings Arizona established a comprehensive visibility monitoring program for the Class I areas and other transport sites in 1996. Arizona is an associate member of the IMPROVE Steering Committee and ensures information from the Arizona network is submitted as required, and participates in the technical leadership of the overall IMPROVE program. Arizona has included in the SIP comprehensive long-term strategy components to address regional haze visibility impairment and RAVI from BART eligible sources. Arizona’s R18-2-410 (Article 4, New Source Review, Arizona Administrative Code) address requirements of new sources to meet performance standards to assure emissions will not have an impact on visibility. Chapter in SIP 5.4 5.5 5.6 Table ES-2 summarizes the requirements in 40 CFR 51.309 for regional haze, the approach taken by the State of Arizona to address the requirements, and the chapter in this SIP addressing the requirements. Table ES-2. Summary of Requirements for Regional Haze Visibility Impairment Under 40 CFR 51.309 Requirement of 40 CFR 51.309 (d)(1) Time Period Covered (d)(2) Projection of Visibility Improvement (d)(3) Treatment of Clean Air Corridors (d)(4), (f), and (h) Implementation of Stationary Source Reductions (d)(5) Mobile Sources Executive Summary Summary of Approach, Content, or Findings This SIP addresses reasonable progress at the Class I areas on the Colorado Plateau from December 31, 2003 through December 31, 2018. Projected emissions and estimated visibility changes for each of the Class I areas on the Colorado Plateau were performed by the Western Regional Air Partnership (WRAP). The only Clean Air Corridor for the Class I areas on the Colorado Plateau does not include any area within Arizona. Arizona will include the results of future analyses in its periodic plan revisions. General stationary source requirements are contained in Chapter 7. Chapter 8 contains a description of the SO2 Milestone and Backstop Trading Program. Federal programs (such as low sulfur diesel, engine standards, etc.) are identified and describe mobile source emissions throughout the planning period. ES - 2 Chapter in SIP 1.1 Ch. 14 Ch. 6 Ch. 7 (general) Ch. 8 (SO2) Ch. 9 Arizona Regional Haze SIP Requirement of 40 CFR 51.309 (d)(6) Programs Related to Fire (d)(7) Area Sources of Dust Emissions From Paved and Unpaved Roads (d)(8) Pollution Prevention (d)(9) Additional Recommendations (d)(10) Periodic Revisions (d)(11) State Planning and Interstate Coordination (f)(4) Geographic Enhancement (g) Reasonable Progress for Additional Class I Areas Summary of Approach, Content, or Findings Arizona revised its open burning and smoke management regulations (A.A.C. R18-2-602 and A.A.C R18-2-1501 1515) to address the federal requirements. WRAP’s analysis concluded dust emissions from paved and unpaged roads are currently not a significant regional contributor to visibility impairment within the Colorado Plateau 16 Class I areas. Arizona will continue to support further research on this issue, as it develops its periodic plan revisions under 40 CFR 51.309(d)(10). Programs and policies within Arizona related to renewable energy and energy efficiency are described. The status of implementation of other strategies and options in the Grand Canyon Visibility Transport Commission Report are summarized. In addition, an overview of sources in and near each Arizona GCVTC Class I area is included. Arizona will submit periodic plan revisions to this SIP in 2008, 2013 and 2018. Arizona has and will continue to participate in the WRAP. As periodic plan revisions are done, consultation will also be made with states and tribes not implementing 40 CFR 51.309. WRAP has developed a model MOA to be executed by Arizona and Federal Land managers to address geographic enhancement of the regional haze SO2 Milestone and Backstop Trading Program (Ch. 8) for reasonably attributable visibility impairment. A supplement to this plan revision to address regional haze at the Additional 8 Class I areas in Arizona will be developed in accordance with 40 CFR 51.309(g)(2-3) and submitted by December 31, 2008. Chapter in SIP Ch. 10 Ch. 11 Ch. 12 Ch. 13 Ch. 16 Ch. 15 Ch. 8 in 8.5 Ch. 17 While the above tables are organized in the order of the provisions of the regional haze rule, the SIP itself is organized according to the logic of pollution control plans. Consequently, the chapters of the SIP do not correspond precisely to the order of the requirements in the regional haze rule. Finally, the Technical Support Document (TSD) developed by the Western Regional Air Partnership (WRAP) is a reference for this SIP (herein referred to as the “WRAP TSD”). Executive Summary ES - 3 Arizona Regional Haze SIP 1. BACKGROUND 1.1. Introduction Good visibility is important to fully enjoy the experience of visiting the State’s and Country’s national parks and wilderness areas. Visibility is how far and how well a person can see, and can be reduced or impaired by light scattering and absorption caused by particulate matter and gases in the atmosphere that occur from both natural and human-caused activities. Visibility impairing natural sources may include rain, wildland fires, volcanic activity, and wind blown dust. Visibility also can be impaired by human-caused sources of air pollution such as industrial processes, (utilities, smelters, refineries, etc.), mobile sources (cars, trucks, trains, etc.) and area sources (residential wood burning, prescribed burning, agricultural activities, wind blown dust from disturbed soils, etc.) Congress established a program to protect visibility in the larger national parks and wilderness areas which referred to as the mandatory Class I Federal areas (herein referred to as “Class I areas”). The State of Arizona is submitting this SIP to address the requirements (40 CFR 51.300-307) for visibility protection in the Class I areas and remove the existing Federal Implementation Plan (FIP) (52 FR 45132, November 24, 1987). This SIP also fulfills the requirements under 40 CFR 51.309 for Arizona’s 4 Colorado Plateau Class I areas in addition to the other 12 Class I areas studied by the Grand Canyon Visibility Transport Commission (GCVTC). It contains all necessary measures to address reasonably attributable visibility impairment and regional haze visibility impairment necessary to ensure the State of Arizona makes reasonable progress toward the national goal for visibility contained in 42 U.S.C. 7491 (Clean Air Act), specifically “...the prevention of any future, and remedying of any existing impairment of visibility in mandatory Class I Federal areas, which impairment results from man-made air pollution.” The Regional Haze Rule (RHR) defines this goal as achieving natural visibility conditions by 2064. This SIP addresses reasonable progress toward the national goal for the planning period from December 31, 2003 thorough December 31, 2018. 1.2. Definitions This SIP duplicates terms and phrases defined in 40 CFR 51.301, 40 CFR 51.309(b), and other terms specific to the programs set forth in this Plan. These definitions are contained in Appendix A-1a of this SIP. 1.3. 1977 Clean Air Act In the 1977 Clean Air Act (CAA), Congress established requirements for the prevention of significant deterioration of air quality in areas within the United States and for the review of pollution controls on new sources.1 Coupled with this, Congress established a visibility protection program and the national goal (Section 169A) for larger national parks and wilderness areas.2 The visibility protection program also requires states to address any visibility impairment caused by emissions of air pollutants from certain large industrial sources if the source was less than 15 years old as of August 1977, through the establishment of emission limits based on best available retrofit technology (BART). Congress also 1 Clean Air Act Amendments of 1977, United States Congress. 42 U.S.C. 7470-7479. Government Printing Office: Washington, D.C. August 7, 1977. 2 Clean Air Act Amendments of 1977, Section 169A, United States Congress. 42 U.S.C. 7491. Government Printing Office: Washington, D.C. August 7, 1977. Chapter 1 – Background -1- Arizona Regional Haze SIP established mandatory criteria for states to use when establishing BART emission limits and developing long-term strategies for reasonable progress toward the national goal. 1.4. Reasonably Attributable Visibility Impairment In 1980, the United States Environmental Protection Agency (EPA) issued final regulations to address the requirements of the 1977 Clean Air Act, requiring states with Class I areas to submit State Implementation Plan (SIP) revisions with new source review plans, monitoring plans, BART implementation plans, and long-term strategies to address reasonable progress toward the national visibility goal.3 Arizona did not submit a SIP to address visibility, and in 1987 (52 FR 45132) EPA issued a Federal Implementation Plan. 1.5. 1990 Clean Air Act Although the 1980 regulations addressed reasonably attributable visibility impairment from specific sources, also know as plume blight, it did not adequately address visibility impairment from large collections of sources whose emissions are mixed and transported over long distances, creating a uniform haze (regional haze). In the 1990 amendments to the Clean Air Act (CAA), Congress established the requirements to address regional haze visibility impairment, giving the EPA authority to establish visibility transport commissions and promulgate regulations to address regional haze, and requiring the establishment of a visibility transport commission to investigate and report on regional haze visibility impairment in the Grand Canyon National Park located in northern Arizona.4 The Regional Haze SIP meets the requirements of Section 110, Implementation Plans, of the CAA. Demonstration of the public review process can be found in Chapter 18 and its related Appendix. Information to satisfy Section 110(a)(2)(E), adequate personnel to carry out such an implementation plan, can be found in Appendix A-1b). 1.6. Grand Canyon Visibility Transport Commission In response to the 1990 CAA, the Grand Canyon Visibility Transport Commission (GCVTC) was established in November 1991. Membership evolved over the approximately four and one-half years of its activities. When the GCVTC issued recommendations to EPA in June 1996, membership consisted of eight western governors (or their designees), four western tribal leaders, five ex-officio members representing federal land management agencies, an ex-officio tribal representative, and EPA. The transport region studied by the GCVTC consisted of nine western states: Arizona, California, Colorado, Idaho, New Mexico, Nevada, Oregon, Utah, and Wyoming. Arizona’s Governor Symington chaired the GCVTC. The GCVTC members agreed to expand the scope of technical and policy studies to include all 16 of the Class I areas on the Colorado Plateau. The GCVTC elected to use a stakeholder-driven process to accomplish its objectives to review current science and policy information and determine what actions, if any, were needed to address regional haze visibility impairment at the Class I areas on the Colorado Plateau. Ultimately, the organization included over 200 political, policy and technical stakeholders, who staffed a variety of committees and subcommittees. The GCVTC was funded by EPA grants and contributions from stakeholders, including substantial in-kind labor. The GCVTC submitted its recommendations to EPA in June 1996.5 The major recommendations of the GCVTC included: 3 40 CFR Part 51 - Protection of Visibility, United States Environmental Protection Agency, 45 FR 80089. Government Printing Office: Washington, D.C. December 2, 1980. 4 Clean Air Act Amendments of 1990, Section 169B, United States Congress. 42 U.S.C. 7492. Government Printing Office: Washington, D.C. November 15, 1990. 5 Recommendations for Improving Western Vistas, Grand Canyon Visibility Transport Commission; Western Governors' Association: Denver, CO, June 10, 1996. Chapter 1 – Background -2- Arizona Regional Haze SIP • • • • • • • • • • 1.7. The need to promote energy conservation, energy efficiency and renewable energy production; The need to track emissions growth that may affect air quality in clean air corridors; The need to manage emissions of stationary sources of sulfur dioxide with a voluntary program using emission reduction milestones coupled with a backstop cap-and-trade program that would be implemented if emissions reductions milestones were exceeded. The need to cooperate and work with federal land managers to do further studies of sources in and adjacent to Class I areas; The need to manage emissions of mobile sources through the implementation of more stringent national engine and fuel standards; The need to manage emissions of mobile sources from large urban areas that contribute significantly to visibility impairment in any of the 16 GCVTC Class I areas; The need to analyze the contribution of road dust emissions on visibility in the Class I areas; The need to promote programs to encourage emissions reductions in Mexico; The need to manage the visibility impacts resulting from the growth of emissions from prescribed fires needed to restore the ecosystem; and, The need to establish a successor organization to the GCVTC to oversee, promote, and support the GCVTC’s recommendations. Western Regional Air Partnership The GCVTC’s successor, the Western Regional Air Partnership (WRAP) was formed in September 1997. Though the WRAP's charter allows it to address any air quality issue of interest to WRAP members, its current work is focused on developing the policy and technical work products needed by states and tribes for regional haze SIPs or Tribal Implementation Plans (TIPs). Figure 1-1 shows the WRAP region. The WRAP Board is composed of representatives from 13 states, 13 tribes, the US Department of Agriculture, the US Department of the Interior, and EPA. The WRAP operates on a consensus basis and conducts business through stakeholder-based technical and policy groups charged with assisting the development of regional haze work products. Additional information about the WRAP can be found at http://www.wrapair.org. 1.8. 1999 Regional Haze Rule EPA proposed regional haze regulations in 1997.6 The proposed regulations described a national program but did not include provisions to address the recommendations of the GCVTC. The Western Governors' Association (WGA) subsequently developed a recommendation related to the Colorado Plateau area and submitted it to EPA in June 1998.7 Based on this and other comments, EPA issued the final regional haze rule in July 1999. In addition to the national program that could apply to any state or tribe and the final rule contained requirements for an optional program relying on the work of the GCVTC.8 1.9. 2002 Annex Rule for Stationary Sources of Sulfur Dioxide One of the requirements of the RHR was the development and submission to EPA of a 6 40 CFR Part 51 - Regional Haze Regulations; Proposed Rule - 62 FR 41138. United States Environmental Protection Agency, Government Printing Office: Washington, D.C. July 31, 1997. 7 Leavitt, M. O, Governor of Utah, Letter to EPA Administrator Browner on behalf of the Western Governors' Association, June 29, 1998. 8 40 CFR Part 51 - Regional Haze Rule; Final Rule, 64 FR 35714. United States Environmental Protection Agency, Government Printing Office: Washington, D.C. July 1, 1999. Chapter 1 – Background -3- Arizona Regional Haze SIP supplement or Annex to the GCVTC recommendations to define the program for stationary sources of sulfur dioxide by October 1, 2000. The WRAP established the Market Trading Forum (MTF) consisting of key stakeholders in the region to develop the Annex. The MTF analyzed the technical and policy issues surrounding the establishment of the voluntary emission reduction milestones with a backstop program to assure emission reductions were achieved and deliberated the content of the Annex. Chapter 1 – Background -4- Arizona Regional Haze SIP Figure 1-1. Western Regional Air Partnership Region Chapter 1 – Background -5- Arizona Regional Haze SIP The WRAP approved and submitted the Annex to the GCVTC recommendations to define a voluntary program of sulfur dioxide emission reduction milestones coupled with a backstop markettrading program to assure emission reductions on September 30, 2000. EPA proposed changes to the regional haze rule to incorporate the GCVTC Annex,9 and the final rule was published in the Federal Register on June 5, 2003 (68 FR 33764). 1.10. 2003 Rule Change to Mobile Source Requirements for National Strategies The GCVTC developed long-term projections of emissions in the GCVTC transport region based on information available in the early 1990’s. Those emission projections showed that emissions from mobile sources were expected to decline through approximately 2005 and then begin to increase through 2040. As a result, the GCVTC recommendations included recommended actions for national strategies, that were out of the control of the GCVTC, and local strategies. The local strategies included the concept of capping emissions from mobile sources in large urban areas that contribute significantly to visibility impairment in any of the 16 GCVTC Class I areas in the year 2005, or some other year that emissions reached its minimum levels. This strategy was adopted in the RHR in 40 CFR 51.309(d)(5)(ii) and (iii). After the RHR was adopted, EPA promulgated several new emission and fuel standards for mobile sources. Emission projections developed by the WRAP demonstrated emissions from mobile sources would decline significantly through the entire planning period from 2003 through 2018, and possibly beyond. Each pollutant was expected to decline except for sulfur dioxide from off-road mobile sources unless pending rule making for fuel standards were promulgated by EPA. Given the significant reduction in emissions, the WRAP determined that the current requirement under 40 CFR 51.309(d)(5)(ii) and (iii) were no longer an effective management tool for mobile sources, and developed proposed changes to the RHR to address emissions from mobile sources. In 2003, the WRAP formally requested that EPA make revisions to the mobile sources section of the Regional Haze Rule (40 CFR 51.309(d)(5)) to reflect changes in emissions due to federal programs developed since the rule was promulgated in 1999. The basis for the WRAP request was EPA’s adoption of more stringent national vehicle emission and fuel standard that result in mobile source emissions declining throughout the region during the 2003-2018 planning period covered by plans being submitted in December 2003. EPA proposed changes to 40 CFR 51.309(d)(5) on July 3, 2003 (68 FR 39842 and 68 FR 39888). EPA held a hearing on October 7, 2003, on the proposed change and promulgated the final rule on December 22, 2003 (68 FR 71009). 9 40 CFR Part 51 - Regional Haze Regulations; Proposed Rule, 67 FR 30418, United States Environmental Protection Agency. Government Printing Office: Washington, D.C. May 6, 2002. Chapter 1 – Background -6- Arizona Regional Haze SIP 2. PHYSICAL, DEMOGRAPHIC, AND ECONOMIC DESCRIPTIONS OF ARIZONA This section of the SIP provides an overview of the physical, demographic and economic characteristics, along with some history of the formation of the state. Appendix A-2a contains a bibliography of sources for the information presented in this chapter. 2.1. Climate and Physiography Arizona encompasses nearly 114,000 square miles, ranging in elevation from 70 feet above sea level on the Colorado River at the Arizona-Mexico border, to 12,643 feet in the north at Humphreys Peak just north of Flagstaff. It contains four desert regions and hundreds of mountains, remnants of state’s past volcanic activity. Arizona borders states of California and Nevada on the West, Utah on the North, Colorado to the Northeast, New Mexico on the East, and the country of Mexico to the South. Figure 2-1. Class I Areas and Physiography Regions in Arizona Chapter 2 – Descriptions of Arizona -7- Arizona Regional Haze SIP Arizona has three main topographical areas: 1) a high plateau in the northeast; 2) a mountainous region oriented southeast to northwest; and 3) low mountain ranges and desert valleys in the southwestern portion of the state. These regions bring a wide range of climate to the state with lows well below zero in the high plateau and mountainous regions of central and northern Arizona, while temperatures can exceed 125°F within the desert areas. Precipitation throughout Arizona is governed by elevation and time of year, with the highest elevations averaging between 25 to 30 inches of precipitation annually. The desert southwest averages as low as three to four inches per year. The average number of days per year with measurable precipitation varies from near 70 days in the north (Flagstaff area) to 15 in the southwest (Yuma area). From November through March, storm systems from the Pacific Ocean cross the state, some bringing blizzard conditions to the high elevations. Summer rainfall begins early in July and usually lasts until midSeptember. The moisture-bearing winds come from either the southwest (Gulf of California) or southeast (Gulf of Mexico), and during a wind shift called, “the North American Monsoon,” large thunderstorms can occur in the mountainous regions on down through the central and southeastern portion of the state. Blowing dust prior to onset of rain can occur during these storms. Flash floods can also occur. Approximately 70% of Arizona’s land is owned and managed by the federal government and the 21 federally recognized Indian tribes. The state owns nearly 13%, leaving about 18% of the state land is under private ownership. Arizona is host to some of the country’s most spectacular and beloved national parks and wilderness areas. Of the 158 national parks and wilderness areas classified as mandatory Class I Federal areas, 12 are located in Arizona (40 CFR 81.403). Four of the 12 Arizona Class I areas are on the Colorado Plateau, the area of study by the GCVTC. A list of all 16 Class I areas that were part of the GCVTC study of Colorado Plateau Class I areas can be found in Chapter 3 of this SIP. Detailed information on Arizona’s four Colorado Plateau Class I areas also can also be found in Chapter 3. Figure 2-2 shows Arizona Class I areas. 2.2. Population The Arizona Territory was formed in 1863 from the western part of the New Mexico Territory.10 As part of the New Mexico Territory in 1860, “Arizona County” had an 1860 population of 6,482. By 1870, Arizona Territory’s population grew to 9,658 with most of the inhabitants living in Pima County. Arizona’s population during the 2000 Census had grown to 5,130,632. Arizona has six urbanized areas (i.e., 50,000 people or more), two of which are major urban areas (i.e., 250,000 people or more), and three represent newly qualified areas based on the results of the 2000 Census (see Table 2-1). Two of these urbanized areas, Flagstaff and Prescott, are located in northern Arizona. Flagstaff is in Coconino County near two of the four Class I areas: Grand Canyon National Park and Sycamore Canyon Wilderness. 10 Arizona was the name given to the territory. The town of Arizona actually was located south of the new border in Sonora, Mexico. The old name of the region was ‘Pimería Alta.’ The Treaty of Guadalupe Hidalgo in 1848 ended the war between the U.S. and Mexico. The treaty required Mexico to cede hundreds of thousands of square miles of land to the U.S. The geographical areas included western New Mexico, Arizona north of the Gila River, California, Nevada, Utah, as well as parts of Colorado, Wyoming, Kansas, and Oklahoma. Then, in 1853 with the Gadsden Purchase, which added the land south of the Gila River, Arizona formed its present borders. Chapter 2 – Descriptions of Arizona -8- Arizona Regional Haze SIP Figure 2-2. Counties and Class I Areas in Arizona Table 2-1 Arizona’s Urbanized Areas: Census 2000 Urbanized Areas Arizona County Population Avondale Maricopa 67,875 Flagstaff Coconino 57,050 Phoenix-Mesa Maricopa 2,907,049 Prescott Yavapai Tucson Pima 61,909 720,425 Yuma (AZ-CA) Yuma Source: U.S. Bureau of the Census 94,950 Table 2-2 shows Census 2000 county populations as well as 2002 mid-year county population estimates for Arizona. According to these data, the state grew 6.7 percent between 2000 and 2002. The two largest Metropolitan Statistical Areas (MSAs), Phoenix-Mesa and Tucson, grew at 7.3 percent and 5.5 percent, respectively, during these two years. The Phoenix-Mesa MSA includes Maricopa and Pinal Counties. Pinal County was added to the Phoenix-Mesa MSA in 1993. Chapter 2 – Descriptions of Arizona -9- Arizona Regional Haze SIP Table 2-2 Growth of Arizona’s Counties: 2000-2002 County Census 2000 (April) 2002 Estimate (July) Apache 69,423 70,105 Cochise 117,755 124,040 Coconino 116,320 125,420 Gila 51,335 53,015 Graham 33,489 34,070 Greenlee 8,547 8,605 19,715 20,365 3,072,149 3,296,250 Mohave 155,032 166,465 Navajo 97,470 101615 Pima (Tucson MSA) 843,746 890,545 Pinal* 179,727 192,395 38,381 39,840 Yavapai 167,517 180,260 Yuma 160,026 169,760 La Paz Maricopa* Santa Cruz State Total 5,130,632 5,472,750 * Part of Phoenix-Mesa Metropolitan Statistical Area Source: U.S. Bureau of the Census; Population Statistics Unit, Research Administration, Department of Economic Security, December 6, 2002. The Phoenix-Mesa MSA ranks 14th among all metropolitan areas by total population for 2000. However, the Phoenix-Mesa MSA is one of the fastest-growing metropolitan areas in the nation. As a county, however, Maricopa County gained the most number of people numerically, ranking it as the fourth largest county in the nation. Table 2-3 portrays population projections for selected areas in Arizona including the PhoenixMesa MSA and Tucson MSA in five-year increments from 2000 to 2020. The county population projections for the four counties where the Arizona Colorado Plateau Class I areas are located and the projected state totals also are included for reference. Chapter 2 – Descriptions of Arizona - 10 - Arizona Regional Haze SIP Table 2-3 Population Projections for Selected Arizona MSAs and Counties: 2000-2020 Area 2000 2005 2010 2015 2020 Phoenix-MesaScottsdale MSA 3,115,787 3,511,048 3,909,281 4,317,999 4,747,319 854,329 943,795 1,031,623 1,119,342 1,206,244 67,925 72,236 76,645 81,173 85,766 Coconino County 123,329 135,595 147,352 158,753 169,343 Mohave County 147,529 171,504 194,403 215,988 236,396 88,898 94,395 99,979 105,843 111,946 152,966 175,693 198,052 219,614 240,849 Tucson MSA Apache County Navajo County Yavapai County State Total 4,961,953 5,553,849 6,145,108 6,744,754 7,363,604 Source: Population Statistics Unit, Research Administration, Department of Economic Security (DES), Approved by Director August 1, 1997. According to these projections, the state’s population is projected to grow by 48 percent in 20 years. While these are the official population projections for the State, they are under estimates. The 2000 projection is 4.2% below the 2000 official U.S. Census count and the decennial growth rates for 2000 through 2010 and 2010 through 2020 are 20% and 10%, respectively. If the average decennial growth rate of 40 percent from 1960 through 2000 is maintained, Arizona’s population in 2010 would almost be equivalent to the 2020 DES population projection. Carrying the 40 percent decennial growth rate forward to 2020 would mean a state population of about 10 million compared to the 7.3 million projected in 2020 by DES. 2.3. Economy Arizona’s growth in gross state product ranked first in the nation during 1992 through 1999, increasing from $85 billion in 1992 to $140 billion in 1999. Contributing to this growth were high-tech manufacturing industries, wholesale and retail trade, services, and construction industries.11 Manufacturing output averaged 13.2 percent annually during this eight-year time period. The other sectors grew predominantly as the population of the state grew. Table 2-4 shows a time series of civilian non-farm labor force data. The last column shows the annual average growth rate in employment between 1990 and 2001. Total non-farm and private employment grew at rates over 50%. By contrast the minimum decennial growth rate for 1960 through 2000 was 35%. Figure 2-3 shows the change in employment from 1990 through 2001. It should be noted that reliable data for agricultural employment are not available due to large seasonal fluctuations in employment. 11 Based on construction data through the 1990s, it is evident that the single family housing sector was a major force, coupled with the commercial sector, behind the state’s construction and real estate industries. Chapter 2 – Descriptions of Arizona - 11 - Arizona Regional Haze SIP Table 2-4 Average Number of Non-Farm Employees in Arizona 1990-2001 (10,000s) Year 1990 Goods 1992 1994 1996 1998 2000 2001 Annual Avg. Growth 27.33 26.22 30.35 34.69 37.30 38.78 38.48 4.1% Services 120.98 125.49 138.86 154.54 170.18 185.49 188.01 4.0% Total Non-Farm 148.31 151.71 169.20 189.23 207.47 224.27 226.50 3.9% Private 122.41 124.03 139.77 157.44 173.32 187.61 188.72 3.2% Source: Arizona Department of Economic Security in cooperation with U.S. Department of Labor, Bureau of Labor Statistics. * Percent change between 1990 and 2001. Figure 2-3. Non-Farm Employment in Arizona: 1990-2001 Non-Farm Employment In Arizona 1990 - 2001 Total Full-Time Employees in Thousands 2500 2000 1500 1000 500 0 1990 Goods 1992 Services 1994 1996 1998 2000 2001 Private (Goods & Svcs) Table 2-5 contains selected economic indicators forecast for Arizona for 2001 through 2005. All indicators are forecast to increase except for mining, manufacturing, and TCPU. The forecast largest gains are for personal income (27.9%), restaurant and bar sales (26.0%), retail sales (19.8%), food sales (17.9%), and services (16.7%). Chapter 2 – Descriptions of Arizona - 12 - Arizona Regional Haze SIP Table 2-5 Projected Economic Indicators for Arizona: 2001-2005 Economic Indicator Personal Income ($millions) 2001 2002 2003 2004 2005 137,313.5 143,291.1 150,549.4 161,338.3 175,570.2 Retail Sales ($millions) 55,421.2 55,928.2 58,288.5 61,477.6 66,369.8 Food Sales ($millions) 7,262.7 7,491.3 7,678.3 8,050.4 8,565.3 Restaurant & Bar Sales ($millions) 6,360.6 6,490.3 6,851.4 7,367.4 8,014.0 Gasoline Sales ($millions) 3,492.3 3,476.4 3,693.4 3,717.5 3,845.0 Total Employment (10,000s) 226.63 224.74 229.23 238.10 248.87 9.6 8.8 8.7 8.5 8.3 Construction (1,000s) 164.9 159.4 161.6 160.8 166.6 Manufacturing (1,000s) 210.1 194.0 188.8 193.0 204.4 TCPU (1,000s)** 110.7 105.6 105.1 107.5 110.4 Trade (1,000s) 533.2 537.2 547.8 570.8 594.9 FIRE (1,000s)*** 150.7 149.9 155.1 164.4 173.2 Services (1,000s) 711.1 707.3 736.8 783.5 829.7 Government (1,000s) 376.4 385.3 388.6 392.7 401.2 Mining (1,000s) Unemployment Rate 4.7% 5.7% 5.2% 4.4% 4.1% Source: Economic Outlook 03/04. The University of Arizona. Eller College of Business and Public Administration, Table 3. * Includes bar sales as well ** Transportation, Communication, and Public Utilities *** Finance, Insurance, and Real Estate Chapter 2 – Descriptions of Arizona - 13 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 2 – Descriptions of Arizona - 14 - Arizona Regional Haze SIP 3. MANDATORY CLASS I FEDERAL AREAS ON THE COLORADO PLATEAU This chapter describes the 16 Class I areas on the Colorado Plateau studied by the Grand Canyon Visibility Transport Commission and addressed in this SIP in response to 40 CFR 51.309. Figure 3-1 shows the location of the national parks and wilderness areas addressed by this SIP. Figure 3-1. Colorado Plateau Class I areas 3.1. Arizona Class I Areas There are a total of 12 mandatory Class I Federal areas in Arizona. Of the four Arizona Class I areas addressed by this SIP, two, Grand Canyon National Park and Sycamore Canyon Wilderness are located in the northwestern portion of the state. Grand Canyon National Park extends over toward the state’s western border with Nevada, and Sycamore Canyon Wilderness Area is located south of Flagstaff. The third Class I area, Petrified Forest National Park, occupies land adjacent to and directly south of the Navajo Reservation. The fourth, Mt. Baldy Wilderness Area, occupies a comparatively small portion of land on the eastern side of the state and is one of the many extinct volcanoes found throughout the state. All four of these Arizona Class I areas are part of a larger formation known as the Colorado Plateau. This high, semi-arid tableland includes, along with northern Arizona, southeast Utah, northwest New Mexico, and western Colorado. Chapter 3 – Class I Areas - 15 - Arizona Regional Haze SIP Figure 3-2. Arizona Class I Areas. 3.1.1. Grand Canyon National Park The Grand Canyon National Park is on the southwestern Colorado Plateau. Over time, the Colorado River and its tributaries cut through the many layers of rock that make up the southwestern Colorado Plateau, forming a gorge one-mile deep and several miles wide. This cut into the earth begins at Lees Ferry, below Glen Canyon Dam, and extends 277 miles with a variation in width from 10-18 miles wide to just hundreds of yards in Marble Canyon to the northeast. The western part of the canyon extends into the Mohave Desert, while the eastern part reaches into the Great Basin Desert. The Park, after being designated a national monument in 1908, became a national park on February 26, 1919. The Park is contained within Mohave and Coconino Counties. The Grand Canyon was designated a World Heritage Site in 1979. The Grand Canyon is a spectacular example of weathering and erosion, featuring unmatched vistas and intriguing landforms comprised of irregular-shaped cliffs and valleys caused by differential erosion, buttes, mesas, and rock depositions forming talus cones and aprons. Because of these geological spectacles, the Grand Canyon ranks among the world’s greatest attractions with on-going erosion revealing much about the earth’s geological history. Every year millons of visitors from all over the world visit the Park. Chapter 3 – Class I Areas - 16 - Arizona Regional Haze SIP Figure 3-3. View From South Rim of The Grand Canyon National Park Figure 3-4. Map of Grand Canyon National Park Area Chapter 3 – Class I Areas - 17 - Arizona Regional Haze SIP 3.1.2. Sycamore Canyon Wilderness Approximately 40 miles southwest of Flagstaff is the Class I Area known as Sycamore Canyon Wilderness. Designated in 1935 as a Primitive Area, Congress formally established the area as a federally protected area in 1972. It became a Wilderness Area through the 1977 Arizona Wilderness Act. The area, split between Coconino and Yavapai Counties, contains 55,937 acres, beginning with pine and fir forests on the Colorado Plateau through part of the Mogollon Rim, ending at the desert mouth of the Verde Valley. Sycamore Canyon Wilderness, containing beautiful red rock, buttes, and sheer cliffs, is only 15 miles west of Oak Creek Canyon and Sedona area, one of Arizona’s most popular tourist destinations. Motorized or mechanized vehicles are not allowed in the area. Figure 3-5. Map of Sycamore Canyon Wilderness Area Chapter 3 – Class I Areas - 18 - Arizona Regional Haze SIP 3.1.3. Petrified Forest National Park Petrified Forest National Park is located in northeastern Arizona. The Park lies within both Navajo and Apache Counties, covering a total of 93,533 acres. It was designated a national monument in 1906 and a national park in 1962. The southern portion of Petrified Forest National Park contains one of the world’s largest concentrations of petrified wood. The northern portion of the Park encompasses the badlands of the Chinle Formation that extends along the Little Colorado River valley to the west for about 125 miles. Known more commonly as “the Painted Desert” with its colored soils ranging from blues and reds to yellows and grays, this area includes at its southern tip, the Rainbow Forest Figure 3-6. Petrified Forest National Park Figure 3-7. Map of Petrified Forest National Park Area Chapter 3 – Class I Areas - 19 - Arizona Regional Haze SIP 3.1.4. Mt. Baldy Wilderness Not to be confused with California’s Mt. Baldy, located in the San Gabriel Mountains, Mt. Baldy Wilderness, located in Apache County about 90 miles south of the Petrified Forest National Park. Mt. Baldy Wilderness, 7,079 acres, is an ancient volcano and the second highest peak in Arizona. It is located in the White Mountains along the southern edge of the Colorado Plateau. The summit of Mt. Baldy is on the White Mountain Apache Indian Reservation and is closed to all non-tribal members. This SIP is only for the portion of Mt. Baldy under the jurisdiction of the State. Figure 3-8. Map of Mount Baldy Wilderness Area Four rivers have headwaters on the slopes of Mt. Baldy: the Black, Blue, White, and Little Colorado rivers. Fishing and camping are major recreational activities where 25 lakes are scattered among the mountains. Livestock grazing is common on the meadows and pine forests of the White Mountains. The area has a wide range of weather, with snow at the higher elevations. The same conditions and restrictions that pertain to the Sycamore Canyon Wilderness Area also pertain to Mt. Baldy Wilderness area – no motorized or mechanized vehicles, no bicycles, and no power equipment is allowed. Chapter 3 – Class I Areas - 20 - Arizona Regional Haze SIP 3.2. Class I Areas Outside Arizona The four Class I areas on the Colorado Plateau are joined by 12 other Class I areas to make up the total of 16 Class I areas originally examined by the GCVTC. A brief description of each of these 12 areas follows.12 Capitol Reef National Park, Utah – Capitol Reef received its name from the barrier created by a 100 mile long ridge of rock that was thrust up from the earth millions of years ago. The rock is said to resemble the dome-like structures seen on capitol buildings in Washington, D.C. The park is fairly isolated in the south central part of Utah, 60 miles south of I-70. Bryce Canyon National Park, Utah – Also in southern Utah, Bryce Canyon represents the effect of centuries of erosion that has shaped the colorful Claron limestones, sandstones, and mudstones of this park into thousands of spires, pinnacles and mazes. The local name for these shapes is “hoodoos,” one of which forms a natural amphitheatre along the eastern edge. Zion National Park, Utah – On the southern edge of the Colorado Plateau, Zion is known for its highly variable weather due to its elevation changes of 3,666 feet at its lowest point in Coalpits Wash to 8,726 feet at its highest, Horse Range Mountain in the Kolob Canyon section. The variable weather an elevations have led to numerous “microenvironments” that range from hanging gardens to isolated mesas. Arches National Park, Utah - Arches National Park contains over two thousand natural sandstone arches, including the famous Delicate Arch. The park, also known for its balanced rocks and pinnacles, is located near Moab, Utah. Protected since 1929, it became a national park in 1971. Canyonlands National Park, Utah – Canyonlands preserves one of the last, relatively undisturbed areas of the Colorado Plateau. It contains a large portion of the Colorado River and its tributaries, which carve out numerous canyons and gorges. The unique desert ecosystem has been visited by different groups of settlers for over 10,000 years, in concert with available resources. Its national park designation in 1964 is an attempt to maintain its natural beauty while still allowing for continued visitors. Mesa Verde National Park, Colorado – Spanish for “green table,” Mesa Verde allows visitors to experience both cultural and physical influences on the land. From approximately 600 A.D. through 1300 A.D., settlements flourished in stone villages throughout the alcoves of the canyon walls. Twenty-four tribes in the southwest have ancestral affiliation with the sites at Mesa Verde. The park is 35 miles west of Durango in southwestern Colorado, just off US Highway 160. Flattops Wilderness Area, Colorado – Flattops has a less friendly history than Mesa Verde, witnessing the “Meeker Massacre” of 1879 when federal troops forcibly removed the Ute Indians, who had resided in the area for perhaps thousands of years. Originally destined to become a summer home area, it was instead recommended for wilderness area designation in 1919. In fact, Flattops became the keystone in the establishment of the National Wilderness Preservation System. Maroon Bells Wilderness Area, Colorado – Maroon Bells, and its neighboring area, Snowmass, see a large amount of visitors every year. There are over 100 miles of trail, and despite peaks that rise above 14,000 feet, people literally swarm throughout the park’s over 181,000 acres to enjoy some of the most beautiful views, some say of wildflowers alone, in the country. The park is named not for a flower, but 12 The State of Arizona thanks the USDA and US Park Service for providing information on the national parks and wilderness areas that comprise the Colorado Plateau through its various web sites and literature. Chapter 3 – Class I Areas - 21 - Arizona Regional Haze SIP for Maroon Bells peak, one of the most photographed mountains, especially when it is reflected in Maroon Lake. West Elk Wilderness Area, Colorado – As busy as Maroon Bells Wilderness Area is with visitors, West Elk is fairly devoid of people. Only hunters populate the area in the fall, when elk and deer number in the thousands. Long lava flows are found throughout the area, where trails can lead to areas containing ridges that the wind and water have carved into formations that resemble the turrets of castles. Black Canyon of the Gunnison Wilderness Area, Colorado – The Black Canyon of the Gunnison’s unique and spectacular landscape was formed slowly by the action of water and rock scouring down through hard Proterozoic crystalline rock. No other canyon in North America combines the narrow opening, sheer walls, and startling depths offered by the Black Canyon of the Gunnison. Weminuche Wilderness Area, Colorado – Weminuche is Colorado’s largest wilderness area. It contains 63 high altitude lakes, known for their deep blue color. The area encompasses a total of 488,210 acres that include the headwaters of both the Rio Grande and San Juan Rivers. The area also contains the Continental Divide Trail and is said to exemplify the mission of the Wilderness Act of 1964 by securing the benefits of an enduring resource of wilderness for generations to come. San Pedro Parks Wilderness Area, New Mexico – This area, at the same latitude as the Grand Canyon National Park where the Colorado Plateau dips into New Mexico and Arizona, has an elevation of 10,000 feet above sea level. But unlike its counterpart in Arizona, the area has rolling mountaintops and meadows with large grassy areas. The area sees frequent rain in late summer and snow by November. Its mountain streams are a favorite of local trout anglers. Chapter 3 – Class I Areas - 22 - Arizona Regional Haze SIP 4. TECHNICAL BASIS FOR REGULATION OF REGIONAL HAZE This chapter provides a brief introduction to the science of visibility and the technical basis for the regulation of regional haze. A more detailed presentation of the concepts contained in this chapter can be found in the 1999 document entitled Introduction to Visibility by William C. Malm, Ph.D., available from CIRA (Cooperative Institute for Research in the Atmosphere) at Colorado State University. 4.1. How Do We See? Light waves, like radio waves, are a form of electromagnetic radiation. All electromagnetic radiation travels in the form of waves at the speed of light which is approximately 186,000 miles per second. Light waves, like radio waves, also have distinct frequencies (the number of times per second the wave goes from crest to crest) and a corresponding wave length (the distance between the crest of each wave). As an example, when you tune your radio to 550 on the AM dial, your radio receives a signal that has a frequency of 550 thousand cycles per second with a corresponding wave length of approximately 1,800 feet (six football fields). In contrast, blue light has a frequency of about 3.5 trillion cycles per second corresponding wave length of 1.5 millionths of an foot. Unlike radio waves that require humans to use a radio receiver to capture information, the human eye directly captures information contained in light waves. Light waves are made up of small energy packets, or photons, that travel through the air. Light photons each have a defined energy level that give them a distinct color corresponding to its frequency or wave length. Red light waves are at the lowest energy level and the longest wavelength. Blue light waves are at the higher energy level and shorter wavelength. White light, like sunlight, is made up of a mixture of all of the different wave lengths of light. When white sunlight goes through a prism, or through rain drops, the photons can be separated by energy level and generate a rainbow of colors. The human eye is a sophisticated receiver of electromagnetic radiation in the form of light. Unlike a radio receiver that can only detect and interpret one frequency at a time, the human eye can detect all frequencies, or wavelengths, of visible light simultaneously. The human eye can distinguish a wide variety of colors and light intensities of objects. In order to distinguish an object from its background, there must be a contrast between the object and its background. The contrast necessary to distinguish an object from its background varies depending on color and texture, but generally, a 2% contrast is necessary in order to be detected by the human eye. When sunlight hits a solid object, the surface absorbs some photons and reflect others. The wavelength of the light reflected defines the color that the human eye perceives. For example, the reason an apple looks red is that red photons are mostly reflected, and photons in the other color wavelengths are mostly absorbed. An egg looks white because the surface absorbs and reflects all of the color components of light at about the same level. Sunlight reflected from surfaces on the earth, or scattered by particles and gases in the air, interfere with the view that would be experienced under ideal conditions. Gases and very small particles preferentially scatter blue light in all directions. Large particles tend to scatter all colors of light (white light) in the forward direction. This causes a very strong white haze to appear to the eye when looking toward the sun, and much lighter haze when looking away from the sun. Chapter 4 – Technical Background - 23 - Arizona Regional Haze SIP 4.2. How Particulates and Gases Impair Visibility As light photons travel through the air, they collide with molecules of gases and particles. This collision results in the light photons either being scattered or absorbed. When sunlight travels through clear air (i.e., with no particles), light photons corresponding with the higher energy level blue wavelengths of light are preferentially scattered, resulting in the human eye perceiving the sky as being blue, even though air is a colorless gas. Figure 4-1 shows how particles and gases interact with light. Figure 4-1. Interaction of Particles and Gases with Light. There is a limit to how far the eye can see. That limit is defined by the rate at which light is extinguished (scattered or absorbed) as it travels through the air. The light extinction coefficient defines the rate at which light is removed as it travels through the air. In clear air (i.e., with no particles in the air), that limit is approximately 350 kilometers and results from Rayleigh scattering caused by light encountering molecules of oxygen and nitrogen in clear air. This corresponds to a light extinction coefficient of approximately 10 inverse mega-meters (10 Mm-1). Particles in the air, which are also referred to as aerosols, also interfere with light as it travels, especially particles that are approximately the same size as the wavelength of light. As light travels, light photons will be scattered and absorbed by particles in the air. A higher concentration of particles in the air will result in a higher light extinction coefficient and more visibility impairment. Different types of particles have different effects on visibility. For visibility studies, concentrations of particles in the air are expressed in millionths of grams (micrograms) per cubic meter of air. Filters are used to collect the particles for laboratory analysis. The equipment used to collect the Chapter 4 – Technical Background - 24 - Arizona Regional Haze SIP filters separate the particles by size. Some filters only collect fine particles that are smaller than 2.5 microns in diameter, while others collect both fine particles and courser particles smaller than 10 microns in diameter. Light extinction efficiencies are used to convert the concentration of particles in the air into the impact on the light extinction coefficient. As was noted above, smaller particles are more efficient at scattering light than larger particles. 4.3. Types of Particles and Gases Contributing to Visibility Impairment There are two distinct categories of particles in the air: primary particulates that are directly emitted into the air, and secondary particulates that are formed by the chemical reaction of gases emitted into the air. Primary particulates include course soils, fine soils, elemental carbon (soot), and organic carbon. Secondary particulates include ammonium sulfate formed from gaseous sulfur dioxide, ammonium nitrate formed from gaseous oxides of nitrogen, and also organic carbon particles formed from volatile organic carbon gases. An additional factor that effects visibility is that ammonium sulfate and ammonium nitrate particles also can absorb moisture in the air causing the particles to grow, which increases light extinction. For regional haze visibility assessment studies, Table 4-1 summarizes the particles of interest, light extinction efficiencies, and the effect of relative humidity on the extinction efficiencies for ammonium sulfate and ammonium nitrate particles. Table 4-1. Light Extinction Efficiencies of Particles Type of Particle Relative Humidity Humidity Dependent Ammonium Sulfate Ammonium Nitrate Humidity Independent Organic Carbon Elemental Carbon Fine Soil Coarse Soil Light Extinction Efficiency & Effect of Relative Humidity (RH) 30% RH 60% RH 90% RH 3.0 3.0 4.8 4.8 11.4 11.4 4.0 10.0 1.0 0.6 4.0 10.0 1.0 0.6 4.0 10.0 1.0 0.6 Source: EPA Visibility Monitoring Guidance EPA-454/R-99-003. Humidity effects derived from Figure 2-3. Light Extinction Efficiencies are expressed in units of square-meters per gram. The key concepts to understand from Table 4-1 are: • The extinction efficiency varies widely depending on the type of particle. For instance, elemental carbon, which not only scatters light but also absorbs light has 16.7 times the influence on visibility than coarse soil. • Relative humidity is important if ammonium sulfates or ammonium nitrates are present. At high relative humidity the extinction efficiency can be a factor of 4 higher than under low relative humidity. • Understanding of the composition of the particles present in the atmosphere is necessary to accurately characterize the impact on visibility. Chapter 4 – Technical Background - 25 - Arizona Regional Haze SIP 4.4. Sources of Particulates and Gases Contributing to Visibility Impairment on the Colorado Plateau Sources of emissions that contribute to the particles in the atmosphere that cause visibility impairment fall into two broad classes: natural sources of emissions, and human-caused (or anthropogenic) sources of emissions. The GCVTC developed comprehensive emission inventories for areas contributing to visibility impairment at the 16 GCVTC Class I areas on the Colorado Plateau. Natural sources of emissions include a wide variety of pollutants that are emitted to the atmosphere. Wildfire emissions include primarily fine particulates (organic carbon, elemental carbon, and fine soils), course soils, oxides of nitrogen, and volatile organic compounds. Volcanic activity produces fine and course soils, and in many instances, sulfur dioxide. High winds can create emissions from natural undisturbed lands that contain primarily coarse and some fine soils. Achieving visibility conditions comparable to those that would be experienced with only natural sources is the long-term goal of the regional haze program. Human-caused sources of emissions also contribute to visibility impairment. Point sources (such as utility boilers, smelters, industrial boilers, and refineries) produce the majority of the sulfur dioxide in the GCVTC region, and about 25% of the oxides of nitrogen. Mobile sources (such as cars, trucks, offroad equipment, trains, and planes), produce the majority of the oxides of nitrogen in the GCVTC region and half of the human-caused volatile organic carbon emissions. In addition to direct emissions from mobile sources, road dust can be an important source of course and fine soil emissions. Prescribed fire on wildlands produce emissions similar to natural occurring wildfires. Finally, area sources (which make up all the other source types not discussed above) generate a broad range of emissions of all pollutants of interest for visibility and can be important especially in large population centers. States are required to develop long-term strategies to manage human-caused sources of visibility impairment to make reasonable progress toward the national goal of eliminating human-caused visibility impairment. 4.5. Visibility Conditions on the Colorado Plateau The Colorado Plateau generally has the best visibility conditions in the country. Unlike the eastern United States where ammonium sulfates are the most significant contributor to visibility impairment, there is no one type of particle that is the most significant contributor on the Colorado Plateau. The GCVTC found that particle based visibility impairment results equally from ammonium sulfates, the combination of organic carbon and elemental carbon, and the combination of coarse and fine soils. The GCVTC found that ammonium nitrate is a relatively small contributor to visibility impairment on the Colorado Plateau. On a day-to-day basis there can be one type of particle that has a more pronounced impact on visibility than others. However, all sources of these types of particles must be reviewed to develop an effective long-term strategy to make reasonable progress toward the national goal. 4.6. State of Arizona Visibility Monitoring Plan and Network The Arizona Department of Environmental Quality (ADEQ), local agencies, and federal land managers at Arizona’s 12 Class I areas are cooperatively operating a visibility monitoring network to track impairment of visual air quality. The Arizona Class I visibility network consists of visibility monitoring equipment provided by the Interagency Monitoring of PROtected Visual Environments (IMPROVE) monitoring program and additional equipment provided by ADEQ. The IMPROVE aerosol samplers collect particulate matter on filters (both PM2.5 and PM10 fractions) which are routinely analyzed for chemical constituents. ADEQ and the National Park Service (NPS) have added optical monitoring equipment to measure visibility impairment, and meteorological monitoring equipment at most sites. Chapter 4 – Technical Background - 26 - Arizona Regional Haze SIP Arizona maintains a visibility monitoring operation plan. This visibility monitoring plan is updated when necessary to reflect updated IMPROVE and EPA guidance, and specific needs identified by ADEQ. ADEQ is an Associate Member of the IMPROVE Steering Committee and participates in the technical oversight of the IMPROVE network. The chemical constituent data from the IMPROVE samplers are used to identify the chemical species and emission sources responsible for existing human-caused visibility impairment. The optical data show the visual air quality at a point as a person might experience the view. Nephelometers measure light scattering by particles at points collocated with the IMPROVE samplers, and at four areas, transmissometers also provide optical data on total light extinction along a path. Meteorological data are collected to provide a more complete understanding of the behavior of the atmosphere in general, as well as clarifying local air movement. These data are collectively used to track short-term and long-term trends, assess source contributions to visibility impairment that are reasonably attributable to a single source or group of sources, and determine the causes of regional visibility impairment at a given location. The intent of this visibility monitoring operational plan is to characterize long-term trends in all Arizona Class I areas as completely as possible using ambient visibility measurements, within constraints of an area’s size, terrain, or logistics, for each of the 12 federally-protected Class I areas in Arizona. In practical terms, one monitoring site or a group of sites may represent several Class I areas, or multiple locations of the same or different types of sites may represent an individual Class I area. This monitoring plan is designed to meet the following requirements of 40 CFR 51.305 and 40 CFR 51.308(d)(4): 1) to have a long-term monitoring strategy; 2) to track visibility trends at Arizona Class I areas; 3) to assist in identifying any attributable visibility impairment; and 4) to provide monitoring data, if necessary, for evaluating the impact of new or major modifications of categorical major sources. Arizona’s monitoring program began in the spring of 1996, and the monitoring plan was updated in 2002. In addition to the state-sponsored IMPROVE monitoring, the National Park Service has maintained IMPROVE monitors (transmissometer and particle samplers) in Petrified Forest and Grand Canyon national parks since 1987, providing a long baseline of visibility measurements. Pursuant to 40 CFR 51.305 and 40 CFR 51.308(d)(4), the State of Arizona maintains a monitoring plan to address visibility impairment. The State of Arizona relies on the IMPROVE program for data collection and processing and commits to the reporting of all visibility monitoring data to the Administrator at least annually for each Class I area in the State. Chapter 4 – Technical Background - 27 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 4 – Technical Background - 28 - Arizona Regional Haze SIP 5. STRATEGY TO ADDRESS REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT (RAVI) Section 169A of the CAA contains the national goal that requires states to remedy existing visibility impairment and prevent future visibility impairment in the Class I areas. Initially, states containing mandatory Class I Federal areas were required to address the specific type of air pollution coming from existing stationary sources that could be anticipated to cause or contribute to visibility impairment. This type of pollution was commonly referred to as “plume blight,” or more formally, reasonably attributable visibility impairment (RAVI). On December 2, 1980, the EPA determined that there were two types of air pollution that reduced or impaired visibility (45 FR 80084). One type was described as “smoke, dust, colored gas plumes, or layered haze emitted from stacks,” and the second type was “widespread, regionally homogeneous haze from a multitude of sources” (Ibid, p. 80085). The existing stationary sources subject to this regulation include any reconstructed source that was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year of any regulated pollutant. “In existence” is interpreted by the EPA to be consistent with the term, “commence construction” found in Prevention of Serious Deterioration (PSD) regulations (40 CFR 51.165(a)(1)(xvi) and 40 CFR 52.21(b)(9)). If construction commenced after August 7, 1977, the source would be subject to the PSD/NSR (new source review) program. The SIPs developed to address visibility impairment from sources that could be reasonably anticipated to cause or contribute to visibility impairment in Class I areas had to include four specific things: (1) a monitoring plan to assist in the determination of what type of emissions were actually occurring in and near the Class I Area; (2) a way to determine what type of technological controls (best available retrofit technology or BART) could be used at a source should that source be found to cause or contribute – be found attributable – for the air pollution; (3) a process for addressing possible visibility impairment from new sources through existing New Source Review regulations, including review of that process by the FLMs; and (4) long-term strategies for dealing with existing and any future visibility impairment from stationary sources. SIPs for 36 states were due to EPA by December 2, 1980. Unable to comply by the deadline, Arizona along with several other states, was cited on July 12, 1985, as failing to meet the requirements of 40 CFR 51.305, monitoring, and 51.307, new source review (50 FR 28545). On November 24, 1987, Arizona was cited as failing to meet the requirements of 40 CFR 51.306, long-term strategies, and 51.302, control strategies (i.e., BART).13 Failure to meet the requirements in 40 CFR 51.302, 305, 306, and 307 through a SIP meant EPA imposed a Federal Implementation Plan or FIP (52 FR 45134, November 24, 1987). Included in the 1987 FIP was FLM certification of three Class I areas in Arizona for visibility impairment: Grand Canyon National Park, Petrified Forest National Park, and Saguaro Wilderness. On September 15, 1988, EPA published its assessment of the Class I areas certified by the FLMs that included an assessment of the three Arizona areas named in 1987 (53 FR 35956). By 1991, EPA published a final rule that revised Arizona’s FIP to reflect an analysis of the visibility impairment at Grand Canyon National Park for an attributable stationary source, Navajo Generating Station (56 FR 50172). For the purpose of addressing the process the State of Arizona could use in the event of future certifications, a State rule has been promulgated for reasonably attributable visibility impairment. That 13 Arizona was not cited for failure to meeting 51.304, integral vistas, as no integral vistas have been listed in Arizona. Integral vistas are areas outside the boundary of a Class I Area, but visible from within it. Chapter 5 – Attributable Impairment - 29 - Arizona Regional Haze SIP rule, effective December 2, 2003, can be found in Appendix A-5a. The following sections discuss how Arizona is now meeting the requirements of 40 CFR 51.302 through 307, which should allow EPA to remove the existing FIP. 5.1. Implementation of Control Strategies Pursuant to 40 CFR 51.302, states must have a procedure in place to analyze and, if necessary, implement control strategies for RAVI, and imposition of best available retrofit technology (BART) for any eligible source whose emissions are found to cause or contribute to visibility impairment. Arizona’s RAVI rule can be found in Appendix A-5a; a list of the BART-eligible sources is listed in Section 1601 of the rule. Arizona’s RAVI rule also serves as the authority for the possible implementation of controls under “geographical enhancement” for any stationary source found to impair visibility via the WEB Trading Program as outlined in Chapter 8 of this SIP. 40 CFR 51.302 also requires the state to communicate with the FLMs and provide for consultation on any matters pertaining to visibility impairment. A letter notifying the FLMS of the State of Arizona’s visibility contact person, as well as the opportunity to review this SIP prior to any public hearings, can be found in Appendix A-5b. A subsequent letter notifying the FLMs of the public comment period, and locations and dates of public hearings for this SIP can also be found in Appendix A-5b. All supporting documents related to the promulgation of Arizona’s RAVI rule can also be found in Appendix A-5c. 5.2. Exemptions from Controls Pursuant to 40 CFR 51.303, any source found attributable for visibility impairment and required to install and operate BART, may request a federal exemption from BART. This federal exemption process is incorporated by reference in R18-2-1606 of Arizona’s RAVI rule. At this time, no source in the State of Arizona has requested a federal exemption from BART. 5.3. Identification of Integral Vistas Pursuant to 40 CFR 51.304, any identified integral vista must be addressed on an equivalent basis as for any Class I Area. An integral vista is a specific landmark or panorama located outside the boundary of a mandatory Federal Class I Area, but visible from that Class I Area. Therefore, any impairment within the Class I Area could possibly impact the integral vista as well. No integral vistas have been identified to date for the State of Arizona’s 12 mandatory Class I Federal areas (52 FR 45132, November 24, 1987). 5.4. Monitoring Pursuant to 40 CFR 51.305, the State of Arizona has developed a monitoring plan for the 12 Class I areas. The plan, Arizona Class I Area Visibility Monitoring Operational Plan (Monitoring Plan), published in 1996 and updated in 2002, includes a commitment to, “characterize long-term trends in all Arizona Class I areas as completely as possible using ambient visibility measurements, within constraints of an area’s size, terrain, or logistics, for each of the 12 Class I areas in Arizona” (p. 3 Monitoring Plan). Arizona’s Monitoring Plan was developed with the full cooperation of the FLMs, other related agencies and counties as well as air quality specialists in the field of monitoring, data gathering and assessment, and meteorology. The Monitoring Plan is reviewed annually and contains four objectives that also serve to meeting the needs of any visibility regulations promulgated by the State of Arizona to meet RAVI. The objectives are: (1) long-term monitoring strategy, (2) track visibility trends at Arizona Chapter 5 – Attributable Impairment - 30 - Arizona Regional Haze SIP Class I areas, (3) assist in identifying any reasonably attributable visibility impairment impacts, and (4) provide monitoring data if necessary for new or major modifications of categorical major sources. Along with providing a network of visibility monitors, the Monitoring Plan also accounts for the long-standing IMPROVE monitoring program and integration with EPA’s PM 2.5 monitoring guidance. IMPROVE was established in 1985 to coordinate the monitoring of national parks and wilderness areas and to ensure sound and consistent scientific methods were being employed. The IMPROVE Steering Committee established monitoring protocols for visibility measurement, particulate matter measurement, and scientific photography of the Class I areas. IMPROVE monitoring is designed to established reference information on visibility conditions and trends to aid in the development of visibility protection programs. 5.5. Long-term Strategy Requirements Pursuant to 40 CFR 51.306, a long-term strategy for RAVI must be established in the SIP. This strategy must cover a 10-15 year period. Arizona’s submittal under 40 CFR 51.309 fulfills the long-term strategy requirements for RAVI for stationary sources. Should any source be found attributable for visibility impairment and subsequently required to install and operate BART, the State of Arizona commits to submitting a SIP revision (as required by R18-2-1605(B)), meeting the review requirements for the long-term strategies as outlined in 51.306(e), including any impact resulting from the imposition of controls or exemption from controls for BART. 5.6. New Source Review for Visibility Protection Pursuant to 51.307, the State of Arizona’s R18-2-410 (Article 4, New Source Review, Arizona Administrative Code) addresses the requirements of new sources to meet performance standards to assure emissions will not have an impact on visibility in Arizona’s 12 Class I areas. The rule can be found in Appendix A-5d. On September 1, 1994, EPA deemed the State of Arizona SIP revision for New Source Review (NSR) / Prevention of Significant Deterioration (PSD) and minor NSR source programs complete and is awaiting further EPA action. Chapter 5 – Attributable Impairment - 31 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 5 – Attributable Impairment - 32 - Arizona Regional Haze SIP 6. LONG-TERM STRATEGY FOR THE CLEAN AIR CORRIDOR 6.1. Regulatory History and Requirements One of the requirements of the Regional Haze Rule (40 CFR 51.309(d)(3)) is to finalize earlier work initiated by the GCVTC to address clean-air corridors. One of the tasks of the GCVTC required by CAA 169B was to determine whether any clean-air corridors exist for any of the 16 GCVTC Class I areas. A clean-air corridor is a geographic region that contributes clean air to a Class I area on the days with best visibility. If clean-air corridor(s) were found to exist, the GCVTC was required to recommend whether additional control strategies were needed to manage emissions growth to protect visibility on the least impaired days in the Class I areas. For the purpose of its assessment, the GCVTC considered the average of the days representing the 20% best visibility conditions to be the least impaired days. EPA also used this definition in defining the term in the 1999 Regional Haze Rule (40 CFR 51.308 and 40 CFR 51.309). In 1995, the GCVTC Meteorology Subcommittee completed an analysis of the geographical source areas contributing to least impaired days in the 16 GCVTC Class I areas. The analysis, in a report entitled, Clean-Air Corridors: A Framework for Identifying Regions that Influence Clean Air on the Colorado Plateau,14 showed that the area north and west of the Grand Canyon National Park does provide clean air to the Grand Canyon area primarily due to a combination of favorable meteorological conditions and low emissions of pollutants from the sparsely populated area. The GCVTC Public Advisory Committee (PAC) reviewed the clean-air corridor analysis and emission projections and determined expected emissions growth was less than the amount that would degrade visibility on the least impaired days in the 16 Class I areas. Based on this finding, the PAC recommended emissions growth be monitored in the future but that no additional control strategies were needed in the identified clean-air corridor at that time. The GCVTC adopted this recommendation and included it in its final report to EPA, which was integrated into the regional haze rule (40 CFR 51.309(d)(3)). The Regional Haze Rule requires states submitting SIPs under 40 CFR 51.309 to determine if there were additional areas(s) to be considered as clean-air corridors for emission tracking purposes in the GCVTC areas. The successor to the GCVTC, the Western Regional Air Partnership (WRAP), completed an economic/technical analysis to validate the growth projections in the clean air corridors. This analysis was included as part of a consensus policy adopted by the WRAP Board in November, 2002. A copy of this policy, WRAP Policy on Clean Air Corridors, is contained in Appendix A-6a. The WRAP policy defined a clean air corridor consistent with the range of optional clean air corridor definitions identified by the GCVTC Meteorology Subcommittee. The final clean air corridor included a recognition of county-level emissions inventory practices, and an emissions tracking requirement in the clean air corridor. The technical studies and findings used as the basis for the WRAP Clean-Air Corridor Policy are located in Chapter 3 of the WRAP Technical Support Document. The most recent projections of visibility conditions at the 16 GCVTC Class I areas performed by WRAP is discussed in Chapter 14. 14 Clean Air Corridors: Framework for Identifying Regions that Influence Clean Air on the Colorado Plateau, Meteorology Subcommittee of the Grand Canyon Visibility Transport Commission; Western Governors' Association: Denver, CO, July 1995. Chapter 6 – Clean Air Corridor - 33 - Arizona Regional Haze SIP 6.2. Identification of Clean Air Corridor; Other Clean Air Corridors Pursuant to 40 CFR 51.309(d)(3)(i), the State of Arizona concurs that there is an existing cleanair corridor as defined in the WRAP Policy on Clean-Air Corridors. The boundary of the clean-air corridor is indicated on the map in Figure 6-1 provided below. No portion of Arizona is inside the clean-air corridor. Figure 6-1. Map of the Clean Air Corridor in the Transport Region This Clean Air Corridor was identified using studies conducted by the Meteorological Subcommittee of the Grand Canyon Visibility Transport Commission, and then updated by the WRAP based on an assessment described in the WRAP Policy on Clean-Air Corridors, and related technical analysis conducted by the WRAP. The State of Arizona, pursuant to 40 CFR 51.309(d)(3)(v), has determined, based on the WRAP Policy on Clean-Air Corridors and technical analysis, that no other clean-air corridors are identified at this time. The State of Arizona commits to participating in a regional effort to review this determination as part of periodic plan revisions required under 40 CFR 51.309(d)(10). Chapter 6 – Clean Air Corridor - 34 - Arizona Regional Haze SIP 6.3. Strategy for Clean Air Corridors (a) Comprehensive emissions tracking program. Pursuant to 40 CFR 51.309(d)(3), a comprehensive emissions tracking system has been established to track emissions inside and outside the clean-air corridor, as specified in (b) below, to ensure that visibility is not degraded on the least-impaired days in any of the 16 Class I areas of the Colorado Plateau. This comprehensive emissions tracking system was developed by the WRAP to assist the above states in meeting this requirement. Appendix A6b of this SIP describes the WRAP comprehensive emissions tracking system, and the process by which the WRAP will summarize annual emission trends in order to identify any significant emissions growth that could lead to visibility degradation in the 16 Class I areas. Included in this summary will be an assessment of whether any significant emissions growth has occurred within the Clean Air Corridor, in accordance with (c) below. The State of Arizona will work cooperatively with states not submitting a plan revision under 40 CFR 51.309 that have emissions within or outside the clean-air corridor that could affect air quality in the clean-air corridor, to assure the emissions are incorporated into the tracking program through inter-state consultation. (b) Patterns of growth within the clean-air corridor. Pursuant to 40 CFR 51.309(d)(3)(ii), the State of Arizona has determined, based on the WRAP Policy on Clean-Air Corridors and WRAP technical analysis, that current projections of emissions changes inside the identified clean-air corridor will not contribute to degradation of visibility on the least impaired days in the 16 Class I areas during the planning period through 2018. Future emissions growth will be tracked in accordance with the comprehensive emissions tracking system noted in (a) above. The WRAP will summarize annual emission trends within the clean-air corridor and assess whether any significant emission growth has occurred within the corridor as an analysis tool for states. (c) Patterns of growth outside the Clean Air Corridor. Pursuant to 40 CFR 51.309(d)(3)(iii), the State of Arizona has determined, based on the WRAP Policy on Clean-Air Corridors and technical analysis conducted by the WRAP, that outside the Clean Air Corridor identified in Section 6.2, above, there is no emissions growth occurring at this time that is contributing to visibility impairment within the Clean Air Corridor in any of the 16 Class I areas of the Colorado Plateau As part of the WRAP’s annual summary of emission trends within the corridor, an assessment will be made of emission and monitoring data trends outside the Clean Air Corridor, in order to determine if significant emissions growth is occurring outside the corridor that could be impairing air quality within the corridor, and resulting in visibility impairment in the 16 Class I areas. (d) Actions if impairment inside or outside the Clean Air Corridor occurs. The State of Arizona, in coordination with other transport region states and tribes, will review the WRAP’s annual summary of emission trends within the Clear Air Corridor and whether any significant emissions growth was identified within the corridor in accordance with (b) above, or was identified outside the corridor, in accordance with (c) above. If significant emissions growth is identified, the State of Arizona in coordination with other transport region states and tribes, will conduct or seek WRAP assistance in conducting an analysis of the effects of this emissions growth in terms of possible impact on air quality within the corridor and possible degradation of the least-impaired days in any of the 16 Class I areas of the Colorado Plateau. Pursuant to 40 CFR 51.309(d)(3)(iv), if this analysis finds that this growth is causing visibility impairment in the 16 Class I areas, the State of Arizona in coordination with other transport states and tribes will evaluate the need for additional emission reduction measures, and identify an implementation schedule for such measures, if needed. The implementation of any additional emission measures shall be coordinated with all appropriate transport region states and tribes, on a mutually agreed upon timetable, and reported to EPA in accordance with the periodic progress reports required under 40 CFR 51.309(d)(10)(i). If the WRAP regional planning process is unable to perform such an analysis for Chapter 6 – Clean Air Corridor - 35 - Arizona Regional Haze SIP the GCVTC Class I areas in Arizona, or come to a consensus on the interpretation of such an analysis, the State of Arizona will perform such studies and engage in independent interstate consultation provided for under 40 CFR 51.309(d)(11). Chapter 6 – Clean Air Corridor - 36 - Arizona Regional Haze SIP 7. LONG-TERM STRATEGY FOR STATIONARY SOURCES 7.1. Regulatory History and Requirements The Grand Canyon Visibility Transport Commission (GCVTC) studied the long-term projected changes of emissions from stationary sources. It was found that emissions of sulfur dioxide from stationary sources would decline by at least 13% between 1990 and 2000. Also, emissions of sulfur dioxide would continue to decline through 2040 when only 30% to 50% of the 1990 emission levels would remain. This decline was due to the normal turnover of source technology as older sources retire and are replaced by newer and cleaner technologies. The GCVTC decided that the most effective way to address emissions of sulfur dioxide from stationary sources was to establish regional emission milestones and provide for a backstop program to achieve necessary emission reductions. If the emission reduction milestones are not achieved, then a backstop market trading program will be implemented. In Section 309(d)(4)(ii-iv) of the Regional Haze Rule, EPA required the states to complete the development of a backstop market trading program for sulfur dioxide. The WRAP submitted the Annex to EPA in October 2000.15 On June 5, 2003, EPA approved the program (68 FR 33764). Chapter 8 of this SIP contains the regional Sulfur Dioxide Milestones and Backstop Trading Program as required under Section 309(h) of the June 5, 2003, revised Regional Haze Rule. To keep the actual program as detailed in Chapter 8 intact, what follows here is a summary of the major elements of the program. • Regional milestones, SO2 emissions tracking requirements, and methodology the State of Arizona would use to determine allocations and manage the allowance tracking system should the program be “triggered” by the violation of any of the milestones as shown in Figure 7-1. Figure 7-1. Regional Sulfur Dioxide Emission Milestones S O 2 M ile s t o n e s GCVTC Region Total Annual S O2 of Tons (000) 90 0 831 80 0 723 720 715 70 0 6 82 60 0 655 677 625 1 3 % R e d u c t io n 510 50 0 480 40 0 5 2 % R e d u c t io n 30 0 20 0 10 0 0 1 99 0 2000 2010 w/ S me lt e r S e t -a s id e 2020 2030 2040 w / o S m e lt e rs 15 Western Regional Air Partnership. Voluntary Emissions Reduction Program for Major Industrial Sources of Sulfur Dioxide in Nine Western States and a Backstop Market Trading Program, An Annex to the Report of the Grand Canyon Visibility Transport Commission. Denver, CO. September 29, 2000. Chapter 7 – Stationary Sources - 37 - Arizona Regional Haze SIP • Description of the regulatory authority for the SO2 Milestones and Backstop Trading Program. The Western Backstop SO2 Trading Program Rule establishes the procedures and compliance requirements for the participating states, tribes, and affected sources. Appendix A-7a contains the State of Arizona’s draft rule based on the Western Backstop SO2 Trading Program Model Rule. This draft rule also contains requirements for participating sources under the pre-trigger portion of the program found in Section 8.2.1 of the SO2 Milestones and Backstop Trading Program. The State of Arizona commits to the promulgation of a State rule for the Western Backstop SO2 Trading Program as expeditiously as practicable. • Authority to require major industrial sources of SO2 to submit an annual emissions inventory in the pre-trigger phase of the program to measure compliance with the regional SO2 milestones. The authority for Arizona to require sources to meet this requirement of Section 8.2.1 of the SO2 Milestones and Backstop Trading Program is contained in the draft rule in Appendix A-7a. Again, the State of Arizona commits to the promulgation of a State rule for the Western Backstop SO2 Trading Program as expeditiously as practicable. • Establishment of a WRAP standing committee to develop the coordination procedures for the program. This “309 Coordinating Committee” will be formally proposed at the WRAP Board Meeting to be held in October 2003. Appendix A-7b contains the proposal approved by the WRAP Board on October 15, 2003 for the establishment of the WRAP 309 Coordinating Committee. 7.2. Monitoring and Reporting of Stationary Source Sulfur Dioxide Emissions. Achievement of Greater Than a 13% Reduction in Sulfur Dioxide by 2000. One item that must be included in the first SIP under Section 309(d)(4)(i) is monitoring and reporting of stationary source sulfur dioxide (SO2) emissions. This monitoring and reporting data must be sufficient to determine whether a 13 % reduction in actual stationary source SO2 emissions has occurred between the years 1990 and 2000, and whether milestones required by Section 51.309(d)(4)(ii) have been achieved for the transport region. As shown in Table 7-1, regional SO2 emission totals show that there has been a 25 percent reduction in these emissions from 1990 to 2000.16 Details of the source of emission inventories used for this calculation are in the Chapter 4 of the WRAP TSD. Table 7-1. State-by-State Comparison of 1990 and 2000 Stationary Source Sulfur Dioxide Emissions in the 9 GCVTC Transport Region States (tons per year) States Arizona California Colorado Idaho Nevada New Mexico Oregon Utah Wyoming Totals 1990 185,398 52,832 95,534 24,652 52,775 177,994 17,705 85,567 136,318 828,775 2000 99,133 38,501 99,161 27,763 53,943 117,344 23,362 38,521 124,110 621,838 7.3. 16 Year 2000 Point Source SO2 Emissions Analysis - 9 State Western Region Report, E.H. Pechan & Associates, Inc. for the Western Governors’ Association; Denver, CO, May 2002. Chapter 7 – Stationary Sources - 38 - Arizona Regional Haze SIP Report on Assessment of NOx/PM Strategies Provisions for Stationary Source NOX and PM. Pursuant to 40 CFR 51.309(d)(4)(v), the State of Arizona has included in this SIP a report which assesses emissions control strategies for stationary sources of NOx and PM, and the degree of visibility improvement that would result from implementation of the identified strategies. The report, Stationary Source NOx and PM Emissions in the WRAP Region: An Initial Assessment of Emissions, Controls, and Air Quality Impacts, was prepared by the WRAP and is included in Appendix A-7c. The report represents the State of Arizona’s initial assessment of stationary source NOx and PM strategies for regional haze. The State of Arizona has determined that NOx and PM strategies are not needed at this time. The State of Arizona commits to adopting long-term strategies and Best Available Retrofit Technology (BART) requirements for stationary sources of NOx and PM as a SIP revision in 2008 if Arizona determines such emission control strategies are needed to demonstrate reasonable progress. Chapter 7 – Stationary Sources - 39 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 7 – Stationary Sources - 40 - Arizona Regional Haze SIP 8. SO2 MILESTONES AND BACKSTOP TRADING PROGRAM 8.1. Milestones and Determination of Program Trigger 8.1.1. Regional SO2 Milestones (1) Base Milestone Values. The regional sulfur dioxide base milestones for the years 2003 through 2018 are provided in Table 8-1. The base milestones will be adjusted annually as described in paragraphs 8.1.1(2), (3) and (4) of this plan. Table 8-1. Base Sulfur Dioxide Emissions Milestones (excludes Smelter Set-aside) Column 1 Column 2 Column 3 For the year the base regional sulfur and the annual SO2 emissions for these years will dioxide milestone is determine whether emissions are greater than or less than the milestone 2003 682,000 tons SO2 2003 2004 682,000 tons SO2 Average of 2003 and 2004 2005 682,000 tons SO2 Average of 2003, 2004 and 2005 2006 682,000 tons SO2 Average of 2004, 2005 and 2006 2007 682,000 tons SO2 Average of 2005, 2006 and 2007 2008 680,333 tons SO2 Average of 2006, 2007 and 2008 2009 678,667 tons SO2 Average of 2007, 2008 and 2009 2010 677,000 tons SO2 Average of 2008, 2009 and 2010 2011 677,000 tons SO2 Average of 2009, 2010 and 2011 2012 677,000 tons SO2 Average of 2010, 2011 and 2012 2013 659,667 tons SO2 Average of 2011, 2012 and 2013 2014 642,333 tons SO2 Average of 2012, 2013 and 2014 2015 625,000 tons SO2 Average of 2013, 2014 and 2015 2016 625,000 tons SO2 Average of 2014, 2015 and 2016 2017 625,000 tons SO2 Average of 2015, 2016 and 2017 2018 480,000 tons SO2 Year 2018 only 2019 forward, 480,000 tons SO2 Annual; no multiyear averaging until replaced by an approved SIP (2) Adjustments for participation by eligible States and Tribes. The amount provided in Table 8-2 below will be subtracted from the milestone in Table 3 for each state and tribe that does not have an Implementation Plan approved by the EPA Administrator as meeting the requirements of 40 CFR 51.309 as of December 31 of the year following the milestone year. The first adjustment to the 2003 milestone will be made no later than March 31, 2005, and will be based on all states and tribes that do not have a federally-approved Implementation Plan as of December 31, 2004. Chapter 8 – SO2 Milestones/Backstop - 41 - Arizona Regional Haze SIP Table 8-2a. (Years 2003-2010) Amounts of SO2 Tons To Be Subtracted from the Base Milestones for States and Tribes That Do Not Have an Approved Implementation Plan under 40 CFR 51.309* State or Tribe 2003 2004 2005 2006 2007 2008 2009 2010 1. Arizona 117,372 117,372 117,372 117,372 117,372 117,941 118,511 119,080 2. California 37,343 37,343 37,343 37,343 37,343 36,363 35,382 34,402 3. Colorado 98,897 98,897 98,897 98,897 98,897 98,443 97,991 97,537 4. Idaho 18,016 18,016 18,016 18,016 18,016 17,482 16,948 16,414 5. Nevada 20,187 20,187 20,187 20,187 20,187 20,282 20,379 20,474 6. New Mexico 84,624 84,624 84,624 84,624 84,624 84,143 83,663 83,182 7. Oregon 26,268 26,268 26,268 26,268 26,268 26,284 26,300 26,316 8. Arizona 42,782 42,782 42,782 42,782 42,782 42,795 42,806 42,819 9. Wyoming 155,858 155,858 155,858 155,858 155,858 155,851 155,843 155,836 10. Navajo Nation 53,147 53,147 53,147 53,147 53,147 53,240 53,334 53,427 11. Shoshone4,994 4,994 4,994 4,994 4,994 4,994 4,994 4,994 Bannock Tribe of the Fort Hall Reservation 12. Ute Indian 1,129 1,129 1,129 1,129 1,129 1,129 1,129 1,129 Tribe of the Uintah and Ouray Reservation 13. Wind River 1,384 1,384 1,384 1,384 1,384 1,384 1,384 1,384 Reservation *These numbers differ from Annex opt-in/-out tables in that the smelter set-aside is excluded and the new source set-aside is included. Table 8-2b. (Years 2011-2018) Amounts of SO2 tons to be Subtracted from the Base Milestones for States and Tribes that do not have an Approved Implementation Plan under 40 CFR 51.309* State or Tribe 1. Arizona 2. California 3. Colorado 4. Idaho 5. Nevada 6. New Mexico 7. Oregon 8. Utah 9. Wyoming 10. Navajo Nation 11. Shoshone-Bannock Tribe of the Fort Hall Reservation 12. Ute Indian Tribe of the Uintah and Ouray Reservation 13. Wind River Reservation 2011 119,080 34,402 97,537 16,414 20,474 83,182 26,316 42,819 155,836 53,427 4,994 2012 119,080 34,402 97,537 16,414 20,474 83,182 26,316 42,819 155,836 53,427 4,994 2013 116,053 33,265 94,456 15,805 20,466 81,682 24,796 41,692 151,232 52,707 4,994 2014 113,025 32,128 91,375 15,197 20,457 80,182 23,277 40,563 146,629 51,986 4,994 2015 109,998 30,991 88,294 14,588 20,449 78,682 21,757 39,436 142,025 51,266 4,994 2016 109,998 30,991 88,294 14,588 20,449 78,682 21,757 39,436 142,025 51,266 4,994 2017 109,998 30,991 88,294 14,588 20,449 78,682 21,757 39,436 142,025 51,266 4,994 2018 82,302 27,491 57,675 13,227 20,232 70,000 8,281 30,746 97,758 44,772 4,994 1,135 1,135 1,135 1,135 1,135 1,135 1,135 1,135 1,384 1,384 1,384 1,384 1,384 1,384 1,384 1,384 *These numbers differ from Annex opt-in/-out tables in that the smelter set-aside is excluded and the new source set-aside is included. (3) Adjustment for Future Operation of Copper Smelters in Arizona and New Mexico. If either the BHP San Manuel smelter in Arizona or the Phelps Dodge Hidalgo smelter in New Mexico resumes Chapter 8 – SO2 Milestones/Backstop - 42 - Arizona Regional Haze SIP operation, the milestones will be increased as described below. The adjustment will occur only if the respective state has a State Implementation Plan approved by the EPA Administrator under 40 CFR 51.309. Once the adjustments have been made, the milestones will not be changed due to future suspensions or changes in plant operations, except as provided below. If Arizona or New Mexico elect not to submit a SIP under 40 CFR 51.309, the emissions for the smelters in the state opting out will be subtracted from the smelter set-aside. (a) If one or both smelters resume operations under their existing permits, the milestone will be adjusted upward for each smelter respectively by the following amounts: 1. Phelps Dodge Corporation, Hidalgo Smelter: 22,000 tons SO2 2. BHP, San Manuel Smelter: 16,000 tons SO2 3. For the 2013 through 2018 milestones, the maximum increase will be 30,000 tons SO2. (b) If Arizona or New Mexico determines that either smelter will resume operation by operating only a portion of the plant, the milestone adjustment in (a) will be reduced by a percentage to reflect current conditions. If the smelter resumes normal operations at a later date, the full adjustment described in (a) will be applied. (c) If one or both smelters resume operations after going through new source review, the milestone adjustment will be based on the new permitted level for the source, but in no instance may the adjustment to the milestones exceed 22,000 tons SO2 per year for the Hidalgo Smelter or 16,000 tons SO2 per year for the San Manuel Smelter. (d) If one or both smelters do not resume operation, the State of Arizona will determine, based on the calculation procedures in section 8.1.3(4) of this plan, the amount of source-specific set aside that will be added to the milestone to account for capacity expansion at the remaining smelters. This set-aside will only be available for use if sulfur input and emissions from the copper smelters are above the baseline level listed in Table 8-3 in any particular year as a result of increased capacity. The increase to the milestone will be based on a smelter’s proportional increase above its baseline sulfur input. The set-aside will be recalculated every year to reflect actual operations of the remaining copper smelters. The set-aside may not be traded under the backstop trading program. Table 8-3. Preliminary Smelter-Specific Set Aside Company/Smelter BHP San Manuel Asarco Hayden Phelps Dodge Chino Phelps Dodge Hidalgo Phelps Dodge Miami Kennecott Copper Corporation, Smelter and Refinery TOTAL Baseline Sulfur Input 417,200 tons 235,000 tons 212,800 tons 256,800 tons 208,700 tons Baseline Allocation 16,000 tons SO2 23,000 tons SO2 16,000 tons SO2 22,000 tons SO2 8,000 tons SO2 Smelter-specific Set-aside 1,500 tons SO2 3,000 tons SO2 3,000 tons SO2 4,000 tons SO2 2.000 tons SO2 340,269 tons 1,000 tons SO2 100 tons SO2 1,670,769 tons 86,000 tons SO2 13,600 tons SO2 (4) Other Milestone Adjustments. (a) All other milestone adjustments will require a SIP revision. Section 8.1.3(3) of this plan outlines adjustments to be made to the emissions inventory to ensure a consistent comparison to Chapter 8 – SO2 Milestones/Backstop - 43 - Arizona Regional Haze SIP the milestones. These adjustments will be incorporated into the milestones every five years as part of the periodic SIP revisions required by 40 CFR 51.309(d)(10). Adjustments to the milestones shall be tracked in the annual emissions report in section 8.1.3(3) of this plan. (b) Within ninety days of the periodic SIP revision incorporating adjustments based on section 8.1.3(3) of this plan, the State of Arizona shall provide notice to sources whose records were used to calculate the adjustments, including the date of the SIP revision reflecting the milestone adjustment to sources whose records were used as the basis for the milestone adjustment and a statement that the source needs to retain the record for at least five years from the date of the SIP revision, or ten years from the date of establishing the record, whichever is longer. 8.1.2. Regional Program Administration (1) Pre-trigger tracking of regional SO2 emissions. The State of Arizona will work cooperatively with the states and tribes that are participating in the SO2 Milestones and Backstop Trading Program to ensure that an emission tracking system for the regional SO2 inventory is developed and maintained. The State of Arizona is responsible for all regional program administration functions as described in this plan. The State of Arizona will perform these functions using the Western Regional Air Partnership (WRAP) as the State of Arizona’s agent. The WRAP compiled the SO2 emission inventories that were used during the development of the Annex, and the WRAP continues to refine and improve the overall tracking system for the regional haze. The WRAP will maintain the outlined pre-trigger emissions tracking functions in the foreseeable future. If the WRAP is no longer able to fulfill this function, then the State of Arizona will ensure that other arrangements are made, either through a different regional organization or through a contractor, to maintain the SO2 tracking system that is described in this plan. The WRAP has no authority to make regulatory determinations. The WRAP has limited authority under this plan to perform tracking and accounting functions, prepare reports, and perform other administrative functions as directed by the State of Arizona. The State of Arizona will work expeditiously to correct any problems if the WRAP fails to perform any of the functions described in this plan in a timely manner. (2) Designation of the Tracking System Administrator. If the backstop trading program is triggered due to an exceedance of the SO2 milestones as outlined in section 8.1.3 of this plan, the State of Arizona will work cooperatively with the other participating states and tribes to designate one Tracking System Administrator (TSA). The TSA will be designated as expeditiously as possible, but no later than six months after the program trigger date. In addition, before the TSA is designated, the State of Arizona will enter into a binding contract with the TSA that will require the TSA to perform all TSA functions described in this plan. The State of Arizona has sufficient authority under State contract law to ensure that the functions in this plan are carried out by the TSA. (3) Information Provided by other States and Tribes. The State of Arizona will accept the emission inventory and permitting information provided by the other participating states and tribes in order to determine the milestone value and program trigger if such other states and tribes have provided proper documentation and followed the public notification process in their federally approved implementation plans. 8.1.3. Determination of Program Trigger (1) Until the program has been triggered and source compliance is required, the State of Arizona will submit an annual emissions report to the WRAP and all participating states and tribes by September 30 of each year. The report will document actual sulfur dioxide emissions during the previous calendar year for all sources subject to the Sulfur Dioxide Milestone Inventory requirements. The first report for calendar year 2003 will be submitted by September 30, 2004. The State of Arizona will prepare the supporting documentation that is included with the annual emissions report as noted in (2) and (3) below. Chapter 8 – SO2 Milestones/Backstop - 44 - Arizona Regional Haze SIP (2) The annual emissions report for Arizona will include a source emissions change report that contains the following information: (a) identification of any new sources that were not contained in the previous calendar year’s emissions report, and an explanation of why the source is now included in the program; (b) identification of any sources that were included in the previous year’s report and are no longer included in the program, and an explanation of why this change has occurred; and (c) an explanation for increases or decreases of emissions at any applicable source or more than twenty percent from the previous year. (3) The annual emissions report for Arizona will include the proposed emission adjustment as described in (a) through (c) to ensure a consistent comparison to the milestones. (a) Changes in flow rate measurement methods. Actual emission inventories for utilities that use EPA’s Reference Method 2F, 2G, or 2H to measure stack flow rate will be adjusted to be comparable with the flow rate assumptions that were used in 1999, the base year inventory for the Annex. The adjustment may be calculated using any of the following three methods, and emissions for the year 2018 will not be adjusted. (i) Directly determine the difference in flow rate through a side-by-side comparison of data collected with the new and old flow reference methods during a relative accuracy test audit (RATA) test. (ii) Compare the annual average heat rate using Acid Rain heat input data (MMBtu) and total generation (MWHrs) as reported to the Federal Energy Information Administration. Under this approach, the flow adjustment factor will be calculated using the following ratio: Heat input/MW for first full year of data using new flow rate method / Heat input/MW for last full year of data using old flow rate method. (iii) Compare the standard CFM per MW before and after the new flow reference method based on CEMs data submitted in the Acid Rain Program, as follows: SCF/Unit of Generation for first full year of data using new flow rate method SCF/Unit of Generation for last full year of data using old flow rate method. (b) Changes in emission monitoring or calculation methods. Actual emission inventories for sources that change the method of monitoring or calculating their emissions will be adjusted to be comparable to the emission monitoring or calculation method that was used in the base year inventory for the Annex (1999 for utilities and 1998 for all other sources). (c) Changes due to enforcement actions. (i) Adjustments due to enforcement actions arising from settlements. Adjustments to the milestones shall be made, as specified in section 8.1.3(3) and (4), if: Chapter 8 – SO2 Milestones/Backstop - 45 - Arizona Regional Haze SIP (A) an agreement to settle an action, arising from allegations of a failure of an owner or operator of an emissions unit at a source in the program to comply with applicable regulations which were in effect during the base year, is reached between the parties to the action; (B) the alleged failure to comply with applicable regulations affects the assumptions that were used in calculating the source’s base year and forecasted sulfur dioxide emissions; and (C) the settlement includes or recommends an adjustment to the milestones. (ii) Adjustments due to enforcement actions arising from administrative or judicial orders. Adjustments to the milestones shall be made as directed by any final administrative or judicial order, as specified in section 8.1.3(3) and (4). Where the final administrative or judicial order does not include a reforecast of the source's baseline, the State of Arizona shall evaluate whether a reforecast of the source's baseline emissions is appropriate. (iii) Adjustments method and effective dates. Based on section 8.1.3(3) and (4), the milestone must be decreased by an appropriate amount based on a reforecast of the source’s decreased sulfur dioxide emissions. The adjustments do not become effective until after the source has reduced its sulfur dioxide emissions as required in the settlement agreement, or administrative or judicial order. All adjustments based upon enforcement actions must be made in the form of an SIP revision that complies with the procedural requirements of 40 CFR 51.102 and 51.103. (iv) Documentation of adjustments for enforcement actions. In the periodic plan revision required under 40 CFR 51.309(d)(10), the State of Arizona shall include the following documentation of any adjustment due to an enforcement action: (A) identification of each source under the State of Arizona 's jurisdiction that has reduced sulfur dioxide emissions pursuant to a settlement agreement or an administrative or judicial order; (B) for each source identified, a statement indicating whether the milestones were adjusted in response to the enforcement action; (C) discussion of the rationale for the State of Arizona 's decision to adjust or not to adjust the milestones; and (D) if SO2 emissions reductions over and above those reductions needed for compliance with the applicable regulations were part of an agreement to settle an action, a statement indicating whether such reductions resulted in any adjustment to the milestones or allowance allocations, and a discussion of the rationale for the State of Arizona 's decision on any such adjustment. (4) The annual sulfur dioxide milestone and emissions report for Arizona will document any adjustments that should be made to the milestone for the previous year as follows. Chapter 8 – SO2 Milestones/Backstop - 46 - Arizona Regional Haze SIP (a) The State of Arizona will document the submittal date of this Implementation Plan to implement the regional WEB Trading Program, and the approval date by the EPA Administrator, if applicable. (b) If actual emissions and sulfur input are greater than the baseline level in Table 3, and either the BHP San Manuel smelter in Arizona or the Phelps Dodge smelter in New Mexico have not resumed operation, the State of Arizona will determine the milestone adjustment for all copper smelters in Arizona by determining the increase in the milestone based on the proportional increase in sulfur input over baseline levels. For each smelter, the adjustment will not exceed the smelter-specific set-aside listed in Table 8-3. (c) Arizona shall determine the status of BHP San Manuel copper smelter during the previous year. If the smelter resumed operation during the milestone year, the report shall include: (i) the date the smelter resumed operation; (ii) a determination by Arizona that either, (A) the smelter resumed production consistent with past operations, (B) the smelter was required to go through new source review, in which case Arizona shall include the new SO2 permitted limit for BHP San Manuel in the report, or (C) the smelter resumed operations in a substantially different manner such that emissions will be less than for past operations, in which case Arizona shall determine expected emissions from the operations. (d) a proposed adjustment to the sulfur dioxide milestone to account for the operation of the BHP San Manuel smelter. (e) Comparison of actual emissions from all smelters in [state] to the baseline emissions level for that smelter listed in Table 3. If actual emissions and sulfur input are greater than the baseline levels in Table 3, and either the BHP San Manuel smelter in Arizona or the Phelps Dodge smelter in New Mexico have not resumed operation, [state] shall determine the milestone adjustment by determining the increase in the milestone based on the proportional increase in sulfur input over baseline levels. For each smelter, the adjustment shall not exceed the smelter-specific set-aside listed in Table 3. The following example is for illustrative purposes: Asarco’s baseline SO2 emissions are 23,000 tons Asarco’s baseline sulfur input is 235,000 tons For example, in 2005: Asarco’s S02 emissions were 25,000 tons Asarco’s sulfur input was 250,000 tons. Because Asarco’s 2005 emissions and sulfur input exceeded it’s baseline emissions and sulfur input: need to calculate the percent increase in sulfur input in the year 2005 = [(2005 sulfur input) - (baseline sulfur input)] ÷ [baseline sulfur input] = [250,000 - 235,000] ÷ [235,000] Chapter 8 – SO2 Milestones/Backstop - 47 - Arizona Regional Haze SIP = [15,000] ÷ [235,000] = 0.0638 = 6.38% The adjustment to the milestone based on Asarco’s increase in production is to increase the milestone by 1,564 tons of SO2 (which is ok, since it is less than the maximum of 3,000 tons in Table 3 for Asarco). adjustment = 6.38% x baseline emissions adjustment = 6.38% x 23,000 (5) Compilation of Reports. (a) The WRAP will compile the annual emissions reports submitted by all participating states and tribes into a draft regional emission report for sulfur dioxide. The WRAP will follow additional quality assurance procedures developed by states and tribes to identify possible errors in the emissions data, including screening for missing or added sources, name changes, and significant changes in reported emissions. Any questions or anomalies regarding Arizona’s report will be resolved by the State of Arizona for resolution prior to the submission of the draft regional emission report. (b) By December 31 of each year, the WRAP will submit the draft regional emission and milestone report to the State of Arizona and all participating states and tribes and will post the report on the WRAP’s web page. The report will include the following information for all states and tribes that have an implementation plan that has been approved by the EPA Administrator under 40 CFR 51.309(h): (i) Actual regional sulfur dioxide emissions in tons per year, (ii) Adjustments to account for: (A) changes in flow rate measurement methods, (B) changes in emission monitoring or calculation methods, and (C) enforcement actions or settlement agreements as a result of enforcement actions; (iii) average adjusted emissions for the last three years for comparison to the regional milestone, if adjustments were made. (iv) regional milestone adjustments to account for participation by eligible states and tribes and the future operation of smelters in Arizona and New Mexico. A separate report that includes additional states and tribes that have submitted implementation plans that are still under review by the Environmental Protection Agency will also be prepared for information purposes. (6) The State of Arizona will evaluate the draft regional emissions report and will propose a draft determination that the sulfur dioxide milestone has either been met in the region, or has been exceeded. In the event that the TSA has not submitted a draft regional emissions and milestone report to the State of Arizona by the December 31 deadline for any year, the State of Arizona will prepare the report for that year based upon the annual emissions reports submitted by all participating states and tribes to the WRAP for that year. The State of Arizona will modify the data in these annual emissions reports, or use data where such report(s) have not been submitted, based upon direction received from the Environmental Protection Agency. (7) The State of Arizona will advertise availability of the draft regional emissions report and will notify the public of the draft determination by publishing a notice in newspapers of general circulation Chapter 8 – SO2 Milestones/Backstop - 48 - Arizona Regional Haze SIP throughout Arizona. A 30-day public comment period will be established, and a public hearing will be held during the public comment period. The State of Arizona will also submit the draft determination to EPA for review and comment concurrently. (8) The State of Arizona will consider any comments received during the comment period, and will submit a copy of all comments to the WRAP and to all participating states and tribes along with a response that addresses the comments. (9) The WRAP will compile the comments and responses from all participating states and tribes and prepare a draft final regional emissions report. The report will be submitted to the states and tribes that are participating in the program and, if necessary, the report will propose a common program trigger date. (10) The State of Arizona will review and approve the final regional emissions report. The State of Arizona will then submit this report to the Environmental Protection Agency along with a final determination that the milestone either has been met in the region, or that the milestone has been exceeded and the WEB Trading Program has been triggered in Arizona. This determination will be submitted to the Environmental Protection Agency by the end of March, fifteen months following the milestone year. The first determination will be submitted by March 31, 2005, for the 2003 milestone. If the milestone has been exceeded, the common trigger date proposed in the regional report will become the program trigger date for purposes of implementing the WEB Trading Program. In the event that the program trigger date must be established by the State of Arizona in the absence of a regional emissions and milestone report prepared by the WRAP, the program trigger date will be March 31 of the applicable year. (11) The State of Arizona will publish a notice of the final determination in newspapers of general circulation throughout the state of Arizona. This notice will include the milestone and the final annual regional SO2 emissions for that year. If the milestone has been exceeded, the notice will specify the program trigger date and the first year that WEB sources must be in compliance with the WEB Trading Program provisions. 8.1.4. Year 2013 Assessment (1) Initial Assessment in 2013 Periodic SIP Review. (a) The State of Arizona will work cooperatively through the WRAP with other participating states and tribes to develop a projected emission inventory for SO2 through the year 2018, using the 2010 regional inventory as a baseline. This projected inventory will be included in the 2010 annual emission and milestone report that will be completed in March 2012 as outlined in section 8.1.3 of this plan. (b) The State of Arizona will evaluate the projected inventory, and based upon this information will make an assessment of the likelihood of meeting the regional milestone for the year 2018. The State of Arizona will include this assessment as part of Arizona’s progress report that must be submitted by December 31, 2013, as required by 40 CFR 51.309(d)(10). (2) Regional Emissions Report for 2012. (a) The State of Arizona will prepare an SO2 emission report for the year 2012 by September 30, 2013, as described in section 8.1.3(1) of this plan. The State of Arizona will include a list of all known or anticipated sources in Arizona that are anticipated to affect total SO2 emissions in 2018. Chapter 8 – SO2 Milestones/Backstop - 49 - Arizona Regional Haze SIP This may include permitted sources, projects that are still in the planning stage, or projections from the affected sources of anticipated emissions in 2018. The status of these projects will be described to provide a better understanding of the degree of certainty that individual projects will be completed by 2018. (b) The WRAP will compile the information from all participating states and tribes, prepare draft SO2 inventory projections for the year 2018, and estimate the effect of known future sources on SO2 emissions. Projected 2018 emissions will be compared to the 2018 milestone. This information will be included in the draft regional emissions report for 2012 that will be submitted to the State of Arizona by December 31, 2013, as outlined in section 8.1.3(5) of this plan. (3) Consensus Decision. The State of Arizona commits to meet with the participating states and tribes in March 2014 to discuss any comments received on the 2018 emission projections in the draft report. The participating states and tribes will decide, through a consensus process, whether it is necessary to trigger the WEB trading program early in order to meet the SO2 emission reduction goals in 2018. (4) Early Trigger: Timing. If the participating states and tribes unanimously decide in the March 2014 meeting that an early trigger of the backstop trading program is necessary, the State of Arizona will trigger the WEB Trading Program and the timing of the program elements will be adjusted as follows to ensure that the WEB Trading Program is in place in 2018. (a) The date of the consensus decision by the participating states and tribes to voluntarily trigger the WEB trading program will become the program trigger date. (b) Allowances for 2018 will be distributed to WEB sources by January 1, 2015. (c) The first control period will be the year 2018. WEB sources will need to demonstrate at the end of the first control period that they have enough allowances to cover their 2018 SO2 emissions. (5) Public Notification. The State of Arizona will publish notice of the decision in newspapers of general circulation in Arizona. If applicable, the notice will include a statement that the WEB Trading Program is in effect and will specify the program trigger date. 8.1.5. Special Penalty Provisions for the 2018 Milestone If the WEB Trading Program is triggered as outlined in the section 8.1 of this plan, and the first control period will not occur until after the year 2018, a special penalty shall be assessed for the exceedance of the 2018 milestone. (1) The State of Arizona will allocate allowances to all WEB sources using the methods established in the 2013 SIP revision described in section 8.4 of this plan. WEB sources will have the option to buy and sell allowances during a two-month allowance transfer period. (2) At the end of this two-month allowance transfer period, compliance with the allowance limitation will be determined. Penalties will be assessed for SO2 emissions that are greater than the allowance limitation for each WEB source. However, SO2 emissions in the year 2018 for each WEB source will be determined in accordance with the Sulfur Dioxide Milestone Inventory requirements. (3) The 2018 special penalty provision shall continue to be applied each year after 2018 until the 2018 milestones have been achieved. Chapter 8 – SO2 Milestones/Backstop - 50 - Arizona Regional Haze SIP 8.2. 8.2.1. Pre-Trigger Emissions Tracking Requirements SO2 Emission Inventory 40 CFR 51.309 sets forth emissions inventory requirements for tracking compliance with the SO2 milestones. Arizona’s Article 3 (Permits and Permit Requirements) and Article 7 (Existing Stationary Source Performance Standards) in addition to the requirements of the state-specific WEB Trading Program rule, contain the inventory requirements to satisfy the needs of this program. (1) Applicability. The sulfur dioxide milestone inventory requirements of R18-2-306 require all stationary sources with actual emissions of 100 tons per year or more of SO2 in the year 2000, or in any subsequent year, to submit an annual inventory of SO2 emissions, beginning with the 2003 emission inventory. A source that meets these criteria and then emits less than 100 tons per year in a later year must continue to submit an SO2 inventory for tracking compliance with the regional SO2 milestones until 2018 or until the WEB Trading Program has been fully implemented and emission tracking is occurring under the state-specific rule, whichever is earlier. (2) Enforceable requirements for WEB sources as found in the state-specific rule. (a) Each source shall submit an annual inventory of SO2 emissions and smelters also must submit an annual report of sulfur input in tons per year. (b) Each source shall use appropriate emission factors and estimating techniques and document the emissions monitoring or estimation methodology used. (c) Each source shall include emissions from start up, shut down, and upset conditions in the annual total inventory. (d) Each source subject to the federal acid rain program shall use methods from 40 CFR Part 75 to report emissions from all sources. (e) Each source shall include the rate and period of emissions, the specific installation that is the source of the air pollution, composition of air contaminant, type and efficiency of the air pollution control equipment and other information necessary to quantify operation and emissions, and to evaluate pollution control. (f) Each source shall retain records for a minimum of 10 years from the date of their creation, or if the record was the basis for an adjustment to a milestone, 5 years from the date of a SIP revision, whichever is longer. (3) The State of Arizona will quality-assure the submitted inventory data as outlined in the Inventory Preparation Plan. The State of Arizona will screen the inventories to identify changes in emission measurement techniques that would require an inventory and milestone adjustment as outlined in section 8.1 of this plan. (4) The State of Arizona will retain historical emission inventory records for non-utilities from 1996 and 1998 that may affect milestone calculations under section 8.1 of this plan and allocation decisions under section 8.1 of this plan until the year 2018 to ensure that changes in emissions monitoring techniques can be tracked. Chapter 8 – SO2 Milestones/Backstop - 51 - Arizona Regional Haze SIP 8.2.2. Development of Emission Tracking System The State of Arizona will work cooperatively with the states and tribes that are participating in the WEB Trading Program to ensure that an emission tracking system for the regional SO2 inventory is developed and maintained. 8.2.3. Periodic Audit of Pre-Trigger Emission Tracking Database (1) During the pre-trigger phase when the State of Arizona is tracking compliance with the regional SO2 milestones, the State of Arizona will work cooperatively with the participating states and tribes to ensure that an independent audit of the tracking database is conducted to make sure that the WRAP is accurately compiling the regional emissions report. (a) The first audit will occur during the year 2006 and will review data collected during the first two years of the program. (b) Subsequent audits will occur in 2011, which will cover emissions years 2005-2009, and 2016, which will cover emissions years 2010-2014. (2) The primary focus of the audit will be the process that is used to compile the regional inventory from the data provided by each state and tribe, and the tracking of accumulated changes during the period between SIP revisions. The audit will also review the accuracy and integrity of the regional reports that are used to determine compliance with the milestones. The audit will not be a full review of Arizona’s process for compiling and reporting SO2 emissions, but will include a broad review of Arizona’s inventory management and quality assurance systems, including the presence and exercise of systems to assure data quality and integrity. (3) The audit will discuss the uncertainty of emissions calculations, and whether this uncertainty is likely to affect the annual determination of whether the milestone is exceeded. It will identify any recommended changes to emissions monitoring or calculation methods or data quality assurance systems. It will also review and recommend any changes to improve the administrative process of collecting the annual emissions data at the state and tribal level, compiling a regional emission inventory, and making the annual determination of whether the WEB Trading Program has been triggered. (4) Changes to the WEB trading program, including any changes to the milestones due to the results of these periodic audits, will be submitted to EPA as a SIP revision as part of the five-year SIP review required by 40 CFR 51.309(d)(10). (5) The State of Arizona will advertise the availability of the draft audit report by publishing a notice in newspapers of general circulation in Arizona. A 30-day public comment period will be established, and a hearing will be held during the public comment period. The State of Arizona will respond to comments and provide notice of the availability of the final audit report. The State of Arizona will submit the final audit report to the EPA regional office. 8.3. 8.3.1. WEB Trading Program Requirements Initial Allocation of SO2 Allowances (1) Draft Allocation Report. Within six months of the program trigger date, as outlined in section 8.1.3(11) of this plan, the State of Arizona will submit a draft allocation report to all participating states and tribes and to the TSA. This report will contain the following information: Chapter 8 – SO2 Milestones/Backstop - 52 - Arizona Regional Haze SIP (a) A list of all WEB sources in Arizona as defined in the state-specific rule. Those sources are grouped into two categories: (i) Category 1: WEB sources that commenced operation prior to January 1, 2003. These sources will receive a floor allocation and will be eligible for the reducible portion of the allocation. (ii) Category 2: WEB sources that commenced operation on January 1, 2003 or a later date. These sources will receive a floor allocation, but will not be eligible for the reducible allocation. The floor allocation for Category 2 sources will be deducted from the new source set-aside. WEB sources that have received a retired source exemption will be included in the allocation process in the same manner as WEB sources that are currently operating. However, sources that were permanently shut down prior to the program trigger date are not considered WEB sources and would therefore not be included in the allocation process. (b) The floor allocation for all WEB sources in Arizona. (i) For non-utility category 1 WEB sources, the floor allocation shall be as established in the E.H. Pechan Report, Market Trading Forum Non-Utility Sector Allocation Final Report from the Allocations Working Group (November 2002). The Pechan Report can be found in Appendix A8a. If any additional category 1 sources are identified, the State of Arizona shall calculate a floor allocation using the methodology outlined in the E.H. Pechan Report. (ii) For utility category 1 WEB sources, the floor will be calculated by first assigning a “clean unit” emission rate to each unit. The clean unit emission rate will then be multiplied by an annual heat input (MMBtu) that represents a realistic upper bound for the unit. [Note: The floor level approach described above is designed to address equity issues regarding the allocation process for utilities. The State of Arizona is participating in ongoing discussions with the other participating states, tribes and regional stakeholders to ensure that all equity issues have been addressed. ] Principles • Each unit will have enough allowances to operate as a clean source and at an operating rate (capacity factor) that is a realistic upper bound for the unit. There will not be significant winners and losers in this process. The focus is on a fair approach that is applied equally to all sources rather than on state and tribal budgets. The allocation process will use data that reflect current conditions, including current monitoring methodologies. • • • Equity Issues • Sources that are currently burning very low sulfur coal may see changes in their supply in the future. Historic actual emissions may not reflect future operations. Chapter 8 – SO2 Milestones/Backstop - 53 - Arizona Regional Haze SIP • Sources that are currently operating at a low utilization may not reach full capacity in the future. Assumptions about growth that are realistic on the regional level may provide a windfall to some sources, and not provide adequate allowances for other sources. • There are some utility units in the region that are not BART-eligible and are operating at a low level of control for SO2. The relative responsibility of BART-eligible vs. nonBART-eligible is a consideration in the process. • Sources that are operating at a high level of control are already bearing the cost of control and this affects their ability to compete in the market. • Sources that have no SO2 controls are facing a large expense that could affect their ability to continue to operate. • Emission rate disparities exist throughout the region. (iii) For Category 2 WEB sources the floor allocation shall be the lower of the permitted SO2 annual emissions for the WEB source, or SO2 annual emissions calculated based on a level of control equivalent to BACT and assuming 100% utilization of the WEB source. (c) A list of certified early reductions, expressed as tons of SO2. Early reductions will be calculated and certified as follows: (i) Any WEB source that installs control technology and accepts new permit emissions limits that are, for a non-utility source, below its floor as established in this section, or, for a utility source, below BACT, may apply for an early reduction credit. The application must show that the floor was calculated in a manner that is consistent with the monitoring requirements and the new permit must contain monitoring requirements that are consistent with the state-specific rule. The credits accumulate from the time the new controls come on line until the program trigger date and will be allocated to the WEB source over a 10 year period. The use of early reduction credits in any control period is limited to no more than five percent, system-wide, of the existing available allowances, as provided in section 8.1.3(2)(f) of this plan. (ii) The State of Arizona will review the application and will certify early reductions for each full year between 2003 and the program trigger year that meet the requirements of the state-specific rule and this plan. (iii) A source’s certified early reductions for all years will be added together to obtain the total certified early reductions for that source. (d) A list of all renewable energy plants and sources in Arizona that began operation after October 1, 2000, and the MW of installed nameplate capacity for each of these resources. Renewable energy credits will be granted at a rate of 2.5 tons per MW, and will accumulate from the beginning of the facility’s operation. Their use in any control period is limited to no more than five percent, system-wide, of the existing available allowances, as provided in section 8.1.3(2)(g) of this plan. Chapter 8 – SO2 Milestones/Backstop - 54 - Arizona Regional Haze SIP (e) Historical SO2 emissions data for all Category 1 sources for the purposes of calculating the reducible allocation. (i) For utilities, the average of the years 2000 – 2002. Another time period may be used for individual emission units, if needed, to be representative of normal operating conditions. (ii) For non-utilities, the average of annual SO2 emissions for the years 1996 and 1998. (f) Changes due to enforcement actions or settlement agreements as a result of enforcement actions. The adjustment shall be determined in accordance with section 8.1.3 of this SIP. The difference between the WEB source’s allocations prior to enforcement and after the enforcement action shall be removed from the allocation pool. (2) Compiled Allocation Report. The TSA will compile the information provided by all participating states and tribes into a draft regional allocation report, and will submit this draft regional report to the State of Arizona and all participating states and tribes for review and comment thirty days after receiving the preliminary allocation reports. The draft regional allocation report will include a proposed budget for each state and tribe and the proposed allocation for each WEB source in Arizona. The following methodology for calculating the proposed regional allocation for utilities and nonutilities is based on the assumption that the states of Arizona, Oregon, New Mexico, Utah and Wyoming are the only participating states in the WEB Trading Program. These 5 states are actively pursuing a SIP under section 309 of the Regional Haze Rule and it is unlikely that any other states will be able to develop a SIP under section 309 by the deadline of December 31, 2003. The State of Arizona will work closely with the other four states that are developing 309 SIPs to ensure that the regional allocation is distributed consistently and fairly and to address any change in status that may affect this process. Tribal nations may participate in the program at a later date under the provisions of the Tribal Authority Rule. There are currently four category 1 sources operating on tribal lands under the jurisdiction of three tribal nations. The following methodology will remain unchanged if any of these tribal nations opt in to the program at a later date because the allocation for any of the four existing tribal sources will be covered by the opt-in adjustment for the tribe, and the allocation for any new sources will be covered by the regional newsource set-aside. (a) Table 8-4 shows the calculation of the available allocation for existing sources. The base milestone for the 5-state region (i.e., those states currently committed to a SIP under Section 309; namely: Arizona, New Mexico, Oregon, Utah, and Wyoming) calculated in accordance with section 8.1 of this plan is the starting point. The base milestone does not include the smelter setaside. 20,000 tons of SO2 is then subtracted for a tribal set-aside. Chapter 8 – SO2 Milestones/Backstop - 55 - Arizona Regional Haze SIP Table 8-4. Utility/Non-utility Split. 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Base Milestone from Table 2 446,904 446,904 446,904 446,904 446,904 447,014 447,123 447,333 447,333 447,333 435,455 423,676 411,898 411,898 411,898 309,087 Tribal SetAside 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 New Source Set-aside 6,390 6,390 6,390 6,390 6,390 12,902 12,902 12,902 12,902 12,902 19,370 19,370 19,370 19,370 19,370 19,370 Remaining Allocation Utility Portion 420,514 420,514 420,514 420,514 420,514 414,112 414,221 414,331 414,331 414,331 396,085 384,306 372,528 372,528 372,528 269,717 Non-utility portion 275,027 275,027 275,027 275,027 275,027 275,636 275,708 275,782 275,782 275,782 259,171 251,463 243,757 243,757 243,757 155,367 145,488 145,488 145,488 145,488 145,488 138,476 138,513 138,549 138,549 138,549 136,914 132,843 128,771 128,771 128,771 114,350 (b) Table 8-5 shows the new source set-aside for the 5-state region. (i) The new source set-aside is calculated by subtracting the new source set-aside adjustment listed in Table 8-5 for all states and tribes that do not have a federally approved Implementation Plan for the WEB trading program under 40 CFR 51.309 as of the program trigger date from the maximum possible set-aside for each of the first five years of the trading program. Table 8-5. New Source Set-Aside Adjustment 2003 - 2007 Maximum Possible SetAside 9,000 Chapter 8 – SO2 Milestones/Backstop 2013 - 2018 18,000 27,000 Adjustment (tons/yr SO2) State or Tribe 1. Arizona 2. California 3. Colorado 4. Idaho 5. Nevada 6. New Mexico 7. Oregon 8. Arizona 9. Wyoming 10. Tribes 2008 - 2012 1,757 559 1,480 270 302 1,267 393 640 2,333 No adjustment needed - 56 - 3,596 1,039 2,945 496 618 2,512 795 1,293 4,706 No adjustment needed 5,437 1,532 4,364 721 1,011 3,889 1,075 1,949 7,020 No adjustment needed Arizona Regional Haze SIP (ii) Subtract the floor allocation for all WEB sources in the region that were identified as Category 2 from the new source set-aside for the 5-state region to determine the available allocation for new sources that begin operation after the program trigger date. The allocation process for these new sources is described in section 8.3.3 of this plan. Example calculation of the new source set-aside. The example uses the following assumptions: (i) Emissions exceed the milestones based on an average of the years 2003-2005. (ii) The program trigger date is March 31, 2007. (iii) The first 5 years of the program are 2011-2015. (iii) Five states are participating in the program (AZ, NM, OR, UT, WY). (iv) New sources that commenced operation between January 1, 2003 and the program trigger date have a total floor allocation of 6,000. Maximum Possible Set-Aside 5-State Adjustment Floor for Category 2 Sources Remaining New Source Setaside 2011 18,000 - 5,098 -6,000 6,902 2012 18,000 -5,098 -6,000 6,902 2013 27,000 -7,628 -6,000 13,372 2014 27,000 -7,628 -6,000 13,372 2015 27,000 -7,628 -6,000 13,372 (c) The remaining allocation shown in Table 8-5 is available for distribution to category 1 sources. The final two columns in Table 8-5 split this remaining allocation into a utility allocation and a non-utility allocation. Apply any milestone adjustments due to the smelter set-aside as outlined in section 8.1 of this plan to the non-utility allocation listed in Table 8-5. (d) Subtract the floor allocations for all category 1 utility and non-utility sources in the region from the utility allocation or the non-utility allocation. (e) Calculate the early reduction allocation. (i) Divide the number of certified early reduction credits for all WEB sources in the region by ten. (ii) Add the utility allocation for 2018 to the non-utility allocation for 2018 and then multiply this total by 0.05. (iii) If the product of paragraph (i) is no more than the product of paragraph (ii), the product of paragraph (i) is the early reduction allocation, and each source is allocated ten percent of its early reduction credits. (iv) If the product of paragraph (i) is more than the product of paragraph (ii), the early reduction allocation for the region is the product of paragraph (ii). To determine a source’s allocation, divide the product of paragraph (ii) by 0.10 times the total number of early reduction credits and apply that ratio to the early reduction credits claimed by the source. Chapter 8 – SO2 Milestones/Backstop - 57 - Arizona Regional Haze SIP (v) Split the regional early reduction allocation based on the ratio of utility to non-utility allocations in 2018 and subtract the early reduction allocation from the utility and nonutility allocation totals. (vi) The early reduction allocation will be calculated in a similar manner for the second five-year allocation period under this program, and will then be discontinued for any future allocation periods. (g) Calculate the regional renewable energy allocation. (i) Add together the reported MW of installed nameplate capacity for renewable energy facilities reported by the participating states and tribes, and then multiply this number by 2.5. (ii) Add the utility allocation for 2018 to the non-utility allocation for 2018 and then multiply this total by 0.05. (iii) If the product of paragraph (i) is no more than the product of paragraph (ii), the product of paragraph (i) is the renewable energy allocation. (iv) If the product of paragraph (i) is greater than or equal to the product of paragraph (ii), the renewable energy allocation for the region is the product of paragraph (ii). To determine a source’s allocation, divide the product of paragraph (ii) by the total number of renewable energy credits and apply that ratio to the early reduction credits claimed by the source. (v) Split the regional renewable energy allocation based on the ratio of utility to nonutility allocations in 2018 and subtract the renewable energy allocation from the utility and non-utility allocation totals. (h) Any remaining allowances in the utility allocation or the non-utility allocation after subtraction of the early reduction allocation and the renewable energy allocation is considered the reducible allocation and will be assigned to Category 1 sources. (i) For non-utility sources, add together the historic SO2 emissions in accordance with section 8.1.3(1)(e) of this plan for all Category 1 non-utility sources in the region to determine an historic emission total. Determine a percent contribution of SO2 emissions for each WEB source to the historic emission total. Multiply the non-utility reducible allocation calculated in paragraph ((i)) below by the percent contribution for each WEB source to determine a reducible allocation for each WEB source. (ii) For utility sources, the reducible allocation will be distributed to sources that emitted above their floor in the baseline period (2000 through 2002) based on their percentage of total floor emissions for sources emitting above the floor times the number of reducible allowances available for the first five years of the WEB Trading Program. The number of allowances for any source receiving a reducible allocation shall not exceed a recent historic emission rate times a heat input that represents a realistic upper bound for the unit. Chapter 8 – SO2 Milestones/Backstop - 58 - Arizona Regional Haze SIP [Note: The approach for distributing the reducible utility allocation described above is designed to address equity issues regarding the allocation process for utilities. The State of Arizona is participating in ongoing discussions with the other participating states, tribes and regional stakeholders to ensure that all equity issues have been addressed. The principles and equity issues that are under discussion are listed in section 8.1 of this plan.] (i) Add together the floor allocation, early reduction allocation, renewable energy resource allocation, and reducible allocation for each WEB source and each renewable energy source to determine the proposed allocations for the first five years of the WEB Trading Program. (j) Add together the proposed allocations for all of the WEB sources in the jurisdiction of each participating state and tribe to determine a draft SO2 allowance budget for each state and tribe. (3) Public Comment Period. The State of Arizona will publish notice of availability of the draft regional allocation report in newspapers of general circulation throughout Arizona. A 30-day public comment period will be established, and a hearing will be held during the comment period. The State of Arizona will consider the comments, and will revise the draft report as needed. (4) Proposed Changes Submitted to Tracking System Administrator. The State of Arizona will submit proposed changes to the budget and source allocations to the TSA within sixty days of receipt of the draft regional allocation report. (5) Compilation of Changes. The TSA will compile the proposed changes and will submit a final draft regional allocation report to the State of Arizona for approval within 30 days of receipt of the recommended changes. (6) Final Regional Allocation Report. The State of Arizona will review the final regional allocation report and will determine the budget for Arizona and allocations for WEB sources within Arizona in accordance with the provisions of this plan within thirty days of receipt of the final draft allocation report. The State of Arizona will submit the budget and allocations for all WEB sources in Arizona to EPA, and will notify the TSA that the WEB source allocations should be recorded in the allowance tracking system. (7) The State of Arizona will notify all WEB sources within Arizona of the number of allowances that have been recorded in their compliance account. The notice will include a warning to the WEB sources that reported annual sulfur dioxide emissions may change due to the implementation of new monitoring methods. Allocations for the first five years of the program will not be adjusted to account for changes due to the new monitoring method. However, allocations during the next five-year distribution will be adjusted as needed to account for paper changes in emissions due to changes in monitoring methodology. 8.3.2. Distribution of Allowances for Future Control Periods. By December 1 of the year five years after the initial allocation, the State of Arizona will follow the process outlined in section 8.1 of this plan to distribute allowances for the next five-year period. This process will continue every five years until allowances have been allocated through the year 2018. Chapter 8 – SO2 Milestones/Backstop - 59 - Arizona Regional Haze SIP 8.3.3. Distribution of the New Source Allocation (1) The new source set-aside will be available for two categories of sources. (a) A new WEB source is eligible to receive an annual allocation equal to the annual sulfur dioxide limit in the source’s approval order, beginning with the first full year of operation and in accordance with the provisions of the state-specific rule. (b) An existing WEB source that has increased production capacity by first obtaining a new approval order is eligible to receive an allocation from the new source set-aside equal to: (i) the permitted annual sulfur dioxide emission limit for a new unit; or (ii) the permitted annual SO2 emission increase for the WEB source due to the replacement of an existing unit with a new unit or the modification of an existing unit that increased the production capacity of the WEB source. The allocation from the new source set-aside in the first year of operation will be adjusted to account for the number of days that the source is operating in that first year. EXAMPLE. A new unit with a nameplate capacity of 400 MW is constructed at a power plant with two existing units with nameplate capacities of 400 MW and 300 MW. The two existing units install SO2 controls and reduce emissions to meet PSD requirements for the construction of the new unit. In this example, the source would continue to receive a floor and a reducible allocation for each of the existing units, and would also be eligible to receive an allocation from the new source set-aside for the new unit. Even though total SO2 emissions will decrease at this plant due to the construction of the new unit, the allowances allocated to the source will increase to reflect the increase in production capacity of 400 MW of electricity. If the new unit comes on line on July 1 the allocation for the first year will be reduced by 50 percent because the unit was operational for half of the year. (2) Allocations from the new source set-aside will remain constant for the applicable WEB source and will be made on an annual basis by March 31 of each year for the current control period. When the next five-year allocation block is distributed as outlined in section 8.1 of this plan, all sources with an allocation under the new source set-aside will receive a five-year allocation block from the new source set-aside, and will continue to receive this allocation in future five-year allocation blocks. (3) Owners or operators of new WEB sources or modified WEB sources that meet the eligibility requirements of (1) may apply for an allocation from the new source set-aside by submitting a written request to the State of Arizona. (4) The State of Arizona will review the application for an allocation for accuracy and completeness, and will notify the source of intent to distribute allocations from the regional new source set-aside pending verification that allowances are available in the new source set-aside account. The State of Arizona will then forward the request to the TSA. (5) The TSA will document the date that the request is received by the TSA. Requests for allocation of allowances from the new source set-aside will be processed in the order received. The TSA will deduct the number of allowances requested from the regional new source set-aside that was established by the participating states and tribes, and will then record an equal number of allowances in the source’s compliance account for each remaining year of the five-year period. The TSA will then send Chapter 8 – SO2 Milestones/Backstop - 60 - Arizona Regional Haze SIP written notification to the source and to the State of Arizona that the allowances have been recorded in the source’s compliance account. (6) If there are insufficient allowances remaining in the new source set-aside to fulfill the request, the source must to purchase the allowances required to demonstrate compliance. Any eligible WEB source that does not receive an allocation from the new source set-aside because the set-aside was depleted will be first in line to receive an allocation when the new source set-aside is increased in the next five-year period as outlined in Table 8-5 of this plan. If there is more than one such source, their allocation requests will be processed in the order they were received by the TSA. (7) A source that has received a retired source exemption and continues to receive an allocation as a retired WEB source is not eligible to receive an allocation from the new source set-aside. 8.3.4. Regional Tribal Set-aside (1) Each year after the program is triggered, 20,000 allowances will exist as a tribal set-aside. (2) The tribal caucus of the WRAP has stated its intent to determine the means for distributing the allowances among the tribes within one year after the program trigger date. The State of Arizona understands that there will be a process that will meet the tracking and data security requirements of the allowance tracking system by which a tribe will move its set-aside allowances into the trading program for the purposes of trading. (3) The State of Arizona recognizes that the tribal set-aside allowances are bonus allowances for the tribes and, as such, are separate and additional to any allowances included in a tribal budget or the new source set-aside as outlined in the allocation report that is prepared in accordance with section 8.1.3(6) of this plan. 8.3.5. Opt-in Sources. The WRAP Market Trading Forum has recommended including provisions in this plan that would allow smaller sources to opt in to the program. Opt-in sources may provide a more cost-effective way to reduce overall regional SO2 emissions, and therefore may strengthen the market incentives of this program. While the benefits of allowing sources to opt in to the program are important, the program must also provide safeguards to ensure that the integrity of the program is not affected. For example, it would be counterproductive to allow sources that were already planning to shut down to opt in to the program and then sell allowances to an existing source. In this example, regional emissions could slowly creep upward in a manner that is not consistent with the goals of the SO2 milestones. The State of Arizona is deferring inclusion of provisions for opt-in sources until a future SIP revision to allow time to thoroughly consider how to provide the flexibility and potential benefits to the market by expanding the program while also ensuring that the SO2 emission reduction goals are maintained. 8.3.6. WEB Allowance Tracking System (WEB ATS) Section 40 CFR 51.309(h)(4)(v) requires a centralized system for the tracking of allowances and emissions. The centralized system will be referred to as the WEB Allowance Tracking System (WEB ATS or ATS). The WEB ATS must provide that all necessary information regarding emissions, allowances, and transactions is publicly available in a secure, centralized database. The ATS must ensure that each allowance is uniquely identified, allow for frequent updates, and include enforceable procedures for recording data. Chapter 8 – SO2 Milestones/Backstop - 61 - Arizona Regional Haze SIP The State of Arizona will work cooperatively with other states and tribes participating in the WEB Trading Program to designate this system. The State of Arizona will be responsible for ensuring that all the ATS provisions are completed as described in this plan. The ATS will not exist unless the program is triggered. Prior to the implementation of the WEB Trading Program, a separate emissions tracking database will be employed to track the ongoing emissions of sources emitting SO2 at amounts equal to or greater than 100 tons per year. The emissions tracking database, which was used to track and measure SO2 emissions against the milestones, will still exist once the WEB Trading Program is triggered; however, it will become incorporated into the SO2 Allowance Tracking System. Both the emissions tracking database and the ATS will be centralized systems and data will be posted in an electronic, Web-based program and available to all persons. The participating states and tribes will contract with a common TSA to service and maintain the WEB ATS. It is envisioned that the ATS will require the use of a contracted consultant or database design engineer to create a secure, efficient and transparent tracking system. Because the ATS will be utilized by all states and tribes participating in the program, the design will require a uniform approach and level of security that will satisfy regional needs and concerns as well as meet the electronic, Web-based, access needs and security provisions. Due to the dynamic needs of the marketplace, the ATS will require a database that will reflect the current status of allowances and allowance transactions. The ATS will be operational within one year after the program trigger date. Specifications of the WEB ATS such as emissions tracking, the recording of allowance transactions, account management, system integrity and transparency are outlined in Appendix A-8b to this Plan. Appendix A-8b and requirements found in the state-specific rule detail how a WEB source will register for the ATS and how the source will, through an account representative, establish accounts, transfer allowances, and track unused allowances from a previous year. The account representative will also look to Appendix A-8b to determine the appropriate interface with the ATS. Neither the State of Arizona nor the TSA will adjudicate any dispute between the parties concerning the authorization of any account representative with regard to any representation, action, inaction, or submission of the account representative. As an example of how the WEB ATS will generally function, once the WEB Trading Program is triggered, a WEB source will have its allowance allocation determined. At the same time, the WEB source’s account representative will register for the ATS, and a compliance account will be established. Each allowance will be assigned a serial number. The allowance serial number will be used by the WEB ATS to track allowance allocations, transfers, and deductions, and to account for any unused allowances from a previous year. The serial number also will be assigned to each allowance recorded in a general account, which is an account for allowances that are not held to meet program compliance requirements. Furthermore, the ATS will track tribal allowance set-asides and new source allowance set-asides not yet assigned to either a compliance or general account. It is important to note that while this plan has provided a design for and an operational understanding of the ATS, the components of the ATS will need to be examined and possibly altered upon each required SIP revision. Chapter 8 – SO2 Milestones/Backstop - 62 - Arizona Regional Haze SIP 8.3.7. Allowance Transfers (1) 40 CFR 51.309(h)(4)(viii) requires the Plan to include provisions detailing the process for transferring allowances between parties. Transfers are defined as the conveyance from one account to another account (compliance account or general account) of one or more allowances by whatever means, including but not limited to purchase, trade, or gift in accordance with the procedures established in the state-specific rule. This includes the transfer of allowances for the purpose of retirement. Once an allowance is retired, it is no longer available for transfer to or from any account. Allowances may be purchased by any person for the purpose of retirement. (2) The TSA will have specific recording duties involving transfers. These required procedures will be detailed in the service contract and will include the following activities. (a) Recording of Allowance Transfers. (i) Within five business days of receiving an allowance transfer, except when the transfer does not meet the requirements of the state-specific rule, the TSA will record an allowance transfer by moving each allowance from the transferor account to the transferee account as specified by the request, provided that the transfer is correctly submitted and that the transferor account includes each allowance identified in the transfer. (ii) Any allowance transfer that is submitted for recording following the allowance transfer deadline and that includes any allowances allocated for a control period prior to or the same as the control period to which the allowance transfer deadline applies will not be recorded until after completion of the compliance account reconciliation. (iii) Where an allowance transfer submitted for allowance transfer recording fails to meet the requirements of the state-specific rule, the TSA will not record the transfer. (2) Notification of the Recording of Allowance Transfers. The TSA has specific responsibilities involving the notification of the recording of any transferred allowances, including the failure to record any transfer of allowances. Again, these required procedures will be outlined in the service contract, but include the following. (a) Within five business days of the recording of an allowance transfer, the TSA will notify the transferor’s and transferee’s account representatives of both accounts, and make the transfer information publicly available on the Internet. (b) Within five business days of receipt of an allowance transfer that fails to meet the requirements of the state-specific rule, the TSA will notify the account representatives of both accounts of the decision not to record the transfer, and the reasons for not recording the transfer. 8.3.8. Use of Allowances from a Previous Year (1) Background. 40 CFR 51.309(h)(4)(ix) allows states to include in the plan provisions for the accounting of unused allowances from a previous year. The unused allowances may be kept for use in future years and there are restrictions on the use of the allowances in accordance with the state-specific rule. The federal rule also requires that allowances kept for use in future years may be used in calendar year 2018 only to the extent that the plan guarantees that such allowances will not interfere with the achievement of the 2018 milestone as outlined in Table 3 of this plan, adjusted according to the provision Chapter 8 – SO2 Milestones/Backstop - 63 - Arizona Regional Haze SIP of sections 8.1.3(2) (3) and (4) of this plan. The state-specific rule addresses this by prohibiting the use after the year 2017 of allowances allocated for the years 2003 – 2017. This provision ensures that actual emissions will be less than the 2018 milestone because only allowances allocated for the year 2018 could be used to show compliance in that year. The provision also maintains flexibility by resetting the baseline to the year 2018 and then allowing sources to once again use extra allowances to show compliance in any future year. This flexibility is important for sources that have variable operations because the source may build up a reserve of unused allowances for use in a high production year. The Annex explains the benefits of allowing the WEB source to use unused allowances from previous years, including increased flexibility and early reduction stimulus. The risk in allowing the use of allowances carried from a previous year could be an increase in emissions in later years as the unused allowances are withdrawn for compliance. Because the regional haze SIP is based on reasonable progress requirements related to the remedying or prevention of any future visibility impairment, it is important to assure the use of these allowances will not interfere with attainment or maintenance of any reasonable progress goals. The safeguard employed here to mitigate this type of risk is termed, “flow control”, and is described in paragraph (2) below. (2) Flow Control Provisions. (a) At the end of each control period, WEB sources may transfer allowances in and out of their compliance account for a period of 60 days to ensure that the account will contain enough allowances to cover sulfur dioxide emissions during the previous year. At the end of the sixty-day transfer period, allowances shall be deducted from the compliance account of each WEB sources in an amount equal to the sulfur dioxide emissions of that source during the control period. (b) After the deductions have been completed, the Tracking System Administrator shall perform the following calculations and prepare a report according to 8.1.5 of this plan. (i) Determine the total number of allowances remaining in the allowance tracking system that were allocated for the just completed control period and all previous control periods. (ii) If the number calculated in (i) exceeds 10 percent of the milestone for the next control period, then the flow control procedures found in the state-specific rule shall be triggered for that next control period. These flow control provisions will discourage the excessive use of allowances that were allocated for an earlier control period without establishing an absolute limit on their use. WEB sources will maintain the option to use allowances allocated for an earlier control period, but will be required to use two allowances for each ton of SO2 emissions. Flow Control operates as follows. (A) The flow control ratio shall be calculated by multiplying 0.1 times the milestone for the next control period, divided by the total number of unused allowances remaining in the system. (B) To calculate the number of prior-year allowances that can be used without restriction by a source for the next control period, the TSA shall multiply the prior-year allowances by the flow control ratio. The resulting number of allowances may be used on a one-to-one ratio to show compliance with the source’s emission limitation. Chapter 8 – SO2 Milestones/Backstop - 64 - Arizona Regional Haze SIP (C) The remaining prior-year allowances may be used on a two-to-one ratio to show compliance. Thus, WEB sources will maintain the option to use allowances allocated for an earlier control period, but will be required to use two of those allowances for each ton of SO2 emissions. Example: On March 1, 2010 (the compliance transfer deadline for the 2009 control period) the Tracking System Administrator deducts allowances from the compliance account for each WEB source to cover 2009 SO2 emissions from that source. After completing these deductions, the TSA reports the following information: Total number of allowances still in the system for the years 2003 – 2009 2010 milestone (5-state, no smelter) Percent of milestone = = = 75,000 508,223 14.75 % Because the number of allowances not used in previous control periods is greater than 10% of the milestone, flow control procedures are triggered. In the annual report required in XX.E.3.j(1)(6) the TSA will then calculate the flow control ratio for 2010: 0.1 x 2010 Milestone ÷ prior year allowances = flow control ratio 0.1 x 508,223 ÷ 75,000 = 0.67 On March 1, 2011 (the compliance transfer deadline for the 2010 control period) the TSA will apply the 2010 flow control ratio before deducting allowances from each WEB source’s compliance account WEB Source A 2010 Allowances Remaining Prior Year Allowances 2010 Emissions = = = 1,000 500 1,400 In this example, the TSA would multiply the prior year allowances by 0.67 to determine the number of prior year allowances that could be used without restriction, at a one-to-one ratio. This would equal 335. The remaining prior year allowances would then be used at a 2:1 ratio. 130 allowances would be needed to cover the remaining 65 tons of SO2 emissions. The TSA would therefore deduct a total of 1,465 allowances (1,000 + 335 + 130) to cover 1,400 tons of SO2 emissions. 8.3.9. Monitoring/Recordkeeping (1) For WEB sources subject to 40 CFR Part 75, the TSA shall use data that has been quality assured and finalized by the EPA. For WEB sources subject to a state-specific monitoring protocol, the State of Arizona will quality assure and finalize the data in accordance with these provisions for submission to the TSA. (2) The data will be verified and submitted to the emissions tracking database as soon as reasonably feasible after annual emissions are reported by the WEB sources. These timelines will be modified, as necessary, according to the monitoring protocols. Chapter 8 – SO2 Milestones/Backstop - 65 - Arizona Regional Haze SIP 8.3.10. Compliance and Penalties (1) Compliance. When a WEB source exceeds its allowance limitation, the State of Arizona will require the TSA to deduct allowances from the following year’s allocation in an amount equal to two times the WEB source’s emissions of SO2 in excess of its allowance limitation. This deduction will be made from the WEB source’s compliance account after deductions for compliance are made. If sufficient allowances do not exist in the compliance account for the next control period to cover this amount, the State of Arizona will require the TSA to deduct the required number of allowances, regardless of the control period for which they were allocated, whenever the allowances are recorded in the account. (2) Penalties. The amount of the financial penalty shall be evaluated at each five-year SIP review, and adjusted to ensure that penalties per ton exceed the expected cost of allowances to ensure that this remains a stringent penalty. The state-specific rule establishes a penalty of $5,000 per ton for each ton of emissions above the source’s allowance limitation. This amount is in addition to the two allowances from the next year’s allocation to be deducted from the account for each one allowance of exceedance. For a violation of any provision of the market trading program, each day of the control period is a separate violation under Arizona’s rule, and each ton of excess emissions is a separate violation. 8.3.11. Periodic Evaluation of the Trading Program. (1) Annual Report. (a) Beginning one year after compliance with the trading program is required, the State of Arizona will obtain from the TSA an annual report that contains the following information: (i) the level of compliance program-wide; (ii) a summary of the use and transfer of allowances, both geographically and temporally; (iii) a source-by-source accounting of allocations compared to emissions; (iv) a report on the use of unused allowances from a previous year, in order to determine whether these emissions have or have not contributed to emissions in excess of the cap; and (v) the total number of WEB sources participating in the trading program and any changes to eligible sources, such as retired sources, or sources that emit more than 100 tons of SO2 after the program trigger date. (b) Within 10 months after the allowance transfer deadline for each control period when compliance with the trading program is required, the TSA will prepare a draft report that lists: (i) the total number of allowances deducted for the control period, (ii) the total number of allowances remaining in the Allowance Tracking System allocated for that control period and any earlier control period, (iii) a proposed determination that flow control procedures have either been triggered or have not been triggered for the next control period, and Chapter 8 – SO2 Milestones/Backstop - 66 - Arizona Regional Haze SIP (iv) if flow control procedures have been triggered, a draft flow control ratio calculated according to 8.3.8(2). (c) The State of Arizona will evaluate the draft report, and will propose a determination that flow control procedures either have been triggered or have not been triggered for the next control period. (d) The State of Arizona will publish a notice of availability of the draft report in newspapers of general circulation in Arizona, and will hold a 30-day public comment period. (e) After the comment period the State of Arizona will make a final determination that the flow control procedures either have been triggered or have not been triggered for the next control period. If the flow control procedures have been triggered, the State of Arizona will notify all WEB sources in Arizona that flow control procedures will be in effect during the next control period. (2) Five-year Evaluation. (a) The State of Arizona will work cooperatively with other participating states and tribes to conduct an audit of the WEB Trading Program no later than three years following the first full year of the trading program, and at least every five years thereafter. This evaluation does not replace the Plan assessments in 2008, 2013, and 2018. The evaluation will be conducted by an independent third party and include an analysis of: (i) whether the total actual emissions could exceed the values in Table 3 of this Implementation Plan of the WEB Trading Program even though sources comply with their allowances; (ii) whether the program achieved the overall emission milestone it was intended to reach; (iii) the effectiveness of the compliance, enforcement and penalty provisions; (iv) a discussion of whether states and tribes have enough resources to implement the WEB Trading Program; (v) whether the trading program resulted in any unexpected beneficial effects, or any unintended detrimental effects; (vi) whether the actions taken to reduce sulfur dioxide have led to any unintended increases in other pollutants; (vii) whether there are any changes needed in emissions monitoring and reporting protocols, or in the administrative procedures for program administration and tracking; (viii) the effectiveness of the provisions for interstate trading, and whether there are any procedural changes needed to make the interstate nature of the program more effective; and (ix) the integrity of the emissions and allowance tracking system, including whether the procedures for recording transactions are adequate, whether the procedures are being Chapter 8 – SO2 Milestones/Backstop - 67 - Arizona Regional Haze SIP followed and in a timely manner, whether the information on sources’ emissions are accurately recorded, whether the emissions and allowance tracking system has procedures in place to ensure that the transactions are valid, and whether back-up systems are in place to account for problems with loss of data. (b) The public will have an opportunity to participate in this trading program evaluation. (c) In the event that any audit results in recommendations for program revisions, the State of Arizona, in consultation with the WRAP, will make appropriate modifications to this Plan. The State of Arizona will revise this Plan if the program is not meeting its emission reduction goals. (d) The State of Arizona will submit a copy of the report to the EPA regional office. 8.3.12. Retired Source Exemption The state-specific rule outlines the procedure that a WEB source must follow to receive a retired source exemption. The exemption would allow the source to continue to receive an allocation, but would exempt the source from monitoring and recordkeeping requirements that would serve no useful function for a source that has ceased operations. The State of Arizona (i.e., the Director) will notify the source of its obligation to apply for a retired source exemption upon the cancellation or relinquishment of a permit. To receive a retired source exemption, the source must submit a request for the exemption to the State of Arizona. The State of Arizona will review this request, and within 60 days of receipt of the request will notify the source that the retired source exemption has been granted or has been rejected. If the exemption has been rejected, the notification will contain an explanation of the reasons for rejecting the request. The TSA will record an allocation to a WEB source that has received a retired source exemption. However, the allowances will be recorded in a general account rather than a compliance account for the source. A WEB source that is permanently retired and that does not request a retired source exemption will forfeit all abandoned allowances in that source’s compliance account. The forfeited allowances will not be redistributed to other sources, and will be permanently retired from the Allowance Tracking System. During the next five-year allowance distribution period the retired source will not receive an allocation, and the allowances that would have been distributed to that source will be added to the new source set-aside. 8.3.13. Integration into Permits 40 CFR 51.309 requires that the requirements for emissions reporting and for the trading program be incorporated into a permit that is enforceable as a practical matter by EPA and by citizens to the extent permitted by the Act. It is expected that all WEB sources will at least initially be subject to Arizona’s Title V permitting requirements. Arizona’s delegated Title V permitting program, the pre- and posttrigger requirements of the market trading program fall under the definition of “applicable requirements”, and will be incorporated into each source’s Title V permit. As found in the state-specific rule, any source that for any reason and at any time is not required to have a permit under the requirements of the statespecific rule, must obtain a New Source Review permit that incorporates the same requirements. Both types of permits are enforceable both federally and by citizens pursuant to Arizona’s SIP. Chapter 8 – SO2 Milestones/Backstop - 68 - Arizona Regional Haze SIP 8.4. 2013 SIP Revision; Backstop for Beginning of Second Planning Period In addition to the requirements of 40 CFR 51.309(d)(10), the periodic SIP revision due in 2013 will include the following information: a. Source specific allocations for all WEB sources in Arizona for the year 2018; and b. Either the provisions of a program designed to achieve reasonable progress for stationary sources of SO2 beyond 2018 or a commitment to submit a SIP revision containing the provisions of such a program no later than December 31, 2016. The program will ensure that the requirements of 40 CFR 51.309 for the first planning period, including requirements that cannot be measured until after 2018, such as the determination of compliance with the 2018 milestone. This 2013 SIP revision will provide certainty to sources regarding their potential liability under the special penalty provisions for the year 2018 outlined in section 8.1.5 of this plan. The calculation of these allocations is delayed until 2013 to provide certainty about the number of sources that will qualify as WEB sources at that time; the allocations needed for new sources in the region, and the magnitude of renewable energy development and early reductions that will be included in the allocation process. It is difficult to estimate the impact of these factors in 2003 because circumstances may change during the next 10 years. If the 2018 milestone is not met, the starting point for the next planning period shall be the 2018 milestones, not actual emissions in 2018. 8.5 Geographic Enhancement Program The requirements for geographic enhancement are discussed on page 35757 in the Preamble to the RHR (64 FR 35714, July 1, 1999). These requirements are related to Section 51.309(f)(1) which describes requirements for the Annex. The Annex allows states to submit a SIP, or tribes a TIP, which adopts an alternative measure to regional haze BART. Geographic enhancement is a voluntary approach that can be included in the Annex for addressing reasonably attributable visibility impairment (RAVI) for stationary sources, under the provisions of Section 51.302(c). RAVI is different from regional haze in that it addresses “hot spots” or situations where visibility impairment in a Class I area is reasonably attributable to a single source or small group of sources in relatively close proximity to the Class I area. The geographic enhancement approach would allow states or tribes to use the efficiencies and reduced cost provided by the market trading program in the Annex to accommodate situations where RAVI needs to be addressed. Additional information is contained in the WESTAR report, Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable BART,17 contained in Appendix A-8c. (a) Procedure for addressing Reasonably Attributable Visibility Impairment under the Regional Haze Rule. Pursuant to 40 CFR 51.309(f)(4), the State of Arizona shall use the following process to address reasonably attributable impairment (RAVI) in any Class I area, and the potential need for Best Available Retrofit Technology (BART), as specified in 40 CFR 302(c): (1) The State of Arizona will work with the National Park Service of the Department of Interior, and the U.S. Forest Service of the Department of Agriculture, on the agreed upon principles that will be followed for addressing RAVI within the context of regional SO2 milestones and a backstop emission trading program that have been developed to address regional haze. As part of 17 WESTAR , “Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable BART”, report to WRAP, [Date] Chapter 8 – SO2 Milestones/Backstop - 69 - Arizona Regional Haze SIP the Federal Land Managers’ obligation to protect the visibility in the areas that Congress has designated as mandatory Class I Federal areas, in the course of certifying impairment, the National Park Service or U.S. Forest Service may make recommendations to the State of Arizona regarding a source or sources to which impairment may be reasonably attributable. Within the context of established regional milestones for SO2 and a backstop trading program, the National Park Service and U.S. Forest Service will use the following screening process in making these recommendations as part of the certification process: (i) The National Park Service or U.S. Forest Service determines that sulfate concentrations are not decreasing since the year 2000, based on ambient monitoring, and (ii) There are BART-eligible sources of sulfur dioxide within 150 km of the mandatory Federal Class I area, and (iii) The BART-eligible sources have not installed control technology to reduce sulfur dioxide emissions at a rate equivalent to capture of 85% of potential annual emissions. (2) In approximately 2009 to 2010, but no later than December 2010, the State of Arizona will conduct a public meeting to facilitate the exchange of information regarding current visibility monitoring data at Class I areas in Arizona or in nearby states within 100 miles of any BARTeligible sources located in Arizona. The purpose of the meeting will be to provide as much information as possible to all interested parties about the potential for a certification to occur. The information will include visibility trends, as well as the type of impairment that is occurring at individual areas (e.g., haze, episodic impairment, and other types of screening criteria). The goal of this meeting is to provide information to sources and to the trading market so that potential problems could be addressed in the most cost-effective manner. (3) If the National Park Service or U.S. Forest Service certifies impairment, the State of Arizona will fulfill its obligation to determine attribution and if necessary determine BART for the applicable source or group of sources in accordance with Arizona's SIP for visibility protection submitted to EPA in Chapter 5 of this Implementation Plan. (i) The WESTAR report titled Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable BART, contained in Appendix A-8c, periodically augmented by new techniques and information available at the time of review, will be used to provide a toolbox of appropriate technical criteria and techniques for determining attribution. (ii) If attribution is determined, then the following alternative remedy solutions will be considered when determining BART for the applicable source: (A) BART-level controls could be installed on the attributed source or group of sources; (B) SO2 emission reductions that may be more cost-effective or have other air quality benefits could be required at nearby sources in lieu of, or in combination with controlling the attributed source to achieve greater visibility improvements that the application of BART. Chapter 8 – SO2 Milestones/Backstop - 70 - Arizona Regional Haze SIP 9. LONG-TERM STRATEGY FOR MOBILE SOURCES 9.1. Regulatory History and Requirements In its June 1996 Report, the GCVTC recommended EPA move forward on new national vehicle emission and fuel standards to reduce emissions from mobile sources. The GCVTC also recommended other regional and local strategies be considered to manage mobile source emissions. One of the local strategies was to establish emission budgets for those pollutants in urban areas shown to significantly contribute to visibility impairment in any of the 16 GCVTC Class I areas. The budget caps were to be set at the 2005 emission levels. When EPA finalized the RHR in July 1999, the rule acknowledged the GCVTC recommendations related to national vehicle emission and fuel standards. EPA included a status of planned actions on those recommendations as of July 1999 (Preamble to the regional haze rule, 64 FR 35753). EPA noted these new measures were over and above those included in the RHR for mobile sources that simply required a cap on emissions in significantly contributing urban areas at the 2005 level. EPA also indicated that emission reductions resulting from new standards adopted after the RHR was approved would be creditable toward reasonable progress. EPA also committed to work with the states if new national standards impacted the efficacy of regional or local strategies. After the RHR rule was finalized, EPA established new standards for on-road vehicle emission and fuel standards (65 FR 6698). As a result, current mobile source emission projections developed by WRAP for the GCVTC Transport Region indicate overall mobile source emissions will decline continuously from 2003 through the end of the SIP planning period in 2018, which exceeds the level of emission reductions that EPA approved as meeting reasonable progress; i.e., holding mobile source emissions from major urban areas to their lowest level during the planning period. In addition, new standards for non-road vehicles were proposed by EPA on April 15, 2003, and are expected to be finalized in the near future. These new standards for non-road vehicles will further reduce overall mobile source emissions. At the April 2003 WRAP Board meeting, the WRAP approved a recommendation that EPA modify the RHR eliminating the current requirements related to mobile source emission significance determination and budgets for urban areas (40 CFR 309(d)(5)), and replace those requirements with a new requirement focused on tracking mobile source emission reductions resulting from national standards to assure reasonable progress. This action was based on the finding that emissions of all pollutants from onroad and non-road mobile sources, except for sulfur dioxide from non-road engines, are expected to decline significantly through 2018. The overall emission trends for mobile sources are summarized in Table 9-1 contained in Section 9.2, below, with additional details contained in Chapter 5 of the WRAP TSD. If EPA adopts new low-sulfur standards for non-road mobile sources, then non-road mobile source sulfur dioxide emissions would also decline dramatically through 2013 with a very small increase expected through 2018. On July 3, 2003, EPA issued a proposed rule (68 FR 39888) and a direct final rule (68 FR 39842) to amend the mobile sources provision of the Regional Haze Rule consistent with the recommendations of the WRAP. One adverse comment was received, so the direct final rule was withdrawn. On December 22, 2003, EPA promulgated the final rule (68 FR 71009) changing the mobile source requirements in 40 CFR 51.309. The revisions changed the requirements under 40 CFR 51.309(d)(5)(i) and eliminated the previous requirements under 40 CFR 51.309(d)(5)(ii & iii) for setting mobile sources emissions budgets using the lowest projected level as a planning objective and performance indicator for each urban area. Chapter 9 – Mobile Sources - 71 - Arizona Regional Haze SIP The former 40 CFR 51.309(d)(5)(iv), which addresses the other GCVTC mobile source recommendations, was retained as 40 CFR 51.309(d)(5)(ii). The new Section 51.309(d)(5)(i)(A) requires statewide inventories of mobile source emissions, for each 5-year implementation plan reporting period required under 40 CFR 51.309(d)(10), to be reviewed to demonstrate a continuous decline in emissions of each pollutant of concern over the planning period through 2018. Should mobile source emission not decline as expected, the State of Arizona will review control options for mobile sources and determine if additional controls are needed, consistent with the criteria for reasonable progress. If the State of Arizona determines that additional controls are needed, Arizona will prepare a revision to the implementation plan within one year after the progress report is due under 40 CFR 51.309(d)(10)(i), as required under 40 CFR 51.309(d)(10)(ii)(D). In addition to the new revisions to 40 CFR 51.309(d)(5)(i) and the elimination of the former Sections 51.309(d)(5)(ii) and (iii), a backstop provision as outlined by the WRAP was added. The new 40 CFR 51.309(d)(5)(i)(B), requires the State of Arizona to assess the need for any long-term strategies to address SO2 from non-road mobile sources by no later than December 31, 2008. Under this provision, Arizona will determine if a SIP revision is necessary to address SO2 from mobile sources by considering whether the emission reductions anticipated or achieved by any Federal standards in place addressing fuel sulfur content for non-road engines are sufficient to meet reasonable progress. To assist in the investigative and deliberative process related to mobile source emissions and their significance, ADEQ established a Mobile Source Work Group (MSWG) made up of a wide range of Arizona stakeholders including industry, environmental, metropolitan planning organization representatives, and regulators. The MSWG monitored the WRAP Mobile Source Forum process and work products. In addition, the MSWG collected and analyzed data to assist in the deliberative process. The MSWG provided ADEQ tabular information on projected emissions in addition to recommendations for the mobile source regional haze SIP component. The MSWG issued a final memoranda summarizing findings and recommendations to ADEQ that are contained in Appendix A-9a, entitled “Arizona Mobile Source Work Group Findings and Recommendations Related to Mobile Source Emissions.” 9.2. Inventory of Current and Projected Emissions from Mobile Sources (a) Inventory of Current and Projected Emissions from Mobile Sources. Pursuant to 40 CFR 51.309(d)(5)(i)(A), the State of Arizona, in collaboration with the WRAP, assembled a comprehensive statewide inventory of mobile source emissions. This is summarized in Table 9-1, and is described in detail in the WRAP TSD in Chapter 1 and Chapter 5. This emission inventory showed the year with the lowest level of emissions would be at the end of the SIP planning period in 2018 instead of 2005 as anticipated by the GCVTC. The substantial reduction of projected mobile source emissions from 2003 to 2018 is due to the adoption of new on-road vehicle emission and fuel standards by EPA. The figures in Table 9-1 do not include the anticipated reduction from the pending proposal to reduce sulfur content of non-road sources. Table 9-1. Statewide Mobile Source Emissions for Arizona (Tons per Day) Year 1996 2003 2008 2013 2018 VOC 553.2 448.7 319.9 256.9 222.0 NOx 655.0 496.5 381.2 296.7 237.3 PM2.5 37.2 23.0 22.0 19.1 18.0 SO2 33.3 20.9 10.0 9.5 18.6 Total 1,278.7 989.1 733.1 582.2 495.9 Source: 1996 from WRAP 1996 Base Emission Inventory 2003-2018 from WRAP Mobile Source Worksheets Chapter 9 – Mobile Sources - 72 - Arizona Regional Haze SIP (b) Program to assure continuous decline in mobile source emissions. Pursuant to 40 CFR 51.309(d)(5)(i)(A), the State of Arizona commits to monitoring the emissions from mobile sources to assure a continuous decline in emissions as defined in 40 CFR 51.309(b)(6). If Arizona determines that a continuous decline in emissions is not being achieved, additional control measures will be reviewed to determine if they are needed to demonstrate reasonable progress. If Arizona determines such measures are needed, Arizona will submit an SIP revision to address the identified control measures. (c) Backstop provision to address potential increase in non-road emissions in the event proposed Federal standards are not finalized. Pursuant to 40 CFR 51.309(d)(5)(i)(B), the State of Arizona commits to provide for a SIP revision no later than December 31, 2008, containing long-term strategies necessary to reduce emission of SO2 from non-road mobile sources consistent with the goal of reasonable progress. The need for a SIP revision will be determined by a consideration of the emission reductions achieved or anticipated to be achieved by proposed Federal standards should those standards addressing fuel sulfur content for non-road engines not be in place. 9.3. Other GCVTC Strategies for Mobile Sources Pursuant to 40 CFR 51.309(d)(5)(ii), the State of Arizona has reviewed the other mobile source recommendations contained in the GCVTC report. The results of that review are included in Chapter 13 of this SIP that addresses all recommendation of the GCVTC report, including mobile source recommendations. Chapter 9 – Mobile Sources - 73 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 9 – Mobile Sources - 74 - Arizona Regional Haze SIP 10. LONG-TERM STRATEGY FOR FIRE PROGRAMS 10.1. Regulatory History and Requirements In its 1996 final report, the GCVTC recognized that past land management practices, including decades of fire suppression, have led to an increase of accumulated forest fuels. Wildfires are becoming larger in size, unnaturally destructive, and more dangerous and costly to control. Fire, however, is a component of most natural ecosystems in the West and therefore must be a component of processes to meet land management, human health and visibility objectives. The GCVTC recognized that prescribed fire and wildfire levels are projected to increase significantly for decades to come, and that programs to minimize emissions and visibility impacts, and to educate the public, should be implemented. The Regional Haze Rule (40 CFR 51.309(d)(6)) requires documentation that all federal, state and private prescribed fire programs in the state evaluate and address the degree of visibility impairment from smoke. In addition, a statewide inventory and emissions tracking system must be established for volatile organic compounds, nitrogen oxides, elemental and organic carbon, and fine particle emissions from fire. Any administrative barriers to the use of alternatives to burning should be identified and removed where possible along with an enhanced smoke management program based on specific criteria that addresses visibility as well as health and nuisance objectives. Finally, annual emission goals for fire shall be established, in cooperation with states, tribes, federal land managers and private entities, to minimize emissions increases from fire to the maximum extent feasible. The WRAP's effort to document and understand the incidence of fire and its effect on visibility in Class I areas has been extensive and productive. Chapter 6 of the WRAP TSD, “Assessment of Fire Programs,” details the results of WRAP’s analyses of fire on visibility to date. Different emission reduction scenarios for the 2018 projected inventories were the basis for the analyses. WRAP modeling shows that emissions from fire will continue to affect visibility for some time on an episodic basis. 10.2. Prescribed Fire Program Evaluation Pursuant to 40 CFR 51.309(d)(6)(i), the State of Arizona evaluated the State’s Enhanced Smoke Management Plan and all Federal, State, and private prescribed fire smoke management programs in the State, based on the potential to contribute to visibility impairment in the 16 Class I areas of the Colorado Plateau, and how visibility protection from smoke is addressed in planning and operation. The State of Arizona relied upon the WRAP report Assessing Status of Incorporating Smoke Effects into Fire Planning and Operations (see Appendix A-10a) as well as EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires (see Appendix A-10b) as a guides for making this evaluation along with input from a stakeholder-based work group familiar with the policies and regulations related to fire and land management within the State. The State of Arizona also evaluated whether the State’s existing fire regulations as part of an Enhanced Smoke Management Plan contained the following elements: actions to minimize emissions; evaluation of smoke dispersion; alternatives to fire; public notification; air quality monitoring; surveillance and enforcement; and program evaluation. The result of this evaluation process was the determination that revisions to Arizona’s existing fire regulations, R18-2-602, “Unlawful Open Burning,” and Article 15, “Forest and Range Management Burns,” would be necessary. 10.3. Emission Inventory and Tracking System The State of Arizona has made revisions to R18-2-602, “Unlawful Open Burning,” and Article 15, “Forest and Range Management Burns,” to allow for the tracking of all types of fire in the State. Chapter 10 – Fire Programs - 75 - Arizona Regional Haze SIP These state-approved rules along with the related public participation and review process, can be found in Appendix A-10c, with Appendix A-10d containing supporting information related to the promulgation of these rules. Most of the changes made to Article 15 relate directly to the requirement of Section 309(d)(6), including to the collection and recording of burn data. Changes to R18-2-602 allow Arizona to meet the tracking requirements in 12 counties throughout the state. The three remaining counties, Maricopa, Pima and Pinal, have their own fire rules (Maricopa County Rule 341; Pima County Rule 17.12.480, et seq.; and Pinal County Rule 3-8-700 and 3-8-710.). The three counties will revise their existing rules to comply the requirements of R18-2-602. The State of Arizona commits to submit updated county rules based on the revised Arizona rules in a SIP revision by December 31, 2004. In addition to its own emissions tracking, the State of Arizona will review the WRAP data on post-burn activity and utilize the WRAP’s regional emission tracking system. In addition, fire emission inventory updates will be provided in future progress reports, as part of the periodic SIP revisions, pursuant to 40 CFR 51.309(d)(10). See Appendix A-10e, entitled, Policy on Fire Tracking Systems for further information on the emissions inventory and tracking system to be utilized by Arizona. 10.4. Strategy for Use of Non-burning Alternatives The State of Arizona is continuing to develop a process with key public and private entities, including the State Department of Agriculture, State Land Department, Federal Land Managers’, farming and forestry associations, etc. to identify and remove administrative barriers to the use of non-burning alternatives to prescribed fire on federal, state, and private lands, pursuant to 40 CFR 51.309(d)(6)(iii). The process is collaborative and provides for continuing identification and removal of administrative barriers, and considers economic, safety, technical and environmental feasibility criteria, and land management objectives. This process is outlined in the related sections of the Arizona fire rules (see Table 10.1, “Alternative to fire”). In developing this process, the State of Arizona will rely on two documents: (1) Nonburning Alternatives for Vegetation and Fuel Management (see Appendix A-10f), and (2) Burning Management Alternatives on Agricultural Lands in the Western United States (see Appendix A-10g), prepared by the WRAP that describe a variety of non-burning alternatives and methods of assessing their potential applicability. 10.5. Enhanced Smoke Management Program Pursuant to 40 CFR 51.309(d)(6)(iv), the smoke management programs that operate within Arizona are consistent with the WRAP Enhanced Smoke Management Programs for Visibility (see Appendix A-10h). This approach calls for programs to be based on the criteria of efficiency, economics, law, emission reduction opportunities, land management objectives, and reduction of visibility impacts. The WRAP Enhanced Smoke Management Programs for Visibility lists the previously identified elements under 40 CFR 51.309(d)(6)(i) as well as adding “burn authorization” and “regional coordination” elements to ensure visibility protection and to meet the designation of “enhanced.” An Enhanced Smoke Management Plan (ESMP) comprises a series of key policies and management practices. In general the ESMP must specifically address visibility effects and apply to all fire sources as do all smoke management plans in the State of Arizona. The ESMP should also apply uniformly to source sectors or be tailored to source sectors and/or geographical areas. In addition, the ESMP must provide the opportunity to work collaboratively with state, tribal, local, and federal agencies, and private parties while considering the criteria of efficiency, economics, law, emission reduction opportunities, land management objectives, and reduction of visibility impact. The State of Arizona Chapter 10 – Fire Programs - 76 - Arizona Regional Haze SIP ESMP meets all of these requirements. The State of Arizona will conduct annual meetings of all affected parties to discuss smoke management issues and objectives. Arizona’s Article 15 (R18-2-1501-1515), Forest and Range Management Burns, and R18-2-602 (Section 602), Unlawful Open Burning, upon revision now includes the following specific elements required of an ESMP, and are enumerated in the Table 10-1. Table 10-1. Inclusion of ESMP Elements Into Arizona Regulations Enhanced Smoke Management Plan Element Actions to minimize emission from fire Evaluation of smoke dispersion Alternative to fire Public notification of burning Air quality monitoring Surveillance and enforcement Program evaluation Burn Authorization Regional Coordination Rule Citation R18-2-1509 R18-2-602(D)(3)(e) R18-2-1506 and 1510 R18-2-602(D)(3)(m) and (o) R18-2-602(B)(3)(d) R18-2-1503(C)(8), 1503(D) and 1503(G) R18-2-602(H)* R18-2-1513 R18-2-602(D)(3)(g) R18-2-1508 and 1511 R18-2-602(H)* R18-2-1514 R18-2-602** R18-2-1503 R18-2-602(H)* R18-2-1505 and 1508 R18-2-602(D)(3)(g) R18-2-1513 and 1515 R18-2-602(H)* * R18-2-602(H) allows the State of Arizona to examine at its annual meeting any need to address monitoring, regional coordination, or alternatives to burning as they arise in an overall discussion of program evaluation for unlawful opening burning. Issues that could arise in these areas are difficult to determine ahead of time, and are driven by proximity and volume. ** Any violations under R18-2-602 have penalty authority under Arizona Revised Statute 49-501. A copy of ARS 49-501 can be found in Appendix A-10i. 10.6. Annual Emission Goal Pursuant to 40 CFR 51.309(d)(6)(v), efforts will be made within the State of Arizona to minimize emission increases in fire, excluding wildfire, to the maximum extent feasible, through the use of annual emission goals, in accordance with the WRAP Annual Emission Goals for Fire (see Appendix A-10j). The Annual Emission Goals for Fire recognizes that Emission Reduction Techniques (ERTs) can be used to minimize emissions from fire. The State of Arizona commits to the establishment of a collaborative mechanism for setting annual emission goals, and development of a process for tracking their attainment on a yearly basis. The authority to proceed with this commitment can be found in Arizona’s revised Article 15, subsection 1503 and 1509. It can also be found in the tracking timeline Chapter 10 – Fire Programs - 77 - Arizona Regional Haze SIP contained within Arizona’s revised R18-2-602 rule. A list of current ERTs is contained in the rule appendix to R18-2-602. The projection and tracking of ERT use is a minimum element of the quantifiable annual emission goal. The Annual Emissions Goal will utilize the projection of total emissions inventory for prescribed fire and agricultural burning, as provided by the emissions inventory and tracking systems outlined in Section 10.3 of this chapter, such that the effect of projected emission reduction techniques or percentage of ERT use is shown in relation to projected total emissions. Should projected annual emissions not be available, the State commits to submit a timeline to develop the necessary inventory. Where ERT use or other emission reduction methods cannot be quantified with confidence due to the current state of the science (such as for agricultural burning), the State of Arizona commits to participate in the development of further refinements in emission reduction or emissions averted calculation methodologies. The use of ERTs to meet the 51.309(d)(6)(iv) requirement, as with the ESMP, is subject to economic, safety, technical and environmental feasibility, and land management objectives. Chapter 10 – Fire Programs - 78 - Arizona Regional Haze SIP 11. AREA SOURCES OF DUST EMISSIONS FROM PAVED AND UNPAVED ROADS 11.1. Regulatory History and Requirements In its 1996 report to EPA Recommendations for Improving Western Vistas the GCVTC stated that dust emissions from vehicles traveling on paved and unpaved roads are generally near-field transport issues rather than long-range transport issues, especially with respect to larger, coarse materials that settle out of the atmosphere before being transported long distances. Due to considerable uncertainty regarding the ability of emission and air quality models to accurately characterize the contribution of road dust to visibility impairment, the GCVTC also recommended further analysis to resolve the uncertainties regarding both near-field and distant effects of road dust prior to recommending any remedial actions. As a result, the Regional Haze Rule (40 CFR 51.309(d)(7)) requires states to assess the impact of dust emissions from paved and unpaved roads on regional haze in the 16 Class I areas located on the Colorado Plateau in the SIPs due by December 31, 2003. The WRAP, the GCVTC’s successor organization, analyzed this issue, including efforts to improve methods for estimating road dust emission inventories as applied to regional scale modeling and characterization of transport and deposition. The WRAP’s modeling work demonstrated road dust is not a measurable contributor on a regional level to visibility impairment in the 16 Class I areas. Due to this finding, no additional road dust control strategies are needed in the current SIP. The State of Arizona, in consultation with the WRAP, will perform further assessments of road dust impacts on visibility in the 16 GCVTC Class I areas in the progress updates and status reports due in 2008, 2013 and 2018. Based on these assessments, if road dust emissions are determined to be a significant contributor to visibility impairment, the State of Arizona commits to implement emissions management strategies to address the impact as necessary and appropriate to demonstrate reasonable progress. 11.2. Strategy for Road Dust Sources Impact of paved and unpaved road dust emissions and contribution to visibility impairment finding. Pursuant to 40 CFR 51.309(d)(7), a regional scale assessment was made by the WRAP of the impact of dust emissions from paved and unpaved roads from transport region states on the 16 Class I areas of the Colorado Plateau. Chapter 7 of the WRAP TSD contains the results of the following technical work: (1) a summary of 1996 and 2018 emission inventories for re-entrained road dust from paved and unpaved roads; (2) a description of the definition of significance for road dust in the 16 Class I areas; (3) road dust modeling results – regional versus localized air quality impacts; and (4) a discussion of WRAP’s finding of no measurable contribution to regional haze. Based on these findings, no emission management strategies have been identified at this time. Tracking of Road Dust Emissions. The State of Arizona commits to track road dust emissions with the assistance of the WRAP, and provide an update on paved and unpaved road dust emission trends, including any modeling or monitoring information regarding the impact of these emissions on visibility in the Colorado Plateau 16 Class I areas. These updates shall include a re-evaluation of whether road dust is a measurable contributor to visibility impairment. These updates shall be part of the periodic SIP revisions, pursuant to 40 CFR 51.309(d)(10). Chapter 11 – Road Dust - 79 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 11 – Road Dust - 80 - Arizona Regional Haze SIP 12. POLLUTION PREVENTION AND RENEWABLE ENERGY PROGRAMS 12.1. Regulatory History and Requirements In its 1996 Report, the GCVTC recommended several pollution prevention strategies from education to supporting development of renewable energy sources. The GCVTC also identified regional goals of renewable energy usage of 10% by 2005 and 20% by 2015. These are referred to below as the “10/20 goals.” The GCVTC also recommended that 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.18 40 CFR 51.309(d)(8) includes the regulatory language for the GCVTC’s recommendations. The Air Pollution Prevention (AP2) Forum was created in September, 1998 by WRAP to study the issues related to pollution prevention required in 40 CFR 51.309(d)(8), and to develop work products the states and tribes could rely on when developing SIPs. The AP2 Forum’s documents may be found at www.wrapair.org. These include information related to identifying barriers and policies that could lead to increased investment in renewable energy and energy efficiency in the Grand Canyon Visibility Transport Region. The Forum also performed an analysis related to potential emissions reductions, energy cost savings, and secondary environmental and economic benefits of meeting the GCVTC’s 10/20 goals. The Arizona Department of Environmental Quality established a Pollution Prevention Work Group (P2WG) to assist in developing the material necessary for this SIP. The P2WG included representatives from utilities, environmentalists, state energy regulators, and local regulators. The P2WG work products relied upon the work of the WRAP AP2 Forum, and independent research necessary to assemble the materials in this chapter. Arizona's P2WG reviewed WRAP's policy on renewable energy and energy efficiency. Appendix A-12a entitled “Arizona Pollution Prevention Work Group Review of WRAP Policy on Renewable Energy and Energy Conservation” contains a copy of a comment letter sent to WRAP's Air Pollution and Prevention Forum (AP2 Forum) along with a copy of the WRAP Policy entitled, "Renewable Energy and Energy Efficiency As Pollutuion Prevention Strategies For Regional Haze." 12.2. Approach to Addressing Requirements Under 40 CFR 51.309(d)(8) Pursuant to 40 CFR 51.309(d)(8), the following sections, (1) identify, describe and/or inventory programs being implemented by various companies, organizations and agencies in the State of Arizona, including renewable energy programs, incentive programs, programs to preserve and expand energy conservation efforts, and programs to demonstrate progress towards renewable energy goals; and (2) project emission reductions, visibility improvements and other impacts anticipated to result from such programs. Arizona’s approach to address the specific requirements of 40 CFR 51.309(d)(8) are summarized in Table 12-1. 18 Recommendations for Improving Western Vistas, Grand Canyon Visibility Transport Commission; Western Governors' Association: Denver, CO, June 10, 1996, page 30. Chapter 12 – Pollution Prevention - 81 - Arizona Regional Haze SIP Table 12-1. Arizona’s Approach to Address 40 CFR 51.309(d) Requirements Citation in 40 CFR 51.309(d) (d)(i) (d)(i) (d)(i) (d)(ii) (d)(iii) (d)(iv) (d)(v) (d)(vi) (d)(vi) Description of Requirement Description of Existing Pollution Prevention Programs Renewable Energy Generation Capacity and Production Summary of Anticipated Renewable Energy Contribution Incentive Programs Programs to Preserve and Expand Energy Conservation Potential for Renewable Energy Projection of Pollution Prevention Programs on Visibility Programs Relied on to Achieve GCVTC Renewable Goals Future Progress Reports Addressed in Section 12.3 12.4 12.5 12.6 12.7 12.8 12.9 12.10 12.11 The inclusion in the SIP of these programs and estimated emission reductions and impacts shall not render such programs and estimates mandatory and/or federally enforceable, nor are such programs or estimates relied on for purposes of meeting the visibility goals established as part of the SIP planning process. These programs are voluntary or state programs that were never intended to be federally enforceable, and the projected emission reductions are estimates only. It is expected that these programs and the associated emissions impacts will change over time and will be reflected in the progress reports for 2008, 2013, and 2018 required under 40 CFR 51.309(d)(10). 12.3. Description of Existing Pollution Prevention Programs in Arizona Pursuant to 40 CFR 51.309(d)(8)(i), Tables 12-2 and 12-3 summarizes all pollution prevention programs currently in place in Arizona. Table 12-2 summarizes the renewable energy programs currently in place. Table 12-3 summarizes the energy efficiency programs currently in place for Arizona. Table 12-4 summarizes planned renewable energy projects as of 2002. Table 12-2. Summary of Renewable Energy Programs Currently in Place in Arizona Program Title Program Description Environmental Portfolio Standard The Arizona Corporation Commission (ACC) approved rules implementing the Environmental Portfolio Standard, in March 2002 (ACC R14-2-1618). The standard requires a minimum percentage of retail electricity sales to be from eligible solar electric or “environmentally friendly renewable electricity technologies.” Technologies included are: photovoltaics, solar thermal resources that generate electricity, solar water heaters, solar air conditioning systems, in-state landfill gas generators, wind generators, and biomass generators. The standard began with 0.2% in 2001, rises to 1.1% in 2007, and then remains stable until 2012. 2001 2002 2003 2004 2005 2006 2007-12 0.2% 0.4% 0.6% 0.8% 1.0% 1.05% 1.1% At least 50% of the portfolio standard must be solar electric in early years, increasing to 60% solar electric in 2004. The portfolio includes incentives or “extra credit multipliers” for early installation, for installation in Arizona, for using equipment manufacturers in Arizona, for use in “distributed” Chapter 12 – Pollution Prevention - 82 - Arizona Regional Haze SIP Program Title Program Description applications or various programs including green pricing, net metering, solar leasing, or customersited systems. This standard only applies to electric suppliers who are regulated by the Arizona Corporation Commission. It does not apply to municipal utilities, irrigation districts, electrical district, and other quasi-governmental utilities. Further information can be found at the Arizona Corporation Commission website, http://www.cc.state.az.us/utility/electric/R14-2-1618.htm 2001/2002Arizona Environmental Portfolio Standard Results (in kWh Credits1) 2001 2002 Arizona Public Service Solar Electricity (Utility) 17,237,202 9,126,664 Solar Hot Water 6,541,328 2,208,334 Solar Air Conditioning ----Landfill Gas 11,307,931 44,938,574 Biomass ----Wind ----Total 34,786,461 56,273,572 (99.1% of requirement) (59.68% of requirement) Tucson Electric Power Solar Electricity (Utility) Solar Hot Water Solar Air Conditioning Landfill Gas Biomass Wind Total Citizens Communications Solar Electricity Total Navopache Electric Landfill Gas Total 2,990,538 ----6,884,068 ----9,874,606 (71.7% of requirement) 9,006,169 ----16,024,836 --388,070 25,419,075 (79.31% of requirement) 152,000 152,000 (6% of requirement) 39,000 39,000 (1% of requirement) 150,000 150,000 (50% or requirement) 644,377 644,377 (50% or requirement) 1 The portfolio includes incentives or “extra credit multipliers” for early installation, for installation in Arizona, for using equipment manufacturers in Arizona, for use in “distributed” applications or various programs including green pricing, net metering, solar leasing, or customer-sited systems. Therefore the Total number of actual kWh achieved is less than the kWh credits shown in the table above. Further information can be found at http://www.cc.state.az.us/utility/electric/R14-2-1618.htm. Regulated Utility Customer Funding or System Benefit Charge Funding for Renewables The lead agency in implementing this strategy is the Arizona Corporation Commission. Regulated utilities in Arizona have utility customer funding or system benefit charge (SBC) funding to support low income, demand-side management (DSM), environment, renewables, and other programs beneficial to society. A portion of the funds is targeted to the development of renewable energy, including the support of the Environmental Portfolio Standard. System benefit charges (SBC) are funds approved by the state’s regulatory oversight body, the Arizona Corporation Commission. Further information can be found at: http://www.cc.state.az.us/utility/electric/rules-electric.htm Arizona Public Service: 2002 -- $7 million in approved spending, of which $6 million was used for renewable energy programs and technology development, and $1 million for low-income customer Chapter 12 – Pollution Prevention - 83 - Arizona Regional Haze SIP Program Title Program Description support. In addition, under the EPS program, APS collected an additional$6,571,745 for renewable energy programs in 2002. Salt River Project Customer Funding Government Purchase Requirements Consumer Education and Information Tucson Electric Power: 2002 --$3 million in approved SBC spending, of which $2 million was for renewable energy programs and $1 Million for low income and energy efficiency programs. In addition, the EPS surcharge collected $2.4 million for renewables. Salt River Project (SRP) has a SBC that supports customer assistance programs, renewable energy development and maintenance, and other programs. Since December 31, 1998, the SBC has generated approximately $123 million. In 2002, this generated $3.8 million in funding for renewable resources. In addition, SRP designated additional program funding each year and plans to continue this funding in future years. SRP customers support renewable energy programs through the SRP EarthWise Energy green pricing program. Revenues received from these premiums are used to build new renewable energy projects in the community. ARS 34-452 Arizona law requires that new state building projects over six thousand square feet follow prescribed solar design standards and that solar improvements be evaluated on the basis of life cycle costing. Such new buildings include state office buildings, school districts, community college districts and universities. These projects must include evaluation of (a) proper site orientation, (b) active and passive solar energy systems for space heating, (c) solar water heating, and (d) use of solar day-lighting devices. The life cycle costing requirements state that solar energy and energy conservation design, equipment and materials shall be used if the simple payback in energy savings is eight years or less. http://www.azleg.state.az.us/ars/34/00452.htm Million Solar Roofs program – educates consumers on solar products and encourages them to install photovoltaics on homes and businesses. The major utilities in the state operate programs to market the renewable energy they produce. APS – Solar Partners SRP- EarthWise Energy TEP-Greenwatts APS has programs to educate customers about renewable energy and energy efficiency. Examples include: Project SOL (http//:projectsol.aps.com) where customers can learn about solar power and see how they can be used to generate electricity; the APS Solar Test and Research Center (www.aps.com/solar) where customers and students are provided tours of one of the leading solar research center in the world to see and learn about the latest in solar technology; and the APS web site www.aps.com where anyone with access to the web can keep abreast of APS’ many renewable and energy efficiency programs including home energy audits and energy savings and conservation information. Net Metering SRP also has a Customer Support Group that helps with program development and evaluation, and to assist in communicating program messages to the community. The Arizona Solar Energy Industries Association operated the Solar Options in Arizona program through their hotline for consumer education. They also have homeowners’ association education program on installation of solar hot water systems. Arizona Solar Center is a website run by a non-profit offering a variety of information for consumers. Tucson Coalition for Solar – conducts an annual home tour and ongoing education on renewable energy. In 1981, the ACC adopted a net metering rule (Decision No. 52345) requiring the state’s regulated utilizes to offer net metering for renewable and cogeneration resources with the capacity of 100 kilowatts or less. Excess electricity generated by the system is purchased at each utility’s avoided cost. Further information can be found on the net metering rule at: http://www.eren.doe.gov/greenpower/netmetering/index.shtml#AZ Arizona Public Service (APS) company filed in 1994 to allow net billing of all renewable energy generators under 10kW. Net excess generation under the APS tariff is purchased at the utility’s avoided cost. Chapter 12 – Pollution Prevention - 84 - Arizona Regional Haze SIP Program Title Information Disclosure Green Pricing Program Description Tucson Electric Power Company (TEP) filed two net metering tariffs in 1996 that were revised in 2003. The first is Tariff 101which applies to all qualifying non-firm customers, and Tariff 102 applies to all qualifying firm customers. Under both tariffs, net metering is allowed for QFs whose maximum monthly usage is 100 kW or less. These tariffs are for customers who have installed either a single solar to electricity or wind to electricity conversion system of AC electrical peak capability of 10 kW or less, and meet all TEP qualifications. Excess net generation is credited to the customer’s account each billing month (when applicable), and credits may be applied throughout the calendar year. However, each January any remaining credit to the customer’s account will be zeroed out. 1996 Arizona Corporation Commission Rule R14-2-1617 ACC adopted disclosure provisions as part of the 1996 Retail Electric Competition Rules. Under the disclosure provision, all retail suppliers of electricity must disclose composition, fuel mix, and emissions characteristics upon request. http://www.cc.state.az.us/utility/electric/rules-electric.htm Arizona Public Service Solar Partners APS was the first utility in the state to develop a green energy option for its customers in 1996 with the APS Solar Partner Program. APS customers have the option to support the development of solar power in APS service territory by purchasing 15kWh of 100% solar power for $2.64 though the APS Solar Partner Program. Customers may choose as many 15 kWh blocks of solar power as they wish. The funds raised go towards the development of additional new solar power plants for APS Solar Partners. APS has installed a combination of fixed, tracking and concentrating solar technologies and will continue to install new solar power plants that are the most cost effective for our customers. www.aps.com/solarpartners Salt River Project: SRP provides a solar energy purchase option to its customers. Dubbed EarthWise Energy, SRP customers can purchase 100-watt block of solar power capacity for $3.00 per month. For more details see http://www.eren.doe.gov/greenpower/gp_munipu.html#srp Economic Incentive for Renewable Manufacturers Financial Incentives TEP Green Watts: Launched in January 2000, Green Watts is a TEP program that enables supporters to invest directly in the creation of “green” power. For each Green Watt that a customer adopts, TEP will generate 20-kilowatt hours per moth from renewable energy resources. The first Green Watt is $2.00 and each additional Green Watt is $1.50. This amount appears as a line item on a customer’s monthly statement. Every ten Green Watts that are adopted save a ton of coal per year from being used and encourages environmental conservation in Southern Arizona. 100% of the dollars raised go directly to building and maintaining renewable facilities in Arizona. http://greenwatts.com/gw_pages/gw_Home.html Arizona’s Environmental Portfolio Standard provides extra credit for Arizona solar-electric capacity that incorporates Arizona-built components. From the rules (C.2.b): In-State Manufacturing and Installation Content Extra Credit Multiplier: Solar electric power plants shall receive up to a .5 extra credit multiplier related to the manufacturing and installation content that comes from Arizona. The percentage of Arizona content of the total installed plant cost shall be multiplied by .5 to determine the appropriate extra credit multiplier. So, for instance, if a solar installation included 80% Arizona content, the resulting extra credit multiplier would be .4 (which is .8 X .5). Environmental Technology Facility Credit – Allows a personal or corporate income tax credit of 10% of the cost of construction of a qualified environmental technology manufacturing, producing or processing facility. (Source: DSIRE Database http://www.ncsc.ncsu.edu) Solar and Wind Energy System Tax Credit- ARS-43-1083, ACC R14-2-1618, Provides a personal income tax credit of 25% of the cost of a solar or wind energy device. (Source: DSIRE Database http://www.ncsc.ncsu.edu) Solar and Energy Equipment Tax Exemption – Provides a retail sales tax exemption of up to $5000 for solar and wind energy equipment. Legislation http://www-solar.mck.edu/finance/AZ08.htm (Source: DSIRE Database http://www.ncsc.ncsu.edu/dsire.htm) APS offers the APS EPS Credit Purchase program. This program provides a financial incentive to APS customers for the installation of solar electric and solar water heating systems on customer Chapter 12 – Pollution Prevention - 85 - Arizona Regional Haze SIP Program Title Program Description homes. Customers that choose to include Photovoltaic systems on their homes or businesses can receive $2.00 per watt-dc for the installation of systems up to 5 kW. In addition, APS also provides an incentive to customers that replace or supplement electric water heaters with solar water heating. Customers receive $350 for the professional installation of a new solar water heating system. APS pays these customers for opportunity to use the environmental benefits from these systems to meet its own EPS goals. Once the system is professionally installed, the customer submits the application to APS and APS pays the customer directly. http://www.aps.com/my_community/Solar/eps.html TEP SunShare: Launched in 2002, TEP’s SunShare program is designed to encourage customers to install new photovoltaic equipment at their residence or business. TEP currently offers two options for those who are interested in investing in solar. SunShare, option #1, requires that customers provide their own photovoltaic equipment while SunShare Kit, option #2, requires that customers purchase the solar equipment from TEP. Under the SunShare programs, systems of 1kW to 5kW are eligible. The customer may either purchase a qualifying system, 1kW thru 5kW, from a third party or may purchase one to five 1-kW system kits from TEP. Under SunShare, option #1, TEP will credit the customer $2,000 per AC kW of proven, installed solar generating capacity. Under the SunShare Kit, option #2, TEP will credit the customer $2,000 for each 1kW system, up to $10,000 for five systems. The kit includes panels, inverter, supports, meter, and meter socket. The retail cost for a 1 kW solar kit is approximately $9,000 plus installation costs. However, a kit purchased from TEP will cost $4000 after the $2000 credit. TEP also offers a net metering option which credits the customer with the energy sent into the grid on a kWh basis. http://greenwatts.com/gw_pages/gw_sunshare.html Table 12-3 summarizes the energy efficiency programs currently in place for Arizona. There is a long list of energy efficiency programs, including programs offered by the State Energy Office and the utilities. Summaries of the programs are provided. A few programs have listed quantification information in terms of energy savings or program expenditures; many are not quantified because this type of information is currently not available. Table 12-3. Summary of Energy Efficiency Programs in Place in Arizona Program Title Arizona Energy Office, Arizona Dept of Commerce Program Description The Energy Office’s $2.3 million annual budget is funded through a combination of federal funds and Petroleum Violation Escrow funds. Director: Craig Marks (602) 771-1139 craigm@azcomerce.com http://www.azcommerce.com?energy/default.asp 2002 Status The Energy Office’s mission is to encourage energy efficiency and renewable-energy usage, provide energy education and community outreach, offer policy advise to the Executive and Legislative branches, and help Arizona low-income residents to reduce their utility bills and improve their comfort and safety. Ref. 3,4 Low Income Weatherization The Energy Office administers Arizona’s $3 annual million (federal and private funds), low-income, weatherization program. The primary mission of this program is to reduce the energy required for space heating and cooling for income eligible households applying for assistance through one of ten sub-grantees, statewide. This program receives its primary funding from the U.S. Department of Energy and the U.S. Department of Health and Human Services. The program also leverages additional funds through partnership with utilities, 17,000 homes weatherized to date. 3 Chapter 12 – Pollution Prevention - 86 - In 2002, 695 homes were weatherized statewide, with present- value utility savings of three million dollars. In addition to approximately $2.2 million in federal funds, the utilities provided the following: 2002 Utility Funding: Arizona Regional Haze SIP Program Title Special Project Grants Program Description and other federal and state housing programs. Many aspects of the Residential Training and Technical Assistance Programs are now incorporated into the training of Weatherization sub-grantees, which assures that savings are maximized. The following are done under the program: • Adding thermal insulation to the residential building envelope, most typically attic insulation. Shading sunexposed windows, primarily for houses using central refrigeration cooling. • Implementing air leak control measures to reduce excessive infiltration of outside air. • Testing, tuning and maintaining heating and cooling equipment. • Reducing duct leakage where heating and central refrigerated air is distributed by a forced air system. • Installing low-flow showerheads and other general energy and water efficiency measures. • Other energy conservation improvements as identified by the home energy auditor. The Energy Office administers the State Energy Project – Special Project Grants. Each year states submit proposals in response to a DOE solicitation identifying how specific technologies could be implemented in their region of the country. DOE then selects the projects that best meet national energy goals. The Energy Office publicizes grant availability, helps prepare grant applications, and administers grants. The Energy Office is currently administering $2,865,375 SEP Special Project funds. Chapter 12 – Pollution Prevention - 87 - 2002 Status SW Gas $350,000 APS $302,397 TEP $180,000 Citizens $68,885 Co-ops $4,500 Total $905,782 2002 Special Project Awards $800,000 to Pinnacle West for Hydrogen Power Park $75,000 to Tucson USD for Tucson Solar Schools $100,000 for Teaching Energy Conservation Supports Implementation of Energy Codes in Tucson Metro Area and Southern Arizona Communities $25,000 for Tucson Regional Clean Cities Coordinator $48,808 to AZ Energy Office to Film New Solar in Arizona Documentary $45,000 to Energy Office for State Industries of the Future Program Federal IOF – 9 Industries Targeted to Improve Energy Efficiency and Productivity, and to Manage Waste Streams AZ IOF Chapter Will Target 4 of the Federal IOFs – Agriculture, Aluminum, Forest Products, and Mining Goal – Establish Industry, Government, University Partnerships, With MOU Executed by 2004. Arizona Regional Haze SIP Ref. Program Title ResidentialMarket Training and Technical Transfer Program Description Over 30,000 new homes are built each year in metro-Phoenix, making it one of the largest new home markets in the United States. Thousands more homes are built each year in other fastgrowing Arizona communities. Improving the energy efficiency of new homes has an enormous impact on Arizona’s energy usage. The Energy Office has long partnered with Arizona utilities to provided technical assistance and training for the building trades on the latest energy efficiency technologies and techniques, including: Infrared imaging to analyze insulation performance; Smoke generation to show duct leakage; and Using pressure diagnostics, such as the blower door testing, duct blasters, and digital monometers, to confirm envelope integrity. Overall the goal is to encourage builders and subcontractors to take a scientific systems approach to home construction and incorporate energyefficient techniques into the building process. Municipal Energy Management Program The MEMP (Municipal Energy Management Program) encourages and assists in the development and implementation of energy management programs by facilitating the planning process and providing the necessary basic tools, staff training and technical assistance. As part of MEMP, the Energy Office makes funds available for energy saving projects. Those eligible to apply include incorporated Arizona cities, towns, counties, improvement districts, and Indian tribes with populations under 70,000. 2002 Status Arizona’s largest HVAC contractor now seals all ductwork, which has saved Arizonans over $27 million in energy bills since 1997. Over the past year, in partnership with the home-building industry and Arizona utilities, the Arizona Energy Office provided 23 days of training to over 2,500 attendees from the building-trades industry. Because of the innovations and techniques brought to the market, builders have helped develop and introduce Energy Star-certified homes into the Arizona market. Energy Star is a joint program offered by the U. S. Environmental Protection Agency and the U. S. Department of Energy. Energy Star certification requires a home to be 30% more efficient than the 1995 Model Energy Code, which saves the average homebuyer approximately $400 a year. Of the 34,000 Energy Star homes built nationally in 2001, over 8,000 were built in Arizona. Arizona homebuilders are also national leaders in offering guaranteed heating and cooling costs. These homes are typically 40% to 50% more efficient than required by the 1995 Code, and have guaranteed annual heating and cooling costs of approximately $ .30 per square foot. Regional and national homebuilders now market entire subdivisions where each home comes with guaranteed energy bills. $150,000 awarded to Arizona communities in 2002 The MEMP approach to energy conservation is a simple and direct step-by-step approach. The first step is to understand where energy is being consumed and how much it costs, based on the utility bill analysis and audits. The second step identifies strategies for lowering energy costs. The third step assists in incorporating energy management into future development through an energy management plan. Chapter 12 – Pollution Prevention - 88 - Arizona Regional Haze SIP Ref. Program Title Federal Energy Management Program Market Design Initiatives Regulated Utility Customer Funding or System Benefit Charge Funding for Energy Efficiency Residential New Construction and New Home Guarantee Programs Program Description Goal: reduce the cost and environmental impact of the federal government by advancing energy efficiency and water conservation, promoting the use of distributed and renewable energy, and improving utility management decisions at federal sites. Funds are occasionally available to the Arizona Energy Office to partner with Indian communities and military bases or other federally-owned facilities Salt River Project’s M-Power is a residential prepayment program, which uses a special electric meter located outside the home, a small display unit located inside the home and smart cards, which work in a way similar to prepaid telephone calling cards. The SRP M-Power display shows how much energy is used daily and hourly, and when to buy more energy via the smart cards. With actual information on cost of consumption, customers conserve and can save as much as 10% on electric bills. At the same time, SRP reduces turn-off and turn-on costs, while improving customer satisfaction. Tucson Electric Power: 2002 --$3 million in approved SBC spending, of which $2 million was for renewable energy programs and $1 million for low income and energy efficiency programs. Arizona Public Service: 2002 - $7 million in approved spending, of which $6 million was used for renewable energy programs and technology development, and $1 million for low-income customer support and other programs. In addition, under the EPS program, APS collected an additional $6,571,745 for renewable energy programs in 2002. See also the listing in Table 12-2 under the heading Regulated Utility Customer Funding or System Benefit Charge Funding for Renewable Energy. To help promote the value of energy efficient residential construction, APS works with builders and building material vendors to provide buyers with a heating and cooling guarantee. All participating builders must offer their homebuyers a 2-year guarantee that the monthly costs to heat and cool their home will be less than a specified amount. APS has promoted the concept of guaranteed heating and cooling bills through a multi-media campaign including TV, print, on-line, and point-of-sale materials. In 1997, TEP designed and implemented the first utility operated new home guarantee program in the nation. The program philosophy addresses the Chapter 12 – Pollution Prevention - 89 - 2002 Status Ak Chin Community. This outreach was funded by thee Western Area Power Administration and FEMP. The Energy Office performed the following services for the Community: Residential Energy Audits Weatherization Training Currently four of the top ten production builders in the Phoenix metro area are participating in the program and over 3500 home lots have been committed. Since inception to December 2002, there were 5590 homes either completed, in some progress of completion or waiting for Arizona Regional Haze SIP Ref. Program Title New Construction Energy Efficiency Research and Training Program Description issues of affordability, durability, comfort, health and safety using scientific laws of airflow, moisture-flow and pressure management within a home. Homes are constructed to high standards set by TEP and include on-site inspections of framing areas related to energy performance, insulation installation, and HVAC system design and installation. On-site testing is also provided to measure duct leakage, whole-house infiltration and pressure management within the home under various operating conditions. If a home passes all inspection and testing criteria, the homeowner receives a guarantee from TEP that heating and cooling costs will not exceed a predetermined average cost per day (calculated on each separate model home) and a guarantee for comfort for a preset time period. Homes permitted prior to February 20, 2003 receive a 3-year guarantee and homes permitted after February 20, 2003 receive a 5-year guarantee. Homeowners who purchase a TEP Guarantee home qualify for a specially designed rate-tariff that reduces the cost of all electricity used in the home by 12% annually compared to the standard residential electric rate. The homeowners also have the option to increase this electric rate savings to either 18% or 22% depending on their selection of TOU and/or the installation of solar water heating systems. In partnership with the Arizona Energy Office, APS has conducted extensive research and testing on new residential construction with blower doors, duct blasters, infrared cameras, and other diagnostic tools. The result of these tests is a list of building construction details that need the most focus to improve home performance. In 1998, APS and the Arizona Energy Office began offering Building Science training for residential builders. 2002 Status construction to begin. The program is operated within the utility structure with quality control provisions and the guarantee provided by a utility. All TEP Guarantee Homes qualify for ENERGY STAR since the qualifications from TEP are more stringent than ENERGY STAR. TEP provides the DOE/EPA program documents to customers along with the Guarantee certification. In 1998, APS and the Arizona Energy Office began offering Building Science training for residential builders. To date, over 2000 building industry members have attended. Coupled with the heating/cooling guarantee program, this has resulted in substantial improvements in the real world performance of residential new construction as confirmed through field studies by the Arizona Energy Office. TEP hosts quarterly education programs to target audiences of builders, sub-contractors, and city/county code officials, architects and consumers. These programs are designed to educate all audiences on the scientific approach of building new homes or retrofitting existing homes to gain the maximum benefit in affordability, durability, comfort and health and safety. TEP also adds matching funds for grants provided to the City of Tucson ‘Teaching Energy Conservation’ project which educates consumers, builders, contractors, consumers and code officials on various conservation related issues. The SRP-Certified Home (SCH) program was introduced in May 1995. For a subdivision to be Chapter 12 – Pollution Prevention - 90 - Between 1999 and 2002, approximately Arizona Regional Haze SIP Ref. Program Title Qualified Contractor Program High Efficiency Appliance Programs Program Description SRP certified, SRP works directly with the builder to ensure that each home design meets our energyefficiency standards. SRP certification means the home design includes certain energy-efficient features. Certification is based on the SRPCertified Homes Point Sheet that primarily is a construction specification trade-off system. With the system, one design feature may be substituted for another if the overall design complies with the SRP-Certified Home energy consumption standard. Between 1999 and 2002, approximately 21,000 SCH contracts were signed. In 2002 SRP announced a new addition to the SRPCertified Home program. Energy Code Compliance certification is now available upon request. SRP can provide REM/Design compliance reports for 1998/2000 International Energy Conservation Codes (IECC), CABO Model Energy Code (MEC), and ASHRAE 90.2 By adding the new "Code Compliance" feature to the program we can now assist builders in meeting the energy efficiency codes required by the various municipalities. APS offers referrals to customers seeking qualified, professional HVAC contractors for service or replacement of their existing AC/heat pumps. To qualify for the program, residential HVAC contractors are required to meet stringent requirements and complete ongoing rigorous APS education courses for their service technicians. APS High Efficiency Air Conditioners Program For several years APS has worked with the air conditioner contractor community. This partnership has been instrumental in moving the market for resale air conditioners and heat pumps to high efficiency equipment. Evidence suggests that the resale market is about 90% 12 SEER, which is 15% more efficient than standard equipment, reducing demand and energy consumption. SRP Rebates on Highly-Efficient Refrigerators and Heat Pumps – Over the last several years, SRP has independently offered customers rebates on highly efficient refrigerators and heat pumps. Time of use rates 2002 Status 21,000 SCH contracts were signed. To date, APS has subsidized technical training for over 6000 service technicians. APS currently provides free contractor referrals to approximately 4000 customers each year, ensuring that units are properly serviced and installed. Since 1998, APS and contractors have distributed over 20,000 copies of the Consumer’s Guide to an Energy Efficient Air Conditioning System as an education tool for customers. SRP has issued more than 8,500 rebates on refrigerators labeled by ENERGY STAR® as exceeding federal standards and more than 1,000 rebates on heat-pumps with a 13-SEER rating that also meet additional strict criteria. APS Time of use rates - Approximately 40% of all residential customers are on a time of use rate. It is one of the highest penetrations of TOU rates in the country. APS is one of the only utilities nationwide to offer a demand rate for residential customers. Most new APS customers apply for one of the two Chapter 12 – Pollution Prevention - 91 - Arizona Regional Haze SIP Ref. Program Title Peak Reduction Campaign Shade Trees Campaign Program Description TOU rates. Evidence suggests it reduces demand and shifts load. A recent survey of customers indicates that over 75% of TOU customers do shift some of their energy use to off-peak time periods. Customers feel it gives them control over their electric bill and helps conserve peak energy. 2002 Status Ref. SRP has approximately 140,000 customers on our peak-load shifting program, Time-of-Use (TOU). Residential TOU customers average 75% off-peak usage annually, while non-TOU residential customers average 72% - 73% off-peak usage annually. The result of TOU is that SRP has been successful in shifting 2%-3% of our average annual energy consumption to off-peak. Commercial Peak Reduction Campaign -- Since the summer of 2001, APS has promoted a voluntary summer peak energy management initiative with commercial customers. Participating customers pledge to save energy on extreme summer days when temperatures exceed 110 degrees in Phoenix. Customers receive an email on “Peak Power Days” asking them to turn thermostats up two degrees, turn off unnecessary lights and equipment, and adjust the schedule of energy-intensive processes. The campaign has helped shave peak consumption and heightened awareness of the need to save energy on extreme summer days. The TEP Trees Program promotes energy conservation and the environmental benefits associated with planting low-water usage trees and other vegetation. Desert-adapted trees have been provided to residential neighborhoods, low-income families, public areas and schools by TEP. The residential trees are to be located on the south, west and east sides of homes in the TEP service area with the objective of continuing positive community service as well as providing DemandSide Management (“DSM”) benefits. Residential Program: There were 3,000 trees distributed to roughly 1,500 homes for the period January 1, 2002 through December 31, 2002. School and Community Programs: For the period January 1, 2002 through December 31, 2002, this program provided 105 fifteen-gallon-sized and 41 five-gallon-sized trees to 43 schools. In addition, 63 community projects received 115 fifteen-gallonsized and 111 five-gallon-sized trees. Chapter 12 – Pollution Prevention - 92 - Arizona Regional Haze SIP Program Title Energy Efficiency Education Program Description APS provides a free on line energy analysis on aps.com. It allows customers and prospective customers to analyze their home and business energy use and identify customized energy efficient measures. APS provides seasonal energy savings tips online and in customer bill inserts. 2002 Status Ref. SRP Energy Savings Solutions Campaign Energy Savings Solutions (ESS) is a multi-media campaign, which runs from May through September. The goal of ESS is to educate customers about effective energy management. ESS provides customers with useful and easy ways to lower their energy usage and enables customers to make informed decisions everyday by demonstrating how home energy conservation efforts can help reduce energy costs. Energy Star Energy Efficiency Audits TEP provides free class sets of booklets to schools in its area, including, "Learning to Save Energy", which is geared to grades 3-5. TEP also offers teacher training and back up materials for two hands-on activities: The Insulation Station (which deals with residential energy issues) and The Energy Patrol (where a class or group of students learn about energy efficiency, and then try to "patrol" their school, helping remind others how to save energy). TEP also provides seasonal energy tips on-line and in mailings to customers and handouts at presentations. Customer Education on Purchasing Decisions SRP has been an ENERGY STAR® partner since 1999. This DOE/EPA program establishes stricter efficiency criteria for new products. As a partner, SRP has been able to not only increase awareness of ENERGY STAR, but also to provide information for customers so that they can make informed purchase decisions. This information has been incorporated into our monthly newsletters and our Energy Savings Solutions campaign and has also been heavily featured in on-going publications to both residential and commercial customers via Powerful Solutions and eNews. For approximately the last two years, SRP has been working with third party contractors and other entities such as the Arizona Department of Commerce to provide free or low cost energy efficiency audits and educational programs to energy consumers in the commercial, industrial and government sectors. The focus of the programs to date has been on high-efficiency lighting retrofits, energy information services, and improvements to compressed air systems. Chapter 12 – Pollution Prevention - 93 - Arizona Regional Haze SIP Program Title State Energy Efficiency Demonstration Program State Facility Managers Training Program Energy Efficient Schools State Energy Code Governor’s Awards for Energy Efficiency Program Description TEP offers the Energy Advisor, a quick, free, online analysis of a home's or business's monthly energy use, as well as suggestions on how to reduce energy costs. Working with the Department of Administration and agency facility managers, the Energy Office provides training, technical assistance and funding to implement energy savings and demand-reduction measures in state-controlled facilities. Matching grant program. Based on results of the forensic audits and utility tracking, the Energy Office provides training and technical assistance to state facility management staff with the goal of identifying actions that may be taken to decrease electricity consumption in state facilities. This training will assist facility managers in performing diagnostics on their facilities, complete retrofits on equipment and buildings, and track energy consumption. Energy Office partnership with School Facilities Board. A jointly funded engineer works with architects and vendors to incorporate cost-effective, energy-efficient designs and equipment. Energy audits of existing facilities are also available. HB 2541 (2001) Is a voluntary model energy code (AZ=home rule). This bill designates the State Energy Code as a legislative tool to create incentives for the use of energy saving devices and practices. It established a State Energy Code Advisory Commission to review and recommend changes to the State Energy Code. http://www.azleg.state.az.us/legtext/44leg/2r/bills/h b2451p/pdf The Energy Office recognizes local governments, state agencies, and educational institutions for exceptional energy-conservation accomplishments. 2002 Status Ref. Ongoing. Ongoing. Significant opportunities have been found in replacement of HVAC package units, lighting retrofits, and central heating and cooling systems, for a total avoided energy costs of $8,916,197 per year. Energy Code Advisory Commission. Code Advisory Commission members were appointed. First meetings held by the Energy Office to provide technical support to Arizona municipalities In 2001, the Energy Office applied for and received a $100,000 grant from the U. S. Department of Energy to build on the legislative initiative and to initiate an outreach and training program for municipalities, governmental entities, code officials, and the building industry on codes and the impact on Arizona’s energy consumption. In 2002, Energy Office efforts on codes are being concentrated in the areas of 1) codes adoption, and 2) training provided to the building industry designed to help insure that structures designed to code will also perform as designed. The 2002 Governor's Awards for Energy Efficiency were presented to Arizona cities, educational institutions and state government agencies in recognition of successful energy conservation programs. Awards of Excellence, the highest honor, went to the City of Bullhead City, Arizona School Facilities Board, Mesa Unified School District and the Tucson Unified School District. Chapter 12 – Pollution Prevention - 94 - Arizona Regional Haze SIP 1 Program Title Program Description 2002 Status Ref. The City of Tucson received Awards of Merit for two energy-saving projects. Awards of Merit were also given to the City of Coolidge, Arizona Department of Administration, Arizona Department of Public Safety and the Arizona Department of Game and Fish. The Arizona Department of Emergency and Military Affairs received Awards of Merit for two energy-conservation projects. Rebuild America Green Buildings Leadership in Energy & Environmental Design (LEED) Utility Tracking U.S. D.O.E. Program supported by Arizona Energy Office. - Helps businesses and communities reduce energy use in buildings. Green buildings are use design and construction practices that significantly reduce or eliminate the negative impact of buildings on the environment The concept includes: - Sustainable site planning - Safeguarding water and water efficiency - Energy efficiency and renewable energy - Conservation of materials and resources - Indoor environmental quality This program facilitates positive results for the environment, occupant health and financial return. It defines “green” by providing a standard for measurement, prevents false or exaggerated claims, and promotes whole-building, and integrated design process. LEEDS evaluated and recognizes performance in accepted green design categories, existing and proven technologies. There are four levels of certification. Developed by the Energy Office for entities with multiple accounts (e.g., schools, municipalities, large businesses). Uses Microsoft Excel to track utility usage by meter. Captures data from utility’s web site. The program identifies problems, and raises questions. Chapter 12 – Pollution Prevention - 95 - In addition, Awards of Special Recognition were bestowed on the City of Tucson, Arizona Department of Administration, Arizona Department of Emergency and Military Affairs, Isaac Elementary School District and the Scottsdale Unified School District. The City of Mesa and the City of Phoenix both received Awards of Special Recognition for two energy-saving projects. http://www.azcommerce.com/Energy/eaward. htm Ongoing. Energy-efficiency seminar presented to Arizona school officials in September 2002. City of Scottsdale Green Building Program. This is weighted rating checklist that emphasizes a system’s approach by requiring 26 prerequisites. Established in 1998, 47 builders, 129 homes constructed by 2002. http://www.ci.scottsdale.az.us/greenbuilding/ Southern Arizona Green Building Alliance (in progress) This green building program is in its infancy and details are still being determined Contact Loretta Ishida, The Development Center of Appropriate Technology (520) 6246628 Loretta@dcat.net, http://www.dcat.net April Green Building Forum – sponsored by Phoenix, Scottsdale and Surprise. New capital mall buildings including Arizona Department of Environmental Quality and Department of Administration buildings built in 2002. Ongoing. 1 2 1 1 Arizona Regional Haze SIP Program Title National Industries of the Future Industrial Assessment Centers Income Subtraction for Construction of an Energy Efficient Residence Building America Governor’s Smart Energy Usage Program Program Description Administered by Department of Energy – Office of Industrial Technologies 9 Industries targeted that together supply 90% of the materials vital to US economy. The 9 industries are: agriculture, aluminum, chemicals, forest products, glass, metal casting, mining, petroleum, and steel. Goal: Promote energy efficiency and manage waste streams. Administered by DOE, OIT Enables eligible small and medium-sized manufacturers to have comprehensive industrial assessments performed at no cost to the manufacturers. Teams of engineering faculty and students from the center, located at 26 universities around the country, conduct energy audits, or industrial assessment and provide recommendations to manufacturers to help them identify opportunities to improve productivity, reduce waste, and save energy. For taxable years beginning from and after December 31, 2001, through December 31, 2010, Arizona law (A.R.S. 43-1031) allows a subtraction for a residence that is 50% more efficient than the 1995 Model Energy Code (MEC). The subtraction is allowed for selling one or more new energy efficient residences located in Arizona. The subtraction is equal to 5% of the sales price excluding commissions, taxes, interest, points, and other brokerage, finance and escrow charges. The subtraction cannot exceed $5,000 for each new qualifying residence. A home’s energy efficiency must be demonstrated by a score of at least 90 points (indicating that the home is 50% better than the MEC threshold) on a home energy rating. A Certified Home Energy Rater must provide the home energy rating. Building America is a private/public partnership that provides energy solutions for production housing. The Energy Office assists in disseminating the results of this effort to the Arizona market place. "Conservation saves money, which makes sense during tight budget times. And decreased energy production saves water, which makes sense during a drought. These two reasons provide more-thanenough motivation to conserve this summer," Arizona Governor Jane Dee Hull said when announcing the Smart Energy: Phase II program for summer 2002. As a result of the success of the 2001 campaign, Governor Hull ordered all agencies under her Chapter 12 – Pollution Prevention - 96 - 2002 Status Arizona Industries of the Future being developed by Energy Office with D.O.E grant. 4 industries targeted - Agriculture - Aluminum - Forest Products - Mining Ref. 1 Recommendations from industrial assessments have averaged about $55,000 in potential annual savings for each manufacturer ASU operates one of the 28 National Centers Director: Dr. Patrick E. Phelan (480) 965-1625 phelan@asu.edu 1 Ongoing 4 Ongoing 4 The Smart Energy campaigns of 2001 and 2002 require state agencies to set thermostats up two degrees to save energy. As a result it is estimated that these conservation efforts reduced energy usage from 7 to 10 percent and saved the state $115,000 in utility bills during the summer of 2001 The campaign also called upon Arizonans to do their part. "Two Degrees - No Sweat” encouraged Arizonans to save energy by raising thermostats two degrees. 4 Arizona Regional Haze SIP Program Title Program Description jurisdiction to take a number of energy-saving steps for the second summer in a row. The Governor also asked that state residents voluntarily comply with the "Arizona Smart Energy: Phase II" program. 2002 Status Ref. As part of the Smart Energy: Phase II program, the Governor asked all state employees to implement the following energy saving measures: • Every agency will use power management tools like Energy Star to keep computers, monitors and other devices in stand-by mode when not in use. • Employees will turn off lights and office equipment, as much as possible, when they expect to be out of the office for more than one hour. • Agencies will reduce all lighting that does not affect productivity, health or safety. • Thermostats in all state-controlled facilities, will be increased during the months of June through September by two degrees or brought within the 76-79 degrees F range, whichever is greater. • Agencies will implement a professional, casual-dress policy from June through September, consistent with the type of work being performed. 1 Presentation by Craig Marks, of the Arizona Energy Office, Department of Commerce, to the Pollution Prevention Workgroup, July 26, 2002. 2 “Summary of Green Building Programs,” Prepared for National Renewable Energy Laboratory, by National Association of Home Builders Research Center, Second Edition, August 2002. 3 U.S Department of Energy, Office of Building, Technology, State & Community Projects, http://www.eere.energy.gov/buildings/state_energy/ 4 Arizona Department of Commerce, Energy Office, http://www.azcommerce.com/Energy/default.asp The regional haze rule and the 10/20 goals look ahead to future years. While not specifically required, Arizona is providing the following Table 12-4 on renewable energy capacity that is planned as of 2002 to provide information on projects that are in the planning stages and have the potential to provide additional renewable energy capacity in the future. Table 12-4. Planned Renewable Energy Capacity as of 2002 Program Title Program Description Ref. Land fill Gas Pipeline Project This is a partnership with Salt River Project, Detroit Edison and Salt River Pima Maricopa Indian Community. The pipeline is between Salt River and Tri-Cities Landfills. It extends the fuel supply to the Tri-Cities Landfill Gas Generation Plant. Facility is expected to be commissioned in the second quarter of 2004 This SRP sponsored project will generate 750 kW. It has roof mounted solar placed on the turbine building. Facility is to be commissioned in second quarter of 2003. 1 Arizona Falls Project Chapter 12 – Pollution Prevention - 97 - Arizona Regional Haze SIP 1 Program Title Program Description Ref. Mesa City Library Photovoltaic Parking SRP Park & Ride Photovoltaic This is a 25kW system with covered parking for 34 spaces. Provides green energy for SRP Earthwise Energy customers. Project is expected to be completed May 2003. 1 This SRP sponsored project is for a 100kW PV system on parking structures. The PV system is expected to be complete in July 2003. It also has a goal to increase public awareness of renewable energy. 1 APS Prescott Airport Solar Power Plant APS Prescott Airport Solar Power Plant - Prescott – 5 MW projected in 3 yrs (possibly expandable to 10 MW), This is currently the largest single axis tracking system in the state and is expected to become the largest PV site in the country consisting of both single axis tracking and concentrating PV technologies. APS is building a 1MW demonstration solar thermal trough project that will be tested for performance compared to photovoltaic technologies. 10 Units ordered for test once the technology demonstrates performance and price characteristics that exceed photovoltaics. There a two 3 MW and one 70 kW landfill gas opportunities being explored by APS. Additionally, new technologies including for generating electricity from methane are being explored including reciprocating engines and micro turbines. APS is exploring wind opportunities as they become available and demonstrate financial viability. Biogas - Possible opportunities being explored by APS include Water Treatment Plant (6 MW) and Bovine Power (2 MW) using an anaerobic digestion process to convert animal waste into biogas which can the be used to generate electricity. APS is beginning evaluation of technology for potential future installation in SE AZ (10 MW). 2 APS is Exploring the development of Plasma gasification, waste wood (3 MW) biomass opportunities to extract energy from the waste wood resulting from forest management processes due to the State’s extended draught and the bark beetle infestation. As of December 2002, TEP has 2.4 MW solar capacity installed at the Springerville Generating Station in Eastern Arizona. By the end of 2003, the Springerville facility will have 3.5MW of capacity and TEP will have 4MW of capacity overall. 2 APS Solar Trough APS Dish Stirling tests APS Landfill Gas to Energy APS Wind APS Biogas APS Geothermal APS Biomass Springerville Solar Generating Station 1 “Overview of SRP’s Renewable Energy Program,” Presentation by Herjinder Hawkins to PPWG on March 24, 2003. 2 “Renewable Energy Opportunities in Arizona,” Presentation by Cassius McChesney to PPWG on June 2002. 3 “Statewide Economic Study 2002 – Arizona’s Energy Infrastructure,” Prepared for the Arizona’s Department of Commerce by Rebecca Holmes, SRP, and Craig Marks, ACC, September 2002, p. 13. 12.4. Inventory of All Renewable Energy Generation Capacity and Production in Arizona Pursuant to 40CFR 51.309 (d)(8)(i), Table 12-5 summarizes all renewable energy generation capacity and production in use or planned as of 2002 (expressed in MW and MWh). Appendix A-12b entitled Details of Renewable Energy Generation and Capacity contains a detailed inventory of existing and currently planned renewable energy production projects and their references. Chapter 12 – Pollution Prevention - 98 - Arizona Regional Haze SIP 2 2 2 2 2 2 3 Table 12-5. Summary of Renewable Energy Generation Capacity and Production Categories Solar Methane Wind Wood Chips Low-Impact Hydro TOTAL Existing Capacity Existing & Planned Total Production in 2002 Capacity as of 2002 in 2002 (MW) (MW) (MWh) 6.222 6.733 10,579.764 9.500 9.570 63,715.000 0 0 0 0 3.000 0 0 0.750 0 15.722 20.053 74,294.764 The total electric-energy production in the State of Arizona for 2000 was 89,101,000 megawatthours. (Energy Information Administration). The approximate percentage of renewable electric energy generated in 2002 was 0.08%. Generation capacity as of 2002 is summarized in Table 12-6. Table 12-6. Summary of Arizona’s Total Energy Generation Capacity and Production19 Rank Operator Plant Name Fuel MW Percent 1 Arizona Public Service Company Palo Verde Uranium 3,730 19.2% 2 Salt River Project Navajo (SRP)20 Coal 2,255 11.6% 3 U.S. Bureau of Reclamation Glen Canyon Water 1,300 6.7% 4 Pinnacle West Redhawk Units 1 and 2 Gas 1,060 5.4% 5 U.S. Bureau of Reclamation Hoover AZ Water 1,042 5.4% 6 Arizona Public Service Company Cholla Coal 995 5.1% 7 Tucson Electric Power Co Springerville Coal 800 4.1% 8 Salt River Project Coronado Coal 760 3.9% 9 Duke Energy North America Griffith Energy Project Gas 620 3.2% 10 Salt River Project Agua Fria Gas 619 3.2% 11 Duke Energy North America Arlington Valley Gas 570 2.9% 12 Arizona Electric Power Cooperative Apache Coal/Gas 560 2.9% 13 Reliant Energy Power Gene Desert Basin Gas 560 2.9% Total, Top 13 Plants 14,871 76% Balance of State 4,581 Arizona Total 19,412 MW Sources: Statewide Economic Study 2002, Arizona Energy Infrastructure, Prepared for the Arizona Department of Commerce, September 2002, pg. 7. Second Biennial Transmission Assessment, 2002-2011, Arizona Corporation Commission, P Plus Corporation, December 2002, pg. 107-124 12.5. Summary of Anticipated Renewable Energy Contribution The approximate percentage of renewable electric energy generated in Arizona for 2002 was 0.08%. Generation capacity as of 2002 is summarized in Table 12-6 above. Pursuant to 40CFR 51.309 (d)(8)(i), Appendix A-12b entitled of this SIP summarizes the State of Arizona’s anticipated contribution toward meeting the GCVTC renewable energy goals for 2005 and 2015. Also see Section 12.10, below. 19 20 Based on summertime generating capacity. This facility is on tribal lands (Navajo Nation). Chapter 12 – Pollution Prevention - 99 - Arizona Regional Haze SIP 12.6. Incentive Programs Pursuant to 40CFR 51.309 (d)(8)(ii), Table 12-7 below identifies incentive programs in the State of Arizona that reward efforts to go beyond compliance and/or achieve early compliance with air pollution related requirements. Table 12-7. Summary of Arizona’s Incentive Programs Program Title Market Trading Western Backstop SO2 Trading Program Early Reduction Credits Western Backstop SO2 Trading Program Renewable Energy Credits Program Description Arizona has opted into the Section 309 regional SO2 “cap-and-trade program”, as outlined in the Annex, under the Regional Haze Rule. As further described in Section C1.1 of the stationary source provisions of this plan, industrial sources of SO2 subject to the trading program which, upon verification by the State, reduce emissions to levels below their floor amount prior to the program trigger date shall receive additional emission allowances. Such allowances may be used by the source for compliance purposes or may be sold to other parties, hence, providing an incentive for sources to go beyond compliance (i.e., their floor) or to achieve early compliance (i.e., reductions prior to the program trigger date). As further described in Section C1.1 of the stationary source provisions of this plan, allowances shall be provided to the owners of renewable energy facilities installed since October 1, 2000. Such allowances will hold a market value and therefore provide an incentive for power suppliers to invest in renewable energy facilities with zero or very low air pollutant emissions. 12.7. Programs to Preserve and Expand Energy Conservation Efforts Pursuant to 40 CFR 51.309 (d)(8)(iii), Table 12-8 identifies programs in Arizona that preserve and expand energy conservation efforts. Table 12-8. Programs that Preserve and Expand Energy Conservation in Arizona Program Title Program Description Energy Conservation in State Buildings Legislation passed in 2003 requires that state agencies (the Department of Administration and Transportation and the Board of Regents) reduce energy use by 10 percent by July 1, 2008 and 15 percent by July 1, 2011. Purchase of Energy Star Projects by State Agencies Preserve and Expansion Description: This program will expand energy efficiency activities of state agencies. Industry projections for savings from implementation of this measure are projected to be $11 million per year by 2011, with $90 million of cumulative energy efficiency savings over the period 2004-2015. Legislation passed in 2003 requires all state agencies to purchase products certified as Energy Star or certified under FEMP in all categories unless the products is shown not to be cost effective on a life cycle cost basis. Preserve and Expansion Description: State agencies already purchase some products that are Energy Star certified. This program will expand existing energy efficient equipment purchase and have a long-term effect on energy use by state agencies. School districts and all political subdivisions can also purchase these energy star products off of the state contacts, which could further increase the impact of this program. Chapter 12 – Pollution Prevention - 100 - Arizona Regional Haze SIP Program Title Program Description Regulated Utility Customer Funding or System Benefit Charge Funding for Energy Efficiency Residential New Construction and New Home Guarantee Programs Tucson Electric Power: 2002 --$3 million in approved SBC spending, of which $2 million was for renewable energy programs and $1 million for low income and energy efficiency programs. Arizona Public Service: 2002 - $7 million in approved spending, of which $6 million was used for renewable energy programs and technology development, and $1 million for low-income customer support and other programs. In addition, under the EPS program, APS collected an additional $6,571,745 for renewable energy programs in 2002. See also the listing in Table 12-2 under the heading Regulated Utility Customer Funding or System Benefit Charge Funding for Renewable Energy. To help promote the value of energy efficient residential construction, APS works with builders and building material vendors to provide buyers with a heating and cooling guarantee. All participating builders must offer their homebuyers a 2-year guarantee that the monthly costs to heat and cool their home will be less than a specified amount. Currently four of the top ten production builders in the Phoenix metro area are participating in the program and over 3500 home lots have been committed. APS has promoted the concept of guaranteed heating and cooling bills through a multi-media campaign including TV, print, on-line, and point-of-sale materials. In 1997 TEP designed and implemented the first utility operated new home guarantee program in the nation. The program philosophy addresses all of the issues of affordability, durability, comfort, health and safety using scientific laws of airflow, moisture-flow and pressure management within a home. Homes are constructed to high standards set by TEP and include on-site inspections of framing areas related to energy performance, insulation installation, and HVAC system design and installation. Onsite testing is also provided to measure duct leakage, whole-house infiltration and pressure management within the home under various operating conditions. If a home passes all inspection and testing criteria, the homeowner receives a Guarantee from TEP that heating and cooling costs will not exceed a predetermined average cost per day (calculated on each separate model home) and a guarantee for comfort for a pre-set time period. Homes permitted prior to February 20, 2003 receive a 3-year guarantee and homes permitted after February 20, 2003 receive a 5-year guarantee. Homeowners who purchase a TEP Guarantee home qualify for a specially designed rate-tariff that reduces the cost of all electricity used in the home by 12% annually compared to the standard residential electric rate. The homeowners also have the option to increase this electric rate savings to either 18% or 22% depending on their selection of TOU and/or the installation of solar water heating systems. There are currently over 5500 homes either completed, in some progress of completion or waiting for construction to begin. The program is operated within the utility structure with quality control provisions and the guarantee provided by a utility. All TEP Guarantee Homes qualify for ENERGY STAR since the qualifications from TEP are more stringent than ENERGY STAR. TEP provides this DOE/EPA program documents to customers along with the Guarantee certification. The SRP-Certified Home (SCH) program was introduced in May 1995. For a subdivision to be SRP certified, SRP works directly with the builder to ensure that each home design meets our energyefficiency standards. SRP certification means the home design includes certain energy-efficient features. Certification is based on the SRP-Certified Homes Point Sheet that primarily is a construction specification trade-off system. With the system, one design feature may be substituted for another if the overall design complies with the SRP-Certified Home energy consumption standard. Between 1999 and 2002, approximately 21,000 SCH contracts were signed. New Construction Energy Efficiency In 2002 SRP announced a new addition to the SRP-Certified Home program. Energy Code Compliance certification is now available upon request. SRP can provide REM/Design compliance reports for 1998/2000 International Energy Conservation Codes (IECC), CABO Model Energy Code (MEC), and ASHRAE 90.2 By adding the new "Code Compliance" feature to the program we can now assist builders in meeting the energy efficiency codes required by the various municipalities. In partnership with the Arizona Energy Office, APS has conducted extensive research and testing on new residential construction with blower doors, duct blasters, infrared cameras, and other diagnostic tools. The result of these tests is a list of building construction details that need the most focus to improve home performance. In 1998, APS and the Arizona Energy Office began offering Building Chapter 12 – Pollution Prevention - 101 - Arizona Regional Haze SIP Program Title Program Description Research and Training Science training for residential builders. To date, over 2000 building industry members have attended. Coupled with the heating/cooling guarantee program, this has resulted in substantial improvements in the real world performance of residential new construction as confirmed through field studies by the Arizona Energy Office. Qualified Contractor Program High Efficiency Appliance Programs Time of use rates TEP hosts quarterly education programs to target audiences of builders, sub-contractors, and city/county code officials, architects and consumers. These programs are designed to educate all audiences on the scientific approach of building new homes or retrofitting existing homes to gain the maximum benefit in affordability, durability, comfort and health and safety. TEP also adds matching funds for grants provided to the City of Tucson ‘Teaching Energy Conservation’ project which educates consumers, builders, contractors, consumers and code officials on various conservation related issues. APS offers referrals to customers seeking qualified, professional HVAC contractors for service or replacement of their existing AC/heat pumps. To qualify for the program, residential HVAC contractors are required to meet stringent requirements and complete ongoing rigorous APS education courses for their service technicians. To date, APS has subsidized technical training for over 6000 service technicians. APS currently provides free contractor referrals to approximately 4000 customers each year, ensuring that units are properly serviced and installed. APS High Efficiency Air Conditioners Program For several years APS has worked with the air conditioner contractor community. This partnership has been instrumental in moving the market for resale air conditioners and heat pumps to high efficiency equipment. Evidence suggests that the resale market is about 90% 12 SEER, which is 15% more efficient than standard equipment, reducing demand and energy consumption. Since 1998, APS and contractors have distributed over 20,000 copies of the Consumer’s Guide to an Energy Efficient Air Conditioning System as an education tool for customers. SRP Rebates on Highly-Efficient Refrigerators and Heat Pumps – Over the last several years, SRP has independently offered customers rebates on highly efficient refrigerators and heat pumps. SRP has issued more than 8,500 rebates on refrigerators labeled by ENERGY STAR® as exceeding federal standards and more than 1,000 rebates on heat-pumps with a 13-SEER rating that also meet additional strict criteria. APS Time of use rates - Approximately 40% of all residential customers are on a time of use rate. It is one of the highest penetrations of TOU rates in the country. APS is one of the only utilities nationwide to offer a demand rate for residential customers. Most new APS customers apply for one of the two TOU rates. Evidence suggests it reduces demand and shifts load. A recent survey of customers indicates that over 75% of TOU customers do shift some of their energy use to off-peak time periods. Customers feel it gives them control over their electric bill and helps conserve peak energy. SRP has approximately 140,000 customers on our peak-load shifting program, Time-of-Use (TOU). Residential TOU customers average 75% off-peak usage annually, while non-TOU residential customers average 72% - 73% off-peak usage annually. The result of TOU is that SRP has been successful in shifting 2%-3% of our average annual energy consumption to off-peak. Peak Reduction Campaign TEP has approximately 7,700 customers on our peak-load shifting program, Time-of-Use (TOU). Residential TOU customers average 80% off-peak usage annually, while non-TOU residential customers average 77% - 78% off-peak usage annually. The result of TOU is that TEP has been successful in shifting 2%-3% of our average annual energy consumption to off-peak. Commercial Peak Reduction Campaign -- Since the summer of 2001, APS has promoted a voluntary summer peak energy management initiative with commercial customers. Participating customers pledge to save energy on extreme summer days when temperatures exceed 110 degrees in Phoenix. Customers receive an email on “Peak Power Days” asking them to turn thermostats up two degrees, turn off unnecessary lights and equipment, and adjust the schedule of energy-intensive processes. The campaign has helped shave peak consumption and heightened awareness of the need to save energy on extreme summer days. Chapter 12 – Pollution Prevention - 102 - Arizona Regional Haze SIP Program Title Program Description Shade Trees Campaign The TEP Trees Program promotes energy conservation and the environmental benefits associated with planting low-water usage trees and other vegetation. Desert-adapted trees have been provided to residential neighborhoods, low-income families, public areas and schools by TEP. The residential trees are to be located on the south, west and east sides of homes in the TEP service area with the objective of continuing positive community service as well as providing Demand-Side Management (“DSM”) benefits. Residential Program: There were 3,000 trees distributed to roughly 1,500 homes for the period January 1, 2002 through December 31, 2002. School and Community Programs: For the period January 1, 2002 through December 31, 2002, this program provided 105 fifteen-gallon-sized and 41 five-gallon-sized trees to 43 schools. In addition, 63 community projects received 115 fifteen-gallon-sized and 111 five-gallon-sized trees. APS provides a free on line energy analysis on aps.com. It allows customers and prospective customers to analyze their home and business energy use and identify customized energy efficient measures. Approximately 30,000 customers have used this service since 2001. APS offers an energy answer line service to answer questions about home energy efficiency. This service receives about 6000 calls per year. APS provides seasonal energy savings tips online and in customer bill inserts. Energy Efficiency Education SRP Energy Savings Solutions Campaign Energy Savings Solutions (ESS) is a multi-media campaign, which runs from May through September. The goal of ESS is to educate customers about effective energy management. ESS provides customers with useful and easy ways to lower their energy usage and enables customers to make informed decisions everyday by demonstrating how home energy conservation efforts can help reduce energy costs. Energy Star Energy Efficiency Audits Pre-Pay Program Arizona Energy Office, Arizona Dept of Commerce TEP provides free class sets of booklets to schools in its area, including, "Learning to Save Energy", which is geared to grades 3-5. TEP also offers teacher training and back up materials for two handson activities: The Insulation Station (which deals with residential energy issues) and The Energy Patrol (where a class or group of students learn about energy efficiency, and then try to "patrol" their school, helping remind others how to save energy). TEP also provides seasonal energy tips on-line and in mailings to customers and handouts at presentations. Customer Education on Purchasing Decisions SRP has been an ENERGY STAR® partner since 1999. This DOE/EPA program establishes stricter efficiency criteria for new products. As a partner, SRP has been able to not only increase awareness of ENERGY STAR, but also to provide information for customers so that they can make informed purchase decisions. This information has been incorporated into our monthly newsletters and our Energy Savings Solutions campaign and has also been heavily featured in on-going publications to both residential and commercial customers via Powerful Solutions and eNews. For approximately the last two years, SRP has been working with third party contractors and other entities such as the Arizona Department of Commerce to provide free or low cost energy efficiency audits and educational programs to energy consumers in the commercial, industrial and government sectors. The focus of the programs to date has been on high-efficiency lighting retrofits, energy information services, and improvements to compressed air systems. TEP offers the Energy Advisor, a quick, free, online analysis of a home's or business's monthly energy use, as well as suggestions on how to reduce energy costs. SRP has approximately 31,000 customers on our pre-pay program, M-Power. M-Power customers have reduced their energy consumption by 10% on average. This energy conservation is due to the intensive educational information provided by the program and the discipline required from the customer. M-Power is the largest program of its kind in North America. The Energy Office’s $2.3 million annual budget is funded through a combination of federal funds and Petroleum Violation Escrow funds. Director: Craig Marks (602) 771-1139 craigm@azcomerce.com Chapter 12 – Pollution Prevention - 103 - Arizona Regional Haze SIP Program Title Low Income Weatherization Special Project Grants ResidentialMarket Training and Technical Transfer Municipal Energy Management Program Federal Energy Management Program State Energy Efficiency Demonstration Program State Facility Managers Training Program Program Description http://www.azcommerce.com?energy/default.asp The Energy Office administers Arizona’s $3 annual million (federal and private funds), low-income, weatherization program The primary mission of this program is to reduce the energy required for space heating and cooling for income eligible households applying for assistance through one of ten sub-grantees, statewide. This program receives its primary funding from the U.S. Department of Energy and the U.S. Department of Health and Human Services. The program also leverages additional funds through partnership with utilities, and other federal and state housing programs. Many aspects of the Residential Training and Technical Assistance Programs are now incorporated into the training of weatherization sub-grantees, which assures that savings are maximized. The Energy Office administers the State Energy Project – Special Project Grants. Each year states submit proposals in response to a DOE solicitation identifying how specific technologies could be implemented in their region of the country. DOE then selects the projects that best meet national energy goals. The Energy Office publicizes grant availability, helps prepare grant applications, and administers grants. The Energy Office is currently administering $2,865,375 SEP Special Project funds. Over 30,000 new homes are built each year in the harsh desert environment of metro-Phoenix, making it one of the largest new home markets in the United States. Thousands more homes are built each year in other fast-growing Arizona communities. Improving the energy efficiency of new homes has an enormous impact on Arizona’s energy usage. The Energy Office has long partnered with Arizona utilities to provided technical assistance and training for the building trades on the latest energy efficiency technologies and techniques, including: Infrared imaging to analyze insulation performance; Smoke generation to show duct leakage; and Using pressure diagnostics, such as the blower door testing, duct blasters, and digital monometers, to confirm envelope integrity. Overall the goal is to encourage builders and subcontractors to take a scientific systems approach to home construction and incorporate energy-efficient techniques into the building process. The MEMP (Municipal Energy Management Program) encourages and assists in the development and implementation of energy management programs by facilitating the planning process and providing the necessary basic tools, staff training and technical assistance. As part of MEMP, the Energy Office makes funds available for energy saving projects. Those eligible to apply include incorporated Arizona cities, towns, counties, improvement districts, and Indian tribes with populations under 70,000. The MEMP approach to energy conservation is a simple and direct step-by-step approach. The first step is to understand where energy is being consumed and how much it costs, based on the utility bill analysis and audits. The second step identifies strategies for lowering energy costs. The third step assists in incorporating energy management into future development through an energy management plan. Goal: reduce the cost and environmental impact of the federal government by advancing energy efficiency and water conservation, promoting the use of distributed and renewable energy, and improving utility management decisions at federal sites. Funds are occasionally available to the Arizona Energy Office to partner with Indian communities and military bases or other federally-owned facilities Working with the Department of Administration and agency facility managers, the Energy Office provides training, technical assistance and funding to implement energy savings and demand-reduction measures in state-controlled facilities. Matching grant program. Based on results of the forensic audits and utility tracking, the Energy Office provides training and technical assistance to state facility management staff with the goal of identifying actions that may be taken to decrease electricity consumption in state facilities. This training will assist facility managers in performing diagnostics on their facilities, complete retrofits on equipment and buildings, and track Chapter 12 – Pollution Prevention - 104 - Arizona Regional Haze SIP Program Title Energy Efficient Schools State Energy Code Governor’s Awards Rebuild America Green Buildings Leadership in Energy & Environmental Design (LEED) Utility Tracking National Industries of the Future Industrial Assessment Centers Income Subtraction for Construction of an Energy Efficient Residence Building America Program Description energy consumption. Energy Office partnership with School Facilities Board. A jointly funded engineer works with architects and vendors to incorporate cost-effective, energy-efficient designs and equipment. Energy audits of existing facilities are also available. HB 2541 (2001) Is a voluntary model energy code (AZ=home rule). This bill designates the State Energy Code as a legislative tool to create incentives for the use of energy saving devices and practices. It established a State Energy Code Advisory Commission to review and recommend changes to the State Energy Code. The Energy Office recognizes local governments, state agencies, and educational institutions for exceptional energy-conservation accomplishments. U.S. D.O.E. Program supported by Arizona Energy Office help businesses and communities reduce energy use in buildings. Green buildings are use design and construction practices that significantly reduce or eliminate the negative impact of buildings on the environment The concept includes: - Sustainable site planning - Safeguarding water and water efficiency - Energy efficiency and renewable energy - Conservation of materials and resources - Indoor environmental quality This program facilitates positive results for the environment, occupant health and financial return. It defines “green” by providing a standard for measurement, prevents false or exaggerated claims, and promotes whole-building, and integrated design process. LEEDS evaluated and recognizes performance in accepted green design categories, existing and proven technologies. There are four levels of certification. Developed by the Energy Office for entities with multiple accounts (e.g., schools, municipalities, large businesses). Uses Microsoft Excel to track utility usage by meter. Captures data from utility’s web site. The program identifies problems, and raises questions. Administered by Department of Energy – Office of Industrial Technologies Nine industries targeted that together supply 90% of the materials vital to US economy. The 9 industries are: agriculture, aluminum, chemicals, forest products, glass, metal casting, mining, petroleum, and steel. Goal: Promote energy efficiency and manage waste streams. Administered by DOE, OIT Enables eligible small and medium-sized manufacturers to have comprehensive industrial assessments performed at no cost to the manufacturers. Teams of engineering faculty and students from the center, located at 26 universities around the country, conduct energy audits, or industrial assessment and provide recommendations to manufacturers to help them identify opportunities to improve productivity, reduce waste, and save energy. For taxable years beginning from and after December 31, 2001, through December 31, 2010, Arizona law (A.R.S. 43-1031) allows a subtraction for a residence that is 50% more efficient than the 1995 Model Energy Code (MEC). The subtraction is allowed for selling one or more new energy efficient residences located in Arizona. The subtraction is equal to 5% of the sales price excluding commissions, taxes, interest, points, and other brokerage, finance and escrow charges. The subtraction cannot exceed $5,000 for each new qualifying residence. A home’s energy efficiency must be demonstrated by a score of at least 90 points (indicating that the home is 50% better than the MEC threshold) on a home energy rating. A Certified Home Energy Rater must provide the home energy rating. Building America is a private/public partnership that provides energy solutions for production housing. The Energy Office assists in disseminating the results of this effort to the Arizona market place. Chapter 12 – Pollution Prevention - 105 - Arizona Regional Haze SIP Program Title Program Description Governor’s Smart Energy Usage Program "Conservation saves money, which makes sense during tight budget times. And decreased energy production saves water, which makes sense during a drought. These two reasons provide more-thanenough motivation to conserve this summer," Arizona Governor Jane Dee Hull said when announcing the Smart Energy: Phase II program for summer 2002. As a result of the success of the 2001 campaign, Governor Hull ordered all agencies under her jurisdiction to take a number of energy-saving steps for the second summer in a row. The Governor also asked that state residents voluntarily comply with the "Arizona Smart Energy: Phase II" program. As part of the Smart Energy: Phase II program, the Governor asked all state employees to implement the following energy saving measures: - Every agency will use power management tools like Energy Star to keep computers, monitors and other devices in stand-by mode when not in use. - Employees will turn off lights and office equipment, as much as possible, when they expect to be out of the office for more than one hour. - Agencies will reduce all lighting that does not affect productivity, health or safety. - Thermostats in all state-controlled facilities will be increased during the months of June though September by two degrees or brought within the 76-79 degree range whichever is greater. - Agencies will implement a professional, casual-dress policy from June through September, consistent with the type of work being performed. 12.8. Potential for Renewable Energy Pursuant to 40CFR 51.309 (d)(8)(iv), the State of Arizona has made an assessment of areas where there is the potential for renewable energy to supply power in a cost-effective manner. This section summarizes the findings of this assessment beginning with a review of the geographic distribution of renewable energy potential contained in Figures 12-1 through 12-4. Chapter 12 – Pollution Prevention - 106 - Arizona Regional Haze SIP Figure 12-1. Map of Arizona Solar Photovoltaic Resources Chapter 12 – Pollution Prevention - 107 - Arizona Regional Haze SIP Figure 12-2. Map of Arizona Concentrating Solar Power Resources Chapter 12 – Pollution Prevention - 108 - Arizona Regional Haze SIP Figure 12-3. Map of Arizona Biomass Energy Resources Chapter 12 – Pollution Prevention - 109 - Arizona Regional Haze SIP Figure 12-4. Map of Arizona Collocated Geothermal Energy Resources Chapter 12 – Pollution Prevention - 110 - Arizona Regional Haze SIP Arizona is not blessed to the same degree with wind resources as Montana, geothermal resources as Nevada, or the hydroelectric resources of the northwest. However, Arizona has renewable energy resources that have yet to be tapped. A consortium of business, government and academic institutions are actively evaluating the state’s wind resources. Initial data suggest that commercial-scale wind resources may exist in the state on developable lands. The cost of utility scale wind installations has dropped dramatically in the past decade resulting in a robust new wind industry. Between 2000 and 2001, wind generated installations doubled in capacity and in 2001 alone, 1,700 MW of wind were installed in the U.S. Depending on the wind resource and local, state and federal subsidies, costs are equal to or nearing the cost of generating electricity with conventional fuels. Projects are underway to evaluate or develop electricity generation projects in two areas of the state. In addition, large reserves of geothermal resources are available for direct use, hot water applications. Renewable resource development is site specific, dependent on access, and availability of transmission, land ownership issues and economics of developing the known resource. In terms of renewable energy resources, Arizona leads the nation in potential solar-energy resources. Solar electric generating plants cost much more than plants that employ conventional technologies. Large natural gas-fired, combined-cycle plants can be built for approximately six-hundred dollars per kilowatt, while the best solar technologies are still estimated to cost at least six to ten times as much. Figure 12-5. Projected Cost of Solar Energy Technologies Projected Cost of Energy from Solar Energy Technologies - 2000 c/kWh ($1997 - levelized) 40 35 30 25 20 15 10 5 Central Receiver Dish - Hybrid Utility Thin Film Trough PV - Residential Concentrator Source: DOE/EPRI Source: WRAP AP2 Renewables, “Recommendations of the Air Pollution Prevention Forum to Increase Generation of Electricity from Renewable Energy Resources,” p. I-13. Chapter 12 – Pollution Prevention - 111 - Arizona Regional Haze SIP Table 12-9. Cost Estimates of Solar Options Technology Plant Size (MW) Cost ($Million) Parabolic Trough 50 200 Power Tower 15 60 Dish Engine 1 6 Photovoltaic 1 6 Concentrating Photovoltaic 1 6 Organic Rankine Cycle Trough 1 <5 Source: Presentation by Dr. Peter Johnson, Arizona Public Service Company, June 2002 Cost per kilowatt 4,000 4,000 6,000 6,000 6,000 <5,000 Balanced against the higher capital costs of solar technologies are lower operation and maintenance costs. Fuel is the most expensive component of conventional power generation; sunlight is free. However, a conventional plant can be called on (dispatched) at any time, while solar plants can operate only while the sun is out and generation will be reduced on cloudy days. Because electricity cannot be stored cost effectively, the inability to dispatch the plant is a significant drawback to solar and wind-powered generation. Overall, solar electric generation cannot compete yet with conventional plants on pure economics. But solar generation requires no imported fuel, produces no air emissions, and consumes no water. Further, like any newer technology, it is expected that costs will come down as economies of scale are realized and production techniques improve. Finally, solar and other renewable generation have cost-effective applications in remote areas where it may be too expensive to extend a power line. For example, solar energy is being used to provide electricity for landfills, ranches, rural streetlights, emergency phones, and entire homes. Solar water heating can be cost effective even in urban areas, particularly in competition with electric water heating. Overall, the next ten years should see substantially increased penetration of solar and other renewable resources into Arizona’s generation mix. Figure 12-5. Projected Cost of Renewable Energy Technologies Projected Cost of Energy from Renewable Energy Technologies - 2000 c/kWh ($1997 - levelized) 9 8 7 6 5 4 3 2 1 Conv. Biomass Wind (Class 4) Flash Geothermal Adv. Biomass Wind (Class 6) Binary Geothermal Source: WRAP AP2 Renewables, “Recommendations of the Air Pollution Prevention Forum to Increase Generation of Electricity from Renewable Energy Resources,” p. I-13. Chapter 12 – Pollution Prevention - 112 - Arizona Regional Haze SIP 12.9. Projections of Renewable Energy Goals, Energy Efficiency, and Pollution Prevention Activities Pursuant to 40CFR 51.309 (d)(8)(v), projections have been made by the WRAP of the short and long term emissions reductions, visibility improvements, cost savings, and secondary benefits associated with “renewable energy goals, energy efficiency and pollution prevention activities.” A complete description of the WRAP projections is contained in the report ICF Assessment of Renewable Energy and Energy Efficiency Programs included as Appendix A-12c. Projections of visibility improvements for the 16 Class I areas on the Colorado Plateau are provide in Section 14.2. These projections include the combined effects of all measures in this SIP, including air pollution prevention programs. Although emission reductions and visibility improvements from air pollution prevention programs are expected at some level, they were not explicitly calculated because the resolution of the regional air quality modeling system is not currently sufficient to show any significant visibility changes resulting from the marginal nitrogen oxide emission reduction described above for air pollution prevention programs. Details of the modeling methodology are contained in the WRAP TSD in Chapter 8 entitled, “Assessment of Pollution Prevention.” 12.10. Programs to Achieve GCVTC Renewable Energy Goal Pursuant to 40 CFR 51.309 (d)(8)(vi), the programs relied upon by the State of Arizona to demonstrate progress in achieving the renewable energy goal of the GCVTC that renewable energy comprise 10 percent of the regional power needs by 2005 and 20 percent by 2015 are the environmental portfolio standard, and the utility customer funding or system benefit charge funding for renewables in addition to the other programs that are listed in Table 12-2. The approximate percentage of renewable electric energy generated in Arizona for 2002 was 0.08%. Generation capacity as of 2002 is summarized in Table 12-6 above. Appendix A-12b entitled Details of Renewable Energy Generation and Capacity provides additional information on the programs relied upon by Arizona to meeting the 10/20 regional goals. Appendix A-12c entitled ICF Assessment of Renewable Energy and Energy Efficiency Program, contains the regional modeling assessment performed by WRAP on the potential economic and visibility impacts associated with achieving the 10/20 regional goals. Section 12.8, above, contains an assessment of the potential for renewable energy resources. 12.11. Future Progress Reports Pursuant to 40 CFR 51.309 (d)(8)(vi), the State of Arizona commits to submit progress reports in 2008, 2013 and 2018, describing the State’s contribution toward meeting the GCVTC renewable energy goals. This description will be consistent with Section 12.9 above. To the extent that is not feasible for the State to meet its contribution to these goals, the State commits to identify measures that were implemented to achieve its contribution, and explain why meeting its contribution was not feasible. Chapter 12 – Pollution Prevention - 113 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 12 – Pollution Prevention - 114 - Arizona Regional Haze SIP 13. OTHER GCVTC RECOMMENDATIONS 13.1. Regulatory History and Requirements The recommendations of the GCVTC are presented throughout the June 1996 final report with varying degrees of specificity. Not all are included in the Regional Haze Rule. However, some of the recommendations were intended as a menu of options, with no expectation that any geographic area would implement all of them. The GCVTC pointed out in its final report that: 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. [BOLD emphasis in original] 13.2. Other Long-term Strategy Components (a) Evaluation of additional Grand Canyon Visibility Transport Commission recommendations. Pursuant to 40 CFR 51.309(d)(9), the State of Arizona has evaluated the “additional” recommendations of the Grand Canyon Visibility Transport Commission, to determine if any of these recommendations can be practicably included in this SIP. The State of Arizona reviewed the Commission's 1996 report, Recommendations for Improving Western Vistas, to identify those recommendations that were not incorporated into Section 309 of the Regional Haze Rule. This evaluation is described in Appendix A13a of this SIP. (b) Implementation of Additional Recommendations. The State of Arizona has identified those additional strategies that have been implemented at the national, regional, state, and local levels. Based on the evaluation made by the State of Arizona, as described in Appendix A-13a, no additional measures have been identified as being practicable or necessary to demonstrate reasonable progress at this time. The State of Arizona will re-evaluate the status of implementation of additional recommendation in future plan revisions required under 40 CFR 51.309(d)(10). 13.3. Sources In and Near GCVTC Class I Areas Pursuant to 40 CFR 51.309(d)(9), the SIP must provide for implementation of all other recommendations in the Commission report that can be practicably included as enforceable emission limits, schedules of compliance or other enforceable measure to make reasonable progress toward remedying existing and preventing future regional haze in the GCVTC Class I areas. The GCVTC report also recognizes the importance of visibility issues related to emission sources in and near Class I areas and includes recommendations regarding emissions within and near these areas. In addition, the GCVTC recommendations for road dust include actions contained in the “In and Near” section of the report to address the control or reduction of emissions related to road dust. The State of Arizona has in place existing strategies to address the requirements of 40 CFR 51.309(d)(9) for area sources of dust. The State of Arizona commits to the evaluation of sources of dust in and near the GCVTC Class I areas and will develop and implement controls as necessary to Chapter 13 – Other GCVTC Options - 115 - Arizona Regional Haze SIP demonstrate reasonable progress toward the national goal in future SIP revisions as required under 40 CFR 51.309(d)(10). The State of Arizona continues to address the impact of road dust and other dust sources at the Colorado Plateau Class I areas and has reviewed, with the help of Federal Land Managers (FLMs) with knowledge of the Grand Canyon National Park, Mt. Baldy Wilderness Area, Petrified Forest National Park, and Sycamore Canyon Wilderness Area, the type of localized sources of dust that may affect visibility in and near these four areas. Descriptions of the Class I areas and summaries of the observational and quantitative information provided by the Federal Land Managers to the Arizona Regional Haze SIP Dust Management Work Group are found below and in Appendix A-13b, Tables 1 through 4. In addition, in-and-near micro-inventories are being developed by the WRAP for the four Arizona Class I areas within the 16 GCVTC Class I areas. Further, the Dust Emissions Joint Forum is endeavoring to determine the affects of both regionally and near-field wind-blown dust. This work fulfills the need identified by the GCVTC to develop accurate emission inventories and air quality modeling to determine appropriate emission control strategies from road dust and other dust sources for each Class I area. 13.3.1. Grand Canyon National Park The Grand Canyon National Park encompasses 1,218,375 acres of the Colorado River canyon and adjacent uplands. This natural preserve is under the jurisdiction of the U.S. National Park Service. Intensive visitor use is confined to relatively small areas on the North and South rims, while most of the park is remote and primitive. Large areas of Forest Service, Tribal, and private lands surround the Park. A summary of emission information for sources of dust within and near the Grand Canyon area is contained in Appendix A-13b, Table 1, including information for paved and unpaved roads and wind generated emissions. 13.3.2. Mt. Baldy Wilderness Area The Mt. Baldy Wilderness is located in the White Mountains along the southern edge of the Colorado Plateau and comprises 7,079 acres pine and fir forest on the northeastern flank of Mt. Baldy. The Wilderness and areas to the east are primarily under the jurisdiction of the Apache-Sitgreaves National Forest. Tracts of State and private land are also included in this multi-use region. Areas to the west are under the jurisdiction of the Fort Apache Indian Reservation. The FLM survey of dust sources includes information on seasonal recreational access roads. A summary of emission information for the Mt. Baldy area is found in Appendix A-13b, Table 2. 13.3.3. Petrified Forest National Park The Petrified Forest National Park covers 93,533 acres of grasslands and high desert plateau. State, Tribal, and private land are adjacent to the Park. The FLM survey of potential sources of dust in this popular preserve includes information on wind generated emissions. A summary of emission information for the Petrified Forest area is found in Appendix A-13b, Table 3. Chapter 13 – Other GCVTC Options - 116 - Arizona Regional Haze SIP 13.3.4. Sycamore Canyon Wilderness The Sycamore Canyon Wilderness area comprises 55,937 acres of pine and fir forest on the Colorado Plateau and extends southwest, ending at the desert mouth of sycamore creek in the Verde Valley. The wilderness and surrounding area is primarily under the jurisdiction of the Prescott, Coconino, and Kaibab National Forests. Areas of State, Tribal, and private lands are also located near the Wilderness. The FLM survey of potential sources of dust in this recreational area includes information on wind generated emissions. A summary of emission information for the Sycamore Canyon area is found in Appendix A-13b, Table 4. Chapter 13 – Other GCVTC Options - 117 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 13 – Other GCVTC Options - 118 - Arizona Regional Haze SIP 14. PROJECTION OF VISIBILITY IMPROVEMENT The Western Regional Air Partnership (WRAP) performed extensive data gathering and modeling to determine the impact of the regional haze program on visibility at the 16 GCVTC Class I areas on the Colorado Plateau. The WRAP work effort began with development of a regional comprehensive inventory of emissions for all categories of sources. In addition, econometric models and new technology profiles were used to project changes in emissions over time expected from implementation of current requirements under the Clean Air Act (CAA). The WRAP also estimated emission changes resulting from the programs contained in the long-term strategy for regional haze under 40 CFR 51.309. The emission inventories and projections were then used by the WRAP Regional Modeling Center to estimate aerosol concentrations and visibility changes at each of the 16 Class I areas using the Community Multi-scale Air Quality (CMAQ) model to estimate aerosol concentrations from the emission inventories and projections. The WRAP results are contained in the WRAP Technical Support Document (WRAP TSD) and include detailed descriptions of the emission inventory and projection methods, as well as the air quality modeling techniques and results (see WRAP TSD Chapter 1). The projection of expected visibility changes are contained in Chapter 2 of the WRAP TSD. The following sections contain an overview of the resultant projected changes in emissions and visibility resulting from the implementation of the Regional Haze Rule. 14.1. Effect on Emissions of Long-term Strategy Components 14.1.1. Inventory Methodology and Scope The WRAP 1996 base emission inventories used for assessment of visibility included the following pollutants: • Volatile Organic Compounds (VOCs); • Oxides of Nitrogen (NOX); • Carbon Monoxide (CO); • Sulfur Dioxide (SO2); • Particulate Matter smaller than 10 microns (PM10); • Particulate Matter smaller than 2.5 microns (PM2.5); and, • Ammonia (NH3). For visibility modeling, the PM2.5 emission inventory was broken down into components, or species, representing the key visibility impairing species of interest. Breaking down the PM2.5 into its components is necessary since each component has a different effect on visibility. These PM2.5 species are organic carbon particles, elemental carbon particles, and other fine material (soils and dusts). The factors used to allocate PM2.5 into its components are based on source-specific speciation factors. In addition, the coarse material (CM) fraction of PM10 (i.e., PM10 minus PM2.5) was also computed, since course particulate matter has a different effect on visibility than fine particulate matter. The geographic domain for the inventory included the 22 states west of the Mississippi River, and portions of Mexico and Canada. The inventory included emissions from the following categories of sources: • Area Sources; • Stationary Point Sources; Chapter 14 – Projection of Visibility - 119 - Arizona Regional Haze SIP • • • • Mobile Sources (both on-road and non-road); Road Dust (both from paved and unpaved road surfaces); Fire Emissions (agricultural burning, prescribed fire, and wildfire); and, Biogenic Sources. In addition to the 1996 base year emission inventory used for model validation, a projected base year emission inventory for the year 2018 was developed from the base 1996 inventory and other information related to growth and technology issues, but excluding expected changes from control strategies required by the Regional Haze Rule. This 2018 base case emission inventory was then modified to reflect the impact of the control strategies required by the Regional Haze Rule. This is referred to as “Scenario 2” in the WRAP TSD, and are referred to as “2018 w/309” in the tables below. The ADEQ established an Emission Inventory Work Group (EIWG) made up of key Arizona stakeholders to assist with the review of WRAP’s emission inventory for Arizona’s SIP sources. This review was performed in two parts. First, the EIWG reviewed the WRAP’s 1996 base emission inventory, comparing estimates with other Arizona reference inventories used for non-attainment SIPs. The EIWG’s findings were summarized in a memorandum to WRAP (see Appendix A-14a). The EIWG concluded that the 1996 inventory was adequate for current Regional Haze SIP modeling, but identified several areas that should be addressed in future WRAP emission inventory improvement projects. Second, the EIWG reviewed the 2018 emission growth/projection factors used to develop the 2018 inventory. This review included an analysis of accuracy of earlier projections, such as the growth factors used in the GCVTC Integrated Assessment System, and more recent projections performed by the Arizona Department of Economic Security, U.S. Census Bureau data, and forecasts prepared by the metropolitan planning organizations. Although differences were found, the EIWG concluded that the long-range forecast factors were within the level of uncertainty in any long-range economic forecast. Areas for future improvement of the WRAP inventory projections were summarized in a memorandum to WRAP (also in Appendix A-14a). In addition to the EIWG, ADEQ also established the Technical Assessment Work Group (TAWG) to review the assessment and modeling methodologies used by the WRAP. The TAWG reviewed the WRAP TSD and identified areas for future improvements in a memorandum to WRAP (also in Appendix A-14a). 14.1.2. Projected Changes in Emissions for Arizona The projected change in emissions for the State of Arizona are summarized in Table 14-1. As shown, emissions of sulfur dioxide are expected to decrease by 36% by 2018. In addition, by 2018 emissions of oxides of nitrogen and volatile organic compounds are expected to decline by 16% and 25%, respectively. Table 14-2 shows similar emission reductions for the nine-state GCVTC Transport Region. Appendix A-14b, Tables 1 through 3, provide more detailed summaries of emissions by source category, including emissions estimates for the 2018 WRAP Base Case. Also, Appendix A-14b, Table 4, summarizes the detailed county-level emission for Arizona. Information in Appendix A-14b were derived from WRAP county-level emission inventories contained in the WRAP TSD emission appendices. Chapter 14 – Projection of Visibility - 120 - Arizona Regional Haze SIP Table 14-1. Changes in Emissions from 1996 to 2018 for Arizona Sources (Tons per Year) Year PM2.5* CM SO2 NOx 147.9 98.8 217.9 454.0 1996 143.3 103.6 139.3 383.2 2018 w/309 % Change -3% 5% -36% -16% * PM2.5 includes organic carbon, elemental carbon, and fine soils/dusts. VOC 372.3 277.8 -25% Table 14.2. Changes in Emissions from 1996 to 2018 for 9 GCVTC States (Tons per Year) CM SO2 NOx Year PM2.5* 1,196.7 1,170.6 1,036.3 3,952.1 1996 1,228.3 1,198.4 808.9 2,691.8 2018 w/309 % Change 3% 2% -22% -32% * PM2.5 includes organic carbon, elemental carbon, and fine soils/dusts. VOC 3,325.3 2,339.2 -30% 14.2. Projected Changes in Visual Air Quality 14.2.1. Applicable Class I Areas This projection of visibility improvement addresses the 16 Class I areas of the Colorado Plateau, as defined in 40 CFR 51.309(b)(1) that are described in Chapter 3 of the WRAP TSD. 14.2.2. Projected visibility improvement Pursuant to 40 CFR 51. 309(d)(2), Tables 14-3 and 14-4 indicate the projected visibility conditions in deciviews for each of the 16 Class I areas, from the baseline emission projection year of 1996 through December 31, 2018. These projections were made for the 20% worst days and 20% best days, and are expressed in deciviews (dV). The first column represents the best estimate of actual visibility conditions in 1996. Because the IMPROVE monitoring network was significant expanded from 1999 through 2001, the actual visual air quality values in the first column represent the most recent and representative five years of monitoring data from 1997 through 2001. The second column represents the expected conditions in 2018 without the implementation of the strategies and programs contained in this SIP. The final column represents the expected conditions in 2018 with the implementation of this SIP strategies and programs. Chapter 2 and Appendix A of the WRAP TSD describe the control strategies included in the air quality modeling projections. Chapter 14 – Projection of Visibility - 121 - Arizona Regional Haze SIP Table 14-3. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018 on the Average 20% Worst Days, resulting from implementation of “All 309 Control Strategies”. State 1996 - 20% Worst Days’ Visibility (dV) (Base Case) 2018 - 20% Worst Days’ Visibility (dV) (Base Case - all controls “on the books” as of 2002) 2018 - 20% Worst Days’ Visibility (dV) (All §309 Control Strategies including Optimal Smoke Management) AZ 12.30 11.62 11.51 AZ 14.30 12.22 11.96 AZ 13.00 11.99 11.74 AZ 15.40 11.63 11.48 CO 11.30 10.90 10.60 CO 10.50 11.04 10.73 CO 10.60 11.15 10.84 CO 13.10 12.24 11.84 Weminuche Wilderness CO 10.60 11.19 10.84 West Elk Wilderness CO 11.30 11.08 10.72 San Pedro Parks Wilderness NM 10.70 12.33 11.71 Arches National Park UT 12.10 12.41 12.15 UT 11.80 12.26 11.95 UT 12.10 12.41 12.18 UT 12.10 12.51 12.36 UT 13.60 12.13 12.03 Colorado Plateau Class I Area Grand Canyon National Park Mount Baldy Wilderness Petrified Forest National Park Sycamore Canyon Wilderness Black Canyon of the Gunnison NP Wilderness Flat Tops Wilderness Maroon Bells Wilderness Mesa Verde National Park Bryce Canyon National Park Canyonlands National Park Capitol Reef National Park Zion National Park Chapter 14 – Projection of Visibility - 122 - Arizona Regional Haze SIP Table 14-4. Projected Visibility Improvement at the 16 Colorado Plateau Class I Areas in 2018, on the Average 20% Best Visibility Days, resulting from implementation of “All 309 Control Strategies”. 2018 - 20% Best Days’ Visibility (dV) (All §309 Control Strategies including Optimal Smoke Management) State 1996 - 20% Best Days’ Visibility (dV) (Base Case) 2018 - 20% Best Days’ Visibility (dV) (Base Case - all controls “on the books” as of 2002) AZ 4.80 4.76 4.64 AZ 5.50 5.49 5.36 AZ 6.50 5.18 5.10 AZ 6.30 4.85 4.75 CO 4.60 3.89 3.75 CO 3.10 3.96 3.81 CO 3.10 3.90 3.80 CO 5.50 4.40 4.33 Weminuche Wilderness CO 3.10 3.89 3.74 West Elk Wilderness CO 4.60 3.97 3.82 NM 4.00 5.59 5.36 UT 5.50 4.85 4.61 UT 4.30 3.91 3.89 UT 5.60 4.87 4.67 UT 5.60 4.85 4.75 UT 5.90 3.81 3.75 Colorado Plateau Class I Area Grand Canyon National Park Mount Baldy Wilderness Petrified Forest National Park Sycamore Canyon Wilderness Black Canyon of the Gunnison NP Wilderness Flat Tops Wilderness Maroon Bells Wilderness Mesa Verde National Park San Pedro Parks Wilderness Arches National Park Bryce Canyon National Park Canyonlands National Park Capitol Reef National Park Zion National Park Chapter 14 – Projection of Visibility - 123 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 14 – Projection of Visibility - 124 - Arizona Regional Haze SIP 15. STATE PLANNING/INTERSTATE COORDINATION AND TRIBAL IMPLEMENTATION 15.1. Participation in Regional Planning and Coordination Pursuant to 40 CFR 51.309(d)(11), the State of Arizona has participated in regional planning and coordination with other states in developing its emission reduction strategies under 40 CFR 51.309, related to protecting the 16 Class I areas of the Colorado Plateau. This participation was through Arizona’s leadership of the Grand Canyon Visibility Transport Commission (GCVTC) and participation in the Western Regional Air Partnership (WRAP). The State of Arizona has provided staff in leadership positions of many of the WRAP committees and forums, and encourages participation of Arizona stakeholders in the WRAP process. The State of Arizona has been nominated to assume the position of Co-chair of the WRAP and will continue to participate actively in WRAP activities. In order to coordinate implementation issues associated with this SIP, the State of Arizona will serve on the recently established “309 Coordinating Committee” of the WRAP. This standing committee is chartered to perform the necessary implementation tracking for the states and tribes submitting SIPs and TIPs to address the requirements of 40 CFR 51.309. 15.2. Applicability to Tribal Lands Pursuant to 40 CFR 51.309(d)(12), and in accordance with the Tribal Authority Rule (63 FR 7253, February 12, 1998), all Tribes have the option to develop a regional haze Tribal Implementation Plan (TIP) for their lands to assure reasonable progress in the 16 Class I areas of the Colorado Plateau. As such, no provisions of this SIP are applicable to tribal lands. Chapter 15 – Coordination - 125 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 15 – Coordination - 126 - Arizona Regional Haze SIP 16. PERIODIC IMPLEMENTATION PLAN REVISION (a) Periodic Progress Reports for demonstrating Reasonable Progress. Pursuant to 40 CFR 51.309(d)(10)(i), the State of Arizona commits to submit to EPA periodic progress reports for the years 2008, 2013 and 2018. The demonstration may be conducted by the WRAP, with assistance from Arizona, and shall address the elements listed under 40 CFR 51.309(d)(10)(i)(A) through (G) for the Colorado Plateau areas: 1. 2. 3. 4. 5. 6. 7. Implementation status of this SIP’s measures; Summary of emissions reductions; Assessment of the 20% most/least impaired days; Analysis of emission reductions by pollutant; Analysis of significant changes in anthropogenic emissions; Assessment of this SIP’s adequacy; and Assessment of visibility monitoring strategy. (b) Actions to be taken concurrent with Periodic Progress Reports. Pursuant to 40 CFR 51.309(d)(10)(ii), the State of Arizona commits to take one of the following actions based upon information contained in each periodic progress report: 1. Provide a negative declaration statement to EPA saying that no SIP revision is needed if reasonable progress is being made, in accordance with section (a) above; 2. If the State finds that the SIP is inadequate to ensure reasonable progress due to emissions from outside the State, the State of Arizona commits to notify EPA and the other contributing state(s), and initiate efforts through a regional planning process to address the emissions in question. The State of Arizona commits to identify in the next progress report the outcome of this regional planning effort, including any additional strategies that were developed to address the plan’s deficiencies; 3. If the State finds that the SIP is inadequate to ensure reasonable progress due to emissions from another country, the State of Arizona commits to notify EPA and provide information on the impairment being caused by these emissions; or 4. If the State finds that the SIP is inadequate to ensure reasonable progress due to emissions from within Arizona, the State of Arizona commits to develop additional strategies to address the plan deficiencies and revise the SIP no later than one year from the date that the progress report was due. Chapter 16 – Plan Revisions - 127 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 16 – Plan Revisions - 128 - Arizona Regional Haze SIP 17. DECLARATION OF TREATMENT FOR ADDITIONAL CLASS I AREAS UNDER 40 CFR 51.309(g) The requirements for reasonable progress for Additional Class I areas are discussed on page 35758 in the Preamble to the RHR. Section 309 of the RHR requires that the first SIP due by December 31, 2003 address the 16 Class I areas of the Colorado Plateau. Additional Class I areas do not need to be addressed until December 31, 2008. 40 CFR 51.309(g)(1) requires states to declare in the SIP due by December 31, 2003 whether the Additional Class I areas will be addressed under 40 CFR 51.308, or under 40 CFR 51.309(g). a. Declaration for Additional Class I areas. Pursuant to 40 CFR 51.309(g)(1), the State of Arizona commits to submittal of a SIP supplement under 40 CFR 51.309(g) for the eight Additional Class I areas in the State of Arizona. Arizona shall submit the SIP revision for the eight Additional Class I areas as early as practicable, but no later than December 31, 2008. The eight Additional Class I areas in Arizona that will be addressed under 40 CFR 51.309(g) include: Chiricahua National Monument and Chiricahua, Galiuro, Mazatzal, Pine Mountain, Saguaro, Sierra Ancha, and Superstition Wilderness Areas. These Additional Class I areas are shown in Figure 17-1. Figure 17-1 Arizona Additional non-GCVTC Class I Areas. Chapter 17 – Additional Class I Areas - 129 - Arizona Regional Haze SIP The State of Arizona, if necessary to address reasonable progress for non-GCVTC Additional Class I areas outside of Arizona, will rely the procedures under 40 CFR 51.309(g)(2) and (3) and submit a SIP revision by December 31, 2008, to address reasonable progress for any such areas. Chapter 17 – Additional Class I Areas - 130 - Arizona Regional Haze SIP 18. PUBLIC PARTICIPATION AND REVIEW PROCESS Public participation and review process documents for the rulemakings described in this SIP can be located in the appendix for the related chapter in which those rules are references (e.g., for the RAVI rule see Chapter 5; for WEB trading program rule see Chapter 7; and, for the fire rules see Chapter 10). This chapter contains the public participation and review process documents associated with the SIP only. 18.1. Public Hearing Notice Notices of the public hearings were published in The Arizona Republic (Phoenix and statewide), The Arizona Daily Star and Tucson Citizen (Tucson Newspapers), and the Arizona Daily Sun (Coconino County/Flagstaff) on October 24, 2003. Copies of the notices are contained in Appendix A-18a. 18.2. Hearing Transcripts Agendas, sign-in sheets, transcripts and hearing officer certifications for the public hearings held on November 24, 2003 in Phoenix, Arizona, and Flagstaff, Arizona, are contained in Appendix A-18b. 18.3. Written Comments Received Several written comments were received by ADEQ before the end of the comment period (December 3, 2003). These were utilized in finalizing revisions to this SIP and are contained in Appendix A-18c. 18.4. Responsiveness Summary Based on the oral comments received at the public hearings, and written comments received by the close of the comment period, the State of Arizona made appropriate revisions the Public Review Draft of the SIP released on October 24, 2003. Appendix A-18d contains the response to comments developed by the State of Arizona addressing the requirements under 40 CFR 51.102. Chapter 18 - Public Participation - 131 - Arizona Regional Haze SIP (This page intentionally blank) Chapter 18 - Public Participation - 132 - Arizona Regional Haze SIP REGIONAL HAZE STATE IMPLEMENTATION PLAN FOR THE STATE OF ARIZONA APPENDICES - VOLUME I Appendix A-1 through Appendix A-9 Air Quality Division Arizona Department of Environmental Quality LIST OF APPENDICES APPENDIX VOLUME I APPENDIX A-1. BACKGROUND Appendix A-1a. Definitions Appendix A-1b. Arizona Department of Environmental Quality – Air Quality Division Organization Charts APPENDIX A-2. DESCRIPTIONS OF ARIZONA Appendix A-2a. Bibliography for Chapter 2 APPENDIX A-5. ATTRIBUTABLE IMPAIRMENT Appendix A-5a. Arizona’s RAVI rule Appendix A-5b. Notification letters to FLMS on contact person, and Public Comment Period Appendix A-5c. Supporting Documents Related To The Promulgation Of Arizona’s RAVI Rule Appendix A-5d. New source review rule-R18-2-410 APPENDIX A-6. CLEAN AIR CORRIDOR Appendix A-6a. WRAP Policy on Clean Air Corridors Appendix A-6b. WRAP Emission Tracking System and Assessment Process for the Clean Air Corridor APPENDIX A-7. STATIONARY SOURCES Appendix A-7a. Arizona Draft Western Backstop SO2 Trading Program Rule Appendix A-7b. Proposed WRAP 309 Coordinating Committee Charter Appendix A-7c. WRAP Report on Assessment of NOx/PM Strategies APPENDIX A-8. SO2 MILESTONES/BACKSTOP Appendix A-8a. WRAP Market Trading Forum Non-Utility Sector Allocation Final Report from the Allocations Working Group (November 2002) Appendix A-8b. Western Emissions Backstop (WEB) Emissions & Allowance Tracking Systerm (EATS) Analysis Appendix A-8c. Recommendations for Making Additional Determinations in the Context of Reasonably Attributable BART APPENDIX A-9. MOBILE SOURCES Appendix A-9a. Arizona Mobile Source Work Group Findings and Recommendations Related to Mobile Source Emissions List of Appendices Arizona Regional Haze SIP LIST OF APPENDICES (Cont.) APPENDIX VOLUME II APPENDIX A-10. FIRE PROGRAMS Appendix A-10a. WRAP report “Assessing Status of Incorporating Smoke Effects into Fire Planning and Operation” Appendix A-10b. EPA’s “Interim Air Quality Policy on Wildland and Prescribed Fires” Appendix A-10c. Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10d. Supporting Documents Related to the Promulgation of Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10e. WRAP “Policy on Fire Tracking Systems” Appendix A-10f. WRAP report “Nonburning Alternatives for Vegetation and Fuel Management” Appendix A-10g. WRAP report “Burning Management Alternatives on Agricultural Lands in the Western United States” Appendix A-10h. WRAP report “Enhanced Smoke Management Programs for Visibility” Appendix A-10i. Arizona Revised Statute 49-501 Appendix A-10j. WRAP report “Annual Emission Goals for Fire” List of Appendices Arizona Regional Haze SIP LIST OF APPENDICES (Cont.) APPENDIX VOLUME III APPENDIX A-12. POLLUTION PREVENTION Appendix A-12a. Arizona Pollution Prevention Work Group Review of WRAP Policy on Renewable Energy and Energy Conservation Appendix A-12b. Details of Renewable Energy Generation and Capacity Appendix A-12c. ICF Assessment of Renewable Energy and Energy Conservation Programs APPENDIX A-13. OTHER GCVTC OPTIONS Appendix A-13a. Arizona’s Assessment of Other Recommendations Of The Grand Canyon Visibility Transport Commission Appendix A-13b. Summary of Discussions with Federal Land Managers on Emissions In-and-Near the Four Arizona GCVTC Class I Areas APPENDIX A-14. PROJECTION OF VISIBILITY Appendix A-14a. Arizona Technical Review Memoranda of WRAP Emission Inventories and Technical Support Document Appendix A-14b. Summary of Emission Inventories used in WRAP Modeling APPENDIX A-18. PUBLIC PARTICIPATION Appendix A-18a. Notices of Public Hearings Appendix A-18b. Hearing Agendas, Sign-in Sheets, Transcripts, and Certifications Appendix A-18c. Written Comments Received During Comment Period Appendix A-18d. Responsiveness Summary List of Appendices Arizona Regional Haze SIP APPENDIX A-1. BACKGROUND This appendix contains work products and references relied upon by Arizona in the development of Chapter 1 of the Regional Haze SIP. Appendix A-1. Background Arizona Regional Haze SIP Appendix A-1a. Definitions Appendix A-1. Background Arizona Regional Haze SIP Applicable definitions from 40 CFR 51.301: BART-eligible source means an existing stationary facility as defined in this section. Best Available Retrofit Technology (BART) means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant, which is emitted by an existing stationary facility. The emission limitation must be established, on a case-by-case basis, taking into consideration the technology available, the costs of compliance, the energy and non-air quality environmental impacts of compliance, any pollution control equipment in use or in existence at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology. Deciview means a measurement of visibility impairment. A deciview is a haze index derived from calculated light extinction, such that uniform changes in haziness correspond to uniform incremental changes in perception across the entire range of conditions, from pristine to highly impaired. The deciview haze index is calculated based on the following equation (for the purposes of calculating deciview, the atmospheric light extinction coefficient must be calculated from aerosol measurements): Deciview haze index = 10 1ne (bext/10 Mm-1). Where bext = the atmospheric light extinction coefficient, expressed in inverse megameters (Mm1 ). Existing stationary facility means any of the following stationary sources of air pollutants, including any reconstructed source, which was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any air pollutant. In determining potential to emit, fugitive emissions, to the extent quantifiable, must be counted. Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour heat input, Coal cleaning plants (thermal dryers), Kraft pulp mills, Portland cement plants, Primary zinc smelters, Iron and steel mill plants, Primary aluminum ore reduction plants, Primary copper smelters, Municipal incinerators capable of charging more than 250 tons of refuse per day, Hydrofluoric, sulfuric, and nitric acid plants, Petroleum refineries, Lime plants, Phosphate rock processing plants, Coke oven batteries, Appendix A-1. Background Arizona Regional Haze SIP Sulfur recovery plants, Carbon black plants (furnace process), Primary lead smelters, Fuel conversion plants, Sintering plants, Secondary metal production facilities, Chemical process plants, Fossil-fuel boilers of more than 250 million British thermal units per hour heat input, Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, Taconite ore processing facilities, Glass fiber processing plants, and Charcoal production facilities. Federal Class I area means any Federal land that is classified or reclassified Class I. Federal Land Manager means the Secretary of the department with authority over the Federal Class I area (or the Secretary's designee) or, with respect to Roosevelt-Campobello International Park, the Chairman of the Roosevelt-Campobello International Park Commission. Federally enforceable means all limitations and conditions which are enforceable by the Administrator under the Clean Air Act including those requirements developed pursuant to parts 60 and 61 of this title, requirements within any applicable State Implementation Plan, and any permit requirements established pursuant to Sec. 52.21 of this chapter or under regulations approved pursuant to part 51, 52, or 60 of this title. Implementation plan means, for the purposes of this part, any State Implementation Plan, Federal Implementation Plan, or Tribal Implementation Plan. Indian tribe or tribe means any Indian tribe, band, nation, or other organized group or community, including any Alaska Native village, which is federally recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians. In existence means that the owner or operator has obtained all necessary preconstruction approvals or permits required by Federal, State, or local air pollution emissions and air quality laws or regulations and either has (1) begun, or caused to begin, a continuous program of physical on-site construction of the facility or (2) entered into binding agreements or contractual obligations, which cannot be cancelled or modified without substantial loss to the owner or operator, to undertake a program of construction of the facility to be completed in a reasonable time. Least impaired days means the average visibility impairment (measured in deciviews) for the twenty percent of monitored days in a calendar year with the lowest amount of visibility impairment. Appendix A-1. Background Arizona Regional Haze SIP Major stationary source and major modification mean major stationary source and major modification, respectively, as defined in Sec. 51.166. Mandatory Class I Federal Area means any area identified in part 81, subpart D of this title. Most impaired days means the average visibility impairment (measured in deciviews) for the twenty percent of monitored days in a calendar year with the highest amount of visibility impairment. Natural conditions includes naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration. Potential to emit means the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable. Secondary emissions do not count in determining the potential to emit of a stationary source. Reasonably attributable means attributable by visual observation or any other technique the State deems appropriate. Reasonably attributable visibility impairment means visibility impairment that is caused by the emission of air pollutants from one, or a small number of sources. Regional haze means visibility impairment that is caused by the emission of air pollutants from numerous sources located over a wide geographic area. Such sources include, but are not limited to, major and minor stationary sources, mobile sources, and area sources. State means ``State'' as defined in section 302(d) of the CAA. Stationary Source means any building, structure, facility, or installation, which emits or may emit any air pollutant. Visibility impairment means any humanly perceptible change in visibility (light extinction, visual range, contrast, coloration) from that which would have existed under natural conditions. Applicable Definitions from 40 CFR 51.309: 16 Class I areas means the following mandatory Class I Federal areas on the Colorado Plateau: Grand Canyon National Park, Sycamore Canyon Wilderness, Petrified Forest National Park, Mount Baldy Wilderness, San Pedro Parks Wilderness, Mesa Verde National Park, Weminuche Wilderness, Black Canyon of the Gunnison Wilderness, West Elk Wilderness, Maroon Bells Wilderness, Flat Tops Wilderness, Arches National Park, Canyonlands National Park, Capital Reef National Park, Bryce Canyon National Park, and Zion National Park. Appendix A-1. Background Arizona Regional Haze SIP Transport Region State means one of the States that is included within the Transport Region addressed by the Grand Canyon Visibility Transport Commission (Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming). Commission Report means the report of the Grand Canyon Visibility Transport Commission entitled Recommendations for Improving Western Vistas, dated June 10, 1996. Fire means wildfire, wildland fire (including prescribed natural fire), prescribed fire, and agricultural burning conducted and occurring on Federal, State, and private wildlands and farmlands. Milestone means the maximum level of annual regional sulfur dioxide emissions for a given year, assessed annually consistent with paragraph (h)(2) of this section beginning in the year 2003. Mobile Source Emission Budget means the lowest level of VOC, NOx, SO2, elemental and organic carbon, and fine particles which are projected to occur in any area within the transport region from which mobile source emissions are determined to contribute significantly to visibility impairment in any of the 16 Class I areas. Geographic enhancement means a method, procedure, or process to allow a broad regional strategy, such as a milestone or backstop market trading program designed to achieve greater reasonable progress than BART for regional haze, to accommodate BART for reasonably attributable impairment. BHP San Manuel means: (i) The copper smelter located in San Manuel, Arizona which operated during 1990, but whose operations were suspended during the year 2000, (ii) The same smelter in the event of a change of name or ownership. Phelps Dodge Hidalgo means: (i) The copper smelter located in Hidalgo, New Mexico which operated during 1990, but whose operations were suspended during the year 2000, (ii) The same smelter in the event of a change of name or ownership. Definitions for the Fire Programs Land Manager means any federal, state, local, or private entity that owns, administers, directs, oversees or controls the use of public or private land, including the application of fire to the land. Prescribed fire or prescribed burn means any fire ignited by management actions to meet specific objectives, such as achieving resource benefits. Wildland Fire Used for Resource Benefits means naturally ignited wildland fire that is managed to accomplish specific prestated resource management objectives in predefined geographic areas. Appendix A-1. Background Arizona Regional Haze SIP Definitions for the Western Emission Backstop Trading Program Applicable to Sections 7 and 8 of Implementation Plan EPA Administrator means the Administrator of the United States Environmental Protection Agency or the Administrator’s duly authorized representative. Floor allocation means the amount of allowances set by the Director in accordance with this Plan that represents the minimum necessary for a source to operate under stringent control assumptions. Reducible allocation means the amount of allowances set by the Director in accordance with this Plan that represents, for each source, emissions in excess of the floor allocation that shall be reduced over time as the regional milestone is decreased. Tribal Set-Aside means a 20,000-ton SO2 WEB allowance allocated to tribes on an annual basis. The tribes will decide how to distribute the allowances in the set-aside among tribes in the region. The set-side is intended to ensure equitable treatment for tribal economies and to prevent barriers to economic development. Trigger refers to the activation of the WEB Trading Program for SO2 in accordance with this Plan. WEB Trading Program refers to the Western Backstop (WEB) Trading Program Rule that shall be triggered as a backstop in accordance the provisions of this Plan to ensure that regional SO2 emissions are reduced. Western Regional Air Partnership (WRAP) means the collaborative effort of tribal governments, state governments, and federal agencies to promote and monitor implementation of recommendations from the Grand Canyon Visibility Transport Commission authorized under Section 169B(f) of the Clean Air Act, and to address other common Western regional air quality issues. Appendix A-1. Background Arizona Regional Haze SIP Appendix A-1b. Arizona Department of Environmental Quality – Air Quality Division Organization Charts Appendix A-2. Descriptions of Arizona Arizona Regional Haze SIP Appendix A-2. Descriptions of Arizona Arizona Regional Haze SIP APPENDIX A-2. DESCRIPTIONS OF ARIZONA This appendix contains work products and references relied upon by Arizona in the development of Chapter 2 of the Regional Haze SIP. Appendix A-2. Descriptions of Arizona Arizona Regional Haze SIP Appendix A-2a. Bibliography for Chapter 2 Appendix A-2. Descriptions of Arizona Arizona Regional Haze SIP Appendix A-2a. Bibliography for Chapter 2 Arizona Business. April 1999. “In 1990s, single-family sector drove AZ real estate.” Arizona State University (vol 46, No. 4). Arizona Business. January 1998. “Arizona population likely to grow rapidly.” Arizona State University (vol 45, No. 1). Arizona Business. May 1995. “AZ production of fruits, vegetables relatively high.” Arizona State University (vol 42, No. 5). Arizona Business. June 1994. “Metro Phoenix one of the nation’s high-tech centers.” Arizona State University (vol 41, No. 6). Arizona Department of Economic Security. David Lillie. August 1986. A Demographic Guide To Arizona 1985. Population Statistics Unit, Report #14. Arizona Department of Economic Security. State Data Center Newsletter. Spring 2001. Berman, David R. 1998. Arizona Politics & Government: The Quest for Autonomy, Democracy, and Development. University of Nebraska Press, Lincoln. Campbell, Julie A. 1998. Studies in Arizona History. Arizona Historical Society, Tucson. Economic Outlook 03/04. The University of Arizona. Eller College of Business and Public Administration. Employment Security Commission of Arizona. August 1963. Arizona: A Century of Growth. Economics and Research Unit. Hecht, Melvin E. and Richard W. Reeves. 1981. the Arizona Atlas. University of Arizona, Tucson. Office of Arid Lands Studies. Mattern, Hal. June 5, 2001. The Arizona Republic. “Arizona was No. 1 for growth in > 90s” Web sites: http://www.nps.gov/grca http://www.fs.fed.us/r3/kai/recreation/wild_syc http://www.wilderness.net/nwps/wilderness.cfm/Sycamore%20Canyon http://www.americansouthwest.net/arizona/sycamore_canyon http://www.cr.nps.gov/worldheritage/grcan Appendix A-2. Descriptions of Arizona Arizona Regional Haze SIP Appendix A-2a. Bibliography for Chapter 2 (Continued) http://www.petrifiedforest.areaparks.com/parkinformation http://www.wmonline.com/attract/pforest/pforest http://www.geo.arizona.edu/geos256/azgeology/pwood/parkintro http://cpluhna.nau.edu/Places/white_mountains http://www.flyfishingworld.com/features/mwwhiteriver http://geography.asu.edu/azclimate/narrative Appendix A-2. Descriptions of Arizona Arizona Regional Haze SIP APPENDIX A-5. ATTRIBUTABLE IMPAIRMENT This appendix contains work products and references relied upon by Arizona in the development of Chapter 5 of the Regional Haze SIP. Appendix A-5 – Attributable Impairment Arizona Regional Haze SIP Appendix A-5a. Arizona’s RAVI rule Appendix A-5 – Attributable Impairment Arizona Regional Haze SIP Arizona Administrative Register / Secretary of State Notices of Final Rulemaking NOTICES OF FINAL RULEMAKING The Administrative Procedure Act requires the publication of the final rules of the state’s agencies. Final rules are those which have appeared in the Register first as proposed rules and have been through the formal rulemaking process including approval by the Governor’s Regulatory Review Council or the Attorney General. The Secretary of State shall publish the notice along with the Preamble and the full text in the next available issue of the Register after the final rules have been submitted for filing and publication. NOTICE OF FINAL RULEMAKING TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL PREAMBLE 1. Sections Affected R18-2-101 Article 16 R18-2-1601 R18-2-1602 R18-2-1603 R18-2-1604 R18-2-1605 R18-2-1606 Rulemaking Action Amend New Article New Section New Section New Section New Section New Section New Section 2. The statutory authority for the rulemaking, including both the authorizing statute (general) and the statutes the rules are implementing (specific): Authorizing statutes: A.R.S. §§ 49-104(A)(11) and 49-425 Implementing statutes: A.R.S. §§ 49-414 and 49-414.01 3. The effective date of the rules: December 2, 2003 4. A list of all previous notices appearing in the Register addressing the final rules: Notice of Rulemaking Docket Opening: 9 A.A.R. 390, February 7, 2003 Notice of Proposed Rulemaking: 9 A.A.R. 763, March 7, 2003 5. 6. The name and address of agency personnel with whom persons may communicate regarding the rulemaking: Name: Deborrah “Corky” Martinkovic Address: ADEQ, Air Quality Planning Section 1110 W. Washington Phoenix, AZ 85007 Telephone: (602) 771-2372 (Any extension may be reached in-state by dialing 1-800-234-5677, and asking for a specific number.) Fax: (602) 771-2366 E-mail: martinkovic.deborrah@ev.state.az.us An explanation of the rules, including the agency’s reasons for initiating the rules: Summary. This rule sets forth the process Arizona Department of Environmental Quality (ADEQ) will use to determine whether Best Available Retrofit Technology (BART) will be required for sources determined to be contributing to visibility impairment in a mandatory Federal Class I area. Federal regulations allow Federal Land Managers (FLMs) to certify sources defined in 40 CFR 51.301 as potential contributors to visibility impairment in any of the Arizona mandatory Federal Class I areas under Section 169A of the Clean Air Act (CAA). Background. In 1977 Congress added a new section to the Clean Air Act - Section 169A, Visibility Protection for Federal Class I Areas - which established a national goal for, “the prevention of any future, and the remedying of any existing impairment of visibility in mandatory class I Federal areas which impairment results from man-made air pollution.” In addition, the section required states to submit state implementation plans (SIPs) requiring best available retrofit technology (BART) for certain existing stationary sources found to cause or contribute to visibility impair- October 24, 2003 Page 4541 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking ment. On November 30, 1979, EPA promulgated a list of mandatory Federal Class I Areas (Class I areas) where visibility is an important value (44 FR 69122). There are 12 Class I areas identified in Arizona: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness (40 CFR 81.403). On December 2, 1980 (45 FR 80084), EPA defined the role of the FLMs in certifying visibility impairment in the mandatory Federal Class I areas. On November 24, 1987 (52 FR 45132), FLMs identified Petrified Forest National Park, Saguaro Wilderness, and Grand Canyon National Park, as having visibility impairment possibly attributable to stationary sources. Under the 1980 rule, if found to cause or contribute to the impairment, certain existing stationary sources operating in or near the identified Class I areas could be subject to BART (A list of sources eligible for the possible application of BART can be found at 40 CFR 51.301). On October 3, 1991, the Navajo Generating Station (NGS) was found by EPA to be causing or contributing to visibility impairment for the Grand Canyon National Park and eligible for BART (56 FR 50172). BART control analyses were subsequently performed by EPA, and other parties through related court actions. Under the 1980 rule, the federal expectation is that actions for determination of possible source attribution will be performed by the states. Therefore, Arizona needs to be prepared to proceed with an attribution analysis and assessment for the application of controls upon any determination of a BART eligible source being the possible cause or contributor to visibility impairment in a Class I area. This rule addresses that need. Current Conditions. ADEQ has determined that this rule applies to any source in existing stationary source categories identified in 40 CFR 51.301 that are operating in or near the mandatory federal Class I areas in Arizona. The source is an existing stationary facility that includes any reconstructed source that was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year of any regulated pollutant. ADEQ estimates that there are potentially 10 such sources within Arizona. “In existence” is interpreted by EPA to be consistent with the term, “commence construction” found in Prevention of Serious Deterioration (PSD) regulations (40 CFR 51.165(a)(1)(xvi) and 40 CFR 52.21(b)(9)). If construction commenced after August 7, 1977, the source would be subject to the PSD/NSR (new source review) program (the state regulations are found at 18 A.C.C. 2, Article 4). However, EPA also notes “that sources, are not BART eligible if the only change at the plant was the addition of pollution controls. For example, if the only change at a copper smelter during the 1962 through 1977 time period was the addition of acid plants for the reduction of SO2 emissions, these emission controls would not themselves trigger a BART review.”1 [1EPA proposed rule, 66 Federal Register 38119, July 20, 2001.] Under this rule, ADEQ, when analyzing an attributable source for BART controls, must consider several factors including, for example, costs, remaining useful life of the source, and degree of improvement anticipated to result from the application of the controls (the factors are detailed in R18-2-1605). Sources required by ADEQ to install and operate BART controls have a final opportunity to request exemption from the requirement prior to the application of controls. This opportunity for a federal exemption from BART, is contained in R18-2-1606, and 40 CFR 51.303. Summary. This rule outlines the process through which sources eligible for the application of BART will proceed if certified by the state of Arizona or an FLM as possibly causing or contributing to visibility impairment due to attribution. If found to be attributable for the impairment, a BART analysis will be performed to determine the level of controls necessary to remedy the impairment. This rule enables Arizona to fulfill the requirements of the Clean Air Act and the goal of section 169A of the Act to return the Nation’s federal parks and wilderness areas to natural conditions. Section-by-Section Explanation for the Rules R18-2-1601 This Section lists the definitions that apply to this rule. R18-2-1602 This Section lists the Class I areas addressed by this rule for the applicable existing stationary facilities, as defined in R18-2-1601(2). R18-2-1603 This Section establishes the procedure for certification of impairment by either a Federal Land Manager with authority over a mandatory Federal Class I area, or the Director, should either believe there exists reasonably attributable visibility impairment in a Federal Class I area as listed in R18-2-1602. R18-2-1604 This Section establishes the procedure for an attribution analysis after certification of a source or group of sources as outlined in R18-2-1603. Upon completion of the attribution analysis, the procedure for the Director to issue draft and final attribution findings is outlined in R18-21604(C). R18-2-1605 This Section establishes the best available retrofit technology (BART) analysis procedure after a source is identified under R18-2-1604. Upon completion of the BART analysis, the procedure for the Director to issue draft and final BART findings, including alternatives to emission standards, is outlined in R18-2-1605(B) and (C), respectively. The specific conditions where BART would be satisfied due to past or planned actions by the facility are outlined in R18-21605(D). EPA determinations regarding new technology that might require a BART analysis Volume 9, Issue 43 Page 4542 October 24, 2003 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking for an applicable source, regardless of a source or small group of sources previously being certified and found attributable, are covered in R18-2-1605(E). R18-2-1606 This Section establishes the procedures for obtaining a federal exemption from a BART requirement. 7. A reference to any study relevant to the rules that the agency reviewed and either relied on in its evaluation of or justification for the rules or did not rely on in its evaluation of or justification for the rules, where the public may obtain or review each study, all data underlying each study, and any analysis of each study and other supporting material: None 8. A showing of good cause why the rules are necessary to promote a statewide interest if the rules will diminish a previous grant of authority of a political subdivision of this state: Not applicable 9. The summary of the economic, small business, and consumer impact: A. Rule Identification These rules amend R18-2-101 (“visibility impairment” definition) and add new Sections R18-2-1601 through R18-21606. For sources under ADEQ jurisdiction, the rules take the place of federal regulations that currently govern this area. B. Entities Directly Impacted 1. Federal Land Managers. R18-2-1603 allows Federal Land Managers (FLMs) to certify visibility impairment in mandatory Class I areas. This was already allowed by federal rule. Under R18-2-1601 of the rule, the FLMs able to certify impairment in Arizona are with the United States Forest Service and the National Park Service. There are no FLMs in Arizona from the United States Fish and Wildlife Service, because this agency does not have jurisdiction over any of Arizona’s mandatory federal Class I areas. 2. ADEQ. R18-2-1604 requires ADEQ to identify stationary sources that could cause or contribute to the certified visibility impairment. Prior to this rule, this function was carried out by EPA. R18-2-1605 would require ADEQ to analyze for BART (best available retrofit technology) controls those sources identified as causing or contributing to visibility impairment. Prior to this rule, this function was carried out by EPA. The impact of this rule on ADEQ will primarily be on the Air Quality Division, Permits and Assessment sections, with a corresponding reduction of impact on EPA. 3. Stationary sources. R18-2-1605 also requires stationary sources identified in #2 to install or operate the BART as determined by the Director. Prior to this rule, only EPA determined and required BART. To determine impacted stationary sources, ADEQ staff reviewed Title V permits from ADEQ’s Air Permit files. Of the 26 industry categories listed in 40 CFR 51.301, only five categories were found to exist under ADEQ’s jurisdiction: steam electric plants, cement plants, primary copper smelters, lime plants, and industries using non-utility boilers. As a result, potentially 10 sources, representing 16 BART eligible units (boilers and kilns), could be affected by this rule. The combined potential to emit from these sources totaled 94,287 tons per year for NO x, 141,036 tons per year for SO2, and 12,146 tons per year for PM. The combined potential to emit for all pollutants for these 10 sources total approximately 250,000 tons per year. C. Probable Costs and Benefits Associated with the BART/Visibility Impairment Process 1. Direct Costs - FLMs: FLM activities to certify visibility impairment in mandatory Class I areas may involve preparation and analysis of monitoring data, emission inventories, meteorological records, etc. ADEQ estimates that this cost per certification could be as much as $50,000 if extensive analysis is conducted. These costs exist whether or not these rules became final. 2. Direct Costs - ADEQ: ADEQ costs related to identifying whether a BART eligible stationary source causes or contributes to visibility impairment in Class I areas are based on the activities identified in R18-2-1604(A). ADEQ estimates that these costs could range from $100,000 – 200,000 per attribution analysis, and be primarily borne by the ADEQ’s Air Quality Assessment Section. Costs related to analyzing identified sources for BART are based on the activities identified in R18-2-1605(A) and will be moderate, but less expensive than the attribution analysis. These costs will be primarily borne by ADEQ’s Permits Section. These costs will accrue to the state. Finally, incorporating BART into an existing state air quality permit may require additional resources from the Permits Section. However, these costs, unlike costs for the attribution and BART analysis, would be covered by permit revision fees paid by the source, and would have existed whether or not these rules became final. 3. Direct Costs - Stationary sources: If a source or small group of sources is found to cause or contribute to visibility impairment, and the BART determination requires installation of retrofit controls, the costs to sources required to install BART will be substantial. The total cost to install a technology similar to BART at the Navajo Generating Station was estimated by SRP to be in the hundreds of millions of dollars (51 Federal Register 50172, October 3, 1991). However, the example of the Navajo Generating Station shows costs to install technology similar to BART can result even where there is no state rule. According to EPA, “Where a State defaults on its obligations under the visibility October 24, 2003 Page 4543 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking regulations, EPA may act in place of the State pursuant to a FIP under section 110(c) of the Act, 42 U.S.C. 7410(c)2, and promulgate such limitation and measures as are required to achieve reasonable progress.” (Ibid. at 50173, footnote not included). Although ADEQ is listing these costs for information purposes, ADEQ is not attributing any costs to install and operate BART to this rule because such requirements can be imposed by the federal government without any state rule. Benefits. Two kinds of benefits are associated with this rule. The first benefit is derived from reduced emissions. Although, BART could be required to be installed on sources even without this state rule, it is helpful to list the emission benefits. When BART is installed, visibility is improved. Over four million recreation visits were made to Grand Canyon National Park in FY 2001. These visits generate substantial revenue in and for the state of Arizona. Other scenic resources could also be improved with the installation of BART, and, though less significant than the Grand Canyon, would enhance the tourism resources of Arizona, as well as the quality of life for Arizona citizens. In addition, reduction of visibility-impairing emissions also has health benefits. The second benefit is through the replacement of federal regulation with state regulation. The lack of state regulations implementing BART results in Arizona sources being subject to federal regulation implemented by EPA from Washington and San Francisco, headquarters for EPA’s Region IX. These rules place the identification and analysis of BART sources with ADEQ rather than with EPA. Arizona is currently under a visibility Federal Implementation Plan (FIP), and one or two Arizona sources have considered or implemented technology similar to BART under federal rules. Because ADEQ already permits many of these sources, ADEQ will be more familiar with the various factors that go into the BART analysis. This would be a benefit to sources being regulated. ADEQ would be implementing the same BART rules that EPA does, with a resulting increase in costs for ADEQ and a decrease in costs for EPA. This final rule further allows ADEQ to proceed with the implementation of the entire federal rule for visibility improvement. The rule addresses the requirements of 40 C.F.R. §§ 51.302 – 51.307. These sections must be satisfied before ADEQ can implement the requirements of 40 C.F.R. §§ 51.308 and 51.309. The plan to implement Section 309 must be submitted to EPA by December 31, 2003. D. Small Business Analysis A.R.S. § 41-1055(B)(5) requires agencies to state the probable impact of a rulemaking on small businesses. A.R.S. § 41-1035 requires agencies to reduce the impact of a rule on small businesses by using certain methods when they are legal and feasible in meeting the statutory objectives for the rulemaking. These methods include: (1) exempting them from any or all rule requirements, (2) establishing performance standards which would replace any design or operational standards, or (3) instituting reduced compliance or reporting requirements. An agency may accomplish the third method by establishing less stringent requirements, consolidating or simplifying requirements, or setting less stringent schedules or deadlines. “Small business” is defined in A.R.S. § 41-1001 as “a concern, including its affiliates, which is independently owned and operated, which is not dominant in its field and which employs fewer than one hundred full-time employees or which had gross annual receipts of less than four million dollars in its last fiscal year.” Interpreting this definition means that if a concern has annual gross receipts of more than four million dollars, but fewer than 100 employees, it would not be classified as a small business. ADEQ expects that none of the potential BART eligible sources will be classified as a small business. ADEQ’s conclusion is that this rule will not impact small business sources. However, if a BART eligible source would qualify as a small business, under federal rule, ADEQ could not establish different requirements for these small business sources. If there are any small businesses that sell, install, or maintain BART-related technology, they will benefit from this rule. In the preliminary EIS, ADEQ requested comment and additional information relating to any of the conclusions reached above and did not receive any. 10. A description of the changes between the proposed rules, including supplemental notices, and final rules (if applicable): Changes were made with the cooperation of G.R.R.C. Staff to improve the clarity, conciseness and understandability of the rule. The changes are shown below: A new definition was placed at R18-2-101(71), to clarify a term used in the proposed definition of “visibility impairment” at R18-2-101(123): 71. “Natural conditions” includes naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration. In addition, the word “and” was removed from the definition of “visibility impairment,” as shown: 123.124.“Visibility impairment” means any humanly perceptible change in visibility (light extinction, visual range, contrast, and coloration) from that which would have existed under natural conditions. Both definitions are copied exactly from federal regulations at 40 CFR 51.308. Volume 9, Issue 43 Page 4544 October 24, 2003 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking In addition, new Article 16 was amended as follows: ARTICLE 16. VISIBILITY; REGIONAL HAZE R18-2-1601. Definitions In addition to the definitions contained in Articles 1 and 4 of this Chapter and A.R.S. § 49-401.01, the following definitions apply to this Article: 1. “Best available retrofit technology (BART)” means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant that is emitted by an existing stationary facility. The emission limitation is established on a case-by-case basis in accordance with under R18-2-1605. 2. “Existing stationary facility” means any of the following stationary sources of air pollutants, including any reconstructed source, which was not in operation prior to before August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any air pollutant. In determining A person who determines potential to emit, shall count fugitive emissions, to the extent quantifiable, must be counted. a. Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour heat input,; b. Coal cleaning plants (thermal dryers),; c. Kraft pulp mills,; d. Portland cement plants,; e. Primary zinc smelters,; f. Iron and steel mill plants,; g. Primary aluminum ore reduction plants,; h. Primary copper smelters,; i. Municipal incinerators capable of charging more than 250 tons of refuse per day,; j. Hydrofluoric, sulfuric, and nitric acid plants,; k. Petroleum refineries,; l. Lime plants,; m. Phosphate rock processing plants,; n. Coke oven batteries,; o. Sulfur recovery plants,; p. Carbon black plants (furnace process),; q. Primary lead smelters,; r. Fuel conversion plants,; s. Sintering plants,; t. Secondary metal production facilities,; u. Chemical process plants,; v. Fossil-fuel boilers of more than 250 million British thermal units per hour heat input,; w. Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels,; x. Taconite ore processing facilities,; y. Glass fiber processing plants,; and z. Charcoal production facilities. 3. “Federal Land Manager” means the Secretary of the department, or the Secretary’s designee, with authority over the Federal Class I area. 4. “Mandatory Federal Class I Area” means any area identified in 40 CFR §§ 81.400-81.436. 5. “Reasonably attributable” means ascribable by visual observation or other techniques the Director deems appropriate described in R18-2-1604. 6. “Reasonably attributable visibility impairment” means visibility impairment that is caused by the emission of air pollutants from one source, or a small group of sources. R18-2-1602. Applicability This Article applies to any existing stationary source located in the state that may reasonably be anticipated to cause or contribute to visibility impairment in any mandatory Federal Class I area identified in 40 CFR §§ 81.401-81.436. Mandatory Federal Class I areas within Arizona are: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness. R18-2-1603. Certification of Impairment A. A Federal Land Manager with authority over a mandatory Federal Class I area may certify to the Director, at any time, that there exists a reasonably attributable visibility impairment exists in the a mandatory Federal Class I area. The Director may also certify that there exists reasonably attributable visibility impairment exists in any mandatory Federal Class I area as necessary to assure reasonable progress under section 169A(b)(2) of the Clean Air Act. October 24, 2003 Page 4545 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking B. Documentation from the affected Federal Land Manager or Director that supports the Federal Land Manager or Director’s certification shall include: 1. The mandatory Federal Class I area for which visibility impairment is being certified, 2. Any information documenting the basis for the certification of impairment. R18-2-1604. Attribution Analysis; Finding A. Upon certification of reasonably attributable visibility impairment in any mandatory Federal Class I area If a mandatory Federal Class I area is certified as having reasonably attributable visibility impairment, the Director shall conduct an attribution analysis to identify each existing stationary source that may be reasonably anticipated to cause or contribute to visibility impairment. The Director shall notify the Federal Land Manager, affected source or small group of sources, and local air pollution control officer of the intent to conduct an attribution analysis. The attribution analysis shall be based on the following: 1. Monitoring information obtained through the Arizona Class I Visibility Monitoring Network or special studies approved by ADEQ to ascertain: a. The times visibility impairment occurred, and b. The pollutants contributing to the visibility impairment.; 2. Transport analysis or air quality modeling based upon meteorological records to ascertain whether the pollutants were transported to the mandatory Federal Class I area.; 3. Other available studies, modeling analyses, and emissions inventories of point, area, and mobile source emissions to ascertain: a. The pollutant or pollutants causing the impairment, and b. The source, or a small group of sources, emitting the impairing pollutant; or pollutants. 4. Other relevant supporting documentation provided by the Federal Land Manager or Director used to make the draft attribution analysis finding.; and 5. Consideration of any documentation provided by the source, or a small group of sources., or other interested parties. B. In conducting the attribution analysis, the Director shall use monitoring information, meteorological records, and emissions inventories that represent times and locations reasonably concurrent with the visibility impairment. C. The Director shall issue a draft attribution finding that impairment has or has not occurred, and provide public notice of the draft attribution finding. The Director shall publish notice of the draft attribution finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, if any, and shall clearly set forth reasons why the Director should review the draft attribution finding should be reviewed. The Director shall issue A a final attribution finding shall be issued after the public comment period. If the Director finds existing stationary sources found to cause or contribute to visibility impairment in a mandatory Federal Class I area, the source shall be subject to a BART Control Analysis under R18-21605. R18-2-1605. BART Control Analysis; Finding A. The Director shall analyze for BART controls each existing stationary source for which a final attribution finding is made under R18-2-1604(C). The Director shall consider the following factors: 1. Available control technology; 2. New source performance standards (NSPS) as adopted in Article 9; 3. Alternative control systems if retrofitting to comply with applicable NSPS standards adopted in Article 9 is found infeasible.; 4. Cost of compliance; 5. Energy and non-air quality environmental impacts of compliance; 6. Existing pollution control technology in use at the source or small group of sources; 7. Remaining useful life of the source or small group of sources; 8. Net environmental impact associated with the proposed emission control system; 9. Economic impacts associated with installing and operating the proposed emission control system; and 10. Degree of improvement in visibility anticipated to result from application of the proposed emission control system. B. The Director shall issue a draft BART finding, and provide public notice of the draft BART finding. The Director shall publish notice of the draft BART finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, and shall clearly set forth reasons why the Director should review the draft BART finding should be reviewed. The Director shall issue a final BART finding after the public comment period. 1. The Director shall submit each final BART finding that an existing stationary source is required to meet BART to the Administrator as a revision to the state implementation plan (SIP). Volume 9, Issue 43 Page 4546 October 24, 2003 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking 2. The Director shall require that each existing stationary source meet BART as expeditiously as practicable but in no case later than five years after EPA approval of the revision to Arizona’s State Implementation Plan SIP revision. C. If the Director determines that technological or economic limitations on the applicability of measurement methodology to a particular existing stationary source would make the imposition of an emission standard infeasible, the Director may, as part of the finding under subsection (B), instead prescribe a design, equipment, work practice, or other operational standard, or combination thereof of design, equipment, work practice, or operational standard. Such The standard, to the degree possible, is to shall set forth the emission reduction to be achieved by implementation of such the design, equipment, work practice, or operation, and must shall provide for compliance by means which that achieve equivalent results. D. The Director shall make a finding that the attributable source has satisfied satisfies the BART requirement if the attributable source has: 1. Voluntarily applied applies best available retrofit technology; 2. Previously applied emission control standards equivalent to BART; or 3. Agreed Agrees to shutdown or curtail operations at the attributable source within 5 five years of the finding. An attributable source that does not shutdown or curtail operations shall proceed to meet BART as expeditiously as practicable, but in no case later than five years after EPA’s approval of the revision to Arizona’s State Implementation Plan the SIP. E. If the Director determines that the imposition of BART or a standard pursuant to under subsection (C) of this section is not feasible infeasible at the time of the finding, the Director shall require the attributable source shall be required to install and operate BART upon a determination by the Director at a later date when the Director determines that BART or equivalent controls are now feasible. F. The Director shall provide for a BART control analysis of any existing stationary source that might cause or contribute to impairment of visibility in any mandatory Federal Class I area identified under this Article at such times, as determined by the Administrator, determines new control technology for control of the pollutant becomes reasonably available if: 1. The pollutant is emitted by that existing stationary source, 2. Controls representing BART for the pollutant have not previously been required under this Article, and 3. The impairment of visibility in any mandatory Federal Class I area is reasonably attributable to the emissions of that pollutant. R18-2-1606. Exemption from BART Any existing stationary source required to install, operate, and maintain BART pursuant to under this Article, may apply to the Administrator for an exemption from that requirement according to 40 CFR 51.303. by obtaining prior written concurrence from the Director according to 40 CFR 51.303. The existing stationary source shall obtain the Director’s written concurrence before sending the application for exemption to the Administrator. 11. A summary of the comments made regarding the rules and the agency response to them: ADEQ received one written comment. It expressed general support for the rules and for protecting visibility in Arizona’s Class I parks and wilderness areas. Comment: ADEQ received an oral comment that the word “facility” should be replaced by “source” in the definitions of “best available retrofit technology” and “existing stationary facility” to be consistent with the rest of the rule. Response: ADEQ has kept these definitions the same as the federal definitions to ensure consistency. The definitions use the term “source” to define the terms, and “source” is used thereafter in the rules. ADEQ is not aware of any inconsistency. 12. Any other matters prescribed by statute that are applicable to the specific agency or to any specific rule or class of rules: Not applicable 13. Incorporations by reference and their location in the rules: Not applicable 14. Were these rules previously adopted as emergency rules? No 15. The full text of the rules follows: TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL October 24, 2003 Page 4547 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking ARTICLE 1. GENERAL Section R18-2-101. Definitions ARTICLE 16. VISIBILITY; REGIONAL HAZE Section R18-2-1601. R18-2-1602. R18-2-1603. R18-2-1604. R18-2-1605. R18-2-1606. Definitions Applicability Certification of Impairment Attribution Analysis; Finding BART Control Analysis; Finding Exemption from BART ARTICLE 1. GENERAL R18-2-101. Definitions In addition to the definitions prescribed in A.R.S. §§ 49-101, 49-401.01, 49-421, 49-471, and 49-541, in this Chapter, unless otherwise specified: 1. No change 2. No change a. No change b. No change c. No change d. No change e. No change 3. No change 4. No change 5. No change 6. No change 7. No change 8. No change 9. No change 10. No change a. No change b. No change c. No change d. No change e. No change f. No change 11. No change a. No change b. No change c. No change 12. No change 13. No change 14. No change a. No change b. No change 15. No change 16. No change 17. No change 18. No change 19. No change 20. No change 21. No change 22. No change 23. No change 24. No change 25. No change 26. No change Volume 9, Issue 43 Page 4548 October 24, 2003 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking 27. No change a. No change b. No change 28. No change 29. No change 30. No change 31. No change 32. No change 33. No change 34. No change 35. No change 36. No change 37. No change 38. No change 39. No change 40. No change 41. No change 42. No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change 43. No change 44. No change a. No change b. No change c. No change d. No change 45. No change 46. No change 47. No change 48. No change 49. No change 50. No change 51. No change 52. No change 53. No change 54. No change 55. No change 56. No change 57. No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change October 24, 2003 Page 4549 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking 58. 59. 60. 61. 62. 63. No change No change No change No change No change No change a. No change b. No change c. No change i. No change ii. No change iii. No change iv. No change v. No change (1) No change (2) No change vi. No change vii. No change viii. No change (1) No change (2) No change ix. No change (1) No change (2) No change x. No change xi. No change 64. No change a. No change b. No change i. No change ii. No change c. No change i. No change ii. No change iii. No change iv. No change v. No change vi. No change vii. No change viii. No change ix. No change x. No change xi. No change xii. No change xiii. No change xiv. No change xv. No change xvi. No change xvii.No change xviii.No change xix. No change xx. No change xxi. No change xxii.No change xxiii.No change xxiv.No change xxv. No change xxvi.No change xxvii.No change Volume 9, Issue 43 Page 4550 October 24, 2003 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking 65. 66. 67. 68. 69. 70. 71. No change No change No change No change No change No change “Natural conditions” includes naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration. 71.72.No change 72.73.No change a. No change i. No change ii. No change b. No change i. No change ii. No change c. No change d. No change e. No change f. No change i. No change ii. No change iii. No change iv. No change g. No change 73.74.No change 74.75.No change 75.76.No change 76.77.No change 77.78.No change 78.79.No change 79.80.No change 80.81.No change 81.82.No change 82.83.No change 83.84.No change a. No change b. No change c. No change d. No change 84.85.No change 85.86.No change 86.87.No change 87.88.No change 88.89.No change 89.90.No change 90.91.No change 91.92.No change 92.93.No change 93.94.No change 94.95.No change a. No change b. No change c. No change d. No change 95.96.No change 96.97.No change 97.98.No change a. No change October 24, 2003 Page 4551 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking b. No change c. No change d. No change e. No change 98.99.No change a. No change i. No change ii. No change iii. No change iv. No change v. No change vi. No change vii. No change b. No change c. No change 99.100.No change a. No change b. No change 100.101.No change 101.102.No change 102.103.No change 103.104.No change 104.105.No change a. No change b. No change c. No change d. No change 105.106.No change 106.107.No change 107.108.No change a. No change b. No change 108.109.No change 109.110.No change 110.111.No change 111.112.No change 112.113.No change 113.114.No change 114.115.No change 115.116.No change 116.117.No change 117.118.No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change m. No change n. No change o. No change p. No change q. No change Volume 9, Issue 43 Page 4552 October 24, 2003 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking r. No change s. No change t. No change u. No change v. No change w. No change x. No change y. No change z. No change aa. No change bb. No change cc. No change dd. No change ee. No change ff. No change gg. No change hh. No change ii. No change jj. No change kk. No change ll. No change mm.No change nn. No change oo. No change pp. No change qq. No change rr. No change ss. No change tt. No change uu. No change vv. No change ww. No change xx. No change 118.119.No change 119.120.No change 120.121.No change 121.122.No change 122.123.No change 123.124.“Visibility impairment” means any humanly perceptible change in visibility (light extinction, visual range, contrast, coloration) from that which would have existed under natural conditions. 124.125.No change 125.126.No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change m. No change n. No change o. No change p. No change q. No change October 24, 2003 Page 4553 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking r. No change s. No change t. No change u. No change v. No change w. No change x. No change y. No change z. No change aa. No change bb. No change cc. No change dd. No change ee. No change ff. No change gg. No change hh. No change ii. No change jj. No change kk. No change ll. No change mm.No change nn. No change oo. No change pp. No change qq. No change rr. No change ss. No change i. No change ii. No change iii. No change iv. No change 126.127.No change ARTICLE 16. VISIBILITY; REGIONAL HAZE R18-2-1601. Definitions In addition to the definitions contained in Articles 1 and 4 of this Chapter and A.R.S. § 49-401.01, the following definitions apply to this Article: 1. “Best available retrofit technology (BART)” means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant emitted by an existing stationary facility. The emission limitation is established on a case-by-case basis under R18-2-1605. 2. “Existing stationary facility” means any of the following stationary sources of air pollutants, including any reconstructed source, which was not in operation before August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any air pollutant. A person who determines potential to emit shall count fugitive emissions to the extent quantifiable. a. Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour heat input; b. Coal cleaning plants (thermal dryers); c. Kraft pulp mills; d. Portland cement plants; e. Primary zinc smelters; f. Iron and steel mill plants; g. Primary aluminum ore reduction plants; h. Primary copper smelters; i. Municipal incinerators capable of charging more than 250 tons of refuse per day; j. Hydrofluoric, sulfuric, and nitric acid plants; k. Petroleum refineries; l. Lime plants; m. Phosphate rock processing plants; n. Coke oven batteries; Volume 9, Issue 43 Page 4554 October 24, 2003 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking 3. 4. 5. 6. o. Sulfur recovery plants; p. Carbon black plants (furnace process); q. Primary lead smelters; r. Fuel conversion plants; s. Sintering plants; t. Secondary metal production facilities; u. Chemical process plants; v. Fossil-fuel boilers of more than 250 million British thermal units per hour heat input; w. Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels; x. Taconite ore processing facilities; y. Glass fiber processing plants; and z. Charcoal production facilities. “Federal Land Manager” means the secretary of the department, or the secretary’s designee, with authority over the Federal Class I area. “Mandatory Federal Class I Area” means any area identified in 40 CFR 81.400 through 81.436. “Reasonably attributable” means ascribable by visual observation or other techniques described in R18-2-1604. “Reasonably attributable visibility impairment” means visibility impairment that is caused by the emission of air pollutants from one source, or a small group of sources. R18-2-1602. Applicability This Article applies to any existing stationary source located in the state that may reasonably be anticipated to cause or contribute to visibility impairment in any mandatory Federal Class I area identified in 40 CFR 81.401 through 81.436. Mandatory Federal Class I areas within Arizona are: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness. R18-2-1603. Certification of Impairment A. A Federal Land Manager with authority over a mandatory Federal Class I area may certify to the Director, at any time, that a reasonably attributable visibility impairment exists in a mandatory Federal Class I area. The Director may also certify that reasonably attributable visibility impairment exists in any mandatory Federal Class I area to assure reasonable progress under section 169A(b)(2) of the Clean Air Act. B. Documentation that supports the Federal Land Manager or Director’s certification shall include: 1. The mandatory Federal Class I area for which visibility impairment is being certified, 2. Any information documenting the basis for the certification of impairment. R18-2-1604. Attribution Analysis; Finding A. If a mandatory Federal Class I area is certified as having reasonably attributable visibility impairment, the Director shall conduct an attribution analysis to identify each existing stationary source that may be reasonably anticipated to cause or contribute to visibility impairment. The Director shall notify the Federal Land Manager, affected source or small group of sources, and local air pollution control officer of the intent to conduct an attribution analysis. The attribution analysis shall be based on the following: 1. Monitoring information obtained through the Arizona Class I Visibility Monitoring Network or special studies approved by ADEQ to ascertain: a. The times visibility impairment occurred, and b. The pollutants contributing to the visibility impairment; 2. Transport analysis or air quality modeling based upon meteorological records to ascertain whether the pollutants were transported to the mandatory Federal Class I area; 3. Other available studies, modeling analyses, and emissions inventories of point, area, and mobile source emissions to ascertain: a. The pollutant causing the impairment, and b. The source, or a small group of sources, emitting the pollutant; 4. Other relevant supporting documentation provided by the Federal Land Manager or Director used to make the draft attribution analysis finding; and 5. Consideration of any documentation provided by the source, a small group of sources, or other interested parties. B. In conducting the attribution analysis, the Director shall use monitoring information, meteorological records, and emissions inventories that represent times and locations reasonably concurrent with the visibility impairment. C. The Director shall issue a draft attribution finding that impairment has or has not occurred, and provide public notice of the draft attribution finding. The Director shall publish notice of the draft attribution finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name October 24, 2003 Page 4555 Volume 9, Issue 43 Arizona Administrative Register / Secretary of State Notices of Final Rulemaking of the person and the person’s agent or attorney, if any, and shall clearly set forth reasons why the Director should review the draft attribution finding. The Director shall issue a final attribution finding after the public comment period. If the Director finds existing stationary sources cause or contribute to visibility impairment in a mandatory Federal Class I area, the source shall be subject to a BART Control Analysis under R18-2-1605. R18-2-1605. BART Control Analysis; Finding A. The Director shall analyze for BART controls each existing stationary source for which a final attribution finding is made under R18-2-1604(C). The Director shall consider the following factors: 1. Available control technology; 2. New source performance standards (NSPS) in Article 9; 3. Alternative control systems if retrofitting to comply with applicable NSPS standards in Article 9 is infeasible; 4. Cost of compliance; 5. Energy and non-air quality environmental impacts of compliance; 6. Existing pollution control technology in use at the source or small group of sources; 7. Remaining useful life of the source or small group of sources; 8. Net environmental impact associated with the proposed emission control system; 9. Economic impacts associated with installing and operating the proposed emission control system; and 10. Degree of improvement in visibility anticipated to result from application of the proposed emission control system. B. The Director shall issue a draft BART finding, and provide public notice of the draft BART finding. The Director shall publish notice of the draft BART finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, and shall clearly set forth reasons why the Director should review the draft BART finding. The Director shall issue a final BART finding after the public comment period. 1. The Director shall submit each final BART finding to the Administrator as a revision to the SIP. 2. The Director shall require that each existing stationary source meet BART as expeditiously as practicable but in no case later than five years after EPA approval of the SIP revision. C. If the Director determines that technological or economic limitations on the applicability of measurement methodology to a particular existing stationary source would make the imposition of an emission standard infeasible, the Director may, as part of the finding under subsection (B), prescribe a design, equipment, work practice, operational standard, or combination of design, equipment, work practice, or operational standard. The standard, to the degree possible, shall set forth the emission reduction to be achieved by implementation of the design, equipment, work practice, or operation, and shall provide for compliance by means that achieve equivalent results. D. The Director shall make a finding that the attributable source satisfies the BART requirement if the attributable source: 1. Voluntarily applies best available retrofit technology; 2. Previously applied emission control standards equivalent to BART; or 3. Agrees to shutdown or curtail operations at the attributable source within five years of the finding. An attributable source that does not shutdown or curtail operations shall meet BART as expeditiously as practicable, but in no case later than five years after EPA’s approval of the revision to the SIP. E. If the Director determines that the imposition of BART or a standard under subsection (C) is infeasible at the time of the finding, the Director shall require the attributable source to install and operate BART at a later date when the Director determines that BART or equivalent controls are feasible. F. The Director shall provide for a BART control analysis of any existing stationary source that might cause or contribute to impairment of visibility in any mandatory Federal Class I area identified under this Article at such time as the Administrator determines new control technology for the pollutant becomes reasonably available: 1. The pollutant is emitted by that existing stationary source, 2. Controls representing BART for the pollutant have not previously been required under this Article, and 3. The impairment of visibility in any mandatory Federal Class I area is reasonably attributable to the emissions of that pollutant. R18-2-1606. Exemption from BART Any existing stationary source required to install, operate, and maintain BART under this Article, may apply to the Administrator for an exemption from that requirement according to 40 CFR 51.303. The existing stationary source shall obtain the Director’s written concurrence before sending the application for exemption to the Administrator. Volume 9, Issue 43 Page 4556 October 24, 2003 Appendix A-5b. Notification letters to FLMS on contact person, and Public Comment Period Appendix A-5 – Attributable Impairment Arizona Regional Haze SIP AQDP LN00:088 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Governor Jane Dee Hull Jacqueline E. Schafer, Director April 13, 2000 Eleanor Townes US Forest Services 517 Gold Avenue SW Region Albuquerque, New M exico 87105 Dear M s. Townes: I am writing to welcome your participation in the Arizona Department of Environmental Quality’s (ADEQ) efforts to improve visibility in our Class I areas. One of our duties under the EPA Regional Haze Regulations (64 Fed. Reg. 35,714, July 1, 1999) is to notify you of our state contact person for regional haze issues. M ike George, Assessment Section M anager, Air Quality Division, has been assigned this responsibility. He can be reached at (602)207-2274. General inquiries may also be directed to Corky M artinkovic of the Air Quality Planning Section at (602)207-2372. ADEQ will also send written notices to all affected federal land managers of public hearings to be held prior to submittal of a related State Implementation Plan (SIP) to EPA. Arizona is presently under a Federal Implementation Plan (FIP) for reasonably attributable visibility impairment, but is developing a SIP revision to replace the FIP. You will receive an official notice when the public hearing date is finalized, which is expected to be later this year. A draft SIP will be included with the notice of public hearing date for review and comment. Further, affected federal land managers will be notified of applicable rulemaking activities. ADEQ looks forward to working with you to protect our clean air resource. If you have questions or comments, you may contact me at (602)207-2308, or M ike and Corky at the above phone numbers. Sincerely, Nancy C. Wrona, Director Air Quality Division 3033 North Central Avenue, P hoenix, Arizona 85012, (602)207-2300 cc: M ike George, ADEQ Theresa Pella, ADEQ Pete Lahm, ADEQ 3033 North Central Avenue, P hoenix, Arizona 85012, (602)207-2300 A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Joseph Alston, Federal Land Manager Grand Canyon National Park P.O. Box 129 Grand Canyon, AZ 86023 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Alston: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Joseph Alston Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Lee Baiza, Federal Land Manager Petrified Forest National Park P.O. Box 2217 Petrified Forest, AZ 86028 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Baiza: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper Lee Baiza August 22, 2003 Page 2 cc: Joseph Alston Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Carl Bowman, Federal Land Manager Grand Canyon National Park P.O. Box 129 Grand Canyon, AZ 86023 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Bowman: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Carl Bowman Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Ms. Sarah Craighead, Federal Land Manager Saguaro National Monument 3693 S. Old Spanish Trail Tucson, AZ 85730 Re: Arizona’s Regional Haze State Implementation Plan Dear Ms. Craighead: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Sarah Craighead Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Harv Forsgren, Federal Land Manager U.S. Forest Service – Southwest Region 333 Broadway SE Albuquerque, NM 87102 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Forsgren: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Harv Forsgren Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Michael King Pete Lahm Neil Mangum John McGee Colleen McKaughan Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Michael King, Federal Land Manager Pine Mountain Wilderness 344 S. Cortez Street Prescott, AZ 86303 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Siderits: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Michael King Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Sideritz Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Pete Lahm, Federal Land Manager U.S. Forest Service c/o Arizona Department of Environmental Quality 1110 W. Washington Street, 3415A-3 Phoenix, AZ 85007 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Lahm: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Pete Lahm Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Neil Mangum John McGee Colleen McKaughan Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Neil Mangum, Federal Land Manager Chiricuahua National Park 13063 E. Boenito Canyon Wilcox, AZ 85643 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Mangum: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Neil Mangum Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. John McGee, Federal Land Manager Galiuro Wilderness 300 W. Congress Tucson, AZ 85701 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. McGee: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division John McGee Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Bruce Polkowsky, Federal Land Manager National Park Service P.O. Box 25287 Denver, CO 80225 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Polkowsky: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Bruce Polkowsky Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum John McGee Colleen McKaughan Joseph Mikitish Nora Rasure Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Ms. Nora Rasure, Federal Land Manager Sycamore Canyon Wilderness 2323 E. Greenlaw Lane Flagstaff, AZ 86004 Re: Arizona’s Regional Haze State Implementation Plan Dear Ms. Rasure: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Nora Rasure Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Chris Shaver Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Ms. Chris Shaver, Federal Land Manager National Park Service P.O. Box 25287 Denver, CO 80225 Re: Arizona’s Regional Haze State Implementation Plan Dear Ms. Shaver: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Chris Shaver Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum John McGee Colleen McKaughan Joseph Mikitish Bruce Polkowsky Nora Rasure Karl Siderits Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Karl Siderits, Federal Land Manager Sierra Ancha/Superstition/Mazatzal Wildernesses 2324 E. McDowell Road Phoenix, AZ 85006 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Siderits: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Karl Siderits Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Mike Williams Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Mr. Mike Williams, Federal Land Manager Sycamore Canyon Wilderness 800 S. 6th Street Williams, AZ 86046 Re: Arizona’s Regional Haze State Implementation Plan Dear Mr. Williams: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Mike Williams Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Elaine Zieroth A RIZONA D EPARTMENT OF E NVIRONMENTAL Q UALITY Janet Napolitano Governor 1110 West Washington Street y Phoenix, Arizona 85007 (602) 771-2300 y www.adeq.state.az.us Stephen A. Owens Director August 22, 2003 Ms. Elaine Zieroth, Federal Land Manager Mt. Baldy Wilderness P.O. Box 640 Springerville, AZ 85938 Re: Arizona’s Regional Haze State Implementation Plan Dear Ms. Zieroth: The purpose of this letter is to provide notice to you in accordance with 40 CFR 51.302(a)(2)(ii), regarding the availability of a draft Regional Haze State Implementation Plan (SIP) for Arizona. In April 2000, I sent notices to the federal land managers that Arizona was beginning to develop a state implementation plan to address visibility impairment in the Class I areas. Arizona’s Regional Haze SIP will address visibility impairment for the four mandatory Federal Class I areas in Arizona that are part of the Grand Canyon Visibility Transport Commission’s Colorado Plateau: Grand Canyon National Park, Petrified Forest National Park, Sycamore Canyon Wilderness, and Mount Baldy Wilderness. Consultation with the federal land managers is an integral part of the regional haze regulations, and we invite you to participate in the review of the proposed SIP during the upcoming 30-day public comment period. The proposed SIP will be posted to the ADEQ Website at www.adeq.state.az.us/environ/air/plan/haze. It is ADEQ’s intent to have the Regional Haze SIP available for public comment in mid-September of this year, culminating with public hearings held throughout the state during the middle or end of October. A notice regarding the commencement of the public comment period and dates/locations of the public hearings will be sent separately. The SIP must be submitted to EPA by December 31, 2003, to meet the requirements of 40 CFR 51.309. Until further notice, I will be the contact person for regional haze at ADEQ. General inquiries may still be directed to Corky Martinkovic of the Air Quality Planning Section at (602) 7712372 or dam@ev.state.az.us. ADEQ looks forward to working with you to protect our national parks and wilderness areas. Sincerely, Nancy C. Wrona, Director Air Quality Division Elaine Zieroth Northern Regional Office 1515 East Cedar Avenue y Suite F y Flagstaff, AZ 86004 (928) 779 0313 Southern Regional Office 400 West Congress Street y Suite 433 y Tucson, AZ 85701 (520) 628 6733 Printed on recycled paper August 22, 2003 Page 2 cc: Joseph Alston Lee Baiza Carl Bowman Sarah Craighead Harv Forsgren Michael King Pete Lahm Neil Mangum Colleen McKaughan John McGee Joseph Mikitish Bruce Polkowsky Nora Rasure Chris Shaver Karl Siderits Mike Williams Appendix A-5c. Supporting Documents Related To The Promulgation Of Arizona’s RAVI Rule Appendix A-5 – Attributable Impairment Arizona Regional Haze SIP ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 West Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director MEMORANDUM DATE: January 7, 2003 TO: Visibility Rule Stakeholders FROM: Nancy C. Wrona, Director Air Quality Division SUBJECT: Preliminary Draft Notice of Proposed Rulemaking for Reasonably Attributable Visibility Impairment (RAVI) Rule You are invited to a stakeholder meeting on Tuesday, January 14, 2003, 1:30 p.m., Room 145, ADEQ, 1110 W. Washington, Phoenix, Arizona. The purpose of this meeting is to review a draft Notice of Proposed Rulemaking (NPRM) for the Reasonably Attributable Visibility Impairment (RAVI) rule. The RAVI rule, formerly known as the “visibility rule,” has had numerous stakeholder reviews, but now contains the preamble portion required for submission to the Secretary of State. Once the RAVI rule is submitted to the Secretary of State for publication in the Arizona Administrative Register, the rule will have a 30 day public review period, culminating in a public hearing in mid March 2003. The proposed rule deals with state requirements within the federal visibility/regional haze rule 40 CFR §§51.302 - 307. Sections 302 through 307 deal with a specific type of visibility impairment caused by certain categories of exiting stationary sources operating in and near national parks and wilderness areas (federal Class I areas). Due to the length of the draft NPRM, we will not be faxing the document with this notice. However, you can access the RAVI rule via the ADEQ Web page at www.adeq.state.az.us/environ/air/plan/haze.html. You can also receive a copy of the draft NPRM by contacting Corky Martinkovic at the number or e-mail shown below. I look forward to seeing you on January 14th. If you have any questions regarding the meeting, please call me at (602) 771-2308 or Corky Martinkovic at (602) 771-2372, or by e-mail at martinkovic.deborrah@ev.state.az.us. If you are in Arizona, but outside of the Phoenix area, call 1-800-234-5677, then dial extension 771-2372. Copies of the draft NPRM will also be available at the January 14th meeting. Northern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 86004 (928) 779-0313 Southern Regional Office 400 West Congress Street • Suite 433 • Tucson, AZ 85701 (520) 628-6733 Printed on recycled paper PUBLIC NOTICE ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY PUBLIC HEARING ON NOTICE OF PROPOSED RULEMAKING REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT RULE The Arizona Department of Environmental Quality (ADEQ) will hold a public hearing to receive comments on the Notice of Proposed Rulemaking for Reasonably Attributable Visibility Impairment (RAVI) rule. This rule impacts specific stationary sources emitting 250 tons per year or more of visibility impairing air pollutants in or near Arizona’s 12 mandatory federal class I areas (national parks and wilderness areas). The rule directs the state of Arizona and the stationary sources on the actions necessary should a source or small group of sources be certified by a Federal Land Manager as possibly causing or contributing to visibility problems in any of the 12 national parks and wilderness areas. A public hearing on the Notice of Proposed Rulemaking will be held on Wednesday, April 7, 2003, at the Coconino Library, 300 W. Aspen, Flagstaff, Arizona. All interested parties will be given an opportunity at the public hearing to submit relevant comments, data, and views, orally and in writing. Written comments must be received at ADEQ by 5:00 p.m. on Friday, April 11, 2003. ADEQ anticipates sending the proposed rule and any comments received to the Governor’s Regulatory Review Council on or after April 21, 2003. All written comments should be addressed, faxed, or e-mailed to: Deborrah “Corky” Martinkovic Air Quality Planning Section Arizona Department of Environmental Quality 1110 W. Washington Street Phoenix, AZ 85012-2905 FAX: (602) 771-2366 E-Mail: martinkovic.deborrah@ev.state.az.us Copies of the proposal are available for review beginning Thursday, March 13 (ADEQ) and March 17 (Flagstaff), 2003, at the following locations: Arizona Department of Environmental Quality First Floor Library 1110 W. Washington Street Phoenix, Arizona 85012 Lorraine Akey, (602) 771-4335 Locally: Coconino Library 300 W. Aspen Flagstaff, Arizona Dawn Gardner, (928) 779-7670 PUBLIC NOTICE ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY PUBLIC HEARING ON NOTICE OF PROPOSED RULEMAKING REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT RULE The Arizona Department of Environmental Quality (ADEQ) will hold a public hearing to receive comments on the Notice of Proposed Rulemaking for Reasonably Attributable Visibility Impairment (RAVI) rule. This rule impacts specific stationary sources emitting 250 tons per year or more of visibility impairing air pollutants in or near Arizona’s 12 mandatory federal class I areas (national parks and wilderness areas). The rule directs the state of Arizona and the stationary sources on the actions necessary should a source or small group of sources be certified by a Federal Land Manager as possibly causing or contributing to visibility problems in any of the 12 national parks and wilderness areas. A public hearing on the Notice of Proposed Rulemaking will be held on Wednesday, April 8, 2003, at the Arizona Department of Environmental Quality, 1110 W. Washington Street, Room 145, Phoenix, Arizona. All interested parties will be given an opportunity at the public hearing to submit relevant comments, data, and views, orally and in writing. Written comments must be received at ADEQ by 5:00 p.m. on Friday, April 11, 2003. ADEQ anticipates sending the proposed rule and any comments received to the Governor’s Regulatory Review Council on or after April 21, 2003. All written comments should be addressed, faxed, or e-mailed to: Deborrah “Corky” Martinkovic Air Quality Planning Section Arizona Department of Environmental Quality 1110 W. Washington Street Phoenix, AZ 85012-2905 FAX: (602) 771-2366 E-Mail: martinkovic.deborrah@ev.state.az.us Copies of the proposal are available for review beginning Thursday, March 13, 2003, at the following locations: Arizona Department of Environmental Quality First Floor Library 1110 W. Washington Street Phoenix, Arizona 85012 Lorraine Akey, (602) 771-4335 Other Hearing Locations: Flagstaff - April 7, 2003 Tucson - April 9, 2003 PUBLIC NOTICE ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY PUBLIC HEARING ON NOTICE OF PROPOSED RULEMAKING REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT RULE The Arizona Department of Environmental Quality (ADEQ) will hold a public hearing to receive comments on the Notice of Proposed Rulemaking for Reasonably Attributable Visibility Impairment (RAVI) rule. This rule impacts specific stationary sources emitting 250 tons per year or more of visibility impairing air pollutants in or near Arizona’s 12 mandatory federal class I areas (national parks and wilderness areas). The rule directs the state of Arizona and the stationary sources on the actions necessary should a source or small group of sources be certified by a Federal Land Manager as possibly causing or contributing to visibility problems in any of the 12 national parks and wilderness areas. A public hearing on the Notice of Proposed Rulemaking will be held on Wednesday, April 9, 2003, at the State Office Building, 400 W. Congress, Room 158, Tucson, Arizona. All interested parties will be given an opportunity at the public hearing to submit relevant comments, data, and views, orally and in writing. Written comments must be received at ADEQ by 5:00 p.m. on Friday, April 11, 2003. ADEQ anticipates sending the proposed rule and any comments received to the Governor’s Regulatory Review Council on or after April 21, 2003. All written comments should be addressed, faxed, or e-mailed to: Deborrah “Corky” Martinkovic Air Quality Planning Section Arizona Department of Environmental Quality 1110 W. Washington Street Phoenix, AZ 85012-2905 FAX: (602) 771-2366 E-Mail: martinkovic.deborrah@ev.state.az.us Copies of the proposal are available for review beginning Thursday, March 13 (ADEQ) and March 17 (Tucson), 2003, at the following locations: Arizona Department of Environmental Quality First Floor Library 1110 W. Washington Street Phoenix, Arizona 85012 Lorraine Akey, (602) 771-4335 Locally: State Office Building 400 W. Congress, Room 158 Tucson, Arizona Julie Benner, (520) 628-6902 NOTICE OF PROPOSED RULEMAKING TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL ARTICLE 16. VISIBILITY; REGIONAL HAZE PREAMBLE 1. 2. Sections Affected Rulemaking Action R18-2-101 Amend R18-2-1601 New Section R18-2-1602 New Section R18-2-1603 New Section R18-2-1604 New Section R18-2-1605 New Section R18-2-1606 New Section The statutory authority for the rulemaking, including both the authorizing statute (general) and the statutes the rules are implementing (specific): General Authority: A.R.S. §§ 49-104(A)(11) and 49-425 Specific Authority: A.R.S. §§ 49-414 and 414.01 3. A list of all previous notices appearing in the Register addressing the proposed rule: Notice of Docket Opening: 9 A.A.R. 390, February 7, 2003 4. The name and address of agency personnel with whom persons may communicate regarding the rulemaking. Name: Deborrah “Corky” Martinkovic Address: ADEQ, Air Quality Planning Section, 1110 West Washington Street, Phoenix, AZ 85007 Telephone: (602) 771-2372 (Any extension may be reached in-state by dialing 1800-234-5677, and asking for a specific number.) Fax: (602) 771-2366 E-mail: martinkovic.deborrah@ev.state.az.us ADEQ RAVI NPRM, 2/4/03 1 5. An explanation of the rule, including the agency’s reasons for initiating the rule: Summary. This rule sets forth the process Arizona Department of Environmental Quality (ADEQ) will use to determine whether Best Available Retrofit Technology (BART) will be required for sources determined to be contributing to visibility impairment in a mandatory Federal Class I area. Federal regulations allow Federal Land Managers (FLMs) to certify sources defined in 40 CFR 51.301 as potential contributors to visibility impairment in any of the Arizona mandatory Federal Class I areas under Section 169A of the Clean Air Act (CAA). Background. In 1977 Congress added a new section to the Clean Air Act - Section 169A, Visibility Protection for Federal Class I Areas - which established a national goal for, “the prevention of any future, and the remedying of any existing impairment of visibility in mandatory class I Federal areas which impairment results from man-made air pollution.” In addition, the section required states to submit state implementation plans (SIPs) requiring best available retrofit technology (BART) for certain existing stationary sources found to cause or contribute to visibility impairment. On November 30, 1979, EPA promulgated a list of mandatory Federal Class I Areas (Class I areas) where visibility is an important value (44 FR 69122). There are 12 Class I areas identified in Arizona: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness (40 CFR 81.403). On December 2, 1980 (45 FR 80084), EPA defined the role of the FLMs in certifying visibility impairment in the mandatory Federal Class I areas. On November 24, 1987 (52 FR 45132), FLMs identified Petrified Forest National Park, Saguaro Wilderness, and Grand Canyon National Park, as having visibility impairment possibly attributable to stationary sources. Under the 1980 rule, if found to cause or contribute to the impairment, certain existing stationary sources operating in or near the identified Class I areas could be subject to BART (A list of sources eligible for the possible application of BART can be found at 40 CFR 51.301). On October 3, 1991, the Navajo Generating Station (NGS) was found by EPA to be causing or contributing to visibility impairment for the Grand Canyon National Park and eligible for BART (56 FR 50172). BART control analyses were subsequently performed by EPA, and other parties through related court actions. Under the 1980 rule, the federal expectation is that actions for determination of possible source attribution will be performed by the states. Therefore, Arizona needs ADEQ RAVI NPRM, 2/4/03 2 to be prepared to proceed with an attribution analysis and assessment for the application of controls upon any determination of a BART eligible source being the possible cause or contributor to visibility impairment in a Class I area. This rule addresses that need. Current Conditions. ADEQ is proposing that this rule apply to any source in existing stationary source categories identified in 40 CFR 51.301 that are operating in or near the mandatory federal Class I areas in Arizona. The source is an existing stationary facility that includes any reconstructed source that was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year of any regulated pollutant. ADEQ estimates that there are potentially 10 such sources within Arizona. “In existence” is interpreted by EPA to be consistent with the term, “commence construction” found in Prevention of Serious Deterioration (PSD) regulations (40 CFR 51.165(a)(1)(xvi) and 40 CFR 52.21 (b)(9)). If construction commenced after August 7, 1977, the source would be subject to the PSD/NSR (new source review) program (the state regulations are found at 18 A.C.C. 2, Article 4). However, EPA also notes “that sources, are not BART eligible if the only change at the plant was the addition of pollution controls. For example, if the only change at a copper smelter during the 1962 through 1977 time period was the addition of acid plants for the reduction of SO2 emissions, these emission controls would not themselves trigger a BART review.”1 Under this proposed rule, ADEQ, when analyzing an attributable source for BART controls, must consider several factors including, for example, costs, remaining useful life of the source, and degree of improvement anticipated to result from the application of the controls (the factors are detailed in R18-21605). Sources required by ADEQ to install and operate BART controls have a final opportunity to request exemption from the requirement prior to the application of controls. This opportunity for a federal exemption from BART, is contained in R18-2-1606, and 40 CFR 51.303. Summary. This rule outlines the process through which sources eligible for the application of BART will proceed if certified by the state of Arizona or an FLM as possibly causing or contributing to visibility impairment due to attribution. If found to be attributable for the impairment, a BART analysis will be performed to determine the level of controls necessary to remedy the impairment. This rule enables Arizona to fulfill the requirements of the Clean Air Act and the goal of section 169A of the Act to return the Nation’s federal parks and wilderness areas to natural conditions. 1 EPA proposed rule, 66 Federal Register 38119, July 20, 2001. ADEQ RAVI NPRM, 2/4/03 3 Section-by-section Explanation for the Proposed Rule R18-2-1601 This section lists the definitions that apply to this rule. R18-2-1602 This section lists the Class I areas addressed by this rule for the applicable existing stationary facilities, as defined in R18-2-1601(2). R18-2-1603 This section establishes the procedure for certification of impairment by either a Federal Land Manager with authority over a mandatory Federal Class I area, or the Director, should either believe there exists reasonably attributable visibility impairment in a Federal Class I area as listed in R18-2-1602. R18-2-1604 This section establishes the procedure for an attribution analysis after certification of a source or group of sources as outlined in R18-2-1603. Upon completion of the attribution analysis, the procedure for the Director to issue draft and final attribution findings is outlined in R18-2-1604(C). R18-2-1605 This section establishes the best available retrofit technology (BART) analysis procedure after a source is identified under R18-2-1604. Upon completion of the BART analysis, the procedure for the Director to issue draft and final BART findings, including alternatives to emission standards, is outlined in R18-21605(B) and (C), respectively. The specific conditions where BART would be satisfied due to past or planned actions by the facility are outlined in R18-21605(D). EPA determinations regarding new technology that might require a BART analysis for an applicable source, regardless of a source or small group of sources previously being certified and found attributable, are covered in R18-21605(E). R18-2-1606 This section establishes the procedures for obtaining a federal exemption from a BART requirement. 6. A reference to any study relevant to the rule that the agency proposes to rely on in its evaluation of or justification for the proposed rule or proposes not to rely on in its evaluation of or justification for the rule, where the public may obtain or review each study, all data underlying each study, and any analysis of each study and other supporting material: Not Applicable ADEQ RAVI NPRM, 2/4/03 4 7. A showing of good cause why the rule is necessary to promote a statewide interest if the rule will diminish a previous grant of authority of a political subdivision of this state: Not applicable 8. The preliminary summary of the economic, small business, and consumer impact: A. Rule Identification These rules would amend R18-2-101 (“visibility impairment” definition) and add new sections R18-21601 through R18-2-1606. For sources under ADEQ jurisdiction, the rules would take the place of federal regulations that currently govern this area. B. Entities Directly Impacted 1. Federal Land Managers. Proposed R18-2-1603 would allow Federal Land Managers (FLMs) to certify visibility impairment in mandatory Class I areas. This is already allowed by federal rule. Under R18-21601 of the proposed rule, the FLMs able to certify impairment in Arizona are with the United States Forest Service and the National Park Service. There are no FLMs in Arizona from the United States Fish and Wildlife Service, because this agency does not have jurisdiction over any of Arizona’s mandatory federal Class I areas. 2. ADEQ. Proposed R18-2-1604 would require ADEQ to identify stationary sources that could cause or contribute to the certified visibility impairment. This function is currently carried out by EPA. Proposed R18-2-1605 would require ADEQ to analyze for BART (best available retrofit technology) controls those sources identified as causing or contributing to visibility impairment. This function is currently carried out by EPA. The impact of this rule on ADEQ would primarily be on the Air Quality Division, Permits and Assessment sections. 3. Stationary sources. Proposed R18-2-1605 would also require stationary sources identified in #2 to install or operate the BART as determined by the Director. Currently, EPA determines and requires BART. To determine impacted stationary sources, ADEQ staff reviewed Title V permits from ADEQ’s Air Permit files. Of the 26 industry categories listed in 40 CFR 51.301, only five categories were found to exist under ADEQ’s jurisdiction: steam electric plants, cement plants, primary copper smelters, lime plants, and industries using non-utility boilers. As a result, potentially 10 sources, representing 16 BART eligible units (boilers and kilns), could be affected by this proposed rule. The combined potential to emit ADEQ RAVI NPRM, 2/4/03 5 from these sources totaled 94,287 tons per year for NO x, 141,036 tons per year for SO 2, and 12,146 tons per year for PM. The combined potential to emit for all pollutants for these 10 sources total approximately 250,000 tons per year. C. Probable Costs and Benefits Associated with the BART/Visibility Impairment Process 1. Direct Costs - FLMs: FLM activities to certify visibility impairment in mandatory Class I areas may involve preparation and analysis of monitoring data, emission inventories, meteorological records, etc. ADEQ estimates that this cost per certification could be as much as $50,000 if extensive analysis is conducted. These costs exist whether or not these proposed rules become final. 2. Direct Costs - ADEQ: ADEQ costs related to identifying whether a BART eligible stationary source causes or contributes to visibility impairment in Class I areas are based on the activities identified in R182-1604(A). ADEQ estimates that these costs could range from $100,000 – 200,000 per attribution analysis, and be primarily borne by the ADEQ’s Air Quality Assessment Section. Costs related to analyzing identified sources for BART are based on the activities identified in proposed R18-2-1605(A) and will be moderate, but less expensive than the attribution analysis. These costs will be primarily born by the Permits Section. These costs would not accrue to the State unless the proposed rule becomes final. Finally, incorporating BART into an existing State air quality permit may require additional resources from the Permits Section. However, these costs, unlike costs for the attribution and BART analysis, would be covered by permit revision fees paid by the source, and would exist whether or not these proposed rules become final. 3. Direct Costs - Stationary sources: If a source or small group of sources is found to cause or contribute to visibility impairment, and the BART determination requires installation of retrofit controls, costs to sources required to install BART would be substantial. The total cost to install a technology similar to BART at the Navajo Generating Station was estimated by SRP to be in the hundreds of millions of dollars (51 Federal Register 50172, October 3, 1991). However, the example of the Navajo Generating Station shows costs to install technology similar to BART can result even where there is no state rule. According to EPA, “Where a State defaults on its obligations under the visibility regulations, EPA may act in place of the State pursuant to a FIP under section 110(c) of the Act, 42 U.S.C. 7410(c) 2, and promulgate such limitation and measures as are required to achieve reasonable progress.”(Ibid. at 50173, footnote not included). Although ADEQ is listing these costs for information purposes, ADEQ is not attributing any costs to install and operate BART to this rule because such requirements can be imposed by the federal government without any State rule. ADEQ RAVI NPRM, 2/4/03 6 Benefits. Two kinds of benefits are associated with this proposed rule. The first is reduced emissions. Although, BART could be required to be installed on sources even without this state rule, it is helpful to list the emission benefits. When BART is installed, visibility is improved. Over 4 million recreation visits were made to Grand Canyon National Park in FY 2001. These visits generate substantial revenue in and for the state of Arizona. Other scenic resources that could also be improved with the installation of BART, and, though less significant than the Grand Canyon, would enhance the tourism resources of Arizona, as well as the quality of life for Arizona citizens. In addition, reduction of visibility-impairing emissions also has health benefits. The second benefit is replacement of federal regulation with state regulation. The lack of state regulations implementing BART results in Arizona sources being subject to federal regulation implemented by EPA from Washington and San Francisco. These proposed rules would place the identification and analysis of BART sources at ADEQ rather than with EPA. Arizona is currently under a visibility Federal Implementation Plan (FIP), and one or two sources have considered or implemented technology similar to BART under federal rules. Because ADEQ already permits many of these sources, ADEQ is more familiar with the various factors that go into the BART analysis. This would be a benefit to sources being regulated. ADEQ would be implementing the same BART rules that EPA does. The rule further allows ADEQ to proceed with the implementation of the entire federal rule for visibility improvement. The proposed rule addresses the requirements of 40 C.F.R. §§51.302 – 307. These sections must be satisfied before ADEQ can implement the requirements of 40 C.F.R. §§51-308 and 309. The plan to implement Section 309 must be submitted to EPA by December 31, 2003. D. Small Business Analysis A.R.S. §41-1055(B)(5) requires agencies to state the probable impact of a rulemaking on small businesses. A.R.S. §41-1035 requires agencies to reduce the impact of a rule on small businesses by using certain methods when they are legal and feasible in meeting the statutory objectives for the rule making. These methods include: (1) exempting them from any or all rule requirements, (2) establishing performance standards which would replace any design or operational standards, or (3) instituting reduced compliance or reporting requirements. An agency may accomplish the third method by establishing less stringent requirements, consolidating or simplifying requirements, or setting less stringent schedules or deadlines. ADEQ RAVI NPRM, 2/4/03 7 "Small business" is defined in A.R.S. §41-1001 as “a concern, including its affiliates, which is independently owned and operated, which is not dominant in its field and which employs fewer than one hundred full-time employees or which had gross annual receipts of less than four million dollars in its last fiscal year.” Interpreting this definition means that if a concern has annual gross receipts of more than four million dollars, but fewer than 100 employees, it would not be classified as a small business. ADEQ expects that none of the potential BART eligible sources would be classified as a small business. A preliminary conclusion is that this proposed rule will not impact other small businesses. However, if a BART eligible source would qualify as a small business, ADEQ is unable to establish different requirements for small businesses. Except for applying for an exemption, as mentioned under “Alternative Methods,” ADEQ cannot establish less stringent requirements or exemptions for small businesses, or any BART eligible source. ADEQ requests comment and additional information relating to any of the conclusions reached in this preliminary EIS. 9. The name and address of agency personnel with whom persons may communicate regarding the accuracy of the economic, small business, and consumer impact statement: Name: David Lillie Address: ADEQ, Air Quality Planning Section, 1110 West Washington, Phoenix, AZ 85007 Telephone: (602) 771-4461 (Any extension may be reached in-state by dialing 1-800-234- 5677, and asking for a specific number.) Fax: (602) 771-2366 E-mail: Lillie.David@ev.state.az.us 10. The time, place, and nature of the proceedings for the making, amendment, or repeal of the rule or, if no proceeding is scheduled, where, when and how persons may request an oral proceeding on the proposed rule: Date: April 7, 2003 Time: 4:30 p.m. Location: Coconino Library, 300 W. Aspen, Flagstaff, AZ ---------------------------------------ADEQ RAVI NPRM, 2/4/03 8 Date: April 8, 2003 Time: 4:30 p.m. Location: ADEQ, 1110 W. Washington St, Rm 145, Phoenix, AZ --------------------------------------Date: April 9, 2003 Time: 4:30 p.m. Location: State Office Building, 400 W. Congress, Rm 158, Tucson, AZ ---------------------------------------Nature: Oral Proceedings with opportunity for formal comments on the record Close of Comment: 5:00 p.m., April 11, 2003 11. Any other matters prescribed by statute that are applicable to the specific agency or to any specific rule or class of rules: Not applicable 12. Incorporation by reference and their location in the rule: Not applicable 13. The full text of the rule follows: ADEQ RAVI NPRM, 2/4/03 9 TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL ARTICLE 1. GENERAL Section R18-2-101 Definition of “visibility impairment” …………………………… Amend ARTICLE 16. VISIBILITY; REGIONAL HAZE Section R18-2-1601 Definitions ……………………………………………………… New Section R18-2-1602 Applicability ……………………………………………………. New Section R18-2-1603 Certification of Impairment …………………………………….. New Section R18-2-1604 Attribution Analysis; Finding …………………………………... New Section R18-2-1605 BART Control Analysis; Finding ……………………………….New Section R18-2-1606 Exemption from BART ………………………………………… New Section ARTICLE 1. GENERAL R18-2-101. Definitions In addition to the definitions prescribed in A.R.S. §§ 49-101, 49-401.01, 49-421, 49-471, and 49-541, in this Chapter, unless otherwise specified: 1. No change 2. No change a. No change b. No change c. No change d. No change e. No change 3. No change 4. No change 5. No change 6. No change ADEQ RAVI NPRM, 2/4/03 10 7. No change 8. No change 9. No change 10. No change 11. a. No change b. No change c. No change d. No change e. No change f. No change No change a. No change b. No change c. No change 12. No change 13. No change 14. No change a. No change b. No change 15. No change 16. No change 17. No change 18. No change 19. No change 20. No change 21. No change 22. No change 23. No change 24. No change 25. No change 26. No change 27. No change a. No change ADEQ RAVI NPRM, 2/4/03 11 b. No change 28. No change 29. No change 30. No change 31. No change 32. No change 33. No change 34. No change 35. No change 36. No change 37. No change 38. No change 39. No change 40. No change. 41 No change 42. No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change 43. No change 44. No change a. No change b. No change c. No change ADEQ RAVI NPRM, 2/4/03 12 d. No change 45. No change 46. No change 47. No change 48. No change 49. No change 50. No change 51. No change 52. No change 53. No change 54. No change 55. No change 56. No change 57. No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change 58. No change 59. No change 60. No change 61. No change 62. No change 63. No change a. No change b. No change c. No change ADEQ RAVI NPRM, 2/4/03 13 i. No change ii. No change iii. No change iv. No change v. No change No change (2) No change vi. No change vii. No change viii. No change ix. 64. (1) (1) No change (2) No change No change (1) No change (2) No change x. No change xi. No change No change a. No change b. No change c. i. No change ii. No change No change i. No change ii. No change iii. No change iv. No change v. No change vi. No change vii. No change viii. No change ix. No change x. No change ADEQ RAVI NPRM, 2/4/03 14 xi. No change xii. No change xiii. No change xiv. No change xv. No change xvi. No change xvii. No change xviii. No change xix. No change xx. No change xxi. No change xxii. No change xxiii. No change xxiv. No change xxv. No change xxvi. No change xxvii. No change 65. No change 66. No change 67. No change 68. No change 69. No change 70. No change 71. No change 72. No change a. b. No change i. No change ii. No change No change i. No change ii. No change c. No change d. No change ADEQ RAVI NPRM, 2/4/03 15 e. No change f. No change g. i. No change ii. No change iii. No change iv. No change No change 73. No change 74. No change 75. No change 76. No change 77. No change 78. No change 79. No change 80. No change 81. No change 82. No change 83. No change a. No change b. No change c. No change d. No change 84. No change 85. No change 86. No change 87. No change 88. No change 89. No change 90. No change 91. No change 92. No change 93. No change 94. No change ADEQ RAVI NPRM, 2/4/03 16 a. No change b. No change c. No change d. No change 95. No change 96. No change 97. No change 98. a. No change b. No change c. No change d. No change e. No change No change a. 99. No change i. No change ii. No change iii. No change iv. No change v. No change vi. No change vii. No change b. No change c. No change No change a. No change b. No change 100. No change 101. No change 102. No change 103. No change 104. No change a. No change b. No change ADEQ RAVI NPRM, 2/4/03 17 c. No change d. No change 105. No change 106. No change 107. No change a. No change b. No change 108. No change 109. No change 110. No change 111. No change 112. No change 113. No change 114. No change 115. No change 116. No change 117. No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change m. No change n. No change o. No change p. No change ADEQ RAVI NPRM, 2/4/03 18 q. No change r. No change s. No change t. No change u. No change v. No change w. No change x. No change y. No change z. No change aa. No change bb. No change cc. No change dd. No change ee. No change ff. No change gg. No change hh. No change ii. No change jj. No change kk. No change ll. No change mm. No change nn. No change oo. No change pp. No change qq. No change rr. No change ss. No change tt. No change uu. No change vv. No change ww. No change ADEQ RAVI NPRM, 2/4/03 19 xx. No change 118. No change 119. No change 120. No change 121. No change 122. No change 123. “Visibility impairment” means any humanly perceptible change in visibility (light extinction, visual range, contrast, and coloration) from that which would have existed under natural conditions. 124. No change 125. No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change m. No change n. No change o. No change p. No change q. No change r. No change s. No change t. No change u. No change v. No change ADEQ RAVI NPRM, 2/4/03 20 w. No change x. No change y. No change z. No change aa. No change bb. No change cc. No change dd. No change ee. No change ff. No change gg. No change hh. No change ii. No change jj. No change kk. No change ll. No change mm. No change nn. No change oo. No change pp. No change qq. No change rr. No change ss. No change 126. i. No change ii. No change iii. No change iv. No change No change ARTICLE 16. VISIBILITY; REGIONAL HAZE R18-2-1601. Definitions In addition to the definitions contained in Articles 1 and 4 of this Chapter and A.R.S. § 49-401.01, the ADEQ RAVI NPRM, 2/4/03 21 following definitions apply to this Article: 1. “Best available retrofit technology (BART)” means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant that is emitted by an existing stationary facility. The emission limitation is established on a case-by-case basis in accordance with R18-2-1605. 2. “Existing stationary facility” means any of the following stationary sources of air pollutants, including any reconstructed source, which was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any air pollutant. In determining potential to emit, fugitive emissions, to the extent quantifiable, must be counted. a. Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour heat input, b. Coal cleaning plants (thermal dryers), c. Kraft pulp mills, d. Portland cement plants, e. Primary zinc smelters, f. Iron and steel mill plants, g. Primary aluminum ore reduction plants, h. Primary copper smelters, i. Municipal incinerators capable of charging more than 250 tons of refuse per day, j. Hydrofluoric, sulfuric, and nitric acid plants, k. Petroleum refineries, l. Lime plants, m. Phosphate rock processing plants, n. Coke oven batteries, o. Sulfur recovery plants, p. Carbon black plants (furnace process), q. Primary lead smelters, r. Fuel conversion plants, s. Sintering plants, t. Secondary metal production facilities, u. Chemical process plants, v. Fossil-fuel boilers of more than 250 million British thermal units per hour heat input, ADEQ RAVI NPRM, 2/4/03 22 3. w. Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, x. Taconite ore processing facilities, y. Glass fiber processing plants, and z. Charcoal production facilities. “Federal Land Manager” means the Secretary of the department, or the Secretary's designee, with authority over the Federal Class I area. 4. “Mandatory Federal Class I Area” means any area identified in 40 CFR §§81.400-81.436. 5. “Reasonably attributable” means ascribable by visual observation or other techniques the Director deems appropriate. 6. “Reasonably attributable visibility impairment” means visibility impairment that is caused by the emission of air pollutants from one source, or a small group of sources. R18-2-1602. Applicability This Article applies to any existing stationary source located in the state that may reasonably be anticipated to cause or contribute to visibility impairment in any mandatory Federal Class I area identified in 40 CFR §§81.401-81.436. Mandatory Federal Class I areas within Arizona are: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness. R18-2-1603. A. Certification of Impairment A Federal Land Manager with authority over a mandatory Federal Class I area may certify to the Director, at any time, that there exists reasonably attributable visibility impairment in the mandatory Federal Class I area. The Director may also certify that there exists reasonably attributable visibility impairment in any mandatory Federal Class I area as necessary to assure reasonable progress under section 169A(b)(2) of the Clean Air Act. B. Documentation from the affected Federal Land Manager or Director shall include: 1. The mandatory Federal Class I area for which visibility impairment is being certified, 2. Any information documenting the basis for the certification of impairment. R18-2-1604. A. Attribution Analysis; Finding Upon certification of reasonably attributable visibility impairment in any mandatory Federal ADEQ RAVI NPRM, 2/4/03 23 Class I area, the Director shall conduct an attribution analysis to identify each existing stationary source that may be reasonably anticipated to cause or contribute to visibility impairment. The Director shall notify the Federal Land Manager, affected source or small group of sources, and local air pollution control officer of the intent to conduct an attribution analysis. The attribution analysis shall be based on the following: 1. Monitoring information obtained through the Arizona Class I Visibility Monitoring Network or special studies approved by ADEQ to ascertain: 2. a. The times visibility impairment occurred, and b. The pollutants contributing to the visibility impairment. Transport analysis or air quality modeling based upon meteorological records to ascertain whether the pollutants were transported to the mandatory Federal Class I area. 3. Other available studies, modeling analysis, and emissions inventories of point, area and mobile source emissions to ascertain: a. The pollutant or pollutants causing the impairment, and b. The source, or small group of sources, emitting the impairing pollutant or pollutants. 4. Other relevant supporting documentation provided by the Federal Land Manager or Director used to make the draft attribution analysis finding. 5. B. Consideration of any documentation provided by the source or small group of sources. In conducting the attribution analysis, the Director shall use monitoring information, meteorological records, and emissions inventories that represent times and locations reasonably concurrent with the visibility impairment. C. The Director shall issue a draft attribution finding that impairment has or has not occurred, and provide public notice of the draft attribution finding. The Director shall publish notice of the draft attribution finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, if any, and shall clearly set forth reasons why the draft attribution finding should be reviewed. A final attribution finding shall be issued after the public comment period. Existing stationary sources found to cause or contribute to visibility impairment in a mandatory Federal Class I area shall be subject to a BART Control Analysis under R18-2-1605. ADEQ RAVI NPRM, 2/4/03 24 R18-2-1605. A. BART Control Analysis; Finding The Director shall analyze for BART controls each existing stationary source for which a final attribution finding is made under R18-2-1604(C). The Director shall consider the following factors: 1. Available control technology; 2. New source performance standards (NSPS) as adopted in Article 9; 3. Alternative control systems if retrofitting to comply with applicable NSPS standards adopted in Article 9 is found infeasible. 4. Cost of compliance; 5. Energy and non-air quality environmental impacts of compliance; 6. Existing pollution control technology in use at the source or small group of sources; 7. Remaining useful life of the source or small group of sources; 8. Net environmental impact associated with the proposed emission control system; 9. Economic impacts associated with installing and operating the proposed emission control system; and 10. Degree of improvement in visibility anticipated to result from application of the proposed emission control system. B. The Director shall issue a draft BART finding, and provide public notice of the draft BART finding. The Director shall publish notice of the draft BART finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, and shall clearly set forth reasons why the draft BART finding should be reviewed. The Director shall issue a final BART finding after the public comment period. 1. The Director shall submit each final BART finding that an existing stationary source is required to meet BART to the Administrator as a revision to the state implementation plan (SIP). 2. The Director shall require that each existing stationary source meet BART as expeditiously as practicable but in no case later than five years after EPA approval of the revision to Arizona’s State Implementation Plan. C. If the Director determines that technological or economic limitations on the applicability of measurement methodology to a particular existing stationary source would make the imposition of an emission standard infeasible, the Director may, as part of the finding under subsection (B), ADEQ RAVI NPRM, 2/4/03 25 instead prescribe a design, equipment, work practice, or other operational standard, or combination thereof. Such standard, to the degree possible, is to set forth the emission reduction to be achieved by implementation of such design, equipment, work practice or operation, and must provide for compliance by means which achieve equivalent results. D. The Director shall make a finding that the attributable source has satisfied the BART requirement if the attributable source has: 1. Voluntarily applied best available retrofit technology; 2. Previously applied emission control standards equivalent to BART; or 3. Agreed to shutdown or curtail operations at the attributable source within 5 years of the finding. An attributable source that does not shutdown or curtail operations shall proceed to meet BART as expeditiously as practicable, but in no case later than five years after EPA’s approval of the revision to Arizona’s State Implementation Plan. E. If the Director determines that the imposition of BART or a standard pursuant to subsection C of this section is not feasible at the time of the finding, the attributable source shall be required to install and operate BART upon a determination by the Director at a later date that BART or equivalent controls are now feasible. F. The Director shall provide for a BART control analysis of any existing stationary source that might cause or contribute to impairment of visibility in any mandatory Federal Class I area identified under this Article at such times, as determined by the Administrator, new technology for control of the pollutant becomes reasonably available, if: 1. The pollutant is emitted by that existing stationary source, 2. Controls representing BART for the pollutant have not previously been required under this Article, and 3. The impairment of visibility in any mandatory Federal Class I area is reasonably attributable to the emissions of that pollutant. R18-2-1606. Exemption from BART Any existing stationary source required to install, operate, and maintain BART pursuant to this Article, may apply to the Administrator for an exemption from that requirement by obtaining prior written concurrence from the Director according to 40 CFR 51.303. ADEQ RAVI NPRM, 2/4/03 26 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 West Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director AIR QUALITY DIVISION PUBLIC HEARING on PROPOSED REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT RULE PLEASE NOTE THE MEETING LOCATION AND TIME: Coconino Public Library 300 W. Aspen, Flagstaff, AZ Monday, April 7, 2003, 4:30 p.m. Pursuant to ARS § 49-425 for air quality rule hearings, notice is hereby given that the above referenced meeting is open to the public. Copies of the proposal are available for review locally at the Coconino Public Library and the Arizona Department of Environmental Quality Library, 1110 W. Washington Street, Phoenix, Arizona. AGENDA 1. Welcome and Introductions 2. Purposes of the Oral Proceeding 3. Procedure for Making Public Comment 4. Brief Overview of the Proposed Reasonably Attributable Visibility Impairment Rule 5. Question and Answer Period 6. Oral Comment Period 7. Adjournment of Oral Proceeding For additional information regarding the hearing, please call Corky Martinkovic, ADEQ Air Quality Division, at (602) 7712372] or 1-800-234-5677, Ext. 771-2372. Persons with a disability may request a reasonable accommodation, such as a sign language interpreter, by contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 771-4794. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829. Northern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 86004 Southern Regional Office 400 West Congress Street • Suite 433 • Tucson, AZ 85701 (928) 779-0313 (520) 628-6733 Printed on recycled paper PUBLIC HEARING 04 /07 /03 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALTIY IN THE MATTER OF ARIZONA’S PROPOSED REASONABLY ATTRIBUTABE VISIBILITY IMPAIRMENT RULE. At: Flagstaff, Arizona Date: April 7, 2003 PUBLIC HEARING NOTE: Due to circumstances beyond ADEQ’s control, the official transcript for this public hearing is not available. The hearing did follow verbatim the text of the public hearing officer script; therefore, that script has been included here along with a copy of the one comment read into the record. Proposed Reasonably Attributable Visibility Impairment Rule Oral Proceeding Hearing Officer Script April 7, 2003 I now open this oral proceeding. Good afternoon, thank you for coming. This oral proceeding is on the proposed Reasonably Attributable Visibility Impairment Rule. This is a proposed rule to direct the State of Arizona and affected permitted stationary sources on the procedures should a Federal Land Manager certify that any one of these sources or small group of sources have emissions that may cause or contribute to the reduction of visibility at specific national parks or wilderness areas in Arizona or adjacent states. It is now Monday, April 7, 2003, 4:30 [ Library, 300 W. Aspen, Flagstaff, Arizona. ] p.m. The location is Coconino My name is Cathy O’Connell and I have been appointed by the Director of the Arizona Department of Environmental Quality to preside at this proceeding. The purposes of this proceeding are to provide the public an opportunity: (1) to hear about the substance of the proposed rule, (2) to ask questions regarding the proposed rule, and (3) to present oral argument, data and views regarding the proposed rule in the form of comments on the record. Representing the Department are myself and Ms. Corky Martinkovic of the Air Quality Planning Section. The procedure for making a public comment on the record is straightforward. If you wish to comment, you need to fill out a speaker slip, which is available at the sign-in table, and give it to me. Using speaker slips allows everyone an opportunity to be heard and allows us to match the name on the official record with the comments. You may also submit written comments to me today in person or by mail, e-mail, or fax to Corky Martinkovic by the end of the comment period. The end of the comment period is 5:00 p.m. on Friday, April 11, 2003. If mailed, e-mailed, or faxed, written comments must be “postmarked” no later than April 11, 2003. Submit your written comments to: Corky Martinkovic Air Quality Planning Section Arizona Department of Environmental Quality 1110 W. Washington Street Phoenix, Arizona 85007 Fax: (602) 771-2366 E-Mail: martinkovic.deborrah@ev.state.az.us Comments made during the formal comment period are required by law to be considered by the Department in the preparation of the final rulemaking. This is done through the preparation of a concise explanatory statement in which the Department responds in writing to written and oral comments made during the formal comment period. The agenda for this hearing is simple. First, I will present a brief overview of the proposed rule. Next, I will conduct a question and answer period. The purpose of the question and answer period is to provide information that may help you in making comments on the rule. Thirdly, I will conduct the oral comment period. At that time, I will begin to call speakers in the order that I have received speaker slips. Please be aware that any comments you make at today's hearing that you want the Department to formally consider must be given either in writing or on the record during the oral comment period of this proceeding. ***** At this time, I [(or) rule. ] will give a brief overview of the proposed The Reasonably Attributable Visibility Impairment Rule, or RAVI for short, will, upon approval, become a new section in the environmental chapter of the Arizona Administrative Code. States are required to adopt this rule under Federal regulations. The rule addresses a specific type of air pollution that can reduce visibility in national parks and wilderness areas. This type of pollution is a type of air pollution that can be 2 traced to a certain type of existing stationary source. When a source has this type of air pollution traced directly to their operations, they are said to be “reasonably attributable” for that type of pollution. For the purposes of this rule, this type of pollution originates from a specific type of existing stationary source operating in or near federal national parks and wilderness areas, known formally as federal mandatory Class I areas. Arizona has 12 of these Class I areas. These national parks and wilderness areas are managed by Federal Land Managers. Federal Land Managers are able to “certify” for the national park or wilderness area for which they have jurisdiction that there exists a reduction in visibility. They can document the reduction in visibility they observe in the park or wilderness area, and then complete a formal report certifying impairment of visibility. Once the State of Arizona receives a certification of visibility impairment from a Federal Land Manager, under the proposed rule, the State would determine if the source is one of the type of stationary sources covered by the rule. Then the State of Arizona would analyze if that source is in fact causing or contributing to the reduction in visibility, or in the words of the rule, is “reasonably attributable.” If the source is eligible for emission controls and found to be attributable for the reduction in visibility, under the proposed rule, the State of Arizona would then proceed with an analysis for the application and operation of emission controls for that source’s air emissions. The emission controls applied under this rule are known as Best Available Retrofit Technology, or BART. BART is applied to existing stationary sources that are too old to operate under what is termed, New Source Performance Standards, and yet emit 250 or more tons per year of air pollutants that impair visibility. Along with outlining the procedures for the BART control analysis of the attributable source, the proposed rule points to options for a source to pursue equivalent or better alternatives, or apply for a federal- level exemption. This concludes the explanation period of this proceeding on the proposed rule. ***** Are there any questions before we move to the oral comment period? [If there are questions, introduce appropriate staff as the Department's representative to respond to any questions.] 3 [or, "Hearing none, . . . ."] This concludes the question and answer period of this proceeding on the proposed rule. ***** I now open this proceeding for oral comments. [Call speakers in the order in which they submitted their speaker's slips; if there are many speakers present, you may limit each speaker's time to speak.] [or, “Seeing no speaker slips, ...] This concludes the oral comment period of this proceeding. ***** I encourage everyone to submit written comments on the proposed rule. Your participation is an essential part of the rulemaking process. Again, you may also submit written comments by mail, e-mail, or fax to Corky Martinkovic by the end of the comment period. The end of the comment period is 5:00 p.m. on Friday, April 11, 2003. If mailed, e-mailed, or faxed, written comments must be “postmarked” no later than April 11, 2003. Submit your written comments to: Corky Martinkovic Air Quality Planning Section Arizona Department of Environmental Quality 1110 W. Washington Street Phoenix, Arizona 85007 Fax: (602) 771-2366 E-Mail: martinkovic.deborrah@ev.state.az.us Thank you for attending. The time is now __________. I now close this oral proceeding. 4 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 West Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director AIR QUALITY DIVISION PUBLIC HEARING on PROPOSED REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT RULE PLEASE NOTE THE MEETING LOCATION AND TIME: Arizona Department of Environmental Quality, Room 145 1110 W. Washington Street, Phoenix, AZ Tuesday, April 8, 2003, 4:30 p.m. Pursuant to ARS § 49-425 for air quality rule hearings, notice is hereby given that the above referenced meeting is open to the public. Copies of the proposal are available for review at the Arizona Department of Environmental Quality Library, 1110 W. Washington Street, Phoenix, Arizona. AGENDA 1. Welcome and Introductions 2. Purposes of the Oral Proceeding 3. Procedure for Making Public Comment 4. Brief Overview of the Proposed Reasonably Attributable Visibility Impairment Rule 5. Question and Answer Period 6. Oral Comment Period 7. Adjournment of Oral Proceeding For additional information regarding the hearing, please call Corky Martinkovic, ADEQ Air Quality Division, at (602) 7712372] or 1-800-234-5677, Ext. 771-2372. Persons with a disability may request a reasonable accommodation, such as a sign language interpreter, by contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 771-4794. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829. Northern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 86004 Southern Regional Office 400 West Congress Street • Suite 433 • Tucson, AZ 85701 (928) 779-0313 (520) 628-6733 Printed on recycled paper ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 West Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director AIR QUALITY DIVISION PUBLIC HEARING on PROPOSED REASONABLY ATTRIBUTABLE VISIBILITY IMPAIRMENT RULE PLEASE NOTE THE MEETING LOCATION AND TIME: State Office Building, Room 158 400 W. Congress, Tucson, AZ Wednesday, April 9, 2003, 4:30 p.m. Pursuant to ARS § 49-425 for air quality rule hearings, notice is hereby given that the above referenced meeting is open to the public. Copies of the proposal are available for review locally at the State Office Building and the Arizona Department of Environmental Quality Library, 1110 W. Washington Street, Phoenix, Arizona. AGENDA 1. Welcome and Introductions 2. Purposes of the Oral Proceeding 3. Procedure for Making Public Comment 4. Brief Overview of the Proposed Reasonably Attributable Visibility Impairment Rule 5. Question and Answer Period 6. Oral Comment Period 7. Adjournment of Oral Proceeding For additional information regarding the hearing, please call Corky Martinkovic, ADEQ Air Quality Division, at (602) 7712372] or 1-800-234-5677, Ext. 771-2372. Persons with a disability may request a reasonable accommodation, such as a sign language interpreter, by contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 771-4794. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829. Northern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 86004 Southern Regional Office 400 West Congress Street • Suite 433 • Tucson, AZ 85701 (928) 779-0313 (520) 628-6733 Printed on recycled paper NOTICE OF FINAL RULEMAKING TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL ARTICLE 16. VISIBILITY; REGIONAL HAZE PREAMBLE 1. 2. Sections Affected Rulemaking Action R18-2-101 Amend Article 16 New Article R18-2-1601 New Section R18-2-1602 New Section R18-2-1603 New Section R18-2-1604 New Section R18-2-1605 New Section R18-2-1606 New Section The statutory authority for the rulemaking, including both the authorizing statute (general) and the statutes the rules are implementing (specific): General Authority: A.R.S. §§ 49-104(A)(11) and 49-425 Specific Authority: A.R.S. §§ 49-414 and 414.01 3. The effective date of the rules: 60 days after filing with the Secretary of State 4. A list of all previous notices appearing in the Register addressing the final rules: Notice of Docket Opening: 9 A.A.R. 390, February 7, 2003 Notice of Proposed Rulemaking: 9 A.A.R. 763, March 7, 2003 5. The name and address of agency personnel with whom persons may communicate regarding the rulemaking. Name: Deborrah “Corky” Martinkovic Address: ADEQ, Air Quality Planning Section, 1110 West Washington Street, ADEQ RAVI NFRM, 8/11/03+ 1 Phoenix, AZ 85007 Telephone: (602) 771-2372 (Any extension may be reached in-state by dialing 1800-234-5677, and asking for a specific number.) 6. Fax: (602) 771-2366 E-mail: martinkovic.deborrah@ev.state.az.us An explanation of the rules, including the agency’s reasons for initiating the rules: Summary. This rule sets forth the process Arizona Department of Environmental Quality (ADEQ) will use to determine whether Best Available Retrofit Technology (BART) will be required for sources determined to be contributing to visibility impairment in a mandatory Federal Class I area. Federal regulations allow Federal Land Managers (FLMs) to certify sources defined in 40 CFR 51.301 as potential contributors to visibility impairment in any of the Arizona mandatory Federal Class I areas under Section 169A of the Clean Air Act (CAA). Background. In 1977 Congress added a new section to the Clean Air Act - Section 169A, Visibility Protection for Federal Class I Areas - which established a national goal for, “the prevention of any future, and the remedying of any existing impairment of visibility in mandatory class I Federal areas which impairment results from man-made air pollution.” In addition, the section required states to submit state implementation plans (SIPs) requiring best available retrofit technology (BART) for certain existing stationary sources found to cause or contribute to visibility impairment. On November 30, 1979, EPA promulgated a list of mandatory Federal Class I Areas (Class I areas) where visibility is an important value (44 FR 69122). There are 12 Class I areas identified in Arizona: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness (40 CFR 81.403). On December 2, 1980 (45 FR 80084), EPA defined the role of the FLMs in certifying visibility impairment in the mandatory Federal Class I areas. On November 24, 1987 (52 FR 45132), FLMs identified Petrified Forest National Park, Saguaro Wilderness, and Grand Canyon National Park, as having visibility impairment possibly attributable to stationary sources. Under the 1980 rule, if found to cause or contribute to the impairment, certain existing stationary sources operating in or near the identified Class I areas could be subject to BART (A list of sources eligible for the possible application of ADEQ RAVI NFRM, 8/11/03+ 2 BART can be found at 40 CFR 51.301). On October 3, 1991, the Navajo Generating Station (NGS) was found by EPA to be causing or contributing to visibility impairment for the Grand Canyon National Park and eligible for BART (56 FR 50172). BART control analyses were subsequently performed by EPA, and other parties through related court actions. Under the 1980 rule, the federal expectation is that actions for determination of possible source attribution will be performed by the states. Therefore, Arizona needs to be prepared to proceed with an attribution analysis and assessment for the application of controls upon any determination of a BART eligible source being the possible cause or contributor to visibility impairment in a Class I area. This rule addresses that need. Current Conditions. ADEQ has determined that this rule applies to any source in existing stationary source categories identified in 40 CFR 51.301 that are operating in or near the mandatory federal Class I areas in Arizona. The source is an existing stationary facility that includes any reconstructed source that was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year of any regulated pollutant. ADEQ estimates that there are potentially 10 such sources within Arizona. “In existence” is interpreted by EPA to be consistent with the term, “commence construction” found in Prevention of Serious Deterioration (PSD) regulations (40 CFR 51.165(a)(1)(xvi) and 40 CFR 52.21(b)(9)). If construction commenced after August 7, 1977, the source would be subject to the PSD/NSR (new source review) program (the state regulations are found at 18 A.C.C. 2, Article 4). However, EPA also notes “that sources, are not BART eligible if the only change at the plant was the addition of pollution controls. For example, if the only change at a copper smelter during the 1962 through 1977 time period was the addition of acid plants for the reduction of SO2 emissions, these emission controls would not themselves trigger a BART review.”1 Under this rule, ADEQ, when analyzing an attributable source for BART controls, must consider several factors including, for example, costs, remaining useful life of the source, and degree of improvement anticipated to result from the application of the controls (the factors are detailed in R18-2-1605). Sources required by ADEQ to install and operate BART controls have a final opportunity to request exemption from the requirement prior to the application of controls. This opportunity for a federal exemption from BART, is contained in R18-2-1606, and 40 CFR 51.303. Summary. This rule outlines the process through which sources eligible for the application of BART will 1 EPA proposed rule, 66 Federal Register 38119, July 20, 2001. ADEQ RAVI NFRM, 8/11/03+ 3 proceed if certified by the state of Arizona or an FLM as possibly causing or contributing to visibility impairment due to attribution. If found to be attributable for the impairment, a BART analysis will be performed to determine the level of controls necessary to remedy the impairment. This rule enables Arizona to fulfill the requirements of the Clean Air Act and the goal of section 169A of the Act to return the Nation’s federal parks and wilderness areas to natural conditions. Section-by-section Explanation for the Rule R18-2-1601 This section lists the definitions that apply to this rule. R18-2-1602 This section lists the Class I areas addressed by this rule for the applicable existing stationary facilities, as defined in R18-2-1601(2). R18-2-1603 This section establishes the procedure for certification of impairment by either a Federal Land Manager with authority over a mandatory Federal Class I area, or the Director, should either believe there exists reasonably attributable visibility impairment in a Federal Class I area as listed in R18-2-1602. R18-2-1604 This section establishes the procedure for an attribution analysis after certification of a source or group of sources as outlined in R18-2-1603. Upon completion of the attribution analysis, the procedure for the Director to issue draft and final attribution findings is outlined in R18-2-1604(C). R18-2-1605 This section establishes the best available retrofit technology (BART) analysis procedure after a source is identified under R18-2-1604. Upon completion of the BART analysis, the procedure for the Director to issue draft and final BART findings, including alternatives to emission standards, is outlined in R18-21605(B) and (C), respectively. The specific conditions where BART would be satisfied due to past or planned actions by the facility are outlined in R18-21605(D). EPA determinations regarding new technology that might require a BART analysis for an applicable source, regardless of a source or small group of sources previously being certified and found attributable, are covered in R18-21605(E). R18-2-1606 This section establishes the procedures for obtaining a federal exemption from a BART requirement. 7. A reference to any study relevant to the rule that the agency reviewed and either relied on in its evaluation of or justification for the rule or did not rely on in its evaluation of or ADEQ RAVI NFRM, 8/11/03+ 4 justification for the rule, where the public may obtain or review each study, all data underlying each study, and any analysis of each study and other supporting material: None 8. A showing of good cause why the rules are necessary to promote a statewide interest if the rules will diminish a previous grant of authority of a political subdivision of this state: Not applicable 9. The summary of the economic, small business, and consumer impact: A. Rule Identification These rules amend R18-2-101 (“visibility impairment” definition) and add new sections R18-2-1601 through R18-2-1606. For sources under ADEQ jurisdiction, the rules take the place of federal regulations that currently govern this area. B. Entities Directly Impacted 1. Federal Land Managers. R18-2-1603 allows Federal Land Managers (FLMs) to certify visibility impairment in mandatory Class I areas. This was already allowed by federal rule. Under R18-2-1601 of the rule, the FLMs able to certify impairment in Arizona are with the United States Forest Service and the National Park Service. There are no FLMs in Arizona from the United States Fish and Wildlife Service, because this agency does not have jurisdiction over any of Arizona’s mandatory federal Class I areas. 2. ADEQ. R18-2-1604 requires ADEQ to identify stationary sources that could cause or contribute to the certified visibility impairment. Prior to this rule, this function was carried out by EPA. R18-2-1605 would require ADEQ to analyze for BART (best available retrofit technology) controls those sources identified as causing or contributing to visibility impairment. Prior to this rule, this function was carried out by EPA. The impact of this rule on ADEQ will primarily be on the Air Quality Division, Permits and Assessment sections, with a corresponding reduction of impact on EPA. 3. Stationary sources. R18-2-1605 also requires stationary sources identified in #2 to install or operate the BART as determined by the Director. Prior to this rule, only EPA determined and required BART. To determine impacted stationary sources, ADEQ staff reviewed Title V permits from ADEQ’s Air Permit files. Of the 26 industry categories listed in 40 CFR 51.301, only five categories were found to ADEQ RAVI NFRM, 8/11/03+ 5 exist under ADEQ’s jurisdiction: steam electric plants, cement plants, primary copper smelters, lime plants, and industries using non-utility boilers. As a result, potentially 10 sources, representing 16 BART eligible units (boilers and kilns), could be affected by this rule. The combined potential to emit from these sources totaled 94,287 tons per year for NOx, 141,036 tons per year for SO2, and 12,146 tons per year for PM. The combined potential to emit for all pollutants for these 10 sources total approximately 250,000 tons per year. C. Probable Costs and Benefits Associated with the BART/Visibility Impairment Process 1. Direct Costs - FLMs: FLM activities to certify visibility impairment in mandatory Class I areas may involve preparation and analysis of monitoring data, emission inventories, meteorological records, etc. ADEQ estimates that this cost per certification could be as much as $50,000 if extensive analysis is conducted. These costs exist whether or not these rules became final. 2. Direct Costs - ADEQ: ADEQ costs related to identifying whether a BART eligible stationary source causes or contributes to visibility impairment in Class I areas are based on the activities identified in R182-1604(A). ADEQ estimates that these costs could range from $100,000 – 200,000 per attribution analysis, and be primarily borne by the ADEQ’s Air Quality Assessment Section. Costs related to analyzing identified sources for BART are based on the activities identified in R18-2-1605(A) and will be moderate, but less expensive than the attribution analysis. These costs will be primarily borne by ADEQ’s Permits Section. These costs will accrue to the State. Finally, incorporating BART into an existing State air quality permit may require additional resources from the Permits Section. However, these costs, unlike costs for the attribution and BART analysis, would be covered by permit revision fees paid by the source, and would have existed whether or not these rules became final. 3. Direct Costs - Stationary sources: If a source or small group of sources is found to cause or contribute to visibility impairment, and the BART determination requires installation of retrofit controls, the costs to sources required to install BART will be substantial. The total cost to install a technology similar to BART at the Navajo Generating Station was estimated by SRP to be in the hundreds of millions of dollars (51 Federal Register 50172, October 3, 1991). However, the example of the Navajo Generating Station shows costs to install technology similar to BART can result even where there is no state rule. According to EPA, “Where a State defaults on its obligations under the visibility regulations, EPA may act in place of the State pursuant to a FIP under section 110(c) of the Act, 42 U.S.C. 7410(c)2, and promulgate such limitation and measures as are required to achieve reasonable progress.” (Ibid. at 50173, footnote not ADEQ RAVI NFRM, 8/11/03+ 6 included). Although ADEQ is listing these costs for information purposes, ADEQ is not attributing any costs to install and operate BART to this rule because such requirements can be imposed by the federal government without any State rule. Benefits. Two kinds of benefits are associated with this rule. The first benefit is derived from reduced emissions. Although, BART could be required to be installed on sources even without this state rule, it is helpful to list the emission benefits. When BART is installed, visibility is improved. Over 4 million recreation visits were made to Grand Canyon National Park in FY 2001. These visits generate substantial revenue in and for the state of Arizona. Other scenic resources could also be improved with the installation of BART, and, though less significant than the Grand Canyon, would enhance the tourism resources of Arizona, as well as the quality of life for Arizona citizens. In addition, reduction of visibility-impairing emissions also has health benefits. The second benefit is through the replacement of federal regulation with state regulation. The lack of state regulations implementing BART results in Arizona sources being subject to federal regulation implemented by EPA from Washington and San Francisco, headquarters for EPA’s Region IX. These rules place the identification and analysis of BART sources with ADEQ rather than with EPA. Arizona is currently under a visibility Federal Implementation Plan (FIP), and one or two Arizona sources have considered or implemented technology similar to BART under federal rules. Because ADEQ already permits many of these sources, ADEQ will be more familiar with the various factors that go into the BART analysis. This would be a benefit to sources being regulated. ADEQ would be implementing the same BART rules that EPA does, with a resulting increase in costs for ADEQ and a decrease in costs for EPA. This final rule further allows ADEQ to proceed with the implementation of the entire federal rule for visibility improvement. The rule addresses the requirements of 40 C.F.R. §§51.302 – 51.307. These sections must be satisfied before ADEQ can implement the requirements of 40 C.F.R. §§51.308 and 51.309. The plan to implement Section 309 must be submitted to EPA by December 31, 2003. D. Small Business Analysis A.R.S. § 41-1055(B)(5) requires agencies to state the probable impact of a rulemaking on small businesses. A.R.S. § 41-1035 requires agencies to reduce the impact of a rule on small businesses by using certain methods when they are legal and feasible in meeting the statutory objectives for the rule ADEQ RAVI NFRM, 8/11/03+ 7 making. These methods include: (1) exempting them from any or all rule requirements, (2) establishing performance standards which would replace any design or operational standards, or (3) instituting reduced compliance or reporting requirements. An agency may accomplish the third method by establishing less stringent requirements, consolidating or simplifying requirements, or setting less stringent schedules or deadlines. "Small business" is defined in A.R.S. §41-1001 as “a concern, including its affiliates, which is independently owned and operated, which is not dominant in its field and which employs fewer than one hundred full-time employees or which had gross annual receipts of less than four million dollars in its last fiscal year.” Interpreting this definition means that if a concern has annual gross receipts of more than four million dollars, but fewer than 100 employees, it would not be classified as a small business. ADEQ expects that none of the potential BART eligible sources will be classified as a small business. ADEQ’s conclusion is that this rule will not impact small business sources. However, if a BART eligible source would qualify as a small business, under federal rule, ADEQ could not establish different requirements for these small business sources. If there are any small businesses that sell, install, or maintain BART-related technology, they will benefit from this rule. In the preliminary EIS, ADEQ requested comment and additional information relating to any of the conclusions reached above and did not receive any. 10. A description of the changes between the proposed rules, including supplemental notices, and final rules (if applicable): Changes were made with the cooperation of GRRC Staff to improve the clarity, conciseness and understandability of the rule. The changes are shown below: A new definition was placed at R18-2-101(71), to clarify a term used in the proposed definition of "visibility impairment" at R18-2-101(123): 71. “Natural conditions” includes naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration. In addition, the word "and" was removed from the definition of "visibility impairment", as shown: ADEQ RAVI NFRM, 8/11/03+ 8 123124. “Visibility impairment” means any humanly perceptible change in visibility (light extinction, visual range, contrast, and coloration) from that which would have existed under natural conditions. Both definitions are copied exactly from federal regulations at 40 CFR 51.308. In addition, new Article 16 was amended as follows: ARTICLE 16. VISIBILITY; REGIONAL HAZE R18-2-1601. Definitions In addition to the definitions contained in Articles 1 and 4 of this Chapter and A.R.S. § 49-401.01, the following definitions apply to this Article: 1. “Best available retrofit technology (BART)” means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant that is emitted by an existing stationary facility. The emission limitation is established on a case-by-case basis in accordance with under R18-2-1605. 2. “Existing stationary facility” means any of the following stationary sources of air pollutants, including any reconstructed source, which was not in operation prior to before August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any air pollutant. In determining A person who determines potential to emit, shall count fugitive emissions, to the extent quantifiable, must be counted. a. Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour heat input,; b. Coal cleaning plants (thermal dryers),; c. Kraft pulp mills,; d. Portland cement plants,; e. Primary zinc smelters,; f. Iron and steel mill plants,; g. Primary aluminum ore reduction plants,; h. Primary copper smelters,; i. Municipal incinerators capable of charging more than 250 tons of refuse per day,; j. Hydrofluoric, sulfuric, and nitric acid plants,; k. Petroleum refineries,; l. Lime plants,; ADEQ RAVI NFRM, 8/11/03+ 9 3. m. Phosphate rock processing plants,; n. Coke oven batteries,; o. Sulfur recovery plants,; p. Carbon black plants (furnace process),; q. Primary lead smelters,; r. Fuel conversion plants,; s. Sintering plants,; t. Secondary metal production facilities,; u. Chemical process plants,; v. Fossil-fuel boilers of more than 250 million British thermal units per hour heat input,; w. Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels,; x. Taconite ore processing facilities,; y. Glass fiber processing plants,; and z. Charcoal production facilities. “Federal Land Manager” means the Secretary of the department, or the Secretary's designee, with authority over the Federal Class I area. 4. “Mandatory Federal Class I Area” means any area identified in 40 CFR §§81.400-81.436. 5. “Reasonably attributable” means ascribable by visual observation or other techniques the Director deems appropriate described in R18-2-1604. 6. “Reasonably attributable visibility impairment” means visibility impairment that is caused by the emission of air pollutants from one source, or a small group of sources. R18-2-1602. Applicability This Article applies to any existing stationary source located in the state that may reasonably be anticipated to cause or contribute to visibility impairment in any mandatory Federal Class I area identified in 40 CFR §§81.401-81.436. Mandatory Federal Class I areas within Arizona are: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness. R18-2-1603. A. Certification of Impairment A Federal Land Manager with authority over a mandatory Federal Class I area may certify to the ADEQ RAVI NFRM, 8/11/03+ 10 Director, at any time, that there exists a reasonably attributable visibility impairment exists in the a mandatory Federal Class I area. The Director may also certify that there exists reasonably attributable visibility impairment exists in any mandatory Federal Class I area as necessary to assure reasonable progress under section 169A(b)(2) of the Clean Air Act. B. Documentation from the affected Federal Land Manager or Director that supports the Federal Land Manager or Director’s certification shall include: 1. The mandatory Federal Class I area for which visibility impairment is being certified, 2. Any information documenting the basis for the certification of impairment. R18-2-1604. A. Attribution Analysis; Finding Upon certification of reasonably attributable visibility impairment in any mandatory Federal Class I area If a mandatory Federal Class I area is certified as having reasonably attributable visibility impairment, the Director shall conduct an attribution analysis to identify each existing stationary source that may be reasonably anticipated to cause or contribute to visibility impairment. The Director shall notify the Federal Land Manager, affected source or small group of sources, and local air pollution control officer of the intent to conduct an attribution analysis. The attribution analysis shall be based on the following: 1. Monitoring information obtained through the Arizona Class I Visibility Monitoring Network or special studies approved by ADEQ to ascertain: 2. a. The times visibility impairment occurred, and b. The pollutants contributing to the visibility impairment.; Transport analysis or air quality modeling based upon meteorological records to ascertain whether the pollutants were transported to the mandatory Federal Class I area.; 3. Other available studies, modeling analyses, and emissions inventories of point, area, and mobile source emissions to ascertain: a. The pollutant or pollutants causing the impairment, and b. The source, or a small group of sources, emitting the impairing pollutant; or pollutants. 4. Other relevant supporting documentation provided by the Federal Land Manager or Director used to make the draft attribution analysis finding.; and 5. Consideration of any documentation provided by the source, or a small group of sources., or other interested parties. B. In conducting the attribution analysis, the Director shall use monitoring information, ADEQ RAVI NFRM, 8/11/03+ 11 meteorological records, and emissions inventories that represent times and locations reasonably concurrent with the visibility impairment. C. The Director shall issue a draft attribution finding that impairment has or has not occurred, and provide public notice of the draft attribution finding. The Director shall publish notice of the draft attribution finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, if any, and shall clearly set forth reasons why the Director should review the draft attribution finding should be reviewed. The Director shall issue A a final attribution finding shall be issued after the public comment period. If the Director finds existing stationary sources found to cause or contribute to visibility impairment in a mandatory Federal Class I area, the source shall be subject to a BART Control Analysis under R18-2-1605. R18-2-1605. A. BART Control Analysis; Finding The Director shall analyze for BART controls each existing stationary source for which a final attribution finding is made under R18-2-1604(C). The Director shall consider the following factors: 1. Available control technology; 2. New source performance standards (NSPS) as adopted in Article 9; 3. Alternative control systems if retrofitting to comply with applicable NSPS standards adopted in Article 9 is found infeasible.; 4. Cost of compliance; 5. Energy and non-air quality environmental impacts of compliance; 6. Existing pollution control technology in use at the source or small group of sources; 7. Remaining useful life of the source or small group of sources; 8. Net environmental impact associated with the proposed emission control system; 9. Economic impacts associated with installing and operating the proposed emission control system; and 10. Degree of improvement in visibility anticipated to result from application of the proposed emission control system. B. The Director shall issue a draft BART finding, and provide public notice of the draft BART finding. The Director shall publish notice of the draft BART finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. ADEQ RAVI NFRM, 8/11/03+ 12 The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, and shall clearly set forth reasons why the Director should review the draft BART finding should be reviewed. The Director shall issue a final BART finding after the public comment period. 1. The Director shall submit each final BART finding that an existing stationary source is required to meet BART to the Administrator as a revision to the state implementation plan (SIP). 2. The Director shall require that each existing stationary source meet BART as expeditiously as practicable but in no case later than five years after EPA approval of the revision to Arizona’s State Implementation Plan SIP revision. C. If the Director determines that technological or economic limitations on the applicability of measurement methodology to a particular existing stationary source would make the imposition of an emission standard infeasible, the Director may, as part of the finding under subsection (B), instead prescribe a design, equipment, work practice, or other operational standard, or combination thereof of design, equipment, work practice, or operational standard. Such The standard, to the degree possible, is to shall set forth the emission reduction to be achieved by implementation of such the design, equipment, work practice, or operation, and must shall provide for compliance by means which that achieve equivalent results. D. The Director shall make a finding that the attributable source has satisfied satisfies the BART requirement if the attributable source has: 1. Voluntarily applied applies best available retrofit technology; 2. Previously applied emission control standards equivalent to BART; or 3. Agreed Agrees to shutdown or curtail operations at the attributable source within 5 five years of the finding. An attributable source that does not shutdown or curtail operations shall proceed to meet BART as expeditiously as practicable, but in no case later than five years after EPA’s approval of the revision to Arizona’s State Implementation Plan the SIP. E. If the Director determines that the imposition of BART or a standard pursuant to under subsection (C) of this section is not feasible infeasible at the time of the finding, the Director shall require the attributable source shall be required to install and operate BART upon a determination by the Director at a later date when the Director determines that BART or equivalent controls are now ADEQ RAVI NFRM, 8/11/03+ 13 feasible. F. The Director shall provide for a BART control analysis of any existing stationary source that might cause or contribute to impairment of visibility in any mandatory Federal Class I area identified under this Article at such times, as determined by the Administrator, determines new control technology for control of the pollutant becomes reasonably available if: 1. The pollutant is emitted by that existing stationary source, 2. Controls representing BART for the pollutant have not previously been required under this Article, and 3. The impairment of visibility in any mandatory Federal Class I area is reasonably attributable to the emissions of that pollutant. R18-2-1606. Exemption from BART Any existing stationary source required to install, operate, and maintain BART pursuant to under this Article, may apply to the Administrator for an exemption from that requirement according to 40 CFR 51.303. by obtaining prior written concurrence from the Director according to 40 CFR 51.303. The existing stationary source shall obtain the Director’s written concurrence before sending the application for exemption to the Administrator. 11. A summary of the comments made regarding the rule and the agency response to them: ADEQ received one written comment. It expressed general support for the rule and for protecting visibility in Arizona’s Class I parks and wilderness areas. Comment: ADEQ received an oral comment that the word “facility” should be replaced by "source” in the definitions of “best available retrofit technology” and “existing stationary facility” to be consistent with the rest of the rule. Response: ADEQ has kept these definitions the same as the federal definitions to ensure consistency. The definitions use the term “source” to define the terms, and “source” is used thereafter in the rules. ADEQ is not aware of any inconsistency. 12. Any other matters prescribed by statute that are applicable to the specific agency or to any specific rule or class of rules: Not applicable ADEQ RAVI NFRM, 8/11/03+ 14 13. Incorporation by reference and their location in the rule: Not applicable 14. Were these rules previously adopted as emergency rules? No 15. The full text of the rule follows: ADEQ RAVI NFRM, 8/11/03+ 15 TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL ARTICLE 1. GENERAL Section R18-2-101 Definitions ARTICLE 16. VISIBILITY; REGIONAL HAZE Section R18-2-1601 Definitions R18-2-1602 Applicability R18-2-1603 Certification of Impairment R18-2-1604 Attribution Analysis; Finding R18-2-1605 BART Control Analysis; Finding R18-2-1606 Exemption from BART ADEQ RAVI NFRM, 8/11/03+ 16 ARTICLE 1. GENERAL R18-2-101. Definitions In addition to the definitions prescribed in A.R.S. §§ 49-101, 49-401.01, 49-421, 49-471, and 49-541, in this Chapter, unless otherwise specified: 1. No change 2. No change a. No change b. No change c. No change d. No change e. No change 3. No change 4. No change 5. No change 6. No change 7. No change 8. No change 9. No change 10. No change 11. a. No change b. No change c. No change d. No change e. No change f. No change No change a. No change b. No change c. No change 12. No change 13. No change 14. No change ADEQ RAVI NFRM, 8/11/03+ 17 a. No change b. No change 15. No change 16. No change 17. No change 18. No change 19. No change 20. No change 21. No change 22. No change 23. No change 24. No change 25. No change 26. No change 27. No change a. No change b. No change 28. No change 29. No change 30. No change 31. No change 32. No change 33. No change 34. No change 35. No change 36. No change 37. No change 38. No change 39. No change 40. No change. 41 No change 42. No change a. No change ADEQ RAVI NFRM, 8/11/03+ 18 b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change 43. No change 44. No change a. No change b. No change c. No change d. No change 45. No change 46. No change 47. No change 48. No change 49. No change 50. No change 51. No change 52. No change 53. No change 54. No change 55. No change 56. No change 57. No change a. No change b. No change c. No change ADEQ RAVI NFRM, 8/11/03+ 19 d. No change e. No change f. No change g. No change h. No change i. No change j. No change 58. No change 59. No change 60. No change 61. No change 62. No change 63. No change a. No change b. No change c. No change i. No change ii. No change iii. No change iv. No change v. No change (1) No change (2) No change vi. No change vii. No change viii. No change ix. (1) No change (2) No change No change (1) No change (2) No change x. No change xi. No change ADEQ RAVI NFRM, 8/11/03+ 20 64. No change a. No change b. No change c. i. No change ii. No change No change i. No change ii. No change iii. No change iv. No change v. No change vi. No change vii. No change viii. No change ix. No change x. No change xi. No change xii. No change xiii. No change xiv. No change xv. No change xvi. No change xvii. No change xviii. No change xix. No change xx. No change xxi. No change xxii. No change xxiii. No change xxiv. No change xxv. No change xxvi. No change xxvii. No change ADEQ RAVI NFRM, 8/11/03+ 21 65. No change 66. No change 67. No change 68. No change 69. No change 70. No change 71. “Natural conditions” includes naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration. 71.72. No change 72.73. No change a. b. No change i. No change ii. No change No change i. No change ii. No change c. No change d. No change e. No change f. No change g. i. No change ii. No change iii. No change iv. No change No change 73.74. No change 74.75. No change 75.76. No change 76.77. No change 77.78. No change 78.79. No change 79.80. No change 80.81. No change ADEQ RAVI NFRM, 8/11/03+ 22 81.82. No change 82.83. No change 83.84. No change a. No change b. No change c. No change d. No change 84.85. No change 85.86. No change 86.87. No change 87.88. No change 88.89. No change 89.90. No change 90.91. No change 91.92. No change 92.93. No change 93.94. No change 94.95. No change a. No change b. No change c. No change d. No change 95.96. No change 96.97. No change 97.98. No change a. No change b. No change c. No change d. No change e. No change 98.99. No change a. No change i. ADEQ RAVI NFRM, 8/11/03+ No change 23 ii. No change iii. No change iv. No change v. No change vi. No change vii. No change b. No change c. No change 99.100. No change a. No change b. No change 100.101. No change 101.102. No change 102.103. No change 103.104. No change 104.105. No change a. No change b. No change c. No change d. No change 105.106. No change 106.107. No change 107.108. No change a. No change b. No change 108.109. No change 109.110. No change 110.111. No change 111.112. No change 112.113. No change 113.114. No change 114.115. No change 115.116. No change ADEQ RAVI NFRM, 8/11/03+ 24 116.117. No change 117.118. No change a. No change b. No change c. No change d. No change e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change m. No change n. No change o. No change p. No change q. No change r. No change s. No change t. No change u. No change v. No change w. No change x. No change y. No change z. No change aa. No change bb. No change cc. No change dd. No change ee. No change ADEQ RAVI NFRM, 8/11/03+ 25 ff. No change gg. No change hh. No change ii. No change jj. No change kk. No change ll. No change mm. No change nn. No change oo. No change pp. No change qq. No change rr. No change ss. No change tt. No change uu. No change vv. No change ww. No change xx. No change 118.119. No change 119.120. No change 120.121. No change 121.122. No change 122.123. No change 123.124. “Visibility impairment” means any humanly perceptible change in visibility (light extinction, visual range, contrast, coloration) from that which would have existed under natural conditions. 124.125. No change 125.126. No change a. No change b. No change c. No change d. No change ADEQ RAVI NFRM, 8/11/03+ 26 e. No change f. No change g. No change h. No change i. No change j. No change k. No change l. No change m. No change n. No change o. No change p. No change q. No change r. No change s. No change t. No change u. No change v. No change w. No change x. No change y. No change z. No change aa. No change bb. No change cc. No change dd. No change ee. No change ff. No change gg. No change hh. No change ii. No change jj. No change kk. No change ADEQ RAVI NFRM, 8/11/03+ 27 ll. No change mm. No change nn. No change oo. No change pp. No change qq. No change rr. No change ss. No change 126.127. i. No change ii. No change iii. No change iv. No change No change ARTICLE 16. VISIBILITY; REGIONAL HAZE R18-2-1601. Definitions In addition to the definitions contained in Articles 1 and 4 of this Chapter and A.R.S. § 49-401.01, the following definitions apply to this Article: 1. “Best available retrofit technology (BART)” means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant emitted by an existing stationary facility. The emission limitation is established on a case-by-case basis under R18-2-1605. 2. “Existing stationary facility” means any of the following stationary sources of air pollutants, including any reconstructed source, which was not in operation before August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any air pollutant. A person who determines potential to emit shall count fugitive emissions to the extent quantifiable. a. Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour heat input; b. Coal cleaning plants (thermal dryers); c. Kraft pulp mills; d. Portland cement plants; ADEQ RAVI NFRM, 8/11/03+ 28 3. e. Primary zinc smelters; f. Iron and steel mill plants; g. Primary aluminum ore reduction plants; h. Primary copper smelters; i. Municipal incinerators capable of charging more than 250 tons of refuse per day; j. Hydrofluoric, sulfuric, and nitric acid plants; k. Petroleum refineries; l. Lime plants; m. Phosphate rock processing plants; n. Coke oven batteries; o. Sulfur recovery plants; p. Carbon black plants (furnace process); q. Primary lead smelters; r. Fuel conversion plants; s. Sintering plants; t. Secondary metal production facilities; u. Chemical process plants; v. Fossil-fuel boilers of more than 250 million British thermal units per hour heat input; w. Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels; x. Taconite ore processing facilities; y. Glass fiber processing plants; and z. Charcoal production facilities. “Federal Land Manager” means the Secretary of the department, or the Secretary's designee, with authority over the Federal Class I area. 4. “Mandatory Federal Class I Area” means any area identified in 40 CFR §§81.400-81.436. 5. “Reasonably attributable” means ascribable by visual observation or other techniques described in R18-2-1604. 6. “Reasonably attributable visibility impairment” means visibility impairment that is caused by the emission of air pollutants from one source, or a small group of sources. R18-2-1602. Applicability This Article applies to any existing stationary source located in the state that may reasonably be anticipated to cause or contribute to visibility impairment in any mandatory Federal Class I area identified ADEQ RAVI NFRM, 8/11/03+ 29 in 40 CFR §§81.401-81.436. Mandatory Federal Class I areas within Arizona are: Chiricahua National Monument Wilderness, Chiricahua Wilderness, Galiuro Wilderness, Grand Canyon National Park, Mazatzal Wilderness, Mount Baldy Wilderness, Petrified Forest National Park, Pine Mountain Wilderness, Saguaro Wilderness, Sierra Ancha Wilderness, Superstition Wilderness, and Sycamore Canyon Wilderness. R18-2-1603. A. Certification of Impairment A Federal Land Manager with authority over a mandatory Federal Class I area may certify to the Director, at any time, that a reasonably attributable visibility impairment exists in a mandatory Federal Class I area. The Director may also certify that reasonably attributable visibility impairment exists in any mandatory Federal Class I area to assure reasonable progress under section 169A(b)(2) of the Clean Air Act. B. Documentation that supports the Federal Land Manager or Director’s certification shall include: 1. The mandatory Federal Class I area for which visibility impairment is being certified, 2. Any information documenting the basis for the certification of impairment. R18-2-1604. A. Attribution Analysis; Finding If a mandatory Federal Class I area is certified as having reasonably attributable visibility impairment, the Director shall conduct an attribution analysis to identify each existing stationary source that may be reasonably anticipated to cause or contribute to visibility impairment. The Director shall notify the Federal Land Manager, affected source or small group of sources, and local air pollution control officer of the intent to conduct an attribution analysis. The attribution analysis shall be based on the following: 1. Monitoring information obtained through the Arizona Class I Visibility Monitoring Network or special studies approved by ADEQ to ascertain: 2. a. The times visibility impairment occurred, and b. The pollutants contributing to the visibility impairment; Transport analysis or air quality modeling based upon meteorological records to ascertain whether the pollutants were transported to the mandatory Federal Class I area; 3. Other available studies, modeling analyses, and emissions inventories of point, area, and mobile source emissions to ascertain: a. The pollutant causing the impairment, and b. The source, or a small group of sources, emitting the pollutant; ADEQ RAVI NFRM, 8/11/03+ 30 4. Other relevant supporting documentation provided by the Federal Land Manager or Director used to make the draft attribution analysis finding; and 5. Consideration of any documentation provided by the source, a small group of sources; or other interested parties. B. In conducting the attribution analysis, the Director shall use monitoring information, meteorological records, and emissions inventories that represent times and locations reasonably concurrent with the visibility impairment. C. The Director shall issue a draft attribution finding that impairment has or has not occurred, and provide public notice of the draft attribution finding. The Director shall publish notice of the draft attribution finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, if any, and shall clearly set forth reasons why the Director should review the draft attribution finding. The Director shall issue a final attribution finding after the public comment period. If the Director finds existing stationary sources cause or contribute to visibility impairment in a mandatory Federal Class I area, the source shall be subject to a BART Control Analysis under R18-2-1605. R18-2-1605. A. BART Control Analysis; Finding The Director shall analyze for BART controls each existing stationary source for which a final attribution finding is made under R18-2-1604(C). The Director shall consider the following factors: 1. Available control technology; 2. New source performance standards (NSPS) in Article 9; 3. Alternative control systems if retrofitting to comply with applicable NSPS standards in Article 9 is infeasible; 4. Cost of compliance; 5. Energy and non-air quality environmental impacts of compliance; 6. Existing pollution control technology in use at the source or small group of sources; 7. Remaining useful life of the source or small group of sources; 8. Net environmental impact associated with the proposed emission control system; 9. Economic impacts associated with installing and operating the proposed emission control system; and ADEQ RAVI NFRM, 8/11/03+ 31 10. Degree of improvement in visibility anticipated to result from application of the proposed emission control system. B. The Director shall issue a draft BART finding, and provide public notice of the draft BART finding. The Director shall publish notice of the draft BART finding in a newspaper of general circulation in each county containing the mandatory Federal Class I area and the affected source. The Director shall provide at least 30 days from the date of the notice for public comment. Written comments to the Director shall include the name of the person and the person’s agent or attorney, and shall clearly set forth reasons why the Director should review the draft BART finding. The Director shall issue a final BART finding after the public comment period. 1. The Director shall submit each final BART finding to the Administrator as a revision to the SIP. 2. The Director shall require that each existing stationary source meet BART as expeditiously as practicable but in no case later than five years after EPA approval of the SIP revision. C. If the Director determines that technological or economic limitations on the applicability of measurement methodology to a particular existing stationary source would make the imposition of an emission standard infeasible, the Director may, as part of the finding under subsection (B), prescribe a design, equipment, work practice, operational standard, or combination of design, equipment, work practice, or operational standard. The standard, to the degree possible, shall set forth the emission reduction to be achieved by implementation of the design, equipment, work practice, or operation, and shall provide for compliance by means that achieve equivalent results. D. The Director shall make a finding that the attributable source satisfies the BART requirement if the attributable source: 1. Voluntarily applies best available retrofit technology; 2. Previously applied emission control standards equivalent to BART; or 3. Agrees to shutdown or curtail operations at the attributable source within five years of the finding. An attributable source that does not shutdown or curtail operations shall meet BART as expeditiously as practicable, but in no case later than five years after EPA’s approval of the revision to the SIP. E. If the Director determines that the imposition of BART or a standard under subsection (C) is infeasible at the time of the finding, the Director shall require the attributable source to install and operate BART at a later date when the Director determines that BART or equivalent controls are feasible. ADEQ RAVI NFRM, 8/11/03+ 32 F. The Director shall provide for a BART control analysis of any existing stationary source that might cause or contribute to impairment of visibility in any mandatory Federal Class I area identified under this Article at such time as the Administrator determines new control technology for the pollutant becomes reasonably available: 1. The pollutant is emitted by that existing stationary source, 2. Controls representing BART for the pollutant have not previously been required under this Article, and 3. The impairment of visibility in any mandatory Federal Class I area is reasonably attributable to the emissions of that pollutant. R18-2-1606. Exemption from BART Any existing stationary source required to install, operate, and maintain BART under this Article, may apply to the Administrator for an exemption from that requirement according to 40 CFR 51.303. The existing stationary source shall obtain the Director’s written concurrence before sending the application for exemption to the Administrator. ADEQ RAVI NFRM, 8/11/03+ 33 Appendix A-5d. New source review rule - R18-2-410 Appendix A-5 – Attributable Impairment Arizona Regional Haze SIP R18-2-410. Visibility Protection A. For any new major source or major modification subject to the provisions of this Chapter, no permit or permit revision under this Article shall be issued to a person proposing to construct or modify the source unless the applicant has provided: 1. An analysis of the anticipated impacts of the proposed source on visibility in any Class I areas which may be affected by the emissions from that source; and 2. Results of monitoring of visibility in any area near the proposed source for such purposes and by such means as the Director determines is necessary and appropriate. B. A determination of an adverse impact on visibility shall be made based on consideration of all of the following factors: 1. The times of visitor use of the area; 2. The frequency and timing of natural conditions in the area that reduce visibility; 3. All of the following visibility impairment characteristics: a. Geographic extent, b. Intensity, c. Duration, d. Frequency, e. Time of day; 4. The correlation between the characteristics listed in subsection (B)(3) and the factors described in subsections (B)(1) and (2). C. The Director shall not issue a permit or permit revision pursuant to this Article or Article 3 of this Chapter for any new major source or major modification subject to this Chapter unless the following requirements have been met: 1. The Director shall notify the individuals identified in subsection (C)(2) within 30 days of receipt of any advance notification of any such permit or permit revision under this Article. 2. Within 30 days of receipt of an application for a permit or permit revision under this Article for a source whose emissions may affect a Class I area, the Director shall provide written notification of the application to the Federal Land Manager and the federal official charged with direct responsibility for management of any lands within any such area. The notice shall: a. Include a copy of all information relevant to the permit or permit revision under this Article, b. Include an analysis of the anticipated impacts of the proposed source on visibility in any area which may be affected by emissions from the source, and c. Provide for no less than a 30-day period within which written comments may be submitted. 3. The Director shall consider any analysis provided by the Federal Land Manager that is received within the comment period provided in subsection (C)(2). a. Where the Director finds that the analysis provided by the Federal Land Manager does not demonstrate to the satisfaction of the Director that an adverse impact on visibility will result in the area, the Director shall, within the public notice required under R18-2-330, either explain the decision or specify where the explanation can be obtained. b. When the Director finds that the analysis provided by the Federal Land Manager demonstrates to the satisfaction of the Director that an adverse impact on visibility will result in the area, the Director shall not issue a permit or permit revision under this Article for the proposed major new source or major modification. 4. When the proposed permit decision is made, pursuant to R18-2-304(J), and available for public review, the Director shall provide the individuals identified in subsection (C)(2) with a copy of the proposed permit decision and shall make available to them any materials used in making that determination. Historical Note Adopted effective May 14, 1979 (Supp. 79-1). Former Section R9-3-410 renumbered without change as Section R18-2-410 (Supp. 87-3). Section R18-2-410 renumbered to R18-2-610, new Section R18-2-410 adopted effective November 15, 1993 (Supp. 93-4). APPENDIX A-6. CLEAN AIR CORRIDOR This appendix contains work products and references relied upon by Arizona in the development of Chapter 6 of the Regional Haze SIP. Appendix A-6 – Clean Air Corridor Arizona Regional Haze SIP Appendix A-6a. WRAP Policy on Clean Air Corridors Appendix A-6 – Clean Air Corridor Arizona Regional Haze SIP WRAP Policy on Clean Air Corridors Approved by WRAP Board November 13, 2002 I. Summary of WRAP Policy 1. Pursuant to 40 CFR 51.309(d)(3), the WRAP directs its Technical Oversight Committee (TOC) to track emissions and to describe the tracking process in such a way that can be included in state and tribal implementation plans. At a minimum, using the most recent state emission inventories available, the TOC should produce a report for each five-year implementation plan revision on the current and projected emissions in the clean air corridor and in areas outside the corridor and compare these emissions to a 1996 baseline for purposes of this section. 2. Pursuant to 40 CFR 51.309(d)(3)(i), the WRAP identifies one clean air corridor as shown in Figure 1. The counties within the corridor are listed in Table 1. For ease of administration, the corridor’s boundary follows county lines. 3. Pursuant to 40 CFR 51.309(d)(3)(ii), the WRAP has examined patterns of growth in the corridor and finds that they are not causing significant emission increases that could have or are having visibility impacts at one or more of the 16 Class I areas. Nor, at this time, are such emission increases expected during the first planning period (2003-2018). Analyses performed by the Grand Canyon Visibility Transport Commission found that an increase of 25% in weighted emissions would result in a 0.7 dv reduction in visibility, whereas the weighted emission increase expected by 2018 is only 4%. 4. Pursuant to 40 CFR 51.309(d)(3)(iii), the WRAP has examined emissions growth in areas outside the corridor and finds that significant emissions growth is not occurring that could begin or is beginning to impair the quality of the air in the corridor and thereby lead to visibility degradation for the least impaired days in one or more of the 16 Class I areas. 5. Since impairment of air quality in clean air corridors has not been identified pursuant to 40 CFR 51.309(d)(3)(ii) and (iii), the WRAP finds no requirement under 40 CFR 51.309(d)(3)(iv) for further visibility impact analysis or additional emission reduction measures until at least the next SIP revision (2008). However, the WRAP encourages its appropriate technical activities – such as the Causes of Haze report – to take into account the assessment and protection of clean air corridors. 6. Pursuant to 40 CFR 51.309(d)(3)(v), the WRAP finds no other clean air corridors beyond the corridor identified in Figure 1. WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 II. 2 Clean Air Corridors, The Clean Air Act, And The Regional Haze Rule The Clean Air Act Amendments of 1990 specifically require that visibility transport commissions, including the Grand Canyon Visibility Transport Commission (“Commission”), address “the establishment of clean air corridors, in which additional restrictions on increases in emissions may be appropriate to protect visibility in affected class I areas.”1 The Clean Air Act also requires protection of clean air corridors in a less direct way. The Act establishes as a national goal the prevention of any future impairment of visibility in mandatory Class I areas. As a measure of progress towards this goal, the U.S. Environmental Protection Agency (EPA) has established a criteria of no degradation on the 20% cleanest days. Such days on the Colorado Plateau are usually dominated by northwest winds, hence defining a corridor to the northwest that must be protected to meet the broader visibility goal of the Clean Air Act. In its regional haze rule, the EPA provides more specificity on the requirements to protect clean air corridors, based largely on the recommendations of the Commission. The preamble of the rule defines a clean air corridor as “a region that generally brings clean air to a receptor region” The preamble also says, “the requirement to track emissions will enable states to quickly determine if changes in patterns of emissions will reduce the number of clean air days (defined as the average of the 20% clearest days) in any of the 16 Class I areas.” The actual requirements of the rule are found in 40 CFR 51.309(d)(3): The [state implementation] plan must describe and provide for implementation of comprehensive emission tracking strategies for clean-air corridors to ensure that the visibility does not degrade on the least-impaired days at any of the 16 Class I areas. The strategy must include: (i) An identification of clean-air corridors. The EPA will evaluate the State’s identification of such corridors based upon the reports of the Commission’s Meteorology Subcommittee and any future updates by a successor organization. (ii) Within areas that are clean-air corridors, an identification of patterns of growth or specific sites of growth that could cause, or are causing, significant emissions increases that could have, or are having, visibility impairment at one or more of the 16 Class I areas. (iii) In areas outside of clean-air corridors, an identification of significant emissions growth that could begin, or is beginning, to impair the quality of air in the corridor and thereby lead to visibility degradation for the least-impaired days in one or more of the 16 Class I areas. (iv) If impairment of air quality in clean air corridors is identified pursuant to §§51.309(d)(3)(ii) and (iii), an analysis of the effects of increased emissions, including provisions for the identification of the need for additional emission reductions measures, and implementation of the additional measures where necessary. 1 42 U.S.C. 2169B(d)(2)(A). WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 3 (v) A determination of whether other clean air corridors exist for any of the 16 Class I areas. For any such clean air corridors, an identification of the necessary measures to protect against future degradation of air quality in any of the 16 Class I areas. These requirements do not apply to states submitting state implementation plans (SIPs) under §308 of the rule. However, such states should provide the data necessary for other states to comply and should make a good faith effort to protect the integrity of clean air corridors. III. The Commission’s Findings and Recommendations The Commission found that clean air corridors exist and that, generally, clean air comes to the Colorado Plateau from the northwest.2 The Commission determined that one such corridor covers southern Utah, eastern Oregon, southwestern Idaho, and major portions of Nevada. This corridor was identified by the Commission’s Meteorology Subcommittee, which examined the size and boundaries of the corridor under varying assumptions about the number of days defined as clean and the amount of protection to be afforded.3 Related work by Green et. al. 4 identifies three factors that explain why air from the northwest is clean when it arrives at the Colorado Plateau: low emissions of air pollutants, enhanced dispersion of the air pollutants due to higher average ventilation (wind speed multiplied by mixing depth), and increased removal of pollutants due to precipitation. Although the corridor is mostly arid, the cleanest days occur most frequently in the winter, when there is more precipitation than average. Green et al., nonetheless, conclude that the most important factor at the south rim of the Grand Canyon for most weather conditions is the low emissions of pollutants in the area to the northwest. In addition to identifying a clean air corridor, the Commission projected emissions growth within the corridor through 2040 and found that growth is not expected to have a perceptible negative impact on the cleanest days on the Colorado Plateau. Specifically, a working group within the Meteorology Subcommittee used results from the IAS model (the model used to project visibility impacts in other Commission work) to estimate the emissions increase from 1990 that would be necessary to cause a perceptible decrease in visibility on the Plateau.5 The working group found that increasing emissions by 25% within the corridor would result in an average change of 0.7 deciviews (dv), which would be imperceptible to most people under most conditions, while a 100% increase in emissions within the corridor would result in a change of 2.5 dv.6 This 2 Grand Canyon Visibility Transport Commission. Recommendations for Improving Western Vistas. Western Governors’ Association. Denver, CO. June 1996. 3 Meteorological Subcommittee, Grand Canyon Visibility Transport Commission. Clean Air Corridors: A Framework for Identifying Regions that Influence Clean Air on the Colorado Plateau. Denver, CO. August 1995. 4 Green, M. C.; Pitchford, M. L.; and Ashbaugh, L.L. Identification of Candidate Clean Air Corridors for the Colorado Plateau. J. Air & Waste Manage. Assoc. 1996. 46(5), 446. 5 Marc Pitchford. Oral communication. October 3, 2002. Participants on the working group included Dr. Pitchford, Dr. William Malm, and Dr. Ivar Tombach. 6 BBC Research & Consulting, Inc., for the Operations Committee of the Grand Canyon Visibility Transport Commission. Clean Air Corridor: An Economic Perspective. Denver, CO. November 1995. Page III-2:6. WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 4 estimate was not based on a specific boundary for the corridor but rather on the general understanding of a corridor to the northwest of the Plateau. The implication, nonetheless, is that a 25% increase in emissions within the corridor could be considered a level of growth that would not impact visibility. Using one of the proposed corridor alignments examined by the Meteorology Subcommittee – a corridor that would protect the 30% cleanest days on the Colorado Plateau, adjusted to account for emissions density and IAS region boundaries – BBC Research & Consulting conducted an economic and demographic assessment of the corridor to determine whether emissions would increase 25% by 2040. The assessment found that emissions are not expected to increase 25% by 2040.7 Specifically, BBC used a weighting scheme defined in the IAS model to account for the varying effects of different pollutants on visibility. Total weighted emissions of elemental carbon, nitrogen oxides, organic carbon, particulate matter, reactive organic gases, and sulfur oxides in 1990 were 52,073 VEEU tons.8 A 25% increase would yield 65,092 VEEU tons. BBC projected that emissions in the corridor would increase to 55,047 VEEU tons by 2040, thus leaving an ample margin of safety of 10,054 VEEU tons.9 As a result of these analyses, the Commission recommended that no targeted policies or regulatory programs to control emissions growth were needed at that time, but that a regional tracking and accounting system be implemented to make sure that the frequency of clear days does not decrease at the 16 Class I areas and that the Commission’s assumptions about increased emissions are proven reliable. The Commission recommended that, within areas that are sources of clean air, the tracking and accounting system should identify patterns of growth that have a negative impact on visibility and that, in areas outside the clean air corridors, the tracking and accounting system should identify significant emissions growth that begins to impair the quality of air in the corridor. IV. WRAP Policy A. EMISSIONS TRACKING – §309(d)(3) The WRAP directs its Technical Oversight Committee (TOC) to track emissions and to describe the tracking process in such a way that can be included in state and tribal implementation plans. At a minimum, using the most recent state emission inventories available, the TOC should produce a report for each five-year implementation plan revision on the current and projected emissions in the clean air corridor and in areas outside the corridor and compare these emissions to a 1996 baseline for purposes of this section. The tracking described above is intended to ensure that any unexpected changes are identified. This tracking would coincide with the periodic SIP revisions required in 2008, 2013, and 2018. States and tribes already prepare inventories at least every three years to meet federal 7 BBC report, page III-5 Visibility Equivalency Emission Units 9 BBC report, page III-6. 8 WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 5 requirements and will prepare detailed inventories annually for sources of sulfur dioxide of 100 tons per year or greater for compliance with the stationary source provisions of §309.10 The WRAP will use these state and tribal data for tracking emissions in general and can summarize emissions for the counties and tribal lands within the corridor and for areas outside the corridor for use by states and tribes as they revise their regional haze SIPs every five years. Further information on tracking point sources and area sources is provided below. POINT SOURCES. Any new, large source will be required to undergo a Prevention of Significant Deterioration review and an Air Quality Related Values analysis before receiving an air quality permit and will also be subject to New Source Performance Standards and other requirements, giving the public, states, tribes, and federal land managers ample opportunity to evaluate any possible visibility impacts on the 16 Class I areas. Thus, it is unlikely that point sources will lead to a 25% increase and even less likely that a trend in that direction would go unnoticed. AREA AND MOBILE SOURCES. Population and economic growth is expected to be slow in the corridor, holding down emissions from area and mobile sources within the corridor. Federal standards recently promulgated for on-road sources and additional ones pending for non-road sources are expected to reduce emissions from both of these source categories during the first planning period of the implementation plans (2018). However, emissions from prescribed burning are expected to increase and, depending on the location of the burns, could affect visibility in the 16 Class I areas. It is hard to predict how great the effect will be on clean days, but it is not expected to be severe. For one, prescribed fires generally occur in the spring and fall, whereas most clear days occur in the winter. In addition, prescribed fires are much less intense than wild fires. Nonetheless, careful fire emissions tracking is warranted and is being developed under separate WRAP policy and technical efforts. B. BOUNDARY OF THE CLEAN AIR CORRIDOR – §309(d)(3)(i) The WRAP identifies one clean air corridor as shown in Figure 1. The counties within the corridor are listed in Table 1. For ease of administration, the corridor’s boundary follows county lines. The WRAP adopts this boundary based on a balancing of demographic, economic, and air quality impact analyses performed on this corridor and their subsequent review and consensusbased approval by the Commission. The boundary identified is a slight modification of the boundary defined in the BBC report described above. The grid cells in the air quality analyses did not follow state or county boundaries, and for ease of administration the WRAP has removed small areas of southern Washington and southwestern Montana from the corridor. These small areas are far from the Colorado Plateau and unlikely to affect the Class I areas on the Plateau. In contrast, counties have been added to the corridor that were not originally included in the boundary defined in the BBC report. These include Box Elder, Tooele, and Grand Counties in Utah, Wasco and Sherman Counties in Oregon, and Cassia and Lemhi Counties in Idaho. 10 Also see Western Regional Air Partnership. Voluntary Emissions Reduction Program for Major Industrial Sources of Sulfur Dioxide in Nine Western States and a Backstop Market Trading Program, An Annex to the Report of the Grand Canyon Visibility Transport Commission. Denver, CO. September 29, 2000. WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 6 C. IDENTIFICATION OF EMISSIONS INCREASES – §309(d)(3)(ii) and (iii) Pursuant to 40 CFR 51.309(d)(3)(ii), the WRAP has examined patterns of growth in the corridor and finds that they are not causing significant emission increases that could have or are having visibility impacts at one or more of the 16 Class I areas. Nor, at this time, are such emission increases expected during the first planning period (2003-2018). Analyses performed by the Grand Canyon Visibility Transport Commission found that an increase of 25% in weighted emissions would result in a 0.7 dv reduction in visibility, whereas the weighted emission increase expected by 2018 is only 4%. Patterns of growth in the corridor are first examined by comparing 1990 emissions (those used in the Commission’s final report) to 1996 emissions (the most recent comprehensive data set). This comparison is not easily made because emissions were aggregated into different categories. Nonetheless, it appears that emissions in 1996 were only slightly higher than in 1990. In the clean air corridor 73,637 tons of SO2 were emitted in 1990 and 73,756 were emitted in 1996; 232,704 tons of NOx were emitted in 1990 and 256,762 were emitted in 1996. In addition, the WRAP examined data from IMPROVE monitors and found that none of the seven long-term sites showed any significant decrease in visibility on the cleanest days for the period from 1988 through 1998.11 The WRAP is recommending, as part of this policy, that future clean air corridor analyses use a baseline year of 1996 to quantify emission increases. The first reason for this recommendation is that the 1996 inventory has been more carefully assembled than the 1990 inventory. The second reason is that future inventories are more likely to be structured like the 1996 inventory, thereby facilitating comparison. In addition, the most recent and comprehensive projection of emissions (discussed below) is based on the 1996 inventory, not the 1990 inventory. The WRAP also examined emission projections. These are used as a means to identify potential future increases that should be more carefully tracked and to identify preventive measures that could be implemented in a timely fashion. Table 2 summarizes the projected change in emissions between 1996 and 2018. PM10 and PM2.5 emissions are expected to increase about 7% and 18%, respectively. NOx and VOC emissions, however, are expected to decrease about 15% and 26%, respectively. SO2 emissions are expected to increase about 5% within the corridor, even with the declining milestones of the backstop emissions trading program. Overall, SO2 emissions are expected to decline by 17% in the 13-state contiguous WRAP region by 2018, 12 and the fact that the projections show a 5% increase in SO2 within the clean air corridor is a result of non-road mobile sources using high-sulfur diesel fuel. This source of sulfur dioxide is expected to be drastically reduced (e.g., from a fuel sulfur content of 3,000 ppm to 15 ppm) before 2018 according to announcements by EPA to develop new engine certification and fuel standards for non-road vehicles and equipment. Thus, 5% should be viewed as an upper bound on the possible increase of SO2. 11 12 EPA. Visibility in Mandatory Federal Class I Areas (1994-1998), A Report to Congress. EPA-452/R-01-008. WRAP Emissions Inventory Forum. 2018-1996 Difference: Actual to Control Spreadsheet. WRAP Web Site. September 25, 2002. WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 7 Since different pollutants have different impacts on visibility, the WRAP estimated a weighted emissions increase according to the VEEU system used by the Commission. As shown in Table 3, the weighted increase is expected to be 4%, substantially less than the 25% increase thought to be necessary to achieve an impact that may be perceptible. It is also worth noting the safety margins included within this analysis – the fact that the BBC corridor protects 30% of the clean days, not 20%; the benefits of new non-road mobile source standards; and the uncertainty in where additional electricity generating capacity will be located. Pursuant to 40 CFR 51.309(d)(3)(iii), the WRAP has examined emissions growth in areas outside the corridor and finds that significant emissions growth is not occurring that could begin or is beginning to impair the quality of the air in the corridor and thereby lead to visibility degradation for the least impaired days in one or more of the 16 Class I areas. The WRAP sees two purposes for emissions tracking in areas outside the corridor: first, to determine if such emissions are degrading visibility in the corridor, which may potentially affect one or more of the 16 Class I areas; and second, to compensate for any uncertainties in establishing the boundary of the corridor, such as those relating to computed airmass trajectories or introduced by aligning the corridor with county boundaries. Again, SO2 emissions are expected to decline throughout the WRAP region. Emissions of other pollutants are also expected to decline. All visibility-impairing pollutants from on-road mobile sources, with the exception of some minor ammonia emissions, are expected to decline substantially. And all visibility impairing pollutants from non-road mobile sources are expected to decline, especially in areas upwind of the corridor. This decline would be greatly enhanced if the EPA promulgates stricter standards for non-road engines and fuel, as it has announced to do. Also, NOx and PM from existing stationary sources remains to be addressed in future implementation plans by 2008 under Sections 308 and 309 of the regional haze rule. Finally, all states will have to implement measures to achieve reasonable progress in other Class I areas by 2008. Such measures are likely to “overlap” the clean air corridor and areas outside the corridor in such a way that provide further protection to the 16 Class I areas on the 20% cleanest days. D. IF IMPAIRMENT OF AIR QUALITY IN THE CORRIDOR IS IDENTIFIED – §309(d)(3)(iv) Since impairment of air quality in clean air corridors has not been identified pursuant to 40 CFR 51.309(d)(3)(ii) and (iii), the WRAP finds no requirement under 40 CFR 51.309(d)(3)(iv) for further visibility impact analysis or additional emission reduction measures until at least the next SIP revision (2008). However, the WRAP encourages its appropriate technical activities – such as the Causes of Haze report – to take into account the assessment and protection of clean air corridors. The rule specifies that if impairment of air quality in the clean air corridor is identified, the plan must include "an analysis of the effects of increased emissions, including provisions for the identification of the need for additional emission reduction measures, and implementation of the WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 8 additional measures if necessary." For reasons stated above, the WRAP finds no need at this time for additional emission reduction measures. The periodic WRAP inventories to be produced by the TOC, as instructed above, will identify growth in emissions, and the periodic updates to the WRAP Causes of Haze report will help identify any effect on visibility that may result from such emissions increases. Should any effects be identified, the WRAP will conduct an analysis to determine the sources of impairment within six months of completion of the inventory indicating the increase. Additional control measures that may be warranted would be developed within another six months. The criteria the states and tribes would follow in making this determination are (a) the location of the significant emissions growth, (b) type of source activity causing the emissions growth, and (c) the appropriate control measure for the source(s) based on feasibility, cost, and anticipated visibility benefits. Any necessary additional control measures would be added in the next five-year SIP revision. E. DO OTHER CORRIDORS EXIST? – §309(d)(3)(v) The WRAP finds no other clean air corridors beyond the corridor identified in Figure 1. The regional haze rule requires that implementation plans identify whether any other clean air corridors exist for any of the 16 Class I areas. The WRAP finds no such areas other than the corridor to the northwest of the Colorado Plateau identified in Figure 1. The WRAP recognizes, however, that additional work to identify clean air corridors may be needed. For example, several monitors have recently been installed at Class I areas on the Plateau which were not previously monitored. These may generate a slightly different set of 20% cleanest days and a slightly different set of back trajectories on those days, especially at sites furthest to the north and east. This may result in a broader or separate corridor. Such analysis should be performed when sufficient data are available. Adequate monitoring data could be available by 2004, and analysis of those data could be published by the WRAP as part of its Causes of Haze report. V. Conclusion The bottom line is that, while the area to the northwest of the Colorado Plateau delivers clean air to the Plateau on the cleanest days, emissions from throughout much of the region affect the Class I areas on the Plateau. Thus, emissions throughout the WRAP region will be tracked carefully. Ongoing WRAP efforts to improve the quality of inventories and the models used to make projections, and to produce a periodic Causes of Haze report, will bring increased understanding of the role that clean air corridors play in protecting the cleanest days. In the final analysis, the indicator of success or failure will be whether the measured light extinction at the Class I areas on the Colorado Plateau improves or declines on the cleanest days. Any indication of deterioration on the cleanest days should trigger an immediate investigation of the cause, as well as efforts to correct the problem. WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 Figure 1. Clean Air Corridor Endorsed by the WRAP. 9 WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 10 Table 1. Counties Within the Clean Air Corridor Endorsed by the WRAP. State Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Idaho Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Nevada Oregon Oregon Oregon Oregon County Ada Adams Blaine Boise Butte Camas Canyon Cassia Custer Elmore Gem Gooding Idaho Jerome Lemhi Lincoln Minidoka Owyhee Payette Twin Falls Valley Washington Churchill Douglas Elko Esmeralda Eureka Humboldt Lander Lincoln Lyon Mineral Nye Pershing Storey Washoe White Pine Carson City Baker Crook Deschutes Gilliam State Oregon Oregon Oregon Oregon Oregon Oregon Oregon Oregon Oregon Oregon Oregon Oregon Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah Utah County Grant Harney Jefferson Lake Malheur Morrow Sherman Umatilla Union Wallowa Wasco Wheeler Beaver Box Elder Carbon Emery Garfield Grand Iron Juab Kane Millard Piute San Juan Sanpete Sevier Tooele Washington Wayne WRAP Policy on Clean Air Corridors Submitted for Board Approval, 11/13/02 11 Table 2. Changes in Clean Air Corridor Emissions (Assuming SO2 Milestones Are Met). SO2 1996 2018 2018-1996 Point 51,413 45,330 -6,082 Area On Road Non Road 9,260 2,065 10,838 10,614 413 21,596 1,354 -1,652 10,758 Paved Unpaved 0 0 0 0 0 0 Total 73,576 77,954 4,378 NOx 1996 2018 2018-1996 85,782 109,863 24,080 12,935 17,576 4,641 93,581 28,692 -64,889 64,462 62,557 -1,905 0 0 0 0 0 0 256,762 218,689 -38,072 PM10 1996 2018 2018-1996 27,055 32,748 5,692 142,776 154,966 12,190 3,872 2,640 -1,232 5,952 6,763 811 5,740 12,402 6,662 47,733 38,828 -8,904 233,128 248,347 15,219 PM2.5 1996 2018 2018-1996 11,987 14,583 2,595 41,595 52,069 10,474 3,495 2,058 -1,438 5,487 6,228 740 1,435 3,101 1,665 7,160 5,824 -1,336 71,160 83,863 12,702 VOC 1996 2018 2018-1996 5,993 7,921 1,927 95,921 95,515 -406 69,899 22,651 -47,248 38,535 29,233 -9,301 0 0 0 0 0 0 210,349 155,321 -55,029 Table 3. Total Change in Emissions Weighted to Reflect Relative Impact on Visibility. 1996 VEEU 2018 VEEU SO2 5,445 5,769 NOx 1,746 1,487 PM10 1,958 2,086 PM2.5 932 1,099 VOC 294 217 EC* 902 985 OC* 856 935 Total 12,133 12,578 Change -4% * Estimates of elemental and organic carbon, EC and OC, were not available to the CAC Work Group for the 1996 and 2018 emission inventories. Values for this analysis were derived from the estimates of EC and OC for the 1990 inventory of the 9 GCVTC states. The method used was to take the proportion of EC to fine and coarse particulates (PM2.5 + PM10) in the 1990 inventory and use that same proportion to calculate an EC value for the 1996, 2018, and 2018 milestone inventories. The same method was used for OC. ** VEEU – Visibility Equivalency Emission Units (Used in the GCVTC IAS Model.) VEEU weights PM2.5 PM10 NOx VOC SO2 EC OC 0.0131 0.0084 0.0068 0.0014 0.0740 0.6497 0.2466 Each category in the inventory is multiplied by these factors to create the VEEU-weighted inventory. Appendix A-6b. WRAP Emission Tracking System and Assessment Process for the Clean Air Corridor Appendix A-6 – Clean Air Corridor Arizona Regional Haze SIP FINAL NEEDS ASSESSMENT FOR EVALUATION AND DESIGN OF AN EMISSIONS DATA REPORTING, MANAGEMENT, AND TRACKING SYSTEM Prepared for Western Governor’s Association Western Regional Air Partnership 1515 Cleveland Place Suite 200 Denver, Colorado 80202 Prepared by EA Engineering, Science, and Technology 15 Loveton Circle Sparks, MD 21152 July 25, 2003 NEEDS ASSESSMENT FOR EVALUATION AND DESIGN OF AN EMISSIONS DATA REPORTING, MANAGEMENT, AND TRACKING SYSTEM Prepared for Western Governor’s Association Western Regional Air Partnership 1515 Cleveland Place Suite 200 Denver, Colorado 80202 Prepared by EA Engineering, Science, and Technology 15 Loveton Circle Sparks, MD 21152 July 25, 2003 EA Project No: 1406601 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT CONTENTS 1.0 INTRODUCTION............................................................................................................... 1 1.1 1.2 1.3 1.4 1.5 1.6 2.0 WORKSHOPS AND QUESTIONNAIRE FINDINGS ................................................... 5 2.1 2.2 2.3 3.0 Description of Workshops ...................................................................................... 5 Description of Questionnaire .................................................................................. 5 Findings................................................................................................................... 5 COMPARATIVE ANALYSIS........................................................................................... 9 3.1 3.2 3.3 4.0 Regional Haze......................................................................................................... 1 Consolidated Emission Reporting Rule (CERR).................................................... 1 RPO Data Exchange Protocol................................................................................. 2 Western Air Partnership (WRAP) .......................................................................... 2 Regulatory Framework for Tribal Visibility Implementation Plans....................... 2 Objectives ............................................................................................................... 3 Conceptual WRAP EDMS...................................................................................... 9 Comparison ........................................................................................................... 10 Existing EDMS ..................................................................................................... 10 RECOMMENDATIONS.................................................................................................. 16 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 4.12 Flow Chart of the WRAP EDMS.......................................................................... 16 Point Source Module............................................................................................. 16 Area Source Module ............................................................................................. 17 Mobile source Module .......................................................................................... 18 Biogenic source Module ....................................................................................... 20 Windblown Dust Source Module.......................................................................... 20 Fire Source Module............................................................................................... 21 Standard Reports and Queries............................................................................... 22 Special Section 309 Tracking ............................................................................... 23 GIS Module........................................................................................................... 27 DBA Module......................................................................................................... 28 QA/QC Module..................................................................................................... 29 5.0 CONCLUSIONS ............................................................................................................... 31 6.0 REFERENCES.................................................................................................................. 32 APPENDIX A1: FIRST WORKSHOP PRESENTATION APPENDIX A2: FIRST WORKSHOP DISCUSSION SUMMARY APPENDIX A3: FIRST WORKSHOP PARTICIPANTS APPENDIX B1: SECOND WORKSHOP PRESENTATION APPENDIX B2: SECOND WORKSHOP DISCUSSION SUMMARY APPENDIX B3: SECOND WORKSHOP PARTICIPANTS ii EA Engineering, Science, and Technology FINAL TECHNICAL REPORT APPENDIX C: QUESTIONNAIRE RESULTS AND OTHER CORRESPONDENCES APPENDIX D: CONCEPTUAL WRAP AND SELECTED EDMS COMPARISON APPENDIX E: NEI DATA SUBMISSION FORMAT APPENDIX F: NEI QA/QC PROCESS APPENDIX G: WRAP EDMS FLOW CHART APPENDIX H: CAC BONDARIES iii EA Engineering, Science, and Technology 1.0 INTRODUCTION 1.1 Regional Haze FINAL TECHNICAL REPORT Regional haze is defined as air pollution that is transported long distances and reduces visibility in national parks and wilderness areas. The pollutants that create this haze are sulfates, nitrates, organic carbon, elemental carbon, and soil dust. Human-caused haze sources include industry, motor vehicles, agricultural and forestry burning, and windblown dust from roads and farming practices. In 1999, the US Environmental Protection Agency (EPA) issued regulations that address regional haze in one hundred fifty six (156) national parks and wilderness areas across the country. The goal of the Regional Haze Rule (RHR) is to eliminate human-caused visibility impairment in national parks and wilderness areas across the country. It contains strategies to improve visibility over the next sixty (60) years, and requires states to adopt implementation plans. The RHR provides two paths to address regional haze. One is 40 CFR 51.308 (Section 308), and requires most states to develop long-term strategies out to the year 2064. These strategies must be shown to make “reasonable progress” in improving visibility in Class I areas inside the state and in neighboring jurisdictions. The other is 40 CFR 51.309 (Section 309), and is an option for nine states - Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming - and the two hundred eleven (211) Tribes located within those States to adopt regional haze strategies for the period from 2003 to 2018. These strategies are based on recommendations from the Grand Canyon Visibility Transport Commission (GCVTC), for protecting the sixteen (16) Class I areas in the Colorado Plateau area (GCTVC, 1996). Adopting these strategies constitutes reasonable progress until 2018. These same strategies can also be used by the nine western states and tribes to protect the other Class I areas within their own jurisdiction. The RHR specifically requires comprehensive emissions tracking and reporting for clean air corridors (CAC), sulfur dioxide (SO2) stationary sources, fire sources, mobile sources, and windblown dust sources among other requirements. 1.2 Consolidated Emission Reporting Rule One of the recent EPA’s rules that will affect the data submission requirements of the RHR is the Consolidated Emission Reporting Rule (CERR) (67 FR 39602-39616) issued in 2002. The CERR will simplify and consolidate emissions inventory reporting requirements to a single location within the CFR and establish new reporting requirements related to particulate matter with aerodynamic size less than 2.5 µm (PM2.5), regional haze, and statewide reporting of area and mobile source emissions. In fact, new inventories will add PM2.5 and ammonia (NH3). Currently area and mobile sources are reported by nonattainment area, and under the CERR, inventories will include all sources statewide by county. Moreover, there will be an option to report smaller point sources once every three years or one-third of the sources every year. 1 EA Engineering, Science, and Technology 1.3 FINAL TECHNICAL REPORT RPO Data Exchange Protocol The RPO data exchange protocol will also affect the data submission and reporting requirements. The goal of the RPO data exchange protocol is to facilitate the sharing of databases for emissions modeling in a regionally consistent and model-independent nature. Therefore, it seeks to develop data exchange formats and naming conventions so that emissions modelers from the five RPOs and states and tribes have common datasets from which to pursue regulatory modeling of ozone (O3), regional haze, and PM. It includes nine different protocols: · · · · · · · · · Industrial point source protocol Area source protocol Temporal allocation and profile assignment protocol On-road mobile sources protocol Off-road mobile sources protocol Continuous emissions monitoring and day-specific protocol Spatial surrogate protocol Speciation profile protocol Growth and control factors protocol The data sources, data formats, and issues associated with each of these protocols are further detailed in the Midwest RPO’s Draft RPO Data Exchange Protocol (Pechan, 2003). 1.4 Western Regional Air Partnership The Western Regional Air Partnership (WRAP) is a regional planning organization (RPO) that was established in 1997 as the successor organization of the GCVTC. The WRAP is a collaborative effort of tribal governments, state governments, and various federal agencies to implement the recommendations of the GCVTC and to develop the technical and policy tools needed by western states and tribes to comply with the RHR. The WRAP Emissions Forum (EF) oversees the development of a comprehensive emissions tracking and forecasting system which can be utilized by the WRAP or its member entities to monitor the trends in actual emissions, and forecast the anticipated emissions which will result from current regulatory requirements and alternative control strategies. In addition, this forum is responsible for the oversight of the assembly and quality assurance of the emissions inventories and forecasts to be utilized by the WRAP forums. 1.5. Regulatory Framework for Tribal Visibility Implementation Plans The RHR explicitly recognizes the authority of tribes to implement the provisions of the rule, in accordance with principles of federal Indian law, and as provided by the Clean Air Act (CAA) Section 301(d) and the tribal authority rule (TAR) (40 CFR 49.1–11). Those provisions create the following framework: · · Absent special circumstances, reservation lands are not subject to state jurisdiction. Federally recognized tribes may apply for and receive delegation of federal authority to implement CAA programs, including visibility regulation, or "reasonably severable" 2 EA Engineering, Science, and Technology · · · FINAL TECHNICAL REPORT elements of such programs (40 CFR 49.3, 49.7). The mechanism for this delegation is a tribal implementation plan (TIP). A reasonably severable element is one that is not integrally related to program elements that are not included in the plan submittal, and is consistent with applicable statutory and regulatory requirements. The RHR expressly provides that tribal visibility programs are “not dependent on the strategies selected by the state or states in which the tribe is located” (64 FR 35756), and that the authority to implement Section 309 TIPs extends to all tribes within the GCVTC region (40 CFR 51.309(d)(12)). The EPA has indicated that under the TAR, tribes are not required to submit Section 309 TIPs by the end of 2003. Rather, they may choose to opt-in to Section 309 programs at a later date (67 FR 30439). Where a tribe does not seek delegation through a TIP, EPA, as necessary and appropriate, will promulgate a federal implementation plan (FIP) within reasonable timeframes to protect air quality in Indian country (40 CFR 49.11). EPA is committed to consulting with tribes on a government-to-government basis in developing tribe-specific or generally applicable TIPs where necessary (63 FR 7263-64). The amount of modification, if any, needed for this report to fulfill tribal needs may vary considerably from tribe to tribe. The authors have striven to ensure that all references to tribes in the document are consistent with principles of tribal sovereignty and autonomy as reflected in the above framework. Any inconsistency with this framework is strictly inadvertent and not an attempt to impose requirements on tribes, which are not present under existing law. Tribes, along with states and federal agencies, are full partners in the WRAP, having equal representation on the WRAP Board as states. Whether Board members or not, it must be remembered that all tribes are governments, as distinguished from the “stakeholders” (private interest) which participate on Forums and Committees but are not eligible for the Board. Despite this equality of representation on the Board, tribes are very differently situated than states. There are over four hundred (400) federally recognized tribes in the WRAP region, including Alaska. The sheer number of tribes makes full participation impossible. Moreover, many tribes are faced with pressing environmental, economic, and social issues, and do not have the resources to participate in an effort such as the WRAP, however important its goals may be. These factors necessarily limit the level of tribal input into and endorsement of WRAP products. The tribal participants in the WRAP, including Board members, Forum and Committee members, and co-chairs, make their best effort to ensure that WRAP products are in the best interest of the tribes, the environment, and the public. One interest is to ensure that WRAP policies, as implemented by states and tribes, will not constrain the future options of tribes who are not involved in the WRAP. With these considerations and limitations in mind, it is anticipated that the tribal participants will join the state, federal, and private stakeholder interests in approving this report as a consensus document. 1.6 Objectives The EF is currently seeking to implement a comprehensive internet web-based air pollution emissions data reporting, management, and tracking system to support state and tribal regional 3 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT haze implementation plan (SIP/TIP) development. The system is to be capable of receiving and storing emissions data in EPA-compliant emissions reporting formats commonly used by various agencies and sources with little or no additional effort, producing user-specified reports, performing user-selected quality control and assurance tests, allowing data queries and graphic display, and presenting this information in geographic information system (GIS) format. The EF contracted with EA Engineering, Science, and Technology, Inc (EA) to assess the needs of the WRAP emissions database management system (WRAP EDMS). The overall approach of this needs assessment consists of the following tasks. · · · Task 1: Determine the emissions data to be reported, managed and tracked. Task 2: Conduct a comparative analysis of existing emissions data management systems approved and in use by EPA and state air quality agencies. Task 3: Prepare a report addressing issues associated with developing a new system, long-term system maintenance and operation of the recommended data management system, by integrating information gathered in Tasks 1 and 2. This report presents the results of Task 3 and represents the final technical report of the project. It provides the documentation from the two workshops and questionnaires, the findings based on the input received from the two workshops and questionnaires, an evaluation of existing EDMS, and the system recommendations. 4 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 2.0 WORKSHOP AND QUESTIONNAIRE FINDINGS 2.1 Description of the Workshops The WRAP EDMS needs assessment survey consisted of two interview workshops. The first workshop took place in Santa Fe, New Mexico, on March 20th, 2003. It was intended for members of the WRAP Forums. Thirty-five (35) people attended the meeting. The workshop lasted approximately three hours, and included a presentation by the EA team covering the project overview and timeline, the goals and roles of the WRAP EDMS, a comparative summary of existing systems, a straw man presentation of the conceptual WRAP EDMS, and the conceptual timeline of the development and population of the WRAP EDMS. The presentation was followed by specific discussions on the WRAP EDMS needs. Appendices A1, A2, and A3 present the EA presentation, a summary of the discussion points, and the list of the workshop participants respectively. The second workshop took place in Denver, Colorado, on May 7th, 2003 and was planned in order to provide an opportunity for state, tribe, and local (STL) air pollution control agencies staff and other stakeholders to participate in the project. Prospective attendees were notified by email several weeks prior to the meeting, and via an online questionnaire. Thirteen (13) people attended this day long workshop. The session included a presentation by the EA team that covered the project overview and timeline, the goals and roles of the WRAP EDMS, a summary of the RHR and CERR, a comparative summary of existing systems, a straw man presentation of the conceptual WRAP EDMS, the conceptual timeline of the development and population of the WRAP EDMS, and the summary of the Santa Fe workshop. This was followed by an oral presentation of the special needs of the Fire Emission Joint Forum (FEJF) and specific discussions on the WRAP EDMS needs were brought up during and after the presentations. Appendices B1, B2, and B3 present the EA presentation, a summary of the discussion points, and the list of the workshop participants respectively. 2.2 Description of Questionnaire As mentioned above, in addition to the interview workshop, a web-based questionnaire was posted on http://wrap.eaest.com for a period of three months. All potential users of the WRAP EDMS, stakeholders, and interested parties were invited to fill it out. The questionnaire comprised thirty-four (34) questions designed to collect ideas on all the possible needs of the WRAP EDMS. Overall, twenty (20) peoples responded to the web-based questionnaire. Appendix C shows the results of this questionnaire. Furthermore, one person responded to this questionnaire via email before it was posted on the internet. Appendix C also shows these responses. 2.3 Findings The workshop interviews and questionnaire results underscored the emerging project consensus that the WRAP EDMS needs to be different from any of the other existing systems (including the national emissions inventory (NEI)) because of its architecture, technical capabilities, and contents. The system needs to be developed with all possible users in mind, and with the intent 5 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT to accommodate several distinct user groups. The WRAP EDMS will not only be a repository of the WRAP regional emissions inventories but will also be able to be used to implement the emissions tracking and reporting requirements of the RHR. The WRAP EDMS would be located either at the WRAP regional modeling center (RMC) or at a university center as is the monitoring database. Moreover, it will be made publicly accessible through the internet and will contain online training manuals. The WRAP EDMS will track all the visibility-impairing pollutants: volatile organic compounds (VOC), nitrogen oxides (NOx), SO2, PM10, PM2.5, elemental carbon (EC), organic carbon (OC), carbon monoxide (CO), and NH3 and all the necessary activity data for all the sources and emission factors needed to calculate their emissions. A metadata describing and characterizing all of the emissions data will be developed. Furthermore, The WRAP EDMS will be linked to other related external databases. These databases will contain related surrogate and activity data used to estimate some of the emissions such as mobile, biogenic, and windblown dust sources emissions as well as speciation profiles for VOC and PM data. The WRAP EDMS will also adopt the RPO data exchange protocol in order to capture all the necessary external data. The emissions data will primarily be submitted by STL agencies. Emissions from mobile, biogenic, and windblown dust sources may be estimated through modeling using activity data submitted by STL agencies and other surrogate data. The estimated emissions will be sent to STL agencies for review and approval before inclusion in the final database. Fire source emissions data that are not generated by STL agencies will be estimated by the WRAP EDMS based on fire activity data submitted by STL agencies, federal agencies, private entities, or generated by WRAP. Some STL agencies may estimate fire emissions themselves. These emissions would be submitted by the STL agencies along with all the activity and surrogate data used for the estimation. WRAP will obtain and process the international (Canada and Mexico) data. The large majority of participants in both workshops felt that the WRAP EDMS should be developed and populated in two phases. In Phase I, the system will include the core database architecture, including all of the functioning modules and all of the reporting and queries capabilities (see Section 4). It will be used primarily to store emissions data that will be used to implement the tracking and reporting requirements of both Sections 308 and 309. The focus will be on the implementation of the emissions tracking and reporting requirements of the CAC, fire sources, stationary SO2 sources, and mobile sources. The minimum spatial resolutions of the emissions data will be the county and reservation levels. The submittal temporal resolution of the activity data would be variable (i.e. hourly, daily, seasonal, and annual) depending on the source category. However, the emissions will be reported and tracked on an annual resolution basis. In Phase II, the system could be expanded to incorporate new and updated technical functionality that would allow for storage, tracking, and reporting of hourly, daily, seasonal, and annual emissions data as necessary. The system would include others pollutants (e.g. methane (CH4), mercury (Hg), etc) and their emissions data. It may be used to track other RHR requirements 6 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT (e.g. annual emission goals) and other regulations (e.g. Clear Skies, Greenhouse Gas, etc) requirements. There was general agreement that the WRAP EDMS will be built and tested by the end of 2003 and will be live on the web in early 2004. This first version of the WRAP EDMS will be populated with the 2002 comprehensive emissions data. The collection, processing, and quality assurance/quality control (QA/QC) of these data from the STL agencies will start in early 2004 and will continue throughout 2004. At the same time, the 2002 base and 2018 projection years’ emissions files that will be used by RMC will be produced. The system will also produce the emission reports as needed for both Sections 308 and 309. From 2005 to 2007, annual emissions will be generated from the 2002 comprehensive emissions data in order to satisfy the tracking and reporting requirements of the RHR. At the same time, refined emissions inventories representing the effect of control strategies in 2018 will be developed, and the 2005 comprehensive emissions data will be collected from STL agencies, processed, and QA/QC’d. It should be noted that the emissions data submitted by tribal agencies may be from any given inventory year. Moreover, wherever tribal emissions data are available, the state should adjust its inventory taking into account these tribal data. The conceptual development timeline of the WRAP EDMS is as follow. · · · · · · Mid 2003: finish needs assessment project Late 2003: 1. WRAP contractor builds and alpha tests Phase I of WRAP EDMS 2. Beta test of the WRAP EDMS Early 2004: 1. Initiate live Phase I of the WRAP EDMS on the web 2. Provide training and user support Throughout 2004: begin collection, processing, and QA/QC of 2002 emissions from STL agencies Late 2004: 1. Implement Phase II of the WRAP EDMS 2. Provide training and user support 3. Produce emissions reports as needed for Section 308 and 309 requirements 4. Prepare 2002 base and 2018 projection years' emissions files for use by RMC 2005-2007: ongoing operation of the WRAP EDMS 1. Track emissions as needed for Section 308 and 309 2. Develop refined emissions inventories representing the effect of control strategies in 2018 3. Provide training and user support 4. Populate the WRAP EDMS with annual emissions data to meet Section 308 and 309 regulatory requirements 5. Collection, processing, and QA/QC of 2005 emissions from STL agencies There was also consensus that the WRAP EDMS should be built in a modular fashion, to allow for easy expansion and improvement. It will include six major modules representing the sources (point, area, fire, mobile, windblown dust, and biogenic) in addition to the GIS, QA/QC, and database administrator (DBA) modules. The submission formats will be similar to that of the 7 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT NEI format (NIF) and the minimum submission cycle would coincide with the submission cycle of the NEI (annual and triennial cycles). However, the WRAP EDMS will have an open submittal process, where STL agencies’ emissions data will be submitted at different times. Currently, state submit the NIF in several file formats including ASCII Text (Text), Microsoft Access database (MS Access), and eXtended Markup Language (XML). The results of the questionnaire indicated that, across the WRAP region, states are using Text, MS Access, inhouse developed systems, and other systems (i.e. AMS Tempo) that need to be converted to the NIF. Therefore, the WRAP EDMS will accept all the file formats already accepted by NEI. The WRAP EDMS will be managed by a DBA whose functions could include QA/QC, some emission calculations, data gap filling, data archiving, and data version management among others. 8 EA Engineering, Science, and Technology 3.0 COMPARATIVE ANALYSIS 3.1 Conceptual WRAP EDMS FINAL TECHNICAL REPORT The conceptual WRAP EDMS was developed based on the findings of the interview workshops and the web-based questionnaire. 3.1.1 Data Tracking The WRAP EDMS should contain all visibility-impairing pollutants: VOC, NOx, SO2, PM10, PM2.5, EC, OC, CO, and NH3. The WRAP EDMS should also track all necessary activity data for all the sources and emission factors needed to calculate emissions. These pollutants and related activity data should be tracked for the following sources: point, area, mobile, biogenic, windblown dust, and fire sources. The data will be tracked at the county and reservation level for all sources and also individually for point and fire sources. The emissions data will be submitted to the WRAP EDMS by STL agencies, except for biogenic, mobile, windblown dust, and certain fire sources emissions data that will be calculated by WRAP using emissions estimation models. The submissions will be in a standard format similar to the NIF and done at the NEI minimum cycle but STL agencies may submit emissions data frequently. 3.1.2 Data QA/QC The WRAP EDMS should include a QA/QC module to perform two levels of QA/QC. The first level of QA/QC should include a validation of the format of the submitted data files. This will ensure that the submitting entity supply all data to WRAP in the expected format and also identify any errors. The submittal check will be at the point of entry to the WRAP EDMS in order to minimize the DBA work and encourage STL agencies to submit clean data. The second level of QA/QC should consist of checks of the data that is submitted to WRAP, and include checking reference values and acceptable data ranges for specific data points. The data should also be checked for completeness, ensuring that all data exists for all sources and geographic areas. 3.1.3 Data Reporting The WRAP EDMS should include a series of standard summary reports broken down by source type, geographic location, and pollutant. It should also include a series of reports designed specifically to meet the RHR emissions tracking and reporting requirements. The RHR reports will include special reports for CAC, pre-trigger SO2 stationary sources, mobile sources, fire sources, and windblown dust sources. The WRAP EDMS should also include a series of data export formats for inclusion in external systems including emissions modeling programs such as SMOKE (MCNC, 1999). 3.1.4 GIS Components The WRAP EDMS should include a fully functioning GIS module that provides multiple tools to display data over the internet. The inclusion of a GIS module will provide a means for users to 9 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT select data that is of importance to them and display the data in a fashion that is easily understood. The WRAP EDMS should include the following GIS functionality: pan, zoom, query layer information, ability to add/remove multiple layers of data, point and click, measure distances, buffer, print multiple sizes of maps, and select map features by line, rectangle, or polygon. The WRAP EDMS GIS module should include the following layers of data: county, state and country polygons, tribal reservation polygons, roadways and railroad line features, CAC polygons, international polygons, metropolitan statistical areas polygons, nonattainment area polygons, class I areas polygons, bodies of water polygons, census data polygons, other federal land polygons (i.e. national parks, monuments, forest, and refuges), and WRAP modeling domain grid system. It should have the ability to select and display emissions sources and associated emissions data by geographical area. 3.1.5 User Access and Preferences All reporting features of the WRAP EDMS should be available to the public via the internet. STL agencies will have a separate, non-public interface for submitting their data to a central submission area. The user interface for the WRAP EDMS should be easy and intuitive to use while providing all necessary functionality. 3.2 Comparison Five existing EDMS were evaluated and compared each to the conceptual WRAP EDMS. Each system was evaluated in terms of meeting the design and functionality requirements of the conceptual WRAP EDMS. As expected, none of the individual systems included all of the required elements for the conceptual WRAP EDMS. This was due in part to the fact that none of the systems tracked all of the required pollutants or included emissions data from all of the required, individual sources. In some instances, individual systems included most or all of the required functionality, such as a GIS module or the ability to export data, but did not track emissions data for all of the required pollutants or sources. Without all of the required data available, the output of these systems will be incomplete. Appendix D illustrates the overall comparison between the conceptual WRAP EDMS and the selected existing systems and Section 3.3 below describes these systems further. 3.3 Existing EDMS This section lists each of the selected five existing database management systems, provides a brief description and background information for each, and highlights any elements from each system that could be utilized by the WRAP EDMS. 3.3.1 National Emissions Inventory – NEI The EPA’s Emission Factor and Inventory Group (EFIG) maintains a national emissions inventory containing information on air emissions and their sources for each state in the U.S., the U.S. Virgin Islands, Puerto Rico and the District of Columbia. The NEI has a public website 10 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT (http://www.epa.gov/air/data/index.html) where users can query the emissions database and produce reports based on their specific needs. 3.3.1.1 System Details The NEI tracks seven pollutants: VOC, NOx, SO2, PM10, PM2.5, CO, and NH3. The pollutants are tracked for four source types: point, area, mobile, and biogenic sources. All data is tracked at the county level for all sources, and also individually for point sources. The data is submitted on an annual and triennial basis to EPA by state and tribal agencies. The data is submitted in the EPA’s standard submission format, the NIF. The NEI includes a QA/QC process that performs multiple levels of QA/QC checks. The first level consists of a validation of the format of the submitted data files, which ensures that the submitting entity supplied all data to NEI, in the expected format, and also identifies any errors with the submitted format. The second level of QA/QC checks includes checks of the data that is submitted to NEI. Reference values are checked against standard lists and data points are checked against acceptable data ranges. The data is also checked for completeness, ensuring that all data exists for all sources and geographic areas. If data points are missing, the NEI will replace the missing values with national averages or previous year data for the particular data point. The NEI includes a series of standard summary reports broken down by source category, geographic location, and pollutant. The NEI also includes a data export feature to allow data to be extracted from the NEI database for inclusion in external systems. The NEI includes a basic mapping capability to display emissions data over the internet. The NEI mapping functionality includes the ability to pan, zoom, and displays county, state and country boundaries. All reporting features of the NEI are available to the public via the internet. The NEI user interface is easy to use and navigate to reach the desired data. 3.3.1.2 Key System Elements The NEI has three key elements that should be utilized in the WRAP EDMS. First, the NEI requires a standard submission format (NIF) for all data submitted to the system. The WRAP EDMS could utilize this same submission format for all data sources, except for fire sources. The submission format captures the required emissions and activity data for all pollutants except OC and EC, which can be calculated by the WRAP system, based on the PM2.5 data. Also, since STL agencies are already required to submit their data in the NIF format, no additional work will be necessary on their part to create submissions for the WRAP EDMS. See Appendix E for the recent version of the NIF submission formats. Second, the NEI has a well-established and defined QA/QC process for all submitted emissions data. This process does a thorough analysis of the submission format and data content to identify all possible issues before the data is included in the system. The WRAP EDMS could adopt a 11 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT modified version of this QA/QC Process to ensure that all data submitted to the WRAP EDMS is accurate. However, instead of automatically replacing missing or erroneous data with a default set of data, WRAP could make recommendations for replacing missing data or supplementing existing data to STL agencies while leaving the final approval for all data included in the WRAP EDMS with them. See Appendix F for a detailed explanation of the NEI QA/QC process. Finally, the NEI includes an adequate set of standard reports for users to utilize when accessing the NEI database. The set of reports is not exhaustive, but does provide an excellent basis for data reporting and gathering to serve the public’s data needs. The NEI report interface is also very easy to use and intuitive, making the data gathering process easy for the user. The WRAP EDMS could adopt this report functionality and design for the general data gathering and reporting capabilities of its system. 3.3.2 Tribal Emissions Inventory Software Solution – TEISS Northern Arizona University is currently developing an air emissions inventory for all western region tribes. The Tribal Emissions Inventory Software Solution (TEISS) will be a desktop application where users can query the emissions database and produce reports based on their specific needs. 3.3.2.1 System Details The TEISS tracks seven pollutants: VOC, NOx, SO2, PM10, PM2.5, CO, and NH3. The pollutants are tracked for three source types: point, area, and mobile sources. All data is tracked at the reservation level for all sources, and also individually for point sources. The data is collected from the tribes on a continuing basis. The data is submitted in multiple formats and can also be hand-entered through data entry screens. The TEISS includes a series of standard reports broken down by source category, geographic location, and pollutant. The TEISS also includes a data export feature to allow data to be extracted from the TEISS database for inclusion in external systems, including the NEI and modeling programs such as SMOKE. The TEISS includes a fully functioning GIS module that provides multiple tools to display data geographically. The TEISS includes several advanced GIS features including: pan, zoom, query layer information, ability to add/remove multiple layers of data, measure distances, buffer, print multiple sizes of maps, and select map features by line, rectangle, or polygon. The TEISS GIS module includes several static layers of data, such as county, state and country, and tribal reservation boundaries, and the ability to select and display emissions sources and associated emissions levels by geographical area. The TEISS utilizes an advanced user interface, since it is a desktop application and not accessible via the internet. 12 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 3.3.2.2 Key System Elements The TEISS has two key elements that should be utilized in the WRAP EDMS. First, the TEISS has a fully functioning GIS module embedded in the system. This allows TEISS users to display map features in conjunction with relevant emissions and activity data on a real-time basis. The TEISS GIS module includes a full set of tools for manipulation of any map created in the system. The WRAP EDMS could include a majority of this functionality in its GIS module to provide its users a complete internet GIS capability. However, since current web GIS capabilities are limited compared to desktop capabilities, the WRAP EDMS will not be able to implement all of the features of the TEISS GIS module. Second, the TEISS has a flexible set of exporting functions to allow for multiple data export formats. The WRAP EDMS could include a comparable set of exporting features to accommodate the need of multiple formats for the system’s users. 3.3.3 California Air Resources Board Emissions Inventory – CARBEI The California Air Resources Board maintains an emissions inventory (CARBEI) containing information on air emissions and their sources for the state of California. The CARBEI has a public website (http://www.arb.ca.gov/emisinv/eib.htm) where users can query the emissions database and produce reports based on their specific needs. 3.3.3.1 System Details The CARBEI tracks five pollutants: NOx, SO2, PM10, PM2.5, and CO. The pollutants are tracked for three sources types: point, area, and mobile sources. All data is tracked at the county level for all sources, and also individually for point sources. The data is submitted by local agencies in the California Air Resources Board’s standard submission format, the California Emission Inventory Development and Reporting System (CEIDARS). The CARBEI includes a QA/QC process that performs multiple levels of QA/QC checks. The first level consists of a validation of the format of the submitted data files, which ensures that the submitting entity supplied all data to CARBEI, in the expected format, and also identifies any errors with the submitted format. The second level of QA/QC checks includes checks of the data that is submitted to CARBEI. Data points are checked against acceptable data ranges to ensure the submitted data are accurate and reasonable. The CARBEI includes standard summary reports broken down by source category, geographic location, and pollutant. The CARBEI also includes a data export feature to allow data to be extracted from the CARBEI database for inclusion in external systems. All reporting features of the CARBEI are available to the public via the internet. The CARBEI user interface is easy to use and navigate for the user to reach the desired data. 13 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 3.3.3.2 Key System Elements The CARBEI has one key element that should be utilized in the WRAP EDMS. The CARBEI report interface is very easy to use and intuitive, making the data gathering process easy for the user. The WRAP EDMS could adopt this report functionality and design for the general data gathering capabilities of its system. 3.3.4 Colorado Department of Health Air Pollution Inventory – CAPI The Colorado Department of Health maintains an Air Pollution Inventory (CAPI) containing information on air emissions and their sources for the state of Colorado. The CAPI has a public website (http://emaps.dphe.state.co.us/APInv/viewer.htm) where users can query the emissions database and produce reports based on their specific needs. It should be noted that CAPI is not the Colorado primary emissions inventory system. It is included in this analysis because of its internet capabilities. 3.3.4.1 System Details The CAPI tracks five pollutants: VOC, NOx, SO2, PM10, and CO. The pollutants are tracked for three source types: point, area, and mobile sources. All data is tracked at the county level for all sources, and also individually for point sources. The data is submitted by local agencies on a continuing basis. The CAPI includes standard summary reports broken down by source category, geographic location, and pollutant. The CAPI includes a fully functioning GIS module that provides multiple tools to visually display data. The CAPI includes several advanced GIS features including: pan, zoom, query layer information, ability to add/remove multiple layers of data, measure distances, buffer, print, and select map features by line, rectangle, or polygon. The CAPI GIS module includes several static layers of data, such as county and state boundaries, and various attainment area boundaries. All reporting features of the CAPI are available to the public via the internet. The CAPI user interface is easy to use and navigate for the user to reach the desired data. 3.3.4.2 Key System Elements The CAPI includes a functioning, internet-based GIS module. The CAPI GIS module includes a full set of tools for manipulation of any map created in the system. Although the CAPI does not have the capability of mapping data from the emissions database, it does represent a good example of internet-based GIS functionality. The WRAP EDMS could include this functionality in its GIS module to provide its users internet-based GIS capability. 14 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 3.3.5 Delaware Environmental Navigator – DEN The Delaware Department of Natural Resources and Environmental Control maintains a database of information for all aspects of environmental monitoring and control. The Delaware Environmental Navigator (DEN) has a public website (http://www.dnrec.state.de.us/dnreceis/) where users can query the database and produce reports based on their specific needs. 3.3.5.1 System Details At the air emissions level, the DEN tracks five pollutants: VOC, NOx, SO2, PM10, and CO. The pollutants are tracked for three source types: point, area, and mobile sources. All data is tracked at the county level for all sources, and also individually for point sources. The data is submitted by local agencies on a continuing basis. The DEN includes a limited QA/QC process that performs quality checks of all submitted data. The DEN includes standard summary reports broken down by source category, geographic location, and pollutant. The DEN includes a fully functioning GIS module that provides multiple tools to display data geographically. The DEN includes several advanced GIS features including: pan, zoom, query layer information, ability to add/remove multiple layers of data, measure distances, print, and select map features by line, rectangle or polygon. The DEN GIS module includes several static layers of data, such as county, state and country boundaries, interstate and highway line features, and the ability to select and display data by geographical area. All reporting features of the DEN are available to the public via the internet. The DEN user interface is easy to use and navigate to reach the desired data. 3.3.5.2 Key System Elements The DEN has a fully functioning, internet-based GIS module included in the system. This allows DEN users to display map features in conjunction with relevant emissions and activity data on a real-time basis. The DEN GIS module includes a full set of tools for manipulation of any map created in the system. The DEN was included in this comparison due to its advanced internet-based GIS functionality and its ability to map user defined data queried from the DEN database on a real time basis. The WRAP EDMS could include this functionality in its GIS module to provide its users internet-based GIS capability. 15 EA Engineering, Science, and Technology 4.0 RECOMMENDATIONS 4.1 Flow Chart of the WRAP EDMS FINAL TECHNICAL REPORT Appendix G presents the flow chart of the WRAP EDMS that shows the information needs, from the emissions data submission to the report generations, data queries, graphic display, and GIS presentation. The sections below explain the different parts of this flow chart. 4.2 Point Source Module For point sources, at a minimum, the emissions data listed below should be submitted, stored, and tracked for each inventory. The data file should be organized into records for the submitting format. In the NIF Version 3, the point source file contains eight records with specific key fields represented by these emissions data (see Appendix E). 1) Inventory year 2) Inventory start date 3) Inventory end date 4) Inventory type 5) Country code 6) State and county FIPS code 7) Tribal code 8) Facility ID code 9) Point ID code 10) Process ID code 11) Stack ID code 12) Site name 13) Physical address 14) SCC code 15) Heat content (fuel) (annual average) 16) Ash content (fuel) (annual average) 17) Sulfur content (fuel) (annual average) 18) Pollutant code 19) Activity/throughput (annual) 20) Activity/throughput (daily) 21) Work weekday emissions 22) Annual emissions 23) Emission factor 24) Winter throughput (%) 25) Spring throughput (%) 26) Summer throughput (%) 27) Fall throughput (%) 28) Hours/day in operation 29) Start time (hour) 30) Day/week in operation 31) Weeks/year in operation 16 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 32) X stack coordinate (latitude) 33) Y stack coordinate (longitude) 34) Stack height 35) Stack diameter 36) Exit gas temperature 37) Exit gas velocity 38) Exit gas flow rate 39) SIC code 40) Design capacity 41) Maximum nameplate capacity 42) Primary control efficiency (%) 43) Secondary control efficiency (%) 44) Control device type 45) Rule effectiveness (%) Emissions from point sources will be estimated by STL agencies using emission factors published in AP-42 (EPA, 1998) or from stack test data and submitted at the individual source level on an annual temporal resolution basis. According to the CERR, the minimum point source reporting thresholds are 100 tons per year (tpy) for VOC, NOx, SO2, PM10, PM2.5, and NH3 and 1000 tpy for CO. Many states have different reporting thresholds tied to other state environmental regulations and would like to be able to retrieve data from the EDMS as they are submitted. Therefore, the WRAP EDMS will allow different point source cutoff level submissions and will check for these discrepancies in order to avoid double counting emissions. 4.3 Area Source Module Based on input and discussion, it appears that area sources represent all other stationary sources not included in the point source category, excluding fire and windblown dust sources. These sources also include open burning activities on residential, commercial, and industrial properties. For area sources, at a minimum, the emissions data listed below should be submitted, stored, and tracked for each inventory. Similar to the point sources, the data file should be organized into records. The area source file contains five records in the NIF version 3 (see Appendix E). 1) Inventory year 2) Inventory start date 3) Inventory end date, 4) Inventory type 5) Country code 6) State and county FIPS code 7) Tribal code 8) SCC code 9) Emission factor 10) Activity/throughput level (annual) 11) Total capture/control efficiency (%) 12) Rule effectiveness (%) 17 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 13) Rule penetration (%) 14) Pollutant code 15) Summer/winter work weekday emissions 16) Annual emissions 17) Winter throughput (%) 18) Spring throughput (%) 19) Summer throughput (%) 20) Fall throughput (%) 21) Hours/day in operation 22) Days/week in operation 23) Weeks/year in operation Emissions from area sources will be estimated by STL agencies using mostly emission factors published in AP-42 (EPA, 1998) and submitted at the county level on an annual temporal resolution basis. The area source definitions are different from STL to STL. For example, some STL define gas stations or dry cleaners as point sources while others do as area sources. Therefore, the WRAP EDMS will allow different source category submissions and will check for these discrepancies in order to avoid double counting emissions. 4.4 Mobile Source Module Mobile sources are divided into two main categories: onroad and nonroad mobile sources. Onroad mobile sources are motor vehicles licensed for use on highways or roadways (i.e. automobiles, trucks, etc). Onroad mobile source emissions are the product of emission factors obtained through the execution of the latest EPA’s MOBILE model (EPA, 2002) or the California EMFAC model (CARB, 2002) and activity levels represented by the vehicle mile traveled (VMT). Dust from paved and unpaved roads may be estimated by using either the method in AP-42, Section 11 (EPA, 1998) or the EPA’s PART5 model (EPA, 1995). Nonroad mobile sources are the other mobile sources represented for instance by construction equipment, lawn and garden equipment, snowmobiles, boats, trains, and airplanes. Their emissions can be estimated using the EPA’s NONROAD model (EPA, 2000) and/or published emission factors, especially for boats and trains. Emissions of airplanes and associated ground support equipment and auxiliary power units are estimated using the Federal Aviation Administration (FAA) Emission and dispersion Modeling System model (FAA, 2002). It is not anticipated that the WRAP EDMS will contain these models. Most mobile emissions will be submitted at the county level on an annual temporal resolution basis. However, many mobile source emissions data are seasonal in nature. Therefore, the WRAP EDMS may store applicable seasonal mobile emissions data as well. For unsubmitted and/or missing mobile source emissions data for a given area, the WRAP EDMS DBA will estimate the inventories using available mobile emissions models and area-specific data or national average data. These inventories will be submitted to STL agencies for review and approval before inclusion in the final database. 18 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT For mobile sources, the emissions data listed below should be submitted, stored, and tracked for each inventory. Similar to the point sources, the data file should be organized into records. The onroad and nonroad mobile source files contain three and five records respectively in the NIF version 3 (see Appendix E). For on-road mobile sources, 1) Inventory year 2) Inventory start date 3) Inventory end date 4) Inventory type 5) Country code 6) State and county FIPS code 7) Tribal code 8) SCC code 9) Emission factor 10) Activity (VMT by roadway class) 11) Pollutant code 12) Summer/winter work weekday emissions 13) Annual emission 14) Refueling emissions classification For non-road mobile sources, 1) Inventory year 2) Inventory start date 3) Inventory end date 4) Inventory type 5) Country code 6) State and county FIPS code 7) Tribal code 8) SCC code 9) Emission factor 10) Activity/throughput level (annual) 11) Total capture/control efficiency (%) 12) Rule effectiveness (%) 13) Rule penetration (%) 14) Pollutant code 15) Summer/winter work weekday emissions 16) Annual emissions 17) Winter throughput (%) 18) Spring throughput (%) 19) Summer throughput (%) 20) Fall throughput (%) 21) Hours/day in operation 22) Days/week in operation 19 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 23) Weeks/year in operation 4.5 Biogenic Source Module The latest EPA’s Biogenic Emissions Inventory System (BEIS) model (EPA, 1998) will be used to generate the region-wide biogenic emissions using activity data submitted by STL agencies and other surrogate land use and meteorological data. The emission inventories will then be submitted to STL agencies for review and approval before inclusion in the final database. The reporting spatial resolution will be the county level and the temporal resolution will be annual for the biogenic emissions data in Phase I. In phase II, hourly, daily, or seasonal temporal resolutions may be tracked. The biogenic emissions are currently being generated at RMC on a 36-km grid system for each hour. Therefore, they will need to be converted to a county level and aggregate on an annual temporal resolution basis before being sent to STL agencies for review and subsequent inclusion in the WRAP EDMS. For biogenic sources, at a minimum, the emissions data listed below should be submitted, stored, and tracked for each inventory. Similar to the point sources, the data file should be organized into records. The biogenic source file contains two records in the NIF version 3 (see Appendix E). 1) Inventory year 2) Inventory start date 3) Inventory end date 4) Inventory type 5) Country code 6) State and county FIPS code 7) Tribal code 8) SCC code 9) Pollutant code 10) Summer/winter work weekday emissions 11) Annual emissions 4.6 Windblown Dust Source Module Windblown dust emissions will be generated region-wide through modeling. The emission inventories will then be submitted to STL agencies for review and approval before inclusion in the final database. The spatial resolution will be the county level and the temporal resolution will be annual for the windblown dust source data in Phase I. In phase II, hourly, daily, or seasonal temporal resolutions may be tracked. The dust emissions (PM10 and PM2.5) are currently being estimated using wind data as emissions per grid square. Therefore they will need to be converted to a county level before being sent to STL agencies for review and subsequent inclusion in the WRAP EDMS. For windblown dust sources, at a minimum, the emissions data listed below should be submitted, stored, and tracked for each inventory. Windblown dust source is not included in the NEI as a 20 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT separate source category. Therefore, the data file needs to be created and the records defined. A definition based on the NIF biogenic source file should suffice. 1) Inventory year 2) Inventory start date 3) Inventory end date 4) Inventory type 5) Country code 6) State and county FIPS code 7) Tribal code 8) SCC code 9) Pollutant code 10) Summer/winter work weekday emissions 11) Annual emissions 12) Natural or anthropogenic classification 4.7 Fire Source Module There are four types of fire emissions sources - wildfire, prescribed fire, wildland fire use, and agricultural burning - that will be included in the fire source module of the WRAP EDMS. It should be noted that wildfire, prescribed fire, wildland fire use include rangeland. Fire sources such as open burning activities on residential, commercial, and industrial properties will be included in the area source module. The WRAP Fire Tracking System (FTS) (WRAP, 2001) identified seven essential data (9 – 17) that will provide the basis for calculating the emissions for fire through the use of an emissions calculation mechanism, such as the WRAP emissions inventory system, to integrate the appropriate emissions factors and emission calculation techniques. The FTS also identified optional data (18 – 21) that are equally important in calculating fire emissions. Note that for fire sources, the WRAP EDMS will calculate the emissions. However, some STL agencies may estimate fire emissions themselves. These emissions will be submitted by the STL agencies with all the activity and surrogate data used for the estimation. For fire sources, at a minimum, the emissions data listed below should be submitted, stored, tracked, and also used to calculate fire emissions when necessary. In the NEI, fire sources are contained in the area source category. Therefore, a data file which records are similar to the NIF area source file may define the fire source file. 1) 2) 3) 4) 5) 6) 7) 8) 9) Inventory year Inventory start date Inventory end date Inventory type County code State and county FIPS code Tribal code SCC code Date of burn 21 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 10) Duration of burn 11) Burn location latitude 12) Burn location longitude 13) Area of burn 14) Fuel type 15) Pre-burn fuel loading 16) Type of burn 17) Anthropogenic or natural classification 18) Daily tracking components 19) Fuel consumption 20) Non-burning techniques 21) Additional fire tracking information 22) Pollutant code 23) Emission factor 24) Daily emissions 25) Annual emissions 4.8. Standard Reports and Queries The EDMS should have the capability to produce the following standard reports in tabular and simple plots (i.e. bar graph and pie chart) formats and allow queries of the same information including presentation in GIS format. · · · · · · · A summary report of the annual WRAP emission inventory, compiled at the county and reservation levels and totaled for each state, tribe, and the WRAP region, for all pollutants, broken down by point, area, mobile, fire, biogenic, and windblown dust source categories, and by summed total emissions for all six source categories. A summary report of the annual WRAP emissions from the stationary point sources in each county and reservation and the stationary point sources for each state, tribe and the entire region (broken down by plant name), for each pollutant. A summary report of the annual WRAP emissions from the stationary point sources in each county and reservation and the stationary point sources for each state, tribe and the entire region (broken down by SCC code), for each pollutant. A summary report of the annual WRAP emissions from the area sources in each county and reservation and the area sources for each state, tribe and the entire region (broken down by SCC code), for each pollutant. A summary report of the annual WRAP emissions from the “Top 10” stationary point sources in each county and reservation and the “Top 10” stationary point sources for each state, tribe and the entire region (broken down by plant name), for each pollutant. A summary report of the annual WRAP emissions from the “Top 10” stationary point sources in each county and reservation and the “Top 10” stationary point sources for each state, tribe and the entire region (broken down by SCC code), for each pollutant. A summary report of the annual WRAP emissions from the “Top 10” area sources in each county and reservation and the “Top 10” area sources for each state, tribe and the entire region (broken down by SCC code), for each pollutant. 22 EA Engineering, Science, and Technology · · · · · · · · 4.9. FINAL TECHNICAL REPORT A summary report of the annual WRAP emissions from on-road mobile sources in each county and reservation and on-road mobile sources for each state, tribe and the entire region (broken down by the sixteen (16) mobile source categories), for each pollutant and dust from paved and unpaved road. A summary report of the annual WRAP emissions from non-road mobile sources in each county and reservation and non-road mobile sources for each state, tribe, and the entire region (broken down by SCC code), for each pollutant. A summary report of the annual WRAP emissions from fire sources in each county and reservation and fire sources for each state, tribe, and the entire region (broken down by the 3 fire categories (wildfire, prescribed wild land burning, and agricultural burning activities), for each pollutant. A summary report of the annual WRAP emissions from biogenic sources in each county and reservation and biogenic sources for each state, tribe, and the entire region (broken down by emission source name). Data reports in the NEI Input Format Version 3.0 (NIF V3.0) for submittal to the EPA under the CERR. For stationary point sources, data reports for all emission points on site by text description name and by Stack ID, for NEI file format stack parameters (STKHGT, STKDIAM, STKTEMP, STKFLOW, STKVEL), production rates (BOILCAP, CAP_UNITS, THRUPUT, MAXRATE, NETDC), fuel parameters (HEATCON, SULFCON, ASHCON), standard industrial classification code (SIC), location (LATC, LONG), and emission controls ("pollutant"_CE, "pollutant"_CPRI, "pollutant"_CSEC). For stationary point sources, data reports for all emission points on site by text description name and by Stack ID, for actual emission rates of each pollutant, on an annual (tpy) and on a short term (pounds per hour) basis. This emission data will be summed for a cumulative total of emissions from each stationary point source. In addition to these standard reports, the EDMS will produce regional emission model (SMOKE)-ready emissions input files for the regional visibility modeling efforts. Special Section 309 Tracking Section 309 of the RHR requires that the first SIP be submitted by December 31, 2003 and that SIP must be effective until December 2018. Section 309 also specifically requires comprehensive emissions tracking and reporting for the clean air corridors (CAC), stationary SO2 sources, mobile sources, fire sources, and windblown dust based on annual emissions. 4.9.1 Clean Air Corridors (CAC) The preamble of the RHR defines a CAC as “a region that generally brings clean air to a receptor region”. The preamble also says, “the requirement to track emissions will enable states to quickly determine if changes in patterns of emissions will reduce the number of clean air days (defined as the average of the 20% clearest days) in any of the 16 Class I areas.” The actual requirements state that the Section 309 SIP/TIP must describe and provide for implementation of comprehensive emission tracking strategies for CAC to ensure that the visibility does not degrade on the least-impaired days at any of the 16 Class I areas. The strategy must include: 23 EA Engineering, Science, and Technology · · · · · FINAL TECHNICAL REPORT An identification of CAC. Within areas that are CAC, an identification of patterns of growth or specific sites of growth that could cause, or are causing, significant emissions increases that could have, or are having, visibility impairment at one or more of the 16 Class I areas. In areas outside of CAC, an identification of significant emissions growth that could begin, or is beginning, to impair the quality of air in the corridor and thereby lead to visibility degradation for the least-impaired days in one or more of the 16 Class I areas. If impairment of air quality in CAC is identified, an analysis of the effects of increased emissions, including provisions for the identification of the need for additional emission reduction measures, and implementation of the additional measures where necessary. A determination of whether other clean air corridors exist for any of the 16 Class I areas. For any such CAC, an identification of the necessary measures to protect against future degradation of air quality in any of the 16 Class I areas. WRAP identified one CAC as shown in Appendix H. Using the most recent state emission inventories available through the WRAP EDMS, WRAP will produce a report for each five-year implementation plan revision (2008, 2013, and 2018) on the current and projected emissions in the CAC and in areas outside the corridor and compare these emissions to a 1996 baseline emissions. WRAP has examined patterns of growth in the CAC and found that they are not causing significant emission increases that could have or are having visibility impacts at one or more of the 16 Class I areas. Nor, at this time, are such emission increases expected during the first planning period (2003-2018). WRAP also has examined emissions growth in areas outside the corridor and found that significant emissions growth is not occurring that could begin or is beginning to impair the quality of the air in the corridor and thereby lead to visibility degradation for the least impaired days in one or more of the 16 Class I areas. Since impairment of air quality in clean air corridors has not been identified, WRAP finds no requirement under for further visibility impact analysis or additional emission reduction measures until at least the next SIP revision (2008). WRAP finds no other clean air corridors beyond the corridor identified in Appendix H. Consequently, the EDMS should have the capability to produce the following special reports in tabular and simple plots (i.e. bar graph and pie chart) formats and allow queries of the same information including presentation in GIS format, in addition to the standard reports. · · · A summary report of the annual summed total emissions for all six source categories and all of the pollutants by county/state and tribal lands, as well as for the entire CAC. A summary report of the annual summed total emissions for all six source categories and all of the pollutants for the same types of political boundaries surrounding the CAC. A summary report of the comparison of the annual summed total emissions for all six source categories and all of the pollutants for the same types of political boundaries, as well as the entire CAC and the corresponding base year total emissions. 24 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT 4.9.2 Pre-Trigger SO2 Annex The SO2 Annex program, as proposed by WRAP and adopted by EPA, requires the tracking of SO2 emissions from eligible stationary sources within states or tribal reservations participating in Section 309, to determine if the regional SO2 emissions cap has been exceeded. This is known as “pre-trigger” tracking. Beginning with the 2003 calendar year and continuing through 2018, each state and tribe participating in the program will submit an annual SO2 emissions report to the WRAP EDMS for the sources covered by the program. These annual reports will contain the following information: · · · · Identification and explanation for new/additional SO2 sources which emissions are greater than100 tpy that were not contained in the previous year’s emissions report. Explanation for sources shut down or removed from the previous year’s emissions report. Explanation for emissions variations at any covered source that exceeds +/- 20% from the previous year. Identification and explanation of new emissions reporting methods at any source. WRAP will compile the annual emissions reports submitted by the states and tribes participating in the program into a regional emission report for SO2 using the WRAP EDMS. By December 31 of the year following the applicable compliance year, WRAP will prepare a regional emission report that will include the following information: · · · · · Summary of regional SO2 emissions (tpy). Identification of any paper emission increases and decreases that have occurred due to changes in emission inventory techniques since the last SIP revision for the regional haze SIP. The report will contain a running regional total, as well as supporting documentation identifying the specific changes that have occurred at individual sources. Average emissions for the last three years (if applicable) for comparison to the regional milestone. Regional milestone for the compliance period. Draft determination that the milestone has either been met, or has been exceeded thereby triggering the backstop trading program. Consequently, The EDMS should have the capability to produce the following special reports in tabular and simple plots (i.e. bar graph and pie chart) formats and allow queries of the same information including presentation in GIS format, in addition to the standard reports. · · · A summary report of the annual WRAP emissions from the stationary sources emitting more than 100 tpy of SO2 in the base year for each state, tribe and the entire region. A summary report of the new stationary sources emitting more than 100 tpy of SO2 that were not contained in the previous year’s inventory for each state, tribe and the entire region. A summary report of the stationary sources emitting more than 100 tpy of SO2 that are retired compared to the previous year’s inventory for each state, tribe and the entire region. 25 EA Engineering, Science, and Technology · · · · 4.9.3 FINAL TECHNICAL REPORT A summary report of the regional average SO2 emissions from stationary sources emitting more than 100 tpy of SO2 for the last three years and comparison to the regional milestone for the compliance period. A summary report of the stationary sources emitting more than 100 tpy of SO2 which emissions exceed +/- 20% compared to the previous year’s inventory for each state, tribe and the entire region. A summary report identifying all the stationary sources emitting more than 100 tpy of SO2 that choose to opt in the program for each state, tribe and the entire region. A summary report identifying all the stationary sources emitting more than 100 tpy of SO2 that were not included in the base year for each state, tribe and the entire region. Mobile Emissions For mobile sources, the SIP/TIP submissions must provide for statewide inventories of on-road and non-road mobile source emissions of VOC, NOX, SO2, PM2.5, EC, OC, and paved and unpaved road dust for the years 2003, 2008, 2013, and 2018. The inventories must demonstrate a continuous decline in total mobile source emissions for the aforementioned pollutants, evaluated separately. This means that the statewide mobile source emissions of each pollutant in 2008, 2013, and 2018 must be less than the estimated emissions of that pollutant for the previous period. Consequently, the EDMS should have the capability to produce the following special report in tabular and simple plots (i.e. bar graph and pie chart) formats and allow queries of the same information including presentation in GIS format, in addition to the standard reports. · 4.9.3 A summary report of the comparison of annual WRAP total (on-road plus nonroad) emissions from the mobile sources (VOC, NOx, SO2, PM2.5, EC, OC, and paved and unpaved road dust) for each state, tribe and the entire region and the corresponding previous period total emissions, for each pollutant. Fire Emissions For fire emissions, Section 309 of the RHR specifically calls for a statewide inventory and emissions tracking system (spatial and temporal) of VOC, NOX, EC, OC, and PM2.5 emissions from fire. The WRAP inventory will add SO2, PM10, CO, and NH3 emissions. Under Section 309, states and tribes must identify a method or a timeline to develop a method to track fire activity data and calculate the resulting required emissions inventory in their SIP/TIP. Tracking of fire activity data and calculation of the resulting emissions through the WRAP EDMS will provide information critical to the successful implementation of other requirements under Section, including the development, adoption, and implementation of enhanced smoke management programs, the establishment of annual emission goals, and future projections of fire emissions. The WRAP EDMS will track activity data as reported by states and tribes participating in Section 309, as well as the same type of data provided by other WRAP region state, tribal, and 26 EA Engineering, Science, and Technology FINAL TECHNICAL REPORT local air agencies, and federal/state/private sources using prescribed and/or agricultural burning techniques. The WRAP EDMS will calculate the resulting emissions for fire source types including prescribed fire, wildfire, wildland fire use, and agricultural burning. The EDMS should have the capability to produce a special report in tabular and simple plots (i.e. bar graph and pie chart) formats and allow queries of the same information including presentation in GIS format in the standard report style presented in Section 3.8 of this report. 4.10 GIS Module GIS provides users with the ability to display and analyze data that is related to a geographic location. GIS provides a means for an organization to display data that is easily read and understood. The WRAP EDMS should include a fully functioning GIS module that provides multiple tools to display data over the internet. The inclusion of a GIS module will provide a means for users to select data that is of importance to them and display the data in a fashion that is easily understood. During Phase I of development, the WRAP EDMS should include the following GIS Functionality. · · · · · · · · Pan and zoom Query layer information Ability to add/remove multiple layers of data Point and click Measure distances Buffer Print – multiple sizes of maps Select map features by line, rectangle or polygon Phase II development of the WRAP EDMS could include some of the following additional functionality. · · Export selected maps shape files Generate polygons/layers from coordinates stored in the WRAP EDMS (e.g. create polygons for fire burn areas) The WRAP EDMS GIS module should include the following layers of data for Phase I development. Static layers · County, state and country polygons · Tribal reservation polygons · Metropolitan statistical areas polygons · Nonattainment area polygons · Class I areas polygons 27 EA Engineering, Science, and Technology · · · · · · · · FINAL TECHNICAL REPORT Interstate and highway line features Other roadways and railroad line features Bodies of water polygons Census data polygons Other federal land polygons (i.e. national parks, monuments, forest, and refuges) CAC polygons International area polygons WRAP modeling domain grid system Dynamic/Data driven layers · Select and display emissions sources and associated emissions levels by geographical area. 4.11 DBA Module All major applications and systems include an administrative section or module that allows the application administrator(s) to perform general system maintenance as well as application specific system maintenance. These maintenance routines consist of tasks that are routinely performed by the application or system administrator(s) and can easily be automated through a graphical user interface. Often times there are tasks that administrators need to perform that cannot easily be automated, due to the complexity or changing nature of the task, and would not be included in the administrative module of the application. The WRAP EDMS will require a DBA Module, which will provide the necessary functionality required to perform several administrative tasks. During Phase I of development, the WRAP EDMS should include the following DBA Functionality. · · · · · · · User account maintenance – maintain the list and permissions for users of the WRAP EDMS. Lookup table maintenance (unit conversions, threshold values, etc.) – maintain the multiple lookup tables and associated data that will be included in the WRAP EDMS. Versioning/maintenance of submitted data – ability to version submitted data and determine current version of all data. Data gap filling triggered from a QA/QC check, following specific methods that will be developed by WRAP. International data maintenance – maintain the tables and data for all international data necessary for the WRAP EDMS. Opt-in options for individual states, tribes, and sources – maintain list of states and tribes with associated emissions sources that decide to opt-in for Sections 308 and 309 tracking, after 2003. Others – other DBA module functionality requirements as determined necessary. During Phase II development, the WRAP EDMS should include the following DBA Functionality. 28 EA Engineering, Science, and Technology · · 4.12 FINAL TECHNICAL REPORT Data warehousing/archiving – ability to move historical data out of the production database and into a WRAP data warehouse. Historical data retrieval – ability to generate reports and data sets from the WRAP data warehouse. QA/QC Module The WRAP EDMS will include a QA/QC module to perform two levels of QA/QC. The QA/QC protocol will be similar to that of NEI with some modifications (see Appendix F for the NEI QA/QC process). The first level of QA/QC should include a validation of the format of the submitted data files at the submission point of entry. This would ensure that the submitting entity supplied all data to the WRAP EDMS in the expected format and also identify any errors. The second level of QA/QC should consist of checks of the data that was submitted to WRAP. This should include checking reference values and acceptable data ranges for specific data points. The WRAP EDMS QA/QC module should perform the following types of format checks. · · · Does the file conform to the format specification? - The initial checks performed on each submitted data set will verify that the file format is correct, and therefore readable for further processing (e.g., field widths, begin/end position, data types). Are mandatory data elements reported? - The presence or absence of mandatory data elements will be confirmed. Some of the mandatory data fields are the primary keys (i.e. FIPS codes and SCC Codes) in each record that help relate and maintain the individual records together in a file for subsequent processing. Does the data set contain what the STL agency said they are submitting? - The data in the file will be compared to the Inventory Submittal Form (ISF) that was provided with the file to verify the noted and intended coverage for geographic area, pollutants, source categories, and temporal information. WRAP will keep a log of errors and problems encountered with each of the data submissions, and will provide those to the STL agency when communicating with the agency. The WRAP EDMS QA/QC for data content will consist of two areas of QA/QC. First, the data will be checked for completeness, ensuring that all data exists for all sources and geographic areas. Second, the data integrity will be checked, ensuring that supplied values are within acceptable ranges and all codes are valid. The QA/QC module should perform the following types of data content checks for completeness. · · Add records to fill in missing facilities or source categories, or to fill in for missing geographic areas (e.g., where data were not reported for entire counties). Add, or solve for, data elements missing in existing records. Additionally, the QA/QC module will perform the following data augmentation processes: · Calculate EC and OC emissions. 29 EA Engineering, Science, and Technology · · FINAL TECHNICAL REPORT Aggregate dust and biogenic source data from the supplied grid and hourly levels to county/reservation and annual levels. Modify county data to exclude sources and emissions from tribal reservations that are within the county’s boundaries. The QA/QC module should perform the following types of data integrity checks. · · · · · · · Conditional fields - fields required by other fields in the same table. For example, if there is a PCT Capture Efficiency in the Control Equipment (CE) table, then there should also be a Primary Device Type in the CE Table. Acceptable codes - the Pollutant Code (and all acceptable codes) should be consistent. Numeric values in acceptable range - For example, the annual average days per week in the Emission Point (EP) table should be less than seven. Inter-File Format - fields required by other fields in different tables. If there is an Emission Record in the Emission (EM) table, then there should be an associated activity record in the Activity Code (AC) table. Inter-source relationships Inter-pollutant relationships Advance point source diagnostic – check of largest sources, out of range stacks, stack location. 30 EA Engineering, Science, and Technology 5.0 FINAL TECHNICAL REPORT CONCLUSIONS Under contract with the WRAP EF, EA performed an EDMS needs assessment that included two interview workshops, a web-based questionnaire, and an evaluation of selected existing systems. Five existing database management systems were evaluated and compared to the conceptual WRAP EDMS developed from the findings of the workshops and web-based questionnaire. The workshops and questionnaire results indicated that the WRAP EDMS should be used as the repository of WRAP regional emissions data, and as a tool that can help in the implementation of the emissions tracking and reporting requirements of the RHR. The WRAP EDMS will be able to track all the visibility-impairing pollutants. The emissions data will primarily be submitted by STL agencies in an EPA-compliant format according to an open submittal process. Furthermore, the WRAP EDMS will contain six major sources representing the emissions sources: point, area, mobile, fire, biogenic, and windblown dust sources in addition to a QA/QC module, a GIS module, and a DBA module. Finally, the WRAP EDMS will produce user-specified standard and RHR-special reports and will allow data queries and graphical display, and presentation of this information in GIS format. The results of the comparative analysis showed that the conceptual WRAP EDMS has a unique set of requirements that are not fully implemented in any existing EDMS. Therefore, a new individual EDMS needs to be developed to meet the requirements for the conceptual WRAP EDMS. Also, this new system could utilize some of the features incorporated in several of the existing systems to accomplish some of the WRAP EDMS requirements. 31 EA Engineering, Science, and Technology 6.0 FINAL TECHNICAL REPORT REFERENCES California Air Resources Board (CARB), EMFAC 2002 Vehicle Emission Model, 2002. Code of Federal Regulation (CFR), Chapter 40, Part 51. Code of Federal Regulation (CFR), Chapter 40, Part 49. Federal Aviation Administration (FAA), Emission and Dispersion Modeling System (EDMS) Version 4.1, 2002. Federal Register (FR), Volume 64, PP 35756. Federal Register (FR), Volume 67, PP 30439. Federal Register (FR), Volume 67, PP 7263-64. Federal Register (FR), Volume 67, PP 39602-16. Grand Canyon Visibility Transport Commission (GCVTC), Recommendations for Improving Western Vistas, Report to the EPA, June 10, 1996. MCNC, Sparse Matrix Operator Kernel Emissions (SMOKE) Modeling System, 1999 Pechan, Draft RPO Data Exchange Protocol, 2003. US Environmental Protection Agency (EPA), User’s Guide to Mobile6.1 and Mobile6.2: Mobile source Emission Factor Model, 2002. US Environmental Protection Agency (EPA), Draft User’s Guide to PART5: A Program for Calculating Particle Emissions from Motor Vehicles, 1995. US Environmental Protection Agency (EPA), Draft NONROAD Model for 2007 HD Highway Rulemaking, June 2000. US Environmental Protection Agency (EPA), Biogenic Emission Inventory System Version 2.3, 1998. US Environmental Protection Agency (EPA), Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources, 1998. Western Regional Air Partnership (WRAP), WRAP Policy Fire Tracking System, 2002. 32 APPENDIX A-7. STATIONARY SOURCES This appendix contains work products and references relied upon by Arizona in the development of Chapter 7 of the Regional Haze SIP. Appendix A-7 – Stationary Sources Arizona Regional Haze SIP Appendix A-7a. Arizona Draft Western Backstop SO2 Trading Program Rule Appendix A-7 – Stationary Sources Arizona Regional Haze SIP DRAFT RULE NOTE: This draft rule has been included in Arizona’s Regional Haze State Implementation Plan in order to give the reader an opportunity to see how Arizona has currently interpreted the Model Rule for state-specific rulemaking. This draft rule will go through revisions prior to its submission to Arizona’s Secretary of State, after the public comment period, and is subject to the final review of the Governors’ Regulatory Review Council. TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL ARTICLE 16. VISIBILITY; REGIONAL HAZE Section R18-2-1610 Western Backstop SO2 Trading Program; Definitions ……… R18-2-1611 Pre-trigger Applicability; Monitoring, Recordkeeping and Reporting …………..…………..………………………. New Section New Section R18-2-1612 WEB Trading Program Trigger ………………………. ……… New Section R18-2-1613 WEB Trading Program Applicability ………………………… New Section R18-2-1614 Account Representative for WEB Sources …………………… New Section R18-2-1615 Registration …………………………………………………… New Section R18-2-1616 Allowance Allocations ……………………….……………… New Section R18-2-1617 Establishment of Accounts ……………………..…………… New Section R18-2-1618 Monitoring, Recordkeeping and Reporting ………………… New Section R18-2-1619 Allowance Transfers ………………………………………… New Section R18-2-1620 Use of Allowances from a Previous Year …………………… New Section R18-2-1621 Compliance …………………………………………………… New Section R18-2-1622 Special Penalty Provisions for the 2018 Milestone …………… New Section ARTICLE 16. VISIBILITY; REGIONAL HAZE R18-2-1607. Reserved R18-2-1608. Reserved R18-2-1609. Reserved R18-2-1610. Western Backstop SO2 Trading Program; Definitions A. This rule implements the Western Backstop SO2 Trading Program (“WEB Trading Program”) provisions required under the federal Regional Haze Rule, 40 CFR 51.309, and the SO2 Milestones and Backstop Trading Program. 1. All applicable sources as described in Sections 1611 and 1613 of this Rule shall meet the pre-trigger monitoring, recordkeeping and reporting requirements as outlined in Section 1611 of this Rule. 2. Nothing in this Rule waives any requirement otherwise in effect or subsequently required under another program, including rules governing new sources. B. The definitions in this part apply only to this Rule. 1. “Account Certificate of Representation” means the completed and signed submission required to designate an Account Representative for a WEB source or an Account Representative for a general account. 2. “Account Representative” means the individual who is authorized through an Account Certificate of Representation to represent owners and operators of the WEB source with regard to matters under the WEB Trading Program or, for a general account, who is authorized through an Account Certificate of Representation to represent the persons having an ownership interest in allowances in the general account with regard to matters concerning the general account. 3. “Act” means the federal Clean Air Act, as amended, 42 U.S.C. 7401, et seq. 4. “Actual Emissions” means total annual sulfur dioxide emissions determined in accordance with Section 1618 of this Rule, or determined in accordance with [refer to state or tribal inventory rule] for sources that are not subject to Section 1618 of this Rule. 5. “Allocate” means to assign allowances to a WEB source. 6. “Allowance” means the limited authorization under the WEB Trading Program to emit one ton of SO2 during a specified control period or any control period thereafter subject to the terms and conditions for use of unused allowances as established by this Rule. 7. “Allowance limitation” means the tonnage of SO2 emissions authorized by the allowances available for compliance deduction for a WEB source for a control period under Section 1621(A) of this Rule on the allowance transfer deadline for that control period. 8. “Allowance Tracking System” means the system developed by the Director where allowances under the WEB Trading Program are recorded, held, transferred and deducted. 9. “Allowance Tracking System” account means an account in the Allowance Tracking System established for purposes of recording, holding, transferring, and deducting allowances. 10. “Allowance transfer deadline” means the deadline established in Section 1619(B) of this Rule when allowances must be submitted for recording in a WEB source’s compliance account in order to demonstrate compliance for that control period. 11. “Compliance account” means an account established in the Allowance Tracking System under Section 1617(A) of this Rule for the purpose of recording allowances that a WEB source might hold to demonstrate compliance with its allowance limitation. 12. “Compliance certification” means a submission to the Director by the Account Representative as required under Section 1621(B) of this Rule to report a WEB source’s compliance or noncompliance with this Rule. 13. “Control period” means the period beginning January 1 of each year and ending on December 31 of the same year, inclusive. 14. “Emissions tracking database” means the central database where SO2 emissions for WEB sources as recorded and reported in accordance with this Rule are tracked to determine compliance with allowance limitations. 15. “Emission unit” means any part of a stationary source that emits or would have the potential to emit any pollutant submitted to regulations under the Clean Air Act. 16. “Existing source” means a stationary source that commenced operation before the Program Trigger Date. 17. “Fugitive emissions” means those emissions that could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening. 18. “General account” means an account established in the Allowance Tracking System under Section 1617 of this Rule for the purpose of recording allowances held by a person that are not to be used to show compliance with an allowance limitation. 19. “Milestone” means the maximum level of stationary source regional sulfur dioxide emissions for each year from 2003 to 2018. 20. “New WEB Source” means a WEB source that commenced operation on or after the Program Trigger Date. 21. “New Source Set-aside” means a pool of allowances that are available for allocation to new sources. 22. “Owner or operator” means any person who is an owner or who operates, controls or supervises a WEB source, and includes but is not be limited to any holding company, utility system or plant manager. 23. “Potential to emit” means the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its design if the limitation is enforceable by the EPA Administrator. 24. “Program trigger date” means the date that the Director determines that the WEB Trading Program has been triggered. 25. “Program trigger years” means the years for the applicable milestone if the WEB Trading Program is triggered. 26. “Renewable Energy Resource” means a resource that generates electricity by nonnuclear and non-fossil technologies that results in low or no air emissions. The term includes electricity generated by wind energy technologies; solar photovoltaic and solar thermal technologies; geothermal technologies; technologies based on landfill gas and biomass sources, and new low-impact hydropower that meets the Low-Impact Hydropower Institute criteria. Biomass includes agricultural, food and wood wastes. The term does not include pumped storage or biomass from municipal solid waste, black liquor, or treated wood. 27. “Retired source” means a WEB source that has received a retired source exemption as provided in Section 1613(C) of this Rule. Any retired source resuming operations under Section 1613(C)(4) of this Rule, must submit its exemption as part of its registration materials. 28. “Serial number” means, when referring to allowances, the unique identification number assigned to each allowance by the Tracking Systems Administrator, in accordance with Section 1616(B) of this Rule. 29. “SO2 emitting unit” means any equipment that is located at a WEB source and that emits SO2. 30. “Stationary source” means any building, structure, facility or installation that emits or may emit any air pollutant subject to regulation under the Clean Air Act. 31. “Submit” means sent to the appropriate authority under the signature of the Account Representative. For purposes of determining when something is submitted, an official U.S. Postal Service postmark, or equivalent electronic time stamp, shall establish the date of submittal. 32. “Ton” means 2000 pounds and, for any control period, any fraction of a ton equaling 1000 pounds or more shall be treated as one ton and any fraction of a ton equaling less than 1000 pounds shall be treated as zero tons. 33. “Tracking System Administrator” means the person designated by the Director as the administrator of the Allowance Tracking System and the emissions tracking database. 34. “WEB source” means a stationary source that meets the applicability requirements of Section 1613 of this Rule. 35. “Western Backstop SO2 Trading Program (“WEB Trading Program”)” means in reference to this Rule, the program triggered as a backstop, if necessary, to ensure that regional SO2 emissions are reduced. R18-2-1611. Pre-trigger Applicability; Monitoring, Recordkeeping and Reporting A. Applicable sources are described in Section 1613 of this Rule. B. All applicable sources shall follow the provisions for monitoring, recordkeeping and reporting as outlined in R18-2-304, R18-2-306, R18-2-327, or R18-2-715.01, and, in addition, shall: 1. Submit an annual inventory of SO2 emissions, beginning with the 2003 emission inventory. a. A source that emits 100 tons per year or more of SO2 in a later year shall continue to submit an SO2 inventory for tracking compliance with the regional SO2 milestones until 2018 or until the WEB Trading Program has been fully implemented and emissions tracking is occurring, whichever is earlier. b. Smelters shall submit an annual report of sulfur input in tons per year with the submission of the annual emissions inventory. 2. Utilize appropriate emission factors and estimating techniques, and document the emissions monitoring or estimation methodology used. 3. Include emissions from start up, shut down, and upset conditions in the annual total inventory. 4. Utilize, if subject to the federal acid rain program, methods from 40 CFR Part 75 to report emissions from all sources. 5. Include the rate and period of emissions, the specific installation that is the sources of the air pollution, composition of air contaminant, type and efficiency of the air pollution control equipment, and other information necessary to quantify operation and emissions, and to evaluate pollution control. 6. Retain records for a minimum of 10 years from the date of creation, or if the record was the basis for an adjustment to a milestone, 5 years from the date of a state implementation plan revision, whichever is longer. R18-2-1612. A. WEB Trading Program Trigger Except as provided in 1612(B), Sections 1613 through 1621 of this Rule shall become effective on the program trigger date that is established in accordance with the procedures outlined in the 40 CFR 51.309(4)(h). B. Section 1622 of this Rule, Special Penalty Provisions for Year 2018, shall become effective on January 1, 2018 and shall remain effective until the provisions of Section 1622 of this Rule have been fully implemented. R18-2-1613. A. WEB Trading Program Applicability General Applicability. This Rule applies to any stationary source or group of stationary sources that are located on one or more contiguous or adjacent properties and which are under the control of the same person or persons under common control, belonging to the same industrial grouping, and that are described in paragraphs (1) through (4) of this subsection. A stationary source or group of stationary sources shall be considered part of a single industrial grouping if all of the pollutant emitting activities at such source or group of sources on contiguous or adjacent properties belong to the same Major Group (i.e., all have the same two-digit code) as described in the Standard Industrial Classification Manual, 1987. B. The following are WEB sources: 1. All BART-eligible sources as defined in 40 CFR 51.301 that are BART-eligible due to SO2 emissions. 2. All stationary sources not meeting the criteria of 1613(A) of this Rule that have actual SO2 emissions of 100 tons or more per year in the Program Trigger Years or any subsequent year. The fugitive emissions of a stationary source shall not be considered in determining whether it is a WEB source unless the source belongs to one of the following categories of stationary source: a. Coal cleaning plants (with thermal dryers); b. Kraft pulp mills; c. Portland cement plants; d. Primary zinc smelters; e. Iron and steel mills; f. Primary aluminum ore reduction plants; g. Primary copper smelters; h. Municipal incinerators capable of charging more than 250 tons of refuse per day; i. Hydrofluoric, sulfuric, or nitric acid plants; j. Petroleum refineries; k. Lime plants; l. Phosphate rock processing plants; m. Coke oven batteries; n. Sulfur recovery plants; o. Carbon black plants (furnace process); p. Primary lead smelters; q. Fuel conversion plants; r. Sintering plants; s. Secondary metal production plants; t. Chemical process plants; u. Fossil-fuel boilers (or combination thereof) totaling more than 250 million British thermal units per hour heat input; v. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels; x. Taconite ore processing plants; y. Glass fiber processing plants; z. Charcoal production plants; aa. Fossil-fuel-fired steam electric plants of more than 250 million British thermal units per hour heat input; or bb. Any other stationary source category, which as of August 7, 1980 is being regulated under Section 111 or 112 of the Act. 3. A new source that begins operation after the Program Trigger Date and has the potential to emit 100 tons or more of SO2 per year. 4. The Director may determine on a case-by-case basis, with concurrence from the EPA Administrator, that a source defined in Section 1613(B)(2) of this Rule is not a WEB source if the source: a. In each of the previous five years had actual SO2 emissions of less than 100 tons per year; and b. Had actual SO2 emissions of 100 tons or more in a single year due to a temporary emission increase that was caused by a sudden, infrequent and not reasonably preventable failure of air pollution control equipment, failure of process equipment, or a failure to operate in a normal or usual manner; c. Took timely and reasonable action to minimize the temporary emission increase; and d. Has corrected the failure of air pollution control equipment, process equipment, or process by the time of the Director’s determination under this section; or e. Had to switch fuels or feedstocks on a temporary basis and as a result of an emergency situation or unique and unusual circumstances besides cost of such fuels or feedstocks. f. A temporary emission increase due to poor maintenance or careless operation does not meet the criteria of this section. C. Duration of Program Participation. Except as provided for in Section 1613(D) of this Rule, once a source is subject to the WEB Trading Program, it will remain in the program every year thereafter. D. Application for Retired Source Exemption. Any WEB that is retired shall apply for a retired source exemption. The WEB source may only be considered retired if all SO2 emitting units at the source are retired. The application shall contain the following information: 1. Identification of the WEB source, including plant name and an appropriate identification code in a format specified by the Director. 2. Name of Account Representative. 3. Description of the status of the WEB source, including the date that the WEB source was retired. 4. Signed certification that the WEB source is retired and will comply with the requirements of Sections 1613(D) through (H) of this Rule. 5. Verification that the WEB source has a general account where any unused allowances or future allocations will be recorded. E. Notice of Retired Source Exemption. The retired source exemption becomes effective When the Director, or control officer with jurisdiction over the source, notifies the source that the retired source exemption has been granted. F. Responsibilities of Retired Sources: 1. A retired source shall be exempt from Sections 1618 and 1621 of this Rule, except as provided below. 2. A retired source shall not emit any SO2 after the date the retired source exemption is effective. 3. A source shall submit SO2 emissions reports, as required by Section 1618(H) of this Rule for any time period the source was operating prior to the effective date of the retired source exemption. The retired source shall be subject to the compliance provisions of Section 1621 of this Rule, including the requirement to hold allowances in the source’s compliance account to cover all SO2 emissions prior to the date the source was permanently retired. 4. A retired source that is still in existence but no longer emitting SO2 shall, for a period of five years from the date the records are created, retain records demonstrating the effective date of the retired source exemption for purposes of this Rule. G. Resumption of Operations. Should a retired source desire to resume operation, the retired source must submit registration materials as follows: 1. If the source is required to obtain a new source review permit or operating permit under [refer to applicable new source permitting rule] prior to resuming operation, then registration information as described in Section 1615(A) of this Rule and a copy of the retired source exemption must be submitted with the application required under [refer to applicable new source permitting rule]; 2. If the source is not required to obtain a new source review permit or operating permit under [refer to applicable new source permitting rule] prior to resuming operation, then registration information as described in Section 1615(A) of this Rule and a copy of the retired source exemption must be submitted to the Director at least ninety days prior to resumption of operation. 3. The retired source exemption shall automatically expire on the day the source resumes operation. H. Loss of Future Allowances. 1. A WEB source that is retired and that does not apply to the Director for a retired source exemption within ninety days of the date that the source is retired shall forfeit any unused and future allowances. The abandoned allowances shall be retired by the Tracking System Administrator. Note to Reviewer: This is not intended to be a punitive action, but a method to correct the number of allowances being tracked by the state. The Director will need to establish due process procedures for forfeiting these “abandoned” allowances in a manner that is consistent with the administrative procedures process. This provision is intended to address sources that go out of business, leave no forwarding address, and truly abandon their allowances. It is assumed that the Director will have a process to notify sources that their allowances may be forfeited so this provision does not lead to forfeiture just because the deadline was missed Arizona will draft the appropriate notification language for this section. R18-2-1614. A. Account Representative for WEB Sources Each WEB source must identify one Account Representative and may also identify an alternate Account Representative who may act on behalf of the Account Representative. Any representation, action, inaction or submission by the alternate Account Representative will be deemed to be a representation, action, inaction or submission by the Account Representative. B. Identification and Certification of an Account Representative. 1. The Account Representative and any Alternate Account Representative shall be appointed by an agreement that makes the representations, actions, inactions or submissions of the Account Representative and any alternate binding on the owners and operators of the WEB source. 2. The Account Representative shall submit to the Director and the Tracking System Administrator a signed and dated Account Certificate of Representation (Certificate) that contains the following elements: a. Identification of the WEB source by plant name, state and an appropriate identification code in a format specified by the Director; b. The name, address, e-mail (if available), telephone and facsimile number of the Account Representative and any alternate; c. A list of owners and operators of the WEB source; d. Information to be part of the emission tracking system database in accordance with the Implementation Plan. The specific data elements shall be as specified by the Director to be consistent with the data system structure, and may include basic facility information that may appear in other reports and notices submitted by the WEB source, such as county location, industrial classification codes, and similar general facility information. e. The following certification statement: “I certify that I was selected as the Account Representative or alternate Account Representative, as applicable, by an agreement binding on the owners and operators of the WEB source. I certify that I have all the necessary authority to carry out my duties and responsibilities under the WEB Trading Program on behalf of the owners and operators of the WEB source and that each such owner and operator shall be fully bound by my representations, actions, inactions, or submissions and by any decision or order issued to me by the Director regarding the WEB Trading Program.” 3. Upon receipt by the Director of the complete Certificate, the Account Representative and any alternate Account Representative represents and, by his or her representations, actions, inactions, or submissions, legally binds each owner and operator of the WEB source in all matters pertaining to the WEB Trading Program. The owners and operators shall be bound by any decision or order issued by the Director regarding the WEB Trading Program. 4. No WEB Allowance Tracking System account shall be established for the WEB source until the Tracking System Administrator has received a complete Certificate. Once the account is established, the Account Representative shall make all submissions concerning the account, including the deduction or transfer of allowances. C. Requirements and Responsibilities of the Account Representative. 1. The responsibilities of the Account Representative include, but are not limited to, the transferring of allowances, and the submission of monitoring plans, registrations, certification applications, SO2 emissions data and compliance reports as required by this Rule, and representing the source in all matters pertaining to the WEB Trading Program. 2. Each submission under this program shall be signed and certified by the Account Representative for the WEB source. Each submission shall include the following truth and accuracy certification statement by the Account Representative: “I am authorized to make this submission on behalf of the owners and operators of the WEB source for which the submission is made. I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I amaware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment.” D. Changes to the Account Representative; Owners and Operators. 1. Changes to the Account Representative or the alternate Account Representative. a. The Account Representative or alternate Account Representative may be changed at any time by sending a complete superseding Certificate to the Director and the Tracking System Administrator under Section 1614(B) of this Rule, with the change taking effect upon receipt of such Certificate by the Director. b. Notwithstanding any such change, all representations, actions, inactions, and submissions by the previous Account Representative or alternate prior to the time and date when the Tracking System Administrator receives the superseding Certificate shall be binding on the new Account Representative and the owners and operators of the WEB source. 2. Changes in Owners and Operators. a. Within thirty days of any change in the owners and operators of the WEB source, including the addition of a new owner or operator, the Account Representative shall submit a revised Certificate amending the list of owners and operators to include such change. b. In the event a new owner or operator of a WEB source is not included in the list of owners and operators submitted in the Certificate, such new owner or operator shall be deemed to be subject to and bound by the Certificate, the representations, actions, inactions, and submissions of the Account Representative of the WEB source, and the decisions, orders, actions, and inactions of the Director as if the new owner or operator were included in such list. R18-2-1615. A. Registration Deadlines. 1. Each source that is a WEB source on or before the Program Trigger Date shall register by submitting the initial Certificate required in Section 1614(B) of this Rule to the Director no later than 180 days after the Program Trigger Date. 2. Any existing source that becomes a WEB source after the Program Trigger Date shall register by submitting the initial Certificate required in Section 1614(B) of this Rule to the Director by September 30 of the year following the inventory year in which the source exceeded the emission threshold. 3. Any new WEB source shall register by submitting the initial Certificate required in Section 1614(B) of this Rule to the Director prior to the commencement of operation. B. Integration into Permits 1. Any allocation, transfer or deduction of allowance to or from the compliance account of a WEB source shall not require revision of the WEB source’s operating permit. 2. Any WEB source that is not required to have a permit under [state’s New Source Review Rule] at any time after this Rule becomes effective must at all times possess a permit that includes the requirements of this Rule. If it does not possess a Title V permit under [state’s Title V rule], it may do so by obtaining or modifying a permit under [state or tribe’s New Source Review Rule] to incorporate the requirements of this Rule. The source must at all times possess a permit that includes these requirements. R18-2-1616. A. Allowance Allocations The Tracking System Administrator will record the allowances for each WEB source in the compliance account for a WEB source once the allowances are allocated by the Director. If applicable, the Tracking System Administrator will record a portion of the SO2 allowances for a WEB source in a special reserve account assigned to the Director to account for any allowances to be held by the Director in accordance with Section 1618(A)(2) of this Rule. B. The Tracking System Administrator will assign a serial number to each allowance. C. All allowances shall be allocated, recorded, transferred, or used as whole allowances. To determine the number of whole allowances, the number of allowances shall be rounded down for decimals less than 0.50 and rounded up for decimals of 0.50 or greater. D. An allowance is not a property right, and is a limited authorization to emit one ton of SO2 valid only for the purpose of meeting the requirements of this Rule. No provision of this WEB Trading Program or other law should be construed to limit the authority of the Director to terminate or limit such authorization. E. Early Reduction Bonus Allocation. 1. Any WEB source that reduces permitted annual SO2 emissions to a level that is below the floor level allocation established for that source between 2003 and the program trigger year may apply to the Director for an early reduction bonus allocation. 2. The application must be submitted no later than ninety days after the Program Trigger Date. Any WEB source that applies and receives early reduction bonus allocations must retain the records referenced below for a minimum of five years after the early reduction bonus allowance is certified. 3. The application for an early reduction bonus allocation must contain the following information: a. Copies of all permits or other enforceable documents that include annual SO2 emissions limits for the WEB source during the period the WEB source was generating the early reductions. Such permits or enforceable documents require monitoring for SO2 emissions that meets the requirements in Sections 1618(A)(1) and 1618(A)(3) of this Rule. Note to reviewer: The early reduction bonus allocation needs to address sources that are not using Part 75 equipment monitoring. This is under discussion. b. Copies of emissions monitoring reports, for the period the WEB source was generating the early reductions, that documents the actual annual SO2 emissions and demonstrates that the actual annual SO2 emissions were below the floor level allocation established for that source. c. Demonstration that the floor level established for the source was calculated using data consistent with the new monitoring methodology. If new monitoring techniques change the floor level for the source, then a demonstration of the new floor level based on new monitoring techniques should be included in the application. F. Request for allowances for new WEB sources or modified WEB Sources. 1. A new WEB source or an existing WEB source that has increased production capacity through a permitted change in operations [refer to state’s NSR Rules] may apply to the Director for an allocation from the new source set-aside. a. A new WEB source is eligible to apply for an annual allocation equal to the permitted annual SO2 emission limit for that source after the source has commenced operation. b. An existing WEB source is eligible to apply for an annual allocation equal to the permitted annual SO2 emission limit for that source that is attributable to any amount of production capacity that is greater than the permitted production capacity for that source as of January 1, 2003. c. A source that has received a retired source exemption under Section 1613)D of this Rule is not eligible to apply for an allocation from the new source set-aside. 2. The application for an allocation from the new source set-aside must contain the following information: a. Demonstration that shows the permitted production capacity of the source before and after the new permit; b. For new WEB sources, documentation of the actual date of the commencement of operation and a copy of the permit. R18-2-1617. A. Establishment of Accounts Allowance Tracking System Accounts. 1. All WEB sources are required to open a compliance account. Any person may open a general account for holding and transferring allowances. To open either type of account, an application that contains the following information shall be submitted: a. The name, mailing address, e-mail address, telephone number, facsimile number of the Account Representative. For a compliance account, include a copy of the Account Certificate of Representation of the Account Representative and any alternate as required in Section 1614(B)(2) of this Rule. For a general account, include the Account Certificate of Representation of the Account Representative and any alternate as required in Section 1617(C)(2) of this Rule. b. The WEB source or organization name; c. The type of account to be opened; and d. A signed certification of truth and accuracy by the Account Representative according to Section 1614(C) of this Rule for compliance accounts and for general accounts, certification of truth and accuracy by the Account Representative according to Section 1617(D) of this Rule. B. Account Representative for General Accounts. 1. For a general account, one Account Representative must be identified and an alternate Account Representative may be identified and may act on behalf of the Account Representative. Any representation, action, inaction or submission by the alternate Account Representative will be deemed to be a representation, action, inaction or submission by the Account Representative. C. Identification and Certification of an Account Representative for General Accounts. 1. The Account Representative shall be appointed by an agreement that makes the representations, actions, inactions or submissions of the Account Representative binding on all persons who have an ownership interest with respect to allowances held in the general account. 2. The Account Representative shall submit to the Director and the Tracking System Administrator a signed and dated Account Certificate of Representation (Certificate) that contains the following elements: a. The name, address, e-mail (if available), telephone and facsimile number of the Account Representative and any alternate; b. The organization name; c. The following certification statement: “I certify that I was selected as the Account Representative or alternate Account Representative, as applicable, by an agreement binding on all persons who have an ownership interest in allowances in the general account with regard to matters concerning the general account. I certify that I have all the necessary authority to carry out my duties and responsibilities under the WEB Trading Program on behalf of said persons and that each such person shall be fully bound by my representations, actions, inactions, or submissions and by any decision or order issued to me by the Director regarding the general account.” 3. Upon receipt by the Director of the complete Certificate, the Account Representative represents and, by his or her representations, actions, inactions, or submissions, legally binds each person who has an ownership interest in allowances held in the general account with regard in all matters concerning the general account. Such persons shall be bound by any decision or order issued by the Director. 4. No WEB Allowance Tracking System general account shall be established until the Tracking System Administrator has received a complete Certificate. Once the account is established, the Account Representative shall make all submissions concerning the account, including the deduction or transfer of allowances. D. Requirements and Responsibilities. 1. Each submission for the general account shall be signed and certified by the Account Representative for the general account. Each submission shall include the following truth and accuracy certification statement by the Account Representative: “I am authorized to make this submission on behalf of all person who have an ownership interest in allowances held in the general account. I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment.” E. Changing the Account Representative. 1. The Account Representative or alternate Account Representative may be changed at any time by sending a complete superseding Certificate to the Director and the Tracking System Administrator under Section 1617(C)(2) of this rule, with the change taking effect upon receipt of such Certificate by the Director. Notwithstanding any such change, all representations, actions, inactions, and submissions by the previous Account Representative or alternate prior to the time and date when the Director receives the superseding Certificate shall be binding on the new Account Representative and all person having ownership interest with respect to allowances held in the general account. F. Changes to the Account. 1. Any change to the information required in the application for an existing account under Section 1617(A) of this Rule shall require a revision of the application. R18-2-1618. Monitoring, Recordkeeping and Reporting Note to Reviewer: Theses provisions will be reviewed and compared to the revised provisions prepared by the Western Regional Air Partnership (WRAP) and EPA on August 13, 2003. Revisions to this section of the rule may be necessary. References within this section are to the Model Rule versus this Rule. The Model Rule is available on WRAP’s Web page at www.wrapair.org. A. General Requirements. 1. For each SO2 emitting unit at a WEB source the owner or operator shall comply with the following, as applicable, to monitor and record SO2 mass emissions: a. If a unit is subject to 40 CFR Part 75 under a requirement separate from the WEB Trading Program, the unit shall meet the requirements contained in Part 75 with respect to monitoring, recording and reporting SO2 mass emissions. [As necessary, insert state rule language to address changes to 40 CFR Part 75.] b. If a unit is not subject to 40 CFR Part 75 under a requirement separate from the WEB Trading Program, a unit shall use one of the following monitoring methods, as applicable: i. A continuous emission monitoring system (CEMS) for SO2 and flow that complies with all applicable monitoring provisions in 40 CFR Part 75; ii. If the unit is a gas- or oil-fired combustion device, the excepted monitoring methodology in Appendix D to 40 CFR Part 75, or, if applicable, the low mass emissions (LME) provisions (with respect to SO2 mass emissions only) of section 75.19 of 40 CFR Part 75; iii. One of the optional WEB protocols, if applicable, in Appendix A to this Rule (attached); or iv. A petition for site-specific monitoring that the source submits for approval by the Director, and approval by the U.S. Environmental Protection Agency in accordance with Section I8(e) of this Rule (relating to petitions). c. A permanently retired unit shall not be required to monitor under this Section if such unit was permanently retired and had no emissions for the entire period for which the WEB source implements this paragraph (3) and the Account Representative certifies in accordance with Section L2 of this Rule that these conditions were met. 2. Notwithstanding paragraph (a) of this Section, the owner or operator of a unit that meets one of the conditions of paragraph (b)(1) may elect to have the provisions of this paragraph (b) apply to that unit. a. Any of the following units may implement this paragraph (b): i. Any smelting operation where all of the emissions from the operation are not ducted to a stack; or ii. Any flare, except to the extent such flares are used as a fuel gas combustion device at a petroleum refinery. iii. Any other type of unit without add-on SO2 control equipment, if no control level was assumed for the WEB source in establishing the floor level (and reducible allocation). b. For each unit covered by this paragraph (b), the Account Representative shall submit a notice to request that this paragraph (b) apply to one or more SO2 emitting units at a WEB source. The notice shall be submitted in accordance with the compliance dates specified in Section I6(a) of this Rule, and shall include the following information (in a format specified by the Director with such additional, related information as may be requested): i. A notice of all units at the applicable source, specifying which of the units are to be covered by this paragraph (b); ii. Consistent with the emission estimation methodology used to determine the floor level (and reducible allocation) for the source in accordance with Section C1 of the Implementation Plan, the portion of the WEB source’s overall allowance allocation that is attributable to any unit(s) covered by this paragraph; and iii. c. An identification of any such units that are permanently retired. For each new unit at an existing WEB source for which the owner or operator seeks to comply with this paragraph (b) and for which the Account Representative applies for an allocation under the new source set-aside provisions of Section G6 of this Rule, the Account Representative shall submit a modified notice under paragraph (b)(2) that includes such new SO2 emitting unit(s). The modified notice shall be submitted in accordance with the compliance dates in Section I6(a) of this Rule, but no later than the date on which a request is submitted under Section G6 of this Rule for allocations from the set-aside. d. The Director shall evaluate the information submitted by the WEB source in paragraphs (b)(2) and (b)(3), and may issue a notice to the source to exclude any units that do not qualify under this paragraph (b) or to adjust the portion of allowances attributable to units that do qualify to be consistent with the emission estimation methodology used to establish the floor level (and reducible allocation) for the source. Any such notice shall be provided within 180 days after the date on which the notice from the WEB source was received. e. The Director shall hold allowances equal to the adjusted portion of the WEB source’s allowances under paragraphs (b)(2), (b)(3), and (b)(4) in an account maintained by the Director, provided that no such hold back of the WEB source’s allocation will be required for any unit that is permanently retired. f. The Account Representative for a WEB source shall submit an annual emissions statement for each unit under this paragraph (b). The WEB source shall maintain operating records sufficient to estimate annual emissions in a manner consistent with the emission estimation methodology used to establish the floor level (and reducible allocation) for the source. The Director will retire the allowances held under paragraph (b)(5) to account for the emissions from such units. In addition, if the estimated emissions from all such units at the WEB source are greater than the allowances held under paragraph (b)(5) for the WEB source, the Account Representative will report the excess amount as part of the cumulative annual emissions report for the WEB source and be required to use other allowances in the compliance account for the WEB source to account for such emissions, in accordance with Section I8 of this Rule. g. The remaining provisions of this Section 1618 shall not apply to units covered by this paragraph except where otherwise noted. h. A WEB source may opt to modify the monitoring for an SO2 emitting unit to use monitoring under Section I1(a) of this Rule, but any such monitoring change must take effect on January 1 of the next compliance year. In addition, the Account Representative must submit an initial monitoring plan at least 180 days prior to the date on which the new monitoring will take effect and a detailed monitoring plan in accordance with Section I2 of this Rule. The Account Representative shall also submit a revised notice under paragraph (b)(2) at the same time that the initial monitoring plan is submitted. 3. For any monitoring method that the owner or operator uses under this Section (including paragraph (b)), the owner or operator (and, as applicable, the Account Representative) shall implement, certify, and use such method in accordance with this Section, and record and report the data from such method as required in this Section. In addition, the owner or operator (and, as applicable, the Account Representative) may not: a. Use an alternative monitoring system, alternative reference method or another alternative for the required monitoring method without having obtained prior written approval in accordance with Section I8(e) of this Rule (relating to petitions); b. Operate an SO2 emitting unit so as to discharge, or allow to be discharged, SO2 emissions to the atmosphere without accounting for these emissions in accordance with the applicable provisions of this Section; c. Disrupt the approved monitoring method or any portion thereof, and thereby avoid monitoring and recording SO2 mass emissions discharged into the atmosphere, except for periods of recertification or periods when calibration, quality assurance testing or maintenance is performed in accordance with the applicable provisions of this Section; or d. Retire or permanently discontinue use of an approved monitoring method, except under one of the following circumstances: i. During a period when the unit is exempt from the requirements of this Section, including retirement of a unit as addressed in Section I1(a)(3); ii. The owner or operator is monitoring emissions from the unit with another certified monitoring method approved under this Section for use at the unit that provides data for the same parameter as the retired or discontinued monitoring method; or iii. The Account Representative submits notification of the date of certification testing of a replacement monitoring system in accordance with this Section, and the owner or operator recertifies thereafter a replacement monitoring system in accordance with the applicable provisions of this Section. B. Monitoring Plan. 1. General Provisions. The owner or operator of an SO2 emitting unit that uses a monitoring method under Section I1(a)(2) of this Rule shall meet the following requirements: a. Prepare and submit to the Director an initial monitoring plan for each monitoring method that the owner or operator uses to comply with this Section. In accordance with paragraph I2(C) of this Rule, the plan shall contain sufficient information on the units involved, the applicable method, and the use of data derived from that method to demonstrate that all unit SO2 emissions are monitored and reported. The plan shall be submitted in accordance with the compliance dates specified in Section I5 of this Rule. b. Prepare, maintain and submit to the Director a detailed monitoring plan at least 45 days prior to the first day of certification testing. The plan will contain the applicable information required by paragraph I2(d) of this Rule. the Director may require that the monitoring plan (or portions thereof) be submitted electronically. The Director also may require that the plan be submitted on an ongoing basis in electronic format as part of the quarterly report submitted under Section I8(a) of this Rule or resubmitted separately within 30 days after any change is made to the plan in accordance with the following paragraph (a)(3). c. Whenever the owner or operator makes a replacement, modification, or change in one of the systems or methodologies provided for in Section I1(a)(2), including a change in the automated data acquisition and handling system or in the flue gas handling system, that affects information reported in the monitoring plan (e.g., a change to serial number for a component of a monitoring system), then the owner or operator shall update the monitoring plan. 2. The owner or operator of an SO2 emitting unit that uses a method under Section I1(a)(1) of this Rule (a unit subject to 40 CFR Part 75 under a program other than this WEB Trading Program) shall meet the requirements of Section I2(a)-(f) by preparing, maintaining and submitting a monitoring plan in accordance with the requirements of 40 CFR Part 75, provided that the owner or operator also shall submit the entire monitoring plan to the Director upon request. 3. Initial Monitoring Plan. The Account Representative shall submit an initial monitoring plan for each SO2 emitting unit (or group of units sharing a common methodology) that, except as otherwise specified in an applicable provision in Appendix A, contains the following information: a. For all SO2 emitting units involved in the monitoring plan: i. Plant name and location; ii. Plant and unit identification numbers assigned by the Director; iii. Type of unit (or units for a group of units using a common monitoring methodology); iv. Identification of all stacks or pipes associated with the monitoring plan; v. Types of fuel(s) fired (or sulfur containing process materials used in the SO2 emitting unit), and the fuel classification of the unit if combusting more than one type of fuel and using a 40 CFR Part 75 methodology; vi. Type(s) of emissions controls for SO2 installed or to be installed, including specifications of whether such controls are precombustion, post-combustion, or integral to the combustion process; vii. Maximum hourly heat input capacity, or process throughput capacity, if applicable; viii. Identification of all units using a common stack; and viv. Indicator of whether any stack identified in the plan is a bypass stack. b. For each unit and parameter required to be monitored, identification of monitoring methodology information, consisting of monitoring methodology, monitor locations, substitute data approach for the methodology, and general identification of quality assurance procedures. If the proposed methodology is a site-specific methodology submitted pursuant to Section I1(a)(2)(D) of this Rule, the description under this paragraph shall describe fully all aspects of the monitoring equipment, installation locations, operating characteristics, certification testing, ongoing quality assurance and maintenance procedures, and substitute data procedures. c. If the WEB source intends to petition for a change to any specific monitoring requirement otherwise required under this Section, such petition may be submitted as part of the initial monitoring plan. d. The Director may issue a notice of approval or disapproval of the initial monitoring plan based on the compliance of the proposed methodology with the requirements for monitoring in this Section. Except for any petition contained in the initial monitoring plan, if such notice is not issued within 180 days after the date on which the Director received the initial monitoring plan, the plan shall be deemed approved. 4. Detailed Monitoring Plan. The Account Representative shall submit a detailed monitoring plan that, except as otherwise specified in an applicable provision in Appendix A, shall contain the following information: a. Identification and description of each monitoring component (including each monitor and its identifiable components, such as analyzer and/or probe) in a CEMS (e.g., SO2 pollutant concentration monitor, flow monitor, moisture monitor), a 40 CFR Part 75, Appendix D monitoring system (e.g., fuel flowmeter, data acquisition and handling system), or a protocol in Appendix A, including: i. Manufacturer, model number and serial number; ii. Component/system identification code assigned by the facility to each identifiable monitoring component, such as the analyzer and/or probe; iii. Designation of the component type and method of sample acquisition or operation (e.g., in situ pollutant concentration monitor or thermal flow monitor); b. iv. Designation of the system as a primary or backup system; v. First and last dates the system reported data; vi. Status of the monitoring component; and vii. Parameter monitored. Identification and description of all major hardware and software components of the automated data acquisition and handling system, including: i. Hardware components that perform emission calculations or store data for quarterly reporting purposes (provide the manufacturer and model number); and ii. Software components (provide the identification of the provider and model/version number). c. Explicit formulas for each measured emissions parameter, using component/system identification codes for the monitoring system used to measure the parameter that links the system observations with the reported concentrations and mass emissions. The formulas must contain all constants and factors required to derive mass emissions from component/system code observations and an indication of whether the formula is being added, corrected, deleted, or is unchanged. The owner or operator of a low mass emissions unit for which the owner or operator is using the optional low mass emissions excepted methodology in section 75.19(c) of 40 CFR Part 75 is not required to report such formulas. d. Inside cross-sectional area (ft2) at flow monitoring location (for units with flow monitors, only). e. If using CEMS for SO2 and flow, for each parameter monitored: scale, maximum potential concentration (and method of calculation), maximum expected concentration (if applicable) (and method of calculation), maximum potential flow rate (and method of calculations), span value, full-scale range, daily calibration units of measure, span effective date/hour, span inactivation date/hour, indication of whether dual spans are required, default high range value, flow rate span, and flow rate span value and full scale value (in scfh) for each unit or stack using SO2 or flow component monitors. f. If the monitoring system or excepted methodology provides for use of a constant, assumed, or default value for a parameter under specific circumstances, then include the following information for each value of such parameter: i. Identification of the parameter; ii. Default, maximum, minimum, or constant value, and units of measure for the value; iii. Purpose of the value; iv. Indicator of use during controlled/uncontrolled hours; v. Types of fuel; vi. Source of the value; vii. Value effective date and hour; viii. Date and hour value is no longer effective (if applicable); and viv. For units using the excepted methodology under section 75.19 of 40 CFR Part 75, the applicable SO2 emission factor. g. Unless otherwise specified in section 6.5.2.1 of Appendix A to 40 CFR Part 75, for each unit or common stack on which hardware CEMS are installed: i. The upper and lower boundaries of the range of operation (as defined in section 6.5.2.1 of Appendix A to 40 CFR Part 75), or thousand of lb/hr of steam, or ft/sec (as applicable); ii. The load or operating level(s) designated as normal in section 6.5.2.1 of Appendix A to 40 CFR Part 75, or thousands of lb/hr of steam, or ft/sec (as applicable); iii. The two load or operating levels (i.e., low, mid, or high) identified in section 6.5.2.1 of Appendix A to 40 CFR Part 75 as the most frequently used; iv. The date of the data analysis used to determine the normal load (or operating) level(s) and the two most frequently-used load (or operating) levels; and v. Activation and deactivation dates when the normal load or operating level(s) change and are updated. h. For each unit that is complying with 40 CFR Part 75 for which the optional fuel flow-to-load test in section 2.1.7 of appendix D to 40 CFR Part 75 is used: i. The upper and lower boundaries of the range of operation (as defined in section 6.5.2.1 of Appendix A to 40 CFR Part 75), expressed in thousand of lb/hr of steam; ii. The load level designated as normal, pursuant to section 6.5.2.1 of Appendix A to 40 CFR Part 75, expressed in thousands of lb/hr of steam; and iii. The date of the load analysis used to determine the normal load level. i. Information related to quality assurance testing, including (as applicable): identification of the test strategy; protocol for the relative accuracy test audit; other relevant test information; calibration gas levels (percent of span) for the calibration error test and linearity check; calculations for determining maximum potential concentration, maximum expected concentration (if applicable), maximum potential flow rate, and span; j. If applicable, apportionment strategies under sections 75.10 through 75.18 of 40 CFR Part 75. k. Description of site locations for each monitoring component in a monitoring system, including schematic diagrams and engineering drawings and any other documentation that demonstrates each monitor location meets the appropriate siting criteria. For units monitored by a continuous emission monitoring system, diagrams shall include: i. A schematic diagram identifying entire gas handling system from unit to stack for all units, using identification numbers for units, monitor components, and stacks corresponding to the identification numbers provided in the initial monitoring plan and paragraphs (d)(1) and (3). The schematic diagram must depict the height of any monitor locations. Comprehensive and/or separate schematic diagrams shall be used to describe groups of units using a common stack. ii. Stack and duct engineering diagrams showing the dimensions and locations of fans, turning vanes, air preheaters, monitor components, probes, reference method sampling ports, and other equipment that affects the monitoring system location, performance, or quality control checks. l. A data flow diagram denoting the complete information handling path from output signals of CEMS components to final reports. 5. In addition to supplying the information in paragraphs (c) and (d) above, the owner or operator of an SO2 emitting unit using either of the methodologies in paragraph I.1(a)(2)(B) of this Section shall include the following information in its monitoring plan for the specific situations described: a. For each gas-fired or oil-fired SO2 emitting unit for which the owner or operator uses the optional protocol in appendix D to 40 CFR Part 75 for SO2 mass emissions, the Account Representative shall include the following information in the monitoring plan: i. Parameter monitored; ii. Type of fuel measured, maximum fuel flow rate, units of measure, and basis of maximum fuel flow rate (i.e., upper range value or unit maximum) for each fuel flowmeter; iii. Test method used to check the accuracy of each fuel flowmeter; iv. Submission status of the data; v. Monitoring system identification code; vi. The method used to demonstrate that the unit qualifies for monthly GCV sampling or for daily or annual fuel sampling for sulfur content, as applicable; vii. A schematic diagram identifying the relationship between the unit, all fuel supply lines, the fuel flowmeter(s), and the stack(s). The schematic diagram must depict the installation location of each fuel flowmeter and the fuel sampling location(s). Comprehensive and/or separate schematic diagrams shall be used to describe groups of units using a common pipe; viii. For units using the optional default SO2 emission rate for “pipeline natural gas” or “natural gas” in appendix D to 40 CFR Part 75, the information on the sulfur content of the gaseous fuel used to demonstrate compliance with either section 2.3.1.4 or 2.3.2.4 of appendix D to 40 CFR Part 75; ix. For units using the 720 hour test under section 2.3.6 of appendix D to 40 CFR Part 75 to determine the required sulfur sampling requirements, report the procedures and results of the test; and x. For units using the 720 hour test under section 2.3.5 of appendix D to 40 CFR Part 75 to determine the appropriate fuel GCV sampling frequency, report the procedures used and the results of the test. b. For each SO2 emitting unit for which the owner or operator uses the low mass emission excepted methodology of section 75.19 to 40 CFR Part 75, the designated representative shall include the following information in the monitoring plan that accompanies the initial certification application: i. The results of the analysis performed to qualify as a low mass emissions unit under section 75.19(c) to 40 CFR Part 75. This report will include either the previous three years actual or projected emissions. The following items should be included: (1) Current calendar year of application; (2) Type of qualification; (3) Years one, two, and three; (4) Annual measured, estimated or projected SO2 mass emissions for years one, two, and three; and (5) ii. Annual operating hours for years one, two, and three. A schematic diagram identifying the relationship between the unit, all fuel supply lines and tanks, any fuel flowmeter(s), and the stack(s). Comprehensive and/or separate schematic diagrams shall be used to describe groups of units using a common pipe; iii. For units which use the long term fuel flow methodology under section 75.19(C)(3) to 40 CFR Part 75, a diagram of the fuel flow to each unit or group of units and a detailed description of the procedures used to determine the long term fuel flow for a unit or group of units for each fuel combusted by the unit or group of units; iv. A statement that the unit burns only gaseous fuel(s) and/or fuel oil and a list of the fuels that are burned or a statement that the unit is projected to burn only gaseous fuel(s) and/or fuel oil and a list of the fuels that are projected to be burned; v. A statement that the unit meets the applicability requirements in sections 75.19(a) and (b) to 40 CFR Part 75 with respect to SO2 emissions; and vi. Any unit historical actual, estimated and projected SO2 emissions data and calculated SO2 emissions data demonstrating that the unit qualifies as a low mass emissions unit under sections 75.19(a) and (b) to 40 CFR Part 75. c. For each gas-fired unit the Account Representative shall include the following in the monitoring plan: current calendar year, fuel usage data as specified in the definition of gas-fired in section 72.2 of 40 CFR Part 72, and an indication of whether the data are actual or projected data. 6. An operating permit for a WEB source issued in accordance with Title V of the Clean Air Act shall require a source to maintain a detailed monitoring plan in accordance with this Part, but the specific elements of the plan shall not be part of the permit, and modifications to the elements of the plan shall not require a permit modification. C. Certification/Recertification. 1. All monitoring systems are subject to initial certification and recertification testing as specified in 40 CFR Part 75 or Appendix A to this Rule, as applicable. Certification or recertification of a monitoring system by the U.S. Environmental Protection Agency for a WEB source that is subject to 40 CFR Part 75 under a requirement separate from this Rule shall constitute certification under the WEB Trading Program. 2. The owner or operator of an SO2 emitting unit not otherwise subject to 40 CFR Part 75 that monitors SO2 mass emissions in accordance with 40 CFR Part 75 to satisfy the requirements of this Section shall perform all of the tests required by that regulation and shall submit the following: a. A test notice, not later than 21 days before the certification testing of the monitoring system, provided that the Director may establish additional requirements for adjusting test dates after this notice as part of the approval of the initial monitoring plan under paragraph I2(C) of this Rule; and b. An initial certification application within 45 days after testing is complete. A monitoring system will be considered provisionally certified while the application is pending, and the system shall be deemed certified if the Director does not approve or disapprove the system within six months after the date on which the application is submitted. D. Ongoing Quality Assurance and Quality Control. 1. The WEB source shall satisfy the applicable quality assurance and quality control requirements of Part 75 or, if the WEB source is subject to a WEB protocol in Appendix A, the applicable quality assurance and quality control requirements in Appendix A on and after the date that certification testing commences. E. Substitute Data Procedures. 1. For any period after certification testing is complete in which valid data are not being recorded by a monitoring system specified in this Rule, missing or invalid data shall be replaced with substitute data in accordance with 40 CFR Part 75 or, if the WEB source is subject to a WEB protocol in Appendix A of this rule, with substitute data in accordance with Appendix A of this rule. 2. For an SO2 emitting unit that does not have a certified (or provisionally certified) monitoring system in place as of the beginning of the first control period for which the unit is subject to the WEB Trading Program, the owner or operator shall: a. If the owner or operator will use a CEMS to comply with this Section, substitute the maximum potential concentration of SO2 for the unit and the maximum potential flow rate, as determined in accordance with 40 CFR Part 75. The procedures for conditional data validation under section 75.20(b)(3) may be used for any monitoring system under this Rule that uses these 40 CFR Part 75 procedures, as applicable; b. If the owner or operator will use the 40 CFR Part 75 Appendix D methodology, substitute the maximum potential sulfur content, density or gross calorific value for the fuel and the maximum potential fuel flow rate, in accordance with section 2.4 of Appendix D to 40 CFR Part 75; c. If the owner or operator will use the 40 CFR Part 75 LME methodology, substitute the SO2 emission factor required for the unit as specified in 40 CFR 75.19 and the maximum rated hourly heat input, as defined in 40 CFR 72.2; or d. If using a protocol in Appendix A to this Rule, follow the procedures in the applicable protocol. F. Compliance Dates. 1. The initial monitoring plan shall be submitted by the following dates: a. For each source that is a WEB source on or before the Program Trigger Date, the monitoring plan shall be submitted 180 days after such Program Trigger Date. b. For any existing source that becomes a WEB source after the Program Trigger Date, the monitoring plan shall be submitted by September 30 of the year following the inventory year in which the source exceeded the emissions threshold. c. For any new WEB source, the monitoring plan shall be included with the permit application for New Source Review. [State shall modify the language as necessary to conform with state’s new source review rules.] 2. Emission monitoring systems shall be installed, operational and shall have met all of the certification testing requirements of this Section I (including any referenced in Appendix A) by the following dates: a. For each source that is a WEB source on or before the Program Trigger Date, two years prior to the start of the first control period as described in Section L of this Rule. b. For any existing source that becomes a WEB source after the Program Trigger Date, one year after the due date for the monitoring plan under I1(C)(2) of this Rule. c. For any new WEB source, the earlier of 90 unit operating days or 180 calendar days after the date the new source commences operation. G. Recordkeeping. 1. Except as provided in Section I7(b), the WEB source shall keep copies of all reports, registration materials, compliance certifications, sulfur dioxide emissions data, quality assurance data, and other submissions under this Rule for a period of five years. Unless otherwise requested by the WEB source and approved by the Director, the copies shall be kept on site. 2. The WEB source shall keep all Account Certificates of Representation on site at the source through the year 2018. 3. The WEB source shall keep records of all operating hours, quality assurance activities, fuel sampling measurements, hourly averages for SO2, stack flow, fuel flow, or other continuous measurements, as applicable, and any other applicable data elements specified in this Section or in Appendix A to this Rule. The WEB source shall maintain the applicable records specified in 40 CFR Part 75 for any SO2 emitting unit that uses a Part 75 monitoring method to meet the requirements of this Section. H. Reporting. 1. Quarterly Reports. For each SO2 emitting unit, the Account Representative shall submit a quarterly report within thirty days after the end of each calendar quarter. The report shall be in a format specified by the Director and shall be submitted in a manner compatible with the emissions tracking database designed for the WEB Trading Program. the Director may require the WEB source to submit hourly and quality assurance activity information comparable to quarterly reports under 40 CFR Part 75. If the owner or operator submits a quarterly report under 40 CFR Part 75 to the U.S. EPA Administrator, no additional report under this paragraph (a) shall be required, provided, however, that the Director may require that a copy of that report (or a separate statement of quarterly and cumulative annual SO2 mass emissions) be submitted separately to the Director. 2. Annual Report. Based on the quarterly reports, each WEB source shall submit an annual statement of total annual SO2 emissions for all SO2 emitting units at the source. The annual report shall contain four elements: total emissions for all units monitored in accordance with Section I1(a) of this Rule; total emissions for all units with emissions estimated in accordance with Section I1(b) of this Rule; the number of tons, if any, of SO2 emissions estimated under Section I1(b) of this Rule that are subject to deduction of allowances from the source’s compliance account in accordance with Section I1(b)(6); and the total number of SO2 tons subject to deduction of allowances from the source’s compliance account in accordance with Section 1621 of this Rule. The annual report shall be submitted within 30 days after the end of a control period. 3. The Director may direct that any monitoring plan, report, certification/recertification, or emissions data required to be submitted under this Section be submitted to the Tracking System Administrator. 4. The Director may review and reject any report submitted under this Section I7 that contains errors or fails to satisfy the requirements of this Section, and the Account Representative shall resubmit the report to correct any deficiencies. 5. Petitions. A WEB source may petition for an alternative to any requirement specified in Section I1(a)(2). The petition shall require approval of the Director and the U.S. EPA Administrator. Any petition submitted under this paragraph shall include sufficient information for the evaluation of the petition, including, at a minimum, the following information: a. Identification of the WEB source and applicable SO2 emitting unit(s); b. A detailed explanation of why the proposed alternative is being suggested in lieu of the requirement; c. A description and diagram of any equipment and procedures used in the proposed alternative, if applicable; d. A demonstration that the proposed alternative is consistent with the purposes of the requirement for which the alternative is proposed and is consistent with the purposes of this Rule and that any adverse effect of approving such alternative will be de minimis; and e. 6. Any other relevant information that the Director may require. For any monitoring plans, reports, or other information submitted under Section 1618 of this Rule, the Account Representative shall ensure that, where applicable, identifying information is consistent with the identifying information provided in the most recent certificate of representation for the WEB source submitted under Section 1614 of this Rule. R18-2-1619. A. Allowance Transfers Procedure. 1. To transfer allowances, the Account Representative shall submit the following information to the Tracking System Administrator: a. The transfer account number(s) identifying the transferor account; b. The transfer account number(s) identifying the transferee account; c. The serial number of each allowance to be transferred; and d. The transferor’s Account Representative’s name and signature and date of submission. B. Deadline. 1. The allowance transfer deadline is midnight Pacific Standard Time March 1 of each year (or if this date is not a business day, midnight of the first business day thereafter) following the end of the control period. By this time, the transfer of the allowances into the WEB source’s compliance account must be correctly submitted to the Tracking System Administrator in order to demonstrate compliance under Section 1621(A) of this Rule for that control period. C. Retirement of Allowances. 1. To transfer allowances for the purpose of retirement, the Account Representative shall submit the following information to the Tracking System Administrator: a. The transfer account number(s) identifying the transferor account; b. The serial number of each allowance to be retired; and c. The transferor’s Account Representative’s name and signature and date of submission accompanied by a signed statement acknowledging that each retired allowance as no longer available for future transfers from or to any account. R.18-2-1620. A. Use of Allowances from a Previous Year Any allowance that is held in a compliance account or general account will remain in such an account unless and until the allowance is deducted in conjunction with the compliance process, or transferred to another account. B. In order to demonstrate compliance under Section 1621(A) of this Rule for a control period, WEB sources shall only use allowances allocated for that current control period or any previous year. C. If flow control procedures for the current control period have been triggered, then the use of allowances that were allocated for any previous year will be limited as follows: 1. The number of allowances that are held in each compliance account and general account as of the allowance transfer deadline for the immediately previous year and that were allocated for any previous year will be determined. 2. The number determined in (1) will be multiplied by the flow control ratio to determine the number of allowances that were allocated for a previous year that can be used without restriction for the current control period. 3. Allowances that were allocated for a previous year in excess of the number determined in (2) may also be used for the current control period. If such allowances are used to make a deduction, two allowances must be deducted for each deduction of one allowance required under Section 1621 of this Rule. D. Special provisions for the year 2018. After compliance with the 2017 allowance limitation has been determined in accordance with Section 1621(A) of this Rule, allowances allocated for any year prior to 2018 shall not be used for determining compliance with the 2018 allowance limitation or any future allowance limitation. R18-2-1621. A. Compliance Compliance with Allowance Limitations. 1. The WEB source must hold allowances, in accordance with Section 1620 and Section 1621(A)(2) of this Rule, as of the allowance transfer deadline in the WEB source’s compliance account (together with any current control year allowances held for the WEB source by the Director under Section 1618(A)(2) of this Rule) in an amount not less than the total SO2 emissions for the control period from the WEB source, as determined under the monitoring and reporting requirements of Section 1618 of this Rule. a. For each source that is a WEB source on or before the Program Trigger Date, the first control period is the calendar year that is six years following the calendar year for which SO2 emissions exceeded the milestone. b. For any existing source that becomes a WEB source after the Program Trigger Date, the first control period is the calendar year that is four years following the inventory year in which the source exceeded the SO2 emissions threshold. c. For any new WEB source after the Program Trigger Date the first control period is the first full calendar year that the source is in operation. d. If the WEB Trading Program is triggered in accordance with the 2013 review, the first control period for each source that is a WEB source on or before the Program Trigger Date is the year 2018. 2. Allowance transfer deadline. An allowance may only be deducted from the WEB source’s compliance account if: a. The allowance was allocated for the current control period or meets the requirements in Section 1620 of this Rule for use of allowances from a previous control period, and b. The allowance was held in the WEB source’s compliance account as of the allowance transfer deadline for the current control period, or was transferred into the compliance account by an allowance transfer correctly submitted for recording by the allowance transfer deadline for the current control period. 3. Compliance with allowance limitations shall be determined by comparing the following two numbers: a. The monitored SO2 emissions data reported by the source to the Director, in accordance with Section 1618 of this Rule, and recorded in the emissions tracking database and b. The allowance allocations and transfers recorded in the Allowance Tracking System, adjusted in accordance with Section 1620 of this Rule. 4. To the extent consistent with Section 1620 of this Rule, allowances shall be deducted for a WEB source for compliance with the allowance limitation as directed by the WEB source’s Account Representative. Deduction of any other allowances as necessary for compliance with the allowance limitation shall be on a first-in, first-out accounting basis in the order of the date and time of their recording in the WEB source’s compliance account, beginning with the allowances allocated to the WEB source and continuing with the allowances transferred to the WEB source’s compliance account from another compliance account or general account. The allowances held by the Director for compliance at a WEB source pursuant to Section 1618(A)(2) of this Rule shall be deducted as specified in that Section. B. Certification of Compliance. 1. For each control period in which a WEB source is subject to the allowance limitation, the Account Representative of the source shall submit to the Director a Compliance Certification report for the source. 2. The Compliance Certification report shall be submitted no later than the allowance transfer deadline of each control period, and shall contain the following: a. Identification of each WEB source; b. At the Account Representative’s option, the serial numbers of the allowances that are to be deducted from a source’s compliance account for compliance with the allowance limitation; and c. The Compliance Certification report according to subpart 3 of this section. 3. In the Compliance Certification report, the Account Representative shall certify, based on reasonable inquiry of those persons with primary responsibility for operating the WEB source in compliance with the WEB Trading Program, whether the WEB source for which the compliance certification is submitted was operated during the control period covered by the report in compliance with the requirements of the WEB Trading Program applicable to the source including: a. Whether the WEB source operated in compliance with the SO2 allowance limitation; b. Whether SO2 emissions data has been submitted to [states or tribe] in accordance with Section 1618(A) of this Rule and other applicable guidance, for review, revision as necessary, and finalization for forwarding to the SO2 Allowance Tracking System for recording; c. Whether the monitoring plan that governs the WEB source has been maintained to reflect the actual operation and monitoring of the source, and contains all information necessary to attribute SO2 emissions to the source, in accordance with Section 1618(A) of this Rule; d. Whether all the SO2 emissions from the WEB source if applicable, were monitored or accounted for either through the applicable monitoring or through application of the appropriate missing data procedures; e. If applicable, whether any SO2 emitting unit for which the WEB source is not required to monitor in accordance with Section 1618(A)(1)(c) of this rule remained permanently retired and had no emissions for the entire applicable period; and f. Whether there were any changes in the method of operating or monitoring the WEB source that required monitor recertification. If there were any such changes, the report must specify the nature, reason, and date of the change, the method to determine compliance status subsequent to the change, and specifically, the method to determine SO2 emissions. C. Penalties for any WEB source exceeding its allowance limitations. 1. Allowance deduction penalties. a. If emissions from a WEB source exceed the allowance limitation for a control period, as determined in accordance with Section 1621(A) of this Rule, the source’s allowances held in its compliance account will be reduced by an amount equal to two times the source’s tons of excess emissions. b. If the compliance account does not have sufficient allowances allocated for that control period, the required number of allowances will be deducted from the WEB source’s compliance account regardless of the control period for which they were allocated, once allowances are recorded in the account. c. Any allowance deduction required under this Section shall not affect the liability of the owners and operators of the WEB source for any fine, penalty or assessment or their obligation to comply with any other remedy, for the same violation, as ordered under the Clean Air Act, implementing regulations or applicable state or tribal law.. 2. A financial penalty of $5,000 per ton of SO2 emissions in excess of the WEB source’s allowance limitation shall be levied. 3. WEB Source liability for non-compliance a. Separate and regardless of any automatic penalties assessed for allowance deduction penalty and financial penalty, a WEB source that violates any requirement of this Rule, including monitoring record keeping and reporting requirements, is subject to civil and criminal penalties under the Director law and the Clean Air Act. Each day of the control period is a separate violation, and each ton of SO2 emissions in excess of a source’s allowance limitation is a separate violation. R18-2-1622. Special Penalty Provisions for the 2018 Milestone A. If the WEB Trading Program is triggered and the first control period will not occur until after the year 2018, the following provisions shall apply for the 2018 emissions year. 1. All WEB sources shall register, and open a compliance account within 180 days after the Program Trigger Date, in accordance with Sections 1615(A)and 1617 of this Rule. 2. The Tracking System Administrator will record the allowances for the 2018 control period for each WEB source in the source’s compliance account once the Director allocates the 2018 allowances. 3. The allowance transfer deadline is midnight Pacific Standard Time on May 30, 2021. WEB sources may transfer allowances as provided in Section 1619(A) of this Rule until the allowance transfer deadline. 4. A WEB source must hold allowances allocated for 2018 including those transferred into the compliance account by an allowance transfer correctly submitted by the allowance transfer deadline, in an amount not less than the WEB source’s total SO2 emissions for 2018. Emissions are determined using the pre trigger monitoring provisions in Section 1611 of this rule. 5. An allowance deduction penalty and financial penalty shall be assessed and levied in accordance with Sections 1620(D), 1621(A)(4) and 1621(C) of this Rule, except that SO2 emissions shall be determined under Section 1622(A)(4) of this Rule. B. If the program has been triggered and provision 1622(A) is implemented, the provisions of 1622(C) of this Rule shall apply for each year after the 2018 emission year until: C. 1. The first control period under the WEB trading program; or 2. The Director determined that the 2018 SO2 milestone has been met. If provision in Section 1622(A) has been implemented, the following shall apply to each emissions year after the 2018 emissions year: 1. The Tracking System Administrator will record the allowances for the control period for the specific year for each WEB source in the source’s compliance account once the Director allocates the allowances. 2. The allowance transfer deadline is midnight Pacific Standard Time on March 1 of each year (or if this date is not a business day, midnight of the first business day thereafter) following the end of the specific emissions year. WEB sources may transfer allowances as provided in Section 1619(A) of this Rule until the allowance transfer deadline. 3. A WEB source must hold allowances allocated for that specific emissions year, or any year after 2018, including those transferred into the compliance account by an allowance transfer correctly submitted by the allowance transfer deadline, in an amount not less than the WEB source’s total SO2 emissions for the specific emissions year. Emissions are determined using the pre-trigger monitoring provisions in Section 1611 of this rule. 4. An allowance deduction penalty and financial penalty shall be assessed and levied in accordance with Sections 1620(D), 1621(A)(4) and 1621(C) of this Rule, except that SO2 emissions shall be determined under Section 1622(C)(3) of this Rule. NOTE: Appendix A follows. APPENDIX A: WEB MODEL RULE MONITORING PROTOCOLS Protocol WEB-1: 1. 2. SO2 Monitoring of Fuel Gas Combustion Devices Applicability (a) The provisions of this protocol are applicable to fuel gas combustion devices at petroleum refineries. (b) Fuel gas combustion devices include boilers, process heaters, and flares used to burn fuel gas generated at a petroleum refinery. (c) Fuel gas means any gas which is generated and combusted at a petroleum refinery. Fuel gas does not include (1) natural gas, unless combined with other gases generated at a petroleum refinery, (2) gases generated by a catalytic cracking unit catalyst regenerator, (3) gases generated by fluid coking burners, (4) gases combusted to produce sulfur or sulfuric acid, or (5) process upset gases generated due to startup, shutdown, or malfunctions. Monitoring Requirements (a) Except as provided in paragraphs (b) and (c) of this Section 2, fuel gas combustion devices shall use a continuous fuel gas monitoring system (CFGMS) to determine the total sulfur content (reported as H2S) of the fuel gas mixture prior to combustion, and continuous fuel flow meters to determine the amount of fuel gas burned. (1) Fuel gas combustion devices having a common source of fuel gas may be monitored for sulfur content at one location, if monitoring at that location is representative of the sulfur content of the fuel gas being burned in any fuel gas combustion device. (2) The CFGMS shall meet the performance requirements in Performance Specification 2 in Appendix B to 40 CFR Part 60, and the following: (i) Continuously monitor and record the concentration by volume of total sulfur compounds in the gaseous fuel reported as ppmv H2S. (ii) Have the span value set so that the majority of readings fall between 10 and 95% of the range. (iii) (iv) Record negative values of zero drift. Calibration drift shall be # 5.0% of the span, for initial certification and daily calibration error tests. (v) Methods 15A, 16, or approved alternatives for total sulfur, are the reference methods for the relative accuracy test. The relative accuracy test shall include a bias test in accordance with paragraph 4.(c) of this section. (3) All continuous fuel flow meters shall comply with the provisions of section 2.1.5 of Appendix D to 40 CFR Part 75. (4) The hourly mass SO2 emissions rate for all the fuel gas combustion devices monitored by this approach shall be calculated using the following equation: Et = (CS)(Qt)(K) where: (b) Et = Total SO2 emissions in lb/hr from applicable fuel gas combustion devices CS = Sulfur content of the fuel gas as H2S(ppmv) Qt = Fuel gas flow rate to the applicable fuel gas combustion devices (scf/hr) K = 1.660 x 10-7 (lb/scf)/ppmv In place of a CFGMS in paragraph (a) of this Section 2, fuel gas combustion devices having a common source of fuel gas may be monitored with an SO2 CEMS, a flow CEMS, and (if necessary) a moisture monitoring system at only one location, if the CEMS monitoring at that location is representative of the SO2 emission rate (lb SO2/scf fuel gas burned) of all applicable fuel gas combustion devices. Continuous fuel flow meters shall be used in accordance with paragraph (a), and the fuel gas combustion device monitored by a CEMS shall have separate fuel metering. (1) Each CEMS for SO2, flow, and (if applicable) moisture, shall comply with the operating requirements, performance specifications, and quality assurance requirements of 40 CFR Part 75. (2) All continuous fuel flow meters shall comply with the provisions of section 2.1.5 of Appendix D to 40 CFR Part 75. (3) The SO2 hourly mass emissions rate for all the fuel gas combustion devices monitored by this approach shall be determined by the ratio of the amount of fuel gas burned by the CEMS-monitored fuel gas combustion device to the total fuel gas burned by all applicable fuel gas combustion devices using the following equation: Et = (Em)(Qt)/(Qm) where: Et = Total SO2 emissions in lb/hr from applicable fuel gas combustion devices Em = SO2 emissions in lb/hr from the CEMSmonitored fuel gas combustion device, calculated using Equation F-1 or (if applicable) F-2 in Appendix F to 40 CFR Part 75 Qt = Fuel gas flow rate (scf/hr) to the applicable fuel gas combustion devices Qm = Fuel gas flow rate (scf/hr) to the CEMSmonitored fuel gas combustion device (c) In place of a CFGMS in paragraph (a) of this section, fuel gas combustion devices having a common source of fuel gas may be monitored with an SO2 - diluent CEMS at only one location, if the CEMS monitoring at that location is representative of the SO2 emission rate (lb SO2/mmBtu) of all applicable fuel gas combustion devices. If this option is selected, the owner or operator shall conduct fuel gas sampling and analysis for gross calorific value (GCV), and shall use continuous fuel flow metering in accordance with paragraph (a) of this Section 2, with separate fuel metering for the CEMS-monitored fuel gas combustion device. (1) Each SO2-diluent CEMS shall comply with the applicable provisions for SO2 monitors and diluent monitors in 40 CFR Part 75, and shall use the procedures in section 3 of Appendix F to Part 75 for determining SO2 emission rate (lb/mmBtu) by substituting the term SO2 for NOx in that section, and using a K factor of 1.660 x 10-7 (lb/scf)/ppmv instead of the NOx K factor. (2) All continuous fuel flow meters and fuel gas sampling and analysis for GCV to determine the heat input rate from the fuel gas shall comply with the applicable provisions in sections 2.1.5 and 2.3.4 of Appendix D to 40 CFR Part 75. (3) The SO2 hourly mass emissions rate for all the fuel gas combustion devices monitored by this approach shall be calculated by using the following equation: Et = (Em) (Qt)(GCV)/106 where: Et = from Em = CEMS Total hourly SO2 mass emissions in lb/hr the applicable fuel gas combustion devices SO2 emission rate in lb/mmBtu from the - monitored fuel gas combustion device Qt = Fuel gas flow rate (scf/hr) to the applicable fuel gas combustion devices GCV = Fuel Gross Calorific Value (Btu/scf) 106 = Conversion from Btu to million Btu (d) Calculate total SO2 mass emissions for each calendar quarter and each calendar year based on the emissions in lb/hr and Equations F-3 and F-4 in Appendix F to 40 CFR Part 75, Appendix F. 3. Certification/Recertification Requirements All monitoring systems are subject to initial certification and recertification testing as follows: (a) The owner or operator shall comply with the initial testing and calibration requirements in Performance Specification 2 in Appendix B to 40 CFR Part 60 and paragraph 2 (a)(2) of this section for each CFGMS. (b) Each CEMS for SO2 and flow or each SO2-diluent CEMS shall comply with the testing and calibration requirements specified in 40 CFR Part 75, section 75.20 and Appendices A and B, except that each SO2-diluent CEMS shall meet the relative accuracy requirements for a NOx-diluent CEMS (lb/mmBtu). (c) 4. A continuous fuel flow meter shall comply with the certification and quality-assurance requirements in sections 2.1.5 and 2.1.6 to Appendix D to 40 CFR Part 75. Quality Assurance/Quality Control Requirements (a) A quality assurance/quality control (QA/QC) plan shall be developed and implemented for each CEMS for SO2 and flow or the SO2diluent CEMS in compliance with sections 1, 1.1, and 1.2 of Appendix B to Part 75. (b) A QA/QC plan shall be developed and implemented for each continuous fuel flow meter and fuel sampling and analysis in compliance with sections 1, 1.1, and 1.3 of Appendix B to 40 CFR Part 75. (c) A QA/QC plan shall be developed and implemented for each CFGMS in compliance with sections 1 and 1.1 of Appendix B to 40 CFR Part 75, and the following: (i) Perform a daily calibration error test of each CFGMS at two gas concentrations, one low level and one high level. Calculate the calibration error as described in Appendix A to 40 CFR Part 75. An out of control period occurs whenever the error is greater than 5.0% of the span value. (ii) In addition to the daily calibration error test, an additional calibration error test shall be performed whenever a daily calibration error test is failed, whenever a monitoring system is returned to service following repairs or corrective actions that may affect the monitor measurements, or after making manual calibration adjustments. (iii) Perform a linearity test once every operating quarter. Calculate the linearity as described in Appendix A to 40 CFR Part 75. An out of control period occurs whenever the linearity error is greater than 5.0 percent of a reference value, and the absolute value of the difference between average monitor response values and a reference value is greater than 5.0 ppm. (iv) Perform a relative accuracy test audit once every four operating quarters. Calculate the relative accuracy as described in Appendix A to 40 CFR Part 75. An out of control period occurs whenever the relative accuracy is greater than 20.0% of the mean value of the reference method measurements. (v) Using the results of the relative accuracy test audit, conduct a bias test in accordance with Appendix A to 40 CFR Part 75, and calculate and apply a bias adjustment factor if required. 5. Missing Data Procedures (a) For any period in which valid data are not being recorded by an SO2 CEMS or flow CEMS specified in this section, missing or invalid data shall be replaced with substitute data in accordance with the requirements in Subpart D of 40 CFR Part 75. (b) For any period in which valid data are not being recorded by an SO2-diluent CEMS specified in this section, missing or invalid data shall be replaced with substitute data on a rate basis (lb/mmBtu) in accordance with the requirements for SO2 monitors in Subpart D of 40 CFR Part 75. (c) For any period in which valid data are not being recorded by a continuous fuel flow meter or for fuel gas GCV sampling and analysis specified in this section, missing or invalid data shall be replaced with substitute data in accordance with missing data requirements in Appendix D to 40 CFR Part 75. (d) 6. For any period in which valid data are not being recorded by the CFGMS specified in this section, hourly missing or invalid data shall be replaced with substitute data in accordance with the missing data requirements for units performing hourly gaseous fuel sulfur sampling in section 2.4 of Appendix D to 40 CFR Part 75. Monitoring Plan and Reporting Requirements In addition to the general monitoring plan and reporting requirements of Section I of this Rule, the owner or operator shall meet the following additional requirements: (a) The monitoring plan shall identify each group of units that are monitored by a single monitoring system under this Protocol WEB-1, and the plan shall designate an identifier for the group of units for emissions reporting purposes. For purpose of submitting emissions reports, no apportionment of emissions to the individual units within the group is required. (b) If the provisions of paragraphs 2.(b) or (c) are used, provide documentation and an explanation to demonstrate that the SO2 emission rate from the monitored unit is representative of the rate from non-monitored units. Protocol WEB-2: Predictive Flow Monitoring Systems for Kilns with Positive Pressure Fabric Filter 1. Applicability The provisions of this protocol are applicable to cement kilns or lime kilns that (1) are controlled by a positive pressure fabric filter, (2) combust only a single fuel, no fuel blends, and (3) have operating conditions upstream of the fabric filter that the WEB source documents would reasonably prevent reliable flow monitor measurements. This protocol does not modify the SO2 monitoring requirements in section I of this Rule. 2. Monitoring Requirements (a) A cement or lime kiln with a positive pressure fabric filter shall use a predictive flow monitoring system (PFMS) to determine the hourly kiln exhaust gas flow. (b) A PFMS is the total equipment necessary for the determination of exhaust gas flow using process or control device operating parameter measurements and a conversion equation, a graph, or computer program to produce results in cubic feet per hour. (c) The PFMS shall meet the following performance specifications: (1) Sensors readings and conversion of sensor data to flow in cubic feet per hour must be automated. (2) The PFMS must allow for the automatic or manual determination of failed monitors. At a minimum a daily determination must be performed. (3) The PFMS shall have provisions to check the calibration error of each parameter that is individually measured. The owner or operator shall propose appropriate performance specifications in the initial monitoring plan for all parameters used in the PFMS comparable to the degree of accuracy required for other monitoring systems used to comply with this Rule. The parameters shall be tested at two levels, low: 0 to 20% of full scale, and high: 50 to 100% of full scale. The reference value need not be certified. (4) The relative accuracy of the PFMS must be < 10.0% of the reference method average value, and include a bias test in accordance with paragraph 4(c) of this section. 3. Certification Requirements The PFMS is subject to initial certification testing as follows: (a) Demonstrate the ability of the PFMS to identify automatically or manually a failed monitor. (b) Provide evidence of calibration testing of all monitoring equipment. Any tests conducted within the previous 12 months of operation that are consistent with the QA/QC plan for the PFMS are acceptable for initial certification purposes. (c) Perform an initial relative accuracy test over the normal range of operating conditions of the kiln. Using the results of the relative accuracy test audit, conduct a bias test in accordance with Appendix A to 40 CFR Part 75, and calculate and apply a bias adjustment factor if required. 4. Quality Assurance/Quality Control Requirements A QA/QC plan shall be developed and implemented for each PFMS in compliance with sections 1 and 1.1 of Appendix B of 40 CFR Part 75, and the following: (a) Perform a daily monitor failure check. (b) Perform calibration tests of all monitors for each parameter included in the PFMS. At a minimum, calibrations shall be conducted prior to each relative accuracy test audit. (c) Perform a relative accuracy test audit and accompanying bias test once every four operating quarters. Calculate the relative accuracy (and bias adjustment factor) as described in Appendix A to 40 CFR Part 75. An out of control period occurs whenever the flow relative accuracy is greater than 10.0% of the mean value of the reference method. 5. Missing Data For any period in which valid data are not being recorded by the PFMS specified in this section, hourly missing or invalid data shall be replaced with substitute data in accordance with the flow monitor missing data requirements for non-load based units in Subpart D of 40 CFR Part 75. 6. Monitoring Plan Requirements In addition to the general monitoring plan requirements of Section I of this Rule, the owner or operator shall meet the following additional requirements: (a) The monitoring plan shall document the reasons why stack flow measurements upstream of the fabric filter are unlikely to provide reliable flow measurements over time. (b) The initial monitoring plan shall explain the relationship of the proposed parameters and stack flow, and discuss other parameters considered and the reasons for not using those parameters in the PFMS. The [state or tribe] may require that the subsequent monitoring plan include additional explanation and documentation for the reasonableness of the proposed PFMS. NPRM WEB Trading Program, 11/10/03 47 Appendix A-7b. Proposed WRAP 309 Coordinating Committee Charter Appendix A-7 – Stationary Sources Arizona Regional Haze SIP WRAP Board of Directors Proposal to form a standing 309 Coordinating Committee October 15, 2003 Background: Section 309 of the Regional Haze Rule provides that the 9 western “transport region” states and Indian tribes within those states may opt to develop regional haze SIPs following the recommendations of the Grand Canyon Visibility Transport Commission (GCVTC). If implemented, the GCTVC recommendations satisfy the requisite showing of “Reasonable Progress” toward meeting the national visibility goal. Transport states electing to submit 309 SIPs must incorporate the GCVTC recommendations, and submit their initial SIPs by December 31, 2003. Eligible tribes are not subject to this deadline and may submit 309 TIPs at later dates. Over the last several years the WRAP has performed most of the technical analyses and policy recommendations to support the states on a regional scale. Five transport region states have declared their intent to submit 309 SIPs. These states are AZ, NM, OR, UT, and WY. To date, no tribe has announced its intention to submit a 309 TIP. As these 309 states have moved through their individual planning processes following the work of the WRAP, it is clear they would benefit greatly through continuing the cooperative relationships already established under the WRAP. Likewise, tribes that choose 309 would also benefit greatly from this ongoing collaboration. This would better enable each participant to take advantage of the work done by the other participants on their initial submittals, with higher assurance that the SIPs and TIPs would meet all requirements of the Regional Haze Rule and the Annex. Over the longer term, a coordinated approach provides a forum to facilitate ongoing communications among the participants, and a mechanism to meet particular implementation requirements, such as milestone tracking, monitoring information and data exchange. Proposal: The 309 states propose that the WRAP board create a standing committee, called the “309 Coordinating Committee.” This committee would be formed according to the WRAP Bylaws, II. E., which allows the formation of additional standing committees (see attachment). The committee would be organized as follows: Membership – One designated representative from each state and tribe that submits a plan under §309 (in the case of tribes, a declaration of intent to move ahead with submission of a plan would warrant membership). Additional state and tribal staff may participate in meetings of the committee, as appropriate. The WRAP will appoint Co-Chairs from the membership. Additional members – If issues arise which require participation of federal agencies or stakeholders, the committee at its discretion will extend membership to such federal representatives and stakeholders as appropriate. The WRAP will make these appointments for limited duration as long as the issue requiring federal or stakeholder membership is active. Charge of the Committee – To provide an ongoing forum for 309 states and tribes to facilitate communications and information exchange. To provide a mechanism to achieve consistency in implementing requirements of §309 of the regional haze rule, including but not limited to implementation of: the emissions tracking system to evaluate stationary source compliance with the SO2 milestones; the backstop market-trading program for stationary sources, if required; and emission tracking in clean air corridors, for fire and enhanced smoke management programs, and for mobile and area sources. The committee will also make recommendations to the WRAP Board, as needed, toward improving implementation of programs contained in SIPs and TIPs adopted under §309, and evaluate the value and appropriateness of WRAP involvement in resolving disagreements between states or between states and tribes on 309 matters. ATTACHMENT (From WRAP bylaws, revised 7/23/02) … I. GENERAL GUIDELINES FOR STANDING COMMITTEES REPORTING DIRECTLY TO THE WRAP. A. All meetings shall be open to the public, and should include an opportunity for those members of the public who are observing the meeting to comment on or provide suggestions relevant to the committee's work. B. Whenever processes are directed to be stakeholder based, membership should represent a wide range of social, cultural, economic, geographic, relative population and technical viewpoints. To meet this goal, the following categories of representatives should be considered. * Industry (focused on production sector but excluding the mobile source sector) * Small business (focused on the service sector, including "green industry") * Mobile sources (including vehicle manufacturers and transportation planners) * Federal government * Tribal government * State government * Local government * Academia * Environmental groups * General public In all cases it may not be possible or appropriate to include each of the categories in stakeholder processes. However, whenever a category is not included, an explanation for the exclusion should be recorded. In selecting members for committees, both technical expertise and diversity of viewpoints must be considered in balancing committee membership to provide equity. It is not expected that each member of a committee be a technical expert in all aspects of the committee's work but rather, that all can contribute to the committee's overall goals. II. TECHNICAL OVERSIGHT COMMITTEE (TOC), INITIATIVES OVERSIGHT COMMITTEE (IOC), AND OTHER COMMITTEES … E. Other Committees 1. The WRAP may establish other standing committees, forums or work groups. Membership on such standing committees, forums, or work groups shall consist of state and tribal representatives from the applicable region. 2. The committee shall extend membership to other regional stakeholders as appropriate. Members will be selected by the WRAP from letters of interest. Duration of the appointment shall coincide with the duration of the air quality issue. 3. The WRAP will appoint co-chairs of any standing committees. The cochairs of any standing committees established will be members of the Coordinating Group. Appendix A-7c. WRAP Report on Assessment of NOx/PM Strategies Appendix A-7 – Stationary Sources Arizona Regional Haze SIP Stationary Source NOx and PM Emissions in the WRAP Region: An Initial Assessment of Emissions, Controls, and Air Quality Impacts Final Report of the WRAP Market Trading Forum October 1, 2003 Western Governors’ Association 1515 Cleveland Place, Suite 200 Denver, CO 80202 NOTE: Section VI of this report is bound separately and available on the WRAP Web site at http://www.wrapair.org/forums/mtf/nox-pm.html PREFACE Regulatory Framework for Tribal Visibility Implementation Plans The regional haze rule explicitly recognizes the authority of tribes to implement the provisions of the rule, in accordance with principles of federal Indian law, and as provided by the Clean Air Act §301(d) and the tribal authority rule (TAR) (40 CFR §§49.1– .11). Those provisions create the following framework: 1. Absent special circumstances, reservation lands are not subject to state jurisdiction. 2. Federally recognized tribes may apply for and receive delegation1 of federal authority to implement CAA programs, including visibility regulation, or "reasonably severable" elements of such programs (40 CFR §§49.3, 49.7). The mechanism for this delegation is a tribal implementation plan (TIP). A reasonably severable element is one that is not integrally related to program elements that are not included in the plan submittal, and is consistent with applicable statutory and regulatory requirements. 3. The regional haze rule expressly provides that tribal visibility programs are “not dependent on the strategies selected by the state or states in which the tribe is located” (64. Fed. Reg. 35756), and that the authority to implement §309 TIPs extends to all tribes within the GCVTC region (40 CFR §51.309(d)(12)). 4. The EPA has indicated that under the TAR tribes are not required to submit §309 TIPs by the end of 2003. Rather, they may choose to opt-in to §309 programs at a later date (67 Fed. Reg. 30439). 5. Where a tribe does not seek delegation through a TIP, EPA, as necessary and appropriate, will promulgate a federal implementation plan (FIP) within reasonable timeframes to protect air quality in Indian country (40 CFR §49.11). EPA is committed to consulting with tribes on a government-to-government basis in developing tribe-specific or generally applicable TIPs where necessary (See, e.g., 63 Fed. Reg. 7263-64). The amount of modification, if any, needed for this report to fulfill tribal needs may vary considerably from tribe to tribe. The authors have striven to ensure that all references to tribes in the document are consistent with principles of tribal sovereignty and autonomy as reflected in the above framework. Any inconsistency with this framework is strictly inadvertent and not an attempt to impose requirements on tribes which are not present under existing law. Tribal Participation in the WRAP Tribes, along with states and federal agencies, are full partners in the WRAP, having equal representation on the WRAP Board as states. Whether Board members or not, it must be remembered that all tribes are governments, as distinguished from the “stakeholders” (private interest) which participate on Forums and Committees but are not eligible for the Board. 1 Tribes also possess a more fundamental source of authority to regulate their environments, based on their inherent authority as sovereign nations, which predates the formation of the United States. However, in the context of air pollution regulation and visibility planning in particular, tribal authority will more likely be based on delegation of federal authority. Despite this equality of representation on the Board, tribes are very differently situated than states. There are over four hundred federally-recognized tribes in the WRAP region, including Alaska. The sheer number of tribes makes full participation impossible. Moreover, many tribes are faced with pressing environmental, economic, and social issues, and do not have the resources to participate in an effort such as the WRAP, however important its goals may be. These factors necessarily limit the level of tribal input into and endorsement of WRAP products. The tribal participants in the WRAP, including Board members Forum and Committee members and co-chairs, make their best effort to ensure that WRAP products are in the best interest of the tribes, the environment, and the public. One interest is to ensure that WRAP policies, as implemented by states and tribes, will not constrain the future options of tribes who are not involved in the WRAP. With these considerations and limitations in mind, the tribal participants have joined the state, federal, and private stakeholder interests in approving this report as a consensus document. TABLE OF CONTENTS Section I: Executive Summary Prepared by WRAP Staff Section II: NOx and PM Emissions from Stationary Sources Prepared by WRAP Staff Section III: Nitrate and PM Ambient Concentrations Prepared by WRAP Staff Section IV: A Conceptual Model of Regional Haze in the West and the Role of Stationary Source NOx and PM Emissions Prepared by Armistead Russell, Georgia Institute of Technology Section V: Summary of Air Quality Modeling Results Prepared by WRAP Staff, the University of California at Riverside, and ENVIRON Corporation Section VI: Summary of Emission Controls Available for Large Stationary Sources of NOx and PM Prepared by Reaction Engineering Incorporated and Energy & Environmental Strategies Section VI Bound separately and available at http://www.wrapair.org/forums/mtf/nox-pm.html SECTION I: EXECUTIVE SUMMARY Background and Purpose The primary purpose of this report is to provide the information necessary for western states and tribes to fulfill the requirements of Section 309(d)(4)(v) of the U.S. Environmental Protection Agency’s (EPA) regional haze rule (40 CFR 51.309). Specifically, the rule states: Provisions for stationary source NOx and PM. The plan submission must include a report which assesses emissions control strategies for stationary source NOx and PM, and the degree of visibility improvement that would result from such strategies. In the report, the State must evaluate and discuss the need to establish emission milestones for NOx and PM to avoid any net increase in these pollutants from stationary sources within the transport region, and to support potential future development and implementation of a multipollutant and possibly multisource market-based program. The plan submission must provide for an implementation plan revision, containing any necessary long-term strategies and BART requirements for stationary source PM and NOx (including enforceable limitations, compliance schedules, and other measures) by no later than December 31, 2008. The regional haze rule provides the nine western states within the Grand Canyon Visibility Transport Region (GCVTR) an opportunity to submit state implementation plans (SIPs) containing policies and programs recommended in the final report of the Grand Canyon Visibility Transport Commission (June 1996). Such plans must be submitted by December 31, 2003. GCVTR states electing not to submit SIPs under Section 309 must submit SIPs under Section 308 of the regional haze rule in the 2005-07 time frame. Indian tribes have the option to submit tribal implementation plans (TIPs) under either section at any time. Moreover, the TIPs may include reasonably severable elements of the rule. A map of the WRAP region, mandatory federal Class I areas addressed by the regional haze rule, and WRAP state and tribal members is provided in Figure I-1. A major provision of Section 309 is the control of stationary source sulfur dioxide (SO2) emissions. The provision quoted above – for a report on stationary sources of NOx and PM – is to ensure that states begin the process of evaluating other pollutants from stationary sources. Hence, this report is meant as a starting point for a potentially multi-year process of evaluating stationary sources and designing further control strategies where appropriate. At a minimum, this process must include the determination of best available retrofit technology (BART) for certain sources1 and the resulting visibility improvements and may include an alternative (e.g., emissions trading) program achieving greater reasonable progress towards the national visibility goal of no man-made impairment. 1 BART-eligible sources are those which belong to one of 26 industrial categories, have the potential to emit at least 250 tons per year of a visibility-impairing pollutant, and were put into place between 1962 and 1977. I-1 Organization of Report This report is required for the GCVTR states choosing to submit SIPs under Section 309 of the region haze rule, but since all states must ultimately address stationary source NOx and PM emissions from BART-eligible and potentially other stationary sources, the scope of this report goes somewhat beyond the nine states in the GCVTR and the limited number of BART-eligible sources in the WRAP region. For example, the air quality modeling evaluates the impact of emission changes within the GCVTR, but at all Class I areas within the contiguous WRAP region. Also, emission control technologies evaluated in Section VI were chosen on the basis of source types throughout the WRAP region, which do not differ substantially from those types within the GCVTR. They were also chosen on the basis of all existing source types, not just BART-eligible source types, partly because sources eligible for BART as a result of pollutants other than SO2 have not yet been identified2 and partly because an alternative program to BART could apply to a much broader universe of sources. By extending the scope of this report beyond the nine GCVTR states and beyond the BART-eligible stationary sources, it not only becomes applicable to a wider range of WRAP members and potential control strategies but serves to coordinate regional development of such strategies. It is also a more cost-effective approach than dealing with the nine GCVTR states separately. As noted above, this report contains analyses and information to initiate a process for evaluating stationary sources of NOx and PM – a process required of all states and open to Indian tribes as well. The Executive Summary contains highlights of the report, but it is also where specific issues raised in Section 309(d)(4)(v), such as interpollutant trading, are directly and succinctly discussed. This is intended to help Section 309 states and tribes address the literal requirements of the rule. Table I-1 shows how analyses within this report were designed to address the specific requirements of the rule. Emissions data can be used to assess emission control strategies and to evaluate the need for milestones by illustrating the relative significance of different source categories to total NOx and PM emissions, both now and in the future. Ambient monitoring data can be used to assess emission control strategies by illustrating where and how much nitrate and primary PM may contribute to actual visibility impairment. The conceptual model is intended to support this entire assessment and to provide a common, scientifically-founded understanding of western haze and the role of stationary sources in anticipation of a multi-year assessment of their importance and control options. The conceptual model is intended to provide a more complete framework than what can be provided alone by the air quality modeling and other assessments. Air quality modeling is used in a “sensitivity capacity” to assess emission control strategies, their degree of visibility improvement, and the need for milestones to prevent any future increase in emissions. A summary of current NOx and PM control technologies and their costs, trends, and secondary and multi-pollutant impacts can be used to assess emission control technologies and the need for milestones to support multisource and multipollutant programs. This summary is also a useful starting point for addressing the BART requirements in Section 308 SIPs and Section 309 SIP revisions. All these analyses are expected to be updated and improved by the WRAP before such SIPs are adopted. 2 The full universe of BART-eligible sources does not need to be identified until SIPs and SIP revisions are due in 2005-08, although this identification process is expected to begin in 2003. I-2 Conceptual Model Air Quality Model Control Technologies Assess emission control strategies Ambient Data Requirements of 309(d)(4)(v) Emissions Data Table I-1. Analyses Contained in this Report and Their Relation to the Requirements in Section 309(d)(4)(v) of the Regional Haze Rule. X X X X X X X X X X Assess degree of visibility improvement that would result from such strategies Evaluate and discuss the need to establish milestones to avoid any net increase X Evaluate and discuss the need for milestones to support potential future development of multipollutant and multisource market-based programs X X Implementation plan revision by December 31, 2008 Finally, emissions in Alaska are not presented because resources did not permit examination of a second emissions inventory database, nor are air quality modeling results presented for Alaska because the visibility modeling system for Alaska is currently under development. However, ambient monitoring data for Alaska are presented, and the conceptual model and control technology information are applicable as well. Summary of Findings Analysis of current and future emissions, ambient monitoring data, and very limited modeling results indicates that stationary source emissions of PM probably cause less than 2 percent of the region’s visibility impairment, whereas stationary source NOx emissions result in nitrates3 that probably cause about 2 to 5 percent of the impairment on the Colorado Plateau4 and about 10 percent of the impairment in some areas of the Northern Plains, Pacific Northwest, and southern California. These findings may change as emission projections are updated and as ambient monitoring data from new sites is collected and analyzed, and especially as modeling capabilities are improved and as more data become available for the best and worst visibility days. 3 4 NOx emissions may also increase other PM species. Some of the 20 percent haziest days, however, are dominated by nitrate. I-3 Regardless of this or future regional technical analyses, the remedy embodied in reasonably attributable visibility impairment requirements under the regional haze rule is still available where BART-eligible sources of NOx and PM are found to have direct impact on specific mandatory federal Class I areas. Furthermore, when considering NOx and PM milestones, attention should be given to the reasonable progress goals in the regional haze rule, which generally entail steady and continuing emission reductions and no degradation on the best visibility days. Where stationary source NOx emission reductions are appropriate, substantial reduction may be feasible with commercially-available technologies for about $300 to $1,200 per ton. Assessment of Emission Control Strategies for Stationary Sources of NOx and PM Since this report is primarily a starting point for addressing stationary source NOx and PM emissions, the control of which would not be determined until the 2005-08 timeframe, specific emission control strategies including such elements as level of control, applicability, and emissions trading are not addressed. Rather, this report identifies significant issues in assessing and designing such control strategies and provides some preliminary emissions, monitoring, and modeling results. Stationary source NOx emissions comprise about 25 percent of the WRAP NOx emission inventory. One byproduct of NOx emissions is nitrate aerosols. As described in Section III, during the 20 percent worst days on the Colorado Plateau, nitrate aerosols are responsible for about 6 to 18 percent of the man-made visibility impairment, although on some of these days they are responsible for as much as 40 to 60 percent. At some sites in the Northern Plains, Pacific Northwest, and southern California, nitrate aerosols are responsible for about 40 percent of the man-made visibility impairment during the 20 percent worst days. Assuming the contribution of stationary sources to nitrate is roughly equal to their proportion of the NOx emission inventory, then stationary source NOx emissions might be expected to contribute to about 2-5 percent of the Plateau’s light extinction and to about 10 percent of the extinction in the Northern Plains, Pacific Northwest, and southern California. Potentially increasing these contributions is the fact that stationary sources have unique emission characteristics which may disproportionately impact visibility (e.g., stack heights, transport distances, and proximity to Class I areas). Also, NOx is known to influence the formation of non-nitrate secondary fine particles, to alter the characteristics of primary coarse particles, and its future significance may depend on future changes in sulfur and ammonia emissions. On the other hand, total NOx emission in the WRAP region are expected to decrease by over 25 percent,5 primarily as a result of federal controls on mobile sources, and NOx reductions may, in isolated instances, lead to local increases in nitrate concentrations. To determine the effectiveness of stationary source NOx controls, it is therefore important to have an air quality model that can account for the processes above. The WRAP’s current modeling system, while sufficient for analyzing the regional impact of some emission changes, is not predicting nitrate concentrations well enough to support a decision on whether or not 5 Future NOx emissions will, of course, depend on uncertain activity levels (e.g., oil and gas development) and regulatory developments (e.g., new source review reforms). I-4 stationary source NOx controls are an effective way at achieving reasonable progress – the results are simply too uncertain. Several improvements to the modeling system are underway, but until the model produces better nitrate results, other means of assessment will be necessary to determine the appropriate level of NOx control in future SIPs. Given the model’s current performance, its use in this report is limited to the summer months (July through September), when it is performing best for nitrate, but also when nitrate concentrations are lowest. Furthermore, its use is limited to two “sensitivity analyses” – a 50 percent stationary source NOx reduction and a 50 percent stationary source PM10 reduction. The purpose of the sensitivity analyses is to gauge how nitrate and other atmospheric constituents might respond to significant changes in emissions, albeit such responses may be conservative given the model’s limited application to the July – September time period. Results are summarized in the next part of this Executive Summary and discussed in more detail in Section V of the report. As advancements are made towards understanding the air quality impacts of stationary source NOx emissions, it is appropriate to investigate the potential level of control that can be achieved, and at what cost. Section VI of this report identifies 34 NOx control technologies. Most of these are commercially available, while others are near-available. Those for coal-fired boilers (by far the largest category of stationary source NOx emissions) typically achieve 30 to 50 percent NOx control at a cost of about $300 to $1,200 per ton.6 Actual costs and emission reductions are highly dependent on boiler type, vintage, and configuration, fuel burned, and existing controls. For these reasons, it is important to have recent, extensive, and reliable data on the emission source population, some of which are lacking in the WRAP inventory, such as current control information, utility boiler heat rates, information on the process producing the emissions (e.g., from natural gas compressor stations), and utilization rates (e.g., from industrial internal combustion engines). Future WRAP emission inventories should include such information. Visibility impairment may occur when a high portion of the NOx emissions are in the form of (or converted to) nitrogen dioxide gas (NO2). This may be important in urban hazes and in some coherent plumes, but is typically negligible for regional haze.7 For this reason, NO2 is not included in the light extinction budget in the EPA’s guidance for tracking reasonable progress. Stationary source PM10 emissions8 are currently 6 percent of the WRAP PM10 inventory and may grow slightly to 7 percent by 2018. However, the WRAP inventory does not yet include windblown fugitive dust emissions (currently under development), which will tend to decrease the apparent contribution of stationary source PM10 emissions. PM10 accounts for nearly all the man-made light extinction, but the amount attributable to primary stationary source emissions is difficult to determine. Since most of the coarse fraction (between 2.5 and 10 microns) is believed to be primary and only some of the fine fraction is believed to be primary, the percent of visibility impairment attributable to coarse particles should approximate the contribution of 6 One exception is selective catalytic reduction (SCR), which is capable of achieving 70 to 90+ percent control at costs of approximately $1,200 to $2,000 per ton. 7 See, for example, Watson J., Visibility: Science and Regulation, J. of Air and Waste Manage. Assoc. 52:628. 8 As explained in Section II of this report, the term “PM” used in Section 309(d)(4)(v) of the regional haze rule is construed as primary PM10 emissions. I-5 primary PM10 emissions from all sources. As shown in Section III, this is approximately 10 to 20 percent (on average) across most of the WRAP region, with generally lower percentages in the Pacific Northwest and higher percentages in the southeast part of the region. Assuming the contribution of stationary sources to ambient primary PM10 is roughly equal to their proportion of the PM10 emission inventory, then stationary source PM10 emissions might be expected to contribute to less than 2 percent of the region’s light extinction. Coupled with the fact that stationary source PM10 emissions are relatively well controlled in the West, there does not appear to be much potential in a stationary source PM control strategy for purposes of regional haze. PM10 emissions, however, appear to have a greater visibility impact per ton than NOx emissions, as shown in Section V. Also, some PM10 emission co-benefits may result from multi-pollutant technologies described in Section VI, so reductions in stationary source PM10 emissions could conceivably be part of a broader air quality management strategy and/or part of a broader strategy to achieve reasonable progress under the visibility regulations – e.g., to prevent degradation on the cleanest days. Finally, the appropriate level of stationary source NOx and PM control, if any, should be informed by a comprehensive assessment, which may include some non-visibility impacts (to the extent they can be estimated within WRAP resources and with the WRAP’s visibility-based tools) and the full costs and benefits of controls, not just those associated with facility compliance and visibility improvements. To this end, the WRAP is completing work on an economic analysis framework to conduct such analyses in a consistent and technically sound manner. Degree of Visibility Improvement Resulting from Emission Control Strategies for Stationary Sources of NOx and PM Due to the complex role of NOx emissions in the atmosphere, a regional-scale modeling effort is underway to more carefully assess the visibility improvement from potential control strategies. Given the model’s current performance, its application in this report is limited to the JuneSeptember timeframe – when nitrate performance is best, but also when nitrate concentrations are lowest – and it is only used in a “sensitivity analysis mode”, meaning two scenarios were modeled to gauge how nitrate and other atmospheric constituents might respond to significant changes in emissions: one in which emissions of NOx are reduced by 50 percent (412,000 tpy) from stationary sources in the GCVTR with emissions of NOx greater than 100 tpy, and an identical scenario for PM10 (98,000 tpy). Current modeling results indicate that the stationary source NOx and PM10 emission reductions described above would reduce regional haze (in Mm-1) by 0.5 percent and 0.4 percent, respectively, when averaged across all sites in the GCVTR over the June-September time period, although some areas would see an improvement of 2 to 5 percent on some days.9 On a purely ton-per-ton basis, reductions in stationary source PM10 emissions appear to yield greater regional haze benefits than reductions in NOx emissions, since they produced almost the same visibility benefit at one-fourth the emission change. 9 These results are similar to the more general assessment made in Section IV (see page IV-21). I-6 The NOx emission reductions had the greatest impact in southern CA, where ammonium nitrate concentrations in Class I areas are predicted to decrease by 0.15 to 0.25 ug/m3. A second area of reductions is predicted in the central-east Rocky Mountains, especially in north-central CO. Although the reductions are not as large as in southern CA (0.04 to 0.11 ug/m3), they are larger than average across the domain and exhibit the largest percentage reduction (10 to 20 percent). It is interesting to compare these results with those simulating the effects of the SO2 backstop emissions trading program, or Annex. In the case of the Annex, an SO2 emission reduction of 15 percent (132,000 tons) in the GCVTR produced a sulfate reduction of 4 percent averaged across all Class I areas in the GCVTR on the 20% worst modeled days. In the case of the NOx sensitivity run, a NOx emission reduction of 15 percent (412,000 tons) in the GCVTR produced a nitrate reduction of 5 percent averaged across all Class I areas in the GCVTR on the JulySeptember modeled days. The nitrate reduction does not produce as much visibility benefit at most Class I areas because its concentrations are much smaller than the sulfate concentrations, but the response of nitrate to NOx reductions is similar in proportion to the response of sulfate to SO2 reductions. NOx changes appear to have very little effect on aerosol concentrations beyond changes in nitrate. Other species that could be indirectly affected – e.g., ozone concentrations and subsequent oxidation of SO2 and organic gases into the particulate phase – do not appear influenced by the levels of NOx reductions (16 percent of the total inventory) assumed in this analysis. The PM10 emission reductions had a maximum impact of about 0.1 to 0.5 ug/m3, or about 4 to 8 percent. Compared to the NOx reduction scenario, reductions in ambient PM10 are more dispersed, with a greater number of local maximums. This may reflect the fact that there are a fewer number of large PM10 sources than large NOx sources and that much of the PM10 emissions are coarse particles, with shorter transport distances. All modeling results in this report are subject to change after the modeling improvements described in Section V are implemented. Results may also change when compiled for the best and worst visibility and nitrate days throughout the year, as opposed to a three-month summer average. For reasons described in Section V, the three-month summer average probably tends to reduce the apparent impact of emission changes. The Need to Establish Milestones to Avoid Any Net Increase in NOx and PM Emissions from Stationary Sources Sensitivity modeling was also done to evaluate the impacts of a 25 percent simultaneous increase in stationary source NOx and PM10 emissions. The increase in nitrate formation was approximately half the magnitude of the decrease resulting from the NOx reduction scenario. However, the increase in PM10 (nitrates and primary particulates) and visibility impairment were about the same in the 25 percent increase scenario as in the two 50 percent decrease scenarios because both pollutants were increased simultaneously. I-7 The need to establish milestones to avoid any net increase in NOx and PM emissions from stationary sources should be determined when more complete and accurate modeling results (and ambient data analyses) are available, prior to submittal of the Section 309 SIP revisions in 2007-08. In addition to the modeling results per se, consideration should be given to meeting the reasonable progress goals of the regional haze rule, which generally imply a steady and continuous reduction in emissions and a prevention of degradation on the best visibility days. The Need for Milestones to Support Potential Future Development of Multipollutant and Multisource Market-Based Program Milestones are not absolutely necessary to support potential multipollutant and multisource market-based programs. For example, a group of sources could theoretically comply with an SO2 milestone by reducing emissions of other pollutants, and/or in other sectors, for which no milestones exist. Regardless, the key issues raised by such programs do not involve the milestones as much as the uncertainties associated with such emissions trading. As discussed in Section IV, there are a number issues that must be addressed. Most of these relate to the visibility-improvement value of eliminating a ton of emissions. Different pollutants have different impacts on visibility on a per ton basis. Establishing an “equivalency ratio” to allow X tons of one pollutant to be reduced in lieu of Y tons of another would require significant analysis, and the certainty of such values may be suspect (especially for NOx) or insufficient to ensure a specific level of visibility improvement. Moreover, the equivalency ratio between two pollutants may vary across the region, between seasons, and possibly over time as the composition of the atmosphere changes. These same uncertainties (involving trades among pollutants) also pertain to trades among a single pollutant, most notably NOx, as nitrate concentrations are highly variable by season and location. Trading across emission source categories poses a couple of additional issues. First, all categories would have to have sufficient emissions monitoring to validate emission credits, and monitoring of non-stationary sources is generally less accurate and verifiable than monitoring of stationary sources. Second, concentrated emissions from stacks may have different impacts than diffuse emissions at ground-level. The uncertainties identified above could be reduced through further research, and the remaining uncertainties could be further addressed by limiting the emission trading markets to certain subregions, pollutants, or seasons where the equivalency ratios are fairly certain and stable. However, such market restrictions could limit the economic benefits the market is intended to provide. In short, some level of multipollutant and/or multisource market based program could be a feasible way of meeting the long-term national visibility goal, and several of the technologies described in Section VI of this report are capable of multipollutant reductions, but substantially more research should be performed before committing to such programs, especially in the 2007-08 timeframe. I-8 Figure I-1. Map of the WRAP Region, Members, and Mandatory Federal Class I Areas. I-9 SECTION II: NOx AND PM EMISSIONS FROM STATIONARY SOURCES Data Sources The data presented in this section are based on “Version 1” of the WRAP stationary source emission inventory, downloaded from the WRAP website in June 2002 (filename wga_pt96.dbf). A second version of the inventory was released in October 2002, which contained a couple dozen corrections to point source coordinates, stack parameters, and source classification codes among the 214,000 records in the database. There were also some corrections to the NOx and PM emissions, which reduced the regional point source totals by two percent and six percent, respectively. A third version of the inventory was released in March 2003. This version contained minor NOx and PM emission changes in Pima and Navajo Counties (less than one percent of state-wide point sources) and NOx emission reductions in Nevada amounting to a 4,400 ton (or nine percent) decrease in the state-wide point source inventory. Discrepancies noted in Maricopa, Pima, and Pinal Counties by stakeholders in Arizona have not yet been incorporated into the WRAP database. For the purposes of this regional-scale characterization of NOx and PM sources, the changes made to Version 1 of the stationary source inventory are essentially insignificant. The analysis, therefore, was not repeated. However, the analysis presented in Section VI is based on the most recent inventory since the analysis was begun after the Version 3 was available. This may cause slight discrepancies between the data presented here and in Section VI, but the conclusions are unaffected. The term “PM” used in Section 309(d)(4)(v) of the regional haze rule has been construed in this report as primary PM10 emissions. Precursor emissions are not considered “PM” because they are explicitly referenced where appropriate throughout the rule, as is done with NOx in 309(d)(4)(v). PM10 was chosen over PM2.5 because PM10 includes PM2.5 and because all particles less than 10 microns have visibility impairing attributes. Moreover, many of the PM2.5 emission estimates are derived from PM10 emission factors as opposed to direct PM2.5 measurements – i.e., a certain fraction of the PM10 is assumed to be PM2.5. Emissions Summary Table II-1 provides a summary of air pollutant emissions in the 13-state contiguous WRAP region (including Nevada but not Alaska). NOx emissions from stationary sources are expected to increase slightly, but due to decreases from other sources, their percentage of the total inventory is expected to grow from 22 percent to 33 percent to become the single largest source category. Stationary source PM10 emissions appear less important than NOx emissions, but they may contribute more to haze on a per ton basis, partly because not all NOx emissions are converted to particles and partly because stationary source PM emissions contain some elemental carbon, which is a highly-efficient light absorber. Compared to other source categories, stationary sources do not emit a large amount of PM10, but their emissions may contribute more to haze on a per ton basis than other source categories because they emit particles primarily in II-1 the fine mode (less than 2.5 microns) and often through stacks, making them more likely to be transported to Class I areas. Future work should examine available information on the dispersion characteristics, size distribution, and chemical and optical properties of primary PM emissions from stationary sources relative to other types of sources. Table II-1. Air Pollutant Emissions in the 13-State WRAP Region. 1996 NOx Emissions Category Point Area On-Road Mobile Off-Road Mobile Wildfire Prescribed Fire Agricultural Fire Paved Road Dust Unpaved Road Dust Total * Not available tons 1,059,985 352,623 1,755,573 1,368,663 166,703 16,688 * 0 0 4,720,236 % 22% 7% 37% 29% 4% 0% * 0% 0% 100% 2018 PM10 tons % 196,005 6% 1,921,389 54% 59,098 2% 103,069 3% 755,537 21% 50,057 1% * * 91,322 3% 370,762 10% 3,547,239 100% NOx tons 1,118,460 449,559 485,270 950,414 59,641 338,627 3,504 0 0 3,405,475 % 33% 13% 14% 28% 2% 10% 0% 0% 0% 100% PM10 tons % 247,071 7% 1,981,060 54% 46,139 1% 91,412 2% 270,307 7% 525,393 14% 8,894 0% 165,106 5% 326,042 9% 3,661,423 100% Figure II-1 shows the location and relative magnitude of stationary source NOx emissions in the WRAP region with emissions of NOx greater than 100 tons per year (tpy) on a plant-wide basis. The WRAP 1996 inventory contains over 6,700 point sources of NOx. Approximately 11 percent of these plants (763) emitted 100 tpy or more of NOx and were responsible for 94 percent of total stationary source NOx emissions. Approximately 150 of the plants are electric power plants. Figure II-2 shows the location and relative magnitude of stationary source PM10 emissions in the WRAP region with emissions of PM10 greater than 100 tpy on a plant-wide basis. The WRAP 1996 inventory contains over 6,500 point sources of PM10. Approximately 5 percent of these (338 plants) emitted 100 tpy or more of PM10 and were responsible for 82 percent of total stationary source PM10 emissions. Figures II-3 and II-4 identify and compare emissions from the major stationary source categories of NOx and PM10, respectively. External combustion boilers (utility and industrial) are the largest source categories for both NOx and PM10. Industrial internal combustion engines (mostly natural gas fired) is another substantial source of NOx emissions. This category may warrant more attention since it is not inventoried with the same rigor as electric utility sources. The major source categories of PM10 are more diverse in character than those for NOx, including such broad categories as mineral products, chemical manufacturing, and primary metal production. This part of the inventory may also warrant further investigation since many of the emissions might be fugitive. Categorization of fugitive emission, in addition to source classifications, may vary across states. Further information on stationary source emissions, especially on the largest sources (boilers and internal combustion engines), is provided in Section VI. II-2 Figure II-1. Stationary Source NOx Emissions > 100 tpy in the WRAP Region (1996). II-3 Figure II-2. Stationary PM10 Emissions > 100 tpy in the WRAP Region (1996). II-4 Figure II-3. Categorization of Stationary Source NOx Emissions > 100 tpy in the WRAP Region (1996). Sub/Bituminous Coal Lignite Utility Boilers Natural Gas Distillate Oil (diesel) Utility ICEs Natural Gas Industrial ICEs Natural Gas Sub/Bituminous Coal Distillate Oil Industrial Boilers Wood/Bark Waste These sources comprise 91% of the emissions > 100 tpy Natural Gas Cement Manufacturing Industrial Processes Natural Gas Production Process Heaters (petro) 0 50,000 100,000 150,000 200,000 250,000 Emissions (tpy) II-5 300,000 350,000 400,000 450,000 Figure II-4. Categorization of Stationary Source PM10 Emissions > 100 tpy in the WRAP Region (1996). Sub/Bituminous Coal Utility Boilers Lignite Wood/Bark Waste Industrial Boilers Sub/Bituminous Coal Coal Mining and Handling Nonmetallic Minerals Mining Mineral Products Magnesium Carbonate Chemical Manufacturing Not Classified Metal Mining (General) These sources comprise 78% of the emissions > 100 tpy Iron Production Gold Primary Metal Production Copper Smelting Not Classified Sulfate (Kraft) Pulping Industrial Processes Misc. Manufacturing 0 5,000 10,000 15,000 20,000 Emissions (tpy) II-6 25,000 30,000 35,000 SECTION III: NITRATE AND PM AMBIENT CONCENTRATIONS Figures III-1 through III-11 show spatial patterns of ammonium nitrate (NH4NO3) and PM and historical trends in PM at IMPROVE monitoring sites in 1996 and 2001. The maps and data were downloaded from the VIEWS website (http://vista.cira.colostate.edu/views) on May 20, 2003. At that time, maps were only available for annual and seasonal averages, but some are now available for the best and worst visibility days. Hence, all the maps in this section except one indicate annual averages. Also, because the legends are auto-scaled, they are not the same in each map. For example, the value indicated by a yellow contour in Figure III-1 (1996) is not the same as the value indicated by a yellow contour in Figure III-2 (2201). IMPROVE sites are located in rural settings, typically within Class I areas. They are not representative of more heavily polluted urban areas and tend to represent air quality at regional scales. Due to the size of the IMPROVE monitoring network, the maps for 1996 include data from less than a third of the western Class I areas. The maps for 2001 include data from about two-thirds of the western Class I areas, and additional monitors have been established since then. Figures III-1 and III-2 show the annual average NH4NO3 concentrations in 1996 and 2001, respectively. Concentrations are typically less than 0.6 ug/m3, with some areas in southern CA and the Columbia River Gorge exceeding 1.5 ug/m3. Figures III-3 and III-4 show the percent of aerosol-caused10 annual average light extinction due to NH4NO3 in 1996 and 2001, respectively. This percent is typically less than 14, with some higher areas in the Pacific Northwest and Northern Plains, and especially in southern CA (exceeding 20 percent). Since some aerosols – principally organic carbon and “soil” and “coarse” aerosols – have substantially strong natural sources, the percent contribution of NH4NO3 to man-made haze is somewhat greater than indicated in Figures III-3 and III-4. A rough estimate of the contribution to man-made impairment can be obtained by assuming half the organic carbon, soil, and coarse aerosols are naturally caused. Removing these natural contributions from the light extinction budgets would raise the percent contribution of NH4NO3 by approximately 20 percent in each of the regions noted above (Colorado Plateau, Pacific Northwest, Northern Plains, and southern California).11 For example, where NH4NO3 may contribute to 15 percent of the aerosol-caused light extinction in these areas, it would contribute to about 18 percent of the man-made light extinction. Data recently provided on the VIEWS website indicates that the percent contribution of NH4NO3 to light extinction on the 20 percent worst days, as shown in Figure III-5, is slightly greater than the percent contribution on average, as shown in Figure III-4. Moreover, a cursory examination of daily data collected on the Colorado Plateau in 2001 indicates that some of the 20 percent worst days are dominated by NH4NO3. Some examples are provided in Table III-1. Such episodes should be quantified and studied more thoroughly in future WRAP work. 10 Aerosol-caused light extinction excludes natural (Rayleigh) scattering by air molecules. See Table 3.3 in Malm, William C. et al., Spatial and Seasonal Patterns and Temporal Variability of Haze and Its Constituents in the United States, Colorado State University, May 2000. 11 III-1 Table III-1. A Sample of Hazy Days in 2001 Dominated by NH4NO3 on the Colorado Plateau. Class I Area Date a Bryce Canyon 01/16/01 01/28/01 Light Extinction (Mm-1) 35 28 Canyonlands 01/04/01 01/19/01 01/22/01 23 31 33 NH4NO3 Contribution 55 % 49 % 55 % 48 % 55 % San Pedro 2001 Average Light Extinctiona (Mm-1) 16 2001 Average NH4NO3 Contribution 11 % 14 15 % 01/07/01 16 50 % 11.5 02/09/01 14 31 % 12/21/01 13 36 % a Over and above natural (Rayleigh) scattering by air molecules (10 Mm-1). 10 % Finally, NH4NO3 exhibits a strong seasonal pattern. When averaged across the 32 IMPROVE sites operating in 1996-1999, the light extinction due to NH4NO3 is about 10 percent on an annual basis and about 17 percent in the winter. Figures III-6 and III-7 show the annual average PM10 concentrations in 1996 and 2001, respectively. Specifically, the values are reconstructed total mass – that is, speciated fine mass plus gravimetrically-determined coarse mass (PM10 - PM2.5). (Gravimetric PM10 was not available from the VIEWS website.) PM10 concentrations are typically below 8 ug/m3, with some areas in the Columbia River Gorge, Northern Plains, and southern CA exceeding 10 ug/m3. Figures III-8 and III-9 show the percent of aerosol-caused annual average light extinction due to coarse particulate matter (between 2.5 and 10 microns) in 1996 and 2001, respectively. Since most of the coarse fraction is believed to be primary and only some of the fine fraction is believed to be primary, the percent of visibility impairment attributable to coarse particles should approximate the contribution of primary PM10 emissions from all sources to visibility impairment. As shown in the figures, this is approximately 10 to 20 percent across most of the WRAP region, with generally lower percentages in the Pacific Northwest and higher percentages in the southeast part of the region. Figure III-10 shows trends in (gravimetric) PM10 concentrations during average visibility days at 27 western IMPROVE sites. Data for the best and worst visibility days are available, but only data for average visibility days are shown for comparability with the maps in Figures III-1 through III-7. The values shown are 5-year rolling averages, meaning that the value shown for 1993 represents data collected from 1989-1993. The full names of the sites shown in Figure III10 are provided in Table III-2. III-2 At most sites, there appears to be a gradual decline in PM10 concentrations on days with average visibility, with exceptions at Chiricahua, Grand Canyon, and Guadalupe Mountain. On the worst visibility days, however, there is less of a decline, if any, at most sites. Compare, for example, the trend at the sites shown in Figure III-11 with the first trend chart shown in Figure III-10. Note that the trends, even when averaged over 5-year periods, can sometimes be affected by one or two extremely high events, typically associated with wildfires or dust storms. Trends in NH4NO3 concentrations and the percent of light extinction due to NH4NO3 are not available because of a measurement bias in data collected prior to June 1996. These data, however, are sufficient for showing the spatial patterns in Figures III-1 through III-7. III-3 Figure III-1. Annual Average NH4NO3 Concentrations at IMPROVE Sites (1996). Figure III-2. Annual Average NH4NO3 Concentrations at IMPROVE Sites (2001). III-4 Figure III-3. Percent of Annual Average Aerosol Light Extinction Due to NH4NO3 at IMPROVE Sites (1996). Figure III-4. Percent of Annual Average Aerosol Light Extinction Due to NH4NO3 at IMPROVE Sites (2001). III-5 Figure III-5. Percent of Aerosol Light Extinction Due to NH4NO3 at IMPROVE Sites on the 20 Percent Worst Days (2001). III-6 Figure III-6. Annual Average PM10 Concentrations at IMPROVE Sites (1996). Figure III-7. Annual Average PM10 Concentrations at IMPROVE Sites (2001). III-7 Figure III-8. Percent of Annual Average Light Extinction Due to Coarse Particulate Matter at IMPROVE Sites (1996). Figure III-9. Percent of Annual Average Light Extinction Due to Coarse Particulate Matter at IMPROVE Sites (2001). III-8 Table III-2. Name of IMPROVE Sites Shown in Figure III-9. Code BADL BAND BRCA BRID CANY CHIR CRLA DENA GLAC GRBA GRCA GRSA GUMO JARB Site Name Badlands Bandalier Bryce Canyon Bridger Canyon Lands Chiricahua Crater Lake Denali Glacier Great Basin Grand Canyon Great Sand Dunes Guadalupe Mountain Jarbidge Code LAVO MEVE MORA PEFO PINN PORE REDW ROMO SAGO TONT WEMI YELL YOSE Site Name Lassen Volcanic Mesa Verde Mount Ranier Petrified Forest Pinnacles Point Reyes Redwood Rocky Mountain San Gorgonio Tonto Weminuche Yellowstone Yosemite Figure III-10. Trends in PM10 Concentrations at Western IMPROVE Sites on Days with Average Visibility. 3 PM10 on Days with Average Visibility (ug/m ) 14 12 10 BADL BAND BRCA BRID CANY 8 6 4 2 0 1993 1994 1995 1996 III-9 1997 1998 1999 3 PM10 on Days with Average Visibility (ug/m ) 14 12 10 CHIR CRLA DENA GLAC GRBA 8 6 4 2 0 1993 1994 1995 1996 1997 1998 1999 PM10 on Days with Average Visibility (ug/m3) 14 12 10 GRCA GRSA GUMO JARB LAVO 8 6 4 2 0 1993 1994 1995 1996 III-10 1997 1998 1999 3 PM10 on Days with Average Visibility (ug/m ) 25 20 15 MEVE MORA PEFO PINN PORE 10 5 0 1993 1994 1995 1996 1997 1998 1999 PM10 on Days with Poor Visibility (ug/m3) 30 25 20 BADL BAND BRCA BRID CANY 15 10 5 0 1993 1994 1995 1996 III-11 1997 1998 1999 Figure III-11. Trends in PM10 Concentrations at Western IMPROVE Sites on Days with Poor Visibility (Worst 20 Percent). PM10 on Days with Average Visibility (ug/m3) 25 20 REDW ROMO SAGO TONT WEMI YELL YOSE 15 10 5 0 1993 1994 1995 1996 III-12 1997 1998 1999 SECTION IV: A CONCEPTUAL MODEL OF REGIONAL HAZE IN THE WEST AND THE ROLE OF STAITIONARY SOURCE NOx AND PM EMISSIONS Introduction The objective of this report is to provide a foundation for better understanding the dynamics of PM in the West, with particular attention to the nitrate and primary component that may be due to point source emissions. Further, the report explores how stationary source NOx and primary PM controls might impact FPM levels. As part of that, the utilization of a trading system is discussed. The report sets up a detailed framework to understand the issues by developing a conceptual model of PM formation, atmospheric dynamics, and impacts in the West. Next, the report discusses the likely effectiveness of PM and NOx controls on PM levels in the West and the relationship with visibility. This section also deals with issues involving emission trading. The final two sections discuss potentially useful computer simulations and a summary. Overview of PM in the West The area covered by the Western Regional Air Partnership (WRAP) includes a large fraction of the continental United States. In an air quality management context, this area has very different air quality characteristics. In part, this is due to the diversity in the source characteristics of the region, ranging from large coastal California cities to very sparsely populated and isolated regions. In the former, the emissions are dominated by mobile sources, disperse human activities, and a variety of industries. In the latter, natural sources (e.g., fire, dust, and biogenic emissions) and large point sources (e.g., electricity generating units) can dominate. Similarly important are the meteorological and topographical differences: e.g., rainy and cool coastal areas in the Northwest, dry mountainous regions further inland, and deserts in the Southwest. Pollutant levels and characteristics vary accordingly. Not only do the relative levels of pollutants vary, but the composition and source contributions change as well. This is especially seen in the particulate matter composition. In Los Angeles, nitrate (and the associated ammonia) is a major contributor. Outside of California, nitrate is usually a relatively minor contributor, though the Columbia Gorge and Seattle areas find somewhat elevated levels (Malm et al., 2003). Unlike gases, particulate matter is characterized not only by its composition, but by the particle size as well. From a regulatory standpoint, particulate matter is divided in to three fractions: fine, coarse and very coarse. To a degree, these capture how the particulate mater size distribution is considered from a scientific perspective, which is broken in to four modes of ascending size: nucleation, Aitken, accumulation and coarse modes. The nucleation mode is the very fine fraction where new particles are formed from nucleation of vapors. Recently, as part of the Supersite experiments, regional nucleation events have been seen. These particles then grow into the Aitken mode, which also contains primary emissions from combustion sources, and finally the accumulation mode. The accumulation mode is aptly named as the smaller particles grow in to this mode, but the growth out of accumulation mode particles into the coarse mode is very slow. Recent interest has grown over another possible division of PM: ultrafines (having IV-1 particle diameters less than about 0.1 um). There is relatively less information about ultrafine PM. Fine particulate matter (FPM) is often measured as PM2.5, or particulate matter with an aerodynamic diameter less than 2.5 micrometers (um). Some measurements of FPM have used other cut points, but there is a natural cut point at 2.5 um between the accumulation and coarse modes. On a mass basis, FPM is dominated by PM in the accumulation mode. Thus, coarse particulate matter is the fraction with particle diameters greater than 2.5 um. Given the historical measurements of PM10, coarse PM is often taken as the fraction between 2.5 and 10 um. The fraction above 10 um can be considered as very coarse, and is included (along with the other fractions) in total suspended particulate matter (TSP) measurements. The reasons for using these ranges have to do with the somewhat distinct dependence of the various size fractions on source, their atmospheric dynamics and impacts. Also, if one looks at a size distribution of PM, these modes become apparent. Characteristics of the coarse fraction are that the particles are mechanically generated (e.g. from road dust, construction, mining, etc.) and have relatively shorter atmospheric lifetimes due to settling and deposition, particularly for the very coarse particles. FPM can be mechanically generated (FPM can be present as the tail end portion of emissions that are mostly coarse) or from chemical conversion (SO2 oxidation to sulfate, combustion generation of soot, etc.), the latter often dominating. FPM also has a longer lifetime in the atmosphere as it deposits relatively slowly, though rain can rapidly remove much of the FPM. Ultrafines are due to emissions from combustion sources and chemical reactions in the atmosphere. Like FPM, ultrafines deposit slowly, but have a limited atmospheric lifetime as ultrafines because they grow due to condensation and coagulation. While size differences are important, so are species differences. Sulfate is almost solely a secondary species, formed from the oxidation of SO2 (e.g., from coal-fired EGUs and other combustion processes). This may take place in the gas phase or from heterogeneous reactions. Sulfate is found in the fine fraction. Sulfate tends to be one of the largest components of FPM in the rural West, and still a major fraction in urban areas. Average levels are about 1 ug/m3 in rural western areas. Nitrate is also a secondary component, resulting from the oxidation of NOx to form nitric acid gas, which then undergoes gas-to-particle conversion. NOx emissions are dominated by combustion sources, though there is a small fraction from biogenic emissions. Nitrate is also primarily in the FPM range, though tends to have a somewhat larger average particle diameter than the sulfate. A fraction of the nitrate is found in the coarse mode, indicative of gaseous nitric acid reacting with preexisting CPM (Malm et al., 2003). In the West, typical levels of measured nitrate outside of and not downwind of urban areas and central California tend to be low, averaging well less than 1 ug/m3. In the Los Angeles basin, nitrate levels can exceed 25 ug/m3, and significantly impact areas downwind. Care should be taken in interpreting measured nitrate levels as the techniques used are subject to artifacts (both positive and negative). Organic carbon (OC) is the most complex part of the PM in many ways. First, it is comprised of many different species. Further, it can be primary or secondary, and biogenic and anthropogenic in origin. Again, OC is primarily FPM. Levels are highest in the cities or in areas with biomass burning (e.g., due to wild or planned fires), and there is growing evidence of the importance of secondary OC (Brown et al., 2000). IV-2 Elemental carbon (EC), or black carbon, is due to incomplete combustion, and appears to be primarily from wood burning and diesel vehicle emissions, though other sources contribute, and the actual fraction due to diesel vehicles is under study. Given the sources, EC is highest in urban areas, and a relatively small component of FPM in rural locations. While small on a mass basis, EC does absorb light, so can contribute more significantly to visibility degradation. Metals, metal oxides and other crustal materials are due to a wide variety of sources, largely wind blown dust, as well as combustion, cement manufacture, etc. These are largely in the coarse mode, though a fraction is found as FPM, generally as the tail end of the size distribution of the coarse PM, or from combustion sources. In the non-coastal states of the West, the soil fraction is between about 20-30% of the FPM (Malm et al., 2003). FPM has come to attention as an important fraction of the total particulate matter because of its potential impacts. FPM has been suspect of impacting human health, and recent and continuing studies tend to provide further support. (Less information is available for ultrafines). FPM also exists in a size range (e.g., similar to the wavelength of visible light) that effectively scatters and absorbs light, decreasing visibility, which is of particular concern in the West with its many national parks, forests and wilderness areas. Coarse particulate matter is of less concern (though still some) due to its shorter lifetimes, apparently reduced health effects and it is less effective, on a mass basis, of scattering light. FPM levels in the West go from very low, with some of the lowest annual averages found in the US, to very high, with the Los Angeles area experiencing some of the highest. Other areas in the West experience isolated events of high PM (e.g., due to dust storms and fires) but annual average levels tend to be low. In much of the West and other parts of the country, the FPM is dominated by organic carbon and sulfate, while nitrate is typically a more minor constituent. While levels of these components, as well as FPM in general, are usually lower than in the east, the sources appear to be similar: sulfate comes from fuel combustion, particularly coal fired power plants and organic carbon comes from biomass burning and secondary formation. Of interest, recent results from the BRAVO study using molecular markers (Brown et al, 2002) suggest that a significant fraction of the organic FPM is secondary, as do similar studies in the Southeast. Carbon 14 dating of the organic matter in the Southeast (Edgerton, 2002) further suggest that the secondary organic is biogenic, which, given the emissions in the Big Bend area, would likely be the case there. Unlike most other areas, in Los Angeles and the Central Valley of California nitrate is a significant contributor, along with organic carbon and some sulfate. Literature Review Particulate matter dynamics has been an on-going research topic for decades. In-depth treatments of atmospheric particulate matter are contained in Seinfeld and Pandis (1998) and Friedlander (1977). The impact of PM on visibility has likewise been studied for years, with early work by van de Hulst (1957), and on-going study from the IMPROVE (Interagency Monitoring of Protected Visual Environments) program begun in 1985 (e.g., http://vista.cira.colostate.edu/improve/, and Malm, 2000, and references there in). Early studies IV-3 of nitrate dynamics and response to emissions controls include Stelson and Seinfeld (1982) and Russell and Cass (1984). In the WRAP area, particulate matter studies have been conducted for years. One could group them in to urban vs. pristine area studies, or a second split could be California studies and the rest of the west. The urban vs. pristine area consideration is typified by studies with different considerations, e.g., in urban areas health and attaining the National Ambient Air Quality Standards are often the drivers, while in pristine areas, visibility is of primary importance. The latter distinction, between California and other areas in the west, is made on a couple of bases. First, California has been very active in conducting air quality studies, in part because of the severe air quality problems in that state. Second, as presented in the regional conceptual model discussion below, particulate matter in regions in California is compositionally distinct from what is found over much of the West. Outside of California, the primary information that is available concerning PM in the West is derived from the IMPROVE program (e.g., Malm, 2000), and a number of studies focusing on specific areas. IMPROVE is an ongoing study of visibility in Class I areas in the U.S. most notably national parks. Amongst its objectives are to monitor the composition of particulate matter in protected environments and identify sources. Other, more regionally focused studies include the Big Bend Regional Aerosol and Visibility Observational (BRAVO) study (see Green et al., 2000, Brown et al., 2002) those associated with the Grand Canyon and Colorado Plateau (e.g., Grand Canyon Visibility Transport Commission, 1996 and project MOHAVE: Lowenthal et al., 2000), Mt. Zirkel (e.g., Watson et al., 2001), the Denver Brown Cloud, which included the Northern Front Range Air Quality Study (NFRAQS) (e.g., Watson et al., 1998). The Grand Canyon studies were directed primarily at assessing how nearby power plants (in particular, the Navajo Generating station) impact visibility in areas on the Colorado Plateau, which includes a number of Class I areas, including the Grand Canyon, which had experienced days with decreased visibility. BRAVO is assessing the sources of particulate matter and visibility degradation in the Big Bend area of Texas, and NFRAQS studied visibility in the area around Denver. While not focused on PM in the West, the Southern Appalachians Mountains Initiative (SAMI) study (SAMI, 2002) is relevant here because it addressed many of the same issues, except for the focus on Class I areas in the southeastern United States. Within California, a number of programs are available for providing information on particulate matter in various regions. First, a number of Class I areas in the state do have IMPROVE monitors, which provide both a long term record of PM composition, as well as a means of comparing, directly, levels in California with those in other states. In addition, California has conducted a number of additional, intensive efforts, most notably in the Los Angeles area and the Central Valley. In the Los Angeles (or South Coast) Basin, two studies are of particular note: the Southern California Air Quality Study (SCAQS) and the Southern California Ozone Study, 1997 (SCOS97). There have been a number of additional studies as well, notably those by Cass and coworkers (e.g., Hildemann et al., (1984); Gard et al., 1998), and the current studies associated with the Supersite (e.g., Sioutas et al., 2003). In the Central Valley, the San Jaoquin Valley/Atmospheric Utility Signature Prediction Experiment (SJV/AUSPEX), the California Regional Particulate Matter Air Quality Study (CRPAQS) and the Fresno Supersite are providing IV-4 detailed information on the air quality and sources in that region. The two Supersite studies, however, are more focused on urban air quality, and less focused on visibility in protected areas. A number of publications and reports discuss the results of the IMPROVE program, documenting the composition and trends and their relationship to visibility. A recent manuscript by Malm et al. (2003) presents the annual average fine particulate matter composition in each of 30 IMPROVE regions. In general, sulfate levels in the West are significantly below those in the East. Ammonium nitrate is high in southern California and the Lower Central Valley, with very low concentrations most other locations in the West (generally less than 0.5 ug/m3 except in isolated spots, Malm et al, 2003). It should be noted that ammonium nitrate is actually not measured, but inferred from the nitrate measurements. As they note, nitrate can also be found in other forms, some of which are thermally stable (e.g., from the reaction of nitric acid with soil or sea salt, Malm et al., 1994; Gard et al., 1998 ). Organic carbon, regionally, typically runs between 0.5 and 2 ug/m3. Elemental carbon levels are low, typically below 0.5 ug/m3 on average, but can be an important component in terms of visibility reduction. A recent trends report from IMPROVE (Malm, 2000, also see Sisler et al., 2000 and Malm et al., 2002) shows that trends in PM levels are mixed throughout the West. For example, Sisler et al., (2000) found that of the western sites where a significant trend was found, not quite two thirds reported improvements. In some cases, decreases of one component (e.g., sulfate) were off set by another (e.g., organic carbon), as found at Jarbridge Wilderness area. At the Guadalupe Mountains NM, organics are going down, but nitrate and fine soil are going up, with no real change in visibility. In the Mt. Zirkel Visibility Study (Watson et al., 2001), the major components that impaired visibility were found to be sulfate, organic carbon and crustal material, similar to the results form IMPROVE monitors in the region. Nitrate was a small contributor. Greater amounts of nitrate were found during the NFRAQS study, presumably because of the more concentrated sources of oxidized nitrogen in an urban area, and the proximity of confined animal operations. Given the use of regional PM modeling, it is instructive to compare the modeling conducted here with similar studies, in particular BRAVO and SAMI, as well as other applications of PM regional models. In the SAMI study, the Urban-to-Regional, Multiscale (URM) model was used (Odman et al., 2002), and used the Decoupled, Direct Method (Yang et al., 1997) to assess source impacts and response to controls. They also assessed the response of PM levels to emissions changes corresponding to varying levels of controls. Results of their modeling was used to calculate the expected changes in visibility, stream health and ozone damage (SAMI, 2002). Model simulations led to FPM mass having an normalized error of under 50%. Sulfate and elemental and organic carbon simulations also found errors on the same order, but nitrate predictions were high. Seigneur (2003) recently completed a report discussing regional modeling applications of CMAQ and REMSAD, two of the more commonly used regional PM models. The focus of this review was the model performance in the BRAVO, WRAP, Southeast US and various EPA studies. In general, model performance in the studies outside of the WRAP found PM predictions with a normalized error of 35-90%. Nitrate predictions had the largest error. SAMI air quality modeling dealt with many of the same issues being addressed currently by the WRAP (Odman et al., 2002). Specific issues addressed were quantifying the relationship IV-5 between emissions and various air quality endpoints, including PM levels, deposition and ozone. PM results, which were by species, were used for visibility calculations. Specific results of relevance here include: • PM reductions were sub-linear to controls, and that the degree of sub-linearity increased as PM concentrations decreased. For example, when sulfate concentrations were highest, a 10% reduction in SO2 emissions resulted in an approximately 8-9% reduction in sulfate. At lower sulfate levels, the same 10% reduction led to a smaller percentage change. For nitrate, the sub-linear response was greater. A 10% reduction in NOx led to about a 5% reduction in nitrate, averaged over the year. • Reductions in sulfate led to an increase in nitrate levels. • Increases in ammonia led to an increase in nitrate. • Nitrate formation was generally ammonia-limited. These findings are important both individually and collectively. Over the next few years, SO2 emissions are expected to decrease and ammonia emissions are expected to increase, both leading to increases in nitrate. SAMI results suggest that these increases will be relatively small, but non-zero. However, in many locations, they offset the 27-63% reductions in NOx, such that nitrate actually increased. It is difficult to translate how similar changes will impact the WRAP regions, particularly since the WRAP regions are more heterogeneous. However, the preliminary results from the CMAQ modeling suggest that nitrate formation is ammonia-limited in a large part of the West. The sub-linear response suggests that controls will not get as much reduction as might originally be expected. However, the greatest fractional improvements will occur on the most heavily impacted days. A final reference that provides a good overview of the issue is the NARSTO Assessment (NARSTO, 2003). It provides a more thorough discussion of many of the issues contained here, as well as conceptual models of PM dynamics in a number of areas of the United States. Conceptual Model of Primary PM and Nitrate Dynamics in Western Airsheds Here, conceptual models are developed to help elucidate the dynamics of both primary and nitrate PM in various western airsheds, starting with primary coarse and fine PM, which are not as involved with gas-to-particle conversion and less complicated. Note, secondary species can condense on primary PM, so even primary species can impact the formation and properties of secondary material. Coarse PM is typically emitted by mechanical processes, e.g., grinding operations, transport of solid materials, road dust and wind blown dust. Further, CPM is typically emitted near the ground, not from tall stacks. In part, this is due to controls on large point sources. CPM has a relatively short lifetime, on the order of a few hours, though particles at the upper end of the coarse mode will have very short lifetime. For wind blown dust, this is much of the mass. Primary CPM can be attacked by nitric acid, and because of the shorter lifetime, act as a sink of IV-6 nitrate PM. Given total primary CPM emissions of 70 tons per year (tpy) (1/2 of the total PM10 emissions), one can develop a first order estimate of the contribution to total PM in the region by dividing by the approximate volume of the boundary layer in the WRAP area (~1015 m3), and multiply (~1 hr) by the lifetime. This leads to an average contribution of large point sources to PM of 0.005 ug/m3, a small fraction, again, on average. However, high levels of CPM are often very episodic (dust storms) or very local: i.e., within a few km of the source. Further downwind, the emissions have deposited and been diluted. A portion of the CPM can be secondary, e.g., due to reaction of nitric acid on the surface of the aerosol, or condensation. Measurements suggest that a non-insignificant fraction of the nitrate in the regions outside of the California valleys is coarse. As discussed below, the existence of CPM nitrate is important from a control point of view. CPM nitrate is less likely to be reduced from reductions in ammonia as compared to FPM nitrate. From this conceptual model of CPM, driving points are: • CPM is predominantly primary, with a fraction due to gas-to-particle conversion, e.g., by the reaction of nitric acid with pre-existing particles, • CPM has a relatively short lifetime, • CPM can act as a sink for nitrate, and • CPM is typically episodic, often occurring during periods with large amounts of windblown dust. Primary FPM is emitted, often as a combustion by-product, in to the atmosphere, where it undergoes transport, growth, deposition, rain-out and a variety of other processes. The size of such emissions are typically in the ultrafine region, though from some processes the average particle size can be larger, e.g., as fine and coarse PM (e.g., cement manufacture). If emitted as an ultrafine, the small particles will likely grow in to the accumulation mode via condensation of other compounds to it (primarily) and coagulation with other particles, staying as FPM. Primary FPM is transported very efficiently, essentially as a gas, since its sedimentation velocity (the rate at which it falls due to gravity) is very slow. As such, it will follow the prevailing winds and be distributed vertically and horizontally due to atmospheric turbulence. Removal of FPM occurs due to wash-out (e.g., rain and snow) and dry deposition. Dry deposition is slow, slower than many gases, due to the slow transport of FPM across the fluid dynamic boundary layer near solid surfaces (gases diffuse much more rapidly than particles) and low sedimentation velocities. As an example, for a 1 um particle, the deposition velocity is on the order of 5x10-4 m s-1. Using a boundary layer height (e.g., the well mixed portion of the atmosphere near the earth’s surface) of 1000m, this leads to an atmospheric lifetime of about 3 weeks, and the particles will be transported out of the region before depositing. Larger particles will deposit somewhat faster as their sedimentation velocity is higher (the particles are heavier), and very small particles will as well since they diffuse faster. With such long lifetimes, wash-out can be very important, particularly in areas that have frequent rains. Depending on the intensity of the IV-7 rain, FPM can be very effectively removed, such that the lifetime of the FPM is very directly linked to the frequency of rain. Without rain, FPM is generally transported out of the airshed or, as will be discussed for nitrate, be lost due to some other process. The lifetime due to transport in the region is on the order of 10 days. Using this, along with assuming that one half of the primary PM emissions from stationary sources (Seignuer et al., 2003) are fine, one calculates that the average primary FPM levels would be on the order of 1 ug/m3. This is somewhat above what is measured as crustals in most locations, and more in line with the measured organic carbon. However, organic carbon would be due more to wood boilers and internal combustion engines. Using just those emissions, the average contribution to the organics would be less than 0.1 ug/m3. This is in line with source apportionments that suggest a large fraction of the organic carbon is due to biomass burning and other processes (e.g. Maykut et al., 2003). The stationary source emissions estimates would suggest that primary FPM from stationary sources may have a regionally significant impact, though this calculation is conservative and does not take in to account rainout and other loss processes. If the primary FPM is emitted from the stack of a large point source, it will be transported in the plume with the gaseous pollutants and can undergo somewhat more rapid growth due to the concentration of condensable compounds. It may also be transported above the well mixed boundary layer, delaying the dry deposition loss mechanism, at least temporarily. When the mixed layer grows to capture the plume, the FPM will be diffused downwards. Given the cloud heights relative to the typical effective plume height, washout will typically remove FPM from plumes. During transport, primary FPM can grow. Growth will depend upon the particle size and composition. Of particular importance is the hygroscopicity of the compounds in the particles. Some compounds will readily absorb water, such that in a humid environment, they will grow significantly, e.g., doubling in size. If the compound is hydrophobic, they will undergo more slow growth due to condensation of other compounds. Water is not the only compound that will be selective as to which particles are most readily absorbed. Semi-volatile organic gases can have a preference for particles with similar-structured organic matter already present. SO2(g) can be absorbed in to particles that already contain water, and then oxidized to form sulfate. Nitric acid will prefer non-acidic particulate matter. Important here is to recognize that a primary particle will interact with its environment, and end up as having both primary and secondary components. From a visibility standpoint, this is important since the growth can make the particles more efficient at degrading visibility. While the argument could be made that the condensable species would find some other process to form particulate matter without direct emissions (e.g., nucleation, followed by condensation), there is an abundance of water that would not necessarily do so. Further, as compounds such as sulfate condense on primary FPM, they can become more hygroscopic. Since primary emissions of FPM can undergo atmospheric growth, it is not directly apparent that decreases in FPM emissions will lead to the same level of decrease in FPM in the atmosphere. Indeed, greater reductions may be realized if the nuclei provided by the primary FPM is a limiting factor in the formation of secondary FPM. On the other hand, the observed effects may not be as enhanced since the condensable species will find other particles. IV-8 From this conceptual model of primary FPM, driving points are: • FPM has potentially long lifetimes in the atmosphere, • Wash-out is an important loss mechanism, • Ultrafine primary FPM can grow in to a size range that is efficient at scattering light, • Hygroscopic FPM can pick up water and become diffusive, and • Even if emitted from tall stacks, primary FPM can be diffused downwards to the surface. Particulate nitrate dynamics is significantly more complex than for primary PM because of the added chemistry and gas-to-particle/particle-to-gas conversion. While there is a small amount of primary nitrate emissions, most of the particulate nitrate in the troposphere starts out as NOx which was emitted from a combustion process. NOx, which is well known for its role in the formation of ozone, can be oxidized to nitric acid via two important pathways. During the day, NO2 is oxidized by the hydroxyl radical: NO2 + OH  → HNO3 This reaction is responsible for most of the nitric acid formation. A second route takes place mostly at night. First, NO2 is oxidized by ozone to the nitrate radical, NO3: NO 2 + O 3  → NO 3 + O 2 (The nitrate radical should not be confused with the nitrate ion, NO3-). Next, the nitrate radical reacts with NO2 to form dinitrogen pentoxide, N2O5: NO 2 + NO 3  → N 2 O 5 N2O5 then reacts with water to form two nitric acid molecules: N 2 O5 + H 2 O  → 2HNO3 This reaction is slow in the gas phase, but can occur rapidly on the surface of a particle that contains water. However, the rate of this reaction is very uncertain, and it is believed that the rate used by CMAQ in the past may be too high (Dennis, 2003, personal communication), leading to an over prediction of PM nitrate. NO3 photolyzes very rapidly, and during the daytime it is found at very, very low levels, blocking this formation route when the sun is up. The nitric acid gas formed from the above reactions can dry-deposit out, be washed out, or undergo gas-to-particle conversion. Nitric acid reacts very rapidly with surfaces, and deposits out rapidly. It’s lifetime to dry deposition is on the order of a few hours. Nitric acid is also very soluble, and is removed effectively by rain. IV-9 In terms of particulate matter formation, nitric acid is a strong gas and can attack pre-existing particles, being adsorbed or displacing other compounds present. For example, nitric acid gas can displace chlorine in a sea salt-derived particle, leading to sodium nitrate and HCl(g). Likewise, it can react with alikilinic crustal material to form PM nitrate (e.g., Malm et al., 2003). In both such cases, the particulate nitrate formed is in the coarse fraction because the original particle was in the coarse mode. In many regions, the route to forming FPM nitrate is via the gas phase reaction between nitric acid and ammonia (NH3): → NH 4 NO 3 (aerosol) HNO 3 (g) + NH 3 (g )  followed by gas to particle conversion. The reaction is reversible, and the ammonium nitrate can thermally decompose. The forward and backward reactions are fast enough such that the two reactions are often considered to be in equilibrium: K HNO 3 (g ) + NH 3 (g ) ←→ NH 4 NO 3 (aerosol) where K is the equilibrium constant. Thus, the fraction of nitrate formed is very sensitive to the abundance of ammonia available, as probed later. In areas with substantial quantities of ammonia, large amounts of nitrate can be formed (e.g., in areas with confined animal operations). In areas with relatively little ammonia, or where the ammonia available is bound as ammonium sulfate (or ammonium bisulfate), very little nitrate is present. Another factor is that the equilibrium constant is very temperature dependent, and at higher temperatures, the gas phases of the two compounds is preferred. The equilibrium makes the formation of ammonium nitrate very nonlinear. In some cases, e.g., in an environment rich in ammonia but with little nitric acid, the ammonium nitrate levels are governed almost solely by the available nitrate (e.g., nitric acid formation), and ammonia reductions will have little impact. If ammonia is low, it is the controlling species Surprisingly, nitrate levels, locally, may go up when NOx emissions are decreased. This is analogous to the disbenefit found in the response of ozone to NOx emissions. Regionally, NOx reductions will reduce ozone because NO2 is needed to form ozone. However, locally, reducing NOx can lead to local increases in ozone for two reasons. The most easily understood is that NOx is primarily emitted as NO, which titrates ozone. This is important at night. During the day, NO2 reacts with the hydroxyl radical, significantly lowering OH levels. This decreases the rate of VOC oxidation, which reduces the rate of NO oxidation to NO2, which reduces ozone formation. Most of the hydroxyl radical formed comes from ozone photolysis, so lower ozone reduces OH formation. Thus, there is a positive feedback. NOx emissions increases decrease ozone, decrease OH, and decrease the rate at which NO2 is oxidized to nitrate, locally. Regionally, more nitric acid will be formed. In the SAMI study, this appeared to be a second order effect. Complicating the nitrate formation issue is the presence of other condensed phase species, in particular sulfate. As noted above, ammonium nitrate formation is very sensitive to the availability of ammonia. SO2 oxidation, which is faster in the summer when hydroxyl levels are highest, leads to the formation of sulfuric acid, H2SO4. Sulfuric acid reacts with ammonia to form ammonium bisulfate [(NH4)HSO4], and if enough ammonia is present, ammonium sulfate IV-10 [(NH4)2SO4]. Ammonia will preferentially react with sulfate to form the above two species before reacting with nitric acid to form ammonium nitrate. As such, the presence of sulfate will reduce the amount of ammonia available to form ammonium nitrate. In many cases, there is so little free ammonia that ammonium nitrate is not formed. On the other hand, nitric acid that has reacted with sea salt or crustal material to form sodium/calcium nitrate does not require ammonia, so there can be some aerosol nitrate even in high sulfate areas, though typically not as much as in high ammonia/low sulfate areas. The interaction between sulfate, nitric acid and ammonia has implications for the “lifetime” of nitrate in the atmosphere as sulfate is reduced: decreasing sulfate will make more ammonia available to form PM nitrate, reducing nitric acid gas levels. The PM nitrate deposits much less rapidly than nitric acid, so the total abundance of nitrate in the atmosphere will increase. Thus, decreasing sulfate levels may lead to somewhat more nitrate than is expected from just considering the amount of nitric acid currently available to form PM nitrate. Sulfur dioxide reductions will lead to the reduction of sulfate particulate matter, and hence, can lead to more ammonium being available to form ammonium nitrate, leading to what is referred to as the “rebound effect”. In this case, the sulfur dioxide controls will not lead to the expected (or desired) reductions in particulate matter because as sulfate decreases, nitrate increases due to the availability of ammonia in a condition where nitrate formation was ammonia limited. This was found to be true in the SAMI study to a limited degree. One issue that should be addressed is the impact of certain NOx controls on increasing ammonia emissions, e.g., SCR and SNCR. Compared to other sources of emissions, such controls would represent a very small fraction of the total ammonia emissions. However, in the plume, the ammonia emissions might be high enough to lead to an increase in ammonium nitrate, and hence impact visibility in concentrated plumes. Washout is very important to nitrate levels. Not only will rain remove the nitrate aerosol, but will also remove nitric acid gas and ammonia very effectively. Clouds can also increase the oxidation of SO2 to sulfate, which captures ammonia, and is also washed out. Some of the lowest FPM levels are found following a rain storm. From this conceptual model of PM nitrate, driving points are: • PM nitrate formation is due to both gas and heterogeneous reactions forming nitric acid from nitrogen oxide emissions, followed by gas-to-particle conversion, • FPM nitrate is largely due to reaction with ammonia, while CPM nitrate is due to reactions of nitric acid on a preexisting particle, • Reducing ammonia can reduce nitrate formation in areas that are “ammonia limited”, but may have little impact in areas where there is an abundance of ammonia, and IV-11 • NOx controls can reduce nitrate in areas where ammonium nitrate formation is nitrate limited, as well as areas where nitrate is formed from the reaction of nitric acid on pre-existing particles. This conceptual model is diagrammed in the figure below. It should be noted that this figure, or the discussion above, does not have all of the complexities leading to nitrate formation. The atmospheric chemistry involves hundreds of compounds, and thousands of reactions. Describing the physical processes is equally complex. The systems of equations governing the pollutant evolution are non-linear. Pollutants evolve spatially and temporally. For such reasons, complex computer models are generally used to study the details of the pollutant dynamics. However, a good picture of the system dynamics, and an understanding of the importance of various processes can be developed from a simplified, zero-dimensional model. While very simplified, a zero-dimensional model can be used to demonstrate the important features and resulting formation and loss of particulate nitrate. In this case, the model includes the formation of nitric acid, peaking during the day, an increase in temperature during the day, going from 10 to 30 C, the increase in the equilibrium constant with temperature, deposition of nitric acid, and a constant level of ammonia/ammonium. The result is that the highest levels of PM nitrate occur at night and the early morning, going to zero during the hottest parts of the day. Nitric acid peaks during the day when all of the ammonium nitrate has dissociated. Most of the nitrate deposits during the day since nitric acid is so reactive with surfaces. In the SAMI project, the deposition of oxidized nitrogen due to nitric acid was about an order of magnitude higher than for PM nitrate, due both to the higher nitric acid levels and deposition velocities. One of the important features of this system is that while ammonium nitrate does not deposit rapidly, nitric acid does. Thus, an ammonium nitrate aerosol will disappear relatively rapidly in a continual, two-step process: the nitric acid gas deposits rapidly as a gas. The ammonium nitrate will thermally decompose to replace the lost nitric acid. The nitric acid released will then deposit out, etc.. At higher temperatures, i.e., when a significant amount of the nitrate is in the IV-12 gas phase, this process can be rapid. In cold areas, almost all of the nitrate will be bound as ammonium nitrate, and the thermal decomposition is slow, so the process is inhibited. A multi-day observation of aerosol nitrate levels is shown in Figure 2, along with the temperature trace. As shown, nitrate goes up in the morning due to NOx oxidation along with low temperatures. As the temperature increases, the nitrate decreases and goes to near zero during the day. While not shown, sulfate also increases during the day, scavenging ammonia and further decreasing nitrate levels. Particles and Visibility As noted previously, particles can degrade visibility. The three primary mechanisms are Mie, Rayleigh and Geometric scattering, and absorption. Only a few types of particles absorb visible light effectively. Most notably is elemental carbon. Mie scattering occurs from a complex interaction between light waves and particles of a size similar to the wavelength of light (visible light ranges from about 0.2 to 0.8 um). Larger particles scatter and block light. Air molecules also scatter light (Rayleigh scattering), limiting visibility on even the cleanest days. Visibility, or visual range, xv, is often calculated using the Koschmeider formula: 3.912 xv = bext where bext is called the extinction coefficient, and is generally given in Mm-1. The extinction coefficient is calculated by accounting for all of the processes scattering and absorbing light. While very complex formulas have been derived, a useful parameterization that corresponds to he air quality data usually available from IMPROVE and other sites is: bext = 3 f T ( RH )([ Sulfate] + [ Nitrate ]) + 4 f org ( RH )[Organic ] + [ Soil ] + 0.6[CPM ] + 10[ LAC ] IV-13 where fT(RH) is a function to account for sulfate and nitrate absorbing water (forg(RH) is a similar function for organic material), [Sulfate], [Nitrate], [Organic] and [Soil], are the measured masses of the corresponding fine PM constituents, and [LAC] is the measured mass of the “light absorbing carbon” similar to EC, (depending on measurement technique). The latter term accounts for absorption. At relative humidities (RH) above 40%, fT(RH) is greater than one, going up to above 5. However, forg(RH) is taken as one. Given this, one sees that, on a mass basis, sulfate and nitrate are usually more effective at scattering light than organics, soil and CPM. LAC is very effective at absorbing light, and a small amount can lead to significant light extinction. Another measure of visibility impairment is the deciview (Pitchford and Malm, 1993). It is proportional to the log of the extinction coefficient and relates to the perception of haziness. Given the non-linear nature of the relationship between deciviews and extinction coefficient, but the linear relationship between extinction and PM composition, for the purposes of this report, it is easier to consider extinction. Regional Conceptual Models The above description of the formation and fate of primary FPM and nitrate was done for a general case, without consideration of regional differences in either the processes impacting primary FPM and nitrate. In the West, many such regions exist. To provide a better understanding of how such differences manifest themselves, four sub-regions of the WRAP are identified based on their meteorological and FPM characteristics. The four regions are: wet coastal, dry mountainous, southwest desert, and California valleys. Wet coastal regions include the coastal regions starting in northern California to the Olympic Peninsula, and include the coastal mountains. The dry mountainous sub-region includes the Rockies, the Sierras, and other drier mountainous areas. The southwest desert region would include non-mountainous areas in Arizona, New Mexico, Colorado and Nevada. California valleys include the Los Angeles basin and the surroundings (including the mountainous and desert areas downwind) and the Central Valley and surrounding mountains. A fifth case, considered separately, but not as a separate region, “in-and-near,”., i.e., those regions that have significant sources of PM either directly within or nearby. For example, a Class I area near a major city or facility with very large emissions, or if the activities within a Class I area led to significant emissions. The IMPROVE investigators have dissected the west in to 15 regions, which is more than is needed for developing the conceptual models as done below. However, which “IMPROVE” regions fall in to each of the four given below are noted. Wet, Coastal Subregion This subregion occurs along the Pacific coast and the Puget Sound, in to the coastal mountains and the Cascades. As such, it includes the IMPROVE Pacific Coastal and Cascade Mountains. As the name implies, this region tends to be wet, and is known for rain, and can also experience intense coastal storms. The temperatures tend to be cool. There are a few population centers in this region (e.g., Portland and Seattle). PM levels in the coastal region tend to be low, e.g., on the order of a 3-4 ug/m3 average over the year (Malm et al., 2003). Average levels of nitrate and primary FPM are very low: 0.2-0.8 ug/m3, though nitrate is higher in the Puget Sound and Columbia Gorge areas (Malm et al., IV-14 2003). The rain removes FPM and its precursors and coastal winds ventilate the region. The cloudiness of the area inhibits the rate of oxidation of NO2 to nitric acid. There are relatively fewer sources of FPM and precursors in the region. Higher levels of FPM are experienced in the population centers. In the Class I areas, FPM tends to be primarily sulfate and OC, with little nitrate and primary material. Biomass burning (e.g., forest fires) appears to be a major contributor in some areas, as suggested by high OC levels, particularly during some very high events. In terms of the general conceptual model, discussed above, particulate nitrate can be formed from the reaction of nitric acid with sea salt. Ammonium nitrate formation in the area appears to be limited by the presence of both free nitrate and ammonium. On the other hand, the cool temperatures promote converting what little available nitric acid and ammonia is available in to ammonium nitrate. Without further investigation (e.g., longer term, detailed modeling) it is difficult to tell how nitrate will respond to controls, but it is likely that the formation is limited by NOx emissions, not ammonia. Results from the WRAP modeling suggest that part of Oregon is ammonia sensitive (Tonneson, 2003). The days with the most severe visibility impairment appear to be impacted most heavily by organics (particularly during severe episodes) and sulfate. Dry, Mountainous Subregion This region includes the more inland mountains, and would contain the Sierra Nevada, Wasatch, Northern Rocky, Sierra-Humboldt and Central Rocky Mountain IMPROVE regions. These areas are much drier than the coastal mountains. While not immune to rain and storms, they are less frequent, particularly during the summer. Temperatures tend to get hotter during the summer. During the winter, temperatures can get quite low. The area has a relatively low population density, and few major source regions, though is relatively agricultural. Major point sources include utility boilers, and smelting operations. Confined animal operations can lead to areas of very high ammonia. Forest fires, particularly in the northern mountainous areas (e.g., Montana and Idaho) and the Sierras can lead to very large PM concentrations during episodes. In such cases, OC dominates mass. FPM levels in this region are low, around 2-5 ug/m3 in Class I areas. Again, cities have higher levels. Nitrate and primary FPM levels are a small fraction of the total (0.1 to 0.4 ug/m3, except in the regions of the Sierra Nevada that are influenced by emissions in the Central Valley), particularly during the some of the most polluted events that are dominated by sulfate. Given the low levels of nitrate, and the likely higher ammonia emissions, nitrate formation is likely limited by nitric acid formation from NO2. Simulations by UCR tend to suggest a mixture of sensitivities (Tonneson, 2003). The days with the most severe visibility impairment appear to be impacted most heavily by organic matter or sulfate, though some events have very high levels of coarse mass as well. Nitrate tends to be a relatively small contributor, which is to be expected when sulfate is high. Because the measurements can not distinguish as to the source of primary PM, it is not immediately apparent as to the source of the coarse mass, but given the episodic nature, it is likely that the primary PM is natural in origin. IV-15 Southwest This region includes the far eastern part of southern California, Arizona, New Mexico, southern Colorado and Nevada. IMPROVE regions corresponding to this region are the Great Basin of Nevada, the Colorado Plateau and Sonoran Desert. The Southwest has features similar to the Dry Mountainous subregion, being dry and having low FPM levels. It differs in that temperatures tend to be higher, and there is a greater abundance of major point sources of NOx and FPM. Biogenic sources in much of the southwest are very small, but appear to be a major component of the OC nonetheless (Brown et al., 2000). Ammonia emissions are less dense, though crustal material can be higher from wind blow dust as this area finds higher soil concentrations than the others (Malm et al., 2003).. While more detailed modeling is needed, it would appear that the higher levels of sulfate measured, and the apparently lower levels of ammonia emissions, would make this area ammonia limited much of the time. The days with the most severe visibility impairment appear to be impacted most heavily by sulfate, OC and nitrate, though some of the events with the lowest visibility have very high levels of coarse mass, likely associated with dust storms. There are periods with very high levels of OC, indicative of major biomass burning events (forest fires). California Valleys This subregion is the most distinct of the four, and includes California’s Los Angeles Basin and the Central Valley, and the areas most directly impacted by transport from these regions (e.g., downwind of Los Angeles and the mountains directly along the valley, including part of the Sierra Nevada). This region is relatively dry and warm. There are periods of significant stagnation. Most importantly, this region has greater emission densities of the pollutants impacting nitrate PM, in particular both NOx and ammonia. These characteristics lead to substantially higher FPM levels, especially for nitrate. Nationally, this region has the highest nitrate levels. Of all the regions, most is known about the dynamics of PM here due to a history of studies being sponsored by the state of California, industries and others. In Los Angeles, the high nitrate levels are due to the large emissions of NOx, e.g., from mobile sources, confined animal operations leading to high ammonia emissions, low ventilation rates concentrating both sets of emissions, and plentiful sun, oxidizing the NO2. In parts of the basin, e.g., before the air masses pass over the confined animal operations, nitrate formation is ammonia limited. Further downwind, the formation becomes nitrate-limited as there are plentiful ammonia emissions and the nitric acid continues to deposit out. The highest nitrate levels are found in the fall when the sunlight still leads to rapid oxidation of NO2, winds are light, there is little rain, and the temperatures are lower favoring the formation of ammonium nitrate. On hot summer days, the ammonium nitrate thermally decomposes, though large amounts of nitrate can be present during the cooler hours. The Central valley shares some of the characteristics of the LA basin, but has some unique features. First, the sources of NOx differ, having a larger non-mobile component, and being less dense. There are widespread agricultural and animal operations leading to ammonia emissions IV-16 throughout the valley. There can be long stagnation events with fog and very little ventilation. During these stagnation events, nitrate levels can build. An interesting study of the NOx-nitrate relationship was recently completed for the San Joaquin Valley using a box model (Stockwell et al., 2000). They found that for each gram of NOx emission, approximately 0.6 grams of nitrate is formed. This is a high ammonia region, so while those results are in general agreement with field measurements in the region, the extrapolation of those results elsewhere is limited. For both areas, the days with the greatest visibility impairment are high in nitrate, OC and sulfate, with episodes of coarse material. In and Near A few Class I areas lie very near a major source region (e.g., a city) or specific source (e.g., a major highway, mining operation or power plant). In this case, the PM levels can be higher than experienced by the rest of the region, and have a different composition. Examples that are near source regions include San Gorgonio (downwind of Los Angeles) and Casa Grande and Tonto National Monuments near Phoenix. In this case, the PM takes on a characteristic that is a blend between these in the urban area and the regional background. For example, this can lead to elevated nitrate, as particularly found in San Gorgonio, and organic and elemental carbon. For areas near major sources, the PM can be enriched in the compounds being directly emitted by the source. Secondary pollutants, particularly sulfate, take longer to form, so there is less of a direct impact, but some enrichment is likely (e.g. Grand Canyon Visibility Transport Commission, 1996; Pitchford et al., 1999). Pollutant dispersion reduces the apparent source impact relatively rapidly, so after a few 10s of km, the impact from that source is reduced by an order of magnitude or so. This is particularly true for CPM which also deposits rapidly. Also, human activities within a protected area (e.g., driving, fires, etc.) can contribute to locally higher PM levels. However, these sources are outside of the subject of this study, do not appear to be a significant contributor to visibility degradation regionally, and are not dealt with further here. Particulate Matter Modeling Currently, the most scientifically well-founded approach to assessing how future emissions changes will impact air quality is to use a physically and chemically comprehensive air quality model that describes the evolution of pollutants in the atmosphere. Such models (actually, multiple models are used) are complex, and are run on fast computers. The WRAP is now using such an approach. In particular, the WRAP is using the Models-3 suite of models, including SMOKE for emissions, MM5 for meteorology and CMAQ for air quality, including particulate matter. MM5 is one of the most widely used meteorological models, and CMAQ is an increasingly popular air quality model. MM5 solves the equations governing the motions of the atmosphere. These equations are very complex and non-linear, and sensitive to boundary and initial conditions. The model uses a variety of parameterizations to simulate various processes. For some processes, MM5 has more than one choice of parameterization since no one approach appears to be universally best. This, IV-17 in part, shows the complexity of meteorological models, and that modeling errors can be expected. Errors can grow with time, degrading performance in longer simulations if nothing is done to constrain the growth. For this reason, data assimilation is used where observations are used to adjust the results as the fields evolve. As such, the model results are sensitive to model inputs (including initial and boundary conditions), model parameterizations and errors in the data used in the assimilation. While MM5 often achieves very good performance, there are events where good performance is elusive. CMAQ is a comprehensive chemical transport model, developed primarily by the US EPA and funding from that agency. It represents the state-of-the-science in most aspects, and has been developed for use by the modeling community. Its use by the community is, in part, to help it evolve and continuously improve. CMAQ contains processes describing gas phase chemistry, aerosol dynamics, dry and wet deposition, pollutant transport and more. A common configuration of CMAQ uses CB-IV, a rather older, simplified chemical mechanism, though versions exist with RADM-II and SAPRC-99, two of the newer, most comprehensive and well tested mechanisms. All three models have been used in a variety of efforts in the past. MM5 and CMAQ, the two predictive models, have been able to show good performance, at least for some species, though performance can vary from site to site and study to study. Since CMAQ uses the results from MM5, poor performance by MM5 can lead to similarly poor performance from CMAQ. However, even with ostensibly good performance from MM5, CMAQ may not perform well due to poor emissions inputs and/or problems with CMAQ itself, e.g., how it treats various processes. Further, here, CMAQ is being applied using a 36 km grid resolution. Such large grids are not appropriate for assessing the impact of a point source of CPM on nearby areas because of the rapid deposition of the larger particles, and the artificially large dilution of the emissions over the 36x36 km grid. Model Performance Issues Confidence in using such a model is derived from successful evaluation of the results. What constitutes good model performance varies by pollutants, and for FPM there is no standard criteria. Recent modeling efforts have found errors for sulfate to be within about 50%, OC within a similar range, and nitrate within about 100% (Seignuer, 2003). However, current model performance found for the WRAP effort suggests poor model performance for some species, particularly nitrate (up to a factor of 10 high in the winter, but some days with essentially no nitrate formation simulated in regions where nitrate is monitored to be present). It is difficult to assess the model performance for primary FPM from stationary sources since the measurements and the model results are not able to support such an evaluation. How does poor model performance affect the use of the results, in particular for quantifying the likely impact of emissions changes? First, it is important to understand the likely reasons for the poor nitrate performance. It is unlikely that the NOx emissions estimates are very far off, so other problems likely exist. Ammonia emissions are much more uncertain, and can be part of the problem. Also suspect is the deposition rate used for nitric acid (too low) and the nighttime, heterogeneous oxidation of IV-18 NOx to nitric acid (too high), both leading to higher levels of nitrate. The reasons for having too little nitrate during the summer (e.g., no nitrate is sometimes predicted when some is observed) may be because the nitrate present is particulate nitrate formed from nitric acid attacking preexisting particles to form a thermally stable form of particulate nitrate (e.g., soil material and salt), slight overestimates in the amount of sulfate formed or underestimates in the ammonia emissions. Monitoring has found that a significant amount of the nitrate in Class I areas outside of southern California is larger FPM or coarse, suggesting that it is formed from nitric acid attacking pre-existing aerosol forming a thermally stable form of nitrate. If this is the reason for the discrepancy, and that ammonium nitrate is not present, then the modeled sensitivity to emissions reductions will be very different than would occur. In particular, an area that might appear to be ammonia limited from the modeling, may be nitrate-limited, and most sensitive to NOx emissions. A large error indicates that either the sensitivity to emissions changes is in error, or there is a large error in the emissions. If the latter were true, the model results could be used to scale observed levels to get a reasonably good approximation of how the ambient levels would respond. The decision was made, in advance, in SAMI to use scaling, even for the species where very good performance was found. Note, if performance is perfect, the same results are found if one uses scaling or the model results directly. Thus, the approach is asymptotically correct. If model performance is poor, scaling the observations with model results becomes more questionable. Given the very large errors found for nitrate, the low correlation between observed and simulated levels, and that NOx emissions are relatively well known (probably well within a factor of two), the modeled sensitivity of nitrate levels to NOx emissions could be well off. Indeed, the very low observed nitrate, versus that simulated, suggest that much of the time the model is in a different regime than the actual atmosphere (e.g., the case where the two species, ammonia and nitric acid, are in sufficient supply to form aerosol nitrate vs. the case where one or both are at concentrations low enough to negate ammonium nitrate formation, and what little nitrate found is due to reactions of nitric acid with a crustal material or sea salt). Performance is worst during the winter, but during the summer there are days where no nitrate is predicted, though some is observed. In this case, NOx controls will not lead to any change in predicted nitrate, so scaling will not show any benefit. Given the performance problems, it is difficult to suggest if the sensitivity of either the annual nitrate levels, or the nitrate levels on the days with the most limited visibility, is adequately represented by the model. One issue concerning the use of scaling is that it does not account for spatial inhomogeneities in the controls. For example, control at a specific source, even though it is a very small fraction of the total inventory, will have an enhanced local impact, though little impact further away. This issue can be dealt with by using the model to develop source-receptor relationships, and use those results to help guide the scaling. For primary fine and coarse PM, the response of ambient PM is likely to be quite linear (though not totally due to particle growth), so scaling should work relatively well, as long as the issue of spatial inhomogeneities in the emissions controls is adequately addressed. This can be relatively easily tested using a single model simulation. IV-19 At present, the simulations have not been conducted to provide a complete source apportionment of the PM. By this, one means exercising the model to show how each source (or group of sources) impacts PM at specific receptors (e.g., the Class I areas). Such a calculation can be very helpful in suggesting controls. Further, it is important to understand the magnitude of the problem with which we are dealing, and how to interpret model results and observations. In particular, this is important for primary PM. At most Class I areas, FPM is dominated by secondary species (nitrate, ammonium, sulfate and a fraction of the OC), and primary EC and OC. Other compounds are a relatively small contributor to both FPM mass and visibility. One question, for which the model can be used to help understand, is if a significant fraction of the PM is from stationary sources. If not, i.e., that stationary sources are a small fraction of the primary PM at Class I areas, and that primary PM is a small fraction of the total PM, reductions in primary PM emissions will have a rather small impact. Effectiveness of PM and NOx Controls on PM levels and Visibility in the West As discussed above, nitrate is a major contributor to PM levels and visibility extinction in a few areas of the West, notably in California, and to a lesser amount the Columbia Gorge. In the southern half of California, nitrate can be the major constituent. In most other areas, nitrate is found at relatively small concentrations, around 5-20% of the total FPM. Likewise, point source primary emissions of PM, both coarse and fine, are a small contributor, regionally, as well. Thus, controls on point source emissions of NOx and PM will have a relatively limited effect on both PM and visibility in much of the West, all else being equal. The latter clause is important because, as SO2 emissions are reduced, and ammonia emissions increase (as is forecast in many areas), aerosol nitrate may become a more significant contributor, as was found in SAMI. In and around the California valleys, nitrate formation appears to be nitrate limited. As noted above, Stockwell et al., (2000) found that one gets, roughly, about 0.6 grams of nitrate (as ammonium nitrate) per gram of NOx emissions. This would suggest that, in these areas, NOx controls will reduce nitrate levels. The exact level of benefit will have to come from either analysis of the measurements or modeling after performance improves. The California inventory suggests that about 478 tons per day (tpd), or about 14% of the 3441 tpd statewide, of NOx come from stationary sources. Assuming that stationary sources have a similar impact on nitrate formation (SAMI results suggest this is not totally true, Odman et al., (2002)), this puts an upper bound on the likely benefits of around 15%, and the results of the SAMI study suggest that the actual impact on nitrate mass is more around 7%. This translates in to approximately 2% of the total FPM in areas around Los Angeles where nitrate makes up about 30% of the total FPM and 1% in areas of California, such as the Sierras east of the Central Valley where nitrate is about 15% of the total FPM. In other areas, the stationary source contribution, on average, would be smaller, on average. Three considerations would increase the importance somewhat: on days with the worst visibility in these areas, nitrate makes up a larger fraction of the total (in some cases, over 50%) on days with the highest levels of nitrate, a greater fractional response to NOx reductions is suggested and if the receptor is directly downwind of a major point source, the impact would be increased. The first two considerations might lead to an increased impact of up to 5%. The latter consideration would be very site and meteorology dependent. IV-20 Elsewhere in the West, nitrate levels are relatively small: usually less than a ug/m3, and from 510% of the total PM. The days with the worst visibility tend to be dominated by one of three cases: high CPM and crustal (indicative of dust storms), high organic and elemental carbon (which can indicate forest fires) or high sulfate, which tends to be elevated much of the time, and increases during stagnation. Thus, unless the increasing ammonia and decreasing sulfate lead to significant nitrate increases, stationary point sources will lead to only about 2% (or less) of the visibility extinction, except in areas significantly impacted by major sources. SAMI modeling suggested that there will be small additional benefits of NOx controls in reducing sulfate due to decreased sulfur dioxide oxidation. Thus, NOx controls will have a relatively small impact on PM and visibility in the West. The impacts of primary PM controls on point sources are more difficult to assess at this time since the available data is less specific as to the fraction of PM from point sources. As noted above, CPM has such a short lifetime that reductions will have a small impact on PM levels and visibility, except very near the source. Primary stationary source FPM, while longer lived, still appears to be relatively minor, contributing less than 0.1 ug/m3, so controls on FPM would also have a minor impact on PM levels and visibility. This is in line with the results from studies such as those conducted at Mt. Zirkel (Watson et al., 1996). Total removal would lead to a decrease in extinction of about 0.4 Mm-1, or less than about 0.5% of the total extinction on a day with relatively bad visibility of about 20 miles. The above analysis suggests that primary PM and NOx controls will have limited impact on visibility in the West in the near term, except in areas of California and areas directly impacted by specific stationary sources being controlled. Near-field impacts of sources needs to be conducted on a site-by-site basis. However, as sulfate levels come down, the impact of NOx controls will increase, both because nitrate levels will increase and due to the non-linear relationship between visibility and extinction. Locations whose visibility is currently dominated by sulfate may find that nitrate becomes the species of concern. Looking towards the future, it is prudent to identify the types of controls and mechanisms to increase their cost effectiveness. Emissions Trading Emissions trading is viewed as an economically efficient approach to air quality management, as has been experienced through the acid rain program. However, when trading pollutant emissions, the economic efficiencies tend to decrease as limits are placed on trading, e.g., spatially, temporally, across sectors, and across pollutants. There are issues associated with each. Allowing spatially diverse trades can shift emissions reductions and the resulting air quality improvements. Temporal trading can lead to decreased (or enhanced) benefits. For example, sulfate tends to be higher in the summer due to more rapid oxidation. If the trading results in greater reductions during the winter, average sulfate levels may decrease less than if the reductions were more uniform. On the other hand, if the SO2 reductions are greater in the summer, the benefits could be enhanced. This may be more critical for nitrate which, as discussed above, is very sensitive to temperature, and is thus found predominantly in the winter. Primary emissions would not be affected as much. IV-21 Trading across source sectors may be impacted by (1) the spatial and temporal trading concerns identified above, (2) that sources can emit at different elevations above the ground, and (3) that different sectors do not have the same PM characteristics. Emissions from a tall stack are in to a very different environment than a more dispersed ground level source. First, elevated emissions, e.g., from utilities, tend to be very concentrated in NOx, and the plumes can stay very NOx rich for significant distances. Ground level sources tend to be more disperse and in to environments with higher levels of VOCs. In recent field experiments, this has been found to have an impact on ozone formation efficiencies (e.g., Ryerson et al., 2001). Recent modeling has also found this to be the case for ozone and acid deposition, and nitrate FPM (Odman et al., 2002), though the differences were not as large as that measured for ozone. For primary FPM, this is likely a small impact, though ground level FPM emitted in populated areas would likely lead to a greater exposure than if emitted higher up. It is likely that the spatial and temporal issues are of greater concern. A final concern is that trading primary PM emissions between sectors can lead to a different type (e.g., predominant size) of PM being emitted. For example, utility emissions are likely going to be more fine than, say, cement production or mining emissions (as well as being emitted at different levels). CPM deposits faster, and impacts visibility less. Thus, removing a ton of CPM would not have the same benefit as removing a ton of FPM, all else equal. In this way, trading primary PM emissions between sectors is much like trading pollutant types, with the issues discussed below. Scientifically, the most challenging type of trade is across pollutant types, e.g., SO2 for NOx, primary PM for NOx, etc. This is because it is difficult to quantify how much of one pollutant can be traded for another and have equal air quality benefits. The possibility of displacement reactions further clouds how such trades can be weighted. For example, reducing SO2 will lead to sulfate aerosol reductions. However, this can free up ammonium to react with nitric acid, leading to increased nitrate. While this was found to be the case in SAMI modeling, the “rebound effect” was not large. Finally, the different species will have different impacts, e.g., in terms of visibility reduction. For example, each fraction of the PM has a different impact on visibility per mass. Nitrate and sulfate have a greater impact, on a per mass basis, than soil or CPM. Further, sulfate and nitrate both have a greater impact on visibility at higher humidities, other constituents do not, generally leading those two constituents to have a bigger impact on visibility on a per mass basis than (say) organics. Conversely, elemental carbon is very effective at absorbing light. If one can correctly account for the relationships between emissions and the resulting concentrations, it is straightforward to account for the visibility impairment differences, though the relationships can change with time. For example, as SO2 emissions are reduced in the future, and ammonia emissions increase, the area could become more sensitive to NOx emissions. Thus, one ton of NOx reduction may become more valuable in relationship to one ton of primary FPM. A final issue is that reducing NOx emissions will impact both secondary sulfate and OC formation. This is because NOx is central to the formation of ozone and increasing the oxidizing capacity of the atmosphere. Modeling as part of SAMI suggested that this secondary effect is small, but non-zero, impacting mainly the formation of sulfate. Typically, reducing NOx also reduced sulfate formation slightly, but in some locations NOx reductions led to small sulfate increases due to increasing H2O2 formation and the heterogeneous oxidation of SO2, as well as IV-22 increasing OH levels. In general, these secondary impacts will slightly enhance the effects of NOx emissions reductions, but can be ignored for now due to the larger uncertainties in quantifying the NOx-aerosol nitrate system response. Given the complexities, the question arises is, if emissions trading is to be done, how should trading equity be established. If the trades are somewhat restricted to the point that there are no obvious resulting inequities (e.g., limited spatially and not across pollutants, and that there is little likelihood that there would be little temporal or elevation differences), policy makers could likely proceed without the use of some more extensive approach. However, this would severely restrict the market and the associated economic benefits. Dealing with the issues identified is ideally tackled using a comprehensive air quality modeling effort, such as is being done by the WRAP. In this case, the model could be exercised to identify the appropriate trading ratios and the inequities resulting from various trades. A major problem at this time, as discussed above, is that confidence in a model’s use can only be developed through successful evaluation and good model performance for the species of interest. In the case of the WRAP modeling, nitrate performance was poor, and it would be difficult to use such results to assess how to make trades equitable, e.g., to develop trading ratios across pollutants. While less of an issue, using the model to assess trading SO2 for FPM is also difficult because of the rebound effect. When model performance is such that the WRAP is comfortable that the model is adequately capturing the physics and chemistry affecting pollutant evolution of the compounds of interest, then the model, presumably, can be used to determine how to make trades equitable. Note, this does not mean that performance for all species has to be good. Having poor performance for crustal species would not significantly impact the use of the model for comparing SO2 and NOx trades. Given the successes achieved from emissions trading, it is important to identify model performance problems such that trading guidelines can be established in a sound fashion. None of the issues identified above are “show stoppers”. However, given the level of uncertainty in the modeling results at present, inter-pollutant trading would have the potential to jeopardize visibility improvements in the region. Suggested Model Simulations At present, a few sensitivity simulations have been conducted using CMAQ. While conducted, in part, to understand model performance, they are providing insight into PM dynamics in the West. In particular, the cases where NH3 emissions are being changed to find areas that are most sensitive to NH3 emissions. Such sensitivity calculations are key to addressing trading issues and identifying effective control strategies. After model performance is judged to be adequate, a number of calculations are suggested. A first set of calculations is to conduct a comprehensive source apportionment by source type (e.g., point, area and mobile), pollutant (SO2, NOx, NH3, CPM and FPM), and location (e.g., state or region). The resulting matrix (a total of about 45 sensitivities) can be used to guide trading, assessing the impact of transport, identifying important source regions to pristine areas, and guiding control simulations. While 45 simulations may appear prohibitive, various tools exist to IV-23 facilitate the process. For example, SAMI used DDM-3D. The results of these sensitivities should be stratified into days with very good and poor visibility, and the annual average. The aggregation of days will tend to suggest a more local impact of sources than looking at a typical day. A second set of simulations would be to explore specific control issues, e.g., the imposition of certain sets of controls. A particular interest would be to explore future PM levels as the NOx and SO2 emissions are decreased, but NH3 emissions increase. The interest would be to assess if there is the possibility of increased nitrate formation due to the higher NH3 and lower sulfate in spite of lower NOx emissions, as was found in the SAMI study. In some areas, this may lead to nitrate replacing sulfate as the major contributor to visibility reduction, greatly increasing the impact of NOx controls on visibility. A third calculation would look at how SCR or SNCR controls would impact visibility in a point source plume. The ammonia in such a plume might lead to locally increased ammonium nitrate formation. While, regionally, ammonia emissions from such control technologies are small compared to animal waste decomposition and fertilizer, on a very local scale there may be increased PM formation. Such a calculation may require a finer grid being employed in locations to capture the finer scale impacts of the plume where, presumably, both NOx and NH3 would be elevated. Summary The states that are part of the WRAP have a very diverse chemical/PM “climatology”, represented by extremes ranging from the dry, high nitrate areas in Southern California to the wet, low PM northern coastal mountains, to the dry mountains and deserts inland. Typically, the major constituents of the visibility-impairing PM are fine PM sulfate, OC and, at times, nitrate, though there are episodes of high coarse material. Doing a simple, approximate, mass-lifetime balance on coarse PM emissions from primary sources suggests that, on average, primary CPM emissions from point sources will contribute a very small fraction of the total PM. This is borne out in the observations. Near the source (within a few 10s of km), however, the sources may be significant. FPM is much longer lived than CPM, and is predominantly secondary, being composed primarily of sulfate, OC and nitrate. Primary FPM from point sources is estimated to be a small contributor to FPM mass and light extinction on a regional basis. First, the total amount is small relative to other components of the FPM. Second, it has a lower impact, on a per mass basis, than other constituents. Third, periods of highest extinction do not appear to have significant amounts of point source-derived, primary FPM as compared to the other components, particularly CPM during dust storms, organic and elemental carbon during fires, sulfate during stagnation events, and nitrate in areas of high ammonia. Nitrate is formed from emissions of NOx that react to form nitric acid, which then can undergo gas-to-particle conversion. Much, but not all, of the nitrate is fine, and higher observed concentrations are formed from the reaction between nitric acid and ammonia to form IV-24 ammonium nitrate. A fraction of the nitrate will be formed from nitric acid attacking preexisting PM (coarse or fine). Ammonium nitrate levels can be reduced by either reducing nitric acid formation or ammonia emissions, with the greatest sensitivity to reducing the precursor that is least abundant (on a mole basis). Thus, some parts of the region will be ammonia-limited, others will be nitrate-limited (e.g., areas with high ammonia, such as near confined feeding and intense agricultural operations). The fraction that is formed from nitrate attacking pre-existing PM will not be very ammonia sensitive, responding more to NOx controls. Modeling currently suggests that much of the domain is ammonia-limited (in terms of nitrate formation). However, CMAQ does not include the capability to simulate the nitric acid attacking pre-existing PM, so this may be an artifact. What this suggests is that it is important to get model performance to the point where one is confident that the nitrate formation mechanisms are quantitatively reliable. In areas where nitrate formation is nitric acid-limited, NOx controls will generally reduce PM (with a few local exceptions). However, one ton of emissions reductions will not lead to one less ton of PM being formed. NO, NO2 and nitric acid all deposit out (dry or wet). Indeed, nitric acid deposits very rapidly, and simulations suggest that most of the mass will be removed this way. The WRAP model can develop the response of nitrate PM to NOx emissions. Trading emissions of primary FPM from one source to another would be relatively straightforward compared to other types of trades. The relative height of emission will have little impact on far downwind receptors. As with trading any type of emissions, trades across sources in very different locations may lead to one area receiving greater air quality benefits than another. Trading emissions of point source CPM would be especially sensitive to location in that the major impact is very near the source, dropping dramatically within 10 km. NOx emissions trading to reduce PM formation would be more complex. First, as noted above, some (if not most) regions are likely ammonia-limited, so NOx controls will have relatively smaller impacts on nitrate than might be expected. Second, the oxidation of NOx to nitric acid will depend on emission height and the intensity of emissions (e.g., the concentration of NOx in a plume). Third, reducing NOx will slightly impact the formation of sulfate and OC. Further complicating the issue is that an equitable trade (in terms of visibility) today may not be equitable in the future. Again, trading across large spatial areas may lead to issues in terms of which areas benefit most. Trading between pollutants is more involved yet, and a major concern is that the relationship between NOx emissions and nitrate formation is not well quantified at present. As model performance improves, there is no reason that it would not be practical to use the model to set trading relationships between pollutants. In so doing, one must account for the differing impact on visibility on a mass basis and the response to humidity. IV-25 References Brown SG, Herckes P, Ashbaugh L, et al. (2002) Characterization of organic aerosol in Big Bend National Park, Texas, Atmos. Environ,: 5807-5818 Edgerton, E. (2002) personal communication. Finlayson-Pitts B. J., Pitts J. N., Atmospheric Chemistry: Fundamentals and Experimental Techniques, WileyInterscience, New York, 1986 Friedlander S. K., Smoke, Dust and Haze: Fundamentals of Aerosol Behavior, Wiley-Interscience, New York, 1977 Grand Canyon Visibility Transport Commission (1996) Grand Canyon Visibility Transport Commission: Recommendations for Improving Western Vistas, http://www.westgov.org/wga/publicat/epafin.htm, June, 1996 Gard EE, Kleeman MJ, Gross DS, et al. (1998) Direct observation of heterogeneous chemistry in the atmosphere Science 279, 1184-1187 van de Hulst. HC (1957) Light Scattering by Small Particles, Wiley, New York. Malm, W.C.; Sisler,J.F.;. Pitchford, M.L.; Scruggs, M.; Ames, R.; Copeland, S.; Gebhart, K.A.; Day, D.E.; IMPROVE (Interagency Monitoring of Protected Visual Environments): Spatial and Seasonal Patterns and Temporal Variability of Haze and its Constituents in the United States: Report III, Colorado State University: Fort Collins, CO, ISSN: 0737-5352-47, 2000. Malm, W. C.;. Sisler, J. F.; Huffman, D.; Eldred, R. A.; Cahill, T. A. Spatial and Seasonal Trends in Particle Concentration and Optical Extinction in the U.S., J. of Geophys. Res,, 1994, 99, 1347-1370. Malm, W.C .; Schichtel, B.A..; Ames, R.B.; Gebhart, K.A. A Ten-Year Spatial and Temporal Trend of Sulfate across the United States. J. of Geophys. Res., 2002, 107 (D22). NARSTO (2003) Particulate Matter Science for Policy Makers: A NARSTO Assessment, Electric Power Research Institute, Menlo Park, CA, February. Russell AG, Cass GR, 1986, Verifiction of a Mathematical Model for Aerosol Nitrate and Nitric Acid Formation, and Its Use for Control Measure Evaluation, Atmospheric Environment, 20, pp. 2011-2025 Seigneur, C. (2003) “Review of CMAQ and REMSAD Performance for Regional PM Modeling” AER, San Ramon, CA. Seinfeld, JH and Pandis, SN (1998) “Atmospheric Chemistry and Physics: from Air Pollution to Climate Change” Wiley Interscience, New York. Sisler, J. F.; Malm, W. C. Interpretation of Trends of PM2.5 & Reconstructed Visibility from the Improve Network, J. Air & Waste Manage. Assoc., 2000, 50, 775-789. Stelson, AW and Seinfeld, JH (1982) Relative Humidity and Temperature Dependence of the ammonium nitrate dissociation Constant, Atmos. Environ., 15, 671-679. SAMI (2002) Southern Appalachian Mountains Initiative Final Report, Asheville, NC, August, 2002 Tonneson, G. (2003) Presentation, March 27, Denver, CO. IV-26 Watson, J., E. Fujita, J.C. Chow, B. Zielinska, L. Richards, W. Neff, and D. Dietrich (1998). Northern Front Range Air Quality Study. Final report prepared for Colorado State University, Fort Collins, CO, June 30. Yang Y. J., Wilkinson J. G., Russell A. G., Fast, Direct Sensitivity Analysis of Multi-dimensional Photochemical Models, Environment Science and Technology, 31, pp. 2859-2868, 1997 IV-27 SECTION V: SUMMARY OF AIR QUALITY MODELING RESULTS Context The modeling performed for this report is best described as a “sensitivity analysis.” The intent is to get a preliminary assessment of the general atmospheric response to changes in NOx and PM emissions from stationary sources. A secondary objective is to “practice” this type of modeling to get a better understanding of the key technical issues and to identify the most effective ways at evaluating and displaying model results. The results presented here are the best available predictions at this time, but forthcoming improvements to the modeling system may affect the results in ways that alter the policy implications. For this reason, results are discussed in a fairly broad and qualitative manner – i.e., spatial patterns and relative changes. As the modeling system improves and specific strategies are contemplated, additional emission scenarios will be designed and modeled. Modeling System The WRAP’s regional-scale air quality modeling system used to support other aspects of the Section 309 plans was also used to provide information for this report. A description of the modeling system – in addition to model performance statistics, input files, and detailed model results – is available at http://pah.cert.ucr.edu/rmc. Emission Scenarios Three emission scenarios were simulated: ƒ ƒ ƒ A 50 percent decrease in NOx emissions from plants with NOx emissions > 100 tpy, A 50 percent decrease in PM10 emissions from plants with PM10 emission > 100 tpy, and A 25 percent increase in NOx and PM10 emissions from all stationary sources. The first two scenarios are meant to address the regional haze rule’s requirement to “assesses emissions control strategies for stationary source NOx and PM, and the degree of visibility improvement that would result from such strategies.” As discussed in Section VI of this report, many commercially-available technologies (and various combinations of such technologies) are capable of achieving a 50% or greater NOx emission reduction without having to switch fuels. Hence, the 50% reduction, although intended primarily to gauge the general atmospheric response to NOx reductions, is not an unreasonable level of control to assume for this exercise in terms of technical feasibility. Again with technical (and administrative) feasibility in mind, emission reductions were limited to plants with emissions greater than 100 tpy, similar to the approach in the Annex. The third scenario is meant to address the rule’s requirement to “evaluate and discuss the need to establish emission milestones for NOx and PM to avoid any net increase in these pollutants from stationary sources within the transport region.” Hence, a 25 percent increase from all stationary sources was assumed to simulate potential growth in the V-1 economy and/or disproportionate growth in high-emitting sectors such as energy development, fossil-fueled electricity generation, and mineral processing. For reasons implied in the rule, the emission changes in the scenarios described above were limited to the nine-state GCVTR12. Also, the emission changes were applied to the 2018 inventory, which includes reductions expected from full implementation of the Annex. This provides a basis for comparing results to other strategies being modeled by the WRAP. Model Performance and Future Improvements Nitrate concentrations are poorly predicted by the current modeling system, especially in the winter. For this reason, results for nitrate (and all other species) for the NOx and PM sensitivity runs are only presented for the three month period of July – September. Several aspects of the modeling system are being improved and evaluated, which should improve confidence in future model predictions, both in the summer and winter. These improvements and evaluations involve the chemical mechanisms, the ammonia inventory, a more robust meteorological database (2002 vs 1996), enhanced grid resolution (12 km vs 36 km), plume-ingrid capabilities, the introduction of an inventory for wind-blown dust emissions, and better temporal allocation and chemical speciation of point and area source emissions. A source apportionment mechanism is also expected to be included with the model. Model Results As stated above, results are presented in a fairly broad and qualitative manner – i.e., spatial patterns and relative changes. Relative (percent) changes are of particular interest because their errors are believed to be smaller than those of the absolute concentrations. It is not clear how the seasonal limitation of this analysis (July – September) may affect the relative changes, but it is likely to reduce them to some extent. First, nitrate concentrations tend to be lower in the summer than in the winter, especially in areas where nitrate concentrations are highest and the potential for change the greatest. Second, results are averaged over a full three-month period. Typically, visibility effects are measured by averaging conditions over the worst 20 percent of the days observed per year at an ambient monitoring site, which is approximately 22 days. But in this analysis, because it is limited to the July-September timeframe, the results are averaged over 92 consecutive days and do not represent a measure of the worst conditions, again when the potential for change is the greatest. Thus, while there are many uncertainties surrounding the model’s nitrate predictions, the limitation of this study to July – September will tend to limit the apparent impacts from the NOx (and to some extent) PM10 emission changes. On a ton-per-ton basis, reductions in stationary source PM10 emissions appear to yield greater regional haze benefits than reductions in NOx emissions. For instance, when stationary source PM10 emissions are reduced by 98,000 tpy (a 50 percent reduction from GCVTR facilities > 100 tpy), the average summer-time visibility improvement across all Class I areas in the GCVTR (in Mm-1) is about 0.4 percent. When stationary source NOx emissions are reduced by 12 In 1996, stationary sources in the GCVTR emitted about 75 percent and 83 percent of the NOx and PM10 emissions, respectively, in the13-state WRAP region. V-2 412,000 tpy (a 50 percent reduction from GCVTR facilities > 100 tpy), the visibility improvement is only somewhat greater, at 0.5 percent.13 Hence, on a purely technical basis (without considering existing controls, costs, or other implementation issues), reductions in PM emissions might be more effective at improving regional haze than reductions in NOx emissions. Nevertheless, the 50 percent NOx reduction scenario tends to produce slightly greater regional haze benefits than the 50 percent PM10 reduction scenario. This is because stationary sources comprise 33 percent of the total NOx inventory but only 7 percent of the total PM10 inventory. So even though much of the NOx is never converted to the particulate phase, the sheer volume of NOx emission reductions relative to PM10 reductions and the fact that nitrate (mostly in the fine mode) scatters light more efficiently than primary PM (mostly in the coarse mode) make the NOx reduction scenario more meaningful in terms of regional haze benefits than the PM10 reduction scenario. The fact that stationary source NOx emissions are not as well controlled as stationary source PM10 emissions in the West actually lends some relevance to the outcome that NOx emissions are altered more in the sensitivity analysis than PM10 emissions. For the three-month summer period examined in this analysis, NOx changes have very little effect on aerosol concentrations beyond changes in nitrate. Other species that could be indirectly affected – e.g., ozone concentrations and subsequent oxidation of SO2 and organic gases into the particulate phase – do not appear influenced by the levels of NOx reductions (16 percent of the total inventory) assumed in this analysis. This finding may change after implementing all the model improvements noted above, but since nitrate currently appears as the largest responder to NOx changes, and given the information above regarding the NOx and PM scenarios, the maps, tables, and discussion below place somewhat more emphasis on nitrate and the results of the 50 percent NOx reduction scenario than on other species and scenarios. Figures V-1 and V-2 show the model-predicted 2018 base case (Annex included) surface-layer concentrations of ammonium nitrate (NH4NO3) and PM10, respectively, averaged over the three month period of July-September. The values in these maps should not be construed as the expected ammonium nitrate and PM10 concentrations in 2018, which are determined by scaling the ambient monitoring data by the relative changes predicted by the model. Rather, these maps are intended to provide a sense of the spatial variability and span of concentrations, which are useful for interpreting the following maps of relative (percent) changes – e.g., a high percentage change in a low-concentration area may be less meaningful than a moderate percentage change in a high concentration area. Figures V-3 and V-4 show the absolute and percentage change, respectively, in NH4NO3 concentrations from a 50 percent reduction in stationary source NOx emissions from facilities in the GCVTR greater than 100 tpy. The largest absolute changes occur in southern CA, where concentrations in Class I areas are predicted to decrease by 0.15 to 0.25 ug/m3. A second area of reductions is predicted in the central-east Rocky Mountains, especially in north-central CO. Although the reductions are not as large as in southern CA (0.04 to 0.11 ug/m3), they are larger than average across the domain and exhibit the largest percentage reduction (10 to 20 percent). 13 In some Class I areas, the visibility improvement can be two to five percent on some days. V-3 It is interesting to compare these results with those simulating the effects of the SO2 backstop emissions trading program, or Annex. In the case of the Annex, an SO2 emission reduction of 15 percent (132,000 tons) in the GCVTR produced a sulfate reduction of 4 percent averaged across all Class I areas in the GCVTR on the 20% worst modeled days. In the case of the NOx sensitivity run, a NOx emission reduction of 15 percent (412,000 tons) in the GCVTR produced a nitrate reduction of 5 percent averaged across all Class I areas in the GCVTR on the JulySeptember modeled days. The nitrate reduction does not produce as much visibility benefit at most Class I areas because its concentrations are much smaller, but the response of nitrate to NOx reductions is similar in proportion to the response of sulfate to SO2 reductions. Figures V-5 and V-6 show the absolute and percentage change, respectively, in NH4NO3 concentrations from a 25 percent increase in stationary source NOx and PM10 emissions from all stationary sources in the GCVTR. The spatial pattern of changes is very similar to that in the 50 percent NOx reduction scenario, although the magnitude of changes are about half. Again, it is interesting to see some proportionality in the modeling results – i.e., an emission change that is half as large produces aerosol changes that are about half as large. The percent increase in NH4NO3 concentrations and visibility impairment (in Mm-1) in this scenario is 2 percent and 0.5 percent, respectively, when averaged over all Class I areas in the GCVTR for JulySeptember. Figures V-7 and V-8 show the absolute and percentage change, respectively, in PM10 concentrations from a 50 percent reduction in stationary source PM10 emissions from facilities in the GCVTR greater than 100 tpy. Maximum reductions in PM10 are about 0.1 to 0.5 ug/m3, or about 4 to 8 percent. Compared to the NOx reduction scenario, reductions in ambient PM10 are more dispersed, with a greater number of local maximums. This may reflect the fact that there are a fewer number of large PM10 sources than large NOx sources and that much of the PM10 emissions are coarse particles, with shorter transport distances. Figures V-9 and V-10 show the absolute and percentage change, respectively, in PM10 concentrations from a 25 percent increase in stationary source NOx and PM10 emissions from all stationary sources in the GCVTR. The spatial pattern of changes reflects where both relatively large NH4NO3 changes (southern CA and central-east Rockies) and PM10 changes (additional areas) are predicted. The largest PM10 increases are about 0.1 to 0.3 ug/m3, or 2 to 3 percent. Less than half of this is NH4NO3. Table V-1 shows the predicted change in light extinction and NH4NO3 at each Class I area in the GCVTR averaged over the July-September period as a result of reducing NOx emissions by 50 percent from stationary sources with emissions greater than 100 tpy in the GCVTR.14 As shown in the maps, the greatest impacts occur in southern CA, followed by areas in CO. The average improvements in light extinction in these areas is about 0.3 to 1.5 Mm-1 (1 to 2.5 percent). The average improvement in NH4NO3 is about 0.05 to 0.25 ug/m3 (3 to 20 percent). 14 Tabular, site-specific data for other scenarios is available upon request. Tabulay presentation of results was limitted to this scenario since others tend to produce smaller changes in visibility. V-4 Figure V-1. Base Case Ammonium Nitrate Concentrations (µg/m3) – for purposes of illustrating spatial patterns, not magnitudes. Figure V-2. Base Case PM10 Concentrations (µg/m3) – for purposes of illustrating spatial patterns, not magnitudes. V-5 Figure V-3. Change in Ammonium Nitrate Concentrations Resulting from a 50% Reduction in Stationary Source NOx Emissions > 100 tpy. Figure V-4. Relative Change in Ammonium Nitrate Concentrations Resulting from a 50% Reduction in Stationary Source NOx Emissions > 100 tpy. V-6 Figure V-5. Change in Ammonium Nitrate Concentrations Resulting from a 25% Increase in Stationary Source NOx and PM10 Emissions. Figure V-6. Relative Change in Ammonium Nitrate Concentrations Resulting from a 25% Increase in Stationary Source NOx and PM10 Emissions. V-7 Figure V-7. Change in PM10 Concentrations Resulting from a 50% Reduction in Stationary Source PM10 Emissions > 100 tpy. Figure V-8. Relative Change in PM10 Concentrations Resulting from a 50% Reduction in Stationary Source PM10 Emissions > 100 tpy. V-8 Figure V-9. Change in PM10 Concentrations Resulting from a 25% Increase in Stationary Source NOx and PM10 Emissions. Figure V-10. Relative Change in PM10 Concentrations Resulting from a 25% Increase in Stationary Source NOx and PM10 Emissions. V-9 Table V-1. Light Extinction and Ammonium Nitrate Changes Resulting from a 50% Reduction in Stationary Source NOx Emissions > 100 tpy, Sorted by Average Light Extinction. Light Extinction -1 ∆ Mm ∆% State GCVTR Class I Area CA CA CA CA CA CO CO CO CA CO CO NM CO CO CO CO CO CO CA CA NM AZ NM AZ WY CA CA NM CA OR NM NM AZ OR OR CA CA CA CA AZ CA CA UT Cucamonga Wilderness San Jacinto Wilderness San Gabriel Wilderness Agua Tibia Wilderness San Gorgonio Wilderness Rawah Wilderness Mount Zirkel Wilderness Rocky Mountain NP Joshua Tree NP Eagles Nest Wilderness Great Sand Dunes NM White Mountain Wild. Flat Tops Wilderness La Garita Wilderness West Elk Wilderness Black Canyon of Gunnison Weminuche Wilderness Maroon Bells-Snowmass Dome Land Wilderness Pinnacles NM Wheeler Peak Wilderness Mount Baldy Wilderness Salt Creek Wilderness Petrified Forest NP Bridger Wilderness Hoover Wilderness Emigrant Wilderness Gila Wilderness Minarets Mount Jefferson Wild. San Pedro Parks Wild. Bandelier NM Superstition Wilderness Mount Washington Wild. Mount Hood Wilderness Kaiser Wilderness Kings Canyon NP John Muir Wilderness San Rafael Wilderness Sierra Ancha Wilderness Sequoia NP Yosemite NP Arches NP V-10 -1.59 -1.13 -0.83 -0.81 -0.80 -0.69 -0.61 -0.57 -0.47 -0.45 -0.43 -0.36 -0.34 -0.34 -0.33 -0.31 -0.29 -0.29 -0.27 -0.26 -0.24 -0.22 -0.22 -0.21 -0.20 -0.20 -0.19 -0.18 -0.18 -0.17 -0.17 -0.17 -0.16 -0.16 -0.14 -0.14 -0.14 -0.14 -0.14 -0.13 -0.13 -0.13 -0.13 -1.37 -1.18 -0.82 -1.05 -0.93 -2.41 -2.28 -1.68 -0.77 -1.41 -1.57 -1.11 -1.28 -1.27 -1.19 -0.97 -1.14 -1.00 -0.46 -0.86 -0.91 -0.64 -0.71 -0.73 -0.77 -0.19 -0.25 -0.34 -0.23 -0.28 -0.64 -0.58 -0.40 -0.30 -0.22 -0.19 -0.22 -0.23 -0.32 -0.35 -0.24 -0.17 -0.51 NH4NO3 3 ∆ µg/m µ ∆% -0.25 -0.19 -0.13 -0.12 -0.16 -0.11 -0.09 -0.09 -0.13 -0.07 -0.06 -0.05 -0.05 -0.05 -0.05 -0.04 -0.04 -0.04 -0.04 -0.04 -0.03 -0.03 -0.02 -0.01 -0.03 -0.04 -0.03 -0.02 -0.03 -0.02 -0.02 -0.02 -0.02 -0.02 -0.03 -0.02 -0.02 -0.02 -0.01 -0.01 -0.02 -0.02 -0.01 -3.25 -2.97 -3.06 -2.77 -2.65 -16.84 -20.86 -14.14 -3.69 -11.97 -13.87 -10.51 -13.82 -12.15 -12.09 -14.83 -13.02 -10.62 -4.48 -5.93 -8.94 -6.25 -7.75 -6.88 -7.51 -2.60 -3.08 -3.81 -2.71 -2.59 -10.43 -7.42 -2.04 -2.55 -1.83 -2.63 -2.83 -2.69 -5.40 -1.76 -4.56 -2.63 -14.82 Light Extinction -1 ∆ Mm ∆% State GCVTR Class I Area NM WY NM OR OR OR AZ UT WY WY OR ID OR AZ CA AZ AZ AZ UT OR AZ UT AZ AZ NM OR UT CO CA WY CA ID WY WY CA ID OR CA CA CA CA NV CA CA Pecos Wilderness Fitzpatrick Wilderness Bosque del Apache Wild. Kalmiopsis Wilderness Eagle Cap Wilderness Three Sisters Wilderness Grand Canyon NP Capitol Reef NP Grand Teton NP Teton Wilderness Crater Lake NP Hells Canyon Wilderness Strawberry Mountain Wild. Sycamore Canyon Wild. Marble Mountain Wild. Chiricahua NM Chiricahua Wilderness Galiuro Wilderness Canyonlands NP Diamond Peak Wild. Saguaro Wilderness Bryce Canyon NP Pine Mountain Wild. Mazatzal Wilderness Carlsbad Caverns NP Mountain Lakes Wild. Zion NP Mesa Verde NP Lava Beds Wilderness Yellowstone NP South Warner Wilderness Selway-Bitterroot Wild. North Absaroka Wild. Washakie Wilderness Point Reyes NS Craters of The Moon Wild. Gearhart Mountain Wild. Caribou Wilderness Thousand Lakes Wild. Lassen Volcanic NP Yolla Bolly Middle Eel Wild. Jarbridge Wilderness Ventana Wilderness Redwood NP Average V-11 -0.12 -0.12 -0.12 -0.11 -0.11 -0.11 -0.11 -0.11 -0.11 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10 -0.09 -0.09 -0.09 -0.08 -0.08 -0.08 -0.08 -0.07 -0.07 -0.07 -0.06 -0.06 -0.06 -0.05 -0.05 -0.05 -0.05 -0.04 -0.04 -0.04 -0.03 -0.03 -0.03 -0.03 -0.02 -0.02 -0.21 -0.44 -0.46 -0.44 -0.34 -0.31 -0.24 -0.40 -0.45 -0.36 -0.36 -0.21 -0.13 -0.15 -0.32 -0.23 -0.36 -0.36 -0.30 -0.42 -0.18 -0.28 -0.32 -0.24 -0.23 -0.26 -0.18 -0.21 -0.21 -0.15 -0.20 -0.19 -0.12 -0.19 -0.19 -0.15 -0.14 -0.13 -0.11 -0.09 -0.07 -0.09 -0.13 -0.12 -0.06 -0.51 NH4NO3 3 ∆ µg/m µ ∆% -0.03 -0.02 -0.01 -0.01 -0.02 -0.02 -0.01 -0.01 -0.02 -0.02 -0.01 -0.02 -0.01 -0.01 -0.01 0.00 0.00 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.03 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 0.00 -0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -0.03 -7.29 -4.83 -8.65 -3.05 -4.29 -2.55 -7.36 -8.21 -3.47 -3.56 -2.09 -3.87 -2.89 -5.25 -2.57 -6.65 -6.65 -4.30 -10.61 -2.20 -6.84 -6.14 -2.82 -2.82 -4.03 -2.43 -7.22 -17.68 -2.09 -2.50 -3.77 -2.19 -2.43 -2.43 -2.80 -3.89 -2.24 -3.38 -2.30 -2.28 -1.13 -4.49 -5.24 -2.92 -5.79 SECTION VI: SUMMARY OF EMISSION CONTROLS AVAILABLE FOR LARGE STATIONARY SOURCES OF NOx AND PM Final Report Prepared for: Lee Alter Western Governors’ Association 1515 Cleveland Place, Suite 200 Denver, CO 80202-5114 Prepared by: Constance Senior, Brooke Shiley, Bradley Adams Reaction Engineering International 77 West 200 South, Suite 210 Salt Lake City, UT 84101 Rui Afonso Energy & Environmental Strategies 50 Old Faith Road Shrewsbury, MA 01545 June 30, 2003 TABLE OF CONTENTS 1 INTRODUCTION ...............................................................................................................................................1 1.1 1.2 1.3 2 NOX AND PM SOURCES IN THE WESTERN UNITED STATES ..............................................................6 2.1 2.2 2.3 2.4 2.4 2.5 3 PROPOSED MULTI-POLLUTANT EMISSION REGULATIONS FROM UTILITY BOILERS .......................................51 MULTI-POLLUTANT CONTROL TECHNOLOGIES.............................................................................................52 SUMMARY AND RECOMMENDATIONS...................................................................................................56 6.1 6.2 6.3 6.4 7 OVERVIEW....................................................................................................................................................46 PM CONTROL FOR COAL-FIRED BOILERS AND OTHER COMBUSTION SOURCES ...........................................47 OTHER DEVELOPMENTS ...............................................................................................................................48 COSTS ...........................................................................................................................................................49 MULTI-POLLUTANT CONTROL TECHNOLOGIES ...............................................................................51 5.1 5.2 6 OVERVIEW....................................................................................................................................................24 COAL-FIRED BOILERS ..................................................................................................................................39 RECIPROCATING ENGINES ............................................................................................................................42 CEMENT KILNS .............................................................................................................................................43 NATURAL GAS AND OIL FIRED BOILERS ......................................................................................................43 TURBINES .....................................................................................................................................................44 PM CONTROL TECHNOLOGIES ................................................................................................................46 4.1 4.2 4.3 4.4 5 CHARACTERIZATION OF NOX SOURCES ..........................................................................................................6 COMPARISON WITH OTHER DATABASES FOR NOX CONTROL TECHNOLOGIES ..............................................13 TRENDS IN NOX EMISSIONS AND CONTROLS FOR COAL-FIRED UTILITY BOILERS, 1995-2000. ....................16 CHARACTERIZATION OF SOURCES OF PARTICULATE MATTER (PM).............................................................17 CHARACTERIZATION OF SOURCES OF PARTICULATE MATTER (PM).............................................................18 COMPARISON WITH OTHER DATABASES FOR PM CONTROL TECHNOLOGIES ...............................................22 NOX CONTROL TECHNOLOGIES...............................................................................................................24 3.1 3.2 3.3 3.4 3.5 3.6 4 BACKGROUND ................................................................................................................................................1 OBJECTIVES ....................................................................................................................................................1 DEFINITIONS AND METHODOLOGY .................................................................................................................2 NOX AND PM SOURCES ................................................................................................................................56 CONTROLS FOR NOX AND PM.......................................................................................................................57 WHAT’S ON THE HORIZON? WHAT TRENDS WILL INFLUENCE EMISSIONS AND CONTROL TECHNOLOGIES?...58 RECOMMENDATIONS FOR FUTURE WORK ....................................................................................................59 REFERENCES ..................................................................................................................................................60 APPENDIX A: BREAKDOWN OF NOX EMISSIONS BY STATE APPENDIX B: BREAKDOWN OF PM EMISSIONS BY STATE APPENDIX C: NOX CONTROL TECHNOLOGY SUMMARIES APPENDIX D: PM CONTROL TECHNOLOGY SUMMARIES http://www.reaction-eng.com VI-i REACTION ENGINEERING INTERNATION AL LIST OF ACRONYMS, ABBREVIATIONS AND SYMBOLS ACFM AFBC BART DLN EIA EPA GCVTC GCVTR FGR Hg ICE LEC LNB MBtu MTF NG NOx NSCR NSPS O&M OFA PM PM10 PM2.5 SCC SCR SIP SNCR SO2 TPY WGA WRAP Actual cubic feet per minute Atmospheric fluidized bed combustor Best available retrofit technology Dry Low NOx Energy Information Administration United States Environmental Protection Agency Grand Canyon Visibility Transport Commission Grand Canyon Visibility Transport Region Flue Gas Recirculation Mercury Internal Combustion Engine Low Emission Combustion Low-NOx burner Millions of British Thermal Units Market Trading Forum Natural Gas Nitrogen oxides Non-selective catalytic reduction New Source Performance Standard Operating and Maintenance Overfire air Particulate matter Particulate matter less than 10 microns Particulate matter less than 2.5 microns Source Classification Code Selective catalytic reduction State Implementation Plan Selective non-catalytic reduction Sulfur dioxide Tons per year Western Governors’ Association Western Regional Air Partnership http://www.reaction-eng.com VI-ii REACTION ENGINEERING INTERNATION AL ACKNOWLEDGEMENTS We are grateful to Dr. Praveen Amar for providing help in locating the most recent sources of information on control technologies, as well as for external review of the report from the perspective of making it relevant to readership in the state governments/regional entities. http://www.reaction-eng.com VI-iii REACTION ENGINEERING INTERNATION AL 1 INTRODUCTION 1.1 Background The Western Regional Air Partnership (WRAP) has undertaken a program to assess emissions control technologies and strategies for large stationary sources of NOx and PM emissions in the western states region. The WRAP is a collaborative effort of tribal governments, state governments, and various federal agencies to implement the recommendations of the Grand Canyon Visibility Transport Commission (GCVTC) and to develop the technical and policy tools needed by western states and tribes to comply with the U.S. Environmental Protection Agency’s (EPA) Regional Haze Rule. The WRAP established the Market Trading Forum (MTF), in large part, to develop and recommend emission control strategies for stationary sources of air pollution. A major focus of the MTF has been the establishment of regional emission milestones for sulfur dioxide (SO2) and a regional backstop cap-and-trade program for SO2 to be triggered if the milestones are not met voluntarily. The MTF is also responsible for generating a report required in 40 CFR 51.309(d)(4)(v) of the Regional Haze Rule. The report must assess emission control technologies and strategies for stationary source NOx and PM emissions and the degree of visibility impairment that would result from such strategies. It must also evaluate the need for NOx and PM milestones to avoid any net emissions increase and to support possible multi-pollutant and multi-source control programs. Finally, this year several states must submit state implementation plans (SIPs) to EPA and must commit to a 2008 revision containing any necessary long-term strategies and Best Available Retrofit Technology (BART) requirements for stationary source NOx and PM. This project is essentially a starting point for addressing stationary source NOx and PM emission sources over the next four years, at which point local and/or regional emission control program(s) may be implemented. Future work by the WRAP will investigate these issues further and will attempt more detailed cost estimates and emission reductions achievable in the WRAP region given the nature of its sources and existing controls. 1.2 Objectives The main objectives of this project are to identify and briefly describe for large stationary sources in the western United States: • The universe of modern commercially-available or near-available stationary source NOx and PM controls (either technologies or best management practices); • Trends in such controls; • Their approximate capital and operating costs, control efficiencies, and cost effectiveness; • Secondary environmental impacts, such as control of other air pollutants and generation of solid or hazardous waste; • Real-world experience at facilities implementing or testing such controls; http://www.reaction-eng.com VI-1 REACTION ENGINEERING INTERNATION AL 1.3 • Future opportunities for improvements and demonstrations; and • Recommendations for future work. Definitions and Methodology The work plan for the project consisted of the following tasks: Task 1. Inventory of Stationary Sources in the WRAP Region. This task involved a review of the 1996 WRAP stationary source emissions inventory (version 3, in MS Access format), as well as other recent and relevant databases to determine the number/type of stationary sources with emissions greater than 100 tons per year (TPY) and the type and performance of air pollution control devices installed on those sources. Two subsets were created for NOx and PM emissions, respectively, based on the following criteria: • Sources (defined as emission units, or records, in the database) having annual emissions of the pollutant of interest greater than 100 TPY; and • Sources located in the thirteen-state region: AZ, CA, CO, ID, MT, ND, NM, NV, OR, SD, UT, WA, WY (See Figure 1). Table 1 lists the fields extracted from the WRAP database. Figure 1. Thirteen-state region considered in the technology assessment. http://www.reaction-eng.com VI-2 REACTION ENGINEERING INTERNATION AL Table 1. WRAP database fields used in the technology assessment. Field FIPST POINTID STACKID BLRID SEGMENT ORISID PLANT SCC SCC1_DESC SCC3_DESC SCC6_DESC SCC8_DESC NOX_ANN PM10_ANN CO_ANN SO2_ANN NOX_CPRI PM_CPRI CONTROL_DEVICE_DESC Description FIP State Code NAPAP Point ID Code Stack Number Boiler ID Code Code (utility only) Segment Number ORIS Plant ID (utility only) Plant Name Source Classification Code General category (e.g., External Combustion Boiler) Major industrial group within general category Specific industry or emission source Particular emitting process or fuel type Annual NOx Emissions, tons per year Annual PM Emissions, tons per year Annual CO Emissions, tons per year Annual SO2 Emissions, tons per year Primary Control Equipment Code - NOx Primary Control Equipment Code - PM Control Device Description (either NOx or PM) Note: Codes taken from the 1996 National Emission Trends (NET) PC Inventory File Format The source classification codes (SCCs) used to categorize sources served as general guidelines for choosing the categories in Task 1. The similarities (or differences) in the control technologies applicable to specific SCCs were also factors in grouping sources. For example, a category called “Coal-fired boilers” was created containing emissions data from utility and industrial boilers (of different boiler types) burning coal because the same NOx and PM control technologies can be applied to most of these sources. With this in mind, Table 2 gives the categories created for characterization of the WRAP emissions and a description of the WRAP categories (i.e., SCC codes) used to define the categories in this report. For electric utility point sources, additional databases were used to determine boiler capacity (MBtu/yr), enhance and update information on control technologies in place, and verify other source information. These databases were: EPA CEMs database for 1996 and 2001 [1], EPA EGRID database for 1996 and 2000 [2] and the EIA-767 database for 1996 [3]. The results of Task 1 are discussed in Section 2 of this report. http://www.reaction-eng.com VI-3 REACTION ENGINEERING INTERNATION AL Table 2. List of Categories Used to Characterize Point Sources Category Coal-Fired Boilers Reciprocating Engines NG Diesel Process Gas Cement Kilns Oil/NG Boilers Turbines NG Diesel WRAP Sources (based on SCC Codes contained with the category) All coal-fired external combustion boilers All reciprocating ICE’s Natural gas-fired ICE’s, including 2- and 4-cycle Diesel-fired ICE’s, including large-bore engines Unspecified process gas-fired ICE’s All cement kilns (wet and dry process) External combustion boilers firing oil or natural gas All fired turbines Natural gas-fired turbines Diesel-fired turbines Cement crushing, grinding and drying, asphalt, other drying Mineral Processing applications Flares, cat.crackers, nitric acid plants, unspecified process gas Petrochemical operations, does not include process heaters NG Compressor Technology (reciprocating engine or turbine) not specified Pulp and Paper Recovery boilers, lime kilns, drying and smelting Wood Boilers Wood waste and/or bark boilers, technology unspecified Refinery Process Heaters Process heaters Glass Manufacture Glass melting furnaces Electric arc furnaces, reheat furnaces, material handling and Primary Metal Production unspecified Waste Combustion Liquid waste (Dakota gasifier) and solid waste (WTE) Refinery Unspecified refinery emissions In-process Fuel Use Unspecified combustion systems at glass and cement plants Jet Engine Testing Jet engine testing Oil and Gas Production Flares and unspecified processes Smelting Operations Copper and aluminum smelting Sugar Beet Processing Sugar beet processing Secondary Metal Production Steel foundries Turbines, Steam Geothermal power production http://www.reaction-eng.com VI-4 REACTION ENGINEERING INTERNATION AL Task 2. Survey and Documentation of Emission Control Technologies. In this task, we focused on the identification and compilation of control technologies for NOx and PM (main focus) and for SO2 and Hg (secondary focus). Sources identified in Task 1 that represented minor contributions to the emissions profile of the region, either due to their small number, uniqueness, or size, were considered in a more cursory fashion if their control technology options fell outside of the range of the more common/available technologies. This effort consisted mainly of literature reviews, on-line searches and personal (telephone) contacts and interviews. The following information was collected on each technology or process: • • • • • Type and fundamentals of technology or process; Projected performance; Costs (capital and O&M or cost effectiveness in $/ton of pollutant removed) or cost projections; Status of development and opportunities for or barriers to further development; and Applicability to category (or categories) of WRAP sources identified in Task 1. The results of this task are presented in Sections 3 and 4. Task 3. Control Technology Analysis and Discussion. This task was the main focus of the project, in which a thorough evaluation and discussion of the many identified technologies was conducted. A summary containing the following information was created for each technology: • • • • Process name For each source category to which the technology was applicable, the following information was tabulated: o Total annual NOx or PM emissions from sources greater than 100 TPY o Percentage NOx and PM reduction o Cost ($/ton or $/ACFM) o Development status Detailed descriptions were prepared for the following: o Process description o Achievable NOx or PM reduction o Cost information o Development status o Practical considerations o Compatibility with other air pollution control technologies o Secondary environmental impacts References The results of this task are presented in Appendices C and D. Task 4. Final Report. The draft version of the final report was submitted to WRAP on 25 April 2003. The final report was submitted on 30 June 2003. http://www.reaction-eng.com VI-5 REACTION ENGINEERING INTERNATION AL 2 NOx AND PM SOURCES IN THE WESTERN UNITED STATES 2.1 Characterization of NOx Sources Table 3 gives the annual NOx emissions in the GCVTR as well as in thirteen-state region for sources (defined as emission units, or records, in the WRAP database) exceeding 100 TPY. The cut-off of 100 TPY captures 84% of the stationary source NOx emissions in the WRAP database for the thirteen-state region. Figure 2 shows the distribution of annual NOx emissions (greater than 100 TPY) as a function of state. The largest source category by far in the thirteen-state region is coal-fired boilers (69%); the top five categories (coal-fired boilers, internal combustion engines, cement kilns, turbines and oil and natural gas boilers) account for almost 90% of the NOx emissions. Therefore, this report concentrates on control technologies applicable to these major process categories. The states with the largest NOx emissions are AZ, CA, ND, NM, UT, and WY. Since all these states except ND are in the GCVTR, it is not surprising that emissions from the nine states in the GCVTR (AZ, CA, CO, ID, NM, NV, OR, UT, WY) account for 75% of the thirteen-state emissions greater than 100 TPY. Appendix A contains NOx emissions by process category and by state. 140,000 Annual NOx Emissions, TPY 120,000 100,000 80,000 60,000 40,000 20,000 0 AZ CA CO ID MT ND NM NV OR SD UT WA WY Figure 2. Annual NOx emissions from sources with emissions greater than 100 TPY for the thirteen-state region. http://www.reaction-eng.com VI-6 REACTION ENGINEERING INTERNATION AL Table 3. A comparison of annual emissions of NOx from sources with emissions greater than 100 TPY between the thirteen-state region and the GCVTR. Category 13-States Total NOx TPY (>100 TPY) # Units GCVTR Total NOx TPY # Units (>100 TPY) % NOx in GCVTR Coal-Fired Boilers Reciprocating Engines Cement Kilns Oil/NG Boilers Turbines 151 423 39 112 86 607,748 86,210 41,009 32,910 25,278 117 394 31 80 78 436,882 78,092 32,503 26,116 23,955 72% 91% 79% 79% 95% Mineral Processing, Other Petrochemical NG Compressor Pulp and Paper Wood Boilers Refinery Process Heaters Glass Manufacture Primary Metal Production Waste Combustion Fugitive In-process Fuel Use Fixed Wing Aircraft Oil and Gas Production Smelting Operations Food and Agriculture Secondary Metal Production Turbines, Steam 34 48 16 39 48 38 14 17 6 8 9 4 7 3 3 4 1 16,250 13,719 10,959 10,010 9,776 9,311 5,033 3,476 3,309 3,256 2,605 2,297 1,140 961 730 507 165 25 31 16 20 36 29 12 16 2 8 8 4 5 2 1 0 1 13,342 8,326 10,959 4,619 6,864 7,302 4,379 3,360 339 3,256 2,016 2,297 792 852 111 0 165 82% 61% 100% 46% 70% 78% 87% 97% 10% 100% 77% 100% 70% 89% 15% 0% 100% 1,110 886,659 916 666,527 75% Total (> 100 TPY) http://www.reaction-eng.com VI-7 REACTION ENGINEERING INTERNATION AL With few exceptions, the distribution of NOx sources is similar in the thirteen-state region as compared to the GCVTR. ICE’s (reciprocating engines and turbine) are predominantly in the GCVTR, while pulp and paper emissions are mostly outside the GCVTR. As a result of this similarity, the scope of this project was expanded to include additional WRAP states at minimal cost. The achievable NOx emission rate depends on the fuel type. For coal-fired boilers, lower NOx emission rates are obtained when firing subbituminous coal as compared to bituminous coal. Thus, it is useful to look at the distribution of coals in use in the thirteen-state region. Figure 3 shows the distribution of coals burned in utility boilers as a function of boiler type and coal rank. Most coal burned in the West is burned close to the mine; this distribution of coal rank reflects the native coals in the West. 300,000 Lignite Subituminous Bituminous NOx, tons per year 250,000 200,000 150,000 100,000 50,000 0 Dry Bottom (Wall-fired) Dry Bottom Wet Bottom (Tangential) Stoker Cyclone AFBC Figure 3. NOx emissions from coal-fired utility boilers as a function of boiler type and coal rank for thirteen-state region from WRAP 1996 database. http://www.reaction-eng.com VI-8 REACTION ENGINEERING INTERNATION AL For ICE’s, the application of NOx control technology can depend on the type of fuel. More so than with utility boilers, the design and operation of the engine is often determined by the primary fuel. Most of the stationary ICE’s with annual emissions greater than 100 TPY burn natural gas, as shown in Figure 4. 100,000 Process Gas 90,000 Diesel NG NOx Emissions, tons per year 80,000 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 Reciprocating Engines Turbines Figure 4. NOx emissions from Internal Combustion Engines as a function of engine type and fuel for thirteen-state region from WRAP 1996 database. As long as a source category consists of primarily large sources, the cut-off of 100 TPY will include most of the NOx emission sources. The 100-TPY cut-off captures 84% of the NOx emissions in the WRAP database as a whole. However, certain source categories contain a very large number of small sources. For ICE’s (reciprocating engines and turbines) the 100-TPY cutoff only captures about 56% of the emissions as shown in Figures 5 and 6, although this is by far the second largest source category of stationary source NOx emissions. Thus, NOx control programs for sources in this category will require careful consideration of population attributes (e.g., controlling a large number of small sources). http://www.reaction-eng.com VI-9 REACTION ENGINEERING INTERNATION AL 100% Cumulative NOx Emissions 90% 30, 82.4% 80% 40, 78.0% 50, 73.9% 70% 60% 100, 55.6% 50% 40% 30% 20% 10% 0% 0 500 1000 1500 2000 2500 3000 3500 4000 TPY/sources Figure 5. Cumulative NOx emissions from ICE’s in the thirteen-state region as a function of annual emission per source. TPY/source 53.00 19.20 9.54 4.19 1.84 0.52 0.10 0.00 Cumulative NOx Emissions 100% 90% 30 TPY, 82.4% 40 TPY, 78.0% 50 TPY, 73.9% 80% 70% 60% 100TPY, 55.6% 50% 40% 30% 20% 10% 0% 0 1000 2000 3000 4000 5000 6000 7000 Number of Sources (in order of decreasing TPY/source) 8000 Figure 6. Cumulative NOx emissions from ICE’s in the thirteen-state region as a function of number of sources (in order of decreasing annual emission per source.) http://www.reaction-eng.com VI-10 REACTION ENGINEERING INTERNATION AL The 1996 WRAP database contains information on control technologies for the pollutants of interest. According to the 1996 data for sources greater than 100 TPY, few sources had NOx controls, as shown in Table 4. Overall, just above 4% of the NOx sources greater than 100 TPY in the WRAP 1996 database had installed controls. Coal-fired boilers were the most frequently controlled (15% of the units), followed by petrochemical processes (about 13% of the units). Note that control technologies listed in the right-hand column are as reported in the WRAP database. In a few cases, the description of the control technology does not seem correct (e.g., fabric filter or electrostatic precipitator) for NOx control; this is a limitation of the data available and it is outside the scope of this program to determine the accuracy of the data in the WRAP database. http://www.reaction-eng.com VI-11 REACTION ENGINEERING INTERNATION AL Table 4. NOx Control Technologies in use in 1996 on Sources Greater than 100 TPY from 1996 WRAP database. http://www.reaction-eng.com VI-12 REACTION ENGINEERING INTERNATION AL # Units Units Controlled Total NOx TPY Avg NOx TPY/Unit NOx Control Technology (number of applications in parentheses) Coal-Fired Boilers 151 23 607,748 4,025 Ammonia Injection(2), Fluid Bed Dry Scrubber(1), Low Excess Air Firing(3) , Modified Furnace Or Burner Design(13), Misc.(4) Reciprocating Engines 423 3 86,210 204 Cement Kilns 39 2 41,009 1,052 Oil/NG Boilers 112 4 32,910 294 Low Excess Air Firing(3), SNCR(1) Turbines 86 5 25,278 294 Steam Or Water Injection(5) Mineral Processing 34 1 16,250 478 Fabric Filter - High Temperature, i.e. T>250F(1) Petrochemical 48 6 13,719 286 Catalytic Afterburner(1), Catalytic Afterburner With Heat Exchanger(1), Catalytic Reduction(1), Staged Combustion(2), Tray-Type Gas Absorption Column(1) NG Compressor 16 0 10,959 685 None Pulp and Paper 39 0 10,010 257 None Wood Boilers 48 1 9,776 204 Ammonia Injection(1) Refinery Process Heaters 38 0 9,311 245 None Glass Manufacture 14 0 5,033 360 None Primary Metal Production 17 1 3,476 204 Process Enclosed(1) Waste Combustion 6 0 3,309 552 None Refinery 8 0 3,256 407 None In-process Fuel Use 9 0 2,605 289 None Jet Engine Testing 4 0 2,297 574 None Oil and Gas Production 7 0 1,140 163 None Smelting Operations 3 0 961 320 None Sugar Beet Processing 3 0 730 243 None Secondary Metal 4 0 507 127 None Turbines, Steam 1 0 165 165 None 1,110 46 886,660 799 Category Total Catalytic Reduction(1), Process Change(2) Electrostatic Precipitator – High Efficiency(2) 2.2 Comparison with Other Databases for NOx Control Technologies The level of control for coal-fired boilers in the WRAP database seemed low, even for 1996. Therefore, the 1996 WRAP database was compared with the data available for utility boilers in the 1996 CEMS and E-GRID databases. The EIA-767 database was also searched for NOx control technologies. The E-GRID database should contain the information in the other two databases since it contains data from 24 different federal data sources, including EIA data and other EPA data. Only coal-fired utility boilers were included in this comparison, not all coalfired boilers. However, only 3% of the WRAP NOx emissions from coal-fired boilers in the thirteen-state region were from non-utility boilers. It is worthwhile to take a closer look at utility boilers for two reasons. First, they are by far the largest source of NOx emissions, accounting for 68% of the emissions from sources greater than 100 TPY. Second, the effectiveness of NOx control technologies on boilers depends on the type of the boiler as well as on the fuel burned. For this exercise, the EPA databases (CEMs and E-GRID) were queried to obtain information on capacity (MBtu per year) and control technologies. Data from 1996 was used in order to compare with the WRAP 1996 database. EPA and WRAP records were matched using ORIS Plant ID numbers and plant names. For matching records, control technologies not listed in the WRAP database were added, capacity (MBtu) entries were added, and NOx emissions were replaced from the EPA databases. A comparison of Tables 5 and 6, which contain, respectively, the WRAP data and the WRAP data augmented by the other databases, shows that the combination of the WRAP data and the EPA and EIA data suggests that 44% of the utility boilers had NOx control (in 1996), as compared to only 12% when considering only the WRAP data by itself. The EPA databases probably undergo a more thorough QA/QC procedure than was used to create the WRAP database. Thus, the E-GRID and other federal databases might be expected to have more complete information. http://www.reaction-eng.com VI-13 REACTION ENGINEERING INTERNATION AL Table 5. NOx Emissions and Control Technologies for Utility Boilers in the Thirteen-State Region from WRAP 1996 Database. http://www.reaction-eng.com Number of Units Controlled Units NOx Emissions (TPY) Average Emissions (Tons/Source) Dry Bottom 99 14 489,580 4,945 Modified Furnace/Burner Design (13), Low Excess Air Firing(1) Cyclone 5 1 73,468 14,694 Low Excess Air Firing(1) Wet Bottom 2 0 19,688 9,844 None NG Boiler 48 3 18,813 392 Low Excess Air Firing(3) Stoker 6 0 1,779 296 None Coal-fired AFBC 2 1 1,954 977 None Wood Boiler 2 0 598 299 None None Oil Boilers Total NOx Control Technology 164 19 605,881 3,694 VI-14 Table 6. NOx Emissions and NOx Control Technologies for Utility Boilers in the Thirteen-State Region from WRAP 1996 Database Combined with EPA and EIA Databases. Number of Units Controlled Units NOx Emissions (TPY) Average Emissions (Tons/Source) 100 45 538,003 5,380 Modified Furnace/Burner Design(13) , Low Excess Air Firing(1), Low NOx Burner(21), OFA(3), Misc.(7) Cyclone 5 1 73,528 14,706 Low Excess Air Firing(1) Wet Bottom 3 3 23,409 7,803 Low NOx Burner(3) NG Boiler 47 22 19,917 424 Low Excess Air Firing(3), SCR(2), SNCR(3), Misc.(14) Stoker 6 0 3,987 665 None Coal-fired AFBC 2 2 1,954 977 Low Excess Air Firing(1), Misc.(1) Wood Boiler 3 0 957 319 None Oil Boilers 1 0 110 110 None 167 73 661,866 3,963 Dry Bottom REACTION ENGINEERING INTERNATION AL Total NOx Control Technology The achievable NOx emission rate depends on the boiler-fuel combination. The largest general class of utility boilers (in terms of number and capacity) is the dry bottom boiler. Dry bottom boilers can further be subdivided into wall-fired and tangential. Natural gas boilers emit less NOx than coal-fired boilers per unit of fuel consumed. Of coal-fired boilers, tangential-fired units have the lowest emission rate and cyclones have the highest. The controls in the WRAP database are almost entirely low-NOx burners or other combustion modifications. Figure 7 compares the range of NOx emission rates for all boilers and fuels. Application of low-NOx burners and other combustion modifications can reduce NOx emissions significantly; this can be seen in the large range of NOx emission that is due, in part, to the use of NOx controls on some of the boilers in each subset. Substantial NOx reductions can also be achieved on coal-fired boilers just with combustion modifications. Since 1996, low-NOx burners have continued to improve; currently there are vendors who will guarantee NOx emissions as low as 0.15 lb/MBtu from low-NOx burners or low-NOx firing systems. Furthermore, options have been developed for other combustion modifications, and SCR has begun to be applied to coal-fired boilers. Thus, the potential for NOx control on coalfired boilers is significantly better today than in 1996. 0.6 Tangential fraction of occurrences 0.5 Cyclone 0.4 Natural Gas 0.3 Wall-fired 0.2 0.1 0 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 NOx, lb/MBtu Figure 7. Distribution of NOx emission rates for utility boilers in the thirteen-state region, combination of WRAP and EPA/EIA databases for 1996. http://www.reaction-eng.com VI-15 REACTION ENGINEERING INTERNATION AL 2.3 Trends in NOx Emissions and Controls for Coal-Fired Utility Boilers, 1995-2000. The most recent data available from the EPA databases for electric utility boilers are from 2000. In this section, we compare the 1996 data on NOx emissions and controls discussed in the previous section with data from 2000. Table 7 presents the data for 2000 derived from the EPA E-GRID and CEMS databases; this should be compared with Table 6 for 1996. The capacity of electric utility boilers increased by 37%, from 3,019,873,933 MBtu/yr in 1996 to 4,130,818,353 MBtu/yr in 2000, but the total NOx emissions decreased by 7%. Figure 9 shows that the average annual emissions from dry bottom coal boilers (the largest category) decreased. Overall there was a decrease in emissions and an increase in the number of units that were controlled. The number of sources increased, particularly the number of natural gas boilers, which increased from 47 to 82. The percent of natural gas boilers having NOx controls decreased from 47% to 30%. During the time from 1996 to 2000, low-NOx burners were added to natural gas units; there was also a small increase in SCR and SNCR on these types of boilers. NOx control on dry-bottom boilers increased from 47% to 71% from 1996 to 2000, resulting in a 9% decrease in total NOx emissions from these boilers. The number of units with low-NOx burners doubled. Overfire air (OFA) installations, though small in number, tripled. There were no SCR or SNCR installations on coal-fired boilers in 2000. Thus, there was a modest reduction in NOx emissions from electric utility boilers from 1996 to 2000, accompanied by a substantial increase in generating capacity. NOx control increased, particularly on coal-fired boilers. The added NOx control technologies were primarily low-NOx burners and OFA. http://www.reaction-eng.com VI-16 REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 7. NOx Emissions and NOx Control Technologies for Utility Boilers in the Thirteen-State Region combined with EPA and EIA Databases for 2000. VI-17 Number of Units Controlled Units NOx Emissions (TPY) Average Emissions (Tons/Source) Dry Bottom 96 68 489,680 5,101 Modified Furnace/Burner Design(13), Low Excess Air Firing(1), Low NOx Burner(41), OFA(9), Misc.(4) Cyclone 5 2 66,013 13,203 Low Excess Air Firing(1), OFA(1) NG Boiler 82 25 39,381 480 Wet Bottom 2 2 14,159 15,519 Low NOx Burner(2) Coal-fired AFBC 2 2 2,118 1,059 Low Excess Air Firing(1), Misc.(1) Wood Boiler 2 0 598 299 None Stoker 1 0 335 335 None Oil Boilers 1 0 216 216 None 191 99 612,500 3,207 Total NOx Control Technology Low Excess Air Firing(4), Low NOx Burner(8), OFA(4), SCR(5), SNCR(4) REACTION ENGINEERING INTERNATION AL 2.4 Characterization of Sources of Particulate Matter (PM) Table 8 gives the annual PM emissions for all PM sources in the thirteen-state region with emissions greater than 100 TPY. The cut-off of 100 TPY captures 60% of the PM emissions in the 1996 WRAP database for the thirteen-state region. With few exceptions, the distribution of PM sources is similar in the thirteen-state region as compared to the GCVTR. (Primary metal production emissions are mostly outside the GCVTR.) As a result of this similarity, the scope of this project was expanded to include additional WRAP states at minimal cost. The largest source category (for those sources with emissions greater than 100 TPY) in the thirteen-state region is coal-fired boilers (40%); the top eight categories account for 92% of the PM emissions. Therefore, this report will focus on control technologies applicable to these process categories. The state with the largest PM emissions is WY, followed by AZ, ID, and NM (Figure 9). Since all these states are in the GCVTR, it is not surprising that emissions from the nine states of the GCVTR (AZ, CA, CO, ID, NM, NV, OR, UT, WY) account for 83% of the total stationary source emissions greater than 100 TPY, as shown in Figure 10. Appendix B contains PM emissions by process category and by state. Table 8. Annual Emissions of PM from Sources with Greater than 100 TPY. . Category Coal-Fired Boilers Mineral Processing Petrochemical Wood Boilers Refinery Emissions Primary Metal Production Pulp and Paper Smelting Operations Miscellaneous Oil/NG Boilers Sugar Beet Processing Cooling Tower Cement Kilns Turbines Secondary Metal Production Jet Engine Testing Reciprocating Engines Refinery Process Heaters Total http://www.reaction-eng.com 13-States GCVTR Total PM Total PM TPY (>100 TPY (>100 % PM in # Units TPY) # Units TPY) GCVTR 88 46,010 67 35,137 76% 85 24,499 75 21,824 89% 42 10,836 37 9,716 90% 24 5,718 20 5,210 91% 11 5,631 7 5,011 89% 20 4,697 11 2,244 48% 15 4,476 13 4,119 92% 8 3,555 7 3,397 96% 1 5 5 4 4 2 1 2 3 1 321 2,456 1,379 1,150 932 641 838 537 535 525 176 114,589 VI-18 1 5 3 4 3 2 1 2 3 1 262 2,456 1,379 750 932 524 838 537 535 525 176 95,308 100% 100% 65% 100% 82% 100% 100% 100% 100% 100% 83% REACTION ENGINEERING INTERNATION AL 18,000 1996 Average Emission per Source, TPY 16,000 2000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0 Dry Bottom Cyclone NG Boiler Wet Bottom Coalfired AFBC Wood Boiler Stoker Oil Boilers Figure 8. Average Annual NOx Emissions (greater than 100 TPY) from Electricity Generating Boilers: Comparison of 1996 and 2000 data from EPA Databases. http://www.reaction-eng.com VI-19 REACTION ENGINEERING INTERNATION AL 30,000 Annual PM Emissions, TPY 25,000 20,000 15,000 10,000 5,000 0 AZ CA CO ID MT ND NM NV OR SD UT WA WY Figure 9. Annual PM Emissions from Sources with Emissions Greater than 100 TPY for the Thirteen-State Region. Table 9 lists the control technologies in use in the 1996 WRAP database for particulate matter. 72% of coal-fired boilers, the largest category of emissions, had some form of PM control. Overall, though, only 38% of sources with emissions greater than 100 TPY had controls. http://www.reaction-eng.com VI-20 REACTION ENGINEERING INTERNATION AL Table 9. PM control technologies in use on sources greater than 100 TPY from 1996 WRAP database. http://www.reaction-eng.com PM Control Technology VI-21 REACTION ENGINEERING INTERNATION AL Number of Units Controlled Units Total PM (TPY) Avg PM (TPY/Source) Coal-Fired Boilers 88 64 46,010 523 Centrifugal Collector (Cyclone)(2), Electrostatic Precipitator(35), Fabric Filter(12), Multiple Cyclone(4), Multiple Cyclone/Electrostatic Precipitator(2), Multiple Cyclone/Wet Scrubber(1), Wet Scrubber(8) Mineral Processing 85 29 24,499 288 Centrifugal Collector (Cyclone)(2), Dust Suppression by Chemical Stabilizers or Wetting(5), Dust Suppression by Water Sprays(16), Fabric Filter(1), Water Curtain(1), Wet Scrubber(4) Petrochemical 42 7 10,836 258 Centrifugal Collector (Cyclone)(3), Sulfuric Acid Plant - Contact Process(2), Wet Scrubber(2) Wood Boilers 24 3 5,718 238 Centrifugal Collector (Cyclone)(1), Wet Scrubber(1) Refinery Emissions 11 3 5,631 512 Dust Suppression by Water Sprays(2), Fabric Filter(1) Primary Metal Production 20 7 4,697 235 Alkalized Alumina(2), Dust Suppression by Water Sprays(1), Wet Scrubber(3), Misc.(1) Pulp and Paper 15 3 4,476 298 Centrifugal Collector (Cyclone)(1), Wet Scrubber(1) Smelting Operations 8 0 3,555 444 None Miscellaneous 1 0 2,456 2,456 None Oil/NG Boilers 5 4 1,379 276 Electrostatic Precipitator(4) Sugar Beet Processing 5 1 1,150 230 Centrifugal Collector (Cyclone)(1) Cooling Tower 4 0 932 233 None Turbines 2 0 838 419 None Cement Kilns 4 1 641 160 Electrostatic Precipitator(1) Secondary Metal Production 1 0 537 537 None Jet Engine Testing 2 0 535 267 None Reciprocating Engines 3 0 525 175 None Refinery Process Heaters 1 0 176 176 None 321 122 114,590 357 Total 2.5 Comparison with Other Databases for PM Control Technologies The 1996 WRAP database was compared with the data available for utility boilers in the 1996 CEMS and E-GRID databases. The EIA-767 database was also searched for PM control technologies. The E-GRID database should contain the information in the other two databases since it contains data from 24 different federal data sources, including EIA data and other EPA data. EPA and WRAP records for 1996 were matched using ORIS Plant ID numbers and plant names. For matching records, control technologies not listed in the WRAP database were added, capacity (MBtu) entries were added, and PM emissions were replaced from the EPA databases. The EIA-767 database reported PM emissions as lb PM/MBtu, from which we calculated PM emissions in tons per year. PM emissions data in the EPA databases do not agree with data in the WRAP database, suggesting that the data were obtained from different measurement and/or estimation methods. The differences, illustrated by a few sample records in Table 10, follow no general trend from plant to plant. Table 10. Sample PM Records from WRAP 1996 and EPA 1996 databases. Boiler Four Corners 1 (NM) Four Corners 2 (NM) Four Corners 3 (NM) Four Corners 4 (NM) Four Corners 5 (NM) Capacity (MBtu/yr) 16,530,550 9,369,730 18,823,220 58,100,720 52,759,010 PM Emissions Rate, EPA (PM/MBtu) 0.03 0.03 0.03 0.01 0.01 Reid Gardner 1 (NV) Reid Gardner 2 (NV) Reid Gardner 3 (NV) Reid Gardner 4 (NV) 9,599,371 23,152,788 30,579,084 42,514,192 0.05 0.05 0.05 0.05 PM Emissions Rate, WRAP (PM/MBtu) 0.13 0.13 0.13 0.03 0.03 PM Emissions, EPA (TPY) 248 141 282 291 264 PM Emissions, WRAP (TPY) 1,048 618 1,243 883 789 0.05 0.01 0.02 0.01 240 579 764 1,063 222 128 278 245 A comparison of Tables 11 and 12, which contain, respectively, the WRAP data and the WRAP data augmented by the other databases, shows that the combination of the WRAP data and the EPA and EIA data suggests that about 94% of the utility boilers had PM control (in 1996), as compared to only 53% when considering only the WRAP data by itself. The EPA databases probably undergo a more thorough QA/QC procedure than was used to create the WRAP database. Thus, the E-GRID and other federal databases might be expected to have more complete information. http://www.reaction-eng.com VI-22 REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com VI-23 REACTION ENGINEERING INTERNATION AL 0 1 0 38 3 3 1 1 72 Cyclone Stoker Coal-fired AFBC Wet Bottom Total 39,880 102 381 571 702 1,235 36,889 PM Emissions (TPY) 554 102 381 190 234 309 615 Average Emissions (TPY/Source) None Multiple Cyclone(1) None Electrostatic Precipitator(3) Electrostatic Precipitator(4) Multiple Cyclone(3), Fabric Filter(8), Wet Scrubber(7), Electrostatic Precipitator(12) PM Control Technology 3 Stoker 94 3 Wet Bottom Total 4 NG Boiler 2 5 Cyclone Coal-fired AFBC 77 Dry Bottom Number of Units 88 2 0 2 4 5 75 Controlled Units 88,549 274 571 697 1,235 1,633 84,140 PM Emissions (TPY) 942 137 190 232 309 327 1,093 Average Emissions (TPY/Source) Multiple Cyclone/Electrostatic Precipitator(1), Fabric Filter(1) None Fabric Filter(2) Electrostatic Precipitator(4) Electrostatic Precipitator(4), Fabric Filter(1) Multiple Cyclone(3), Fabric Filter(15), Wet Scrubber(8), Electrostatic Precipitator(44), Multiple Cyclone/Electrostatic Precipitator(3), Multiple Cyclone/Wet Scrubber(2), PM Control Technology Table 12. PM Emissions and Control Technologies for Utility Boilers in the Thirteen-State Region from WRAP 1996 Database Combined with EPA and EIA Databases. 3 4 4 NG Boiler 30 60 Controlled Units Dry Bottom Number of Units Table 11. PM Emissions and Control Technologies for Utility Boilers in the Thirteen-State Region from WRAP 1996 Database. 3 NOx CONTROL TECHNOLOGIES 3.1 Overview As discussed in Section 2, the NOx emissions greater than 100 TPY in the thirteen-state region come predominantly from coal-fired boilers. We have concentrated on obtaining detailed information on NOx control technologies for the top five categories, which account for 90% of the emission, although in some cases, where information was readily available, we have collected information for other source categories (refinery process heaters, glass melters, and wood-fired boilers). Table 13 shows that these source categories together account for 92% of the NOx emissions greater than 100 TPY. Table 13. Annual NOx emissions greater than 100 TPY from major source categories. Category Coal-Fired Boilers Reciprocating Engines Cement Kilns Oil/NG Boilers Turbines Wood Boilers Refinery Process Heaters Glass Manufacture Others Total # Units 151 Total NOx TPY 607,748 423 39 112 86 48 38 14 199 1,110 86,210 41,009 32,910 25,278 9,776 9,311 5,033 69,385 886,660 % of NOx Emissions 68% 10% 5% 4% 3% 1% 1% 1% 8% In this section, the information is organized in two formats. First, Table 14 lists all the technologies considered. For the most part, these are commercial technologies, in that vendors are offering these technologies. Not all technologies listed in Table 14 have demonstrated longterm operation, however. Table 14 gives the following information about each technology: • Name of the technology • Source categories to which the technology can be applied • Was a summary prepared? (Yes/No). If yes, technology summaries are contained in Appendix C. Second, Tables 15 through 22 summarize the NOx control options for major source categories for ease of comparison. More detailed information, particularly on the range of cost and NOx control, is given in Appendix C. These tables contain the following information: • Name of Technology • Process Description • Applicability to units in the source category • Range of performance (NOx removal efficiency) • Range of costs ($/ton of NOx removed, levelized annual cost) • Commercial status http://www.reaction-eng.com VI-24 REACTION ENGINEERING INTERNATION AL Table 14. NOx Control Technologies. Summary in Appendix C (Y/N) Technology Applicability 1 Air or fuel staging Coal-fired boilers, Cement kilns Y 2 Batch/Cullet Preheating Glass Melters Y 3 Biosolids injection Cement kilns N (not common) 4 Burner Modifications Coal-fired boilers 5 Catalytic combustion Gas Turbines Y 6 DLN (fuel-lean combustion) Gas Turbines Y 7 Electric Boost Glass Melters N (too expensive) 8 Flue Gas Recirculation (FGR) Oil/Nat'l Gas Boilers Y 9 Fuel Reburn Coal-fired boilers, Wood/biomass boilers, Glass Melters Y 10 High Energy Ignition Reciprocating Engines Y 11 High-Pressure Fuel Injection Reciprocating Engines Y 12 Hybrid Reburn + SNCR Coal-fired boilers 13 Hybrid SNCR + SCR Coal-fired boilers 14 Hydrocarbon-enhanced SNCR Coal-fired boilers 15 Intelligent controls Coal-fired boilers, Oil/NG boilers, Wood/biomass boilers Y 16 Iron addition (CemStar) Cement kilns Y http://www.reaction-eng.com VI-25 N (see LNB) N (see Reburn, SNCR) N (see SNCR, SCR) N (see SNCR) REACTION ENGINEERING INTERNATION AL Summary in Appendix C (Y/N) N (see O2enhanced combustion) Technology Applicability 17 Kiln dust insufflation Cement kilns 18 Kiln temperature control Cement kilns 19 LNB + FGR Coal-fired boilers, Oil/NG boilers, Process heaters, Pyrolysis furnaces 20 Low-Emission Combustion (LEC) Reciprocating Engines 21 Low NOx Burners Coal-fired boilers, Oil/NG boilers, Glass Melters, Pyrolysis furnaces, Process heaters, Cement kilns Y 22 Low-NOx Calciner Cement kilns Y 23 Mid-kiln or tower tire injection Cement kilns Y 24 Non-Selective Catalytic Reduction Reciprocating Engines (NSCR) Y 25 NOxTech Reciprocating Engines Y 26 Overfire Air Coal-fired boilers, Wood/Biomass boilers. Oil/Nat'l Gas Boilers Y 27 Oxy-Fuel Firing Glass Melters Y 28 Oxygen-enhanced Combustion Modifications Coal-fired boilers, Cement kilns, Glass Melters Y 29 Pre-stratified Charge Reciprocating Engines Y 30 Rich Reagent Injection (RRI) Coal-fired boilers 31 SCONOX Oil/Nat'l Gas Boilers, Reciprocating Engines, Gas Turbines Y 32 SCR Coal-fired boilers, Oil/NG boilers, Glass Melters, Pyrolysis furnaces, Process heaters, Reciprocating Engines, Gas Turbines Y http://www.reaction-eng.com VI-26 Y N (see LNB, FGR) Y N (see SNCR) REACTION ENGINEERING INTERNATION AL Summary in Appendix C (Y/N) Technology Applicability 33 SNCR Coal-fired boilers, Wood/Biomass boilers Oil/NG boilers, Glass Melters, Pyrolysis furnaces, Cement kilns, Reciprocating Engines, Gas Turbines Y 34 Tempering (Steam, water or air injection) Gas turbines, Process heaters, Pyrolysis furnaces Y http://www.reaction-eng.com VI-27 REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 15. Coal-Fired Boilers. VI-28 REACTION ENGINEERING INTERNATION AL Technology Description Applicability Performance Cost, $/T Commercial Burner Modifications Burner air and/or fuel modifications to improve air/fuel interaction Most units. 10 to 30% NOx reduction 100-200 Y Fuel Reburn Inject portion of the fuel into the furnace downstream of burner zone. Usually requires OFA to complete combustion Most units. Furnace height (residence time) may restrict some applications 20 to 30% NOx reduction for Fuel-Lean Gas Reburning (no OFA), and 30 to 60% reduction for conventional reburning. 500-2000 (Highly dependent on cost of reburn fuel) Y Hybrid Reburn + SNCR Co-inject reburning fuel and SNCR reagent. Same as individual technologies. 50-70% 300-600 Y Hybrid SNCR + SCR Overfeed reagent into the furnace, and allow ammonia carryover to further reduce NOx over a catalyst downstream. Same as individual technologies. 50 to 90% NOx reduction, de-pending on how much catalyst is installed. 800-2000 Y Hydrocarbonenhanced SNCR Inject small amount of natural gas to create radicals that enhance SNCR effectiveness at 1700 to 2000 °F. Emerging technology. Most units. Can use more NH3 with less slip. 40 to 60% NOx reduction 500-1000 Y “Intelligent” Controls Sensors and software optimize air-fuel ratio to burners. Available for all units 0 to 30% NOx reduction. <100-300 Y Low-NOx burners (LNB) Burners designed to produce lower NOx emissions – “staged” combustion Most boilers already have LNB. 30-50% NOx reduction. 200-1000 Y Overfire air (OFA) Form of “staged” combustion. Divert portion of the air from the windbox to OFA ports installed above the burners. Most units. Furnace height may restrict some applications 20 to 40% NOx reduction. 250-600 Y http://www.reaction-eng.com Table 15. Coal-Fired Boilers (Continued). Description Applicability Performance Cost, $/T Commercial Oxygen-enhanced combustion modification Improve effectiveness of OFA operation by injecting O2 into fuelrich flames. Operate more fuel-rich without the problems. Emerging technology. Best applied with new OFA system designed to achieve stoichiometric airfuel ratio < 0.8. 30-50% beyond OFA 1000-2000 Y Rich Reagent Injection (RRI) SNCR applied to fuel-rich region of OFA system. Most units. Modeling required to determine injection locations. 20 to 30% additional NOx reduction beyond OFA. 800-1500 Y Selective Catalytic Reduction (SCR) Ammonia added upstream of catalytic reactor installed upstream of air preheater (conventional), downstream of a hot ESP (low dust), or downstream of the cold ESP (tail end). Most units. Space availability may constrain some options. High sulfur fuels more challenging 70 to 90+% NOx reduction 1500-2000 Y Selective Non-catalytic Reduction (SNCR) Inject ammonia-based reagent into upper furnace (1700-2000 degrees F) to destroy NOx. Most. Residence time and temperature characteristics are important. 25 to 50% NOx reduction, depending on the furnace temperature and time for reaction. 800-1500 Y VI-29 Technology REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 16. Reciprocating Engines. Description Applicability Performance Cost, $/T High Energy Ignition Provide continuous electrical discharge at the spark plug gap for 10 to 90 o of crankshaft rotation. This extended energy delivery ensures combustion in the leanest of conditions. For lean-burn engines (to support ignition under very lean conditions) 80% NOx reduction. Use of plasma ignition is new, so there is limited operating experience. 115-200+ High-Pressure Fuel Injection Enhance mixing of fuel and air under lean conditions Same as LEC ~80% Not available, but less than LEC. Low-Emission Combustion (LEC) Retrofit kits available to implement lean burn for new engines as well as retrofit. Not available for all engines, some fuel efficiency decrease. Requires turbo-charging or inter-cooling upgrades. 80-90% NOx reduction VI-30 Technology Y 190-700, depending on engine BHP. $6500 for 80 BHP. Non-Selective Catalytic Reduction (NSCR) Install oxidation-reduction catalyst that uses hydrocarbons in exhaust to destroy NOx. Requires rich-burn engine to produce hydrocarbons used for NOx reduction. 40-98% NOx reduction, depending on engine speed. Average of 95% reduction is achievable. <500 NOxTech Inject chemical reagent into exhaust at temperatures of 1400 to 1500 °F. Applicable to all engines, but exhaust must be heated for most engines. 90-95% NOx reduction, 6080% particulate removal, 50-70% CO removal, 90% hydrocarbon removal. ~ 1000 For carbureted, rich-burn engines. 80-95% NOx reduction. < 500 Pre-stratified Charge Inject air into intake manifold so that the piston initially draws in air, followed by a fuel-rich air-fuel mixture. Commercial Y Y Y Y Y REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 16. Reciprocating Engines (Continued). Technology Description Applicability Performance Cost, $/T SCONOX Add chemical reactor for NOx sorption, followed by regeneration. Theoretically works for all engines. Catalyst regeneration is difficult. Little operating data available. 95% reduction of NOx, CO, and hydrocarbons. Not available All engine types (especially diesel), but difficult to control if load range is wide. 75-90% NOx reduction SCR Inject ammonia upstream of a catalyst that operates at 300-900 °F. Commercial Y < 1000 Y VI-31 REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 17. Cement Kilns. Technology Description Applicability Performance Cost, $/T Air or fuel staging Inject portion of the fuel downstream of the main flame to create locally reducing conditions where NOx can be destroyed. Sometimes includes installing a “NOx fan” to increase burnout. More easily implemented in tower kilns. 0 to 50% NOx reduction, depending on existing equipment. 1000-2000 Add sewerage sludge to mid-kiln or tower for combined SNCR and fuel-staging affect. Tried in long kilns and preheater/precalciner kilns, but effectiveness is limited by poor combustion and increased hydrocarbon or SO2 emissions. 20 to 30% NOx reduction, but can reduce kiln capacity due to high moisture content. 100-500 Iron addition (CemStar) Change cement formulation by adding waste iron to lower clinkering temperature and suppress NOx. Applicable to all kiln types, but may affect cement quality. 20 to 30% NOx reduction, depending on cement specifications 0-100 Kiln dust insufflation Re-inject cement kiln dust (CKD) into flame zone to lower peak temperatures and increase clinker production. Applicable to long kilns. 0 to 20% NOx reduction in conjunction with a 0-5% kiln capacity increase. 100-300 Add temperature-monitoring device to kiln controls to minimize high-temperature excursions where more NOx is emitted. Applicable to all kiln types, but risks unacceptable cement quality. 0 to 20% NOx reduction, and requires less operator attention. 200-500 Replace open pipe burner with multi-annular design. Usually accompanied by installation of an indirect coal feed system to reduce coal transport airflow. Applicable to all kiln types. Can reduce cement quality on some kilns. 0 to 20% NOx reduction; production may increase. 500-1000 Biosolids injection VI-32 Kiln temperature control Low-NOx Burner (LNB) Commercial Y Y Y Y Y Y REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 17. Cement Kilns (Continued). VI-33 Technology Description Applicability Performance Cost, $/T Low-NOx calciners Replace calciner with new lowNOx design. Applicable only to preheater/precalciner kilns. 30-50% NOx. Little experience 1000-5000 Mid-kiln or tower tire injection Inject whole tires or shredded tires downstream of the flame to reduce NOx formed in the burner. Injected mid-kiln in long kilns, and into lower tower for preheater/precalciner kilns. 15 to 30% NOx reduction; generate revenues. 0-1000 Oxygen enrichment O2 lance to decrease fuel requirement for clinker formation. Cement quality could be more difficult to control. 0 to 20% NOx reduction and potential for additional capacity. 200-1000 SNCR Inject ammonia-based reagent into upper furnace (1700-2000oF) to destroy NOx. Applicable to preheater/precalciner kilns. 30 to 70% NOx reductions, depending on access to temperatures in 1600-1800 °F range. 200-1000 Commercial Y Y Y Y REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 18. Oil/Natural Gas-Fired Boilers. Description Applicability Performance Cost, $/T Flue Gas Recirculation (FGR) Recycle 15-25% of the flue gas to the windbox to reduce flame temperature. Can use eductors for induced FGR Most units, but could affect heat balance. Induced FGR requires pressure part changes. 40-80% NOx reduction 500-3000 Y Low-NOx Burners Burners designed to produce lower NOx emissions – “staged” combustion Most boilers. 30-60% NOx reduction 200-1000 Y Overfire Air (OFA) Form of “staged” combustion. Divert portion of the air from the windbox to OFA ports installed above Most units. Furnace height may restrict some applications 40-80% NOx reduction 1000-2000 Y SCONOX Add chemical reactor for NOx sorption, followed by regeneration. Steam-hydrogen regeneration gas not practical for some boilers. Limited testing to date. 70-99% NOx reduction claimed. Not available Y SCR Ammonia added upstream of catalytic reactor. Most units. Space availability may constrain some options. High sulfur fuels more challenging 70-90+% NOx reduction 2000-10000 Y SNCR Inject ammonia-based reagent into upper furnace (1700-2000oF) to destroy NOx. Most. Residence time and temperature characteristics are important. 30-60% NOx reduction 1300-3000 Y VI-34 Technology Commercial REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 19. Turbines. Technology Description Applicability Performance Cost,$/T Catalytic combustion Catalytic combustor reduces combustion temperature below thermal NOx limit. Limited experience. 0.05 lb/MBtu (80% reduction) has been measured. > 500 DLN (fuel-lean combustion) Low NOx combustor is GT “equivalent” of LNB. Most turbines. Flame instability a problem for some gas fuels. 0.1 lb/MBtu (70% reduction) can be guaranteed on new units. 1000-2000 SCONOX Add chemical reactor for NOx sorption, followed by regeneration. Reliability of system not yet proven. 0.02 lb/MBtu (> 90% reduction) claimed. > 7000 Add catalyst section to HRSG to destroy NOx at temperatures of 600 to 900 °F. Applied to most turbines 90 % reduction down to 0.03 lb/MBtu. 500-10000+ Spray water or steam into combustor to suppress flame temperature. Can be applied to most turbines, but some will experience slight efficiency loss. 0.15 lb./MBtu (50% reduction) can be achieved. 2000-7000 SCR VI-35 Tempering (Water/ Steam Injection) Commercial Y Y Y Y Y REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 20. Wood or Biomass-Fired Boilers. Description Applicability Performance Cost, $/T Fuel Reburn Inject portion of the fuel into the furnace downstream of burner zone. Usually requires OFA to complete combustion Stoker, water tube 40-60% NOx reduction 300-3000 "Intelligent" Controls Sensors and software optimize air-fuel ratio to burners. Watertube boilers Overfire air (OFA) Form of “staged” combustion. Divert portion of the air from the windbox to OFA ports installed above the burners. Stoker, watertube Inject ammonia-based reagent into upper furnace (1700-2000o F) to destroy NOx. Stoker, FBC, watertube VI-36 Technology Selective NonCatalytic Reduction (SNCR) Commercial Y 0-20 % NOx reduction 200-500 Y 20-60% NOx reduction 200-2000 Y 40-80 % NOx reduction reported 900-2200 Y REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 21. Process Heaters. Technology Description Applicability Performance Cost, $/Ton LNB + FGR Staged firing with flue gas mixed with precombustion air Oil/gas fired, MD only 50-60% Gas: 1,720-2,480 Oil: 2,390-2,910 Staged firing; Combines staged firing with induced flue gas recirculation Oil/gas fired 30-50% Ammonia added upstream of catalytic reactor. Oil/gas fired Inject ammonia-based reagent into upper furnace (1700-2000o F) to destroy NOx. Oil/gas fired Low-NOx Burners, Ultra Low-NOx Burners SCR VI-37 SNCR Commercial Y Gas: 1,210-1,820 Oil: 1,200-2,340 Ultra-LNB: 50-80% Y Gas: 810-1,280 Oil: 400-1,440 75-90% 50-70% Gas: 5,130-10,600 Oil: 3,710-6,490 Y Gas: 1,470-2,640 Oil: 1,230-2,350 Y REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 22. Glass Melting Furnaces. Technology Description Applicability Performance Cost, $/Ton Commercial Batch/Cullet Preheating Residual heat of waste gas used to preheat batch materials/cullet (recycled glass) Any glass melting furnace w/ >50% cullet in batch 5-25% 890-1,040 Y 10-30% 2,600-9,900 Y 40% 790-1,680 Y 50-65% moderate Y 80-85% 2,150-4,400 Y Electric Boost Low-NOx Burners Natural Gas Reburn Oxy-Fuel Firing Burners designed to produce lower NOx emissions – “staged” b ti Inject portion of the fuel into the furnace downstream of burner zone. Oxygen used instead of air; requires different furnace design Oil/gas fired furnaces VI-38 REACTION ENGINEERING INTERNATION AL The formation of NOx is a byproduct of the combustion of fossil fuels. Nitrogen contained in fuels such as coal and oil, as well as the harmless nitrogen in the air, will react with oxygen during combustion to form nitrogen oxides (NOx). The degree to which this formation evolves is dependent on many factors, including both the combustion process itself and the properties of the particular fuel being burned. This explains why similar boilers firing different fuels or similar fuels burned in different boilers will yield different NOx emissions. As a result of these complex interactions in the formation of NOx, an equally large number of approaches to minimize or reduce its emissions into the atmosphere have been and continue to be developed. A relatively simple way of understanding the many technologies available for NOx emission control is to divide them into two major categories: (1) those that minimize the formation of NOx during the combustion process (e.g., smaller quantities of NOx are formed); and (2) those that reduce NOx after the combustion process. It is common to refer to the first approach as “combustion modifications” whereas technologies in the second category are termed "post-combustion controls." Within each of these categories, several technologies and variations of the same technology exist. Finally, combinations of some of these technologies are not only possible but often desirable as they may produce more effective NOx control than the application of a stand-alone technology. The following summaries describe the major technologies in each category. 3.2 Coal-Fired Boilers Combustion modifications can vary from simple "tuning" or optimization efforts (similar to a "tune-up" of a car) to the deployment of dedicated technologies such as low-NOx burners (LNB), Overfire air (OFA), or Reburn. All combustion modification approaches face a common challenge: that of striking a balance between NOx reduction and fuel efficiency. The concern is exemplified by the typically higher carbon levels in the fly ash, which reflect lower efficiency (more fuel needed for the same electrical output) and which may contaminate the fly ash itself, possibly making it unsuitable for reutilization (e.g., cement and concrete production). Combustion Optimization Combustion optimization efforts can lead to reductions in NOx emissions of 5%-15% or even higher in cases where a unit may be poorly "tuned." It is important to remember that optimization results are truly a function of the "pre-optimization" condition of the power plant or unit, and as such have limited opportunity for drastic emission reductions. Recent development of "intelligent controls" - software-based systems that "learn" to operate a unit and then maintain its performance during normal operation may go a long way towards keeping plants well-tuned as they age. LNB’s and OFA LNB’s and OFA represent practical approaches to minimizing the formation of NOx during combustion. Simply, this is accomplished by controlling the quantities and the way in which http://www.reaction-eng.com VI-39 REACTION ENGINEERING INTERNATION AL fuel and air are introduced and mixed in the boiler (usually referred to as "fuel or air staging"). These technologies are the most prevalent in the power industry at present. For example, plants that have had to comply with Phase I of Title IV of the CAAA of 1990 have largely used these technologies for compliance. (Phase II of the Title IV has required the use of post-combustion technologies to meet more stringent requirements for both Group 1 and Group 2 boilers.) Competing manufacturers have proprietary designs, geared towards application in different boiler types, as well as reflecting their own design philosophies. LNB’s and OFA, which can be used separately or as a system, are capable of NOx reductions of 40% - 60% from uncontrolled levels. Again, the type of boiler (e.g., dry vs. wet-bottom, wall- vs. tangential-fired, NSPS vs. pre-NSPS) and the type of fuel (e.g., bituminous vs. sub-bituminous) will influence the actual performance achieved. NOx emission rates on the order of 0.15 lb/MBtu can be achieved with low NOx burners under circumstances, particularly in dry-bottom boilers burning low-rank coals. LNB’s/OFA have little or no impact on operating costs, other than those noted above. As such, the economics of these technologies are driven by capital/retrofit costs which typically range from $10-$40/kW, with the lower range reflecting easier "plug-in" application, whereas the higher costs are typically associated with more difficult and involved retrofits (e.g., where new controls or other systems may be replaced as part of the LNB retrofit). From the standpoint of scheduling retrofits for existing units, LNB/OFA retrofit projects have "lead" times of 10-14 weeks and can require outages of 6-10 weeks, depending on factors such as scope of work, integration with other plant outage requirements, etc. Reburn Reburn, while generically included in the "Combustion Modification" category, is different from the other technologies in this group (LNBs/OFA) in that it "destroys" NOx through chemically reducing conditions shortly after it is formed rather than minimizing its formation as discussed previously. From a practical standpoint, this is accomplished by introducing the reburn fuel (theoretically any fossil fuel can be used, but natural gas is the most common) into the boiler above the main burner region. Subsequently, this "fuel-rich" environment reacts with and "destroys" the NOx formed in the main burners. This technology has been implemented in the U.S. and overseas, and while not as common as LNB/OFA, it is commercial at this time. Owing to stricter compatibility criteria, reburn is not as universal as LNB/OFA in its applicability to the overall boiler population. Specific criteria such as boiler size, availability of natural gas, type and quality of the main fuel are all important in determining the suitability of a unit for this technology. One important feature of reburn is its compatibility with cyclone boilers, for which the previously mentioned technologies are not particularly well suited. Cyclones boilers represent over 25,000 MW of capacity in the U.S. Reburn performance has been shown to range from 35%-60% depending on such factors as reburn fuel type and quantity, initial NOx level, boiler design, etc. Reburn can be thought of as a "dial-in" NOx technology in that NOx reductions are a function of the amount of reburn fuel. This feature may provide strategic value in compliance scenarios. http://www.reaction-eng.com VI-40 REACTION ENGINEERING INTERNATION AL With respect to cost, systems using natural gas as the reburn fuel range from $15/kW to $30/kW whereas those using coal for reburn range from $30/kW to $60/kW. Operating costs are primarily driven by the fuel cost differential in the case of gas reburn, while for coal or oil reburn fuel preparation costs (pulverization and atomization, respectively) represent the dominating O&M costs. Countering these costs, particularly in the gas reburn case, are SO2, particulates, and CO2 co-benefits proportional to the fraction of gas used. Project retrofit schedules for this technology are on the order of 15 to 20 weeks with 6 to 10 weeks of outage time likely. Recently, reburn technology has evolved into several variations of the original approach. One of these is “Fuel Lean Gas Reburn" (FLGR) developed for specific applications where NOx reductions of around 30%-40% may be required. FLGR uses less gas than conventional reburn (3%-7% vs 15%-20%), and its capital cost is less than $10/kW, making it a potentially effective option in specific applications. SCR and SNCR Readily available post-combustion NOx controls are limited to selective non-catalytic reduction (SNCR) and selective catalytic reduction (SCR). They are fundamentally similar in that both use an ammonia-containing reagent to react with the NOx produced in the boiler and convert it to nitrogen and water. SNCR accomplishes this at higher temperatures (1700ºF-2000ºF) in the upper furnace region of the boiler, while SCR operates at lower temperatures (about 600ºF) and hence needs a catalyst to produce the desired reaction between ammonia and NOx. While this difference between the two technologies may seem minor, it results in significant difference in performance and costs. This is because in the case of SNCR, the reaction occurs in a somewhat uncontrolled fashion (e.g., the existing upper furnace becomes the "makeshift" reactor, which is not what it was originally designed to be), while in the SCR case, a dedicated reactor and the reaction-promoting catalyst ensure a highly controlled, efficient reaction. In practice, this means that SNCR has lower capital costs (no need for a reactor/catalyst); higher operating costs (lower efficiency means that more reagent is needed to accomplish a given reduction in NOx); and finally, has limited NOx reduction capability (typically 30%-40%, with some cases achieving reductions in the 50% range). SCR, on the other hand, has higher capital costs but offers lower operating costs and the opportunity for very high NOx reductions (up to 90%). Capital costs range from $10 to $15/kW and $60 to $100/kW for SNCR and SCR, respectively. Operating costs are driven primarily by the consumption of the chemical reagent – usually urea for SNCR and ammonia for SCR, which in turn is dependent upon the efficiency of the process (usually referred to in terms of reagent utilization) as well as the initial NOx level and the desired percent reduction. Two additional parameters important in the overall operating costs are (1) the potential contamination of fly ash by ammonia, making it unusable and (2) the life cycle of the catalyst due to fly ash. http://www.reaction-eng.com VI-41 REACTION ENGINEERING INTERNATION AL Combined Approaches In theory, most of these technologies can be used together. However, NOx reductions are not necessarily additive, and more importantly, the “economics” of the combined technologies may or may not be cost-effective. Such analyses are highly site- and strategy-specific. However, several such combinations of technology are considered attractive and have or are gaining acceptance. For example, the combination of LNB/OFA with either SCR or SNCR is more prevalent than the application of the post-combustion technologies alone. The economics of this approach are justified by the reduced chemical (SNCR) and capital costs (SCR – smaller reactor/catalyst) due to lower NOx levels entering the SCR/SNCR system. Another example is the combination of Reburn with SNCR, driven by the synergisms between the two (similar location, temperatures in the boiler). This application may yield NOx reductions of 60%-70% with capital costs in the $20-$30/kW range, but has a relatively high operating cost due to reagent and reburning fuel consumption. 3.3 Reciprocating Engines Several control technologies are available for ICE’s, having a wide range of complexity, cost and performance. Some in-cylinder methods offer low to moderate NOx reductions at costs well below $1,000/ton. These include injection timing retard, and air/fuel ratio adjustment (with or without high-energy ignition). These methods are widely available, and NOx performance will vary from one engine design to another. However, fuel efficiency can suffer as a result of these methods and emissions of products of incomplete combustion can increase. Spark-ignited engines that can be retrofitted with Low-Emission Combustion (LEC) technology can potentially achieve significant NOx reductions (80 to 90%). LEC technology can be expensive to retrofit on some engines, and it may not be available from all engine manufacturers. For large, low-speed engines, LEC technology is estimated to provide annual NOx reductions of about 80% at under $1,000/ton under most conditions. LEC technology is estimated to be more cost effective on smaller, medium-speed engines (under $500/ton for annual control under most conditions). It is estimated to be somewhat more expensive for dual-fuel engines (annual control at a capacity factor of 65% is estimated to cost under $1,000/ton). SCR is the only commercially available choice for post-combustion control of diesel and leanburn spark-ignition engines. Experience in the U.S. with SCR on these engines is growing, especially for diesel engines. SCR has been applied to approximately 30 diesel engines and to an equivalent number of constant-load lean burn ICE’s. Experience with SCR on variable-load engines is limited. In analysis using data from case studies, it was estimated that SCR provides annual NOx reductions of as high as 90% at a cost below $1,000/ton in all cases, except for very low capacity factors (~10%), and it provides seasonal reductions at a cost of under $1,000/ton for engines operating at high capacity factors (typically, 65% or greater). Recent developments from the application of urea-SCR on mobile sources (diesel trucks) offer the possibility of reducing the size and capital cost of SCR systems for stationary ICE’s. This http://www.reaction-eng.com VI-42 REACTION ENGINEERING INTERNATION AL new technology, developed from efforts to apply SCR to mobile diesel engines, appears to make it possible to achieve much more cost-effective NOx reduction on stationary ICE’s that operate for only a few hundreds of hours a year. NOx reduction of about 75% is estimated to be possible for under $2,000/ton even for seasonal controls of some stationary ICE’s that operate only a few hundred hours each ozone season. Seasonal control at a cost of under $1,000/ton is estimated to be achievable for most applications with capacity factor greater than 45%. 3.4 Cement Kilns As with other combustion systems, modifying the combustion process is one strategy for reducing NOx in cement kilns. However, the quality of the clinker produced by the kiln can be affected by combustion modifications so these must be undertaken carefully. Monitoring temperature and excess air in the combustion zone increases the efficiency of the cement-making process and can result in reduced NOx emissions. Combustion modifications include staged combustion of air or fuel. Specifically designed low-NOx burners are sometimes used. Even without low-NOx burners, staging can be achieved by adding some of the fuel midkiln, as in mid-kiln injection of tires. Mid-kiln injection of fuel (most often tires) was in practice in twenty kilns in the U.S. in 2000. Iron addition (CemStar process) has been used at about a dozen facilities in the U.S. This reduces the temperature needed in the kiln for formation of clinker and allows the combustion zone to operate cooler (and thus reducing NOx). Post-combustion (post-kiln) NOx controls include SCR and SNCR. SCR has not been used on cement kilns in the U.S.; pilot studies have been conducted in Europe. SNCR technology requires a specific temperature window and residence time; these are not attainable in all cement kilns. SNCR can be applied to preheater/precalciner kilns. SNCR is widely practiced in Europe on cement kilns, but to date there have been only a handful of demonstrations in the U.S. 3.5 Natural Gas and Oil Fired Boilers The menu of NOx control options for gas and oil-fired boilers is essentially the same as for coalfired boilers. One noted exception is the use of Flue Gas Recirculation (FGR), which is not effective in coal applications and hence, is not mentioned there. While the control technologies are common to the coal-fired options, application issues require different considerations and analyses. Examples range from differences in the inherent NOx formation amongst the fuels (thermal NOx vs. “fuel”-NOx), which dictate that combustion-based technologies are designed accordingly for each fuel, to the fact that gas produces no PM or SO2/SO3 and hence can afford some design changes from coal and oil applications. Equally important are the economics of the different fuels, which may favor different technology approaches. In summary it can be said that the available menu of technologies is the same as for coal applications, but that (at least for gas), deployment of these technologies tends to be less constraining than for coal. http://www.reaction-eng.com VI-43 REACTION ENGINEERING INTERNATION AL 3.6 Turbines There have been some important developments in gas turbine NOx control technology, but wellestablished technologies continue to play an important role in reduction of NOx. Dry Low NOx (DLN), catalytic combustion, and some new post-combustion methods are making their way into the control technology market, while water or steam injection and SCR continue to be important technologies for reducing NOx from gas turbines. Many turbine manufacturers can convert or replace conventional combustors on existing turbines with DLN combustors. DLN combustion retrofits have been made possible by recent developments in gas turbine combustor technology. DLN technology offers the potential for substantial reduction of NOx from turbines firing natural gas or other low-nitrogen fuels, as well as improved engine performance when compared to wet controls (water or steam injection). For turbines under about 15 MW in size, NOx emissions of 25 ppm can be guaranteed for new turbines and emissions below 42 ppm can be guaranteed for retrofitted turbines. For large turbines (75 MW and higher in size), controlled NOx emission levels of as low as 9 ppm have been guaranteed, even for retrofits. DLN capital costs vary with the size of the turbine and the specifics of the particular turbine being retrofitted. The baseline NOx level significantly affects the estimate of cost per ton of NOx reduced. Using expected baseline NOx emissions levels provided by the turbine manufacturers and retrofit costs expected to be typical of most applications, retrofit of DLN on industrial turbines (about 3 to 10 MW) originally equipped with conventional combustion control is estimated to provide NOx reductions under $2,000/ton for annual controls with high capacity factors and at a higher cost for seasonal controls. For larger turbines (~75 MW), cost was estimated to be well below $1,000/ton for nearly all conditions. Water injection and steam injection are two well-established technologies that can offer controlled NOx emission levels below 42 ppm in many cases. Because water or steam injection technologies frequently have lower capital cost than DLN but higher variable costs, these technologies can be more attractive for peaking turbines or other turbines that operate infrequently. It was estimated that water injection installed on peaking units that operate 200 hours to 400 hours in the summer would reduce NOx at a cost of about $2,500/ton to about $7,000/ton, depending upon the number of operating hours and the fuel used (gas or distillate oil). SCR continues to be the most widely used post-combustion technology for gas turbines. Catalyst technology developments have made SCR viable over a wider temperature range. This makes SCR a viable control option in situations that were difficult in the past, such as simplecycle turbines that may now benefit from high-temperature SCR and combined-cycle turbines with duct burners that may now benefit from low-temperature SCR. The cost of NOx reduction with SCR varies considerably according to application, turbine size, and the type of SCR technology that is appropriate for the application. As in the case of the DLN cost estimates, expected baseline NOx emissions levels provided by the turbine manufacturers were used as a basis for cost calculations. Conventional SCR on a large (~75MW) combined-cycle turbine with high capacity factors was estimated to cost about http://www.reaction-eng.com VI-44 REACTION ENGINEERING INTERNATION AL $440/ton for annual controls and $870/ton for seasonal controls, for turbines equipped with conventional combustion technology (baseline NOx emissions of 154 ppm). For turbines with lower baseline NOx emissions (such as those equipped with DLN combustors having baseline NOx emissions of 15 ppm), the cost per ton of additional NOx removed was estimated to be greater, ranging from about $3,700/ton (annual control, high capacity factor) to over $13,000/ton (seasonal controls, low capacity factor). On smaller turbines (~5 MW), the cost of conventional SCR is estimated to be as low as $1,300/ton (with annual control and conventional combustion technology having baseline NOx emissions of 142 ppm). Seasonal controls for smaller turbines are estimated at over $15,000/ton of NOx removed at a low capacity factor (45%) with baseline NOx emissions of 42 ppm. For installations that may be better suited for high- or low-temperature SCR variants, such as simple-cycle turbines (high-temperature SCR) or combined-cycle turbines with limited space (low-temperature SCR), the cost of SCR is somewhat higher than for conventional SCR on a combined-cycle plant. A 75 MW turbine at a high capacity factor equipped with conventional combustion technology (baseline NOx emissions of 154 ppm) can be controlled annually with high- or low-temperature SCR for about $550/ton and for about $1,200/ton seasonally. As with conventional SCR, turbines with lower baseline NOx emissions (such as those equipped with DLN combustors) showed a higher cost per ton of NOx reduction. The estimated cost of NOx reduction for a 75 MW turbine with baseline NOx emissions of 15 ppm ranges from $5,170/ton (annual controls, high capacity factor of 85%) to as high as $20,000/ton (seasonal controls, low capacity factor of 45%). On smaller turbines (~5MW), the cost for high- or low-temperature SCR is estimated to be as low as $2,000/ton with annual control and conventional combustion technology (baseline NOx emissions of 142 ppm). Cost is estimated to range from $6,750/ton (annual controls, high capacity factor of 85%) to about $27,000/ton (seasonal controls, low capacity factor of 45%) with baseline NOx emissions of 42 ppm. Emerging combustion technologies (such as catalytic combustion) and post-combustion technologies (such as SCONOx) offer the potential for very low NOx emission levels. Because there is much less experience with these technologies, available cost information is limited. http://www.reaction-eng.com VI-45 REACTION ENGINEERING INTERNATION AL 4 PM CONTROL TECHNOLOGIES 4.1 Overview As discussed in Section 2, 8 source categories make up about 92% of the PM emissions and are summarized in Table 23. Detailed information on PM control technologies has been obtained for industrial processes that generate particulate matter. We have not provided cost information on fugitive emissions, however, since costs of fugitive dust control are highly variable and it is difficult to find an adequate metric for costs and then quantify them. Table 23. PM emissions from top eight source categories. Coal-Fired Boilers Mineral Processing Petrochemical Wood Boilers Refinery Emissions Primary Metal Production Pulp and Paper Smelting Operations Others Total (>100 TPY) # Units 88 85 42 24 11 20 15 8 28 321 Total PM % PM TPY Emissions 46,010 40% 24,499 21% 10,836 9% 5,718 5% 5,631 5% 4,697 4% 4,476 4% 3,555 3% 9,168 8% 114,589 Table 24 lists all the technologies considered. These are commercial technologies, in that vendors are offering these technologies with demonstrated operating experience in a wide range of applications. Table 24 gives the following information about each technology: • Name • Source categories to which the technology can be applied • Summary prepared? (Y/N) Technology summaries are contained in Appendix D. http://www.reaction-eng.com VI-46 REACTION ENGINEERING INTERNATION AL Table 24. PM Control Technologies Technology 1 Cyclones 2 Electrostatic precipitator (ESP) 3 Fabric Filter 4 PM Scrubber 5 6 4.2 Surface modification • Water • Surfactants • Shape Traffic operations Applicability Coal-fired boilers, Oil/NG boilers, Wood/Biomass boilers, Cement kilns, Smelting Coal-fired boilers, Oil/NG boilers, Wood/Biomass boilers, Cement kilns Coal-fired boilers, Oil/NG boilers, Wood/Biomass boilers, Cement kilns Coal-fired boilers, Oil/NG boilers, Wood/Biomass boilers, Cement kilns, smelting Summary (Y/N) Y Y Y Y Fugitive Emissions, Mineral Products N Fugitive Emissions, Mineral Products N PM Control for Coal-Fired Boilers and Other Combustion Sources Particulate matter is generated by a variety of physical and chemical processes. It is emitted to the atmosphere through combustion, industrial processes, fugitive emissions and natural sources. In combustion processes, the mineral matter (inorganic impurities) is converted to ash. The particles suspended in the flue gas are known as fly ash. Fly ash constitutes the primary particulate matter, which enters the particulate control device. Particulate matter is in general referred to as "PM", "PM10", "PM2.5" (particulate matter (PM) with an aerodynamic equivalent diameter of 10 microns or less and 2.5 microns or less, respectively). Quantity and characteristics of the fly ash and particle size distribution depend on the mineral matter content of the fuel, combustion system, and operating conditions. Combustion technique mainly determines the particle size distribution in the fly ash and hence the final particulate emissions. Common combustion systems in pulverized coal firing include dry bottom, wall (front, opposed) and corner (tangential) burners and wet bottom furnaces. In dry bottom boilers, 10-20% of the ash is discharged as dry, bottom ash. In wet bottom boilers, 50-60% of the ash is discharged at the bottom of the boiler as slag. Stokers or grate-fired boilers are used to burn coal, wood and waste. The majority of the ash falls through the grate and is discharged as bottom ash. Mineral composition of the coal and the amount of carbon in the fly ash determine the quantity, resistivity and cohesivity of the fly ash. PM emissions from other point source processes involve similar phenomena where particulate matter is carried with the flue gas, in suspension to the stack. Hence, the general technologies applicable to one source are typically suitable for the others as well. Factors such as type and http://www.reaction-eng.com VI-47 REACTION ENGINEERING INTERNATION AL quantity of PM, characteristics of the process gas (temperature, moisture, other contaminants) will have a major influence on the selection and design of the PM control technology. Without getting into the details of the various technologies, the following four major types of particulate controls technologies are common for a variety of applications: 4.3 • Wet scrubbers – scrubbers work on the principle of rapid mixing and impingement of the particulate with the liquid droplets and subsequent removal with the liquid waste. For particulate controls the “venturi scrubber” is an effective technology whose performance is directly related to the pressure loss across the venturi section of the scrubber. Venturi scrubbers are effective devices for particulate control. However, for higher collecting efficiencies and a wider range of particulate sizes, higher pressures are required. High-energy scrubbers refer to designs operating at pressure losses of 50-70 inches of water. Of course, higher pressure translates to higher energy consumption. Performance of scrubbers varies significantly across particle size range with as little as 50% capture for small (<2 microns) sizes to 99% for larger (>5 microns) sizes. • Electrostatic Precipitators (ESP) –ESP’s operate on the principle of electrophoresis, by imparting a charge to the particulates and collecting them on opposed charged plates. Dry vs. wet refers to whether the gas is water cooled and saturated prior to entering the charged plate area, or is collected dry on the plates. In gases with high moisture content, dry ESP’s are not suitable because the wet gas would severely limit the ability to collect the “sticky” particulates from the plates. The wet ESP technology is capable of very high removal efficiencies and is well-suited for the wet gas environments. Both types of ESP’s are capable of 99+% removals for particle sizes above 1 micron. • Fabric Filters – These are essentially “giant” vacuum cleaners. As in the case of the dry ESP, Fabric Filters are not well suited for wet gas applications. However FFs are extremely efficient in collecting PM including fine (submicron) size fractions. • Cyclones – Cyclones are devices that separate particulates from the gas stream through aerodynamic/centrifugal forces. However, the technology is only effective in removing larger size particulates (greater than about five microns). Other Developments While the technologies above represent the major available options for particulate control from point sources, it is relevant to note that advancements and innovative application of these technologies have and will continue to occur. Examples of these can vary from simple retrofits (e.g. new filter bag materials for Fabric Filters or newer spark control electronics on ESPs) to innovations including electrostatically- enhanced fabric filtration and hybrid concepts that combine attributes of various technologies. The Electric Power Research Institute’s (EPRI) COHPAC process and the University of North Dakota Energy and Environmental Research Center’s Advanced Hybrid Particulate Collector http://www.reaction-eng.com VI-48 REACTION ENGINEERING INTERNATION AL (AHPC) are examples of hybrid particulate collectors. In COHPAC, an ESP is followed by a pulse-jet Fabric Filter either immediately following it or actually integrated into the original casing of the ESP (in the case of larger older ESP’s), where the FF acts as a “polishing” device significantly increasing the overall and fine particulate collection efficiency of the ESP alone. The AHPC technology can be described as an ESP with alternating rows of electrode plates and highly efficient membrane filter bags. In this case, the technology benefits from good synergism between the ESP and FF during bag cleaning resulting in very high performance levels, small sizes and operational flexibility. 4.4 Costs As with most control technologies, the costs of PM controls involve both capital and operating costs. A cost-effectiveness indicator such as $/ton as is typically used for other technologies (e.g. NOx and SO2) is very difficult to address for generic PM control costs, as the range of PM reductions for different fuels and processes is wide that cost ranges become useless. An attempt to summarize costs in terms of capital and O&M components is presented below. Capital While it is customary to indicate capital costs on a $/kW basis for power generation applications, this is not relevant for non-power applications since no electricity is generated. However, one of the main parameters dictating the “sizing” and hence, the costs of a PM control device, is the quantity of flue gas it must handle. As a result, it is more appropriate to generalize capital costs on a “$/ACFM” basis. The following values represent typical costs for several of these technologies (these numbers reflect unit sizes ranging from utility-size units up to about 2,000,000 ACFM to smaller process down to about 10,000 ACFM)) • • • • • • Dry ESPs - $15 - $40/ACFM Wet ESPs - $15 - $40/ACFM Reverse Air Fabric Filter - $17 - $40/ACFM Pulse Jet Fabric Filter - $12 - $40/ACFM Venturi Scrubber - $5 - $20/ACFM Cyclone - $1 - $5/ACFM O&M O&M costs are difficult to generalize for such a variety of technologies and applications, as they are affected by many parameters that include type of fuel, type of process, local ash disposal options, local cost of power, etc. O&M costs include fixed costs (FOM) and variable costs (VOM). The costs provided below are presented in $/year-ACFM and reflect costs for coal based fuels but should reasonably apply to other sources as well. Fixed O&M • • • Dry ESPs - $0.25 - $0.65/yr-ACFM Wet ESPs - $0.15- $0.50/yr-ACFM Reverse Air Fabric Filter - $0.35 - $0.75/yr-ACFM http://www.reaction-eng.com VI-49 REACTION ENGINEERING INTERNATION AL • • • Pulse Jet Fabric Filter - $0.50 - $0.90/yr-ACFM Venturi Scrubber - $0.25 - $0.65/yr-ACFM Cyclone – Not applicable Variable O&M • • • • • • Dry ESPs - $0.45 - $0.60/yr-ACFM Wet ESPs - $0.25 - $0.50/yr-ACFM Reverse Air Fabric Filter - $0.70 - $0.80/yr-ACFM Pulse Jet Fabric Filter - $.90 - $1.1/yr-ACFM Venturi Scrubber - $1.2 - $1.8/yr-ACFM Cyclone – Not applicable http://www.reaction-eng.com VI-50 REACTION ENGINEERING INTERNATION AL 5 MULTI-POLLUTANT CONTROL TECHNOLOGIES Emerging environmental issues and proposed federal legislation (President’s Clear Skies Initiative, Carper Bill, Jeffords’ Bill) as well as state legislation (examples include MA, NY, NC, NH, CT) have driven interest in multi-pollutant (as opposed to single pollutant) control technologies capable of addressing air pollutant emissions more comprehensively with greater flexibility and ultimately lower cost. Multi-pollutant control technologies integrate in-situ and/or post-combustion controls of at least two of the following pollutants: SO2, NOx, and Hg (and other hazardous air pollutants including cadmium, arsenic, and nickel), and CO2. Multi-pollutant controls are intended primarily for large utility coal-fired boilers since the complexity of some of these processes as well as regulatory drivers often limit them to larger, utility boilers. Since coal-fired boilers represent the single largest source category for both NOx (as well as SO2 and Hg) and PM in the thirteen-state region, it is worth considering some of these technologies. 5.1 Proposed Multi-pollutant Emission Regulations from Utility Boilers In 2002 and 2003 three “multi-pollutant” bills were introduced in the US Congress that call for coordinated reductions in NOx, SO2, and Hg from coal-fired power plants [26]. Some of the bills also include emission limits for CO2. The three bills are briefly summarized here. • The Clean Power Act (CPA, Jeffords) would amend the CAA to require electric power generation sources greater than 15 MW. It is the most stringent of the three proposals. It will cap SO2 emissions at 2.26 mm TPY in 2008 (0.28 mm TPY in the western region that includes WRAP states and MT, WY and CA; and 1.98 mm TPY in the eastern region). For NOx, the cap of 1.51 mm TPY is to be met by 2008. The cap on Hg is at 5 TPY, also to be met by 2008. In addition, this bill sets a cap of 2.08 billion TPY for CO2 to be met by 2008 (roughly 1990 levels). Except for Hg, national trading will be allowed to meet the caps. • The Clear Skies Act (CSA) has been proposed by the Bush administration. It is the least stringent of the three proposals. It would cap SO2 emissions at 4.5 mm TPY in 2010 and at 3 mm TPY in 2018. The corresponding limits for NOx are 3 mm TPY (in 2008) and 1.7 mm TPY in 2018. For Hg, the proposed national caps are at 26 TPY in 2010 and 15 TPY in 2018. There are no limits for CO2. A national trading program similar to the existing trading program for SO2 emissions under Title IV of the Clean Air Act will be the implementation mechanism to achieve these caps. All electric generation sources greater than 25 MW would fall under this program. • The Clean Air Planning Act (CAPA, Carper,Breaux, Baucus, and Chafe)) was intended as middle ground between the CPA and CSA. For SO2, the caps are 4.5 mm TPY by 2008, 3.5 mm TPY by 2012, and 2.25 mm TPY by 2015. The caps for NOx are 1.87 mm TPY by 2008 and 1.7 mm TPY by 2012. The Hg cap limits are 24 TPY by 2008, and a potential cap of 516 TPY by 2012 (this cap to be set by EPA and implies a control in the range of 79 to 93% from current Hg emission level). Cap and trade program will be the implementation mechanism for all four pollutants, except trading for Hg will be limited. In a “hybrid” approach, limited trading for Hg would be allowed (each plant will be required to reduce its Hg emissions at site by at least 50% in 2008 and by 75% in 2012). For CO2, CAPA proposes to stabilize CO2 emissions at 2005 levels (approximately 2.6 billion TPY) by 2008, and then stabilize to 2001 levels (approximately 2.4 billion TPY) by 2012. http://www.reaction-eng.com VI-51 REACTION ENGINEERING INTERNATION AL All three bills recognize and incorporate the WRAP SO2 trading program by setting separate caps on SO2 emissions in the West. The CPA and CAPA allow nationwide trading of NOx, while the CSA divides the country into two zones for NOx trading. The western zone includes the ND, SD, NE, OK, KS, western TX, the eleven states west of the Rockies, AK, HI and the U.S. territories. The largest differences among the three bills are in the Hg emissions reduction requirements. The first-phase Hg emissions caps under CSA and CAPA are about the same, but compliance would come two years earlier under CAPA. CPA has the most stringent Hg reduction requirement: a cap of 5 TPY or about 90% control. The CSA would allow nationwide Hg trading, while the CAPA would allow partial trading. There is no trading under CPA. Both CSA and the first phase of CAPA have modest Hg emission reduction targets; these would make it possible in some cases to achieve reduction of Hg as a “co-benefit” of other control technologies, for example, from the combination of an SCR and wet scrubber. If one of these bills were enacted, there might be some additional incentive to install an SCR and/or FGD on plants for which there might not be justification on the basis of a single pollutant. In terms of Hg co-benefits, the West is at a disadvantage as compared to the East. In the latter region, more utilities burn bituminous coals that are high in chlorine (which tends to increase the amount of oxidized Hg in flue gas) and in sulfur. Wet scrubbers are effective for the removal of oxidized Hg, but ineffective for removal of the elemental Hg that is the predominant form of Hg in many western power plants. If all coal-fired power plants must reduce Hg emissions by upwards of 70%, the West will have a more difficult job than the East, owing to differences in coal composition. The bills that allow Hg trading (CSA and CAPA) would allow western power plants to deploy Hg control technology at plants were the highest emissions reductions are likely to be achieved. If the CPA is enacted or if none of the three bills are enacted this year, it is likely that EPA will continue with the MACT process for Hg control, which does not allow trading and which will probably impose a Hg emission reduction target in the range of 70% to 90% (or an emission limit in the range of 0.2 to 0.6 pound of Hg per trillion Btu input). In this case, coal-fired power plants will have to look at application of activated carbon injection, the most mature technology for Hg control currently, or one of the multi-pollutant processes under development. Activated carbon injection may require adding additional particulate control equipment (such as a polishing baghouse with high cloth to air ratio), which will lower PM as well as the emissions of other hazardous pollutants including arsenic, chromium, lead, manganese, and nickel) as a consequence. 5.2 Multi-pollutant Control Technologies A multi-pollutant control technology may be one integrated process or a combination of synergistic processes. In addition to in-situ and post-combustion control processes, options such as advanced power generation technologies, power plant rehabilitation-upgrading-repowering, fuel switching or blending and power plant optimization are sometimes included in the multipollutant control category. Emerging and commercial processes for multi-pollutant control for coal-fired boilers are summarized in Table 25, which is largely taken from Reference 4, with more recent information from the DOE-EPRI-U.S. EPA -A&WMA Combined Power Plant Air Pollutant Control Symposium in Washington, D.C., May 19-22, 2003. http://www.reaction-eng.com VI-52 REACTION ENGINEERING INTERNATION AL Approximately half of the options listed in Table 25 are in commercial and early commercial stages. However, nearly all the options in commercial stage are proven SO2 control technologies, which also remove Hg, advanced power generation options and power plant upgrading-fuel switching options. Nearly all in-situ and post-combustion controls (SO2-NOx or SO2-NOx-Hg) are either in demonstration or pilot-scale. Some technologies (e.g., SNOX, SNRB, Advacate and CZD) have been tested either in pilot or demonstration scale in the early phase of the U.S. Department of Energy’s Clean Coal Technology (CCT) program, but have not been adopted by the industry. Some of these technologies may become more cost-effective if additional controls are required. Most of the environmental control processes increase the auxiliary power requirements of the plant (some up to 5%, but mostly in the range of 1 to 2%), increasing proportionally the CO2 emissions. Emerging post-combustion, multi-pollutant control technologies are being developed by a number of companies. The Electro-Catalytic Oxidation (ECO) system is a four-stage pollution control process that integrates established technologies to remove SO2, NOx, Hg and PM2.5. The system also produces a valuable fertilizer byproduct. The AIRborne process removes SO2 and NOx from plant emissions while turning the leftover material into a high-quality granular fertilizer. EnviroScrub is a dry scrubbing system that results in control of SO2, NOx, and possibly mercury and results in a byproduct that can be sold into the fertilizer, chemical, and/or explosives industry. None of these technologies controls emissions of CO2. Capital costs of options controlling two pollutants (either SO2-NOx or SO2-Hg) are projected to be in the 50-315 $/kW range, but there is significant uncertainty associated with these estimates because of their early stage of development. Also, lack of information, especially associated with O&M costs, makes it difficult to compare their cost-effectiveness. Further monitoring and updating of cost-related information is needed. For reference, the costs of the combined commercial technologies, FGD and SCR are above 200-250 $/kW. Advanced power generation technologies such as circulating fluidized bed (CFB), pressurized fluidized bed (PFBC) and integrated gasification combined cycle (IGCC) are potentially attractive options because they are revenue-generating options, while reducing significantly SO2 and NOx, and to a lesser extent CO2. These options are available mainly for new power plants. Also, supercritical pulverized coal boiler provides an attractive alternative to subcritical pulverized coal boiler for nearly the same investment and results in an additional 4-12% reduction of all emissions. While this may not seem to be a significant percentage, their cost-effectiveness is attractive; also, the amount of CO2 reduction (in tons or tons per year) is significant. Of particular interest are options such as power plant optimization, fuel blending or switching and power plant upgrading. These options may play an important role in a flexible compliance regulatory framework and may result in significant savings for the utility industry compared to the implementation of control technology options. Optimization involves only operating changes, and while it results in only minor emission reductions, its costs are very low and therefore it is an attractive option and should be pursued in all power plants. Fuel blending or switching, and power plant upgrading provide significant opportunities for emission control, but their site-specific nature makes it difficult to generalize regarding their emission reduction potential and cost-effectiveness. A more site-specific assessment is recommended to assess the potential for these options in a typical utility system. http://www.reaction-eng.com VI-53 REACTION ENGINEERING INTERNATION AL http://www.reaction-eng.com Table 25. Commercial and Emerging Multi-Pollutant Control Technologies for External Combustion Boilers. Technology VI-54 Status Emissions Reductions Applicability Issues Dry Scrubbers (conventional) C SO2: >95%; NOx: NA; Hg: 585% Low to medium sulfur coals Hg removal can vary significantly with coal type, operating conditions SO2 sorbents, low temperature P/C SO2: 40-85%; NOx: NA; Hg: 090% Units with ESP or FF for particulate control Potential impacts on ESP or FF SO2 sorbents, furnace injection C/D SO2: 65-70%; NOx: NA; Hg: 65-90% Existing plants, especially older units less than 300 MW Demonstration on long-term basis needed Activated carbon with SO2 sorbent processes P/C SO2: 40-85%; NOx: NA; Hg: 50-90% Units with ESP or FF for particulate control Not used commercially, potential impacts on ESP or FF Wet FGD with mercury oxidation processes P SO2: 95%; NOx: NA; Hg: 80+% Wet Scrubber Plants Full scale demonstration underway, insufficient information at present Wet FGD with wet ESP C/P SO2: 99%; NOx: NA; Hg: 80+% Integration with wet scrubbers, retrofit dry ESPs, new units Few application in power industry, potentially expensive alloys required Advanced Dry FGD P/C SO2: 90-98%; NOx: NA; Hg: <90% NOX-Hg control for low to medium sulfur coals(same as Spray Dryers) Hg removal may vary significantly with coal type, operating conditions (similar to Spray Dryers) E-BEAM C/D SO2: 95+%; NOx: 50-90%; Hg: NA New and retrofit High costs and auxiliary power requirements SNOX C SO2: 90+%; NOx: 50-90%; Hg: 0% New and retrofit Cost-effectiveness SNRB P SO2: 80-90%; NOx: 50-90%; Hg: 0% New and retrofit Requires demonstration AIRborne D New and retrofit Demonstration in progress; capital cost comparable to FGD-SCR Thermal NOX D SO2: 90->99%; NOx: 50-60%; Hg: 30-75% 30 % SO2: 90-95%; NOx: 80-90%; Hg: NA New and retrofit In demonstration SO2/Mercury Control SO2/NOx Control REACTION ENGINEERING INTERNATION AL Status: P = pilot stage; C = commercial; D = demonstration http://www.reaction-eng.com Table 25. Commercial and Emerging Multi-Pollutant Control Technologies for External Combustion Boilers. [Continued] Table 25. Commercial and Emerging Multi-Pollutant Control Technologies for External Combustion Boilers. [Continued] Technology Emissions Reductions Applicability Issues C SO2: 90-98%; NOx: 60-80%; Hg: 90-99% New and retrofit High costs, especially operating costs due to high activated coke costs P/C Hg: 50-90% Retrofit and new units with ESP an/or FF D SO2: 95-98%; NOx: 90%; Hg: 70+% New and Retrofit Not widely demonstrated at full scale, ash salability, ESP/FF performance, impact of mercury speciation Demonstration required D SO2: 99+%; NOx: 99%; Hg: 60-70% New and retrofit. C SO2: 95%; NOx: 90-95%; Hg: 0-80% Plants with SCR and Wet scrubber technologies SO2/NOx/Mercury Control Activated Coke Activated carbon with particulate controls Electro Catalytic Oxidation VI-55 Status EnviroScrub Wet FGD and SCR Status: P = pilot stage; C = commercial; D = demonstration Demonstration required; costs estimated to be 30-50% lower than FGD-SCR Depends on Hg speciation in flue gas. REACTION ENGINEERING INTERNATION AL 6 SUMMARY AND RECOMMENDATIONS 6.1 NOx and PM Sources The main objectives of this project were to identify and briefly describe the available (or emerging) technologies for control of NOx and PM emissions that could be applied to sources in the western United States. The starting point for this work was an analysis of large (greater than 100 TPY) sources from the WRAP 1996 Emission Inventory (Version 3). Sources were limited to those from the thirteen-state region: AZ, CA, CO, ID, MT, ND, NM, NV, OR, SD, UT, WA, and WY. The source profile from the thirteen-state region was compared with that from the nine-state GCVTR: AZ, CA, CO, ID, NM, NV, OR, UT, and WY. The GCVTR accounted for 75% of the NOx emissions and 83% of the PM emissions within the thirteen-state region. Generally, the distribution of sources was the same in the GCVTR as compared to the thirteen-state region. Thus, conclusions based on the thirteen-state region should therefore be valid for the GCVTR while achieving broader applicability to WRAP members. The cut-off of 100 TPY captures 84% of the NOx emissions in the 1996 WRAP database for the thirteen-state region. For ICE’s (reciprocating engines and turbines) the 100 TPY cut-off only captures about 56% of the emissions, though this category is the second largest category and responsible for 10% of stationary source emissions. Thus, NOx control programs for sources in this category will require careful consideration of population attributes (e.g., a large number of small sources). The largest source category for NOx by far in the thirteen-state region is coal-fired boilers (68%); the top five categories (coal-fired boilers, internal combustion engines, cement kilns, turbines and oil and natural gas boilers) account for 90% of the NOx emissions. The states with the largest stationary source NOx emissions according to the 1996 WRAP database were AZ, CA, ND, NM, UT, and WY. According to the WRAP 1996 (Version 3) stationary source emissions database, about 4% of the NOx sources greater than 100 TPY had at least one type of control. Coal-fired boilers had the highest level of control (15%), followed by petrochemical processes (13%). The level of control for coal-fired boilers seemed low, even for 1996. Therefore, the 1996 WRAP database was compared with the data available for utility boilers in the 1996 CEMS and E-GRID databases. The EIA-767 database was also searched for NOx control technologies. This comparison only looked at coal-fired utility boilers and not all coal-fired boilers. However, only 3% of the WRAP NOx emissions from coal-fired boilers in the thirteen-state region were from non-utility boilers. WRAP data augmented by these other databases suggested that 44% of the utility boilers had at least one type of NOx control in 1996, mostly low-NOx burners. The NOx emission rate from external combustion boilers that is achievable with combustion modification depends on the fuel type. For coal-fired boilers, lower NOx emission rates are obtained when firing subbituminous coal as compared to bituminous coal. Considering the http://www.reaction-eng.com VI-56 REACTION ENGINEERING INTERNATION AL amount of subbituminous coal in the West, there is a fairly even split between bituminous and subbituminous coals as fuels for utility boilers. This may have shifted since 1996, however. The cut-off of 100 TPY captures 60% of the PM emissions in the 1996 WRAP database for the thirteen-state region. The largest source category in the thirteen-state region is coal-fired boilers (40%); the top eight categories account for 92% of the PM emissions (greater than 100 TPY): coal-fired boilers, mineral processing, petrochemical, wood boilers, fugitive, primary metal production, pulp and paper, and smelting operations. The state with the largest PM emissions is WY, followed by AZ, ID, and NM. In the 1996 WRAP database, 72% of coal-fired boilers, the largest category of emissions, had PM controls. Overall, though, only 38% of units had PM controls. Controls for NOx and PM 6.2 Many commercially available technologies exist for control of NOx and PM emissions from stationary sources. Twenty-five NOx control technologies and four PM control technologies were summarized. Cost and performance information was obtained for most technologies. There are a lot more technologies available for NOx control because of the different ways in which NOx can be prevented or destroyed. In contrast, PM control on industrial processes is often done only at the back end of the process. This is not to say that process modification cannot be used to reduce PM emissions. Fugitive emissions, for example, can sometimes be controlled by process modification. Further work should be done to look into the details of important industrial processes to determine where process modification will yield significant reductions in PM. Most of the NOx emissions from stationary sources are generated by combustion or by high temperature thermal processing. NOx control technologies fall broadly into two categories: combustion modifications and post-combustion removal or destruction. Combustion systems differ, from internal combustion engines to external combustion boilers. Thus, there are many different strategies for modifying the combustion process. Deciding on an appropriate NOx control technology is highly dependent on the process conditions and on the type of fuel. The existing NOx control technology on a particular source will also influence what additional NOx controls can be added successfully. Post-combustion NOx controls are not truly “back-end” technologies, like ESPs and baghouses for PM control; some degree of process integration is required. Thus, not all post-combustion control processes can be applied to a given source. There is no “one size fits all” solution for NOx control. Deciding which technology to apply to a certain source depends on: • • • • • The fuel type; The specific combustion process; Post-combustion characteristics: temperature, residence times, etc.; The type of NOx control technology already in use; and The target NOx emission rate. http://www.reaction-eng.com VI-57 REACTION ENGINEERING INTERNATION AL Emerging environmental issues and regulatory changes have driven interest in multi-pollutant (as opposed to single pollutant) control technologies capable of addressing air pollutant emissions more comprehensively with greater flexibility and ultimately lower cost. Multi-pollutant control technologies integrate in-situ and/or post-combustion controls of at least two of the following: SO2, NOx, and mercury pollutants, and CO2 emissions. Multi-pollutant controls are intended primarily for external combustion boilers, particularly coal-fired boilers. The complexity of some of these processes as well as regulatory drivers often limit them to larger, power-generation boilers. Emerging post-combustion, multi-pollutant control technologies are being developed for SO2, NOx, and mercury that could be applied to stationary combustion sources in the western U.S. in the next five or ten years. These processes generally produce a saleable byproduct and have SO2 removal rates of greater than 50%, and NOx removal rates of greater than 70%. Several of these processes are currently in pilot or full-scale demonstration. Costs of options controlling two pollutants (either SO2-NOx or SO2-Hg) are projected to be in the 50-315 $/kW range, but there is significant uncertainty associated with these estimates because of their early stage of development. Also, lack of information, especially associated with O&M costs, makes it difficult to compare their cost-effectiveness. Further monitoring and updating of cost-related information is needed. For reference, the costs of the combined commercial technologies, FGD and SCR are above 200-250 $/kW. 6.3 What’s on the horizon? What trends will influence emissions and control technologies? - The rate of advancement and use of multi-pollutant technologies (NOx/Hg, SO2/Hg, PM/Hg, etc.) will depend on the levels of future mercury emissions reduction. - Significant enhancements have been made in the ability of combustion modifications to reduce NOx formation, but they may be reaching their maximum potential given the theoretical limits within the combustion process and given the nitrogen content of some fuels (e.g., coal). Determining how much NOx emissions can be reduced in the West through this type of technology will require closer examination of the types and vintages of combustion modifications already in place. - There is (and always will be) uncertainty in the future mix of fuels for some combustion processes (e.g. electricity production). This influences the retirement of existing sources and the investment in new sources, which, in turn requires that a range of projections be made for future source distribution scenarios. - Historically new technologies have had one major evaluation criteria in common: their performance improvement over the existing technology (e.g. SCR capable of 90% reductions over SNCR). As technologies push the potential control levels to 90% or more, we need to view them from a new perspective, one which includes greater emphasis on overall impacts, costs, inter-pollutant compatibility, etc. http://www.reaction-eng.com VI-58 REACTION ENGINEERING INTERNATION AL 6.4 Recommendations for Future Work Further work must be done in order to generate both accurate costs and reasonable control scenarios to be used in both regional-scale atmospheric models and in evaluating regional control strategies, particularly in light of the multi-pollutant control legislation currently under consideration in Congress. This includes the following: • • • • Accurate cost information (generally available now); Details of the emission-generating processes; NOx and PM control technologies already in place; and Accurate estimates of the current emissions. Better use could be made of existing EPA databases; in addition, the WRAP database should be updated to give a more accurate description of sources and existing control technology. In this work, we found that the EPA databases (CEMs and E-GRID) were easy to use and provided what appeared to be a fairly complete picture of current emissions and control technologies for NOx and PM. Since much has changed in the West since the 1996 WRAP stationary source inventory, these databases are useful for getting more current information on utility boilers, which generate a significant amount of the emissions in the western U.S. It would be worthwhile now to look at trends in emissions and NOx control technologies in the West by analyzing the most recent CEMs and E-GRID databases. Sufficient detail about the configuration and process of the sources is generally not available in the EPA databases and these databases are only for utility boilers. The next WRAP inventory should be used to collect the information needed to make estimates of costs for control. Better identification of sources is important; there are instances in the 1996 WRAP database in which there is insufficient information on the type of source and/or the fuel in use. Obviously, better identification of existing air pollution control technology is critical. For combustion sources, particularly utility boilers, the capacity, in terms of MBtu/yr should also be included in the WRAP database. Consideration should also be given to selecting a subset of sources for detailed characterization and calculate ranges of costs and expected emissions reductions. The subset should be a representative distribution of those sources within the most important source categories. http://www.reaction-eng.com VI-59 REACTION ENGINEERING INTERNATION AL 7 REFERENCES 1. EPA Emissions Tracking System (Acid Rain Program), http://www.epa.gov/airmarkets/emissions/index.html. 2. EPA Emissions & Generation Resource Integrated Database (E-GRID), http://www.epa.gov/airmarkets/egrid/. 3. DOE Energy Information Agency, EIA-767 Steam Electric Plant Report, http://www.eia.doe.gov/fuelelectric.html. 4. “Multi-pollutant Emission Control Technology Options for Coal-Fired Power Plants,” EPA-600/R-02/075, October 2002. 5. Battye, R., Walsh, S., Lee-Greco, J. “NOx Control Technologies for the Cement Industry (Final Report).” EPA Contract No. 68-D98-026, EC/R Incorporated, Chapel Hill, NC, September 2000. 6. Dusome D. (1993). “Staged Combustion for NOX Control at the Calaveras Tehachapi Plant”, presented to the Portland Cement Association. 7. Nielsen, P.B. et al. (1990). “An Overview of the Formation of SOX and NOX in Various Pyroprocessing Systems”, IEEE Cement Industry Technical Conference. 8. SA Johnson and S Haythornthwaite, Summary of Available NOx Control Techniques for the Cement Industry, submitted to the Portland Cement Association, Skokie, IL 1998. 9. Amar, K.P., Staudt, J. “Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers, Internal Combustion Engines; Technologies and Cost Effictiveness.” Norhteast States for Coordinated Air Use Management, Boston, MA, January, 2001. 10. U.S. Environmental Protection Agency. “Alternative Control Techniques DocumentNOx Emissions from Stationary Gas Turbines.” EPA-453/R-93-007, Research Park Triangle, NC, January, 1993. 11. Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68-D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. 12. State of New Jersey Department of Environmental Protection. “State of the Art (SOTA) Manual for Reciprocating Internal Combustion Engines.” Trenton, NJ, July, 1997. 13. SA Johnson and S Haythornthwaite, Summary of Available NOx Control Techniques for the Cement Industry, submitted to the Portland Cement Association, Skokie, IL 1998. 14. State of California Air Resources Board. “CAPCOA/ARB Proposed Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Stationary Internal Combustion Engines (DRAFT).” Sacramento, CA, December, 1997. 15. State of New Jersey Department of Environmental Protection. “State of the Art (SOTA) Manual for Reciprocating Internal Combustion Engines.” Trenton, NJ, July, 1997. 16. European IPPC Bureau. “Reference Document on Best Available Techniques in the Glass Manufacturing Industry.” Seville, Spain, October, 2000. 17. W. Neuffer, U. S. EPA. Summary of Information Provided by Engine Manufacturers on Low Emission Combustion. 18. Telecon. R. Faulkner, Diesel Supply Company, with S. Edgerton, EC/R. April 6, 2000. http://www.reaction-eng.com VI-60 REACTION ENGINEERING INTERNATION AL 19. Cooper-Bessemer. Facsimile from J. W. Hibbard to W. Neuffer, U. S. EPA. Information on Low Emission Combustion. Cooper-Bessemer, Cooper Energy Services, Mount Vernon, OH. March 3, 1999. 4pp. 20. Dresser-Rand. Facsimile from C. F. Willke to W. Neuffer, U. S. EPA. Information on Low Emission Combustion. Dresser-Rand Services, Painted Post, NY. May 7, 1999. 2pp. 21. National Center for Environmental Research, U. S. EPA Office of Research and Development. “1994 Phase II Abstracts: Plasma Ignition Retard for NO(x) Reductions.” http://es.epa.gov/ncerqa_abstracts/sbir/94/topics43.html. 22. Manufacturers of Emission Controls Association. Emission Control Technology for Stationary Internal Combustion Engines. Status Report, July 1997. Pg. 7. 23. NOxTech Inc. Letter and attachments from E. Cazzola to Mary Jo Krolewsky, U. S. EPA Acid Rain Division. April 12, 1999. 24. NOxTech Inc. “NOxTech® Technology.” website. www.noxtechinc.com/products.htm. 25. Goal Line Environmental Technology News. “Cummins Engine Co. Tests SCONOx® for Diesel IC Engines.” Oct 1999. Vol 1, Issue 3. http://www.reaction-eng.com VI-61 REACTION ENGINEERING INTERNATION AL APPENDIX A : Breakdown of NOx Emissions by State Table A-1. WRAP NOx Emissions for sources > 100 TPY by State Category Coal-Fired Boilers Reciprocating Engines NG Diesel Process Gas Cement Kilns Oil/NG Boilers Turbines NG Diesel Mineral Processing Petrochemical NG Compressor Pulp and Paper Wood Boilers Refinery Process Heaters Glass Manufacture Primary Metal Production Waste Combustion Refinery Emissions In-process Fuel Use Jet Engine Testing Oil and Gas Production Smelting Operations Sugar Beet Production Secondary Metal Production Turbines, Steam Total (> 100 TPY) 13-States AZ* CA* CO* Total NOx Total NOx Total NOx Total NOx TPY (>100 TPY (>100 TPY (>100 TPY (>100 TPY) # Units TPY) # Units TPY) # Units TPY) # Units 151 607,748 15 75,018 3 1,544 31 82,927 423 86,210 16 6,441 58 10,274 56 11,328 404 81,786 14 5,731 54 9,436 56 11,328 16 4,021 2 709 3 708 3 403 1 130 39 41,009 2 4,662 16 15,886 4 4,470 112 32,910 4 1,092 40 12,290 9 2,643 86 25,278 8 1,918 37 8,990 9 1,655 83 24,821 7 1,795 37 8,990 9 1,655 3 457 1 123 34 16,250 4 2,861 4 3,263 48 13,719 1 101 13 3,978 4 730 16 10,959 14 10,686 39 10,010 3 602 48 9,776 14 2,430 38 9,311 28 7,096 14 5,033 11 4,128 1 251 17 3,476 2 1,009 2 244 6 3,309 8 3,256 8 3,256 9 2,605 7 1,906 4 2,297 4 2,297 7 1,140 3 961 2 852 3 730 1 111 4 507 1 165 1 165 1,110 886,659 68 104,639 248 78,217 116 104,249 * GCTVR State A-1 Table A-1. WRAP NOx Emissions for sources > 100 TPY by State [continued] Category Coal-Fired Boilers Reciprocating Engines NG Diesel Process Gas Cement Kilns Oil/NG Boilers Turbines NG Diesel Mineral Processing Petrochemical NG Compressor Pulp and Paper Wood Boilers Refinery Process Heaters Glass Manufacture Primary Metal Production Waste Combustion Refinery Emissions In-process Fuel Use Jet Engine Testing Oil and Gas Production Smelting Operations Sugar Beet Production Secondary Metal Production Turbines, Steam Total (> 100 TPY) ID* Total NOx TPY (>100 TPY) # Units 6 2,218 1 MT ND NM* Total NOx Total NOx Total NOx TPY (>100 TPY (>100 TPY (>100 TPY) TPY) TPY) # Units # Units # Units 6 25,452 17 108,007 10 70,193 14 4,357 8 2,569 201 37,755 4 2,056 8 2,569 201 37,755 10 2,301 1 1 0 139 1 1,662 128 0 139 117 1,449 3 5 428 842 3 4 377 708 4 4 920 1,057 1 5,008 1 10 12 909 564 3 1 3 18 3 3 1 564 915 4 2,971 2 348 2 619 12 1,000 3,389 2,947 2,947 1 1 145 124 1 1 360 206 1 140 589 39 * GCTVR State A-2 35,436 40 116,901 239 116,258 Table A-1. WRAP NOx Emissions for sources > 100 TPY by State [continued] Category Coal-Fired Boilers Reciprocating Engines NG Diesel Process Gas Cement Kilns Oil/NG Boilers Turbines NG Diesel Mineral Processing Petrochemical NG Compressor Pulp and Paper Wood Boilers Refinery Process Heaters Glass Manufacture Primary Metal Production Waste Combustion Refinery Emissions In-process Fuel Use Jet Engine Testing Oil and Gas Production Smelting Operations Sugar Beet Production Secondary Metal Production Turbines, Steam Total (> 100 TPY) NV* Total NOx TPY (>100 TPY) # Units 8 39,040 2 6 1 3,789 3,727 191 1 2 OR* Total NOx TPY (>100 # Units TPY) 1 4,195 2 6 3 2 1 191 687 2,155 5,372 5,229 143 218 1 125 1 109 21 47,199 SD Total NOx TPY (>100 TPY) 17,268 # Units 3 3 2,718 2 2 14 17 3,641 3,366 3 514 46 * GCTVR State A-3 19,929 2 1 3 435 2 435 577 10 UT* Total NOx TPY (>100 # Units TPY) 15 66,600 15 2,074 14 1,772 1 303 20,998 565 267 772 3 772 5 2 2 4,542 324 273 7 2 1,263 339 54 77,020 Table A-1. WRAP NOx Emissions for sources > 100 TPY by State [continued] Category Coal-Fired Boilers Reciprocating Engines NG Diesel Process Gas Cement Kilns Oil/NG Boilers Turbines NG Diesel Mineral Processing Petrochemical NG Compressor Pulp and Paper Wood Boilers Refinery Process Heaters Glass Manufacture Primary Metal Production Waste Combustion Refinery Emissions In-process Fuel Use Jet Engine Testing Oil and Gas Production Smelting Operations Sugar Beet Production Secondary Metal Production Turbines, Steam Total (> 100 TPY) WA WY* Total NOx Total NOx TPY (>100 TPY (>100 # Units TPY) # Units TPY) 8 20,138 28 95,148 7 1,191 48 10,219 5 918 48 10,219 2 4 28 3 273 4,126 5,758 324 3 2 4 4 324 4 1,444 553 1,971 1,971 4 11 1,904 3,635 8 7 2,197 1,619 15 8 9 2 1 4,471 1,856 2,009 654 116 1 205 4 652 1 109 4 507 105 *GCVTR State A-4 46,798 106 114,009 : APPENDIX B : Breakdown of PM Emissions by State Table B-1. WRAP PM Emissions for sources > 100 TPY by State Category Coal-Fired Boilers Mineral Processing Petrochemical Wood Boilers Refinery Emissions Primary Metal Production Pulp and Paper Smelting Operations Miscellaneous Oil/NG Boilers Sugar Beet Processing Cooling Tower Cement Kilns Turbines Diesel NG Secondary Metal Production Jet Engine Testing Reciprocating Engines Diesel NG Refinery Process Heaters Total * GCTVR State 13-States AZ* # Units Total PM TPY 88 85 42 24 11 20 15 8 1 5 5 4 4 2 46,010 24,499 10,836 5,718 5,631 4,697 4,476 3,555 2,456 1,379 1,150 932 641 838 1 1 1 2 3 2 1 1 321 # Units Total PM TPY 9 14 2,657 4,932 2 3 3,949 529 1 137 1 210 1 590 590 248 537 535 525 CA* 1 # Units Total PM TPY 1 5 5 3 1 1 2 699 710 834 471 104 139 272 1 2,456 1 110 1 132 # Units Total PM TPY 3 18 4 684 4,700 757 3 1 843 232 1 430 1 248 590 1 2 1 273 252 176 114,589 CO* 32 535 104 1 1 104 13,107 169 1 1 24 248 176 6,638 32 169 8,063 Table B-1. WRAP PM Emissions for sources > 100 TPY by State [continued] Category Coal-Fired Boilers Mineral Processing Petrochemical Wood Boilers Refinery Emissions Primary Metal Production Pulp and Paper Smelting Operations Miscellaneous Oil/NG Boilers Sugar Beet Processing Cooling Tower Cement Kilns Turbines Diesel NG Secondary Metal Production Jet Engine Testing Reciprocating Engines Diesel NG Refinery Process Heaters Total * GCTVR State ID* MT ND # Units Total PM TPY # Units Total PM TPY 8 5 4 6 5,180 1,864 688 1,683 4 9 2 2 3,990 2,565 274 242 1 477 6 2,949 1 158 # Units Total PM TPY # Units Total PM TPY 11 1 1 3,679 110 590 9 2 1 7,285 270 307 4 1,242 1 176 17 9,280 1 1 216 1 117 30 12,579 20 7,825 NM* 14 297 4,676 Table B-1. WRAP PM Emissions for sources > 100 TPY by State [continued] Category Coal-Fired Boilers Mineral Processing Petrochemical Wood Boilers Refinery Emissions Primary Metal Production Pulp and Paper Smelting Operations Miscellaneous Oil/NG Boilers Sugar Beet Processing Cooling Tower Cement Kilns Turbines Diesel NG Secondary Metal Production Jet Engine Testing Reciprocating Engines Diesel NG Refinery Process Heaters Total * GCTVR State NV* OR* # Units Total PM TPY 8 2 5,688 244 1 4 15 211 1,235 7,379 SD UT* # Units Total PM TPY # Units Total PM TPY 1 108 2 236 11 3,056 1 233 1 5 276 898 1 144 1 537 20 5,019 3 469 # Units Total PM TPY 8 11 2,436 2,510 4 857 2 2,017 25 7,820 Table B-1. WRAP NOx Emissions for sources > 100 TPY by State [continued] Category Coal-Fired Boilers Mineral Processing Petrochemical Wood Boilers Refinery Emissions Primary Metal Production Pulp and Paper Smelting Operations Miscellaneous Oil/NG Boilers Sugar Beet Processing Cooling Tower Cement Kilns Turbines Diesel NG Secondary Metal Production Jet Engine Testing Reciprocating Engines Diesel NG Refinery Process Heaters Total *GCVTR State WA WY* # Units Total PM TPY 4 2,968 2 2 3 8 2 255 266 386 1,976 357 1 103 # Units Total PM TPY 20 18 23 10,400 6,594 7,130 1 115 4 932 1 252 1 22 6,311 67 252 25,423 APPENDIC C: NOx Control Technology Summaries Category Cement Kilns Process Description: Process: Air or Fuel Staging NOx, TPY (WRAP %NOx reduction Cost, $/ton 1996) 41,009 0 to 50% 1000-2000 Status Commercial Inject portion of the fuel downstream of the main flame to create locally reducing conditions where NOx can be destroyed. Sometimes includes installing a “NOx fan” to increase burnout. Most commonly applied to preheater/precalciner kilns in which part of the coal is already being fired in the calciner. In this case, airflow is rerouted downstream of the calciner fuel injector. Air and Fuel Staging as commonly applied to large industrial/utility boilers is discussed under the more commonly referred names technologies Overfire Air and Fuel Reburn NOx Reduction: NOx reduction is achieved by creating two separate combustion zones. The burner zone is fired fuel-lean to create the high temperatures needed for clinker formation. Limestone calcination, which takes place at temperatures in the range of 1600 to 1800 °F, is accomplished in the second combustion zone in the tower. NOx reductions as high as 50% can be achieved by controlling the size of the fuel-rich region in the second combustion zone. Conversely, if combustion is fuel-lean or well-mixed in the second zone, NOx would not be reduced. The ideal stoichiometric ratio in the calciner is 0.7 to 0.8. Some systems do not perform well because the second combustion zone is too fuel-rich (SR < 0.6), causing significant NOx production when the staging air is added. Cost Information: Capital cost for the technology includes additional ductwork and controls. This should run between $200,000 and 500,000 depending on the length of new ductwork required. Operating cost should not change unless lower temperatures or locally reducing conditions adversely affect cement quality. Development Status: Commercially available. Practical Considerations: The technology is easier to implement on preheater/precalciner kilns since special injectors are required to introduce fuel or air into the middle of a rotating kiln. In either case, there must be sufficient residence time at high temperature to complete burnout. Compatibility with other air pollution control technologies: Reducing conditions may increase sulfur emissions or require additional SO2 emission controls. C-1 Process: Air or Fuel Staging Secondary Environmental Impacts: None expected. References: Dusome D. (1993). “Staged Combustion for NOx Control at the Calaveras Tehachapi Plant”, presented to the Portland Cement Association. Nielsen, P.B. et al. (1990). “An Overview of the Formation of SOX and NOX in Various Pyroprocessing Systems”, IEEE Cement Industry Technical Conference. Johnson, S.A. and Haythornthwaite, S., “Summary of Available NOx Control Techniques for the Cement Industry”, submitted to the Portland Cement Association, Skokie, IL, 1998. C-2 Category Glass Manufacturing Process Description: Process: NOx, TPY (WRAP 1996) 5,033 Batch/Cullet Preheating %NOx reduction Cost, $/ton 5-25% 890-1,040 Status Commercial Batch and cullet (recycled glass) preheating can be applied by direct preheating, indirect preheating and Edmeston EGB Filter. Direct preheating requires direct contact between the flue gas and the raw material in a cross-counter flow and incorporates a bypass that allows furnace operation to continue when preheater use is either inappropriate of impossible. The indirect preheater is in principle a cross-counter flow, plate heat exchanger. The Edmeston electrified granulate bed (EGB) filter system is a hybrid between an electrostatic precipitator for dust removal and a direct cullet preheater. NOx Reduction: Cullet preheating is primarily an energy saving technique (savings between 10-20%), but its practice reduces NOx emissions due to lower fuel requirements and lower furnace temperatures. Cost Information: Capital costs generally range from $42K-110K. Economics are strongly dependent on the capacity of the furnace and the preheater. Development Status: Commercially available Practical Considerations: Cullet preheating systems can be installed at any existing glass melting furnace with greater than 50% cullet in the batch. For economic reasons, the temperature of the waste gas available should be at least 400-450°C, and a cooling of the flue gases by at least 200-250°C is needed. To prevent material agglomeration, the maximum entry temperature of the flue gases should not exceed 600°C. The design and implementation of the preheating unit should be evaluated with the over-all system configuration. Many technical issues, such as monitoring of the preheating temperature, should be carefully reviewed prior to the implementation. Compatibility with other air pollution control technologies: Cullet preheating is compatible with combustion modification techniques and post-combustion technologies. Secondary Environmental Impacts: • The use of a direct preheater causes increased emissions of particulate matter (up to 2000 mg/Nm3) and secondary particulate abatement is necessary. • Direct preheating reduces acidic compounds, SO2, HF, and HCl by up to 60%, 50%, and 90% respectively (difference before and after cullet bed). References European IPPC Bureau. “Reference Document on Best Available Techniques in the Glass Manufacturing Industry.” Seville, Spain, October, 2000. C-3 Process: Catalytic Combustion NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton Category Combustion or Gas Turbines 25,278 > 80% > 500 Process Description: Status Commercial Catalytic combustion reduces NOx formed from the combustion process by reducing the combustion temperature to reduce thermal NOx. The fuel and air are premixed into a fuel-lean mixture (fuel/air ratio of approximately 0.02) and then pass into a catalyst bed. In the bed, the mixture oxidizes without forming a high-temperature flame font. Peak combustion temperatures can be limited to below 2800 °F, which is below the temperature at which significant amounts of thermal NOx begin to form. Catalytic combustors can also be designed to operate in a rich/lean configuration. In this case, the air and fuel are premixed to form a fuel-rich mixture, which passes through a first stage catalyst where combustion begins. Secondary air is then added to produce a lean mixture, and combustion is completed in a second stage catalyst bed. NOx Reduction: According to one developer of the technology, catalytic combustion has been demonstrated to achieve 3 ppm NOx on a 1.5 MW gas turbine. A NOx level of 3.3 ppm was achieved on a General Electric Frame 9 test stand. Cost Information: Costs referenced above are preliminary and based on DOE reference below. Development Status: Commercially available. Practical Considerations: Catalytic combustion techniques apply to all combustor types and are effective on both diesel- and gasfired turbines. The technology has a limited operating range, and thus cannot be applied to gas turbines subject to rapid load changes. Compatibility with other air pollution control technologies: Compatible with post-combustion technology. Secondary Environmental Impacts: None expected. References: NESCAUM, “ Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers and Internal Combustion Engines: Technologies and Cost Effectiveness,” December 2000 U.S. Environmental Protection Agency. “Alternative Control Techniques Document-NOx Emissions from Stationary Gas Turbines.” EPA-453/R-93-007, Research Park Triangle, NC, January 1993. DOE, “Cost Analyses of NOx Control Alternatives for Stationary Gar Turbines”, November 1999. C-4 C-5 Category Turbines Process Description: Process: DLN (Fuel-lean combustion) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton 25,278 70% 1,000-2,000 Status Commercial Dry Low NOx (DLN) is a combustion technology for gas turbines that enables gas-turbine combustors to produce low NOx emission levels without diluents (such as water or steam) or catalysts. DLN technology utilizes a lean, premixed flame as opposed to a turbulent diffusion flame, a gas turbine equivalent of the LNB. NOx Reduction: Engines from 3-10 MW retrofit with DLN achieved 42 ppm NOx emissions, corresponding to reductions in the range of 60-83%. New and retrofit turbines in the larger, power plant sizes (over 50 MW) have been retrofitted to below 9 ppm of NOx. Cost Information: The cost of NOx reduction by DLN is very sensitive to the capacity factor of the turbine. There is also substantial variation in capital cost measured in terms of dollars/horsepower ($/hp) due to different turbine types and variations in turbine design. Reported costs in case studies show capital costs ranging from $750K-1,950K (4,700 hp at $160/hp and 13,000 hp at $150/hp). These are total project costs that owners attributed to the project, which may include project management or other charges associated with the project beyond the equipment and installation. Development Status: Commercially available As of August 2000, about 50 turbines had been retrofitted and over 500 new turbines were operating with DLN technology. Practical Considerations: Because DLN combustor technology operates under conditions that are much closer to the flammability limit than the conventional combustor technology, there is a significant risk of flame instability. Manufacturers have developed improved electronic turbine controls to address this problem. Some early experience has also found combustor liners failing after only about 5,000 hours compared to over 20,000 hour lifetime for conventional technology. Similarly, manufacturers have developed improved liners to address this problem. Other considerations are: • • DLN is achievable with fuels that can be premixed and are low in fuel nitrogen content, such as natural gas. Turbines that must maintain low NOx levels while operating on fuel oil may not be compatible with DLN. Achieving low NOx across the full load range requires a sophisticated combustor design, often with variable operating modes in order to maintain flame stability. C-6 • Process: DLN (Fuel-lean combustion) The DLN combustor is typically larger than a conventional combustor and can have more limited operating ranges. Compatibility with other air pollution control technologies: Compatible with post-combustion technology (SCR, SNCR). Secondary Environmental Impacts: None expected. References: NESCAUM, “ Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers and Internal Combustion Engines: Technologies and Cost Effectiveness” December 2000. C-7 Category Oil/Natural gas boilers Refinery Process Heaters Process Description: Process: Flue Gas Recirculation (FGR) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton 32,910 40-80% 500-3,000 (combined 9,311 with LNB) 5,900 Status Commercial Commercial Flue Gas Recirculation (FGR) simply refers to a NOx reduction approach that involves reintroducing some flue gas (5% to 15%) into the combustion air (or directly into the burner) to suppress flame temperatures and minimize NOx formation. This technology usually involves a dedicated FGR fan to recirculate the flue gas back to the burner front and it is most applicable to gas fired applications. This is because its main benefit is in the minimization of thermal NOx (NOx formed from nitrogen in the combustion air), as opposed to fuel-NOx (NOx formed from fuel-bound nitrogen). Since in oil and coal sources a significant fraction of NOx comes from “fuelNOx”, FGR is less effective in such applications NOx Reduction: NOx reductions from FGR on gas-fired sources can be in the range of 40% to 80%. FGR is often used in combination with LNBs and discriminating between the relative NOx reduction contributions is difficult in some cases. Cost Information: The main costs associated with FGR involve the retrofit of the FGR fan(s) and required ductwork to route the flue gas to the burner front. Costs in the range of $10 - $20/kW are expected for power generation sources Development Status: FGR is a well-proven technology in commercial operations for many years. Variations of the general concept include Induced FGR where the gas recirculated to the burner zone through an eductor, as well as recirculated to individual burners as opposed to the combustion air windbox for mixing with the combustion air prior to entering the burners. Practical Considerations: As mentioned above, FGR is mostly appropriate for gas-fired applications. Its effectiveness on oil and coal reduce its “appeal” to such sources Care is necessary to ensure that the amount of FGR does not compromise boiler safety by diluting oxygen concentration in the combustion air to unsafe levels C-8 Process: Flue Gas Recirculation (FGR) Compatibility with other air pollution control technologies: FGR is used in combination with LNB’s and OFA. FGR is also compatible with post combustion NOx technologies although the overall cost effectiveness needs to be addressed case-by-case. Secondary Environmental Impacts: None expected. References: EPRI, “Retrofit NOx Control Guidelines for Gas- and Oil-Fired Boilers”, Final Report, December 1993. Poole, L., “Houston Galveston Area NOx Abatement Industries Perspective,” present at the Council of Industrial Boiler Owners, NOx Control XV Conference, Houston, TX, August 2002. C-9 Category Coal-fired boilers Wood/Biomass boilers Glass Melters Process Description: Process: Fuel Reburn NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton 607,748 30-60% 500-2,000 9,776 40-60% 300-3,000 5,033 50-65% “moderate” Status Commercial Commercial Commercial Reburning, while generically included in the “Combustion Modification” category of NOx control technologies, differs from the others (BCM, LNB and OFA) by “destroying” NO rather than by minimizing its formation. Fuel is introduced above the main burner zone in the furnace, creating a fuelrich (reducing) atmosphere in which NOx formed in the main burner zone is destroyed by reacting with hydrocarbon and nitrogen compounds. The hardware needed for reburning includes reburn fuel burners or nozzles and overfire or burnout air ports (see discussion on fuel-lean reburn for deviations from this). The level of complexity of a particular system depends mostly on the choice of the reburn fuel itself (gas, coal, oil, orimulsion), as well as on the status and capability of the existing boiler (e.g., the burner/boiler control system). NOx Reduction: Full load NOx reductions with reburning can be expected to range from 35% to 60% depending on factors such as: • • • reburn fuel type and quantity; typically the reburn fuel needs to provide 15-20% of the total heat input if it is gas or 25-30% if coal to obtain 50-60% ∆NOx initial NOx level “tolerance” of negative impacts (e.g., efficiency loss, ash quality) At low loads, NOx reduction may fall to the 20-40% range, depending on the burner zone stoichiometry and low load operating characteristics of the boiler (e.g., operating at high excess air to control reheat temperature). Reburning, like SNCR and SCR, may be thought of as a “dial-in” technology in that NOx reductions will be a function of the amount of reburn fuel (or the amount of nitrogen compound reagent in the case of SNCR and SCR). This feature may make it particularly attractive for compliance scenarios based on seasonal use, averaging and/or trading. Cost Information: In general, the capital costs range from $15/kW to $30/kW for gas reburn and $30/kW to $60/kW when using coal as the reburn fuel. Operating costs are mainly driven by fuel cost differential (certainly gas vs coal). For other fuels (e.g. coal/orimulsion reburning), fuel preparation costs become more important (micronization, atomization) as there is little or no fuel cost differential. Retrofit schedules are directly related to the scope of the retrofit requirements. In most cases, 3-6 weeks are adequate for a reburn retrofit. C-10 Process: Fuel Reburn Development Status: Commercial While reburning does not account for a significant fraction of installed NOx reduction technologies compared to LNBs, SNCR and SCR worldwide, it is gaining acceptance, and a number of recent activities suggest it has become a viable strategic option for NOx control. This increase in interest is due to two key factors, among others: (1) increased experience and encouraging results, which increase the level of comfort with the technology; and (2) the “proliferation” of advanced reburn technologies, each with its own features, advantages and disadvantages. These “advanced” reburning options involve enhancements of the conventional approach, with features ranging from combinations with SNCR to the outright avoidance of overfire air, as in fuel-lean gas reburn (FLGR). Practical Considerations: Boilers with the following design and operating characteristics are expected to be more suitable candidates for reburning: • firing low-sulfur coals (e.g., less propensity for waterwall corrosion) • low baseline unburned carbon (e.g., to minimize ash salability impacts). • favorable cross-section/height profiles (e.g., tall boilers which provide for adequate mixing/residence time to maximize effectiveness). • gas availability, very efficient/effective coal pulverizers (e.g., approaching micronization) or access to orimulsion for the reburn fuel Of major importance is the choice of reburn fuel. The increasing experience with coal and orimulsion dictates that these must be considered in light of cost, availability, deliverability and overall project objectives. However, the use of natural gas provides benefits from lower maintenance costs (e.g., less demand on pulverizers) and lower emissions of other pollutants (particulate, SOx, CO2). Compatibility with other air pollution control technologies: Reburn Technology can be implemented with both Low NOx combustion approaches (e.g. LNBs) and post combustion technologies (SNCR/SCR). However, the overall NOx reductions are not strictly additive and careful evaluation is required to ensure cost effective strategies. Secondary Environmental Impacts: Reburn technology has the potential to effect both positive and negative secondary environmental impacts depending on factors such as the reburn fuel, main combustion and reburn zone stoichiometries, boiler physical characteristics, etc. The following are potential impacts that must be analyzed on an individual unit basis • CO may increase due to stoichiometry in the reburn zone • LOI may increase due to stoichiometries and OFA design C-11 • Process: Fuel Reburn SO2/CO2 benefits when reburn fuel is gas (proportional to gas input) References: NESCAUM, “Status Report on NOx Control Technologies and Cost Effectiveness for Utility Boilers”, June 1998. EPRI, “Retrofit NOx Controls for Coal-Fired Utility Boilers – 2000 Update”, EPRI Final Report, December 2000. Folsom, B. “Field Experience with Reburn NOx Control”, ICAC Forum 2000, Arlington, VA. March 2000. C-12 Category Reciprocating Engines Process: High Energy Ignition System (HEIS) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton Status 86,210 Commercial 50% - 80% 115 - 200+ Process Description: HEIS technology, also known as plasma ignition, provides a continuous electrical discharge at the gap of a conventional spark plug for 10 to 90 degrees of crankshaft rotation as opposed to traditional spark ignition where the life of the spark is only a fraction of a degree of crankshaft rotation. The extended energy ensures that ignition will occur even in the leanest of conditions. A rich mixture is ignited in a small ignition cell located in the cylinder head. The ignition cell flame passes to the cylinder where it provides a uniform ignition source. NOx Reduction: Laboratory tests and case studies have shown NOx emissions in the range of 2.5 to 3.0 g/bhp-hr while maintaining acceptable engine operation. Emissions of 2.5 b/bhp-hr were achieved on a 2,750-bhp engine, amounting to an 84% reduction from the uncontrolled level. Cost Information: Cost information was not widely reported. Cost range indicated above was taken from the NESCAUM reference below. Development Status: Commercially available HEIS has been installed on numerous engines to meet NOx RACT requirements in the range of 2.5 to 3.0 g/bhp-hr in the Eastern United States. Several users have reported over 80% reduction in NOx emissions. Practical Considerations: HEIS technology can be used only in lean-burn, natural gas-fired spark ignition engines. This technique can be retrofit to turbocharged 2- and 4-cycle engines. Compatibility with other air pollution control technologies: Compatible with post-combustion NOx technologies (SCR, NSCR). However, the overall NOx reductions are not strictly additive and careful evaluation is required to ensure cost effective strategies. Secondary Environmental Impacts: In most cases, NOx reductions have been accompanied by increased power output and increased fuel economy. References: Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. NESCAUM, “ Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers and C-13 Process: High Energy Ignition System (HEIS) Internal Combustion Engines: Technologies and Cost Effectiveness,” December 2000. State of New Jersey Department of Environmental Protection. “State of the Art (SOTA) Manual for Reciprocating Internal Combustion Engines.” Trenton, NJ, July, 1997. Alternative Control Techniques Document: NOx Emissions from Stationary Reciprocating Internal Combustion Engines. EPA Document No. EPA-453/R-93-032, July 1993. C-14 Category Reciprocating Engines Process Description: Process: High-Pressure Fuel Injection NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton Status 86,210 ~80% N/A (less than LEC) Commercial High-Pressure Fuel Injection represents a “second generation” Low Emission Combustion (LEC), according to one vendor of NOx control equipment and retrofit services. The technology uses high pressure to enhance the mixing of air and fuel in the combustion cylinder under fuel lean conditions. This technique reduces the quantity of excess air in comparison to LEC, diminishing the turbocharging and intercooling retrofit requirements. NOx Reduction: Tests from a large (~5,000 bhp) turbocharged Clark engine showed 80% NOx reduction. May be comparable to LEC reductions. Cost Information: Less than LEC because the technology does not require pre-combustion chambers or as much excess air, thus reducing the degree of turbocharging and intercooling required. Development Status: Commercially available Considered emerging in 2000. Practical Considerations: An LEC retrofit vendor stated that NOx emissions cannot be reduced to 2 g/bhp-hr through the use of a high-pressure fuel system alone. Less stringent regulatory requirements cans be met with a combination of ignition timing adjustment, high-pressure fuel injectors, and improve A/F ratio and ignition system controls. Compatibility with other air pollution control technologies: Compatible with post-combustion NOx technologies (SCR, NSCR). However, the overall NOx reductions are not strictly additive and careful evaluation is required to ensure cost effective strategies. Secondary Environmental Impacts: None expected. References: Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. National Center for Environmental Research, U. S. EPA Office of Research and Development. “1994 Phase II Abstracts: Plasma Ignition Retard for NO(x) Reductions.” http://es.epa.gov/ncerqa_abstracts/sbir/94/topics43.html. C-15 C-16 Category Coal-Fired Boilers Oil/Gas Boilers Wood/Biomass Boilers Process Description: Process: “Intelligent” Combustion Controls NOx, TPY (WRAP %NOx 1996) reduction Cost, $/ton 607,748 0-30% 100-300 0-30% 100-500 32,910 9,776 0-20% 200-500 Status Commercial Commercial Commercial Sensors and computer software programs are used to control air-fuel ratio to individual burners. Conventional combustion systems provide measured airflow to the windbox (that feeds all burners) and to each pulverizer (that feeds from two to eight burners). However, coal flow to individual burners may deviate by as much as 50%, while airflow to each burner may deviate by over 20%. Measuring and controlling (using existing or new control valves) these quantities at each burner allows the boiler to operate with lower excess air or slightly staged. Sensors are also available to monitor post-combustion processes. Online measurements of unburned carbon and CO provide feedback for burner adjustments. Other sensors evaluate flame quality, furnace temperature, or boiler heat transfer. Software can be rulebased or neural net. Usually the new software resides on the operator’s digital control system (DCS). NOx Reduction: Full -load NOx reductions with combustion monitoring and tuning can be expected to range from 0% to 30% depending on factors such as: o Current state of “out of tune” combustion system. o Initial NOx level. o Operational flexibility of the burner/furnace design. The highest NOx reductions are usually found on boilers that are able to bias their fuel input to lower burners and bias the airflow to upper burners. At low loads where there may be more operating flexibility, NOx reduction may improve to the 20-40% range, depending on the burner zone stoichiometry and low load operating characteristics of the boiler (e.g., operating at high excess air to control reheat steam temperature). Cost Information: In general, the capital costs for combustion monitoring and tuning are less than $1M per boiler. Operating costs are mainly driven by additional labor to maintain the new equipment. Often the installation of this technology is driven by the potential to reduce boiler operational expenses. For example, if total airflow is minimized, boiler efficiency can be increased. Reducing unburned carbon in the ash residue will not only increase boiler efficiency but also could improve salability of this byproduct to the cement industry. An outage is generally not required when implementing this technology, but coal-flow sensors and adjustable orifices are best installed when a mill is out of service. C-17 Process: “Intelligent” Combustion Controls Development Status: Commercially available. Many of the sensors, however, are relatively new and do not have a track record for reliability and dependability. Since each application of the technology is custom-engineered, there may be a steep learning curve for every user. For now, each installation also requires onsite presence (for a few weeks) from the supplier or other combustion expert to achieve best results. Practical Considerations: Boilers with the following design and operating characteristics are expected to be more suitable candidates for combustion monitoring and tuning: • Combustion equipment must be in good operating condition. The technology will not be able to overcome such factors as poor coal fineness or failure of burner parts. • Favorable cross-section/height profiles (e.g., tall boilers which provide for adequate mixing/residence time to maximize effectiveness). • Excess coal pulverizer capacity so that fuel biasing can be maximized. Of major importance is acceptance from boiler operators. If operators want to stick with old procedures and operating conditions, the effectiveness of the technology may not be realized. Compatibility with other air pollution control technologies: Combustion monitoring and tuning can be implemented with both Low NOx combustion approaches (e.g. LNBs) and post combustion technologies (SNCR/SCR). However, the overall NOx reductions are not strictly additive and careful evaluation is required to ensure cost effective strategies. Secondary Environmental Impacts: Combustion monitoring and tuning has the potential to affect both positive and negative secondary environmental impacts depending on factors such as the fuel, burner stoichiometries, boiler physical characteristics, etc. The following are potential impacts that must be analyzed on an individual unit basis • CO may increase due to stoichiometry in the burner zone • LOI may increase due to increased staging • ESP performance may degrade with increased LOI References: Power Plant Optimization Guidelines, EPRI Report, December 1998 Alternative Control Techniques Document: NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers. EPA Document No. EPA-453/R-94-022, July 1994. Alternative Control Techniques Document: NOx Emissions from Utility Boilers. EPA Document No. C-18 Process: “Intelligent” Combustion Controls EPA-453/R-94-023, July 1994. Fuller, T., “Field Experience with the Flame DoctorTM System”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003 Kohn, D. “Combustion Optimization Case Studies & Emerging Applications”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003 C-19 Category Cement Kilns Process Description: Process: Iron Slag Addition (CemStar) NOx, TPY (WRAP %NOx reduction Cost, $/ton 1996) 41,009 12-30% 0-100 Status Commercial Change cement formulation by adding waste iron to lower clinkering temperature and suppress NOx. The iron waste is usually supplied from local steel production facilities, which limits the technology to certain geographical areas. NOx Reduction: NOx reduction is achieved by reducing clinkering temperature as well as the required heat input to produce a ton of clinker. The technology reduces total NOx emissions by about 20 to 30%, and also may increase clinker production. Cost Information: Iron addition provides an overall economic benefit while reducing total NOx emissions. The technology is currently being used at several cement plants for its original purpose of increasing production capacity. There are no capital costs for installing the technology. Operating and maintenance costs depend on the cost of the iron (shipping can be a large portion of this cost). Development Status: Commercially available. Practical Considerations: There is a limit to how much iron that can be incorporated into the clinker. Cement product specifications may limit or prevent use of this technology for some products. Compatibility with other air pollution control technologies: Should not affect other control systems. Secondary Environmental Impacts: None expected. References: NESCAUM, “Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers, Internal Combustion Engines; Technologies and Cost Effectiveness.” December 2000. C-20 Category Cement Kilns Process Description: Process: NOx, TPY (WRAP 1996) 41,009 Kiln temperature control %NOx reduction Cost, $/ton 0 to 20% 200-500 Status Commercial Add temperature-monitoring device to kiln controls to minimize high-temperature excursions where more NOx is emitted. NOx Reduction: NOx reduction is achieved by measuring a characteristic flame-zone temperature and then controlling heat input to maintain that temperature. Without direct temperature measurement, temperatures fluctuate within a wide range since clinker formation is an exothermic reaction. When clinker formation slows down or stops, temperatures fall. Operators respond with a large burst of fuel that sends temperature up by as much as 500 °F. Then they back off the fuel input. Temperature measurement helps operators avoid losing clinker formation and thus maintain relatively steady kiln temperatures. Cost Information: Capital cost for the technology includes installation of a continuous temperature monitor along with control system upgrades to tie the temperature signal into the coal feed rate. Operating cost should not change unless lower temperatures adversely affect cement quality. Development Status: Commercially available. Practical Considerations: The dynamics of a cement kiln are very difficult to control, even with direct temperature measurement and control. Each kiln will react differently. It will require considerable operator experience to minimize the temperature on each kiln. Compatibility with other air pollution control technologies: Should not affect other control systems. Secondary Environmental Impacts: None expected. C-21 Process: Kiln temperature control References: U.S. Environmental Protection Agency. “Alternative Control Techniques Document: NOx Emissions from Cement Manufacturing.” EPA Document No. EPA-453/R-94-004, January 1994. Johnson, S.A. and Haythornthwaite, S., “Summary of Available NOx Control Techniques for the Cement Industry”, submitted to the Portland Cement Association, Skokie, IL, 1998. C-22 Category Reciprocating Engines Process Description: Process: Low-Emission Combustion (LEC) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton Status 86,210 80-90% 190-700 Commercial NOx formation from a spark-ignited engine is highest when the mixture is slightly fuel-lean. LEC enhances the effectiveness of the air/fuel ratio method by enabling much deeper leaning without the adverse effects associated with lean mixtures. Additional combustion air acts as a heat sink, lowering the temperature in the cylinder and reducing NOx formation. Deeper leaning can be achieved by relocating the spark plug to a precombustion chamber (may use High-Energy Ignition, see associated description) where the mixture is somewhat richer than in the cylinder. Early sparking avoids problems associated with ignition and misfiring that can result form leaning the mixture. Some smaller engines use an “open chamber” LEC design instead of a precombustion chamber. These designs typically incorporate improved air-fuel mixing systems to achieve stable combustion under very lean conditions. NOx Reduction: Large, stationary spark-ignition engines usually achieve 80% NOx reduction through a LEC Retrofit. A NOx emission level of 125 ppm (at 15% oxygen) is an achievable exhaust NOx value. Up to 90% reduction can be achieved in natural gas engines, and about 60-70% for landfill gas engines (probably due to lower initial NOx from the lower heating-value landfill gas). Engines with open-chamber LEC technology typically are designed for excess air levels only slightly above 50%, while engines with precombustion chambers typically are designed for excess air levels of 75-100%. Consequently, prechambered engines have generally lower NOx emissions than do openchamber models. Cost Information: The capital cost of retrofitting these engines depends on the engine BHP. For engines firing a single fuel, retrofits have been implemented costing $340/hp for 3400hp engines. A lower capital cost is expected for smaller, medium-speed engines, about $200/hp. Dual-fuel engines have much greater capital costs. For these engines (larger than 1,000 hp), the capital cost can be estimated by Capital Cost = $405,000 + ($450 x hp). Retrofitting a 2,500 hp engine is projected to cost $615/hp. Development Status: Commercially available The California Air Resources Board considers LEC Retrofit a Reasonably Available Control Technology (RACT) for large spark-ignition engines. LEC based on precombustion chamber technology has been in use for over 20 years. All major manufacturers of lean-burn spark ignition engines offer LEC-equipped models. Retrofit kits are also available. C-23 Process: Low-Emission Combustion (LEC) Practical Considerations: Available for spark-ignition engines fired with gaseous fuels including dual-fuel engines operating in dual-fuel mode (as opposed to firing only diesel fuel). LEC can cause some fuel efficiency decrease. A reasonable fuel efficiency penalty is estimated to be on the order of 0.5%. Turbocharging and intercooling are required to avoid derate. In retrofit situations, this typically involves upgrading or replacing the turbocharger and intercooler, or adding this equipment. Other equipment associated with increased air flows may also need to be modified for LEC, such as the air intake and filtration system, the intercooler radiator, and the exhaust system and muffler. To maintain the optimum A/F ratio, an automated A/F ratio controller typically is used. The challenge with very lean combustion is to achieve proper ignition and stable combustion. Vendors of LEC technology (i.e., engine manufacturers and third-party retrofitters) have met these requirements with some combination of improved combustion chamber design, enhanced air-fuel mixing, and improved ignition systems. Compatibility with other air pollution control technologies: Compatible with post-combustion NOx technologies (SCR, NSCR). However, the overall NOx reductions are not strictly additive and careful evaluation is required to ensure cost effective strategies. Secondary Environmental Impacts: Emissions of products of incomplete combustion can increase. References: Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. NESCAUM. “Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers, Internal Combustion Engines; Technologies and Cost Effectiveness.” December, 2000. State of California Air Resources Board. “CAPCOA/ARB Proposed Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Stationary Internal Combustion Engines (DRAFT).” Sacramento, CA, December, 1997. State of New Jersey Department of Environmental Protection. “State of the Art (SOTA) Manual for Reciprocating Internal Combustion Engines.” Trenton, NJ, July, 1997. U.S. Environmental Protection Agency. “Alternative Control Techniques Document – NOx Emissions from Stationary Reciprocating Internal Combustion Engines.” EPA-453/R-93-032, July, 1993. Cooper-Bessemer. Facsimile from J. W. Hibbard to W. Neuffer, U. S. EPA. Information on Low Emission Combustion. Cooper-Bessemer, Cooper Energy Services, Mount Vernon, OH. March 3, 1999. 4pp. Dresser-Rand. Facsimile from C. F. Willke to W. Neuffer, U. S. EPA. Information on Low Emission Combustion. Dresser-Rand Services, Painted Post, NY. May 7, 1999. 2pp. C-24 Category Coal-Fired Boilers Cement Kilns Oil/NG Boilers Glass Manufacturing Refinery Process Heaters Process Description: Process: Low-NOx Burners NOx, TPY (WRAP %NOx reduction Cost, $/ton 1996) 607,748 30 to 60% 200-1000 41,009 0 to 20% 500-1000 32,910 30 to 60% 200-1000 5,033 ~ 40% 790-1,680 30 to 60% 5,900 (with FGR) 9,311 Status Commercial Commercial Commercial Commercial Commercial LNB’s operate on the principal of carefully controlling the rate of mixing of air and fuel within the flame so that peak flame temperatures are low and fuel-bound nitrogen is released in a region where the concentration of oxygen is very low. This inhibits the formation of both fuel and thermal NOx by reducing the concentration of oxygen in the flame zone. Most LNB’s work by limiting the amount of air in the primary flame creating a central fuel-rich flame core. Additional air is introduced to surround the primary flame where the temperature is lower, limiting thermal NOx formation. A few low-NOx burners split the coal flow into two or more streams to create multiple fuel-rich regions. One Japanese burner concentrates the coal-primary air mixture, and introduces the dilute coal stream downstream of the burner while air is introduced only to the primary flame. The fuel introduced into the primary flame zone results in a high temperature fuel rich central flame. The balance of coal is added outside the primary flame where it burns at a lower temperature. NOx Reduction: Full load NOx reductions with Low-NOx Burners can be expected to range from 30% to 60% depending on factors such as: • Fuel type. • Initial NOx level. • Excess air • Operational flexibility of the boiler or furnace. For coal-fired boilers, NOx emissions rates as low as 0.15 lb/MBtu are achievable, particularly when burning low rank coals. However, the fuel nitrogen content of coal is such that significantly lower emission rates are probably not possible with coal. Lower emission rates can be achieved with natural gas. Installing Low-NOx burners is usually the first step taken to reduce NOx emissions. Cost Information: In general, the capital costs for burners range from $10,000 to 50,000 per burner plus installation. The lower end of this range applies when existing burners are modified instead of replaced to achieve lower NOx. Operating costs are negligible unless increased unburned carbon results in lost revenues from ash sales. An outage is generally required when implementing this technology, but coal-flow sensors and adjustable orifices are best installed when a mill is out of service. C-25 Process: Low-NOx Burners Development Status: Commercially available. Practical Considerations: Since low-NOx Burners usually produce longer flames, the size and shape of the furnace could cause problems for some installations. Flame impingement on sidewalls or rear wall can result in ash deposits, corrosion, or unacceptable unburned carbon in the flue gas. Most burners have optional configurations to shape the flame at the expense of less NOx reduction. Compatibility with other air pollution control technologies: Low-NOx burners can be implemented with other NOx-control technologies such as OFA, SNCR, or SCR. In general, the NOx reduction achieved with LNB make post-combustion NOx control technologies more cost-effective. Secondary Environmental Impacts: Low-NOx burners can cause both positive and negative secondary environmental impacts depending on factors such as the fuel, burner stoichiometries, boiler physical characteristics, etc. The following are potential impacts that must be analyzed on an individual unit basis • CO may increase due to stoichiometry in the burner zone • LOI may increase due to increased staging • ESP performance may degrade with increased LOI or finer particulate. References: EPRI, “Retrofit NOx Controls for Coal-Fired Utility Boilers – 2000 Update”, EPRI Final Report, December 2000 EPRI, “Retrofit NOx Controls for Coal-Fired Utility Boilers – 1996 Update Addendum”, May 1997 C-26 Category Cement Kilns Process Description: Process: Low-NOx Calciners NOx, TPY (WRAP %NOx reduction Cost, $/ton 1996) 41,009 30 to 50% 1000-5000 Status Commercial Replace the riser duct in existing preheater/precalciner kilns with new equipment designed for staged combustion. The new duct has separated air and fuel injection points, and extended residence time downstream of the final air addition point to assure acceptable burnout and minimize CO or hydrocarbon emissions. NOx Reduction: NOx reduction is achieved by creating two separate combustion zones. The burner zone is fired fuel-lean to create the high temperatures needed for clinker formation. Limestone calcination, which takes place at temperatures in the range of 1600 to 1800 °F, is accomplished in the second combustion zone in the tower. NOx reductions as high as 50% can be achieved by controlling the size of the fuel-rich region in the second combustion zone. Conversely, if combustion is fuel lean or well mixed in the second zone, NOx will not be reduced. The ideal stoichiometric ratio in the calciner is 0.7 to 0.8. Some systems do not perform well because the second combustion zone is too fuel-rich (SR < 0.6), causing significant NOx production when the staging air is added. Cost Information: Capital cost for the technology includes additional injectors, ductwork and controls. In some cases, the cyclones used to improve gas-solids contact are also replaced. Capital cost range from $500,000 and 5,000,000 depending on how much of the existing tower is replaced. Operating costs should not change unless cement quality degrades due to lower temperatures or locally reducing conditions. An outage is required to install the new equipment. Development Status: Commercially available. Practical Considerations: Space to fit the newer larger equipment may not be available in all kilns. Compatibility with other air pollution control technologies: Reducing conditions may increase sulfur emissions or require additional SO2 emission controls. Secondary Environmental Impacts: None expected. C-27 Process: Low-NOx Calciners References: Rother, R. and Kupper, D., “Staged Fuel Supply – An Effective Way of Reducing NOx Emissions”, Zement-Kalk-Gips, No. 9. 1989. C-28 Category Cement Kilns Process Description: Process: Mid-Kiln or Tower Tire Injection NOx, TPY (WRAP %NOx reduction Cost, $/ton Status 1996) 41,009 15-30% 0-1000 Commercial Cement kilns are normally fired with a single open-pipe burner fueled by coal or natural gas. However, a portion of the main fuel may be replaced by a waste fuel injected in the mid-kiln region of long, wet or dry kilns, or in the calcining region of tower kilns. Special injectors have been designed to time the introduction of two to four tires into the mid-kiln region as the kiln rotates. Due to rotation, tires can only fall into the kiln once per revolution when the door is on top. Alternately, tires can be dropped into the tower where temperatures are high enough to support combustion. Mid-kiln tire injection is attractive because it not only reduces NOx but also generates revenue in the form of tipping fees and reduced fuel requirements. Cadence Environmental Energy, a subsidiary of Ash Grove Cement, offers an automated whole-tire injection system, including a fork that picks up the tires and drops them into the kiln through a gate assembly. A second option is to set up a tire shredding operation on site and inject tire flake into the kiln. NOx Reduction: NOx is lowered by burning some of the fuel at a lower temperature, and by creating pockets of fuel-rich gas as the tires decompose. Hydrocarbons from tire destruction can reduce NOx formed in the burner flame. Results to date have varied from 15 to 30% NOx reduction, depending on: • Kiln type. • Number of tires injected. • Injection temperature. In some installations, a booster fan has been mounted on the kiln downstream of the tire injection point to provide additional burnout air. This “NOx fan” gets rid of the high CO or smoke emissions caused by the tires, and may allow operation at higher tire injection rates. Cost Information: The capital costs for installing a mid-kiln tire injection system are about $2 to 4M. Operating and maintenance costs should not be affected. Often the installation of this technology is driven by the tipping fee revenue generation. If this is possible, injector costs can be recovered within a few years. An outage is required when implementing this technology, but downtime can be minimized at sites where space is sufficient for installing the injection system ahead of time (without getting in the way of kiln operation). Development Status: Commercially available. C-29 Process: Mid-Kiln or Tower Tire Injection Practical Considerations: The main purpose of a cement kiln is to produce as much high-quality clinker as possible at the lowest energy cost. Over-feeding tires creates locally reducing conditions that cause smoke, soot, and spoil the naturally occurring sulfur capture in the clinker resulting in higher SO2 emissions. The practical limit on tire injection is replacement of about 10 to 30% of the fuel, depending on the kiln design. Also, since tires are injected every two minutes, the NOx emissions rise and fall erratically, making control very difficult. Compatibility with other air pollution control technologies: High airflows from the NOx fans can cause increased carryover of cement kiln dust (CKD) into the exhaust. Reducing conditions in the flame zone increase SO2 emissions. Secondary Environmental Impacts: Combustion monitoring and tuning has the potential to effect both positive and negative secondary environmental impacts depending on factors such as the fuel, burner air-fuel ratio, kiln design, etc. The following are potential impacts that must be analyzed on an individual unit basis • CO, hydrocarbons and soot emissions may increase due to tire byproducts escaping the secondary combustion zone. • SO2 may increase due to increased staging. • ESP performance may degrade with increased CKD. References: U.S. Environmental Protection Agency, “Alternative Control Techniques Document: NOx Emissions from Cement Manufacturing.” EPA Document No. EPA-453/R-94-004, January 1994. “Stick a Fork in It”. Product Brochure from Cadence Inc., 1997. C-30 Process: Non-Selective Catalytic Reduction (NSCR) NOx, TPY (WRAP %NOx 1996) reduction Cost, $/ton Status Category IC Engines, rich-burn only 111,488 40-98% < 500 Commercial Process Description: In NSCR, the engine exhaust is routed to a catalyst bed across which NOx is reduced to nitrogen gas. At the same time, VOC and carbon monoxide are oxidized to water and carbon dioxide. Because the catalyst reduces emissions all three of these pollutants, NSCR is often referred to as a “three-way catalyst” system. These systems are similar to the catalytic converters used on automobiles. For an NSCR system to operate optimally (i.e., to minimize NOx emissions), the inlet exhaust stream must have very low oxygen content, as well as proper concentrations of NOx, hydrocarbons, and carbon monoxide. This requires initial engine adjustments, followed by careful monitoring of oxygen content in the exhaust. For this reason, an automatic air-fuel (A/F) ratio controller typically is used to regulate the exhaust oxygen content entering the catalyst bed. The controller adjusts the A/F ratio based on input from an oxygen sensor upstream from the catalyst bed. Because of the requirement for low oxygen content, NSCR systems are limited to rich-burn SI engines. NOx Reduction: This source indicates that these catalyst systems reduce NOX emissions by over 98 percent, while reducing VOC by 80 percent and carbon monoxide by over 97 percent. NOx levels in the range of 0.1 to 1.0 g/bhp-hr have been achieved. Cost Information: Capital cost for NSCR includes the catalyst as well as the addition of oxygen sensors and controls. Catalyst replacement generally occurs after about 20,000 hours of operation. Development Status: Commercial. Information from vendors of NSCR systems indicates that NSCR three-way catalysts have been installed on over 1,000 IC engines in the United States and have been in use for over 10 years. . Practical Considerations: The engine adjustments required to optimize NSCR systems typically reduce the efficiency of the engine, harming fuel economy. The biggest operational problem associated with NSCR has been damage to the catalyst caused by excessive temperature. This is caused when the exhaust stream is too fuel rich. In this situation, the uncombusted natural gas is rapidly oxidized in the catalyst bed, burning it out. At about 1,300 oF, the catalyst sustains damage. Compatibility with other air pollution control technologies: Enhanced removal of CO and VOC can be achieved. C-31 Process: Non-Selective Catalytic Reduction (NSCR) Secondary Environmental Impacts: None expected. References: Manufacturers of Emission Controls Association. “Emission Control Technology for Stationary Internal Combustion Engines.” Status Report, July 1997. Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. C-32 Process: NOxTech Category Reciprocating Engines Process Description: NOx, TPY (WRAP 1996>100 TPY) 86,210 %NOx reduction Cost, $/ton 90-95% ~ 1000 Status Commercial According to product literature, the NOxTech® emission control system, developed by NOxTech Inc., NOxTech is an automated system in which exhaust gases are chemically treated with a nonhazardous liquid chemical. The technology involves replacing the engine exhaust silencer with a reaction chamber where NOx and reagent react to form nitrogen, water vapor, and carbon dioxide. The non-catalytic chemical reagent is injected into the exhaust at temperatures between 1,400 and 1,500 °F. NOx Reduction: The vendor states that NOxTech has been proven to remove 90-95% of NOx, as seen in the 4,000-bhp diesel-powered generator on Catalina Island. Cost Information: Based on vendor literature, self-sustained, gas-phase autocatalysis reduces emissions of NOx are reduced at costs as low as $1,000/ ton. Development Status: Commercially available As of August 2000, the system has been installed and is operating on several diesel generators in California. Based on commercial performance in these engines, NOxTech has been demonstrated as BACT for some diesel engines. Practical Considerations: The exhaust gas must be heated to achieve the temperatures necessary for the NOxTech system reactions. A heat exchanger should be placed downstream from the reactor to reclaim and reuse this heat energy. Compatibility with other air pollution control technologies: Compatible with low-NOx combustion approaches (LNB, combustion modification). Can be used to augment LEC. Secondary Environmental Impacts: Technology also potentially removes 60-80% of particulate matter, 90% of VOC, and 50-70% of carbon monoxide from the exhaust, as seen in the 4,000-bhp diesel-powered generator on Catalina Island. The process produces trace ammonia emissions of less than 2 to 5 ppmv. C-33 Process: NOxTech References: Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. NOxTech Inc. “NOxTech® Technology.” website. www.noxtechinc.com/products.htm. NOxTech Inc. Letter and attachments from E. Cazzola to Mary Jo Krolewsky, U. S. EPA Acid Rain Division. April 12, 1999. C-34 Category Coal-fired boilers Oil/NG boilers Wood/Biomass boilers Process Description: Process: Overfire Air (OFA) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton 607,748 20-40% 250-600 32,910 40-80% 1,000-2,000 9,776 20-60% 200-2,000 Status Commercial Commercial OFA, like LNB’s, represents practical approaches to minimizing the formation of NOx during combustion. Simply, this is accomplished by "controlling" the quantities and the way in which fuel and air are introduced and mixed in the boiler (referred to as staging). In the case of OFA, the approach consists of diverting some of the combustion air (typically up to about 30%) to dedicated injection nozzles (called OFA ports) located some distance above the burner or main combustion zone. Variations include the design and location of the OFA ports, the supply of air to the OFA (either directly from the windbox, or from a dedicated booster fan). NOx Reduction: OFA, which can be used separately or as a system with LNBs, is capable of NOx reductions of 20% - 40% from uncontrolled levels, when used alone. The type of boiler (e.g., dry vs. wet-bottom, wall- vs. tangential-fired, NSPS vs. pre-NSPS, etc.) and the type of fuel will influence the actual performance achieved. Cost Information: OFA technologies have little or no impact on operating costs (other than the potential for an increase in unburned carbon - efficiency loss -, and the resulting impact on ash disposal options). Retrofit costs are site-specific. As such, the economics of these technologies are driven by capital/retrofit costs which typically range from $5-$10/kW, with the lower range reflecting easier application whereas the higher costs are typically associated with more difficult and involved retrofits. From a schedule standpoint, OFA retrofit projects can require outages of 3 – 6 weeks, depending on factors such as scope of work, integration with other plant outage requirements, etc. Development Status: Commercial OFA and LNB’s are the most prevalent in the power industry at present. Plants that have had to comply with Title IV of the CAAA of 1992 have largely used these technologies for compliance. Competing manufacturers have proprietary designs, geared towards application in different boiler types, as well as reflecting their own design philosophies. Practical Considerations: Boilers with the following design and operating characteristics are expected to be more suitable candidates for OFA applications: • firing lower-sulfur fuels (e.g., less propensity for waterwall corrosion) • low baseline unburned carbon (e.g., to minimize ash salability impacts). C-35 Process: Overfire Air (OFA) • • favorable cross-section/height profiles (e.g., tall boilers which provide for adequate mixing/residence time to maximize effectiveness). units with existing burners in good operating condition, • Potential O&M impacts due to combustion NOx controls include: • Change in optimum excess air level: 0.5-1.5 percentage points increase in excess O2 is possible • 3-5 percentage points increase in LOI is possible; in general, as higher NOx reduction is being sought, the higher the probability for increased LOI (NOx vs. LOI trade-off) • Changes in reheat and superheat steam temperatures (typically lower by 20-50 degrees F) are possible in some applications. Compatibility with other air pollution control technologies: OFA technologies are often used in conjunction with LNB’s. As a main combustion based NOx control approach, OFA is fully compatible with other NOx controls including LNB’s, reburning (OFA is an integral component of reburning), as well as the post combustion technologies such as SNCR and SCR Secondary Environmental Impacts: OFA, like all combustion modification approaches face a common challenge: that of "striking a balance" between NOx reduction and fuel efficiency. The concern is exemplified by the typically higher carbon levels in the fly ash, which reflect lower combustion efficiency but also the contamination of the fly ash itself possibly making it unsuitable for reutilization (e.g., cement industry). References: EPRI, “Retrofit NOx Control Guidelines for Gas- and Oil-Fired Boilers”, Final Report, December 1993. EPRI, “Retrofit NOx Controls for Coal-Fired Utility Boilers – 1996 Update Addendum”, May 1997. EPRI, “Retrofit NOx Controls for Coal-Fired Utility Boilers – 2000 Update”, EPRI Final Report, December 2000 C-36 Category Glass Manufacturing Process Description: Process: Oxy-Fuel Firing NOx, TPY (WRAP %NOx 1996) reduction Cost, $/ton 5,033 80-85% 2,150-4,400 Status Commercial Oxy-fuel melting involves the replacement of the combustion air with oxygen (>90% purity). The technique can be used with either natural gas or oil as the fuel, although the use of gas is more common. The elimination of the majority of the nitrogen form the combustion atmosphere reduces the volume of the waste gases (composed mainly of CO2 and water vapor) by 70-85 % depending on oxygen purity. In general, oxy-fuel furnaces have the same basic design as recuperative melters, with multiple lateral burners and a single waste gas exhaust port. In the most modern furnaces the geometry is optimized for oxy-fuel firing and minimization. Furnaces designed for oxygen combustion do not currently utilize heat recovery systems to pre-heat the oxygen supply to the burners, due to safety concerns; however, the technique potentially involves substantial energy savings because it is not necessary to heat the atmospheric nitrogen to the temperature of the flames. The formation of thermal NOx is greatly reduced because the main source of nitrogen in the furnace is much lower. NOx Reduction: Compared to air-fuel fired furnaces, NOx emissions are generally reduced by 70-90%. This reduction equates to: • <1 kg/ton glass for fiber and container glass furnaces • 1-2 kg/ton glass for special glass (without nitrate addition) The latest versions of oxy-fuel burners combined with optimized furnace design and operation can in some cases reduce emissions to 0.3-0.8 kg NOx/ton of glass melted. No information is available for emissions from flat glass production, but emissions of 0.5 to 1.5 kg/ton of glass melted are considered likely. Cost Information: In general, capital costs for oxy-fuel firing are $1,930K-$9,810K. An important factor in the capital cost is that oxy-fuel furnaces do not have a conventional combustion gas preheat system and so the capital cost is generally lower than for a regenerative or recuperative furnace of comparable pull-rate. In most applications, the determining factor regarding cost effectiveness of oxy-fuel firing will be the difference between the energy savings and the costs of the oxygen compared with the costs of alternative NO abatement techniques. Development Status: Commercially available It is estimated that 5-10% of the world’s glass production is made with oxy-fuel melting, but this figure varies between the sectors. There are several examples of oxy-fuel furnaces operating successfully in the following sectors: container glass, glass wool, special glass (particularly TV glass), continuous filament glass fiber, and frits. Trials have been carried out in the domestic glass sector resulting in good NOx reduction, but problems occurred with severe foaming. The problems encountered in domestic glass production are similar to those initially encountered in other applications e.g. container glass. Similar C-37 Process: Oxy-Fuel Firing solutions are likely to be possible but the higher quality requirements make them more difficult to apply. There are several examples of the technique operating successfully for domestic glass production worldwide. Considerable development work is being undertaken and the number of plants and the level of operating experience are increasing. Practical Considerations: The merits of oxy-fuel firing vary greatly from case to case depending on furnace size and availability of pure oxygen. The technique is most effectively installed during furnace rebuild. Hot installation may lead to energy savings and to an increased pull rate; however, it is unlikely to result in lower NOx emissions, and there is a danger of accelerated refractory wear. Furnace waste-gas temperature can be very high, 1200-1300 °C and will usually require cooling. Due to high water content and concentration of corrosive species, cooling is usually by dilution with air. The higher temperatures associated with the technique can result in higher refractory wear. Oxygen required for combustion can be supplied either by delivery to the site or by on-site production. Except for very small applications, the amounts of oxygen required usually make it more economical to produce the oxygen on-site. Compatibility with other air pollution control technologies: Addition of a cullet preheating system, which can also reduce NOx and other emissions by reducing the amount of fuel required, can add to the energy savings of oxy-fuel firing by recovering heat from the waste gases. See cullet preheating description. Secondary Environmental Impacts: Oxy-fuel firing can also help to reduce overall emissions of volatile materials form the furnace (particulates, fluorides, chlorides etc.), due to reduces gas flow over the melt and in some cases reduced turbulence. • Particulate emissions in soda-lime glass can be reduced to 0.2-0.3 kg/ton. • Particulate emissions most effectively reduced for boron containing glasses (up to 50%). • Reduction in fuel usage leads to lower SO2 emissions for oil-fired furnaces. Concentrations of all pollutants may actually be higher due to reduced gas volume, although the absolute emission is reduced. Dilution with cooling air usually brings the concentrations closer to more normal levels. References: European IPPC Bureau. “Reference Document on Best Available Techniques in the Glass Manufacturing Industry.” Seville, Spain, October, 2000. C-38 Category Coal-fired Boilers Cement kilns Process Description: Process: Oxygen-Enhanced Combustion Modifications NOx, TPY (WRAP %NOx 1996) reduction Cost, $/ton Status 607,748 30 to 80% 1,000-2,000 Near Commercial 0-20% 100-1000 41,009 Commercial In coal-fired boilers, O2 injection is used to improve effectiveness of OFA operation. Small amounts of oxygen are introduced into the burner zone through specially designed lances. The added O2 creates a local hot spot that increases the rate of coal volatile release, encourages more NOx reduction, and enables more fuel-rich operation where less NOx is formed. The technology has been demonstrated on a 44-MW coal-fired boiler. In cement kilns, oxygen lances are used to create a hot spot in the flame zone and achieve higher kiln throughput (increase clinker production). In doing so, NOx is not reduced but NOx emission rates (lb. NOx/ton of clinker) goes down in proportion to the increase in production. O2 injection achieves even higher production when cement kiln dust (CKD) is co-injected. The CKD also quenches peak flame temperature to achieve some reduction in thermal NOx formation. NOx Reduction: In the coal-fired boiler demonstration, conventional OFA reduced NOx to around 0.35 to 0.40 lb./MBtu. O2 injection lowered the NOx further to around 0.22 to 0.25 lb./MBtu, while also decreasing LOI and opacity, and allowing better steam temperature control when firing bituminous coal. NOx reductions down to 0.16-0.19 lb./MBtu were achieved when the unit switched to a blend of 90% sub-bituminous and 10% bituminous coal. In the cement industry, oxygen injection has achieved 0 to 20% NOx reduction in conjunction with a 05% kiln capacity increase. Increased capacity (when it occurs) is the primary cause of the NOx reduction. Cost Information: The primary cost of all these applications of oxygen-enhanced combustion is the cost of the oxygen. Oxygen required for combustion can be supplied either by delivery to the site or by on-site production. Except for very small applications, the amounts of oxygen required usually make it more economical to produce the oxygen on-site. Capital cost for oxygen storage and delivery systems range from $100,000 when pipeline gas is used, to $1,500,000 when on-site storage is required. In general, capital costs are $1,930K-9,810K when on-site generation is chosen. An important factor for the capital cost of oxy-fuel firing is that oxy-fuel furnaces do not have a conventional combustion gas preheat system and so the capital cost is generally lower than for a regenerative or recuperative furnace of comparable pull-rate. In most applications, the determining factor regarding cost effectiveness of oxy-fuel firing will be the difference between the energy savings and the costs of the oxygen compared with the costs of alternative NOx abatement techniques. C-39 Process: Oxygen-Enhanced Combustion Modifications Development Status: The coal-fired boiler technology needs to be demonstrated over several months to show effectiveness, reliability, and safety. Such a demonstration is expected to begin during the summer of 2003. The technologies are commercially available for application to cement and glass manufacturing. Practical Considerations: Using oxygen enrichment results in less flue gas flow since it eliminates the nitrogen in the air it replaces. The merits of oxy-fuel firing vary greatly from case to case depending on furnace size and availability of pure oxygen. The technique is most effectively installed during furnace rebuild. Hot installation may lead to energy savings and to an increased pull rate; however, it is unlikely to result in lower NOx emissions, and there is a danger of accelerated refractory wear. Furnace waste-gas temperature can be very high, 1200-1300 °C and will usually require cooling. Due to high water content and concentration of corrosive species, cooling is usually by dilution with air. The higher temperatures associated with the technique can result in higher refractory wear. Many potential users do not want to own and operate an air-separation plant. Oxygen suppliers offer to build, own, and operate the air separation system in return for a long term contract for oxygen sales. Compatibility with other air pollution control technologies: Oxygen-enhanced combustion on coal-fired boilers can only be effective when implemented with OFA. If O2 is added to an unstaged flame, NOx emissions will increase. The technology can also be combined with SNCR or SCR for greater NOx reductions. O2 can also be used with post-combustion NOx control technologies in cement kilns and glass melters. Secondary Environmental Impacts: Oxygen-enhanced combustion may lessen the impacts of staged combustion. The following are potential impacts that must be analyzed on an individual unit basis: • CO may increase due to stoichiometry in the burner zone • LOI may increase due to increased staging • ESP performance may degrade with increased LOI or finer particulate. Oxy-fuel firing can also help to reduce overall emissions of volatile materials from the kiln or furnace (particulates, fluorides, chlorides etc.), due to reduced gas flow and in some cases reduced turbulence. • • • Particulate emissions in soda-lime glass can be reduced to 0.2-0.3 kg/ton. Particulate emissions most effectively reduced for boron containing glasses (up to 50%). Reduction in fuel usage leads to lower SO2 emissions for oil-fired furnaces. Concentrations of all pollutants may actually be higher due to reduced gas volume, although the absolute emission is reduced. Dilution with cooling air usually brings the concentrations closer to more normal levels. References: U.S. Environmental Protection Agency, “Alternative Control Techniques Document: NOx Emissions from C-40 Process: Oxygen-Enhanced Combustion Modifications Utility Boilers”. EPA Document No. EPA-453/R-94-023, July 1994. Bool, L., “NOx Reduction from a 44MW Wall-Fired Boiler Utilizing Oxygen-enhanced Combustion”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003 C-41 Category Reciprocating Engines Process Description: Process: Pre-Stratified Charge NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton 86,210 80-95% <500 Status Commercial Air is injected into the intake manifold so that during the intake stroke, the piston initially draws in air, followed by a fuel-rich air-fuel mixture. Thus, the mixture near the spark plug is fuel rich, promoting good combustion, while the mixture away form the spark plug is very lean, acting a s a heat sink and suppressing NOx formation. NOx Reduction: From tests for ten engine models ranging from 100 to 800 bhp, NOx emissions ranged from about 0.1 g/bhp-hr to 9.5 g/bhp-hr, with a mean of 0.6 g/bhp-hr. Engines ranging from 300 to 800 bhp averaged 95% reduction, while tests on engines less than 50 bhp showed NOx reductions averaging 77%. Vendors guarantee the achievable NOx emission level of 2.0 g/bhp-hr. Cost Information: See EPA Report below. Development Status: Commercially available. In commercial use since 1980s. Practical Considerations: Applicable only to carbureted (i.e. non-fuel-injected) rich-burn engines. May cause some power derating; 20% has been observed. While the PSC system itself requires very little maintenance, the engines require more frequent overall maintenance. Compatibility with other air pollution control technologies: Compatible with exhaust gas recirculation (EGR), with air injected by PSC system coming form the engine’s exhaust. May also be used in conjunction with post-combustion technologies. However, the overall NOx reductions are not strictly additive and careful evaluation is required to ensure cost effective strategies. Secondary Environmental Impacts: Possible increase in CO and VOC emissions. References: Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. C-42 Category Reciprocating Engines Oil/NG boilers Turbines Process Description: Process: SCONOx Technology NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton 86,210 95% Not available 32,910 70-99% Not available 25,278 >90% >7,000 Status Commercial Commercial Commercial The SCONOx system adds a chemical reactor for NOx sorption using a catalyst/sorbent to remove NOx, carbon monoxide, and VOC. NOx is oxidized in the presence of a platinum-based catalyst and the resulting NO2 is adsorbed onto a potassium carbonate sorbent, forming potassium nitrites. The sorbent must be regenerated periodically by passing a controlled mixture of regeneration gases across its surface in the absence of oxygen. Regeneration gases react with the nitrites to form water and elemental nitrogen. The system is installed as a bed of sorbent/catalyst. A system of louvers and piping allows portions of the bed to oxidize and adsorb pollutants and other portions of the bed to undergo regeneration. NOx Reduction: The first commercial installation in gas turbines achieved NOx emissions below 2 ppm, a reduction of over 90%. Vendor testing shows SCONOx reduced NOx emissions in natural gas-fired reciprocating engines up to 95%. Preliminary testing in diesel engines found the technology reduced NOx by 98.9% to 0.4 g/bhp-hr. Cost Information: Cost for Gas Turbine application is preliminary and from DOE reference below. Development Status: Commercially available First commercial installations in gas turbines commenced in 1999. Commercial applications for natural gas-fired reciprocating engines went online in 2000. Diesel applications were sold in 2000, but further information is unavailable. Practical Considerations: The technology was initially applied only to gas turbines, but variations have been developed for naturalgas and diesel-fired reciprocating engines. Regeneration gas flow is about 1 percent of exhaust gas flow. Typically, natural gas is converted to hydrogen in a reformer at 600-900 °F to produce the regeneration gas. The regeneration step is complicated and the reformer requires additional labor and maintenance. Exhaust temperatures should be controlled at 600-700 °F for best NOx reduction. Performance also improves as exhaust gas oxygen levels approach zero. Temperature and O2 control may be difficult at some sites. The catalyst is de-activated by soot or sulfur species, so catalyst must be cleaned every 20,000 hours. C-43 Process: SCONOx Technology SCOSOx is required to remove SO2, which would otherwise poison the SCONOx catalyst. SCOSOx requires regeneration similar to SCONOx. Compatibility with other air pollution control technologies: Due to the emerging nature of the technology, little is discussed about compatibility with other technologies. Based on tests with LEC engines, issues regarding increases in CO/VOC may be of concern Secondary Environmental Impacts: Carbon monoxide and VOC are also reduced up to 95%. References: Edgerton, S. W., Lee-Greco, J., and Walsh, S. “Stationary Reciprocating Internal Combustion Engines Updated Information on NOx Emissions and Control Techniques (Final Report).” EPA contract No. 68D98-026, EC/R Incorporated, Chapel Hill, NC, August 29, 2000. Amar, K.P., Staudt, J. “Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers, Internal Combustion Engines; Technologies and Cost Effectiveness.” Northeast States for Coordinated Air Use Management, Boston, MA, January, 2001. Goal Line Environmental Technology News. “Cummins Engine Co. Tests SCONOx® for Diesel IC Engines.” Oct 1999. Vol 1, Issue 3. C-44 Category Coal-fired boilers Reciprocating Engines Oil/NG boilers Turbines Refinery Process Heaters Glass Melters Process Description: Process: Selective Catalytic Reduction (SCR) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton Status 607,748 70-90% 1,500-2,000 Commercial 86,210 75-90% <1,000 Commercial 32,910 70-90% 2,000-10,000 Commercial 25,278 ~90% 500-10,000 Commercial 9,311 75-90% 3,700-11,000 Commercial 5,033 75-90% --Commercial Post-combustion NOx controls include Selective Non-Catalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR). They are fundamentally similar, in that both use an ammonia-containing reagent to react with the NOx produced in the boiler, and convert it to harmless nitrogen and water, SNCR accomplishes this at higher temperatures (1700ºF-2000ºF) in the upper furnace region of the boiler, while SCR operates at lower temperatures (about 600ºF to 750°F) and hence needs a catalyst to produce the desired reaction between ammonia and NOx. High temperature catalysts, sometimes used in gas turbine applications can operate at temperatures up to ~1100°F Conventional SCR incorporates a reactor located typically between the economizer and the air preheater. The reactor housing is sized to provide optimum flue gas velocity and catalyst volume. In about one-quarter to one-third of the German SCR installations, the SCR reactor is located downstream of the flue gas desulfurization (FGD) system. This is called a “tail-end” configuration. Because the catalyst operates at temperatures of at least 600+°F, the flue gas temperature needs to be increased between the FGD and tail-end SCR. This reheating the flue gas before it enters the SCR. This extra equipment makes the capital and energy costs higher than in a conventional SCR. On the other hand, the tail-end SCR uses less catalyst, experiences a longer catalyst life, and can be built without impacting plant operations, with tie-in typically occurring during a normal two-week outage. An ammonia injection system is located upstream of the catalyst typically in a grid configuration to inject and disperse the ammonia uniformly into the flue gas. NOx Reduction: NOx reductions of 90+% are capable with SCR. NOx reduction levels are typically limited by the need to control residual ammonia to low levels (2-5ppm), and by cost effectiveness considerations (higher costto-NOx reduction ratio for deeper reductions. SCR applications typically represent a balance between the percentage NOx reduction requirement, residual ammonia limit, SO2 to SO3 oxidation rate, and ability to continuously maintain a uniform, stable NH3/NOx distribution across the entry plane into the catalyst. Cost Information: Capital costs for retrofit SCR systems to power generation sources are mostly within the range of $60/kW to about $140/kW. The lower end of this range applies to retrofits with nominal difficulty. The high end of the range would typically be associated with retrofits having significantly impeded construction access, extensive relocations, and difficult ductwork transitions. C-45 Process: Selective Catalytic Reduction (SCR) Operating costs are mainly driven by cost of reagent, energy penalty (pressure loss, ammonia vaporization), catalyst replacement and dedicated O&M costs Development Status: Commercially available SCR is widely used oversees (Germany and Japan represent over 50,000 MW of installed capacity. In the US, significant activity has recently occurred with SCR installations on coal fired units. Projections for over 100 new installations in the US in the next 5 years have been made. Practical Considerations: From a technical perspective, SCR can be used many different applications and sources. However, the cost can vary considerably depending on retrofit difficulty and plant layout, fuel, or unit operating characteristics. The performance of an SCR system is dependent on the size and arrangement of the catalysts, the fuel burned, gas flow conditions at the catalyst entrance, and the type and amounts of reagent used. A number of factors should be considered when installing an SCR system. They include: • Operating temperature window temperature which is a function of the catalyst formulation but typically ranges between 600°-750°F for sulfur bearing fuels, • Ammonia injection system design to ensure good distribution in proportion to the mass flux of NOx for optimized performance (maximum NOx reduction and minimum NH3 slip) • Flue gas pressure drop which is dependent upon flue gas velocity, catalyst configuration, and quantity of catalyst required to achieve specified NOx reduction • Flue gas flow/temperature distribution, as catalyst guarantees are typically predicated upon predetermined conditions • Fouling potential of catalyst and/or APH surfaces. Reaction of excess ammonia with SO3 generated in the furnace when firing sulfur bearing fuels will form ammonium bisulfate/sulfate that deposits on the cold end sections of the air heater to cause corrosion and increased pressure drop • Flue gas contaminants - alkaline compounds, halogens, and heavy metals can cause catalyst poisoning. • Decreased heat rate at low load if economizer bypass is needed to maintain the required flue gas temperature in the SCR reactor. Compatibility with other air pollution control technologies: SCR applications are fully compatible with combustion NOx controls (LNBs, OFA, reburn, etc.) and can be used with other amine-based controls (e.g. SNCR) in hybrid configurations. In theory, most of these technologies can be used together. However, NOx reductions are not necessarily additive, and more importantly, the “economics” of the combined technologies may or may not be cost-effective. Such analyses are highly site- and strategy-specific. However, several such combinations of technology are considered attractive and have or are gaining acceptance. For example, the combination of LNB/OFA with either SCR or SNCR is more prevalent than the application of the post-combustion technologies alone. The economics of this approach are justified by the reduced chemical and capital costs due to lower NOx levels entering the SCR system. C-46 Process: Selective Catalytic Reduction (SCR) When combining SCR with NOx control technologies whose performance depends on mixing characteristics in the upper furnace (i.e., OFA, reburn, or SNCR), potential stratification of inlet NOx levels to the SCR becomes a key design issue that can impact SCR performance. Secondary Environmental Impacts: Potential impacts arising from the application of SCR include: • • • • • Increased corrosion downstream of the SCR from SO3 formed on the catalysts Air heater fouling due to ammonia bisulfate formation in the cold end Ammonia contamination of fly ash affecting its salability or disposal Increased system pressure drop FGD waste management, if located downstream of SCR These impacts are mostly relevant to applications with sulfur and other contaminants-bearing fuels (e.g. coal/oil). Applications with natural gas are more benign both with respect to catalyst choice and life, as well as other plant impacts. References: EPRI, “Retrofit NOx Controls for Coal-Fired Utility Boilers – 2000 Update”, EPRI Final Report, December 2000 NESCAUM, “Status Report on NOx Control Technologies and Cost Effectiveness for Utility Boilers”, June 1998. Cichanowicz, J., “100 GW of SCR: Installation Status and Implications of Operating Performance on Compliance Strategies”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003 McIlvaine, R., “SCR Operating Experience of German Power Plant Owners as Applied to Challenging US High Sulfur Service”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003 C-47 Process: Selective Non-Catalytic Reduction (SNCR) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton Status Category Coal-fired boilers 607,748 25-50% 800-1,500 Commercial Cement Kilns 41,009 30-70% 200-1,000 Commercial Oil/NG boilers 32,910 30-60% 1,300-3,000 Commercial Wood/Biomass boilers 9,776 40-80% 900-2,200 Commercial Refinery Process Heaters 9,311 50-70% 1,200-2,700 Commercial Glass Melters 5,033 ~40% --Commercial Process Description: Post-combustion NOx controls include Selective Non-Catalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR). They are fundamentally similar, in that both use an ammonia-containing reagent to react with the NOx produced in the boiler, and convert it to harmless nitrogen and water, SNCR accomplishes this at higher temperatures (1700ºF-2100ºF) in the upper furnace region of the boiler, while SCR operates at lower temperatures (about 600ºF to 750°F) and hence needs a catalyst to produce the desired reaction between ammonia and NOx. While this difference between the two technologies may seem minor, it yields significant difference in performance and costs. This is because in the case of SNCR, the reaction occurs in a somewhat uncontrolled fashion (e.g., the existing upper furnace becomes the “reactor”). In practice, this means that SNCR has lower capital costs (no need for a reactor/catalyst); higher operating costs (lower efficiency means that more reagent is needed to accomplish a given reduction in NOx); and limited NOx reduction capability (typically 30%-40%, with some cases achieving reductions in the 50% range). With SNCR, the reagent is introduced directly into the upper furnace, within the temperature window above. Typical applications may include multiple injection nozzles at various elevations (temperature points). in the furnace to optimize the distribution of reagent as well as to allow for operation at various load points. NOx Reduction: SNCR technology is typically capable of NOx reductions in the range of 25% to 80% depending on many design and operating characteristics of the specific application. Cost Information: Capital cots range from $10 to $20/kW for power generation boilers. Operating costs are driven primarily by the consumption of the chemical reagent – usually urea for SNCR - which in turn is dependent upon the efficiency of the as well as the initial NOx level and the desired percent reduction. These are typically in the range of $500-$700/ton of NOx. An additional consideration important in the overall operating costs is the potential contamination of fly ash by ammonia making it potentially unsalable. Development Status: Commercial SNCR is a fully commercial technology widely employed in various industries and applications. Ureabased applications are the predominant approach, as urea seems to have several advantages over ammonia in large-scale applications. C-48 Process: Selective Non-Catalytic Reduction (SNCR) Practical Considerations: SNCR applications must be considered on a site –specific basis as several design and operating characteristics will affect the suitability of the technology. Some key issues include • Available temperature window • Size (cross-section/height) of the furnace for appropriate distribution and mixing of the reagent • Sulfur content of the fuel (SO3 and NH3 form ammonium salts which can have negative impacts on the downstream equipment) • Operational profile of the unit (rapid swings in flows/temperatures often result in poor performance in terms of NOx reduction and ammonia slip) Compatibility with other air pollution control technologies: SNCR applications are compatible with combustion NOx controls (LNBs, OFA, reburn, etc.) and can be used with other amine-based controls (e.g. SCR) in hybrid configurations. In theory, most of these technologies can be used together. However, NOx reductions are not necessarily additive, and more importantly, the “economics” of the combined technologies may or may not be cost-effective. Such analyses are highly site- and strategy-specific. The application of SNCR with reburn has yielded several developments by different companies. Various approaches are available commercially. Essentially they all revolve around the ability to combine the injection the reburn fuel and the amine reagent in the upper furnace region. NOx reductions are not additive but better than the individual technology. While these combined approaches have not gained extensive commercial deployment reductions of 60%-70% have been reported. Economic effectiveness needs to be properly addressed on an individual basis as both the cost of reagent and reburn fuel contribute to the overall cost analyses Other variations of SNCR-based technology include the use of hydrocarbon injection to promote NH3 reduction reactions, as well as reagent injection into a fuel rich zone of the OFA system. These variations while offered commercially are still under demonstration Secondary Environmental Impacts: SNCR has some of the same issues associated with SCR. The two most likely to warrant consideration are • NH3 slip (emissions and impacts on ash) • Formation of nitrous oxide (N2O – a green house gas). This is mostly associated with urea, as opposed to ammonia, and may become a larger concern from the perspective of global climate issues References: NESCAUM, “Status Report on NOx Control Technologies and Cost Effectiveness for Utility Boilers”, June 1998. EPRI, “Retrofit NOx Controls for Coal-Fired Utility Boilers – 2000 Update, Final Report”, December 2000. Himes, R., “A Fresh Look at SNCR”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003 EPRI, “Sate of the Art Assessment of SNCR Technology”, September 1993. EPRI, “SNCR Feasibility and Economic Evaluation Guidelines for Fossil-Fired Utility Boilers”, May 1994 C-49 C-50 Process: Tempering (Water, air, steam injection) NOx, TPY (WRAP 1996>100 %NOx TPY) reduction Cost, $/ton Status Category Turbines 25,278 ~50% 2,000-7,000 Commercial Refinery Process Heaters 9,311 ----Commercial Process Description: Tempering is a combustion control using water, air, or steam to lower the combustion temperatures, which reduces thermal NOx formation. Water or steam, treated to quality levels comparable to boiler feedwater, is injected into the combustor and acts as a heat sink to lower flame temperatures. NOx Reduction: Controlled NOx emission levels range form 25 to 42 ppmv for natural gas fuel and from 42 to 75 ppmv for distillate oil fuel. Cost Information: Capital costs for wet injection include a mixed bed demineralizer and reverse-osmosis water treatment system and an injection system. All costs are based on availability of the injection medium on site. Capital costs range from $388K for a 4,430 hp turbine ($89/hp) to $4,830K for a 216,000 hp turbine ($22/hp). For steam injection, capital costs are slightly higher than for water injection. Development Status: Commercially available Practical Considerations: This technique is available for all new turbine models and can be retrofitted to most existing installations. The decision of which injection medium to use for NOx reduction depends on many factors including the availability of steam injection nozzles and controls from the turbine manufacturer, the availability and cost of steam at the site, and turbine performance and maintenance impacts. This decision is usually driven by site-specific environmental and economic factors. Compatibility with other air pollution control technologies: None. Secondary Environmental Impacts: None expected. References: Alternative Control Techniques Document: NOx Emissions from Stationary Gas Turbines. EPA Document No. EPA-453/R-93-007, January 1993. U.S. Environmental Protection Agency. “Alternative Control Techniques Document – NOx Emissions form Stationary Reciprocating Internal Combustion Engines.” EPA-453/R-93-032, July, 1993. C-51 Process: Tempering (Water, air, steam injection) Poole, L., “Houston Galveston Area NOx Abatement Industries Perspective,” present at the Council of Industrial Boiler Owners, NOx Control XV Conference, Houston, TX, August 2002. C-52 APPENDIX D: PM Control Technology Summaries Category Mineral Processing Petrochemical Wood/Biomass boilers Primary metal production Pulp & Paper Process Description: Process: Cyclones PM, TPY (WRAP 1996 %PM >100 TPY) reduction Cost 24,499 50 – 90% See below 50 – 90% See below 10,836 50 – 90% See below 5,718 50 – 90% See below 4,697 50 – 90% See below 4,476 Status Commercial Commercial Commercial Commercial Commercial Cyclones use centrifugal force to separate particulate from gas streams, and belong to the broader family of mechanical collectors, which use a variety of mechanical forces to collect particulate. A multiple cyclone is an array of a large number of small (several inch diameter) cyclones in parallel. PM Reduction: Multiple cyclones have overall mass removal efficiencies of 70-90%. However, cyclone collection efficiencies fall off rapidly with particle size, so that control of fine particulate (PM-2.5) is limited. While collection efficiency is a function of the cyclone design and particle properties, cyclone removal efficiencies will be 90% or greater for 10 micron particles, dropping to perhaps 70% for 2.5 micron particles, and 50% for 1 micron particles. Addition of a second multiple cyclone in series with the first will allow for increased removal efficiency. The efficiency of a cyclone increases with the gas flow rate through the cyclone. Cyclones are therefore most effective at high boilers loads, where flue gas flow rates are highest, with collection efficiency decreasing at lower loads. Cost Information: The following values represent typical costs for several of these technologies (these numbers reflect unit sizes ranging from utility-size units up to about 2,000,000 ACFM to smaller process down to about 10,000 ACFM). • Capital - $1 - $5/ACFM • O&M - NA Development Status: Commercial. Cyclones have been used extensively in various particulate collection applications over the years. In the past, industrial plants used mainly cyclones. Cyclones are robust technologies that can deal with the cyclic operation and load changes. However, their efficiency is moderate when compared with ESP or fabric filtration Practical Considerations: Cyclones are best suited for applications of relatively large particle sizes as their effectiveness on smaller particles is limited Cyclones are less expensive than other PM controls and have no costs beyond the initial capital cost. D-1 Process: Cyclones Multiple cyclones have no moving parts, but do require regular cleaning to avoid plugging, and preventive maintenance to avoid leaks, which can disrupt flow patterns and thus lower collection efficiency. Compatibility with other air pollution control technologies: Cyclones are compatible with other PM controls and may be desirable in selected applications to minimize PM loadings into downstream controls such as an ESP, FF or PM scrubber Secondary Environmental Impacts: None expected. References: http://www.icac.org http://www.IEA-coal.org.UK/ http://www.croll.com D-2 Category Coal-fired boilers Wood/Biomass boilers Oil/NG boilers Cement kilns Process Description: Process: Electrostatic Precipitator (ESP) PM, TPY (WRAP 1996 %PM >100 TPY) reduction Cost 46,010 90%-99+% See below 5,718 90%-99+% See below 1,379 90%-99+% See below 641 90%-99+% See below Status Commercial Commercial Commercial Commercial ESP’s operate on the principle of electrophoresis, by imparting a charge to the particulates and collecting them on opposed charges plates. Dry vs. wet refers to whether the gas is water cooled and saturated prior to entering the charged plate area, or is collected dry on the plates. Electrostatic precipitators (ESPs), have been in use for particulate control since the early 1920’s, use electrical fields to remove particulate from boiler flue gas. In an electrostatic precipitator, an electric field is maintained between high-voltage discharge electrodes, typically wires or rigid frames, and grounded collecting electrodes, typically plates. A corona discharge from the discharge electrodes ionizes the gas passing through the precipitator, and gas ions subsequently ionize particulates. The electric fields impart electrostatic forces to the negatively charged particles, “driving” them to the collecting electrodes. Particulates are collected from the electrode plates either by mechanical rapping (Dry ESP) or by using a water spray to remove this particulate. (Wet ESP). In a typical electrostatic precipitator, collecting plates are arranged parallel to the gas flow, normally 9-18 inches apart, with discharge electrodes between them. Most precipitators have 3-5 independent electrical sections, i.e., sets of discharge and collecting electrodes with independent power supplies called Transformer/Rectifier (TR) sets, in series. Each independent section removes a fraction of the particulate in the gas stream. This arrangement allows the use of lower power (higher voltages, but lower current) in the first sections of the precipitator, where there is more particulate to be removed. Higher power is needed in the later sections, to collect the smaller particles. A typical wet ESP configuration uses cylindrical collecting electrodes, with discharge electrodes located in the centers of the cylinders. Wet ESPs are useful in obtaining low opacities through the removal of acid gases and mists in addition to fine particulate. In addition, these devices have no rapping re-entrainment losses, and no back corona. PM Reduction: Many factors determine electrostatic precipitator removal efficiency. ESP size is an important one. Size determines residence time (longer particle residence times help collection efficiency) Precipitator size is related to and usually referred to as the specific collection area (SCA), the ratio of the surface area of the collection electrodes to the gas flow. Higher collection areas lead to better removal efficiencies. Collection areas normally are in the range of 200-800 ft²/1000 acfm. In order to achieve collection efficiencies of 99.5%, specific collection areas of 350-400 ft²/1000 acfm are typically used. Electrostatic precipitator collection efficiencies can exceed 99.9%, and efficiencies in excess of 99.5% are common. Precipitators with high overall collection efficiencies will have high collection efficiencies for particles of all sizes. Good control of PM-10 and PM-2.5 can be achieved with well-designed and operated electrostatic precipitators. D-3 Process: Electrostatic Precipitator (ESP) Precipitator collection efficiencies decreases for very small particles (less than 1 micron). The reason for lower efficiency for submicron particles is that both particle charge and the resistance of the gas to particle motion increase with particle size. As particles get smaller, the particle charge is lower, while the resistance to particle motion is higher resulting in poor collection. In practice this effect means that an ESP precipitator with a 99.9% overall mass collection efficiency may only collect over 90% of submicron particles, and over 97-98% of the 0 to 5 micron particles. Some older precipitators on utility boilers are small, with SCAs below 200 ft²/1000 acfm and correspondingly short treatment times. Cost Information: The following values represent typical costs for several of these technologies (these numbers reflect unit sizes ranging from utility-size units up to about 2,000,000 ACFM to smaller process down to about 10,000 ACFM)) • Capital: $15 - $40/ACFM • Fixed O&M: Dry ESP’s - $0.25 - $0.65/yr-ACFM Wet ESP’s - $0.15- $0.50/yr-ACFM • Variable O&M: Dry ESP’s - $0.45 - $0.60/yr-ACFM Wet ESP’s - $0.25 - $0.50/yr-ACFM Development Status: Commercial ESP’s have been in use for over 75 years and are a widely recognized technology option for PM control Practical Considerations: Maximizing electric field strength will maximize precipitator collection efficiency. Other actors limiting precipitator performance include flow non-uniformity and particle re-entrainment. Uniform flow distribution helps ensure that there are no high gas velocity, short treatment time paths through the precipitator. Re-entrainment of collected particles may occur during rapping. Proper rapper design and timing will minimize rapper re-entrainment. Maintenance of appropriate hopper ash levels and of flow uniformity will minimize re-entrainment of ash from the hoppers. A major consideration of ESP collection efficiency is the electrical resistivity of the particles to be collected. Particles with resistivities in the range of 107-1010 ohm-cm are more easily collected with ESPs: these particles are easy to charge, and loose their charge slowly once deposited on a collecting electrode. Particles with low resistivities (less than 107 ohm-cm), on the other hand, loose their charge to a collecting electrode rapidly and tend not to adhere to the electrode, causing high re-entrainment losses. (Carbon black is an example of a low resistivity material). Particles with high resistivity (greater than 1010 ohm-cm) can be difficult to remove with a precipitator: such particles are not easily charged, and thus are not easily collected. High-resistivity particles also form ash layers with very high voltage gradients on the collecting electrodes. Electrical breakdowns in these ash layers lead to injection of positively charged ions into the space between the discharge and collecting D-4 Process: Electrostatic Precipitator (ESP) electrodes ("back corona"), thus reducing the charge on particles in this space and lowering collection efficiency. Fly ash from the combustion of low-sulfur coal typically has a high resistivity, and thus is difficult to collect. Flue gas treatment options exist to address both high and low resistivity problems and include the injection of ammonia, SO3 and other proprietary additives. Compatibility with other air pollution control technologies: ESP’s are compatible with other PM controls and may be desirable in selected applications to minimize PM loadings into downstream controls such as a FF or PM scrubber Secondary Environmental Impacts: None expected. References: EPRI, “Economic Evaluation of Particulate Control Technologies”, Final Report, September 1992. Staehle, R., “The Past, Present and Future of Wet ESPs in Power plant Applications”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003. IEA Coal Research, “Particulate control Handbook”, Final report, July 1997. IEA Coal Research, “Prevention of Particulate Emissions”, Final report, December 2000. ICAC, “ESPs vs. Fabric Filters: A Symposium and Debate”, March 1994. http://www.icac.org http://www.IEA-coal.org.UK/ http://www.croll.com D-5 Category Coal-fired boilers Mineral Processing Wood/Biomass boilers Fugitive Oil/NG boilers Cement kilns Process Description: Process: Fabric Filter PM, TPY (WRAP 1996 %PM >100 TPY) reduction Cost, 46,010 99+% See below 99+% See below 24,499 99+% See below 5,718 99+% See below 5,631 99+% See below 1,379 99+% See below 641 Status Commercial Commercial Commercial Commercial Commercial Commercial Fabric filter (FF) collectors (also referred to as baghouses) are the industrial equivalent of very large vacuum cleaners: by passing flue gas through a tightly woven fabric, particulate in the flue gas will be collected on the fabric by sieving and other mechanisms. The dust cake which forms on the filter from the collected particulate can contribute significantly to the overall collection efficiency. FF types are usually defined by the type of bag cleaning utilized. Major types include: (1) the “reverseair” baghouse, where the flue gas flows upward through the insides of vertical bags, which open downward. The fly ash thus collects on the insides of the bags, and the gas flow keeps the bags inflated. To clean the bags, a compartment of the FF is taken off-line, and the gas flow is reversed. This causes the bags to collapse, and collected dust to fall from the bags into hoppers. (Shaking or other method may be necessary to dislodge the dust from the bags.); and (2) the pulse-jet fabric filter, where the dirty gas flows from the outside of the bags inward, and the bags are mounted on cages to keep them from collapsing. Dust that collects on the outsides of the bags is removed by a reverse pulse of high-pressure air. This cleaning does not require isolation of the bags from the flue gas flow, and thus may be done on-line. PM Reduction: FF’s are capable of 99.9% removal efficiencies. In addition removal efficiency is relatively level across the particle size range, making FF’s good alternatives for very small particle sizes . Key performance factors include the fabric of the bag, the cleaning frequency and methods, and the particulate characteristics. Fabrics can be chosen for different applications, and some fabrics are specialty-coated for enhanced removal of submicron particulate. Cleaning intensity and frequency are also important variables in determining removal efficiency. Because the dust cake can provide a significant fraction of the fine particulate removal capability of a fabric, cleaning which is too frequent or too intense will lower the removal efficiency. On the other hand, if removal is too infrequent or too ineffective, then pressure drop will increase rapidly and impact overall operation. D-6 Process: Fabric Filter Cost Information: FF’s have been used extensively for many years in different industries. The power generation sector while predominantly dominated by ESP’s has started to utilize FF’s in the last 20 years. • Capital: Reverse Air Fabric Filter - $17 - $40/ACFM Pulse Jet Fabric Filter - $12 - $40/ACFM • Fixed O&M: Reverse Air Fabric Filter - $0.35 - $0.75/yr-ACFM Pulse Jet Fabric Filter - $0.50 - $0.90/yr-ACFM • Variable O&M: Reverse Air Fabric Filter - $0.70 - $0.80/yr-ACFM Pulse Jet Fabric Filter - $.90 - $1.1/yr-ACFM Development Status: Commercial. FF’s have been used extensively for many years in different industries. The power generation sector while predominantly dominated by ESP’s has started to utilize FF’s in the last 20 years. Practical Considerations: FF size is determined by the choice of air-to-cloth ratio (A/C), or the ratio of air flow to cloth area, typically expressed in feet per minute (cubic feet per minute of flow divided by square feet of fabric area). The selection of air-to-cloth ratio depends on the particulate loading and characteristics, and the cleaning method used. A high particulate loadings will require the use of a larger FF (lower A/C) in order to avoid forming too heavy a dust cake, resulting in an excessive pressure drop Pulse-jet FF’s are smaller (higher A/C) than reverse-air FFs due to the higher cleaning intensity and resulting bags being cleaner Compatibility with other air pollution control technologies: FF’s are compatible with other PM controls. FF’s are also choices for applications downstream of dry SO2 controls (e.g. spray dryers) as well as in combination with sorbent injection techniques for SO2 and/or Hg control Adding a FF downstream from an existing electrostatic precipitator is a strategy gaining some acceptance in the power industry. Because the ESP removes the bulk of the particulate, the baghouse can be relatively small, and thus less expensive. One commercial approach to this is the installation of a small pulse-jet fabric filter downstream of an ESP, known as a Compact Hybrid Particulate Collector (COHPAC). Physically, it may be separate from the precipitator, or even fully integrated into the last field of the existing ESP, further reducing the over cost and space requirements. Secondary Environmental Impacts: As mentioned above FF’s can represent a complementary option to sorbent injection technologies where they enhance the contact (reaction) times between the sorbent and the flue gas contaminant of interest. This results in enhanced collection efficiency for the pollutant (e.g. mercury), as well as reduced quantities of sorbent needed D-7 Process: Fabric Filter References: EPRI, “Economic Evaluation of Particulate Control Technologies”, Final Report, September 1992. Staehle, R., “Particulate Control Options for Dry FGD Systems”, EPRI/DOE/EPA Mega Symposium, Washington, May 2003. IEA Coal Research, “Particulate control Handbook”, Final report, July 1997. IEA Coal Research, “Prevention of Particulate Emissions”, Final report, December 2000. ICAC, “ESPs vs. Fabric Filters: A Symposium and Debate”, March 1994. http://www.icac.org http://www.IEA-coal.org.UK/ http://www.croll.com D-8 Category Mineral Processing Petrochemical Wood/Biomass boilers Primary Metal production Pulp & Paper Process Description: Process: PM Scrubber PM, TPY (WRAP 1996 %PM >100 TPY) reduction Cost, 24,499 50%-99+% See below 10,836 50%-99+% See below 5,718 50%-99+% See below 4,476 50%-99+% See below 4,476 50%-99+% See below Status Commercial Commercial Commercial Commercial Commercial Scrubbers work on the principle of rapid mixing and impingement of the particulate with the liquid droplets and subsequent removal with the liquid waste. For particulate controls the “venturi scrubber” is an effective technology whose performance is directly related to the pressure loss across the venturi section of the scrubber. Venturi scrubbers are one type of the more commonly used “scrubbers” for particulate collection. As the name implies, the scrubbing liquid and flue gases accelerate through a converging section into a narrow throat. In the throat, very high gas velocity shears the scrubbing liquid into many very fine droplets, which collect particles through numerous “collisions”. PM Reduction: Scrubbers have varying PM reduction capabilities based on deign operating conditions and particle characteristics. Performance can range 50% for the small size fraction (< 2microns) to over 99% for the larger sizes. Higher collecting efficiencies and a wider range of particulate sizes, require higher operating pressures. . High-energy scrubbers refer to designs operating at pressure drop of 50-70 inches of water. Of course, higher pressure translates to higher energy consumption. Cost Information: The following values represent typical costs for several of these technologies (these numbers reflect unit sizes ranging from utility-size units up to about 2,000,000 ACFM to smaller process down to about 10,000 ACFM) • Capital: Venturi Scrubber - $5 - $20/ACFM • Fixed O&M: Venturi Scrubber - $0.25 - $0.65/yr-ACFM • Variable O&M: Venturi Scrubber - $1.2 - $1.8/yr-ACFM Development Status: Commercial Wet scrubbers are widely used in various industries. One advantage of scrubbers is their ability to treat wet gases which are not conducive to other technologies such as dry ESPs and FFs. Practical Considerations: For applications where variation in flow require throat velocity compensation to maintain specified scrubbing efficiencies, automatic and manually variable throat designs are available. D-9 Process: PM Scrubber The automatic throat is used where flow conditions vary widely and frequent adjustments are required. When occasional variations occur, a manually controlled throat is generally sufficient. Compatibility with other air pollution control technologies: Scrubbers are compatible with other PM controls. However, dry ESP’s and FF’s would not be deployed downstream of a scrubber without prior reheating of the flue gas which would make such application economically questionable in general Secondary Environmental Impacts: Liquid waste disposal requires consideration on a case-by-case basis. Since scrubbers have the capability to reduce acid gases, applications where this is important must be considered. References: IEA Coal Research, “Particulate control Handbook”, Final report, July 1997. http://www.icac.org http://www.IEA-coal.org.UK/ http://www.croll.com D-10 APPENDIX A-8. SO2 MILESTONES/BACKSTOP This appendix contains work products and references relied upon by Arizona in the development of Chapter 8 of the Regional Haze SIP. Appendix A-8 – SO2 Milestones/Backstop Arizona Regional Haze SIP Appendix A-8a. WRAP Market Trading Forum Non-Utility Sector Allocation Final Report from the Allocations Working Group (November 2002) Appendix A-8 – SO2 Milestones/Backstop Arizona Regional Haze SIP M ARKET T RADING F ORUM N ON -U TILITY S ECTOR A LLOCATION PECHAN F INAL R EPORT FROM THE A LLOCATIONS W ORKING G ROUP 5528-B Hempstead Way Springfield, VA 22151 703-813-6700 telephone 703-813-6729 facsimile 3622 Lyckan Parkway Suite 2002 Durham, NC 27707 919-493-3144 telephone 919-493-3182 facsimile P.O. Box 1575 Shingle Springs, CA 95682 530-672-0441 telephone 530-672-0504 facsimile Prepared for: Western Governors’ Association 1515 Cleveland Place Denver, CO 80202 Prepared by: E.H. Pechan & Associates, Inc. 5528-B Hempstead Way Springfield, VA 22151 November 2002 WGA Contract No. 30204-48 Pechan Rpt. No. 02.11.001/9422.000 CONTENTS Page TABLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix CHAPTER I INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1 A. ANALYSIS METHODS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1 CH APTER II PETROLEUM REFINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . II-1 B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . II-1 1. Sulfu r Recovery Units . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 2. Fuel Gas C om bustion U nits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2 3. Catalytic Crackers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3 4. Flares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3 C. FLOOR ALLOCATION RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3 D. COMPARISON WITH HISTORICAL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . II-10 E. EXAMPLE CALCULATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10 1. Sulfu r Recovery Unit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10 2. Fuel Gas Com bustion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10 3. Catalytic Crackers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-12 4. Flares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-12 CH APTER III LIME MANUFACTURING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1 A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . III-1 B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . III-1 CH APTER IV INDUSTRIAL BOILERS AND COGENERATORS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . 1. Coal Fired U nits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2. Oil F ired U nits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C. FLOOR ALLOCATION RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D. COMPARISON WITH HISTORICAL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . E. EXAMPLE USE OF CAPACITY UTILIZATION DATA FOR FLOOR ALLOCATION ESTIMATES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1 IV-1 IV-1 IV-2 IV-2 IV-3 IV-3 IV-3 CHAPTER V PULP AND PAPER INDUSTRY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . . 1. Recovery Furnaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2. Lime Kilns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . . 1. Recovery Furnaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2. Lime Kilns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C. FLOOR ALLOCATION RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D. COMPARISON WITH HISTORICAL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . iii V-1 V-1 V-1 V-1 V-2 V-2 V-2 V-2 V-4 CONTENTS (continued) Page CHAPTER VI CEMENT MANUFACTURING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . C. FLOOR ALLOCATION RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D. COMPARISON WITH HISTORICAL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . CH APTER V II NATURAL GAS PROCESSING PLANTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . C. FLOOR ALLOCATION RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1. Genera l Plan ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2. Specific Exa mple . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D. COMPARISON WITH HISTORICAL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . VI-1 VI-1 VI-1 VI-1 VI-4 VII-1 VII-1 VII-1 VII-2 VII-2 VII-3 VII-3 CH APTER V III ELEMENTAL PHOSPHORUS PRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VIII-1 A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . VIII-1 B. FLOOR ALLOCATION ESTIMATION PROCEDURES . . . . . . . . . . . . . . . . . VIII-1 CH APTER IX GLASS MANUFACTURING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IX-1 A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . IX-1 B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . IX-2 CHAPTER X COPPER SMELTERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . . B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . . C. COMPARISON WITH HISTORICAL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . X-1 X-1 X-1 X-2 CHAPTER XI ALUMINUM PRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . XI-1 A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . . XI-1 B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . . XI-2 CH APTER XII SULFURIC ACID PLANTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . XII-1 A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . . XII-1 B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . . XII-2 CH APTER XIII METALLURGIC COKE PRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. SECTOR DESCR IPTION AND SIGNIFICANT SO 2 SOURCES . . . . . . . . . . . 1. By Product Coke Ovens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2. Rotary Calcine rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B. FLOOR ALLOCATION ESTIMATION METHODS . . . . . . . . . . . . . . . . . . . . . C. COMPARISON WITH HISTORICAL EMISSIONS . . . . . . . . . . . . . . . . . . . . . XIII-1 XIII-1 XIII-1 XIII-1 XIII-2 XIII-3 CH APTER XIV FLOOR ALLOCATION SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . XIV -1 iv TABLES Page I-1 II-1 II-2 II-3 III-1 III-2 IV-1 IV-2 IV-3 IV-4 V-1 V-2 V-3 VI-1 VI-2 VI-3 VII-1 VII-2 VII-3 VIII-1 IX-1 X-1 X-2 XI-1 XI-2 XII-1 XIII-1 XIII-2 XIV -1 XIV -2 Methodology for the Calculation of the Floor Allocations for Non-Utility Sources I-3 Sulfur Plants - Required Minimum SO 2 Em ission Re duction E fficiency . . . . . . II-2 Petroleum Refining Floor Allocation Calculation . . . . . . . . . . . . . . . . . . . . . . . . . II-4 Petroleum Refineries – Historical Emissions – 1990 to 2000 . . . . . . . . . . . . . . II-11 Emission Factors for Lime Manufacturing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-3 Lime Manufacturing - Historical Emissions - 1990 to 2000 . . . . . . . . . . . . . . . . . III-4 Assumed Level of Control for SO 2 Floor Allocation . . . . . . . . . . . . . . . . . . . . . . . IV-2 Facility SO 2 Floor A llocation Estimation for ICI Bo ilers . . . . . . . . . . . . . . . . . . . IV-5 Comparison of SO 2 Floor A llocation w ith Historical E mission s for ICI Bo ilers . IV-7 Exam ple Use of Capacity Utilization Data for Floor Allocation Estimates . . . . IV-9 Facility SO 2 Floor Allocation Estimation for Pulp and Paper Facilities Based on Unit Capacity Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3 Facility SO 2 Floor Allocation Estimation for Pulp and Paper Facilities Based on Fuel Throughput . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3 Pulp and Paper - Historical Emissions - 1990 to 2000 . . . . . . . . . . . . . . . . . . . . . . V-5 Floor Allocations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-2 Cement Manufacturing - Historical Emissions - 1990 to 2000 . . . . . . . . . . . . . . VI-3 Exam ple Calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VI-4 Sulfur Plants - Required Minimum SO 2 Em ission Re duction E fficiency . . . . . VII-2 Possible F loor - N atura l Gas Processing Units . . . . . . . . . . . . . . . . . . . . . . . . . . VII-4 Oil and Gas Production - Historical Emissions - 1990 to 2000 . . . . . . . . . . . . . VII-6 Elemental Phosphorus Production - Historical Emissions - 1990 to 2000 . . . VIII-2 Glass Manufacturing - Historical Emissions - 1990 to 2000 . . . . . . . . . . . . . . . . IX-3 Copper Smelter SO 2 Em ission Projections (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . X-2 Recent Historical Copper Smelter SO 2 Emissions . . . . . . . . . . . . . . . . . . . . . . . . . X-3 Aluminum Plant Data Used to Estimate Floor Allocations . . . . . . . . . . . . . . . . . XI-4 Aluminum Smelting - Historical Emissions - 1990 to 2000 . . . . . . . . . . . . . . . . . XI-5 Sulfu ric Acid Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . XII-3 Historical SO 2 Em issions at P4 P roduction , Ro ck S prings, W Y . . . . . . . . . . . . XIII-2 Coking Plant - Historical Emissions - 1990 to 2000 . . . . . . . . . . . . . . . . . . . . . XIII-3 State/Sector Summary of SO 2 Floor A llocations (tons per year) . . . . . . . . . . . . XIV -2 Facility-Level SO 2 Floor Allocations - Comparison with Year 2000 SO 2 Em issions (tons per year) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . XIV -3 v vi ACRONYMS AND ABBREVIATIONS BACT BART BLS CAA CWPB DCE dscf ESPs FCCU GCVTC H 2S HSS ICI kg LAER lbs/M MBtu Mg MTF NO x NSPS ppm ppmv PTE RE CLAIM SCC SIC SIP SO 2 SRU SWPB tpy VSS WGA WRAP Best Available Control Technology Best Available Retrofit Technology Black liquor solids Clean Air Act center-worked prebake cells Direct contact evaporator dry standard cubic foot electrostatic precipitators fluid catalytic cracking unit Grand Can yon Visibility Transport Comm ission hydrogen sulfide horizon tal stud Soderberg industrial, commercial, and institutional kilogram Lowest Achievable Emission Reduction pounds per m illion B ritish therm al un its megagram Market Trading Forum oxides of nitrogen New Sou rce Performance Standards parts per million parts per million volume poten tial to em it Regional Clean Air Incentives Market Source Classification Code Standard Industrial Classification State Implementation Plan sulfur dioxide Sulfu r Recovery Unit side-w orked prebak e cells tons per year vertical stud Soderberg Western Governors’ Association Western Regional Air Partnership vii viii EXECUTIVE SUMMARY This study was perform ed for a Workin g Group of the Western Regional Air Partnerships’ (WRAP) Market Trading Forum. It provides a current, best estimate of the floor allocation for non-utility sources in the region that would be established if western States and tribes adopt a regional, backstop trading program for sulfur dioxide (SO 2) to meet the requirements of Section 309 of the regional haze rule. The major SO 2 emitting non-utility source categories evaluated in this study include the following: petroleum refineries, lime manufacturing, industrial boilers and co-generators, pulp and paper manufacturing, cement manufacturing, natural gas processing and oil and gas production, elem enta l phosphorus production , glass m anu facturin g, aluminum smelters, sulfuric acid plants, and coke production. Of these industry sectors, phosphorus, aluminum smelters, sulfuric acid plan ts, and coke production plants w ere not considered in the origin al source categories for the Market Trading Forum. The floor control technology (or emission rate or SO 2 control effectiveness) was determined by evaluating the emissions performance of other sources in that source category in the western States. The floor is defined to be best available control technology (BAC T), best available retrofit technology (BA RT), or lowest achievable emission rate (LAE R) for existing sources. For some sources, EPA has not determined what these levels of emissions are. SO 2 floor allocations were computed for each of about 200 major non-utility sources in the western States, where major is defined as those so urce s em itting greater tha n 100 tons per year (tpy). While this analysis uses plant and process-level information to estimate floor allocations, if the backstop trading program is triggered, SO 2 allowances under the trading program will be allocated by the participating transport region States and Tribes at that time. This study is only an approximation of how the allocations might be made based upon the limited information that we have today. It is expected that the States and Tribes would be able to obtain more detailed information about current emissions and controls for these non -utility sou rces than h as been available for the curren t project. The floor allocation analysis has been performed separately for each of the 12 ma jor non-utility source categories in the west. The text below summ arizes the key findings for each source category. To simplify the analysis, it was determined that California SO 2 sources are already highly controlled. The California floor allocation of 27,335 tpy is based on the opt-in/out 2018 SO 2 allocation that has been estimated previously by the WRAP Market Trading Forum. Petroleum Refining: There are ten petroleum refineries outside California in the WR AP transport region. Data were received from all of these refineries for the allocation process. These floor allocations were computed for each of the four major SO 2 emitting processes at refineries: sulfur plants, fluidized catalytic cracking units (FCC Us), fuel combustion units, and flares. The SO 2 floor allocation for these ten refineries is 11,418 tpy, or about 5,400 tpy less than historic emissions during 199 6 to 2000. This is one of the best characterized source categories. Cement M anufacturing: The control technology analyses for cement kilns showed that there was no demonstrated SO2 control technique at western State sources that could be applied to reduce SO 2 across the source population. There are widely varying SO 2 emissions rates from these kilns, and the process itself removes sulfur from the off gas. As a re sult, this se ctor’s flo or a llocation of 7,761 tpy w as based on recent historic emissions. The analysis for lime manu facturing reach ed the same conclu sion as that for cement. The lime manufacturing floor allocation is 2,103 tpy. ix Bo ilers a nd Co -gen erators: The floor for boilers and co-generators at industrial facilities was estimated by applying the equivalent of 85 percent SO 2 control to coal and oilfired sources not already at, or near, this control level. Average capacity factors were used to estim ate boiler utilization for estim ating the floo r with a 5 percen t grow th m argin . This assumption is consistent with that used in the utility boiler floor allocations. Some nonutility boilers are operating at low utilization rates. The industrial boiler and cogenerator floor allocation is 7,910 tpy. Pulp and Paper Industry: Recovery furnaces and lime kilns are the SO 2 sources at the Kraft pulp mills in the west. Most of these mills are in Oregon. Floor allocations for recovery furnaces and lime kilns are based on standard U.S. Environmental Protection Agency (EPA) emission factors and 100 percent capacity utilization (or recent annual throu ghput, if capacity estim ates w ere n ot available). The pulp and paper floor allocation is 7,184 tpy. Natural Gas Processing Plants and Oil and Gas Production: SO 2 emissions from natural gas processing plants result from combustion of sour gases. It was decided that the current New Source Performance Standard (NSPS) would serve as the floor. The NSPS requires a variable sulfu r rem ova l efficiency based on the hydrogen sulfide (H 2S) content of the acid gas and the am oun t of sulfur in the gas. If a facility had curre nt con trol leve ls highe r than the assumed floor, the actual average em issions over the past three years were used to estimate the floor. Since emissions from flaring operations both in the plant and the well field are not amenable to control, floor emissions are assumed to be the average of the emissions in three recent years. D ata availability w as a significant issue in determ ining the floor allocations for som e gas plants. The floor allocation for this sou rce category is 28,884 tpy. Elemental Phosphorus Production: One of the two U.S. elemental phosphorus production facilities is in Idaho. Because of the uniqueness of this facility, no floor control technology was identified. The floor allocation is set at year 2000 SO 2 emissions, which were 15,861 tpy. It is expected that the State of Idaho will perform a more detailed evaluation of this facility during preparation of its regional haze State Implementation Pla n (SIP). Glass Manufacturing: The major source of SO 2 emissions in the glass industry is the glass melting operation. There are only two active glass manu facturing facilities in the 8 non-California WRAP States. With a lack of information about SO 2 control techn ique s in practice, the floor allocation for glass manufacturing plants was set according to historical SO 2 emissions. The glass manufacturing floor allocation is 368 tpy. Copper Sm elters: Because of the un ique ness of the existing copper sm elters, retrofit technology an alysis must be pe rformed on a sm elter-by-sme lter basis. A dou ble contact acid plant is co nside red the appropriate retrofit contro l equ ipm ent. A ll coppe r smelters in the western States are currently equipped with double contact acid plants. The current year SO 2 allocation for the six copper sm elters in the 9-State re gion is 86,000 tons. This allocation is reduced to 78,000 tons by 2013 and is the same in 2018. Aluminum Production: There are only 2 primary aluminum plants in the study region and both are located in Oregon. The primary SO 2 source in aluminum production is the sulfur in the coke, and the coal tar pitch binder used to produce the anodes. The floor control technology for aluminum smelters was determined by evaluating the emissions performance at the two Oregon facilities. One facility uses a wet scrubber to achieve a 70 percent SO 2 emission reduction. Therefore, a wet scrubber with a 70 percent SO 2 reduction was selected as the floor technology for aluminum smelters. The aluminum smelter floor allocation is 2,076 tpy. Sulfuric Acid P lants: The only sign ificant source of air em issions from a contact sulfuric acid plant is th e tail ga s leaving th e final abso rbing tower. Th is gas conta ins sm all amounts of SO 2 and even sm aller amoun ts of sulfu r trioxide , sulfuric vapor, and sulfuric x acid m ist. Based on the information available for the 4 sulfuric acid plants in the west, it was decided that the floor allocation should be estimated by applying the NSPS requirements to each sulfuric acid plant. Achieving this standard requires a conversion efficiency of 99.7 percent in an uncontrolled plant, or the equivalent SO 2 collection mechanism in a controlled facility. However, recent historical SO 2 emissions for these facilities were lower than the NSPS emission rate times capacity estimated values, so the sulfuric acid plant floor was estimated using these historical SO 2 emission values. The resulting floor allocation for these sulfuric acid plants is 5,386 tpy. Metallurgic Coke Production: SO 2 em issions from coke oven operations prima rily resu lt from combustion of the byproduct coal gas in the oven. There were three coke production facilities operating in the west during the 1990s. Coke production has recently ceased at two of these facilities. The only facility tha t contin ues to ope rate is a rotary calcine r in Wyom ing. Because of the uniqueness of this operation, the floor allocation is based on recent historic SO 2 emissions, and is 631 tpy. Th ere are two benchmark s that can be used to put the floor allocations in perspective. One is year 2000 historic emissions and the other is the non-utility SO 2 emissions forecast for 2018. The floor allocation estimate in this report is about 2,500 tons higher than year 200 0 historical emissions. However, this com parison of the respective e mission totals is skewed by the fact that year 2000 copper smelter emission were about one-half of the 78 thousand ton allocation for this sector. Wh en copper sm elters are removed from the totals, the floor allocation is about 4 5 th ousand ton s lower than year 20 00 em issions. A comparison of the floor allocation with the SO 2 emissions in the 2018 opt-in/out emission allocations shows that the floor allocation is approximately the same. xi xii CHAPTER I INTRODUCTION This report describes an analysis that was prepared for a Working Group of the Western Regional Air Partnership’s (WRAP) Market Trading Forum (MTF). It provides the current best estim ate of the floor allocation for non -utility sou rces in the region that w ould be established if western States and tribes adopt a regional, backstop trading program for sulfur dioxide (SO 2) to meet the requirem ents o f Section 309 of the regional h aze rule. N ote that this does not establish final allocations for sources in the region. Each State and tribe will determ ine th e appropriate floor level for sources w ithin th eir jurisdiction, an d will include this inform ation in the ir State or tribal implem enta tion plan. T he program is voluntary for western States and tribes. Information is provided to assist eligible States and tribes evaluate the impacts of the program, but decisions to participate in the program will be made by each separate jurisdiction. The distribution of regional SO 2 allowances to existing sources in the nine Comm ission Transport States is composed of two portions: floor and reducible allocation. There are two com ponents o f the floor allocation - an allocation for the California Regional Clean Air Incentives Market (RECLAIM) program, and source-specific floor allocations for nonREC LAIM sources. The floor allocation is a minimum allocation for all existing sources, which will be calculated to ensure that well-controlled sources will receive a full allocation. California RECLA IM Program: 3,462 SO 2 allow ances w ill be included in the California budget for REC LAIM sources. These credits will be a subset of the existing source pool for the State of California and , hence, will n ot consum e an y extra credits from the total credit pool. Source-specific Floor Allocation: A floor allocation will be calculated for all existing sources in the region based on some specified level of control (e.g., Best Available Control Technology [BA CT ], Best A vailable R etrofit Techn ology [BA RT ], Low est Achievable Em ission Reduction [LAE R]) for non-utility sources. The sources affected by the backstop trading programs are all those stationary sources in participating States and tribes that emit SO 2 in an amount greater than or equal to 100 tons per year (tpy). The 100 ton cut off will be assessed at the plant level to correspond with the methodology used in the 1990 em issions inventory. Amon g the source types covered by this definition are utility and industrial boilers, refineries, smelters, pulp and paper mills, cement and lime kilns, and all of the other source categories listed in section 169(g)(7 ) of the Clean A ir Act (CAA ). In this report, the geographic area of analysis is defined to be the nine Comm ission Transport Region States, which are Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming. Facilities included in the analysis are those that emitted 100 tpy or more of SO 2 sometime during the period 1990 to 2000 . Plants that are electric utilities are excluded from this analysis. A. ANALYSIS METHODS The floor allocation analysis for the non-utility sector was performed using the following steps: 1. It was assumed that the SO 2 sources in the State of California are already at the floor. Th is is expected because of the stringe ncy of the air em ission regulations in that State. I-1 2. Because copper smelter allocations for 2018 have already been determined, no additiona l analyse s were performed for copper smelters. Smelter allocations are presented in Chapter X. 3. The focus of the analysis was on non-California, non-smelter facilities that had at least 100 tpy of SO 2 em issions du ring at lea st one year in th e period 1990 to 2000. States included in this analysis were Arizona, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyom ing. 4. The major SO 2 emitting non-utility source categories evaluated in this study included the following: petroleum refineries, lime manu facturing, industrial boilers and co-generators, pulp and paper manufacturing, cement manufacturing, natural gas processing and oil and gas production, elemental phosphorus production, glass manufacturing, aluminum smelting, sulfuric acid production, and metallurgical coke production. 5. The floor control technology or emission rate or SO 2 control effectiveness was determined by evaluating the emissions performance of other sources in that source category in the western States. The floor is defined to be BAC T, BART , or LAER for existing sources. Th e floor for each of the ma jor sou rce categories is summarized in Table I-1. 6. The primary source of emissions information for the western States is the 1996 WR AP point source inventory. The 1996 em ission estimates were prepared under contra ct to the Western Govern ors’ Association (W GA ) by Pacific Environm enta l; Services and Eastern Research Group, Inc. under contract to the WGA (PES, 2001). However, this data set was not sufficient for providing all of the inform ation needed to com pute the floo r allocation for each source. Th e State air pollution control agencies in e ach of the 8 States were contacted to ob tain supplementary data. For most source categories, this additional information included estimates of unit capacities. This could be either the design capacity for boilers, or the production capacity for industrial processes. 7. Once data was received from the State agencies, it was used to estimate the floor allocation by sou rce an d facility based on th e con trol technologies listed in T able I-1 and the unit or plant-specific information about existing capacities and SO 2 control techniques. The chapters that follow explain the floor allocation analyses for each of the key industrial sector source categories in the western United States. I-2 Table I-1 Methodology for the Calculation of the Floor Allocations for Non-Utility Sources Sou rce C ateg ory Technologies or Standard for Floor Co pper Sm elters Due to the uniqueness of the existing smelters, retrofit technology ana lysis m ust be pe rform ed o n a sm elter-by-sm elter ba sis. Currently, the Hidalgo smelter is the only BART-eligible source on the list in this category. A double-contact acid plant will be considered the appropriate retrofit control equipm ent (all sm elte rs in the re gion are c urrently equipped with d oub le-contac t acid p lants). On August 21, 2000, New Mexico completed an engineering analysis that verified earlier determinations by the MTF that the fugitive SO 2 capture system at Hidalgo satisfies BART at 96% overall capture. Refineries There are four sources of SO 2 emissions at the refinery level. Floor based upon N ew Sou rce Perform ance S tandards (N SPS ) where applicable. Description Assum ed Average Control Level Sulfur Recovery Unit (SRU) Meet NSPS Subpart J or the equ ivalent o f 3-stage Clau s un its with a tail gas unit (NSPS and the tail gas unit do es n ot apply to Claus u nits sm aller than 20 long tons /day or less). Fuel gas com bus tion un its Fix at the NSPS emission limit rate of 0.027 pounds per million British thermal units (lbs/MMBtu) assuming fuel gas input and not fuel oil. Catalytic crack ers NSPS (J) selected 9.8 lbs of SO 2 per 1,000 lbs of coke burned. Flares Based upo n averag e of the last 5 years' emission, AP42 factors for calculated. No additional controls. Natural Gas Processing Description Assum ed Average Level of Control Process Emissions Reduction to satis fy NSP S. V ariable reduction depending on hydrogen sulfide (H 2 S) conte nt and plan t size. Flaring Based upo n averag e of the last 5 years' emission. Oil & Gas Production Description Flaring Lime Plants Assum ed Average Level of Control Based upo n averag e of the last 5 years' emission. No additional reduction. Approximately 50% control inherent in the process. Additional SO 2 controls are not in place at lim e plants in the western States. I-3 Table I-1 (continued) Sou rce C ateg ory Industrial Boilers (Cogens) Technologies or Standard for Floor Technology dete rm ination dependent upon current level of c ontrol. Description Assum ed Average Level of Control Un con trolled U nits 85% Units controlled at less than 70% Treat as u ncontrolled (see above ). Units controlled between 70-80% Increase redu ctions by 5% (i.e., if a unit is at 7 2% , wou ld be a ssu m ed to control to 77%). Units controlled greater than 80% No additional reductions. Pulp and Paper Sulfur sources are recovery furnaces and boilers. Boiler discussions covered with industrial boilers. Recovery Furnaces: No additional reduction. Low emissions coupled with lack of more than one example of scrubbing. Cem ent Plan ts No additional reduction. Approximately 70-90 percent control inherent in the process. Additional SO 2 controls are not typic ally applied to these levels of processes. Alum inum Sm elters A wet scrubber with a 70 percent SO 2 emission reduction selected as the floo r ba sed on achieved control levels at NW Alum inum in Oregon. Sulfuric Acid Plants No add itional red uction . Existing un its are already controlled to NSP S levels (4 lbs per ton of 100% acid produce d). Coke Production Only one fac ility is still operatin g. B ecause of the uniqueness of this rotary calciner, the floor allocation is established at historic SO 2 emission levels. I-4 CHAPTER II PETROLEUM REFINING A. SECTOR DESCRIPTION AND SIGNIFICANT SO2 SOURCES The petroleum refining industry in volves num erou s processes that con vert crude oil into more than 2,500 products, including gasoline, liquefied petroleum gas, kerosene, jet fuel, diesel fuel, other fuel oils, lubricating oils, and feed stock for the petrochemical industry. Petroleum refinery activities include the storage of crude oil at the refinery, petroleum han dling and refining operations, an d storage of the refined products prio r to shipment. As of January 1990, there were 189 operating refineries in the United States with a total crude capacity of 15.4 million barrels per calendar day. Removal of sulfur from refinery streams is a pa rt of refinin g. It would be desirable to rem ove all sulfur com pounds before an y crude processing begins, but because this is impractical, sulfur is removed through out the refining process. There are several reasons, besides air pollution con trol, for rem oving sulfur from interm ediate fraction s and products of crude oil. Sulfur removal reduces corrosion, odor, breakdown frequency, catalyst poisoning, and gum formation and improves octane rating, color, and lube oil life. B. FLOOR ALLOCATION ESTIMATION METHODS There are four possible unit types (SO 2 em ission points) within a re finery, as noted in the metho dology for the calculation of the floor allocations for non-utility sources. These four SO 2 sources are: (1) the SRU; (2) fuel gas combustion units; (3) catalytic crackers; and (4) flares. The approach for estimating SO 2 floor allocations is unique for each of these four SO 2 source types within the refinery. Floor calculation methods are presented below for each of these four source types. 1. Sulfur Recovery Units Sulfur recovery refers to conversion of H 2S to elemental sulfur. H 2S is a by product of processing natural gas and refining high sulfur crude oils. The m ost common conversion method use d is the Claus process. Approxim ately 90 to 95 percen t of recovered sulfur is produced by the Claus process. The Claus process typically recovers 95 to 97 percent of the H 2S feed stream. The average production rate of a sulfur recovery plant in the United States varies from 51 to 203 megagram s (Mg) (56 to 224 tons) per day. Some of the small to mid-sized refineries in the we stern States have sulfur plant capacities that are lower than these average value s. The SO 2 floor allocation for SRUs depends on the size of the sulfur plant. For sulfur plan ts of 20 long tons per day or larger, the NSPS requ ire a 3-stage Claus unit with a tail gas unit. Existing NSPS limit sulfur emissions from Claus sulfur recovery plants of greater than 20.32 Mg (22.40 tons) per day capacity to 0.025 percent by volume (250 parts per million volume [ppmv]). The NSPS and tail gas unit do not apply to Claus units smaller than 20 long tons per day or less. For these smaller sulfur plants, the SO 2 floor allocations are estimated as 95 percent SO 2 control. Table 8.13-1 in AP-42 provides the following SO 2 emission factors for modified Claus Recovery Plants: II-1 Em ission Fa ctors for M odified C laus Sulfur Recov ery Plan ts Nu mber of Catalytic Stages 1, Uncontrolled 3, Uncontrolled 4, Uncontrolled 2, Controlled 3, Controlled Average % Sulfur Rec overy 93.5 95.5 96.5 98.6 96.8 SO 2 Emissions lbs/ton of Kilograms (kg)/Mg of Sulfur Produced Sulfur Produced 139 278 94 188 73 145 29 57 65 129 The SO 2 em ission factor for 9 9.8 percent sulfur recovery is 8 lbs/ton and for 96 .8 percent sulfur recovery is 132 lbs/ton of sulfur produced. This e mission factor va lue is multiplied by the sulfur plant capacity in tons per day, 365 days per year, and 1 ton per 2,000 lbs to arrive at an annual SO 2 emissions floor estimate. Equation (1) below shows the above description as a formula: For refineries with su lfur plants sm aller than 20 long tons per day, and lowe r H 2S contents in their acid gas, an SO 2 control level of 96.8 percen t may not be achieva ble. In that situation, an alternative way to calculate the floor is to use the sulfur feed rate and the H 2S content of the acid gas of the affected facility to compute the appropriate minimum SO 2 reduction efficiency using the relationships shown in Table II-1. This table is from the NSPS for onshore natural gas production. Table II-1 Sulfur Plants - Required Minimum SO2 Emission Reduction Efficiency H 2 S Content of Acid Ga s (Y ), % Sulfur Feed Rate (x), Long To ns per Day 2.0300 .0 . . . . . . . 85.35X 0.0144Y 0.0128 . . . . . . . Y>50 74.0 2050 Sulfur Feed Rate (x), Long To ns per Day 2.0300 .0 . . . . . . . 85.35X 0.0144Y 0.0128 . . . . . . . 74.0 or 99.8, whichever is smaller . . . . 85.35X 0.0144Y 0.0128 . . . . or 97.5, whichever is smaller 85.35X 0.0144Y 0.0128 90.8 97.5 90.8 or 90.8, whichever is smaller 74.0 74.0 74.0 Data availability was a significant issue in determining the floor allocation for some plan ts. The data from New M exico was not adequa te to distin guish betw een process plan t, upset flare, and well field emissions. C. FLOOR ALLOCATION RESULTS 1. General Plants Table VII-2 shows the floor allocation calculation for the natural gas processing plants in the 8 non-C alifornia Western Region al Air Partnership (WR AP) States. In Table VII-2, the pla nt nam e an d SC C code are those provided in the State inven tory. The e mission source column (process or flare) notes w hether the em issions are likely to come from the normal processing of natural gas (process) or the result of upset or well field emissions (flare). The distinction was made on the basis of comments in the emission inventory an d confirmed in con versations with the State. Cu rrent em issions are based on the average o f several years d ata (2000, 199 8, 19 96) if available, and on one ye ar's data if that was all that was available. In some cases, new plants were under construction and permit levels were used in lieu of actuals. Current reductions were based on data in the State inventories and confirmed via conve rsations with State agencies. Floor emissions vary by the H 2S content of the gas, the amount of sulfur produced by the plant, the age of the plant (olde r plan ts are n ot sub ject to the NSPS), and S tate regulations. In Wyoming, although individual plants vary, the average H 2S content of natural gas is higher than in other States and the degree of control required under the NSPS is greater. In addition, newer plants tend to be larger and have undergone a BACT review. In New Mexico, the relatively low H 2S content means that less control may be required under the NSPS. This is due both to the H 2S content as well as the small amount of sulfur produced by the processing plants. However, a State rule (20.2.35 NMAC) requires a minimum of a 90 percent reduction for plants that release more than 5 tons per day of sulfur from existing plants regardless of the H 2S content of the gas. The level of control assumed to be the floor will be the most stringent of all of the potential regulatory requirements. However, the application of the potential floor procedures can result in no SO 2 controls having to be applied on some sources. For example, the Duke Energy Artesia plant in New M exico processes less than 2 long tons per day of sulfur (this is equivalent to about 1,600 tpy of SO 2 emissions) and therefore the NSPS does not apply. State regulations do not apply, since the sulfur throughput is below the regulatory threshold. The floor for this plant is based on the average emissions over the past three years. VII-2 2. Specific Example The Burlington Northern Lost Cabin facility in Wyoming provided additional inform ation needed to dem onstrate how the floo r calculations could be applied to a specific facility. Th e Lo st Cabin facility consists of two existing gas pro cessing lines with a capacity of 133 MM CF/day and has one new train with a capacity of 133 MM CF/day. Both lines process a gas with a methane concentration of 68 percent, a carbon dioxide concentration of 20 percent, and an H 2S con tent of 12 percen t. Each train is controlled b y a three stage C laus unit followed by a SCO T tail gas unit. The unit is requ ired to hav e a conversion efficiency of 99.8 percen t. Plantwide em issions are limited to 642 lbs/hr and 1,367 tpy. The plant underwent a BACT review under PSD and exceeds all requirements of the NSPS. Under the NSPS, a reduction of 97.5 percent would have been required since the H 2S content of the acid gas stream is 37 percent (which is defined as the gas stream leaving the am ine regenerator and can be calcu lated as the ratio of the acid gases [H 2S and CO 2] in the in put gas stream ) and the su lfur production exceeds 300 lon g tons per day (see Ta ble VII-1). Since the required reduction exceeds the floor level, the permitted levels represent the floor. Since much of the plant is new, no data on upset emissions is available. Emissions from w ell-field activities are very variable. We lls are very large at this plan t and on e very large well can have up to 1,000 tons of emissions. The plant estimates that annual SO 2 emissions of about 500 tpy from w ell field activities can be expected. D. COMPARISON WITH HISTORICAL EMISSIONS Table VII-3 summ arizes historical SO 2 em issions from natu ral gas processing plants located in th e 9 W RA P States. California facilities are in cluded in th is table. This ta ble provides a point of comparison with the floor allocations shown in Tab le VII-2. For Wyom ing, the historic emissions are close to floor for most sources due to the high level of control. However, a direct comparison is difficult since the historical emissions may include well field and upset emissions. Two New M exico sources will require additional control or additional emission allocations. VII-3 Table VII-2 Possible Floor - Natural Gas Processing Units State NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM UT WY WY WY WY WY WY WY WY WY WY WY Plant Conoco-Maljamar W estern Gas Reso urces Agave Energy Duke Energy Eunice Duke Energy Arte sia Dynergy Midstream Monument Dynergy Midstream Sau nde rs Duke Energy Pla nt 5 Sid Richardson JL Davis Gas Processing Denton Plant M ara thon Oil Duke Energy Lee Gas ARCO Permian Empire Abo Plant Duke Energy Bu rton Fla ts Duke Energy Dagger Draw Plant Duke Energy Huber Gas Plant Tom Brown- Lisbon Plant Ho we ll Pe troleu m - Elk B asin Burlington Resources Lo st C ab in Burlington Resources Lo st C ab in KC S M ou ntain Ains worth Flare KC S M ou ntain Ru shm ore F lare Ma rathon Pitchfo rk Ba ttery Exxon Shute Creek Exxon Shute Creek Amoco W hitney Canyon Amoco W hitney Canyon Texaco Byron Current % Reduction 0 90 0 90 Pe rm it Emissions 3,574 3,127 2,983 2,756 Floor Emission Reduction 87 90 86 .3 90 Po ss ible SO 2 Floor (tpy) 222 3,127 365 2,250 Plant 0 1,459 0 1,192 31000208 Plant 90 1,431 90 675 31000208 Plant 90 1,387 90 163 31000205 Plant 96 .4 1,300 96 .4 1,181 31000201 31000205 Plant Plant 91 .7 0 1,206 1,158 91 .7 0 1,206 840 31000201 31000299 Plant Plant 90 93 1,100 818 90 93 665 04 31000208 Plant 96 565 96 431 31000205 Plant 0 246 0 164 31000208 Plant 98 243 98 218 31000205 Unknown 0 231 0 163 SCC 31000028 31000208 31000205 31000208 Emission Source (Process vs Flare) Plant Plant Plant Plant 31000208 2 Plant Plant Plant 95 93 .5 99 .8 1,593 1,200 1,3672 95 93 .5 99 .8 1,593 1,200 1,367 Flare 0 500 1 0 500 31000205 Flare 0 843 0 843 31000205 Flare 0 118 1 0 118 0 99 .7 0 99 0 0 61 1,206 330 5,379 223 200 31000205 31000205 31000205 31000205 31000205 31000205 31000205 Flare Plant Flare Plant Flare Plant VII-4 0 99 .7 0 99 0 0 1 61 1,206 330 1 5,379 223 1 200 Table VII-2 (continued) State WY WY WY WY WY WY WY WY Plant Chevron Carter Creek Chevron C arter Creek Hallwood Petroleum Federal Packsaddle 1-24 Hallwood Petroleum Federal Packsaddle 1 Oregon Basin Gas Plant KC S G old E agle Flare Interenergy Hiland Gas Plant M ara thon Oil Mill Iron Em iss ion To tals Floor Emission Reduction Po ss ible SO 2 Floor (tpy) 0 0 0 200 133 960 1 0 960 90 0 0 391 790 281 1 90 0 0 391 790 281 0 247 0 247 SCC 31000205 31000205 31000205 Emission Source (Process vs Flare) Plant Flare Flare Current % Reduction 99+ 0 0 Pe rm it Emissions 03 200 133 31000205 Flare 0 31000205 31000205 31000205 Plant Flare Flare 31000205 Flare 39,606 28,884 NOTES: 1. Only one year of data available; 2. Floor based on permit levels; 3. Plant does not incinerate tail gas - no SO 2 emitted; 4. Plant has no emissions listed for the past three years. State SO 2 floor alloc ations bas ed o n the e stima tes in this tab le are N M (1 2,862 tpy), UT (1,5 93 tpy), an d W Y (14,42 9 tpy). VII-5 Table VII-3 Oil and Gas Production - Historical Emissions - 1990 to 2000 Sta te Co unty Fac ility IAS Region SIC ID ID Sta te ID Current Facility Name (if different from 1990) MTF Sector Sector Description Facility Name (1990) CA 6 029 1141 13 1311 6 Oil/Gas SAN T A F E EN E R G Y CA 6 029 1129 13 1311 6 Oil/Gas T E X A C O EX P LO R & P R O D IN C 1,539 855 2,050 2,050 1 89 112 63 CA 6 029 206 13 1311 6 Oil/Gas CA 6 019 71 12 1311 6 Oil/Gas BER R Y PET R O LEU M C OM P AN Y 237 0 0 0 C H E V R O N U S A IN C . - C O A L IN G A 809 0 0 CA 6 029 272 13 1311 6 Oil/Gas M H W H I T T IE R SENECA RESOURCES 347 0 0 CA 6 053 19 12 1311 6 Oil/Gas M O B IL O IL C O RP - S A N A RD O A E R A EN E R G Y 304 0 1 6 CA 6 029 1135 13 1311 6 Oil/Gas S H E L L K E R N R ID G E AERA ENER GY LLC 294 <100 82 55 CA 6 019 64 12 1311 6 Oil/Gas S H E LL W E S T E R N E& P IN C . - C O A LIN G A CA 6 029 331 13 1311 6 Oil/Gas S W E P I- W E S T C O A S T D IV IS IO N CA 6 053 30 12 1311 6 Oil/Gas T E XA C O IN C - S A N A RD O CA 6 029 299 13 1311 6 Oil/Gas U N O C A L - B A K E R S F IE L D T E X A C O C A IN C S O 2 tpy S O 2 tpy S O 2 tpy S O 2 tpy 2000 1998 1996 1990 144 0 0 AERA ENER GY LLC 775 <100 10 100 <100 36 U N O C A L O IL & GA S D IV IS IO N 159 0 0 32 CA 6 059 42775 14 1311 6 Oil/Gas W E S T N EW P O R T O IL C O 297 <100 10 11 CO 8 045 24 51 1311 6 Oil/Gas UNOCAL RETORT-PARACHUTE 679 0 0 0 CO 8 045 0025 51 1311 6 Oil/Gas UNOCAL UPGRADE 177 0 0 0 NM 35 015 0024 65 1311 6 Oil/Gas A G A V E E N E R G Y /Y A T E S P LA N T 962 962 962 2,983 NM 35 015 0002 65 1311 6 Oil/Gas A R C O P E R M IA N /E M P IR E A B O G A S P LN T 700 565 565 565 NM 35 015 0006 65 1311 6 Oil/Gas G P M G A S /IN D IA N H IL L S A M IN E P L N T 900 450 450 900 NM 35 025 0046 65 1311 6 Oil/Gas G P M G A S /L E E G A S PL A N T 818 0 818 818 NM 35 025 0007 65 1311 6 Oil/Gas J .L . D A V IS G A S PR O C E S S /D E N T O N 385 890 891 1,158 NM 35 025 0052 65 1311 6 Oil/Gas T E X A C O /E U N IC E N O R T H G A S P LA N T 673 1,076 1,346 673 NM 35 025 0051 65 1311 6 Oil/Gas T E X A C O /E U N IC E S O U T H G A S P LA N T 4,019 4,386 3,355 5,476 NM 35 015 0003 65 1311 6 Oil/Gas T R A N S W E S T E R N P I PE 221 231 231 231 D U K E E N E R G Y /H U B E R G A S NM 35 041 0001 63 1311 6 Oil/Gas W A R R E N P E T R O LE U M /B L U IT T G A S P LA N T NM 35 025 0061 65 1311 6 Oil/Gas W A R R E N P E T R O LE U M /M O N U M E N T P LA N T M O N U M E N T P LA N T 270 3,348 582 270 1,460 1,709 1,432 1,432 5,475 980 980 3,138 291 0 NA NM 35 045 0247 60 1311 6 Oil/Gas W E S T E R N G A S P R O C E SS O R S /S A N J U A N RV R NM 35 025 0128 65 1311 6 Oil/Gas C IT A T IO N / AN T E L O P E R D G G A S P L A N T NM 35 025 0118 65 1311 6 Oil/Gas CON OCO /BELL LAKE 2 W ELL #6 129 0 NA NM 35 015 0125 65 1311 6 Oil/Gas FEAGA N ENE RGY/W DAGG ER DR AW GAS P LT 240 0 NA NM 35 005 0050 65 1311 6 Oil/Gas Y A T E S P E TR O L E U M /P A T H F IN D E R A M IN E 227 57 57 VII-6 Table VII-3 (continued) Sta te Co unty Fac ility IAS Sta te ID ID ID Region SIC UT 49 037 35 MTF Sector Sector Description Facility Name (1990) 1311 6 Oil/Gas Current Facility Name (if different from 1990) U N O C A L C O R P O R AT IO N T O M B R O W N - L IS B O N P L A N T H O W EL L P ET R O LE U M - EL K B AS IN WY 56 029 0012 9 1311 6 Oil/Gas AM O C O - E LK BA SIN WY 56 041 0012 9 1311 6 Oil/Gas A M O C O - W H I T N EY C A NY O N S O 2 tpy S O 2 tpy S O 2 tpy S O 2 tpy 1990 1996 1998 2000 1,575 1,391 1,478 1,252 1,096 1,218 1,422 2,638 6,401 5,835 11,130 6,889 WY 56 041 0009 9 1311 6 Oil/Gas CHEVRON - CARTER CREEK 1,537 1,165 3,330 2,096 WY 56 023 0013 8 1311 6 Oil/Gas E X XO N - S H U T E C R E E K 1,078 1,999 2,015 1,383 1311 6 Oil/Gas EXXON BLAC K CAN YON DE HY & W ELL FIELD 9 1311 6 Oil/Gas KCS MO UNTA IN RESOU RCES - GOLDEN E AGLE 558 942 9 1311 6 Oil/Gas K C S M O U N T A I N R E S O U R C E S - A IN S W O R T H 807 845 0 9 1311 6 Oil/Gas MA R AT H O N G AS PL AN T - O R EG O N BA SIN 456 388 358 9 1311 6 Oil/Gas M A R A TH O N O IL - M IL L IR O N 9 1311 6 Oil/Gas T E X A S -B Y R O N P LA N T WY 56 WY 56 017 WY 56 003 WY 56 029 WY 56 017 WY 56 003 0007 0012 167 406 17 234 260 0 B IG H O R N G AS P R O C ES S IN G - B Y R O N 192 169 605 257 415 331 576 WY 56 037 0008 9 1311 6 Oil/Gas U N IO N P A C - B R A D Y R M E PET R O L E U M - B R A D Y WY 56 013 008 9 1311 6 Oil/Gas D E V O N SF S O PE R A T IN G C O . BEAVER CREEK 300 831 WY 56 037 0014 9 1311 6 Oil/Gas C O L O R A D O IN T E R S T A T E G A S - T A B L E R O C K 522 20 39 WY 56 003 0013 9 1311 6 Oil/Gas M A R A T H O N O IL C O M P A N Y - G A R L A N D 257 7 10 WY 56 013 9 1311 6 Oil/Gas LO U ISIA N A L AN D & E XP LO R - LO ST CA BIN 4,547 1,336 1,700 34,735 38,346 37,749 BU R LIN G TO N RE SO U R C ES -LO ST CA BIN 36,111 VII-7 VII-8 CHAPTER VIII ELEMENTAL PHOSPHORUS PRODUCTION A. SECTOR DESCRIPTION AND SIGNIFICANT SO2 SOURCES P4 Production has an elementa l phosphorus facility near Soda Springs, Idaho. This is one of the two elemental phosphorus production facilities in the United States. Year 2000 SO 2 emissions from this facility are estimated to be 15,861 tpy. This reflects increased utilization compared with 1996 and 1998 operations. This facility has no SO 2 emissions limit in its operating perm it. The Idah o Departme nt of E nvironm enta l Qu ality is cu rrently evaluating this facility’s SO 2 emissions situation. For the purposes of this report, the floor allocation for P4 Production is set at its year 2000 SO 2 em issions level of 15,861 tons. It is expected that th e State of Ida ho w ill perform a m ore detailed evalua tion of this facility during preparation of its reg ional haze State Im plementation P lan (SIP ). B. FLOOR ALLOCATION ESTIMATION PROCEDURES Recent historical emissions for P4 Production are listed below in Table VIII-1. VIII-1 Table VIII-1 Elemental Phosphorus Production - Historical Emissions - 1990 to 2000 Sta te ID MTF Sta te Co unty Fac ility IAS Region SIC Sector Sector Description ID ID ID 16 029 0001 7 2819 5 Chem icals/Plastics Facility Name (1990) M O N S A NT O /P 4 PR O D U C T IO N VIII-2 Current Facility Name (if different from 1990) P 4 PR O D U C T IO N S O 2 tpy 1990 7,543 S O 2 tpy 1996 7,988 S O 2 tpy 1998 7,601 S O 2 tpy 2000 15,861 CHAPTER IX GLASS MANUFACTURING A. SECTOR DESCRIPTION AND SIGNIFICANT SO2 SOURCES The air emissions from glass manufacturing are in three zones: (1) raw material blen ding and transport, (2) m elting, and (3) form ing a nd finishing. The m ajority o f air emissions are in the melting furnace operation. Melting for container and flat glass is generally conducted in a continuous reverbatory furnace fired by natural gas or oil. Electric boost furnaces have been introduced in some o perations to minimize flue gas emissions. The major source of SO 2 emissions in the glass industry is the glass melting operation. Forming and annealing operations are minor sources. Furnace emissions appear to be attributable to both the m anu facturin g process and th e fuel burn ed. Fuelderived SO 2 emissions are lower from natural gas-fired furnaces than from oil-fired furnaces, unless the oil has been desulfurized. Flue gases from furnaces burning natural gas have been reported to contain 2 parts per million (ppm) SO 2, or less. About 600 ppm SO 2 can be expected in flue gas from a furnace burning fuel oil containing one percent sulfur. Greater use of electric furnaces or electric boosting may decrease SO 2 emissions. Process modifications that may reduce SO 2 emissions include altering the raw material charge to reduce the sulfur content or to increase the fraction of recycled glass, changing the furna ce controls or equipment, and altering the pull rate. Process modifications that redu ce the salt cake conten t in the raw batch can significantly reduce SO 2 emissions. For exam ple, one C alifornia flat-glass plant reportedly redu ced furna ce emissions of SO 2 by 78 percent from 2.1 to 0.5 kilogra ms pe r megagram (kg/Mg) (5.0 to 1.1 lbs/ton) by reducing the salt cake in the raw batch 60 percent (from 12 to 5 kg/Mg, 30 to 12 lbs/ton of san d). Similarly, an other California flat-glass plant has reportedly re duced its SO 2 emissions 75 percent (from 1.6 to less than 0.4 kg/M g, 4 to less than 1 lbs/ton of ba tch constituen ts) by reducin g the inpu t of salt cake. Glass quality was not com prom ised in either case. The salt cake cannot be reduced below certain minimums without effecting glass qua lity. The m inim um salt cak e required varies depending u pon furna ce type , pull rate, glass type, and other variables. Fuel changes have also been shown to reduce SO 2 emissions. These include switching to natural gas or low-sulfur fuel oil, switching to all-electric melting, and using electric boosting for melting. Electric melters significantly reduce SO 2, NO x, and particu late emissions beca use they elim inate the combustion of fossil fuels. Electric melting also is reported to minimize SO 2 and other gaseous losses from the vaporization of raw materials because the surface of the melt is insulated by a semisolid crust. Gases discharg ed through the crust of the m elt consist main ly of carbo n dioxide and w ater. Today, borosilicate, opal, and green glass are produced with electric furnaces. The capacities of such furn aces a re about 100 to 110 Mg/day (110 to 120 tons/day). E lectric melters have n ot been dem onstrated for larger operations, such as large container furnaces, the nom inal capacities of which are ab out 220 M g/day (240 tons/day), and flat-glass furn aces, which range from about 600 to 800 M g/day (66 0 to 880 tons/day). Several emission control systems that are available to the glass industry for particulate control are also capable of achieving various levels of secondary SO 2 con trol. For example, a venturi scrubber system can control SO 2 emissions from com mercial glass plants. Th e system includes a packed tower w here part of the sulfate particulates are removed from the hot furnace flue gases, a dual-throat venture scrubber, where SO 2 and IX-1 additional particulates are rem oved by alkaline w ashing, and a cyclone for fina l particulate collection . Currently, only th e con tainer glass segm ent of the gla ss industry is reported to use scrubber sy stem s for em ission control. Injectin g a sorben t such as alu mina, lim eston e, or nepheline syen ite into a fabric filter system can effectively remove SO 2 from furnace flue gases. The spent sorbent may be landfilled or possibly recycled. One patented system of dry removal involves the combined use of hydrated lime and nephelin e syenite for acid gas neutra lization and fine particle agglomeration. In th is system , hot furnace flue gas is first mixed with q uench water, hydrated lime for primary SO 2 removal, and secondary air to cool the gas stream to a temperature range of 94 o to 427 oC (200 o to 800oF). Next, nepheline syenite is added to the gas stream to capture residual SO 2 and su bm icrometer particulates. Th e gas stream enters the fab ric filter wh ere the solid product is removed for either recycling to the furnace or landfilling. Dry sorbent systems at several commercial glass furnaces reduced SO 2 by 80 to 95 percent at a container glass furnace, 50 to 90 percent at a fiberglass furnace, and 88 to 98 percent at a flat-glass furnace. Mist eliminators apparently have no effect on SO x gases. One sam pling test indicated no decrease in SO 2 and SO 3 concentrations through the control device (EPA, 1981). B. FLOOR ALLOCATION ESTIMATION METHODS It is expected that the floor allocation for glass manu facturing plants will be set according to recent historical SO 2 emissions from these facilities. These SO 2 emissions are listed in Table IX-1. REFERENCES AWM A, 2000: Air and Waste Management Association, “Air Pollution Engineering Manu al,” 2 nd edition, Chapter 15 - Mineral Products Industry, 2000. EPA , 1981: U.S. Environmental Protection Agency, “Control Techniques for Sulfur Oxide Em issions from Stationary Sources,” Secon d Edition, EPA-450/3-81-004, O ffice of Air Quality Planning and Standards, Research Triangle Park, NC, April 1981. IX-2 Table IX-1 Glass Manufacturing - Historical Emissions - 1990 to 2000 Sta te Current Facility Name (if different from 1990) MTF IAS Sta te Co unty Fac ility Region SIC Sector Sector Description Facility Name (1990) ID ID ID CA 6 037 106797 14 3221 8 Glass B A L L- FO S T E R G L A S S C O N T A IN E R C O CA 6 099 1662 11 3221 8 Glass G A L L O G LA S S C O CA 6 039 801 12 3221 8 Glass M AD ER A G LASS C OM PA N Y S A IN T -G O B A IN C O N T A IN E R O W E N S -B R O C K W A Y G L A S S C O N T A IN E R Floor S O 2 tpy S O 2 tpy S O 2 tpy S O 2 tpy 2000 Allocation 1998 1996 1990 <100 <100 166 61 271 269 174 440 108 170 190 104 CA 6 077 593 11 3221 8 Glass O W E N S IL L IN O IS 319 285 218 248 CA 6 037 7427 14 3221 8 Glass O W E N S - B R OC K W A Y G L A SS C O N T AIN E R - V E R N O N 193 323 280 435 CA 6 001 2086 11 3221 8 Glass A N C H O R G L A S S C O N T A IN E R C O R P O R A 119 0 0 122 128 64 57 159 221 234 255 237 103 169 116 108 131 1,284 1,667 1,537 1,821 CA 6 001 30 11 3221 8 Glass O W E N S -B R O C K W A Y G L A S S C O N T A IN E R - O A K L A N D CO 8 059 0008 53 3221 8 Glass COORS GLASS OR 41 051 1876 5 3221 8 Glass Owens-Brockway Glass Container, Inc. ROC KY MOU NTAIN BOT TLE IX-3 IX-4 CHAPTER X COPPER SMELTERS A. SECTOR DESCRIPTION AND SIGNIFICANT SO2 SOURCES Prim ary copper smelters in the W RA P States process copper sulfide ore conce ntrate to produce anode copper. There are six primary copper smelters in the WR AP region. Five of th e prim ary copper sm elte rs are n ear the copper m ine s in the sou thw est United States. These smelters use a batch copper converting process (either Pierce-Smith or Hoboken converter designs) to produce blister copper. Curren tly, only two o f these sm elters are producing copper (the ASAR CO sm elter in Hayden, Arizona and the Phelps Dodge smelter in Miami, Arizona). The other three smelters have suspended operations and are not producing copper at this time. The sixth primary copper smelter in the WRAP States is the Kennecott Utah Copper Corporation near Garfield, Utah. The Kennecott smelter was built during the mid-1990s (rep lacing the existin g sm elte r at the site) an d uses a fla sh copper converting techn ology. This technology allow s blister copper to be produced in a con tinuous process. All primary copper smelters in the region control SO 2 emissions by routing the process off-gases from the sm elting and converting processes to double contact sulfuric a cid plants. B. FLOOR ALLOCATION ESTIMATION METHODS Because of the uniqueness of the existing copper smelters, retrofit technology analysis must be performed on a smelter-by-smelter basis. Currently, the Hidalgo smelter is the only BAR T-eligible source in this category. A double contact acid plant is considered the appropriate retrofit con trol equipm ent (all smelters in the w estern States are cu rrently equipped with double contact acid plants). On August 21, 2000, New M exico completed an engineering analysis that verified earlier determinations by the MTF that the fugitive SO 2 capture system at Hidalgo satisfies BART at 96 percent overall SO 2 capture. The Annex to the Grand Canyon Visibility Transport Commission’s (GCVTC) recommendations defines stepped reduction milestones through 2018 for SO 2 emissions from large industrial sources in the 9-State Commission Transport Region. The current year SO 2 allocation for the six copper sm elters in the 9-State re gion is 86,000 tons. This allocation is reduced to 78,000 tons by 2013 and is the same in 2018. For the recent Emission Forecasts to 2018 analysis, the plant-level difference SO 2 emissions difference between 86,000 tons and 78,000 tons was simulated by subtracting 2,000 tons each from the four largest smelters, which are ASAR CO-Hayden , BHP-San M anuel, Phelps-Dodge Chino Mines, and Phelps Dodge-Hidalgo. The resulting allocations of 2018 SO 2 emissions by facility are shown in Table X-1. Note that the 78,000 tons of SO 2 allocation for copper smelters is a n ag gregate value for the region, rather tha n a re quire ment for each smelter to reduce emissions to prescribed levels. Table X-1 illustrates one way that this regional allocation might be met. Many other examples are provided in the EPA regional haze rule. X-1 Table X-1 Copper Smelter SO2 Emission Projections (tpy) State F ac ility N am e 2018 AZ ASARCO Smelter-Hayden 21,000 AZ BHP-San Manuel 14,000 AZ Cyprus Miami Mine NM Phelps Dodge-Chino Mines 14,000 NM Phelps Dodge-Hidalgo Smelter 20,000 UT Kennecott Utah Copper Corp. 1,000 Total Copper Smelter C. 8,000 78,000 COMPARISON WITH HISTORICAL EMISSIONS Table X-1 SO 2 em ission estim ates ca n be com pared with recent historical (1990 to 2000) emissions for those smelters shown in Table X-2. X-2 Table X-2 Recent Historical Copper Smelter SO2 Emissions State State Co unty Fac ility IAS ID ID ID Region SIC MTF Sector Sector Description Facility Name (1990) Current Facility Name SO 2 tpy (if different from 1990) 1990 SO 2 tpy 1996 SO 2 tpy 1998 SO 2 tpy 2000 Smelter Sector AZ 4 007 0004 45 3331 2 Copper ASARCO SMELTER - HAYDEN AZ 4 021 0032 46 3331 2 Copper BHP (Magm a Metals) AZ 4 007 0006 45 3331 2 Copper C Y PR U S M IA M I M IN E AZ 4 019 0040 46 1021 2 Copper Cyp rus Sie rrita NM 35 017 0001 64 3331 2 Copper PHELPS DODGE/CHINO MINES BHP - San Manuel 29,814 33,124 22,077 16,753 15,900 16,678 10,409 0 5,676 5,737 6,097 6,810 800 548 <100 <100 28,058 14,784 15,685 11,420 NM 35 023 0003 64 3331 2 Copper PHELPS DODGE/HIDALGO SMELTER 41,433 32,121 29,188 0 UT 49 035 0030 32 3331 2 Copper Kennecott Utah Copper Corp. 26,829 1,556 762 937 148,510 104,549 84,218 35,920 X-3 X-4 CHAPTER XI ALUMINUM PRODUCTION A. SECTOR DESCRIPTION AND SIGNIFICANT SO2 SOURCES Primary aluminum production plants in the United States produce aluminum m etal by electrolytically reducing alumina that have been refined from bauxite ore. There are 23 primary aluminum plants in the United States. There are only 2 plants in the study region and both are located in Oregon. Aluminum production is carried out in a sem ibatch ma nner in la rge electrolytic ce lls called pots w ith a direct current input o f up to 280,000 amperes at about 5 volts. T he pot, a rectangular steel shell ranging in size from 30-50 feet long, 9-12 feet wide, and 3-4 feet high, is lined w ith a refractory insu lating shell on which carbon blocks are placed to form the cathode. An aluminum pot will typically emit 20-35 kg per metric ton of gaseous and particu late fluoride and roughly a n eq ual a moun t of particu late m atter. The N SPS lim its emissions to no more than 1 kg fluoride/Mg (2.0 lbs/ton) of aluminum produced for potroom groups at Soderberg plants, 0.95 kg/Mg (1.9 lbs/ton) of aluminum produced at pre-bake plants, and 0.05 kg/Mg (0.1 lbs/ton) of aluminum equivalent for anode bake plants. The reduction cells in use for aluminum production in the United States are of two basic types – prebak e and Soderb erg. There are two types of So derberg cells that are designated according to the manner of mounting the stud in the carbon anode: vertical stud Soderberg (V SS) or horizontal stu d So derberg (H SS). Prebake cells are so named because the anodes are preformed and then baked in a separate facility often referred to as an ano de bake plant. The ano des are then m oun ted in the cell and are consumed in the alum inum production . The ano de butts, which rem ain after the anode is consum ed, are recycled for use in the preparation of new anodes. In the Soderberg process, continuously formed, consumable anodes are used. The ano de pa ste is ba ked by the heat genera ted in the reduction cell. The primary source of sulfur oxide emissions in aluminum production is the sulfur in the coke (normally petroleum coke) and the coal tar pitch binder used to produce the anodes. In the prebake process, the combustion fuel to bake the anodes may be a significant SO 2 emission source. Petroleum coke usually con tains 2.5 to 5 percent su lfur, but may vary from 1.5 to 7 percent sulfur. Pitch normally contains about 0.5 percent sulfur. The sulfur content of the coke depends on the crude petroleum stock and the tendency of the sulfur to concentrate in the still bottoms at the refinery and thus in the coke. As the coke is processed (during prebake) or consumed in the reduction cell, sulfur oxides are released. The em issions include those from the anode prebake operation (prebake), the “prim ary” em issions (w hich are captured by the pot h ood exh aust system ), and the “secondary” emissions (which escape the primary exhaust system and exit through the roof monitors). The great majority of SO2 emissions are collected by the pot hood exhaust system. One source reports uncontrolled SO 2 emissions from anode bake plants range from 5 to 47 ppm, which is 0.7 to 2 kg SO 2/Mg aluminum produced (1.4 to 4 lbs SO 2/ton aluminum XI-1 produced). Other data indicate that emissions are in the range of 0.09 to 1.7 kg SO 2/Mg aluminum produced (0.18 to 3.4 lbs SO 2/ton aluminu m produced). The total amount of SO 2 generated per unit of aluminum produced is essentially the same for the prebake, VSS, and HSS cases. The “primary” cell hooding configuration for collection of process fum es is affected by the chara cteristics of the different cell types. There are two types of prebake cells, center-worked prebake cells (CWPB ) and side-worked prebake cells (SW PB ), as we ll as the two Soderberg processes, VSS an d HSS, w hich are in use by the domestic alu minum indu stry. Inform ation from seven prim ary alum inum plants indicates the following: Cell Type CWPB SWPB VSS HSS Primary Hood Collection Efficiency, % 65 to 98 85 81 80 to 95 Prim ary C ollector Exhau st Rate (106 square cubic feet per ton of aluminum) (4.11 to 5.05) (3.44) (0.67) (5.06 to 7.85) Th is inform ation in dicates th at the ga s volum e associated with th e produ ction of a fixed amount of aluminum is in the range of 5 to 12 times (average 8 times) greater for CWP B, SWPB, or HSS than for VSS. Consequently, the concentration of SO 2 in a volume of exhaust gas in the primary collector system can be expected to be about 8 times greater for a VSS unit than for other units. Reported data on uncontrolled “primary” exhaust system SO 2 emissions are as follows: Un it Prebak e Cell VSS Cell Source A B SO 2 Concentration, ppm 5 Not reported C A B C Not reported 80 200 to 300 200 (average) Total SO 2 emissions, kg SO 2/Mg Aluminum (lbs SO 2/ton aluminum) Not reported 20.9 to 23.4 (41.7 to 46.8) [ave rage of 2 2.4 (4 4.8)] 30 (60) [3% sulfur in the coke] Not reported 17.5 to 25 (35 to 50) Not reported Th e trend in con stru ction of new alu minu m plants is toward prebake system s. A major factor influencin g this trend is th e low er power requ irem ent of the prebake cell compared with Soderberg cells. It is reported that 9 of the 11 aluminum plants opened since 1960 are of the prebak e type, and 99 percent of the 324 G igagrams (357,000 tons) capacity added since 1973 has been at prebake facilities. Of the 23 primary aluminum production plants in the Un ited States, 18 u se the prebake process an d 5 use the Sod erberg process. B. FLOOR ALLOCATION ESTIMATION METHODS There are two alu minum smelters located within the study region, and they are both located in O regon. Th e data provided by the Oregon D epartme nt of E nvironm enta l Qu ality on the unit capacities and SO 2 em issions potential for these two smelters is provided in Table XI-1. This table shows that the SO 2 em issions potential for Reynolds M etal, if operated at its design capacity, is 4,700 tpy. This is the same as their permitted SO 2 emission limit. For NW Aluminum, the SO 2 emissions potential is 518 tpy. XI-2 The NSP S for primary aluminum plants limits fluoride emissions, but does not affect SO 2 emissions. Washington is the only State that has established an SO 2 emission limit sp ecifically for prim ary alum inum plants. The rule lim its the m axim um allow able total SO 2 emissions from all sources within the plant to 60 lbs per ton of aluminum produced on a monthly basis. Based on the SO 2 emission rates by process for Reynolds Metal, which is 65.3 lbs SO 2 per ton of aluminum produced, applying the State of Washington rule would only provide an 8 percent reduction in SO 2 emissions. Comparing the capacity-based SO 2 emission estimates in Table XI-1 with recent historical emissions (see Table XI-2) shows that recent historic SO 2 emissions from Reynolds Metals are considerably below their capacity/permitted emission limit, and that they vary considerably from year-to-year. NW A luminum SO 2 emissions in the period 1996 to 2000 average about 80 percent of total capacity. The floor control technology for aluminum smelters was determined by evaluating the emissions performa nce of Reyno lds Metals and N W A luminu m. NW Alum inum uses a wet scrubber to achieve a 70 percent SO 2 emission reduction. Therefore, a wet scrubber with a 70 percent SO 2 reduction was selected as the floor technology for aluminum smelters. The effect of this floor technology application is shown in the rightmost column of Table XI-1. REFERENCES CFR , 2001: Code of Federal Regulations, “Subpart S - Standards of Performance for Primary Aluminum Plants (60.190-60.195),” July 1, 2001. EPA , 1981: U.S. Environmental Protection Agency, “Control Techniques for Sulfur Oxide Em issions from Stationary Sources,” Secon d Edition, EPA-450/3-81-004, O ffice of Air Quality Planning and Standards, Research Triangle Park, NC, April 1981. XI-3 Table XI-1 Aluminum Plant Data Used to Estimate Floor Allocations Company Em iss ion s U nit Fuel Type Re ynold s M etals Carbon bakes Potroom fugitives Potroom emissions Backup fuel Plant total Natural gas N/A N/A #2 fue l oil Cell line Cell line Casthouse furnace Plant total N/A Propane Natural gas NW Aluminum Actual Ca pac ity Ca pac ity Un its Control Device N/A N/A 97,500 144,000 80,000,000 TA P/yr ga llon s/yr cu bic fee t/yr W et scrubber No No Total SO 2 Emission Factors (lbs/ton) 0.18-.19 2.5 62 .5 0.105 SO 2 Control Efficiency N/A N/A 0.7 N/A N/A SO 2 Emissions Actua l Cap acity (tons/yr) Floor Allocation at 70% Control (tons/yr) 27 177 4,488 7.5 4,700 27 177 1,346.4 7.5 1,557.9 517 <0.1 1 <518 517 <0.1 1 518 5,218 2,076 N O T E S : C o n tr ol D e v ic e : W h ile th e re a re n o p h ys ic a l c o nt ro l d e vic e s, th e m os t e ff ec tiv e fo rm o f S O 2 control is limiting the amount of sulfur in fuel oil. For example, the sulfur c o nt en t in d is tilla te fu e l o il s o ld in N W u s ua lly a ve ra g es m u c h le s s t ha n 0. 1, w he re a s t he ru le lim i t is 0 .5 . A c tu a l C a p ac it y E m i ss io n is lim i te d by th e S O 2 P S E L . S O 2 emission factors are in lbs per ton of aluminum produced. XI-4 Table XI-2 Aluminum Smelting - Historical Emissions - 1990 to 2000 Sta te Sta te ID Co unty ID Fac ility ID IAS Region SIC MTF Sector Sector Description Facility Name (1990) Current Facility Name (if different from 1990) SO2 tpy 1990 SO2 tpy 1996 SO2 tpy 1998 SO2 tpy 2000 1 0 0 t py o r M o r e S O 2 OR 41 065 0001 5 3334 10 Me tals /Min ing /Min era ls Northwest Aluminum Com pany, Inc. OR 41 051 1851 5 3334 10 Me tals /Min ing /Min era ls Reynolds Metals Company XI-5 423 448 375 397 3,340 0 503 1,510 3,763 448 878 1,907 XI-6 CHAPTER XII SULFURIC ACID PLANTS Sulfu ric acid is th e m ost widely u sed in dustrial chemical. Th e chief uses of sulfuric acid are in production of fertilizer, manufacture of chemicals, oil refining, pigment production, iron and steel processing, synthetic fiber production, and metallurgical operation s. The predom inant process used for the production of sulfuric acid is the contact process. The entire discussion in this chapter focuses on the contact process. Sulfuric acid is produced by burning sulfur or sulfur-bearing materials to form SO 2. Sources of SO 2 include: (1) elemen tal sulfur; (2) spent acid; (3) smelter off-gas; (4) pyrites; and (5) waste gas from fossil-fuel-fired boilers. A. SECTOR DESCRIPTION AND SIGNIFICANT SO2 SOURCES Contact sulfuric acid plants are classified as hot gas (sulfur burning) or cold gas (metallurgical and spent acid) systems. Plants operating on elemental sulfur receive hot SO 2 gas directly from the sulfur burner and waste heat recovery system. When SO 2 gas from a m etallurgical operation or other byproduct source (such as spent acid or iron pyrites) is used, it is received cold from the w et scrubber-cooler and purification systems. A basic variation of the contact process is the double absorption technique, also known as double catalysis. This design is largely based on the need to meet air pollution control regulations. The only significant source of air emissions from a contact sulfuric acid plant is the tail gas leaving the final absorbing tower. This gas contains small amounts of SO 2 and even smaller amounts of SO 3, sulfuric vapor, and sulfuric acid m ist. SO 2 emissions are determined primarily by overall plant design (e.g., number of catalyst passes, am oun t of catalyst, dual or sing le absorption, etc.). New plants are u sually designed to meet N SPS em ission limits u sing th e dual ab sorption process. In ce rtain situ ations, plants can achieve bette r than NSP S limits u sing th e dual ab sorptio n process. For example, in a metallurgical acid plant, lower SO 2 emissions can sometimes be achieved catalytically if the process gas from a smelter has a sufficiently high oxygen-to-SO 2 ratio. Proper catalyst volumes and interpass cooling can be incorporated into the initial design, however. Existing plants that are required to reduce their SO 2 em issions usu ally ch oose to convert to dual ab sorption or install a tail gas scrubber. Dual absorption has been generally accepted as BACT. Conceptually, dual absorption is the addition of an other converter and ab sorb ing tow er on the tail end of a single absorption plant (with appropriate heating and cooling of the gas stream ) so there is no new technology involved. Only sulfuric acid is produced in the dual absorption equ ipm ent. Various scrubbing, or tail gas, technologies are available for removing SO 2 from gas stream s. Tail gas trea tme nt is rarely used to achieve NSPS limits for new plants. A tail gas process at the en d of a dual absorption plan t may be the preferred techn ology w here local regulations require substantially lower than NSP S em ission rates. Tail gas processes that produce a by-product that can be recycled to the acid plant (e.g., wea k sulfuric acid) are of special interest beca use they elim inate the n eed for off-site by-product disposal. Two such processes are hydrogen peroxide scrubbing and SO 2 oxidation with activated carbon. XII-1 B. FLOOR ALLOCATION ESTIMATION METHODS Based on the information available for sulfuric acid plants in the west, it was determined that it is appropriate to estimate the floor allocation by applying the NSPS requ irem ents to each sulfuric acid plant. Subpart H - S tand ards o f Perform ance for Sulfuric Acid Plan ts 60.82 Standard for Sulfur Dioxide On or after the date on w hich the perform ance test required to be con ducted b y Sec. 60.8 is com pleted, no ow ner or operator su bject to the provisions of this subpart shall cause to be discharged into the atmosphere from any affected facility any gases which contain SO 2 in excess of 4 lbs per ton of acid produced. Achieving this standard requires a conversion efficiency of 99.7 percent in an uncontrolled plant, or the equivalent SO 2 collection mechanism in a controlled facility. Table XII-1 lists the sulfuric acid plants, their characteristics, and the estimated annual SO 2 floor allocations. An initial SO 2 floor allocation was estimated by multiplying the daily throughput limit by the NSPS emission rate (4 lbs SO 2 per ton 100 percent acid produced), times 365 days pe r year, converted from lbs to tons by dividing by 200 0. In equation form, this is: This based on throughput initial floor allocation was found to exceed the annual SO 2 permit limits for each of these units. Therefore, the estimated floor allocations for these sulfuric acid plants was established using recent historic SO 2 emissions data. These historic emission values are all slightly below the annual SO 2 permit limits. REFERENCES AWM A, 2000: Air and Waste Management Association, “Air Pollution Engineering Manu al,” 2 nd edition, Chapter 12 - Chemical Process Industry, 2000. CFR , 2001: Code of Federal Regulations, Subpart H - Standards of Performance for Sulfuric Acid Plants (60.82), July 1, 2001. Idaho DEQ , 2002a: State of Idaho, Department of Environmental Quality, Air Quality Tier 1 Operating Permit, J.R. Simplot Co. - Don Siding Plant, 2002. Idaho DEQ , 2002b: State of Idaho, Department of Environmental Quality, Air Quality Tier 1 Operating P ermit, Nu-We st Industries, Inc.; Agrium Conda Phosph ate Operations, 2002. XII-2 Table XII-1 Sulfuric Acid Plants State F ac ility N am e Start Da te Su lfur ic Ac id Pla nt ID Control Technique Process Annual SO 2 Pe rm it Lim it (tons) Da ily Throughput Limit (tons) Based on Throughput SO 2 Floor Alloc atio n (tp y) Floor Allocation Us ing His tor ic Emissions Ave ra ge (tpy) Idaho Nu-W est Industries East NA NA 945 1,550 1,131 612 Idaho JR Simplot 300 Single contact 2 stage scrubber system 750 1,750 1,277 1,939 400 Doub le contact Doub le contact with mist eliminator 1,458 NA 1,458 1995 Source 9b MEC 96 3.6 1,320 964 1984 Source 9a Lurgi 1,387 1,900 1,387 W yom ing W yom ing SF Pho sphates, Inc. Koch Sulfur Pro du cts EU -1 NA 719 NA 719 EU -5 NA 721 NA 721 NA = not available. XII-3 1,638 1,197 XII-4 CHAPTER XIII METALLURGIC COKE PRODUCTION A. SECTOR DESCRIPTION AND SIGNIFICANT SO2 SOURCES Metallurgical cok e is derived from coa l an d used in iron and steel industry processes. Coke is m anufactured by pyrolysis, the heating of coal in the absence of air. In this process, high grade, bitum inou s coal is hea ted in a en closed chamber to approxim ately 105 0°C (1925°F), which rem oves all volatile components o f the coal. Th e resu lting product is a solid material consisting of elemental carbon and any minerals that were not volatilized in the heating process. 1. By Product Coke Ovens In a typical coking operation, 35 to 100 coke ovens are located in a row referred to as the oven ba ttery. Each ove n has three m ain parts: coking chambers, heating cham bers, and regenerative chambers. The coking chamber has ports in the top for charging (loading) of the coal. A typical U.S. coke oven produces 7.5 tons to 39 tons of coke per cycle. Most coke plants are co-located with iron and steel production facilities. All ovens currently operating in the United States are by-pro duct recovery ovens. The se oven s operate b y reusing gases (volatiles) emitted b y the hot coal. In by-product recovery ovens, the v olatiles from the coal are collected and sent to a by-product recov ery plant. The off gas is condensed and separated into a liquid fraction (coal tar) and a gaseous fraction (coal gas). The coal gas contains a number of contaminants including hydrogen sulfide. Som e by-produ ct recovery processes rem ove the su lfur from the gas prior to combustion. Approximately 33 percent to 40 percent of the clean coal gas is then returned to the oven battery to be used as fuel. The remaining coal gas can be used as fuel for other processes at the plant or sold to other facilities. Emissions of SO 2 from coke ovens operations primarily result from combustion of the byproduct coal gas in the oven. A small portion of SO 2 emissions comes from uncontrolled “charging”, the process of loading coal into the oven. Control of SO 2 from combustion of coal gas is primarily accomplished by; (a) removing the sulfur from the gas prior to combustion or (b) utilizing low sulfur coal in the coking process. There are a numb er of methods for removing sulfur from the coal gas, such as wet scrubbing. 2. Rotary Calciners There is only one known rotary calciner used for coke production in the United States, P4 P roduction in Rock Springs, WY. It uses a Salem B rosius, 65 foot diameter, continuous feed rotary hearth calciner. Basically, the process involves feeding a mixture of coal and petroleum (pet) coke onto a rotating table located inside a furnace. Th e coal is heated to a high temperature as it rotates to produce coke. The coke exits the hearth and enters a cooling chamber. Like byproduct recovery ovens, the furnace operates by reusing the volatile g ases em itted from the coal. However, in this process, the furn ace is in itially started with natural gas. Once started, the coal gas being emitted during the coking process is utilized as fuel directly. The w aste gas is then du cted to an in cinerator. Byproducts of the process include fine coke, ash, CO 2, SO 2, and rock. Emissions of SO 2from a rotary hearth calciner are primarily due to the volatiles from the heated coal. The waste gas is ducted to an incinerator and baghouse prior to being XIII-1 emitted to the atmosphere. There is no desulfurization of the waste gas. The am ount of SO 2 em itted from the facility is a fun ction of the properties of th e feed coa l. B. FLOOR ALLOCATION ESTIMATION METHODS The analysis was limited to facilities which emit greater than 100 tpy of SO 2 in total. There are three facilities w hich hav e been identified . Two are cokin g plants, Astaris Coking Plant in W yom ing a nd G eneva Steel in Utah. Th ere is one ro tary calciner in Wyom ing, P4 Production, Rock Springs Coal Calcining Plant. The air pollution agencies for Wyom ing and Utah provided information on the coking and calcining facilities for estimating floor allocations. Astaris Coking Plant was shut down in April of 2001. Therefore, this facility does not receive an SO 2 alloca tion . Geneva Steel has committed to ceasing all SO 2 emissions from the coke ovens and the sinter plant. These emissions have been banked for future use or trading as precursor pollutants within the current local Utah County PM 10 SIP. Th e Utah Air Qua lity Board approved this change on June 5, 2002. Since the SO 2 emissions for coking and sintering at the plant are now essentially zero, the SO 2 floor allocation for coking is also zero. The third facility is P4 Production, R ock Springs Coal Calcinin g Pla nt. Th e plant is designed to process 220,000 tpy of feed m aterials to produce 1 10,000 tpy of cok e product. The plant operates for up to 8,00 0 ho urs per year. Th is works ou t to a de sign p rocess rate of 27.5 tons per hour (tph) or 660 tons per day (tpd) of feed. According to the operating perm it, the total facility potential to em it is 2,841.1 tpy of SO 2 based on 8,760 operating hours. There are no NSPS requirements the facility must comply with for SO 2. This rotary coker wa s built in 1972 a nd th us is "grandfathered" from the W yom ing A ir Qu ality Division's perm it requirem ents. T he h istorical emissions for this facility are presented in Table XIII-1. Table XIII-1 Historical SO2 Emissions at P4 Production, Rock Springs, WY Historical Emissions of SO 2 (tpy) Average Annual SO 2 Em issions (tpy) 1990 1996 1997 1998 2000 1996 - 2000 933 663 586 642 633 631 As stated previously, the SO 2 emitted is a function of the feed coal. The plan t uses a blend of coal and petroleum coke (pet coke). The 1994 annual inventory showed that the pet coke blend was 7.2 percent for the year, with SO 2 emissions of 420.0 tpy; up 15 percent from the 365.6 tpy emitted in 1993, when straight coal was used as 100 percent of the feedstock. The most recent year's data shows that the pet coke blend was 25 percent for 1998, the maximum allowable amount to maintain compliance with the SO 2 emissions limit. The procedure for estimating the floor allocation for P4 Productions is difficult for several rea sons. First, there are no iden tified control technologies ava ilable for the rotary calcine r. Secon d, there are n o NSPS requirem ents. T hird, P4 Production h as a poten tial to emit 2,841.1 tpy based on 8,760 hours of operation. This is much higher than the annual emissions reported by the plant. Lastly, the SO 2 emissions from the rotary calciner are a function of the sulfur content of the feed wh ich varies over time. Since the coking process at P4 Production is unique and cannot be compared with emissions from other facilities, the SO 2 allocations for P4 Productions w ill be based on its a verage annual e missions. This is XIII-2 consistent with the allocation approach developed for source categories with no technology available for reducing sulfur and variable sulfur content in the feed such as flaring. The allocation for P4 Production will be based on emissions of SO 2 from years 1996, 1997, 1998 and 2000. Averaging historical emissions results in a floor allocation of 631 tpy of SO 2 for the P4 Production facility. As stated previously, the SO 2 floor allocations for Astaris and Geneva Steel are zero. C. COMPARISON WITH HISTORICAL EMISSIONS Table XIII-2 presents the historical SO 2 emissions and the SO 2 floor allocations for all three coking facilities. Note that Geneva Steel has an SO 2 allocation for its boilers, which is discussed in Section IV. Table XIII-2 Coking Plant - Historical Emissions - 1990 to 2000 Sta te MTF Co unty Fac ility ID SIC Sector ID WY 037 0003 10 WY 023 001 10 UT 049 0027 3312 10 Sector Description Metals/Mining/ Min era ls Metals/Mining/ Min era ls Metals/Mining/ Min era ls Facility Name (1990) Sweetwater Resources Current Facility Name S O 2 tpy S O 2 tpy S O 2 tpy S O 2 tpy 2000 1998 1996 1990 (if different from1990) P4 Production - Rock 933 663 642 633 Springs FMC Coking Plant Astaris Coking Plant Geneva Steel S O 2 Floor Allocation 631 1,194 1,413 1,454 1,409 0 8,473 2,020 881 979 0 REFERENCES AWM A, 2000: Air and Waste Management Association, “Air Pollution Engineering Manual,” 2nd edition, Chapter 14 - Metallurgical Industry, 2000. EPA , 1981: U.S. Environmental Protection Agency, “Control Techniques for Sulfur Oxide Em issions from Stationary Sources,” Secon d Edition, EPA-450/3-81-004, O ffice of Air Quality Planning and Standards, Research Triangle Park, NC, April 1981. EPA , 1998: U.S. Environmental Protection Agency, “Compilation of Air Pollutant Emission Factors,” AP-42, Fifth Edition, Volume I: Stationary Point and Area Source, Section 12.2 C oke P roduction” Office of Air Qu ality Planning a nd Standards, Research Triangle Park, NC, 1998. XIII-3 XIII-4 CHAPTER XIV FLOOR ALLOCATION SUMMARY Table XIV-1 summarizes the SO 2 floor allocation estimates from all of the previous chapters by State and by sector. California estimates listed in Table XIV-1 are based on average SO 2 emissions in these sectors from 1996, 1998, and 2000. Table XIV-1 shows the estimated SO 2 floor allocation for non-utility sources in the 9-State C ommission Tran sport Region to be about 195 thousand tons. If copper smelter SO 2 allocations in 2018 are subtracted from this am ount, the floor allocation is 117 thou sand tons. The non-smelter, non-California SO 2 emissions total is 89,000 tons. Table XIV-2 provides a complete list of the facility-level SO2 floor allocations, and includes year 2000 SO 2 emissions as a point of comparison. XIV -1 Table XIV-1 State/Sector Summary of SO2 Floor Allocations (tons per year) Sectors States Refineries Arizona L im e Manufacturing* 1,365 Industrial Boilers Pulp and Paper Cement Manufacturing 978 320 387 4,936 Natural Gas Processing Elemental Phosphorus ** Glass Manu facturing*** Copper Sm elters Aluminum Pla nts Su lfuric Acid Plan ts Coke Production 43,000 Ca liforn ia 27,335 Colorado 1,614 Idaho 601 Nevada W yom ing NOTES: 1,585 4,142 303 2,010 2,103 7,911 3,418 11,418 237 522 7,174 15,861 2,551 21,342 448 2,244 Oregon Total 1,807 435 New Mexico Utah Total 45,663 883 1,103 12,862 267 1,593 34,000 5,377 2,350 7,184 131 165 14,429 7,761 28,884 2,076 9,169 1,000 15,861 368 * B as e d o n 1 9 98 a nd 2 00 0 hi st or ic a l S O 2 emission estimates. * *B a s ed o n ye a r 2 0 00 S O 2 emission estimates for P4 Production, which are substantially higher than 1996 or 1998 emissions. * ** B as e d o n 1 9 96 , 1 9 98 , a n d 2 0 00 h is to ri ca l S O 2 emission estimates. XIV -2 50,209 78,000 9,315 2,076 2,835 631 23,828 5,386 631 194,918 Table XIV-2 Facility-Level SO2 Floor Allocations Comparison with Year 2000 SO2 Emissions (tons per year) Facility ID Sector Description State AZ Cement/Concrete AZ 0011 Metals/Mining/Minerals AZ 0003 Metals/Mining/Minerals AZ Cement/Concrete AZ 0007 Wood/Paper/Pulp AZ 0001 Oil/Gas AZ 0004 Copper AZ 0032 Copper AZ 0006 Copper AZ 0040 Copper Facility Name (1990) Arizona Portland Cement CHEMICAL LIME (CHEMSTAR) Chemical Lime (Douglas) Phoenix Cement STONE CONTAINER Intermountain Refining ASARCO SMELTER - HAYDEN BHP(Magma Metals) CYPRUS MIAMI MINE Cyprus Sierrita Current Facility Name CHEMICAL LIME - NELSON ABITIBI BHP - San Manuel In Current Report Comments X X X X X X Closed X X X X Total SO2 SO2 NonSO2 SO2 Boiler Boiler Emissions Allocation Allocation Year 2000 Allocation 320 0 0 702 632 632 742 733 733 539 320 320 1,893 0 978 978 0 0 0 16,753 21,000 21,000 0 14,000 14,000 6,810 8,000 8,000 0 0 0 State Totals 45,663 CO CO CO CO CO CO CO CO CO CO CO CO CO CO CO 0048 0004 0003 0008 0002 0001 0097 0003 9 0001 24 0025 0001 0002 Metals/Mining/Minerals Oil/Gas Oil/Gas Glass Cement/Concrete Cement/Concrete Misc. Cement/Concrete Misc. Oil/Gas CHP Oil/Gas Oil/Gas Food Food CFI COLO REFINING CONOCO DENVER COORS GLASS HOLNAM LAPORTE HOLNAM PORTLAND METRO WASTEWATER SOUTHWEST PORTLAND GENERAL SERVICES ADMINISTRATION LANDMARK PETROLEUM TRIGEN-COLORADO ENERGY CORP. UNOCAL RETORT-PARACHUTE UNOCAL UPGRADE WESTERN SUGAR 1 WESTERN SUGAR 2 Wood/Paper/Pulp/Cogeneration Cement/Concrete Power Food Wood/Paper/Pulp Misc. Chemicals/Plastics Food Chemicals/Plastics Chemicals/Plastics Wood/Paper/Pulp Misc. Chemicals/Plastics Food Food Food Food Misc. Tamarack Energy ASHGROVE CEMENT Avista Basic American Foods (Shelly) Boise Cascade - Emmett DOE-INEEL FMC MAGIC VALLEY FOODS MONSANTO/P4 PRODUCTION NU WEST INDUSTRIES POTLATCH RICKS COLLEGE SIMPLOT TASCO (NAMPA) TASCO (PAUL) TASCO (TWIN) Idaho Supreme MTN. HM. AFB Metals/Mining/Minerals Cement/Concrete Cement/Concrete CHEMSTAR APEX NEVADA CEMENT COMPANY Royal Cement ROCKY MOUNTAIN BOTTLE HOLCIM LAPORTE HOLCIM PORTLAND X X X X X CEMEX-LYONS PLT. X Refinery Refinery X X X 267 545 1,972 255 404 3,288 56 50 0 0 2,583 0 0 19 0 562 1,052 237 1,402 3,374 160 0 387 0 562 1,052 237 1,402 3,374 0 160 0 0 387 0 0 0 0 7,174 ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID 0004 0001 0005 0001 0003 0001 0006 0010 0001 0001 0001 X ASTARIS P4 Production X X Elemental Phosphorus Sulfuric acid plants Paper Mill Sulfuric acid plants Amalgamated Sugar (Nampa) Amalgamated Sugar (Paul) Amalgamated Sugar (Twin) 117 1,327 130 149 252 460 0 0 15,861 86 1,694 0 543 1,697 1,322 1,053 0 144 522 15,861 1,807 242 155 203 0 522 0 0 0 0 0 0 15,861 612 1,807 0 1,939 242 155 203 0 0 21,341 NV NV NV 0003 0387 CHEMICAL LIME CO-APEX PLANT FERNLEY PLANT X X Lime plant Not in previous report XIV -3 210 172 193 305 143 193 305 143 Table XIV-2 (continued) State NV NV NV NV NV NV Facility ID 0261 0451 0433 0863 0019 Sector Description Metals/Mining/Minerals Metals/Mining Metals/Mining/Minerals Misc. Metals/Mining Metals/Mining/Minerals Facility Name (1990) GRAYMONT WESTERN US INC SANTA FE PACIFIC GOLD CORP BASIC INC.(Now PREMIER CHEMICALS LLC) HAWTHORNE ARMY Independence Big Springs TITANIUM METALS Current Facility Name PILOT PEAK TWIN CREEKS/NEWMONT MINING CORP PREMIER SERVICES (Gabbs Facility) Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Cement/Concrete Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Oil/Gas Copper Copper AGAVE ENERGY/YATES PLANT ARCO PERMIAN/EMPIRE ABO GAS PLNT CONOCO/MALJAMAR GAS PLANT GIANT INDUSTRIES/BLOOMFIELD REF Giant Refining/Ciniza Refinery GPM GAS EUNICE GAS PLANT GPM GAS/ARTESIA GAS PLANT GPM GAS/INDIAN HILLS AMINE PLNT GPM GAS/LEE GAS PLANT GPM GAS/LINAM RANCH GAS PLANT J.L. DAVIS GAS PROCESS/DENTON MARATHON OIL/INDIAN BSN GAS PLT NAVAJO REFINING/ARTESIA REFINERY PAN ENERGY/BURTON FLATS GAS PLT PAN ENERGY/DAGGER DRAW GAS PLT RIO GRANDE PORTLAND CEMENT SID RICHARDSON GASOLINE/JAL#3 TEXACO/BUCKEYE GASOLINE PLANT TEXACO/EUNICE NORTH GAS PLANT TEXACO/EUNICE SOUTH GAS PLANT TRANSWESTERN PIPE WARREN PETROLEUM/BLUITT GAS PLANT WARREN PETROLEUM/EUNICE GAS PLANT WARREN PETROLEUM/MONUMENT PLANT WARREN PETROLEUM/SAUNDERS PLANT WARREN PETROLEUM/VADA GAS PLANT WESTERN GAS PROCESSORS/SAN JUAN RVR CITATION/ANTELOPE RDG GAS PLANT CONOCO/BELL LAKE 2 WELL #6 FEAGAN ENERGY/W DAGGER DRAW GAS PLT YATES PETROLEUM/PATHFINDER AMINE PHELPS DODGE/CHINO MINES PHELPS DODGE/HIDALGO SMELTER Agave Plant Food Wood/Paper/Pulp Wood/Paper/Pulp Oil/Gas Wood/Paper/Pulp Metals/Mining Metals/Mining/Minerals Wood/Paper/Pulp Wood/Paper/Pulp Metals/Mining/Minerals Glass Amalgamated Sugar Company, The In Current Report Comments X Lime plant ANGLO GOLD SO2 SO2 NonSO2 Total Emissions Boiler Boiler SO2 Year 2000 Allocation Allocation Allocation 249 242 242 113 0 0 0 0 0 State Totals 883 NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM 0024 0002 0004 0023 0008 0044 0011 0006 0046 0035 0007 0008 0010 138 0285 OR OR OR OR OR OR OR OR OR OR OR 0002 0008 55 0052 0051 0003 0001 0060 0061 0063 0064 0247 0128 0118 0125 0050 0001 0003 MALJAMAR GAS PLANT (Gallup) VERSADO GAS PRODUCERS LLC DUKE ENERGY/ARTESIA GAS PLANT Duke Energy Lee Plant Duke Energy Plant 5 X X X X X X X Refinery Refinery X Duke Energy Burton Plant DUKE ENERGY/DAGGER DRAW X X X X X X X Refinery DYNERGY DUKE ENERGY/HUBER GAS Duke Energy EUNICE GAS PLANT Dynergy MONUMENT PLANT Dynergy SAUNDERS PLANT Western Gas Resources Duke Energy Dagger Draw X X X X X X X X X X X X 2,983 565 3,574 920 1,779 2,759 1,459 900 818 1,304 1,158 1,100 980 246 247 1,103 0 673 5,476 231 270 1,226 2,756 1,387 0 3,138 365 431 222 414 603 365 431 222 414 603 0 1,192 0 0 1,181 840 665 1,227 164 218 1,103 1,206 0 0 0 163 0 2,250 675 163 0 3,127 0 0 0 0 14,000 20,000 1,192 0 1,181 840 665 1,227 164 218 1,103 1,206 163 2,250 675 163 3,127 0 11,420 0 0 14,000 20,000 987 0 0 1,532 74 74 411 1,943 258 143 401 0 0 277 1,638 518 131 50,209 1849 0005 0007 2125 0036 0004 0001 1876 X X X X X Boise Cascade Company Georgia-Pacific West, Inc. Glenbrook Nickel Company Globe Metallurgical Inc. James River II, Inc. Northwest Aluminum Company, Inc. Owens-Brockway Glass Container, Inc. Georgia- Pacific (Wauna Mill) XIV -4 X X X X Not in previous report 1,834 Not in previous report 452 0 197 0 643 397 108 0 1,361 518 131 Table XIV-2 (continued) State OR OR OR OR OR OR OR OR OR OR OR OR OR OR Facility ID 3501 1851 6142 8866 0471 8850 5034 2028 0041 0013 5398 2050 0015 Sector Description Wood/Paper/Pulp Metals/Mining/Minerals Wood/Paper/Pulp Wood/Paper/Pulp Wood/Paper/Pulp Wood/Paper/Pulp Wood/Paper/Pulp Misc. Oil/Gas Chemicals/Plastics Wood/Paper/Pulp Wood/Paper/Pulp Misc. Wood/Paper/Pulp Facility Name (1990) Pope & Talbot Pulp, Inc. Reynolds Metals Company Smurfit Newsprint Corporation 2 West Linn Paper Co. Weyerhaeuser Company Willamette Industries, Inc. Collins Products LLC Cascade Steel Rolling Mills, Inc. Copper CHP Oil/Gas Misc. Metals/Mining/Minerals Oil/Gas Metals/Mining/Minerals Oil/Gas Metals/Mining/Minerals Cement/Concrete Oil/Gas Oil/Gas Oil/Gas 10676 Kennecott Utah Copper Corp. Sunnyside Cogeneration Associates Amoco Petroleum Products Brigham Young University Brush Wellman Inc. Chevron Products Company Continental Lime Inc. Flying J Incorporated Geneva Steel Holnam Incorporated Phillips 66 Company Silver Eagle Refining Inc. Unocal Corporation Utelite Corporation Oil/Gas Oil/Gas Oil/Gas Cement/Concrete Oil/Gas Oil/Gas Metals/Mining/Minerals Metals/Mining/Minerals Metals/Mining/Minerals Oil/Gas Metals/Mining/Minerals Food Oil/Gas Oil/Gas Oil/Gas Oil/Gas Chemicals/Plastics AMOCO - ELK BASIN AMOCO - WHITNEY CANYON CHEVRON - CARTER CREEK Centex EXXON - SHUTE CREEK EXXON BLACK CANYON DEHY & WELLFIELD FMC - GRANGER (TEXAS GULF) FMC - GREEN RIVER FMC COKING PLANT FRONTIER OIL & REFINING - CHEYENNE GENERAL CHEMICAL HOLLY SUGAR - TORRINGTON INTERENERGY - HILAND KCS MOUNTAIN RESOURCES - GOLDEN EAGLE KCS MOUNTAIN RESOURCES - AINSWORTH KCS Mountain Resources Rushmore KOCH SULFUR PRODUCTS COMPANY Oil/Gas Oil/Gas Oil/Gas LOUISIANA LAND & EXPLOR - LOST CABIN MARATHON GAS PLANT - OREGON BASIN MARATHON OIL - MILL IRON In Current Report X X X X X X X Current Facility Name SierraPine, Ltd. Weyerhaeuser Co. Kinder Morgan Energy Partners, L.P Georgia-Pacific Resins, Inc. J. Peterkort & Company Ogden Martin Systems of Marion, Inc. Oregon Health Sciences University Weyerhauser - Coos Bay Collins Products LLC Covanta Marion, Inc. OHSU Comments No longer pulping Not in previous report Weyerhaeuser Springfield SO2 SO2 NonSO2 Total Emissions Boiler Boiler SO2 Year 2000 Allocation Allocation Allocation 293 248 107 355 1,510 1,558 1,558 519 0 0 0 211 211 0 0 0 0 327 310 310 1,721 1,668 362 2,030 0 0 State Totals X 0 0 0 X X Hog waste-fired boiler 0 882 0 2,534 1,054 1,368 125 179 1,242 331 300 979 288 601 1,000 0 9,169 UT UT UT UT UT UT UT UT UT UT UT UT UT UT 10572 10096 0004 0004 0001 0003 -9902 0008 0027 0001 0013 WY WY WY WY WY WY WY WY WY WY WY WY WY 0012 0012 0009 -9901 Tesoro Graymont Holcim Tom Brown-Lisbon Plant X X X X X X X X X X X X X Smelter Refining Refining Lime Refining Shutdown coke ovens and sinter plant Cement Refining Not in previous report (Refining) Natural gas processing 1,252 133 700 1,270 1,388 1 23 1,240 303 674 17 267 762 77 1,593 0 1,700 1,270 1,388 1 23 1,240 303 674 17 267 762 77 1,593 0 9,315 WY WY WY WY WY WY WY 0013 0010 48 0001 0001 0002 0001 1 0005 0007 b HOWELL PETROLEUM - ELK BASIN ASTARIS COKING PLANT WILDHORSE ENERGY - HILAND PEAK SULFUR BURLINGTON RESOURCES - LOST CABIN b Oregon Basin Gas Plant XIV -5 X X X X X X X X X X X X X X X X X X X 2,638 6,889 2,096 281 1,200 5,602 200 165 1,536 0 305 956 0 863 750 23 281 17 0 118 1,245 790 843 118 1,197 790 843 118 1,197 213 358 0 1,867 391 247 1,867 391 247 Not in previous report Shutdown April 2001 Refining Sulfuric acid plants 1,383 167 212 4,901 1,409 1,396 5,000 178 269 1,200 5,602 200 165 1,536 305 956 863 750 23 Table XIV-2 (continued) State WY WY WY WY WY WY WY WY WY WY WY WY WY WY WY WY WY WY WY Facility ID 1 0003 0022 0001 0011 0012 0008 0005 0001 008 0003 0002 0001 0014 0013 Sector Description Oil/Gas Metals/Mining/Minerals Chemicals/Plastics Oil/Gas Oil/Gas Oil/Gas Metals/Mining/Minerals Oil/Gas Oil/Gas Misc. Oil/Gas Oil/Gas Metals/Mining/Minerals Oil/Gas Metals/Mining/Minerals Oil/Gas Oil/Gas Oil/Gas Oil/Gas Facility Name (1990) Marthon Oil Pitch Fork Battery SWEETWATER RESOURCES SF PHOSPHATES, INC LITTLE AMERICA REFINING COMPANY SINCLAIR @ SINCLAIR SNYDER OIL - RIVERTON DOME SOLVAY MINERALS TEXAS-BYRON PLANT UNION PAC - BRADY UW CENTRAL HEAT PLANT WYOMING REFINING CO DEVON SFS OPERATING CO. AMERICAN COLLOID - WEST COLONY AMOCO REFINERY BENTONITE CORPORATION COLORADO INTERSTATE GAS - TABLE ROCK MARATHON OIL COMPANY - GARLAND Hallwood Petroleum-Federal Packsaddle 1-24 Hallwood Petroleum-Federal Packsaddle 1 Current Facility Name P4 PRODUCTION - ROCK SPRINGS SINCLAIR - CASPER b Comments Rotary coker Sulfuric acid plants Refining Refining DEVON SFS - RIVERTON DOME BIG HORN GAS PROCESSING - BYRON RME PETROLEUM - BRADY WYOMING REFINING - NEWCASTLE BEAVER CREEK X X X X X X Texaco Refining Closed LOVELL X X TOTALS a In Current Report X X X X X Not in previous report Not in previous report SO2 SO2 NonSO2 Total Emissions Boiler Boiler SO2 Year 2000 Allocation Allocation Allocation 61 61 61 633 631 631 1,790 1,638 1,638 1,458 1,040 1,040 3,407 1,066 1,066 492 0 52 294 294 257 200 200 300 0 193 22 22 876 449 449 831 0 0 0 0 0 0 0 0 0 0 133 133 960 960 170,226 SO2 Allocation based on historical emissions. Plant has just added capacity and allocation is based on current (July 2002 capacity). XIV -6 167,583 State Totals 23,828 167,583 Appendix A-8b. Western Emissions Backstop (WEB) Emissions & Allowance Tracking Systerm (EATS) Analysis Appendix A-8 – SO2 Milestones/Backstop Arizona Regional Haze SIP Western Backstop (WEB) Emissions and Allowance Tracking System (EATS) Analysis Prepared by: Perrin Quarles Associates, Inc. 675 Peter Jefferson Parkway, Suite 200 Charlottesville, VA 22911 July 18, 2003 Table of Contents Page I. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. Overview of the System and Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 III. Functional Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 A. Source Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 B. User Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 C. Account Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 D. Allowance Allocations (Initial and Ongoing) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 E. Allowance Trading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 F. Annual Compliance Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 G. Emissions Tracking and Emissions Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 H. Program Assessment and Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 I. Public Information Needs and Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 IV. Types of Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. State and Tribal Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B. Industry Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C. General Account Holders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D. Tracking System Administrator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E. Public Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 20 21 22 23 24 V. Technical Architecture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B. System Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C. Maintainability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D. System Outputs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E. Application of Platform Selection Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 25 27 28 28 29 VI. Design and Development Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A. Recommended Implementation Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . B. Timing/Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C. Cost Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 30 32 32 VII. TSA Responsibilities and Performance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 A. TSA Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 B. TSA Performance Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 List of Figures Page Figure 1: Figure 2: Figure 3: Figure 4: Figure 5: Figure 6: Figure 7: Figure 8: Overall WEB EATS Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Flow Chart of Allowance Allocation Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Flow Chart of Annual Compliance Assessment Process . . . . . . . . . . . . . . . . . . . . 14 Use Case Diagram: State and Tribal Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Use Case Diagram: Industry Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Use Case Diagram: General Account Holders . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Use Case Diagram: Tracking System Administrator . . . . . . . . . . . . . . . . . . . . . . 23 Use Case Diagram: Public Users . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 July 18, 2003 Western Backstop (WEB) Emissions and Allowance Tracking System (EATS) Analysis I. Introduction This section of the State Implementation Plan/Tribal Implementation Plan (SIP/TIP) is an analysis of the information management needs of the Western Backstop Emissions and Allowance Tracking System (WEB EATS) which is a requirement for the program under 40 CFR 51.309. Section 309(d)(h)(4)(v) of the Regional Haze rule requires that "the Implementation Plan must provide for submitting data to a centralized system for the tracking of allowances and emissions." The purpose of this document is to describe the architectural and system requirements necessary to support a State/Regional emissions trading program information system. The document summarizes the overall needs and objectives of an emissions trading system to ensure successful implementation of the program. It is intended to serve as a roadmap to help WRAP implement the program once it has been triggered. II. Overview of the System and Analysis Figure 1 contains a graphical depiction of the overall information system, including the basic users, functionality needed for each of these user types, and a high level architecture. Section III describes each functional area of the application. Section IV describes the primary user groups and how they relate to the functional areas. Section V describes the considerations affecting the choice of technical architecture for the application. Section VI describes recommended design and development approaches, and Section VII addresses the overall responsibilities of the Tracking System Administrator (TSA). The development and deployment of this application, if needed, would most likely occur after 2013, possibly later. It is assumed that currently available technology would not be used, nor is it possible to project what advancements in technology would be available. For this reason, this report does not address specific technologies, except as a reference point for better understanding or describing capability that would be needed. The focus is on general issues related to technology and the functional requirements for designing and implementing the program. The scope of the application and information system needs which are described do not extend to several areas relating to the possible implementation of the Backstop Trading Program envisioned by Section 309. Excluded areas include the baseline emissions inventory for determining whether the program triggers, performing initial allowance allocations, and evaluating and tracking early reduction credits. Also, it has been assumed that it is not necessary to support a significant level of variation in requirements or needs from different States or tribes and that areas in which these requirements may vary, such as enforcement activities beyond the automatic provisions of the program, would be addressed in other systems. -1- Figure 1 Overall WEB EATS Model Ÿ Ÿ Ÿ Ÿ Complete Registration Transfer Allowances Submit Emissions View Reports Tribal Set-aside Allocation System States/Tribes Ÿ Allocate Allowances Ÿ Approve Sources and Units Ÿ Approve Monitoring Ÿ View Reports Industry -2The System Administrator WEB EATS Ÿ Query Data Ÿ View Standard Reports Application Database Public Data Public EPA Emissions Database Program Emissions Inventory WEB EATS Analysis July 18, 2003 General Accounts Ÿ Add/Update General Accounts Ÿ Transfer Allowances Ÿ View Reports Ÿ Manage Application and Users Ÿ Conduct Compliance Assessment Ÿ Develop Reports Ÿ Coordinate Program Implementation WEB EATS Analysis July 18, 2003 III. Functional Areas The system to support the WEB Trading Program must contain functionality to support implementation of the trading program in the following areas: source inventory, user management, account management, allowance allocations, allowance trading, emissions reporting and collection, compliance, and program assessment. At this time, the system functionality does not include consideration of allowance transfer price data. However, there may be a need to include this functional area in the final system design, and the overall system design needs to allow for this possible expansion of the functional areas. Because the core requirements for allowance transfer price tracking remain uncertain, this section does not discuss this functional area in further detail. Each of the other areas of functionality is described below. In addition, core requirements relating to the areas are defined. A. Source Inventory 1. Description a. Facilities and Units The central focus of the system is the list or inventory of sources which are affected by the program. This inventory is initially derived from the baseline emissions inventory developed to support the development and approval of the WEB Trading Program as part of the SIP/TIP approval process. To this initial inventory, it is expected that States and Tribes may add sources, either during the period prior to triggering the program or after the Program Trigger Date. Throughout, it is expected that sources will permanently cease operation or "retire." To support the dynamic inventory, the information system must allow the addition of new sources and track the status, including the regulatory status, of all sources identified as potential program participants beginning with the baseline period. To support changes in facility operation and ownership in both the pre-trigger and posttrigger period, it will be necessary to track basic changes in facility identity, including facilities which, due to these types of changes, change "identity" or divide into two facilities. This functionality would include tracking facility name changes. It is assumed that States and Tribes would be responsible for identifying all "new" sources to the database and for making decisions and entering data about the applicability of the program to a new source. Once a source is identified as being subject to the program, the maintenance of these data would be the primary responsibility of the owners and operators of affected sources through the source representative. A single, secure portal for changing these data would be provided to authorized industry representatives. -3- WEB EATS Analysis July 18, 2003 b. Source Owners The owners and operators of each source authorize individual(s) to represent them regarding allowance trading, emissions reporting and all other compliance activities. The identity of the owners and operators should be tracked to ensure that legal responsibility for compliance can be accurately determined at any point in time during which compliance is required. The WEB EATS should track changes in owners and operators for a source. c. Source Representatives The designated representatives appointed by the owners and operators of the source are also tracked so that appropriate communication about program activities involving the source and compliance is facilitated. Under the Duty to Register provisions, representatives of a source initially must register and use consistent source identifiers with the source program data first entered by the State or Tribe. The representative is responsible for the accuracy of submissions and certifying source compliance. Program rules should be structured to ensure that at no time during the operational phase of the program is an affected source unrepresented. d. Source and Unit Detail Additional information about the facility and units, including fuels, controls, and other operational information would be necessary for program implementation, particularly with respect to emissions monitoring, and for program assessment. During the design phase for WEB EATS development an assessment of these needs and the availability of information from other sources (for example, a shared air program database at EPA or in a State/Tribe) should be performed. 2. Core Data Entities and Attributes ! Facilities. Location, source category or type, permit IDs, size, Federal and State/Tribal cross identifiers with other data systems, program status, operational status (including retirement status), initial on-line date (for new sources). ! Units. Relationship to facilities, type, Federal and State/Tribal cross identifiers with other data systems, operational status (including retirement status), initial on-line date (for new units). ! People. Type and duration of relationship to facilities, type and duration of agent relationship to representatives, address, affiliation, security level, user ID, passwords (or equivalent), phone numbers, email or equivalent. ! Owners/operators. Address, relationship to facilities. -4- WEB EATS Analysis July 18, 2003 ! Program applicability. Exemptions, opt-in or other program status information, including year affected (or non-affected), identification of Category 1 and 2 sources, etc. Could include permitted production capacity or other permit data. 3. Core Functional Requirements ! ! ! ! ! ! ! ! ! ! Populate initial facilities and units. Add and update facilities and units. Add and update owner/operator information. Change owner/operators for facilities. Add and update individual information for any person utilizing or identified in the application. Change representatives for facilities. For on-line changes, provide to users documentation of changes in owners and representatives to meet recordkeeping requirements. This could be email or other electronic format. Track changes in facility names and program identifiers and relationship to prior entities. Communicate/verify facility and unit inventory changes, particularly where change impacts regulatory status or responsibilities or triggers deadline. Add and update program applicability data. B. User Management 1. Description User security and authentication are key requirements for the WEB EATS. To support these requirements the application must contain functionality to store user identifying information and associate each user with the appropriate security level. A system administrator, or person designated by the system administrator, must use tools provided in the application to review and approve user accounts, and to access and monitor usage. For any on-line access and submission by an industry user, the system should require appropriate compliance certifications and contain a record of certifications. 2. Core Data Entities and Attributes ! People. Relationship to facilities or to representatives and their agent, address, affiliation, type, security level, user ID, passwords (or equivalent), phone numbers, email or equivalent. -5- WEB EATS Analysis July 18, 2003 ! User Access Requests. User identification (per People), information to facilitate approval, status of request (approval, denial). ! Certification Records. Content of certification, date, user identification. 3. Core Functional Requirements ! Receive requests for user registration. ! Approve/deny requests and establish security groups. ! Provide notification of request status and assigned user ID and passwords (or equivalent). ! Develop and apply user privileges for specific functional areas and categories of data. ! Delete or archive users. ! Revoke or modify user access privileges. ! Display appropriate certification statements for review and agreement. C. Account Management 1. Description In the model rule, an Allowance Tracking System account is defined as an account "established for purposes of recording the allocation, and for holding, transferring, or deducting allowances." The WEB EATS should contain at least four types of accounts: general, compliance, retirement and government accounts. It must include a range of functionality to support each type of account. A compliance account holds allowances which are used for compliance purposes. There is one compliance account for each source subject to emissions trading requirements and the compliance account is assumed to have the identical owners and representatives as its associated source. A compliance account should be automatically created for each new source when a source has met the appropriate registration requirements. For specified periods, compliance accounts or the allowances in those accounts may be subject to restrictions on trading to facilitate annual compliance assessment. A general account allows anyone to hold allowances separate from the compliance and true-up process. A representative for a facility must move allowances from a general account to a compliance account before the true-up deadline in order to use them for current year compliance. A general account is created upon request of any individual or entity, and like a facility's compliance account, must have a defined owner and an individual person named as an account representative. General accounts are populated through trading functions, described below. The system administrator should have the ability to archive or deactivate a general account if specified criteria are met (such as containing no allowances for a specified period of time). For analysis purposes, the type of general account holder should be identified. -6- WEB EATS Analysis July 18, 2003 A retirement account holds allowances which have been used for annual compliance to offset emissions or which have been voluntarily removed from the market by its owners. At least one retirement account will be identified initially; additional accounts may be necessary to meet specific needs, if a detailed analysis of requirements indicates that separating retired allowances would be useful for analysis or other purposes. A government account holds allowances which are still under the control of a State or Tribe (or, as their agent, the Tracking System Administrator). These accounts will contain serialized allowances to be allocated in the future. The new source set-aside, for example, is a government account. 2. Core Data Entities and Attributes ! Accounts. Identification number, type, restrictions, relationship to source (if any), State/Tribe, or owner/representatives, owner type. ! People. Type and direction of relationship to accounts, address, affiliation, security level, user ID, passwords (or equivalent), phone numbers, email or equivalent. ! Owners/operators. Address, relationship to accounts. 3. Core Functional Requirements ! ! ! ! ! ! ! Add/create general accounts. Change owner/operators for general accounts. Change representatives for general accounts. Add/create retirement, government, and compliance accounts (system admin only). Implement freeze on account or specific allowances within account. Archive or delete accounts. Notification of changes to user and other responsible persons. D. Allowance Allocations (Initial and Ongoing) 1. Description The system should support both initial and ongoing allocations of allowances from government accounts into compliance accounts. The initial allocation for the first five year period would be provided by States or Tribes in a format to be defined by the TSA and system designers. It is recommended that the allocation process replicate the transfer of allowances from account to account, thus creating an audit trail of the allowance back to its original issuing State or Tribe. It is recommended that the system design include a standard file format for submission of initial allowance allocations by the State or Tribe. -7- WEB EATS Analysis July 18, 2003 All allowances would be serialized according to a numbering system to be determined as part of the system design when they are initially populated in the application. This serial number would be a permanent attribute of each allowance and could not be changed. Ongoing allocations, which occur every five years for all allowances, would be supported through a process similar to the initial allocation, depending primarily on a standard file format, containing allocations determined by the State or Tribe for the period. The application should generate a draft and final Regional Allocation Report for each five year allocation period. The application should support periodic allocations of allowances to compliance accounts for new sources from the new source set-aside. Specialized tracking and reporting would be needed to record the date of all requests and the status of the set-aside account. When this account is depleted, the tracking information would be used to prioritize allocation of future allowances to these sources. The application must support allocations of allowances for opt-in sources on an annual basis. It is assumed that the State or Tribe would provide data to support opt-in source allocation (including source identification) either on-line or in an electronic format. The application must support notification of all allocations to registered sources and to the appropriate State or Tribe. If a source representative elects a monitoring option for a unit under 1.(b) of Section I (Monitoring, Recordkeeping and Reporting) of the model rule, the source representative would submit a request to the State or Tribe about this election, and must provide information about the portion of the facility's allowance allocation attributable to these units. Upon approval of the request by the State or Tribe, the TSA (or the State or Tribe directly) would mark the appropriate number of allowances as "non-tradeable" in the allowance account for the source for all years already allocated. A record of the request and approval would be stored, so that future allocations would also be marked as non-tradeable. If the special monitoring status under Section I1.(b) is revoked or no longer applicable, the "non-tradeable" status of the allowances would be changed by the TSA. 2. Core Data Entities and Attributes ! Accounts. Identification number, type, restrictions, relationship to source, State/Tribe, or owner/representatives, owner type. ! Allowances. Serial number, type, origin, year (if not indicated by serial number), nontradeable indicator. -8- WEB EATS Analysis July 18, 2003 ! Transactions. Transaction identifier, date, allowance range, transferor account, transferee account, type of transaction. ! Action Log. Type of submission or request, user, source, status, etc. 3. Core Functional Requirements ! Import of allowance allocations from file provide by State or Tribe. ! Assign serial numbers to new allowances. ! Notification system to automatically inform industry users of allocations and future responsibilities. ! Notification or report system to keep States and Tribes informed re allocation status. ! Tracking capability for new source set-aside requests. ! Allocations to compliance accounts from new-source set aside. -9- WEB EATS Analysis July 18, 2003 Figure 2 Flow Chart of Allowance Allocation Process WEB EATS imports allowance allocations from file provided by State or Tribe WEB EATS assigns serial numbers to new allowances WEB EATS automatically notifies industry users of allocations and future responsibilities WEB EATS automatically notifies States and Tribes regarding allocation status WEB EATS allocates new-source set-aside to new Source compliance accounts E. Allowance Trading 1. Description The ability to trade allowances supports the underlying principle of an emissions trading program and the functionality to support allowance transfers is critical to the WEB EATS. Security of the data and transparency of the transfer record are critical to the overall program and should be carefully evaluated. The WEB EATS must provide the TSA the ability to maintain information on all current account holdings and an audit trail of all allowance -10- WEB EATS Analysis July 18, 2003 transactions, including both market transactions and regulatory transactions. The current standard for emissions trading programs established by EPA is to allow industry users to record allowance transfers on-line in real-time. These applications support both interactive, on-line transfers and batch transfers using specified file formats to transfer larger numbers of allowances. For batch transfers, industry has developed software to monitor allowance ownership and submit large volumes of allowance transfers with a minimum of user intervention. It is assumed that the technical capability for secure system-to-system interactions will continue to improve and that this approach will be more widely used in the future. Current allowance trading systems also support transfers performed by the TSA based on the receipt of paper forms. It is assumed that the reliance on paper forms will continue to diminish. Whether this functionality should be supported in the WEB EATS should be evaluated. During the true-up period, activity in compliance accounts is frozen to allow the TSA to conduct the necessary compliance evaluation and allowance retirement. The WEB EATS would allow users to submit allowance transfers for allowances involved in an ongoing compliance process, but these transfers would be held and recorded following the completed process. All affected parties would be informed of the status of these transfers both when submitted and when finally recorded or denied. For on-line transfers performed interactively by the transferor, the WEB EATS should provide access only to those accounts over which the transferor currently exercises control. Account access would be determined by the WEB EATS based on the user's relationships to specific general or compliance accounts. From these accounts, the user would select the accounts and specific allowances for the transfer. The user would then identify the account into which the allowances should be transferred. It is assumed that eligible recipients include general accounts, compliance accounts or a voluntary retirement account. The user would be asked to review and verify the transfer prior to its taking affect. The process for electronic transfers of batch transfers will be more technology dependent. It would undoubtedly require definition of file transfer formats and security standards to ensure authentication of the submitter and completeness and quality of the data. It is not feasible to predict standards or available technology for this process at this time. The paper-based process used by the TSA would be similar to the interactive process. Depending on the volume of paper transfers, redundancy of data entry or additional verification should be considered to ensure data quality and accuracy. For all transfers (interactive, batch or paper), the WEB EATS must support a process of communication to both the transferor and transferee so that transfers recorded are fully disclosed to all parties and errors or other disputes between parties can be quickly identified and resolved. -11- WEB EATS Analysis July 18, 2003 The WEB EATS must support a process of either transaction reversal or transaction error correction, or both. This functionality would be restricted to the TSA. Reports would be available to the TSA and designated State/Tribe users to review specific transactions or overall transaction activity at any time. 2. Core Data Entities and Attributes ! Accounts. Identification number, type, relationship to source, State/Tribe, or owner/representatives. ! Allowances. Serial number, type, origin, year (if not indicated by serial number). ! Transactions. Transaction identifier, date, allowance range, transferor account, transferee account, type of transaction, status. 3. Core Functional Requirements ! Interactive transfer. ! Batch transfer. ! Capability to freeze compliance accounts with regard to allowances involved in ongoing compliance assessment. ! Notification to transferor and transferee. ! Reports and summaries. ! Allowance transaction audit trail. F. Annual Compliance Assessment 1. Description Following each control period, the TSA must perform an assessment of annual compliance with the basic program requirement that each affected source hold a number of allowances equal to or exceeding the tons of SO2 emissions for the period. The compliance module of the WEB EATS would support receipt of annual compliance notifications and certifications by the source representative. It is expected that most representatives would provide the certifications and designate allowances to be deducted using an on-line access similar to the allowance transfer capability. Following receipt of the annual compliance forms, the WEB EATS would then compare the allowances held in the compliance account and the level of emissions for the source (taking into account the year of allowances, flow control limitations and prior exceedances) and deduct the appropriate allowances from compliance accounts into retirement accounts. Emissions reported at the unit level would be "rolled" up to the facility level. The process would result in a compliance report or compliance assessment notification to source representatives, States and Tribes. -12- WEB EATS Analysis July 18, 2003 In addition, the WEB EATS would assess the need to apply flow control in subsequent years and determine the appropriate flow control factor. Finally, the WEB EATS would identify any failure to meet allowance limitations. Based on the level of excess emissions the WEB EATS would compute the appropriate penalties, both monetary penalties and deduction of subsequent year allowances. 2. Core Data Entities and Attributes ! Annual compliance certifications. Facilities, submitter name/ID, year, compliance certification statements. ! Tracking. List of facilities for whom an annual compliance certification is required, received, etc. ! Compliance Results. Penalties, deductions, status, year. 3. Core Functional Requirements ! ! ! ! ! Receive and store annual compliance certifications. Perform compliance assessment. Calculate exceedances. Calculate flow control applicability and ratios. Communicate compliance results. -13- WEB EATS Analysis July 18, 2003 Figure 3 Flow Chart of Annual Compliance Assessment Process WEB EATS calculates total emissions per Source including rollup to Facility level Source Representatives place appropriate amount of allowances to be deducted in compliance accounts WEB EATS compares allowances held in compliance accounts and the total level of emissions WEB EATS deducts appropriate allowances in compliance accounts WEB EATS provides compliance assessment notification to Source Representatives, States, and Tribes WEB EATS assesses need to apply flow control in subsequent years and compute appropriate flow control factor WEB EATS computes penalties based on exceedances -14- WEB EATS Analysis July 18, 2003 G. Emissions Tracking and Emissions Reporting 1. Description Emissions tracking and reporting for compliance purposes following the program trigger will require a wide range of functionality and data tables. There will be a need to evaluate carefully how and whether the functionality of the Emissions Tracking Database used for milestone tracking inventory purposes can be utilized to support the post-trigger emissions reporting. Also, it will be very useful to identify any potential overlap with existing emissions reporting systems used for other national or regional trading programs. For example, EPA plans to put into place the Emissions Collection System (ECS) and Monitoring Plan System (MPS) sometime after 2004. Although the software itself may not be adaptable for use as the emissions reporting module of WEB EATS, the system requirements and design should be consulted as an additional, more detailed, roadmap in the initial stage of system design. The following general areas of functionality would be required: Reporting Requirements and Tracking Information. To facilitate program implementation, the WEB EATS would identify monitoring and reporting obligations of each source participating in the program and track the receipt of required information. At least three types of reporters are envisioned: ! Part 75 reporters (submitting SO2 emissions reports directly to EPA); ! Hourly non-Part 75 reporters; and ! Annual reporters (not participating in trading because of monitoring limitations). For each of these type of reporting there are distinctly different reporting obligations and functionality to support submissions and reported information. Monitoring and Emissions Information for Part 75 Units. For Part 75 affected sources who are reporting SO2 monitoring and emissions data directly to EPA, the assumption is that redundant submission of these data would not be required. Instead, the WEB EATS would access or receive information from the EPA system about submissions and reported values under Part 75. Although EPA does not share these data directly with other data systems currently, it is anticipated that technological advances and the demand for shared data by other emissions trading programs would make this not only viable, but routine, by the time the program trigger occurs. Monitoring Information for Non-Part 75 Units. For non-Part 75 units monitoring under Section I of the model rule, the submission requirements are not spelled out in the model rule. We recommend and assume that the program require and support the electronic -15- WEB EATS Analysis July 18, 2003 submission of monitoring plans that are needed to establish an identification base for monitoring methodologies, monitoring locations and monitoring systems. These data are needed to support periodic reporting of hourly emissions data and to ensure that the data from monitoring systems are certified and quality assured. Tracking capability would be needed to assist in identifying whether required submissions (electronic and hardcopy) have been received, reviews conducted and approvals issued. This capability would assist States and Tribes, the TSA, and source representatives in the implementation phase of the monitoring program. Because monitoring plans contain important components which are either graphics or documentation and are not easily stored as data elements, system designers should consider including document management capability to complement the tracking of information and sharing of data between all parties. A robust document manager could provide a submission process and eliminate or greatly reduce submission of hard copy material. This is an area in which technical options and standard practices may improve significantly prior to the program trigger year. Emissions Data for Non-Part 75 Units. For non-Part 75 sources required to monitor SO2 emissions, the WEB EATS would support submission, processing and storage of hourly emissions data. By current standards, the volume of and processing capability for hourly data could be large. However, it is expected that processing power and data storage capability will continue to expand and costs will decline. It is also expected that the submission process would utilize the next generation of broadband access and communication, in whatever direction technology dictates. Standardization of data reporting protocols would probably facilitate design and implementation of data submission requirements. The shape of the WEB EATS would be dictated to a large degree by available technology, supporting basic functionality of receipt, tracking, checking, analysis, and communication between the regulated sources and program management. Quality Assurance of Emissions Data. Underlying successful cap and trade programs is the assumption that the emissions recorded and traded are comparable from State to State, Tribe to Tribe and industry to industry. Clear monitoring protocols and quality emissions data are needed to maintain the viability of the program. The monitoring and emissions data collection process should include the appropriate level of checking, analysis to ensure accurate and complete monitoring and reporting. Part 75 is a useful model of standards and checking which has provided the appropriate level of market assurances about the quality of emissions. The designers and developers of the WEB EATS should provide comparable capability, including calculation checks, assessment of monitoring system quality assurance compliance, and the accuracy of missing data routines. Emissions data should be evaluated to check routinely and periodically for anomalies and inconsistencies. Petition Tracking. To meet SIP approval requirements, petitions for alternative monitoring would require joint approval of the State/Tribe and the U.S. EPA. The WEB EATS should provide a mechanism to track petitions and their approval and disapproval in a centrally -16- WEB EATS Analysis July 18, 2003 accessible location for all State, Tribal and EPA program administrators. The WEB EATS should highlight and define electronically any aspect of the petition which results in allowable changes to reporting of monitoring or emissions data. Annual Emission Statements for Reduced Monitoring Units. For units with reduced monitoring requirements under Model Rule Section I1.(b), the owner or operator would submit an annual emissions statement. The WEB EATS would track receipt of these submissions and record the emissions value reported. Annual production data or other information may also be required on a case-by-case basis as a condition of State or Tribe acceptance of the request under Paragraph b. These data should also be recorded in the data system. 2. Core Data Entities and Attributes ! Tracking. Including projected monitoring and reporting deadlines, submissions, and approvals or other status. ! Emissions Methodology/Reporter Type. Compliance period, Facility/Unit. ! Monitoring Locations. Units, stacks and pipes and attributes. ! Monitoring Systems Detail. Monitoring systems, formulas. ! Certification and Ongoing Quality Assurance Test Data. Test dates, overall results, test detail data. ! Cumulative Quarterly and Annual Emissions. ! Hourly Emissions Data. 3. Core Functional Requirements ! ! ! ! ! ! ! ! Track deadlines, requirements and submissions. Communicate with users about upcoming deadlines or deficiencies. Receive emissions report, quarterly and annual. Receive original and revised monitoring plans. Receive monitoring system certification and quality assurance data. Receive quality assurance test data and perform quality assurance checks. Address data quality problems. Provide final emissions data for annual compliance. -17- WEB EATS Analysis July 18, 2003 H. Program Assessment and Analysis 1. Description Ongoing program assessment and evaluation is an explicit responsibility of the TSA and the system design and requirements should reflect the needs for various types of assessment including: environmental benefits, geographic impacts, market function, implementation successes and failures, co-benefits, and SO2 control strategies. In each of these areas, the proposed database design should be evaluated to determine whether anticipated needs will be met. The analytical utility of the data in WEB EATS will be enhanced in some cases by ensuring that accurate and complete links to other databases are supported and maintained. Similarly, geographic analyses will be enhanced by having high quality and complete locational information. These data will facilitate the availability and use of deposition and other modeling data. It is important to consider the needs of users who want access to basic and repeatable analyses and the needs of users who want access to the data to perform complex analysis or one-time analysis. The basic user may best be served by providing standard reports designed to provide a program overview, summary statistics or status reports on specific types of activity. Combined with basic filtering and sorting options, a well designed report will meet many of the ongoing needs. More flexibility in data analysis could be provided by developing a more robust query tool, perhaps with control over report formats and output file types. For the high end user with more complex analytical needs or requiring use of data volumes beyond the capability of the user interface platform, the ability to request and deliver data in standard formats should be considered. If it is determined that the basic user needs include access to large volumes of data in predictable summary formats or quick access to complex data, the design and development of a data warehouse to facilitate this access should be considered. 2. Core Data Entities and Attributes ! Data warehouse. To provide easier access to aggregated data for analysis purposes. 3. Core Functional Requirements ! ! ! ! Generate standard reports. Provide data query tool. Provide capability for data export and delivery. Provide links to other information systems. -18- WEB EATS Analysis July 18, 2003 I. Public Information Needs and Requirements 1. Description To support market trading, information about market activity must be available to market participants and the general public. This includes, in particular, information about allowance trades and the identity of market participants, including representatives. The specific data content would be evaluated in detail at the time of design and development. It is expected that public access to some data, for example the tribal allocations for set-aside, would be limited. It should be noted that the timeliness of the data is a critical aspect; but it may be appropriate to provide access to different types of information at different intervals. For example, a daily update cycle for allowance trading and representative changes has been adequate for the Federal trading programs; access to reported emissions data may be provided quarterly or even annually. The ease of access for the public is also important. The current standard is to publish data though the Web, either in a readable format such as .pdf, in a standard spreadsheet format or through a query tool which retrieves and displays data in .html format through a browser. Although the technology available for public access to information in the next decade is not easily predicted, it would be expected that similar methods of providing access would be selected. The technical architecture and data formats should be selected based on security, speed or performance, overall accessibility to the technology, and flexibility offered in terms of both output and format. 2. Core Data Entities and Attributes ! Data warehouse. To provide easier access to aggregated data for analysis purposes. 3. Core Functional Requirements ! Timely public access to source inventory, account, allowance and representative information. ! Public access to periodic emissions data. ! Data downloading or extraction. IV. Types of Users As depicted in Figure 1, there are five basic categories of users for the application: State and Tribal users; industry users; general account holders; the Tracking System Administrator; and public users. -19- WEB EATS Analysis July 18, 2003 A. State and Tribal Users Staff members of a State or Tribe participating in the Backstop Emissions Trading Program would be key stakeholders and users of the application. These users would have read-only access to almost all data in the application and a variety of reports. They would provide key data to the system using a combination of data upload or on-line capability. These would include facility and unit and program applicability data, general allowance allocations, allocations from new source set asides, and approvals of monitoring submissions. These users would have no day-to-day responsibilities for the operation, management or maintenance of the application or data. Figure 4 Use Case Diagram: State and Tribal Users States and Tribes Develop Enforceable Procedures for Recording Data Allocate Allowances to New Sources Allocate Allowances to Compliance Accounts Approve Paragraph b Monitoring View Reports Approve Petitions -20- Add New Sources/Units WEB EATS Analysis July 18, 2003 B. Industry Users Representatives of the regulated community would also be key users of the application. These users would have access to data relating to sources under their control, as defined by their roles and responsibilities as source representatives. In this capacity, they would be able to maintain source and unit information, transfer allowances in compliance or general (that they set up) accounts to and from other accounts, and submit required emissions data and compliance certifications. Figure 5 Use Case Diagram: Industry Users Industry Submit Monitoring Petitions and Monitoring Plans Change Source Representatives Update Source/Unit Characteristics Change Source Owners Update Compliance Accounts Transfer Allowances View Reports Submit Emission Reports Certify Compliance -21- WEB EATS Analysis July 18, 2003 C. General Account Holders A representative for a general account would also have access to the application to update general account information, create new accounts, transfer allowances out of their general accounts to other accounts and to view reports. The general account holder would have limited (or no) access to source information, unless the holder is also a compliance account holder or until such information is determined to be public information. Figure 6 Use Case Diagram: General Account Holders General Account Holders Change General Account Representative Change General Account Owner View Reports Transfer Allowances Add/Update General Accounts -22- WEB EATS Analysis July 18, 2003 D. Tracking System Administrator The Tracking System Administrator (TSA) would utilize virtually all functionality contained within the application. In appropriate circumstances the TSA would act on behalf of State/Tribal, industry and general account users. In addition, the TSA would perform all types of system management and maintenance activities to ensure effective operation of the application. The TSA would approve access for all users of the application. Figure 7 Use Case Diagram: Tracking System Administrator Tracking System Administrator Add/Update/ Delete Facilities and Units Add/Update/ Delete/Archive Owners/ Operators Add/Update/ Delete Representatives Generate Reports Track Activities Perform Annual Compliance Assessment Add/Update/ Delete Users Freeze/ Unfreeze Account Trading -23- Populate Compliance Accounts Quality Assure Data WEB EATS Analysis July 18, 2003 E. Public Users Public users have read-only access to selected data within the system. This access would be consistent with the security requirements of the application and data. Figure 8 Use Case Diagram: Public Users Public Query Data View Standard Reports Extract Data V. Technical Architecture A key component of system design is the selection of a common architecture. One of the major components of system architecture is the number of levels or layers in a system. An application installed on a user's machine that does not communicate with any other applications or systems is a 1-tier system. A client-server system, where one application sits on a user's computer (client) and another, related application sits on the server is a 2-tier system. Most Web applications are 3-tier systems, where there is a browser and Web server (client), a business logic server and a database server. The system should be built with at least three layers to separate the display (client), business logic, and database, so that each layer could be modified without having to change other parts. The exact architecture would be determined at the time of system design. The final decisions about system architecture should consider many factors, including security, performance, and maintainability. -24- WEB EATS Analysis July 18, 2003 A. Security Due to the importance of data integrity and accuracy in the WEB EATS, security will be extremely important. The security measures should be based on current best practices and standards. The system's security can be divided into two areas: application and server level security. 1. Application Level Security The system's application level security consists of the protective measures designed into the application's code. These include the logical measures to determine which users may access which areas of the system, the manner in which session management is handled and the protection of sensitive information, like passwords, at the application level. ! Password Encryption. The system must include a process to authenticate all authorized users to the system. Today's system utilizes encryption to protect the vulnerable data elements, such as user passwords. Implementation of an extremely robust encryption, routine or its equivalent should be incorporated into the system. ! Separate Logins. Each user should maintain a unique username and password, with the password encrypted and stored in a secure database. Each user should be assigned a unique ID. ! Separate User Types. The access rights and restrictions should be controlled at the user group level. Each user group would have a unique set of rights and restrictions within the WEB EATS. Upon user login to the system, the user's specific user group security should be verified and rights and restrictions set for the session. If the user belongs to multiple user groups, they should be assigned the highest rights for a given section or action among their user groups. ! Audit Trail. The system design should include specific requirements to maintain an audit trail of data adds, updates, and deletes for critical data elements. This audit trail should be designed to detect and resolve challenges to the data (for example, allowance ownerships), and as an additional means of restoring data should there be a breach of data integrity. ! Session Management. Strict session management control, in which session tokens are properly protected and validated, is essential. When two applications are run remotely from each other (like a browser and a server), they require session tokens to be able to communicate about the application state. To prevent attackers from hijacking active sessions and assuming the identity of a user, session tokens need to be regularly revalidated. -25- WEB EATS Analysis July 18, 2003 2. Server Security The system's server level security consists of the protective measures designed to protect the server itself from inappropriate access. These include proper server maintenance and the modifying of default system passwords. ! Server-Side Data Validation and Business Logic. To the extent possible, all business logic and data validation should be checked and handled at the server level and not be coded at the client or browser level. Server-side validation improves performance and reduces the risk of a user bypassing business logic designed to prevent them from submitting invalid data. Server-side validation includes business logic as well as basic data type validation (i.e., length, range, data type, characters sets). ! Server Maintenance. The servers or host platform should be maintained according to security standards. For example, many of today's current servers are patched on a regular basis with the latest security releases as soon as they are available. Because flaws in server software are usually well known in the hacker community, it is important to protect the server from attackers. ! System Passwords. The system passwords to the servers or host platform should be modified from their defaults and changed on regular intervals. Because the default passwords for commercial servers are commonly known, they pose a security threat and should be changed. Also, standard security practices should be followed regarding the regular changing of passwords. 3. Physical Data Security Physical data security should be provided by the measures to protect the data center, a specialized facility that hosts an application, from dangers. These dangers include theft, natural disasters, manmade catastrophes, and accidental damage (e.g., from electrical surges, extreme temperatures, spilled coffee, etc.). The data center that hosts the WEB EATS should maintain strong security practices and undergo periodic audits. 4. Backup and Recovery The database should be backed up at least daily and the application files should be backed up regularly. It may be advisable to back-up the allowance transaction data at a more frequent interval, based on the frequency of use and level of recoverability deemed necessary. A copy of the backup files should be stored off-site from the data center to ensure minimum downtime should a catastrophe occur. -26- WEB EATS Analysis July 18, 2003 A Catastrophe Recovery Plan (CRP) should be created to enable the application to return to service as soon as possible following a catastrophe. Most CRPs contain the following: ! ! ! ! ! ! ! Threat analysis, Risk assessment, Mitigation steps, Response and recovery plans, Damage assessment process, Salvage procedures, and Rehabilitation plans. B. System Performance The system's performance can be greatly improved with the intelligent application of best practices and procedures for performance tuning and system design. These include the following: 1. Database Design and Query Optimization The database should be designed with performance in mind. All database queries should be optimized to maximize performance. Use of views and indices or similar database functionality should be considered to maximize database performance. By limiting the results to only those that will be utilized immediately, the system will minimize the server and network resource load. 2. Session Variables System design or programming technologies that overuse session variables can degrade the performance of the system. Therefore, only information that absolutely must be maintained to keep the session active should be stored in session variables. Following a user logout or the expiration of a short time limit, session variables should be explicitly purged from memory. 3. Archiving Data Data should be archived regularly to conserve database space and enhance performance. A mechanism should be provided for retrieving the archived data for reporting purposes. 4. Data Volume The data volume of the WEB EATS will be largely determined by the number of sources and the frequency of data collection. With a planned number of sources of less than a thousand, which may include the periodic submittal of hourly data collection, the database is -27- WEB EATS Analysis July 18, 2003 projected to grow approximately 4GB per year. To ensure maximum performance, the database should be regularly re-indexed and monitored for performance. It is recommended that the emissions data collection component sit on a separate server from the business logic server for performance gains. 5. Frequency of Use The system design should take into account the number of users, the level of access, and the volume of data provided by users for specific processes. The WEB EATS usage is expected to be well within the normal expectation of capability for a small to moderate size application. For emissions data submission, the volume of data may be relatively high (by current standards) and require special design consideration. C. Maintainability To achieve a flexible system that evolves with program needs, the system should be developed for maximum maintainability. If the application is based on vendor software, it should be built upon well-known technology and platforms. If it is custom developed, it should be well documented and based upon best programming practices and standards and developed in a common development language. These measures will minimize time and cost to maintain the application following implementation. In addition, the programming team should be required to adhere to programming standards, including code organization and documentation, to facilitate support and enhancements after deployment. Post-deployment modifications should be developed by a set protocol including input from users. D. System Outputs The system should support various types of outputs, including data transfers, electronic communications, like email, and connections to external systems. During the system design, the needs of the proposed users and the archiving of data should determine exactly which system outputs should be available. 1. Data Transfers The periodic transfer of emissions and related data should be communicated to the application via a standard information exchange protocol. The exact protocol and procedure will need to be determined based on best practices and volume of data at the time of implementation. Each data record should be error checked to verify its integrity during the submission process. -28- WEB EATS Analysis July 18, 2003 2. Electronic Communications The application should contain functionality that notifies parties via electronic communication upon the execution of certain actions. These actions would include, for example, allowance transfers, freezing/unfreezing accounts, and system maintenance notices. The exact list of actions, subsequent message media, recipients, and structures should be determined as part of system design. 3. External System Connections The application would be expected to provide data to external data systems such as the Emissions Inventory System that the WRAP will be using to perform the program trigger evaluations tracking. The system should also support connectivity with the National Environmental Information Exchange Network and Tribal Emissions Implementation Software Solution (TEISS). The exact methods used to connect other systems will be determined at the time of system design. The application should also be able to communicate and transfer data files to and from other EPA data and allowance tracking systems, such as the system supporting the federal SO2 emissions trading programs. E. Application of Platform Selection Criteria During the preliminary phases of the system design, a significant decision will be the selection of the technology platforms or architecture for the system. These platforms include the Web server, business logic server, database server, and client interface. For each of these platforms, consider these issues with the following questions in mind: ! Data volume. Will the volume of data which must be maintained, transferred and analyzed be supported by the database and/or the application? Be sure to calculate the data volumes over the estimated life cycle of the project keeping in mind any applicable program specific or overarching regulatory requirements relating to government recordkeeping. ! Performance. What are the minimum performance requirements for basic application tasks, such as accessing the system, updating source information, transferring allowances? What are the minimum performance requirements for infrequent tasks, such as annual compliance assessments, data quality analyses, or submitting hourly emissions data? What are the performance requirements for reports? ! Relative Costs. What are the overall cost constraints? What is the acceptable ratio of design costs to development costs and initial deployment costs versus maintenance costs? Research these issues for comparable systems and platforms. -29- WEB EATS Analysis July 18, 2003 ! Maintainability. What specific standards and assumptions should be imposed for maintainability? ! Connectivity. Which connectivity standards should the system support? ! Efficiency. Are there specific design choices which will impact the efficiency of program implementation? Examine design options and platform options to maximize efficiency benefits of the information system for the overall operation of the program. To what extent should the efficiency benefits to regulated industry, general account holders and the public be taken into account? ! Availability. What level of system availability is acceptable for each type of user? VI. Design and Development Approach The second objective of this document is to serve as a roadmap to help the States and Tribes implement the program once it has been triggered. Outlined below is an implementation methodology that the States and Tribes can follow to design, develop and deploy the system. In addition, this section provides an analysis of cost and scheduling factors that should be considered. A. Recommended Implementation Methodology Upon the trigger of the WEB Trading Program, detailed system requirements will need to be assessed. The following section recommends, steps to design, develop and implement an information system for the program. It is recommended that a workgroup be created and assigned responsibility for this task. The workgroup should be comprised of user group representation, program analyst(s), and technical specialist(s). 1. Requirements Verification The first step following the need to implement the program will be to verify the requirements of the information system. Since many of the procedural elements of the SIP/TIP will be decided in the future, the exact functionality may have changed since the creation of this document. Therefore, detailed requirements should be verified and incorporated into a system analysis document. It is expected that this stage of the process will require significant participation of all stakeholders, particularly the States and Tribes participating in the program. 2. Assessment of Current Standards and Technology Following the verification of requirements, the workgroup should research and assess the current standards and technologies applicable to this type of information system. Since this application would probably not be designed until many years after this document, it was -30- WEB EATS Analysis July 18, 2003 determined that the current standards would have little value and these have not been evaluated or referenced. 3. Technical Architecture Option Evaluation Just as the standards and technology should be evaluated, so should the possible technical architectures, as discussed above. Most systems at the time of the creation of this document are 3-tier, but that should certainly not limit the architecture of the WEB EATS. Also, the suggested measures for security and maintainability may no longer be applicable, and should thus be re-evaluated. 4. Closeness of Fit Based upon the system analysis requirements, standards, and architecture assessments, the workgroup should perform a Closeness of Fit study to analyze the available products, technologies, and platforms available. By analyzing the field of products, technologies, and platforms available, the Closeness of Fit study should conclude with a recommended product or set of development technologies and standards. 5. Decision Based upon the Closeness of Fit study, the workgroup should select a product from a vendor(s), develop a custom system, or a combination of the two. 6. Design/Customization/Development Strategy Following the decision to either select a Commercial Off-the-Shelf (COS) product, develop a custom application, or customize an existing application, the workgroup should select a developer and/or TSA to design, develop and implement the system. The development plan should include a careful review of the schedule of program implementation and requirements to ensure that the necessary elements of the application are in place at the appropriate time. A staged process, with design, development, and deployment of specific system modules, is recommended. For example, the initial phase of development would probably focus on the source registration capability and initial allowance allocations. Later development could include allowance transfers capability, annual compliance assessment or overall program assessments. 7. Development Following agreement upon the system design, the developer or TSA should develop the system utilizing modern development best practices and procedures. It is recommended that the -31- WEB EATS Analysis July 18, 2003 developer and/or TSA work with the members of the requirements gathering workgroup to reaffirm and adjust requirements as needed. 8. Quality Assurance/Testing Following the successful development of the system, the developer/TSA should submit the system for rigorous testing. A test environment should be set up and a test database should be populated with data that closely match the quantity and type of data that will be utilized during live transactions. All phases of the system should be rigorously tested by the developer/TSA, States and Tribes, and a select group of end-users. 9. Deployment Following successful quality assurance of the system, the workgroup and the developer/TSA should agree that the system is ready to be deployed or implemented in a production environment. Prior to production, the database will need to be populated with the necessary baseline information including source inventory data, emissions data, users, etc. The developer/TSA should provide training/instructions to users of the system along with appropriate documentation. It is assumed that participating States and Tribes will work closely with the TSA to define and implement a communication strategy to ensure compliance with all program requirements and full use of the information management system developed to ensure its success. B. Timing/Schedule If there is no significant delay after program trigger in the initiation of the information system design and development process and if a staged approach to deployment is adopted, then an implementation schedule in which the necessary system elements are in place is achievable. This objective should be stated at the outset of the project. It should be noted that the use of COS or the customization of an existing system might reduce the initial development time for the system. To fully design, develop and deploy a custom application by today's standards might extend one to two years. Additional time might be necessary if there were significant issues relating to functionality or process about which State and Tribal participants could not agree. Technology trends indicate that forthcoming design and development methodologies will likely reduce this estimate. C. Cost Factors Factors driving the cost of the information system include technical platform, design complexity, data volume, security level, and the level of and approach to integration with other data systems. The availability of and use of COS or another application as the basis for the application would also affect costs. -32- WEB EATS Analysis July 18, 2003 1. Technical Platform The technical platform includes the server software and business logic systems that are required. There are a wide range of options for the level of solution required and cost. A middle-ground solution is most likely the most suitable for the WEB EATS, one that maximizes flexibility and maintainability. 2. Design Complexity The level of complexity incorporated into the system design will be a large cost factor. Generally, the more complex systems are, the more they cost. Based on the current system analysis, the system design appears to be moderately complex. As with any application, the requirements phase of the project may result in relatively more or less complex requirements, directly affecting costs. 3. Data Volume The amount or volume of data will be a key cost driver in selecting the database server. If only one database is utilized for both the allowance and emissions data in WEB EATS , the database will grow quickly and will require a high-end solution to maintain performance levels. It is expected that the relatively high data volume will require database optimization and regular tuning, which will add to the maintenance costs. 4. Security Level The level of security built into the system will certainly affect the cost. The more robust the security model is, the more time consuming and costly to implement. The security level detailed in Section III(A)(I) dictates a moderate level of security. VII. TSA Responsibilities and Performance Criteria A. TSA Responsibilities The Tracking System Administrator (TSA) will have responsibility for the deployment of the site, ongoing maintenance and the day-to-day program implementation tasks associated with the program. It seems likely that the TSA would also design and develop the information system, but it is not necessary that both development and support should be provided by the same organization. Regardless, the ongoing responsibilities of the TSA would include two types of support: information system and program implementation. -33- WEB EATS Analysis July 18, 2003 1. Information System This category of support is to ensure that the information system is properly administered, supported and performs all required functionality. ! Data security. The TSA would assume responsibility for ensuring that the security of the site and the data is monitored and protected on an ongoing basis. This would include monitoring access to the site and attempted but failed access (particularly if occurring in significant volume). ! Data integrity. The TSA would assume responsibility for ensuring that the integrity of the data is monitored and protected on an ongoing basis. This would include ensuring that the referential integrity of the data is maintained, a data backup plan is implemented, and any opportunities for data corruption are identified and addressed. ! Data quality assessment and corrective maintenance. The TSA would develop within the application and be responsible for performing data checks to identify duplicative information, data omissions or other data of poor quality that are not easily prevented by error checks or data standards. The TSA would make corrections to the data, as necessary, and maintain documentation of changes. ! WEB EATS enhancements. The TSA would document and evaluate any proposed enhancements, modifications or additions to the application. Working with the State/Tribe participants in the trading program and within established budget constraints, the TSA would perform, test and deploy the modifications (in coordination with the assigned programming team). ! WEB EATS documentation. The TSA would have responsibility for maintaining all technical documentation for the WEB EATS (including enhancements and for maintaining records relating to its ongoing operation). ! User technical support. The TSA would provide technical support to all users of the application. This would include telephone support and responses to requests or inquiries through other means of communications. The TSA would maintain records of all technical support and the TSA response. Technical support needs could also be addressed through the use of other support tools, comparable to the FAQs or online support systems currently in use. ! Performance monitoring. The TSA would be responsible for monitoring the overall performance and availability of the application for all types of users. This would include identifying the causes of any disruption of service or availability and identifying any persistent problems experienced by the user community. -34- WEB EATS Analysis July 18, 2003 ! Database administration. The TSA would monitor data performance and perform all maintenance and optimization tasks affecting the performance of the database. The TSA would maintain records of all database administration activities. 2. Program Implementation The TSA is also expected to implement the program for the consortium of States and Tribes participating in the program. This is necessary to ensure that the program will be implemented consistently and cost effectively. ! User access administration. This support would include evaluating and responding to user access requests, password changes, and related usage issues. ! Coordination with States and Tribes. The TSA will coordinate, as necessary, with each State or Tribe participating in the program to ensure that the State or Tribe fulfills their responsibilities and is aware of the need for their participation in decisions or issues. This includes aiding the States and Tribes in developing enforceable procedures for recording the necessary data. For example, the TSA would obtain allocation lists, petitions, retirement approvals, information about new sources, and reduced emissions monitoring under Section I1.(6) of the model rule from the State or Tribe. ! Perform allowance allocations. Using the information provided by the State or Tribe, the TSA would perform allowance transfers from government accounts to compliance accounts. The TSA would provide a report (or electronic file) to the State or Tribe of these actions. ! Periodic status reports on system activity and program implementation issues. On a regular basis (monthly, quarterly and annually), the TSA would provide to the participating State and Tribes a summary of program activity. This report would include, for example, a summary of allowance transfer activities, a status report on emissions reports, or the level of public access to the database. ! Annual compliance assessment. The TSA would perform the annual compliance assessment or true-up and would coordinate with industry, States and Tribes regarding the results of this process. Following review or approval by the participating States and Tribes, the TSA would finalize the compliance assessment by retiring the appropriate number of allowances from compliance accounts. An end-of-year compliance report would be made available. ! Communication strategy development/implementation/support. Throughout the life of the program, the TSA would work with the participating States and Tribes to maintain and implement a communication strategy and plan. The purpose of the plan would be to ensure full participation of affected sources in the emissions trading program and to -35- WEB EATS Analysis July 18, 2003 maximize understanding of and knowledge about the program among all interested parties. The content of the plan would include a strategy for general guidance, day-today communications to sources about their actions (transfer confirmations, data receipts, etc.), State/Tribal reports, communications between States and Tribes about ongoing program issues such as monitoring approvals or petitions, participant or public meetings and publications containing program results or environmental assessments. ! Overall program assessment. The TSA would assist the States and Tribes in designing and conducting an assessment of the overall program operation, costs, and environmental benefits on a periodic basis. ! Error correction, followup and documentation. The TSA would be responsible for correcting any data entry errors reported by users that are not within the security limits for the user. B. TSA Performance Criteria To ensure adequate support for the program, it will be necessary to establish performance criteria for the TSA. 1. Technology Standards For the WEB EATS and technology support, the key criteria should be based on technology standards prevalent at the time of deployment and they should be tailored to the technical architecture selected for the WEB EATS. The following criteria would fall into this category and should be defined at the appropriate time. The importance of each of these factors should also be considered during the WEB EATS system design phase and in the selection of a technical architecture. ! System performance (response time, number of concurrent users supported, frequency of WEB EATS or database errors, etc). ! System availability (average downtime). ! Timeliness of public access to data. -36- WEB EATS Analysis July 18, 2003 2. Contract Performance Standards Other important criteria relating to TSA performance would be the traditional criteria relating to overall performance with respect to basic contract terms. These would include: ! ! ! ! Responsiveness to customer concerns, Timeliness and quality of status reports, Overall cost, and Budget accuracy. -37- WEB EATS Analysis July 18, 2003 References 1. Jenkins, George Henry. Information Systems Policies & Procedures Manual. Paramus, NJ: Prentice Hall, 1997. 2. "The Ten Most Critical Web Security Vulnerabilities." The Open Web Security Project. 13 Jan. 2003. . 3. United States Environmental Protection Agency. Clean Air Market Programs. Emissions & Allowance Tracking System. 4. United States Environmental Protection Agency. State/EPA Information Management Workgroup. Blueprint for a National Environmental Information Exchange Network. June 2001. -38- Appendix A-8c. Recommendations for Making Additional Determinations in the Context of Reasonably Attributable BART Appendix A-8 – SO2 Milestones/Backstop Arizona Regional Haze SIP Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable BART Prepared by: The WESTAR Council Prepared for: The Air Managers Committee, Western Regional Air Partnership May 2003 Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable BART Prepared by: The WESTAR Council RA BART Phase II Working Group: Alice Edwards, Alaska Department of Environmental Conservation; Mike Sundblom, Arizona Department of Environmental Quality; Deb Wolfe, Montana Department of Environmental Quality; Dana Mount, North Dakota Department of Health; Dave DuBois, New Mexico Environment Department; Colleen Delaney, Utah Department of Environment Quality; Alan Newman, Washington Department of Ecology; Lisa Reiner, Quinalt Indian Nation; Bruce Polkowsky and Kristi Gebhart, National Park Service; and Kristin Gaston and Bob Lebens, WESTAR. Prepared for: The Air Managers Committee of the Western Regional Air Partnership in fulfillment of the Western Governors’ Association contract #30203-13 May 2003 Acknowledgements The recommendations regarding the attribution process, the applicable technical approaches and the examples in this report are the product of the RA BART Phase II Working Group. The WESTAR Council acknowledges the generous support of all the Working Group members. Alice Edwards, Alaska Department of Environmental Conservation; Mike Sundblom, Arizona Department of Environmental Quality; Deb Wolfe, Montana Department of Environmental Quality; Dana Mount, North Dakota Department of Health; Dave DuBois, New Mexico Environment Department; Colleen Delaney, Utah Department of Environment Quality; Lisa Reiner, Quinalt Indian Nation; Bruce Polkowsky and Kristi Gebhart, National Park Service; and Kristin Gaston and Bob Lebens, WESTAR. Authors of the Attribution Techniques (Section VI) are Mike Sundblom (Monitoring); Kristi Gebhart (Receptor Modeling); and Dave DuBois (Source Modeling), with assistance from Ajith Kaduwela, California Air Resources Board. Bruce Polkowsky and Colleen Delaney drafted the certification section and provided liaison between the Western Regional Air Partnership Market Trading Forum and the Working Group. Alan Newman, Washington Department of Ecology drafted the portion of the report outlining the example process to which Dana Mount also contributed. Kristin Gaston drafted the regulatory context section and along with Bob Lebens, edited the report. EXECUTIVE SUMMARY This report recommends a general procedure and applicable technical approaches that may be used by states and tribes to assess reasonable attribution in response to a Federal land manager (FLM) certification of visibility impairment in a Class I area (Certification). WESTAR formed the Reasonably Attributable Best Available Retrofit Technology (RA BART) Phase II Working Group with Federal land management agency staff and members of state and tribal air quality agencies knowledgeable about RA BART and associated monitoring and modeling techniques. To provide the necessary framework, the report provides background information about both the certification process and the attribution determination process. However, the recommendations focus on the general principles of the attribution assessment process and the technical criteria used in the assessment. The recommendations are summarized below: General Principles: The attribution assessment should be: A collaborative process that relies on existing data with minimal additional analyses. Technically and legally defensible. Accomplished at a reasonable cost and within a reasonable time frame. No more complex than necessary. Performed by state or tribal agency staff. Adequate to determine whether or not visibility impairment is attributable to an existing stationary source potentially subject to BART. Technical Criteria: Emissions from BART-eligible sources must “cause or contribute to” visibility impairment. Visibility-impairing pollutants of concern must be identified. Factors to consider in assessing impairment include: duration, frequency, geographic extent, magnitude, and time of occurrence. Identify distance from source to Class I area to determine appropriate tools for characterization of the impairment. Quantitative results are preferable, although qualitative results such as photographs may be adequate. Use as many different indicators of impairment as practicable rather than relying on a single indicator. Consider level of uncertainty in the assessment. Use EPA guideline models whenever practicable. Table of Contents I. Background....................................................................................................... 1 A. Introduction and Purpose B. Regulatory Context II. Federal Land Manager Certification of Impairment ........................................ 7 III. The Attribution Determination Process……………………………………...11 IV. General Principles and Criteria ...................................................................... 17 A. General Principles of the Attribution Process B. Technical Criteria C. Examples of the Attribution Process V. Techniques...................................................................................................... 31 A. Monitoring B. Source Modeling C. Observational Modeling VI. Appendix RA BART Rule (40 CFR 51.300-306) I. BACKGROUND A. Introduction and Purpose Reasonably Attributable Best Available Retrofit Technology (RA BART) is the portion of EPA’s visibility rule published in 1980 and codified in 40 CFR 51.302–51.306 that deals with visibility impacts from one source or a small groups of sources. RA BART refers to reasonably attributable visibility impairment and best available retrofit technology for eligible sources and emission limits, and emissions controls as defined by the statute and the rules. Some confusion exists regarding the application of RA BART, the process of assessing sources of visibility impairment, and the technical tools available for an RA BART attribution determination. RA BART is a statutory requirement, although certain of the requirements may no longer be applicable when a source complies with BART or installs BART-like controls or after a state implements a trading program under 51.308(e)(2) or any trading program under 51.309, and if no remaining visibility impacts continue from one source or a small group of sources. This report, therefore, addresses the RA BART attribution process and builds upon case studies WESTAR developed in 2001 to examine and document how Reasonably Attributable Visibility Impairment (RAVI) had been addressed in previous assessments.1 The Federal land managers (FLMs) advocate maintaining RA BART as a tool because RA BART is effective when new monitoring indicates that a previously un-monitored area has visibility problems differing from the regional visibility impairment conditions at other areas. In addition, RA BART is effective when BART-eligible sources in the vicinity of the protected area are causing or contributing to identified visibility impairment.2 First, this report recommends attribution process principles and assessment techniques a state or tribe may consider in an attribution assessment to identify if, and to what degree, an existing source or small group of sources causes or contributes to visibility impairment. The report focuses on RAVI and does not specifically address impairment due to regional haze. Although this report includes references to regional haze, such references serve only to place the attribution process in the larger context of the broad regulatory framework that addresses visibility impairment, including the regional haze regulations. Second, this report includes no recommendations with regard to establishing a threshold level at which reasonably attributable impairment exists. Instead, the working group outlined a recommended general process and recommended technical procedures that may be used as guidelines if an attribution assessment is necessary. Due to the circumstances unique to each attribution assessment and the requirement that the assessment be conducted on a case-by-case basis, recommending one specific analysis for every situation was not possible. A state or tribe should select from the techniques summarized in Section IV. Section IV(C) includes five examples of the attribution assessment process, each providing a range of techniques to be used 1 WESTAR Council, RA BART and RA BART-like Case Studies, June 2001. This document specifically relates to RA BART and does not address broader issues relating to long-term visibility strategies. FLMs generally do not intend to issue Certifications citing specific sources except for situations involving BART sources. 2 1 based on available data. The examples also recommend more refined analyses that may require additional data. Third, this report includes specific information about the current policy of FLM agencies regarding certifications of impairment (Certification), but makes no recommendations regarding the certification process. This report makes no recommendations regarding state process following an attribution determination nor examines options for performing the Best Available Retrofit Technology (BART) analysis or the incorporation of BART requirements into State Implementation Plans (SIPs). Tribal Implementation The recommendations in this document are intended to help states assess reasonable attribution following Certification by an FLM. Subject to the requirements of the Clean Air Act, 42 USC 7601(d) and the Tribal Authority Rule, 40 CFR 49.1– 49.11, a tribe may accept responsibility for making reasonably attributable determinations in response to a Certification by an FLM when a BART-eligible source identified by the FLM in the Certification is on the tribe’s land. The regional haze rule also explicitly recognizes the authority of tribes to implement the provisions of that rule on tribal lands. Those provisions create the following framework: 1. Absent special circumstances, reservation lands are not subject to state jurisdiction. 2. Federally recognized tribes may apply for and receive delegation of federal authority to implement CAA programs (including visibility regulation), or “reasonably severable” elements of such programs. The mechanism for this delegation is a Tribal Implementation Plan (TIP). A reasonably severable element is one that is not integrally related to program elements that are not included in the plan submittal, and is consistent with applicable statutory and regulatory requirements. 3. Where a tribe does not seek delegation through a TIP, the Environmental Protection Agency (EPA), as necessary and appropriate, will promulgate a Federal Implementation Plan (FIP) within a reasonable timeframe to protect air quality on tribal lands. Accordingly, these recommendations also may assist a federally recognized tribe that chooses to adopt a TIP to implement the RA BART provisions. In some cases, a tribe may be able to utilize the recommendations in much the same way as states. In many other cases, however, the recommendations may be modified to meet the unique situation of the tribe and the nature of its air program, including its manner of defining “reasonably severable elements” and its method of dividing responsibilities between the tribe and EPA. Because of these differences, the recommendations that follow do not refer to tribes every time states are referenced. B. Regulatory Context The national goal for visibility is set forth in the Clean Air Act (CAA) at 42 USC 7491: “the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from manmade air pollution.” The requirements apply to 156 designated Class I areas. 2 As stated previously, Congress required that states provide a remedy for visibility impairment that was “reasonably attributable” to one source or a small group of sources. (42 USC 7491). Congress directed EPA to ensure that all SIPs contained measures necessary to make reasonable progress toward meeting the national goal, including requirements for identifying major sources of emissions causing or contributing to visibility impairment, and requirements for the application of BART on such sources. EPA promulgated rules pursuant to Congress’s directive to provide guidelines to the states on appropriate techniques and methods for implementing the SIP requirements. (40 CFR 51.302(c)). (Note: when this report refers to a “source” within the meaning of this regulation, the phrase “or a small group of sources” is implied.) The requirement to install Best Available Retrofit Technology controls on existing sources is a key element of the visibility protection provisions in the CAA demonstrating the need to focus on pollution emitted from a specific set of existing sources. Sources are potentially subject to BART controls if they meet the following criteria: 1. 2. 3. A major stationary source from 1 of 26 source categories identified in the CAA and regulations (see Appendix A); Potential to Emit (PTE) 250 tons per year of any air pollutant; and, Not in operation prior to August 7, 1962 and “in existence” on August 7, 1977. In the 1980 visibility rule, EPA used the term “existing stationary facility” to define a facility that met the above criteria. However, to avoid any confusion about whether that term encompassed a larger group of sources, EPA now uses the term “BART-eligible source.” The term “BART-eligible source” is used throughout this report for similar reasons, but the reader should be aware that some sections of the visibility rule still refer to “existing stationary facilities.” For purposes of the attribution discussion in this paper, these terms are interchangeable. In 1999, EPA added two new sections to the visibility rule to address regional haze (40 CFR 51.308 and 51.309). Pollutants causing regional haze may be transported hundreds of miles, and therefore, regional haze must be addressed as a broader regional issue. The 1980 visibility rule focused on direct visibility impacts of an individual source or small group of sources. The 1999 revisions are commonly referred to as the regional haze rule, although the 1999 rule incorporates the earlier requirements for BART as well as the new regional haze provisions. To remedy RAVI, the regulations outline a process to identify and control emissions from sources that are directly impacting visibility at specific Class I areas (40 CFR 51.302). Three primary steps in this process are: 1. The Federal land manager certifies impairment; 2. The state identifies existing sources that cause or contribute to the visibility impairment; and 3 3. The state performs a BART analysis to determine what controls, if any, are required on any existing source that meets the BART criteria and has been identified as contributing to the impairment. Attribution Process The language of 40 CFR 51.302(c)(4)(i) provides the basic principle upon which the state will rely during the attribution process. That section states that the attribution must indicate each [BART-eligible source] “which may reasonably be anticipated to cause or contribute to impairment of visibility.” Whether or not the impairment is “reasonably attributable” is determined by “visual observation or other technique the state deems appropriate.” (40 CFR 51.301(s)). Because the state is responsible for identifying sources, this report provides recommendations for the state to consider when it undertakes an attribution determination. Once visibility impairment is identified, RAVI is addressed on a case-by-case basis. Under the 1980 regulation, a state evaluates BART-eligible sources only after an FLM certifies the existence of visibility impairment. However, in the context of the current regional haze rule, states must also address BART requirements for regional haze (RH BART).3 Several options exist for addressing RH BART. For example, rather than require a source-specific BART emission limit, a state may choose to develop a trading program, either regionally or within its own jurisdiction, that achieves greater reasonable progress than case-by-case RH BART. If a state develops a trading program, the time period to achieve the emissions reductions may be extended. As a result, visibility conditions at a specific Class I area initially may remain static or even deteriorate during the early implementation period. During this time, FLMs have indicated that the RAVI process may be utilized to provide steady and continuing improvement in visibility. Within the context of the regional haze rule, this may be an example of a “geographic enhancement.” As noted above, the recommendations in this report apply only to case-by-case applications of BART and are not intended to apply to the broader regional haze rule such as a market-based trading program implemented as part of the 1999 rule. A state may find it difficult to determine a source/receptor link for RAVI difficult when there are other sources located in the area, including international sources. However, the regional haze rule provisions do not alter the requirement to undertake the attribution assessment. State determines what controls, if any, are required After the attribution determination, the state is required to perform a BART analysis to determine what types of controls, if any, should be placed on the source(s) found to be contributing to the impairment. The following factors affect the BART determination: 1. 2. 3. Available technology; Costs of compliance; Energy and non air quality environmental impacts of compliance; 3 The RH BART provision was remanded to EPA by the U.S. Court of Appeals as a result of the ruling in American Corn Growers Association v. EPA, No. 9901348 (DC Cir. May 24, 2002) 4 4. 5. Remaining useful life of the source; and, Degree of improvement that can be anticipated to result from the use of the controls. As noted above, this report does not provide guidance regarding state process following an attribution determination nor does it examine options for implementing the BART requirement. 5 6 II. FEDERAL LAND MANAGER CERTIFICATION OF IMPAIRMENT The Federal land managers monitor visibility through a nationwide monitoring network, known as Interagency Monitoring of PROtected Visual Environments (IMPROVE). The IMPROVE network has recently been expanded and the FLMs anticipate reliable trend data for the new IMPROVE sites between the years 2006 and 2008. The FLMs plan to evaluate the current visibility conditions in Class I areas as well as trends occurring over time to identify areas where visibility is not improving. The FLMs generally will use a screening process to identify Class I areas that may be affected by RAVI. This screening process will be influenced by the approach the state relies upon to address RH BART in its SIP. There are three approaches that may be used. 1. Case-by-Case Review of RH BART under 51.308 No distinction exists between emission reductions needed to address RH BART and reductions to address RAVI, therefore, the BART process will address both types of visibility impairment. 2. Trading Program under 51.308 The FLMs anticipate that the following screening criteria may be appropriate, but will not make a final decision until a 308 trading program has been developed. The screening criteria associated with this approach may be similar to the screening criteria associated with the trading program option under 51.309. However, the FLMs have indicated that the screening criteria ultimately selected for 51.308 will depend on how the trading program is structured, the selected emissions cap, and other aspects of the trading program. Potential Screening Process Criteria: (i) Sulfate, nitrate, organic carbon, other fine particulate, etc., levels in the Class I area are not decreasing.4 (ii) One or more BART-eligible sources of SO2, NOx, VOC, PM10, etc., are located within 100 miles of the mandatory federal Class I area. (iii) The BART-eligible sources identified in (ii) are not already well-controlled for pollutants that contribute to visibility impairment. 3. Milestones and Backstop Trading Program under 51.309 The FLMs plan to sign a Memorandum of Understanding (MOU) with the participating states to define the screening criteria the FLMs will use to certify impairment. 4 The decrease of a pollutant (or secondary species of that pollutant) would be measured from the beginning of the market or emissions trading program, and such a trading program would take a long time (10 to 15 years) to reach the level of reduction that “meets” BART. The decrease would be tested over the first 5 to 10 years. A very quick time frame for reductions would negate the need for RA BART criteria. 7 Screening Process criteria:5 (i) Sulfate levels in the Class I area are not decreasing. (ii) One or more BART-eligible sources of SO2 are located within 100 miles of the mandatory federal Class I area. (iii) The BART-eligible sources identified in (ii) are not already well-controlled for SO2 (85% or better SO2 control for coal-fired utility boilers). Goal: For FLMs to complete the certification process between 2006 and 2008.6 These criteria were influenced by the design of the 309 trading program including emission reduction estimates, shape of the declining emission cap, inclusion of sources that were not BART-eligible, and inclusion of new source growth under the cap. Although geographic enhancements do not need to be addressed under the first approach, they must be addressed in the two trading programs described above because emission reductions may occur more gradually in the context of a trading program. The FLMs do not anticipate certifying impairment under these circumstances but do intend to notify the state as part of the SIP development process if concerns arise regarding “hot spot” impacts from sources that may directly affect specific Class I areas. Note: BART for regional haze has been addressed for SO2 under this option. Regional haze BART for NOx and PM will be addressed in SIP revisions that are due in 2008. In all three cases discussed above, if the FLM determines that a certification of visibility impairment is necessary, the FLM will send an official Certification to the state. The Certification will generally include the following information: 1. 2. 3. 4. 5. Class I area(s) impacted; Basis of certification (photographic documentation, monitoring, modeling, etc.); Type of impairment certified: plume impact, or layered or uniform haze; Pollutant(s) of interest; and, Preliminary identification of source(s) believed responsible for impact. FLM, State, and EPA roles in RA BART FLMs are responsible for certifying impairment. The Certification demonstrates the FLM’s determination that there is evidence of visibility impairment from one source or a small group of sources. 5 Within the context of established regional milestones for SO2 and a backstop trading program, the FLMs have said it is appropriate to use the following screening process in making these recommendations as part of the Certification. Voluntary Emissions Reduction Program for Major Industrial Sources of Sulfur Dioxide in Nine Western States and A Backstop Trading Program. An Annex to the Report of the Grand Canyon Visibility Transport Commission. Submitted by the Western Regional Air Partnership to the U.S. Environmental Protection Agency, p. 61, September 29, 2000. 6 This goal will not in any way restrict the ability of the FLMs to certify impairment at a later date if it is necessary to fulfill their statutory obligations. ibid. 8 Following the Certification, states have the following regulatory obligations: (1) identify facilities that “emit an air pollutant which may be reasonably anticipated to cause or contribute to any visibility impairment” in that Class I area, and (2) for sources subject to BART, the state must identify the BART level of control technology. If the source does not have adequate control in place, the state must establish a BART limit in the SIP. EPA has two major responsibilities for the RA BART requirement. First, in the states that do not have a SIP in place to address the RA BART requirements, but where the program is implemented through a FIP, EPA will conduct the BART analysis and establish any BART emission limits. Second, for the states with SIPs that include RA BART regulations, EPA will provide federal enforcement of state-established BART emission limits. 9 10 III. THE ATTRIBUTION DETERMINATION PROCESS This section recommends a process for the state to follow in order to complete an attribution determination after receipt of a Certification from an FLM under 40 CFR 51.302(c)(1). The Certification focuses on the existence of visibility impairment. While the FLM may identify sources or even sources areas that contribute to the Certification, the formal identification of sources is a state responsibility. The state should make a detailed review of the data supporting the Certification to determine which sources or source areas require further evaluation. If the data are insufficient to identify specific sources or source areas, the state may request that the FLM perform more detailed analyses to further substantiate the impairment set forth in the Certification. If the state determines sufficient information exists to proceed, the state should begin the process by: (1) evaluating which sources are BART-eligible, and (2) reviewing the impairment information provided by the FLM in support of the Certification. 1. Evaluate which sources are BART-eligible Congress and EPA established criteria to determine which sources are subject to BART. The categories of sources subject to BART are listed in 40 CFR 51.301, the definition of “existing stationary facility,” and also are included in Appendix A of this report. The state must confirm that the potential source or group of sources is subject to the RA BART process by examining the potential source emissions and the dates of operation. The criteria for determining if a source is BART-eligible may be complicated if a source has multiple units that were constructed at different times and a state may be unable to determine if a specific source would qualify as BART-eligible. EPA published guidelines in 1980 to aid states in implementing the 1980 rule.7 In addition to the 1980 guidelines for determining BARTeligibility, EPA also has proposed guidelines that include criteria for determining if a source is BART-eligible.8 These guidelines are expected to be re-proposed in 2004, promulgated in 2005 and codified at 40 CFR Part 51 as Appendix Y. The state should refer to both sets of guidelines to determine if a source is BART-eligible, although the proposed guidelines are not binding until final promulgation occurs. When using the applicability criteria in Appendix Y, the state should look for information readily available from existing state data such as permitting history, emission inventory, or other similar databases. 7 U.S. Environmental Protection Agency, Guidelines for Determining Best Available Retrofit Technology for Coalfired Power plans and Other Existing Stationary Facilities, EPA-450/3-80-009(b), Office of Air Quality Planning and Standards, Research Triangle Park, N.D., November 1980 (1980 BART Guidelines). 8 66 FR 38108 Proposed Guidelines for Best Available Retrofit Technology (BART) (July 20, 2001). EPA will repropose these guidelines as a result of the remand in American Corn Growers v. EPA. 11 1. If a database of Potential To Emit (PTE) is not available, state emission inventories can be a useful screening tool to determine whether a source meets the size criteria (for example, identify all sources with emissions greater than 100 tons/year of visibility impairing pollutants). Operating permit applications may also contain information about the PTE of a source, or individual units within a source. 2. State business records may be useful to determine when the facility was constructed or when it commenced operation. Newspaper article searches or a detailed historical review of each source may also provide useful information. 3. The state should require the source to provide information regarding the construction dates of individual emission units. 4. Institutional memory within the air agency can be invaluable if records of construction dates of major emission units are not available, although memories will not withstand legal challenges like hard documentary data. 5. New Source Review permitting records may be useful to identify new units that were constructed after 1977, determine the PTE of the source, or determine if reconstruction has occurred. (Note: the draft guidelines in Appendix Y state that modifications at a source do not affect applicability unless the change qualifies as reconstruction of the source). If the source or group of sources identified in the Certification is not BART-eligible, the state should inform the FLM of its finding. The state should look in the vicinity of all the sources suspected of causing or contributing to the impairment identified in the Certification. If no BART-eligible sources exist, an attribution assessment is unnecessary. 2. Review Support Information in the FLM Certification Initially, the state should acquire all the supporting information the FLM used in the Certification and independently evaluate the data. This initial review will help the state determine if the information is sufficient to support a reasonable attribution determination. The state should consider the type of impairment in the Certification: (a) plume impact visibility impairment, (b) uniform haze visibility impairment, or (c) layered haze visibility impairment: (a) Plume impact is the impairment addressed by the original visibility protection program under which the state must make a reasonable attribution determination before proceeding to the BART analysis (40 CFR 51.30151.307). (b) In some instances, uniform haze may be thought to be source-specific haze from a BART-eligible source. If a state can successfully demonstrate there is a source emitting any air pollutant that may reasonably be anticipated to cause or contribute to any impairment of visibility, the state should consider that portion of the uniform haze to be impact from the identified source(s) and, therefore, consider the source to be subject to BART. (c) The visibility impairment may also be defined as layered haze, a condition that results when aerosols are “trapped” under stagnant air mass conditions. 12 Once the FLM has issued a Certification, the responsibility for the attribution assessment shifts to the state. If a state does attribute impairment to a source, the state must be able to defend its finding that one or more BART-eligible sources did cause or contribute to visibility impairment in the Class I area. However, the Ninth Circuit Court of Appeals established a low threshold for unacceptable visibility impairment.9 3. Evaluate Existing Data not included in the Certification When analyzing supporting data, the state should determine if additional information exists that was not available to the FLM. Examples include special project camera studies or ambient monitoring data collected by the state or local air pollution control agency, the potential or actual PSD permit applicant,10 or the university. In certain situations, another agency may have previously collected information that could be used in an attribution determination.11 These data should be reviewed to determine whether they support the FLM Certification. To conclude this portion of the attribution process, the state may wish to prepare a report that summarizes its initial evaluation of the Certification. The purpose of the report is to carefully document the state’s findings and conclusions about its decisions. The report would address two questions: First, the report would assess whether any BART-eligible source(s) exist that potentially contributed to visibility impairment as described in the Certification. The report would contain a preliminary determination of whether the sources are BART-eligible and, if possible, analyze each source’s relative contribution to the impairment (based on available source/receptor information). Second, the report would assess the impairment data. This assessment would include the state’s evaluation of the supporting data in the Certification and an analysis of any additional data used in the attribution assessment. The data gaps found in this review would be identified along with any recommendations for strategies to obtain the missing information. The state may use these recommendations to determine the next steps in the attribution process. If the state believes the Certification is supported by sufficient data, proceeds with an attribution assessment and makes a determination that the data does or does not indicate a source subject to BART, the attribution process is complete. However, if the state determines the data is insufficient to complete an attribution assessment, the evaluation process ends, and the state may proceed to the next step—identification of data gaps and the studies necessary to obtain this information. 9 See Central Ariz. Water Conservation Dist v. EPA, 990 F.2d 1531 (9th Cir. 1993); See also discussion in RA BART and RA BART-like Case Studies. 10 For example, a PSD permit applicant may be required to obtain pre-application ambient air quality information, and that information may not have been available to or known to the FLM. 11 In Washington state, the plume of a defunct copper smelter has been traced by its arsenic deposition. If this were an active facility, this ground tracing of the plume could be used to support a source/receptor connection in an attribution determination. 13 4. Identify data gaps and necessary studies to fill the gaps As part of the data review, the state should note gaps or inconsistencies in the available data. Examples of data gaps and inconsistencies may include: 1. 2. 3. 4. 5. 6. Missing photos in a sequence of photos, Poor resolution of the plume or its source in the photos, Back trajectory analyses done with a very large grid resolution or poor techniques, IMPROVE monitor data missing at critical periods, Lack of association between the source’s emissions and monitored data at the receptor, Special studies performed during a time when a source that potentially contributed to the impairment was not operating, 7. Contemporaneous studies with contradictory results that cannot be explained, 8. Ambient studies that use naturally occurring tracers and, when the suspected source(s) are tested, the tracers do not exist or exist at levels far below (or above) the level indicated by the ambient study results, 9. Tracer studies where the tracer was not found at the anticipated receptors, 10. No explicit exploration of whether wildfire or other natural events significantly caused or contributed to one or more of the impairment episodes, 11. Other differences or inconsistencies in the available data. Once any data gaps have been identified, the state should decide which studies are necessary to obtain the missing information sufficient to complete an attribution assessment. The state should design potential studies and determine the resource needs of those studies. The amount of work necessary will depend on the availability of the information and how critical the information is to the attribution assessment. Section IV provides technical criteria and examples of the technical process the state may consider at this point in the process. 5. Consultation Process The WESTAR review of previous RAVI assessments demonstrated the importance of including all stakeholders in the design of any data collection plans or modeling protocols. Competing studies can be very inefficient, expensive, and time-consuming, and ultimately may not help the state make a final decision. If stakeholders are involved in the design of any data collection efforts or modeling protocols, disagreements may be resolved before the state or source continues with any additional studies. The state should consider involving the following stakeholders in the consultation process: 1. 2. 3. 4. 5. 6. Affected sources Neighboring states and tribes Environmental Protection Agency Federal land managers Local environmental groups Local permitting agencies 14 7. 6. Local government representatives Completion and Review of Additional Visibility Studies When the additional visibility studies, if any, are complete, the state should evaluate the resulting data. The technical staff may wish to finalize the report and make recommendations based on the scientific aspects of the data. 7. Final Determination of Reasonably Attributable Visibility Impairment The state may reach any one of the following conclusions: 1. 2. 3. 4. 5. The impairment certified by the FLM is reasonably attributable to the identified BARTeligible source(s) for specific pollutants; The impairment certified by the FLM is reasonably attributable to the source(s) identified by the FLM and additional sources not identified by the FLM for specific pollutants; There is inadequate data to support a determination that the impairment is due to the source(s) identified by the FLM; The impairment is reasonably attributable to other adjacent BART-eligible sources for specific pollutants; or The impairment certified by the FLM is not reasonably attributable to a BART-eligible source. 15 16 IV. GENERAL PRINCIPLES AND CRITERIA This section provides general principles and technical criteria for the state to consider after receipt of an FLM Certification. After receipt of such a Certification, the state must determine whether BART-eligible sources “emit any air pollutant which may reasonably be anticipated to cause or contribute to any visibility impairment in any” Class I area. While these principles and technical criteria should generally be useful and applicable, each state must decide what is required to support its individual determination. Part A contains general principles to guide the development of a conceptual framework for the attribution assessment process. Part B contains evaluation criteria to guide the decisions regarding a technical framework for the attribution assessment process. Conceptually, the statutory framework for an attribution determination (“may reasonably be anticipated to cause or contribute to visibility impairment”) should be the general principle guiding the attribution process. EPA maintains, and the Ninth Circuit agreed, that an affirmative attribution decision is possible even with considerable uncertainty and a low triggering threshold. However, each state should decide individually what is required to support its determination. A. General Principles of the Attribution Process Attribution process criteria address factors likely to influence the performance of the state attribution assessment. These criteria provide parameters to define and implement the attribution assessment process given resource constraints, legal considerations, administrative decisionmaking requirements, and other relevant factors. The general principles include the following: 1. Whenever possible, an attribution assessment should be a collaborative process that relies on existing data with a minimum of additional analysis (see section III). If supplemental data are needed, field studies should be designed in a collaborative process between affected states and tribes, identified sources, Federal land managers, EPA, and the general public. Past experience has shown that competing technical studies often result in an unnecessarily expensive and unduly complicated process. 2. Attribution assessments should be technically and legally defensible. 3. Attribution assessments should be accomplished at a reasonable cost and within a reasonable time frame. 4. Attribution assessments should be no more complex than necessary, recognizing that the circumstances surrounding a Certification may vary greatly. State or tribal agency staff should be capable of performing the attribution assessment and making the final determination, although contractors may be used for certain types of modeling or monitoring. 5. Reasonably attributable visibility impairment can only be identified if a source/receptor 17 links a potentially BART-eligible source or small group of sources to a Class I area. B. Technical Criteria The technical criteria address the appropriateness of available analytical techniques from a scientific perspective. The rule defines visibility impairment to mean “any humanly perceptible change in visibility (light extinction, visual range, contrast, coloration) from that which would have existed under natural conditions.” The technical criteria include the following: 1. The BART source must emit an air pollutant that may reasonably be anticipated to cause or contribute to any of the impairment. The visibility-impairing pollutants of concern must be identified. 2. The attribution assessment should address the unique visibility impairment in the FLM Certification for the Class I area. Some factors to consider include: a. Duration: source’s length of effect on visibility per episode;12 b. Frequency: how often episodes of impairment occur; c. Geographic extent: how much of the Class I area is affected by the impairment; d. Magnitude: how much visibility impairment is due to the source’s emissions; and e. Time of occurrence: including time of day and time of year. These factors need to be considered together, because they affect each other. An infrequent occurrence of a large magnitude episode may meet the criteria. A frequent occurrence of a small magnitude episode may also meet the criteria. The FLM may provide information about these criteria in the Certification, and the state should review this information as a starting point for its assessment. The state may consider other factors and data, as appropriate. 3. The attribution assessment should identify the distance from the source to the Class I area. This distance will affect the choice of tools appropriate for characterizing the specific source’s impact on visibility impairment. 4. To the extent possible, the attribution assessment should be quantitative. Under certain circumstances, qualitative information, such as photographs or time-lapse video of distinct plumes or source-specific haze events, may be adequate. 5. The state should use as many approaches or indicators of impairment as practicable 12 Based on previous cases, most impairment episodes are relatively short—lasting one to several hours—which may affect monitoring and other assessment techniques. 18 rather than relying on a single method. The assessment may rely on air monitoring and modeling techniques and other supporting scientific data. Consistency between source and observational techniques strengthens the analysis.13 6. The state should consider the level of uncertainty in the assessment. 7. EPA guideline models should be used whenever practicable. When other models are used, additional technical discussions with EPA may be necessary. C. Examples of the Attribution Process The state should consult this section after evaluation of the FLM Certification. At this point, the state will already have decided what gaps need to be filled to complete the attribution assessment. The recommendations in this report recognize that each attribution determination will be unique. Because an attribution determination is a fact-specific and individual determination, it is not possible to recommended a single technical approach for a state to follow. A combination of monitoring and modeling techniques is usually appropriate, but instead of attempting to cover all possible combinations of techniques, this report provides five selected scenarios. The general principles and technical criteria identified in sections A and B are incorporated into these scenarios. The goal is to provide the state with references for use when it is creating its own individualized technical procedure. In addition to the scenarios, this report provides detailed tables and narrative descriptions of techniques that may be considered and/or substituted for the techniques in the scenarios (see Section V). Scenario 1: Limited data/one source Data input: Small amount of existing data (i.e., one IMPROVE site with data for 2-3 years) Evidence of “local” impact. Limited meteorological data. Where it is likely that one major source contributes to impairment, a combination of the following techniques is suggested: 1. 2. 3. 4. 5. 6. 7. 13 Examine IMPROVE data, including quality assurance Look at extinction budget to identify visibility-impairing pollutants Perform some analysis of when the episodes are occurring Perform a simple back trajectory analysis using a method such as HYSPLIT Look at relationships between particulate species Examine source emissions data for correlations with ambient monitoring Perform dispersion model based on data and capabilities such as VISCREEN or CALPUFF Lite WESTAR Council, RA BART and RA BART-like Case Studies, June 2001. 19 8. Examine other data such as source owner data, deposition data, or photographic evidence The results of this initial analysis may not always be conclusive. This level of review may be adequate if a source/receptor relationship can be identified. However, if the results are inconclusive, more data and/or more refined analyses may be necessary and may help the state reach an attribution determination. The state should consider how the available data and choice of techniques might affect its ability to assess the effectiveness of the controls in remedying the impairment. It may be efficient to look ahead to the data and analytical needs of a potential BART analysis. For example, the state may wish to use a more refined model that would be useful for both attribution and remedy assessment. Assuming there is a two-year time period14 to collect data and analyze additional information, the following techniques also can be considered: 1. 2. 3. 4. 5. 6. 7. 8. Better source characterization, including measurement of emissions of trace elements (source profiles) for use in CMB modeling Met monitoring or modeling Camera site, possibly with time-lapse video Additional aerosol monitoring, episodic or saturation In plume trajectory by aircraft, if available Fine time-resolved optical monitoring, such as nephelometer, transmissometer, aethelometer combined with pollutant monitoring (e.g., SO2, NOx, real time PM) for monitoring of episodes More refined chemical visibility model, such as CALPUFF Repeat initial techniques with new data The technical criteria are listed below, followed by techniques that may be used to obtain results about the criteria. 1. The impairment must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified. Techniques: Back trajectory, species relationships, relationship between source emissions and ambient monitoring, dispersion model refined by camera, aerosol, in plume, optical monitoring, and refined dispersion models. 2. The attribution assessment must address the unique visibility impairment certified by 14 The 1999 regional haze rule revised the requirements for general plan requirements for visibility protection. As a result, plan revisions are required once every five years, rather than the Long Term Strategy review requirement of every three years. If an FLM certifies RAVI at least 6 months prior to a plan revision, section 51.302 requires that the State Plan revision address such Certifications. Given this 5-year cycle, we have presumed for this report that an attribution analysis should take about two years to complete in order to allow time for the BART engineering analysis, if needed. 20 the FLM for the Class I area. Some factors to consider include: 3. a. Duration: source’s length of effect per episode Techniques: Monitoring, dispersion model, back trajectory, camera b. Frequency: how often the impairment occurs Techniques: Monitoring, dispersion model, back trajectory, camera c. Geographic extent: how much of the Class I area is impaired Techniques: Monitoring, dispersion model, additional data on deposition and other studies d. Magnitude: how much impairment is due to the source Techniques: Dispersion model, receptor model e. Time of occurrence Techniques: Monitoring, dispersion model, back trajectory, camera Uncertainty of results: Each analytical method will have its own level of uncertainty. These individual uncertainties should be kept in mind as outputs are compared within the overall assessment. If the results of different techniques are the same or similar (within the uncertainties of the techniques), then the overall level of uncertainty is likely to decrease. Scenario 2: Moderate data/multiple sources Data input: Moderate amount of existing data (i.e., one IMPROVE site with data for six or more years) Evidence of an increasing trend in sulfate Meteorological data likely from several stations Assuming the Certification identifies multiple BART sources of different types within a 100mile radius, a combination of the following techniques is suggested: 1. 2. 3. 4. 5. 6. 7. 8. Examine IMPROVE data, including quality assurance Look at extinction budget to identify visibility-impairing pollutants Perform some analysis of when the episodes are occurring Perform multiple back trajectory analyses using a method such as HYSPLIT Look at relationships between particulate species Examine source emissions data for correlations with ambient monitoring Perform dispersion model based on data and capabilities such as CALMET/CALPUFF Examine other data such as source owner data, deposition data, or photographic evidence 9. Wind fields/Synoptic analyses 10. Comparison of different episodes 11. UNMIX, PMF and/or CMB 21 12. Analysis of any regional modeling already conducted, such as CMAQ 13. Long term visual monitoring, such as camera data or transmissometer data, compared to met data to identify quadrants of concern The results of this initial analysis may not be conclusive. This level of review may be adequate if a source/receptor relationship can be identified. However, if the results are inconclusive, more data and/or more refined analyses may be necessary and may help the state reach an attribution determination. The state should consider how the available data might affect the ability to assess the effectiveness of the controls in remedying the impairment. It may be efficient to look ahead to the data and analytical needs of a potential BART analysis. For example, the state may wish to use a more refined model that would be useful for both attribution and remedy assessment. Assuming there is a two-year time period to collect data and analyze additional information, the following techniques also can be considered: 1. 2. 3. 4. 5. 6. 7. 8. Emissions inventory Analysis of a nested domain within the regional model Source profiles (natural tracers) Additional source measurements, such as stack testing Met monitoring or modeling Camera Additional aerosol monitoring, episodic or saturation Monitoring to measure additional parameters, such as precursors, ammonia and oxidants 9. In plume trajectory by aircraft, if available, to characterize plume chemistry 10. Fine time-resolved optical monitoring, such as nephelometer, transmissometer, aethelometer combined with pollutant monitoring (e.g., SO2, NOx, real time PM) for monitoring episodes. 11. Repeat initial techniques with new data The technical criteria are listed below, followed by techniques that may be used to obtain results about the criteria. 1. The impairment must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified. Techniques: Back trajectory, species relationships, relationship between source emissions and ambient monitoring, dispersion model refined by camera, aerosol, in plume, optical monitoring, and refined dispersion models. 2. The attribution assessment must address the unique visibility impairment certified by the FLM for the Class I area. Some factors to consider include: a. Duration: each source’s length of effect per episode 22 Techniques: Monitoring, dispersion model, back trajectory, camera b. Frequency: how often the impairment occurs by source Techniques: Monitoring, dispersion model, back trajectory, receptor model, camera c. Geographic extent: how much of the Class I area is impaired Techniques: Monitoring, dispersion model, additional data on deposition and other studies d. Magnitude: how much impairment is due to each individual source Techniques: Dispersion model, receptor model e. Time of occurrence Techniques: Monitoring, dispersion model, back trajectory, camera Scenario 3: No IMPROVE data, Certification by modeling evidence Data input: Detailed modeling of a source and specific visibility impairment using a CALPUFF run, or detailed (nested) run of regional model. Detailed emissions data and meteorological data were input to the model. No IMPROVE data available for this specific Class I area (monitoring may be at a “representative site”) Some optical data, photographic data, and limited aerosol data from other networks Assuming the Certification points to a specific source, a combination of the following techniques is suggested: 1. Examine IMPROVE data for any nearby Class I areas (especially those included in the modeling domain) to better understand the regional conditions and compare with model outputs of the unique effect 2. Review the model’s outputs on “high impact” days and compare with actual meteorological data of the area (to confirm transport, inversions, or other aspects of the model which may create the unique impact) 3. Review source emissions data used in the model 4. Review other monitoring data (optical measurements, deposition data, ozone data, etc.) to collaborate model predictions 5. Examine any photographic evidence The results of this initial analysis may not always be conclusive. This level of review may be adequate if a source/receptor relationship can be identified. Because no visibility-specific particle monitoring is available in this case, the key to attribution is to determine that the source emissions are indeed reaching the Class I area on days when impairment exists. If the results are inconclusive, more data and/or more refined analyses may be necessary and may help the state reach an attribution determination. The state should consider if the available data and modeling information supplied with this Certification could be used to determine the effectiveness of the 23 controls in remedying the impairment. It may be efficient to look ahead to the data and analytical needs of a potential BART analysis if additional or different modeling will be necessary. Additional data collection and analyses that might be considered: 1. 2. 3. 4. 5. 6. Better source profiles or newer emissions information Met monitoring or modeling Camera New aerosol monitoring (episodic or saturation) In plume trajectory by aircraft, if available Repeat initial analytical techniques with new data The technical criteria are listed below, followed by techniques that may be used to obtain results about the criteria. 1. The impairment must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified. Techniques: Confirm model inputs, compare with any new particle monitoring at Class I area. Examine performance of the model, and perform uncertainty analyses. 2. The attribution assessment must address the unique visibility impairment certified by the FLM for the Class I area. Some factors to consider include: a. Duration: source’s length of effect per episode Techniques: Monitoring, dispersion model, back trajectory, camera b. Frequency: how often the impairment occurs Techniques: Monitoring, dispersion model, back trajectory, camera c. Geographic extent: how much of the Class I area is impaired Techniques: New monitoring and examination of dispersion model outputs, additional data on deposition and other studies d. Magnitude: how much impairment is due to the source Techniques: Dispersion model e. Time of occurrence Techniques: Monitoring, dispersion model, back trajectory, camera Scenario 4: Direct Photographic Evidence Data input: The FLM certified impairment in a wilderness area based on photographic evidence. Photographs taken over a period of two years showed a distinct haze in a valley located in the wilderness area when the wind is from the east. A series of photographs during two episodes showed a distinct plume that 24 originates at an existing stationary source constructed in 1965 and located ten miles east of the wilderness area. The photographic series showed that the plume traveled into the wilderness area. Aerial photos during one episode also show a distinct plume that travels into the wilderness area. The wilderness area does not have an IMPROVE site. A Class I area located 50 miles to the north has an IMPROVE site that was representative for the area. This monitoring site does not show decreased visibility on the days when haze was photographed in the wilderness valley. Assuming the Certification identifies one BART source, the following steps are suggested: 1. Review the photographic evidence and determine whether the photographs show a clear connection between the source and the haze documented in the wilderness area. In this example, the photographic evidence showed a clear connection between the source and the haze in the wilderness area. Qualitative information, such as photographic evidence that establishes a source/receptor link, is allowed under EPA regulations that define reasonable attribution as determined by “visual observation or other technique the State deems appropriate.” (40 CFR 51.301(s)). The results of this initial analysis may not always be conclusive. If the photographic evidence is not compelling, the state may reach a different conclusion. The state may determine that the impairment, as documented by the FLM, was not reasonably attributable to the source identified in the Certification. The FLM would then need to gather additional information to support a Certification. Alternatively, if the state determines that the source may be causing the haze but the qualitative evidence is not quite sufficient to determine attribution, the state could initiate a data collection effort to provide better information regarding visibility impairment at the Class I area. Such techniques may include: 1. 2. 3. 4. 5. 6. Better source characterization, including measurement of emissions of trace elements (source profiles) for use in CMB modeling Met monitoring or modeling Additional aerosol monitoring (episodic or saturation) In plume trajectory by aircraft, if available Fine time-resolved optical monitoring, such as nephelometer, transmissometer, or aethelometer combined with pollutant monitoring (e.g., SO2, NOx, real time PM) for monitoring of episodes. More refined chemical visibility model, such as CALPUFF The technical criteria are listed below, followed by techniques that may be used to obtain results about the criteria. 1. The impairment must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified. Techniques: Back trajectory, species relationships, relationship between source emissions and ambient monitoring, dispersion model refined by camera, aerosol, in 25 plume, optical monitoring, and refined dispersion models. 2. 3. The attribution assessment must address the unique visibility impairment certified by the FLM for the Class I area. Some factors to consider include: a. Duration: source’s length of effect per episode Techniques: Monitoring, dispersion model, back trajectory, camera b. Frequency: how often the impairment occurs Techniques: Monitoring, dispersion model, back trajectory, camera c. Geographic extent: how much of the Class I area is impaired Techniques: Monitoring, dispersion model, additional data on deposition and other studies d. Magnitude: how much impairment is due to the source Techniques: Dispersion model, receptor model e. Time of occurrence Techniques: Monitoring, dispersion model, back trajectory, camera Uncertainty of results: Each analytical method will have its own level of uncertainty. These individual uncertainties should be kept in mind as outputs are compared within the overall assessment. If the results of different techniques are the same or similar (within the uncertainties of the techniques), then the overall level of uncertainty is likely to decrease. The final step in the attribution process scenario would be to verify that the source was operating on the days when the haze was observed in the area. The state should also determine if the source was experiencing unusual upset conditions during the times identified. In this example, the source was determined to have been operating normally. The state would then issue a determination that the visibility impairment at the Class I area was reasonably attributable to the existing stationary facility. Scenario 5: Data Rich Data input: 1. A large special visibility study recently was conducted. Four months of data spanning two seasons was collected including: At one “receptor” site in a Class I area there were multiple meteorological, optical, and particulate samplers including extensive measurements of particle compositions, size distributions, scattering, absorption, light extinction, ions, oxidants, relative humidity, temperature, vertical wind profiles, SO2, photographs, and concentrations of four unique tracers released from four different sources of interest. There were co-located samplers measuring several parameters in more than one way. There are at least some one, six, and twelve-hour particle measurements in addition to twenty-four hour samples. 26 2. 3. 4. 5. 6. 7. This receptor site has been an IMPROVE site for several years and these data are also available. At thirty-five other sites in the region, called “satellite” sites there was an IMPROVE Module-A sampler taking daily twenty-four hour samples which were analyzed for fine mass, S, soil elements, trace metals, and elemental H from which organics can be estimated. The unique tracers were also measured at many of these sites. Aircraft sampling of plumes from source(s) of interest was conducted. An extensive current emissions inventory was created. Wind profilers were deployed at two to three sites in addition to the receptor site. Measurements of the chemical composition of resuspended local dust, smoke from burning local fuels, and emissions from local point and area sources of interest were collected in order to create “source profiles” to be used in receptor modeling. Assuming the certification identifies a BART source within 100 miles of the Class I area from which a unique tracer was released, a combination of the following techniques is suggested: 1. 2. 3. 4. 5. 6. 7. 8. 9. Examine fine particle data, including quality assurance. Use the collocated data to assess accuracy and precision. The one, six, and twelve-hour data should average up to match the twenty-four hour data and if reasonable, be used to examine the diurnal cycles in the fine particle concentrations. Look at the extinction budget to identify visibility-impairing pollutants. Because size distributions were measured, the extinction budget can be estimated from Mie scattering calculations as well as by using simple techniques that assume bulk scattering and absorption efficiencies. Check to see if measured scattering plus absorption add up to the measured and reconstructed extinction. Compare the special study data to historical IMPROVE and archived meteorological data to determine the representativeness of the study period. Perform some analysis of when the episodes are occurring. EOF analysis can be helpful to summarize the massive data set. Use the photographs to create a time-lapse visualization of the scene at the receptor site. Perform back trajectory analyses using HYSPLIT, CAPITA Monte Carlo or ATAD. Examine whether the trajectories change substantially when the study’s wind-profiler data are included. Determine whether trajectories are consistent with tracer concentrations. Look at relationships between particulate species (factor analysis) to see if they identify source types. Look at the spatial and temporal patterns of trace elements and the major constituents of the fine mass. This may suggest dominant source areas and transport patterns for different source types. Use EOF analysis to determine the patterns that explain most of the covariance in the data. Check to see how well these are reconciled with the back trajectory modeling and the deterministic modeling. Check to see if the same dominant sources were indicated. Examine source emissions data for correlations with ambient monitoring. Perform dispersion model such as CALMET/CALPUFF. 27 10. Analyze wind fields, synoptic conditions, and satellite photos. Check to see if they were consistent with more sophisticated meteorological modeling. Look for unusual conditions such as wild fires, hurricanes, stagnation episodes, etc. Look to see if modeled and observed cloud patterns were comparable. 11. Compare the meteorological and chemical characteristics of different episodes 12. UNMIX, PMF and CMB can help determine major source types and when they were important. If, at this point, similar source/receptor relationships have been identified using several different techniques, this level of review is adequate. If the results are inconclusive, and there are differing points of view about the frequency, duration, or significance of the attribution to the BART-eligible source, more analyses may be necessary. Often in a large study, measurements are made, but not immediately analyzed in the lab due to cost. If this is the case, more samples could be analyzed. It is unlikely that any additional field monitoring would be required. The technical criteria are listed below, followed by techniques that may be used to obtain results about the criteria. 1. The impairment must be related to emissions from specific sources. The visibilityimpairing pollutants of concern should be identified. Techniques: Reconstructed particle mass and light extinction including examination of the reconstructions in different size ranges and at different sites in the region, analysis of responses of light scattering to relative humidity, back trajectory analyses, examination of inter-species relationships compared to measured source profiles, dispersion modeling with sophisticated models such as REMSAD and CMAQ, analysis of wind fields and dispersion by comparison to measured tracer concentrations, computer animation of spatial patterns of species of interest, use of receptor models such as TMBR, DMB, and TAGIT that utilize unique tracer information, or other receptor models such as CMB, UNMIX, and PMF that do not require tracer information, but can use it. When so many different models can be used, model reconciliation is usually a part of a data-rich scenario. 2. The attribution assessment must address the unique visibility impairment certified by the FLM for the Class I area. Some factors to consider include: a. Duration: each source’s length of effect per episode Techniques: Monitoring, dispersion model, back trajectory, camera b. Frequency: how often the impairment occurs by source Techniques: Monitoring, dispersion model, back trajectory, receptor model, camera c. Geographic extent: how much of the Class I area is impaired Techniques: Monitoring, dispersion model, analysis of spatial patterns using data from the satellite sites. 28 3. d. Magnitude: how much impairment is due to each individual source Techniques: Dispersion model, receptor model e. Time of occurrence Techniques: Monitoring, dispersion model, back trajectory, camera Uncertainty of results: In this case, the ability of a model to predict the observed tracer concentrations is an indicator of the model’s uncertainty. 29 30 V. TECHNIQUES A. Monitoring Introduction This section describes a variety of ambient air monitoring methods that, if appropriate, might be used to support an attribution analysis. The methods described include those most commonly used in pollution studies or ambient monitoring programs and should not be considered an exhaustive list of potential methods. Methods include, IMPROVE, filter based aerosol, continuous aerosol (includes optical methods such as the nephelometer), continuous gas and canister sampling, transmissometer, scene (includes film, video, digital), and tracer or aircraft methods. Several of the methods described are currently in use as a part of national, state, local, tribal, or private ambient monitoring networks. These sites are generally located in urban areas, but those near the area of study could be used in the attribution analysis thereby reducing the cost of monitoring. The IMPROVE network is designed to assess visibility in Class I areas and routinely measure visibility impairing pollutants. These sites offer value to the attribution analysis if they are located in the area of study. The RA BART case studies show additional examples of the methods used during source attribution studies. The case studies also show that methods, other than ambient monitoring, may be used to support the analysis. Existing programs such as CASTNET (dry deposition network), surface water deposition studies, or snow deposition studies may provide additional data for the attribution analysis. Although not specifically listed as a monitoring technique, meteorological monitoring is an important element the attribution analysis. Collection of meteorological data can range from simple wind, temperature, and relative humidity measurement to an array of acoustic wind profilers. The complexity of the meteorological monitoring program depends on data needs and the availability of existing data. As with ambient monitoring, meteorological data may be available at sites located near the study area and offers reduced monitoring cost. 1. IMPROVE Overview: The Interagency Monitoring of PROtected Visual Environments (IMPROVE) program is a cooperative measurement effort governed by a steering committee composed of representatives from Federal and regional-state organizations. The IMPROVE monitoring program was established in 1985 to aid the creation of Federal and State implementation plans for the protection of visibility in Class I areas (156 national parks and wilderness areas) as stipulated in the 1977 amendments to the Clean Air Act. The objectives of IMPROVE are to: (1) establish current visibility and aerosol conditions in mandatory class I areas; (2) identify chemical species and emission sources responsible for existing man-made visibility impairment; 31 (3) document long-term trends for assessing progress towards the national visibility goal; and (4) with the enactment of the regional haze rule, provide regional haze monitoring representing all visibility-protected federal class I areas where practical. Magnitude: Possible when used in conjunction with appropriate analytical techniques. Frequency: Possible when used in conjunction with appropriate analytical techniques; Limited by twenty-four hour sample integration, and one-in-three day sampling frequency. Duration: Possible when used in conjunction with appropriate analytical techniques; Limited by 24 hour sample integration, and one-in-three day sampling frequency. Principle: Twenty-four hour integrated filter-based ambient monitor; Gravimetric analysis for PM2.5 (Module D) and PM10); S from Particle Induced X-ray Emission (PIXE); NO3 from ion chromatography (denuded nylon filter from Module C); Organic and elemental carbon from Thermal Optical Reflectance (TOR); H from Proton Elastic Scattering (PESA). Uncertainty: All elemental S if from sulfate; All sulfate is ammonium sulfate; NO3 (Denuder efficiency is close to 100%. All nitrate is from ammonium nitrate); Average organic molecule is 70% carbon; Carbon (organic and elemental) is defined by the analytical method; Fine soil based on elemental composition; Course mass (PM10 – PM2.5) consists only of insoluble soil particles. Strengths: Regulatory indicator for regional haze rule; Long term data record in or near many federal Class I areas; Extensive network currently in place. Limitations: Integrated twenty-four hour sample; one-in-three day sampling interval; Nitrate losses due to volatilization from filter; Not capable of distinguishing between primary particulate and atmospherically transformed particulate. Level of Expertise Required: Standard operating procedures available for routine operation and maintenance; Chemical analysis must be conducted by appropriate laboratory. Regulatory Context: Regional Haze rule; Included in SIP Visibility Plan 2. FILTER-BASED AEROSOL Overview: Filter-based aerosol monitoring is used to identify chemical species and obtain concentration measurements of atmospheric constituents that contribute to visibility impairment. Primary techniques include filter-based aerosol samplers that collect samples on various substrates in various size ranges such as PM2.5 or PM10. Aerosol monitoring can provide fine mass concentration, course mass concentration, optical absorption, major and trace elements, organic and elemental carbon, and sulfate, nitrate, and chloride ions. A variety of methods are available to conduct filter based aerosol monitoring. Many methods are approved as an EPA reference method, while some are not, but may offer variability that the reference method does not. 32 Magnitude: Possible when used in conjunction with appropriate analytical techniques. Frequency: Possible when used in conjunction with appropriate analytical techniques; Limited by 24-hour sample integration and sampling frequency (daily sampling is possible depending on instrument selected). Duration: Possible when used in conjunction with appropriate analytical techniques; Limited by 24-hour sample integration and sampling frequency (daily sampling is possible depending on instrument selected). Principle: The methods used for analyses of these filter media include gravimetry (electromicrobalance) for mass; X-ray fluorescence (XRF) and particle induced X-ray emission (PIXE) for trace elements; Ion chromatography (IC) for anions and selected cations; Controlledcombustion for carbon; Gas chromatography/mass spectroscopy (GC/MS) for semi-volatile organic particles; Special measurement needs may include determining particle size and morphology through optical and/or electron microscopy. Strengths: Large network of urban monitoring available; Filter based sampling allows for a variety of chemical/elemental analysis. Limitations: Integrated twenty-four hour sample; Generally operated on one-in-three or one-insix day sampling interval (daily sampling is possible depending on instrument selected); Not capable of distinguishing between primary particulate and atmospherically transformed particulate. Level of Expertise Required: Standard operating procedures available for routine operation and maintenance; Chemical analysis must be conducted by appropriate laboratory. Regulatory Context: Commonly used in NAAQS/SIP compliance monitoring networks. 3. CONTINUOUS AEROSOL Overview: Aerosols can be measured continuously using several different methods. Optical measurement of aerosols can be measured using an instrument such as a nephelometer to measure light scattering (bscat) or a aethelometer to measure light absorption (babs) by aerosols (black carbon). Continuous instruments such as TEOM or BETA can provide PM10 or PM2.5 aerosol concentration. Magnitude: Possible when used in conjunction with appropriate analytical techniques. Frequency: Possible when used in conjunction with appropriate analytical techniques; Limited by twenty-four hour sample integration and sampling frequency (daily sampling is possible depending on instrument selected). 33 Duration: Possible when used in conjunction with appropriate analytical techniques; Limited by twenty-four hour sample integration and sampling frequency (daily sampling is possible depending on instrument selected). Strengths: Continuous measurement with at least hourly time resolution; Nephelometers and Aethelometers are commonly used to support Class I area monitoring programs and an existing data record may be available in some areas. Limitations: Continuous aerosol measurement with methods such as TEOM and BETA are generally made in urban areas to support NAAQS compliance networks; Not capable of distinguishing between primary particulate and atmospherically transformed particulate. Level of Expertise Required: Standard operating procedures available for routine operation and maintenance. Regulatory Context: Commonly used in Class I area monitoring networks or urban NAAQS compliance networks. 4. CONTINUOUS GASEOUS Overview: A variety of gaseous pollutants, such as Ozone (O3), Carbon Monoxide (CO), Nitrogen Dioxide (NOx), nitric oxide (NO), ammonia (NH3), hydrogen peroxide (H2O2), sulfur dioxide (SO2), Organics, and HAPS/TOXICS, can be measured continuously. Gaseous monitoring is generally conducted with instruments that continuously draw sample air and periodically (as frequently as once per second) analyze the sample. Canister systems collect an ambient air sample over a specific period of time in clean evacuated canisters. The canisters are then subject to subsequent analysis at a laboratory using a method such as GC/FID. This method is able to provide time-integrated samples from several hours to twenty-four hours or more. Regular checks of the flow rate, stability, reproducibility, precision, and accuracy of these instruments must be conducted on a regular schedule in order to ensure data quality. Magnitude: Possible when used in conjunction with appropriate analytical techniques. Frequency: Possible when used in conjunction with appropriate analytical techniques. Duration: Possible when used in conjunction with appropriate analytical techniques. Strengths: Continuous measurement with hourly time resolution; Monitors available to identify variety of pollutants. Weaknesses/Limitations: Generally require conditioned environment and frequent performance checks. Practical Considerations: Data may be available from established urban area monitoring networks and some Class I area monitoring networks; Additional cost ($/year) for new sites. 34 Level of Expertise Required: Standard operating procedures available for routine operation and maintenance. Regulatory Context: Commonly used in urban NAAQS compliance and HAPS/TOXICS networks. 5. TRANSMISSOMETER Overview: Transmissometers measure the amount of light transmitted through the atmosphere over a known distance (generally between 0.5 km and 10.0 km) between a light source of known intensity and a receiver. The transmission measurements are electronically converted to hourly averaged light extinction (bext). Magnitude: Possible when used in conjunction with appropriate analytical techniques. Frequency: Possible when used in conjunction with appropriate analytical techniques. Duration: Possible when used in conjunction with appropriate analytical techniques. Uncertainties: A transmissometer must be installed in stable locations with a clear and unobstructed path to avoid interference with the signal. Strengths: Continuous measurement of bext in many Class I areas and some urban areas. Limitations: Not capable of identifying pollutants contributing to visibility impairment. Level of Expertise Required: Standard operating procedures available for routine operation and maintenance; Data processing/quality assurance requires high level of expertise. Regulatory Context: Commonly used in Class I area monitoring networks and in some urban areas. 6. SCENE Overview: Scene monitoring refers to the use of still and/or time-lapse photography (including digital imagery) to provide a qualitative representation of visual air quality. Scene monitoring data quality objective recommendations are to document the appearance of scenes of interest under a variety of air quality and illumination conditions at different times of day and different seasons. Scene monitoring documents the visual condition observed at a monitoring site. The data collection schedule can be tailored to capture the periods when visibility impairment is most likely to occur at specific sites. Time-lapse movies (generally time-lapse video or super 8 mm film) can be used at monitoring sites and during special studies to document the visual dynamics of a scene or source. Magnitude: Cannot provide a quantitative measurement of visibility impairment but can qualitatively illustrate various levels of visibility impairment. 35 Frequency: Possible depending on the method used. Time-lapse video may be able to demonstrate the frequency of the impairment. The use of still photography to document impairment frequency depends upon the number of images acquired over time. Duration: Possible depending on the method used. Time-lapse video may be able to demonstrate the impairment frequency. The use of still photography to document impairment frequency depends upon the number of images acquired over time. Uncertainties: n/a Strengths: Provides image/video record Limitations: Not capable of identifying pollutants contributing to visibility impairment. Level of Expertise Required: Standard operating procedures available for routine operation and maintenance. Regulatory Context: Commonly used in Class I area monitoring networks and in some urban areas. 7. TRACER METHODS, LIDAR SYSTEMS, AIRCRAFT BASED MEASUREMENTS Overview: The methods described in this section are more specialized methods generally reserved for special studies as opposed to the previously described methods that are used more routinely. Tracer methods, lidar systems and aircraft based measurements will be described individually. Tracer Methods: A tracer element or compound is a substance with unique characteristics that allows positive identification at very low concentrations. The tracer compound of choice will vary by source type and composition of the plume being tracked. In general, the tracer must have very low natural background concentrations and ideally would have the same chemical form and properties as the compound being tracked. In ambient applications where use of the ideal tracer is not possible due to potential environmental risk, a near-substitute compound may be used. When used to determine potential source impacts, the chosen compound is released from a source stack and downwind monitors are used to detect the presence of the compound. Lidar Methods: A lidar transmits short pulses of laser light into the atmosphere. The laser beam loses light to scattering as it travels. At each range, some of the light is backscattered into a detector. Because the light takes longer to return from the more distant ranges, the time delay of the return pulses can be converted to the corresponding distance between the atmospheric scatterer and the lidar. The end result is a profile of atmospheric scattering versus distance. Analysis of this signal can yield information about the distribution of aerosols in the atmosphere. The amount of backscatter indicates the density of the scatters. This can be used to measure cloud base height or track 36 plumes of pollution. Other properties of the atmosphere can also be deduced from the lidar return signals. A frequency shift in the light because of the Doppler effect permits measurement of wind speeds. By detecting the amount of depolarization, one can discriminate between liquid droplets and nonspherical ice particles. Differential Absorption Lidar (DIAL) uses absorption, as evidenced by reduced backscatter from greater distances, to measure the concentration of atmospheric gases. A Raman lidar detects particular atmospheric components (such as water vapor) by measuring the wavelength-shifted return from selected molecules (NOAA). Aircraft Based Measurements: Aircraft based measurement systems utilize specially equipped aircraft to make pollutant and meteorological measurements at various elevations throughout the study domain. The aircraft can be equipped with a multitude of gaseous, aerosol, optical and meteorological equipment. This measurement method provides the advantage of vertical profiles of various parameters, the ability to track point source plumes, and the ability to establish boundary conditions for future analytical and modeling exercises. References: NOAA, Atmospheric Light Division, Environmental Technology Laboratory, http://www2.etl.noaa.gov/DIAL_lidar.html U.S. Environmental Protection Agency, Visibility Monitoring Guidance (EPA-454/R-99-003), June 1999. National Research Council, Protecting Visibility in National Parks and Wilderness Areas, National Academy Press, Washington D.C., 1993, pp. 315-357. 37 38 Table 1. Monitoring Techniques Criteria Monitoring Method IMPROVE Filter Based Aerosol Continuous Aerosol Transmissometer Gaseous; Scene Tracer Methods, Lidar 35mmfilm/8mm Continuous systems, Aircraft based video, digital measurements methods, canister sampling, etc. Pollutant PM10 Yes Yes Yes No No No PM2.5 Yes Yes Yes Yes No No NOx (Site specific) No No Yes No No SO2 (Site specific) No No Yes No No Sulfate Yes Yes No No No No Nitrate Yes Yes No No No No Carbon Yes Yes No No No No Organics Yes Yes No Yes No No Total Extinction Visual Parameters Other Reconstructed extinction Nephelometer HAPS, TOXICS Bscat Aethelometer - Babs All Possible Visibility/Concentration Changes Magnitude Yes Yes All Possible All Possible All Possible No All Possible Frequency Yes Yes All Possible All Possible All Possible Yes All Possible Duration Yes Yes Yes Time of Day No No Yes Likely Part of FLM Certification? Possible 39 No Monitoring Techniques (continued) Principal Qualitative/ Quantitative Strengths Quantitative various chemical analysis, large network nationwide Qualitative/Quantitative Continuous Relatively Lidar and airplane based measurement, inexpensive, systems can provided provides light uncomplicated temporal and spatial extinction operational results, tracer methods value, requirements can provide sourcehistorical receptor data record Weaknesses/ Fixed location Integrated 24 hour TEOM, BETA, etc, Generally require Fixed location Number of still Complex and relatively Limitations in or near Class sample generally commonly located in conditioned in or near Class images limited, expensive to operate, I areas, also collected on one- urban areas environment for I areas video requires requires specialized located in in-three schedule, proper operation, storage and training and knowledge several urban commonly in commonly located routine review to operate and analyze areas urban areas in urban areas results Distinguish Possible with Possible with other No Possible with other No Possible with Possible with other BART Sources? other analysis analysis analysis other analysis analysis Practical Considerations Cost Reconstructed extinction calculation, historical record Qualitative Continuous Continuous measurement, measurement, nephelometer variety of possible commonly located in pollutants or near Class I areas Moderate; varies depending on the number of instruments 40 Low High B. Source Modeling Introduction Given the complex natural environment, the state must choose the configuration of modeling techniques that will provide the most information on the contributing source or sources of impairment within the limited resources of current technology, data, budgets, time and staff availability. 1. Physical Models Physical models are those that simulate the meteorology and air quality over an area. Modeling relies on a numerical or analytical model to estimate particulate concentrations in space and time. Because of its nature and sources, particulate matter is difficult to model over all spatial scales. Many air quality models that are currently available were designed to be applied over the regional scale with grid sizes from four to forty kilometers. Modeling requires detailed meteorological fields and emissions inventory over the entire domain. The compilation of data required to run these models can require much effort and expertise. Efforts are underway by government agencies in the U.S. to generate and archive both emissions and estimated activity levels of many source types in geographical information systems. Numerical source-oriented models are designed to simulate atmospheric diffusion or dispersion and estimate concentrations at defined receptors. Numerical source models can be grouped as kinematic, first-order closure, or second-order closure models (Bowne and Lundergan, 1983). Kinematic models are the simplest both mathematically and conceptually. These models simplify the non-linear equations of turbulent motion, thereby permitting a closed analytical approximation to describe pollutant concentration (Green et al., 1980). First-order closure models are based on the assumption of an isotropic pollutant concentration field. Consequently, turbulent eddy fluxes are estimated as being proportional to the local spatial gradient of the transport quantities. The Eulerian grid models, Lagrangian particle models, and trajectory puff/plume models are included in this category. Second-order closure models involve a series of algorithm transformations of the equations of state, mass continuity, momentum, and energy by using the Boussinesque approximation and Reynold’s decomposition theory (Holton, 1992; Stull, 1988). 2. Spatial Scales The model’s applicable spatial scales play a large role meeting the analysis' objectives and its ability to accurately assess spatial variability. PM10 and PM2.5 concentrations modeled or measured at any receptor result from the complex interaction of meteorology, chemical transformations and emissions from nearby and distant sources. For example, a monitor located near an operating construction site will be impacted more by the daily construction activity than the surrounding area. That site may be classified as representing an area of a few tens of meters to no more than one kilometer depending on the size of the construction area and fugitive dust control measures. The dimensions given below are nominal rather than exact and are presented as defined in 40 CFR part 58. 41 a. Micro-Scale (10 to 100 m): This scale does not apply to scenarios relevant to the attribution problem. Modeling at the microscale is usually done by simple Gaussian plume models such as ISCST3. Measurements in urban areas can show considerable variations at this scale while those in pristine areas would not. Variations often occur when monitors are located close to a low-level emissions source, such as a busy roadway, construction site, within a community that uses wood stoves, or a short industrial stack. Fortunately, compliance monitoring site exposure criteria avoids microscale influences even for source-oriented monitoring sites. b. Middle Scale (100 to 500 m): Middle-scale monitors show significant differences between locations that are ~0.1 to 0.5 km apart. These differences may occur near large industrial areas with many different operations or near large construction sites. Monitors with middle-scale zones of representation are often source-oriented, used to determine the contributions from emitting activities with multiple, individual sources to nearby community exposure monitors. c. Neighborhood Scale (500 m to 4 km): Neighborhood-scale monitors do not show significant differences in particulate concentrations with spacing of a few kilometers. This dimension is often the size of emissions and modeling grids used in large urban areas for PM source assessment, so this zone of representation of a monitor is the only one that should be used to evaluate such models. Sources affecting neighborhood-scale sites typically consist of small individual emitters, such as clean, paved, curbed roads, uncongested traffic flow without a significant fraction of heavy-duty vehicles, or neighborhood use of residential heating devices such as fireplaces and wood stoves. d. Urban Scale (4 to 100 km): Urban-scale monitors show consistency among measurements with monitor separations of tens of kilometers. These monitors represent a mixture of particles from many sources within the urban complex, including those from the smaller scales. PM measurements at urban-scale locations are not dominated by any particular neighborhood, however. Urban-scale sites are often located at higher elevations and away from highly traveled roads, industries, and residential heating. e. Regional-Scale Background (100 to 1,000 km): Regional-scale background monitors show consistency among measurements for monitor separations of a few hundred kilometers. Background concentrations are often more consistent for specific chemical compounds, such as sulfate or nitrate, than they are for PM mass concentrations. Regional-scale PM is a combination of naturally-occurring aerosol from windblown dust and marine aerosol as well as particles generated in urban and industrial areas that may be more than 1,000 km distant. Regional-scale sites are best located in rural areas away from local sources, and at higher elevations. National parks, national wilderness areas, and many state and county parks and reserves are appropriate areas for regional-scale sites. Many of the IMPROVE sites characterize PM regional scale background in different regions of the United States. f. Continental-Scale Background (1,000 to 10,000 km): Continental-scale background monitors show little variation even when they are separated by more than 1,000 km. They are hundreds of kilometers from the nearest significant emitters. Though these sites measure a mixture of natural and diluted manmade source contributions, the manmade component is at its minimum expected concentration. The Jarbidge Wilderness IMPROVE site in northern Nevada is a good example of a continental-scale background site for particulate matter in North America. 42 e. Global-Scale Background (>10,000 km): Global-scale background monitors are intended to quantify concentrations transported between different continents as well as naturally-emitted particles and precursors from sea spray, volcanoes, and windblown dust. Yellow sand from China has been detected at the Mauna Loa, HI, laboratory (Darzi and Winchester, 1982; Braaten and Cahill, 1986), as well as on the North American continent. Red dust from Africa’s Sahara desert has been detected at Mt. Yunque, Puerto Rico and over the southeastern United States. Other global-scale sites include McMurdo, Palmer, and Ahmundson-Scott stations in Antarctica (Lowenthal et al., 1996), Pt. Barrow, Alaska, and Mace Head, Ireland. 3. Chemical Composition This section illustrates how the chemical composition of aerosols is an important consideration in the choice of particulate matter models. The knowledge of how the aerosol's composition varies over an area will play a key role in the attribution study design. The relative abundance of chemical components in the atmosphere closely reflect the characteristics of emission sources. Major chemical components of PM2.5 and PM10 mass in urban and rural areas consist of nitrate, sulfate, ammonium, carbon, geological material, sodium chloride, and liquid water. Chemical compositions can vary spatially in all scales of the atmosphere and depend on sources surrounding the monitoring site. For example, on the continental scale, the eastern U.S. fine particulate chemical compositions are different than those of the western states. In the eastern portion of the U.S., nonurban PM2.5 is dominated by secondary sulfate, organics and elemental carbon (EPA, 1996). The data to support this conclusion are based on the IMPROVE and CASTNET networks. These networks provide a background fine-fraction aerosol database because the monitoring sites are primarily located in national parks and wilderness areas. Analysis of this network shows that the western U.S. nonurban PM2.5 aerosol is predominantly carbon in nature. Nitrate also contributes significantly to the fine particle mass budget particularly in central and coastal California. Within these generalizations, obvious departures will be found especially near sources such as near the ocean and urban areas where the aerosol will be primarily influenced by sea salt and combustion particles, respectively. The typical PM2.5 chemical compositions vary by season (Chow et al., 1993a; 1996a, Watson et al., 1997), and consist of the following major components: a. Organic Carbon: Organic carbon is composed of gases and particles containing combinations of carbon and hydrogen atoms. Organic compounds found in ambient air may also be associated with other elements and compounds, particularly oxygen, nitrogen, sulfur, halogens, and metals. Particulate organic carbon consists of hundreds, possibly thousands, of separate compounds (Rogge et al., 1993a). The mass concentration of organic carbon can be accurately measured, as can carbonate carbon (Chow et al., 1993b), but only about ten percent of the specific organic compounds that it contains have been measured. Vehicle exhaust (Rogge et al., 1993b), residential and agricultural burning (Rogge et al., 1998), meat cooking (Rogge et al., 1991), fuel combustion (Rogge et al., 1997), road dust (Rogge et al., 1993c), and particle formation from heavy hydrocarbon gases (Pandis et al., 1992), are the major sources of organic carbon in PM2.5. 43 b. Elemental Carbon: Elemental carbon is black, often called “soot.” Elemental carbon contains pure, graphitic carbon, but it also contains high molecular weight, dark-colored, nonvolatile organic materials such as tar, biological material (e.g., coffee), and coke. Elemental carbon usually accompanies organic carbon in combustion emissions, with diesel exhaust (Watson et al., 1994a, 1998) being the largest contributor. c. Sulfate: Ammonium sulfate ((NH4SO4), ammonium bisulfate (NH4HSO4), and sulfuric acid (H2SO4), are the most common sulfate compounds in PM2.5. These compounds are water-soluble and reside almost exclusively in the PM2.5 size fraction. Sodium sulfate (Na2SO4) has been found in coastal areas where sulfuric acid has been neutralized by sodium chloride (NaCl) in sea salt. Although gypsum (Ca2SO4) and some other geological compounds contain sulfate, these are not easily dissolved in water for chemical analysis and are more abundant in the coarse fraction than in PM2.5; they are usually classified in the geological fraction. d. Nitrate: Ammonium nitrate (NH4NO3) is the most abundant nitrate compound, a large fraction of PM2.5 occurs during winter, and a moderate fraction occurs during fall. Sodium nitrate (NaNO3) is found in the PM2.5 and coarse fractions near the oceans and salt playas. Small quantities of sodium nitrate have been found in summertime particulate matter inland owing to transport from the ocean (Chow et al., 1996b). e. Ammonium: Ammonium sulfate (NH4SO4) and ammonium nitrate (NH4NO3) are the most common compounds containing ammonium from reactions between sulfuric acid, nitric acid, and ammonia gases. While most of the sulfur dioxide and oxides of nitrogen originate from fuel combustion in stationary and mobile sources, most of the ammonia derives from living things, especially animal husbandry practiced in dairies and feedlots. f. Geological Material: Suspended dust consists mainly of oxides of aluminum, silicon, calcium, titanium, iron, and other metal oxides. In areas surrounded by substantial terrain (i.e., mountains), eons of runoff produce mineral compositions in soils that can be fairly homogeneous, with the exception of places where dry lake beds exist that have accumulated salt deposits. Industrial processes such as steel making, smelting, and mining have distinct geological compositions. For instance, cement production and distribution facilities may use alcareous, siliceous, argillaceous, and ferriferous minerals that may not be natural to the region, with limestone (CaCO3) being the most abundant (Greer et al., 1992). Suspended geological material resides mostly in the coarse particle fraction (Houck et al, 1989,1990), and typically constitutes ~50% of PM10 while only contributing 5 to 15% of PM2.5 (Watson et al., 1994b). g. Sodium Chloride: Salt is found in suspended particles near oceans, open playas, and after de-icing materials are applied. Bulk sea water contains 57±7% chloride, 32±4% sodium, 8±1% sulfate, 1.1±0.1% soluble potassium, and 1.2±0.2% calcium (Pytkowicz and Kester, 1971). As noted above, sodium chloride is often neutralized by nitric or sulfuric acid in urban air where it is encountered as sodium nitrate or sodium sulfate. h. Liquid Water: Soluble nitrates, sulfates, ammonium, sodium, other inorganic ions, and some organic material (Saxena and Hildemann, 1997) absorb water vapor from the atmosphere, especially when relative humidity exceeds 70% (Tang and Munkelwitz, 1993). Sulfuric acid absorbs some water or deliquesces at all humidities. Particles containing these compounds grow 44 into the droplet mode as they take on liquid water. Some of this water is retained when particles are sampled and weighed for mass concentration. The precise amount of water quantified in a PM2.5 depends on its ionic composition and the equilibration relative humidity applied prior to laboratory weighing. Ambient mass concentrations contain both primary and secondary particles. Primary particles are directly emitted by sources and usually undergo few changes between source and receptor. Atmospheric concentrations of primary particles are, on average, proportional to the quantities that are emitted. Secondary particles are those that form in the atmosphere from gases that are directly emitted by sources. Sulfur dioxide, ammonia, and oxides of nitrogen are the precursors for sulfuric acid, ammonium bisulfate, ammonium sulfate, and ammonium nitrate particles. “Heavy” volatile organic compounds or HVOC (those containing more than eight carbon atoms) may also change into particles. The majority of these transformations result from intense photochemical reactions that also create high ozone levels. Secondary particles usually form over several hours or days and attain aerodynamic diameters in the accumulation mode between 0.1 and 1 µm. Several of these particles, notably those containing ammonium nitrate, are volatile and transfer mass between the gas and particle phase to maintain a chemical equilibrium. This volatility has implications for ambient concentration measurements as well as for gas and particle concentrations in the atmosphere. Ambient concentrations of secondary aerosols are not necessarily proportional to quantities of emissions since the rate at which they form may be limited by factors other than the concentration of the precursor gases. Secondary particulate ammonium nitrate concentrations depend on gaseous ammonia and nitric acid concentrations as well as temperature and relative humidity. A nearby source of ammonia may cause a localized increase in PM2.5 concentrations by shifting the equilibrium from the gas to the particulate ammonium nitrate phase (Watson et al., 1994c). Ammonium sulfate may form rapidly from sulfur dioxide and ammonia gases in the presence of clouds and fogs, or slowly in dry air. Because fine particle deposition velocities are slower than those of the gaseous precursors, PM2.5 may travel much farther than the precursors, and secondary particles precursors are often found far from their emissions sources and may extend over scales exceeding 1,000 km. 4. Particle Formation Ammonium nitrate and ammonium sulfate aerosols are the most prevalent secondary particles found at urban and non-urban sites throughout the U.S. during the winter. These particles can form when gas molecules are attracted to and adhere to existing particles. Sulfur dioxide gas changes to particulate sulfate through gas- and aqueous-phase transformation pathways. In the gas-phase pathway, ultraviolet sunlight induces photochemical reactions creating oxidizing species that react with a wide variety of atmospheric constituents. The gas-phase transformation rate appears to be controlled more by the presence or absence of the hydroxyl radical and its competing reactions of other gases than by the sulfur dioxide concentrations. 45 In the presence of fogs or clouds, sulfur dioxide dissolves in droplets where it experiences aqueous reactions that are much faster than gas-phase reactions. When ozone and hydrogen peroxide are dissolved in the droplet, the sulfur dioxide is quickly oxidized to sulfuric acid. When ammonia is dissolved in the droplet, the sulfuric acid is neutralized to ammonium sulfate. If the fog or cloud evaporates and relative humidity decreases below 100 percent, the sulfate particle exists as a small droplet that includes a portion of liquid water. As the relative humidity further decreases below 70 percent, the droplet evaporates and a small, solid sulfate particle remains. The reactions within the fog droplet are very fast, and the rate is controlled by the solubility of the precursor gases. Aqueous transformation rates of sulfur dioxide to sulfate are 10 to 100 times as fast as gas-phase rates. These chemical reactions are critical to understanding PM concentrations in areas and downwind of areas that emits large amounts of SO2. The location and SO2 emissions output of large point sources such as coal and oil fired power plants need to be mapped and compared with transport patterns in order to determine the impact of ammonium sulfate particles on ambient surface concentrations. Fogs serve as an environment for creating particles and as vehicles for particle removal. During heavy fogs, particles and precursor gases are scavenged as fog droplets grow to sizes that settle rapidly to the surface. The extent and intensity of these fogs is so poorly characterized, however, that it is not yet possible to determine where and when particle formation overtakes particle deposition, thereby adding to the PM2.5 concentration loading. Nitrogen oxide converts to nitrogen dioxide, primarily by reaction with ozone. Nitrogen dioxide can: 1) change back to nitrogen oxide in the presence of ultraviolet radiation; 2) change to short-lived species which take place in other chemical reactions; 3) form organic nitrates; or 4) oxidize to form nitric acid. The major pathway to nitric acid is a reaction with hydroxyl radicals that transforms nitrogen dioxide to nitric acid. Nitric acid deposits from the atmosphere fairly rapidly but, in the presence of ammonia, it is neutralized to particulate ammonium nitrate. This is an important process in secondary particle production because many agricultural areas surrounding populated urban areas contain large ammonia sources. Chow and Egami (1997) show that San Joaquin Valley ammonia concentrations are large during winter. Conversion rates for nitrogen dioxide to nitric acid, ranging from less than one percent per hour to ninety percent per hour. These rates are typically five to ten times the conversion rates for sulfate formation. Though they vary throughout a twenty-four hour period, these rates are significant during both daytime and nighttime hours, in contrast to the gas-phase sulfate chemistry that is most active during daylight hours. The important nitric acid-ammonia reaction has implications to network design by the need to locate and map possible sources of ammonia. Significant sources of ammonia are associated with animal husbandry and fertilizer applications. Locating and estimating ammonia emissions will be a difficult task because it is not traditionally tabulated in emission inventories and requires further research to refine the methodology to measure the emissions. While ammonium sulfate is a fairly stable compound, ammonium nitrate is not. Its equilibrium with gaseous ammonia and nitric acid is strongly influenced by temperature and relative humidity. Atmospheric particle nitrate can occur in atmospheric aerosol particles as solid ammonium nitrate or as ionized ammonium nitrate in aerosol particles containing water. In both 46 the solid and ionized forms, ammonium nitrate is in equilibrium with gas-phase nitric acid and ammonia. For fixed relative humidity, increasing temperature decreases the particle nitrate fraction. This is a consequence of the direct relation between the equilibrium constants and temperature. As temperature increases, the equilibrium constants increase, which means higher gas-phase pressures can be supported, thereby reducing the particle nitrate fraction. For fixed humidity, decreasing temperature increases the particle nitrate fraction. As temperatures approach 0°C, the curves approach limiting values. Particle fractions of one are used for ion ratios greater than or equal to one, and particle fractions are determined by the amount of available ammonia for ion ratios less than one. For the higher temperatures, increasing relative humidity increases the particle nitrate fraction. This is a consequence of liquid water present for the 60% and 80% relative humidity cases. When there is sufficient ammonia present with 30% relative humidity, more than 90% of the nitrate is in the particle phase for temperatures less than 20°C. More than half of the particle nitrate is gone at temperatures above 30°C, and all of it disappears at temperatures above 40°C. Atmospheric water is another important component of suspended particulate matter. The sharp rise in liquid water content at relative humidities between 55% and 75% is known as deliquescence. A precise humidity at which soluble particles take on liquid water depends on the chemical mixture and temperature. Particles containing these compounds grow into the droplet mode as they take on liquid water, so the same concentration of sulfate or nitrate makes a much larger contribution to light extinction when humidities are high (>70 percent) than when they are low (<30 percent). Excess liquid water is also measured as part of the PM2.5 mass when sampled by light scattering continuous monitors or when filters have not been equilibrated at relative humidities less than 30% prior to weighing. Some of the organic carbon in suspended particles is also of secondary origin. Secondary organic compounds in particulate matter include aliphatic acids, alcohols, aromatic acids, nitroaromatics, carbonyls, esters, phenols, and aliphatic nitrates (Grosjean and Seinfeld, 1989; Grosjean, 1992, Pandis et al., 1992, 1993; Seinfeld and Pandis, 1998). Normally, primary organic carbon particles are more prevalent than secondary organics with exceptions such as those found in Los Angeles where conditions of clear skies and high photochemical smog are frequent. Although secondary organic aerosol was thought to be minimal during winter in central California, recent analyses (Strader et al., 1998) demonstrate that it could be as much as 20% of twenty-four hour organic carbon in some samples. This occurs because low wintertime temperatures lower the saturation vapor pressure for semi-volatile organic compounds. This is probably minor during winter and fall when photochemical reactions are not dominant. The exact precursors of secondary organics are not well understood, but they are believed to consist of heavy hydrocarbons with more than seven carbon atoms. Odum (1997) identifies aromatics as the major group of commonly measured reactive organic gases that affect both ozone and secondary aerosol formation. 47 5. Source Modeling Techniques Before selecting a modeling technique, it is wise to establish a conceptual model. A conceptual model describes the relevant physical and chemical processes that affect emissions, transport, and transformation specific to the region of interest. It is the starting point for any source apportionment process. Conceptual models take advantage of the large body of scientific knowledge already acquired. They identify the sources that are likely to be present and eliminate those that are not. They examine meteorological conditions that affect concentrations and focus further modeling on the conditions conducive to the high concentrations. Modeling techniques relevant to attribution are split into several categories depending complexity, physical attributes, purpose and cost to execute. The following tables on pages 55 to 62 provide a matrix of detailed information on specific models grouped in these categories. a. Puff Modeling Techniques These models are based on a Lagrangian framework where air parcels are tracked spatially and temporally. They can include chemical mechanisms as well as deposition effects. The most commonly used puff model is the CALMET/CALPUFF (Scire et al., 2000). b. Grid Modeling Techniques For estimating PM2.5 levels, Eulerian models that include aerosol modules simulating the physical and chemical processes governing particulate concentrations in the atmosphere are more suitable than Lagrangian models such as plume trajectory models. Eulerian three-dimensional models may use either a simplified treatment of atmospheric chemistry (usually used to address long-term particulate concentrations at urban sites) or include a more detailed atmospheric chemistry treatment (usually used to simulate only a few days of episodes due to their compositional cost). Commonly used long-term Eulerian models with simplified atmospheric processes include (Seigneur et al., 1997): • Urban Airshed Model Version V (UAM-V). • Urban Airshed Model with version V with Linear Chemistry (UAM-LC) • Regulatory Modeling System for Aerosol and Deposition (REMSAD). Short-term Eulerian models with complex atmospheric processes include: • Urban Airshed Model Version V with Aerosols (UAM-AERO), • Urban Airshed Model with Aerosol Inorganic Module (UAM-AIM). • SARMAP Air Quality Model with Aerosols (SAQM-AERO). • Community Multi-scale Air Quality Model (CMAQ) 48 • Comprehensive Air Quality Model with extensions (CAMx) All of the above mentioned Eulerian models have been developed by various scientists from universities, federal and state agencies, and the private sector. These particulate air quality models provide a three-dimensional treatment to simulate the fate and transport of atmospheric contaminants. All of these Eulerian models include gas phase chemistry and aerosol dynamics and simulate atmospheric inorganics (such as sulfate, nitrate, and ammonium), but some of these models do not include the treatment of organics (i.e., REMSAD and UAM-LC). c. Lagrangian Trajectory Model Techniques The advantages of using Lagrangian models are the ease of use, the ability to perform many trajectories and perform back trajectories. Commonly used Lagrangian models include HYSPLIT (Draxler and Hess, 1997) and FLEXPART (Stohl and Siebert, 2001). d. Meteorological Modeling Techniques Meteorological models describe transport, dispersion, vertical mixing, and moisture in time and space. Meteorological models consist of straight line, interpolation (termed diagnostic), and first principle (termed prognostic) formulations, with increasing levels of complexity and requirements for computational and data resources. The straight line model is applied to hourly wind directions from a single monitor, assuming an air mass travels a distance equal to the wind velocity in the measured direction, regardless of the distance from the monitoring site. This model is applicable for a few hours of transport in flat terrain, typically for evaluating a single emissions source. Interpolation models integrate wind speed and directions from multiple measurement locations, including upper air measurements provide by remote sensors or balloon launches. The more advanced of these models allow barriers, such as mountains, to be placed between monitors. Wind fields, therefore, show different directions and velocities at different horizontal and vertical positions. Interpolation wind models are applicable to domains with a large number of well-placed monitors and for estimating the movement of air masses from many sources over transport times of more than half a day. The number and placement of monitors, especially upper air monitors, is especially important in mountainous terrain and in coastal areas where winds are unusual. First principle models (Stauffer and Seaman, 1994; Seaman et al., 1995; Koracin and Enger, 1994) embody scientists’ best knowledge of atmospheric physics and thermodynamics, employing basic equations for conservation and transfer of energy and momentum. Also known as “prognostic models,” first principle models purport to need no data other than values from a sparse upper air network for interpolation. They are computationally intensive, often requiring supercomputers but have become more practical and cost-effective as workstation and desktop computers become more powerful. Modern versions use “four-dimensional data assimilation” or FDDA that compare model-calculated wind, humidity, and temperature fields with measurements and “nudge” model outputs toward observations. 49 A more complex meteorological model is not necessarily a better model for a specific application. One of the most widely used first principle model is the Fifth-Generation NCAR/Penn State Mesoscale Model or MM5 model (Grell et al., 1995). The MM5 meteorological model has been adopted as the platform for central California air quality studies (Seaman et. al., 1995). MM5 input data consist of wind speed, wind direction, temperature, atmospheric pressure, and relative humidity at ground level, within the boundary layer, and above the boundary layer. In many cases in valley situations ten-meter vertical resolution is needed within the surface layer, 30-50 m resolution is needed in the valley wide layer, and 100 m resolution is needed above the valleywide layer up to ~2000 m agl (Watson et al., 1998). Time resolution is at least hourly for these measurements. Measurements are needed where large differences are expected, although this is largely unknown for winter. References: Bowne, N.E.; and Londergan, R.J. (1983). Overview, results and conclusions for the EPRI plume model validation and development project: Plains site. Report No. EA-3074 PROJECT 1616. Prepared by Electric Power and Research Institute, Palo Alto, CA. Braaten, D.A.; and Cahill, T.A. (1986). Size and composition of Asian dust transported to Hawaii. Atmos. Environ., 20:1105-1109. Chow, J.C.; Watson, J.G.; Lowenthal, D.H.; Solomon, P.A.; Magliano, K.L.; Ziman, S.D.; and Richards, L.W. (1993a). PM10 and PM2.5 compositions in California's San Joaquin Valley. Aerosol Sci. Technol., 18:105-128. Chow, J.C.; Watson, J.G.; Pritchett, L.C.; Pierson, W.R.; Frazier, C.A.; and Purcell, R.G. (1993b). The DRI Thermal/Optical Reflectance Carbon Analysis System: Description, Evaluation and Applications in U.S. air quality studies. Atmos. Environ., 27A:1185-1201. Chow, J.C.; Watson, J.G.; Lu, Z.; Lowenthal, D.H.; Frazier, C.A.; Solomon, P.A.; Thuillier, R.H.; and Magliano, K.L. (1996a). Descriptive analysis of PM2.5 and PM10 at regionally representative locations during SJVAQS/AUSPEX. Atmos. Environ., 30:2079-2112. Chow, J.C.; Watson, J.G.; Lowenthal, D.H.; and Countess, R.J. (1996b). Sources and chemistry of PM10 aerosol in Santa Barbara County, CA. Atmos. Environ., 30:1489-1499. Chow, J.C.; and Egami, R.T. (1997). San Joaquin Valley Integrated Monitoring Study: Documentation, evaluation, and descriptive analysis of PM10 and PM2.5, and precursor gas measurements - Technical Support Studies No. 4 and No. 8 - Final report. Prepared for California Regional Particulate Air Quality Study, California Air Resources Board, Sacramento, CA, by Desert Research Institute, Reno, NV. Darzi, M.; and Winchester, J.W. (1982). Aerosol characteristics at Mauna Loa Observatory, Hawaii, after east Asian dust storm episodes. J. Geophys. Res., 87:1251-1258. Draxler, R.R.; and Hess, G.D. (1997). Description of the Hysplit_4 modeling system. Report No. NOAA Tech Memo ERL ARL-224, December 1997. Prepared by Air Resources Laboratory, NOAA, Silver Spring, MD. 50 Green, A.E.; Singhal, R.P.; and Venkateswar, R. (1980). Analytic extensions of the Gaussian plume model. JAPCA, 30:773-776. Greer, W.L.; Johnson, M.D.; Morton, E.L.; Raught, E.C.; Steuch, H.E.; and Trusty, C.B. (1992). Portland cement. In Air Pollution Engineering Manual, Buonicore, A.J. and Davis, W.T., Eds. Van Nostrand Reinhold, New York, NY, pp. 746-766. Grell, G.A.; Dudhia, J.; and Stauffer, D.R. (1995). A description of the fifth-generation Penn State/NCAR Mesoscale Model (MM5). Report No. NCAR Technical Note, NCAR/TN398+STR, June 1995. Prepared by National Center for Atmospheric Research, Boulder, CO. Grosjean, D.; and Seinfeld, J.H. (1989). Parameterization of the formation potential of secondary organic aerosols. Atmos. Environ., 23:1733-1747. Grosjean, D. (1992). In-situ organic aerosol formation during a smog episode: estimated production and chemical functionality. Atmos. Environ., 26A:953-963. Holton, J.R. (1982). An Introduction to Dynamic Meteorology. Academic Press, New York, NY. Houck, J.E.; Chow, J.C.; and Ahuja, M.S. (1989). The chemical and size characterization of particulate material originating from geological sources in California. In Transactions, Receptor Models in Air Resources Management, Watson, J.G., Ed. Air & Waste Management Association, Pittsburgh, PA, pp. 322-333. Houck, J.E.; Goulet, J.M.; Chow, J.C.; Watson, J.G.; and Pritchett, L.C. (1990). Chemical characterization of emission sources contributing to light extinction. In Transactions, Visibility and Fine Particles, Mathai, C.V., Ed. Air and Waste Management Association, Pittsburgh, PA, pp. 437-446. Koracin, D.; and Enger, L. (1994). A numerical study of boundary-layer dynamics in a mountain valley. Part 2: Observed and simulated characterisitcs of atmospheric stability and local flows. Boundary Layer Meteorology, 69:249-283. Lowenthal, D.H.; Chow, J.C.; Watson, J.G.; Dipple, W.A.; and Mazzera, D.M. (1996). PM10 source apportionment at McMurdo Station, Antarctica. EM, 28-30. Odum, J.R.; Jungkamp, T.P.W.; Griffin, R.J.; Forstner, H.J.L.; Flagan, R.C.; and Seinfeld, J.H. (1997). Aromatics, reformulated gasoline, and atmospheric organic aerosol formation. Environ. Sci. Technol., 31:1890-1897. Pandis, S.N.; Harley, R.A.; Cass, G.R.; and Seinfeld, J.H. (1992). Secondary organic aerosol formation and transport. Atmos. Environ., 26A:2269-2282. Pandis, S.N.; Wexler, A.S.; and Seinfeld, J.H. (1993). Secondary organic aerosol formation and transport - II. Predicting the ambient secondary organic aerosol size distribution. Atmos. Environ., 27A:2403-2416. 51 Pytkowicz, R.M.; and Kester, D.R. (1971). The physical chemistry of sea water. Oceanogr. Mar. Biol., 9:11-60. Rogge, W.F.; Hildemann, L.M.; Mazurek, M.A.; and Cass, G.R. (1991). Sources of fine organic aerosol. 1. Charbroilers and meat cooking operations. Environ. Sci. Technol., 25:11121125. Rogge,W.F.; Mazurek, M.A.; Hildemann, L.M.; Cass, G.R.; and Simoneit, B.R.T. (1993a). Quantification of urban organic aerosols at a molecular level: identification, abundance and seasonal variation. Atmos. Environ., 27A:1309-1330. Rogge, W.F.; Hildemann, L.M.; Mazurek, M.A.; Cass, G.R.; and Simoneit, B.R.T. (1993b). Sources of fine organic aerosol. 2. Noncatalyst and catalyst-equipped automobiles and heavy-duty diesel trucks. Environ. Sci. Technol., 27:636-651. Rogge, W.F.; Hildemann, L.M.; Mazurek, M.A.; Cass, G.R.; and Simoneit, B.R.T. (1993c). Sources of fine organic aerosol. 3. Road dust, tire debris, and organometallic brake lining dust: Roads as sources and sinks. Environ. Sci. Technol., 27:1892-1904. Rogge, W.F.; Hildemann, L.M.; Mazurek, M.A.; Cass, G.R.; and Simoneit, B.R.T. (1997). Sources of fine organic aerosol. 8. Boilers burning No. 2 distillate fuel oil. Environ. Sci. Technol., 31:2731-2737. Rogge, W.F.; Hildemann, L.M.; Mazurek, M.A.; Cass, G.R.; and Simoneit, B.R.T. (1998). Sources of fine organic aerosol. 9. Pine, oak, and synthetic log combustion in residential fireplaces. Environ. Sci. Technol., 13-22. Scire, J.S.; Strimaitis, D.G.; and Yamartino, R.J. (2000). A user's guide for the CALPUFF dispersion model (version 5). Prepared by Earth Tech, Inc., Concord, MA. Seaman, N.L.; Stauffer, D.R.; and Lario-Gibbs, A.M. (1995). A multiscale four-dimensional data assimilation system applied in the San Joaquin Valley during SARMAP. Part I: Modeling design and basic performance characteristics. Appl. Meteorol., 34:1739-1761. Seigneur, C.; Pai, P.; Lourensz, R.S.; Hopke, P.K.; and Grosjean, D. (1997). Review of air quality models for particulate matter. Report No. CP015-97-1a. Prepared for American Petroleum Institute, Washington, D.C., by Atmospheric & Environmental Research, Inc., San Ramon, CA. Seinfeld, J.H.; and Pandis, S.N. (1998). Atmospheric Chemistry and Physics. John Wiley & Sons, New York. Stauffer, D.R.; and Seaman, N.L. (1994). Multiscale four-dimensional data assimilation. J. Appl. Meteorol., 33:416-434. Stohl, A.; and Seibert, P. (2001). The FLEXPART particle dispersion model version 4.0 user guide. June 4, 2001. 52 Strader, R.; Pandis, S.N.; and Lurmann, F.W. (1998). Evaluation of secondary organic aerosol formation in winter. Prepared for California Air Resources Board, Sacramento, CA, by Carnegie Mellon University, Pittsburgh, PA. Stull, R.B. (1988). An Introduction to Boundary Layer Meteorology. Kluwer Academic Publishers, Dordrecht. Tang, I.N.; and Munkelwitz, H.R. (1993). Composition and temperature dependence of the deliquescence properties of hygrosopic aerosols. Atmos. Environ., 27A:467-473. Watson, J.G.; Chow J.C.; Lowenthal, D.H.; Pritchett, L.C.; Frazier, C.A.; Neuroth, G.R.; and Robbins,R. (1994a). Differences in the carbon composition of source profiles for dieseland gasoline-powered vehicles. Atmos. Environ., 28:2493-2505. Watson, J.G.; Chow, J.C.; Lu, Z.; Fujita, E.M.; Lowenthal, D.H.; and Lawson, D.R. (1994b). Chemical mass balance source apportionment of PM10 during the Southern California Air Quality Study. Aerosol Sci. Technol., 21:1-36. Watson, J.G.; Chow, J.C.; Lurmann, F.W.; and Musarra, S. (1994c). Ammonium nitrate, nitric acid, and ammonia equilibrium in wintertime Phoenix, Arizona. JAWMA, 44:405-412. Watson, J.G.; Chow ,J.C.; Rogers, C.F.; Dubois, D.; and Cahill, C.F. (1997). Analysis of historical PM10 and PM2.5 measurements in Central California. Prepared for California Air Resources Board, Sacramento, CA, by Desert Research Institute, Reno, NV. Watson, J.G.; Fujita, E.M.; Chow, J.C.; Zielinska, B.; Richards, L.W.; Neff, W.D.; and Dietrich,D. (1998). Northern Front Range Air Quality Study. Final report. Prepared for Colorado State University, Fort Collins, CO, by Desert Research Institute, Reno, NV. Watson, J.G.; DuBois, D.W.; DeMandel, R.; Kaduwela, A.; Magliano, K.; McDade, C.; Mueller, P.K.; Ranzieri, A.; Roth, P.M.; and Tanrikulu, S. (1998). Aerometric monitoring program plan for the California Regional PM2.5/PM10 Air Quality Study. Report No. DRI document No. 9801.1D5. Prepared by Division of Atmospheric Sciences, Desert Research Institute, Reno, NV. 53 Source Modeling and Back Trajectory Attribution Techniques Table 2. Puff, Visibility and Trajectory Modeling Attribution Techniques Air Quality Models Evaluation Criteria Visibility Models CALPUFF Lagrangian Trajectory Models VISCREEN PLUVUEII HYSPLIT RAPTAD FLEXPART NO NO NO NO NO Yes NO NO NO NO NO 4 species model NO NO NO NO NO Inorganic PM (i.e. ions, SO4, NO3, etc) SO4, NO3 NO NO NO NO NO Size distributions (sectional or modal) Coarse and fine modes NO NO Only for deposition NO Applicable spatial scales Micro- to regional scale Neighbor-hood to urban scale Neighborhood to global scale Neighborhood to global scale Neighborhood to global scale Applicable temporal scales (episodic or long term applications) Does the model have the capability to distinguish BART sources? Episodic or Long term N/A N/A Episodic or Long term Episodic or Long term Episodic or Long term YES YES YES YES YES YES Does the model have the capability to ingest field measurements (PM, HNO3, H2O2, NH3, etc) NO; only as background values NO NO NO NO NO Chemical Mechanisms Does the model simulate Yes; reactions for aqueous phase chemistry? (If SO4 and NO3 it does what chemistry mechanism is used and does it include fog/cloud chemistry) Does the model simulate gas phase chemistry? (if it does, what chemical mechanism is implemented) Simulate secondary organic aerosols 55 Air Quality Models (continued) Evaluation Criteria Visibility Models Lagrangian Trajectory Models CALPUFF VISCREEN PLUVUEII HYSPLIT RAPTAD FLEXPART NO NO NO NO NO NO Point source treatment (plume rise, plume in grid) YES YES YES YES YES YES Does the model have the capability to calculate wet and dry deposition? YES NO NO YES NO YES Extinction (total and for SO4, NO3, EC, OC, fine, coarse), Deciviews * * NO NO NO * * Gridded (FNL, EDAS, MM5) Gridded (Use HOTMAC’s prediction) Gridded (ECMWF, MM5) Visibility Modeling Does the model simulate background regional haze Visibility treatment: (extinction, deciview, visual range) Input Requirements Meteorological data required Gridded; able to (single site, gridded, number run with single site of levels, etc) Emission data required (single stack, multiple point sources, gridded, etc) Multiple point, area, volume * * Multiple point sources, gridded inventory Single stack or multiple point sources * Allow for initial and boundary conditions (is it required or not applicable) YES NO NO NO NO NO Has the model been compared against field program data? Has the model been peer reviewed? Does enough data exist now to run the model (Does data exist in a format ready for the model? Are current databases adequate for the model?) YES YES YES YES YES NO Use CALMET with existing stations or MM data YES YES Gridded met data Use HOTMAC to obtain available on NOAA wind and turbulence data ARL ftp site (FNL, EDAS); adaptable to read in MM5 56 * Air Quality Models (continued) Evaluation Criteria Visibility Models Lagrangian Trajectory Models CALPUFF VISCREEN PLUVUEII HYSPLIT Inexpensive; PC, Windows, up to 20GB (with CALMET) Inexpensive; PC, DOS, 1MB Inexpensive; PC, DOS, 1MB Inexpensive; PC, Windows, 20MB Have protocols or procedures been developed to run and interpret the model? Is the source code available? FLAG for Class I AQRVs FLAG for Class I AQRVs NO NO NO YES YES FLAG for Class I AQRVs YES NO YES YES Are beginning user training classes available? YES; by EarthTech, BEELine EPA; APTI EPA; APTI NO YES NO YES; one list-serve YES; through EPA SCRAM YES; through EPA SCRAM NO YES NO Practical Considerations Costs to run (hardware platforms, file storage, operating system) Are user support groups available? Level of expertise required to run and interpret results (Level of Linux, UNIX, PC skills required) Moderate; able to Simple; able to run on Simple; able Simple; able to run run PC DOS PC DOS and windows to run on PC on PC running programs; DOS and Windows knowledge of Windows atmospheric chemistry & physics Output visualization required to interpret output numbers FLEXPART Inexpensive: Linux PC, Inexpensive; Linux PC, Redhat; can be Redhat compiled on PC Simple to run: GUI Moderate; must compile source code for allows the user to easily PC, Linux or UNIX; knowledge of met run the program input formats Knowledge is needed to interpret results YES NO NO YES; has built in visualization YES; has built in visualization YES * * * * Applicable from building scale to terrain scale. * EarthTech EPA EPA Other strengths Availability RAPTAD www.src.com NOAA Air Yamada Science & Art; http://www.forst.uniResource http://www.ysasoft.com muenchen.de/EXT/LST/METEO/stohl/f Laboratory; lexpart.html www.arl.noaa.gov/s s/models/hysplit.ht ml * No information available at this time 57 Source Modeling and Back Trajectory Attribution Techniques Table 3. Eulerian Grid Based Modeling Attribution Techniques Air Quality Models Evaluation Criteria CMAQ REMSAD CAMx Chemical Mechanisms Does the model simulate aqueous phase chemistry? (If it does, what chemistry mechanism is used and does it include fog/cloud chemistry) 35 equilibria and 99 reactions for SO4 and NO3 1 reaction for SO4 1 reaction for SO4 Does the model simulate gas phase chemistry? (if it does, what chemical mechanism is implemented) CBM-IV (93 reactions) or RADM2 (158 reactions) CBM-IV (93 reactions) or RADM2 (158 reactions) CB-IV with enhanced isoprene or SAPRC97 Simulate secondary organic aerosols Primary from emissions; secondary from organics Primary from emissions Inorganic PM (i.e. ions, SO4, NO3, etc) SO4, NO3 and other material SO4, NO3, NH4, and other material SO4, NO3, NH4, Cl, other ions and materials Size distributions (sectional or modal) Lognormal; three modes: Aitken, Accumulation and coase PM2.5 fraction, coarse Discrete bins, user mode specified up to 10 Applicable spatial scales Applicable temporal scales (episodic or long term applications) Does the model have the capability to distinguish BART sources? Grid Models UAM-AERO UAM-VPM URM CalGrid 35 equilibria and 99 reactions for SO4 and NO3 * 2 reactions for sulfate NO SAPRC97 (185 reactions) CB Primary from Secondary from gas emissions; secondary phase reactions of from gas phase organic precursors reactions of organic using yields precursors using yields LCC YES (both CBM-IV (about 100 reactions) and SAPRC) Primary from emissions Primary from emissions; secondary from gas phase reactions of organic precursors using production fractions NO SO4, NO3, NH4, Cl, other ions and materials SO4, NO3, NH4, and other materials SO4, NO3, NH4, Cl, other ions and materials NO Discrete bins, user specified up to 10 Lognormal bins; user specified Discrete bins; user specified NO Mesoscale Episodic Mesoscale Long term Mesoscale Episodic Urban scale Episodic Urban scale Episodic Mesoscale Episodic Urban to Regional Episodic YES; using plume in grid NO YES NO NO NO NO 58 Air Quality Models (continued) Evaluation Criteria Chemical Mechanisms (continued) Does the model have the capability to ingest field measurements (PM,HNO3,H2O2,NH3,etc) Visibility Modeling Does the model simulate background regional haze Point source treatment (plume rise, plume in grid) Does the model have the capability to calculate wet and dry deposition? Visibility treatment: (extinction, deciview, visual range) Input Requirements Meteorological data required (single site, gridded, number of levels, etc) CMAQ REMSAD CAMx Grid Models UAM-AERO UAM-VPM URM CalGrid YES; as initial and Uses default profiles YES; as initial and YES; as initial and YES; as initial and YES; as initial and YES; as initial and boundary conditions boundary conditions boundary conditions boundary conditions boundary conditions boundary conditions YES YES YES YES (with processing) YES YES NO Plume in grid NO Plume in grid NO NO NO NO YES YES YES YES YES YES YES NO YES (with processing) * * NO Extinction (total and Extinction (total and for SO4, NO3, EC, for SO4, NO3, EC, OC, fine, coarse), OC, fine, coarse), Deciviews Deciviews Gridded Gridded Gridded Gridded Gridded Gridded Gridded CALMET date Emission data required (single stack, multiple point sources, gridded, etc) Gridded Gridded Gridded Gridded Gridded Gridded Gridded Allow for initial and boundary conditions (is it required or not applicable) YES YES YES YES YES YES YES Has the model been compared against field program data? Has the model been peer reviewed? YES YES YES YES YES YES YES Extensive need for detailed emissions and meteorological fields Extensive need for detailed emissions and meteorological fields Extensive need for detailed emissions and meteorological fields Extensive need for detailed emissions and meteorological fields Extensive need for detailed emissions and meteorological fields * Extensive need for detailed emissions and meteorological fields Does enough data exist now to run the model (Does data exist in a format ready for the model? Are current databases adequate for the model?) 59 Air Quality Models (continued) Evaluation Criteria CMAQ REMSAD CAMx Grid Models UAM-AERO UAM-VPM URM CalGrid Practical Considerations Costs to run (hardware platforms, file storage, Can be run Can be run Can be run Can be run Can be run Can be run Can be run operating system) inexpensively; Linux inexpensive; Linux inexpensively; Linux inexpensively; Linux inexpensively; Linux inexpensively; Linux inexpensively; Linux PC, up to 1 TB PC PC PC PC PC PC (annual runs) Has a protocol or procedures been developed to run the model? NO; but RPOs have regional haze protocols NO; but RPOs have regional haze protocols NO NO NO NO NO YES * YES YES YES YES YES Are beginning user training classes available? YES; through EPA and RPOs NO YES; through SAI and RPOs NO NO NO NO Are user support groups available? YES; through EPA and RPOs NO NO NO NO NO NO Considerable expertise in UNIX or Linux; knowledge of atmospheric chemistry & physics * Moderate to extensive Moderate to extensive * * Moderate YES; use PAVE YES; use PAVE YES YES YES YES YES Is the source code available? Level of expertise required to run and interpret results (Level of Linux, UNIX, PC skills required) Output visualization required to interpret output numbers Availability EPA; Sharon LeDuc SAI; Sharon Douglas ENVIRON; Ralph SAI; Sharon Douglas SAI; Sharon Douglas Georgia Tech; Ted 919-541-1335 415-507-7108 Morris 415-899-0700 415-507-7108 415-507-7108 Russel, Talat Odman * No information available at this time 60 California Air Resources Board Table 4. Meteorological Modeling Attribution Techniques Diagnostic Models Mesoscale Prognostic Models Evaluation Criteria CALMET Applicable spatial scales Urban to regional scale Hourly to annual Diagnostic Wind Model Urban to regional scale Hourly to annual Depends on area Depends on area Depends on area Depends on area Depends on area Depends on area Depends on area N/A N/A Yes Yes Yes Yes Yes N/A N/A NOAA is running the model for the east coast Several federal agencies and regional consortiums are running MM5 NOAA is running the Eta model and fields available through NCEP ftp site Yes Yes Yes Yes Yes Applicable temporal scales Does enough data exist in organization now to run the model? Are the existing monitoring networks adequate within the domain? For the prognostic models: Capable of FDDA? For the prognostic models: Are files available (archived) from real-time? Data storage/archival requirements for simulation of episodic and annual events Simulate clouds/precipitation fields? At what time intervals? Has the model been compared against field program data? Has the model been peer reviewed? RAMS MM5 Eta * ARPS HOTMAC Urban to global scale Hourly to annual Urban to global scale Hourly to annual Urban to global scale Hourly to annual Urban to global scale Hourly to annual Urban to mesoscale Hourly to annual It can be No initialized using NCEP analyses files as well as individual observations Depends on Depends on Depends on Depends on Depends on Depends on Depends on modeling domain, modeling domain, modeling domain, modeling domain, modeling domain, modeling domain, modeling domain, grid size, number of grid size, number grid size, number grid size, number grid size, number grid size, number grid size, number species and length of species and of species and of species and of species and of species and of species and of simulation length of length of length of length of length of length of simulation simulation simulation simulation simulation simulation No No Yes – minutes to Yes – minutes to Yes – minutes to Yes – minutes to Yes – minutes to days days days days days 61 Yes Yes Meteorological Modeling Attribution Techniques (continued) Diagnostic Models Mesoscale Prognostic Models Diagnostic Wind CALMET RAMS MM5 Eta * ARPS HOTMAC Evaluation Criteria Model Tools available to Yes – Unix, Linux, Yes – Unix, Yes – Unix, Linux Yes – Unix, Linux Yes – Unix, Linux Yes – Unix, Linux Yes – Built-in visualize output fields? Windows Linux, Windows GUI; Unix, Linux, What operating systems? Windows Are user groups, Yes Yes Yes Yes No Yes Yes listservers available when problems arise? Cost to run (hardware, PC Windows, PC PC Linux, UNIX; PC Linux; licensed PC Linux, UNIX; PC Linux, UNIX; PC Linux, UNIX; PC Linux; licensed software) Linux; Free source Free source code Free source code Free source code Free source code source code code Level of expertise Moderate Moderate High High High High High required to run and interpret results (Level of Linux, UNIX, PC skills required) Availability of user Yes Yes Yes Yes No Yes Yes training Is the source code Yes Yes Yes Yes No Yes Yes available? Has a protocol or Yes Yes Yes Yes Yes Yes Yes procedures been developed to run the model? Strengths Relatively easy to Relatively easy to Detailed 3-D, Detailed 3-D, Detailed 3-D, Detailed 3-D, Detailed 3-D, use; little observed use; little observed complex flow in complex flow in complex flow in complex flow in complex flow in data needed data needed time time time time time Weaknesses/ Parameterization Parameterization Large computer Large computer Large computer Large computer No real time data Limitations depended; may not depended; may not time; time time; time time; time time; time initialization capture various capture various consuming to consuming to consuming to consuming to flows flows debug debug debug debug * While the Eta is not considered a mesoscale model, it has been used to simulate meteorology down to 10 km grid scales. The workstation Eta is available from NOAA and used experimentally by some NWS offices. * No information available at this time 62 C. Observational Modeling Techniques Introduction Observational or receptor modeling refers to a group of analysis techniques in which monitoring data collected at or in the region of a receptor are analyzed in various ways in order to infer information about the pollutants and the sources of the pollutants causing visibility impairment. These types of models often are used as the first technique for source apportionment in order to get an initial understanding of the source-receptor relationships in a region. They are also used to verify or reconcile deterministic models, and to aid in planning intensive monitoring studies. Results of observational models can either be quantitative or qualitative. Quantitative results are estimates of the fractions of a measured species that can be attributed to a single source or attributed among several sources or source areas. Qualitative results include such information as the wind directions and other meteorological conditions most associated with high concentrations, or inferences about probable source types based on the relationships between trace elements at a single site, or information about source areas based on the spatial and temporal patterns in the concentrations of a single species. Often several observational models are used together to form hypotheses about the important source areas and source types affecting the concentrations at a receptor. Advantages of receptor models are that they are generally quick and inexpensive to run and require relatively little input data. Disadvantages include the necessity of employing simplifying assumptions such as linear relationships and often the results are limited to averages over long periods of time or large spatial areas. Subjective user judgment is required to choose appropriate input data and/or interpret the results of many receptor models. As an example, suppose the UNMIX model data located a source associated with high concentrations of Br, K, elemental carbon, and organic carbon, and another source associated with high Se and S. It is the judgment of the modeler regarding the relationship of the individual species to a specific source that determines that first source is “smoke” and the second is “coal-fired power plants.” Receptor models could potentially be grouped in several different ways, based on their different attributes. Here they are somewhat arbitrarily put into four categories, with each category requiring incrementally more particulate data at the receptor: 1) back-trajectory analyses; 2) analyses of interspecies relationships; 3) analyses of spatial and temporal patterns; and 4) analyses that require a unique tracer. Some models that fall into each category are listed below: Category 1. Back-Trajectory Analyses a. Residence Time Analyses including residence time, source contribution function, conditional probability, and so forth. These give qualitative information about source areas and transport patterns. 63 b. Trajectory Mass Balance – Regression of residence time of back trajectories in selected source areas against concentrations yielding quantitative source attributions. Category 2. Analyses of Interspecies Relationships a. Chemical Mass Balance (CMB) - Quantitative source attributions are obtained by a weighted regression of known source profiles against measured concentrations of several species. b. UNMIX – By looking for “edges” in the relationships between species, UNMIX estimates both the source profiles and the quantitative source contributions from each source. c. Positive Matrix Factorization (PMF) – PMF, like UNMIX, uses the relationships between species to estimate the number and composition of the sources and the quantitative source contributions. d. Enrichment Factors (EF) – The “enrichment” of certain ratios of trace elements is used to qualitatively infer source types impacting a receptor. Category 3. Analyses of Spatial and Temporal Patterns a. Empirical Orthogonal Function Analysis (EOF) – Analysis of spatial and temporal patterns leading to qualitative information about locations of dominant source areas, frequency and timing of source impacts and meteorological conditions associated with them. b. Receptor Model Applied to Patterns in Space (RMAPS) – With additional assumptions applied to EOFs, quantitative source attributions are estimated. Category 4. Tracer Analyses a. Tracer Mass Balance Regression (TMBR) – Tracer concentrations, possibly weighted by other factors, are regressed against concentrations of the species of interest to give a quantitative estimate of the contribution from the source that emitted the tracer. b. Differential Mass Balance (DMB) - The differential ratios of tracer to pollutant between source and receptor are adjusted based on simple chemistry and meteorology to give an estimate of the contribution of the tracer source to the receptor. c. Tracer-Aerosol Gradient Interpretive Technique (TAGIT) – By comparing the ratios of tracer to concentration of interest at “background” sites to the ratios at tracer-affected sites, a quantitative attribution of the tracer source to the receptor is estimated. Following are brief descriptions of each of these models and a few references giving further details and examples of their use. 1a. Qualitative Back Trajectory Residence Time Analyses There are several methods of statistically analyzing the relationships between where air masses arrived from and the concentrations measured at a receptor. These include, but are not limited to: 1) where was air most likely to arrive from when concentrations are high; 2) if air arrived from a given area, what is the probability that the concentration at the receptor was high when the air mass arrived there; 3) what is the mean (or median or maximum or distribution) of 64 concentrations at the receptor when air masses arrived from a given area. Selected References: Ashbaugh et al. (1985), Gebhart et al. (2001), Poirot and Wishinski (1986). Data Needed: A time series of concentrations of the species of interest. One or more back trajectories of three to five days duration corresponding to each concentration. Back trajectories can be calculated by any of several methods including ATAD, Hysplit, the CAPITA Monte Carlo Model, as well as others. Standard National Weather Service upper air data can be used as input, though more detailed meteorological data can be input if available. Dispersion can be included in some of these models. Model Assumptions: Errors in trajectory placement are random and uncorrelated. Variations in deposition, chemistry, emissions, and so forth, have less influence on measured concentrations on average than variations in transport directions. Biggest Potential Problems: Results of these types of analyses are qualitative rather than quantitative. Results are more statistically robust when averaged over long time periods, usually a minimum of one season and preferably several years. Nearby sources cannot be resolved. User judgment is required to choose trajectories of an appropriate type, height, and length and also to choose appropriate definitions of “high” concentrations. Some concentrations that vary seasonally may have all “high” concentrations in a single season, necessitating some compensation in the analysis. Model results are probably more appropriate for species such as particulate sulfate that are relatively uniform over large spatial scales, rather than, for example, particulate nitrate, which is more volatile and seems to be more related to local sources than long-range transport. 1b. TrMB (Trajectory Mass Balance) This is a multiple linear regression of the frequency of occurrence of trajectory endpoints in each of several source areas against the corresponding concentrations at the receptor. The result is the average attribution of a single species among up to about 25 source areas over a long time, for example, one season or year, or several years. Selected references: Gebhart and Malm (1989), Stohl (1998). Data Needed: Time series of concentrations of the pollutant of interest at a single site. One or more back trajectories associated with each concentration. Input data for these are upper air winds, temperatures, and moisture over a large area. Often data are obtained from the standard National Weather Service observations, but other data such as higher resolution wind fields, wind profiler data specific to a given study, can also be used if available. Emission data can be used if available, but must vary in time to be useful. Simple chemistry and/or deposition can be used if data are available. The user defines the size and locations of the source areas to be considered. Model Assumptions: Average contributions of each source area can be written as a linear combination of the contributions from several source areas. Average chemistry and deposition are adequate to explain average source contributions. Errors in back trajectories are random and normally distributed. 65 Biggest Potential Problems: No attribution to single sources—only to source areas. Attributions must be averaged over long time periods. Nearby sources cannot be modeled accurately. Subjectivity in choosing source areas. Violation of assumptions of linear chemistry. 2a. Chemical Mass Balance (CMB) CMB is a multiple linear regression of measured concentrations against known source profiles. It is used for the attribution of all measured chemical species among several sources for each concentration measurement period for a single monitoring site. Regressions are weighted by the uncertainties in both the source profiles and the concentrations. Selected References: Watson et al. (1984 and 2001). Data Needed: Concentrations and measurement uncertainties of both the chemical species of interest and of as many trace elements as possible are necessary for each time period and location for which attributions are desired. IMPROVE data can be used. A source profile is needed for each source. These are the relative amounts of each emitted chemical species and the uncertainties in these values. Model Assumptions: Compositions of source emissions are constant over the period of ambient and source sampling. Chemical species do not react with each other, for example, they add linearly. All sources with a potential for significantly contributing to the receptor have been identified and have had their emissions characterized. The sources’ compositions are linearly independent of each other. The number of sources or source categories is less than or equal to the number of chemical species. Measurement uncertainties are random, uncorrelated and normally distributed. Biggest Potential Problems: The model cannot directly apportion secondary species such as sulfates, nitrates, and secondary organics. There are some workarounds for this. The usual tactic is to apportion these species between the known primary sources and a source designated as “secondary particles.” It is also possible to use “fractionated” or “aged” source profiles where an attempt is made to pre-determine the chemical processes that occurred between source and receptor and then adjust the source profile accordingly. Obtaining all necessary source profiles can be difficult. In some studies, other receptor models have estimated source profiles. 2b. UNMIX For a selection of measured species, UNMIX uses singular value decomposition with additional non-negativity constraints to estimate the number of sources, the source compositions, and the source contributions to each sample at a single monitoring site. UNMIX attempts to find the “edges” in the relationships between species and relates these to sources. Selected References: Henry (1997a, 1999), Lewis et al. (1998). Data Needed: A time series of concentrations of several species measured at a single site. IMPROVE data can be used. 66 Model Assumptions: Concentrations are linear combinations of an unknown number of sources of unknown composition. Contributions from sources are positive. Source compositions are approximately constant in time. For each source there are some samples that contain little or no contribution from that source. Biggest Potential Problems: A maximum of seven sources can be identified. There is some subjectivity in choosing fitting species, number of sources, how to deal with missing or below detection limit values, and which time periods and species should be analyzed together. Sources of secondary species will probably violate the assumption of constant source composition. This can cause multiple sources to be identified for a single physical source that impacts the receptor under differing conditions. Supplemental analysis may be required to deconvolute these. 2c. Positive Matrix Factorization (PMF) PMF uses an iterative weighted least squares method to decompose a time-by-species matrix to estimate the number and composition of the sources and the contributions of each source to each measured species. It will also calculate error estimates for these values. Selected References: Paatero and Tapper (1994), Paatero (1997); Xie et al. (1999). Data Needed: A time series of concentrations and their uncertainties for several species at a single monitoring location. IMPROVE data can be used. Model Assumptions: Concentrations are linear combinations of an unknown number of sources of unknown composition. Contributions from sources are positive. Source compositions are approximately constant in time. Biggest Potential Problems: Correlations in detection limits or uncertainties as well as in concentrations can influence the results. For example, PMF may detect positive correlations between species either due to source activity (desirable) or measurement protocol changes (undesirable). 2d. Enrichment Factors (EF) The differences in ratios of elemental concentrations between a reference sample and a measured sample are used to determine how sources may have “enriched” the concentrations of certain species. Some examples include: high Al/Ca has been linked to Saharan dust, high Br/Pb may indicate lead is linked to autos rather than industry, high Se is linked to coal burning, heavy metals are linked to smelting, V and Ni are linked to residual oil combustion. Selected References: Lawson and Winchester (1979), Parekh et al. (1989), Perru (1997), Roshid and Griffiths (1993). Data Needed: Time series of concentrations of trace elements and the species of interest. Some historical information about the “standard” crustal, sea salt, or other ratios for a region. Model Assumptions: Elemental ratios depend mostly on enrichment of trace elements by a source and have less dependence on meteorology. The reference ratios are constant. 67 Biggest Potential Problems: Attributions are generally to source areas, not to single sources. 3a. Empirical Orthogonal Function Analysis (EOF) A few (typically two to six) spatial patterns that explain most of the covariance in the spatial and temporal patterns of a measured species are obtained by singular value decomposition. Associations between the spatial patterns and source areas and/or transport of air pollutants into the study area can often be inferred, but are qualitative. The original data matrix can be approximately reconstructed by linearly recombining these few patterns. Selected References: Gebhart and Malm (1997), Henry et al. (1991), Malm et al. (1990), Malm and Gebhart (1997). Data Needed: Measurements of a single air pollutant of interest at several sites for several time periods. Typically used are concentrations measured at fifteen to forty sites for thirty or more time periods. There must be more time periods than sites. Data from special studies are often analyzed in this way. Model Assumptions: Only a few spatial patterns are required to explain a large majority of the covariance in the spatial and temporal patterns. These patterns have a physical meaning that can be inferred, such as transport of emissions from a source into the study area or local stagnation. Biggest Potential Problems: Source attributions are qualitative, not quantitative and interpretation of the spatial patterns is subjective. The model requires a site by time matrix with no missing values, so some method of eliminating or filling in both missing and below detection limit values is necessary. 3b. Receptor Model Applied to Patterns in Space (RMAPS) Determines the average attribution of a single species among a few source areas by decomposing the time by site matrix of concentrations into a source matrix and a time weighting matrix. Similar to UNMIX, the edges in the scatterplots between sources and non-negativity requirements are used to constrain the identification of sources. Selected References: Henry (1997 b, c, d), White (1999). Data Needed: Time series of concentrations of the pollutant of interest at several sites within a region. The model previously has been used in special studies such as Project MOHAVE and PREVENT where there are fifteen to forty sites within a one or two state region collecting data daily for several weeks or months. Model Assumptions: Average contributions of each source area can be written as a nonnegative linear combination of the major principal components of the data. The spatial scale of the pollutant is large compared to the spacing of the sampling sites. Biggest Potential Problems: If the second major assumption is violated, the concentrations of the pollutant at each site will have little correlation with the other sites; therefore the model would not apply because it relies on the common variations among sites. 68 4a. Tracer Mass Balance Regression (TMBR) also called Multiple Linear Regression (MLR) on Marker Species Estimates the attribution of the aerosol species of interest by a source or source type, which emitted or emits a unique tracer. Uncertainty estimates are also generated if included in the regression. The model is a regression of the tracer, possibly weighted by other factors against the species of interest. Selected References: Malm et al. (1989 a, b, c). Data Needed: Time series of ambient concentrations and their uncertainties for the aerosol species being apportioned and also the tracer species. Model Assumptions: The tracer(s) are uniquely emitted by non-overlapping groups of sources. Source emissions are constant over the period of ambient sampling. Deposition and conversion are constant for all sampling periods and can be estimated by first-order approximations. In the WHITEX application, sulfate oxidation rates were assumed to be related to RH, where RH was a surrogate for time the air mass spent in clouds. Measurement errors are random, uncorrelated, and normally distributed. Biggest Potential Problems: Tracer concentrations are not often available. Source profiles, deposition, and conversion all vary in time and space. 4b. Differential Mass Balance (DMB) DMB estimates the fraction of a species of interest attributable to a single source that can be tagged with a unique tracer. The ratio of measured tracer to measured sulfate or nitrate is assumed to be related to the fractional contribution of the traced source. The ratio is adjusted based on the estimated difference between the ratio at the source to the ratio at the receptor. Travel times between the source and receptor are estimated based on winds, and then by using simple estimates of dispersion, deposition and oxidation, the tracer to secondary species ratio is adjusted. Selected References: Malm (1989b, c). Data Needed: Time series of tracer concentrations and concentrations and emission rates of the species of interest and its precursors, for example, sulfur dioxide and sulfate. Estimates of wind speed and direction, mixing heights, deposition and oxidation rates. Model Assumptions: Wind direction does not change during transport time. The rates for deposition and conversion are first-order and invariant in space and time along the transport path between the source and the receptor. The ratio of the emission rates for the species of interest or its parent species and the tracer is known. Biggest Potential Problems: Simple chemistry and meteorology may not be adequate, especially for long transport times, complex terrain, and/or changing chemical regimes. Tracer concentrations unique to a single source are often not available. The fraction of attributable concentration may only be calculable to within a range based on the reasonable ranges of rate coefficients. 69 4c. Tracer-Aerosol Gradient Interpretive Technique (TAGIT) Results are the attribution of primary or secondary species associated with the source “tagged” by a tracer release. TAGIT computes attributions on a sample period-by-sample period basis. For each sample period, background concentration of the species of interest is determined by averaging the concentrations of the species at nearby sites that do not have tracer concentrations and are significantly above background. These sites are presumed to be unaffected by the tracer-tagged source and thus represent the average background. This background for each sample period is then subtracted from the concentration of the species of interest at impacted receptor sites for corresponding sample periods. The difference is the concentration attributable to the tagged source. Green (2001), Kuhns et al. (1999), Pitchford et al. (2000). Data Needed: Concentrations of a unique tracer from a source of interest and simultaneous concentrations of a pollutant of interest at several sites in a region. Model Assumptions: There is no impact from the tagged source if the tracer concentration is less than the level considered to be “significantly” above its’ background. Background concentrations of the species of interest do not vary systematically in space. Biggest Potential Problems: Assuming no impact from the tagged source when tracer is not statistically above background can lead to an underestimation of attribution. Measured tracer concentrations often have large uncertainties. Some sampling periods will have a negative concentration attributed to the tagged source. References: Ashbaugh, Lowell L., William C. Malm, Willy Z. Sadeh (1985) “A Residence Time Probability Analysis of Sulfur Concentrations at Grand Canyon National Park,” Atmospheric Environment, 19, 1263-1270. Gebhart, Kristi A., Sonia A. Kreidenweiss, and William C. Malm (2001) “Back-Trajectory Analyses of Fine Particulate Matter Measured at Big Bend National Park in the Historical Database and the 1996 Scoping Study” Science of the Total Environment, 276, 185-204. Gebhart, Kristi A. and William C. Malm (1989) “Source Apportionment of Particulate Sulfate Concentrations at Three National Parks in the Eastern United States,” in Transactions of the A&WMA/EPA Specialty Conference-Visibility and Fine Particles, Estes Park, CO, Oct. 15-19, 1989, pp. 898-913, C.V. Mathai, Ed. Gebhart, Kristi A. and William C. Malm (1997) “Spatial and Temporal Patterns in Particle Data Measured during the MOHAVE Study,” J. of the Air & Waste Management Assoc., 47, 119-135 Green, Mark, 2001 (Informal paper, BRAVO) 70 Henry, R.S. (1997a) “History and fundamentals of multivariate air quality receptor models,” Chemometrics and Intelligent Laboratory Systems, 37, 37-42. Henry, R.C. (1997b) “Receptor Model Applied to Patterns in Space (RMAPS) Part I – Model Description” JA&WMA, 47, 216-219. Henry, R.C. (1997c) “Receptor Model Applied to Patterns in Space (RMAPS) Part II – Apportionment of Airborne Particulate Sulfur from Project MOHAVE” JA&WMA, 47, 220-225. Henry, R.C. (1997d) “Receptor Model Applied to Patterns in Space (RMAPS) Part III – Apportionment of Airborne Particulate Sulfur Western Washington State” JA&WMA, 47, 226-230. Henry, R.C. (1999) “Comparing a new algorithm with the classic methods for estimating the number of factors,” Chemometrics and Intelligent Laboratory Systems, 48, 91-97. Lewis, C.W., R.C. Henry, and J.H. Shreffler (1998) “An Exploratory Look at Hydrocarbon Data from the Photochemical Assessment Monitoring Stations Network” J. Air & Waste Management Assoc. 48, 71-76. Henry, Ronald C., Yi-Jin Wang, and Kristi A. Gebhart (1991) “The Relationship Between Empirical Orthogonal Functions and Sources of Air Pollution,” Atmospheric Environment, 25A, 503-509. Kuhns et al. (1999) Lawson, D.R. and J.W. Winchester (1979) “A Standard crustal aerosol as a reference for elemental enrichment factors,” Atmospheric Environment, 13, 517-523. Malm, William C, Hari K. Iyer, and Kristi Gebhart (1989a) “Application of Tracer Mass Balance Regression to WHITEX Data” in Transactions of the A&WMA/EPA Specialty Conference: Visibility and Fine Particles, Estes Park, CO, Oct. 15-19, 1989, pp. 806-818, C.V. Mathai, Ed. Malm, William C., Hari K. Iyer, John Watson, and Douglas A. Latimer (1989b) “Survey of a Variety of Receptor Modeling Techniques,” Transactions of the A&WMA/EPA Specialty Conference-Visibility & Fine Particles, Estes Park, CO, Oct. 15-19, 1989, pp. 781-805, C.V. Mathai, Ed. Malm, William, Kristi Gebhart, Douglas Latimer, Thomas Cahill, Robert Eldred, Roger Pielke, Roger Stocker, and John Watson (1989) “National Park Service Report On the Winter Haze Intensive Tracer Experiment” National Park Service, Air Quality Division, Research Branch, Fort Collins, CO, Dec. 4, 1989 71 Malm, William C. and Kristi A. Gebhart (1997) “Source apportionment of sulfur and light extinction using receptor modeling techniques,” Journal of the Air & Waste Management Association, 47, 250-258. Malm, William C., Kristi A. Gebhart, and Ronald C. Henry (1990) “An Investigation of the Dominant Source Regions of Fine Sulfur in the Western United States and their Areas of Influence,” Atmospheric Environment, 24A, 3047-3060. Paatero, P. (1997) “Least squares formulation of robust non-negative factor analysis,” Chemometrics and Intelligent Laboratory Systems, 37, 15-35. Paatero, P. and U. Tapper (1994) “Positive Matrix Factorization – a Nonnegative Factor Model with Optimal Utilization of Error-Estimates of Data Values,” Environmetrics, 5, 111-126. Parekh, P.P., B. Ghauri, and L. Husain (1989) “Identification of Pollution Sources of Anomalously Enriched Elements,” Atmospheric Environment, 23, 1435-1442. Perru, K.D., T.A. Cahill, R.A. Eldred, and D.D. Dutcher (1997) “Long-range Transport of North African dust to the eastern United States,” J. Geophys. Res., 102, 11,225-11,238. Pitchford, Marc, Mark Green, Hampden Kuhns, and Robert J. Farber (2000) “Characterization of Regional Transport and Dispersion Using Project MOHAVE Tracer Data” J. Air & Waste Manage. Assoc. 50: 733-745. (This is not exactly TAGIT, but the 1999 reference may be a conference paper.) Poirot, Richard L. and Paul R. Wishinski (1986) “Visibility, Sulfate and Air Mass history Associated with the Summertime Aerosol in Northern Vermont,” Atmospheric Environment, 20, 1457-1469. Roshid, M. and R.F. Griffiths (1993) “Ambient K, S, and Si in fine and coarse aerosols of Kuala Lumpur, Malaysia,” Journal of Aerosol Science, 24, 597-601. Stohl, A. (1998) “Computation, Accuracy and Applications of Trajectories - A Review and Bibliography,” Atmospheric Environment, 32, 947-966. Watson, John G., John A. Cooper, and James J. Huntzicker (1984) “The Effective Variance Weighting for Least Squares Calculations Applied to the Mass Balance Receptor Model,” Atmospheric Environment, 18, 1347-1355. Watson, John G., Judith C. Chow and Eric M. Fujita (2001) “Review of volatile organic compound source apportionment by chemical mass balance” Atmospheric Environment, 35, 1567-1584. White, Warren H. (1999) “Phantom Spatial Factors: An Example,” J. of the Air & Waste Management Assoc., 49, 345-349. 72 Xie, Yu-Long, Philip K. Hopke, Pentti Paatero, Leonard A. Barrie, and Shao-Meng Li (1999) “Identification of Source Nature and Seasonal Variations of Arctic Aerosol by Positive Matrix Factorization,” J. of the Atmospheric Sciences, 56, 249-260. 73 74 Table 5. Observational Modeling Techniques Analyses of Back Trajectories Criteria Residence Time & Source Contribution Function Conditional Probability Quantitative Source Attribution? Number of sources that can be distinguished? No Typically only about 10 or fewer transport patterns are distinguishable No Maximum of 10-15 Averaging Time of Result? Weeks to years Weeks to years Concentration Statistics by Air Mass History (Mean, Max, Median) No 1/grid cell, typically 50x50 (2500), though usually only about 5-20 transport patterns are distinguishable Weeks to years Previous use at Class I Areas? (See Text for References) Magnitude of impacts? Frequency of impacts? Duration of impacts? Time of Day of impacts? Time of Year of impacts? Appropriate for what source-receptor distances? Yes No Yes Yes Depends on particle data Yes Regional Scale Yes No No No Depends on particle data Yes Regional Scale Yes Yes No No Depends on particle data Yes Regional Scale Yes No Yes Yes Depends on particle data Yes Regional Scale Attribution of Secondary Species? Cost to run? Yes Minimal Yes Minimal Yes Minimal Code Available? Equations and/or algorithms available? No Yes No Yes Computer Hardware Needed Additional software necessary? PC Any programming language or statistical package and graphics and/or mapping software that allows overlay of data on a map EPA Approved Model? No Cluster Analysis Hit – No Hit Trajectory Mass Balance No 2-15 No 1 Yes 20-30 max Weeks to years Daily, possibly hourly Yes No Yes Yes Yes Months to years Yes Yes Yes Yes Depends on particle data Yes Regional Scale Yes Minimal Yes Regional Scale Yes Minimal No Yes No Yes No None needed No Yes PC Any programming language or statistical package and graphics and/or mapping software that allows overlay of data on a map PC Any programming language or statistical package and graphics and/or mapping software that allows overlay of data on a map PC Graphing or mapping software that allows overlay of data on a map PC Any programming language or statistical package and graphics and/or mapping software that allows overlay of data on a map No No PC Any programming language or statistical package and graphics and/or mapping software that allows overlay of data on a map No No No 75 Yes Minimal Observational Modeling Techniques(continued) Analyses of inter-species relationships Criteria Quantitative Source Attribution? Number of sources that can be distinguished? Averaging Time of Result? CMB Yes Usually < 10 Same as monitoring data Yes PMF Yes Usually < 10 Same as monitoring data No? Yes Yes Yes Depends on input data Yes Urban to regional scales With additional information Free to purchase, minimal to run Yes Yes Yes Depends on input data Yes Urban to regional scales With additional information $700 to purchase, minimal to run Code Available? Equations and/or algorithms available? Computer Hardware Needed Additional software necessary? Yes Yes PC No Yes Yes PC No EPA Model? Yes No? Previous use at Class I Areas? (See Text for References) Magnitude of impacts? Frequency of impacts? Duration of impacts? Time of Day of impacts? Time of Year of impacts? Appropriate for what source-receptor distances? Attribution of Secondary Species? Cost to run? UNMIX Yes 7 Analyses of Spatial and Temporal Patterns Factor Analysis No < Number of species analyzed EOF No Usually 4-8 transport patterns Same as monitoring data RMAPS Yes Usually 4-8 transport patterns Same as monitoring data No? Yes Yes Yes Yes Yes Yes Depends on input data Yes Urban to regional scales No Yes No Depends on input data Yes Urban to regional scales No Yes Yes Depends on input data Yes Regional Scale Yes Yes Yes Depends on input data With additional information Yes Yes Yes Currently free to purchase, minimal to run, $100 (student)1500 (full) for MATLAB Yes Yes PC MATLAB with optimization toolbox Minimal Minimal Minimal No Yes PC Any statistics package No Yes PC Any statistics package with ability to do singular value decompositions No No Yes PC Any statistics package with ability to do singular value decompositions Same as monitoring data Yes? 76 No Yes Regional Scale No Observational Modeling Techniques (continued) Analyses of Unique Tracer Data Criteria Quantitative Source Attribution? Number of sources that can be distinguished? Averaging Time of Result? Previous use at Class I Areas? (See Text for References) Magnitude of impacts? Frequency of impacts? Duration of impacts? Time of Day of impacts? Time of Year of impacts? Appropriate for what source-receptor distances? Attribution of Secondary Species? Cost to run? Code Available? Equations and/or algorithms available? Computer Hardware Needed Additional software necessary? EPA Model? TMBR DMB TAGIT Yes 1-3 Yes 1-3 Yes 1/tracer Same as particulate data Yes Same as particulate data Yes Yes Yes Yes Depends on particulate data Yes Urban to Regional Scale Yes Minimal No Yes Yes Yes Yes Depends on particulate data Yes Yes Yes Depends on particulate data Yes Urban to Regional Scale Yes Minimal No Yes PC Any programming language, spreadsheet, or statistical package No 77 PC Any programming language, spreadsheet, or statistical package No Yes Yes Regional Scale Yes Minimal No Yes PC Any programming language, spreadsheet, or statistical package No Appendix A: RA BART Rule (40 CFR 51.300-306) Sec. 51.300 Purpose and applicability. Authority: Secs. 110, 114, 121, 160-169, 169A, and 301 of the Clean Air Act, (42 U.S.C. 7410, 7414, 7421, 7470-7479, and 7601). Source: 45 FR 80089, Dec. 2, 1980, unless otherwise noted. (a) Purpose. The primary purposes of this subpart are to require States to develop programs to assure reasonable progress toward meeting the national goal of preventing any future, and remedying any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from manmade air pollution; and to establish necessary additional procedures for new source permit applicants, States and Federal Land Managers to use in conducting the visibility impact analysis required for new sources under Sec. 51.166. This subpart sets forth requirements addressing visibility impairment in its two principal forms: ``reasonably attributable'' impairment (i.e., impairment attributable to a single source/small group of sources) and regional haze (i.e., widespread haze from a multitude of sources which impairs visibility in every direction over a large area). (b) Applicability. (1) General Applicability. The provisions of this subpart pertaining to implementation plan requirements for assuring reasonable progress in preventing any future and remedying any existing visibility impairment are applicable to: (i) Each State which has a mandatory Class I Federal area identified in part 81, subpart D, of this title, and Each State in which there is any source the emissions from which may reasonably be anticipated to cause or contribute to any impairment of visibility in any such area. (ii)The provisions of this subpart pertaining to implementation plans to address reasonably attributable visibility impairment are applicable to the following States: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Florida, Georgia, Hawaii, Idaho, Kentucky, Louisiana, Maine, Michigan, Minnesota, Missouri, Montana, Nevada, New Hampshire, New Jersey, New Mexico, North Carolina, North Dakota, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Virgin Islands, Washington, West Virginia, Wyoming. (3) The provisions of this subpart pertaining to implementation plans to address regional haze visibility impairment are applicable to all States as defined in section 302(d) of the Clean Air Act (CAA) except Guam, Puerto Rico, American Samoa, and the Northern Mariana Islands. [45 FR 80089, Dec. 2, 1980, as amended at 64 FR 35763, July 1, 1999] Sec. 51.301 Definitions. For purposes of this subpart: Adverse impact on visibility means, for purposes of section 307, visibility impairment which interferes with the management, protection, preservation, or enjoyment of the visitor's visual experience of the Federal Class I area. This determination must be made on a case-by-case basis taking into account the geographic extent, intensity, duration, frequency and time of visibility impairments, and how these factors correlate with (1) times of visitor use of the Federal Class I area, and (2) the frequency and timing of natural conditions that reduce visibility. This term does not include effects on integral vistas. Agency means the U.S. Environmental Protection Agency. BART-eligible source means an existing stationary facility as defined in this section. Best Available Retrofit Technology (BART) means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant which is emitted by an existing stationary facility. The emission limitation must be established, on a case-by-case basis, taking into consideration the technology available, the costs of compliance, the energy and nonair quality environmental impacts of compliance, any pollution control equipment in use or in existence at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology. Building, structure, or facility means all of the pollutant-emitting activities which belong to the same industrial grouping, are located on one or more contiguous or adjacent properties, and are under the control of the same person (or persons under common control). Pollutant-emitting activities must be considered as part of the same industrial grouping if they belong to the same Major Group (i.e., which have the same two-digit code) as described in the Standard Industrial Classification Manual, 1972 as amended by the 1977 Supplement (U.S. Government Printing Office stock numbers 4101-0066 and 003-005-00176-0 respectively). Deciview means a measurement of visibility impairment. A deciview is a haze index derived from calculated light extinction, such that uniform changes in haziness correspond to uniform incremental changes in perception across the entire range of conditions, from pristine to highly impaired. The deciview haze index is calculated based on the following equation (for the purposes of calculating deciview, the atmospheric light extinction coefficient must be calculated from aerosol measurements): Deciview haze index = 10 lne (bext/10Mm-1) Where bext = the atmospheric light extinction coefficient, expressed in inverse megameters (Mm-1). Existing stationary facility means any of the following stationary sources of air pollutants, including any reconstructed source, which was not in operation prior to August 7, 1962, and was in existence on August 7, 1977, and has the potential to emit 250 tons per year or more of any air pollutant. In determining potential to emit, fugitive emissions, to the extent quantifiable, must be counted. Fossil-fuel fired steam electric plants of more than 250 million British thermal units per hour heat input, Coal cleaning plants (thermal dryers), Kraft pulp mills, Portland cement plants, Primary zinc smelters, Iron and steel mill plants, Primary aluminum ore reduction plants, Primary copper smelters, Municipal incinerators capable of charging more than 250 tons of refuse per day, Hydrofluoric, sulfuric, and nitric acid plants, Petroleum refineries, Lime plants, Phosphate rock processing plants, Coke oven batteries, Sulfur recovery plants, Carbon black plants (furnace process), Primary lead smelters, Fuel conversion plants, Sintering plants, Secondary metal production facilities, Chemical process plants, Fossil-fuel boilers of more than 250 million British thermal units per hour heat input, Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, Taconite ore processing facilities, Glass fiber processing plants, and Charcoal production facilities. Federal Class I area means any Federal land that is classified or reclassified Class I. Federal Land Manager means the Secretary of the department with authority over the Federal Class I area (or the Secretary's designee) or, with respect to Roosevelt-Campobello International Park, the Chairman of the Roosevelt-Campobello International Park Commission. Federally enforceable means all limitations and conditions which are enforceable by the Administrator under the Clean Air Act including those requirements developed pursuant to parts 60 and 61 of this title, requirements within any applicable State Implementation Plan, and any permit requirements established pursuant to Sec. 52.21 of this chapter or under regulations approved pursuant to part 51, 52, or 60 of this title. Fixed capital cost means the capital needed to provide all of the depreciable components. Fugitive Emissions means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening. Geographic enhancement for the purpose of Sec. 51.308 means a method, procedure, or process to allow a broad regional strategy, such as an emissions trading program designed to achieve greater reasonable progress than BART for regional haze, to accommodate BART for reasonably attributable impairment. Implementation plan means, for the purposes of this part, any State Implementation Plan, Federal Implementation Plan, or Tribal Implementation Plan. Indian tribe or tribe means any Indian tribe, band, nation, or other organized group or community, including any Alaska Native village, which is federally recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians. In existence means that the owner or operator has obtained all necessary preconstruction approvals or permits required by Federal, State, or local air pollution emissions and air quality laws or regulations and either has (1) begun, or caused to begin, a continuous program of physical on-site construction of the facility or (2) entered into binding agreements or contractual obligations, which cannot be cancelled or modified without substantial loss to the owner or operator, to undertake a program of construction of the facility to be completed in a reasonable time. In operation means engaged in activity related to the primary design function of the source. Installation means an identifiable piece of process equipment. Integral vista means a view perceived from within the mandatory Class I Federal area of a specific landmark or panorama located outside the boundary of the mandatory Class I Federal area. Least impaired days means the average visibility impairment (measured in deciviews) for the twenty percent of monitored days in a calendar year with the lowest amount of visibility impairment. Major stationary source and major modification mean major stationary source and major modification, respectively, as defined in Sec. 51.166. Mandatory Class I Federal Area means any area identified in part 81, subpart D of this title. Most impaired days means the average visibility impairment (measured in deciviews) for the twenty percent of monitored days in a calendar year with the highest amount of visibility impairment. Natural conditions includes naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration. Potential to emit means the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable. Secondary emissions do not count in determining the potential to emit of a stationary source. Reasonably attributable means attributable by visual observation or any other technique the State deems appropriate. Reasonably attributable visibility impairment means visibility impairment that is caused by the emission of air pollutants from one, or a small number of sources. Reconstruction will be presumed to have taken place where the fixed capital cost of the new component exceeds 50 percent of the fixed capital cost of a comparable entirely new source. Any final decision as to whether reconstruction has occurred must be made in accordance with the provisions of Sec. 60.15 (f) (1) through (3) of this title. Regional haze means visibility impairment that is caused by the emission of air pollutants from numerous sources located over a wide geographic area. Such sources include, but are not limited to, major and minor stationary sources, mobile sources, and area sources. Secondary emissions means emissions which occur as a result of the construction or operation of an existing stationary facility but do not come from the existing stationary facility. Secondary emissions may include, but are not limited to, emissions from ships or trains coming to or from the existing stationary facility. Significant impairment means, for purposes of Sec. 51.303, visibility impairment which, in the judgment of the Administrator, interferes with the management, protection, preservation, or enjoyment of the visitor's visual experience of the mandatory Class I Federal area. This determination must be made on a case-by-case basis taking into account the geographic extent, intensity, duration, frequency and time of the visibility impairment, and how these factors correlate with (1) times of visitor use of the mandatory Class I Federal area, and (2) the frequency and timing of natural conditions that reduce visibility. State means ``State'' as defined in section 302(d) of the CAA. Stationary Source means any building, structure, facility, or installation which emits or may emit any air pollutant. Visibility impairment means any humanly perceptible change in visibility (light extinction, visual range, contrast, coloration) from that which would have existed under natural conditions. Visibility in any mandatory Class I Federal area includes any integral vista associated with that area. [45 FR 80089, Dec. 2, 1980, as amended at 64 FR 35763, 35774, July 1, 1999] Sec. 51.302 Implementation control strategies for reasonably attributable visibility impairment. (a) Plan Revision Procedures. (1) Each State identified in Sec. 51.300(b)(2) must have submitted, not later than September 2, 1981, an implementation plan meeting the requirements of this subpart pertaining to reasonably attributable visibility impairment. (2)(i) The State, prior to adoption of any implementation plan to address reasonably attributable visibility impairment required by this subpart, must conduct one or more public hearings on such plan in accordance with Sec. 51.102. (ii) In addition to the requirements in Sec. 51.102, the State must provide written notification of such hearings to each affected Federal Land Manager, and other affected States, and must state where the public can inspect a summary prepared by the Federal Land Managers of their conclusions and recommendations, if any, on the proposed plan revision. (3) Submission of plans as required by this subpart must be conducted in accordance with the procedures in Sec. 51.103. (b) State and Federal Land Manager Coordination. (1) The State must identify to the Federal Land Managers, in writing and within 30 days of the date of promulgation of these regulations, the title of the official to which the Federal Land Manager of any mandatory Class I Federal area can submit a recommendation on the implementation of this subpart including, but not limited to: (i) A list of integral vistas that are to be listed by the State for the purpose of implementing section 304, (ii) Identification of impairment of visibility in any mandatory Class I Federal area(s), and (iii) Identification of elements for inclusion in the visibility monitoring strategy required by section 305. (2) The State must provide opportunity for consultation, in person and at least 60 days prior to holding any public hearing on the plan, with the Federal Land Manager on the proposed SIP revision required by this subpart. This consultation must include the opportunity for the affected Federal Land Managers to discuss their: (i) Assessment of impairment of visibility in any mandatory Class I Federal area, and (ii) Recommendations on the development of the long-term strategy. (3) The plan must provide procedures for continuing consultation between the State and Federal Land Manager on the implementation of the visibility protection program required by this subpart. (c) General plan requirements for reasonably attributable visibility impairment. (1) The affected Federal Land Manager may certify to the State, at any time, that there exists reasonably attributable impairment of visibility in any mandatory Class I Federal area. (2) The plan must contain the following to address reasonably attributable impairment: (i) A long-term (10-15 years) strategy, as specified in Sec. 51.305 and Sec. 51.306, including such emission limitations, schedules of compliance, and such other measures including schedules for the implementation of the elements of the long-term strategy as may be necessary to make reasonable progress toward the national goal specified in Sec. 51.300(a). (ii) An assessment of visibility impairment and a discussion of how each element of the plan relates to the preventing of future or remedying of existing impairment of visibility in any mandatory Class I Federal area within the State. (iii) Emission limitations representing BART and schedules for compliance with BART for each existing stationary facility identified according to paragraph (c)(4) of this section. (3) The plan must require each source to maintain control equipment required by this subpart and establish procedures to ensure such control equipment is properly operated and maintained. (4) For any existing reasonably attributable visibility impairment the Federal Land Manager certifies to the State under paragraph (c)(1) of this section, at least 6 months prior to plan submission or revision: (i) The State must identify and analyze for BART each existing stationary facility which may reasonably be anticipated to cause or contribute to impairment of visibility in any mandatory Class I Federal area where the impairment in the mandatory Class I Federal area is reasonably attributable to that existing stationary facility. The State need not consider any integral vista the Federal Land Manager did not identify pursuant to Sec. 51.304(b) at least 6 months before plan submission. (ii) If the State determines that technologicial or economic limitations on the applicability of measurement methodology to a particular existing stationary facility would make the imposition of an emission standard infeasible it may instead prescribe a design, equipment, work practice, or other operational standard, or combination thereof, to require the application of BART. Such standard, to the degree possible, is to set forth the emission reduction to be achieved by implementation of such design, equipment, work practice or operation, and must provide for compliance by means which achieve equivalent results. (iii) BART must be determined for fossil-fuel fired generating plants having a total generating capacity in excess of 750 megawatts pursuant to ``Guidelines for Determining Best Available Retrofit Technology for Coal-fired Power Plants and Other Existing Stationary Facilities'' (1980), which is incorporated by reference, exclusive of appendix E, which was published in the Federal Register on February 6, 1980 (45 FR 8210). It is EPA publication No. 450/3-80-009b and is for sale from the U.S. Department of Commerce, National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22161. It is also available for inspection at the Office of the Federal Register Information Center, 800 North Capitol NW., suite 700, Washington, DC. (iv) The plan must require that each existing stationary facility required to install and operate BART do so as expeditiously as practicable but in no case later than five years after plan approval. (v) The plan must provide for a BART analysis of any existing stationary facility that might cause or contribute to impairment of visibility in any mandatory Class I Federal area identified under this paragraph (c)(4) at such times, as determined by the Administrator, as new technology for control of the pollutant becomes reasonably available if: (A) The pollutant is emitted by that existing stationary facility, (B) Controls representing BART for the pollutant have not previously been required under this subpart, and (C) The impairment of visibility in any mandatory Class I Federal area is reasonably attributable to the emissions of that pollutant. [45 FR 80089, Dec. 2, 1980, as amended at 57 FR 40042, Sept. 1, 1992; 64 FR 35764, 35774, July 1, 1999] Sec. 51.303 Exemptions from control. (a)(1) Any existing stationary facility subject to the requirement under Sec. 51.302 to install, operate, and maintain BART may apply to the Administrator for an exemption from that requirement. (2) An application under this section must include all available documentation relevant to the impact of the source's emissions on visibility in any mandatory Class I Federal area and a demonstration by the existing stationary facility that it does not or will not, by itself or in combination with other sources, emit any air pollutant which may be reasonably anticipated to cause or contribute to a significant impairment of visibility in any mandatory Class I Federal area. (b) Any fossil-fuel fired power plant with a total generating capacity of 750 megawatts or more may receive an exemption from BART only if the owner or operator of such power plant demonstrates to the satisfaction of the Administrator that such power plant is located at such a distance from all mandatory Class I Federal areas that such power plant does not or will not, by itself or in combination with other sources, emit any air pollutant which may reasonably be anticipated to cause or contribute to significant impairment of visibility in any such mandatory Class I Federal area. (c) Application under this Sec. 51.303 must be accompanied by a written concurrence from the State with regulatory authority over the source. (d) The existing stationary facility must give prior written notice to all affected Federal Land Managers of any application for exemption under this Sec. 51.303. (e) The Federal Land Manager may provide an initial recommendation or comment on the disposition of such application. Such recommendation, where provided, must be part of the exemption application. This recommendation is not to be construed as the concurrence required under paragraph (h) of this section. (f) The Administrator, within 90 days of receipt of an application for exemption from control, will provide notice of receipt of an exemption application and notice of opportunity for public hearing on the application. (g) After notice and opportunity for public hearing, the Administrator may grant or deny the exemption. For purposes of judicial review, final EPA action on an application for an exemption under this Sec. 51.303 will not occur until EPA approves or disapproves the State Implementation Plan revision. (h) An exemption granted by the Administrator under this Sec. 51.303 will be effective only upon concurrence by all affected Federal Land Managers with the Administrator's determination. [45 FR 80089, Dec. 2, 1980, as amended by 64 FR 35774, July 1, 1999] Sec. 51.304 Identification of integral vistas. (a) On or before December 31, 1985 the Federal Land Manager may identify any integral vista. The integral vista must be identified according to criteria the Federal Land Manager develops. These criteria must include, but are not limited to, whether the integral vista is important to the visitor's visual experience of the mandatory Class I Federal area. Adoption of criteria must be preceded by reasonable notice and opportunity for public comment on the proposed criteria. (b) The Federal Land Manager must notify the State of any integral vistas identified under paragraph (a) of this section, and the reasons therefor. (c) The State must list in its implementation plan any integral vista the Federal Land Manager identifies at least six months prior to plan submission, and must list in its implementation plan at its earliest opportunity, and in no case later than at the time of the periodic review of the SIP required by Sec. 51.306(c), any integral vista the Federal Land Manager identifies after that time. (d) The State need not in its implementation plan list any integral vista the identification of which was not made in accordance with the criteria in paragraph (a) of this section. In making this finding, the State must carefully consider the expertise of the Federal Land Manager in making the judgments called for by the criteria for identification. Where the State and the Federal Land Manager disagree on the identification of any integral vista, the State must give the Federal Land Manager an opportunity to consult with the Governor of the State. [45 FR 80089, Dec. 2, 1980, as amended by 64 FR 35774, July 1, 1999] Sec. 51.305 Monitoring for reasonably attributable visibility impairment. (a) For the purposes of addressing reasonably attributable visibility impairment, each State containing a mandatory Class I Federal area must include in the plan a strategy for evaluating reasonably attributable visibility impairment in any mandatory Class I Federal area by visual observation or other appropriate monitoring techniques. Such strategy must take into account current and anticipated visibility monitoring research, the availability of appropriate monitoring techniques, and such guidance as is provided by the Agency. (b) The plan must provide for the consideration of available visibility data and must provide a mechanism for its use in decisions required by this subpart. [45 FR 80089, Dec. 2, 1980, as amended at 64 FR 35764, July 1, 1999] Sec. 51.306 Long-term strategy requirements for reasonably attributable visibility impairment. (a)(1) For the purposes of addressing reasonably attributable visibility impairment, each plan must include a long-term (10-15 years) strategy for making reasonable progress toward the national goal specified in Sec. 51.300(a). This strategy must cover any existing impairment the Federal Land Manager certifies to the State at least 6 months prior to plan submission, and any integral vista of which the Federal Land Manager notifies the State at least 6 months prior to plan submission. (2) A long-term strategy must be developed for each mandatory Class I Federal area located within the State and each mandatory Class I Federal area located outside the State which may be affected by sources within the State. This does not preclude the development of a single comprehensive plan for all such areas. (3) The plan must set forth with reasonable specificity why the long-term strategy is adequate for making reasonable progress toward the national visibility goal, including remedying existing and preventing future impairment. (b) The State must coordinate its long-term strategy for an area with existing plans and goals, including those provided by the affected Federal Land Managers, that may affect impairment of visibility in any mandatory Class I Federal area. (c) The plan must provide for periodic review and revision, as appropriate, of the long-term strategy for addressing reasonably attributable visibility impairment. The plan must provide for such periodic review and revision not less frequently than every 3 years until the date of submission of the State's first plan addressing regional haze visibility impairment in accordance with Sec. 51.308(b) and (c). On or before this date, the State must revise its plan to provide for review and revision of a coordinated long-term strategy for addressing reasonably attributable and regional haze visibility impairment, and the State must submit the first such coordinated long-term strategy. Future coordinated long-term strategies must be submitted consistent with the schedule for periodic progress reports set forth in Sec. 51.308(g). Until the State revises its plan to meet this requirement, the State must continue to comply with existing requirements for plan review and revision, and with all emission management requirements in the plan to address reasonably attributable impairment. This requirement does not affect any preexisting deadlines for State submittal of a long-term strategy review (or element thereof) between August 30, 1999, and the date required for submission of the State's first regional haze plan. In addition, the plan must provide for review of the long-term strategy as it applies to reasonably attributable impairment, and revision as appropriate, within 3 years of State receipt of any certification of reasonably attributable impairment from a Federal Land Manager. The review process must include consultation with the appropriate Federal Land Managers, and the State must provide a report to the public and the Administrator on progress toward the national goal. This report must include an assessment of: (1) The progress achieved in remedying existing impairment of visibility in any mandatory Class I Federal area; (2) The ability of the long-term strategy to prevent future impairment of visibility in any mandatory Class I Federal area; (3) Any change in visibility since the last such report, or, in the case of the first report, since plan approval; (4) Additional measures, including the need for SIP revisions, that may be necessary to assure reasonable progress toward the national visibility goal; (5) The progress achieved in implementing BART and meeting other schedules set forth in the long-term strategy; (6) The impact of any exemption granted under Sec. 51.303; (7) The need for BART to remedy existing visibility impairment of any integral vista listed in the plan since the last such report, or, in the case of the first report, since plan approval. (d) The long-term strategy must provide for review of the impacts from any new major stationary source or major modifications on visibility in any mandatory Class I Federal area. This review of major stationary sources or major modifications must be in accordance with Sec. 51.307, Sec. 51.166, Sec. 51.160, and any other binding guidance provided by the Agency insofar as these provisions pertain to protection of visibility in any mandatory Class I Federal areas. (e) The State must consider, at a minimum, the following factors during the development of its long-term strategy: (1) Emission reductions due to ongoing air pollution control programs, (2) Additional emission limitations and schedules for compliance, (3) Measures to mitigate the impacts of construction activities, (4) Source retirement and replacement schedules, (5) Smoke management techniques for agricultural and forestry management purposes including such plans as currently exist within the State for these purposes, and (6) Enforceability of emission limitations and control measures. (f) The plan must discuss the reasons why the above and other reasonable measures considered in the development of the long-term strategy were or were not adopted as part of the long-term strategy. (g) The State, in developing the long-term strategy, must take into account the effect of new sources, and the costs of compliance, the time necessary for compliance, the energy and nonair quality environmental impacts of compliance, and the remaining useful life of any affected existing source and equipment therein. [45 FR 80089, Dec. 2, 1980, as amended at 64 FR 35764, 35774, July 1, 1999] APPENDIX A-9. MOBILE SOURCES This appendix contains work products and references relied upon by Arizona in the development of Chapter 9 of the Regional Haze SIP. Appendix A-9 – Mobile Sources Arizona Regional Haze SIP Appendix A-9a. Arizona Mobile Source Work Group Findings and Recommendations Related to Mobile Source Emissions Appendix A-9 – Mobile Sources Arizona Regional Haze SIP Arizona Regional Haze Mobile Source Working Group Mobile Source Significance Determination INTRODUCTION Statement of Purpose This report presents the findings of the Mobile Source Working Group (MSWG) regarding the significance of Arizona mobile source emissions on the visibility impairment for the 16 Class I areas on the Colorado Plateau. The other Class I areas within the State will not be addressed here but will be addressed under Section 309(g) of the Regional Haze Rule (RHR) later. The MSWG’s analysis was based on the regulatory requirements in 40 CFR 51.309(d)(5)(i-iii), the Grand Canyon Visibility Transport Commission (GCVTC) report that formed the basis for those regulations, and information from the Western Regional Air Partnership (WRAP). The MSWG provides this report to the Arizona Department of Environmental Quality (ADEQ) for their consideration in preparing the Arizona Regional Haze State Implementation Plan (SIP). Summary of Findings Based on the analysis of available data, the MSWG finds that mobile source emissions in Arizona do not significantly contribute to visibility impairment in any of the 16 GCVTC Class I areas on the Colorado Plateau. In reaching that conclusion, the MSWG analyzed mobile source pollutant emissions data of volatile organic compounds (VOC), oxides of nitrogen (NOX), sulfur dioxide (SO2), elemental carbon (EC), organic carbon (OC), and fine particulates (PM2.5) for the years 2003 to 2018; air quality modeling and other technical information available from the WRAP; their approach in making the significance determination for the region, and the Environmental Protection Agency (EPA) current and future programs and their potential benefits. This conclusion is based upon the findings listed below, and explained in this report. 1) Mobile source emissions of VOC, NOx, PM2.5, SO2, EC, and OC will decline from 2003 to 2018. 2) Year to year mobile source emissions of VOC, NOx PM2.5, EC, and OC are expected to decline from 2003 to 2018. 3) Annual mobile source emissions of SO2 are expected to decline from 2003 to 2013 with a slight increase from 2013 to 2018 with proposed federal standards for non-road equipment and diesel fuel. The minor increase is uncertain and cannot be accurately quantified and will be further addressed in the Technical Support Document (TSD). In the event that the EPA proposed non-road standards are not adopted, Arizona will be required to submit a SIP revision as proposed by the WRAP, in their letter dated May 6, 2003 to ensure reasonable progress prior to December 31, 2008. 4) Annual mobile source emissions of VOC, NOx PM2.5, EC, and OC are expected to have a minimal impact on visibility. 5) Reasonable progress will be achieved over the planning period with the projected emission reductions. 6) The relative contribution of mobile source SO2 emissions is insignificant compared to that of the emissions from stationary sources. 7) There is considerable uncertainty in regulations and projections of emissions. The projected increase in SO2 for the later part of the planning period is not certain. By 2008, the emissions for 2013 can be better assessed with some certainty. REGULATORY REQUIREMENT Regional Haze Rule The federal RHR relies upon the GCVTC report as the basis for states to submit a SIP under 40 CFR 51.309(d)(5). Section 309 of the RHR requires states to evaluate mobile source emissions, and if they are determined to significantly contribute to regional haze in the 16 Class I areas, then additional provisions apply. SIPs developed under Section 309 must include the following elements: • A statewide inventory of current mobile source emissions and projected future emissions of VOC, NOX, SO2, PM2.5, EC, and OC, for the years 2003 to 2018. The emissions inventory must also include projections for 2005, or an alternative year when the mobile source emissions are found to be at their lowest levels (40 CFR 51.309(d)(5)(i)). • A determination of whether mobile source emissions from any areas in the state “contribute significantly” to visibility impairment at any of the 16 Class I areas (40 CFR 51.309(d)(5)(ii)). • If any area of the state is found to contribute significantly to visibility impairment at any of those 16 Class I areas, the SIP must also include: 2 o An emission budget (cap) and measures to ensure that emissions do not increase beyond their lowest projected levels for the planning period (40 CFR 51.309(d)(5)(iii)(A)). o An emission tracking system to ensure that mobile source emissions do not increase thereafter (40 CFR 51.309(d)(5)(iii)(B)). • Progress reports to EPA on the implementation of mobile source recommendations of the GCVTC (40 CFR 51.309(d)(5)(iv). In the event that EPA finalizes the rule change as proposed, 51.309(d)(5)(ii) and (iii) above will then be removed (see below). WRAP APPROACH TO SIGNIFICANCE DETERMINATION Recently, the WRAP concluded that the attempt to measure mobile source significance is no longer necessary because new federal programs will achieve continual emission reductions as required for significant areas in Section 309(d)(5)(iii). On May 6, 2003, the WRAP submitted a letter to EPA proposing amendments to the RHR to eliminate the requirement to conduct the mobile source significance determination, and to address non-road mobile sources of SO2. The WRAP letter is provided in Attachment A. The EPA has published these changes to the rule (Federal Register Vol.68, No. 128, July 3, 2003), along with a 30-day comment period. EPA has proposed a direct final for the rule. Even if the rule is challenged it still could be finalized by the end of the year. Proposed WRAP Amendments: Significance Requirements The GCVTC and the final RHR assumed that mobile sources were expected to decline from 2003-2005 and increase annually through 2018. As noted above, the rule required emission budgets in “significant” areas to prevent the increase in emissions. That goal is being achieved without emission caps because of new federal programs: Tier 1 gasoline sulfur controls in January 2001, and Tier 2 motor vehicle controls in February 2000, and heavy-duty engine and vehicle standards and highway diesel sulfur controls in October 2000 and January 2001. New and updated emissions models predict dramatic emission reductions from these programs. Therefore, the WRAP recommended that EPA remove the requirements for the significance determination in Sections 40 CFR 51.309(d)(5)(ii) and (iii) and amend the rule to require states to demonstrate and monitor a continuous reduction of mobile source emissions of each of the pollutants. Proposed WRAP Amendments: SO2 Emission Reductions The WRAP recommendation also specifically addresses the issue of the projected increase in SO2 emissions from non-road mobile sources in the late years of the planning period (2013-2018). Earlier this year, EPA proposed new standards for nonroad equipment and non-road diesel fuels that will dramatically reduce SO2 emission 3 and ensure continued emission reductions for this pollutant (Federal Register Vol.68, No. 100, May 23, 2003). Those rules will not be finalized before December 31, 2003, the deadline for states to submit their Regional Haze SIPs. Therefore, the WRAP proposed amendment would require states to submit SIP revisions by 2008 to assess whether reasonable progress is being made and if necessary take action to reduce nonroad SO2 emissions if the EPA does not adopt the proposed federal standard to ensure reasonable progress. SIGNIFICANCE DETERMINATION AND FINDINGS The MSWG has determined that mobile sources emissions within areas in Arizona do not contribute significantly to visibility degradation at the 16 Class I areas. This conclusion also supports the WRAP recommendation that determination of mobile source emissions impact should be removed from the RHR and replaced with a requirement for states to demonstrate continual mobile source emission reductions over the planning period, considering economic and technological reasonableness and applicable state authority of the strategy. In making the significance determination, the MSWG analyzed the Arizona mobile source emissions and the impact of the new federal programs to determine if continuous reductions were achieved for each of the pollutants throughout the planning period. The MSWG evaluated the technical data and recent modeling results prepared by ENVIRON for the WRAP. The findings provided below are based upon that review. Current and Projected Emissions from Mobile Sources Inventory The WRAP developed comprehensive emission inventories for mobile sources for the State of Arizona and other western states in 5-year increments. It is assumed that interim years follow the 5-year trends. This inventory included the two major urban areas in the state (Phoenix region represented as Maricopa County, and Tucson region represented as Pima County). The emissions from these two counties follow that of the State totals, with their emissions continuing to decline over the planning period. The current and projected statewide inventories of emissions from mobile sources are shown in Table 1. Table 1: Arizona Projected Emissions for Mobile Sources 2003 through 2018 TPD AZ. Total 2003 2008 2013 2018 % Change 4 989.1 733.1 582.2 495.9 -50% Finding 1. Mobile source emissions of all pollutants (VOC, NOx, PM2.5, EC, OC, and SO2) decline from 2003 to 2018. The analysis of the Arizona data parallels that of the regional analysis conducted by the WRAP. The success of new mobile source control programs is demonstrated most clearly in the dramatic reductions of emissions from 2003 to 2018. During this period of continued growth in population and vehicle miles traveled (VMT), all mobile source emissions are reduced. The total of all mobile source emissions decline 50% for the planning period. An analysis of the data for each pollutant during that same period shows that emissions of VOC and NOx steadily decline (by 51% and 52% respectively), while PM2.5 shows a decrease of 22%. Additionally, because both EC and OC are represented as a percentage of the PM2.5 we can assume that both EC and OC will follow the reduction observed in PM2.5; SO2 also declines by 11% (Attachment B). Finding 2. Year to year mobile source emissions of VOC, NOx, PM2.5, EC, and OC are expected to decline from 2003 to 2018. The GCVTC recommended that emissions show reasonable progress. The GCVTC defined reasonable progress as steady and continuing emission reductions that, in the long-term, lead to improvements in visibility. This is used as the measure of reasonable progress under Section 309. The WRAP and EPA interpretation of the rule requires that each pollutant must be measured separately in the demonstration of continual reductions. Attachment B provides a demonstration that VOC, NOx, and PM2.5, and hence EC and OC, each show annual reductions in the planning period and thus meet the reasonable progress goal in the RHR. Finding 3. Annual mobile source emissions of SO2 are expected to continually decline from 2003 to 2013 with a minor increase from 2013 to 2018 with proposed federal sulfur standards for non-road diesel. Annual mobile source emissions of SO2 show an overall decline of 11% over the planning period with existing federal programs (Attachment B). The proposed non-road federal standards are expected to ensure annual emission reductions (Attachment C). As noted in the WRAP letter of May 6, 2003, the proposed federal non-road standards are critical to this progress. As long as EPA adopts the proposed federal non-road standards, reasonable progress is achieved. Without these standards, the annual emission reductions for mobile sources are achieved only until 2013 when SO2 emissions increase from 9.5 tons/day to 18.6 tons/day (Attachment B). If the non-road standards are adopted, the overall SO2 emissions will decline by 27% from 2003 to 2018. The slight increase from 2013 to 2018 is uncertain and cannot be accurately quantified and will be further addressed in the TSD. If EPA fails to adopt the proposed 5 standards by 2008, Arizona will have adequate time to reassess the progress and adopt state standards if necessary to account for any emissions increases in mobile source emissions. Even though some uncertainty exists in these projections, the new standards would ensure that annual emissions would decline for SO2 emissions and therefore all mobile sources emissions in the state. The RHR clearly does not require a separate analysis of on-road and non-road emissions in making the significance determination. However, the evaluation of the SO2 emissions data demonstrates the importance of the federal non-road rule (see Attachments B and C). A comparison of emissions in the years 2003 and 2018 from Attachment B shows that on-road SO2 emissions decrease by 78%, while non-road SO2 emissions decrease until 2013 and then increase late in the planning period, resulting in a 46% increase overall. That increase is without the proposed federal non-road standards. Assuming the proposed federal standards are adopted (see Attachment C), the non-road SO2 emissions decline by 27%. The point is made even more dramatically in a comparison of 2018 non-road SO2 emissions in Attachments B and C, showing that 2018 SO2 emissions will be 16.5 tons/day without controls and 8.2 tons/day if the proposed federal standards are adopted. This will result in a 50% reduction in non-road SO2 emissions. Finding 4. Annual mobile source emissions of VOC, NOx, PM2.5, EC, and OC are expected to have a minimal impact on visibility. The WRAP performed a modeling analysis to estimate the impact of mobile source emissions from Phoenix Metropolitan area at the GCVTC Class I in 2018. The forecast year 2018 was chosen since it represents the year with the lowest emissions, and is at the end of the planning period. Table 2 summarizes the relative impact of emissions from the Phoenix Metropolitan area at the 16 GCVTC Class I areas, expressed as a percentage of the projected WRAP 2018 Base Case light extinction. Based on WRAP modeling, by 2018 the impact of mobile sources from Arizona urban areas on the GCVTC class I areas will be between 0% and 4% of the projected light extinction. Table 2. Contribution to Light Extinction from Phoenix Mobile Source Emissions (Expressed as a % of WRAP 2018 Base Case Light Extinction) Class I Area on the Colorado Plateau Arches NP Black Canyon NP Bryce Canyon NP Canyonlands NP Capitol Reef NP Flat Tops Wilderness Grand Canyon NP Maroon Bells Wilderness Mesa Verde NP Mount Baldy Wilderness Phoenix 0% 0% 0% 0% 0% 0% 1% 0% 1% 2% 6 Petrified Forest NP San Pedro Parks WA Sycamore Canyon WA West Elk Wilderness 4% 1% 2% 0% Weminuche Wilderness 0% Zion NP 0% Source: Table 3. Percent change in light extinction over 2018 WRAP Base Case Conditions at the 16 Class I areas on the Colorado Plateau due to Mobile Source Emissions from the 9 GCVTC States, California, Phoenix, and Las Vegas, “WRAP Technical memorandum from the Air Quality Modeling Forum to the Mobile Source Forum”, November 4, 2002. Finding 5. Reasonable progress will be achieved over the planning period with the projected emission reductions for all mobile source pollutants. The GCVTC definition of reasonable progress is thus met in findings 2 and 3 above, assuming the adoption of the proposed federal non-road rules. Finding 6. The relative contribution of mobile source SO2 is insignificant compared to that of stationary sources. Based upon data from the WRAP Annex, the category of stationary sources is the primary source of SO2 contributing to regional haze in the GCVTC 16 class I areas. In Arizona, the mobile source contribution to the total concentration of SO2 is relatively small. In 2003, it represents about 5.3% of the total; while in 2018, with EPA’s proposed rule, it is about 3.9% of total emissions. These data also show that the potential relative contribution of mobile sources emissions to the total SO2 would be decreasing at a greater rate than that of stationary sources with EPA’s new proposed non-road rule. This continued improvement in mobile source emissions is the result of stringent federal programs created after the 1995 GCVTC report. Therefore, the WRAP concluded that the Commission’s concern about the potential impact from mobile sources has been addressed. Additional federal control programs for mobile sources will provide an even greater improvement in emissions in upcoming years. Finding 7. The uncertainty in regulations and projections in emissions adds to the determination. It is important to note that uncertainty exists in several areas: 1) the adoption of the proposed federal non-road standards as proposed on May 23, 2003; 2) the projected benefits that might be achieved, and 3) the projections of emissions from the model for the later years. When looking at the data, the projections for the early years are likely to be more valid than those estimated for 2018. This uncertainty can be addressed through periodic reporting on the progress of the reduction in mobile source emissions and then making adjustments in the SIP. 7 MSWG RECOMMENDATION TO ADEQ FOR SIGNIFICANCE DETERMINATION: Based on this analysis, the MSWG concludes that mobile source emissions do not significantly contribute to regional haze at any of the 16 GCVTC Class I areas. This finding does not attempt to address the other Class I areas in the State that will be addressed in the future under Section 309(g) of the RHR. In evaluating the impact of mobile source emissions in the 16 Class I areas, the MSWG considered a wide range of information from the WRAP analysis as well as Arizonaspecific data on total emissions as well as specific pollutants. The Working Group concludes that reductions in mobile source emissions will meet the GCVTC goal of continued reduction throughout the planning period based upon new and proposed federal programs with the EPA adoption of the proposed non-road rules. In the event that EPA’s proposed non-road standards are not realized, the WRAP recommends that states be required to file a SIP revision to ensure reasonable progress prior to December 31, 2008. Based upon the findings above, the MSWG recommends that ADEQ consider this report in preparing the significance determination for the Arizona Regional Haze SIP. Should the proposed revisions to the RHR become effective prior to the submission of the Arizona SIP under Section 309, references to 40 CFR 51.309(d)(5)(ii-iii) will be eliminated. List of Attachments: Attachment A “WRAP Letter to EPA (Dated May 6, 2003)” Attachment B “Total Arizona Mobile Source Emissions by Pollutant Projected for 2003 through 2018 Assuming No New Regulations” Attachment C “Total Arizona Mobile Source Emissions by Pollutant Projected for 2003 through 2018, Assuming a 15 ppm Sulfur Non-road Diesel Standard” 8 Attachment A 9 10 11 12 Attachment B Total Arizona Emission by Pollutant Projections for 2003 through 2018 Assume No New Regulations (TPD) 2003 2008 2013 2018 % Change VOC 448.7 319.9 256.9 222.0 -51% NOx 496.5 381.2 296.7 237.3 -52% State Total PM2.5 23.0 22.0 19.1 18.0 -22% SO2 20.9 14.6 16.6 18.6 -11% Total 989.1 737.7 589.3 495.9 -50% 2003 2008 2013 2018 % Change VOC 112.1 77.7 70.3 69.7 -38% NOx 150.2 124.4 111.1 107.8 -28% Non-road PM2.5 14.2 13.8 13.3 13.4 -6% SO2* 11.3 13.0 14.8 16.5 46% Total 287.8 228.9 209.5 207.4 -28% *2003 and 2018 are actual model outputs; 2008 and 2013 are extrapolated and assumed to be linear. 2003 2008 2013 2018 % Change VOC 336.6 242.2 186.6 152.3 -55% NOx 346.3 256.8 185.6 129.5 -63% On-road PM2.5 8.8 8.2 5.8 4.6 -48% SO2 9.6 1.6 1.8 2.1 -78% Total 701.3 508.8 379.8 288.5 -59% Note: Both EC and OC are represented as a percentage of the PM2.5 and we can assume that both EC and OC will follow the changes observed in PM2.5 13 Attachment C Total Arizona Emission by Pollutant Projections for 2003 through 2018 Assume a 15 ppm Sulfur Non-road Diesel Standard (TPD) 2003 2008 2013 2018 % Change VOC 448.7 319.9 256.9 222.0 -51% NOx 496.5 381.2 296.7 237.3 -52% State Total PM2.5 23.0 22.0 19.1 18.0 -22% SO2 20.9 10.0 9.5 10.3 -51% Total 989.1 733.1 582.2 487.6 -51% Note: Assumes all the reductions associated with 15 ppm Standard come between 2013 and 2018 2003 2008 2013 2018 % Change VOC 112.1 77.7 70.3 69.7 -38% NOx 150.2 124.4 111.1 107.8 -28% Non-road PM2.5 14.2 13.8 13.3 13.4 -6% 2003 2008 2013 2018 % Change VOC 336.6 242.2 186.6 152.3 -55% NOx 346.3 256.8 185.6 129.5 -63% On-road PM2.5 8.8 8.2 5.8 4.6 -48% SO2 11.3 8.4 7.7 8.2 -27% Total 287.8 224.3 202.4 199.1 -31% SO2 9.6 1.6 1.8 2.1 -78% Total 701.3 508.8 379.8 288.5 -59% Note: Both EC and OC are represented as a percentage of the PM2.5 and we can assume that both EC and OC will follow the changes observed in PM2.5 14 REGIONAL HAZE STATE IMPLEMENTATION PLAN FOR THE STATE OF ARIZONA APPENDICES - VOLUME II Appendix A-10 Air Quality Division Arizona Department of Environmental Quality LIST OF APPENDICES APPENDIX VOLUME I APPENDIX A-1. BACKGROUND Appendix A-1a. Definitions Appendix A-1b. Arizona Department of Environmental Quality – Air Quality Division Organization Charts APPENDIX A-2. DESCRIPTIONS OF ARIZONA Appendix A-2a. Bibliography for Chapter 2 APPENDIX A-5. ATTRIBUTABLE IMPAIRMENT Appendix A-5a. Arizona’s RAVI rule Appendix A-5b. Notification letters to FLMS on contact person, and Public Comment Period Appendix A-5c. Supporting Documents Related To The Promulgation Of Arizona’s RAVI Rule Appendix A-5d. New source review rule-R18-2-410 APPENDIX A-6. CLEAN AIR CORRIDOR Appendix A-6a. WRAP Policy on Clean Air Corridors Appendix A-6b. WRAP Emission Tracking System and Assessment Process for the Clean Air Corridor APPENDIX A-7. STATIONARY SOURCES Appendix A-7a. Arizona Draft Western Backstop SO2 Trading Program Rule Appendix A-7b. Proposed WRAP 309 Coordinating Committee Charter Appendix A-7c. WRAP Report on Assessment of NOx/PM Strategies APPENDIX A-8. SO2 MILESTONES/BACKSTOP Appendix A-8a. WRAP Market Trading Forum Non-Utility Sector Allocation Final Report from the Allocations Working Group (November 2002) Appendix A-8b. Western Emissions Backstop (WEB) Emissions & Allowance Tracking Systerm (EATS) Analysis Appendix A-8c. Recommendations for Making Additional Determinations in the Context of Reasonably Attributable BART APPENDIX A-9. MOBILE SOURCES Appendix A-9a. Arizona Mobile Source Work Group Findings and Recommendations Related to Mobile Source Emissions List of Appendices Arizona Regional Haze SIP LIST OF APPENDICES (Cont.) APPENDIX VOLUME II APPENDIX A-10. FIRE PROGRAMS Appendix A-10a. WRAP report “Assessing Status of Incorporating Smoke Effects into Fire Planning and Operation” Appendix A-10b. EPA’s “Interim Air Quality Policy on Wildland and Prescribed Fires” Appendix A-10c. Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10d. Supporting Documents Related to the Promulgation of Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10e. WRAP “Policy on Fire Tracking Systems” Appendix A-10f. WRAP report “Nonburning Alternatives for Vegetation and Fuel Management” Appendix A-10g. WRAP report “Burning Management Alternatives on Agricultural Lands in the Western United States” Appendix A-10h. WRAP report “Enhanced Smoke Management Programs for Visibility” Appendix A-10i. Arizona Revised Statute 49-501 Appendix A-10j. WRAP report “Annual Emission Goals for Fire” List of Appendices Arizona Regional Haze SIP LIST OF APPENDICES (Cont.) APPENDIX VOLUME III APPENDIX A-12. POLLUTION PREVENTION Appendix A-12a. Arizona Pollution Prevention Work Group Review of WRAP Policy on Renewable Energy and Energy Conservation Appendix A-12b. Details of Renewable Energy Generation and Capacity Appendix A-12c. ICF Assessment of Renewable Energy and Energy Conservation Programs APPENDIX A-13. OTHER GCVTC OPTIONS Appendix A-13a. Arizona’s Assessment of Other Recommendations Of The Grand Canyon Visibility Transport Commission Appendix A-13b. Summary of Discussions with Federal Land Managers on Emissions In-and-Near the Four Arizona GCVTC Class I Areas APPENDIX A-14. PROJECTION OF VISIBILITY Appendix A-14a. Arizona Technical Review Memoranda of WRAP Emission Inventories and Technical Support Document Appendix A-14b. Summary of Emission Inventories used in WRAP Modeling APPENDIX A-18. PUBLIC PARTICIPATION Appendix A-18a. Notices of Public Hearings Appendix A-18b. Hearing Agendas, Sign-in Sheets, Transcripts, and Certifications Appendix A-18c. Written Comments Received During Comment Period Appendix A-18d. Responsiveness Summary List of Appendices Arizona Regional Haze SIP APPENDIX A-10. FIRE PROGRAMS This appendix contains work products and references relied upon by Arizona in the development of Chapter 10 of the Regional Haze SIP. Appendix A-10 –Fire Programs Arizona Regional Haze SIP Appendix A-10a. WRAP report “Assessing Status of Incorporating Smoke Effects into Fire Planning and Operation” Appendix A-10 –Fire Programs Arizona Regional Haze SIP ASSESSING STATUS OF INCORPORATING SMOKE EFFECTS INTO FIRE PLANNING AND OPERATIONS Prepared by: Entranco 345 E. Mountain Avenue Fort Collins, CO 80524 In association with: Core Environmental Consulting Forest Stewardship Concepts, Ltd. Contents Tables ................................................................................................................................. i Figures ................................................................................................................................ i 1.0 Introduction ................................................................................................................. 1 2.0 Methods....................................................................................................................... 3 2.1 Programmatic Plans .................................................................................................. 5 2.2 Operational Plans ..................................................................................................... 6 2.3 Guidance Documents............................................................................................... 7 3.0 Findings ....................................................................................................................... 8 3.1 Programmatic Plans .................................................................................................. 9 3.2 Operational Plans ................................................................................................... 12 3.3 Guidance Documents............................................................................................. 24 4.0 Summary.................................................................................................................... 28 Tables Table 1. Land Managers Requested to Provide Fire/Burn Plans for the Project..................... 3 Table 2. Affirmative Criterion Responses for Programmatic Plans for Prescribed Fire ........ 10 Table 3. Affirmative Criterion Responses for Programmatic Plans for WFU ....................... 10 Table 4. Affirmative Criterion Responses for Operational Plans for Prescribed Fire ........... 12 Table 5. Affirmative Criterion Responses for Operational Plans for WFU .......................... 16 Table 6. Affirmative Criterion Responses for Operational Plans for WFSA......................... 17 Table 7. Affirmative Criterion Responses for Implementation of Prescribed Fire................ 19 Table 8. Affirmative Criterion Responses for Implementation of WFU .............................. 22 Table 9. Affirmative Criterion Responses for Guidance Documents .................................. 24 Figures Figure 1. Results from Operational Plans for Prescribed Fire ............................................. 13 Figure 2. Results from Implementation of Prescribed Fire ................................................. 21 Figure 3. Results from Evaluation of Guidance Documents............................................... 24 Appendices Appendix A. List of Plans Reviewed for Project Appendix B. Guidance Documents Reviewed Appendix C. Evaluation Results and Review Comments for Guidance Documents i 1.0 Introduction The Western Governor's Association (WGA), in conjunction with federal, state, tribal, and local entities throughout the west, formed the Western Regional Air Partnership (WRAP). The purpose of WRAP is to build on the work of the Grand Canyon Visibility Transport Commission (GCVTC) in developing and planning programs that can reduce visibilityimpairing emissions and improve visibility throughout the West. WRAP can recommend regional approaches to improving air quality and reducing regional haze, but the authority and responsibility for implementing any or all WRAP recommendations lies with individual states, tribal entities, and local governments. WRAP has a principal planning group, the Initiatives Oversight Committee (IOC), and a principal technical group, the Technical Oversight Committee (TOC). Under the IOC and TOC are several forums that develop technical and policy options for specific areas of interest to WRAP. One such forum is the Fire Emissions Joint Forum (FEJF), which reports to both the IOC and TOC. The FEJF is tasked with making recommendations on strategies and methods to manage emissions from prescribed fire. The Smoke Effects Task Team is part of the FEJF and is the sponsoring agent for the project described in this report. Smoke from fires produces a variety of air pollutants. The predominant sources of smoke in the region typically are from fires for prescribed burns, natural wildland fires and agricultural burns. GCVTC recognized the need to address air quality effects from prescribed fire and managed natural fire (or wildland fire use [WFU]) because of increased use of prescribed fire throughout the West. GCVTC concluded that fire planning efforts should consider more thoroughly the effects of smoke on visibility, public nuisance, and the National Ambient Air Quality Standards (NAAQS) (GCVTC, 1996), and also as required by the Environmental Protection Agency’s (EPA) Regional Haze Rule (EPA, 1999). State Governments in WRAP The following sections describe a project that is one step in investigating the existing level of consideration given to smoke impacts in fire planning documents, and this was the overall purpose of the project. The project involved gathering and reviewing a number of different types of fire-related documents from a variety of agencies and tribal entities that perform or authorize controlled or natural burns, to assess the emphasis placed on smoke impacts. The project had several objectives, including: • assess the status of federal, state, local, tribal, and private prescribed fire programs in considering smoke effects from prescribed fires and WFUs in strategic planning documents, known as programmatic plans, • evaluate whether non-burning alternatives were considered by land managers in programmatic plans, 1 • assess the status of federal, state, local, tribal, and private prescribed fire programs in considering smoke effects from prescribed fires and WFUs in operational plans, including use of the Wildland Fire Situation Analysis (WFSA) by federal land managers, • evaluate the smoke effects from implementation of operational plans for prescribed fires and WFUs, including use of WFSA by federal land managers, • identify and summarize relevant guidance documents for agencies on consideration of air quality effects from prescribed fire and WFU in programmatic and operational plans, and • identify and summarize relevant guidance documents for use of the WFSA process for assessing air quality effects for wildfire and WFU incidents. Prescribed Fire is defined as a management-ignited wildland fire that burns under specified conditions where the fire is confined to a predetermined area and produces the fire behavior and fire characteristics required to attain planned fire treatment and resource management objectives. WFU refers to the management of naturally-ignited fires to accomplish specific, pre-stated resource management objectives in predefined geographic areas that are outlined in the governing programmatic plan. Prescribed Natural Fire is another term often used to describe WFU, and both terms refer to the same concepts. WFU operational plans are only developed by Federal Land Management agencies that have approved Wildland Fire Management Plans. WFU does not apply to state or county agencies, private land managers or tribal entities. WFSA is a decision-making process jointly established by the Federal Land Managers that evaluates alternative management strategies related to firefighter safety, environmental, social, economic, political, and resource management objectives. As such, WFSA plans only apply to wildland fires on federally managed lands. Consequently, WFSA plans were not received from state, county, private or tribal entities. The documents of interest fit into three general categories: programmatic plans, operational plans, and guidance documents. The discussion of methodology and results of the project is broken out by these categories. Steps in Federal Fire Planning Processes Bureau of Land Management Level of Plan Resource Management Plan Programmatic (Environmental Impact Statement) National Park Service Forest Service General Management Planning Forest Land Management Plan Fire Management Plan (Environmental Fire Management Plan (Environmental Assessment) Assessment) Burn Plan Burn Plan Project (Environmental Assessment) Programmatic Operational 2 Phase 1 Analysis (Environmental Assessment) Fire Management Plan 2.0 Methods The overall approach within the project was to gather various burn plans/documents from designated agencies and tribal entities, and assess the plans/documents relative to specific project evaluation criteria. The results from the assessments were recorded, tabulated, and summarized. One directive for the project was to summarize results to maintain individual agency anonymity. A sample of various recent fire planning and execution documents prepared by a number of different agencies (or other entities) that use fire/burning for resource management was the goal of the document collection task. The sample size and contacts were predetermined by FEJF before the project began. Table 1 is a summary of the land managers and agencies that were contacted for the project. The list includes tribal entities, federal, local, private, state, and tribal land managers. It must be emphasized that most of the plans received and reviewed for the project (excluding guidance documents) were selected by the resource agencies in Table 1, not the project team. Each land manager was requested to provide examples of the following types of documents: • Programmatic plans Programmatic for prescribed fire ‰ Programmatic for WFU ‰ • Operational plans Operational for prescribed fire ‰ Implementation of prescribed fire ‰ Operational for WFU ‰ Implementation of WFU ‰ WFSA documentation ‰ • Guidance documents, air quality regulations, and statutes supporting plan preparation It should be noted that this plan-naming convention is not universal for all of the land managers; the plan names are most applicable to federal processes. Not every land manager uses or is required to use each of the named plan types. Therefore, each plan type was not necessarily available from every land manager. In addition, there is considerable variability in complexity within a category of plans, depending on the goals, objectives, and regulatory requirements of the land manager. Where necessary, a specific fire/burn document without an obvious category was designated as the closest matching plan type. A comprehensive list of the burn plans reviewed is presented in Appendix A. The plans were assessed by comparing the contents of the plans/documents against a set of evaluation criteria. The evaluation criteria were developed by FEJF. Different types of plans had different evaluation criteria. The criteria by which each fire/burn plan was evaluated are presented below. Note that some of the criteria have multiple conditions joined by “and.” In these cases, all criteria conditions must be true for an affirmative response to that criterion. With an “or” or “e.g.,” a single true condition elicits an affirmative response. The results for each evaluation criterion were recorded on data forms. The data were then transferred to an electronic database developed specifically to contain project information, to facilitate analysis of the results. The database enabled the project team to view data in 3 both specific and anonymous terms as the project progressed. The database was also used to track the progress of receipt and review of the various plans. Table 1. Land Managers Requested to Provide Fire/Burn Plans for the Project Type Agency Region Bureau of Indian Affairs Bureau of Land Management Alaska Arizona Colorado Idaho Montana New Mexico Nevada Oregon Utah Wyoming Department of Defense Federal National Park Service U.S. Fish and Wildlife Service U.S. Forest Service Local Private State Tribal 4 Bernalillo County, New Mexico Boulder County, Colorado Columbia County, Washington Jefferson County, Oregon Missoula County, Montana Pinal County, Arizona San Joaquin Valley, California The Nature Conservancy Plum Creek Timber USDA Natural Resources Conservation Service Colorado Division of Forestry Montana Division of Forestry Nevada Division of Forestry State of Arizona Agriculture State of California Agriculture State of Idaho Agriculture State of Montana Agriculture State of Oregon Agriculture State of Washington Agriculture Institute for Tribal Environmental Professionals Intertribal Timber Council Alaska Intermountain Midwest Pacific West 1 2 6 1 2 3 4 5 6 2.1 Programmatic Plans Programmatic plans are strategic land management plans for prescribed fire and/or WFU that include fuel treatment activities at a program level. They usually cover a 1- to 20-year planning period for a specific management area. Examples of federal programmatic plans are Resource Management Plans or Fire Management Plans for a specific land management unit (e.g., a BLM district or national forest). Comparable planning documents are uncommon outside federal agencies for burning that occurs on private lands, tribal lands or under open burning permits issued to the general public. Nevertheless, example programmatic documents that had been prepared within the past 3 years (or their equivalent) were requested from all of the contacts listed in Table 1. The programmatic plans were evaluated for two types of beneficial fire use: prescribed fire and WFU. Different evaluation criteria were used for prescribed fire and WFU. 2.1.1 Programmatic Plans for Prescribed Fire The evaluation criteria for programmatic prescribed fire plans were: 1. Was there evaluation of cumulative effects of smoke (qualitative and/or quantitative analysis)? 2. Was there evaluation of potential intrusions to Class I or other identified smokesensitive areas? 3. Was there identification and determination of compliance with applicable laws and relevant policies? 4. Any identification of smoke management techniques to reduce fire emissions and mitigate smoke impacts? 5. Analysis of recent historic (within 10 years) and projected (for life of plan) annual or seasonal emissions from prescribed fire and WFU? 6. Identification of non-burning alternatives that were analyzed or utilized as a fuel treatment method? 7. Completion of General Conformity determination for projects in nonattainment areas? 2.1.2 Programmatic Plans for Wildland Fire Use The evaluation criteria for programmatic WFU plans were: 1. Was there consideration of cumulative effects of smoke (qualitative and/or quantitative analysis)? 2. Was there assessment of potential intrusions to Class I or other identified smokesensitive areas? 3. Are any burn decisions tied to specific air quality criteria? 5 4. Identification of non-burning alternatives that were analyzed or utilized as a fuel treatment method? 2.2 Operational Plans The operational plan category contains two general groups of documents: pre-burn and post-burn. The true “operational” plans in this category are the pre-burn plans that describe in advance how beneficial fire is planned for a specific land unit. The post-burn plans in this category consist of the implementation of a pre-burn operational plan and are referred to as implemented plans below. Operational plans for this project are relevant for prescribed fire, WFU, and WFSA. Once again, this is primarily federal terminology, however, most non-federal land managers have an equivalent pre-burn operational document. Most planned beneficial fire, whether it occurs under a simple burning permit or a complex program to accomplish a large wildland fire, has some type of operational plan. For the purposes of this survey, a recent operational plan was requested from the sources listed in Table 1. In the case of implemented plans, any available documentation on the results of the fire was requested, as formal post-burn reports proved to be uncommon. 2.2.1 Operational Plans for Prescribed Fire, WFU and WFSA To identify and assess federal, state and local-level operational plans with respect to air quality effects from prescribed fire, WFU and WFSA smoke effects, available documents were gathered and evaluated. The documents were gathered through telephone requests from contacts specified by FEJF at the beginning of the project (Table 1). The evaluation criteria for operational plans for prescribed fire, WFU, and WFSA were as follows: 1. Did the document estimate emissions of visibility-impairing air pollutants and their effects on visibility (regional haze and plume blight), NAAQS, and nuisance? 2. Did the document discuss actions to be taken to minimize fire emissions and/or smoke impacts? 3. Was the use of smoke dispersion evaluation or criteria discussed in the document? 4. Did the document discuss the use of public notification procedures? 5. Did the document discuss the use of air quality monitoring? 6. Were predetermined “trigger points” for designating air quality impact discussed in the document? 7. Did the document discuss predetermined contingency actions to be taken when air quality impacts occurred? 8. Was planned cooperation with downwind receptors, regulatory agencies, and compliance with their laws, rules, and guidance discussed in the document? 9. Was planned coordination with adjacent and downwind land managers discussed in the document? 6 10. For projects in nonattainment areas, did the document discuss completion of the General Conformity determination? (Note: This criterion is for prescribed fire plans only.) In reviewing these documents, an affirmative evaluation was given if the criterion topic was mentioned or discussed, even if only briefly. The project team did not attempt to assess the thoroughness or adequacy of the criterion discussion, only its presence. If the criterion topic was not found, a negative evaluation was given. In some cases, a criterion may not be applicable (e.g., Criterion 10) for a plan. 2.2.2 Implementation of Prescribed Fire and WFU Implementation of WFSAs did not seem to be documented typically and was consequently not available for evaluation under the project. Therefore, the evaluation criteria for implemented prescribed fire and WFU plans were as follows. 1. Were smoke effects avoided? 2. Were unfavorable smoke effects experienced? 3. Was the frequency of verified public nuisance complaints reported in the document? 4. Were air quality regulatory citations documented? 5. Were contacts made with downwind receptors, regulatory agencies, and land managers according to predetermined plans? 6. Were all of the smoke management elements of the burn plan implemented? 7. Were any contingency actions taken as a result of air quality impacts? 8. Were public notification and exposure reduction procedures followed? 9. Was compliance met with all applicable air quality laws, rules, and guidance? 10. Was the air quality monitoring plan followed? 11. Were actions taken to avoid smoke impacts and effects? In reviewing these documents, an affirmative evaluation was given if the criterion topic was mentioned, even if only briefly. If the criterion topic was not found, a negative evaluation was given. In some cases, a criterion may not be applicable (e.g., Criterion 10) for a plan. It must be emphasized that formal implementation reports seem to be uncommon, so the “implementation plan” often consisted of field notes, participant summaries, etc. The project team had no way to verify independently the completeness of the data provided for review, rather we relied on the diligence of the providing agency. 2.3 Guidance Documents To identify and assess federal, state, and local-level guidance with respect to air quality effects of prescribed fire and WFU smoke effects, available guidance documents were 7 gathered and evaluated. An initial set of guidance documents to be reviewed was specified by FEJF at the beginning of the project, but other guidance was identified and added by the project team. The documents included smoke management plans from throughout the West, local open burning permit requirements, national smoke management guidance and training materials, agricultural burning smoke management program documents from Oregon and Washington, as well as federal and state and local air quality regulations. The documents were gathered from the Internet, from personal libraries, by telephone requests and from local libraries. These documents were selected with the intent of assessing reporting requirements for smoke effects from a representative set of air quality regulations as well as land manager guidance documents. The guidance documents reviewed are listed in Appendix B. The evaluation criteria used for guidance documents were as follows: 1. Did the document provide guidance on the use of categorical exclusions under the National Environmental Policy Act (NEPA)? 2. Was guidance provided on the use of non-burning alternatives? 3. Did the document include information on applicable air quality laws, rules, and guidance and the general conformity requirements of the Clean Air Act? 4. Was guidance provided on estimation of air pollutant emissions and their effects on visibility (regional haze and plume blight) as well as the National Ambient Air Quality Standards (NAAQS)? 5. Were predetermined “trigger points” to indicate when an air quality impact occurs discussed in the document? 6. Were contingency actions to be taken when air quality impacts occur discussed? 7. Was coordination with adjacent and downwind land managers, regulatory agencies, and other downwind receptors discussed? 8. Did the guidance cover cumulative effects of smoke through either a qualitative or quantitative analysis of prescribed fire projections from other land managers and other stationary or mobile sources? In reviewing these documents, an affirmative evaluation was given if any guidance on the criterion topic was provided, no matter how brief. If discussion of the criterion topic was not present, a negative evaluation was given. In addition, the criteria as provided by the FEJF were treated quite literally. For example, the phrasing of Criterion 3 with “and” requires several conditions all to be met for a document to receive an affirmative response. As a result, any documents that might address some of the conditions of the criterion but not others received a negative evaluation for the criterion. 3.0 Findings In considering the results from the project tasks, a few points must be emphasized. The great majority of the plans (excluding guidance documents) included in this project were selected at the sole discretion of the providing agency. The project team mentioned some 8 desired characteristics of the plans to be reviewed (such as 1998 or more recent, and fully completed) but the agencies ultimately selected the individual plans on their own. (In a few instances at the end of the project, the project team acquired a few plans on their own to fill gaps in the overall project matrix.) In addition, the project team had no access to the agency files and therefore had no control over the completeness of the documentation provided for review. Every effort was made to ensure that the contacted agencies were aware of the project goals, but the project team had no way of knowing if relevant documentation was not provided by the agencies. Follow-up calls to the agencies were made to ensure the relevant information was provided, but ultimately this was beyond the project team’s control. The findings from the evaluations of programmatic plans, operational plans and guidance documents are presented below. The findings are divided into tables according to plan type. Each table is summarized by agency type. The tables show the total number of each type of plan reviewed, the number of those plans with an affirmative (i.e., “yes”) evaluation for each criterion, and the corresponding percentage of the total represented by the latter number. Negative evaluations for a criterion could be due to absence from the document reviewed or non-applicability of the criterion to the particular document. Please note that negative evaluations do not necessarily mean a “poor” or “bad” finding, as in the case of whether any air quality citations were issued. Finally, the following sections present few findings regarding tribal activities. This outcome appeared to be due to several factors, including (1) limited suppliers of tribal documents (Institute for Tribal Environmental Professionals [ITEP], Intertribal Timber Council, Bureau of Indian Affairs), and (2) an official request process through tribal entities that was too lengthy for the time constraints on the project. The ITEP study (An Assessment of Tribal Air Quality Data and Programs in the Western United States) indicated that some Federal Implementation Plans and tribal Smoke Management Plans have been developed, but copies of those plans, programmatic plans or operations plans are not readily available. Therefore, it would be incorrect to presume that the lack of numbers of tribal plans below corresponds to a lack of involvement in smoke issues by tribal agencies; rather, the project team had difficulty acquiring plans within the framework of the project. 3.1 Programmatic Plans A total of 18 prescribed fire and 12 WFU programmatic plans were received from federal agencies. One local prescribed fire programmatic plan was reviewed (a county prescribed fire planning document), and one tribal prescribed fire plan was reviewed. Results of the assessment for programmatic plans are presented in Tables 2 and 3. 3.1.1 Programmatic Plans for Prescribed Fire The review of prescribed fire programmatic plans prepared by federal agencies indicates that while most plans do address the assessment criteria in very qualitative terms, none of the plans provided quantitative analysis of the effects of smoke on air quality and Class I visibility. Many of the plans defer such matters to the smoke management program under which they operate, noting only that the burning to be conducted will comply with smoke management plan requirements. This infers that all applicable laws and relevant policies are complied with and that smoke management techniques will be applied. The majority of the plans also note that prescribed burning may temporarily impact air quality and Class I area visibility. 9 A programmatic plan for prescribed fire was obtained from both a tribal and a local agency. These seemed to be rather rare occurrences. These two plans were somewhat hit-and-miss regarding coverage of evaluation criteria, and the large range in percentages (Table 2) is reflective of the low number of plans available. Table 2. Affirmative Criterion Responses for Programmatic Plans for Prescribed Fire Count Percent Count Percent 1) cumulative effects of smoke 2) intrusions into Class I or other areas 3) applicable laws and relevant policies 4) smoke management techniques 5) annual or seasonal emissions 6) non-burning alternatives 7) General Conformity (in nonattainment/maintenance areas only) Number of Documents Federal Percent Criteria Agency Type Local Count Tribal 0 0 1 100 7 39 0 0 1 100 10 56 0 0 0 0 15 83 0 0 1 100 11 61 1 100 0 0 4 22 1 100 1 100 8 44 6 NA NA 1 1 1 18 NA—not applicable Table 3. Affirmative Criterion Responses for Programmatic Plans for WFU 1) cumulative effects of smoke 2) intrusions into Class I or other areas 3) burn decisions tied to air quality criteria 4) non-burning alternatives Number of Documents Percent Criteria Count Agency Type Federal 4 33 7 58 12 100 9 12 75 ♦ Criterion 1: Cumulative effects 10 About a third of the federal plans discussed this topic, usually rather minimally. It was covered in the local plan, but not the tribal plan. ♦ Criterion 2: Impacts on Class I areas About half the federal plans covered this, often as a component of smoke estimation. It was covered in the local plan, but not the tribal plan. ♦ Criterion 3: Laws and policies A large majority of the federal plans discussed the laws that the plans must comply with, and this was often done in terms of the governing local Smoke Management Plan. It was not covered in the local plan or the tribal plan. ♦ Criterion 4: Smoke management techniques This was kind of a mixed bag with the federal plans, though a majority of plans addressed the topic. Some made mention of techniques such as backing fires. It was covered in the local plan, but not the tribal plan. ♦ Criterion 5: Annual or seasonal emissions estimates Few of the federal plans discussed this topic. It was not covered in the local plan, but was in the tribal plan. ♦ Criterion 6: Non-burning alternatives Just under half of the federal plans discussed this topic and such discussions are often quite brief and not comprehensive. It was also covered in the local plan, and briefly in the tribal plan. ♦ Criterion 7: General Conformity This criterion is relevant only for planned federal activities (e.g., prescribed fire) in areas that are nonattainment or maintenance areas for one or more NAAQS; conformity is not an issue in attainment areas. This topic was relevant for only one of the federal resource areas, and it was discussed in the relevant plan. This topic was not relevant to either the local or tribal resource areas and was therefore not presented. 3.1.2 Programmatic Plans for WFU All of the programmatic plans for WFU reviewed were from federal agencies (Table 3). The other agency types generally suppress any naturally-started fires. ♦ Criterion 1: Cumulative effects Only about a third of the federal plans discussed this topic, usually rather minimally ♦ Criterion 2: Impacts on Class I areas About half the federal plans covered this, often as a component of smoke modeling. Some plans deferred this evaluation until ready to burn. 11 ♦ Criterion 3: Burn decision tied to air quality Each of the federal plans indicated that atmospheric conditions must be favorable for the action to proceed, although the required atmospheric conditions were not always identical. ♦ Criterion 4: Non-burning alternatives Three-quarters of the plans discussed alternatives such as mechanical treatments. In some instances, there are agency policies or other limitations on use of mechanical treatments. 3.2 Operational Plans There are five subgroups of operational plans for the project, covering both operational plans and the implementation of operational plans. For the project, a total of 47 operational plans and 19 implementation “reports” were reviewed. These documents were provided by a variety of agency types and covered a wide gamut of technical needs. The results are presented in Tables 4, 5 and 6. Table 4. Affirmative Criterion Responses for Operational Plans for Prescribed Fire NA—not applicable 12 Percent Count Percent Count Percent Count Percent Federal Count 1) estimation of emissions 0 1a) estimation of emissions, 0 but ignoring regional haze portion 2) actions to minimize 1 emissions 3) smoke dispersion 1 evaluation 4) public notification 1 5) air quality monitoring 1 6) predetermined trigger 0 points 7) predetermined 1 contingency actions 8) cooperation with 1 downwind receptors 9) coordination with adjacent and downwind land 1 managers 10) completion of General NA Conformity Number of Plans 1 Agency Type Private Local State Percent Criteria Count Tribal 0 0 0 0 0 0 0 0 0 0 0 0 3 50 2 25 8 44 100 2 100 5 83 7 88 12 67 100 2 100 6 100 8 100 18 100 100 1 50 2 100 2 100 4 33 67 4 5 50 16 89 63 16 89 3 50 5 63 10 56 100 2 100 4 67 6 75 14 78 100 1 50 4 67 8 100 16 89 100 1 50 2 33 4 50 11 61 0 1 50 NA NA NA NA 2 6 8 18 3.2.1 Operational Plans for Prescribed Fire A total of 35 operational plans for prescribed fire were reviewed for the project, and plans were received from all five agency categories (Table 4). This was the plan type that was most complete for the project. The types of plans received in this category ranged from simple 1-page county open burn forms to Environmental Impact Statements. The results from the evaluations of operational plans for prescribed fire are presented in Table 4 and are graphed in Figure 1. Comparison of plans from different agency categories showed a wide range in plan content and complexity. However, the operational plans for prescribed fire from federal agencies (Table 1) were fairly consistent in content as well as appearance. In general terms, federal plans tended to be the most comprehensive and complete. State forestry agencies often use prescribed fire on lands they manage. These agencies typically prepare burn plans prior to unit ignition, as required by their respective state smoke management plans. Figure 1. Results from Operational Plans for Prescribed Fire 1. Estimation of emissions 2. Actions to minimize emissions 3. Smoke dispersion evaluation Criteria 4. Public notification 5. Air quality monitoring 6. Predetermined trigger points 7. Predetermined contingency actions 8. Cooperation with downwind receptors 9. Coordination with downwind land managers 10. Completion of General Conformity Not applicable 0 20 40 60 80 100 Affirmative Responses (%) Tribal Private Local State Federal 13 Several states also regulate agricultural burning and require simple plans as a condition of burn permit issuance. A variety of documents were provided by the various state agricultural and local entities on the list (Table 1), but these documents fit into two general categories: those prepared for state/local agency approval and those that were not. Examples of documents provided that were not for state/local approval included copies of burn plans by other agencies (e.g., Forest Service) that were distributed through burn notification requirements. These documents were evaluated for the project, but were materially different from the next category. The documents that were prepared for state/local approval were limited to open burning permit applications. These permits were for ditch burning on private lands, burning of agricultural debris from orchards and grass seed production, forestlands and general land clearing operations. The open burn documents are typically simple in scope, limiting the kinds of materials that can be burned, the notification procedures that must be used and burn day smoke dispersion requirements. The one exception was a local parks department that provided an operational plan for prescribed fire that resembled the operational plans for prescribed fire acquired from federal agencies. The private land owners contacted for this project operated under open burn permits, and sometimes they must prepare burn plans as a condition of permit issuance. Some of the land owners proactively prepare burn plans for their own internal planning purposes, even if not required in the permitting process. The scope of these plans can vary considerably depending on smoke management program requirements. One operational prescribed fire plan was obtained from a tribal organization. All of the project document types discussed in this section were included in the operational plan assessment for prescribed burns. Generally speaking, the operational plans for prescribed fire covered the evaluation criteria pretty well, as most of the results are well over 50% (Table 4). This indicates that the fire planners are giving the topics of concern at least some consideration. Criterion 3 had universal recognition in the plans. Criteria 1 and 6 showed some of the lowest recognition. Criterion 10 received no recognition because none of the reviewed plans were in NAAQS non-attainment areas. Results for the other criteria fell somewhere in between, but were generally relatively high. The following discusses findings relevant to each of the assessment criteria. ♦ Criterion 1: Estimation of emissions The wording of this criterion should be noted. There are a number of conditions that must all be true for an affirmative response to this criterion, and typically impacts to regional haze (or more) were not addressed. Therefore, none of the reviewed plans received an affirmative response when following the wording of the criterion. When the regional haze portion of the criterion is ignored (Table 4 Line 1a), there are several affirmative responses. In most cases, SASEM was run to estimate emissions. ♦ Criterion 2: Actions to minimize emissions A large majority of the plans addressed this topic. For the federal reports, the most common actions discussed were aerial ignition and ignition patterns. For the state it was limiting the area burned and for local it was ignition technique. 14 ♦ Criterion 3: Smoke dispersion evaluation Every operational plan for prescribed fire that was reviewed addressed this criterion. Scheduling involving the time of day and/or year that burning was permitted was the most common way that achieving dispersion was addressed in all report types. Wind speed and direction, mixing height were also very common. ♦ Criterion 4: Public notification A large majority of the plans addressed this topic. All but two of the federal reports indicated that public notification would take place usually via press releases to local newspapers. Radio and signage were other methods mentioned. The majority of the reports from other agency types address this criterion as well. ♦ Criterion 5: Air quality monitoring A large majority of the plans addressed this topic. All but two of the federal reports indicated that air quality monitoring would take place. The most common form of monitoring for all agency types was visual monitoring, except for the state reports in which instrument monitoring was mentioned. ♦ Criterion 6: Predetermined trigger points For about half the federal reports the most common trigger point was smoke hitting a major roadway within the vicinity of the burn. Other agency types tended to have very qualitative assessment points. ♦ Criterion 7: Predetermined contingency actions A large majority of the plans addressed this topic. Halting of ignition was the most common recommended action in federal reports while extinguishing the fire was more common for state reports. ♦ Criterion 8: Cooperation with downwind receptors Planned cooperation with downwind receptors was discussed in all but five of the operational plan for prescribed fire that were reviewed. ♦ Criterion 9: Coordination with other managers Planned coordination with other managers was discussed in approximately half of the operational plan for prescribed fire that were reviewed. ♦ Criterion 10: General Conformity in nonattainment areas All responses to this question were “not applicable” because none of the sites were in nonattainment areas. 15 3.2.2 Operational Plans for WFU A total of 5 operational plans for WFU were reviewed for the project. Only federal agencies make use of these types of plans. The results from the evaluations of operational plans for WFU are presented in Table 5. Generally speaking, the operational plans for WFU did not cover the evaluation criteria as well as prescribed fire (Table 5). There were not nearly as many plans to review, but at least one plan gave each topic at least some consideration. The following discusses findings relevant to each of the assessment criteria. ♦ Criterion 1: Estimation of emissions The wording of this criterion should be noted. There are a number of conditions that must all be true for an affirmative response to this criterion, and typically impacts to regional haze (or more) were not addressed. Therefore, none of the reports received an affirmative response when following the wording of the criterion. When the regional haze portion of the criterion is ignored (Table 5 Line 1a), there are two affirmative responses. Two of the reports indicated that emissions had been estimated as well as their effects on visibility, NAAQS, and nuisance. In one case SASEM had been run. Table 5. Affirmative Criterion Responses for Operational Plans for WFU Criteria Count Percent Agency Type Federal 1) estimation of emissions 1a) estimation of emissions, but ignoring regional haze portion 2) actions to minimize emissions 3) smoke dispersion evaluation 4) public notification 5) air quality monitoring 6) predetermined trigger points 7) predetermined contingency actions 8) cooperation with downwind receptors 9) coordination with adjacent and downwind land managers Number of Plans 0 0 2 40 2 40 4 80 5 4 100 80 1 20 2 40 3 60 4 80 16 5 ♦ Criterion 2: Actions to minimize emissions Two reports discussed actions to minimize emissions. ♦ Criterion 3: Smoke dispersion evaluation The majority of the reports addressed smoke dispersion. Wind speed and direction and the use of other meteorological data were the most common methods. ♦ Criterion 4: Public notification All of the reviewed plans indicated that public notification would take place through various types of media. ♦ Criterion 5: Air quality monitoring Four of the five reports indicated that air quality monitoring would take place. The most common type of monitoring was visual. ♦ Criterion 6: Predetermined trigger points Only one report addressed trigger points. ♦ Criterion 7: Predetermined contingency actions Two reports addressed contingency actions such as stopping ignitions. ♦ Criterion 8: Cooperation with downwind receptors Three reports addressed planned cooperation with downwind receptors. ♦ Criterion 9: Coordination with other managers Four reports addressed planned coordination with other managers. 3.2.3 Operational Plans for WFSA A total of 7 operational plans for WFSA were reviewed for the project. Only federal agencies make use of these types of plans. The results from the evaluations of operational plans for WFSA are presented in Table 6. Generally speaking, the operational plans for WFSA did not cover the evaluation criteria as well as either prescribed fire or WFU. This is likely a function of WFSAs being nearly “after the fact” plans where the fire is already burning before the WFSA process begins. The following discusses findings relevant to each of the assessment criteria. ♦ Criterion 1: Estimation of emissions The wording of this criterion should be noted. There are a number of conditions that must all be true for an affirmative response to this criterion, and typically impacts to regional haze (or more) were not addressed. Therefore, none of the reviewed plans received an 17 affirmative response when following the wording of the criterion. When the regional haze portion of the criterion is ignored (Table 6 Line 1a), there is one affirmative responses. One of the WFSA documents mentioned estimated emissions. ♦ Criterion 2: Actions to minimize emissions Few of the plans mentioned this. Most typically, the fundamental emissions control action is to put the fire out as quickly as possible. One plan mentioned that safety and suppression were the priorities. ♦ Criterion 3: Smoke dispersion evaluation One of the WFSA documents mentioned this. Table 6. Affirmative Criterion Responses for Operational Plans for WFSA Criteria Count Percent Agency Type Federal 1) estimation of emissions 1a) estimation of emissions, but ignoring regional haze portion 2) actions to minimize emissions 3) smoke dispersion evaluation 4) public notification 5) air quality monitoring 6) predetermined trigger points 7) predetermined contingency actions 8) cooperation with downwind receptors 9) coordination with adjacent and downwind land managers Number of Plans 0 0 1 14 2 29 1 14 4 1 57 14 1 14 0 0 1 14 1 14 7 ♦ Criterion 4: Public notification About half of the plans mentioned this, the other half did not. ♦ Criterion 5: Air quality monitoring 18 Only one plan mentioned any kind of air monitoring. ♦ Criterion 6: Predetermined trigger points One plan described a rather qualitative trigger; if smoke becomes noticeable in an adjacent area. ♦ Criterion 7: Predetermined contingency actions One of the WFSA documents mentioned this. ♦ Criterion 8: Cooperation with downwind receptors One of the plans discussed this criterion. One plan seemed to indicate there would be communication only if complaints were received. ♦ Criterion 9: Coordination with other managers One of the WFSA documents mentioned this. 3.2.4 Implementation of Prescribed Fire A total of 15 reports detailing the implementation of operational plans for prescribed burns were reviewed for the project, and plans were received from three of the five agency categories. The results from the evaluations of operational plans for WFSA are presented in Table 7 and graphed in Figure 2. The majority of these reports (13) were received from federal agencies, although it should be noted that these were not truly “reports” but rather collections of information. These reports were often a collection of individual documents obtained from a number of sources including air agencies, smoke management programs, and district and regional offices. In cases where adverse smoke impacts occurred as a result of a fire, the post-burn report can be voluminous, but in most cases the reports were brief and often incomplete with respect to the assessment criteria. Only Criterion 1 exceeded 50% in coverage. Most of the non-federal reports gave next to no consideration to the evaluation criteria, and usually the documentation was quite thin. The following discusses findings relevant to each of the assessment criteria. ♦ Criterion 1: Avoided smoke effects The majority of reports indicated that there was no smoke effect because of good dispersion; the others (from all agency categories) were silent on the topic. ♦ Criterion 2: Unfavorable smoke effects Two federal reports mentioned that there were effects. None of the other reports mentioned this topic. ♦ Criterion 3: Verified public nuisance complaints 19 Three federal reports addressed the topic by indicating there had been complaints. None of the other reports mentioned this topic. Table 7. Affirmative Criterion Responses for Implementation of Prescribed Fire Percent 1 100 1 100 9 0 0 0 0 2 69 15 0 0 0 0 5 38 0 0 0 0 0 0 0 0 0 0 5 38 0 0 1 100 6 46 0 0 0 0 1 8 0 0 0 0 4 31 0 0 0 0 4 31 0 0 1 100 5 38 0 0 0 15 1 0 Count Percent 1) avoided smoke effects 2) unfavorable smoke effects 3) verified public nuisance complaints 4) air quality citations 5) contacts made with downwind receptors 6) smoke management elements of burn plan implemented 7) contingency actions taken as a result of air quality impacts 8) public notification and exposure reduction 9) compliance with air quality laws 10) air quality monitoring plan followed 11) actions taken to avoid smoke impacts Number of Plans 1 Count Criteria Count Percent Agency Type Private Local Federal 2 13 ♦ Criterion 4: Air quality citations One of the federal reports indicated that a citation had been issued, but it was later rescinded upon further investigation. That was the only mention of the topic. ♦ Criterion 5: Contacts made with downwind receptors Most of the operational plans indicated that this would be done during the burn. If this was executed during implementation, it was not well documented in most of the reports. ♦ Criterion 6: Smoke management elements implemented The local agency report seemed to indicate that this was done. A few federal reports indicated that this was done, while most of the reports were silent on the topic. One federal report seemed to indicate that the data specified in the operational plan was not all collected during the burn. The private agency report did not mention the topic. 20 Figure 2. Results from Implementation of Prescribed Fire 1. Avoided smoke effects 2. Unfavorable smoke effects 3. Verified public nuisance complaints Criteria 4. Air quality citations 5. Contact downwind receptors 6. Smoke management implemented 7. Contingency actions taken 8. Public notification 9. Compliance with air quality laws 10. Air quality monitoring followed 11. Actions to avoid smoke impacts 0 20 40 60 80 100 Affirmative Responses (%) Private Local Federal ♦ Criterion 7: Contingency actions For one federal burn, new ignitions were halted. No other such actions were mentioned. ♦ Criterion 8: Public notification Again, if this was executed during implementation, it was not well documented in most of the reports. ♦ Criterion 9: Compliance with air quality laws The reports typically did not discuss their status with this criterion. ♦ Criterion 10: Air quality monitoring The majority of reports did not contain data showing this was done. It is possible monitoring was performed but was not provided in the data package. ♦ Criterion 11: Actions taken to avoid smoke impacts 21 Very few of the documented burns needed to act to reduce smoke (water drops, reduce fuel consumed, etc.). This complements Criterion 1 where good smoke dispersion was typically reported. 3.2.5 Implementation of WFU A total of four reports detailing the implementation of operational plans for WFU were reviewed for the project. The results from the evaluations of operational plans for WFU are presented in Table 8. Table 8. Affirmative Criterion Responses for Implementation of WFU Criteria Count Percent Agency Type Federal 1) avoided smoke effects 2) unfavorable smoke effects 3) verified public nuisance complaints 4) air quality citations 5) contacts made with downwind receptors 6) smoke management elements of burn plan implemented 7) contingency actions taken as a result of air quality impacts 8) public notification and exposure reduction 9) compliance with air quality laws 10) air quality monitoring plan followed 11) actions taken to avoid smoke impacts Number of Plans 1 2 25 50 2 50 0 0 4 100 3 75 1 25 4 100 2 50 3 75 1 25 4 These reports were available only from federal agencies. Again, these were not truly “reports” but often just collections of information. These post-burn reports may include information on how the burn was actually accomplished, tons of fuel actually burned, smoke complaints (if any) received, plume transport and other information detailing what actually happened during the burn. These reports were often a collection of individual documents obtained from a number of sources including air agencies, smoke management programs, and district and regional offices. The reports tended to be brief and often incomplete with respect to the assessment criteria. There were few reports available for 22 review, and the results were inconsistent (Table 8). The following discusses findings relevant to each of the assessment criteria. ♦ Criterion 1: Avoided smoke effects Two burns had poor dispersion and some smoke effects, one had good dispersion and one did not mention the topic. ♦ Criterion 2: Unfavorable smoke effects Half the burns had effects from poor dispersion. ♦ Criterion 3: Verified public nuisance complaints Half the burns had some complaints, though these were not always the same burns as Criterion 2. ♦ Criterion 4: Air quality citations No citations were reported. ♦ Criterion 5: Contacts made with downwind receptors All the reports described contacting downwind receptors. ♦ Criterion 6: Smoke management elements implemented One burn did not document smoke modeling. Otherwise, the elements seemed to have been implemented. ♦ Criterion 7: Contingency actions In one case, any new fires were extinguished as a contingency action. ♦ Criterion 8: Public notification The reports indicated that this was done. ♦ Criterion 9: Compliance with air quality laws One burn report did not mention the topic. Another burn report did not show daily monitoring as recommended in the agency guidelines. ♦ Criterion 10: Air quality monitoring As with Criterion 9, one burn report did not show daily monitoring. ♦ Criterion 11: Actions taken to avoid smoke impacts An action was taken for one burn by removing vegetation on ridge tops. 23 3.3 Guidance Documents In total, 68 guidance documents were reviewed for the project: 25 local documents, 21 state-level documents including smoke management plans, and, 22 federal guidance documents. Table 9 and Figure 3 summarize the results of the assessment. Detailed findings for each guidance document are tabulated in Appendix C. Table 9. Affirmative Criterion Responses for Guidance Documents Count Percent Count Percent 1) categorical exclusions 2) non-burning alternatives 3) evaluation of air quality laws and rules including general conformity 4) estimation of air pollutants and visibility impacts 5) predetermined trigger points 6) contingency actions to be taken 7) coordination with adjacent and downwind land managers 8) cumulative effects of smoke Number of Documents Percent Criteria Count Agency Type Local State Federal 0 5 0 20 0 9 0 43 5 13 23 59 1 4 2 10 12 55 5 20 9 43 14 64 1 4 7 33 8 36 4 16 7 33 7 32 2 8 5 24 7 32 0 0 1 5 3 14 25 21 22 • Findings presented in Table 9 underscore the scarcity of General Conformity guidance in state or local-level documents relative to wildland fire use or agricultural burning. All of these documents do, however, address air quality regulatory requirements of state or local air agencies or districts. Most of the General Conformity guidance is found in documents drafted by federal agencies and about half of documents reviewed provide guidance on this issue. • Few of the documents discuss categorical exemptions within NEPA as applied to smoke effects. • About one-third of the federal and state guidance and fewer than 10% of the local documents define “trigger points” used to quantitatively determine when smoke impacts occur. In most of the guidance, smoke impacts that exceed NAAQS are the implied “trigger point” level, but in many cases the meaning of “smoke impact” is left undefined. • Guidance on the cumulative impacts of smoke when considered in combination with other point and area sources (including other burning activity) is either not generally 24 available or is treated only in very qualitative terms. Less than one-fifth of the federal guidance and none of the state or local guidance discuss this issue. While many smoke management plans include centralized, daily burn authorization to coordinate burning activity and collectively minimize smoke effects on visibility and NAAQS, few of these programs also coordinate with WFU or agricultural or general open burning activity. Guidance on quantitative assessment of cumulative impacts of smoke is in the realm of regional transport modeling, not the practitioner guidance/air quality regulations reviewed here. Fire practitioners are typically concerned about smoke effects from the single fire they are responsible for managing rather than the broad-scale cumulative effects of smoke. Figure 3. Results from Evaluation of Guidance Documents 1. Categorical Exclusions 2. Non-burning Alternatives 3. AQ Laws & Conformity Criteria 4. Estimate Pollutant. & Visibility 5. Trigger Points 6. Contingency Actions 7. Downwind Coordination 8. Cumulative Effects of Smoke Federal State Local 0 20 40 60 80 100 Affirmative Responses (%) • Local guidance documents generally consisted of open burning permit requirements that are intended to minimize the nuisance effects of smoke, regulate the kinds of materials burned and fire hazard issues, only. As a result, much of the local guidance/air quality regulations reviewed dealt only with compliance with county or district air quality rules and regulations. Many of the criteria assessed here do not apply to these documents. • Private landowners and tribal entities commonly use federal and state guidance documents in their fire use programs. We were unable to identify or obtain any smoke management (or any other guidance documents) from tribal entities for this assessment. 25 Nationally, there are no adopted Tribal Implementation Plans, so none could be reviewed. 3.3.1 Federal Guidance Documents In overview, the federal guidance documents provided the best and most thorough discussion of air quality-smoke effect issues. Many of these documents are widely used by fire practitioners and air quality regulators, nationwide and cover a wealth of technical, policy, fire planning and regulatory issues that apply to most forestland managers. Since federal guidance documents focus on national issues that apply to federal land managers, discussions of matters of more local significance, such as fire permit authorization, are not generally included in these documents. In response to new air regulatory requirements, National Wildfire Coordinating Group (NWCG) Smoke Management Guide has greatly expanded sections on regional haze, visibility, emission reduction methods and nonburning alternatives. NWCG provides both guidance and training materials. 3.3.2 State Guidance Documents Documents in this category include the state smoke management plans for both wildland fire and agricultural burning. They describe air quality rules and regulations, programs and policies that apply to wildland fire, agricultural, and open burning. They also provide useful information and describe services to fire practitioners that help minimize emissions and smoke impacts, including meteorological forecasting. They do not address issues of special significance to Federal Land Managers such as NEPA categorical exclusions. As noted in Table 9, about one-quarter of the state guidance documents reviewed included coordination with downwind agencies and the public, as this is a common element of smoke management plans. About one-third included either a requirement that contingency actions be specified in the burn plan in the event of smoke impacts or that actual measures to be taken are identified. 3.3.3 Local Guidance Documents The local-scale guidance, as noted above, is almost solely limited to local air quality open burning and, in a few cases, smoke management programs adopted by local air quality agencies and districts. With the exception of the smoke management plans adopted by county and district-level agencies, the majority of these documents describe procedures for issuance of open burn permits, coordination with fire protection agencies and reporting requirements. 3.3.4 Review of the Assessment Criteria The following discusses findings relevant to each of the assessment criteria. ♦ Criterion 1: NEPA Categorical Exclusions Of the 22 federal guidance or air quality regulations reviewed, very few provided any guidance on NEPA categorical exclusions. The most extensive discussion was found in the National Park Service National Director’s Guidance 12: NEPA and in the BLM Land Use Planning Handbook H-1601. The US Forest Service guidance “Describing Air Resource Impacts of Prescribed Fire Projects in NEPA documents” is also useful. No other documents 26 were found that addressed the topic. None of the state or local-level guidance documents addressed this issue. ♦ Criterion 2: Non-Burning Alternatives Consideration of non-burning alternatives in the prescribed fire/WFU planning process is a relatively new requirement of many state/local smoke management plans and as a result, newly published federal guidance documents now include more guidance on this topic. For example, the 1985 NWCG Prescribed Fire Smoke Management Guide had only brief mention of alternatives to fire while Chapter 8 of the new NWCG Smoke Management Guide 2001 Edition has extensive information of the subject. The discussions in state/local guidance documents and air quality rules are principally focused on their requirements for fire practitioners to consider and document non-burning alternatives to fire in the state/local smoke management programs and permitting process. ♦ Criterion 3: Air Quality Laws and General Conformity Most of the federal documents did discuss air quality laws, rules applicable to prescribed fire or WFU but few provided any guidance on General Conformity. Within the federal guidance category, the most extensive guidance is found in NWCG RX-450/410 training course materials and in Chapter 4 of the new NWGC Smoke Management Guide 2001 Edition. The EPA Interim Air Quality Policy outlines relatively new and groundbreaking policy with respect to wildland fire smoke impacts on air quality. The Policy recognizes the important role that fire plays in the ecosystems of the nation's forests while urging wildland managers to consider air quality impacts of fires and take steps to minimize these impacts, emphasizing consideration of alternative treatments rather than the use of fire. State and local regulations deal almost exclusively with applicable air quality regulations that apply to wildland and agricultural burning but exclude the issue of General Conformity. ♦ Criterion 4: Estimation of Pollutants and Visibility Effects Calculations of pollutant emissions are commonly required in state and local regulations but only 20% of the local and 43% of the state guidance or air quality regulations require estimation of both pollutant emissions and evaluation of the effect of these pollutants on Class I visibility. The federal guidance (Table 9) more commonly (about two-thirds) addresses both topics. In the case of state and local regulations, estimation of PM-10 emissions prior to unit ignition is required by the smoke management plans. Some also require SASEM modeling but none of the guidance reviewed require modeling of smoke effects on Class I visibility. Most smoke management plans do, however, strive to protect Class I area visibility through meteorological forecasting and burn scheduling. Again, the NWCG Smoke Management Guide provides the most up-to-date guidance on emission estimates (Chapter 11) and visibility effects (Chapter 3). ♦ Criterion 5: Evaluation of Predetermined Trigger Points Clear definitions of “trigger points” that signal a smoke impact is unusual in local regulations (less than 10%). About one-third of the state air regulations and federal guidance documents use NAAQS exceedances as a benchmark of an unacceptable smoke impact. Only two of the guidance documents reviewed used a quantitative measure of extinction (light scattering) as a “trigger point” which, if exceeded, would require action to minimize fire emissions. None of the guidance documents reviewed adequately addressed 27 this issue. What constitutes a “trigger point” defining an unacceptable smoke impacts involves considerations of public nuisance, visibility impairment, possible human health effects and how regulatory agencies define a “significant contribution” to particulate matter under the NAAQS. ♦ Criterion 6: Contingency Actions About one-third of the state and federal documents reviewed either provided guidance on or required that contingency actions be taken in the event of a smoke impact. Less than one-fifth of the local air regulations required contingency plans to minimize emissions from a burn causing a smoke impact. In state and federal documents, which do include a required contingency action plan, the specific measures that must be taken are left to the fire practitioner managing the fire. The best and most current guidance is found in two documents. The NWCG Smoke Management Guide describes smoke management and emission reduction techniques, including rapid mop-up and fuels isolation. Section VI.C.3 of the EPA Interim Air Quality Policy on Wildland and Prescribed Burning provides a helpful list of contingency actions that can be taken to reduce public exposure to smoke. ♦ Criterion 7: Coordination with Downwind Agencies Again, federal guidance documents provide the best source of information on coordination measures to be taken with downwind air agencies, the media or the public. This coordination is usually done (if done at all) through the respective smoke management program. About one-third of the federal guidance specifically discussed this topic but only one-quarter of the state air regulations or smoke management plans reviewed required downwind coordination. Less than one-tenth of the local air regulations mentioned downwind coordination. Section 6.0 (Public Awareness) of the EPA BACM Technical Information Document provides helpful guidance on coordination with downwind agencies, the public and the burn community. ♦ Criterion 8: Evaluation of Cumulative Effects of Smoke Very little guidance on evaluation of the cumulative effects of smoke when considered in combination with other stationary and mobile sources of air pollution was found in the guidance reviewed. This topic was not addressed in any of the local guidance and in only one of the state-level documents. The best guidance was found in the NWCG Smoke Management Guide 2001 Edition, which discusses the role of smoke in regional haze, numeric models that may be used to evaluate visibility impacts of smoke on Class I areas and research activities. Comprehensive guidance on this topic is, however, beyond the scope of the documents reviewed here. 4.0 Summary The preceding section detailed the findings from the plan reviews performed for the project. For a number of reasons, there were some holes in the agency/plan type matrix. Some of the contacts did not respond in a timely fashion so their plans could not be included. Some of the contacts did not utilize certain plan types, so they had no plans to contribute to the project. Other contacts chose not to participate. While the number of plans reviewed for the project may have been less than originally envisioned, a number of plans and guidance documents were reviewed. 28 The preceding sections present few findings regarding tribal activities. This outcome appeared to have several contributors that were previously discussed. It would be incorrect to presume that the lack of numbers of tribal plans corresponds to a lack of involvement in smoke issues by tribal entities; rather, the project team had difficulty in acquiring plans. Several project objectives were listed in the Introduction. To summarize the overall project, the outcome for each objective is listed below. • Many of the agency contacts (i.e., non-federal) do not use programmatic plans, so they can not consider smoke effects in such plans. Those that do use programmatic plans showed mixed results regarding the evaluation criteria. • Just over half of the programmatic plans discussed non-burning alternatives. • Operational plans for prescribed fire (or its equivalent) were obtained from all five agency categories. Only federal agencies used WFU or WFSA as tools. Content and complexity of these plans was quite variable. The results regarding the evaluation criteria were somewhat mixed, but, in general, the plans addressed the criteria reasonably well. • Relatively few of the implemented plans showed smoke effects (of any kind) from the fires. • Guidance documents for programmatic and operational plan preparation were reviewed. The findings were that there was often incomplete or inconsistent guidance regarding the evaluation criteria. • Guidance documents for WFSA were reviewed. Again, the project review process tended to be generous. If a document discussed the topic of a criterion, even briefly, then credit was given for addressing the topic. The project team did not attempt to assess the thoroughness or adequacy of the criterion discussion, only its presence. This approach has the effect of painting a more optimistic picture of the comprehensiveness of the documents that were reviewed. 29 Appendices Appendix A: List of Plans Reviewed for Project Agency Type Agency Federal Region Plan Type Plan/Burn Name Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management AZ AZ AZ CO CO CO CO ID Implemented Rx Operational Rx WFSA Implemented Rx Operational Rx Programmatic Rx Programmatic WFU Programmatic Rx Bureau of Land Management Bureau of Land Management Bureau of Land Management MT MT MT Implemented Rx Operational Rx Programmatic Rx Bureau of Land Management MT Programmatic WFU Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management MT NV NV NV NV WFSA Implemented RX Operational Rx Programmatic Rx Programmatic WFU Sam Springs Sam Springs Mt. Emma Big Duck Lobo/China Wall Little Snake/Brown's Park Little Snake/Brown's Park Owyhee Resource Management Plan Elk Creek Elk Creek Missoula Field Office Fire Mgmt. Plan Elkhorn Wildland Fire Guidebook High Ore Road/Boulder Hill Stormy Stormy Elko Fire Management Plan Elko Fire Management Plan Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management OR OR UT UT UT Operational Rx Programmatic Rx Implemented Rx Operational Rx Programmatic Rx Bureau of Land Management Bureau of Land Management Bureau of Land Management Bureau of Land Management National Park Service National Park Service National Park Service UT WY WY WY Intermountain Intermountain Intermountain WFSA Implemented Rx Operational Rx Programmatic Rx Implemented WFU Operational WFU Operational Rx National Park Service National Park Service National Park Service National Park Service National Park Service National Park Service National Park Service National Park Service National Park Service National Park Service Intermountain Intermountain Midwest Midwest Midwest Midwest Midwest Pacific West Pacific West Pacific West Programmatic Rx Programmatic WFU Implemented Rx Operational Rx Programmatic Rx Programmatic WFU WFSA Implemented Rx Operational Rx Programmatic Rx Brady Butte Lakeview RMP DEIS Dry Creek Dry Creek Cedar City Fire Management Plan Lydia's Canyon Sawmill Sawmill Kemmerer RMP-FEIS Langston Fire Complex Langston Fire Complex Loop Hazard Fuels Reduction Plan Unit 4 Pile Wildland FMP-Zion NP Wildland FMP-Zion NP Bison Flats Bison Flats Wind Cave NP FMP Wind Cave NP FMP Highland Creek East Buttress Meadow East Buttress Meadow Yosemite Fire Management Plan 1991 Agency Type Agency Region Plan Type Plan/Burn Name Federal National Park Service Pacific West Programmatic WFU U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service 1 1 2 2 2 Operational Rx Programmatic Rx Implemented Rx Operational Rx Programmatic Rx U.S. Fish and Wildlife Service 6 Implemented Rx U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service 6 6 6 1 1 1 1 1 1 2 2 2 2 3 3 3 3 3 Operational Rx Programmatic Rx Programmatic WFU Implemented WFU Operational WFU Operational Rx Programmatic Rx Programmatic WFU WFSA Implemented Rx Operational Rx Programmatic Rx Programmatic WFU Implemented Rx Implemented WFU Operational WFU Operational Rx Programmatic Rx U.S. Forest Service 3 Programmatic WFU U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service U.S. Forest Service 3 4 4 4 4 4 WFSA Implemented Rx Implemented WFU Operational WFU Operational Rx Programmatic Rx U.S. Forest Service 4 Programmatic WFU U.S. Forest Service U.S. Forest Service U.S. Forest Service 4 5 5 WFSA Operational Rx Programmatic Rx U.S. Forest Service 5 Programmatic WFU U.S. Forest Service 6 Operational WFU Yosemite Fire Management Plan 1991 Kern NWR Marsh Unit 1 Hart Mountain Buenos Aries Hill 1 Buenos Aries Hill 1 Buenos Aires NWR Fire Mgmt. Plan Ruppel Waterfowl Production Area (WPA) Fish Springs NWR Brown's Park Brown's Park Birk Fire Birk Fire South Fork Sun Burn Bitterroot NF FMP Bitterroot NF FMP Little Blue Polhemus Prescribed Burn Polhemus Prescribed Burn San Juan FMP San Juan FMP Water Canyon Bloodgood Complex Fire Bloodgood Fire Complex Water Canyon Gila NF Fire Management Plan Gila NF Fire Management Plan Homestead Gregory-Johnson Iron Creek Fire Iron Creek Fire Gregory-Johnson Bridger-Teton Forest Fire Management Plan Bridger-Teton Forest Fire Management Plan Sawyer Georgetown R2H2 Burn Sierra Nevada Forest Plan Amendment Sierra Nevada Forest Plan Amendment French Creek Agency Type Agency Region Plan Type Plan/Burn Name Local Boulder County Colorado Implemented Rx Boulder County Colorado Operational Rx Boulder County Jefferson County Colorado Oregon Programmatic Rx Operational Rx Missoula County Montana Operational Rx Pinal County Arizona Operational Rx San Joaquin Valley California Operational Rx San Joaquin Valley California Operational Rx Rabbit Mtn.-Little Thompson Overlook Rabbit Mtn.-Little Thompson Overlook General regulations Open Burning Permit, SMP, & Regulations Unified Outdoor Burning Permit Agricultural Open Burn Permit Nobe A Burn--Forest Service Hercules Restoration Burn-Park Service Albany Pine BushFirebrand Albany Pine Bush-Friendly General burn permit Woodland Park Section 16 Open Burn Permit Incline Village Yuma County Pest Control Field Burning Registration From & Rules 2001 USFS Region 1 permit Not specified Wagoner Toychet Farm Centennial Mountain Colville Integrated Resource Management Plan Private State Nature Conservancy Implemented Rx Nature Conservancy Plum Creek Timber Colorado State Forest Service Montana Division of Forestry Nevada Division of Forestry State of Arizona Ag State of Idaho Ag Operational Rx Operational Rx Operational Rx Operational Rx Operational Rx Operational Rx Operational Rx State of Montana Ag Operational Rx State of Oregon Ag State of Washington Ag Tribal Operational Rx Operational Rx Chippewa Cree Operational Rx Colville Programmatic Rx Confederated Appendix B: Guidance Documents Reviewed State/Local Open Burning and Smoke Management 1. California Rules & Regulations a. Smoke Management Guidelines for Agricultural & Prescribed Burning, Title 17 of the California Code of Regulations b. Northeast Air Alliance Smoke Management Plan for Butte, Lassen, Modoc, Plumas, Shasta, Siskiyou, Tehama. August 2000 c. Amador County Air Pollution Control District Open Burning Rules 306; Wildland Vegetation Management Burning Rule 308.1 and Forest Management Burning 309.1. d. Antelope Valley Air Pollution Control District Rule 444 Open Fires e. Bay Area Air Quality Management District Regulation 5 Open Burning f. Butte County Air Quality Management District Rule 300 Open Burning g. Colusa County Air Pollution Control District Rule VI Agricultural Burning h. Great Basin Unified Air Pollution Control District Rule 410 Forest Management Burning and Rule 411 Wildland Vegetation Management Burning in Wildland and Wildland/Urban Interface Areas. i. Mariposa County Air Pollution Control District Rule 307 Wildland Vegetation Management Burning j. Northern Sierra Air Quality Management District Rule 306 Forest Management Burning and 307 Wildlands Vegetation Management Burning. k. Placer County Air Pollution Control District Rule 316 Range Improvement /Forest Management Burning and 317 Wildland Vegetation Management Burning. l. Sacramento Air Quality Management District Rule 501 Agricultural Burning (includes forest management burning) m. San Joaquin Valley Unified Air Pollution Control District Rule 4106 Prescribed Burning and Hazard Reduction Burning. n. Shasta County Air Quality Management District Rule 2:6 Open Burning o. Siskiyou County Air Pollution Control District Rule 7 Open Burning p. South Coast Air Quality Management District Rule 444 Open Fires q. Tuolumne County Air Pollution Control District Rule 300 Open Burning r. Feather River Air Quality Management District Rule 2.17 Wildland Vegetative Management Burning. s. Calaveras County Air Pollution Control District Rule 300 Open Burning t. San Joaquin Valley Unified APCD Prescribed Burning MOU u. Proposed Amendments to California’s Agricultural Burning Guidelines. Staff Report. California Air Resources Board. February 2000. v. Sacramento Valley Smoke Management Program. Sacramento Valley Basinwide Air Pollution Control Council. June 15, 2001. 2. Montana a. Open Burning Rule 17.8 b. Missoula County Open Burning Rules Chapter 7 c. It’s Fall. Why Can’t I Burn? – Missoula County Health Department d. Montana – Idaho State Airshed Group Smoke Management Program 8/2001 3. Arizona a. Forest and Range Management Burns Chapter 2 Article 15 b. Smoke Management Plan Chapter 3 4. Colorado a. State Open Burning Procedure E008 b. Smoke Management Memorandum of Understanding Feb. 2001 c. Boulder County Health Department Air Quality/Prescribed Fire Guidance Document. March 1, 1999. d. Boulder County Health Department Open Burning Policy. Jan. 1, 2001 e. Desk Guide for CSFS Prescribed Fire Procedures 5. Nevada Smoke Management Plan 6. Wyoming Open Burning & Smoke Management Regulations: Chapter 10 7. Oregon a. Smoke Management Program, Administrative Rules & Directives b. Open Burning Rules Division 264 c. Willamette Valley Field Burning Permit Agent Manual. March 2001. 8. Utah a. Smoke Management Plan b. Utah DEQ Smoke Management Rule R307-204 9. Washington a. State Smoke Management Plan b. Agricultural Burning Best Management Practices, Permit and Focus Sheet 10. Alaska a. Open Burning Rules, Policy & Guidelines b. Open Burning Rule 18AAC50 11. New Mexico Smoke Management MOU Federal Guidance Documents, Training Materials & Laws 1. EPA Interim Air Quality Policy on Wildland and Prescribed Fires 2. NWCG Prescribed Fire Smoke Management Guide, 1985 3. EPA Prescribed Burning Background and Technical Information Document for Prescribed Burning Best Available Control Measures 4. USDI Bureau of Land Management Handbook H-1601-1 5. USDI National Park Service Director’s Order #18: Wildland Fire Management 6. USDI National Park Service Director’s Order #12: NEPA 7. US Fish & Wildlife Service Part 621 Fire Management – Prescribed Fire 8. Clean Air Act – Title I: Part A Air Quality and Emission Limitations Sec. 101-131 9. Clean Air Act – Title I: Part C Prevention of Significant Deterioration Sec. 160-169; Subpart 2, Sec. 169A and 169B 10. Clean Air Act – Title I, Part D, Sec. 176c Conformity 11. CFR Title 40, Part 51 Subpart P Protection of Visibility 12. USDI Bureau of Land Management Manual M-1601- Land Use Planning 13. USDA Forest Service Guidelines for Preparing a NEPA Air Quality Analysis 14. Describing Air Resource Impacts from Prescribed Fire Projects in NEPA Documents For Montana and Idaho in Region 1 and Region 4 15. Forest Service Manual 16. Forest Service Desk Guide for Integrating Air Quality and Fire Management into Land Management Planning--Draft 17. NWCG Smoke Management Techniques RX-450 Training Manual-Instructor’s Guide 18. USDA Forest Service Air Quality Conformity Handbook 19. USDA Forest Service Desk Reference for NEPA Air Quality Analysis 20. US Fish & Wildlife Service Fire Management Handbook 21. NWCG Smoke Management Guide for Prescribed and Wildland Fire 22. NWCG Wildland & Prescribed Fire Mgmt Policy Implementation Procedures Reference Guide Tribal Laws & Plans A number of potential sources were contacted in an effort to obtain information on tribal laws, programs and plans. Calls to EPA Regions 8, 9 and 10 indicated that (1) EPA could not provide Tribal Implementation Plans or relevant Federal Implementation Plans and (2) EPA could not provide tribal smoke management plans. Other calls to the White Mountain Apache Tribe, the Intertribal Forestry Council, the Institute for Tribal Environmental Professionals (ITEP) and BIA staff at the National Interagency Fire Center all failed to produce any guidance documents that (1) could be made available for review or (2) were in existence somewhere else. A study by ITEP (available on the WRAP website) indicated that 15 tribes have smoke management plans, but those tribes were not identified in the study. ITEP has been a tribal liaison for FEJF in the past, but ITEP was not able to provide the types of documents needed in the timeframe available for the project. Appendix C. Evaluation Results and Review Comments for Guidance Documents Guidance Type Agency Guidance Title Criterion 1 Response Comment State Criterion 2 Response Comment Criterion 3 Response Comment Page 1 Criterion 4 Criterion 5 Criterion 6 Criterion 7 Criterion 8 Response Comment Response Comment Response Comment Response Comment Response Comment No No No No No No No No No No No No. Burners must specify how public will be advise No No No No No No No No No No No No Alaska Department of Environmental Conservation Alaska Department of Environmental Conservation Open Burning Rule 18AAC50. Jan. 1997. No No No No No Guidance on open burning laws, only No No Alaska Department of Environmental Conservation Alaska Open Burning Policy and Guidelines No No No No No Conformity not mentioned No No Arizona Department of Environ. Quality Forest and Range Management Burns: Title 18, Chapter 2, Article 15 No No Yes R18-2-1509; Best Management Practices No Conformity not mentioned No No No No Arizona Department of Environ. Quality State of Arizona Smoke Management Plan: Title 18, Chapter 3. Dept. Env Qual. Article 15. No No Yes Under BMP requirements No Conformity not mentioned No Plan only requires that this be done No No California Air Proposed Resources Board Amendments to California's Agricultural Burning Guidelines: Staff Report. February 2000 No No Yes Page 19. Brief. No No. Conformity not discussed No No No No No No No No No No California EPA Title 17, California Code of Regulations Subchpt 2: Smoke Management for Agriculture & Rx Fire No No No No. If done, it must be attached to burn plan. No Conformity No Only with reference to NAAQS No No No No No No Colorado Department of Public Health Colorado Open Burning Rules Document E008. Nov. 24, 1995 No No No No No Conformity not mentioned No No No No No No No No Colorado Department of Public Health Colorado Smoke Management MOU. Jan 1, 2001 No No Yes Required. Form SMP-C Colorado State Forest Service Desk Guide for CSFS Prescribed Fire Procedures No State does not do NEPA Yes Montana Department of Environmental Quality State of Montana Open Burning Rule Chapter 8, Sub-Chapter 6 No No No No No Conformity not mentioned No No No No Montana/Idaho Airshed Group Montana/Idaho Airshed Group Operating Guide. Aug. 2001 No No No No. Encourages use of alternative methods No Conformity not mentioned No No No definition of "intrusion" provided Nevada Division of Environmental Protection Nevada Smoke Management Plan July 6, 1999 No No Yes Detailed description of alternatives required No Conformity not mentioned No Conformity guidance in Appendix F Yes Yes No No Yes NAAQS Yes Under BMP-Managing Smoke Impacts Yes SASEM modeling required; Yes NAAQS; <20 deciview Yes Required Yes Yes Yes Yes Distance from Class I & nonattainment areas Yes NAAQS Yes Public notification req'd. Agency contacts listed No No No No No No No No No No No No No No No No No No Yes Requires that such plans be identified by burners Yes Affected agency notification required No No Appendix C. Evaluation Results and Review Comments for Guidance Documents Guidance Type Agency State Local Guidance Title Criterion 1 Criterion 2 Response Comment Response Comment Criterion 3 Response Comment New Mexico Environment Department New Mexico Smoke Management MOU 1997-2002 No No No No No Conformity not mentioned Oregon Department of Environmental Quality Oregon Open Burning Rules Division 264 (Nov. 15, 2001) No No No No No Conformity not mentioned Oregon Department of Forestry Oregon Smoke Management Plan and Rules No No No No No Conformity not mentioned Oregon Dept. Agriculture Field Burning Permit Agent Manual: Willamette Valley, Oregon. March 2001 No No No No No No. Conformity not mentioned Utah Department of Environmental Quality Utah Emission Standards: Smoke Management. Rule 307-204. Sept 1, 2001 No No Utah Division of Air Quality Utah Smoke Management Plan 7/20/00 Rev. 3/23/00 No No Washington Department of Ecology Agricultural Burning Permit Application and Best Management No No Yes Growers reqd to evaluate No No mention of conformity Washington Department of Natural Resources Washington State Smoke Management Plan. Rev. 1995. No No Yes Alternative use required when possible No Conformity not mentioned Wyoming DEQ Wyoming Smoke Management Chapter 10 No No No No No Conformity not mentioned Amador County CA Amador County Air Pollution Control District Open Burning Rules No No No No Antelope Valley APCD Antelope Valley APCD Open Fires No No Bay Area AQMD Bay Area AQMD Open Burning Regulation 5 Boulder County Health Department Boulder County Health Department Yes Description required No No Yes R307-204-7(k) No Conformity not mentioned Page 2 Criterion 4 Response Comment Criterion 5 Response Comment Yes Emission calculations No No Yes Emission calculations No No Yes Emission calculations Yes Requires daily emissions estimates Criterion 6 Response Comment Yes NAAQS No No Yes Light scattering and visibility No No Yes NAAQS: Criterion 7 Response Comment Yes Managers must have contingency plans. No No Yes Directives Appendix 4 No No Yes Contingency plan required Criterion 8 Response Comment No No. Burners must notify local officials No No No No No No Yes No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No Conformity not mentioned No No No No No No No No No No No No No Conformity no referenced No No No No No No No No No No No No No No No Conformity No No No No No No No No No No Air Quality/Prescribed Fire Guidance Document No No Yes Brief No No No No Open Burning Policy No No No No No No No No No No Yes Requirements to calculate emissions No No discussion of conformity Yes Briefly No No No No Yes SASEM modeling required No No Yes Briefly No No Yes Public notification required No No Yes Yes Eastern Great Basin Coord Center does daily report No No No No Appendix C. Evaluation Results and Review Comments for Guidance Documents Guidance Type Agency Local Guidance Title Criterion 1 Criterion 2 Response Comment Response Comment Page 3 Criterion 3 Response Comment Criterion 4 Criterion 5 Criterion 6 Criterion 7 Criterion 8 Response Comment Response Comment Response Comment Response Comment Response Comment Butte County AQMD Butte County AQMD Open Burning Rule 300, 309 No No No No No Conformity No No No No No No No No No No Calaveras County APCD Calaveras County APCD Open Burning Rule 300 No No No No No Conformity No No No No No No No No No No Colusa County APCD Colusa County APCD Reguation VIAgricultural Burning Rule 6.18 & 6.19 No No No No No Conformity No No No No No No No No No No Feather River AQMD Feather River AQMD Open Burning Rule 2.17 & 2.8: Wildland Veg. & Range Burning No No No No No Conformity not mentoned No No No No No No No A notification procedure must be submitted No No Great Basin Unified APCD Great Basin Unified APCD Wildland Veg. Burning & Forest Management Burning Rules 410, 411 No No No Analysis must be attached to burn application No Conformity not mentioned No No No No No No No Public notification procedures need be submitted No No Mariposa County Mariposa County APCD APCD Rule307 Wildland Burning No No No No No Burn permit requirements. Conformity No No No No No No No No but procdures to distribute burn info is reqd No No Missoula County It's Fall: Why Can't I Health Dept. Burn? No No No No No No No No No No No No No No No No Missoula County Missoula County Open Health Dept. Burning Rules, Chapter 7 No No No No No Conformity not mentioned No No No No No No No No Northern Sierra AQMD No No No No No Permit requirements only. Conformity not mentioned No No No No No No No No No No Placer Cty APCD Placer County APCD Open Burning Rule 316 & 317 Wildland Fire and Veg. Management Rules No No No No No Burn permit requirments only No No No No No No No No No No Sacramento County AQMD Sacramento AQMD Agricultural Burning Rule 501 (Applies to forestry burning) No No No No No Requirements for OB Permit No No No No No No No No. Method of public notification must be specifid No No Sacramento Valley AQMD Sacramento Valley Smoke Management Program. June, 2001 No No No No No No No No No No No No No No No No San Joaquin APCD San Joaquin APCD Prescribed Burning Rule 4106 No No Yes Requires description of BACM considered No Burn plan requirements only but not conformity Yes Requries ID of smoke sensitive areas No No San Joaquin Valley Unified APCD San Joaquin Valley Unified APCD Prescribed Burning MOU (7/21/97 Draft) No No Yes BACM Workplan Sec.7 No Conformity not mentioned Yes Requries calculation of emissions No No Northern Sierra AQMD Open Burn Rules 300,306, 307 & 315 Yes NAAQS Yes Requires that contingencies be identified No No. Does require description of methods to be used Yes Requires description of public notification method No No No No No No Appendix C. Evaluation Results and Review Comments for Guidance Documents Guidance Type Agency Guidance Title Criterion 1 Response Comment Local Federal Criterion 2 Response Comment Page 4 Criterion 3 Response Comment Seven Air Districts in Northern CA Northeast Air Alliance Smoke Management Plan No No No No but requires an analysis be done Shasta County AQMD Shasta County AQMD Open & Ag. Burning Rules 2:6- No No Yes Evaluation of alternatives must be attached Siskiyou County APCD Siskiyou County APCD Open Burning Rule 7.1; 7.5 No No No No South Coast AQMD South Coast AQMD Open Fires Rule 444; Conformity Rule 1901 No No No No Tuolumne County APCD Tuolumne County APCD Open Burn Rule 300; Wilaland Veg. Management Burning Rule 307, No No No No Congress/EPA Clean Air Act Title 1 Part A: Air Quality and Emission Limititations Sectioins 101-131 No No Congress/EPA Clean Air Act Title 1 Part C Prevention of Significant Deterioration Sec. 160 - 169. Congress/EPA Criterion 4 Response Comment Criterion 5 Response Comment Criterion 6 Response Comment Criterion 7 Criterion 8 Response Comment Response Comment No No No No No No. Public notification procedures required No No No No No No but requires an estimate be submitted No No No Conformity not mentioned No No No No No Conformity not mentioned No No No No No No No No No No No No No Specs for disseminating project info is required No No No Conformity not mentioned No No No No No No No Specs. For disseminating project info required No No No No No This section does not include Conformity No No No No No No No No No No No No No No No Conformity not in this section of the CAA No No No No No No Clean Air Act Title 1 Part D Section 176c No No No No Yes Conformity section of the CAA No No No No No No Interagency NWCG Wildland & Prescribed Fire Mgmt Policy Implementation Procedures Reference No No National Wildfire Coordinating Group Prescribed Fire Smoke Management Guide, Feb. 1985 No No National Wildfire Coordinating Group Smoke Management Guide for Prescribed and Wildland Fire 2000 Edition (draft) No No Yes Extensive Yes Part I Sections 4.1 and 4.2 Yes National Wildfire Coordinating Group Smoke Management Techniques: RX-450 Instructor and Student Guides No No Yes Yes Yes US EPA 40 CFR Chapter 1, Subpart C, Part 51 Subpart P - Protection of Visibility No No Yes 51.309 (d) (6) (iii) Yes No No Yes Rule 1901. Applies to federal actions Yes PSD increments No No No No Yes No No No Nothing on Conformity Yes No No No Visibility Protection requirements, Excl Conform. Yes Yes Part I Section 3.3 No No Yes Sec. 51.301 definition of adverse impact No No but requires contingencies be identified Yes Contingency action must be described Yes No No Yes Requires a procedure to disseminate project info. Yes No No Yes Yes Yes Yes Yes General requirements of No No No No Yes If applicable to prescribed fire No No No No No Yes No No No No Appendix C. Evaluation Results and Review Comments for Guidance Documents Guidance Type Agency Guidance Title Criterion 1 Response Comment Federal US EPA Interim Air Quality Policy on Wildland and Prescribed Fires Criterion 2 Response Comment Page 5 Criterion 3 Response Comment Criterion 4 Response Comment Criterion 6 Response Comment No No No No US EPA OAQPS Prescribed Burning Sept 92 Background Document and Technical Information Document for Prescribed Burn BACM No No Yes Extensive US Fish and Wildlife Service Fire Management Policies and Responsibilities for Fire Managers Part 621 Chpt. 3 No No US Fish and Wildlife Service USFWS - Fire Management Handbook Yes Yes Yes Yes Yes USDA Forest Service A Desk Reference for NEPA Air Quality Analysis Yes Pg. 2-9. Refers to FSH 1909.15. Yes Pg. 3.1.2-7. Yes Page 2-6 to 2-8. Yes Chapter 3. Yes Page 2-14. USDA Forest Service Air Quality Conformity Handbook Yes Yes USDA Forest Service Describing Air Yes Resource Impacts from Prescribed Fire Projects in NEPA Documents for Montana & Idaho Yes Appendix A USDA Forest Service Guidelines for Preparing a NEPA Air Quality Analysis No Not directly. When NEPA anal. Is needed included. Yes Yes Conformity discussion included Yes Emissions calculations guidance USDA Forest Service USDA Forest Service Manual System 2580 & 5100 No No Yes Yes Yes Yes Yes Yes No USDA Forest Service Desk Guide for Integra- No ting Air Quality and Fire Management into Land Management Planning No Yes Yes No No No No USDI Bureau of Land Management USDI Bureau of Land Management Land Use Planning Handbook H-1601-1 USDI Bureau of Land Management USDI Bureau of Land Management Manual 1601: Land Use Planning USDI National Park Service NPS Director's Order 12: NEPA USDI National Park Service USDI National Park Service Director's Order #18: Wildland Fire Management. Nov. 17, 1998 No Yes Ref. Manual 516 DM2, App1 and 516 DM6 App 5.4 No No Yes Secs. 3.0 has an extensive discussion No No No Yes App C Page 9 No Conformity not specifically noted No Conformity not specifically addressed Yes No No Yes Fuels consumption and emission estimates Yes In State smoke management plan summaries No No No NAAQS implied Yes NAAQS No No Yes No No Yes Criterion 8 Response Comment Yes Brief description No Conformity Yes Briefly Criterion 7 Response Comment No No No No Yes Section IX A Criterion 5 Response Comment Yes Briefly in state smoke plan summaries No No Yes Briefly No No No No Yes Yes No No No No No No No No No No No No No No No No No No No Yes App. C Page 2 No No No No No No No No No No No No Yes Requires compliance with Fed., state, local regs. No No No No No No No No No No No No No Conformity not specifically noted No No No No No No No No No No No Item 10F requires air rule compliance No No No No No No No No No No Yes Item 10a describes mechanical treatment. Vs fire Appendix A-10b. EPA’s “Interim Air Quality Policy on Wildland and Prescribed Fires” Appendix A-10 –Fire Programs Arizona Regional Haze SIP INTERIM AIR QUALITY POLICY ON WILDLAND AND PRESCRIBED FIRES April 23, 1998 TABLE OF CONTENTS I. PURPOSE II. SCOPE AND APPLICABILITY III. BACKGROUND A. Role of Fire in the Wildland ...................................... 3 B. Changes in Fire Management Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 C. Air Quality Considerations ...................................... 5 D. Visibility Impairment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 IV. DESCRIPTION OF POLICY 7 V. COLLABORATION AMONG LAND AND AIR QUALITY MANAGERS . . A. Land and Vegetation Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 2. B. ........................................ 1 ......................... 2 ........................................... ................................ Alternative Treatments 9 a. Utilization and mechanical treatments b. Chemical treatments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 c. Fire treatments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Role of Federal Land Managers (FLM’s) ............... 3 ..................... a. Federal land use and fire management planning b. Evaluating environmental impacts 10 11 ......... 11 ..................... 13 3. Role of State and Other Public Land Managers 4. Role of Private Land Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 5. Role of Indian Land Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 6. Role of Air Quality Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Air Quality Management ............... 14 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 1. Role of State/Local Air Quality Managers ..................... 16 2. Role of Tribal Air Quality Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 3. Role of Public Land Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 i VI. SMOKE MANAGEMENT PROGRAMS (SMP’s) . . . . . . . . . . . . . . . . . . . . . A. Authorization to Burn B. Minimizing Air Pollutant Emissions C. Smoke Management Components of Burn Plans 17 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 ..................... 1. Actions to Minimize Emissions 2. Evaluate Smoke Dispersion 3. Public Notification and Exposure Reduction Procedures 4. Air Quality Monitoring 20 . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 ......... 21 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 D. Public Education and Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 E. Surveillance and Enforcement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 F. Program Evaluation G. Optional Air Quality Protection VII. ACCOUNTABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 ............................................. 24 A. B. Role of State/Tribal Air Quality Managers 1. Wildfires 2. Fires Managed for Resource Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Role of the Environmental Protection Agency 1. Impacts with a SMP 2. Impacts without a SMP 3. Interstate Transport of Smoke ..................... 25 ..................... 26 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 C. Role of Wildland Owners/Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 VIII. DATA ON WILDLAND AND PRESCRIBED FIRES IX. MEETING OTHER CLEAN AIR ACT REQUIREMENTS A. Demonstrate Conformity of Federal Activities B. Visibility/Regional Haze Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 C. Prevention of Significant Deterioration . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 DEFINITIONS ............... 28 ......... 30 ..................... 30 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 ii LIST OF WHITE PAPERS AVAILABLE ON THE WORLD WIDE WEB Background on the Role of Fire What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can Land Management Goals Still Be Met? Air Monitoring for Wildland Fire Operations Emissions Inventories for SIP Development Estimating Natural Emissions From Wildland and Prescribed Fire iii I. PURPOSE This policy statement has been prepared in response to plans by some Federal, tribal and State wildland owners/managers to significantly increase the use of wildland and prescribed fires to achieve resource benefits in the wildlands.1 Many wildland ecosystems are considered to be unhealthy as a result of past management strategies. The absence of fire effects has allowed plant species (e.g., trees and shrubs) that would normally be eliminated by fires to proliferate, vegetation to become dense and insect infestations to go unchecked. Wildland owners/managers plan to significantly increase their use of fires to correct these unhealthy conditions and to reduce the risk of wildfires to public and fire fighter safety. The largest increases are expected mainly on Federal lands in western States in ecosystems where fires would naturally occur every few years (35 years or less) if not suppressed. Fire has continued to be a management tool used by many public and private wildland owners/managers in the southeastern States. However, Federal land managers in the southeast also plan to significantly increase their use of fire above current annual levels. This policy statement integrates two public policy goals, (1) to allow fire to function, as nearly as possible, in its natural role in maintaining healthy wildland ecosystems, and (2) to protect public health and welfare by mitigating the impacts of air pollutant emissions on air quality and visibility. This document provides guidance on mitigating air pollution impacts caused by fires in the wildlands and the wildland/urban interface. It identifies the responsibilities of wildland owners/managers and State/tribal air quality managers to work together to coordinate fire activities, minimize air pollutant emissions, manage smoke from wildland and prescribed fires managed for resource benefits, and establish emergency action programs to mitigate the unavoidable impacts on the public. This policy is not intended to limit opportunities by private wildland owners/ managers to use fire so that burning can be increased on publicly owned wildlands. Thoughtful use of fire by private, public and Indian wildland owners/managers within SMP’s is promoted to maintain healthy wildland ecosystems. Neither is this policy intended to 1 This document contains EPA policy and, therefore, does not establish or affect legal rights or obligations. It does not establish a binding norm and it is not finally determinative of the issues addressed. In applying this policy in any particular case, the EPA will consider its applicability to the specific facts of that case, the underlying validity of the interpretations set forth in this memorandum, and any other relevant considerations, including any that may be required under applicable law and regulations. imply that States/tribes should relax existing SMP’s or limit a State’s/tribe’s ability to regulate fires managed for resource benefits. The EPA used a deliberative process involving a multi-stakeholder workgroup to develop recommendations for this policy. The workgroup did not reach consensus on all of the issues raised. The EPA addressed all of the recommendations and concerns raised by the stakeholders to the extent possible. The multi-stakeholder workgroup also produced several “white papers” on a number of topics previously identified in earlier drafts of the policy as Appendices to the policy. These papers will be published as a separate document and can also be found on EPA’s TTN2000 website: http://134.67.104.12/html/o3pmrh/pbissu.htm, and on the Western States Air Resources Council (WESTAR) website: http://www.westar.org/proj_frame.html. A list of these papers is provided in the Table of Contents. II. SCOPE AND APPLICABILITY The EPA does not directly regulate the use of fire within a State or on Indian lands. The EPA’s authority is to enforce the requirements of the CAA. The CAA requires States and tribes to attain and maintain the NAAQS adopted to protect public health and welfare. This policy recommends that States/tribes implement SMP’s to mitigate the public health and welfare impacts of fires managed for resource benefits. While SMP’s will also mitigate nuisance smoke intrusions, nuisance issues have been left for the individual air quality agencies to address. This policy applies to all wildland and prescribed fires managed to achieve resource benefits on public, Indian and privately owned wildlands, regardless of the cause of ignition (e.g., lightning, arson, accidental, land management decision, etc.) or purpose of the fire (e.g., natural, resource management, hazard reduction, etc.). Federal land management agencies sometimes manage naturally ignited fires to achieve resource benefits. Planning for naturally ignited fires is obviously limited, but the agencies require fire management plans to be included in land use plans for an area before a naturally ignited fire can be managed for resource benefits. Fires ignited in areas without fire management plans are 2 unwanted or wildfires. The interface between this policy and the Natural Events Policy2 regarding ambient PM10 concentrations caused by wildfires is addressed in section VII. This policy does not apply to other open burning activities, such as burning at residential, commercial or industrial sites; open burning of land clearing waste or construction debris. It also does not apply to open burning of agricultural waste, crop residue or land in the USDA Conservation Reserve Program. The EPA is working with the USDA Agriculture Air Quality Task Force to develop equitable policies for emissions from activities that could be classified as agricultural burning. This policy addresses the impacts of air pollutant emissions from fires managed for resource benefits on public health and welfare. The primary indicators of public health impacts used are ambient air quality impacts above the NAAQS for fine particles with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM2.5), and particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers (PM10). There are both 24hour (daily) and annual NAAQS for PM2.5 and PM10. Emissions of nitrogen oxides (NOx ), VOC, and CO from fires can also impact the NAAQS for NO2, O3, and CO. However, the actions required to reduce VOC and CO emissions are the same as those recommended in this document to mitigate impacts on the PM2.5, and PM10 NAAQS. Emissions of NOx, on the other hand, can increase under some of the burning conditions used to decrease emissions of other pollutants. The effects of fire emissions on the public welfare aspects of the NAAQS for PM are addressed in terms of visibility impairment and regional haze. The policy also addresses the treatment of fire emissions to meet other CAA requirements, such as prevention of significant deterioration (PSD) and conformity with SIP’s or TIP’s. III. BACKGROUND A. The Role of Fire in the Wildlands The role of fire in North American ecosystems has been undergoing change since people began to play a more active role in managing their natural resources. Native Americans actively used fire to alter vegetative patterns, to ease travel, or for hunting purposes. Prior to European 2 See memorandum from Mary D. Nichols, Assistant Administrator for Air and Radiation to EPA Regional Offices titled Areas Affected by PM10 Natural Events, May 30, 1996. 3 settlement, fire played a natural role as a necessary disturbance phenomena, keeping fuel density in check as well as insects and the diseases they carry, thereby maintaining North American wildlands in a healthy state. After European settlement and the introduction of grazing herds of cattle and sheep, and the practice of fire suppression, public land management agencies have recognized that not allowing fire to play its natural role in our wildlands has had unintended negative effects. When forests and grasslands are not allowed to burn naturally (lighting serving as the principal source of ignition) the result can be heavy accumulation of dead vegetation which provides fuel for unwanted fires (wildfires). Because of this unhealthy build-up of fuels, the risk of catastrophic wildfires is much greater as evidenced by several recent fires in our national forests and other publicly owned lands. These fires put firefighters and the general public in danger while destroying millions of acres of forests and costing millions of dollars to suppress. The lack of fire also has unintended ecological effects, leading to the loss of habitat for rare species and the decline of ecosystems. Fire exclusion can lead to an alteration in natural community types, and an important loss of biodiversity. Many plant and animal species are on the decline because they exist in fire-dependent habitats that haven't burned in decades. This situation has led to a rethinking of Federal land management and fire management policy. B. Changes in Fire Management Policy In 1995, a Federal Wildland Fire Management Policy and Program Review was conducted in response to the unhealthy condition of our public wildlands, and the increase in unplanned fires that occurred in 1987, 1988, 1992 and again in 1994. As a result of this review, the five principal Federal fire/land management agencies [the Forest Service (FS) under the Department of Agriculture; and the Bureau of Land Management (BLM), National Park Service (NPS), Fish and Wildlife Service (FWS), and the Bureau of Indian Affairs (BIA) under the DOI] agreed on need for several changes to existing fire/land management practices. Their recommendations include the reintroduction of fire (allowing it to play its natural role) into Federal land management programs in “an ongoing and systematic manner, consistent with public health and environmental quality considerations.” The goals of this change in land management policy are to reduce unnatural fuel densities that contribute to increasing unplanned fire hazards, and to restore wildland ecosystems to their healthy natural states. The Federal agencies previously mentioned 4 began increasing the use of fire in their most vulnerable wildlands in 1997. Annual treatment targets for all Federal land management agencies will be increased to more than 5 million acres per year by 2005. C. Air Quality Considerations Burning wildland vegetation causes emissions of many different chemical compounds such as small particles, Nox, CO and organic compounds. The components and quantity of emissions depends in part on the types of fuel burned, its moisture content, and the temperature of combustion. Complex organic materials may be absorbed into or onto condensed smoke particles. Tests indicate that, on average, 90 percent of smoke particles from wildland and prescribed fires are PM10, and 70 percent are PM 2.5. Historically, EPA’s NAAQS for PM have tended to focus emission control efforts on “coarse” particles--those larger than PM 2.5. Before 1987, EPA’s PM standards focused on “Total Suspended Particles,” including particles as large as 100 micrometers in diameter. The EPA revised the standards in 1987 to focus control on PM10 in response to new science showing that it was the smaller particles capable of penetrating deeply into the lungs that were associated with the most adverse health effects. For comparison, a human hair is about 70 micrometers in diameter. The most recent review of health studies focused attention on the need to better address the “fine” fraction particles - PM2.5. These more recent studies provide consistent and coherent, “evidence that serious health effects (mortality, exacerbation of chronic disease, increased hospital admissions, etc.) are associated with exposures to ambient levels of PM found in contemporary urban airsheds even at concentrations below current U. S. PM standards” (Criteria DocumentU.S. EPA 1996a, p. 13-1). PM concentrations currently found in many communities are associated with adverse health effects in the general population, including increased mortality and morbidity, altered lung function, increased respiratory symptoms, aggravated respiratory and cardiovascular disease. Sensitive sub-populations, such as children, the aged and those with existing cardiopulmonary or infectious respiratory disease, may experience effects at lower levels of PM than the general population, and the severity of effects might be greater. These studies are the basis for the July, 1997 promulgation of new NAAQS for PM2.5 , which are designed to 5 protect public health, with an adequate margin of safety. Fine particles are also a major cause of visibility impairment in such places as national parks that are valued for their scenic views and recreation. D. Visibility Impairment Visibility conditions are affected by scattering and absorption of light by particles and gases. The fine particles most responsible for visibility impairment are sulfates, nitrates, organic compounds, soot and soil dust. Fine particles are more efficient per unit mass than coarse particles at scattering light. Light scattering efficiencies also go up as humidity rises, due to water adsorption on fine particles, which allow the particles to grow to sizes comparable to the wavelength of light. There are distinct regional variations in visibility between eastern and western States, due, to generally higher relative humidities in the East. Naturally occurring visual range in the East may be between 105 to 190 kilometers, while natural visual range in the West is between 190 to 270 kilometers. Visibility is an important public welfare consideration because of its significance to enjoyment of daily activities in all parts of the country. Protection of visibility as a public welfare consideration is addressed nationally through the secondary PM NAAQS which are equivalent to the primary PM NAAQS. Visibility protection is particularly important in the 156 mandatory Class I Federal areas, “Areas of Great Scenic Importance,” and is addressed for these areas by the special provisions of Sections 169A and 169 B of the CAA. The effects of smoke from wildland and prescribed fires on air quality will be discussed throughout this document. The term air quality, as used in this document, refers to ambient concentrations of pollutants (primarily PM in locations accessible to the general public), and, where applicable, to impacts on visibility in mandatory Class I Federal areas. Thus, wherever this document discusses the need for wildland owners/managers to consider the impacts of their actions on air quality, this may include consideration of the effects of their actions on visibility in mandatory Class I Federal areas. Existing requirements to consider effects on visibility which are reasonably attributable to a single nearby source or small number of sources are contained in the regulations published by EPA in 1980 at 40 CFR 51.300 (Protection of Visibility). Additional regulations are currently 6 being developed to address impairment of visibility that is more regional in its character and origins (“regional haze”). This interim policy may be revised to be made consistent with the regional haze rules when they become final. Please refer to the white paper, “Background on the Role of Fire,” for more complete background information. See Section I to obtain a copy. IV. DESCRIPTION OF POLICY The EPA’s policy regarding wildland and prescribed fires managed for resource benefits is that owners/managers of public, private and Indian wildlands should collaborate with State/tribal air quality managers (air regulators) to achieve their goals of: (1) allowing fire to function in its natural role in the wildlands, and (2) protecting public health and welfare by minimizing smoke impacts. The EPA urges air quality managers to participate in public land use planning activities which involve selecting appropriate resource management treatments, including the use of fire, and to help identify air quality criteria for fire management plans. Air quality managers are urged to help evaluate the potential impacts of alternative resource treatments and assure that air quality concerns (also visibility and regional haze concerns, where appropriate) are adequately addressed in the public land use planning process. They are urged to solicit information from private and Indian wildland owners/managers on plans to use fire for resource management, to encourage them to consider appropriate alternative treatments, and to assist them in evaluating the potential air quality impacts of alternatives to meet particular management objectives. Wildland owners/managers are urged to: (1) notify air quality managers of plans to significantly increase their future use of fire for resource management, (2) consider the air quality impacts of fires and take appropriate steps to mitigate those impacts, (3) consider appropriate alternative treatments, (4) and participate in the development and implementation of State/tribal SMP’s. The EPA will allow States/tribes flexibility in their approach to regulating fires managed for resource benefits. They are not required to change their existing fire regulations if those regulations adequately protect air quality. However, there are incentives for States/tribes to certify to EPA that they have adopted and are implementing a SMP that includes the basic components identified in this policy. The main incentive is that, as long as fires do not cause or 7 significantly contribute to daily or annual PM2.5 and PM10 NAAQS violations, States/tribes may allow participation by burners in the basic SMP to be voluntary and the SMP does not have to be adopted into the SIP. Another incentive is the commitment by EPA to use its discretion not to redesignate an area as nonattainment when fires cause or significantly contribute (see section VII.B.) to PM NAAQS violations, if the State/tribe required those fires to be conducted within a basic SMP. Rather, if fires cause or significantly contribute violations, States/tribes will be required to review the adequacy of the SMP, in cooperation with wildland owners/managers, and make appropriate improvements. If States/tribes do not certify that a basic SMP is being implemented, no special consideration will be given to PM violations attributed to fires managed for resource benefits. Rather, EPA will call for a SIP revision to incorporate a basic SMP and/or will notify the governor of the State or the tribal government that the area should be redesignated as nonattainment. The SMP adopted in response to the SIP/TIP call must require mandatory participation for greater than de minimis fires, and must be adopted into the SIP/TIP so that it is Federally enforceable. Also, the SIP/TIP must meet all other CAA requirements applicable to nonattainment areas. Fire data requirements for SIP’s/TIP’s are addressed in section VIII of this policy. Guidance for meeting CAA requirements to show conformity of Federal fire activities with SIP’s, to address visibility/regional haze impacts, and to address prevention of significant deterioration of air quality are addressed in section IX. The following are guiding principles for implementing this policy: < Air quality and visibility impacts from fires managed for resource benefits should be treated equitably with other source impacts. < Land and vegetation management practices should be promoted that are best for wildland ecosystems, yet protect public health and avoid visibility impairment. < States/tribes should foster collaborative relationships among wildland owners/managers, air quality managers and the public to develop and implement SMP’s. < States/tribes will be allowed the flexibility (prior to measuring violations of the PM2.5 or PM10 NAAQS attributable to fires managed for resource benefits) to decide when a SMP 8 is needed and how the program will be designed to prevent adverse air quality impacts. This does not preclude wildland owners/managers from including smoke management components in burn plans for fires they conduct in the absence of an applicable State/tribal program. < All parties (wildland owners/managers, air quality managers and the public) are expected to act in good faith and will be held accountable for implementing their respective parts of fire and SMP’s. V. COLLABORATION AMONG LAND AND AIR QUALITY MANAGERS Wildland owners/managers and air quality managers can overcome the barriers to achieving their goals of: (1) returning fire to its natural role in the wildlands and (2) protecting air quality and visibility, by working together toward those ends. Wildland owners/managers should notify State/tribal air quality managers if they are planning to significantly increase the use of fire to manage wildland resources. Air quality managers with Federal/State/local public wildlands within their jurisdictions have a responsibility to participate in the public planning processes conducted for the management of those publicly owned lands. To arrive at the best choice of resource treatments and response to fire, it is essential that the air quality impacts of planned land management activities are adequately addressed. Air quality managers, by participating in the public land use planning process, can help select the scope of land uses; help evaluate alternative management tools and help identify when fire is appropriate; and review projected air quality and visibility impacts. Air quality managers should also consult with private wildland owners/managers to determine long-range resource management objectives and help them evaluate the applicability of alternative treatments based on air quality and visibility considerations. Wildland owners/managers also have a responsibility to participate with the other stakeholders and State/tribal air quality managers in developing rules and SMP’s for fires managed for resource benefits. Air quality managers that intend to develop or revise regulations, plans or policies applicable to fires should solicit the early participation of all affected wildland owners/managers in making those revisions. A. Land and Vegetation Management 9 Wildlands are managed by Federal, State and local public agencies (referred to in this document as public land management agencies); tribal and BIA authorities; and private land owners. The goals of public land management agencies vary, but are generally to develop, maintain and enhance wildlife habitat; protect endangered plant and animal species; preserve and protect cultural resources, scenic vistas and wilderness; provide for recreation; and to sustain production of natural resources. The goals of private wildland owners/managers may be sustained production of natural resources, preservation of wildlife habitat, improved grazing conditions, etc. The goals of tribal wildland owners/managers are generally similar to public land management agency goals, but may also include aspects of private land owners. Another common goal of all wildland owners/managers is to minimize the potential for catastrophic wildfires that could result from heavy accumulations of vegetative fuels. 1. Alternative Treatments Wildland owners/managers may have an array of tools, including fire, that can be used to accomplish land use plans, depending on the resource benefits to be achieved. Several factors should be considered when selecting appropriate treatments. Those factors include the costs of treatment, the environmental impacts (e.g., air and water quality, soils, wildlife, etc.), and whether fire must be used to meet management objectives. The best combination of treatments are those that meet management goals with the most favorable environmental impacts at the most reasonable costs. a. Utilization and mechanical treatments Mechanical treatments may be appropriate tools when management objectives are to reduce fuel density to reduce a wildfire hazard, or to remove logging waste materials (slash) to prepare a site for replanting or natural regeneration. On-site chipping or crushing of woody material, removal of slash for off-site burning or biomass utilization, whole tree harvesting, and yarding (pulling out) of unmerchantable material may accomplish these goals. Mechanical treatments are normally limited to accessible areas, terrain that is not excessively rough, slopes of 40 percent or less, sites that are not wet, areas not designated as national parks or wilderness, areas not protected for threatened and endangered species and areas without cultural or paleological resources. 10 b. Chemical treatments When the management objective is to preclude, reduce or remove live vegetation and/or specific plant species from a site, chemical treatments may be appropriate tools. Other potential environmental impacts caused by applying chemicals must also be considered, however. c. Fire treatments Fire is one of the basic tools relied upon by wildland owners/managers to achieve a myriad of management objectives in fire dependent ecosystems. Most North American plant communities evolved with recurring fire and, therefore, are dependent on recurring fire for maintenance. The natural fire return interval may vary from 1-2 years for prairies, 3-7 years for some long-needle pine species, 30-50 years for species such as California chaparral, and over one hundred years for species such as lodgepole pine and coastal Douglas-fir. When one management objective is to maintain a fire dependent ecosystem the effects of fire cannot be duplicated by other tools. In such cases, fire may be the preferred management tool even when other treatments may be equally effective for meeting other objectives. Fire can also be used to reduce heavy fuel loads and prevent catastrophic wildfires. When fire is the chosen management tool, a combination of treatment methods may be the best approach to achieving the desired resource benefits with minimum air quality impacts. Combinations of treatments may include mechanically pretreating an area to thin the fuel load prior to the use of fire. 2. Role of Federal Land Managers (FLM’s) The major Federal agencies with land management responsibilities include the USDA FS, the DOI NPS, and FWS, BLM, and BIA. These agencies manage national parks, forests, monuments, wilderness areas, prairie grasslands, sea shores, Indian lands, wildlife refuges, etc. The Department of Defense and Department of Energy also manage millions of acres of Federal land at military bases, training centers and for other purposes. a. Federal land use and fire management planning Federal land use planning is an open process for setting land use and management goals and objectives. The planning process is designed for public participation, and must comply with NEPA. State/tribal air quality managers are given the opportunity to participate in land use 11 planning as part of normal intergovernmental consultation procedures. It is important for air quality managers to participate in public land use planning decisions to ensure that air quality concerns are adequately addressed. Through the public participation process, issues are identified and alternatives are discussed regarding methods for implementing land management activities such as trail building, improvement of wildlife habitat, timber harvesting, use of fire, etc. The environmental impacts of these activities are analyzed including, among other things, impacts on cultural resources, wildlife, vegetation, soils, riparian areas, wetlands, water quality, air quality, and visibility. Consideration of the air quality impacts of land management activities is essential to arriving at the best choice of treatments and response to fire. Two or more levels of land use planning are conducted by FLM’s to achieve management goals. First, broad scale and long-range land use plans must be developed for administrative units (e.g., forests, parks, refuges, sanctuaries, etc.). The land use plan identifies the scope of actions and goals for the lands and resources administered, and typically covers a 10 to 15-year period. In addition to land use plans, there are other shorter term (typically 1-5 years) planning efforts where decisions are made concerning specific activities and programs, including the use of fire to achieve resource benefits. These may include programmatic plans, such as FMP’s, or specific project plans. The FMP’s are strategic plans that define how wildland and prescribed fires will be managed to meet land use objectives. The FMP’s must contain prescriptive criteria which are measurable and will guide selection of appropriate management actions in response to fires. The criteria can relate to suppression actions or describe when fire can be managed to gain resource benefits. This allows the use of a full range of appropriate management responses to fire, which may include: full suppression of a wildland fire; suppression on part of a wildland fire while allowing another portion of the fire to continue playing a natural ecological role and achieve resource benefits; or the use of prescribed fire. Project plans are strategic plans to accomplish specific actions and goals established in a land use plan. Project plans may involve decisions regarding trade-offs between using mechanical, chemical and fire treatments. When projects include fires treatments, burn plans are also required. Burn plans are operational plans for managing specific fires. Burn plans prepared by 12 FLM’s should include smoke management components to minimize fire emissions and mitigate air quality impacts. b. Evaluating environmental impacts Federal agencies evaluate the environmental impacts of the tools used for resource management on publicly owned lands using NEPA. They generally consider the impacts on, among other things, plant and animal species in the area, aquatic life, cultural resources, soil conditions, riparian areas, wetlands, water quality, air quality and visibility. Such analyses should be undertaken at both the individual project planning level and at the regional planning level if warranted by the extent of similar activities over a large area. The impacts of resource management activities, particularly fire, on air quality can vary significantly by region. The impacts can be strongly affected by meteorology; existing air quality; the size, timing and duration of the activity; and other activities occurring in the same airshed at the same time. State/tribal air quality managers can provide technical assistance with evaluating potential air quality impacts, thus aiding FLM’s in their selection of tools and evaluation of the environmental impacts. Air quality and visibility impact evaluations of fire activities on Federal lands should: - include recent historic (e.g. 10 years) and projected (life of the plan) annual or seasonal emissions from wildland and prescribed fires. Emission projections should be based on estimates provided by wildland owners/managers of acres burned, pre-burn fuel loading by vegetation type and consumption, - be related to analyses of cumulative impacts of fires on regional and subregional air quality, when possible. - identify applicable regulations, plans or policies (e.g. burn plans, authorization to burn, conformity, etc.), - identify sensitive receptors, - include description of planned measures to reduce smoke impacts, - identify the potential for smoke intrusions into sensitive areas, and model air quality and visibility impacts, when possible, - describe ambient air monitoring plans, when appropriate. 13 3. Role of State and Other Public Land Managers State and local land management agencies manage publicly owned lands similar to Federal lands. These agencies differ from agency to agency, but can include forestry, conservation, park service, or fish and game agencies, as well as State or local fire protection agencies. Many agencies prepare long-range land use plans as well as project specific plans. The FMP’s, similar to those prepared by Federal agencies, may also be prepared. Public land management agencies generally assess the environmental impacts of proposed projects, such as fires managed for resource benefits, although the impacts evaluated vary from agency to agency. Some State/local wildland managers also have responsibilities for private lands. Such responsibilities may include using fires and other fuels reduction programs aimed at reducing the potential for wildfires in the wildland/urban interface. Land use planning for State and locally owned wildlands, although somewhat different from the Federal process, also requires preparation of written documents that are subject to public review. State/local wildland managers should notify air quality managers of long-range plans to use fire for resource management. They should consider alternative management tools and evaluate the potential air quality impacts of fires. State/local wildland managers should also participate in the development of State SMP’s. 4. Role of Private Land Managers Private wildland owners/managers may or may not prepare written land use or project plans depending on the organization and the size of the property. States/tribes may or may not require written plans, but activities on privately owned lands must meet all applicable State and Federal environmental requirements. State requirements include any specific SIP requirements applicable to private land owners which are designed to ensure that the State complies with CAA requirements. Private land owners/managers should provide information to the State on longrange plans to use fire for resource management and should participate in the development of State SMP’s. 14 5. Role of Indian Land Managers Land use plans for Indian wildlands are not subject to review by the general public and are not subject to State regulations. Activities on Indian lands must meet the requirements of the CAA and the TIP, however, if one has been adopted. It is important that Indian wildland managers consider alternative vegetation management tools and consider the air quality impacts of the management practices chosen both on and off of Indian lands. They are encouraged to collaborate with other near-by wildland owners/managers and air quality managers on regional SMP’s to assure that fires managed for resource benefits will not cause adverse air quality impacts at sensitive receptors in the region. 6. Role of Air Quality Managers State air quality managers which have publicly owned wildlands within their jurisdiction, have a responsibility to participate in the public planning process conducted for those lands to be assured that air quality concerns are adequately addressed and they can meet the goals of their SIP’s. They can participate in selecting the scope of land uses, identify air quality issues, and participate in evaluating and selecting alternative resource management tools. They can also participate in identifying basic air quality criteria for fire prescriptions. To accomplish this, air quality agencies should heed solicitations of public participation from land managers and contact public land management agencies within their jurisdiction State/tribal air quality managers should also encourage private and Indian wildland owners/managers to consider alternative treatments and help them evaluate the potential air quality impacts of alternatives to meet particular management objectives. B. Air Quality Management State/tribal air quality managers are responsible for adopting plans and rules sufficient to attain and maintain national and State air quality standards, prevent significant deterioration of air quality, remedy existing visibility impairment and prevent future impairment in mandatory Class I Federal areas caused by manmade sources of pollution. This is accomplished mainly by developing SIP’s and TIP’s. The SIP’s/TIP’s include all programs and rules required by the CAA to meet and assure maintenance of Federal standards. The SIP’s/TIP’s are frequently amended as State/tribal rules are revised and new rules are adopted to meet changing CAA requirements. The 15 EPA has the authority to adopt and implement Federal Implementation Plans (FIP’s) to address air quality protection in areas where States or tribes do not adopt plans. 1. Role of State/Local Air Quality Managers The SIP’s are developed in an extensive public process involving workshops and public hearings in which all stakeholders are invited to participate in developing the technical components of the plans including: (1) emission inventories; (2) modeling analyses; (3) attainment demonstrations; (4) transportation and general conformity emission budgets; (5) analyses of air quality data; and (6) control strategy development. State/local air quality managers should solicit information on the planned use of fire for resource management from all wildland owners/managers, just as they obtain information on other emission sources within their jurisdiction, when fires are expected to significantly impact air quality. Air quality managers should also work with adjacent States to mitigate potential impacts from interstate transport of smoke. 2. Role of Tribal Air Quality Managers Eligible tribes may develop TIP’s to administer CAA requirements on Indian lands. The CAA recognizes tribal governments as the most appropriate parties to regulate the environment on Indian lands and grants EPA the authority to approve tribal programs. The EPA has developed strategies for Federally implementing CAA requirements if tribes do not adopt TIP’s. Tribal air quality managers should solicit information on the planned use of fire for resource management within their jurisdiction and the potential for air quality impacts on or from adjacent jurisdictions. They are encouraged to collaborate with other near-by air quality managers to develop regional SMP’s which assure that fire activities will not cause adverse air quality impacts at sensitive receptors in the region. 3. Role of Public Land Managers Public land managers have the responsibility to participate with the other stakeholders and air quality managers in developing SIP’s. Public land managers, as experts in what is needed to meet land use and other environmental objectives, need to provide information on the areas that are to be treated with fire, air pollutant emissions estimates, and assistance in developing programs to track emissions, monitor air quality and visibility, and mitigate air quality impacts. 16 The FLM’s of mandatory Class I Federal areas must participate in the development of SIP’s for regional haze and visibility impairment. Congress gave FLM’s a key consulting role in the administration of visibility protection and “affirmative responsibility to protect air quality related values (including visibility) in mandatory Class I Federal areas.” [See section 165 of the CAA.] VI. SMOKE MANAGEMENT PROGRAMS (SMP’s) The SMP’s establish a basic framework of procedures and requirements for managing smoke from fires managed for resource benefits and are typically developed by States/tribes with cooperation and participation by wildland owners/managers. The purposes of SMP’s are to mitigate the nuisance and public safety hazards (e.g., on roadways and at airports) posed by smoke intrusions into populated areas; to prevent deterioration of air quality and NAAQS violations; and to address visibility impacts in mandatory Class I Federal areas. Some strong indications that an area needs a SMP are: (1) citizens increasingly complain of smoke intrusions; (2) the trend of monitored air quality values is increasing (approaching the daily or annual NAAQS for PM2.5 or PM10) because of significant contributions from fires managed for resource benefits; (3) fires cause or significantly contribute to monitored air quality that is already greater than 85 percent of the daily or annual NAAQS for PM2.5 or PM10; or (4) fires in the area significantly contribute to visibility impairment in mandatory Class I Federal areas. If a State/tribe determines that a SMP is needed, they can adopt any type of program they believe will prevent NAAQS violations and address visibility impairment. For example, general fire regulations may establish basic parameters, such as wind speed, direction, location and distance to sensitive receptors, etc., within which fires can be ignited or naturally ignited fire can be allowed to continue to burn. States/tribes may allow wildland owners/managers to voluntarily notify them of fire plans or may require prior authorization. They may also exempt de minimis fires (fires that will cover fewer than X acres or consume less than Y tons of fuel, as established by the State/tribe) from meeting the regulations. Such regulations leave much discretion to wildland owners/managers as to when to ignite fires, and what management strategy to follow with naturally ignited fires. States/tribes may exercise enforcement authorities when wildland owners/managers are found to have ignited the fire outside of the parameters of the rule, or not to 17 have appropriately responded to air quality impacts caused by naturally ignited fires. General fire regulations may be adequate for areas where fires managed for resource benefits rarely cause or contribute to air quality problems. However, when plans to use fire on a large scale could cause significant air quality impacts, or several wildland owners/managers within an airshed are expected to use fires concurrently, a more structured SMP requiring cooperation and coordination of fire activities may be required to minimize emissions and mitigate the air quality impacts. State/tribal air quality managers, public wildland managers, private and Indian wildland owners/managers, and the general public should collaborate in the development and implementation of State/tribal SMP’s. The State/tribal air quality manager must certify in a letter to the Administrator of EPA that at least a basic program has been adopted and implemented in order to receive special consideration under this policy of air quality data resulting from fire impacts, as explained in section VII. The SMP does not have to be incorporated into the SIP/TIP or be Federally enforceable, however. The following describes the basic components (A - F) of a certifiable SMP. There is considerable latitude within the components for individual State/tribal preferences. A. Authorization to Burn The SMP should include a process for authorizing or granting approval to manage fires for resource benefits within a region, State, or on Indian lands and identify a central authority responsible for implementing the program. The process may be as simple as receiving applications for permission to burn and granting approval via telephone or facsimile. The SMP central authority must review fire applications, consult with the applicants, if necessary, and promptly make burn/no burn decisions. When authorizing a fire, the authority should consider all open burning activities (land clearing and construction wastes, agricultural wastes, etc.) allowed within an airshed. The central authority should strive to treat public and private wildland owners/managers equitably when authorizing fires. Neighboring States/tribes are encouraged to create partnerships to coordinate fire projects when inter-jurisdictional impacts are expected, so as to meet air quality and fire management objectives. Fire emissions should be minimized and the air quality impacts should be mitigated regardless of political boundaries. 18 States/tribes may or may not require written burn plans for de minimis fires, especially if the central authority records pertinent fire information. However, written burn plans are strongly recommended for greater than de minimis fires. Burn plans should be prepared by the wildland owners/managers. The central authority should assist private land owners that cannot prepare their own plans. When written burn plans are required, especially for fires on publicly owned lands, they should include such information as the: - location and description of the area to be burned, - personnel responsible for managing the fire, - type of vegetation to be burned, - area (acres) to be burned, - amount of fuel to be consumed (tons/acre), - fire prescription including smoke management components (discussed below), - criteria the fire manager will use for making burn/no burn decisions, - safety and contingency plans addressing smoke intrusions. The central authority’s criteria for authorizing fires should be based on existing air quality and the ability of the airshed to disperse emissions (e.g., meteorological conditions) from all burning activities on the day of the burn. For fires lasting longer than one day, predicted meteorological conditions for several days should be considered to avoid aggravating existing problems. Persons receiving authorization to ignite fires must comply with all applicable local, State, tribal and Federal requirements. Persons responsible for managing greater than de minimis fires should be adequately trained in fire and smoke management. Fire managers should be required to follow the authorized burn plan or explain why it was necessary to deviate from the plan. B. Minimizing Air Pollutant Emissions The SMP should encourage wildland owners/managers to consider the alternative treatments discussed in section V.A.1., above. Public land managers typically consider and evaluate alternative treatments that may achieve management objectives, their costs and the environmental impacts of each method. States/tribes should assist private land owners to also identify economically feasible treatments that will meet their objectives with minimum air pollutant 19 emissions. When the use of fire is selected as the best means to accomplish management goals, there are several ways to reduce emissions from a single fire. The approaches fall into four categories and their applicability varies by fuel type, (1) minimize the area burned, (2) reduce the fuel loading in the area to be burned, (3) reduce the amount of fuel consumed by the fire, (4) minimize emissions per ton of fuel consumed. These emission reduction techniques rely almost exclusively on reducing the amount of fuel consumed by a particular fire. The excluded fuels could be consumed by a subsequent fire, however, unless they are removed from the area or biologically decompose. Also, generally these techniques cannot be used to reduce emissions from naturally ignited fires. Emission reduction techniques are discussed further in the white paper “What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can Land Management Goals Still be Met?” See Section I to obtain a copy. C. Smoke Management Components of Burn Plans When burn plans are required they should include the following smoke management components. 1. Actions to Minimize Fire Emissions The burn plan should document the steps taken prior to the burn and actions that will be taken during and after the burn to reduce air pollutant emissions. This includes measures that will be taken to reduce residual smoke, such as rapid and complete mop-ups, mop-ups of certain fuels, etc. 2. Evaluate Smoke Dispersion The central authority should evaluate dispersion conditions prior to authorizing fires. Burn plans should evaluate potential smoke impacts at sensitive receptors and time fires to minimize exposure of sensitive populations and avoid visibility impacts in mandatory Class I Federal areas. The plan should identify the distance and direction from the burn site to local sensitive receptor areas and to regional/interstate areas where appropriate. Fire prescriptions submitted prior to the day of the fire must specify minimum requirements for the atmospheric capacity for smoke dispersal such as minimum surface and upper level wind speeds, desired wind direction, minimum mixing height, and dispersion index. It may be necessary to purchase 20 meteorological services from private companies if they are not available from the National Weather Service. 3. Public Notification and Exposure Reduction Procedures The plan should identify actions that will be taken to notify populations and authorities (e.g., local air quality managers) at sensitive receptors, including those in adjacent jurisdictions, prior to the fire. The plan should also identify contingency actions that will be taken during a fire to reduce the exposure of people at sensitive receptors if smoke intrusions occur. The central authority should perform these functions, if needed, for some private land owners. Appropriate short-term (less than 24-hour) contingency actions may, among other things, include: - Notifying the affected public (especially sensitive populations) of elevated pollutant concentrations, - Suggesting actions to be taken by sensitive persons to minimize their exposure (e.g., remain indoors, avoid vigorous activity, avoid exposure to tobacco smoke and other respiratory irritants), - Providing clean-air facilities for sensitive persons, - Halting ignitions of any new open burning that could impact the same area, - Analyzing the fire situation and identifying alternative management responses upon becoming aware that a fire is out of air quality prescription with regard to the air quality criteria, (Federal land management agencies perform a Wildland Fire Situation Analysis)3, - Consulting State/tribal air quality managers regarding appropriate short-term fire management response to abate verified impacts, - Implementing management responses that will mitigate the adverse impacts to public health, 3 A Wildland Fire Situation Analysis (WFSA) is a decision-making process that evaluates alternative fire management strategies considering fire fighter and public safety, risk to property and resources, fire fighting resources available, land management objectives, and environmental, social, economic and political constraints. The environmental and social constraints considered include, among other things, how air quality and/or visibility will be affected at sensitive receptors by each alternative fire management strategy. The positive, neutral or negative effects of each alternative on the criteria above are weighed to select the appropriate management response to the fire. Therefore, while mitigating air quality and visibility impacts must be considered by the FLM when managing a fire that is not within a prescription, they are just two of several important criteria evaluated. 21 - Reporting the steps taken to mitigate adverse impacts to the public and appropriate State/tribal agencies after they have been completed. 4. Air Quality Monitoring The plan should identify how the effects of the fire on air quality at sensitive receptors, and visibility in mandatory Class I Federal areas will be monitored. The extent of the monitoring plan should match the size of the fire. For small fires, visual monitoring of the direction of the smoke plume and monitoring nuisance complaints by the public may be sufficient. Other monitoring techniques include posting personnel on vulnerable roadways to look for visibility impairment and initiate safety measures for motorists; posting personnel at other sensitive receptors to look for smoke intrusions; using aircraft to track the progress of smoke plumes; and continued tracking of meteorological conditions during the fire. For large fires expected to last more than one day, locating real-time PM monitors at sensitive receptors may be warranted to facilitate timely response to smoke impacts. If needed, the central authority may perform these monitoring functions for some private land owners. For additional information on monitoring wildland fire impacts see the white paper “Air Monitoring for Wildland Fire Operations.” See Section I to obtain a copy. D. Public Education and Awareness The SMP should establish criteria for issuing health advisories when necessary, and procedures for notifying potentially affected populations, including those in adjacent jurisdictions, of planned fires. A program should be implemented to explain the use and importance of fire for ecosystem management, the implications to public health and safety, and the goals of the SMP. Wildland and air quality managers should work with the press to announce pre-fire health advisories, and post-fire results including such things as the management objectives met; smoke intrusions observed, and/or successful minimization of air quality impacts. E. Surveillance and Enforcement The SMP should include procedures to ensure that wildland owners/managers will comply with the requirements of the SMP. Fire managers must follow the burn plan, including the fire prescription and smoke management components, or explain any deviations from the plan. Memorandums of understanding may be used to specify the responsibilities of each State/tribal 22 agency in implementing the SMP. F. Program Evaluation The SMP should provide for periodic review by all stakeholders of its effectiveness and revision of the program as necessary. The effectiveness review should be based on observations such as reports of smoke intrusions, nuisance complaints, and monitored air quality impacts. Post-burn reports should be required for fires that exceed their air quality prescription and/or fires that cause smoke impacts at sensitive receptors. Post-burn reports for escaped fires should describe the incident, describe the contingency plan implemented, and provide recommendations to prevent future smoke related problems. State/tribal SMP’s should include procedures for re-evaluating the effectiveness of rules and regulations every 3 to 5 years. Such procedures should involve all the original participants (e.g., wildland owners/managers, air quality managers, the public, etc.) and should review the: - Acres of fires managed for resource benefits planned for the next 5 years, - Need to expand the scope of the program to include authorization of other open burning, G. Need for changes in the SMP. Optional Air Quality Protection The following components are not required in a basic SMP, but States/tribes may adopt more stringent SMP’s or include additional smoke management requirements. For example, “special protection zones” may be established to provide better protection against smoke impacts. Special protection zones could be buffers (e.g., 10 - 25 miles) around wildland/urban interface areas, nonattainment areas, or mandatory Class I Federal areas. Additional requirements for burns within a special protection zone may include no burning if high pollution levels already exist in the area. Also, special protections may only be required for burns that will last overnight, for multi-day burns or burns during specific seasons. States/tribes may also establish “performance standards” that would trigger implementation of additional smoke management requirements if exceeded in an area. The performance standards could set limits on the frequency and intensity (e.g., hours/day, PM concentration, visibility impairment) of smoke intrusions. Implementation of performance 23 standards may require real-time monitoring of air quality. Additional requirements for fires after the performance standards are exceeded may include better dispersion parameters (e.g., increased wind speed, mixing height, dispersion index, etc.). VII. ACCOUNTABILITY A. Role of State/Tribal Air Quality Managers High PM concentrations attributable to fires managed for resource benefits are valid air quality data that can be used to determine the attainment status of the area represented by the data for both the daily and annual NAAQS. State/tribal air quality managers are responsible for monitoring citizen complaints and air quality trends attributable to fires to determine when a SMP is needed to minimize emissions and mitigate air quality impacts. Air quality managers should initiate the collaborative process needed to develop and adopt regulations for a SMP. If the State/tribal air quality manager certifies in a letter to the Administrator of EPA that at least a basic program (described in section VI) has been adopted and implemented, special consideration will be given under this policy to air quality data resulting from fires managed for resource benefits. 1. Wildfires High PM concentrations attributable to wildfires (unwanted wildland fires) can be treated as due to a natural event under EPA’s Natural Events Policy. The Natural Events Policy provides that when areas violate the PM10 NAAQS due to a natural event, EPA will: (1) exercise its discretion, under section 107(d)(3) of the CAA, not to redesignate areas as nonattainment if the State develops and implements a plan to respond to the health impacts of natural events; and, (2) redesignate nonattainment areas as attainment by applying appendix K, on a case-by-case basis, to discount [ambient air quality] data in circumstances where an area would attain but for exceedances that result from uncontrollable natural events. The elements of a State/tribal action plan to respond to the health impacts of natural events are described in the Natural Events policy statement. The EPA plans to revise the Natural Events Policy to also cover PM2.5 NAAQS violations. 2. Fires Managed for Resource Benefits High PM concentrations attributable to fires managed for resource benefits will be given special consideration under this policy, as described in section VII.B., if the State/tribe has 24 certified to EPA that it is implementing a basic SMP. States/tribes should flag monitored values influenced by fires when submitting the data to EPA’s Atmospheric Information Retrieval System. They must also document the basis for flagging the data. Supporting information could include the location of fires relative to the monitor, meteorological data such as wind speed and direction, filter analyses indicating heavy carbon deposits, the sample date (collected during the fire season), and the absence of other carbon sources during that period, among other things. The documentation should address the possible influence of other carbon sources such as wood-fired boilers, residential wood combustion and wildfires. The type and amount of documentation should be sufficient to demonstrate that fires managed for resource benefits caused flagged values to be above the level of the annual NAAQS. The documentation should be made available to the public for review. [For example, newspaper announcements, periodic air quality reports, distribution at public meetings.] When smoke intrusions cause high PM concentrations, air quality managers have two goals: (1) to reduce immediate impacts on public health, and (2) to take appropriate steps to mitigate future impacts. To meet these goals, air quality managers must contact the wildland owner/manager responsible for the fire(s) to determine the cause of the impacts. The air quality manager should verify that contingency actions to reduce exposure are being implemented, and determine whether, (i) the fire was authorized, (ii) a burn plan (including the smoke management components) was followed, (iii) the prescription failed and why. If requirements of the SMP were not met, the State/tribe can exercise various enforcement authorities to address the problem. If the fire manager complied with the SMP, the adequacy of the requirements should be reviewed. If air quality data are frequently flagged as resulting from failure of the smoke management components of the burn plan, EPA will call on the State/tribe to work with wildland owners/managers to improve future burn plans and the SMP. When a fire managed for resource benefits breaks out of its fire prescription, and cannot be returned to the prescription, the fire manager will treat it as a wildfire for the purposes of suppression. However, any resulting high PM concentrations must continue to be addressed under this policy, and the data can not be treated as due to a wildfire natural event. B. Role of the Environmental Protection Agency 25 1. Impacts with a SMP If fires managed for resource benefits cause or significantly contribute to violations (see definition) of the daily or annual PM2.5 or PM10 NAAQS, the State/tribe must submit the following documentation to EPA to avoid a SIP/TIP call or redesignation of the area to nonattainment: < Evidence supporting the finding that flagged air quality values were due to fires managed for resource benefits, < Evidence that the fires were subject to a certified State/tribal SMP. The State/tribe may consider that such fires caused or significantly contributed to violations of the daily NAAQS if 25 percent of all the PM concentrations that are above the level of the daily NAAQS, have been flagged as being due to fire impacts. The State/tribe may consider that such fires caused or significantly contributed to violations of the annual NAAQS if the sum of the measured concentrations for all days flagged as due to fires, divided by the total number of sample days (fire days plus non-fire days) is greater than or equal to 25 percent of the annual NAAQS (i.e., 4 µg/m 3 for PM2.5 or 12 µg/m 3 for PM10). If the evidence is convincing, EPA will exercise its discretion under section 107(d)(3) not to redesignate the area as nonattainment. Rather, following the first NAAQS violation based on 3 calendar years of PM air quality data, EPA will call on the State/tribe to review the effectiveness of the SMP in collaboration with wildland owners/managers and make appropriate improvements to mitigate future air quality impacts. The same procedure will be followed if a second NAAQS violation occurs the following year. If fires cause or significantly contribute to a third consecutive NAAQS violation, EPA will call for the SMP to be made part of the SIP/TIP and be Federally enforceable.4 If the area was designated nonattainment previously, EPA will also call on the State/tribe to review the effectiveness of the SMP and make appropriate improvements. 2. Impacts Without a SMP If a certified SMP has not been implemented, EPA will not give special consideration to the high PM concentrations attributed to fires managed for resource benefits that cause or 4 For example, the first violation of the PM10 NAAQS may be determined using air quality data for calendar years 1997-1999. Subsequently, 1998-2000 data for the same area could show a second violation, and data for 19992001 could identify a third violation for the area. 26 significantly contribute to: (1) violations of a PM2.5 or PM10 NAAQS, (2) visibility impairment in mandatory Class I Federal areas, or (3) failure to achieve reasonable progress toward the national visibility goal. Rather, EPA will call for adoption of the basic SMP, described in section VI, as part of the SIP/TIP for PM and visibility. The EPA will also notify the governor of the State or the tribal government that the area should be redesignated as nonattainment. The SMP adopted in response to the SIP/TIP call must require mandatory participation for greater than de minimis fires, must be adopted into the SIP/TIP, and must be Federally enforceable. The SIP/TIP will also have to meet all other CAA requirements applicable to nonattainment areas. 3. Interstate Transport of Smoke Several key provisions of the CAA address interstate pollutant transport. Section 110(a)(2)(D) provides that a SIP must contain provisions preventing subject sources from contributing significantly to nonattainment problems or interfering with maintenance in any other State. That section also prohibits interference with any SIP required measures under part C to prevent significant deterioration or to protect visibility. Section 169A authorizes EPA to promulgate regulations requiring states that “may reasonably be anticipated to cause or contribute to” visibility impairment in mandatory Class I Federal areas to include in their SIP’s measures necessary to eliminate or reduce such impairment. Section 126 provides that, in response to petitions from government entities regarding significant pollutant transport, EPA may prescribe certain corrective measures. Also, sections 169B, 176A and 184 contain provisions for cooperatively addressing interstate pollution problems by establishing interstate transport regions and commissions to address region wide pollution and visibility concerns. The EPA promulgated a final rule, pursuant to the requirements of section 301(d) of the CAA that authorizes eligible Indian tribes to also implement these provisions.5 If fires managed for resource benefits in one State (or on Indian lands) cause or significantly contribute to NAAQS violations in another State (or on Indian lands), EPA is authorized to take action under section 110(k)(5) of the CAA to address the problem. If, among other things, EPA finds that a SIP/TIP is substantially inadequate to attain or maintain the NAAQS, it may require the SIP/TIP to be revised to correct the 5 See Volume 63 Federal Register 7254, February 12, 1998. 27 inadequacy (e.g., transported smoke). C. Role of Wildland Owners/Managers Wildland owners/managers are responsible for following State/tribal regulations applicable to fires, obtaining authorization to burn, and following the approved burn plan, when one is required. Owners/managers are responsible for taking appropriate actions to control the fire and reduce exposure to smoke when adverse air quality impacts result from a failure of the air quality prescription or an escaped fire. There is a special need for fires managed by Federal agencies to have burn plans that include smoke management components. Fires managed by Federal agencies are most likely to impact air quality in recreation areas (national parks, forest, etc.) and impair visibility in mandatory Class I Federal areas. The EPA encourages Federal agencies to include smoke management components in all burn plans, regardless of the existence of a State/tribal SMP. VIII. DATA ON WILDLAND and PRESCRIBED FIRES Most of a State/tribal program to protect air quality is contained in a SIP or TIP. Since the use of fire for resource management is expected to increase substantially, especially on Federal lands, State/tribal air quality managers will need information to develop potential annual or seasonal air pollutant emission estimates for SIP/TIP planning. As for any source, emissions from fires can be estimated by multiplying the estimated level of activity by an emission factor. The level of activity for fire is the mass of biomass (fuel) consumed, usually expressed in tons. Emission factors expressed in pounds per ton of fuel consumed are available in EPA’s publication AP-42 (which is scheduled to be updated). Emission factors are derived from an estimate of overall combustion efficiency (i.e. stoichiometric ratio). The mass of fuel consumed is the product of fire size (acres), pre-burn fuel loading (tons per acre), and fuel consumption (percent of pre-burn loading). An emission inventory can be compiled by the affected air agency for an individual fire, a statistical class of fires, a burn program, or a population of fires in a given area over a period of time based on this information. Federal land management agencies currently collect data on wildland and prescribed fires, however, no standard reporting format is followed. These raw data are usually limited to the time and approximate location of the fire, fire perimeter area, weather (occasionally) and a 28 qualitative description of fuels at the point of ignition. The data are not collected for the purpose of calculating air pollutant emissions and are probably inadequate for that purpose. A National Interagency Fire Statistics Information Project has been initiated to develop an easily accessible system for storing a set of commonly agreed upon fire data. Post-burn data, such as that described above, on future wildland and prescribed fires would be stored in this database. The database will be accessible by air quality managers to estimate past, current, and future emission trends from this source category. The EPA encourages the Federal land management agencies to develop the fire statistics database and FLM’s to report fire data to the system. These fire data will be needed by air quality managers in regions where most wildland and prescribed fires occur on Federal lands. Air quality managers should request similar fire data for wildland and prescribed fires on State, private and Indian wildlands as well as information on other types of open burning to complete their emission inventories. Statewide emissions from fire use in all 50 states during 1989 have been estimated based on a survey of [Federal, State and private] land owners/managers. [Ref. Peterson/Ward] Also, a spatially resolved inventory of prescribed burning by county for 1990 and by 50km grid for 1995, 2015 and 2040 was prepared for 10 western States as part of the Grand Canyon Visibility Transport Commission’s activities. [Ref. Peterson/Lahm] The emission estimates are based on fuel models derived from 14 types of vegetative cover spatially mapped throughout the area and estimates of fuel loadings as either low, medium or high. The procedures followed by Peterson and Lahm to estimate emissions for the western states provide a good model for developing emissions estimates for other areas, also. Further information on developing emissions estimates and the data required can be found in the white paper “Emission Inventories for SIP Development.” See Section I to obtain a copy. IX. MEETING OTHER CLEAN AIR ACT REQUIREMENTS A. Demonstrate Conformity of Federal Activities Activities on Federal lands must meet the requirements of the CAA, including the provisions of section 176(c), that such activities "conform" to the purpose of the applicable SIP. The EPA’s Conformity rules, implementing the provisions of section 176(c), only apply to 29 Federal actions taken within a nonattainment or maintenance area. The Transportation Conformity rules govern transit-related activities, and all other type of activities are governed by the General Conformity rules. The rules require a Federal agency to demonstrate, prior to initiating a project, that its action conforms to all applicable requirements in a SIP and will not cause or contribute to NAAQS violations. The General Conformity rules provide Federal agencies with several options for demonstrating conformity. The following options are most typically followed : (1) a modeling demonstration to show that emissions from the project will not increase the frequency or severity of a NAAQS violation, (2) obtaining emission reductions that offset the new project emissions, or (3) showing that the project’s emissions are already included in, or accommodated by, the emissions inventory of the SIP for the relevant nonattainment or maintenance area. Federal activities occurring on tribal lands will be addressed by EPA consistent with its Tribal Air Rule and the requirements of the CAA. The above procedures can be followed to demonstrate conformity of fire projects for a Federal land management agency’s administrative units based on the FMP’s developed for such units. The demonstration can be made on an annual basis for all burns within the airshed of a nonattainment or maintenance area. Alternatively, the demonstration can be made for each individual fire project conducted at the administrative unit. In addition to the previously cited methods for demonstrating conformity of Federal fire projects, EPA will pursue, in consultation with the other Federal agencies, adding an alternative method to the General Conformity rules through rulemaking. At a minimum, EPA believes that the alternate method should require a Federal agency to document that its fire projects are managed within a certified SMP. The SMP also must require regional coordination (cooperation of all jurisdictions in an airshed) of burn plan authorization and real-time air quality monitoring at sensitive receptors, when warranted, in addition to the basic program components discussed in section VI. B. Visibility/Regional Haze Requirements The EPA's visibility regulations (45 FR 80084, December 2, 1980) protect mandatory Class I Federal areas from manmade impairment that is "reasonably attributable" to a single emission source or small group of sources. FLM’s for mandatory Class I Federal areas have a key 30 consultative role and responsibility to participate in the development of SIP’s for visibility impairment that is reasonably attributable to specific sources. In Part C of the CAA which includes the visibility protection mandate, Congress assigned FLM’s the "affirmative responsibility to protect air quality related values (including visibility)" in mandatory Class I Federal areas. Under EPA’s regulations, States must take appropriate actions to address all sources of visibility impairment, including fires, in response to a FLM’s certification of reasonably attributable impairment in mandatory Class I Federal areas. A new regulatory program to protect mandatory Class I Federal areas from "regional haze" impairment was proposed by EPA on July 31, 1997 (62 FR 41137). After the regional haze rules become final, States will need to address the impacts of fires and other contributing sources on meeting reasonable progress in their control strategy analyses, as well as during periodic progress assessments. The EPA will revisit this section of the Air Quality Policy on Wildland and Prescribed Fires after the final rules for implementing the regional haze program have been promulgated. The EPA will also develop guidance on assessing natural background visibility to aid in implementing the regional haze rules, and will consider the following paper at that time. The white paper “Estimating Natural Emissions From Wildland and Prescribed Fire” presents preliminary options for defining natural wildland and prescribed fire emissions that may or may not be consistent with the final regional haze rules. See Section I to obtain a copy. C. Prevention of Significant Deterioration Title I, part C of the CAA requires SIP’s to include provisions to prevent the significant deterioration of air quality in areas designated as attainment or unclassifiable for any NAAQS. “Significant deterioration” for any pollutant is defined as an unacceptable incremental increase in ambient concentrations above the baseline concentration for that pollutant in an area. The PSD “increments” have been established for SO2, NO2, and PM10. The EPA adopted NAAQS for PM2.5, which became effective on September 16, 1997. However, no increments have yet been promulgated for PM2.5, The SIP’s are required to contain emission limits and such other measures as may be necessary to prevent significant deterioration of air quality. See section 161 of the Act. In addition, SIP’s are required to include a preconstruction review permit program for new and 31 modified major stationary sources. See section 165 of the Act. The SIP’s must ensure that increases in emissions from all types air pollution sources do not cause the allowable increment for a pollutant to be exceeded. While fires managed for resource benefits generally are not subject to a preconstruction review and the issuance of a PSD permit, the emissions from such activities may affect the air quality in a PSD area. Under adverse conditions, the combined PM emissions from increased fire activities and from other sources could possibly result in ambient concentrations that exceed the allowable PSD increments for PM. Historically, EPA has often regarded fires managed for resource benefits to be temporary activities.6 The PM emissions resulting from fire activities differ from the PM emissions generated by most other sources because they are generally shortlived. That is, the burning generally is carried out infrequently at a specific location (once every 5-20 years) and the duration tends to be short (approximately 1-2 days). Even with the proposed increased utilization of fire as a resource management tool, the resulting PM emissions are expected to be relatively uncommon at a particular location and of short duration. Section 163(c)(1)(C) of the Act authorizes States with approved PSD programs to exclude (with the Administrator’s approval) concentrations of PM caused by “construction or other temporary emission-related activities” when determining compliance with the PSD increments. The EPA generally supports the concept of allowing States with approved SIP’s to exclude emissions caused by temporary managed fire activities from increment analyses, provided the exclusion does not result in permanent or long-tern air quality deterioration. Nevertheless, the decision as to whether PM emissions from fire activities should be counted against the PSD increments for PM is a decision to be made by individual States. The EPA expects States to consider the extent to which a particular type of prescribed burning activity is truly temporary, as opposed to those activities which can be expected to occur in a particular area with some regularity over a period of time. 6 See Volume 58 Federal Register 31633, June 3, 1993. 32 DEFINITIONS Air Quality: The characteristics of the ambient air (all locations accessible to the general public) as indicated by concentrations of the six air pollutants for which national standards have been established [i.e., particulate matter (PM), sulfur dioxide (SO2), nitrogen dioxide (NO2), ozone (O3), carbon monoxide (CO) and lead], and by visibility in mandatory Federal Class I areas. For the purposes of this policy, concentrations of PM are taken as the primary indicators of ambient air quality. Air Quality Manager: The regulatory body responsible for managing the air quality protection program for a State, local or tribal government. Air Quality Related Values (AQRV): Those special attributes of a mandatory Class I Federal area that deterioration of air quality may adversely affect. Some examples of AQRV include: flora and fauna, water, visibility, and odor among others. Ambient Air: That portion of the atmosphere, external to buildings, to which the general public has access. Administrative Unit: A unit of land (Forest, Refuge, Park, etc.) under the administration of a public land management agency. AP-42: The Environmental Protection Agency’s (EPA) Compilation of Air Pollutant Emission Factors for stationary point, area, and mobile sources. An emission factor is a representative value that attempts to relate the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant. Emission factors are then used to estimate the magnitude of a source’s pollutant emissions. The plan includes the project objective, fire prescription (including smoke management components), personnel, organization, equipment, etc. Class I Area: An area set aside under the Clean Air Act (CAA) to receive the most stringent protection from air quality degradation. Mandatory Class I Federal areas are (1) international parks, (2) national wilderness areas which exceed 5,000 acres in size, (3) national memorial parks which exceed 5,000 acres in size, and (4) national parks which exceed 6,000 acres and were in existence prior to the 1977 CAA Amendments. The extent of a mandatory Class I Federal area includes subsequent changes in boundaries, such as park expansions. 33 De Minimis Fires: Fires that will cover fewer than X acres or consume less than Y tons of fuel, as established by a State or tribe. Federal Implementation Plan (FIP): A plan (or portion thereof) promulgated by the Administrator, as provided for under the CAA and any applicable EPA regulations, including regulations governing tribal air plans, to fill all or a portion of a gap or otherwise correct all or a portion of an inadequacy in a State or tribal implementation plan (TIP), and which may include enforceable emission limitations or other control measures, means or techniques (including economic incentives, such as marketable permits or auctions of emissions allowances), and provides for attainment of the relevant national ambient air quality standard (NAAQS). Federal Land Manager (FLM): With respect to any lands in the United States, the Secretary of the Federal department with authority over such lands. Generally, the Secretaries delegate their authority to specific elements within each department. For example, the National Park Service and the Fish and Wildlife Service manage those areas under the authority of the Department of the Interior. Fire Dependent Ecosystem: A community of plants and animals that must experience recurring disturbances by fire, in order to sustain its natural plant succession, structure and composition of vegetation, and maintain appropriate fuel loading and nutrient cycling to ensure proper ecosystem function. Fire Management Plan (FMP): A strategic plan that defines a program to manage wildland and prescribed fires, and documents the FMP to meet management objectives outlined in the approved land use plan. The plan is supplemented by operational procedures such as preparedness plans, burn plans and prevention plans. Fuel: Includes combustible vegetative matter such as grass, trees, shrubs, limbs, branches, duff, and stumps. Indian Land: Indian land in this document refers to Indian country which is (a) all land within the limits of any Indian reservation under the jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights-of-way running through the reservation, (b) all dependent Indian communities within the borders of the United States whether within the original or subsequently acquired territory thereof, and whether within or without the 34 limits of a state, and (c) all Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same. [See 18 U.S.C. 1151.] Land Use Plan: A broad scale, long range plan (e.g., forest plan, refuge plan or resource management plan) that identifies the scope of actions and goals for the land and resources administered by a land owner/manager. National Ambient Air Quality Standards (NAAQS): Standards for maximum acceptable concentrations of pollutants in the ambient air to protect public health with an adequate margin of safety, and to protect public welfare from any known or anticipated adverse effects of such pollutants (e.g., visibility impairment, soiling, materials damage, etc.) in the ambient air. National Environmental Policy Act (NEPA): Establishes procedures that Federal agencies must follow in making decisions on Federal actions which may impact the environment. Procedures include evaluation of environmental effects of proposed actions, and alternatives to proposed actions; involvement of the public and cooperating agencies. Nuisance Smoke: Amounts of smoke in the ambient air which interfere with a right or privilege common to members of the public, including the use or enjoyment of public or private resources. Particulate Matter (PM): Any airborne finely divided material, except uncombined water, which exists as a solid or liquid at standard conditions (e.g., dust, smoke, mist, fumes, or smog). PM2.5: Particles with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers. PM10: Particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers (including PM2.5). Prescribed Fire: Any fire ignited by management actions to meet specific objectives (i.e., managed to achieve resource benefits). . Prescription: Measurable criteria which guide selection of appropriate management response and actions. Prescription criteria may include the meteorological conditions affecting the area under prescription, as well as factors related to the state of the area to be burned such as 35 the fuel moisture condition and other physical parameters. Other criteria which may be considered include safety, economic, public health, environmental, geographic, administrative, social or legal considerations, and ecological and land use objectives. Prevention of Significant Deterioration (PSD): A requirement in the CAA, which establishes the maximum allowable increases in ambient air concentrations of selected air pollutants above baseline concentrations in areas designated as Class I, Class II, or Class III. Project Plan: A strategic plan for accomplishing specific actions and goals (objectives) established in a land use plan. A project may include several activities such as cutting and hauling trees and shrubs, planting trees, building trails, and fire treatment. Regional Haze: Generally, concentrations of fine particles in the atmosphere extending up to hundreds of miles across a region and promoting noticeably hazy conditions; wide-spread visibility impairment, especially in mandatory Class I Federal areas where visibility is an important value. Sensitive Receptors: Population centers such as towns and villages, camp grounds and trails, hospitals, nursing homes, schools, roads, airports, mandatory Class I Federal areas, etc. where smoke and air pollutants can adversely affect public health, safety and welfare. Smoke Management Program (SMP): Establishes a basic framework of procedures and requirements for managing smoke from fires that are managed for resource benefits. The purposes of SMP’s are to mitigate the nuisance and public safety hazards (e.g., on roadways and at airports) posed by smoke intrusions into populated areas; to prevent deterioration of air quality and NAAQS violations; and to address visibility impacts in mandatory Class I Federal areas in accordance with the regional haze rules. State Implementation Plan (SIP): A CAA required document in which States adopt emission reduction measures necessary to attain and maintain NAAQS, and meet other requirements of the Act. Suppression: A management action intended to protect identified values from a fire, extinguish a fire, or alter a fire's direction of spread. Tribal Implementation Plan (TIP): A document authorized by the CAA in which eligible tribes adopt emission reduction measures necessary to attain and maintain NAAQS, and 36 meet other requirements of the CAA for lands within tribal jurisdictions. Violation of the PM NAAQS: As revised in 1997, the daily PM10 standard is violated when the 99th percentile of the distribution of 24-hour concentrations for a period of 1 year (averaged over 3 calendar years) exceeds 150 µg/m 3 at any monitor within an area. The annual PM10 standard is violated when the arithmetic average of 24-hour concentrations for a period of 1 year (averaged over 3 calendar years) exceeds 50 µg/m 3 at any monitor within an area. The new NAAQS levels for PM2.5 are set at a daily concentration less than or equal to 65 µg/m 3, and an annual mean concentration of less than or equal to 15 µg/m 3. The daily standard is violated when the 98th percentile of the distribution of the 24-hour concentrations for a period of 1 year (averaged over 3 calendar years) exceeds 65 µg/m 3 at any monitor within an area. The annual standard is violated when the annual arithmetic mean of the 24-hour concentrations from a network of one or more population-oriented monitors (averaged over 3 calendar years) exceeds 15 µg/m 3. Compliance with the annual PM2.5 NAAQS is based on population-oriented monitors because the health information, upon which the standard is based, relates area-wide health statistics to area-wide air quality as measured by one or more monitors. Volatile Organic Compounds (VOC): Any organic compound which participates in atmospheric photochemical reactions, which are measured by a reference method, an equivalent method, or an alternative method. Some compounds are specifically listed as exempt due to their having negligible photochemical reactivity. [See 40 CFR 51.100.] Photochemical reactions of VOC’s with oxides of nitrogen and sulfur can produce O3 and PM. Wildfire: An unwanted wildland fire. Wildland: An area where development is generally limited to roads, railroads, power lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less frequently than once in 10 years), is not fallow, and is not in the United States Department of Agriculture (USDA) Conservation Reserve Program. The land may be neglected altogether or managed for such purposes as wood or forage production, wildlife, recreation, wetlands or protective plant cover. [The distinction between wildlands, to which the recommendations in this document apply, and agricultural lands is subject to further discussion.] Wildland Fire: Any non-structural fire, other than prescribed fire, that occurs in the 37 wildland. Note: Wildland fires include unwanted (wild) fires and naturally ignited fires that are managed within a prescription to achieve resource benefits. Wildland Fire Situation Analysis (WFSA): A real time decision-making process carried out by federal land management agencies to select an appropriate management response to wildland fire. The WFSA considers fire fighter and public safety, risk to property and resources, fire fighting resources available, land management objectives and environmental, social economic and political constraints. The environmental and social constraints considered include, among other things, how air quality and/or visibility will be affected at sensitive receptors by each alternative fire management strategy. Wildland/Urban Interface: The line, area or zone where structures and other human development meets or intermingles with the wildland. 38 Appendix A-10c. Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10 –Fire Programs Arizona Regional Haze SIP NOTICE OF FINAL RULEMAKING TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL PREAMBLE 1. Sections Affected Rulemaking Action Article 6 R18-2-602 Amend Article 15 2. R18-2-1501 Amend R18-2-1502 Amend R18-2-1503 Amend R18-2-1504 Amend R18-2-1505 Amend R18-2-1506 Amend R18-2-1507 Amend R18-2-1508 Amend R18-2-1509 Amend R18-2-1510 Renumber R18-2-1510 New Section R18-2-1511 Renumber R18-2-1511 Amend R18-2-1512 Renumber R18-2-1512 Amend R18-2-1513 Renumber R18-2-1513 Amend R18-2-1514 Repeal R18-2-1514 Renumber R18-2-1514 Amend R18-2-1515 Amend The statutory authority for the rulemaking, including both the authorizing statute (general) 602ART15NFRMGRRC120903.DOC 12/9/03 1 and the statutes the rules are implementing (specific): 3. Authorizing statute: A.R.S. '' 49-414, 49-414.01 and 49-425 Implementing statutes: A.R.S. ' 49-501 The effective date of the rules: 60 days after filing with the Secretary of State. 4. A list of all previous notices appearing in the Register addressing the final rules: Notice of Rulemaking Docket Opening: 9 A.A.R. 3386, August 1, 2003 Notice of Proposed Rulemaking: 9 A.A.R. 4066, September 19, 2003 5. The name and address of agency personnel with whom persons may communicate regarding the rulemaking: Name: Kevin Force Address: Arizona Department of Environmental Quality 1110 W. Washington Ave. Phoenix, AZ 85007 Telephone: (602) 771-4480 (This number may be reached in-state by dialing 1-800-234-5677 and requesting the seven digit number.) Fax: 6. (602) 771-2366 An explanation of the rules, including the agency=s reasons for initiating the rules: Summary. This final rule amends Arizona=s existing open burning and prescribed burning rules to make them conform to EPA requirements for states= Regional Haze State Implementation Plans. In addition, these amendments make other technical changes, including improvements of the rules= clarity, conciseness, and understandability. Regional Haze SIP Requirements. The revisions to R18-2-602 and Article 15 will allow the state=s Regional Haze SIP that Arizona is required to submit to EPA by December 31, 2003, to meet the approvability test. (40 CFR 51.309(c)) The specific requirements for state regional haze SIPs are found at 40 CFR 51.308 and 51.309. Under 40 CFR 51.309(d)(6), Programs Related to Fire, the plan must provide for: 602ART15NFRMGRRC120903.DOC 12/9/03 2 A(i) Documentation that all Federal, State, and private prescribed fire programs within the State evaluate and address the degree visibility impairment from smoke in their planning and application. In addition the plan must include smoke management programs that include all necessary components including, but not limited to, actions to minimize emissions, evaluation of smoke dispersion, alternatives to fire, public notification, air quality monitoring, surveillance and enforcement, and program evaluation. (ii) A statewide inventory and emissions tracking system (spatial and temporal) of VOC, NOX, elemental and organic carbon, and fine particle emissions from fire. In reporting and tracking emissions from fire from within the State, States may use information from regional data-gathering and tracking initiatives. (iii) Identification and removal wherever feasible of any administrative barriers to the use of alternatives to burning in Federal, State, and private prescribed fire programs within the State. (iv) Enhanced smoke management programs for fire that consider visibility effects, not only health and nuisance objectives, and that are based on the criteria of efficiency, economics, law, emission reduction opportunities, land management objectives, and reduction of visibility impact. (v) Establishment of annual emission goals for fire, excluding wildfire, that will minimize emission increases from fire to the maximum extent feasible and that are established in cooperation with States, tribes, Federal land management agencies, and private entities.@ In early 2002, ADEQ's Regional Haze stakeholders established a Fire Emissions Work Group (FEWG) to discuss visibility issues related to fire emissions and make recommendations to ADEQ for the Regional Haze SIP. Fifteen stakeholders, representing public and private entities in geographically diverse areas of the state, agreed to participate in the work group. The FEWG held a series of meetings from June 2002 through May 2003 to learn about and discuss options for all categories of burning activities that occur in the state. The draft rules were presented at public workshops in Casa Grande, Flagstaff, Phoenix, Show Low, and Yuma from April 10-17, 2003. The extensive meeting schedule was proposed by work group members in order to provide local access to the rulemaking process and obtain early input from sectors of the community who would be most affected by these rules. The current final rule is a joint effort of ADEQ and the FEWG based on input received at those public meetings and the decisions of the FEWG. Structure of open burning authority in Arizona. A.R.S. ' 49-425 provides ADEQ with general air quality rule authority, including authority to promulgate rules for open burning permits. It requires the Director to adopt rules determined necessary and feasible Ato reduce the release into the atmosphere of air contaminants 602ART15NFRMGRRC120903.DOC 12/9/03 3 originating within the territorial limits of the state.@ A.R.S. ' 49-501 adds related authority by excepting from its provisions those open outdoor fires that are permitted by any rule issued pursuant to A.R.S. ' 49-425 (see subsections (C)(5)), and in(E), by allowing the director to delegate authority to issue open burn permits to a Acounty, city, town, or fire district.@ A.R.S. ' 49-414.01(A) sets forth regional haze goals and requires the Director to submit a plan to EPA that addresses Aprograms related to emissions from fire sources@ Aas necessary to submit an approvable plan@ and authorizes rules necessary for the revisions to the state implementation that address regional haze.@ R18-2-602 and A.R.S. ' 49-501 govern open burning activities under ADEQ=s jurisdiction. A.R.S. ' 49-501 was last amended in 1997. In 1996, the delegation subsection E was added. In 1994, the general permit for household waste was added. Based on the statute and rule, ADEQ published guidelines on open burning in February, 1997. Open Burning Revisions At the public meetings mentioned above, the three frequent topics for comment were: time-of-day burning restrictions in R18-2-602(D)(3), permitting requirements for air curtain destructors, and the relationship of the state rule to counties that have independent authority to permit fires. However, in the public comment period, most commenters mentioned ADEQ=s proposed inclusion of fire training in those permits that would require an open burn permit. ADEQ has returned fire training to those fires that are exempted from an open burning permit. The issue is discussed in more detail in item 11 of this preamble. Compared to the existing rule, this final rule contains a number of additional definitions in a separate subsection. ADEQ has finalized definitions for various categories of open burning, such as agricultural, construction, and residential. In addition, there are new definitions for Adelegated authority@, Aindependent authority to permit fires@, and Aprohibited materials@. Prohibited materials were previously described in the February 97 guidelines. By placing all of the necessary material from the guidelines in the final rule, ADEQ intends that this amended R18-2-602 will replace the guidelines as of the effective date of the rule. The final rule also clarifies which open burning activities require open burning permits and those that are exempt from a permit. The final rule contains a more complete list of information that is required to be in the permit. This is both for more efficient permit administration, and to comply with various aspects of the regional haze rule. 602ART15NFRMGRRC120903.DOC 12/9/03 4 ADEQ considered exempting certain fires using air curtain destructors from the open burn permit requirement in order to remove an administrative barrier to this type of burning. The Regional Haze Rule requires that administrative barriers to the use of alternatives to burning be removed wherever feasible. (See 40 CFR 51.309(d)(6)(iii)) ADEQ considered a barrier to a burning method with arguably lower emissions in the same way. Air curtain destructors (ACDs) are basically incinerators with high velocity air blown across and into the upper portion of the combustion chamber. This curtain of air traps particulates (smoke) and oxygenates the chamber, resulting in better combustion and less smoke. After reviewing two studies and considering the comments, ADEQ has remained with its conclusion that these devices do require oversight and it is appropriate that they be subject to permits under the rule. ADEQ does not view the requirement that ACDs obtain an open burning permit as much of an administrative barrier. ADEQ also notes that certain air curtain destructors are subject to New Source Performance Standards (see 40 CFR 60, subparts CCCC and DDDD). The issue is discussed in more detail in item 11 of this preamble. Studies reviewed by ADEQ relevant to air curtain destructors are listed in item 7 of this preamble. ADEQ has added language in the final rule clarifying that the state rule will not operate in counties with independent authority to permit fires, and has listed the three counties in the definition. This independent authority is derived in part from language in A.R.S. ' 49-501(C)(5) specifying that fires permitted pursuant to county rules are excepted from A.R.S. ' 49-501. The three counties referenced in the definition all have rules creating permits for open outdoor fires, other than dangerous materials. (see Maricopa County Rule 341; Pima County Rule 17.12.480, et seq.; Pinal County Rule 3-8-700 and 3-8-710.) Pursuant to A.R.S. ' 49501(G) and the current Phoenix area PM10 SIP, the Maricopa County rule prohibits burning of household waste. The final rule also clarifies provisions on burning of dangerous materials and household waste. Finally, new restrictions on permits issued by delegated authorities that minimize the potential for conflict of interest on the part of delegated authorities have been included in subsection (G). First, the final rule specifies that a delegated authority may not issue itself open burning permits. Second, the rule prohibits private fire protection providers from conditioning the issuance of open burning permits on the applicant being their customer. Final Prescribed Burning Revisions State and federal forest and range land make up more than half of the land in Arizona. Despite potential air 602ART15NFRMGRRC120903.DOC 12/9/03 5 quality concerns, state and federal land managers (F/SLMs) use fire as a resource management tool on this land for a variety of purposes. Article 15 governs those fires that are set or allowed to burn on these lands in Arizona from a general air quality perspective. The two primary air quality concerns are violations of national ambient air quality standards (NAAQS) for particulates, and visibility impairment. Research indicates that, on average, 90 percent of smoke particles from wildland and prescribed fires are PM10, and 10 percent are PM2.5. Arizona=s Prescribed Burning requirements in Article 15 address these air quality concerns, primarily through efforts to ensure the best times for >burns= and by promoting other techniques to reduce the amount of smoke produced and the effects of that smoke. A.R.S. ' 49-414.01 specifically requires the Director to submit a plan to EPA, and allows ADEQ to promulgate rules addressing programs related to emissions from wildland fire, including prescribed fires and wildfires (see A.R.S. ' 49-414.01(A)(7)). The final revisions to Article 15 of the Code, which govern the procedures relating to prescribed and wildland fires, will better conform to EPA=s regional haze requirements, be more understandable, and facilitate enhanced compliance. Most of the final changes to Article 15 directly reflect the mandates of the EPA=s regional haze rule requirements, particularly those relating to the collection and recording of burn data, the evaluation of burn programs and setting of annual emission goals. The former structure of the rule remains intact: 1) Annual registration; 2) submittal of a Burn Plan at least 14 days before the burn; 3) a daily Burn Request; and 4) a Burn Accomplishment Form. Section by Section Explanation of significant final changes. Article 6 R18-2-602 This rule describes the process by which permits may be issued for open burns, and identifies open burning activities that are exempt from the permit requirement. Article 15 R18-2-1501 This section lists the definitions applicable to Article 15. In response to the EPA regulation, there are new definitions for AAnnual Emissions Goal,@ and Anon-burning alternatives to fire.@ In addition, ABest Management Practices@ has been replaced by ASmoke management techniques@ and AEmission reduction techniques,@ and APrescribed natural fire@ has been replaced by AWildland fire use.@ R18-2-1502 This section limits the applicability of the rule to state and federal land 602ART15NFRMGRRC120903.DOC 12/9/03 6 mangers, while excluding Indian Trust lands. The final change clarifies that private burners, such as the Nature Conservancy, may also be subject to the Article. R18-2-1503 This section describes the process by which land managers annually register their planned burns with ADEQ. The final changes incorporate emission reduction techniques and non-burning alternatives to fire and facilitate the setting of annual emission goals. A new annual period and other clarifying changes have been included. R18-2-1504 This section requires the details of each burn to be included in the Burn Plan form to be submitted to ADEQ 14 days before requesting permission to ignite. The final changes clarify the process and supplement the information related to it. R18-2-1505 This section requires land mangers to submit a daily burn request for each day of the burn and describes optional agency response to the request. The final changes are primarily clarifying. R18-2-1506 This section describes how the agency will determine whether and how much burning to allow. The final changes also add clarifying factors not directly related to regional haze. R18-2-1507 This section requires land managers to report acreage and fuel types burned, the emission reduction and smoke management techniques used, and requires ADEQ to keep records of this information. A subsection has been added for wildfire reporting to allow those fires= emissions to be entered into the regional haze emission tracking system. R18-2-1508 This section describes how land managers shall inform the agency of wildfires and seek permission for wildland burn uses. Clarifications have been included based on recent experiences with wildfires. R18-2-1509 This section replaces the former BMP section and describes Emission Reduction Techniques, many of which were listed previously as BMPs. It requires land mangers to use as many as feasible. R18-2-1510 This section also replaces the former BMP section and describes Smoke Management Techniques, some of which were listed previously as BMPs. It requires land managers to use as many as feasible. R18-2-1511 This section describes how the agency may require land managers to 602ART15NFRMGRRC120903.DOC 12/9/03 7 monitor aspects of their prescribed burns and wildland burn uses. The final changes are clarifications and minor changes to weather and air quality monitoring. R18-2-1512 This section requires all burn projects to be conducted by personnel trained in prescribed fire and smoke management techniques. The final changes are clarifications. R18-2-1513 This section directs the agency to conduct burn-related public awareness programs and make burn information available to the public. The final changes attempt to promote regional coordination. R18-2-1514 This section describes how the agency may inspect, verify, and audit burn information, and actions the agency may take regarding enforcement. R18-2-1514(former) In a recent 5-year-review report, ADEQ stated that it would reevaluate the need for this section. ADEQ is deleting subsection (B) because the changes in R18-2-1503 provide for a more efficient and effective system. Subsection (A) has been moved to R18-2-1511(B). R18-2-1515 This section directs the agency to make its forms and data relating to prescribed burns and wildland burn uses available in an electronic format. The final changes are clarifying only. 7. A reference to any study relevant to the rules that the agency reviewed and either relied on in its evaluation of or justification for the rules or did not rely on in its evaluation of or justification for the rules, where the public may obtain or review each study, all data underlying each study, and any analysis of each study and other supporting material: The Use of Air Curtain Destructors for Fuel Reduction, Alan R. Shapiro, United States Department of Agriculture, Forest Service Technology and Development Program (September 2002). Reducing PM2.5 Emissions Through Technology, Evaluations of the Effectiveness of an Air Curtain Incinerator, Ronald A. Scott, Ronald Babbitt, Emily Lincoln, and Wei Min Hao, USDA Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory, Missoula MT (October 2002) Studies available for review at the ADEQ Library, First Floor, 1110 W. Washington St., Phoenix, AZ 85007. 8. A showing of good cause why the rules are necessary to promote a statewide interest if the rules 602ART15NFRMGRRC120903.DOC 12/9/03 8 will diminish a previous grant of authority of a political subdivision of this state: Not Applicable 9. The summary of the economic, small business, and consumer impact: A. Rule Identification The sixteen rules amended in this rulemaking are R18-2-602, AUnlawful Open Burning,@ and Article 15, AForest and Range Management Burns,@ R18-2-1501 through R18-2-1515. B. Entities Affected by R18-2-602, AUnlawful Open Burning@ Open burning may be done by many entities for a variety of purposes, such as waste disposal, weed control, site preparation, disease and pest prevention, resource management, and training and fire prevention. Unless specifically exempted by this rule, persons setting outdoor fires would have to obtain a permit from ADEQ or a delegated authority, a city or fire district, or one of the three counties with independent authority to issue permits (Maricopa, Pima, Pinal). Persons who might be subject to this final rule therefore include: (1) individuals; (2) businesses, such as farms, ranches, orchards, electric generating plants, construction and mines; (3) federal sources, such as military installations; (4) state agencies, such as the Departments of Transportation and Corrections; and, (5) political subdivisions, such as counties, cities, irrigation districts, and fire districts. ADEQ has delegated authority to issue permits to about 50 fire departments, fire districts and cities or towns located in 9 of Arizona=s 15 counties. Authority to issue permits in Graham County is delegated to Graham County Health Department, while Maricopa, Pima and Pinal Counties have independent authority to permit fires. ADEQ has jurisdiction to issue permits in areas outside the delegated authorities= jurisdiction in these counties. ADEQ typically issues more than 100 open burning permits annually to a wide variety of permittees, most of which are for burns in Gila and Cochise Counties. Permits for burns in LaPaz, Yavapai, Santa Cruz, Apache, Greenlee and Coconino Counties are also common. The following represents a sampling of the level of permits issued by delegated authorities based on the calendar year 2002. The City of Prescott in Yavapai County issued about 200 permits in 2002, of which the majority was for residential burning. The City of Yuma issued 15 open burning permits, mainly for agriculture. Rural Metro Fire Department, which has jurisdiction outside of the municipalities of Somerton 602ART15NFRMGRRC120903.DOC 12/9/03 9 and Yuma, typically issues 300-400 residential open burning permits and 50-60 permits for agriculture in Yuma County. The City of Payson in Gila County issued 146 open burning permits for brush and weeds. Bullhead City in Mohave County annually issues 50-70 open burning permits of which the majority is for residential burning. The 384 open burning permits issued by Graham County Health Department in fiscal year 2003 were all for purposes of weed abatement. C. Potential Impact of R18-2-602 This rulemaking only makes minor changes and incorporates current practice, therefore ADEQ expects the rule to create minimal actual impact, such as the costs associated with minor changes in record-keeping, documentation, and reporting requirements. ADEQ and delegated authorities will have to maintain copies of effective permits, as well as prepare annual reports for submission to ADEQ. While some of these changes will generate minimal costs, ADEQ expects the overall benefits to exceed those costs. It should also be noted that ADEQ does not charge fees for open burning permits because most permits are issued in a day or two and it would require minimal administrative effort. D. Entities Affected by Article 15, AForest and Range Management Burns@ Since ADEQ has jurisdiction, outside tribal lands, over air pollution resulting from prescribed burning, this rule will impact the following federal and state agencies that do burning: (1) Federal Land Managers (FLMs) involved in burning activities, such as U.S. Forest Service, U.S. Fish and Wildlife Service, National Parks Service, Bureau of Land Management, Bureau of Reclamation, Department of Defense; (2) State Land Managers (SLMs), such as Arizona State Land Department, Arizona Department of Transportation, Arizona Department of Game and Fish, and Parks Department. Additionally, there are entities not actually subject to this rule but who may voluntary comply with some or all of the rule provisions, such as the Bureau of Indian Affairs, one of the largest burners in Arizona. Also, private land managers, such as The Nature Conservancy, or individuals, might also need to comply with this rule or request assistance from one of the F/SLMs. Each year, ADEQ receives more than 1,000 daily burn requests from F/SLMs. For example, in calendar year 2002, about 1,400 requests to burn were received, and slightly more than 104,000 acres were burned, which represents about 56 percent of the total acres approved to burn. This figure is approximately equal to the the number of acres burned each year for the past ten years (106,429) on federal, state, and tribal lands. The major fuel types burned in 2002 and their relative proportions include: piled ponderosa pine (22%), non-piled ponderosa pine (21%), and natural ponderosa pine (17%). The remaining 40% of fuel types include: natural 602ART15NFRMGRRC120903.DOC 12/9/03 10 shrub, non-piled grass and ponderosa pine, natural grass, natural grass and ponderosa pine, non-piled mixed, and other. For comparison, in 1999, F/SLMs requested nearly 450,000 acres to burn. Although ADEQ approved close to 80 percent of the requested acreage, the actual number of acres burned was about 200,000. The fuel types burned in 1999 were: broadcast slash (32%), ponderosa pine (22%), grass (20%), slash piles (14%), brush (10%), and pinyon juniper (2%). As shown with these two years, proportions, however, vary from one year to another. Combining acres burned for 1994 through 1999, shows the percentage of acres burned by F/SLMs agencies: U.S. Forest Service (49%), Bureau of Indian Affairs (30%), National Park Service (7%), Bureau of Land Management (7%), U.S. Fish and Wildlife (6%), Arizona State Land Department (1%), and other (1%). E. Potential Impact of Article 15 Because this rule involves forest and range management burning by federal and state land managers, private persons, political subdivisions of the state, and small businesses will not bear any direct incremental costs from the final rule changes. However, because the rule requires both better tracking of emissions, better management of smoke, and public education and notification, benefits are expected to accrue to the public, particularly to populations living close to the burns. Specifically, there is potential for incremental benefits arising from better planning and implementation of measures which increase burn efficiency, prevent wildfires, improve visibility, and reduce smoke impacts to both the general public and more sensitive segments of the population. F/SLMs currently pay for two full-time positions to work with ADEQ at an estimated annual value of $120,000 at ADEQ. Office space and equipment are provided by ADEQ. ADEQ currently supports one fulltime position for the smoke management program. Although implementing this amended rule may require minimally increased planning and evaluation time, ADEQ does not expect to need additional employees to handle the workload. This increased workload, together with administrative costs associated with making burn information publicly available and conducting public awareness programs, are all that comprise the incremental impact to ADEQ. Thus, ADEQ judges that the costs to the agency are minimal. The incremental impact of the changes to Article 15 is based on the rule=s new requirements, and are 602ART15NFRMGRRC120903.DOC 12/9/03 11 expected to result in minimal economic impact to F/SLMs and ADEQ. For example, F/SLMs will have to provide more information about their prescribed burns, including emission reduction techniques and nonburning alternatives. They will also be encouraged to attend annual meetings for program evaluation and the establishment of annual emissions goals, and will be looked to for the development of long-term projections of future prescribed fire and wildland fire use activities. The information provided by F/SLMS will be used by ADEQ to assess visibility impairment and other air quality concerns. Additional compliance costs include those associated with the incorporation of additional emission reduction and smoke management techniques. Together, these rule changes are expected to improve the state=s smoke management program, which could lead to improvements in air quality through reduction and better management of burns. Evidence shows that exposure to criteria pollutants, either to individual pollutants such as particulate matter (PM), or collectively to a variety of pollutants, is associated with increased mortality. The positive correlation is most closely related to ambient air concentrations of PM. Human health effects of PM, for example, include premature mortality, bronchitis, new asthma cases and exacerbated asthma in existing individuals, increased hospital admissions, lower and upper respiratory illness, shortness of breath, respiratory symptoms, restricted activity days, and lost days of work. Other health effects ascribed to exposure to PM include changes in pulmonary function, chronic respiratory diseases (other than chronic bronchitis), morphological changes, neonatal mortality, cancer, altered host defense mechanisms, and non-asthma respiratory emergency room visits. Estimated economic values have been assigned to death and other adverse health effects. For example, a statistical death has been estimated to cost $6.3 million (in year 2000 dollars), chronic bronchitis due to PM costs $260,000 per patient, mortality life years lost is valued at $293,000 per each life year, and work days lost due to PM is worth about $83 per day. (EPA, The Benefits and Costs of the Clean Air Act 1990-2010, Office of Air and Radiation, Office of Policy, November 1999, Table 5-1.) F. Reduction of Impacts to Small Businesses for R18-2-602 and Article 15 These rules create minimal increased compliance costs for ADEQ to administer the open burning and prescribed forestry burning programs. ADEQ considered each of the methods prescribed in A.R.S. ' 41-1035 for reducing the impact on small businesses. Likewise, it considered each of the methods prescribed in A.R.S. ' 41-1055(B)(5)(c). For example, A.R.S. ' 41-1035 requires agencies implementing rules to reduce the impacts on small businesses by using certain methods where legal and feasible. Methods that may be used include the following: (1) exempt them from any or all rule requirements, (2) establish performance standards which could replace more costly design or operational requirements, or (3) institute reduced compliance or 602ART15NFRMGRRC120903.DOC 12/9/03 12 reporting requirements. ADEQ cannot provide additional regulatory relief for small businesses applying for open burning permits. As the agency does not charge fees for open burning permits, ADEQ expects that R18-2-602's reporting requirement (on forms developed by ADEQ) will create minimal economic impacts to individual persons or small businesses. The rule procedures have been kept as simple and straightforward as possible. Article 15 does not directly impact small businesses as it applies primarily to public entities. 10. A description of the changes between the proposed rules, including supplemental notices, and final rules (if applicable): In response to comments, and to improve clarity, conciseness, and understandability, ADEQ has made the following changes to the proposed rule: ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES R18-2-602. A. Unlawful Open Burning In addition to the definitions contained in A.R.S. ' 49-501, in this Section: 1. AAgricultural Burning burning@ means burning of vegetative materials related to the production producing and harvesting of crops and raising of animals for the purpose of marketing for profit, or providing a livelihood, but does not including include the burning of household waste or prohibited materials. Burning may be conducted A person may conduct agricultural burns in fields, piles, ditch banks, fence rows, or canal laterals for purposes such as weed control, waste disposal, disease and pest prevention, or site preparation. 2. AApproved waste burner@ means an incinerator constructed of fire resistant material with a cover or screen which that is closed when in use having and has openings in the sides or top no greater than one inch in diameter. 3. AClass I Area@ means any one of the Arizona mandatory federal class I areas defined in A.R.S. ' 49-401.01. 4. AConstruction burning@ means burning of wood or vegetative material from land clearing, site preparation, or fabrication, erection, installation, demolition, or modification of any buildings or other land improvements, but does not including include the burning of household waste or prohibited materials material. 5. ADangerous material@ is means any substance or combination of substances that is capable 602ART15NFRMGRRC120903.DOC 12/9/03 13 of causing bodily harm or property loss unless neutralized, consumed, or otherwise disposed of in a controlled and safe manner. 6. ADelegated authority@ means any of the following: a. A county, city, town, air pollution control district, or fire district that has been delegated authority to issue open burning permits by the Director under A.R.S. ' 49-501(E); or b. A private fire protection service provider that has been assigned authority to issue open burning permits by one of the authorities in subsection (a). 7. ADirector@ means the Director of the Department of Environmental Quality, or his designee. 8. AEmission reduction techniques@ are means techniques methods for controlling emissions from open outdoor fires to minimize the amount of emissions output per unit or of area burned. 9. AFlue,@ as used in this subsection Section, means any duct or passage for air or combustion gases, such as a stack or chimney. 10. AHousehold waste@means any solid waste including garbage, rubbish, and sanitary waste from a septic tanks tank that is generated from households including single and multiple family residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas, but does not including include construction debris, landscaping rubble, or demolition debris. 11. AIndependent authority to permit fires@ means the authority of a county to permit fires by a rule adopted pursuant to under Arizona Revised Statutes, Title 49, Chapter 3, Article 3, and includes only Maricopa, Pima, and Pinal counties. have independent authority to permit fires. 12. AOpen outdoor fire or open burning@ means the combustion of material of any type outdoors, and in the open, where the products of combustion are not directed through a flue. Open outdoor fires include agricultural, residential, prescribed, and construction burning, and fires using air curtain destructors. Purposes for fires can include prevention of a fire hazard, instruction in the methods of fighting fires, watershed rehabilitation, disease and pest prevention. 13. AProhibited materials@ means nonpaper garbage from the processing, storage, service, or consumption of food; chemically treated wood; lead-painted wood; linoleum flooring, or composite counter-tops; tires; explosives or ammunition; oleanders; asphalt shingles; tar 602ART15NFRMGRRC120903.DOC 12/9/03 14 paper; plastic and rubber products, including bottles for household chemicals; plastic grocery and retail bags; waste petroleum products, such as waste crankcase oil, transmission oil, and oil filters; transformer oils; asbestos; batteries; anti-freeze; aerosol spray cans; electrical wire insulation; thermal insulation; polyester products; hazardous waste products such as paints, pesticides, cleaners and solvents, stains and varnishes, and other flammable liquids; plastic pesticide bags and containers; and hazardous material containers including those that contained lead, cadmium, mercury, or arsenic compounds. 14. AResidential burning@ means open burning of vegetative materials conducted by or for the occupants of residential dwellings, but does not including include burning of household waste or prohibited materials material. 15. B. APrescribed burning@ has the same meaning as in R18-2-1501. Unlawful open burning. Notwithstanding any other rule in this Chapter, it is unlawful for any a person to shall not ignite, cause to be ignited, permit to be ignited, or suffer, allow, or maintain any open outdoor fire in a county without independent authority to permit fires except as provided in A.R.S. ' 49-501 and this Section. C. Open outdoor fires exempt from a permit. The following fires do not require an open burning permit from the Director or a delegated authority: 1. Fires used only for: a. Cooking of food;, b. Providing warmth for human beings;, c. Recreational purposes;, d. Branding of animals;, e. Orchard heaters for the purpose of frost protection in farming or nursery operations;, and f. 2. The proper disposal of flags under 4 U.S.C. ' 8. Any fire set or permitted by any public officer in the performance of official duty, if such the fire is set or permission given for the following purpose of: a. Fire Control of an active wildfire; or b. Instruction in the method of fighting fires, except that the person setting these fires must comply with the reporting requirements of subsection (D)(3)(f). 3. Fires Fire set by or permitted by the Director of Department of Agriculture for the purpose of disease and pest prevention in an organized, area-wide control of an epidemics or 602ART15NFRMGRRC120903.DOC 12/9/03 15 infestations infestation affecting livestock or crops. 4. Prescribed burns set by or assisted by the federal government or any of its departments, agencies or agents, or the state or any of its agencies, departments, or political subdivisions, pursuant to regulated under Article 15 of this Chapter. D. Open outdoor fires requiring a permit. 1. The following open outdoor fires are allowed with an open burning permit from the Director or a delegated authority: a. Construction burning; b. Agricultural burning; c. Residential burning; d. Prescribed burns conducted on private lands without the assistance of a federal or state land manager as defined under R18-2-1501; e. Any fire set or permitted by a public officer in the performance of official duty, if such the fire is set or permission given for the purpose of weed abatement, the prevention of a fire hazard, or instruction in the methods of fighting fires, unless such the fire is exempt from the permit requirement under subsection (C)(3); 2. f. Open outdoor fires of dangerous material under subsection (E); and g. Open outdoor fires of household waste under subsection (F).; and h. Open outdoor fires that use an air curtain destructor, as defined in R18-2-101. A person conducting an open outdoor fire in a county without independent authority to permit fires shall obtain a permit from the Director or a delegated authority unless exempted under subsection (C). Permits may be issued for a period not to exceed one year. A person shall obtain a permit by completing an ADEQ-approved application form. 3. Open outdoor fire permits issued under this Section shall include: a. A list of the materials that the permittee may be burned burn under the permit; b. A means of contacting the person permittee authorized by the permit to set an open fire in the event that an order to extinguish the open outdoor fire is issued by the Director or the delegated authority; c. A requirement that burns be conducted during the following periods, unless otherwise waived or directed by the Director on a specific day basis: i. Year round: start ignition ignite fire no earlier than 1one hour after sunrise; and ii. Year round: extinguish fire must be extinguished no later than 2two hours 602ART15NFRMGRRC120903.DOC 12/9/03 16 before sunset. d. A requirement that the permittee conduct all open burning shall be conducted only during atmospheric conditions which that: i. Prevent dispersion of smoke into populated areas; ii. Prevent visibility impairment on traveled roads or at airports that results in a safety hazard; e. iii. Do not create a public nuisance or adversely affect public safety; iv. Do not cause an adverse impact to visibility in a Class I area; and v. Do not cause uncontrollable spreading of the fire; A listing list of the types of actions emission reduction techniques that the permittee shall be utilized use to minimize fire emissions; including any emission reduction techniques; f. A reporting requirement that the permittee shall be met meet by providing the following information in a format provided by the Director for each date open burning occurred, on either a daily basis on the day of the fire, or in an annual basis in a report to the Director or delegated authority due on March 31 for the previous calendar year: i. The date of the burn; ii. The type and quantity of fuel burned for each date open burning occurred; iii. The fire type, such as pile or windrow pit, for each date open burning occurred; and iv. For each date open burning occurred, the legal location, to the nearest section, or latitude and longitude, to the nearest degree minute, or street address for residential burns. g. A requirement that the person conducting the open burn notify the local fire-fighting agency, or private fire protection service provider, if the service provider is a delegated authority, before burning. or If none neither is in existence, the person conducting the burn shall notify the state forester., prior to commencement of open burning; h. A requirement that the permittee start each open outdoor fire be started using items that do not cause the production of black smoke; i. A requirement that the permittee attend the fire shall be attended at all times until it is completely extinguished; 602ART15NFRMGRRC120903.DOC 12/9/03 17 j. A requirement that the permittee provide fire extinguishing equipment must be onsite for the duration of the burn; k. A requirement that the permittee ensure that a burning pit, burning pile, or approved waste burner be at least 50 feet from any structure; l. A requirement that the burner must permittee have a copy of the burn permit on-site during open burning; m. A requirement that the permittee not conduct no open burning shall be conducted when an air stagnation advisory, as issued by the National Weather Service, is in effect in the area of the burn or during periods when smoke can be expected to accumulate to the extent that it will significantly impair visibility in Class I areas; n. A requirement that the permittee not conduct no open burning shall be conducted when any stage air pollution episode is declared under R18-2-220. o. A statement that the Director, or any other public officer may order that the burn be extinguished or prohibit burning during periods of inadequate smoke dispersion, excessive visibility impairment, or during periods of extreme fire danger; and p. A copy list of the activities prohibited and the criminal penalties provided under A.R.S. ' 13-1706. 4. The Director or a delegated authority shall not issue an open burning permit under this Section: a. That would allow the burning of prohibited materials other than under a permit for the burning of dangerous materials; b. If the applicant has applied for a permit under this Section to burn a dangerous materials material which are is also hazardous waste under 40 CFR 261, but does not have a permit for the burning to burn of hazardous waste under 40 CFR 264, or is not an interim status facility allowed to burn hazardous waste under 40 CFR 265; or c. If the burning would occur at a solid waste facility in violation of 40 CFR 258.24 and the Director has not issued a variance approval under A.R.S. ' 49-763.01(A). E. Open outdoor fires of dangerous material. A fires fire set for the disposal of a dangerous materials material are is allowed by the provisions of this Section, when the materials material are is too dangerous to store and transport, as permitted in writing by and the Director has issued a permit for the fire. A permits permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The Director shall permit fires set for the disposal of dangerous materials shall be permitted only when there is no safe alternative method of 602ART15NFRMGRRC120903.DOC 12/9/03 18 disposal exists, and when the burning of such the materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts that will endanger health or safety. F. Open outdoor fires of household waste. An open outdoor fires fire for the disposal of household waste are is allowed by provisions of this Section when permitted in writing by the Director or a delegated authority. Permits A permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The applicant shall conduct open outdoor fires of household waste shall be burned in an approved waste burner and shall either: 1. Burn household waste generated on-site on farms or ranches of 40 acres or more where no household waste collection or disposal service is available; or 2. Burn household waste generated on-site where no household waste collection and disposal service is available and where the nearest other dwelling unit is at least 500 feet away. G. Permits issued by a delegated authority. The Director may delegate authority for the issuance of open burning permits to a county, city, town, air pollution control district, or fire district. A delegated authority may not issue a permit for its own open burning activity. Authority The Director shall not delegate authority for issuance of permits to burn dangerous material under subsection (E). shall be retained by the Director and not delegated. A county, city, town, air pollution control district, or fire district with delegated authority from the Director may assign that authority to one or more private fire protection service providers that perform fire protection services within the county, city, town, air pollution control district, or fire district. A private fire protection provider shall not directly or indirectly condition the issuance of open burning permits on the applicant being a customer. Permits issued under this subsection shall comply with the requirements in subsection (D)(3) and be in a format prescribed by the Director. Each delegated authority shall: 1. Maintain a copy of each permit issued for the previous five years available for inspection by the Director; 2. For each permit currently issued, have a means of contacting the person authorized by the permit to set an open fire in the event that if an order for extinguishing of to extinguish open burning is issued; and 3. Annually submit to the Director by May 15 a record of daily burn activity, excluding household waste burn permits, on a form provided by the Director for the previous calendar year containing the information required in subsections (D)(3)(e) and (D)(3)(f). H. The Director shall hold an annual public meeting for interested parties to review operations of the open outdoor fire program and discuss emission reduction techniques. 602ART15NFRMGRRC120903.DOC 12/9/03 19 I. Nothing in this Section is intended to permit any practice which that is a violation of any statute, ordinance, rule, or regulation. ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS R18-2-1501. Definitions In addition to the definitions contained in A.R.S. ' 49-501 and R18-2-101, in this Article: 1. AActivity fuels@ means those fuels created by human activities such as thinning or logging. 1.2. "ADEQ" means the Department of Environmental Quality. 2.3. AAnnual emissions goal@ means the annual establishment in cooperation with the F/SLM=s, under R18-2-1503(G), of a planned quantifiable value of emissions reduction from prescribed fires and fuels management activities. 3.4. ABurn plan@ means the ADEQ form that includes information on the conditions under which the a burn will occur with details of the burn and smoke management prescriptions. 4.5. "Burn prescription" means, with regard to a burn project, the pre-determined area, fuel, and weather conditions required to attain planned resource management objectives. 5.6. "Burn project" means an active or planned prescribed burn, including a wildland fire use incident. 6.7. "Duff" means forest floor material consisting of decomposing needles and other natural materials. 7.8. AEmission reduction techniques (ERT)@ means techniques methods for controlling emissions from prescribed fires to minimize the amount of emission output per unit of area burned. 8.9. AFederal land manager (FLM)@ means any department, agency, or agent of the federal government, including the following: 9.10. a. United States Forest Service, b. United States Fish and Wildlife Service, c. National Park Service, d. Bureau of Land Management, e. Bureau of Reclamation, f. Department of Defense, g. Bureau of Indian Affairs, and h. Natural Resources Conservation Service. "F/SLM" means a federal land manager or a state land manager. 10.11. "Local fire management officer" means a person designated by a F/SLM as responsible for fire management in a local district or area. 602ART15NFRMGRRC120903.DOC 12/9/03 20 11.12. "Mop-up" means the act of extinguishing or removing burning material from a prescribed fire to reduce smoke impacts. 12.13. "National Wildfire Coordinating Group" means the national inter-agency group of federal and state land managers that shares similar wildfire suppression programs and that has established standardized inter-agency training courses and qualifications for fire management positions. 13.14. ANon-burning alternatives to fire@ are means techniques that replace fire for at least five years as a means to treat activity fuels created to achieve a particular land management objective (e.g., reduction of fuel-loading, manipulation of fuels, enhancement of wildlife habitat, and ecosystem restoration, etc.). These alternatives are not used in conjunction with fire. Techniques used in conjunction with fire are referred to as emission reduction techniques (ERTs). 14.15. "Planned resource management objectives" means public interest goals in support of land management agency objectives including silviculture, wildlife habitat management, grazing enhancement, fire hazard reduction, wilderness management, cultural scene maintenance, weed abatement, watershed rehabilitation, vegetative manipulation, and disease and pest prevention. 15.16. "Prescribed burning" means the controlled application of fire to wildland fuels that are in either a natural or modified state, under certain burn prescription conditions and smoke management prescription conditions that have been specified by the land manager in charge of or assisting the burn, to attain planned resource management objectives. Prescribed burning does not include a fire set or permitted by a public officer to provide instruction in fire fighting methods, or construction or residential burning under R18-2-602. 16.17. "Prescribed fire manager" means a person designated by a F/SLM as responsible for prescribed burning for that land manager. 17.18. "Smoke management prescription" means the predetermined meteorological conditions that affect smoke transport and dispersion under which a burn could occur without adversely affecting public health and welfare. 18.19. ASmoke management techniques@ (SMT) means management and dispersion practices used during a prescribed burn or wildland fire use incident which affect the direction, duration, height, or density of smoke. 19.20. "Smoke management unit" means any of the geographic areas defined by ADEQ whose area is based on primary watershed boundaries and whose outlines are outline is determined by diurnal windflow patterns that allow smoke to follow predictable drainage patterns. A map of the state divided into the smoke management units is on file with ADEQ. 20.21. "State land manager (SLM)" means any department, agency, or political subdivision of the state 602ART15NFRMGRRC120903.DOC 12/9/03 21 government including the following: a. State Land Department, b. Department of Transportation, c. Department of Game and Fish, and d. Parks Department. 21.22. "Wildfire" means an unplanned wildland fire subject to appropriate control measures. Wildfires include those incidents where suppression may be limited for safety, economic, or resource limitations concerns. 22.23. AWildland fire use@ means a wildland fire that is ignited by natural causes, such as lightning, that and is subsequently managed using the same controls and for the same planned resource management objectives as prescribed burning. R18-2-1502. A. Applicability A F/SLM that is conducting or assisting a prescribed burn shall follow the requirements of this Article. B. A private or municipal burner with whom ADEQ has entered into a memorandum of agreement shall follow the requirements of this Article. C. The provisions of this Article apply to all areas of the state except Indian Trust lands. All federallymanaged lands and all state lands, parks, and forests are under the jurisdiction of ADEQ in matters relating to air pollution from prescribed burning. D. Notwithstanding subsection (B) (C), ADEQ and any Indian tribe may enter into a memorandum of agreement to implement this Article. E. ADEQ and any private or municipal prescribed burner may enter into a memorandum of agreement to implement this Article. R18-2-1503. A. Annual Registration, Program Evaluation and Planning Each F/SLM shall register annually with ADEQ on a form prescribed by ADEQ, all planned burn projects, including areas planned for wildland fire use. B. Each planned year extends from January 1 of the registration year to December 31 of the same year. Each F/SLM shall use best efforts to register before December 31 and no later than January 31 of each year. C. A F/SLM shall include the following information on the registration form: 602ART15NFRMGRRC120903.DOC 12/9/03 22 1. The F/SLM's name, address, and business telephone number; 2. The name, address, and business telephone number of an air quality representative who will provide technical support to ADEQ for decisions regarding prescribed burning. The same air quality representative may be selected by more than one F/SLM; 3. All prescribed burn projects and potential wildland fire use areas planned for the next year; 4. By prescribed burn project, Maximum project and annual acres to be burned, maximum daily acres to be burned, fuel types within project area, and planned use of emission reduction techniques to support the annual emissions goal for each prescribed burn project; 5. By prescribed burn project, Planned use of any smoke management techniques for each prescribed burn project; 6. By area planned for wildland fire use, Maximum project and annual acres projected to be burned, maximum daily acres projected to be burned, and a map of the anticipated project area, fuel types and loading within the planned area for an area the F/SLM anticipates for wildland fire use; 7. A list of all burn projects that were completed during the previous year; 8. By area to be treated using non-burning alternatives to fire, Project area for treatment, treatment type, fuel types to be treated, and activity fuel loading to support the annual emissions goal for areas to be treated using non-burning alternatives to fire; and 9. The area treated using non-burning alternatives to fire utilized during the previous year including the number of acres, the specific types of alternatives utilized, and the location of these areas. D. After consultation with the F/SLM, ADEQ may request additional information for registration of prescribed burns and wildland fire use to support regional coordination of smoke management, annual emission goal setting utilizing using ERTs, and non-burning alternatives to fire. E. A F/SLM may amend a registration at any time with a written submission to ADEQ. F. ADEQ shall accept accepts a facsimile or other electronic methods as a means of complying with the deadline for registration. If an electronic means are is used, the F/SLM shall deliver the original paper registration form to ADEQ for its records. ADEQ shall acknowledge in writing the receipt of each registration. G. ADEQ shall hold an annual a meeting after January 31 and prior to before April 1 of each year between ADEQ and F/SLM=s for program evaluation to evaluate the program and to cooperatively establish the annual emission goal. The annual emission goal shall be developed to minimize prescribed fire emissions to the maximum extent feasible using emission reduction techniques and 602ART15NFRMGRRC120903.DOC 12/9/03 23 alternatives to burning subject to economic, technical, and safety feasibility criteria, and consistent with land management objectives. H. At least once every five years, ADEQ shall request long-term projections of future prescribed fire and wildland fire use activity from the F/SLMs to support planning for visibility impairment and assessment of other air quality concerns by ADEQ. R18-2-1504. Prescribed Burn Plan Each F/SLM planning a prescribed burn, shall complete and submit to ADEQ the "Burn Plan" form supplied by ADEQ no later than 14 days before the date on which the F/SLM requests permission to burn. The information supplied on the Burn Plan Form are considered ADEQ shall consider the information supplied on the Burn Plan Form as binding conditions under which the burn shall be conducted. A Burn Plans shall be maintained by ADEQ until notification from the F/SLM of the completion of the burn project. Revisions to the Burn Plan for a burn project shall be submitted in writing no later than 14 days before the date on which the F/SLM requests permission to burn. To facilitate the Daily Burn authorization process under R18-2-1505, the F/SLM shall include on the Burn Plan form: 1. An emergency telephone number that is answered 24 hours a day, seven days a week; 2. Burn prescription; 3. Smoke management prescription; 4. The number of acres to be burned, the quantity and type of fuel, type of burn, and the ignition technique to be used; 5. The land management objective or purpose for the burn such as restoration or maintenance of ecological function and indicators of fire resiliency; 6. A map depicting the potential impact of the smoke unless waived either verbally orally or in writing by ADEQ. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the burn site, with smoke-sensitive areas delineated. The map shall use the appropriate scale to show the impacts of the smoke adequately; 7. Modeling of smoke impacts unless waived either verbally orally or in writing by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulates, a carbon monoxide non-attainment area, or other smoke-sensitive area. In consultation with the F/SLM, ADEQ shall provide guidelines on modeling; 8. The name of the official submitting the Burn Plan on behalf of the F/SLM; and 602ART15NFRMGRRC120903.DOC 12/9/03 24 9. After consultation with the F/SLM, any other information to support the Burn Plan needed by ADEQ to assist in the Daily Burn authorization process for smoke management purposes or assessment of contribution to visibility impairment of Class I areas. R18-2-1505. A. Prescribed Burn Requests and Authorization Each F/SLM planning a prescribed burn, shall complete and submit to ADEQ the "Daily Burn Request" form supplied by ADEQ. The Daily Burn Request form shall include: 1. The contact information of the F/SLM conducting the burn; 2. Each day of the burn; 3. The area to be burned on that the day for which the Burn Request is submitted, with reference to the Burn Plan, including size, legal location to the section and latitude/ and longitude to the minute; 4. Projected smoke impacts; and 5. Any local conditions or circumstances known to the F/SLM that, if conveyed to ADEQ, could impact the Daily Burn authorization process. B. After consultation with the F/SLM, ADEQ may request additional information related to the burn, meteorological, smoke dispersion, or air quality conditions to supplement the Daily Burn Request form and to aid in the Daily Burn authorization process. C. The F/SLM shall submit the Daily Burn Request form to ADEQ as expeditiously as practicable, but no later than 2 p.m. of the business day preceding the burn. An original form, a facsimile, or an electronic information transfer are acceptable submittals. D. An F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ, as follows: 1. ADEQ shall approve, approve with conditions, or disapprove a burn on the same business day as the Burn Request submittal. 2. If ADEQ fails to address a Burn Request by 10 p.m. of the business day on which the request was is submitted, the Burn Request is approved by default after the burner makes a good faith effort to contact ADEQ to confirm that the Burn Request was received. 3. ADEQ may communicate its decision by verbal, written, or electronic means. ADEQ shall provide a written or electronic reply if requested by the F/SLM. E. If weather conditions cease to conform to those in the smoke management prescription of either the Burn Plan or an Approval with Conditions, the F/SLM shall take appropriate action to reduce further smoke impacts, ensure safe and appropriate fire control, and notify the public when necessary. After consultation with ADEQ, the smoke management prescription or burn plan may be modified. 602ART15NFRMGRRC120903.DOC 12/9/03 25 F. The F/SLM is responsible for shall ensure that there is appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a prescribed fire. R18-2-1506. Smoke Dispersion Evaluation ADEQ shall approve, approve with conditions, or disapprove a Daily Burn Request submitted pursuant to under R18-2-1505, by using the following factors for each smoke management unit: 1. Analysis of the emissions from burns in progress and residual emissions from previous burns on a day-to-day basis; 2. Analysis of emissions from active wildland fire use incidents, and active multiple-day burns, and consideration of potential long-term emissions estimates; 3. Analysis of the emissions from wildfires greater than 100 acres and consideration of their potential long-term growth; 4. Local burn conditions; 5. Burn prescription and smoke management prescription from the applicable Burn Plan; 6. Existing and predicted local air quality; 7. Local and synoptic meteorological conditions; 8. Type and location of areas to be burned; 9. Protection of the national visibility goal for Class I Areas pursuant to under ' 169A(a)(1) of the Act and 40 CFR 51.309; 10. Assessment of duration and intensity of smoke emissions to minimize cumulative impacts; and 11. Minimization of smoke impacts in Class I Areas, areas that are non-attainment for particulate matter, carbon monoxide non-attainment areas, or other smoke-sensitive areas.; and 12. R18-2-1507. A. Protection of the National Ambient Air Quality Standards. Prescribed Burn Accomplishment; Wildfire Reporting Each F/SLM conducting a prescribed burn shall complete and submit to ADEQ the "Burn Accomplishment" form supplied by ADEQ. For each burn approval, the F/SLM shall submit a Burn Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burning burn. The F/SLM shall include the following information on the Burn Accomplishment form: 1. Any known conditions or circumstances that could impact the Daily Burn decision process; 2. The date, location, fuel type, fuel loading, and acreage accomplishments; 3. The ERTs and SMTs described in R18-2-1509 and R18-2-1510, respectively, and may 602ART15NFRMGRRC120903.DOC 12/9/03 26 include any further ERTs and SMTs that become available, that the F/SLM used to reduce emissions or manage the smoke from the burn. B. The F/SLM shall submit the Burn Accomplishment form as an original form, a facsimile, or an electronic information transfer. C. ADEQ shall maintain a record of Burn Requests, Burn Approvals/Conditional Approvals/Denials and Burn Accomplishments for 5 five years. D. The F/SLM in whose jurisdiction a wildfire occurs shall make available to ADEQ no later than the day after the activity all required information for wildfire incidents that burned more than 100 acres per day in timber or slash fuels or 300 acres per day in brush or grass fuels. For each day of a wildfire incident that exceeded exceeds the daily activity threshold, the F/SLM shall provide the location, an estimate of predominant fuel type and quantity consumed, and an estimate of the area blackened that day. R18-2-1508. Wildland Fire Use: Plan, Authorization, Monitoring; Inter-agency Consultation; Status Reporting A. In order for ADEQ to participate in the wildland fire use decision-making process, the F/SLM shall notify ADEQ as soon as practicable of any wildland fire use incident projected to attain or attaining a size of 50 acres of timber fuel or 250 acres of brush or grass fuel. B. For each wildland fire use incident that has been declared as such by the F/SLM, the F/SLM shall complete and submit to ADEQ a Wildland Fire Use Burn Plan in a format approved by ADEQ in cooperation with the F/SLM. The F/SLM shall submit the Wildland Fire Use Burn Plan to ADEQ as soon as practicable but no later than 72 hours after the wildland fire use incident is declared or under consideration for such designation. The F/SLM shall include the following information in the Wildland Fire Use Burn Plan: 1. An emergency telephone number that is answered 24 hours a day seven days a week; 2. Anticipated burn prescription; 3. Anticipated smoke management prescription; 4. The estimated daily number of acres, quantity, and type of fuel to be burned; 5. The anticipated maximum allowable perimeter or size with map; 6. Information on the condition of the area to be burned, such as whether it is in maintenance or restoration, its ecological function or , and other indicators of fire resiliency; 7. The anticipated duration of the wildland fire use incident; 602ART15NFRMGRRC120903.DOC 12/9/03 27 8. The anticipated long-range weather trends for the site; 9. A map depicting the potential impact of the smoke. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the wildland fire use incident, with smoke-sensitive areas delineated. Mapping is mandatory unless waived either verbally orally or in writing by ADEQ. The map shall use the appropriate scale to show the impacts of the smoke adequately; and 10. Modeling or monitoring of smoke impacts, if requested by ADEQ after consultation with the F/SLM. C. ADEQ shall approve or disapprove a Wildland Fire Use Burn Plan within 3 three hours of receipt. ADEQ shall consult directly with the requesting F/SLM before disapproving a Wildland Fire Use Burn Plan. If ADEQ fails to address the Wildland Fire Use Burn Plan within the time allotted, the Plan is approved by default under the condition that the F/SLM makes a good faith effort to contact ADEQ to confirm that the Plan was received. Approval by ADEQ of a Wildland Fire Use Burn Plan shall be is binding upon ADEQ for the duration of the wildland fire use incident, unless smoke from the incident creates a threat to public health or welfare. If a threat to public health or welfare is created, ADEQ shall consult with the F/SLM regarding the situation and develop a joint action plan for reducing further smoke impacts. D. The F/SLM shall submit a Daily Status Report for each wildland fire use incident to ADEQ for each day of the burn that the fire burns more than 100 acres in timber or slash fuels or 300 acres in brush or grass fuels. The F/SLM shall include a synopsis of smoke behavior, future daily anticipated growth, and location of the activity of the wildland fire use incident in the Daily Status Report. E. The F/SLM shall consult with ADEQ prior to initiating man-made human-made ignition on the wildland fire use incident when greater than 250 acres is anticipated to be burned by the ignition. Emergency man-made human-made ignition on the incident for protection of public or fire-fighter safety does not require consultation with ADEQ regardless of the size of the area to be burned. F. The F/SLM is responsible for shall ensure that there is appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a wildland fire use incident. R18-2-1509. A. Emission Reduction Techniques Each F/SLM conducting a prescribed burn shall implement as many Emission Reduction Techniques as are feasible subject to economic, technical, and safety feasibility criteria, and land management objectives. 602ART15NFRMGRRC120903.DOC 12/9/03 28 B. Emission reduction techniques include : 1. Reducing biomass to be burned by use of techniques such as yarding or consolidation of unmerchandisable material, multi-product timber sales, or public firewood access, when economically feasible; 2. Reducing biomass to be burned by fuel exclusion practices such as preventing the fire from consuming dead snags or dead and downed woody material through lining, application of fire-retardant foam, or water; 3. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires of high fuel density areas such as logging slash decks; 4. Burning only fuels essential to meet resource management objectives; 5. Minimizing consumption and smoldering by burning under conditions of high fuel moisture of duff and litter; 6. Minimizing fuel consumption and smoldering by burning under conditions of high fuel moisture of large woody fuels; 7. Minimizing soil content when slash piles are constructed by using brush blades on materialmoving equipment and by constructing piles under dry soil conditions or by using hand piling methods; 8. Burning fuels in piles; 9. Using a backing fire in grass fuels; 10. Burning fuels with an air curtain destructor, as defined in R18-2-101, operated pursuant according to manufacturer specifications and meeting applicable State state or local opacity requirements; 11. Extinguishing or mopping-up of smoldering fuels; 12. Chunking of piles and other consolidations of burning material to enhance flaming, and fuel consumption, and to minimize smoke production; 13. Burn Burning before litter fall; 14. Burn Burning before green-up of fuels; 15. Burn Burning before recently cut large fuels cure in areas with activity; and 16. Burn Burning just prior to before precipitation to reduce fuel smoldering and consumption. R18-2-1510. A. Smoke Management Techniques Each F/SLM conducting a prescribed burn shall implement as many Smoke Management Techniques as are feasible subject to economic, technical, and safety feasibility criteria, and land management 602ART15NFRMGRRC120903.DOC 12/9/03 29 objectives. B. Smoke Management Techniques management techniques include: 1. Burning from March 15 through September 15, when meteorological conditions allow for good smoke dispersion; 2. Igniting burns under good-to-excellent ventilation conditions; 3. Suspending operations under poor smoke dispersion conditions; 4. Considering smoke impacts on local community activities and land users; 5. Burning piles when other burns are not feasible, such as when snow or rain is present; 6. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires with short duration impacts; 7. Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; 8. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; 9. When allowing public firewood access, provide Providing information on the adverse impacts of using green or wet wood as fuel when public firewood access is allowed; 10. Implementing maintenance burning in a periodic rotation to shorten prescribed fire duration and to reduce excessive fuel accumulations which that could result in excessive smoke production in a wildfire; and 11. Using wildland fire-use strategies to shift smoke into more favorable smoke dispersion seasons. R18-2-1511. A. Monitoring ADEQ may require a F/SLM to monitor air quality before or during a prescribed burn or a wildland fire use incident if necessary to assess smoke impacts. Air quality monitoring may be conducted using both federal and non-federal reference method as well as other techniques. B. ADEQ may require a F/SLM to monitor weather before or during a prescribed burn or a wildland fire use incident, if necessary to predict or assess smoke impacts. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or area-representative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ. An F/SLM planning to make a change to any long-term established remote automated weather station shall give ADEQ notice and an opportunity to comment before making the any change to a long-term established remote automated weather station. 602ART15NFRMGRRC120903.DOC 12/9/03 30 C. A F/SLM shall employ the following types of monitoring, unless waived by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulate matter, carbon monoxide, or ozone, or other smoke-sensitive area: 1. Smoke plume measurements, using a format supplied by ADEQ; and 2. The release of pilot balloons (PIBALs) at the burn site to verify needed wind speed, direction, and stability. In lieu Instead of pilot balloons, a test burn at the burn site may be used for specific prescribed burns on a case-by-case basis as approved by ADEQ, to verify needed wind speed, direction, and stability. D. An F/SLM shall make monitoring information required pursuant to under subsection (C) available to ADEQ on the business day following the burn ignition. E. The F/SLM shall keep on file for 1 one year following the burn date any monitoring information required pursuant under to this Section. R18-2-1512. A. Burner Qualifications All burn projects shall be conducted by personnel trained in prescribed fire and smoke management techniques as required by the F/SLM in charge of the burn and established by National Wildfire Coordinating Group training qualifications. B. A Prescribed Fire Boss or other local Fire Management Officer of the F/SLM having jurisdiction over prescribed burns shall have smoke management training obtained through one of the following: 1. Successful completion of a National Wildfire Coordinating Group or F/SLM-equivalent course addressing smoke management; or 2. R18-2-1513. A. Attendance at an ADEQ-approved smoke management workshop. Public Notification and Awareness Program; Regional Coordination The Director shall conduct a public education and awareness program in cooperation with F/SLMs and other interested parties to inform the general public of the smoke management program described by this Article. The program shall include smoke impacts from prescribed fires and the role of prescribed fire in natural ecosystems. B. ADEQ shall make annual registration, prescribed burn approval, and wildfire and wildland fire use activity information readily available to the public and to facilitate regional coordination efforts and public notification. 602ART15NFRMGRRC120903.DOC 12/9/03 31 R18-2-1514. A. Surveillance and Enforcement An F/SLM conducting a prescribed burn shall permit ADEQ to enter and inspect burn sites unannounced to verify the accuracy of the Daily Burn Request, Burn Plan, or Accomplishment data as well as matching burn approval with actual conditions, smoke dispersion, and air quality impacts. On-ground site inspection procedures and aerial surveillance shall be coordinated by ADEQ and the F/SLM for safety purposes. B. ADEQ may use remote automated weather station data if necessary to verify current and previous meteorological conditions at or near the burn site. C. ADEQ may audit burn accomplishment data, smoke dispersion measurements, or weather measurements from previously conducted burns, if necessary to verify conformity with, or deviation from, procedures and authorizations approved by ADEQ. D. Deviation from procedures and authorizations approved by ADEQ constitute a violation of this Article. Violations may require containment or mop-up of any active burns and may also require, in the Director's discretion, a 5 five-day moratorium on ignitions by the responsible F/SLM. Violations of this Article are also subject to a civil penalty of not more than $10,000 per day per violation pursuant to under A.R.S. ' 49-463. R18-2-1515. A. Forms; Electronic Copies; Information Transfers ADEQ shall make available on paper and in electronically-readable format any form required to be developed by ADEQ and completed by a F/SLM. B. After consultation with the an F/SLM, ADEQ may require each the F/SLM to provide data in a manner that facilitates electronic transfers of information. 11. A summary of the comments made regarding the rule and the agency response to them: Comment #1: A large number of commenters focused on the proposed requirement that fires set for the purpose of training firefighters now be permitted. In the current rule, fires set for training purposes are excepted from the permit requirement. Commenters felt that requiring permits for such fires was an unnecessary and impracticable interference in their operations. Response #1: ADEQ had proposed to require that fires set for training purposes be permitted in an effort to 602ART15NFRMGRRC120903.DOC 12/9/03 32 better track and report emissions data from such fires through the notice requirement included in fire permits (R18-2-602(D)(3)(f)). However, ADEQ agrees that requiring fire officers to apply to ADEQ or a delegated authority could be impracticable; the data can be adequately tracked with a similar notice requirement while still exempting such fires from the actual permit requirement. ADEQ will add language to R18-2-602(C)(2), the subsection which enumerates those fires exempted from the permit requirement, to read A. . . if such fire is set or permission given for the purpose of fire control of an active wildfire, or instruction in the methods of fighting fires,@ with the inclusion of a notice requirement similar to the one in subsection (D)(3)(f). It should be noted that this notice requirement can be satisfied by an annual report to the Director or delegated authority; it is not required that each individual training fire be reported. Comment #2: One commenter suggested that subsection (G), which deals with permits issued by a delegated authority, be changed. Specifically, there is a provision in that subsection which prohibits delegated authorities from issuing permits to themselves. Commenter suggested adding a sentence (APermits issued by a delegated authority for the purpose of instruction in the methods of fire fighting are excepted from the provisions of this rule.@) excepting training fires from this prohibition. Response #2: Exempting training fires from the permit requirement, generally, makes it unnecessary to add an exception to subsection (G). Comment #3: One commenter objected to subsection (G), claiming it was unenforceable and would create administrative and practical difficulties. Commenter asked, Aif an agency is not responsible enough to control its own fires and training then why should they be allowed to issue permits to the public?@ Response #3: ADEQ does not intend to prevent a delegated authority from issuing any permits, just permits from themselves to themselves. ADEQ thinks it is appropriate to oversee permits to delegated authorities, both to avoid potential conflicts of interest as well as better track emissions data. It should be noted that a number of commenters think that these permits are issued on a fire-by-fire basis. In fact, open burning permits have a term of up to one year, and can cover multiple burn projects. Comment #4: One commenter asked if any of the model fire codes, or the National Fire Protection Agency Standards were consulted when drafting these rules. 602ART15NFRMGRRC120903.DOC 12/9/03 33 Response #4: No. ADEQ has reviewed the National Fire Protection Agency Standards and the NFPA 1 Uniform Fire Code, 2003 Edition, to determine their relevance to air quality and whether their consideration might improve the proposed rules. ADEQ found that these documents deal with fire safety, fire-fighting and fire preparedness issues. These areas fall outside the scope of this rule. ADEQ=s fire rules deal with the control of emissions and the tracking of emissions related data, rather than the actual control of fires themselves. Comment #5: One commenter requested clarification on the difference between subsection (C)(3), fires set for the Apurpose of disease and pest prevention in organized, area-wide control of epidemics or infestations . . .@ which are exempt from permit requirements, and subsection (D)(1)(e) fires set for the Apurpose of weed abatement, the prevention of a fire hazard . . .@ which are subject to permit requirements. Response #5: Fires described in (C)(3) would be fires authorized by the Director of the Department of Agriculture in an emergency in order to prevent the spread of disease or pest infestation. In such a situation, time constraints may make the normal permitting procedure ineffective. Representatives from the Department of Agriculture were included in the Fire Emissions Work Group. They indicated that they needed this authority so that they might effectively deal with such an emergency. It should be noted that there has been no need, up to the present time, for this authority to be exercised. Fires under (D)(1)(e), however, are not likely to be emergency in nature, and such burners should go through the normal permitting procedure. Comment #6: Commenter proposed changing (D)(3)(c) so that it reads A[a] requirement that burns be conducted during the following periods, unless otherwise waived or directed by the Director or delegated authority on a specific day basis@. The provision limits fires from one hour after sunrise to 2 hours before sunset. Response #6: ADEQ thinks it is appropriate that the Director retain authority in this matter. Atmospheric conditions change just before sunset, usually minimizing smoke dispersion. For this reason, most burns should be conducted during the day. There are circumstances where nighttime, or extended daytime, burns might be appropriate, but ADEQ thinks that authority to make that decision should, in general, remain centralized with the Director. Comment #7: Commenter noted that R18-2-602(D)(3)(f) is in reference to a reporting requirement, and asks 602ART15NFRMGRRC120903.DOC 12/9/03 34 if the report form will be available to the delegated authority or will each applicant be responsible for providing this information. Response #7: The most likely scenario is that the burner will be required by his or her permit to notify the permitting authority of their burn, either on a daily or annual basis. The delegated authority would then take down the pertinent information on the form provided by ADEQ for this purpose, and report that information to ADEQ, under subsection (G)(3), in an annual report to the Director. Comment #8: Commenter suggested that, in (D)(3)(g) Aa notation should be made that the applicant contact the local fire jurisdiction to determine what local open burning requirements have been established, to obtain a local permit if required, and to follow all local adopted fire code requirements.@ Response #8: ADEQ thinks that this issue is adequately addressed by R18-2-602(I) which states that A[n]othing in this Section is intended to permit any practice which is a violation of any statute, ordinance, rule, or regulation.@ Comment #9: Commenter pointed out that ADEQ=s preamble to the proposed rule was inaccurate. The preamble suggested that a permit exemption for air curtain destructors was considered, under the federal regional haze rule, in order to remove an administrative barrier to certain types of burning. In fact, the regional haze rule requires removal of administrative barriers for alternatives to burning. Response #9: ADEQ has retained and clarified the referenced paragraph in the preamble. The preamble now distinguishes between alternatives to burning and burning with a method that has lower emissions, but notes that removing an administrative barrier to either could be beneficial. Comment #10: Commenter noted that subsection (D)(1)(a) allows construction burning, with a permit. (A)(4) defines Aconstruction burning@ as including materials from Ademolition or modification of any buildings@ but precludes burning of Aprohibited materials.@ (A)(13) defines Aprohibited materials@ to include a number of common building materials, but that the list is not exhaustive and does not include other potentially harmful materials such as linoleum flooring, lead-painted wood, and composite counter-tops. He suggested adding such materials to (A)(13). Additionally, he suggested requiring a separate permit for the burning of building materials, as does Pinal County. Such a permit requires an on-site inspection before the 602ART15NFRMGRRC120903.DOC 12/9/03 35 permit is issued. Response #10: ADEQ thinks that onsite inspections are an inefficient use of limited resources. However, the list of prohibited materials in R18-2-602(A)(13) can be expanded to include those items that commenter suggested. Comment #11: Commenter noted that under subsection (D)(3)(g) permittees should know to make daily notifications of burning activity to the Alocal fire-fighting agency,@ or to the State Forester. He thought it unclear whether Alocal fire-fighting agency@ includes private fee-for-service firefighting corporations or is limited to municipal fire departments and local fire districts. Private for-profit services operate outside of jurisdictional limits and it is unclear how Aoperational bounds@ of such services would be defined for the purposes of informing permittees whom to notify. Response #11: ADEQ will clarify, in the rule, that private fee-for-service fire-fighting corporations are considered Alocal fire-fighting agencies,@ for the purpose of fulfilling notice requirements, when such private services are delegated authorities as defined in R18-2-602(A)(6). In the absence of such a delegated authority, permittees would be required to notify the state forester, as indicated by subsection (D)(3)(g). Comment #12: Commenter noted that subsection (F) allows the permitting of household waste burning. Commenter thinks that such burning inevitably leads to nuisance and suggested that statutory authority to allow it does not equal legislative mandate, and therefore suggested that subsection (F) be deleted. Response #12: ADEQ thinks it better to deal with the issue of household waste on an individual basis. Writing household waste entirely out of the rule would not allow for such individual assessment of each such burn. If the burning is likely to cause a nuisance, the application for that burn permit can be denied. Such nuisance is more likely to be an issue in urban counties than it would in rural. Therefore, ADEQ will retain subsection (F) in the rule of statewide application. Those counties with more urban development such as Maricopa, Pima and Pinal, which have independent authority to permit fires, may prohibit such burning if they so choose, as is the case with the Maricopa county rules. Comment #13: Commenter asserted that 40 CFR 51.308 and 51.309, the Regional Haze rule, refers to prescribed burning, which does not include fire-fighting training. Commenter listed a number of reasons how 602ART15NFRMGRRC120903.DOC 12/9/03 36 sections 308 and 309 do not apply to fires set for training purposes and stated that those fires should continue to be exempt from permit requirements. Response #13: Without addressing the issue of whether or not 40 CFR 51.308 and 309 do apply to fires set for the purpose of conducting fire-fighting training, ADEQ has decided to exempt such fires from the open burning permit requirement, while retaining the notice requirements that would allow ADEQ to track the relevant emissions data. Comment #14: Commenter stated that the limitations, in subsection (D)(3)(c), set on the hours when permitted burns may be conducted unreasonably limit such fires to daylight hours. They claimed that in order to properly train their fire-fighters to combat fires arising from aircraft incidents, training must be conducted both day and night. Response #14: Since ADEQ has decided to exempt fires set for training purposes from the permit requirement, subsection (D)(3)(c) no longer applies to such fires. Comment #15: Commenter listed several practical problems that would make training difficult if they are required to apply for a permit from ADEQ for each training exercise. Response #15: These issues should be adequately addressed by ADEQ=s decision to continue to exempt training fires from the permit requirement. While ADEQ will retain a notice requirement to allow for the tracking and monitoring of necessary emissions data, it should be noted that this requirement can be filled by the filing of an annual report; it is unnecessary to report on a fire-by-fire basis. Comment #16: Commenter expressed concern that the requirements of Article 15 relating to Burn Plans, Authorizations, and Accomplishment Forms will be a burdensome addition to his paperwork when conducting his own range management burns on his privately owned land. Commenter was uncertain of what the actual burden was on a private landowner. Response #16: Under R18-2-1502, the provisions of this Article do not apply to private landowners conducting burns unless they enter into a memorandum of agreement with ADEQ. Private landowners conducting burns would be governed by the provisions of R18-2-602, Unlawful Open Burning. However, 602ART15NFRMGRRC120903.DOC 12/9/03 37 when a private landowner conducts a range management burn in cooperation with a State or Federal Land Manager, that Land Manager, not the private landowner, would be covered by the provisions of Article 15, Forest and Range Management Burns. Comment #17: Commenter was concerned with the language used in R18-2-1503(C)(6) A[b]y area planned for wildland fire use, . . . and annual acres to be burned . . .@ etc. (emphasis added). Commenter noted that wildland fires cannot, by virtue of their very nature, be planned, and asked if there is more appropriate language that might be used. Response #17: ADEQ recognizes that wildland fires, or wildfires, cannot be accurately predicted. However, a wildland fire use, as defined in this rule, is a pre-planned event, and a wildland fire use may only take place in an area planned for it. The purpose of R18-2-1503(C)(6) is to get an estimate of the area, fuel types and acreage that may be burned in a wildland fire use incident. ADEQ has clarified some language but kept the phrase Aplanned area.@ Comment #18: Commenter wondered how one should properly coordinate prescribed burning activities on federal land with adjacent private landowners. Response #18: ADEQ considers this to be an operational issue not addressed in the scope of these rules, but is better dealt with at a practical level between the appropriate Land Manager and the private landowner. Comment #19: Commenter asked if there is a definition of Anuisance@ for R18-2-602(D)(3)(d)(iii). Response #19: The definition of Anuisance@ appropriate to this section is to be found in A. R. S. ' 13-2917, Public Nuisance; Abatement; Classification. Comment #20: Commenter asked whether the reporting requirement of R18-2-602(D)(3)(f) falls on the permit applicant or the delegated authority. Response # 20: While the specific forms dealing with these requirements are still being designed, the permit applicant would, under R18-2-602(D)(3)(g) notify the local fire-fighting agency or state forester of the burn. That official would, at that time, collect the necessary data to meet the reporting requirement of (D)(3)(f) which would then be reported to the Director or delegated authority in their daily or annual report. 602ART15NFRMGRRC120903.DOC 12/9/03 38 Comment #21: Commenter suggested that it be clarified that fires using air curtain destructors are required to be permitted. Response #21: Fires using air curtain destructors will be added to R18-2-602(D), Open Outdoor Fires Requiring a Permit, under subsection (D)(1). Comment #22: Commenter expressed some confusion over whether, under R18-2-602(C)(4) all fires set by the federal government or any of its departments, agencies or agents, etc., are exempt from the permit open outdoor fire permit requirement. Response #22: Only those fires set by the federal government that would be regulated under Article 15, Forest and Range Management Burns, would be exempt from the requirements of R18-2-602, Unlawful Open Fires. ADEQ will change the language of subsection (C)(4) to better reflect the intention that such fires are to be governed by either the open burning rule, or the range management rules. Comment #23: Commenter was concerned with the inclusion of Awindrows@ in R18-2-602(D)(3)(f)(iii) as an example of the fire types to be included in the permit reporting requirement. He suggested that such fires are dangerously unstable and would like mention of them to be removed from rule. Response #23: ADEQ has removed Awindrow@ as an example and substituted Apit@ in subsection (D)(3)(f)(iii). 12. Any other matter prescribed by statute that are applicable to the specific agency or to any other specific rule or class of rules: Not applicable 13. Incorporations by reference and their location in the rules: Not applicable 14. Was this rule previously made as an emergency rule? No 602ART15NFRMGRRC120903.DOC 12/9/03 39 15. The full text of the rules follows: 602ART15NFRMGRRC120903.DOC 12/9/03 40 TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITYAIR POLLUTION CONTROL ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES Section R18-2-602. Unlawful Open Burning ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS Section R18-2-1501. Definitions R18-2-1502. Applicability R18-2-1503. Annual Registration, Program Evaluation and Planning for Prescribed Burns R18-2-1504. Prescribed Burn Plan Contents R18-2-1505. Prescribed Burn Requests and Authorization R18-2-1506. Smoke Dispersion Evaluation R18-2-1507. Prescribed Burn Accomplishment; ADEQ Recordkeeping; Wildfire Reporting R18-2-1508. Prescribed Natural Fires; Wildland Fire Use: Plan;, Authorization;, Monitoring; Interagency Consultation; Status Reporting R18-2-1509. Emission Reduction Techniques; BMP R18-2-1510. Smoke Management Techniques R18-2-1510 R18-2-1511. Monitoring R18-2-1511 R18-2-1512. Burner Qualifications R18-2-1512 R18-2-1513. Public Notification and Awareness Program; Regional Coordination R18-2-1514. Oversight R18-2-1514. Surveillance and Enforcement R18-2-1515. Forms; Electronic Copies; Information Transfers 602ART15NFRMGRRC120903.DOC 12/9/03 41 ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES R18-2-602. A. Unlawful Open Burning Notwithstanding the provisions of any other rule in this Chapter, it is unlawful for any person to ignite, cause to be ignited, permit to be ignited, or suffer, allow or maintain any open outdoor fire. B. "Open outdoor fire," as used in this rule, means any combustion of combustible material of any type outdoors, in the open where the products of combustion are not directed through a flue. "Flue," as used in this rule, means any duct or passage for air, gases or the like, such as a stack or chimney. C. The following fires are excepted from the provisions of this rule: 1. Fires used only for cooking of food or for providing warmth for human beings or for recreational purposes or the branding of animals or the use of orchard heaters for the purpose of frost protection in farming or nursery operations. 2. Any fire set or permitted by any public officer in the performance of official duty, if such fire is set or permission given for the purpose of weed abatement, the prevention of a fire hazard, or instruction in the methods of fighting fires. 3. Fires set by or permitted by the state entomologist or county agricultural agents of the county for the purpose of disease and pest prevention. 4. Fires set by or permitted by the federal government or any of its departments, agencies or agents, the state or any of its agencies, departments or political subdivisions, for the purpose of watershed rehabilitation or control through vegetative manipulation. D. Permission for the setting of any fire given by a public officer in the performance of official duty under subsections (C)(2), (3), or (4) shall be given, in writing, and a copy of such written permission shall be transmitted immediately to the Director of the Department of Environmental Quality and the control officer, if any, of the county, district or region in which such fire is allowed. The setting of any such fire shall be constructed in a manner and at such time as approved by the Director, unless doing so would defeat the purpose of the exemption. E. The following fires may be excepted from the provisions of this Section when permitted in writing by the Director of the Department of Environmental Quality or the control officer of the county, district or region in which such fire is allowed: 1. Fires set for the disposal of dangerous materials where there is no safe alternative method of disposal. a. "Dangerous material" is any substance or combination of substances which is able or 602ART15NFRMGRRC120903.DOC 12/9/03 42 likely to inflict bodily harm or property loss unless neutralized, consumed or otherwise disposed of in a controlled and safe manner. b. Fires set for the disposal of dangerous materials shall be permitted only when there is no safe alternative method of disposal, and when the burning of such materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts which will endanger health or safety. 2. Open outdoor fires for the disposal of ordinary household trash in an approved waste burner in nonurban areas of less than 100 well spread out dwelling units per square mile where no refuse collection and disposal service is available. a. An "approved waste burner" is an incinerator constructed of fire resistant material with a cover or screen which is closed when in use having openings in the sides or top no greater than 1 inch in diameter. b. Open burning of the following materials is forbidden: Garbage resulting from the processing, storage, service or consumption of food; asphalt shingles; tar paper; plastic and rubber products (such as waste crankcase oil, transmission oil and oil filters); transformer oils; and hazardous material containers including those that contained inorganic pesticides, lead, cadmium, mercury, or arsenic compounds. F. The Director of the Department of Environmental Quality or the air pollution control officer, if any, of the county, district, or region may delegate the authority for the issuance of allowable open burning permits to responsible local officers. Such permits shall contain conditions limiting the manner and the time of the setting of such fires as specified in the Arizona Guidelines for Open Burning and shall contain a provision that all burning be extinguished at the discretion of the Director or his authorized representative during periods of inadequate atmospheric smoke dispersion, periods of excessive visibility impairment which could adversely affect public safety, or periods when smoke is blown into populated areas so as to create a public nuisance. Any local officer delegated the authority for issuance of open burning permits shall maintain a copy of all currently effective permits issued including a means of contacting the person authorized by the permit to set an open fire in the event that an order for extinguishing of open burning is issued. G. Nothing in this rule is intended to permit any practice which is a violation of any statute, ordinance, rule or regulation. A. In addition to the definitions contained in A.R.S. ' 49-501, in this Section: 1. AAgricultural burning@ means burning vegetative materials related to producing and harvesting crops and raising animals for the purpose of marketing for profit, or providing a 602ART15NFRMGRRC120903.DOC 12/9/03 43 livelihood, but does not include burning of household waste or prohibited materials. A person may conduct agricultural burns in fields, piles, ditch banks, fence rows, or canal laterals for purposes such as weed control, waste disposal, disease and pest prevention, or site preparation. 2. AApproved waste burner@ means an incinerator constructed of fire resistant material with a cover or screen that is closed when in use, and has openings in the sides or top no greater than one inch in diameter. 3. AClass I Area@ means any one of the Arizona mandatory federal class I areas defined in A.R.S. ' 49-401.01. 4. AConstruction burning@ means burning wood or vegetative material from land clearing, site preparation, or fabrication, erection, installation, demolition, or modification of any buildings or other land improvements, but does not include burning household waste or prohibited material. 5. ADangerous material@ means any substance or combination of substances that is capable of causing bodily harm or property loss unless neutralized, consumed, or otherwise disposed of in a controlled and safe manner. 6. ADelegated authority@ means any of the following: a. A county, city, town, air pollution control district, or fire district that has been delegated authority to issue open burning permits by the Director under A.R.S. ' 49-501(E); or b. A private fire protection service provider that has been assigned authority to issue open burning permits by one of the authorities in subsection (A)(6)(a). 7. ADirector@ means the Director of the Department of Environmental Quality, or designee. 8. AEmission reduction techniques@ means methods for controlling emissions from open outdoor fires to minimize the amount of emissions output per unit of area burned. 9. AFlue,@ as used in this Section, means any duct or passage for air or combustion gases, such as a stack or chimney. 10. AHousehold waste@means any solid waste including garbage, rubbish, and sanitary waste from a septic tank that is generated from households including single and multiple family residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day-use recreation areas, but does not include construction debris, landscaping rubble, or demolition debris. 602ART15NFRMGRRC120903.DOC 12/9/03 44 11. AIndependent authority to permit fires@ means the authority of a county to permit fires by a rule adopted under Arizona Revised Statutes, Title 49, Chapter 3, Article 3, and includes only Maricopa, Pima, and Pinal counties. 12. AOpen outdoor fire or open burning@ means the combustion of material of any type, outdoors and in the open, where the products of combustion are not directed through a flue. Open outdoor fires include agricultural, residential, prescribed, and construction burning, and fires using air curtain destructors. 13. AProhibited materials@ means nonpaper garbage from the processing, storage, service, or consumption of food; chemically treated wood; lead-painted wood; linoleum flooring, and composite counter-tops; tires; explosives or ammunition; oleanders; asphalt shingles; tar paper; plastic and rubber products, including bottles for household chemicals; plastic grocery and retail bags; waste petroleum products, such as waste crankcase oil, transmission oil, and oil filters; transformer oils; asbestos; batteries; anti-freeze; aerosol spray cans; electrical wire insulation; thermal insulation; polyester products; hazardous waste products such as paints, pesticides, cleaners and solvents, stains and varnishes, and other flammable liquids; plastic pesticide bags and containers; and hazardous material containers including those that contained lead, cadmium, mercury, or arsenic compounds. 14. AResidential burning@ means open burning of vegetative materials conducted by or for the occupants of residential dwellings, but does not include burning household waste or prohibited material. 15. B. APrescribed burning@ has the same meaning as in R18-2-1501. Unlawful open burning. Notwithstanding any other rule in this Chapter, a person shall not ignite, cause to be ignited, permit to be ignited, allow, or maintain any open outdoor fire in a county without independent authority to permit fires except as provided in A.R.S. ' 49-501 and this Section. C. Open outdoor fires exempt from a permit. The following fires do not require an open burning permit from the Director or a delegated authority: 1. Fires used only for: a. Cooking of food, b. Providing warmth for human beings, c. Recreational purposes, d. Branding of animals, e. Orchard heaters for the purpose of frost protection in farming or nursery operations, 602ART15NFRMGRRC120903.DOC 12/9/03 45 and f. 2. The proper disposal of flags under 4 U.S.C. ' 8. Any fire set or permitted by any public officer in the performance of official duty, if the fire is set or permission given for the following purpose: a. Control of an active wildfire; or b. Instruction in the method of fighting fires, except that the person setting these fires must comply with the reporting requirements of subsection (D)(3)(f). 3. Fire set by or permitted by the Director of Department of Agriculture for the purpose of disease and pest prevention in an organized, area-wide control of an epidemic or infestation affecting livestock or crops. 4. Prescribed burns set by or assisted by the federal government or any of its departments, agencies, or agents, or the state or any of its agencies, departments, or political subdivisions, regulated under Article 15 of this Chapter. D. Open outdoor fires requiring a permit. 1. The following open outdoor fires are allowed with an open burning permit from the Director or a delegated authority: a. Construction burning; b. Agricultural burning; c. Residential burning; d. Prescribed burns conducted on private lands without the assistance of a federal or state land manager as defined under R18-2-1501; e. Any fire set or permitted by a public officer in the performance of official duty, if the fire is set or permission given for the purpose of weed abatement, or the prevention of a fire hazard, unless the fire is exempt from the permit requirement under subsection (C)(3); 2. f. Open outdoor fires of dangerous material under subsection (E); g. Open outdoor fires of household waste under subsection (F); and h. Open outdoor fires that use an air curtain destructor, as defined in R18-2-101. A person conducting an open outdoor fire in a county without independent authority to permit fires shall obtain a permit from the Director or a delegated authority unless exempted under subsection (C). Permits may be issued for a period not to exceed one year. A person shall obtain a permit by completing an ADEQ-approved application form. 3. Open outdoor fire permits issued under this Section shall include: 602ART15NFRMGRRC120903.DOC 12/9/03 46 a. A list of the materials that the permittee may burn under the permit; b. A means of contacting the permittee authorized by the permit to set an open fire in the event that an order to extinguish the open outdoor fire is issued by the Director or the delegated authority; c. A requirement that burns be conducted during the following periods, unless otherwise waived or directed by the Director on a specific day basis: d. i. Year round: ignite fire no earlier than one hour after sunrise; and ii. Year round: extinguish fire no later than two hours before sunset. A requirement that the permittee conduct all open burning only during atmospheric conditions that: i. Prevent dispersion of smoke into populated areas; ii. Prevent visibility impairment on traveled roads or at airports that result in a safety hazard; e. iii. Do not create a public nuisance or adversely affect public safety; iv. Do not cause an adverse impact to visibility in a Class I area; and v. Do not cause uncontrollable spreading of the fire; A list of the types of emission reduction techniques that the permittee shall use to minimize fire emissions. f. A reporting requirement that the permittee shall meet by providing the following information in a format provided by the Director for each date open burning occurred, on either a daily basis on the day of the fire, or an annual basis in a report to the Director or delegated authority due on March 31 for the previous calendar year: i. The date of each burn; ii. The type and quantity of fuel burned for each date open burning occurred; iii. The fire type, such as pile or pit, for each date open burning occurred; and iv. For each date open burning occurred, the legal location, to the nearest section, or latitude and longitude, to the nearest degree minute, or street address for residential burns. g. A requirement that the person conducting the open burn notify the local fire-fighting agency or private fire protection service provider, if the service provider is a delegated authority, before burning. If neither is in existence, the person conducting the burn shall notify the state forester. 602ART15NFRMGRRC120903.DOC 12/9/03 47 h. A requirement that the permittee start each open outdoor fire using items that do not cause the production of black smoke; i. A requirement that the permittee attend the fire at all times until it is completely extinguished; j. A requirement that the permittee provide fire extinguishing equipment on-site for the duration of the burn; k. A requirement that the permittee ensure that a burning pit, burning pile, or approved waste burner be at least 50 feet from any structure; l. A requirement that the permittee have a copy of the burn permit on-site during open burning; m. A requirement that the permittee not conduct open burning when an air stagnation advisory, as issued by the National Weather Service, is in effect in the area of the burn or during periods when smoke can be expected to accumulate to the extent that it will significantly impair visibility in Class I areas; n. A requirement that the permittee not conduct open burning when any stage air pollution episode is declared under R18-2-220. o. A statement that the Director, or any other public officer, may order that the burn be extinguished or prohibit burning during periods of inadequate smoke dispersion, excessive visibility impairment, or extreme fire danger; and p. A list of the activities prohibited and the criminal penalties provided under A.R.S. ' 13-1706. 4. The Director or a delegated authority shall not issue an open burning permit under this Section: a. That would allow burning prohibited materials other than under a permit for the burning of dangerous materials; b. If the applicant has applied for a permit under this Section to burn a dangerous material which is also hazardous waste under 40 CFR 261, but does not have a permit to burn hazardous waste under 40 CFR 264, or is not an interim status facility allowed to burn hazardous waste under 40 CFR 265; or c. If the burning would occur at a solid waste facility in violation of 40 CFR 258.24 and the Director has not issued a variance under A.R.S. ' 49-763.01. E. Open outdoor fires of dangerous material. A fire set for the disposal of a dangerous material is allowed by the provisions of this Section, when the material is too dangerous to store and transport, 602ART15NFRMGRRC120903.DOC 12/9/03 48 and the Director has issued a permit for the fire. A permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The Director shall permit fires for the disposal of dangerous materials only when no safe alternative method of disposal exists, and burning the materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts that will endanger health or safety. F. Open outdoor fires of household waste. An open outdoor fire for the disposal of household waste is allowed by provisions of this Section when permitted in writing by the Director or a delegated authority. A permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The permittee shall conduct open outdoor fires of household waste in an approved waste burner and shall either: 1. Burn household waste generated on-site on farms or ranches of 40 acres or more where no household waste collection or disposal service is available; or 2. Burn household waste generated on-site where no household waste collection and disposal service is available and where the nearest other dwelling unit is at least 500 feet away. G. Permits issued by a delegated authority. The Director may delegate authority for the issuance of open burning permits to a county, city, town, air pollution control district, or fire district. A delegated authority may not issue a permit for its own open burning activity. The Director shall not delegate authority to issue permits to burn dangerous material under subsection (E). A county, city, town, air pollution control district, or fire district with delegated authority from the Director may assign that authority to one or more private fire protection service providers that perform fire protection services within the county, city, town, air pollution control district, or fire district. A private fire protection provider shall not directly or indirectly condition the issuance of open burning permits on the applicant being a customer. Permits issued under this subsection shall comply with the requirements in subsection (D)(3) and be in a format prescribed by the Director. Each delegated authority shall: 1. Maintain a copy of each permit issued for the previous five years available for inspection by the Director; 2. For each permit currently issued, have a means of contacting the person authorized by the permit to set an open fire if an order to extinguish open burning is issued; and 3. Annually submit to the Director by May 15 a record of daily burn activity, excluding household waste burn permits, on a form provided by the Director for the previous calendar year containing the information required in subsections (D)(3)(e) and (D)(3)(f). H. The Director shall hold an annual public meeting for interested parties to review operations of the 602ART15NFRMGRRC120903.DOC 12/9/03 49 open outdoor fire program and discuss emission reduction techniques. I. Nothing in this Section is intended to permit any practice that is a violation of any statute, ordinance, rule, or regulation. ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS R18-2-1501. Definitions In addition to the definitions contained in A.R.S. ' 49-501 and R18-2-101, in this Article: 1. AActivity fuels@ means those fuels created by human activities such as thinning or logging. 1.2. "ADEQ" means the Department of Environmental Quality. 3. AAnnual emissions goal@ means the annual establishment in cooperation with the F/SLM=s, under R18-2-1503(G), of a planned quantifiable value of emissions reduction from prescribed fires and fuels management activities. 2. "BMP" means best management practices as described in R18-2-1509. 4. ABurn plan@ means the ADEQ form that includes information on the conditions under which a burn will occur with details of the burn and smoke management prescriptions. 3.5. "Burn prescription" means, with regard to a burn project, the pre-determined area, intensity of heat, and rate of spread fuel, and weather conditions required to attain planned resource management objectives. 4.6. "Burn project" means an active or planned prescribed burn, including a prescribed natural fire wildland fire use incident. 5. "Class I Area" means a mandatory area designated pursuant to Section 169A of the Clean Air Act Amendments of 1990. 6.7. "Duff" means forest floor material consisting of decomposing needles and other natural materials. 8. AEmission reduction techniques (ERT)@ means methods for controlling emissions from prescribed fires to minimize the amount of emission output per unit of area burned. 7.9. AFederal land manager (FLM)@ means any department, agency, or agent of the federal government, including the following: a. United States Forest Service, b. United States Fish and Wildlife Service, c. National Park Service, d. Bureau of Land Management, e. Bureau of Reclamation, 602ART15NFRMGRRC120903.DOC 12/9/03 50 f. Department of Defense, g. Bureau of Indian Affairs, and h. United States Soil Conservation Service. Natural Resources Conservation Service. 8.10. "F/SLM" means a federal land manager or a state land manager. 9.11. "Local fire management officer" means a person designated by a F/SLM as responsible for fire management in a local district or area. 10.12. "Mop-up" means the act of extinguishing or removing burning material from a prescribed fire to reduce smoke impacts. 11.13. "National Wildfire Coordinating Group" means the national inter-agency group of federal and state land managers that shares similar wildfire suppression programs and has established standardized inter-agency training courses and qualifications for fire management positions. 14. ANon-burning alternatives to fire@ means techniques that replace fire for at least five years as a means to treat activity fuels created to achieve a particular land management objective (e.g., reduction of fuel-loading, manipulation of fuels, enhancement of wildlife habitat, and ecosystem restoration). These alternatives are not used in conjunction with fire. Techniques used in conjunction with fire are referred to as emission reduction techniques (ERTs). 12.15. "Planned resource management objectives" means public interest goals in support of land management agency objectives including silviculture, wildlife habitat management, grazing enhancement, fire hazard reduction, wilderness management, cultural scene maintenance, weed abatement, watershed rehabilitation, vegetative manipulation, and disease and pest prevention. 13.16. "Prescribed burning" means the controlled application of fire to wildland fuels that are in either a natural or modified state, under certain burn prescription conditions and smoke management prescription conditions that have been specified by the land manager in charge of or assisting the burn, to attain planned resource management objectives. Prescribed burning includes does not include a fire set or permitted by a public officer to provide instruction in fire fighting methods, or construction or residential burning under R18-2-602. A prescribed fire may be ignited either by a trained fire specialist or by natural causes such as lightning. 14.17. "Prescribed fire manager" means a person designated by a F/SLM as responsible for prescribed burning for that land manager. 15. "Prescribed natural fire" means a wildland fire that is ignited by natural causes such as lightning rather than by a trained fire specialist, that is subsequently allowed to continue burning using the same controls and for the same planned resource management objectives as prescribed burning. 16.18. "Smoke management prescription" means the predetermined meteorological conditions that affect 602ART15NFRMGRRC120903.DOC 12/9/03 51 smoke transport and dispersion under which a burn could occur without adversely affecting public health and welfare. 19. ASmoke management techniques@ (SMT) means management and dispersion practices used during a prescribed burn or wildland fire use incident which affect the direction, duration, height, or density of smoke. 17.20. "Smoke management unit" means any of 11 the geographic areas defined by ADEQ whose area is based on primary watershed boundaries and whose outlines are outline is determined by diurnal windflow patterns that allow smoke to follow predictable drainage patterns. A map of the state divided into 11 the smoke management units is on file with ADEQ. 18.21. "State land manager (SLM)" means any department, agency, or political subdivision of the state government that is responsible for wildland management including the following: a. State Land Department, b. Department of Transportation, c. Department of Game and Fish, and d. Parks Department. 19.22. "Wildfire" means a an unplanned wildland fire subject to appropriate control measures that does not meet resource management objectives and that may threaten life, property, public health, or the ecosystem. Wildfires include those incidents where suppression may be limited for safety, economic, or resource concerns. 20. "Wildland" means an area in which development is essentially non-existent, except for pipelines, power lines, roads, railroads, or other transportation or conveyance facilities. 23. AWildland fire use@ means a wildland fire that is ignited by natural causes, such as lightning, and is managed using the same controls and for the same planned resource management objectives as prescribed burning. R18-2-1502. A. Applicability A F/SLM that is conducting or assisting a prescribed burn shall follow the requirements of this Article. B. A private or municipal burner with whom ADEQ has entered into a memorandum of agreement shall follow the requirements of this Article. B.C. The provisions of this Article apply to all areas of the state except Indian Trust lands. All federallymanaged lands and all state lands, parks, and forests are under the jurisdiction of ADEQ in matters 602ART15NFRMGRRC120903.DOC 12/9/03 52 relating to air pollution from prescribed burning. C.D. Notwithstanding subsection (B) (C), ADEQ and any Indian tribe may enter into a memorandum of agreement to implement this Article. E. ADEQ and any private or municipal prescribed burner may enter into a memorandum of agreement to implement this Article. R18-2-1503. A. Annual Registration, Program Evaluation and Planning for Prescribed Burns Each F/SLM shall register annually with ADEQ, on a form prescribed by ADEQ, all planned burn projects, including areas considered for potential prescribed natural fires planned for wildland fire use, for the following year. C.B. Each planned year extends from August January 1 of the registration year to July December 31 of the same following year. Each F/SLM shall use best efforts to register before August December 31 and no later than January 31 of each year. B.C. A F/SLM shall provide include the following information on the registration form: 1. The F/SLM's name, address, and business telephone number; 2. The name, address, and business telephone number of an air quality representative who will provide technical support to ADEQ for decisions regarding prescribed burning. The same air quality representative may be selected by more than one F/SLM or Indian tribe; 3. All prescribed burn projects and potential prescribed natural fire wildland fire use areas planned for the next year; and 4. Maximum project and annual acres to be burned, maximum daily acres to be burned, fuel types within project area, and planned use of emission reduction techniques to support the annual emissions goal for each prescribed burn project; 5. Planned use of any smoke management techniques for each prescribed burn project; 6. Maximum project and annual acres projected to be burned, maximum daily acres projected to be burned, and a map of the anticipated project area, fuel types and loading within the planned area for an area the F/SLM anticipates for wildland fire use; 4.7. A list of all burn projects that were completed during the previous year; 8. Project area for treatment, treatment type, fuel types to be treated, and activity fuel loading to support the annual emissions goal for areas to be treated using non-burning alternatives to fire; and 9. The area treated using non-burning alternatives to fire during the previous year including the number of acres, the specific types of alternatives utilized, and the location of these areas. 602ART15NFRMGRRC120903.DOC 12/9/03 53 D. After consultation with the F/SLM, ADEQ may request additional information related to tracking burn projects for registration of prescribed burns and wildland fire use to support regional coordination of smoke management, annual emission goal setting using ERTs, and non-burning alternatives to fire. E. A F/SLM may amend a registration at any time with a written submission to ADEQ. ADEQ shall approve a new prescribed burn even if the F/SLM has failed to amend a registration if the F/SLM has complied with the other provisions of this Article. F. ADEQ shall accept accepts a facsimile or other electronic method as a means of complying with the deadline for registration. If an electronic means is used a facsimile is submitted, the F/SLM shall deliver the original paper registration form to ADEQ for its records. ADEQ shall acknowledge in writing the receipt of each registration. If ADEQ and the F/SLMs jointly develop an electronic filing and reporting system, the original paper form may be waived, and ADEQ shall notify all F/SLMs of this change. G. No later than 14 days before a F/SLM requests permission to proceed with a registered burn project other than a prescribed natural fire, the F/SLM shall submit a Burn Plan to ADEQ, as described in R18-2-1504. A Burn Plan for a prescribed natural fire shall be submitted as prescribed by R18-21508. G. ADEQ shall hold a meeting after January 31 and before April 1 of each year between ADEQ and F/SLM=s to evaluate the program and cooperatively establish the annual emission goal. The annual emission goal shall be developed to minimize prescribed fire emissions to the maximum extent feasible using emission reduction techniques and alternatives to burning subject to economic, technical, and safety feasibility criteria, and consistent with land management objectives. H. At least once every five years, ADEQ shall request long-term projections of future prescribed fire and wildland fire use activity from the F/SLMs to support planning for visibility impairment and assessment of other air quality concerns by ADEQ. R18-2-1504. A. Prescribed Burn Plan Contents Each F/SLM planning a prescribed burn other than a prescribed natural fire, shall complete and submit to ADEQ the "Burn Plan" form supplied by ADEQ no later than 14 days before the date on which the F/SLM requests permission to burn. ADEQ shall consider the information supplied on the Burn Plan Form as binding conditions under which the burn shall be conducted. A Burn Plan shall be maintained by ADEQ until notification from the F/SLM of the completion of the burn project. 602ART15NFRMGRRC120903.DOC 12/9/03 54 Revisions to the Burn Plan for a burn project shall be submitted in writing no later than 14 days before the date on which the F/SLM requests permission to burn. The F/SLM shall provide the following information on the "Burn Plan" form To facilitate the Daily Burn authorization process under R18-2-1505, the F/SLM shall include on the Burn Plan form: 1. An emergency telephone number that is answered 24 hours a day, seven days a week; 2. Burn prescription; 3. Smoke management prescription; 4. The number of acres to be burned, the quantity and type of fuel, type of burn, and the ignition technique to be used; 5. The land management objective or purpose for the burn such as restoration or maintenance of ecological function and indicators of fire resiliency; 5.6. A map depicting the potential impact of the smoke unless waived either orally or in writing by ADEQ. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the burn site, with smokesensitive areas delineated. The map shall use the appropriate scale to show the impacts of the smoke adequately; 6.7. Modeling of smoke impacts unless waived either orally or in writing by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulates, a carbon monoxide nonattainment area, or other smoke-sensitive area. Air quality modeling for these areas is mandatory unless waived either verbally or in writing by ADEQ. In consultation with the F/SLM, ADEQ shall provide guidelines on modeling; 7.8. The name of the official submitting the Burn Plan on behalf of the F/SLM; and 8.9. After consultation with the F/SLM, any other information to support the Burn Plan needed by ADEQ to assist in the Daily Burn authorization process for smoke management purposes or assessment of contribution to visibility impairment of Class I areas. B. A Burn Plan shall be submitted for a prescribed natural fire as prescribed by R18-2-1508. R18-2-1505. A. Prescribed Burn Requests and Authorization Each F/SLM planning a prescribed burn, other than a prescribed natural fire, shall complete and submit to ADEQ the "Daily Burn Request" form supplied by ADEQ. The F/SLM shall include the following information on the Daily Burn Request form shall include: 1. The contact information of the F/SLM conducting the burn; 602ART15NFRMGRRC120903.DOC 12/9/03 55 2. Each day of the burn; 2.3. The area to be burned per on the day for which the Burn Request is submitted, with reference to the Burn Plan, including size, and legal location to the section, and latitude and longitude to the minute; 4. Projected smoke impacts; and 3.5. Any local conditions or circumstances known to the F/SLM that, if conveyed to ADEQ, could impact the Daily Burn authorization process. B. After consultation with the F/SLM, ADEQ may request additional information related to the burn, meteorological, smoke dispersion, or air quality conditions to supplement the Daily Burn Request form and to aid in the Daily Burn authorization process. This information may include same day onsite and area meteorological, smoke dispersion, or air quality measurements. C. The F/SLM shall submit the Daily Burn Request form to ADEQ as expeditiously as practicable, but no later than 2 p.m. of the business day preceding the burn. An original form, a facsimile, or an electronic information transfer are acceptable submittals. D. An F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ, as follows: 1.D. ADEQ shall approve, approve with conditions, or disapprove a burn on the same business day as the Burn Request submittal. 2. If ADEQ fails to address a Burn Request by 10 p.m. of the business day on which the request is submitted, the Burn Request is approved by default after the burner makes a good faith effort to contact ADEQ to confirm that the Burn Request was received. 3. ADEQ may communicate its decision by verbal, written, or electronic means. ADEQ shall provide a written or electronic reply if requested by the F/SLM. If ADEQ does not communicate its decision, or a confirmation that the Burn Request was received, by 10 p.m., the burn is deemed approved. E. Except as provided in subsection (D), an F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ. F.E. If weather conditions cease to conform to those in the smoke management prescription of either the Burn Plan or an Approval with Conditions, the F/SLM shall cease ignitions and take appropriate action to reduce further smoke impacts, ensure safe and appropriate fire control, and notify the public when necessary., unless after After consultation with ADEQ, the smoke management prescription or burn plan may be is modified. F. The F/SLM shall ensure that there is appropriate signage and notification to protect public safety on 602ART15NFRMGRRC120903.DOC 12/9/03 56 transportation corridors including roadways and airports during a prescribed fire. G. Burn authorization for prescribed natural fires shall be as prescribed by R18-2-1508. H. The F/SLM in whose jurisdiction a wildfire occurs shall report all wildfires greater than 100 acres on a daily basis to ADEQ. The F/SLM shall include in the report the location, estimated control date, and estimated incident size of each wildfire. The F/SLM shall provide information on projected smoke and air quality impacts and on estimated control size upon request by ADEQ. R18-2-1506. Smoke Dispersion Evaluation ADEQ shall approve, approve with conditions, or disapprove a Daily Burn Request submitted pursuant to under R18-2-1505, by using the following factors for each smoke management unit: 1. Analysis of the emissions from burns in progress and residual emissions from previous burns on a day-to-day basis; 2. Analysis of emissions from active prescribed natural fires wildland fire use incidents, and active multiple-day burns, and consideration of potential long-term emissions estimates; 3. Analysis of the emissions from wildfires greater than 100 acres and consideration of their potential long-term growth; 4. Local burn conditions; 5. Burn prescription and smoke management prescription from the applicable Burn Plan; 6. Existing and predicted local air quality; 7. Local and synoptic meteorological conditions; 8. Type and location of areas to be burned; 9. Protection of the national visibility goal for Class I Areas pursuant to under ' 169A(a)(1) of the Act and 40 CFR 51.309; and 10. Assessment of duration and intensity of smoke emissions to minimize cumulative impacts; 10.11. Minimization of smoke impacts in Class I Areas, roads or highways, airports, areas that are non-attainment for particulate matter, carbon monoxide non-attainment areas, or other smoke-sensitive areas.; and 12. R18-2-1507. A. Protection of the National Ambient Air Quality Standards. Prescribed Burn Accomplishment; ADEQ Recordkeeping; Wildfire Reporting Each F/SLM conducting a prescribed burn shall complete and submit to ADEQ the "Burn Accomplishment" form supplied by ADEQ. For each burn approval, the F/SLM shall submit a Burn 602ART15NFRMGRRC120903.DOC 12/9/03 57 Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burn. The F/SLM shall include the following information on the Burn Accomplishment form: 1. Any known conditions or circumstances that could impact the Daily Burn decision process; 2. The subsequent date, location, fuel type, fuel loading, and acreage accomplishments; 3. The BMP ERTs and SMTs for emission reduction described in R18-2-1509 and R18-2-1510, respectively, and may include any further ERTs and SMTs that become available, that the F/SLM used to reduce emissions or manage the smoke from the burn. B. For each burn approval, the F/SLM shall submit a Burn Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burning. C.B. The F/SLM shall submit the Burn Accomplishment form as an original form, a facsimile, or an electronic information transfer. D.C. ADEQ shall maintain a record of Burn Requests, Burn Approvals/Conditional Approvals/Denials and Burn Accomplishments for 5 five years. D. The F/SLM in whose jurisdiction a wildfire occurs shall make available to ADEQ no later than the day after the activity all required information for wildfire incidents that burned more than 100 acres per day in timber or slash fuels or 300 acres per day in brush or grass fuels. For each day of a wildfire incident that exceeds the daily activity threshold, the F/SLM shall provide the location, an estimate of predominant fuel type and quantity consumed, and an estimate of the area blackened that day. R18-2-1508. Prescribed Natural Fires; Wildland Fire Use: Plan;, Authorization;, Monitoring; Inter- agency Consultation; Status Reporting A. In order for ADEQ to participate in the wildland fire use decision-making process, the A F/SLM shall notify ADEQ as soon as practicable of any potential wildland fire use incident prescribed natural fire when it is projected to attain or attaining a size of 50 acres of timber fuel or 250 acres of brush or grass fuel. B. For each wildland fire use incident prescribed natural fire that has been declared as such by the F/SLM, the F/SLM shall complete and submit to ADEQ a Wildland Fire Use Burn prescribed natural fire Plan in a format approved by ADEQ in cooperation with the F/SLM. The F/SLM shall submit the Wildland Fire Use Burn prescribed natural fire Plan to ADEQ as soon as practicable but no later than 72 hours after the wildland fire use incident prescribed natural fire is declared or under consideration for such designation 1st observed. The F/SLM shall include the following information in the 602ART15NFRMGRRC120903.DOC 12/9/03 58 Wildland Fire Use Burn prescribed natural fire Plan: 1. An emergency telephone number that is answered 24 hours a day, seven days a week; 2. Anticipated burn prescription and anticipated emissions; 3. Anticipated smoke management prescription; 3.4. The estimated daily anticipated growth in the number of acres, quantity, and type of fuel to be potentially burned; 4.5. The anticipated maximum allowable perimeter or size with map; 5.6. The type or types of fuel involved; Information on the condition of the area to be burned, such as whether it is in maintenance or restoration, its ecological function, and other indicators of fire resiliency; 6.7. The anticipated duration of the wildland fire use incident prescribed natural fire; 7.8. The anticipated long-range weather trends for the site onsite; 8.9. A map depicting the potential impact of the smoke. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the wildland fire use incident burn site, with smoke-sensitive areas delineated. Mapping is mandatory unless waived either orally or in writing by ADEQ. The map shall use the appropriate scale to show the impacts of the smoke adequately; The map shall use the standard agency scale for that F/SLM; and 9.10. Modeling or monitoring of smoke impacts, if requested by ADEQ after consultation with the F/SLM. C. ADEQ shall approve or disapprove a Wildland Fire Use Burn prescribed natural fire Plan within 3 three hours of receipt. ADEQ shall consult directly with the requesting F/SLM before disapproving a Wildland Fire Use Burn prescribed natural fire Plan. If ADEQ fails to address the Wildland Fire Use Burn Plan within the time allotted, the Plan is approved by default under the condition that the F/SLM makes a good faith effort to contact ADEQ to confirm that the Plan was received. If ADEQ fails to respond to the submittal of the prescribed natural fire Plan, approval of the prescribed natural fire may be assumed by the F/SLM. Approval by ADEQ of a Wildland Fire Use Burn prescribed natural fire Plan shall be is binding upon ADEQ for the duration of the wildland fire use incident prescribed natural fire project, unless smoke from the incident prescribed natural fire creates a threat to public health or welfare. If a threat to public health or welfare is created, ADEQ shall consult with the F/SLM regarding the situation and the development of develop a joint action plan for reducing further smoke impacts. D. The F/SLM shall submit a Daily Status Report for each wildland fire use incident prescribed natural 602ART15NFRMGRRC120903.DOC 12/9/03 59 fire to ADEQ for each day of the burn that the fire burns more than 100 acres in timber or slash fuels or 300 acres in brush or grass fuels perimeter increases. The F/SLM shall include a synopsis of smoke behavior, future daily anticipated growth, and location of the activity of the wildland fire use incident prescribed natural fire in the Daily Status Report. E. The F/SLM shall consult with ADEQ prior to initiating human-made ignition on the wildland fire use incident when greater than 250 acres is anticipated to be burned by the ignition. Emergency humanmade ignition on the incident for protection of public or fire-fighter safety does not require consultation with ADEQ regardless of the size of the area to be burned. F. The F/SLM shall ensure that there is appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a wildland fire use incident. R18-2-1509. A. Emission Reduction Techniques; BMP Each F/SLM conducting a prescribed burn shall implement as many Emission Reduction Techniques BMP for emission reduction as are feasible subject to economic, technical, and safety feasibility criteria, and land management objectives. for the specific burn and shall include the BMP in the Burn Accomplishment submitted pursuant to R18-2-1507. B. The following measures are considered Emission Reduction Techniques include BMP: 1. Reducing biomass to be burned by use of techniques such as yarding or consolidation of unmerchandisable material, multi-product timber sales, or public firewood access, when economically feasible. When allowing public firewood access, provide information on the adverse impacts of using green or wet wood as fuel; 2. Burning in seasons characterized by meteorological conditions that allow for good smoke dispersion, especially March 15 through September 15; 2. Reducing biomass to be burned by fuel exclusion practices such as preventing the fire from consuming dead snags or dead and downed woody material through lining, application of fire-retardant foam, or water; 3. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires of high fuel density areas such as logging slash decks with short duration impacts; 4. Igniting burns under good-to-excellent ventilation conditions and suspending operations under poor smoke dispersion conditions; 5. Considering smoke impacts on local community activities and land users; 6.4. Burning only fuels essential fuels to meet resource management objectives; 7.5. Minimizing duff consumption and smoldering by burning under conditions of high through 602ART15NFRMGRRC120903.DOC 12/9/03 60 fuel moisture of duff and litter considerations; 6. Minimizing fuel consumption and smoldering by burning under conditions of high fuel moisture of large woody fuels; 8.7. Minimizing dirt soil content when slash piles are constructed by using brush blades on material-moving equipment and by constructing piles under dry soil conditions or by using hand piling methods; 8. Burning fuels in piles; 9. Burning piles when other burns are not feasible, such as when snow or rain is present; 9. Using a backing fire in grass fuels; 10. Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; 10. Burning fuels with an air curtain destructor, as defined in R18-2-101, operated according to manufacturer specifications and meeting applicable state or local opacity requirements; 11. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; 11. Extinguishing or mopping-up of smoldering fuels; 12. Using chunking Chunking of piles and other consolidations of burning material to enhance flaming and fuel consumption, and to minimize smoke production; 13. Implementing maintenance burning in a periodic rotation mimicking natural fire cycles to reduce excessive fuel accumulations and subsequent excessive smoke production through smoldering or wildfire; 13. Burning before litter fall; 14. Using prescribed natural fires and unplanned ignitions; and 14. Burning before green-up of fuels; 15. Managing smoke impacts as follows: a. Limiting smoke impacts to roads, highways, and airports to the amounts, frequencies, and durations consistent with any guidance provided by highway and airport personnel; 15. b. Using appropriate signing if smoke will impact any roadways; c. Notifying control towers if smoke will intrude in any air traffic control zone; d. Determining nighttime impacts and taking appropriate precautions; and e. Contacting appropriate authorities as needed regarding smoke or visibility impacts. Burning before recently cut large fuels cure in areas with activity; and 602ART15NFRMGRRC120903.DOC 12/9/03 61 16. R18-2-1510. A. Burning just before precipitation to reduce fuel smoldering and consumption. Smoke Management Techniques Each F/SLM conducting a prescribed burn shall implement as many Smoke Management Techniques as are feasible subject to economic, technical, and safety feasibility criteria, and land management objectives. B. Smoke management techniques include: 1. Burning from March 15 through September 15, when meteorological conditions allow for good smoke dispersion; 2. Igniting burns under good-to-excellent ventilation conditions; 3. Suspending operations under poor smoke dispersion conditions; 4. Considering smoke impacts on local community activities and land users; 5. Burning piles when other burns are not feasible, such as when snow or rain is present; 6. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires with short duration impacts; 7. Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; 8. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; 9. Providing information on the adverse impacts of using green or wet wood as fuel when public firewood access is allowed; 10. Implementing maintenance burning in a periodic rotation to shorten prescribed fire duration and to reduce excessive fuel accumulations that could result in excessive smoke production in a wildfire; and 11. Using wildland fire-use strategies to shift smoke into more favorable smoke dispersion seasons. R18-2-1510. R18-2-1511. A. Monitoring ADEQ may require a F/SLM to monitor weather and air quality before or during a prescribed burn or a excluding wildland fire use incident prescribed natural fires, which are governed by R18-2-1508, if necessary to accurately predict assess smoke impacts. Air quality monitoring may be conducted using both federal and non-federal reference method as well as other techniques. B. ADEQ may require a F/SLM to monitor weather before or during a prescribed burn or a wildland fire 602ART15NFRMGRRC120903.DOC 12/9/03 62 use incident, if necessary to predict or assess smoke impacts. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or area-representative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ. An F/SLM shall give ADEQ notice and an opportunity to comment before making any change to a long-term established remote automated weather station. B.C. A F/SLM shall employ the following types of monitoring, unless waived by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulate matter, a carbon monoxide, or ozone nonattainment area, or other smoke-sensitive area: 1. Smoke plume measurements, using a format supplied by ADEQ; and 1.2. The release of pilot balloons (PIBALs) at the burn site to verify needed wind speed, direction, or and stability.; and 2. Smoke plume measurements, using a format supplied by ADEQ. Instead of pilot balloons, a test burn at the burn site may be used for specific prescribed burns on a case-by-case basis as approved by ADEQ, to verify needed wind speed, direction, and stability. C.D. A An F/SLM shall make monitoring information required pursuant to under subsection (B)(C) available to ADEQ on the business day following the burn ignition. D. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or arearepresentative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ, if necessary to accurately predict smoke impacts. E. The F/SLM shall keep on file for 1 one year following the burn date any monitoring information required pursuant to under this Section. R18-2-1511. R18-2-1512. A. Burner Qualifications All burns burn projects shall be conducted by personnel trained in prescribed fire and smoke management techniques to the minimum level as required by the F/SLM in charge of the burn and established by National Wildfire Coordinating Group training qualifications. B. A Prescribed Fire Manager Boss or other local Fire Management Officer of the F/SLM having jurisdiction over prescribed burns shall have smoke management training obtained through one of the following: 1. Successful completion of a National Wildfire Coordinating Group or F/SLM-equivalent course dedicated to addressing smoke management; or 602ART15NFRMGRRC120903.DOC 12/9/03 63 2. Attendance at an ADEQ-approved smoke management workshop. R18-2-1512. R18-2-1513. A. Public Notification and Awareness Program; Regional Coordination At the Director's discretion, The Director shall conduct a public education and awareness program may be conducted by ADEQ in cooperation with F/SLMs and other interested parties to inform the general public of the smoke management program described by this Article. If conducted, the The program shall include smoke impacts from prescribed fires and the role of prescribed fire in natural ecosystems. B. ADEQ shall make annual registration, prescribed burn approval, and wildfire and wildland fire use activity information readily available to the public and to facilitate regional coordination efforts and public notification. R18-2-1514. A. Oversight An F/SLM planning to make a change to any long-term established remote automated weather station shall give ADEQ notice and an opportunity to comment before making the change. B. On or before August 15 of each year, each F/SLM shall submit to ADEQ a report generally describing each of the following: 1. The emissions reductions for each project from the previous year as a result of using BMP. Emissions reductions may be estimated using methods and emission factors developed jointly by ADEQ and F/SLMs; 2. The smoke management cost estimates for each active project from the previous year including estimates for monitoring, training, applying emission reduction techniques, research, and compliance with the requirements of this Article; and 3. Any research on or development of innovative techniques for emission reductions. R18-2-1513. R18-2-1514. A. Surveillance and Enforcement An F/SLM conducting a prescribed burn shall permit ADEQ to enter and inspect burn sites unannounced to verify the accuracy of the Daily Burn Request, Burn Plan, or Accomplishment data described pursuant to R18-2-1505 as well as matching burn approval with actual conditions, and smoke dispersion, and air quality impacts. On-ground site inspection procedures and aerial surveillance shall be coordinated by ADEQ and the F/SLM for safety purposes. B. ADEQ may use remote automated weather station data if necessary to verify current and previous 602ART15NFRMGRRC120903.DOC 12/9/03 64 meteorological conditions at or near the burn site. C. ADEQ may audit burn accomplishment data, smoke dispersion measurements, or weather measurements from previously conducted burns, if necessary to verify conformity with, or deviation from, procedures and authorizations approved by ADEQ. D. Deviation from procedures and authorizations approved by ADEQ constitute a violation of this Article. Violations may require containment or mop-up of any active burns and may also require, in the Director's discretion, a 5 five-day moratorium on ignitions by the responsible F/SLM. Violations of this Article are also subject to a civil penalty of not more than $10,000 per day per violation pursuant to under A.R.S. ' 49-463. R18-2-1515. A. Forms; Electronic Copies; Information Transfers ADEQ shall make available on paper and in electronically-readable format any form required to be developed by ADEQ and completed by a F/SLM. B. After consultation with the an F/SLM, ADEQ may require each the F/SLM to provide data in a manner that allows for and facilitates electronic transfers of information. 602ART15NFRMGRRC120903.DOC 12/9/03 65 Appendix A-10d. Supporting Documents Related to the Promulgation of Revised Arizona R18-2-602, “Unlawful Open Burning” and Article 15, “Forest and Range Management Burns” Appendix A-10 –Fire Programs Arizona Regional Haze SIP PLEASE NOTE: A certified copy of the ad for the fire rule public hearing in the Show Low area paper is not available; however, a copy of the invoice showing that an ad was placed in the area paper is attached. Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking NOTICES OF PROPOSED RULEMAKING Unless exempted by A.R.S. § 41-1005, each agency shall begin the rulemaking process by first submitting to the Secretary of State’s Office a Notice of Rulemaking Docket Opening followed by a Notice of Proposed Rulemaking that contains the preamble and the full text of the rules. The Secretary of State’s Office publishes each Notice in the next available issue of the Register according to the schedule of deadlines for Register publication. Under the Administrative Procedure Act (A.R.S. § 41-1001 et seq.), an agency must allow at least 30 days to elapse after the publication of the Notice of Proposed Rulemaking in the Register before beginning any proceedings for making, amending, or repealing any rule. (A.R.S. §§ 41-1013 and 41-1022) Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking a. Proof of at least twenty-four hours of training in interpreting each year that a valid certification is not held or EIPA passing score is not attained, and b. Documentation of a plan for the individual to meet the required qualifications within three years of employment. If the qualifications are not attained within three years, but progress toward attainment is demonstrated, the plan shall be modified to include an intensive program for up to one year to meet the provisions of subsection (B)(1). 3. An individual employed under the provisions of subsection (2) of this rule must also have the following: a. A valid fingerprint clearance card, and b. A high school diploma or GED. C. Compliance with these rules will be reviewed at the same time as a PEA is monitored for compliance with the requirements of the Individuals with Disabilities Education Act (IDEA). NOTICE OF PROPOSED RULEMAKING TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL PREAMBLE 1. Sections Affected R18-2-602 R18-2-1501 R18-2-1502 R18-2-1503 R18-2-1504 R18-2-1505 R18-2-1506 R18-2-1507 R18-2-1508 R18-2-1509 R18-2-1510 R18-2-1511 R18-2-1511 R18-2-1512 R18-2-1512 R18-2-1513 R18-2-1513 R18-2-1514 R18-2-1514 R18-2-1514 R18-2-1515 Rulemaking Action Amend Amend Amend Amend Amend Amend Amend Amend Amend Amend New Section Renumber Amend Renumber Amend Renumber Amend Repeal Renumber Amend Amend 2. The statutory authority for the rulemaking, including both the authorizing statute (general) and the statutes the rules are implementing (specific): Authorizing statutes: A.R.S. §§ 49-414, 49-414.01, and 49-425 Implementing statute: A.R.S. § 49-501 3. A list of all previous notices appearing in the Register addressing the proposed rules: Notice of Rulemaking Docket Opening: 9 A.A.R. 3386, August 1, 2003 4. The name and address of agency personnel with whom persons may communicate regarding the rulemaking: Name: Kevin Force Address: Arizona Department of Environmental Quality 1110 W. Washington Phoenix, AZ 85007 Telephone: (602) 771-4480 (This number may be reached in-state by dialing 1-800-234-5677 and requesting the seven digit number.) Fax: (602) 771-2366 Volume 9, Issue 38 Page 4066 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking 5. An explanation of the rules, including the agency’s reasons for initiating the rules: Summary. This proposed rule would amend Arizona’s existing open burning and prescribed burning rules to make them conform to EPA requirements for states’ Regional Haze State Implementation Plans. In addition, these amendments make other technical changes, including improvements of the rules’ clarity, conciseness, and understandability. Regional Haze SIP Requirements. The proposed revisions to R18-2-602 and Article 15 will allow the state’s Regional Haze SIP that Arizona is required to submit to EPA by December 31, 2003, to meet the approvability test. (40 CFR 51.309(c)) The specific requirements for state regional haze SIPs are found at 40 CFR 51.308 and 51.309. Under 40 CFR 51.309(d)(6), Programs Related to Fire, the plan must provide for: “(i) Documentation that all Federal, State, and private prescribed fire programs within the State evaluate and address the degree visibility impairment from smoke in their planning and application. In addition the plan must include smoke management programs that include all necessary components including, but not limited to, actions to minimize emissions, evaluation of smoke dispersion, alternatives to fire, public notification, air quality monitoring, surveillance and enforcement, and program evaluation. (ii) A statewide inventory and emissions tracking system (spatial and temporal) of VOC, NOX, elemental and organic carbon, and fine particle emissions from fire. In reporting and tracking emissions from fire from within the State, States may use information from regional data-gathering and tracking initiatives. (iii) Identification and removal wherever feasible of any administrative barriers to the use of alternatives to burning in Federal, State, and private prescribed fire programs within the State. (iv) Enhanced smoke management programs for fire that consider visibility effects, not only health and nuisance objectives, and that are based on the criteria of efficiency, economics, law, emission reduction opportunities, land management objectives, and reduction of visibility impact. (v) Establishment of annual emission goals for fire, excluding wildfire, that will minimize emission increases from fire to the maximum extent feasible and that are established in cooperation with States, tribes, Federal land management agencies, and private entities.” In early 2002, ADEQ’s Regional Haze stakeholders established a Fire Emissions Work Group (FEWG) to discuss visibility issues related to fire emissions and make recommendations to ADEQ for the Regional Haze SIP. Fifteen stakeholders, representing public and private entities in geographically diverse areas of the state, agreed to participate in the work group. The FEWG held a series of meetings from June 2002 through May 2003 to learn about and discuss options for all categories of burning activities that occur in the state. The draft rules were presented at pubic workshops in Casa Grande, Flagstaff, Phoenix, Show Low, and Yuma from April 10-17, 2003. The extensive meeting schedule was proposed by work group members in order to provide local access to the rulemaking process and obtain early input from sectors of the community who would be most affected by these rules. The current proposed rule is a joint effort of ADEQ and the FEWG based on input received at those public meetings and the decisions of the FEWG. Structure of open burning authority in Arizona. A.R.S. § 49-425 provides ADEQ with general air quality rule authority, including authority to promulgate rules for open burning permits. It requires the Director to adopt rules determined necessary and feasible “to reduce the release into the atmosphere of air contaminants originating within the territorial limits of the state.” A.R.S. § 49-501 adds related authority by excepting from its provisions those open outdoor fires that are permitted by any rule issued pursuant to A.R.S. § 49-425 (see subsections (C)(5) and in (E)) by allowing the director to delegate authority to issue open burn permits to a “county, city, town, or fire district.” A.R.S. § 49-414.01(A) sets forth regional haze goals and requires the Director to submit a plan to EPA that addresses “programs related to emissions from fire sources” “as necessary to submit an approvable plan” and authorizes rules necessary for the revisions to the state implementation that address regional haze.” R18-2-602 and a related statute, A.R.S. § 49-501, govern open burning activities under ADEQ’s jurisdiction. A.R.S. § 49-501 was last amended in 1997. In 1996, the delegation subsection (E) was added. In 1994, the general permit for household waste was added. Based on the statute and rule, ADEQ published guidelines on open burning in February, 1997. Proposed Open Burning Revisions At the public meetings mentioned above, the three frequent topics for comment were: time-of-day burning restrictions in R18-2-602(D)(3), permitting requirements for air curtain destructors, sometimes called air curtain incinerators, and the relationship of the state rule to counties that have independent authority to permit fires. Compared to the existing rule, this proposed rule contains a number of additional definitions in a separate subsection. ADEQ has proposed definitions for various categories of open burning, such as agricultural, construction, and residential. In addition, there are new definitions for “delegated authority,” “independent authority to permit fires,” and “prohibited materials.” Prohibited materials were previously described in a guidance document. By placing all of the necessary material from the guidelines in the proposed rule, ADEQ intends that this amended R18-2-602 will replace the guidelines as of the effective date of the rule. September 19, 2003 Page 4067 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking The proposed rule also clarifies which open burning activities require open burning permits and those that are exempt from a permit. The proposed rule contains a more complete list of information that is required to be in the permit. This is both for more efficient permit administration, and to comply with various aspects of the regional haze rule. ADEQ considered exempting certain fires using air curtain destructors from the open burn permit requirement in order to remove an administrative barrier to this type of burning, as required by the Regional Haze Rule (see 40 CFR 51.309(d)(6)(iii)). Air curtain destructors (ACDs) are basically incinerators with high velocity air blown across and into the upper portion of the combustion chamber. This curtain of air traps particulates (smoke) and oxygenates the chamber, resulting in better combustion and less smoke. After reviewing two studies, ADEQ decided that these devices do require oversight and it is appropriate that they be subject to permits under the rule. ADEQ does not view the requirement that ACDs obtain a permit as an administrative barrier. ADEQ also notes that certain air curtain destructors are subject to New Source Performance Standards (see 40 CFR 60, subparts CCCC and DDDD). Studies reviewed by ADEQ relevant to air curtain destructors are listed in item #6 of this preamble. ADEQ has added language in the proposed rule clarifying that the state rule will not operate in counties with independent authority to permit fires, and has listed the three counties in the definition. This independent authority is derived in part from language in A.R.S. § 49-501(C)(5) specifying that fires permitted pursuant to county rules are excepted from A.R.S. § 49-501. The three counties referenced in the definition all have rules creating permits for open outdoor fires, other than dangerous materials. (see Maricopa County Rule 341; Pima County Rule 17.12.480, et seq.; Pinal County Rule 3-8-700 and 3-8-710.) Pursuant to A.R.S. § 49-501(G) and its current PM10 SIP, Maricopa County prohibits burning of household waste. The proposed rule also clarifies provisions on burning of dangerous materials and household waste. Finally, new restrictions on permits issued by delegated authorities that minimize the potential for conflict of interest on the part of delegated authorities have been included in proposed subsection (G). First, the proposed rule specifies that a delegated authority may not issue itself open burning permits. Second, the rule proposes to prevent private fire protection providers from conditioning the issuance of open burning permits on the applicant being their customer. Proposed Prescribed Burning Revisions State and federal forest and range land make up more than half of the land in Arizona. Despite potential air quality concerns, state and federal land managers (F/SLMs) use fire as a resource management tool on this land for a variety of purposes. Article 15 governs those fires that are set or allowed to burn on these lands in Arizona. The two primary air quality concerns are violations of national ambient air quality standards (NAAQS) for particulates, and visibility impairment. Research indicates that, on average, 90 percent of smoke particles from wildland and prescribed fires are PM10, and 10 percent are PM2.5. Arizona’s Prescribed Burning requirements are in Article 15 of the Administrative Code address these air quality concerns, primarily through efforts to ensure the best times for ‘burns’ and by promoting other techniques to reduce the amount of smoke produced and the effects of that smoke. A.R.S. § 49-414.01 specifically requires the Director to submit a plan to EPA, and allows ADEQ to promulgate rules addressing programs related to emissions from wildland fire, including prescribed fires and wildfires (see A.R.S. § 49-414.01(A)(7)). The proposed revisions to Article 15 of the Code, which governs the procedures relating to prescribed and wildland fires, will better conform to EPA’s regional haze requirements, be more understandable, and facilitate enhanced compliance. Most of the proposed changes to Article 15 directly reflect the mandates of the EPA’s regional haze rule requirements, particularly those relating to the collection and recording of burn data, the evaluation of burn programs and setting of annual emission goals. The former structure of the rule remains intact: 1) Annual registration; 2) submittal of a Burn Plan at least 14 days before the burn; 3) a daily Burn Request; and 4) a Burn Accomplishment Form. Section by Section Explanation of significant proposed changes. Article 6 R18-2-602 This rule describes the process by which permits may be issued for open burns, and identifies open burning activities which are exempt from the permit requirement. Article 15 R18-2-1501 This Section lists the definitions applicable to Article 15. In response to the EPA regulation, there are new definitions for “Annual Emissions Goal,” and “non-burning alternatives to fire.” In addition, “Best Management Practices” has been replaced by “Smoke management techniques” and “Emission reduction techniques,” and “Prescribed natural fire” has been replaced by “Wildland fire use.” R18-2-1502 This Section limits the applicability of the rule to state and federal land mangers, while excluding Indian Trust lands. The proposed change clarifies that private burners, such as the Nature Conservancy, may also be subject to the Article. R18-2-1503 This Section describes the process by which land managers annually register their planned burns with ADEQ. The proposed changes incorporate emission reduction techniques and non- Volume 9, Issue 38 Page 4068 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking burning alternatives to fire and facilitate the setting of annual emission goals. A new annual period and other clarifying changes are proposed. R18-2-1504 This Section requires the details of each burn to be included in the Burn Plan form to be submitted to ADEQ 14 days before requesting permission to ignite. The proposed changes clarify the process and supplement the information related to it. R18-2-1505 This Section requires land mangers to submit a daily burn request for each day of the burn and describes optional agency response to the request. The proposed changes are primarily clarifying. R18-2-1506 This Section describes how the agency will determine whether and how much burning to allow. The proposed changes also add clarifying factors not directly related to regional haze. R18-2-1507 This Section requires land managers to report acreage and fuel types burned, the emission reduction and smoke management techniques used, and requires ADEQ to keep records of this information. A subsection has been added for wildfire reporting to allow those fires’ emissions to be entered into the regional haze emission tracking system. R18-2-1508 This Section describes how land managers shall inform the agency of wildfires and seek permission for wildland burn uses. Clarifications have been proposed based on recent experiences with wildfires. R18-2-1509 This Section is proposed to replace the former BMP section and describes Emission Reduction Techniques, many of which were listed previously as BMPs. It requires land mangers to use as many as feasible. R18-2-1510 This Section is also proposed to replace the former BMP section and describes Smoke Management Techniques, some of which were listed previously as BMPs. It requires land managers to use as many as feasible. R18-2-1511 This Section describes how the agency may require land managers to monitor aspects of their prescribed burns and wildland burn uses. The proposed changes are clarifications and minor changes to weather and air quality monitoring. R18-2-1512 This Section requires all burn projects to be conducted by personnel trained in prescribed fire and smoke management techniques. The proposed changes are clarifications. R18-2-1513 This Section directs the agency to conduct burn-related public awareness programs and make burn information available to the public. The proposed changes attempt to promote regional coordination. R18-2-1514 This Section describes how the agency may inspect, verify, and audit burn information, and actions the agency may take regarding enforcement. R18-2-1514(former) In a recent five-year review report, ADEQ stated that it would reevaluate the need for this Section. ADEQ is proposing to delete subsection (B) because the changes in R18-2-1503 provide for a more efficient and effective system. Subsection (A) has been moved to R18-2-1511(B). R18-2-1515 6. This Section directs the agency to make its forms and data relating to prescribed burns and wildland burn uses available in an electronic format. The proposed changes are clarifying only. A reference to any study relevant to the rules that the agency reviewed and either proposes to rely on in its evaluation of or justification for the rules or proposes not to rely on in its evaluation of or justification for the rules, where the public may obtain or review each study, all data underlying each study, and any analysis of each study and other supporting material: The Use of Air Curtain Destructors for Fuel Reduction, Alan R. Shapiro, United States Department of Agriculture, Forest Service Technology and Development Program (September 2002). Reducing PM2.5 Emissions Through Technology, Evaluations of the Effectiveness of an Air Curtain Incinerator, Ronald A. Scott, Ronald Babbitt, Emily Lincoln, and Wei Min Hao, USDA Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory, Missoula, MT (October 2002) Studies available for review at the ADEQ Library, 1110 W. Washington, First Floor, Phoenix, AZ 85007. 7. A showing of good cause why the rules are necessary to promote a statewide interest if the rules will diminish a previous grant of authority of a political subdivision of this state: Not applicable September 19, 2003 Page 4069 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking 8. The preliminary summary of the economic, small business, and consumer impact: A. Rule Identification The rules amended in this rulemaking are R18-2-602, “Unlawful Open Burning,” and Article 15, “Forest and Range Management Burns,” R18-2-1501 through R18-2-1515. B. Entities Affected by R18-2-602, “Unlawful Open Burning” Open burning may be done by many entities for a variety of purposes, such as waste disposal, weed control, site preparation, disease and pest prevention, resource management, training and fire prevention. Unless specifically exempted by this rule, persons setting outdoor fires would have to obtain a permit from ADEQ or a delegated authority, a city or fire district, or one of the three counties with independent authority to issue permits (Maricopa, Pima, Pinal). Persons who might be subject to this proposed rule therefore include: (1) individuals; (2) businesses, such as farms, ranches, orchards, electric generating plants, construction and mines; (3) federal sources, such as military installations; (4) state agencies, such as the Departments of Transportation and Corrections; and, (5) political subdivisions, such as counties, cities, irrigation districts, and fire districts. ADEQ has delegated authority to issue permits to about 50 fire departments, fire districts and cities or towns located in nine of Arizona’s 15 counties. Authority to issue permits in Graham County is delegated to Graham County Health Department, while Maricopa, Pima and Pinal Counties have independent authority to permit fires. ADEQ has jurisdiction to issue permits in areas outside the delegated authorities’ jurisdiction in these counties. ADEQ typically issues more than 100 open burning permits annually to a wide variety of permittees, most of which are for burns in Gila and Cochise Counties. Permits for burns in La Paz, Yavapai, Santa Cruz, Apache, Greenlee and Coconino Counties are also common. The following represents a sampling of the level of permits issued by delegated authorities based on the calendar year 2002. The City of Prescott in Yavapai County issued about 200 permits in 2002, of which the majority was for residential burning. The City of Yuma issued 15 open burning permits, mainly for agriculture. Rural Metro Fire Department, which has jurisdiction outside of the municipalities of Somerton and Yuma, typically issues 300-400 residential open burning permits and 50-60 permits for agriculture in Yuma County. The City of Payson in Gila County issued 146 open burning permits for brush and weeds. Bullhead City in Mohave County annually issues 50-70 open burning permits of which the majority is for residential burning. The 384 open burning permits issued by Graham County Health Department in fiscal year 2003 were all for purposes of weed abatement. C. Potential Impact of R18-2-602 Much of what previously existed as guidelines in 1997 is being incorporated into R18-2-602. Therefore, the baseline for calculating the proposed rule impacts is the current rule requirements, effective in 1990, and these guidelines. The difference between the combined rule provisions and guidelines, and the implementation of the revised R18-2-602 represents the potential impact. Because this rulemaking proposes only minor changes and incorporates already existing guidance, ADEQ expects the rule to create minimal actual impact, such as the costs associated with minor changes in recordkeeping, documentation, and reporting requirements. ADEQ and delegated authorities will have to maintain copies of effective permits, as well as prepare annual reports for submission to ADEQ. While some of these changes will generate minimal costs, ADEQ expects the overall benefits to exceed those costs. It should also be noted that ADEQ does not charge fees for open burning permits because most permits are issued in a day or two and it would require minimal administrative effort. D. Entities Affected by Article 15, “Forest and Range Management Burns” Since ADEQ has jurisdiction, outside tribal lands, over air pollution resulting from prescribed burning, this proposed rule will impact the following federal and state agencies that do burning: (1) Federal Land Managers (FLMs) involved in burning activities, such as U.S. Forest Service, U.S. Fish and Wildlife Service, National Parks Service, Bureau of Land Management, Bureau of Reclamation, Department of Defense; (2) State Land Managers (SLMs), such as Arizona State Land Department, Arizona Department of Transportation, Arizona Department of Game and Fish, and Parks Department. Additionally, there are entities not actually subject to this rule but who may voluntary comply with some or all of the rule provisions, such as the Bureau of Indian Affairs, one of the largest burners in Arizona. Also, private land managers, such as The Nature Conservancy, or individuals, might also need to comply with this rule or request assistance from one of the F/SLMs. Each year, ADEQ receives more than 1,000 daily burn requests from F/SLMs. For example, in calendar year 2002, about 1,400 requests to burn were received, and slightly more than 104,000 acres were burned, which represents about 56 percent of the total acres approved to burn. This figure is approximately equal to the number of acres burned each year for the past ten years (106,429) on federal, state, and tribal lands. The major fuel types burned in 2002 and their relative proportions include: piled ponderosa pine (22%), non-piled ponderosa pine (21%), and natural ponderosa pine (17%). The remaining 40% of fuel types include: natural shrub, non-piled grass and ponderosa pine, natural grass, natural grass and ponderosa pine, non-piled mixed, and other. Volume 9, Issue 38 Page 4070 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking For comparison, in 1999, F/SLMs requested nearly 450,000 acres to burn. Although ADEQ approved close to 80 percent of the requested acreage, the actual number of acres burned was about 200,000. The fuel types burned in 1999 were: broadcast slash (32%), ponderosa pine (22%), grass (20%), slash piles (14%), brush (10%), and pinyon juniper (2%). As shown with these two years, proportions, however, vary from one year to another. Combining acres burned for 1994 through 1999, shows the percentage of acres burned by F/SLMs agencies: U.S. Forest Service (49%), Bureau of Indian Affairs (30%), National Park Service (7%), Bureau of Land Management (7%), U.S. Fish and Wildlife (6%), Arizona State Land Department (1%), and other (1%). E. Potential Impact of Article 15 Because this rule involves forest and range management burning by federal and state land managers, private persons, political subdivisions of the state, and small businesses will not bear any direct incremental costs from the proposed rule changes. However, because the proposed rule requires both better tracking of emissions, better management of smoke, and public education and notification, benefits are expected to accrue to the public, particularly to populations living close to the burns. Specifically, there is potential for incremental benefits arising from better planning and implementation of measures which increase burn efficiency, prevent wildfires, improve visibility, and reduce smoke impacts to both the general public and more sensitive segments of the population. F/SLMs currently pay for two full-time positions to work with ADEQ at an estimated annual value of $120,000 at ADEQ. Office space and equipment are provided by ADEQ. ADEQ currently supports one full-time position for the smoke management program. Although implementing this amended rule may require minimally increased planning and evaluation time, ADEQ does not expect to need additional employees to handle the workload. This increased workload, together with administrative costs associated with making burn information publicly available and conducting public awareness programs, are all that comprise the incremental impact to ADEQ. Thus, ADEQ judges that the costs to the agency are minimal. The incremental impact of the proposed changes to Article 15 is based on the rule’s new requirements, and are expected to result in minimal economic impact to F/SLMs and ADEQ. For example, F/SLMs will have to provide more information about their prescribed burns, including emission reduction techniques and non-burning alternatives. They will also be encouraged to attend annual meetings for program evaluation and the establishment of annual emissions goals, and will be looked to for the development of long-term projections of future prescribed fire and wildland fire use activities. The information provided by F/SLMS will be used by ADEQ to assess visibility impairment and other air quality concerns. Additional compliance costs include those associated with the incorporation of additional emission reduction and smoke management techniques. Together, these rule changes are expected to improve the state’s smoke management program, which could lead to improvements in air quality through reduction and better management of burns. Evidence shows that exposure to criteria pollutants, either to individual pollutants such as particulate matter (PM), or collectively to a variety of pollutants, is associated with increased mortality. The positive correlation is most closely related to ambient air concentrations of PM. Human health effects of PM, for example, include premature mortality, bronchitis, new asthma cases and exacerbated asthma in existing individuals, increased hospital admissions, lower and upper respiratory illness, shortness of breath, respiratory symptoms, restricted activity days, and lost days of work. Other health effects ascribed to exposure to PM include changes in pulmonary function, chronic respiratory diseases (other than chronic bronchitis), morphological changes, neonatal mortality, cancer, altered host defense mechanisms, and non-asthma respiratory emergency room visits. Estimated economic values have been assigned to death and other adverse health effects. For example, a statistical death has been estimated to cost $6.3 million (in year 2000 dollars), chronic bronchitis due to PM costs $260,000 per patient, mortality life years lost is valued at $293,000 per each life year, and work days lost due to PM is worth about $83 per day. (EPA, The Benefits and Costs of the Clean Air Act 1990-2010, Office of Air and Radiation, Office of Policy, November 1999, Table 5-1.) F. Reduction of Impacts to Small Businesses for R18-2-602 and Article 15 These rules create minimal increased compliance costs for ADEQ to administer the open burning and prescribed forestry burning programs. ADEQ considered each of the methods prescribed in A.R.S. § 41-1035 for reducing the impact on small businesses. Likewise, it considered each of the methods prescribed in A.R.S. § 41-1055(B)(5)(c). For example, A.R.S. § 41-1035 requires agencies implementing rules to reduce the impacts on small businesses by using certain methods where legal and feasible. Methods that may be used include the following: (1) exempt them from any or all rule requirements, (2) establish performance standards which could replace more costly design or operational requirements, or (3) institute reduced compliance or reporting requirements. ADEQ cannot provide additional regulatory relief for small businesses applying for open burning permits. As the agency does not charge fees for open burning permits, ADEQ expects that the proposed R18-2-602’s reporting requirement (on forms developed by ADEQ) will create minimal economic impacts to individual persons or small businesses. The rule procedures have been kept as simple and straightforward as possible. Article 15 does not directly impact small businesses as it applies primarily to public entities. September 19, 2003 Page 4071 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking 9. The name and address of agency personnel with whom persons may communicate regarding the accuracy of the economic, small business, and consumer impact statement: Name: David Lillie, Economist Address: ADEQ 1110 W. Washington Phoenix, AZ 85007 Telephone: (602) 771-4461 (This number may be reached in-state by dialing 1-800-234-5677 and requesting the seven digit number) Fax: (602) 771-2366 10. The time, place, and nature of the proceedings for the making, amendment, or repeal of the rules, or if no proceeding is scheduled, where, when, and how persons may request an oral proceeding on the proposed rules: Time: October 20, 2003, 1:30 p.m. Place: Yuma Public Works, Training Room 155 W. 14th Street Yuma, AZ 85364 Time: October 21, 2003, 1:30 p.m. Place: Casa Grande Parks & Recreation Office, Armadillo Room 440 E. Florence Blvd. Casa Grande, AZ 85222 Time: October 22, 2003, 1:30 p.m. Place: Show Low City Hall, Council Chambers 200 W. Cooley Show Low, AZ 85901 Time: October 23, 2003, 1:30 p.m. Place: Flagstaff City-Coconino County Public Library 300 W. Aspen Flagstaff, AZ 86001 Nature: Public hearings on proposed rules with opportunity for formal comments on the record. Please call (602) 771-4795 for special accommodations pursuant to the Americans with Disabilities Act. Close of comment: October 24, 2003, 5:00 p.m. 11. Any other matters prescribed by statute that are applicable to the specific agency or to any specific rule or class of rules: Not applicable 12. Incorporations by reference and their location in the rules: Not applicable 13. The full text of the rules follows: TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES Section R18-2-602. Unlawful Open Burning Volume 9, Issue 38 Page 4072 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS Section R18-2-1501. R18-2-1502. R18-2-1503. R18-2-1504. R18-2-1505. R18-2-1506. R18-2-1507. R18-2-1508. Definitions Applicability Annual Registration, Program Evaluation and Planning for Prescribed Burns Prescribed Burn Plan Contents Prescribed Burn Requests and Authorization Smoke Dispersion Evaluation Prescribed Burn Accomplishment; ADEQ Recordkeeping; Wildfire Reporting Prescribed Natural Fires; Wildland Fire Use: Plan;, Authorization;, Monitoring; Interagency Consultation; Status Reporting R18-2-1509. Emission Reduction Techniques; BMP R18-2-1510. Smoke Management Techniques R18-2-1510. R18-2-1511. Monitoring R18-2-1511. R18-2-1512. Burner Qualifications R18-2-1512. R18-2-1513. Public Notification and Awareness Program; Regional Coordination R18-2-1514. Oversight R18-2-1513. R18-2-1514. Surveillance and Enforcement R18-2-1515. Forms; Electronic Copies; Information Transfers ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES R18-2-602. Unlawful Open Burning A. Notwithstanding the provisions of any other rule in this Chapter, it is unlawful for any person to ignite, cause to be ignited, permit to be ignited, or suffer, allow or maintain any open outdoor fire. B. “Open outdoor fire,” as used in this rule, means any combustion of combustible material of any type outdoors, in the open where the products of combustion are not directed through a flue. “Flue,” as used in this rule, means any duct or passage for air, gases or the like, such as a stack or chimney. C. The following fires are excepted from the provisions of this rule: 1. Fires used only for cooking of food or for providing warmth for human beings or for recreational purposes or the branding of animals or the use of orchard heaters for the purpose of frost protection in farming or nursery operations. 2. Any fire set or permitted by any public officer in the performance of official duty, if such fire is set or permission given for the purpose of weed abatement, the prevention of a fire hazard, or instruction in the methods of fighting fires. 3. Fires set by or permitted by the state entomologist or county agricultural agents of the county for the purpose of disease and pest prevention. 4. Fires set by or permitted by the federal government or any of its departments, agencies or agents, the state or any of its agencies, departments or political subdivisions, for the purpose of watershed rehabilitation or control through vegetative manipulation. D. Permission for the setting of any fire given by a public officer in the performance of official duty under subsections (C)(2), (3), or (4) shall be given, in writing, and a copy of such written permission shall be transmitted immediately to the Director of the Department of Environmental Quality and the control officer, if any, of the county, district or region in which such fire is allowed. The setting of any such fire shall be constructed in a manner and at such time as approved by the Director, unless doing so would defeat the purpose of the exemption. E. The following fires may be excepted from the provisions of this Section when permitted in writing by the Director of the Department of Environmental Quality or the control officer of the county, district or region in which such fire is allowed: 1. Fires set for the disposal of dangerous materials where there is no safe alternative method of disposal. a. “Dangerous material” is any substance or combination of substances which is able or likely to inflict bodily harm or property loss unless neutralized, consumed or otherwise disposed of in a controlled and safe manner. b. Fires set for the disposal of dangerous materials shall be permitted only when there is no safe alternative method of disposal, and when the burning of such materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts which will endanger health or safety. 2. Open outdoor fires for the disposal of ordinary household trash in an approved waste burner in nonurban areas of less than 100 well spread out dwelling units per square mile where no refuse collection and disposal service is available. a. An “approved waste burner” is an incinerator constructed of fire resistant material with a cover or screen which is closed when in use having openings in the sides or top no greater than 1 inch in diameter. b. Open burning of the following materials is forbidden: Garbage resulting from the processing, storage, service or consumption of food; asphalt shingles; tar paper; plastic and rubber products (such as waste crankcase oil, transmission oil and oil filters); transformer oils; and hazardous material containers including those that contained inorganic pesticides, lead, cadmium, mercury, or arsenic compounds. September 19, 2003 Page 4073 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking F. The Director of the Department of Environmental Quality or the air pollution control officer, if any, of the county, district, or region may delegate the authority for the issuance of allowable open burning permits to responsible local officers. Such permits shall contain conditions limiting the manner and the time of the setting of such fires as specified in the Arizona Guidelines for Open Burning and shall contain a provision that all burning be extinguished at the discretion of the Director or his authorized representative during periods of inadequate atmospheric smoke dispersion, periods of excessive visibility impairment which could adversely affect public safety, or periods when smoke is blown into populated areas so as to create a public nuisance. Any local officer delegated the authority for issuance of open burning permits shall maintain a copy of all currently effective permits issued including a means of contacting the person authorized by the permit to set an open fire in the event that an order for extinguishing of open burning is issued. G. Nothing in this rule is intended to permit any practice which is a violation of any statute, ordinance, rule or regulation. A. In addition to the definitions contained in A.R.S. § 49-501, in this Section: 1. “Agricultural Burning” means burning of vegetative materials related to the production and harvesting of crops and raising of animals for the purpose of marketing for profit, or providing a livelihood, but not including the burning of household waste or prohibited materials. Burning may be conducted in fields, piles, ditch banks, fence rows or canal laterals for purposes such as weed control, waste disposal, disease and pest prevention, or site preparation. 2. “Approved waste burner” means an incinerator constructed of fire resistant material with a cover or screen which is closed when in use having openings in the sides or top no greater than one inch in diameter. 3. “Class I Area” means any one of the Arizona mandatory federal class I areas defined in A.R.S. § 49-401.01. 4. “Construction burning” means burning of wood or vegetative material from land clearing, site preparation, or fabrication, erection, installation, demolition, or modification of any buildings or other land improvements, but not including the burning of household waste or prohibited materials. 5. “Dangerous material” is any substance or combination of substances that is capable of causing bodily harm or property loss unless neutralized, consumed or otherwise disposed of in a controlled and safe manner. 6. “Delegated authority” means any of the following: a. A county, city, town, air pollution control district, or fire district that has been delegated authority to issue open burning permits by the Director under A.R.S. § 49-501(E); or b. A private fire protection service provider that has been assigned authority to issue open burning permits by one of the authorities in subsection (a). 7. “Director” means the Director of the Department of Environmental Quality, or his designee. 8. “Emission reduction techniques” are techniques for controlling emissions from open outdoor fires to minimize the amount of emissions output per unit or area burned. 9. “Flue,” as used in this subsection, means any duct or passage for air or combustion gases, such as a stack or chimney. 10. “Household waste” means any solid waste including garbage, rubbish and sanitary waste from septic tanks that is generated from households including single and multiple family residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day use recreation areas, not including construction debris, landscaping rubble or demolition debris. 11. “Independent authority to permit fires” means the authority of a county to permit fires by a rule adopted pursuant to Arizona Revised Statutes, Title 49, Chapter 3, Article 3. Maricopa, Pima, and Pinal counties have independent authority to permit fires. 12. “Open outdoor fire or open burning” means the combustion of material of any type outdoors, in the open, where the products of combustion are not directed through a flue. Open outdoor fires include agricultural, residential, prescribed and construction burning. Purposes for fires can include prevention of a fire hazard, instruction in the methods of fighting fires, watershed rehabilitation, disease and pest prevention. 13. “Prohibited materials” means nonpaper garbage from the processing, storage, service, or consumption of food; chemically treated wood; tires; explosives or ammunition; oleanders; asphalt shingles; tar paper; plastic and rubber products, including bottles for household chemicals; plastic grocery and retail bags; waste petroleum products, such as waste crankcase oil, transmission oil and oil filters; transformer oils; asbestos; batteries; anti-freeze; aerosol spray cans; electrical wire insulation; thermal insulation; polyester products; hazardous waste products such as paints, pesticides, cleaners and solvents, stains and varnishes and other flammable liquids; plastic pesticide bags and containers; and hazardous material containers including those that contained lead, cadmium, mercury, or arsenic compounds. 14. “Residential burning” means open burning of vegetative materials conducted by or for the occupants of residential dwellings, but not including burning of household waste or prohibited materials. 15. “Prescribed burning” has the same meaning as in R18-2-1501. B. Unlawful Open Burning. Notwithstanding any other rule in this Chapter, it is unlawful for any person to ignite, cause to be ignited, permit to be ignited, or suffer, allow or maintain any open outdoor fire in a county without independent authority to permit fires except as provided in A.R.S. § 49-501 and this Section. Volume 9, Issue 38 Page 4074 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking C. Open Outdoor Fires Exempt From a Permit. The following fires do not require an open burning permit from the Director or a delegated authority: 1. Fires used only for: a. Cooking of food; b. Providing warmth for human beings; c. Recreational purposes; d. Branding of animals; e. Orchard heaters for the purpose of frost protection in farming or nursery operations; and f. The proper disposal of flags under 4 U.S.C. 8. 2. Any fire set or permitted by any public officer in the performance of official duty, if such fire is set or permission given for the purpose of fire control of an active wildfire. 3. Fires set by or permitted by the Director of Department of Agriculture for the purpose of disease and pest prevention in organized, area-wide control of epidemics or infestations affecting livestock or crops. 4. Prescribed burns set by or assisted by the federal government or any of its departments, agencies or agents, the state or any of its agencies, departments or political subdivisions, pursuant to Article 15 of this Chapter. D. Open Outdoor Fires Requiring a Permit. 1. The following open outdoor fires are allowed with an open burning permit from the Director or a delegated authority: a. Construction burning; b. Agricultural burning; c. Residential burning; d. Prescribed burns conducted on private lands without the assistance of a federal or state land manager as defined under R18-2-1501; e. Any fire set or permitted by a public officer in the performance of official duty, if such fire is set or permission given for the purpose of weed abatement, the prevention of a fire hazard, or instruction in the methods of fighting fires, unless such fire is exempt from the permit requirement under subsection (C)(3); f. Open outdoor fires of dangerous material under subsection (E); and g. Open outdoor fires of household waste under subsection (F). 2. A person conducting an open outdoor fire in a county without independent authority to permit fires shall obtain a permit from the Director or a delegated authority unless exempted under subsection (C). Permits may be issued for a period not to exceed one year. A person shall obtain a permit by completing an ADEQ-approved application form. 3. Open outdoor fire permits issued under this Section shall include: a. A list of the materials that may be burned under the permit; b. A means of contacting the person authorized by the permit to set an open fire in the event that an order to extinguish the open outdoor fire is issued by the Director or the delegated authority; c. A requirement that burns be conducted during the following periods, unless otherwise waived or directed by the Director on a specific day basis: i. Year round: start ignition no earlier than one hour after sunrise; and ii. Year round: fire must be extinguished two hours before sunset. d. A requirement that all open burning shall be conducted only during atmospheric conditions which: i. Prevent dispersion of smoke into populated areas; ii. Prevent visibility impairment on traveled roads or at airports that results in a safety hazard; iii. Do not create a public nuisance or adversely affect public safety; iv. Do not cause an adverse impact to visibility in a Class I area; and v. Do not cause uncontrollable spreading of the fire; e. A listing of the types of actions that shall be utilized to minimize fire emissions including any emission reduction techniques; f. A reporting requirement that shall be met by providing the following information in a format provided by the Director for each date open burning occurred, on either a daily basis on the day of the fire, or in an annual report to the Director or delegated authority due on March 31 for the previous calendar year: i. The date of the burn; ii. The type and quantity of fuel burned for each date open burning occurred; iii. The fire type, such as pile or windrow, for each date open burning occurred; and iv. For each date open burning occurred, the legal location, to the nearest section, or latitude and longitude, to the nearest degree minute, or street address for residential burns. g. A requirement that the person conducting the open burn notify the local fire-fighting agency, or if none is in existence, the state forester, prior to commencement of open burning; h. A requirement that each open outdoor fire be started using items that do not cause the production of black smoke; i. A requirement that the fire shall be attended at all times until it is completely extinguished; j. A requirement that fire extinguishing equipment must be on-site for the duration of the burn; September 19, 2003 Page 4075 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking k. A requirement that the burning pit, burning pile, or approved waste burner be at least 50 feet from any structure; l. A requirement that the burner must have a copy of the burn permit on-site during open burning; m. A requirement that no open burning shall be conducted when an air stagnation advisory, as issued by the National Weather Service, is in effect in the area of the burn or during periods when smoke can be expected to accumulate to the extent that it will significantly impair visibility in Class I areas; n. A requirement that no open burning shall be conducted when any stage air pollution episode is declared under R18-2-220. o. A statement that the Director, or any other public officer may order that the burn be extinguished or prohibit burning during periods of inadequate smoke dispersion, excessive visibility impairment, or during periods of extreme fire danger; and p. A copy of the activities prohibited and the criminal penalties provided under A.R.S. § 13-1706. 4. The Director or a delegated authority shall not issue an open burning permit under this Section: a. That would allow the burning of prohibited materials other than under a permit for the burning of dangerous materials; b. If the applicant has applied for a permit under this Section to burn dangerous materials which are also hazardous waste under 40 CFR 261, but does not have a permit for the burning of hazardous waste under 40 CFR 264, or is not an interim status facility allowed to burn hazardous waste under 40 CFR 265; or c. If the burning would occur at a solid waste facility in violation of 40 CFR 258.24 and the Director has not issued a variance approval under A.R.S. § 49-763.01(A). E. Open Outdoor Fires of Dangerous Material. Fires set for the disposal of dangerous materials are allowed by the provisions of this Section, when the materials are too dangerous to store and transport, as permitted in writing by the Director. Permits issued shall contain all provisions in subsection (D)(3) except for subsections (e) and (f). Fires set for the disposal of dangerous materials shall be permitted only when there is no safe alternative method of disposal, and when the burning of such materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts that will endanger health or safety. F. Open Outdoor Fires of Household Waste. Open outdoor fires for the disposal of household waste are allowed by provisions of this Section when permitted in writing by the Director or a delegated authority. Permits issued shall contain all provisions in subsection (D)(3) except for subsections (e) and (f). Open outdoor fires of household waste shall be burned in an approved waste burner and shall either: 1. Burn household waste generated on-site on farms or ranches of 40 acres or more where no household waste collection or disposal service is available; or 2. Burn household waste generated on-site where no household waste collection and disposal service is available and where the nearest other dwelling unit is at least 500 feet away. G. Permits Issued by a Delegated Authority. The Director may delegate authority for the issuance of open burning permits to a county, city, town, air pollution control district, or fire district. A delegated authority may not permit its own open burning activity. Authority for issuance of permits to burn dangerous material under subsection (E) shall be retained by the Director and not delegated. A county, city, town, air pollution control district, or fire district with delegated authority from the Director may assign that authority to one or more private fire protection service providers that perform fire protection services within the county, city, town, air pollution control district, or fire district. A private fire protection provider shall not directly or indirectly condition the issuance of open burning permits on the applicant being a customer. Permits issued under this subsection shall comply with the requirements in subsection (D)(3) and be in a format prescribed by the Director. Each delegated authority shall: 1. Maintain a copy of each permit issued for the previous five years available for inspection by the Director; 2. For each permit currently issued, have a means of contacting the person authorized by the permit to set an open fire in the event that an order for extinguishing of open burning is issued; and 3. Annually submit to the Director by May 15 a record of daily burn activity, excluding household waste burn permits, on a form provided by the Director for the previous calendar year containing the information required in subsections (D)(3)(e) and (f). H. The Director shall hold an annual public meeting for interested parties to review operations of the open outdoor fire program and discuss emission reduction techniques. I. Nothing in this Section is intended to permit any practice which is a violation of any statute, ordinance, rule, or regulation. ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS R18-2-1501. Definitions In addition to the definitions contained in A.R.S. § 49-501 and R18-2-101, in this Article: 1. “ADEQ” means the Department of Environmental Quality. 2. “Annual Emissions Goal” means the annual establishment in cooperation with the F/SLMs, under R18-2-1503(G), of a planned quantifiable value of emissions reduction from prescribed fires and fuels management activities. Volume 9, Issue 38 Page 4076 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking 2. 3. “BMP” means best management practices as described in R18-2-1509. “Burn Plan” means the ADEQ form that includes information on the conditions under which the burn will occur with details of the burn and smoke management prescriptions. 3.4. “Burn prescription” means, with regard to a burn project, the pre-determined area, intensity of heat, and rate of spread fuel and weather conditions required to attain planned resource management objectives. 4.5. “Burn project” means an active or planned prescribed burn, including a prescribed natural fire wildland fire use incident. 5. “Class I Area” means a mandatory area designated pursuant to Section 169A of the Clean Air Act Amendments of 1990. 6. “Duff” means forest floor material consisting of decomposing needles and other natural materials. 7. “Emission reduction techniques (ERT)” means techniques for controlling emissions from prescribed fires to minimize the amount of emission output per unit of area burned. 7.8. “Federal land manager (FLM)” means any department, agency, or agent of the federal government, including the following: a. United States Forest Service, b. United States Fish and Wildlife Service, c. National Park Service, d. Bureau of Land Management, e. Bureau of Reclamation, f. Department of Defense, g. Bureau of Indian Affairs, and h. United States Soil Conservation Service. Natural Resources Conservation Services 8.9. “F/SLM” means a federal land manager or a state land manager. 9.10.“Local fire management officer” means a person designated by a F/SLM as responsible for fire management in a local district or area. 10.11.“Mop-up” means the act of extinguishing or removing burning material from a prescribed fire to reduce smoke impacts. 11.12.“National Wildfire Coordinating Group” means the national inter-agency group of federal and state land managers that shares similar wildfire suppression programs and that has established standardized inter-agency training courses and qualifications for fire management positions. 13. “Non-burning Alternatives to Fire” are techniques that replace fire for at least five years as a means to treat activity fuels created to achieve a particular land management objective (e.g., reduction of fuel-loading, manipulation of fuels, enhancement of wildlife habitat, ecosystem restoration, etc.). These alternatives are not used in conjunction with fire. Techniques used in conjunction with fire are referred to as emission reduction techniques (ERTs). 12.14.“Planned resource management objectives” means public interest goals in support of land management agency objectives including silviculture, wildlife habitat management, grazing enhancement, fire hazard reduction, wilderness management, cultural scene maintenance, weed abatement, watershed rehabilitation, vegetative manipulation, and disease and pest prevention. 13.15.“Prescribed burning” means the controlled application of fire to wildland fuels that are in either a natural or modified state, under certain burn prescription conditions and smoke management prescription conditions that have been specified by the land manager in charge of or assisting the burn, to attain planned resource management objectives. Prescribed burning includes does not include a fire set or permitted by a public officer to provide instruction in fire fighting methods, or construction or residential burning under R18-2-602. A prescribed fire may be ignited either by a trained fire specialist or by natural causes such as lightning. 14.16.“Prescribed Fire Manager” means a person designated by a F/SLM as responsible for prescribed burning for that land manager. 15. “Prescribed natural fire” means a wildland fire that is ignited by natural causes such as lightning rather than by a trained fire specialist, that is subsequently allowed to continue burning using the same controls and for the same planned resource management objectives as prescribed burning. 16.17.“Smoke management prescription” means the predetermined meteorological conditions that affect smoke transport and dispersion under which a burn could occur without adversely affecting public health and welfare. 18. “Smoke Management Techniques” (SMT) means management and dispersion practices used during a prescribed burn or wildland fire use incident which affect the direction, duration, height or density of smoke. 17.19.“Smoke management unit” means any of 11 the geographic areas defined by ADEQ whose area is based on primary watershed boundaries and whose outlines are determined by diurnal windflow patterns that allow smoke to follow predictable drainage patterns. A map of the state divided into 11 the smoke management units is on file with ADEQ. 18.20.“State land manager (SLM)” means any department, agency, or political subdivision of the state government that is responsible for wildland management including the following: a. State Land Department, September 19, 2003 Page 4077 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking b. Department of Transportation, c. Department of Game and Fish, and d. Parks Department. 19.21.“Wildfire” means a an unplanned wildland fire subject to appropriate control measures that does not meet resource management objectives and that may threaten life, property, public health, or the ecosystem. Wildfires include those incidents where suppression may be limited for safety, economic, or resource limitations. 20. “Wildland” means an area in which development is essentially non-existent, except for pipelines, power lines, roads, railroads, or other transportation or conveyance facilities. 22. “Wildland fire use” means a wildland fire that is ignited by natural causes, such as lightning, that is subsequently managed using the same controls and for the same planned resource management objectives as prescribed burning. R18-2-1502. Applicability A. A F/SLM that is conducting or assisting a prescribed burn shall follow the requirements of this Article. B. A private or municipal burner with whom ADEQ has entered into a memorandum of agreement shall follow the requirements of this Article. B.C.The provisions of this Article apply to all areas of the state except Indian Trust lands. All federally-managed lands and all state lands, parks, and forests are under the jurisdiction of ADEQ in matters relating to air pollution from prescribed burning. C.D.Notwithstanding subsection (B), ADEQ and any Indian tribe may enter into a memorandum of agreement to implement this Article. E. ADEQ and any private or municipal prescribed burner may enter into a memorandum of agreement to implement this Article. R18-2-1503. Annual Registration, Program Evaluation and Planning for Prescribed Burns A. Each F/SLM shall register annually with ADEQ, on a form prescribed by ADEQ, all planned burn projects, including areas considered for potential prescribed natural fires planned for wildland fire use, for the following year. C.B.Each planned year extends from August January 1 of the registration year to July December 31 of the same following year. Each F/SLM shall use best efforts to register before August December 31 and no later than January 31 of each year. B.C.A F/SLM shall provide include the following information on the registration form: 1. The F/SLM’s name, address, and business telephone number; 2. The name, address, and business telephone number of an air quality representative who will provide technical support to ADEQ for decisions regarding prescribed burning. The same air quality representative may be selected by more than one F/SLM or Indian tribe; 3. All prescribed burn projects and potential prescribed natural fire wildland fire use areas planned for the next year; and 4. By prescribed burn project, maximum project and annual acres to be burned, maximum daily acres to be burned, fuel types within project area and planned use of emission reduction techniques to support the annual emissions goal; 5. By prescribed burn project, planned use of any smoke management techniques; 6. By area planned for wildland fire use, maximum project and annual acres to be burned, maximum daily acres to be burned, and a map of project area, fuel types and loading within the planned area; 4.7. A list of all burn projects that were completed during the previous year; 8. By area to be treated using non-burning alternatives to fire, project area for treatment, treatment type, fuel types to be treated, activity fuel loading to support the annual emissions goal; and 9. The area treated using non-burning alternatives to fire utilized during the previous year including the number of acres, the specific types of alternatives utilized, and the location of these areas. D. After consultation with the F/SLM, ADEQ may request additional information related to tracking burn projects for registration of prescribed burns and wildland fire use to support regional coordination of smoke management, annual emission goal setting utilizing ERTs, and non-burning alternatives to fire. E. A F/SLM may amend a registration at any time with a written submission to ADEQ. ADEQ shall approve a new prescribed burn even if the F/SLM has failed to amend a registration if the F/SLM has complied with the other provisions of this Article. F. ADEQ shall accept a facsimile or other electronic methods as a means of complying with the deadline for registration. If electronic means are used a facsimile is submitted, the F/SLM shall deliver the original paper registration form to ADEQ for its records. ADEQ shall acknowledge in writing the receipt of each registration. If ADEQ and the F/SLMs jointly develop an electronic filing and reporting system, the original paper form may be waived, and ADEQ shall notify all F/ SLMs of this change. G. No later than 14 days before a F/SLM requests permission to proceed with a registered burn project other than a prescribed natural fire, the F/SLM shall submit a Burn Plan to ADEQ, as described in R18-2-1504. A Burn Plan for a prescribed natural fire shall be submitted as prescribed by R18-2-1508. Volume 9, Issue 38 Page 4078 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking G. ADEQ shall hold an annual meeting after January 31 and prior to April 1 of each year between ADEQ and F/SLMs for program evaluation and to cooperatively establish the annual emission goal. The annual emission goal shall be developed to minimize prescribed fire emissions to the maximum extent feasible using emission reduction techniques and alternatives to burning subject to economic, technical, and safety feasibility criteria, and consistent with land management objectives. H. At least once every five years, ADEQ shall request long-term projections of future prescribed fire and wildland fire use activity from the F/SLMs to support planning for visibility impairment and assessment of other air quality concerns by ADEQ. R18-2-1504. Prescribed Burn Plan Contents A. Each F/SLM planning a prescribed burn, other than a prescribed natural fire, shall complete and submit to ADEQ the “Burn Plan” form supplied by ADEQ no later than 14 days before the date on which the F/SLM requests permission to burn. The information supplied on the Burn Plan Form are considered binding conditions under which the burn shall be conducted. Burn Plans shall be maintained by ADEQ until notification from the F/SLM of the completion of the project. Revisions to the Burn Plan for a burn project shall be submitted in writing no later than 14 days before the date on which the F/SLM requests permission to burn. The F/SLM shall provide the following information on the “Burn Plan” form To facilitate the Daily Burn authorization process under R18-2-1505, the F/SLM shall include on the Burn Plan: 1. An emergency telephone number that is answered 24 hours a day; 2. Burn prescription; 3. Smoke management prescription; 4. The number of acres to be burned, the quantity and type of fuel, type of burn, and the ignition technique to be used; 5. The land management objective or purpose for the burn such as restoration or maintenance of ecological function and indicators of fire resiliency; 5.6. A map depicting the potential impact of the smoke unless waived either verbally or in writing by ADEQ. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the burn site, with smoke-sensitive areas delineated. The map shall use the appropriate scale to show the impacts of the smoke adequately; 6.7. Modeling of smoke impacts unless waived either verbally or in writing by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulates, a carbon monoxide non-attainment area, or other smoke-sensitive area. Air quality modeling for these areas is mandatory unless waived either verbally or in writing by ADEQ. In consultation with the F/SLM, ADEQ shall provide guidelines on modeling; 7.8. The name of the official submitting the Burn Plan on behalf of the F/SLM; and 8.9. After consultation with the F/SLM, any other information to support the Burn Plan needed by ADEQ to assist in the Daily Burn authorization process for smoke management purposes or assessment of contribution to visibility impairment of Class I areas. B. A Burn Plan shall be submitted for a prescribed natural fire as prescribed by R18-2-1508. R18-2-1505. Prescribed Burn Requests and Authorization A. Each F/SLM planning a prescribed burn, other than a prescribed natural fire, shall complete and submit to ADEQ the “Daily Burn Request” form supplied by ADEQ. The F/SLM shall include the following information on the Daily Burn Request form shall include: 1. The contact information of the F/SLM conducting the burn; 2. Each day of the burn; 2.3. The area to be burned per on that day with reference to the Burn Plan, including size, and legal location to the section and latitude/longitude to the minute; 4. Projected smoke impacts; 3.5. Any local conditions or circumstances known to the F/SLM that, if conveyed to ADEQ, could impact the Daily Burn authorization process. B. After consultation with the F/SLM, ADEQ may request additional information related to the burn, meteorological, smoke dispersion or air quality conditions to supplement the Daily Burn Request form and to aid in the Daily Burn authorization process. This information may include same day on-site and area meteorological, smoke dispersion, or air quality measurements. C. The F/SLM shall submit the Daily Burn Request form to ADEQ as expeditiously as practicable, but no later than 2:00 p.m. of the business day preceding the burn. An original form, a facsimile, or an electronic information transfer are acceptable submittals. D. An F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ, as follows: D.1.ADEQ shall approve, approve with conditions, or disapprove a burn on the same business day as the Burn Request submittal. September 19, 2003 Page 4079 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking 2. If ADEQ fails to address a Burn Request by 10:00 p.m. of the business day on which the request was submitted, the Burn Request is approved by default after the burner makes a good faith effort to contact ADEQ to confirm that the Burn Request was received. 3. ADEQ may communicate its decision by verbal, written, or electronic means. ADEQ shall provide a written or electronic reply if requested by the F/SLM. If ADEQ does not communicate its decision, or a confirmation that the Burn Request was received, by 10 p.m., the burn is deemed approved. E. Except as provided in subsection (D), an F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ. F.E. If weather conditions cease to conform to those in the smoke management prescription of either the Burn Plan or an Approval with Conditions, the F/SLM shall cease ignitions and take appropriate action to reduce further smoke impacts, ensure safe and appropriate fire control, and notify the public when necessary., unless after After consultation with ADEQ, the smoke management prescription or burn plan may be is modified. F. The F/SLM is responsible for appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a prescribed fire. G. Burn authorization for prescribed natural fires shall be as prescribed by R18-2-1508. H. The F/SLM in whose jurisdiction a wildfire occurs shall report all wildfires greater than 100 acres on a daily basis to ADEQ. The F/SLM shall include in the report the location, estimated control date, and estimated incident size of each wildfire. The F/SLM shall provide information on projected smoke and air quality impacts and on estimated control size upon request by ADEQ. R18-2-1506. Smoke Dispersion Evaluation ADEQ shall approve, approve with conditions, or disapprove a Daily Burn Request submitted pursuant to R18-2-1505, by using the following factors for each smoke management unit: 1. Analysis of the emissions from burns in progress and residual emissions from previous burns on a day-to-day basis; 2. Analysis of emissions from active prescribed natural fires wildland fire use incidents, active multiple-day burns, and consideration of potential long-term emissions estimates; 3. Analysis of the emissions from wildfires greater than 100 acres and consideration of their potential long-term growth; 4. Local burn conditions; 5. Burn prescription and smoke management prescription from the applicable Burn Plan; 6. Existing and predicted local air quality; 7. Local and synoptic meteorological conditions; 8. Type and location of areas to be burned; 9. Protection of the national visibility goal for Class I Areas pursuant to § 169A(a)(1) of the Act and 40 CFR 51.309; and 10. Assessment of duration and intensity of smoke emissions to minimize cumulative impacts; and 10.11.Minimization of smoke impacts in Class I Areas, roads or highways, airports, areas that are non-attainment for particulate matter, carbon monoxide non-attainment areas, or other smoke-sensitive areas. 12. Protection of the National Ambient Air Quality Standards. R18-2-1507. Prescribed Burn Accomplishment; ADEQ Recordkeeping; Wildfire Reporting A. Each F/SLM conducting a prescribed burn shall complete and submit to ADEQ the “Burn Accomplishment” form supplied by ADEQ. For each burn approval, the F/SLM shall submit a Burn Accomplishment form to ADEQ by 2:00 p.m. of the business day following the approved burning. The F/SLM shall include the following information on the Burn Accomplishment form: 1. Any known conditions or circumstances that could impact the Daily Burn decision process; 2. The subsequent date, location, fuel type, fuel loading and acreage accomplishments; 3. The BMP ERTs and SMTs for emission reduction described in R18-2-1509 and R18-2-1510, respectively, and may include any further ERTs and SMTs that become available, that the F/SLM used to reduce emissions or manage the smoke from the burn. B. For each burn approval, the F/SLM shall submit a Burn Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burning. C.B.The F/SLM shall submit the Burn Accomplishment form as an original form, a facsimile, or an electronic information transfer. D.C.ADEQ shall maintain a record of Burn Requests, Burn Approvals/Conditional Approvals/Denials and Burn Accomplishments for five years. D. The F/SLM in whose jurisdiction a wildfire occurs shall make available to ADEQ no later than the day after the activity all required information for wildfire incidents that burned more than 100 acres per day in timber or slash fuels or 300 acres per day in brush or grass fuels. For each day of a wildfire incident that exceeded the daily activity threshold, the F/SLM shall provide the location, an estimate of predominant fuel type and quantity consumed, and an estimate of the area blackened that day. Volume 9, Issue 38 Page 4080 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking R18-2-1508. A. B. C. D. E. F. Prescribed Natural Fires; Wildland Fire Use: Plan;, Authorization;, Monitoring; Inter-agency Consultation; Status Reporting In order for ADEQ to participate in the wildland fire use decision-making process, the A F/SLM shall notify ADEQ as soon as practicable of any potential wildland fire use incident prescribed natural fire when it is projected to attain or attaining a size of 50 acres of timber fuel or 250 acres of brush or grass fuel. For each wildland fire use incident prescribed natural fire that has been declared as such by the F/SLM, the F/SLM shall complete and submit to ADEQ a Wildland Fire Use Burn prescribed natural fire Plan in a format approved by ADEQ in cooperation with the F/SLM. The F/SLM shall submit the Wildland Fire Use Burn prescribed natural fire Plan to ADEQ as soon as practicable but no later than 72 hours after the wildland fire use incident prescribed natural fire is declared or under consideration for such designation 1st observed. The F/SLM shall include the following information in the Wildland Fire Use Burn prescribed natural fire Plan: 1. An emergency telephone number that is answered 24 hours a day; 2. Anticipated burn prescription and anticipated emissions; 3. Anticipated smoke management prescription; 3.4. The estimated daily anticipated growth in the number of acres, quantity and type of fuel to be potentially burned; 4.5. The anticipated maximum allowable perimeter or size with map; 5.6. The type or types of fuel involved; Information on the condition of the area to be burned, such as whether it is in maintenance or restoration, its ecological function or other indicators of fire resiliency; 6.7. The anticipated duration of the wildland fire use incident prescribed natural fire; 7.8. The anticipated long-range weather trends for the site onsite; 8.9. A map depicting the potential impact of the smoke. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the wildland fire use incident burn site, with smoke-sensitive areas delineated. Mapping is mandatory unless waived either verbally or in writing by ADEQ. The map shall use the appropriate scale to show the impacts of the smoke adequately; The map shall use the standard agency scale for that F/SLM; and 9.10.Modeling or monitoring of smoke impacts, if requested by ADEQ after consultation with the F/SLM. ADEQ shall approve or disapprove a Wildland Fire Use Burn prescribed natural fire Plan within three hours of receipt. ADEQ shall consult directly with the requesting F/SLM before disapproving a Wildland Fire Use Burn prescribed natural fire Plan. If ADEQ fails to address the Wildland Fire Use Burn Plan within the time allotted, the Plan is approved by default under the condition that the F/SLM makes a good faith effort to contact ADEQ to confirm that the Plan was received. If ADEQ fails to respond to the submittal of the Wildland fire use prescribed natural fire Plan, approval of the prescribed natural fire may be assumed by the F/SLM. Approval by ADEQ of a Wildland Fire Use Burn prescribed natural fire Plan shall be binding upon ADEQ for the duration of the wildland fire use incident prescribed natural fire project, unless smoke from the incident prescribed natural fire creates a threat to public health or welfare. If a threat to public health or welfare is created, ADEQ shall consult with the F/SLM regarding the situation and the development of develop a joint action plan for reducing further smoke impacts. The F/SLM shall submit a Daily Status Report for each wildland fire use incident prescribed natural fire to ADEQ for each day of the burn that the fire burns more than 100 acres in timber or slash fuels or 300 acres in brush or grass fuels perimeter increases. The F/SLM shall include a synopsis of smoke behavior, future daily anticipated growth, and location of the activity of the wildland fire use incident prescribed natural fire in the Daily Status Report. The F/SLM shall consult with ADEQ prior to initiating man-made ignition on the wildland fire use incident when greater than 250 acres is anticipated to be burned by the ignition. Emergency man-made ignition on the incident for protection of public or fire-fighter safety does not require consultation with ADEQ regardless of the size of the area to be burned. The F/SLM is responsible for appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a wildland fire use incident. R18-2-1509. Emission Reduction Techniques; BMP A. Each F/SLM conducting a prescribed burn shall implement as many Emission Reduction Techniques BMP for emission reduction as are feasible subject to economic, technical and safety feasibility criteria, and land management objectives. for the specific burn and shall include the BMP in the Burn Accomplishment submitted pursuant to R18-2-1507. B. The following measures are considered Emission Reduction Techniques include BMP: 1. Reducing biomass to be burned by use of techniques such as yarding or consolidation of unmerchandisable material, multi-product timber sales or public firewood access, when economically feasible. When allowing public firewood access, provide information on the adverse impacts of using green or wet wood as fuel; 2. Burning in seasons characterized by meteorological conditions that allow for good smoke dispersion, especially March 15 through September 15; 2. Reducing biomass to be burned by fuel exclusion practices such as preventing the fire from consuming dead snags or dead and downed woody material through lining, application of fire-retardant foam, or water; September 19, 2003 Page 4081 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking 3. 4. 5. 6.4. 7.5. 6. 8.7. 8. 9. 9. 10. 10. 11. 11. 12. 13. 13. 14. 14. 15. 15. 16. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires of high fuel density areas such as logging slash decks with short duration impacts; Igniting burns under good-to-excellent ventilation conditions and suspending operations under poor smoke dispersion conditions; Considering smoke impacts on local community activities and land users; Burning only fuels essential fuels to meet resource management objectives; Minimizing duff consumption and smoldering by burning under conditions of high through fuel moisture of duff and litter considerations; Minimizing fuel consumption and smoldering by burning under conditions of high fuel moisture of large woody fuels; Minimizing dirt soil content when slash piles are constructed by using brush blades on material-moving equipment and by constructing piles under dry soil conditions or by using hand piling methods; Burning fuels in piles; Burning piles when other burns are not feasible, such as when snow or rain is present; Using a backing fire in grass fuels; Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; Burning fuels with an air curtain destructor, as defined in R18-2-101, operated pursuant to manufacturer specifications and meeting applicable state or local opacity requirements; Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; Extinguishing or mopping-up of smoldering fuels; Using chunking Chunking of piles and other consolidations of burning material to enhance flaming, fuel consumption and to minimize smoke production; Implementing maintenance burning in a periodic rotation mimicking natural fire cycles to reduce excessive fuel accumulations and subsequent excessive smoke production through smoldering or wildfire; Burn before litter fall; Using prescribed natural fires and unplanned ignitions; and Burn before green-up of fuels; Managing smoke impacts as follows: a. Limiting smoke impacts to roads, highways, and airports to the amounts, frequencies, and durations consistent with any guidance provided by highway and airport personnel; b. Using appropriate signing if smoke will impact any roadways; c. Notifying control towers if smoke will intrude in any air traffic control zone; d. Determining nighttime impacts and taking appropriate precautions; and e. Contacting appropriate authorities as needed regarding smoke or visibility impacts. Burn before recently cut large fuels cure in areas with activity; and Burn just prior to precipitation to reduce fuel smoldering and consumption. R18-2-1510. Smoke Management Techniques A. Each F/SLM conducting a prescribed burn shall implement as many Smoke Management Techniques as are feasible subject to economic, technical and safety feasibility criteria, and land management objectives. B. Smoke Management Techniques include: 1. Burning from March 15 through September 15, when meteorological conditions allow for good smoke dispersion; 2. Igniting burns under good-to-excellent ventilation conditions; 3. Suspending operations under poor smoke dispersion conditions; 4. Considering smoke impacts on local community activities and land users; 5. Burning piles when other burns are not feasible, such as when snow or rain is present; 6. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires with short duration impacts; 7. Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; 8. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3:00 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; 9. When allowing public firewood access, provide information on the adverse impacts of using green or wet wood as fuel; 10. Implementing maintenance burning in a periodic rotation to shorten prescribed fire duration and to reduce excessive fuel accumulations which could result in excessive smoke production in a wildfire; and 11. Using wildland fire use strategies to shift smoke into more favorable smoke dispersion seasons. Volume 9, Issue 38 Page 4082 September 19, 2003 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking R18-2-1510. R18-2-1511. Monitoring A. ADEQ may require a F/SLM to monitor weather and air quality before or during a prescribed burn or a excluding wildland fire use incident prescribed natural fires, which are governed by R18-2-1508, if necessary to accurately predict assess smoke impacts. Air quality monitoring may be conducted using both federal and non-federal reference method as well as other techniques. B. ADEQ may require a F/SLM to monitor weather before or during a prescribed burn or a wildland fire use incident, if necessary to predict or assess smoke impacts. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or area-representative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ. An F/SLM planning to make a change to any long-term established remote automated weather station shall give ADEQ notice and an opportunity to comment before making the change. B.C.A F/SLM shall employ the following types of monitoring, unless waived by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulate matter, a carbon monoxide, or ozone non-attainment area, or other smoke-sensitive area: 1. Smoke plume measurements, using a format supplied by ADEQ; and 1.2. The release of pilot balloons (PIBALs) at the burn site to verify needed wind speed, direction, or and stability.; and 2. Smoke plume measurements, using a format supplied by ADEQ. In lieu of pilot balloons, a test burn at the burn site may be used for specific prescribed burns on a case-by-case basis as approved by ADEQ, to verify needed wind speed, direction and stability. C.D.A An F/SLM shall make monitoring information required pursuant to subsection (B)(C) available to ADEQ on the business day following the burn ignition. D. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or area-representative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ, if necessary to accurately predict smoke impacts. E. The F/SLM shall keep on file for one year following the burn date any monitoring information required pursuant to this Section. R18-2-1511. R18-2-1512. Burner Qualifications A. All burns burn projects shall be conducted by personnel trained in prescribed fire and smoke management techniques to the minimum level as required by the F/SLM in charge of the burn and established by National Wildfire Coordinating Group training qualifications. B. A Prescribed Fire Manager Boss or other local Fire Management Officer of the F/SLM having jurisdiction over prescribed burns shall have smoke management training obtained through one of the following: 1. Successful completion of a National Wildfire Coordinating Group or F/SLM-equivalent course dedicated to addressing smoke management; or 2. Attendance at an ADEQ-approved smoke management workshop. R18-2-1512. R18-2-1513. Public Notification and Awareness Program; Regional Coordination A. At the Director’s discretion, The Director shall conduct a public education and awareness program may be conducted by ADEQ in cooperation with F/SLMs and other interested parties to inform the general public of the smoke management program described by this Article. If conducted, the The program shall include smoke impacts from prescribed fires and the role of prescribed fire in natural ecosystems. B. ADEQ shall make annual registration, prescribed burn approval, wildfire and wildland fire use activity information readily available to the public and to facilitate regional coordination efforts and public notification. R18-2-1514. Oversight A. An F/SLM planning to make a change to any long-term established remote automated weather station shall give ADEQ notice and an opportunity to comment before making the change. B. On or before August 15 of each year, each F/SLM shall submit to ADEQ a report generally describing each of the following: 1. The emissions reductions for each project from the previous year as a result of using BMP. Emissions reductions may be estimated using methods and emission factors developed jointly by ADEQ and F/SLMs; 2. The smoke management cost estimates for each active project from the previous year including estimates for monitoring, training, applying emission reduction techniques, research, and compliance with the requirements of this Article; and 3. Any research on or development of innovative techniques for emission reductions. R18-2-1513. R18-2-1514. Surveillance and Enforcement A. An F/SLM conducting a prescribed burn shall permit ADEQ to enter and inspect burn sites unannounced to verify the accuracy of the Daily Burn Request, Burn Plan, or Accomplishment data described pursuant to R18-2-1505 as well as matching burn approval with actual conditions, and smoke dispersion, and air quality impacts. On-ground site inspection procedures and aerial surveillance shall be coordinated by ADEQ and the F/SLM for safety purposes. September 19, 2003 Page 4083 Volume 9, Issue 38 Arizona Administrative Register / Secretary of State Notices of Proposed Rulemaking B. ADEQ may use remote automated weather station data if necessary to verify current and previous meteorological conditions at or near the burn site. C. ADEQ may audit burn accomplishment data, smoke dispersion measurements, or weather measurements from previously conducted burns, if necessary to verify conformity with, or deviation from, procedures and authorizations approved by ADEQ. D. Deviation from procedures and authorizations approved by ADEQ constitute a violation of this Article. Violations may require containment or mop-up of any active burns and may also require, in the Director’s discretion, a five-day moratorium on ignitions by the responsible F/SLM. Violations of this Article are also subject to a civil penalty of not more than $10,000 per day per violation pursuant to A.R.S. § 49-463. R18-2-1515. Forms; Electronic Copies; Information Transfers A. ADEQ shall make available on paper and in electronically-readable format any form required to be developed by ADEQ and completed by a F/SLM. B. After consultation with the F/SLM, ADEQ may require each F/SLM to provide data in a manner that allows for and facilitates electronic transfers of information. Volume 9, Issue 38 Page 4084 September 19, 2003 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 W. Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director AGENDA Air Quality Division Regional Haze State Implementation Plan Development PUBLIC HEARING/ORAL PROCEEDING October 20, 2003, 1:30 p.m. Yuma Public Works Training Room 155 West 14th Street, Yuma, Arizona Pursuant to [cite 40 CFR § 51.102 for SIP hearings and ARS § 49-425 for air quality rule hearings], notice is hereby given that the above referenced meeting is open to the public. Welcome and Introductions Purposes of the Oral Proceeding/Procedures for Making Public Comment Brief Overview of the Proposed Rule Question and Answer Period Oral Comment Period Adjournment of Oral Proceeding Comment period ends 5:00 p.m., Friday, October 24, 2003. Please direct comments and questions to Kevin Force, ADEQ Air Quality Division, at (602) 7714480 or 1-800-234-5677, Ext. 771-4480. Order of agenda items is subject to change. For additional information regarding the meeting, please call [NAME], ADEQ Air Quality Division, at (602) 771-[ ] or 1-800-234-5677, Ext. [ ]. Persons with a disability may request a reasonable accommodation such as a sign language interpreter, by contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 4794. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829. Northern Regional Office Southern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 400 West Congress Street • Suite 433 • Tucson, AZ 86004 85701 (928) 779-0313 (520) 628-6733 Printed on recycled paper Arizona Department of Environmental Quality Air Quality Division Please Sign In SUBJECT NAME 1. 2. 3. 4. 5. Yuma Public Hearing – Fire Rules ORGANIZATION DATE PHONE FAX E-MAIL PLEASE NOTE: THE SIGN-IN SHEET FOR THE YUMA HEARING HAS BEEN LOST. HOWEVER, A TRANSCRIPT OF THE YUMA HEARING AND ANY COMMENTS RECEIVED IS INCLUDED IN THIS APPENDIX. PUBLIC HEARING 10/20/2003 1 1 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 2 3 4 5 6 IN THE MATTER OF THE PROPOSED REVISIONS TO ARIZONA ADMINISTRATIVE CODE R18-2-602, THE UNLAWFUL OPEN BURNING RULE, AND ARTICLE 15, THE RULES COVERING FOREST AND RANGE MANAGEMENT BURNS. ) ) PUBLIC HEARING ) ) ) ) ) ) 7 8 9 10 11 12 At: Yuma, Arizona 13 Date: October 20, 2003 14 Filed: 15 16 REPORTER'S TRANSCRIPT OF PROCEEDINGS 17 18 19 20 21 ARIZONA REPORTING SERVICES, INC. Court Reporting Suite Three 2627 North Third Street Phoenix, Arizona 85004-1103 22 By: 23 MICHELE E. BALMER, RPR Certified Court Reporter Certificate No. 50489 24 25 ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 2 1 BE IT REMEMBERED that the above-entitled and 2 numbered matter came on regularly to be heard before 3 the Arizona Department of Environmental Quality, at the 4 Yuma Public Works Training Room, 155 West 14th Street, 5 Yuma, Arizona, commencing at 1:30 p.m. on the 20th day 6 of October, 2003. 7 BEFORE: SEAN McCABE, HEARING OFFICER 8 9 10 11 12 13 14 APPEARANCES: MARK LEWANDOWSKI, SIP and Rulemaking Development Unit Supervisor, Planning Section, on behalf of ADEQ; EMILY BONANNI, Compliance Officer, Air Quality Compliance Section, on behalf of ADEQ; GREG FERGUSON, Southwest Arizona Community Liaison, on behalf of ADEQ. 15 16 17 MICHELE E. BALMER Certified Court Reporter Certificate No. 50489 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 3 1 HEARING OFFICER McCABE: Good afternoon. 2 Welcome to this hearing of the Arizona Department of 3 Environmental Quality. 4 The subject of the hearing is proposed 5 revisions to Arizona Administrative Code Rule 6 R18-2-602, the unlawful open burning rule, and Article 7 15, the rules covering forest and range management 8 burns. 9 The hearing is now open. The date is Monday, 10 October 20, 2003, and the time is 1:30. 11 is the Yuma Public Works Training Room at 155 West 14th 12 Street, Yuma, Arizona, 85364. 13 My name is Sean McCabe. The location I'm the Rule 14 Development Manager for the Drinking Water Section of 15 the Water Quality Division of ADEQ, and I've been 16 appointed by the ADEQ Director to conduct this hearing. 17 The purposes of this hearing are to provide the 18 public an opportunity to, one, hear about the substance 19 of the proposed revisions to the Arizona Administrative 20 Code Rule R18-2-602 and Article 15; and two, to ask 21 questions concerning the proposed rule revisions; and 22 finally, three, to present oral arguments, data, and 23 views concerning the proposed rule revisions in the 24 form of comments on the record. 25 Other ADEQ Air Quality representatives in ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 4 1 attendance today are Mark Lewandowski, State 2 Implementation Plan and Rulemaking Development Unit 3 Supervisor in the Planning Section, Greg Ferguson, and 4 Emily Bonanni? 5 MS. BONANNI: Yes. Hello. 6 HEARING OFFICER McCABE: If you plan to make a 7 public comment on the record, the procedure is straight 8 forward. 9 sign-in table. 10 Where did we have -- MR. LEWANDOWSKI: 11 table. 12 know. 13 Please complete a speaker slip found at the We don't have a sign-in But it's such a small hearing, just let us HEARING OFFICER McCABE: We'll just wing it. 14 I'll just -- we'll just call people in the order that 15 they raise their hands, I guess. 16 You may also submit written comments to me 17 today in person if you have them, or you may submit 18 comments by mail, e-mail or fax. 19 comments by the end of the comment period, 5:00 p.m. on 20 Friday, October 24, 2003. 21 received no later than October 24, 2003. 22 Please submit any Any written comment must be Submit your written comments to Kevin Force. 23 And I have business cards here for Kevin on either side 24 if you want to pick them up. 25 Section, Arizona Department of Environmental Quality, Air Quality Planning ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 5 1 1110 West Washington Street, Third Floor, Phoenix, 2 Arizona, 85007. 3 Kevin's e-mail address is force.kevin@ev.state.az.us. 4 The fax number is (602) 771-2366. And Notice of this hearing was published originally 5 in the Arizona Republic and The Sun on September 19th, 6 2003. 7 the formal comment period be considered by ADEQ in 8 their preparation of a final rule, in which the 9 Department responds in writing to written and oral 10 State statutes require that comments made during comments made during the formal comment period. 11 The agenda for this hearing is simple. 12 First, I will ask Mark Lewandowski to provide an 13 overview of the proposed rulemaking. 14 conduct a question and answer period. 15 the question and answer period is to provide 16 information that might help you in making comments on 17 the rulemaking. 18 Second, I will The purpose of And third, I will conduct the oral comment 19 period. 20 make a comment on the record and you can make your 21 comments. 22 At that time I will call speakers who want to Please be aware that any comments you make at 23 today's hearing that you want the Department to 24 formally consider must be given either in writing or on 25 the record during the oral comment period of the ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 6 1 2 proceeding. At this time Mark Lewandowski will give a brief 3 overview of the background concerning Arizona's 4 proposed revisions to R18-2-602 and Article 15. 5 MR. LEWANDOWSKI: Thank you, Sean. We also 6 forgot to bring -- I forgot to bring sign-in sheets, so 7 I would like to just pass around this sign-in sheet. 8 If you would just put your name and affiliation, 9 chances are we'll be able to track you down in case we 10 need to contact you again or add you to our mailing 11 list for this subject. 12 Sometimes hearings on rules are called oral 13 proceedings. And oral proceedings is the technical 14 name it's given in the statute, but this is basically a 15 hearing on a proposed rule. 16 published in The Register -- which is the official 17 place that it's published -- September 19, 2003. 18 can also find it on our website if you want to take a 19 closer look at it later on. And the proposed rule was You 20 The only thing we kind of have to follow very 21 carefully is the close of comment, which, if you look 22 at your agenda, it's shown on there October 24, 2003. 23 And almost all of the data on where to send comments is 24 either on the card. 25 the card or on the agenda. For example, the fax machine is on ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 7 1 These proposed rules -- actually, it's called 2 one proposed rule, but it's a combination of two 3 different areas. 4 burning or forest and range management burning, which 5 probably is not as apropos down here in Yuma as the 6 other part which is unlawful open burning. 7 One of them is prescribed forestry But we put them in the same rulemaking because 8 they come from the same -- we have the same purpose for 9 them, which is Federal regional haze rules, which has 10 to do with visibility. 11 little money because they're related. 12 And in addition, we can save a We're actually having four hearings this week. 13 Today's the first hearing in Yuma. 14 Grande, which we advertised in Tucson and which covers 15 some of the forestry burning down there in the southern 16 half of the state. 17 Show Low. 18 people, but on Thursday DEQ will be in Flagstaff for 19 the last hearing. 20 Friday. 21 Tomorrow in Casa And on Wednesday we're going to And on Thursday -- not all of the same And then the close of comment is on Now, these proposed rules would amend -- when 22 they go final -- Arizona's existing open burning and 23 prescribed burning rules. 24 It's 602. 25 which is Article 15 of about 15 sections. Open burning is one section. And prescribed burning is a whole article, ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 8 1 We want to make them conform -- the reason we 2 started the rulemaking is because we want to make those 3 two rules conform to EPA's requirements for states', 4 that's plural, states' Regional Haze State 5 Implementation Plans or SIPs. 6 forward by December 31st of this year and submit to EPA 7 a Regional Haze State Implementation Plan. 8 9 All states have to come Because we opened these rules for that, in addition these proposed amendments make other technical 10 changes, including improvement of the rules' clarity, 11 conciseness, and understandability, which is a separate 12 requirement under state statute. 13 As I mentioned, these revisions will be 14 included in our state's Regional Haze SIP, which we're 15 required to submit to EPA by December 31st, 2003. 16 I want to just give you a little background 17 about all of the work that we've done so far. In early 18 2002, we formed a Fire Emissions Work Group to discuss 19 visibility issues related to fire emissions and make 20 recommendations to us, DEQ, regarding necessary changes 21 to any rules. 22 effort of ADEQ and that Fire Emissions Work Group based 23 on input received at those public meetings. 24 a meeting right here in this room probably in April, I 25 think it was, that was one of those public meetings. The current proposed rule is a joint ARIZONA REPORTING SERVICE, INC. Realtime Specialists And we had (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 9 1 The specific requirements for state Regional 2 Haze SIPs can be found in Federal regulations. 3 40 CFR, 51.308 and 51.309. 4 It's Basically, they include greater tracking and 5 monitoring of open burning and burn plans. Also, 6 regular evaluation of data, increased collection of 7 data, and the establishment of annual emission goals. 8 Now, the annual emissions goal is in the prescribed 9 forestry burning portion of this proposed rule, and 10 establishment of annual emission goals for fire in 11 cooperation with states, tribes, and Federal land 12 management agencies and private entities. 13 When I described this rule to, for example, the 14 County Supervisors Association in Phoenix, I called 15 what we did to 602 kind of an overhaul, comparing it to 16 what you might do to an engine. 17 we did to Article 15, forestry burning, as a tune-up. 18 And I described what In the 602 rule, we added a separate section 19 for definitions, including definitions for various 20 categories of open burning like agricultural, 21 construction and residential. 22 In addition, based on the comments we had 23 received this spring, we added new definitions for 24 "delegated authority," the phrase "independent 25 authority to permit fires," and "prohibited materials," ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 10 1 which came from our guidance document. 2 The proposed rule on open burning also 3 clarifies which open burning activities will require 4 open burning permits and those that are exempt from a 5 permit. 6 meetings. 7 This was another popular topic during our It also contains a more complete list of 8 information of what is required to be in the permit. 9 This sort of comes from the EPA regulations. It also 10 helps for more efficient permit administration and to 11 comply with the various aspects of the regional -- with 12 other various aspects of the regional haze rule. 13 DEQ has added language in the proposed rule 14 clarifying that the state rule will not operate in 15 counties with independent authority to permit fires, 16 and we've listed those three counties in the rule: 17 Maricopa, Pima and Pinal. 18 similar to 602 in existence, and the state statute 19 says, therefore, they have independent authority. 20 those three counties will not be covered by the 602 21 rule. 22 They already have rules So Other than dangerous materials, those counties 23 do permit open burning. If they get a request to burn 24 dangerous materials, those three counties will forward 25 that request to ADEQ and we'll handle it in our permit ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 11 1 section as if it was an individual permit. 2 We also considered based on comments and a lot 3 of information from the Fire Emissions Work Group to 4 exempt certain fires that use air curtain destructors, 5 also known as air curtain incinerators, from the open 6 burn permit requirement in order to remove what was 7 called an administrative barrier to this type of 8 burning. 9 administrative barriers to any kind of burning that 10 11 And the Federal rule requires us to remove might reduce smoke. However, after reviewing two studies -- and 12 they're listed in the proposed rule -- DEQ management 13 decided that these devices, air curtain destructors, do 14 require oversight and that it is appropriate that they 15 be subject to permits under this rule. 16 Obviously, it's still subject to comment, and 17 we will invite your comments on the pros and cons of 18 that proposed decision. 19 view the requirement that air curtain destructors 20 obtain a permit as a very big administrative barrier. 21 At the present time, we do not Now, the proposed revisions to Article 15 of 22 the code, which is forest and range management burns, 23 will better conform to EPA's regional haze requirements 24 and facilitate enhanced compliance. 25 changes directly reflect the mandates of EPA's original ARIZONA REPORTING SERVICE, INC. Realtime Specialists Most of those (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 12 1 haze rule, particularly relating to collection and 2 recording of burn data, evaluation of burn programs, 3 and, as I mentioned previously, setting annual emission 4 goals. 5 The former structure of that rule remains 6 intact. 7 submittal of a burn plan at least 14 days before the 8 burn, a daily burn request, which is usually faxed to 9 us, and a burn accomplishment form. 10 There was annual registration of burn plans, That concludes the comments that I had on the 11 oversight or on the summary of the rule. 12 to add a couple of things that weren't included in 13 there. 14 I just wanted Our timeline for this rule is that, as I 15 mentioned, we'll have four hearings this week, and 16 October 24th will be close of comment. 17 We plan to submit the final rulemaking to GERC 18 after we respond to comments, and write that up around 19 November 24th, just before Thanksgiving. 20 based on that schedule that GERC will approve or 21 consider this rule on January 6th. 22 is a Tuesday, and that would be their monthly meeting. 23 And so we will have that rule on that agenda if all 24 goes well. 25 We would hope I think January 6th However, as I mentioned previously, we have to ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 13 1 submit the SIP before the first of the year. 2 will submit the SIP with the rule, the not yet approved 3 rule that we submitted to GERC, and EPA will use that 4 as the opening -- for opening consideration. 5 So we If we stay on schedule, the rule will be 6 effective approximately 60 days after we file it, which 7 is approximately the beginning of March. 8 this March 9th, 2004. 9 I have on If anybody is interested in who is on the Fire 10 Emissions Work Group, I have a list of those people 11 here. 12 in this rule. And so they were partly responsible for what is 13 And I have a list of their meeting times here. 14 They met between August 8, 2002, and May 9, 2003 about 15 15 times it looks like. 16 That concludes my summary of the proposed rule. 17 Are there any questions? 18 to you now. 19 20 Oh, actually, I turn it back HEARING OFFICER McCABE: questions? 21 (No response.) 22 HEARING OFFICER McCABE: 23 Are there any All right. Hearing none -- go ahead. 24 MR. DUFFY: I got a question in regards to -- 25 MR. LEWANDOWSKI: Sir, would you mind stating ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 14 1 2 3 4 your name for the record. MR. DUFFY: Yeah. Charles Duffy. Fire Chief, Marine Corps Air Station, Yuma. The last meeting I attended when you were here 5 in Yuma last, there was discussion on who is authorized 6 to issue the burn permit and whether there is local 7 jurisdiction. 8 going to be able to issue these permits. 9 if I've got a clear understanding reading through this 10 11 In our case, the marine base itself was I'm not sure how that's going to work. MR. LEWANDOWSKI: Under the 602 rule, there's a 12 section on delegation, which I didn't summarize. 13 in addition there is a -- well, there's a section on 14 delegation. 15 And And one of the things we put in that is that if 16 your delegated authority -- for example, the 17 Rural/Metro, I think, here is delegated authority from 18 DEQ to issue open burn permits. 19 restriction that a delegated authority could not issue 20 itself permits. 21 part of your question. 22 But we put in there a And I think that might be an answer to MR. DUFFY: I'm not sure -- I mean, in our case 23 we're looking at two issues. One, we control all 24 burning on the base as far as any welding on up, you 25 know, depending on -- no matter what you're talking ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 15 1 2 about, if you're putting heat to it we control it. But we have two issues that we're really 3 concerned with. 4 both for the structural side and the aircraft 5 firefighters. 6 purchased a number of acres of farmland citrus that now 7 fall within our boundary. 8 9 One, of course, is training fires, Also, we have in the last year or so And the issuing of burn permits is controlled, you know, I mean, usually by us. Where by this, the 10 only thing I'm reading is we have to go to the County 11 or Rural/Metro to do that? 12 MR. LEWANDOWSKI: I think that's the way the 13 proposed rule currently reads. 14 get burn permits from anybody? 15 16 MR. DUFFY: No. Now, do you currently Right now we haven't done anything with that property that -- 17 MR. LEWANDOWSKI: 18 MR. DUFFY: 19 MR. LEWANDOWSKI: Yeah. You mean the citrus? That's been purchased. As I understand it, the 20 proposed rule would require the Marine Corps to get a 21 burn permit for those activities that need burn permits 22 from either one of the delegated authorities or DEQ. 23 MR. DUFFY: Are you delegated? 24 MR. MEADOWS: 25 That's what my question was going to be. Paul Meadows, City of Yuma Fire. ARIZONA REPORTING SERVICE, INC. Realtime Specialists We've (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 16 1 been issuing our own burn permits. 2 MR. FOSTER: 3 MR. MEADOWS: 4 You are delegated. So we are -- we will remain delegated? 5 MR. FOSTER: Yes. 6 MR. LEWANDOWSKI: 7 MR. FERGUSON: However -- go ahead, Greg. It's my understanding that Yuma 8 County is the delegated authority for you, and then 9 Yuma County -- 10 MR. FOSTER: 11 MR. FERGUSON: 12 Goes to us. Goes -- yeah. delegated by -- 13 MR. FOSTER: 14 COURT REPORTER: 15 your name, please, sir? 16 17 18 He's not MR. FOSTER: We're not delegated by -- okay. I'm sorry. Curt Foster. Could you give me Rural/Metro Fire Department. MR. FERGUSON: It's my understanding that Yuma 19 County would have approval of Yuma, Rural/Metro, and 20 San Luis? Or is that Somerton? 21 MS. BONANNI: 22 MR. FERGUSON: Somerton. One of them. 23 it from the County, I believe. 24 the actual -- 25 MR. FOSTER: Yeah. But they all get I think the County is Even your rule change ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 17 1 states in here that -- it says a private fire 2 protection service provider that has been assigned 3 authority to issue open burn permits by one of the 4 authorities in Subsection A, which is a county, city, 5 town or control district. 6 MR. LEWANDOWSKI: Right. So I can just clarify 7 a little bit, the statute kind of sets out two 8 different ways that authority can come down to people 9 to issue these permits. And number one is the 10 delegation to another governmental agency. 11 the other way is a transfer. 12 other than delegate. 13 moment, but the transfer of authority to a private fire 14 protection service provider. 15 16 MR. FOSTER: They use a different verb I can't think of it at the I think ours is listed as a memorandum of understanding. 17 And then That sounds right. HEARING OFFICER McCABE: A memorandum of 18 understanding between the fire department and the 19 County? 20 MR. FOSTER: What's that? 21 HEARING OFFICER McCABE: It's a memorandum of 22 understanding between the fire department and the 23 County? 24 25 MR. FOSTER: Yeah. Yuma County Health Department. ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 18 1 2 HEARING OFFICER McCABE: And so the ADEQ is not a party to that? 3 MR. FOSTER: Well, they oversee what the County 4 does, and the recording comes from us to the County to 5 ADEQ. 6 data over a six-month period and send it directly to 7 ADEQ. And a number of times we will simply compile our I think it's Probat? 8 9 MR. LEWANDOWSKI: Yeah. Probat is no longer with us but -- 10 11 Is that -- MS. BONANNI: permit section. 12 Yes. But he was the director of the I've seen it. MR. LEWANDOWSKI: The verb I was looking for in 13 the rule, it's Subsection G is the subsection that 14 discusses delegation, and we repeated the verb from the 15 statute. 16 But once you're delegated authority, that is 17 the County, city, town, or air pollution control 18 district or a fire district, which is in a sense a 19 governmental unit, once you're delegated that 20 authority, you may assign that authority to one or more 21 private fire protection services. 22 So when you go outside of the government 23 boundaries, you're no longer delegating authority. 24 You're assigning it. 25 responsibility in a sense. You are reserving some ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 19 1 MR. MEADOWS: 2 So the City is delegated as a government 3 Paul Meadows, Yuma Fire. agency? 4 MR. LEWANDOWSKI: I can't speak to that 5 directly because I don't know that there is, in fact, 6 in existence a delegation agreement that goes to that. 7 MR. FERGUSON: 8 MR. LEWANDOWSKI: 9 I'll go get it. But Greg is walking with a purposeful manner. 10 11 I got a copy. MR. FERGUSON: Yeah. I think I got a copy of it. 12 MR. LEWANDOWSKI: 13 MS. BONANNI: Oh, okay. I believe there is an MOU between 14 ADEQ and the City of Yuma Fire Department itself 15 directly. 16 MR. LEWANDOWSKI: 17 MS. BONANNI: Okay. You're right. Everything that 18 falls under your area of responsibility you have 19 jurisdiction over to approve or disapprove. 20 21 MR. MEADOWS: So our status is not going to change, then, based on these changes. 22 MS. BONANNI: No. 23 MR. LEWANDOWSKI: Well, other than this rule 24 prohibits you from issuing an open burn permit to 25 yourself. ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 20 1 MR. MEADOWS: 2 MR. FOSTER: 3 MS. BONANNI: Okay. You can't burn yourself, Paul. But it would seem to be the same 4 for the Marine Corps Air Station. 5 on your own land, that you would require -- you're 6 going to have to have someone else to get you the 7 permit, whether it's the City of Yuma, the County, or 8 DEQ itself. 9 MR. DUFFY: If you want to burn Well, normally it's going to be -- 10 the land backs up to the farmers, so the farmers are 11 going to be requesting the burn permit. 12 for in the case of training fires and things of that 13 nature. Now, except Now, we are talking about ourselves. 14 MS. BONANNI: 15 approve it yourself. 16 goes back to DEQ itself. 17 required at one time to get a permit for training 18 exercises. 19 the rule is changing that. 20 permit. 21 22 23 24 25 Yes, you are. But you can't Fire training, I believe, still You didn't -- you weren't You just had to notify DEQ. MR. DUFFY: Right. I believe now That you must apply for a That is what I was curious about. MS. BONANNI: I'm really, really sure it does change this time. HEARING OFFICER McCABE: David. ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 21 1 2 MR. RODRIGUEZ: David Rodriguez, Marine Corps Station, Environmental Department. 3 I think what is really concerning us, under the 4 formal rule fire fighting was exempted from the rule. 5 Therefore, we conducted our own fires and we maintain 6 our own records of what we burn. 7 What we're concerned about now especially is 8 for our crash fire rescue personnel which can't meet 9 the 14-day notice in there and things of that nature. 10 Because we train -- firefighters throughout the United 11 States come to Yuma to train. 12 weekly basis, monthly basis. 13 in any one given day. 14 And that can be on a We could have 10, 20, 30, This is going to really put a hamper on our 15 training missions because our firefighters got to meet 16 other qualifications through FAA, NAVAIR instructions, 17 and there are three or four different Federal 18 instructions that they have to abide by and keep 19 current. 20 Each firefighter, I believe -- and don't quote 21 me on this -- but something like three fires a month 22 they have to be able to go out. 23 they have to learn how to fight fires at night, because 24 we don't schedule our aircraft when to crash. 25 these guys aren't trained at night how to fight a fire In addition to that, ARIZONA REPORTING SERVICE, INC. Realtime Specialists So if (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 22 1 at night, what good is it going to do the first time we 2 have a night crash? 3 4 MR. LEWANDOWSKI: Excuse me. You mentioned a 14-day requirement? 5 MR. RODRIGUEZ: 6 MS. BONANNI: Yes. I read something in here. I understand the second thing he 7 just said about fire training at night. Right now, I'm 8 not sure if that would be as an individual basis, that 9 would be an individual permit that would -- for that 10 particular purpose you could possibly get a permit. 11 Right now -- 12 13 14 COURT REPORTER: I'm sorry. I couldn't hear your last sentence. MS. BONANNI: Right now, the rules do prohibit 15 training exercises after sundown. 16 whether it's mentioned in the rule or not, they will 17 have to apply for an individual permit on a 18 case-by-case basis to get approval for burning at night 19 at sundown. 20 MR. LEWANDOWSKI: And it's possible, That's one possibility. But 21 we do need the details surrounding your comment. 22 Again, it's not just DEQ that put this together, but 23 it's this Fire Emissions Work Group. 24 MR. RODRIGUEZ: 25 MR. LEWANDOWSKI: Right. And, you know, they were ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 23 1 thinking a lot about smoke and monitoring smoke for 2 regional haze purposes. 3 Before we leave, there was -- the first part of 4 your comment, which was fire. 5 comment from you was that you would use -- somehow you 6 would use propane? 7 MR. DUFFY: 8 MR. RODRIGUEZ: 9 As I recall an early We're looking at going propane. We are going propane. We're just purchasing mobile propane fire fighting equipment 10 is going to come, and it's going to be stationed here 11 but used back and forth and bring propane. 12 MR. LEWANDOWSKI: Would you include some 13 details of that in your comment if you are going to 14 send written comments? 15 MR. RODRIGUEZ: 16 MR. LEWANDOWSKI: Yes. Including how these propane 17 might reduce the use of smoke? 18 MR. RODRIGUEZ: 19 MR. LEWANDOWSKI: 20 MR. RODRIGUEZ: 21 HEARING OFFICER McCABE: 22 MR. FOSTER: Yes. Or the production of smoke. Yes. Mr. Foster. I think you have it covered in -- 23 it's in your notice of proposed rulemaking number 4 24 under C. 25 by the Federal government, or any of its departments, It says: Prescribed burn set by or assisted ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 24 1 agencies or agents, the state or any of its agents, 2 departments or political subdivisions, do not require a 3 burn permit. It's in your rules. 4 MR. FERGUSON: 5 MR. FOSTER: 6 7 8 9 10 Where at? On page 4075, Section C. Open, outdoor fire exempt from a permit under C, number 4. MR. LEWANDOWSKI: But the last phrase says: Pursuant to Article 15. MR. FOSTER: Right. MR. LEWANDOWSKI: So we're talking about 11 Federal land managers doing prescribed burning in a 12 National Forest. 13 14 MR. FOSTER: Right. Federal government, and the Base is Federal. 15 MR. LEWANDOWSKI: 16 MR. FOSTER: 17 18 But this is talking about Right. It's not part of the range or the forest management program. MR. LEWANDOWSKI: The fires that are exempt 19 from an unlawful open burning permit under 602 are the 20 ones that are set under Article 15 under the second 21 part of this rule. 22 regulation. 23 MR. FOSTER: So in other words, there's not dual If I were to read this and ask 24 myself, I would say I would not need a permit. 25 a federal agent on federal property, this says that I ARIZONA REPORTING SERVICE, INC. Realtime Specialists If I'm (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 25 1 don't have to have one. 2 3 4 5 6 MR. LEWANDOWSKI: That's not the way it was drafted. MR. FOSTER: Well, I'm just -- all I'm doing is reading it word for word. MR. LEWANDOWSKI: I'm only making that comment 7 so that the people here know that the intent was not to 8 exempt the Federal government or any of its departments 9 from open burning permits. But the intent was to 10 exempt it from open burning permits when those 11 activities would be covered under the second part of 12 this rule where they get prescribed burn plans and they 13 register 14 days. 14 Now, the 14 days you mentioned, that also 15 applies, I know, in the second part of this rule for 16 prescribed forestry burning. 17 don't recall where there is a 14-day requirement in 18 602, which is unlawful open burning. 19 20 21 MS. BONANNI: But as far as I know, I I have to agree with you. I'm not aware of that at all. MR. RODRIGUEZ: And that's what we were 22 concerned about. I just read the 14 days in the -- 23 and, again, going back to what you were saying, it 24 refers back to Article 15 when you're talking about the 25 actual AG burning. We're talking about -- our main ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 26 1 concern is our firefighters to save lives. 2 You know, the fire department uses their 3 building for the firefighters that do entries or crash 4 fire recuses using the mock airplanes to demonstrate an 5 aircraft fire. 6 oranges here in Article 15. 7 So I think we're talking apples and MR. LEWANDOWSKI: Well, we saved money by 8 putting the rules together, but maybe we didn't in the 9 long run because we've got some confusion here. 10 As I mentioned in the beginning, they're fairly 11 separate in terms of what and who is being -- what is 12 being burned and who is doing the burning. 13 National Forest Service, Parks Department, the people 14 who manage the forests, they'll burn to prevent or to 15 mitigate future forest fires. 16 Article 15. 17 The And that's covered under That's a completely separate program. Rule 602, which is the rule that I think 18 applies mostly to the Yuma area, covers agriculture 19 burning. 20 statutory definition of unlawful open burning. 21 think I just would like to read that: 22 It covers burning that is defined by the And I Combustion of material of any type outdoors in 23 the open where the products of combustion don't go 24 through a flue. 25 agriculture, residential, prescribed and construction Open outdoor fires can include ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 27 1 2 burning. And then it goes on: Further purposes, 3 prevention of a fire hazard, instruction in the method 4 of fighting fires, watershed rehabilitation and disease 5 and pest prevention. 6 Now, because of the way the rules are legally 7 interpreted, this definition in Article 6 applies in 8 Article 6 and doesn't apply in Article 15. 9 we should insert something that open outdoor fires does 10 11 But perhaps not include forestry burning under Article 15. To clarify -- to get back to your comment, as 12 far as Emily and I know, there is no 14-day requirement 13 for open burning that you would conduct on the Marine 14 Corps Air Station. 15 As I recall -- and Emily is involved more with 16 the issuance of these permits, you can get an annual 17 permit for burning of this type, and they're free. 18 From DEQ they're free. 19 And so if that would still present you a 20 problem, then we would like to hear about it. 21 course, the nighttime burning is a separate issue. 22 Of Just so people know, in the rule we replaced 23 the old time of day burn requirements. In other words, 24 I think it used to say 9:00 a.m. -- or it currently 25 says 9:00 a.m. to 3:00 p.m. We now say start ignition ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 28 1 no earlier than one hour after sunrise, or that it must 2 be extinguished two hours before sunset. 3 Now, in terms of special purpose burning like 4 you would do conducting it at night, I would have to go 5 back to the Fire Emissions Work Group and say, what 6 about that? 7 propane, the fire training, and with the nighttime fire 8 training, we would like to see some more details. 9 Maybe we can make some fine-tuning adjustments to this 10 11 And so that's why -- again, both with the rule. MR. DUFFY: I'm not sure I'm clear on the 12 permitting process and just specifically talking about 13 training issues here. 14 If the City of Yuma was going to have a 15 training fire, do they have to turn to Rural/Metro to 16 get a burn permit for that? 17 MS. BONANNI: Because they have an agreement 18 with DEQ, they turn to DEQ and ask to do a fire 19 training exercise. 20 are they -- 21 MR. DUFFY: Because DEQ is going to ask them If I wanted to run a training fire 22 on the base myself, I would have to turn to one of 23 these two? 24 25 MS. BONANNI: See, I thought all training exercises go back to DEQ. It's only if you want to ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 29 1 burn the agricultural land you include those. 2 MR. DUFFY: 3 MS. BONANNI: That's another issue. It is. But to do fire training, 4 I thought I was understanding the concept was all fire 5 training from the fire departments will have to go to 6 DEQ for approval now. 7 new rule, I understand that we're making the change 8 that everyone -- everyone will have to do it. 9 10 MR. MEADOWS: You don't today. But with the Paul Meadows, Yuma Fire. So can we get, quote, an annual permit for 11 training fires or do we have to schedule -- call you 12 for each time we're going to burn? 13 MS. BONANNI: I'm going to say -- they haven't 14 actually explained it, but I'm going to say their idea 15 is that they're going to call every time you want to do 16 a training exercise. 17 MR. MEADOWS: So is there any time limit? I 18 mean, once in a while they find themselves, oh, we got 19 two hours this afternoon. 20 21 22 23 MS. BONANNI: 24-hour voicemail. MR. MEADOWS: Let's go burn. Well, the thing is, DEQ has got So I'm not sure. They might be calling at noon and burning at 1:30. 24 MS. BONANNI: For training. 25 MR. MEADOWS: Is that going to be a problem? ARIZONA REPORTING SERVICE, INC. Realtime Specialists Yeah. (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 30 1 MS. BONANNI: We have not discussed that. So 2 that answer I can't give you today, but it will 3 certainly be worth looking up, is there going to be a 4 time frame. 5 MR. LEWANDOWSKI: I also have the feeling that 6 there is a limitation about -- in other words, if A 7 delegates to B, and B delegate to C, then B can't get 8 -- or it would seem unusual for B to get a permit to 9 burn from C, whom it delegated authority to in the 10 11 first place. Just like the reason we limited people giving 12 permits to themselves is not so much because we have a 13 big history of things going wrong, but because it 14 doesn't look right. 15 For example, if we elected a president who was 16 a doctor, he or she could probably give themselves a 17 really good physical. 18 require that the president get an independent physical 19 even though they could do it themselves. 20 way with the open burn permits. 21 government for government not to permit itself. 22 But still, government would And the same It just -- it's better And so if the County delegates to Rural/Metro 23 and the County wanted to burn, I'm not sure that it 24 would be the best thing for Rural/Metro to give a 25 permit to the County. ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 31 1 2 Although does that happen? burns -- is there anybody from the County here? 3 MR. FOSTER: 4 MR. FERGUSON: 5 6 7 8 9 When the County I have no idea. I don't know what the County would burn. MR. STANSBURY: Apart from structures where we have -- Monty Stansbury, Yuma County. Apart from dilapidated structures or structures that are abandoned, normally we'll, I think, try to 10 work with Rural/Metro so they can use in some instances 11 those structures for practice purposes. 12 be the only incident is trying to raze the structures 13 through that means. 14 But that would That's the only -- MR. LEWANDOWSKI: Well, I think there are some 15 areas that we have to clarify here in terms of the 16 timing of permission to burn and how often it needs to 17 be obtained. 18 HEARING OFFICER McCABE: Everybody realizes 19 that we're still not formally into the formal comment 20 period, so if you want to restate these issues once we 21 have the formal comment. 22 MR. DUFFY: I think there's also a training 23 issue here. I mean, if you look at Yuma, you look up 24 in the Valley area where you got Phoenix and Mesa and 25 Tempe, if Phoenix is going to put on a training fire ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 32 1 for one of their engine companies, are you saying that 2 they got to go to Tempe to get the burn permit? 3 of -- I mean, maybe not. 4 MR. LEWANDOWSKI: 5 right. 6 the County. 7 Kind I'm saying that may not seem It could be that Phoenix would have to go to It has to go up a level or to the State. MR. DUFFY: But you see where I'm going with 8 that. Kind of like down here in the Yuma area, you've 9 got two of the fire departments that can issue permits. 10 Us, YPG cannot issue permits. 11 that I have to go to another fire department to conduct 12 my training. 13 14 MR. LEWANDOWSKI: So you're saying almost When you have your own -- I understand the -- 15 MR. DUFFY: There's no efficiency there. 16 MR. LEWANDOWSKI: Yeah. Especially when you 17 have your own fire prevention or your fire 18 extinguishing equipment on the base. 19 MR. DUFFY: Right. 20 HEARING OFFICER McCABE: 21 MR. FOSTER: Mr. Foster. You know, it just seems like we're 22 just -- we just keep beating this thing to death. 23 seems to me to make this thing neat and clean and 24 efficient is just to have fire trainings be exempt. 25 was exempt for 20 years. ARIZONA REPORTING SERVICE, INC. Realtime Specialists It (602) 274-9944 Phoenix, AZ It PUBLIC HEARING 10/20/2003 33 1 2 MS. BONANNI: It was exempt. And I can't tell you why the committee brought it back in. 3 MR. FOSTER: 4 MS. BONANNI: I don't know. No. I wasn't here. You weren't there. It was 5 people that are not in your type of work is what 6 brought it in. 7 can't tell you why it was now you have to. 8 9 And unless we went back to the notes, I MR. FOSTER: It was just thrown on the table. But it seems to me like all of the mumbo jumbo that's 10 going around with this thing, you should make it exempt 11 and be done with it. 12 13 MR. FERGUSON: April, we beat this same subject to death. 14 MS. BONANNI: 15 MR. FERGUSON: 16 When we had the meeting here in I know it came up. And we said then, it's exempt. Why are they taking away the exemption? 17 Because I hope somebody realizes that if every 18 fire department and every fire district and every fire 19 station in Arizona comes to you every time they want a 20 training burn, somebody's going to be overwhelmed. 21 don't think you -- somebody's not -- it's not 22 registering how many phone calls they're going to get. 23 I mean, I would hate to just do it in Yuma County. 24 25 MS. BONANNI: Right. That's true. I Like Mark said, it obviously has to be looked at and have a yes ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 34 1 or no answer. 2 MR. LEWANDOWSKI: One of the concerns that was 3 raised by our permitting people was we don't know what 4 things are going to be combusted during training 5 exercises, and we would like to. 6 that ahead of time. 7 MR. FOSTER: We would like to know Let me give you a heads up. 8 You're never going to know, because you are 214 miles 9 away. Somebody in Yuma is going to call you for a 10 permit to burn or have a training fire, you have no 11 clue. 12 that, then you better have somebody be doing a physical 13 inspection of that fire prior to ignition. 14 If you're going to do that, if you're to require You can't do it. Trust me. 15 this too long. 16 negative. 17 that type restriction out there, you're going to have 18 to enforce it with a body to do a site inspection prior 19 to ignition. 20 21 You can't do it. I've been doing I'm not being I'm just telling you, if you're going to put HEARING OFFICER McCABE: Mr. Stansbury, did you have a comment? 22 MR. STANSBURY: Monte Stansbury again. 23 What effect does the rule change have on 24 entertainment value fires such as chimeneas, pit 25 barbecues, pit fires? ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 35 1 MR. LEWANDOWSKI: Oh, I see. We don't have a movie 2 exemption. I followed -- yeah. 3 Entertainment barbecue fires, things like that. 4 MR. FOSTER: 5 MR. LEWANDOWSKI: 6 7 8 9 They're exempt. We talked about that. Believe it or not, we did talk about it. MR. STANSBURY: Some of them get to be exceptionally elaborate and some of them quite large. MR. MEADOWS: Many of those can be covered by 10 enforcement of the fire code in that jurisdiction. 11 the City of Yuma, we can limit the size and the 12 materials through the fire code. 13 MR. STANSBURY: I sure would hope so. In People 14 come and ask us questions. We normally refer them to 15 Rural/Metro. 16 go out on their patio and they want to have a chimenea 17 going for a party for two or three hours. 18 would be that there is some level of exemption or a 19 small reporting requirement, if any at all. But for things such as that, individuals 20 MR. LEWANDOWSKI: 21 HEARING OFFICER McCABE: 22 23 My hope Okay. I think we're closing in on the free comment discussion, unless anybody -MR. FERGUSON: I would just like to say, 24 according to my records, the City of Yuma and the City 25 of Somerton and Yuma County are delegated. ARIZONA REPORTING SERVICE, INC. Realtime Specialists And then (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 36 1 Yuma County has re-delegated, subdelegated, something, 2 to Rural/Metro. 3 County? 4 number of different -- 5 MR. RODRIGUEZ: See there at the bottom of Yuma But Somerton and the City of Yuma have a That goes back to who is 6 guarding the chicken coop. 7 That's what it sounds like. 8 9 You know what I mean? HEARING OFFICER McCABE: I was thinking one of the reasons they might have put in the restrictions on 10 training burns is you have to have some control over 11 who is going to be doing them and if they're qualified 12 to be doing them. 13 MR. RODRIGUEZ: But the rules are clear. It 14 says a federal or state official in performance of 15 official duties. 16 guidelines of what you can burn, what you can't burn, 17 we're fixing something that's not broke. 18 I mean, then if you gave the Now, I know back in '93 when the air station 19 got our first permit, our fire fighting was on our 20 permit. 21 was there, and I took it off once I found out it was 22 there. 23 And that's because I didn't know the exemption However, under Probat, what I was doing is I 24 was doing a monthly report to the state on the dates we 25 had fires, the times the fires were conducted, and what ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 37 1 we burned, how many people we trained and who they 2 were, whether they from here or from New Mexico, 3 wherever, and I sent this in on a monthly basis. 4 That gave good control until I called the State 5 one more time and asked to get copies, and nobody knew 6 who in the heck I was sending these reports to. 7 didn't know who had them. 8 about the reports. 9 sending these reports, and nobody knew where they went 10 to. MR. LEWANDOWSKI: 12 MR. RODRIGUEZ: 13 MR. FOSTER: 14 MR. RODRIGUEZ: 15 MS. BONANNI: 17 Nobody in Air Quality knew At least three years I've been 11 16 Probat You were ahead of your time. That's crazy. They went the same place mine did. Exactly. Actually, they know your name so they do save yours. MR. LEWANDOWSKI: Well, now EPA is going to be 18 asking us about the reports that we receive under the 19 Federal regulations. 20 Thank you so much for all of your intelligent 21 questions. I'm sure glad we came out here to go over 22 this one last time. 23 MR. MEADOWS: We're not done yet. 24 MR. LEWANDOWSKI: 25 HEARING OFFICER McCABE: I know you're not done. Well, if there is no ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 38 1 more discussion, I can open up the proceeding for oral 2 comments at this time. 3 MR. LEWANDOWSKI: By the way, we're going to 4 look at the discussion on the transcript to make sure 5 that we understand your comments as fully as possible. 6 So don't think you have to repeat everything, but if 7 you want to repeat the main points. 8 HEARING OFFICER McCABE: 9 MR. MEADOWS: 10 Mr. Meadows. Paul Meadows, Yuma Fire. I would just like to see a -- my proposal is 11 that fire training be exempted from these rule changes, 12 and the fire training be, you know, federal, state, 13 county, city, or delegated to someone. 14 might not be the right word since you have a special 15 term. 16 And delegated But in the instance I use, the instance of the 17 County cooperating with Rural/Metro as a private 18 company, they should be exempt from this rule, or at 19 least just an annual permit where you have maybe some 20 standards that are on that annual permit that must be 21 adhered to and they sign that agreement. 22 Because it just doesn't make sense to -- first 23 of all, the City of Yuma is the State Fire Marshal's 24 representative for Yuma County. 25 right there that the State Fire Marshal is not going to I mean, that tells me ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 39 1 be able to support this. Their staff is shrinking. 2 The State is taking money from everyone else. 3 sounds like we're setting up a bureaucracy of paper 4 trails that's going to go nowhere, to staffs who can't 5 support it anyway because they're overwhelmed with 6 things that are wrong. 7 fire training. So it And there's nothing wrong with 8 So just a proposal to look into that, get that 9 out of here, or make it an annual permit that you fill 10 out annually and with information that ADEQ needs, and 11 that you sign at the bottom that we will adhere to 12 this. 13 wrong. 14 wrong with it because the fire departments of all of 15 the departments in the government I think are probably 16 the -- you know, maybe I'm a little prejudice here, but 17 we're the most good faith department you're going to 18 find. And don't worry about it unless something goes And then -- but I don't see anything going Thank you. 19 MR. LEWANDOWSKI: Anybody else? 20 MR. RODRIGUEZ: 21 I just want to reemphasize the issue on the David Rodriguez again. 22 times for the burns and the need to be authorized to 23 burn at night, at least for the Marine Corps 24 firefighters. 25 don't schedule the airplanes when they're going to For safety, it's a big issue. ARIZONA REPORTING SERVICE, INC. Realtime Specialists Again, we (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 40 1 crash. 2 able to fight it at night. 3 And when they crash at night, they've got to be MR. FOSTER: But also keep in mind that if 4 there's rule changes made where fire fighting fires are 5 not required to be permitted, you don't worry about it. 6 MS. BONANNI: 7 MR. FOSTER: True. Because it's only those fires that 8 are permitted that have to abide by the rules. 9 Non-permitted fires do not. 10 MR. MEADOWS: That goes out the window. If you put in an annual thing, 11 there should be something in there that allows and 12 takes into consideration nighttime fire training. 13 MS. BONANNI: I'm going to say what we'll need 14 to check out is if it's strictly an emissions reason 15 why the fire department is being asked to now get 16 permission for every training exercise, perhaps what 17 Paul was saying may satisfy that requirement. 18 If we get an annual report from each fire 19 department saying I've had this many training exercises 20 and conducted these days, the duration of the fire 21 training took so many hours, that might answer the 22 question if it's strictly from an emissions question. 23 If it is what materials you're burning -- back 24 on another statement -- no, that won't answer that 25 question. But that's probably the best proposal. ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 41 1 MR. MEADOWS: Paul Meadows again. Under your 2 annual, you could say these types of fuels are 3 permitted. These types of fuels are not. 4 MR. RODRIGUEZ: 5 MR. MEADOWS: 6 7 Are burn permits issued now? I mean, this isn't rocket science. MS. BONANNI: If that's what the concern is, 8 that might be perfect. 9 committee. 10 Exactly. We don't know until we ask the MR. RODRIGUEZ: And we have our own SOPs. The 11 fire department when they do their tower burns, all 12 they burn is wood. 13 any kind of paint or shellac is allowed to be burned. 14 We have policies in place already. There's no plastics. No wood with 15 Right now -- well, we're not burning 16 JP anymore, but at that time we were only allowed to 17 burn virgin JP. 18 MR. LEWANDOWSKI: 19 MR. RODRIGUEZ: And what is JP? JP-5 jet fuel. 20 contaminated with anything. 21 it, it's got to be virgin material. 22 23 It can't be If you're going to burn So the policies are in place. The state is going to know that we're burning by an annual report. 24 MR. MEADOWS: Paul Meadows again, Yuma Fire. 25 We are guided by the National Fire Protection ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 42 1 Association. 2 And a department that doesn't go by that standard has 3 just opened themselves up for a bunch of trouble well 4 beyond what we're talking about here. 5 I don't remember the number right now -- covers all of 6 the safety and that type of stuff. 7 They have a standard for fire training. But the NFPA -- So, again, I would like to reiterate, we are 8 self-regulated. And what good does it do the taxpayer 9 to have us creating other regulating bodies when money 10 is the big issue anyway? Just a for instance, the 11 State is in trouble. 12 picked up a lot of their responsibility as the 13 jurisdiction having authority, and I think this falls 14 under that jurisdiction having authority. We all know that. And we've 15 MR. RODRIGUEZ: David Rodriguez again. 16 I think maybe one thing that we could do is 17 probably go out and see what the community is doing. 18 mean, I think we will probably be surprised. 19 I On the air station, we're probably as strict or 20 more strict than anyone else around. If a firefighter 21 wants to burn, they have to tell us, my department, 22 Marie Stewart here, 24 hours ahead of time that they're 23 going to have a training burn. 24 and they call us, we say, sorry, you can't burn. 25 got to wait for the next day. If they fail to do that You Then they're not allowed ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 43 1 to burn until we make the phone call, get the 800 2 number and we call them back. 3 to burn. 4 5 You're good to go. MR. LEWANDOWSKI: 9 MR. FOSTER: 12 We would be happy to receive that policy if you wish to send it to us. MR. RODRIGUEZ: 11 Maybe we need to find out what everybody is doing. 8 10 It's a good day We've got our policies in place. 6 7 Okay. You have a lot of work to do. They call that delegating, don't they? HEARING OFFICER McCABE: All right. If there are no further comments -- 13 MR. FOSTER: 14 not the same issue. Well, I have a comment, but it's Different issue. 15 HEARING OFFICER McCABE: 16 MR. FOSTER: Okay. Under Section D, lower F, number 17 3, it says the type of fires such as pile or windrow. 18 We need to get rid of that word "windrow." 19 disappear quickly. 20 21 MR. LEWANDOWSKI: Could you suggest an alternative? 22 MR. FOSTER: 23 MR. LEWANDOWSKI: 24 MR. FOSTER: 25 It needs to Take it out completely. Piles. Okay. Since the introduction of the air current destructor, the piles of citrus and other ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 44 1 debris that are being burned are set up in piles and 2 the air current destructor handles that very well. 3 4 5 When you get into windrows that are 300 or 400 feet long, you have no control over anything. MR. LEWANDOWSKI: Well, I thought you were 6 suggesting getting rid of it because it no longer 7 happens, but what you're saying is that that might 8 happen and that it's not as safe? 9 10 MR. FOSTER: That's very unpredictable. MR. LEWANDOWSKI: So we would want to know, if 11 it was a windrow -- unless your suggestion is that we 12 should prohibit windrow. 13 MR. FOSTER: Prohibit windrows. If you leave 14 it in there, somebody is going to see it and they're 15 going to do windrows because it's cheaper to push it 16 into windrows than piles. 17 measures in a windrow, you have no emissions controls 18 in a windrow, and you don't have time in a windrow. 19 20 You have no fire control I guess you could replace it, if you wanted to fill the space in, with a pit. 21 MR. LEWANDOWSKI: 22 HEARING OFFICER McCABE: 23 (No response.) 24 HEARING OFFICER McCABE: 25 Piles or a pit. Thank you. Any other comment? Okay. This concludes the oral comment period of the proceeding. ARIZONA REPORTING SERVICE, INC. Realtime Specialists We (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 45 1 encourage everyone to submit written comments on the 2 proposed rulemaking. 3 comments must be received no later than 5:00 p.m. 4 Friday, October 24th. 5 6 Please remember that all of the this And we thank you all for attending and thank you for all of your suggestions. 7 MR. MEADOWS: Just one last question. Since we 8 made these proposals during the oral comment period, do 9 we have to resubmit them or are they on the record for 10 11 action? HEARING OFFICER McCABE: They're on the record. 12 I don't know if you want to be any more specific in the 13 written comment or not. 14 15 MR. LEWANDOWSKI: The oral comments are as good or sometimes better as the written. 16 HEARING OFFICER McCABE: Thank you. 17 (The Public Hearing concluded at 2:30 p.m.) 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ PUBLIC HEARING 10/20/2003 46 1 2 STATE OF ARIZONA ) ) ss. COUNTY OF MARICOPA ) 3 4 5 6 I, MICHELE E. BALMER, Certified Court Reporter 7 No. 50489 for the State of Arizona, do hereby certify 8 that the foregoing printed pages constitute a full, 9 true and accurate transcript of the proceedings had in 10 the foregoing matter, all done to the best of my skill 11 and ability. 12 13 WITNESS my hand this 1st day of November, 2003. 14 15 16 17 MICHELE E. BALMER Certified Court Reporter Certificate No. 50489 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. Realtime Specialists (602) 274-9944 Phoenix, AZ ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 W. Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director AGENDA Air Quality Division Regional Haze State Implementation Plan Development PUBLIC HEARING/ORAL PROCEEDING October 21, 2003, 1:30 p.m. Casa Grande Parks & Recreation Office, Armadillo Room 404 East Florence Boulevard, Casa Grande, Arizona Pursuant to [cite 40 CFR § 51.102 for SIP hearings and ARS § 49-425 for air quality rule hearings], notice is hereby given that the above referenced meeting is open to the public. Welcome and Introductions Purposes of the Oral Proceeding/Procedures for Making Public Comment Brief Overview of the Proposed Rule Question and Answer Period Oral Comment Period Adjournment of Oral Proceeding Comment period ends 5:00 p.m., Friday, October 24, 2003. Please direct comments and questions to Kevin Force, ADEQ Air Quality Division, at (602) 7714480 or 1-800-234-5677, Ext. 771-4480. Order of agenda items is subject to change. For additional information regarding the meeting, please call [NAME], ADEQ Air Quality Division, at (602) 771-[ ] or 1-800-234-5677, Ext. [ ]. Persons with a disability may request a reasonable accommodation such as a sign language interpreter, by contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 4794. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829. Northern Regional Office Southern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 400 West Congress Street • Suite 433 • Tucson, AZ 86004 85701 (928) 779-0313 (520) 628-6733 Printed on recycled paper PUBLIC HEARING 10-21-2003 1 1 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 2 3 4 5 6 IN THE MATTER OF THE PROPOSED ) REVISIONS TO ARIZONA ) PUBLIC HEARING ADMINISTRATIVE CODE R18-2-602, ) THE UNLAWFUL OPEN BURNING RULE, ) AND ARTICLE 15, THE RULES ) COVERING FOREST AND RANGE ) MANAGEMENT BURNS. ) _________________________________) 7 8 9 10 11 12 At: Casa Grande, Arizona 13 Date: October 21, 2003 14 Filed: 15 16 REPORTER'S TRANSCRIPT OF PROCEEDINGS 17 18 19 20 ARIZONA REPORTING SERVICE, INC. Court Reporting Suite Three 2627 North Third Street Phoenix, Arizona 85004-1126 21 22 23 By: Prepared for: 24 KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 ADEQ 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 2 1 BE IT REMEMBERED that the above-entitled and 2 numbered matter came on regularly to be heard before 3 the Arizona Department of Environmental Quality, at the 4 Casa Grande Parks & Recreation Office Armadillo Room, 5 404 East Florence Boulevard, Casa Grande, Arizona, 6 commencing at 1:30 p.m. on the 21st day of October, 7 2003. 8 BEFORE: SHUDEISH MAHADEV, HEARING OFFICER 9 10 11 12 13 APPEARANCES: MARK LEWANDOWSKI, SIP and Rulemaking Development Unit Supervisor, Planning Section, on behalf of ADEQ; KEVIN FORCE, Rule Writer, Planning Section, on behalf of ADEQ. 14 15 16 KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 17 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 3 1 HEARING OFFICER MAHADEV: Good afternoon. 2 Welcome to this Arizona Department of Environmental 3 Quality hearing. 4 The subject of this hearing is proposed 5 revisions to Arizona Administrative Code R18-2-602, the 6 unlawful open burning rule, and Article 15, the rules 7 covering forest and range management burns. 8 9 The hearing is now open. The date is Tuesday, October 21st, 2003, and the time is 1:38 p.m. 10 The location is the Armadillo Room of the Casa Grande 11 Parks and Recreation Office at the following address, 12 404 East Florence Boulevard, Casa Grande, Arizona 13 85222. 14 My name is Shudeish Mahadev. I'm an 15 Environmental Engineering Specialist for the Permits 16 Section of the Air Quality Division at ADEQ, and I have 17 been appointed by the ADEQ Director to conduct this 18 hearing. 19 The purposes of this hearing are to provide 20 the public an opportunity to, one, hear about the 21 substance of the proposed revisions to the Arizona 22 Administrative Code Rule 18-2-602 and Article 15; two, 23 ask questions concerning the proposed rule revisions; 24 and present oral arguments, data, and views concerning 25 the proposed rule revisions, in the form of comments on ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 4 1 the record. 2 Other ADEQ Air Quality representatives in 3 attendance today are Mark Lewandowski, SIP and 4 Rulemaking Development Unit Supervisor for the Planning 5 Section; Kevin Force, Rule Writer from the Planning 6 Section. 7 If you plan to make a public comment on the 8 record, the procedure is straightforward. Please 9 complete a speaker slip found at the sign-in table and 10 hand your slip to me. Using speaker slips allows 11 everyone an opportunity to be heard and allows us to 12 match the name on the official record with the 13 comments. 14 You may also submit written comments to me 15 today in person, or you may submit comments by mail, 16 e-mail, or fax. 17 the comment period, 5:00 p.m. on Friday, October 24, 18 2003. 19 than October 24, 2003. 20 Please submit comments by the end of Any written comment must be received no later Submit your written comments to Kevin Force, 21 Air Quality Planning Section, Arizona Department of 22 Environmental Quality, 1110 West Washington Street, 23 Third Floor, Phoenix, Arizona 85007. 24 602-771-2366 and his e-mail is 25 force.kevin@ev.state.az.us. ARIZONA REPORTING SERVICE, INC. His fax is (602) 274-9944 PUBLIC HEARING 10-21-2003 5 1 Notice of this hearing was published in The 2 Arizona Republic and The Arizona Daily Star on 3 September 19, 2003. 4 State statutes require that comments made 5 during the formal comment period be considered by ADEQ 6 in the preparation of a final rule, in which the 7 Department responds in writing to written and oral 8 comments made during the formal comment period. 9 The agenda for this hearing is simple. 10 First, I will ask Mark Lewandowski to provide an 11 overview of the proposed rulemaking. 12 Second, I will conduct a question and answer 13 period. 14 is to provide information that may help you in making 15 comments on the rulemaking. 16 The purpose of the question and answer period Third, I will conduct an oral comment period. 17 At that time, I will call speakers in the order in 18 which I have received their speaker slips. 19 Please be aware that any comments you make at 20 today's hearing that you want the Department to 21 formally consider must be given either in writing or on 22 the record during the oral comment period of this 23 proceeding. 24 25 At this time Mark Lewandowski will give a brief overview of the background concerning ADEQ's ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 6 1 proposed revisions to A.A.C. Rule 18-2-602 and Article 2 15. 3 MR. LEWANDOWSKI: Thank you. These 4 proposed rules would amend Arizona's existing open 5 burning and prescribed burning rules to make them 6 conform to EPA requirements for states' Regional Haze 7 State Implementation Plans, or SIPS. 8 these amendments make other technical changes, 9 including improvements of the rules' clarity, 10 In addition, conciseness, and understandability. 11 We're going to include revisions to 602 and 12 Article 15 in the state's Regional Haze SIP, which we 13 are required to submit to EPA by December 31st, 2003. 14 And, in fact, that's an EPA requirement, an EPA 15 deadline. 16 2002 we formed a Fire Emissions Work Group to discuss 17 visibility issues related to the fire emissions and 18 made recommendations to ADEQ regarding necessary 19 changes to the rules. 20 joint effort of ADEQ and the Fire Emissions Work Group 21 based on input received at those public meetings and 22 the decisions of them. We planned a lot for these two rules. In The current proposed rule is a 23 The specific requirements for state regional 24 haze SIPs are found in the Code of Federal Regulations 25 at Title 40, CFR 51.308 and 51.309. ARIZONA REPORTING SERVICE, INC. Most notably they (602) 274-9944 PUBLIC HEARING 10-21-2003 7 1 include greater tracking and monitoring of open burning 2 and burn plans, regular evaluation of data, and the 3 establishment of annual emission goals for fire in 4 cooperation with States, tribes, Federal land 5 management, and private entities. 6 With regard to the changes to R18-2-602, the 7 Unlawful Open Burning Rule, we kind of overhauled that 8 section. 9 definitions. We added a new subsection that contains just We added definitions for various 10 categories of open burning like agricultural, 11 construction, residential. 12 "delegated authority" and the phrase "independent 13 authority to permit fires" and "prohibited materials." 14 Prohibited materials was previously described but not 15 defined in a guidance document. We added definitions for 16 The proposed rule also clarifies which open 17 burning activities require open burning permits under 18 the rule and those that are exempt from that permit. 19 It contains a more complete list of information 20 required to be in the permit. 21 various requirements of the Regional Haze Rule, but in 22 the petition it promotes more efficient permit 23 administration. 24 25 This is because of the We also added language in the body of the rule clarifying that the state rule will not operate in ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 8 1 counties with independent authority to permit fires. 2 And in the definition we have listed these three 3 counties, Maricopa, Pinal, and Pima. 4 counties all have rules creating permits for open 5 outdoor fires other than dangerous materials, which as 6 I understand it are normally referred to ADEQ for 7 processing. 8 9 Those three ADEQ considered exempting certain fires that use air curtain destructors from the open burn permit 10 requirement in order to remove an administrative 11 barrier to this type of burning, as referenced by the 12 Regional Haze Rule. 13 studies, ADEQ decided that these devices do require 14 oversight and it is appropriate that they be subject to 15 permits under the rule. 16 view the requirement that ACDs obtain a permit as an 17 administrative barrier. 18 However, after reviewing two In addition, ADEQ does not The other part of this rule has to do with 19 Article 15 of the Code, the Code being Title 18, 20 Chapter 2 of the Arizona Administrative Code. 21 title of that article is Forest and Range Management 22 Burns, and it will better conform to EPA's regional 23 haze requirements. 24 understandable and facilitate enhanced compliance. 25 Unlike the overhaul of 602, this rule merely needed a The We're trying to make it more ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 9 1 tune-up. 2 The former structure of the rule remains 3 intact; that is, there is an annual registration, a 4 submittal of a Burn Plan at least 14 days before the 5 burn, a daily Burn Request, and a Burn Accomplishment 6 Form that is sent to ADEQ after the burn. 7 The rule has been strengthened to aid in the 8 collection and the recording of the burn data, the 9 evaluation of the burn programs, and the setting of 10 annual emission goals, which is specifically required 11 under the Regional Haze Rule. 12 Finally, I'd like to mention that we did send 13 the Article 15 rule to EPA for comments early in the 14 process, and they did send us back the comments and we 15 did our best to respond to them. 16 sending it to them again in the near future. But we will be 17 That concludes the overview. 18 HEARING OFFICER MAHADEV: Thanks, Mark 19 Lewandowski, for providing us the overview. 20 move to the question and answer period. 21 22 Are there any questions? We'll next Please introduce yourself. 23 MR. GABRIELSON: 24 process is. 25 period? I'm not sure what the Is this a free form question and answer ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 10 1 HEARING OFFICER MAHADEV: Yeah. Initially, 2 we'll do the free form question and answer period, and 3 the formal period will start after this. 4 MR. HAWK: Larry Hawk from the County DEQ. 5 Mark, on the air curtain destructors, I want 6 to be clear on this, that air curtain destructor use is 7 considered open outdoor burning for purposes of 602, 8 thus, it needs a permit? 9 MR. LEWANDOWSKI: 10 11 Is that what you're saying? MR. HAWK: That's correct. Now, where is that in the rule? can't find it right now. 12 MR. LEWANDOWSKI: 13 the rule. 14 a permit, it would have showed up in the list of 15 activities that are exempt from the permit. 16 absent from that list because we consider them an open 17 outdoor fire. 18 It would have -- It's not specifically in MR. HAWK: Had they been exempt from They're Why do we consider them an open 19 outdoor fire under the rule? I understand they're not 20 specifically exempted, therefore, the presumption is 21 that they're going to be included because they're not 22 exempted. 23 exempted doesn't necessarily mean they are included if 24 they don't fit the definition or the inclusionary 25 language. And I could argue that because they're not Where is it in the inclusionary language ARIZONA REPORTING SERVICE, INC. (602) 274-9944 I PUBLIC HEARING 10-21-2003 11 1 that would include an air curtain destructor in 602? 2 MR. GABRIELSON: 3 MR. HAWK: 4 MR. LEWANDOWSKI: 5 6 7 8 A12. They're not -I'd appreciate any help from the audience. MR. GABRIELSON: A12 defines open outdoor fire, which basically states -MR. HAWK: And I'm not taking a position here 9 or advocating for a position, except I just want to be 10 clear, as far as the rule is concerned, that if an air 11 curtain destructor requires a permit, that it's clear 12 that it requires a permit in 602. 13 MR. LEWANDOWSKI: 14 the inclusionary language. 15 inclusionary language. 16 curtain destructor is used in the rule. 17 MR. HAWK: Your question is, where is I'm not sure there is I'm not sure the phrase air In the definitions under A2, 18 there's a definition of an approved waste burner, 19 meaning an incinerator, blah, blah, blah. 20 where we get back to 601, which is not under 21 consideration here. 22 considered an incinerator, or is an incinerator under 23 the definition of incinerator, and therefore is an 24 approved waste burner, does that matter insofar as 25 having air curtain destructors included within the This is If an air curtain destructor is ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 12 1 rule? 2 In other words, our earlier conversation, I'm 3 unclear -- you know, when we started talking about the 4 section 601 that's not here -- I can't remember what 5 601 said. 6 curtain destructors -- I'm not sure that open outdoor 7 fire or open burning under the definition under 12 8 necessarily would include an air curtain destructor. 9 But it would seem to me if we want air MR. LEWANDOWSKI: 10 me. 11 sure that we were -- people were clear that we are 12 including air curtain destructors, now that the phrase 13 doesn't appear in the rule, we might want to mention 14 the phrase air curtain destructors, for example, under 15 an open outdoor fire. 16 17 18 I see your point. That sounds reasonable to MR. HAWK: And if we wanted to make extra And what was the thing in 601 -- What does 601 say again? MR. FORCE: 601 says, "For purposes of this 19 Article, any source of air contaminants which, due to 20 lack of an identifiable emission point or plume, cannot 21 be considered a point source, shall be classified as a 22 nonpoint source. 23 as air curtain destructors ... shall be considered to 24 have identifiable plumes." 25 In applying this criteria, such items MR. HAWK: That makes them a point source. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 13 1 MR. LEWANDOWSKI: 2 nonpoint, doesn't it? 3 identifiable plumes. 4 MR. HAWK: 5 under 601? 6 issue. 7 Okay. No. That makes them a Air curtain destructors have Therefore, they are a point source That was our problem -- or, the So if an air curtain destructor is 8 considered, by virtue of its plume, to be a point 9 source as we read 601, then an air curtain destructor 10 would not be within the purview of 602, because this is 11 a nonpoint source. 12 13 Isn't that what our issue was? MR. GABRIELSON: Wouldn't that trigger a permit requirement under 49-426? 14 MR. LEWANDOWSKI: 15 MR. HAWK: It might. The thing is, if we want to permit 16 air curtain destructors, for good reason, then we do 17 need to -- don't we need to address that other rule? 18 MR. LEWANDOWSKI: Well, it's too late now. 19 We're not going to have time to go back and open that 20 one up. 21 we can come up with a better one -- is that whether an 22 air curtain destructor is a point or nonpoint source is 23 irrelevant to the 602 Rule. 24 25 So the position that we're adopting -- unless 602 happens to be a rule concerning open outdoor fires, but it happens to be in an article ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 14 1 entitled nonpoint sources. 2 means that every phrase in 602 only applies to nonpoint 3 sources. 4 5 MR. HAWK: But I don't think that that That's interesting. I think that's something we need to look at. 6 But in any event, if we don't have a 7 definition, if we're going to try to fit the air 8 curtain destructor into this definition under A12, I 9 think that's weak. And especially when you look at the 10 subject matter here is nonpoint sources. 11 nonpoint and point sources; it's not nonpoint sources 12 except for -- do you know what I mean -- air curtain 13 destructors. 14 It's not Because, I'll tell you, if I own an air 15 curtain destructor or I want to use one and I don't 16 want to get a permit, I'm going to be looking for 17 loopholes in the rules, and it would seem to me that 18 there's one here. 19 about, are people who are looking to avoid the 20 permitting process. 21 know -- And that's all we're concerned We're not looking for people, you 22 MR. LEWANDOWSKI: 23 MR. HAWK: Right. People who don't care or think 24 they ought to be permitted, those people aren't going 25 to show up. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 15 1 MR. GABRIELSON: I have a copy of 601 in 2 front of me. 3 curtain destructor as a source of an identifiable 4 plume, therefore making it a point source, then at 5 least initially it would be subject to a permit 6 requirement under 426. 7 And to the extent that 601 defines an air And it sounds like the question is, are you 8 intending, with 602, to exempt them from the permit 9 requirement that seemingly arises under 601? Clearly 10 the intent at this point doesn't appear to be to exempt 11 them altogether. 12 MR. LEWANDOWSKI: That's something that we 13 could, perhaps, discuss in a response to comments. 14 initial and formal response would be, we have not 15 expressed such an intent. 16 air curtain destructor having an identifiable plume 17 means that it's presumed to not be a nonpoint source. 18 Double negative, but that's logically -- or, exactly 19 what it says, not a nonpoint source because it has an 20 identifiable plume. 21 My The 601 identification of an There's some problems here that we're going 22 to have to kind of just work through. 23 to put it in A12, but it maybe that that's what we're 24 going to have to do. 25 MR. HAWK: It may be weak For purposes of this rule, though, ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 16 1 forgetting about 601 and going straight to 602, you 2 believe if 601 did not exist that air curtain 3 destructors would be within 602 because what? 4 5 6 7 MR. LEWANDOWSKI: Because they fall under the definition of an open outdoor fire. MR. HAWK: burning under A12? An open outdoor fire or open That's our basis? 8 MR. LEWANDOWSKI: 9 MR. GABRIELSON: Right. Rather than try to identify 10 the statutory basis for inclusion, could you just 11 include a blurb in the preamble that explains that it 12 is not the intent of these provisions to exempt them 13 from a permit requirement? 14 requirement open-ended so that you're not trying to 15 resolve point source versus open burning permit 16 requirement, you're just saying we're not trying to 17 exempt it and make that part of it clear. 18 which category they fall in, that's a question for 19 another day. 20 MR. LEWANDOWSKI: And leave the phrase permit And as to Well, you say rather than, 21 we could also do it in addition to the blurb. 22 words, we could discuss in the preamble and in the 23 rule, perhaps, how we consider them to be open outdoor 24 fires and subject to 602, in addition to saying that 25 we're not intending to exempt them from a permit ARIZONA REPORTING SERVICE, INC. In other (602) 274-9944 PUBLIC HEARING 10-21-2003 17 1 requirement. 2 MR. GABRIELSON: But to the extent you're 3 saying that they're subject to an open burning permit 4 to 602, you're necessarily implying that they're not 5 subject to a point source permit requirement. 6 MR. LEWANDOWSKI: I wouldn't put the word 7 necessarily in there. 8 conclusion, but I don't think it would be necessarily a 9 conclusion you would have to draw. 10 MR. HAWK: I mean, that could be somebody's Under 601, assuming air curtain 11 destructors are point sources and you're citing 426, 12 have air curtain destructors been permitted as point 13 sources by ADEQ previously? 14 15 MR. LEWANDOWSKI: I don't know that they have. 16 MR. HAWK: I think they haven't. 17 MR. GABRIELSON: Looking at this from a 18 pragmatic perspective, I don't know what air curtain 19 destructors are used for in the contemplation of the 20 Fire Management Task Force in clearing the slash up in 21 the forest, whatever it may be. 22 the desert where things are developing and you've got 23 substantial commercial vegetation that's been growing, 24 be it orchards or vineyards or other vegetation, an 25 initial step in the development process involves the ARIZONA REPORTING SERVICE, INC. But on the floor of (602) 274-9944 PUBLIC HEARING 10-21-2003 18 1 wholesale clearing of all of that and building a lot of 2 fires. 3 that are occurring in immediate proximity to developed 4 areas, it's the kind of activity that really calls out 5 for some sort of on-the-ground or close-in-hand 6 supervision. 7 And to the extent that you've got big fires And it's my impression that, generally 8 speaking, ADEQ's open burning permit contemplates a 9 pretty hands-off kind of a permitting transaction, when 10 you come in, get a no-cost permit, and go out and do 11 what you're going to do and there's no inspection, 12 there's no on-the-ground management by an 13 administrative authority as to what's going on. 14 a practical matter, wholesale land clearing does call 15 for some level of supervision so you don't wind up with 16 substantial nuisance impacts with respect to 17 development that may be immediately next door to the 18 areas being cleared. 19 MR. LEWANDOWSKI: And as Do you see ADEQ's rule 20 affecting Pinal County inasmuch as that you would be 21 encouraged to follow up with what we did? 22 MR. GABRIELSON: Larry raised this earlier, 23 and there's really two considerations that come into 24 play. 25 stringent as. 49-479 says that we have to be at least as 49-112 says if we're going to be more ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 19 1 stringent than, we need to come up with some sort of 2 identifiable local risk to public health, is basically 3 the standard. 4 To the extent that you have an existing set 5 of rules or an existing ordinance in place that is 6 arguably as stringent as, you don't really need to do 7 anything as a result. 8 On the other hand, inevitably you will need 9 to change that ordinance or set of rules -- something 10 will change in the requirement. 11 it's a legitimate question to ask, do you need to 12 either drop down to what I'll call the lowest common 13 denominator defined by ADEQ's rule, or in the 14 alternative, do you need to be able to articulate an 15 immediate risk of public health? 16 And at that point, And if I'm talking about nuisance level 17 impacts as being the real issue, 49-112 won't allow for 18 a nuisance level impact to be justification for more 19 stringent rules. 20 112 calls for articulation of a risk to health, and 21 that's not always going to be easy to do. 22 However, it wouldn't be an issue. MR. LEWANDOWSKI: So we have a lot of 23 questions and not a whole lot of answers in the air 24 curtain destructor area. 25 MR. GABRIELSON: I would really broaden the ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 20 1 discussion beyond just air curtain destructors because, 2 at least from the perspective of Pinal County, the real 3 question is wholesale land clearing. 4 you're clearing land on a wholesale basis by just 5 piling it up in 20-foot piles and burning it or you're 6 using an air curtain destructor, it's basically the 7 same issue in either case. 8 occurring that could be in an immediate proximity to 9 developed areas. 10 11 And whether You've got a lot of burning And to what extent that would require more handing and management -MR. LEWANDOWSKI: Okay. We're going to have 12 to take a lot of this under consideration. 13 you for your bringing it to our attention, both today 14 and in the past. 15 16 17 18 19 HEARING OFFICER MAHADEV: And I thank For the gentleman who just walked in -MR. WALCH: I'm Kale Walch with Pinal County Air Quality. HEARING OFFICER MAHADEV: -- we're just in 20 the process of doing an informal question and answer. 21 If you want to make a formal comment, you can fill out 22 a speaker slip and bring it to me. 23 right after this. 24 25 MR. GABRIELSON: We'll be doing that I guess I would ask that you take a look at page 4068 of the publication of the ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 21 1 register and the reference there to the Regional Haze 2 Rule as possibly a justification for exempting air 3 curtain destructors. 4 reconcile with the language of the Regional Haze Rule, 5 because this is not -- air curtain destructors aren't 6 an alternative to burning, air curtain destructors are 7 just a different form of burning. I'm not sure that that does 8 MR. LEWANDOWSKI: 9 MR. GABRIELSON: Okay. Comment noted. On which note, I will leave 10 air curtain destructors alone for the rest of the day. 11 I promise. 12 Taking a look at 18-2-602.A.4 and D.1(a), 13 they respectively define construction burning, and 14 D.1(a) allows construction burning. 15 16 17 MR. LEWANDOWSKI: I can't turn the pages quite that fast. MR. GABRIELSON: A.14 is really the crux of 18 the comment here, because it allows for the burning of 19 demolition materials. 20 special category for burning demolition materials. 21 And in Pinal County we have a Burning demolition materials raises 22 asbestos-related issues, and it's been our experience 23 that it takes some direct oversight to get people to 24 understand what they can and cannot burn. 25 obviously to their advantage to just pile things up in ARIZONA REPORTING SERVICE, INC. It's (602) 274-9944 PUBLIC HEARING 10-21-2003 22 1 a pile and burn them, because it's a lot cheaper than 2 hauling anything to the landfill and it's also a lot 3 cheaper than going through and sorting the material 4 out. 5 So if you take a look at A.13, it defines 6 prohibited materials. 7 it has taken our going out and visiting directly with 8 the person who is going to conduct the burning to get 9 them to sort out the things that shouldn't be burned. 10 And my point is, that many times So, again, without some sort of meaningful 11 oversight, I question what level of compliance you're 12 going to get with the stated objective of excluding 13 prohibited materials. 14 motivation on the part of somebody who's going to burn 15 a building after they knock it down to just burn it all 16 and be done with it. 17 to A.4. 18 19 Again, there's a strong economic So that's a comment with regard Turning to 18-2-602.D.3, the reporting requirement -- 20 MR. HAWK: What page are you on? 21 MR. GABRIELSON: 4075. Why don't I go 22 through these just in a question and answer format, and 23 I'll try to put this on paper and get it to you rather 24 than trying to transcribe my rambling on the fly. 25 MR. LEWANDOWSKI: Did you say D.3? ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 23 1 MR. GABRIELSON: I'm looking at D.3(f). 2 I understand that from the perspective of 3 regional haze modeling, one of the many holes in the 4 emission inventory structure was having a better 5 understanding of short term temporal and spacial 6 distribution of fire emissions, if you will. 7 objective was to come up with better data. 8 9 On the other hand, I also work in accounting where we've been issuing thousands of burning permits 10 per year. 11 include Jimmie Kerr, in particular, who is the 12 supervisor for District Three. 13 14 So the And I work for a group of supervisors, which MR. LEWANDOWSKI: Can you spell his last name? 15 MR. GABRIELSON: 16 He's made clear that he doesn't want to see 17 K-e-r-r. Pinal County get acidified at this point. 18 So we had initially come up with a proposed 19 rule that tracks ADEQ's rule, or at least I thought it 20 was. 21 was a daily report with respect to burning activity, 22 when did it occur, and what did you burn. And what we were actually proposing to require 23 And I thought about that and I thought about 24 Mr. Kerr's concern about not unduly imposing upon the 25 citizenry. And then I took a look at ADEQ's rule, and ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 24 1 in (f) it seems to say that, as an acceptable 2 alternative, you can either provide a daily report of 3 what you've done or send in an annual report. 4 I guess I'd like to ask the ADEQ, is 5 submission of an annual report by the person with the 6 burn permit an acceptable level of reporting? 7 Because from a practical perspective, that's 8 a lot less onerous burden to impose on people who buy a 9 lot of burn permits that are requiring that they get a 10 month-long or six-month or however long the burn permit 11 is and call us every day. 12 the data that you get back if you had them call every 13 day. 14 for an annual report, in all candidness, that's what I 15 would propose to do at the County level. I recognize the quality of On the other hand, if your proposed rule allows 16 MR. LEWANDOWSKI: My recollection is that the 17 Fire Emissions Work Group did talk a lot about that and 18 did think that an annual report was an acceptable 19 alternative. 20 21 22 MR. GABRIELSON: Okay. That one was a question. The next one is a comment, and I'm on page 23 4076, paragraph F.2. It's my understanding that the 24 legislature amended the A.R.S. 49-501(f) to allow the 25 issuance of a general permit to allow burning household ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 25 1 waste for people engaged in farming or ranching on 40 2 acres or more. 3 4 HEARING OFFICER MAHADEV: This is an informal comment, right? 5 MR. GABRIELSON: Sure. Right. 6 To the extent that that's permissive, I 7 realize one could infer a mandate from the legislature 8 in affording ADEQ that authority. 9 lives out in still a relatively rural area of the state But as one that 10 of Arizona, I can unequivocally say people burning 11 garbage is really an obnoxious thing. 12 And I realize in F.2 you have an admonition 13 that you have to be at least 500 feet away from an 14 adjoining dwelling. 15 I can tell you that the stench of burning garbage can 16 carry for miles. 17 it's obnoxious. 18 can do it, but from my perspective I respectfully 19 submit it's not a good idea to do even if you have the 20 authority to do it. 21 But based on personal observation, You get a nice burning condition, and And the legislature may have said you MR. LEWANDOWSKI: There's, perhaps, a point 22 of clarification. 23 so I believe the 500 feet requirements would not apply 24 for household waste generated on farms or ranches. 25 F.1 and F.2 are in the alternative, MR. GABRIELSON: That would appear to be the ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 26 1 case. 2 preclude you from parking all your garbage in one 3 corner of your 40 acres and lighting it off next to 4 your neighbor's house. 5 nuisance perspective or a public policy perspective 6 doesn't really seem like the kind of image I would like 7 to project from the state of Arizona, that it is a 8 third-world country because it's okay to have a burn 9 barrel in your backyard and burn garbage. 10 And if you look at the F.1, there's nothing to Which, again, from a public That one was a comment. 11 I'm not clear on any of this, how will this 12 be enforced and what are the relevant penalties? 13 given that this was going to be a minimal 14 administrative burden, how will it be enforced and what 15 will the penalties be? 16 MR. LEWANDOWSKI: And I don't recall, either, any 17 specific penalties or enforceability provisions in 602 18 itself. 19 MR. MINCH: Isn't there a $25 fine? 20 MR. GABRIELSON: Well, actually, what 21 49-501.I says is that any violation of this section 22 shall be punishable by a fine not to exceed $25. 23 But in terms of the administrative burden, 24 the assumption is that this isn't going to be any 25 administrative burden to do all of this. ARIZONA REPORTING SERVICE, INC. Then I guess (602) 274-9944 PUBLIC HEARING 10-21-2003 27 1 my question is, does that mean you're not contemplating 2 enforcing any of it? 3 MR. LEWANDOWSKI: 4 MR. GABRIELSON: Absolutely not. Is that for the record? 5 That's not what you're contemplating or you're not 6 contemplating enforcing it? 7 8 MR. LEWANDOWSKI: That's not what we're contemplating. 9 MR. HAWK: On that household waste, this 10 doesn't indicate to me that the household waste that is 11 permissible has to be your household waste. 12 be burning household waste for someone else or for 13 neighbors. 14 15 16 17 18 MR. LEWANDOWSKI: So I could I think that's why we put in the phrase on site. MR. HAWK: On site where? Of the household or of where it's burned, is that the idea? MR. LEWANDOWSKI: If the waste is generated 19 on the farms or ranches, on site, that would be F.1. 20 And F.2 seems to imply, although it's not as clear, at 21 the site of the household. 22 MR. HAWK: And household waste -- There's a 23 definition of household waste; then there's a 24 definition of prohibited material which includes a lot 25 of household waste, except that it's prohibited ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 28 1 materials. 2 How does the definition of prohibited 3 materials -- Where in the rule do I hear about 4 prohibited materials, such that -- 5 plastic retail and grocery bags are prohibited 6 materials, but common household garbage consists of 7 that. 8 how would I know to take my plastic household-generated 9 waste, take the plastic bags out because they're How would I -- For instance, If I know what the rule says, 10 prohibited materials? 11 prohibited materials, where does prohibited materials 12 apply in the rule? 13 Other than being defined as MR. LEWANDOWSKI: One logical place where it 14 could have been -- and I don't see it -- is in the 15 definition of household waste. 16 17 18 MR. HAWK: That's what I would suggest, is that household waste excludes prohibited materials. MR. LEWANDOWSKI: Another place it could 19 be -- and I'm going to check now -- is in subsection F. 20 I don't see it there either. 21 MR. GABRIELSON: On the other hand, if you 22 define household waste to exclude prohibited materials 23 which includes nonpaper garbage, plastic and rubber 24 products including bottles, plastic grocery and retail 25 bags, aerosol spray cans -ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 29 1 2 MR. LEWANDOWSKI: Things that are normally household waste. 3 MR. GABRIELSON: There's not a lot left in 4 your garbage can by the time you get through emptying 5 those things out. 6 7 MR. HAWK: use an air curtain destructor. 8 9 In order to do it, you've got to We're supposed to use an approved waste burner. An approved waste burner is not necessarily an 10 air curtain destructor, but the incinerator -- that is 11 an incinerator. 12 burner, it says, means an incinerator, and I think 13 incinerator is defined somewhere else. 14 15 16 17 18 This waste -- MR. LEWANDOWSKI: The approved waste Yeah. It's defined in Article 1 of the State. MR. HAWK: And that includes an air curtain destructor, I think. MR. LEWANDOWSKI: Yeah, but that wouldn't 19 necessarily mean that this is one. 20 burner is an incinerator and an air curtain destructor 21 is an incinerator, but that doesn't mean -- there's 22 just different classes of an incinerator. 23 MR. GABRIELSON: Approved waste Historically an approved 24 waste burner was a 55-gallon barrel with a screen laid 25 across the top and holes punched in the bottom. ARIZONA REPORTING SERVICE, INC. That (602) 274-9944 PUBLIC HEARING 10-21-2003 30 1 was what the definition of an approved waste burner 2 was. 3 MR. LEWANDOWSKI: 4 I mean, if you think the definition would be 5 improved by instead of saying an incinerator saying -- 6 just saying a device constructed of fire resistant 7 material. 8 conflict between -- 9 And it still is. I'm not sure if there's any specific MR. FORCE: "Incinerator means any equipment, 10 machine, device, contrivance, or other article, and all 11 the pertinences thereof, used for combustion of refuse, 12 salvage materials, or any other combustible material, 13 except fossil fuels, for the purpose of reducing the 14 volume of the material." 15 MR. LEWANDOWSKI: 16 definition. 17 an identifiable plume. 18 burning device. 19 20 Doesn't require a plume -- doesn't require MR. HAWK: Does that approved waste burner MR. LEWANDOWSKI: 22 decide that, do we? 23 MR. HAWK: 25 An incinerator kind of means a have a plume? 21 24 It sounds like a broad I don't think we need to Because that would make it a point source. MR. LEWANDOWSKI: Well, would it be a point ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 31 1 source? 2 the legislature seems to have given a specific niche to 3 the household waste. 4 legislature terms a general permit, I think. 5 I'm not sure we'd have to decide that, because It falls under what the MR. GABRIELSON: To the extent that the 6 allowance from the legislature was to adopt a general 7 permit, does this rule do that? 8 9 MR. LEWANDOWSKI: My hunch, without having analyzed that precisely, is that it continues the 10 general permit that was previously adopted in 602. 11 yes, this rule does do that. 12 general permit; it continues the general permit. 13 14 15 MR. GABRIELSON: It doesn't create a So there is an existing general permit? MR. LEWANDOWSKI: Not in the sense of the 16 Title 5 general permits. 17 definition of a general permit. 18 MR. GABRIELSON: I think it means a broader But is there a document that 19 has been issued that says, "General permit for open 20 burning in accord with 49-501.F"? 21 22 23 24 25 So MR. LEWANDOWSKI: I'm not aware that there is one, and it could be that the rule is a general permit. MR. GABRIELSON: But to the common understanding, the rule isn't the general permit. MR. LEWANDOWSKI: I've heard the phrase ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 32 1 permit by rule. 2 MR. GABRIELSON: 3 MR. LEWANDOWSKI: I've heard the phrase too. So in terms of general 4 understanding, there might be some people that do 5 understand that. 6 MR. GABRIELSON: But then this isn't giving 7 blanket permission, this is requiring individual 8 permits, isn't it? 9 is saying to -- 10 This isn't a permit by rule, this MR. LEWANDOWSKI: I simply noted -- and I'm 11 going to check it right now -- that 49-501, I thought, 12 used the phrase general permit. 13 14 MR. FORCE: "The general permit shall include the following." 15 MR. GABRIELSON: Right. 602.D.1 allows for 16 residential burning, and F allows open outdoor fires -- 17 F still requires permits, but I guess between D and F 18 they're basically providing authority to issue these 19 permits. 20 MR. LEWANDOWSKI: 21 MR. GABRIELSON: I was still turning pages. D.1(c) requires a permit for 22 residential burning, and F allows for burning of 23 household waste when permitted in writing by the 24 Director. 25 the -- And the permits issued shall contain in So F really seems to be another species of ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 33 1 burning as defined in D.1 for a type of permit. 2 MR. LEWANDOWSKI: However, residential 3 burning does not include burning of household waste, 4 according to this definition. 5 MR. GABRIELSON: True. Okay. So F would 6 really seem to be more properly scheduled as another 7 paragraph under D.1. 8 9 MR. LEWANDOWSKI: Other than the fact that this legislature has given it special status in the 10 statute, we thought we needed to give it special status 11 in the rule. 12 13 MR. GABRIELSON: I guess my comment was really just editorial in nature anyway. 14 The other question I had that I haven't noted 15 here, I don't see anywhere in here where it defines the 16 term -- 17 a period not to exceed one year." 18 Oh, I see. In D.2, "Permits may be issued for MR. LEWANDOWSKI: Right. Some people get 19 annual burn permits because they do a lot of burning. 20 And, for example, you pay for an annual permit. 21 Whereas other people burn once and they don't want to 22 pay the $90 for the annual, so the shorter term is 23 offered there. 24 25 MR. GABRIELSON: And I guess, just as another comment, in D.3(g) there's a requirement that anybody ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 34 1 that lights a fire needs to notify either the local 2 fire fighting agency or the State Forester. 3 Again, I realize that DEQ has historically 4 issued on the order of 100 burn permits a year, more or 5 less. 6 And I just wonder, to the extent that this rule seems 7 to be substantially expanding the universe of people 8 who will be getting a permit from ADEQ, is the State 9 Forester prepared to get thousands of phone calls about 10 We've been issuing thousands in Pinal County. fires being lit? 11 MR. LEWANDOWSKI: The State Forester did 12 attend the Fire Emissions Work Group and was asked a 13 question very similar to that, and he sounded ready to 14 me. 15 going to be thousands. Although, I'm not sure he believed that there was 16 MR. MINCH: I think Curt said something to 17 the effect that there's a lot of land, area wise, and a 18 big area of the state that is not under any fire 19 district. So he had to do something for them. 20 MR. LEWANDOWSKI: 21 MR. HAWK: Ed Minch, M-i-n-c-h. What is the point of that 22 provision? 23 thing that somebody has to do, and for what public 24 purpose? 25 That just seems unnecessary. It's another They've gone and they've gotten the permit -MR. LEWANDOWSKI: Are you taking ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 35 1 unnecessary on the State Forester's part or the 2 notification period? 3 MR. HAWK: The notification period. They're 4 getting a permit, and what is having the fire chief 5 know that somebody is doing household burning or 6 whatever, what does that got to do with anything? 7 MR. LEWANDOWSKI: As I recall, one of the 8 things was that if somebody complains and calls up the 9 fire department, that way the fire department knows 10 ahead of time that it is an authorized burn or that it 11 is not. 12 citizen, we know about it, and they can be ready. In other words, they can tell the concerned 13 For example, if all the trucks are out at 14 some other place, they can at least start planning. 15 I recall, in the Fire Emissions Work Group, and, of 16 course, the fire departments were there, but they 17 thought they needed to have notice that that was going 18 to happen. 19 MR. MINCH: They didn't want to see the smoke 20 and then send their crew out there to find out it was 21 somebody who had a burn permit. 22 MR. HAWK: As So you want to make sure your 23 house doesn't catch on fire next to a permitted burn, 24 because they're going to say, "No problem. 25 a burn permit." They've got And then your house burns down because ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 36 1 2 nobody showed. MR. GABRIELSON: The two issues that I've 3 heard are the waste of resources phenomenon where they 4 don't want to go running out to fires that are legit. 5 And the other one is, in issuing the thousands 6 of burning permits -- 7 regulatory business, and I think the face of our burn 8 permit has the illusion of the fact that if you don't 9 properly manage this fire, you may be subject to all I'm in the air quality 10 sorts of civil consequences if you burn your house down 11 or your neighbor's house down or Central Arizona down. 12 But I've taken a hands-off position about 13 being in the fire safety business, because I'm not. 14 And to use the Apache Junction Fire District as an 15 example, there they actually require that the permits 16 be countersigned by the fire district. 17 the authority, as the fire marshal, to ban burning. 18 Whether I permit it or not, they can ban it. 19 bring the permit in to get it countersigned, they put a 20 big X through all of the burning permit conditions and 21 they staple their own sheet on that says here's what 22 you can do. 23 And they have When you So from a fire safety perspective, fire 24 supression organizations have a legitimate interest in 25 watching what's going on. Whether the State Forester ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 37 1 is meaningfully equipped to do that on a statewide 2 basis or not, I'm not so sure. 3 4 5 6 7 MR. LEWANDOWSKI: Well, we'll check with them. MR. GABRIELSON: Back to the one year. One year seems like a long time. MR. LEWANDOWSKI: As I recall, a lot of 8 permits have been issued for one year, and part of it 9 is just momentum. That's just the way we've done it. 10 DEQ doesn't charge for its permits. 11 want to start issuing a shorter permit -- 12 MR. GABRIELSON: I'm not sure if we On the other hand, if the 13 underlying motivation is to flush out the emission 14 inventory with regard to open burning activity for 15 purposes of coming up with a better picture of what you 16 need for the Regional Haze Rule, I seriously doubt 17 whether a one-year permit and an annual report is going 18 to get you anything approaching meaningful information. 19 MR. LEWANDOWSKI: As we discussed this rule, 20 we continually looked to a couple people at DEQ in 21 terms of, now do we have enough information collected 22 from this new rule to satisfy EPA. 23 So we're going to probably rely on their judgment. 24 25 And they said yes. In Yuma we got comments on not being able to -- delegated authority not to being able to issue ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 38 1 its own permit, or permit to itself. 2 dissatisfaction up there. 3 MR. HAWK: There was some Any thoughts about that? My personal view is that there's 4 no reason -- 5 In Yuma isn't it the fire district that's issuing the 6 permits? 7 that's issuing permits. It's not the fire district, it's Rural/Metro 8 9 I don't understand why that's the case. MR. GABRIELSON: Can they do that now, fire districts? 10 MR. LEWANDOWSKI: The private fire protection 11 service provider can be assigned -- 12 delegate it, but they're assigned delegated authority 13 by a government unit to issue open burn permits. 14 MR. HAWK: The phrase doesn't I think one of the things that 15 maybe we were concerned about, from a County 16 perspective, is if you have -- where we are, the air 17 quality control district can have a concern about air 18 quality in the region having jurisdictions issuing burn 19 permits, where that's not what their focus is. 20 there may be opportunities where people can burn under 21 pretexts, maybe, as a fire fighting exercise when maybe 22 you're clearing ranch land. 23 that, sort of that disinterested third party maybe. 24 25 MR. GABRIELSON: arise. That And having the control on That situation shouldn't I mean, to the extent that in Title 49 allows ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 39 1 the delegation to a fire supression organization, a 2 fire district -- a Title 48 fire district could issue 3 burn permits under the Uniform Fire Code. 4 Uniform Fire Code specifically provides for issuing 5 burn permits. 6 still get a burn permit under Title 49, you may need 7 two burn permits. 8 9 10 Because the To get a permit under Title 48 and to MR. HAWK: What about if I were a Title 48 permitter, I would think that my Title 48 permit would be sufficient and let somebody complain about it. 11 MR. GABRIELSON: 12 MR. LEWANDOWSKI: This is a surprisingly 13 complex area to do a rule. I've done rules in air 14 quality control for 25 years now, and you have to 15 encompass so many different needs and factors. 16 confident that we're going to end up with a better 17 rule. 18 MR. WALCH: You'd be wrong. So I'm Who can delegate it to the fire 19 district? Does it have to be ADEQ or the local fire 20 district? Is there anybody else other than those two 21 that can delegate it? 22 23 24 25 MR. LEWANDOWSKI: It's specified right in the statute. MR. HAWK: ADEQ delegates -- Excuse me. We wouldn't delegate our delegated authority to the fire ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 40 1 district. 2 3 We wouldn't have to, but we could. MR. LEWANDOWSKI: You wouldn't have to, but you could. 4 MR. HAWK: Like a subdelegation? 5 MR. LEWANDOWSKI: They call it an assignment. 6 For some reason they use the phrase assign. 7 person can't, perhaps, receive delegation, but they can 8 be assigned. 9 MR. GABRIELSON: A private I think 501.E says the 10 Director may delegate. 11 County would have an interest in delegating, at least 12 speaking for Pinal County. 13 MR. HAWK: I don't see any reason why a We can -- A County that has been 14 delegated the authority may assign the issuance of 15 these permits to a private fire protection service 16 provider that performs -- may assign the issuance of 17 these permits. 18 What does that mean? MR. GABRIELSON: That's looking to a County 19 that has delegated authority. 20 of this rule proposal is that Pinal, Pima, and Maricopa 21 County have statutory authority. 22 to get a delegation of authority under this rule. 23 We've got statutory authority. 24 25 And I think the premise And we're not going So if ADEQ delegates authority to Yavapai County, Yavapai County could then continue to delegate ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 41 1 on down the chain. 2 Pima County could delegate under that, unless you want 3 to go to ADEQ and get a delegation in the first place. 4 It's renounced the statutory authority to delegated 5 authority. 6 7 8 9 But I don't read this to say that MR. FORCE: I don't think you could do that. If you have independent statutory authority -MR. GABRIELSON: position that we've taken. Well, that's at least the And that's all predicated 10 on Mark's initial comment about 49-501 is an 11 interesting statute, that if you hold it up to the 12 light and turn it just right, you can understand it. 13 MR. FORCE: If you have independent statutory 14 authority, then you would have been granted also the 15 power also to delegate authority. 16 MR. GABRIELSON: 17 MR. HAWK: 18 MR. LEWANDOWSKI: Sounds good to me. Specific authority. The original question, 19 Larry, was what does that mean. 20 goes on and on and on. 21 as delegated, but the receiver is a private entity 22 rather than a government entity. 23 24 25 MR. HAWK: Actually, that statute To me, assigned means the same And they're doing certain things. I wanted to read more of that. In the delegation agreements, ADEQ uses terms ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 42 1 -- uses the term subdelegation, I believe, as I recall. 2 MR. LEWANDOWSKI: Any more questions? 3 MR. GABRIELSON: 4 HEARING OFFICER MAHADEV: Nope. 5 to the oral comments. 6 County will now make his comment. 7 8 9 10 11 Not here. Let's proceed now Mr. Don Gabrielson from Pinal MR. GABRIELSON: I will defer my comments and provide them in writing. HEARING OFFICER MAHADEV: Is there anybody else who wants to make any comments? There's no further oral comments, so I'm 12 going to close the oral comment period of this 13 proceeding. 14 I encourage everyone to submit written 15 comments on the proposed rulemaking. 16 that all comments must be received no later than 17 5:00 p.m. on Friday, October 24th, 2003. 18 19 20 Thank you all for attending. Please remember The time is now 2:40, and I'll close this proceeding. (The public hearing concluded at 2:40 p.m.) 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-21-2003 43 1 STATE OF ARIZONA 2 COUNTY OF MARICOPA ) ) ss. ) 3 4 5 6 I, KATHRYN A. BLACKWELDER, Certified Court 7 Reporter No. 50666 for the State of Arizona, do hereby 8 certify that the foregoing printed pages constitute a 9 full, true and accurate transcript of the proceedings 10 had in the foregoing matter, all done to the best of 11 my skill and ability. 12 13 WITNESS my hand this 5th day of November, 2003. 14 15 16 17 ___________________________ KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 W. Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director AGENDA Air Quality Division Regional Haze State Implementation Plan Development PUBLIC HEARING/ORAL PROCEEDING October 22, 2003, 1:30 p.m. Show Low City Hall, Council Chambers 200 West Cooley, Show Low, Arizona Pursuant to [cite 40 CFR § 51.102 for SIP hearings and ARS § 49-425 for air quality rule hearings], notice is hereby given that the above referenced meeting is open to the public. Welcome and Introductions Purposes of the Oral Proceeding/Procedures for Making Public Comment Brief Overview of the Proposed Rule Question and Answer Period Oral Comment Period Adjournment of Oral Proceeding Comment period ends 5:00 p.m., Friday, October 24, 2003. Please direct comments and questions to Kevin Force, ADEQ Air Quality Division, at (602) 7714480 or 1-800-234-5677, Ext. 771-4480. Order of agenda items is subject to change. For additional information regarding the meeting, please call [NAME], ADEQ Air Quality Division, at (602) 771-[ ] or 1-800-234-5677, Ext. [ ]. Persons with a disability may request a reasonable accommodation such as a sign language interpreter, by contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 4794. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829. Northern Regional Office Southern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 400 West Congress Street • Suite 433 • Tucson, AZ 86004 85701 (928) 779-0313 (520) 628-6733 Printed on recycled paper PUBLIC HEARING 10-22-2003 1 1 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 2 3 4 5 6 IN THE MATTER OF THE PROPOSED ) REVISIONS TO ARIZONA ) PUBLIC HEARING ADMINISTRATIVE CODE R18-2-602, ) THE UNLAWFUL OPEN BURNING RULE, ) AND ARTICLE 15, THE RULES ) COVERING FOREST AND RANGE ) MANAGEMENT BURNS. ) _________________________________) 7 8 9 10 11 12 At: Show Low, Arizona 13 Date: October 22, 2003 14 Filed: 15 16 REPORTER'S TRANSCRIPT OF PROCEEDINGS 17 18 19 20 ARIZONA REPORTING SERVICE, INC. Court Reporting Suite Three 2627 North Third Street Phoenix, Arizona 85004-1126 21 22 23 By: Prepared for: 24 KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 ADEQ 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 2 1 BE IT REMEMBERED that the above-entitled and 2 numbered matter came on regularly to be heard before 3 the Arizona Department of Environmental Quality, at the 4 Show Low City Hall, Council Chambers, 200 West Cooley, 5 Show Low, Arizona, commencing at 1:30 p.m. on the 22nd 6 day of October, 2003. 7 BEFORE: BRUCE FRIEDL, HEARING OFFICER 8 9 10 APPEARANCES: THERESA PELLA, Air Planning Section Manager, on behalf of ADEQ; 11 12 KEVIN FORCE, Rule Writer, Planning Section, on behalf of ADEQ. 13 14 KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 15 16 17 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 3 1 HEARING OFFICER FRIEDL: Good afternoon, and 2 welcome to this Arizona Department of Environmental 3 Quality hearing. 4 The subject of this hearing is proposed 5 revisions to Arizona Administrative Code R18-2-602, the 6 "Unlawful Open Burning Rule," and Article 15, the rules 7 covering "Forest and Range Management Burns." 8 hearing is now open. 9 The The date is Wednesday, October 22nd, 2003, 10 and the time is 1:35 p.m. 11 Chambers of the Show Low City Hall at 200 West Cooley, 12 Show Low, Arizona 85901. 13 The location is the Council My name is Bruce Friedl. I'm an 14 Environmental Programs Specialist for the Planning 15 Section of the Air Quality Division at ADEQ, and I have 16 been appointed by the ADEQ Director to conduct this 17 hearing. 18 The purposes of this hearing are to provide 19 the public an opportunity, one, to hear about the 20 substance of the proposed revisions to the Arizona 21 Administrative Code R18-2-602 and Article 15; two, to 22 ask questions concerning the proposed rule revisions; 23 and three, to present oral arguments, data, and views 24 concerning the proposed rule revisions, in the form of 25 comments on the record. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 4 1 Other ADEQ Air Quality representatives in 2 attendance today are Theresa Pella to my left, Air 3 Quality Planning Section Manager, and Kevin Force, Rule 4 Writer, Planning Section. 5 Byron James, Community Liaison in the ADEQ Northern 6 Regional Office. 7 Kathryn Blackwelder. 8 9 And in the back of the room Also present is our court reporter, If you plan to make a public comment on the record, the procedure is straightforward. Please 10 complete a speaker slip found at the sign-in table and 11 hand your slip to me. 12 everyone the opportunity to be heard and allows us to 13 match the name on the official record with the 14 comments. Using speaker slips allows 15 You may also submit written comments to me 16 today in person, or you may submit comments by mail, 17 e-mail, or fax. 18 the comment period, 5:00 p.m. on Friday, October 24th, 19 2003. 20 than October 24th, 2003. 21 to Kevin Force, K-e-v-i-n F-o-r-c-e, Air Quality 22 Planning Section, Arizona Department of Environmental 23 Quality, 1110 West Washington Street, Third Floor, 24 Phoenix, Arizona 85007. 25 You can e-mail to force.kevin@ev.state.az.us. Please submit comments by the end of Any written comment must be received no later Submit your written comments Or by fax at 602-771-2366. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 5 1 Notice of this hearing was published in The 2 Arizona Republic and The White Mountain Independent on 3 September 19th, 2003. 4 State statutes require that comments made 5 during the formal comment period be considered by ADEQ 6 in the preparation of a final rule, in which the 7 Department responds in writing to written and oral 8 comments made during the formal comment period. 9 The agenda for this hearing is simple. 10 First, I will ask Theresa Pella to provide an overview 11 of the proposed rulemaking. 12 Second, I will conduct a question and answer 13 period. 14 is to provide information that may help you in making 15 comments on the rulemaking. 16 The purpose of the question and answer period Third, I will conduct an oral comment period. 17 At that time, I will call speakers in the order in 18 which I have received their speaker slips. 19 Please be aware that any comments that you 20 want the Department to formally consider must be given 21 either in writing or on the record during the oral 22 comment period of this proceeding. 23 At this time Theresa Pella will give a brief 24 overview of the background concerning ADEQ's proposed 25 revisions to A.A.C. R18-2-602 and Article 15. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 6 1 MS. PELLA: Thank you. And again, welcome, 2 everybody. 3 your day to attend this public hearing. 4 Thank you for coming and taking time out of These proposed rules would amend Arizona's 5 existing open burning and prescribed burning rules to 6 make them conform to EPA requirements for states' 7 Regional Haze State Implementation Plans, otherwise 8 known as SIPs. 9 other technical changes, including improvements to the 10 11 In addition, these amendments make rules' clarity, conciseness, and understandability. The revisions to R18-2-602, which is our 12 Unlawful Open Burning Rule section of the regulation, 13 and Article 15, which is the Smoke and Range Management 14 Rule, will be included in the state's Regional Haze 15 SIP, which ADEQ is required to submit to EPA by 16 December 31st of 2003. 17 In early 2002, ADEQ formed a Fire Emissions 18 Work Group to discuss visibility issues related to fire 19 emissions and make recommendations to ADEQ regarding 20 necessary changes to the rules. 21 rule, that you have in front of you, is a joint effort 22 of ADEQ and the Fire Emissions Work Group based on 23 input received at not only the Work Group meetings, but 24 also a series of public meetings that we held 25 throughout the state earlier this year. ARIZONA REPORTING SERVICE, INC. The current proposed I believe it (602) 274-9944 PUBLIC HEARING 10-22-2003 7 1 was in April. So what we've got in front of us is a 2 result of those meetings and the Work Group's efforts. 3 The specific requirements for state Regional 4 Haze SIPs can be found at Title 40, Code of Federal 5 Regulations Chapter 51.308 and 51.309. 6 most notably, greater tracking and monitoring 7 requirements of open burning and burn plans, regular 8 evaluation of such data that comes from burning, and 9 the establishment of annual emission goals under the 10 Smoke and Range Management Rules in cooperation with 11 States, tribes, Federal land management agencies, and 12 private entities that do prescribed burns. 13 They include, Changes to R18-2-602, again, the Unlawful 14 Open Burning Rule of our rules, are not extensive. 15 However, we did -- you'll notice we did kind of strike 16 out the entire rule as it exists and kind of did a new 17 underlying rule. 18 improving the understandability and the flow of the 19 rule. 20 version, it doesn't mean that the content and the 21 substance of the rule was changed that much from the 22 original version. 23 And we basically did that mostly for So even though you see a completely stricken This proposed rule contains some additional 24 definitions that have been added in a separate 25 subsection, including definitions for various ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 8 1 categories of open burning, such as agricultural, 2 construction, and residential. 3 new definitions for "delegated authority," "independent 4 authority to permit fires," and "prohibited materials." In addition, there are 5 The proposed rule revisions also clarify 6 which open burning activities require open burning 7 permits and those that are exempt from having to obtain 8 a permit. 9 information that's required to be in the permit itself. It also contains a more complete list of 10 This is both for more efficient permit administration 11 from ADEQ's side and to comply with the various aspects 12 of the Regional Haze Rule as it is contained in 40 CFR 13 51.309. 14 ADEQ has also added in the language in the 15 proposed rule revisions clarifying that the state rule 16 is not applicable in counties with independent 17 authority to permit fires. 18 counties in Arizona of which that is the case, and 19 those three counties are Maricopa, Pima, and Pinal 20 Counties, that are also identified in that particular 21 definition. 22 their own rules that have permit -- require permits for 23 open outdoor fires, other than dangerous materials. 24 25 And there are three The three counties referenced all have ADEQ considered exempting certain fires under which air curtain destructors are used from the open ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 9 1 burning permit requirement in order to remove what's 2 considered an administrative barrier to this type of 3 burning, as is contained in the Regional Haze Rule. 4 However, after reviewing two studies and getting input 5 from the Work Group and also the public meetings that 6 we had, ADEQ decided that the air curtain destructors 7 do require some oversight, and so it's appropriate that 8 they be permitted, as well as other open burning 9 activities. So ADEQ does not view this requirement, 10 that air curtain destructors obtain a permit, as an 11 administrative barrier, though, to operation of such. 12 Moving on to Article 15, the Smoke and Range 13 Management portion of our rule. 14 to this article are such that ADEQ is trying to better 15 conform to, again, the Federal Regional Haze Rule 16 requirements to make the article more understandable, 17 and to facilitate enhanced compliance by those 18 organizations that do prescribed burns. 19 The proposed revisions Most of the proposed changes to the article 20 directly reflect the mandates in the federal rule, 21 particularly those relating to the collection and 22 recording of burn data from such burns, the evaluation 23 of burn programs, and the setting of annual emission 24 goals. 25 intact. The former structure of the rule remains You've got the annual registration which the ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 10 1 organization needs to submit to DEQ, the submittal of a 2 Burn Plan At least 14 days before any burn begins, and 3 a daily Burn Request that is also submitted to DEQ, and 4 a Burn Accomplishment Form, which is submitted after 5 the fire to gather information related to how many 6 acres were burned and that sort of stuff. 7 Article 15 relates to prescribed burns, and R18-2-602 8 relates to the Unlawful Open Burning Rule. 9 10 This concludes the overview of the proposed rulemaking. 11 12 HEARING OFFICER FRIEDL: Does anybody have any questions on the rule 14 revisions? 15 please? 17 18 19 Next, we'll move to the question and answer period. 13 16 So again, Would you state your name for the record, MR. ESSWEIN: My name is Paul Esswein and I'm from Pine Top/Lakeside. I have a question on the open burning permit section, paragraph D3 -- 20 MR. FORCE: 21 MR. ESSWEIN: Paragraph what? It's paragraph D3.d.3. The 22 question I have is, is there a definition of nuisance 23 in the rule anywhere? 24 25 MS. PELLA: No, there probably isn't. Nuisance is one of those words that according to -ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 11 1 well, sometimes we go by Webster's. If there's a clear 2 definition in Webster's that a reasonable person would 3 understand, then we don't do a special definition in 4 our rules. 5 nuisance to be one of those words. And in this instance, we've considered 6 Do you think that it should be? 7 MR. ESSWEIN: 8 9 10 I think it should be defined or have some standard for defining it. MS. PELLA: Okay. Would you repeat that during the oral comment period? 11 MR. ESSWEIN: Yes. 12 I have another question on the next 13 paragraph, it's D3.e, and it indicates that there's a 14 reporting requirement for all open burning permits. 15 I'm just curious as to how, on residential 16 burns, that information is going to be collected and 17 how the material that's burned is measured? 18 MR. FORCE: 19 MR. ESSWEIN: 20 MR. FORCE: You're talking about 3.f? It's f. I'm sorry. For residential burns, that is 21 going to be difficult. We're sort of trusting the 22 permitted person. 23 that they notify the fire department. 24 fire district in their area, they are to notify the 25 State Forester so that someone is aware of the fact There's a notification requirement ARIZONA REPORTING SERVICE, INC. If there's no (602) 274-9944 PUBLIC HEARING 10-22-2003 12 1 that a burn is taking place. 2 fire departments, in that situation, will be able to 3 forward that information to us. 4 burner. 5 MS. PELLA: I don't think that the There is -- It's up to the actual Right. That's where 6 the delegated authority is going to come into place. 7 And I think this is actually a comment that was raised 8 at one of the previous meetings. 9 hearing in Yuma on Monday and in Casa Grande yesterday, We had a public 10 and I think there was a similar question that came up. 11 So again, it will be something that we'll be 12 considering and looking at again as we go back to the 13 final rulemaking stage. 14 MR. JAMES: I was on the Fire Emissions Work 15 Group that helped to draft the rules and so forth, and 16 one of the ways in which -- 17 Federal Regional Haze criteria so that our State 18 implementation plan could be improved. 19 things we needed to do was have some sort of feedback, 20 because we had no idea how much open burning actually 21 took place. 22 we had to have something like that in there. 23 We needed to meet the And one of the So to meet the regional haze requirements And the goal of the Fire Emissions Work 24 Group, even though there needs to be a feedback 25 requirement, is to make it as simple as possible. ARIZONA REPORTING SERVICE, INC. And (602) 274-9944 PUBLIC HEARING 10-22-2003 13 1 in the development of the program, there would be ways 2 to try to make that simple, either through a phone 3 call, a message with ADEQ on a toll-free phone number, 4 where you could just say, "Hey, I burned today, this is 5 how much I burned," and leave it at that and make it 6 very simple. 7 form how to accomplish that. 8 9 And it would actually say on the permit MS. PELLA: Right. Yeah. That's one of the options that we've been considering. 10 MR. MOLENHAUR: I have a question here on the 11 unlawful burning. 12 burn, one hour after sunrise to two hours before 13 sunset. 14 an open burn permit. 15 and DEQ says, "You can't have them. 16 different periods of the year at different times of the 17 day." 18 morning to 2:00 in the afternoon. 19 They list the hours that you can I'm from Abbott Tibbey Consolidated. We have We've tried to get these hours, You can only burn And right now they have, like, from 10:00 in the Well, up here you have problems with winds 20 blowing, in the morning it's fairly calm. 21 miles out of town. 22 model in Yuma, so these are the hours you have." 23 We're 15 And they tell me, "Well, we do the If this is basically the same regulations 24 that exist now, why are these hours allowed in this and 25 not at the present time? ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 14 1 MS. PELLA: 2 hours in our proposal? 3 we did. You mean we're extending the I'm trying to find -- 4 MR. MOLENHAUR: 5 MS. PELLA: I think It's 602.D3.c. Right. This is another thing 6 that came up during our public meetings, was the fact 7 that different parts of the state, the environment 8 isn't the same. 9 year-round it's one hour after sunrise or two hours 10 So, yeah, here under D3.c, for before sunset. 11 MR. MOLENHAUR: 12 MS. PELLA: 13 MR. MOLENHAUR: Yes. Is that posing a problem? No. I mean, that's 14 beneficial. 15 tell us we can't have this time right now. 16 MS. PELLA: 17 improvement. 18 197- -- 19 20 Well, look at it as an Those current regs were written in MR. MOLENHAUR: There is nothing that restricts the time at the present time. 21 22 It's not in the current regs, yet they MS. PELLA: But I think it's up to the discretion of DEQ right now, correct? 23 MR. MOLENHAUR: Well, every year we get a new 24 permit. Every year we've gone back to -- well, they 25 bounce between Phoenix and Flagstaff -- and we say, ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 15 1 "We'd like the extended hours that we had last year." 2 And every year up until this year they've said okay. 3 This year they say, "No. 4 regulations. 5 it by reading anything. 6 You can't have it." MR. JAMES: It's in the And yet I can't find At the present time, the hours of 7 burning are in the ADEQ guidelines. And one of the 8 goals of the Fire Emissions Work Group was to put those 9 guidelines into rule so that we apply them 10 consistently. 11 in the rule allows a longer time period than what the 12 guidelines currently specify. 13 And you're right, the way it's written MS. PELLA: We're actually trying -- This is 14 one of the ways where we could make it easier for the 15 regulating community as well as us. 16 MR. FORCE: The rules try to incorporate all 17 those guidelines so that there's only one source for 18 the authority in this case. 19 MR. MOLENHAUR: Well, that may or may not be 20 good. It depends on if you're in the middle of Phoenix 21 or if you're 15 miles from town when you're doing your 22 open burning. 23 24 25 MS. PELLA: They don't do open burning in Phoenix. MR. MOLENHAUR: But, I mean, if you're in the ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 16 1 middle of town or if you're 15 miles from town, to say 2 one thing fits all, that's why I could see why they 3 would have discretion on doing things. 4 can't get that at the present time -- 5 6 MS. PELLA: HEARING OFFICER FRIEDL: Are there any other questions? 9 10 As I indicated, the current regs are very old. 7 8 But why you Next we'll move on to the oral comment period. 11 And the first speaker slip is Mr. Jack Babb. MR. BABB: Maybe I should have asked during 12 the question and answer period, but I tried to get this 13 off the Internet and wasn't able to download it, for 14 whatever reason. 15 it just now. 16 So I've just been able to glance at A little confusion has come up. Currently, 17 State permits are issued for a specific length of time. 18 Is there going to be a change to that? 19 20 MR. FORCE: Are you asking regarding the Open Burning Rule? 21 MR. BABB: 22 MR. FORCE: Yes, sir. I think that there's a limitation 23 -- a term limit of one year for the open burning 24 permits. 25 MR. BABB: Because I read in here something ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 17 1 that a daily request has to be made. 2 MR. FORCE: Is that -- Those are for prescribed burn 3 plans. The daily burn request is for a prescribed burn 4 plan for wildland fire use. 5 permit, the term limit is one year. 6 MR. BABB: For an open burning Well, to the prescribed burn 7 limits, ADEQ is looking to request or require a daily 8 burn plan? 9 MR. FORCE: Well, first, there's a burn plan 10 that's required to be filed with ADEQ no later than 14 11 days before the proposed planned burn. 12 get to the actual burn activities, you submit a daily 13 burn request to ADEQ with the pertinent information 14 that's listed in the rule. 15 Then when you Now, the request in this case is really more 16 of a formality. 17 gather information for the purposes of satisfying the 18 Federal Regional Haze Rules. 19 question -- 20 being burned, how much is being burned. 21 As Byron was saying, we're trying to It's more of a We need the data about the burn, what is MS. PELLA: They actually do a daily call-in 22 now. The Federal Land Managers, when they do 23 prescribed burns, they're calling in daily to ADEQ now. 24 MR. BABB: 25 MS. PELLA: So that would remain? That would remain. ARIZONA REPORTING SERVICE, INC. What we would (602) 274-9944 PUBLIC HEARING 10-22-2003 18 1 be asking for is a little bit more information that -- 2 we will make a concerted effort to gather information 3 related to what's being burned, how many acres, that 4 type of stuff, in order to fulfill our federal tracking 5 requirements. 6 7 MR. BABB: You may want to consider changing that to a final report after the burn. 8 MS. PELLA: There is -- 9 MR. FORCE: There is a final report. 10 MR. BABB: Because to come in daily with the 11 areas changing and topography and climate and so forth, 12 it may be difficult for the range managers or fire 13 operations officers to go in and say, this is how much 14 we plan on burning, this is the types of fuels, and so 15 forth. 16 rain in all of a sudden, or because of a change in 17 topography and fuels, it may explode on you. 18 remaining within the confines of their prescription, 19 but it may burn more than what they anticipated for 20 that burn period. 21 It may be reduced drastically because we get a MS. PELLA: Right. Still I'm trying to find the 22 exact spot in Article 15 where it requires a kind of 23 end-of-the-project type report. 24 25 MR. FORCE: It's the burn accomplishment report. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 19 1 MS. PELLA: What section? 2 MR. FORCE: That is 1507. 3 MS. PELLA: It's in there, but your point is 4 very well taken. 5 6 MR. BABB: allowed for up to one year? 7 MR. FORCE: 8 MR. BABB: 9 And you did say permits would be For open burning. One of the things that we look at, from the fire department standpoint, is anybody with an 10 adopted code has got specific regulations to open 11 burning, permitting, and so forth. 12 fire department also uses the same code to administer 13 open burning training such as wildland training for one 14 day. 15 event-by-event basis may be difficult, whereas if we 16 obtained the permit for one year for a general area 17 rather than a specific location, that would be more 18 beneficial overall. 19 20 But then again, the And for us to go in and try to get a permit on an MS. PELLA: We received that exact comment at one of the other public hearings. 21 MR. FORCE: About training. 22 MS. PELLA: I don't know what you guys -- how 23 24 25 you dealt with it in Yuma. We'll make sure that when we do our final analysis of the rule that we especially list out that ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 20 1 particular item and our response to it. 2 MR. BABB: 3 HEARING OFFICER FRIEDL: 4 5 Okay. Thank you. I believe the gentleman in the back, Mr. Paul Esswein, had something. MR. ESSWEIN: I would like to suggest that 6 the Department consider adding a definition for the 7 word nuisance under the open burning section of the 8 rule and provide some standard for how that is applied. 9 MS. PELLA: Okay. 10 HEARING OFFICER FRIEDL: 11 Does anybody else want to make a comment on 12 13 14 15 Thank you. the record? This concludes the oral comment period of this proceeding. I encourage everyone to submit written 16 comments on the proposed rulemaking. 17 that all comments must be received no later than 18 5:00 p.m. on Friday, October 24th, 2003. 19 20 21 Thank you for attending. Please remember The time is now 2:03, and I now close this oral proceeding. (The public hearing concluded at 2:03 p.m.) 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-22-2003 21 1 STATE OF ARIZONA 2 COUNTY OF MARICOPA ) ) ss. ) 3 4 5 6 I, KATHRYN A. BLACKWELDER, Certified Court 7 Reporter No. 50666 for the State of Arizona, do hereby 8 certify that the foregoing printed pages constitute a 9 full, true and accurate transcript of the proceedings 10 had in the foregoing matter, all done to the best of 11 my skill and ability. 12 13 WITNESS my hand this 5th day of November, 2003. 14 15 16 17 ___________________________ KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Janet Napolitano Governor 1110 W. Washington Street • Phoenix, Arizona 85007 (602) 771-2300 • www.adeq.state.az.us Stephen A. Owens Director AGENDA Air Quality Division Regional Haze State Implementation Plan Development PUBLIC HEARING/ORAL PROCEEDING October 23, 2003, 1:30 p.m. Flagstaff City-Coconino County Public Library 300 West Aspen, Flagstaff, Arizona Pursuant to [cite 40 CFR § 51.102 for SIP hearings and ARS § 49-425 for air quality rule hearings], notice is hereby given that the above referenced meeting is open to the public. Welcome and Introductions Purposes of the Oral Proceeding/Procedures for Making Public Comment Brief Overview of the Proposed Rule Question and Answer Period Oral Comment Period Adjournment of Oral Proceeding Comment period ends 5:00 p.m., Friday, October 24, 2003. Please direct comments and questions to Kevin Force, ADEQ Air Quality Division, at (602) 7714480 or 1-800-234-5677, Ext. 771-4480. Order of agenda items is subject to change. For additional information regarding the meeting, please call [NAME], ADEQ Air Quality Division, at (602) 771-[ ] or 1-800-234-5677, Ext. [ ]. Persons with a disability may request a reasonable accommodation such as a sign language interpreter, by contacting Katie Huebner at (602) 771-4794 or 1-800-234-5677, Ext. 4794. Requests should be made as early as possible to allow sufficient time to make the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829. Northern Regional Office Southern Regional Office 1515 East Cedar Avenue • Suite F • Flagstaff, AZ 400 West Congress Street • Suite 433 • Tucson, AZ 86004 85701 (928) 779-0313 (520) 628-6733 Printed on recycled paper PUBLIC HEARING 10-23-2003 1 1 ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY 2 3 4 5 6 IN THE MATTER OF THE PROPOSED ) REVISIONS TO ARIZONA ) PUBLIC HEARING ADMINISTRATIVE CODE R18-2-602, ) THE UNLAWFUL OPEN BURNING RULE, ) AND ARTICLE 15, THE RULES ) COVERING FOREST AND RANGE ) MANAGEMENT BURNS. ) _________________________________) 7 8 9 10 11 12 At: Flagstaff, Arizona 13 Date: October 23, 2003 14 Filed: 15 16 REPORTER'S TRANSCRIPT OF PROCEEDINGS 17 18 19 20 ARIZONA REPORTING SERVICE, INC. Court Reporting Suite Three 2627 North Third Street Phoenix, Arizona 85004-1126 21 22 23 By: Prepared for: 24 KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 ADEQ 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 2 1 BE IT REMEMBERED that the above-entitled and 2 numbered matter came on regularly to be heard before 3 the Arizona Department of Environmental Quality, at the 4 Flagstaff City-Coconino County Public Library, 300 West 5 Aspen, Flagstaff, Arizona, commencing at 1:30 p.m. on 6 the 23rd day of October, 2003. 7 BEFORE: BRUCE FRIEDL, HEARING OFFICER 8 9 10 APPEARANCES: THERESA PELLA, Air Planning Section Manager, on behalf of ADEQ; 11 12 KEVIN FORCE, Rule Writer, Planning Section, on behalf of ADEQ. 13 14 KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 15 16 17 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 3 1 HEARING OFFICER FRIEDL: Good afternoon. 2 Welcome to this Arizona Department of Environmental 3 Quality hearing. 4 The subject of this hearing is proposed 5 revisions to Arizona Administrative Code R18-2-602, the 6 "Unlawful Open Burning Rule," and Article 15, the rules 7 covering "Forest and Range Management Burns." 8 hearing is now open. 9 The The date is Thursday, October 23rd, 2003, and 10 the time is 1:36 p.m. 11 Flagstaff-Coconino County Public Library at 300 West 12 Aspen, Flagstaff, Arizona 86001. 13 The location is the My name is Bruce Friedl and I'm an 14 Environmental Programs Specialist for the Planning 15 Section of the Air Quality Division at ADEQ, and I have 16 been appointed by the ADEQ Director to conduct this 17 hearing. 18 The purposes of this hearing are to provide 19 the public an opportunity to hear about the substance 20 of the proposed revisions to the Arizona Administrative 21 Code R18-2-602 and Article 15; two, to ask questions 22 concerning the proposed rule revisions; and three, to 23 present oral arguments, data, and views concerning the 24 proposed rule revisions in the form of comments on the 25 record. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 4 1 Other ADEQ Air Quality representatives in 2 attendance today are Theresa Pella, Air Quality 3 Planning Section Manager, and Kevin Force, Rule Writer, 4 Planning Section. 5 Kathryn Blackwelder. 6 Also present is our court reporter, If you plan to make a public comment on the 7 record, the procedure is straightforward. Please 8 complete a speaker slip found at the sign-in table and 9 hand your slip to me. Using speaker slips allows 10 everyone an opportunity to be heard and allows us to 11 match the name on the official record with the 12 comments. 13 You may also submit written comments to me 14 today in person, or you may submit comments by mail, 15 e-mail, or fax. 16 the comment period, 5:00 p.m. on Friday, October 24th, 17 2003. 18 than October 24th, 2003. 19 Please submit comments by the end of Any written comment must be received no later Submit your written comments to Kevin Force, 20 K-e-v-i-n F-o-r-c-e, Air Quality Planning Section, 21 Arizona Department of Environmental Quality, 1110 West 22 Washington Street, Third Floor, Phoenix, Arizona 85007. 23 The fax number is 602-771-2366. 24 comments to force.kevin@ev.state.az.us. 25 You can e-mail written Notice of this hearing was published in The ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 5 1 Arizona Republic and The Arizona Daily Sun on September 2 19, 2003. 3 State statutes require that comments made 4 during the formal comment period be considered by ADEQ 5 in the preparation of a final rule, in which the 6 Department responds in writing to written and oral 7 comments made during the formal comment period. 8 9 10 The agenda for this hearing is simple. First, I will ask Theresa Pella to provide an overview of the proposed rulemaking. 11 Second, I will conduct a question and answer 12 period. 13 is to provide information that may help you in making 14 comments on the rulemaking. 15 The purpose of the question and answer period Third, I will conduct an oral comment period. 16 At that time, I will call speakers in the order in 17 which I have received their speaker slips. 18 Please be aware that any comments you make at 19 today's hearing that you want the Department to 20 formally consider must be given either in writing or on 21 the record during the oral comment period of this 22 proceeding. 23 At this time, Theresa Pella will give a brief 24 overview of the background concerning the ADEQ's 25 proposed revisions to A.A.C. R18-2-602 and Article 15. ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 6 1 MS. PELLA: Thank you, and welcome. For 2 those of you who are here, thank you for joining us 3 this afternoon and taking time out of your busy 4 schedules. 5 These proposed rules would amend Arizona's 6 existing open burning rule R18-2-602, Unlawful Open 7 Burning, and the prescribed burning rules under Article 8 15, which are also known as the Smoke and Range 9 Management Fire Rules, to make the rules conform to 10 EPA's requirements for states' Regional Haze State 11 Implementation Plans, or SIPs, as we call them. 12 addition, these amendments make other technical 13 changes, including improving the rules' clarity, 14 conciseness, and understandability. 15 In The revisions to R18-2-602 and Article 15 16 will be included in the state's Regional Haze SIP, 17 which ADEQ is required to submit to EPA by 18 December 31st, 2003. 19 In early 2002, ADEQ formed a Fire Emissions 20 Work Group to discuss visibility issues related to fire 21 emissions and make recommendations to ADEQ regarding 22 necessary changes to the rules. 23 rule is a joint effort of ADEQ and the Fire Emissions 24 Work Group, based on input received from the Work Group 25 meetings and public meetings that were held earlier ARIZONA REPORTING SERVICE, INC. The current proposed (602) 274-9944 PUBLIC HEARING 10-23-2003 7 1 this year in Yuma, Casa Grande, Show Low, and 2 Flagstaff. 3 The specific requirements for state Regional 4 Haze SIPs can be found at Title 40, Code of Federal 5 Regulations Sections 51.308 and 51.309 and include, 6 most notably, more complete tracking and monitoring of 7 open burning and burn plans, periodic review of the 8 data collected by DEQ, and the establishment of annual 9 emission goals for fire, in cooperation with States, 10 tribes, Federal land management agencies, and private 11 entities. 12 of Environmental Quality does not have jurisdiction on 13 tribal land, but the tribes have been participating. 14 But they would need to adopt their separate rules. 15 It should be noted that Arizona Department Changes to R18-2-602, the Unlawful Open 16 Burning Rule, are not extensive, although the current 17 rule has been completely stricken. 18 revisions was to write the rule in a more clear manner 19 that's easier to follow than the current rule. 20 what we've done is added a definitions subsection and 21 included definitions for various categories of open 22 burning, such as agricultural, construction, and 23 residential. 24 for "delegated authority," "independent authority to 25 permit fires," and "prohibited materials." The intent of the And so In addition, there are new definitions ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 8 1 The proposed rule revisions also clarifies 2 which open burning activities require open burning 3 permits and those activities that are exempt from a 4 permit. 5 information that is required to be in the permit. 6 is both for more efficient permit administration by the 7 DEQ and its delegated authority and to comply with 8 various aspects of the Regional Haze Rule. It also contains a more complete list of This 9 ADEQ has also added language in the proposed 10 rule clarifying that the state rule is not -- will not 11 operate in counties with independent authority to 12 permit fires, and has listed those three counties, 13 which are Maricopa, Pima, and Pinal. 14 counties all have their own rules that allow for 15 permitting for open outdoor fires, other than danger 16 materials. 17 Those three ADEQ considered exempting fires using air 18 curtain destructors from the open burning permit 19 requirement in 602 in order to remove an administrative 20 barrier to this type of burning. 21 administrative barriers and what are alternatives is 22 required in the Federal Regional Haze Rule under 40 CFR 23 51.309(d)(6)(iii). 24 studies and public meetings that we had, ADEQ decided 25 that the air curtain destructors do require oversight The identification of However, after reviewing two ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 9 1 and it is appropriate that they be subject to permits. 2 So they are included as having to obtain a permit under 3 this proposed rule. 4 that air curtain destructors obtain a permit as an 5 administrative barrier. 6 ADEQ does not view the requirement To comply to the federal rule, the proposed 7 revisions to Article 15 of Title 18, Chapter 2, the 8 Forest and Range Management Burns Article, is made to 9 -- or, the changes are made to better conform to EPA's 10 regional haze requirements to again, hopefully, be more 11 understandable to both the community and the regulators 12 and to facilitate enhanced compliance with the rule. 13 Most of the proposed changes to Article 15 14 directly reflect the mandates of the federal rule, 15 particularly those relating to the collection and 16 recording of burn data, the evaluation of burn 17 programs, and the establishment of annual emission 18 goals. 19 intact. 20 those who burn, there's a submittal of a Burn Plan that 21 needs to be submitted to ADEQ at least 14 days before a 22 burn, there's a daily Burn Request that the burner will 23 submit to ADEQ, and there's a Burn Accomplishment Form 24 at the end of the project that's submitted to ADEQ. 25 The former structure of the rule remains That is, there's an annual registration by The Article 15 rule applies primarily to ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 10 1 federal and state land managers, as those are the ones 2 within the state of Arizona that do prescribed burns. 3 However, there may be some private burners that Article 4 15 may also apply to. 5 Article 15 does not apply to burns that are completed 6 on tribal lands. 7 8 HEARING OFFICER FRIEDL: Thank you. Next we'll move to the question and answer period. 9 10 And as I indicated earlier, Does anybody have any questions on the rule revisions? 11 MR. MACAULEY: I'm a private landowner, I 12 have a ranch, and I'm doing -- we've been doing burns 13 for 60 years. 14 MS. PELLA: Uh-huh. 15 MR. MACAULEY: You talk about increasing my 16 paperwork burden, this makes it exponential. 17 spend more time doing paperwork than I will burning. 18 19 20 21 22 23 24 25 MS. PELLA: now? I'll What's the process you have to do And Article 15 would apply to you? MR. MACAULEY: If I'm going to burn, you know, I'd like to burn 2,800 acres next year. MS. PELLA: And you do that in connection with the federal land managers? MR. MACAULEY: private estate. No. Do you work with them? My ranch is strictly I do the State land in conjunction ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 11 1 with the State Land Department. 2 But when you're talking about trying to 3 manage -- 4 designation of who owns what land. 5 both sides of the fence the same way, as far as 6 livestock is concerned and as far as wildlife is 7 concerned. 8 burn. 9 around here for centuries. 10 The fence that's not there, we put on the I try to manage To get rid of the overstore, you need to That's part of the fire regimen that's been But to do 2,800 acres requires to be burning 11 at your property for three weeks or longer, if you 12 can't get it to run. 13 MS. PELLA: 14 MR. MACAULEY: Right. So you're talking about doing 15 something every single day at the end of the burn day 16 -- 17 MS. PELLA: No. Just at the beginning of the 18 day. 19 process is similar as it happens today. 20 daily phone call to ADEQ that says this is what I'm 21 planning on burning today. 22 The daily burning request is generally -- the There's a We're still working out the details of the 23 implementation of it, but there will be forms that ADEQ 24 is creating that the burners can use. 25 an initial one of those saying, for example, I'd like ARIZONA REPORTING SERVICE, INC. They'll submit (602) 274-9944 PUBLIC HEARING 10-23-2003 12 1 to burn 2,800 acres, and here's the time line that I'm 2 thinking of doing it. 3 whenever you think you're ready to, and then the 4 14-day -- 5 And then you can submit that MR. MACAULEY: Last time we tried to do the 6 same 2,800 acres, we got about 20 acres burned and got 7 rained off. 8 very rapidly and can change from day to day. 9 The thing is, the weather up here changes MR. FORCE: Do you work in conjunction with 10 the State Land Manager? 11 MR. MACAULEY: 12 I try to unless I'm doing it strictly on private property. 13 Historically, I'd get a burn permit in May 14 and it would work until the end of October and we'd 15 burn all summer long. 16 17 MS. PELLA: And you'd burn all summer without having to do a 14-day burn -- 18 MR. MACAULEY: The only individuals I'd call 19 would be the Forest Service and let them know, I'd call 20 the volunteer fire departments and the local law 21 enforcement and go burn. 22 MS. PELLA: Right. And I believe you might 23 want to -- We can include that as an official comment, 24 that we need to take that into consideration for 25 private burning. I don't think much would change for ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 13 1 you. 2 MR. MACAULEY: Other than filing all the 3 paperwork. 4 they generally fax it to me, and that was the last bit 5 of paperwork I did. 6 7 To date, I fill out a burn application, and MS. PELLA: And what did you do when the project was done? 8 MR. MACAULEY: 9 MS. PELLA: 10 Nothing. Nothing. Okay. So the purpose of the rule changes here is -- 11 the main purpose of why we're asking for a completed 12 form of how many acres were burned, what type of fuel, 13 et cetera, is that under the federal rule requirements 14 we need to report to the EPA, from our standpoint, some 15 estimate of emissions that were created from burns. 16 And so what we were trying to do with this 17 rule is to figure out what's the least cap of 18 resistance for the burners to give that information to 19 ADEQ so that we can comply with our federal 20 requirements. 21 when all is said and done, was one of the easiest ways 22 that we thought would be least resistant. 23 24 25 And so having an accomplishment form, But we'll take it as a formal comment that you think it's going to be cumbersome. MR. MACAULEY: How am I supposed to tell you ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 14 1 how many tons of fuel -- 2 MS. PELLA: 3 MR. MACAULEY: 4 5 6 You don't. proportionate to how dense the trees are on the acre. MS. PELLA: Right. MR. MACAULEY: 8 MS. PELLA: 10 11 But you know how many acres you burned? 7 9 I mean, that's directly Right. And you kind of know the fuel type, you know mostly what type of vegetation it was. MR. MACAULEY: Are you talking about woody or grass or -- 12 MS. PELLA: Right. 13 MR. MACAULEY: The whole idea is to increase 14 the ground cover of the grasses, is what you're trying 15 to accomplish. 16 MS. PELLA: Right. And what we're trying to 17 do -- and we create the forms themselves that you guys 18 fill out -- is, again, trying to make it as easy for 19 you guys to fill out as possible. 20 kind of thing where you just circle some things, where 21 you don't even have to write out in longhand the 22 information. 23 we're trying to figure out how we can comply with the 24 federal rule requirement. 25 It might be some But that's the general onus of it, is MR. MACAULEY: So what you're trying to do on ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 15 1 private lands -- 2 it run through an area and take the standing as well as 3 what you've cut and let dry or you bushed or cabled, 4 you could get a lot more bang for your buck. 5 it's expensive to go out there and physically cut down 6 the trees. 7 green, the whole idea is to get it to run to cover 8 hundreds of thousands of acres at a time. 9 10 If you can start a fire here and have Because And if you run into the green and take the MS. PELLA: Right. No one is arguing that prescribed -- 11 MR. MACAULEY: What's going to happen, 12 though, is you're not going -- 13 not going to have a daily estimate of how many acres 14 have been burned, unless you go out there and walk it 15 or measure it or take some sort of activity to clarify. 16 And if the fire is burning, you're going to try to let 17 it run, and it may go beyond the scope of the fire 18 plan. 19 the ranch, that's what you're trying to accomplish. 20 If that happens, you're But as long as it stays within the boundary of MS. PELLA: Right. I totally agree with you. 21 And if the situation is the prime time -- you want to 22 burn as much as you can, right? 23 If the conditions are right, it's not limiting what you 24 can burn in a daily situation. 25 the morning, you call in the morning and you say this ARIZONA REPORTING SERVICE, INC. And there's nothing -- I mean, you report in (602) 274-9944 PUBLIC HEARING 10-23-2003 16 1 is what we're estimating we're going to burn. 2 your project is done, that's your accomplishment form. 3 Am I capturing that right, Carl, as you recall it? 4 MR. BOWMAN: 5 MS. PELLA: And when As I recall, yeah. I mean, we don't want you having 6 to call DEQ twice a day or the State Land Manager, or 7 however it's set up who your particular person is. 8 We're not trying to get you to have to do that at all. 9 MR. MACAULEY: I just think -- Just trying 10 to find the time to fill out all the paperwork and 11 comply with all the rules and regulations, it is 12 becoming cumbersome. 13 MS. PELLA: Okay. We will take that as a 14 formal comment and make sure we put something in our 15 response and summary. 16 17 HEARING OFFICER FRIEDL: Are there any other questions? 18 MR. LETZ: I had a question. 19 It's been a while since I've read the 20 proposed rules, but in one of the initial drafts there 21 were some requirements to provide annual estimates on 22 the number of papers that would be burned in the 23 wildland burn use strategy. 24 25 MS. PELLA: prescribed burns. Not for wildland fires, ADEQ is committed to holding an ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 17 1 annual meeting with State and Federal Land Managers and 2 other interested parties to discuss annual emission 3 goals. But you can't estimate wildland fires. 4 MR. LETZ: 5 MS. PELLA: 6 Wild fires are lightening strikes -- 7 MR. LETZ: 8 MS. PELLA: 9 That was exactly my comment. that get burned. Well, so is it -Wildland is lightening strikes So once you classify your terms into 10 a wildland fire, the Land Manager -- Federal Land 11 Manager is watching it and knows where they want the 12 wildland fire to go. 13 MR. FORCE: I think the provision he's asking 14 about is still in there. Wildland fire use is a wild 15 fire that we -- 16 a wildland fire use is going to be on the annual 17 registration form. They're asking us to project how much 18 MS. PELLA: Okay. 19 MR. FORCE: And I'm wondering about that one 20 21 myself. Carl, do you remember -MR. BOWMAN: I think our comments were along 22 the lines -- if I remember the comments we sent in, it 23 was the area of, in our case, the park that was 24 suitable for wildland fire use. 25 MR. FORCE: Maybe we should clarify that ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 18 1 language a little bit. 2 MR. BOWMAN: Since it's a wild fire, instead 3 of putting this out, we're going to manage it. 4 don't really know if it's going to start, if it's going 5 to grow. 6 about a tenth of an acre, and we've gotten another one 7 that's gotten to 8,000. We've had some this year that have gotten to 8 MS. PELLA: 9 MR. LETZ: 10 MS. PELLA: 11 Regional Office. 12 comment. 13 14 15 You So it's really hard. Okay. Are you Craig? Yes. He's with the ADEQ Northern We'll put that down as a formal MR. LETZ: I'm Craig Letz with the Grand Canyon National Park. HEARING OFFICER FRIEDL: The gentleman who 16 spoke first, if we could get you to fill out a speaker 17 slip just so we can match your name to the comment on 18 the official record? 19 MS. PELLA: 20 HEARING OFFICER FRIEDL: 21 MS. PELLA: 22 Good point, Craig. Carl, do you have anything you want to add? 23 MR. BOWMAN: 24 MR. MACAULEY: 25 Any other questions? No. I'm woefully unprepared. My name is Mike MaCauley. Besides being a rancher, I'm also the chairman of the ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 19 1 Natural Resource Conservation District. The concern I 2 have with fires -- I mean, when we go out and set a 3 fire, the idea is -- the reality is, we can't -- unless 4 you do a great deal of pretreatment to have that fire 5 stay within a defined physical boundary, you're not 6 going to have control unless you have a lot of water 7 available. 8 water, because there's -- in my part of the world 9 there's no live water, there's no wells, there's no And the ability to transport a lot of 10 streams. 11 is very expensive, to try to put out a fire or fight a 12 fire in that type of situation. 13 So you end up having to haul the water, which The idea of managing a fire, if you really 14 want to manage a fire, there's certain things you have 15 to do. 16 that gets exceedingly cost prohibitive. 17 Government money like the Forest Service does, the pay 18 for that sort of thing, yeah, I could do that. 19 from a private standpoint, that's not feasible. 20 And one of them is pretreat the boundaries, and MS. PELLA: If I had the But We'll also take that down as a 21 formal comment, that there's some concern about the 22 cost when it's related to private land. 23 MR. MACAULEY: One of the issues I also said, 24 when we're talking about doing some sort of interface 25 treatment, is the private landowner. ARIZONA REPORTING SERVICE, INC. How do you (602) 274-9944 PUBLIC HEARING 10-23-2003 20 1 coordinate with the private landowner what you're doing 2 on the federal lands? 3 point, because the monies are not there unless the 4 private landowner is willing to ante up. 5 And that has become a stumbling So when you're treating an area and you have 6 islands that you can't treat because it's 7 cost-prohibitive, you're, in a sense, defeating your 8 own purpose because you cannot treat the entire area 9 the same. So you're leaving pockets of areas where you 10 can have wild fires grow or become a problem and then 11 spread in other areas that may have been treated or 12 beyond. 13 HEARING OFFICER FRIEDL: Does anybody else 14 have any questions or formal comments that they would 15 like ADEQ to consider? 16 17 18 This concludes the question and answer and the formal comment period. We encourage everyone to submit written 19 comments on the proposed rulemaking. 20 remember that all comments must be received no later 21 than 5:00 p.m. on Friday, October 24th, 2003. 22 23 24 Thank you for attending. And please The time is now 2:04 p.m., and I now close this oral proceeding. (The public hearing concluded at 2:04 p.m.) 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 PUBLIC HEARING 10-23-2003 21 1 STATE OF ARIZONA 2 COUNTY OF MARICOPA ) ) ss. ) 3 4 5 6 I, KATHRYN A. BLACKWELDER, Certified Court 7 Reporter No. 50666 for the State of Arizona, do hereby 8 certify that the foregoing printed pages constitute a 9 full, true and accurate transcript of the proceedings 10 had in the foregoing matter, all done to the best of 11 my skill and ability. 12 13 WITNESS my hand this 5th day of November, 2003. 14 15 16 17 ___________________________ KATHRYN A. BLACKWELDER Certified Court Reporter Certificate No. 50666 18 19 20 21 22 23 24 25 ARIZONA REPORTING SERVICE, INC. (602) 274-9944 NOTICE OF FINAL RULEMAKING TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITY AIR POLLUTION CONTROL PREAMBLE 1. Sections Affected Rulemaking Action Article 6 R18-2-602 Amend Article 15 2. R18-2-1501 Amend R18-2-1502 Amend R18-2-1503 Amend R18-2-1504 Amend R18-2-1505 Amend R18-2-1506 Amend R18-2-1507 Amend R18-2-1508 Amend R18-2-1509 Amend R18-2-1510 Renumber R18-2-1510 New Section R18-2-1511 Renumber R18-2-1511 Amend R18-2-1512 Renumber R18-2-1512 Amend R18-2-1513 Renumber R18-2-1513 Amend R18-2-1514 Repeal R18-2-1514 Renumber R18-2-1514 Amend R18-2-1515 Amend The statutory authority for the rulemaking, including both the authorizing statute (general) 602ART15NFRMGRRC120903.DOC 12/9/03 1 and the statutes the rules are implementing (specific): 3. Authorizing statute: A.R.S. '' 49-414, 49-414.01 and 49-425 Implementing statutes: A.R.S. ' 49-501 The effective date of the rules: 60 days after filing with the Secretary of State. 4. A list of all previous notices appearing in the Register addressing the final rules: Notice of Rulemaking Docket Opening: 9 A.A.R. 3386, August 1, 2003 Notice of Proposed Rulemaking: 9 A.A.R. 4066, September 19, 2003 5. The name and address of agency personnel with whom persons may communicate regarding the rulemaking: Name: Kevin Force Address: Arizona Department of Environmental Quality 1110 W. Washington Ave. Phoenix, AZ 85007 Telephone: (602) 771-4480 (This number may be reached in-state by dialing 1-800-234-5677 and requesting the seven digit number.) Fax: 6. (602) 771-2366 An explanation of the rules, including the agency=s reasons for initiating the rules: Summary. This final rule amends Arizona=s existing open burning and prescribed burning rules to make them conform to EPA requirements for states= Regional Haze State Implementation Plans. In addition, these amendments make other technical changes, including improvements of the rules= clarity, conciseness, and understandability. Regional Haze SIP Requirements. The revisions to R18-2-602 and Article 15 will allow the state=s Regional Haze SIP that Arizona is required to submit to EPA by December 31, 2003, to meet the approvability test. (40 CFR 51.309(c)) The specific requirements for state regional haze SIPs are found at 40 CFR 51.308 and 51.309. Under 40 CFR 51.309(d)(6), Programs Related to Fire, the plan must provide for: 602ART15NFRMGRRC120903.DOC 12/9/03 2 A(i) Documentation that all Federal, State, and private prescribed fire programs within the State evaluate and address the degree visibility impairment from smoke in their planning and application. In addition the plan must include smoke management programs that include all necessary components including, but not limited to, actions to minimize emissions, evaluation of smoke dispersion, alternatives to fire, public notification, air quality monitoring, surveillance and enforcement, and program evaluation. (ii) A statewide inventory and emissions tracking system (spatial and temporal) of VOC, NOX, elemental and organic carbon, and fine particle emissions from fire. In reporting and tracking emissions from fire from within the State, States may use information from regional data-gathering and tracking initiatives. (iii) Identification and removal wherever feasible of any administrative barriers to the use of alternatives to burning in Federal, State, and private prescribed fire programs within the State. (iv) Enhanced smoke management programs for fire that consider visibility effects, not only health and nuisance objectives, and that are based on the criteria of efficiency, economics, law, emission reduction opportunities, land management objectives, and reduction of visibility impact. (v) Establishment of annual emission goals for fire, excluding wildfire, that will minimize emission increases from fire to the maximum extent feasible and that are established in cooperation with States, tribes, Federal land management agencies, and private entities.@ In early 2002, ADEQ's Regional Haze stakeholders established a Fire Emissions Work Group (FEWG) to discuss visibility issues related to fire emissions and make recommendations to ADEQ for the Regional Haze SIP. Fifteen stakeholders, representing public and private entities in geographically diverse areas of the state, agreed to participate in the work group. The FEWG held a series of meetings from June 2002 through May 2003 to learn about and discuss options for all categories of burning activities that occur in the state. The draft rules were presented at public workshops in Casa Grande, Flagstaff, Phoenix, Show Low, and Yuma from April 10-17, 2003. The extensive meeting schedule was proposed by work group members in order to provide local access to the rulemaking process and obtain early input from sectors of the community who would be most affected by these rules. The current final rule is a joint effort of ADEQ and the FEWG based on input received at those public meetings and the decisions of the FEWG. Structure of open burning authority in Arizona. A.R.S. ' 49-425 provides ADEQ with general air quality rule authority, including authority to promulgate rules for open burning permits. It requires the Director to adopt rules determined necessary and feasible Ato reduce the release into the atmosphere of air contaminants 602ART15NFRMGRRC120903.DOC 12/9/03 3 originating within the territorial limits of the state.@ A.R.S. ' 49-501 adds related authority by excepting from its provisions those open outdoor fires that are permitted by any rule issued pursuant to A.R.S. ' 49-425 (see subsections (C)(5)), and in(E), by allowing the director to delegate authority to issue open burn permits to a Acounty, city, town, or fire district.@ A.R.S. ' 49-414.01(A) sets forth regional haze goals and requires the Director to submit a plan to EPA that addresses Aprograms related to emissions from fire sources@ Aas necessary to submit an approvable plan@ and authorizes rules necessary for the revisions to the state implementation that address regional haze.@ R18-2-602 and A.R.S. ' 49-501 govern open burning activities under ADEQ=s jurisdiction. A.R.S. ' 49-501 was last amended in 1997. In 1996, the delegation subsection E was added. In 1994, the general permit for household waste was added. Based on the statute and rule, ADEQ published guidelines on open burning in February, 1997. Open Burning Revisions At the public meetings mentioned above, the three frequent topics for comment were: time-of-day burning restrictions in R18-2-602(D)(3), permitting requirements for air curtain destructors, and the relationship of the state rule to counties that have independent authority to permit fires. However, in the public comment period, most commenters mentioned ADEQ=s proposed inclusion of fire training in those permits that would require an open burn permit. ADEQ has returned fire training to those fires that are exempted from an open burning permit. The issue is discussed in more detail in item 11 of this preamble. Compared to the existing rule, this final rule contains a number of additional definitions in a separate subsection. ADEQ has finalized definitions for various categories of open burning, such as agricultural, construction, and residential. In addition, there are new definitions for Adelegated authority@, Aindependent authority to permit fires@, and Aprohibited materials@. Prohibited materials were previously described in the February 97 guidelines. By placing all of the necessary material from the guidelines in the final rule, ADEQ intends that this amended R18-2-602 will replace the guidelines as of the effective date of the rule. The final rule also clarifies which open burning activities require open burning permits and those that are exempt from a permit. The final rule contains a more complete list of information that is required to be in the permit. This is both for more efficient permit administration, and to comply with various aspects of the regional haze rule. 602ART15NFRMGRRC120903.DOC 12/9/03 4 ADEQ considered exempting certain fires using air curtain destructors from the open burn permit requirement in order to remove an administrative barrier to this type of burning. The Regional Haze Rule requires that administrative barriers to the use of alternatives to burning be removed wherever feasible. (See 40 CFR 51.309(d)(6)(iii)) ADEQ considered a barrier to a burning method with arguably lower emissions in the same way. Air curtain destructors (ACDs) are basically incinerators with high velocity air blown across and into the upper portion of the combustion chamber. This curtain of air traps particulates (smoke) and oxygenates the chamber, resulting in better combustion and less smoke. After reviewing two studies and considering the comments, ADEQ has remained with its conclusion that these devices do require oversight and it is appropriate that they be subject to permits under the rule. ADEQ does not view the requirement that ACDs obtain an open burning permit as much of an administrative barrier. ADEQ also notes that certain air curtain destructors are subject to New Source Performance Standards (see 40 CFR 60, subparts CCCC and DDDD). The issue is discussed in more detail in item 11 of this preamble. Studies reviewed by ADEQ relevant to air curtain destructors are listed in item 7 of this preamble. ADEQ has added language in the final rule clarifying that the state rule will not operate in counties with independent authority to permit fires, and has listed the three counties in the definition. This independent authority is derived in part from language in A.R.S. ' 49-501(C)(5) specifying that fires permitted pursuant to county rules are excepted from A.R.S. ' 49-501. The three counties referenced in the definition all have rules creating permits for open outdoor fires, other than dangerous materials. (see Maricopa County Rule 341; Pima County Rule 17.12.480, et seq.; Pinal County Rule 3-8-700 and 3-8-710.) Pursuant to A.R.S. ' 49501(G) and the current Phoenix area PM10 SIP, the Maricopa County rule prohibits burning of household waste. The final rule also clarifies provisions on burning of dangerous materials and household waste. Finally, new restrictions on permits issued by delegated authorities that minimize the potential for conflict of interest on the part of delegated authorities have been included in subsection (G). First, the final rule specifies that a delegated authority may not issue itself open burning permits. Second, the rule prohibits private fire protection providers from conditioning the issuance of open burning permits on the applicant being their customer. Final Prescribed Burning Revisions State and federal forest and range land make up more than half of the land in Arizona. Despite potential air 602ART15NFRMGRRC120903.DOC 12/9/03 5 quality concerns, state and federal land managers (F/SLMs) use fire as a resource management tool on this land for a variety of purposes. Article 15 governs those fires that are set or allowed to burn on these lands in Arizona from a general air quality perspective. The two primary air quality concerns are violations of national ambient air quality standards (NAAQS) for particulates, and visibility impairment. Research indicates that, on average, 90 percent of smoke particles from wildland and prescribed fires are PM10, and 10 percent are PM2.5. Arizona=s Prescribed Burning requirements in Article 15 address these air quality concerns, primarily through efforts to ensure the best times for >burns= and by promoting other techniques to reduce the amount of smoke produced and the effects of that smoke. A.R.S. ' 49-414.01 specifically requires the Director to submit a plan to EPA, and allows ADEQ to promulgate rules addressing programs related to emissions from wildland fire, including prescribed fires and wildfires (see A.R.S. ' 49-414.01(A)(7)). The final revisions to Article 15 of the Code, which govern the procedures relating to prescribed and wildland fires, will better conform to EPA=s regional haze requirements, be more understandable, and facilitate enhanced compliance. Most of the final changes to Article 15 directly reflect the mandates of the EPA=s regional haze rule requirements, particularly those relating to the collection and recording of burn data, the evaluation of burn programs and setting of annual emission goals. The former structure of the rule remains intact: 1) Annual registration; 2) submittal of a Burn Plan at least 14 days before the burn; 3) a daily Burn Request; and 4) a Burn Accomplishment Form. Section by Section Explanation of significant final changes. Article 6 R18-2-602 This rule describes the process by which permits may be issued for open burns, and identifies open burning activities that are exempt from the permit requirement. Article 15 R18-2-1501 This section lists the definitions applicable to Article 15. In response to the EPA regulation, there are new definitions for AAnnual Emissions Goal,@ and Anon-burning alternatives to fire.@ In addition, ABest Management Practices@ has been replaced by ASmoke management techniques@ and AEmission reduction techniques,@ and APrescribed natural fire@ has been replaced by AWildland fire use.@ R18-2-1502 This section limits the applicability of the rule to state and federal land 602ART15NFRMGRRC120903.DOC 12/9/03 6 mangers, while excluding Indian Trust lands. The final change clarifies that private burners, such as the Nature Conservancy, may also be subject to the Article. R18-2-1503 This section describes the process by which land managers annually register their planned burns with ADEQ. The final changes incorporate emission reduction techniques and non-burning alternatives to fire and facilitate the setting of annual emission goals. A new annual period and other clarifying changes have been included. R18-2-1504 This section requires the details of each burn to be included in the Burn Plan form to be submitted to ADEQ 14 days before requesting permission to ignite. The final changes clarify the process and supplement the information related to it. R18-2-1505 This section requires land mangers to submit a daily burn request for each day of the burn and describes optional agency response to the request. The final changes are primarily clarifying. R18-2-1506 This section describes how the agency will determine whether and how much burning to allow. The final changes also add clarifying factors not directly related to regional haze. R18-2-1507 This section requires land managers to report acreage and fuel types burned, the emission reduction and smoke management techniques used, and requires ADEQ to keep records of this information. A subsection has been added for wildfire reporting to allow those fires= emissions to be entered into the regional haze emission tracking system. R18-2-1508 This section describes how land managers shall inform the agency of wildfires and seek permission for wildland burn uses. Clarifications have been included based on recent experiences with wildfires. R18-2-1509 This section replaces the former BMP section and describes Emission Reduction Techniques, many of which were listed previously as BMPs. It requires land mangers to use as many as feasible. R18-2-1510 This section also replaces the former BMP section and describes Smoke Management Techniques, some of which were listed previously as BMPs. It requires land managers to use as many as feasible. R18-2-1511 This section describes how the agency may require land managers to 602ART15NFRMGRRC120903.DOC 12/9/03 7 monitor aspects of their prescribed burns and wildland burn uses. The final changes are clarifications and minor changes to weather and air quality monitoring. R18-2-1512 This section requires all burn projects to be conducted by personnel trained in prescribed fire and smoke management techniques. The final changes are clarifications. R18-2-1513 This section directs the agency to conduct burn-related public awareness programs and make burn information available to the public. The final changes attempt to promote regional coordination. R18-2-1514 This section describes how the agency may inspect, verify, and audit burn information, and actions the agency may take regarding enforcement. R18-2-1514(former) In a recent 5-year-review report, ADEQ stated that it would reevaluate the need for this section. ADEQ is deleting subsection (B) because the changes in R18-2-1503 provide for a more efficient and effective system. Subsection (A) has been moved to R18-2-1511(B). R18-2-1515 This section directs the agency to make its forms and data relating to prescribed burns and wildland burn uses available in an electronic format. The final changes are clarifying only. 7. A reference to any study relevant to the rules that the agency reviewed and either relied on in its evaluation of or justification for the rules or did not rely on in its evaluation of or justification for the rules, where the public may obtain or review each study, all data underlying each study, and any analysis of each study and other supporting material: The Use of Air Curtain Destructors for Fuel Reduction, Alan R. Shapiro, United States Department of Agriculture, Forest Service Technology and Development Program (September 2002). Reducing PM2.5 Emissions Through Technology, Evaluations of the Effectiveness of an Air Curtain Incinerator, Ronald A. Scott, Ronald Babbitt, Emily Lincoln, and Wei Min Hao, USDA Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory, Missoula MT (October 2002) Studies available for review at the ADEQ Library, First Floor, 1110 W. Washington St., Phoenix, AZ 85007. 8. A showing of good cause why the rules are necessary to promote a statewide interest if the rules 602ART15NFRMGRRC120903.DOC 12/9/03 8 will diminish a previous grant of authority of a political subdivision of this state: Not Applicable 9. The summary of the economic, small business, and consumer impact: A. Rule Identification The sixteen rules amended in this rulemaking are R18-2-602, AUnlawful Open Burning,@ and Article 15, AForest and Range Management Burns,@ R18-2-1501 through R18-2-1515. B. Entities Affected by R18-2-602, AUnlawful Open Burning@ Open burning may be done by many entities for a variety of purposes, such as waste disposal, weed control, site preparation, disease and pest prevention, resource management, and training and fire prevention. Unless specifically exempted by this rule, persons setting outdoor fires would have to obtain a permit from ADEQ or a delegated authority, a city or fire district, or one of the three counties with independent authority to issue permits (Maricopa, Pima, Pinal). Persons who might be subject to this final rule therefore include: (1) individuals; (2) businesses, such as farms, ranches, orchards, electric generating plants, construction and mines; (3) federal sources, such as military installations; (4) state agencies, such as the Departments of Transportation and Corrections; and, (5) political subdivisions, such as counties, cities, irrigation districts, and fire districts. ADEQ has delegated authority to issue permits to about 50 fire departments, fire districts and cities or towns located in 9 of Arizona=s 15 counties. Authority to issue permits in Graham County is delegated to Graham County Health Department, while Maricopa, Pima and Pinal Counties have independent authority to permit fires. ADEQ has jurisdiction to issue permits in areas outside the delegated authorities= jurisdiction in these counties. ADEQ typically issues more than 100 open burning permits annually to a wide variety of permittees, most of which are for burns in Gila and Cochise Counties. Permits for burns in LaPaz, Yavapai, Santa Cruz, Apache, Greenlee and Coconino Counties are also common. The following represents a sampling of the level of permits issued by delegated authorities based on the calendar year 2002. The City of Prescott in Yavapai County issued about 200 permits in 2002, of which the majority was for residential burning. The City of Yuma issued 15 open burning permits, mainly for agriculture. Rural Metro Fire Department, which has jurisdiction outside of the municipalities of Somerton 602ART15NFRMGRRC120903.DOC 12/9/03 9 and Yuma, typically issues 300-400 residential open burning permits and 50-60 permits for agriculture in Yuma County. The City of Payson in Gila County issued 146 open burning permits for brush and weeds. Bullhead City in Mohave County annually issues 50-70 open burning permits of which the majority is for residential burning. The 384 open burning permits issued by Graham County Health Department in fiscal year 2003 were all for purposes of weed abatement. C. Potential Impact of R18-2-602 This rulemaking only makes minor changes and incorporates current practice, therefore ADEQ expects the rule to create minimal actual impact, such as the costs associated with minor changes in record-keeping, documentation, and reporting requirements. ADEQ and delegated authorities will have to maintain copies of effective permits, as well as prepare annual reports for submission to ADEQ. While some of these changes will generate minimal costs, ADEQ expects the overall benefits to exceed those costs. It should also be noted that ADEQ does not charge fees for open burning permits because most permits are issued in a day or two and it would require minimal administrative effort. D. Entities Affected by Article 15, AForest and Range Management Burns@ Since ADEQ has jurisdiction, outside tribal lands, over air pollution resulting from prescribed burning, this rule will impact the following federal and state agencies that do burning: (1) Federal Land Managers (FLMs) involved in burning activities, such as U.S. Forest Service, U.S. Fish and Wildlife Service, National Parks Service, Bureau of Land Management, Bureau of Reclamation, Department of Defense; (2) State Land Managers (SLMs), such as Arizona State Land Department, Arizona Department of Transportation, Arizona Department of Game and Fish, and Parks Department. Additionally, there are entities not actually subject to this rule but who may voluntary comply with some or all of the rule provisions, such as the Bureau of Indian Affairs, one of the largest burners in Arizona. Also, private land managers, such as The Nature Conservancy, or individuals, might also need to comply with this rule or request assistance from one of the F/SLMs. Each year, ADEQ receives more than 1,000 daily burn requests from F/SLMs. For example, in calendar year 2002, about 1,400 requests to burn were received, and slightly more than 104,000 acres were burned, which represents about 56 percent of the total acres approved to burn. This figure is approximately equal to the the number of acres burned each year for the past ten years (106,429) on federal, state, and tribal lands. The major fuel types burned in 2002 and their relative proportions include: piled ponderosa pine (22%), non-piled ponderosa pine (21%), and natural ponderosa pine (17%). The remaining 40% of fuel types include: natural 602ART15NFRMGRRC120903.DOC 12/9/03 10 shrub, non-piled grass and ponderosa pine, natural grass, natural grass and ponderosa pine, non-piled mixed, and other. For comparison, in 1999, F/SLMs requested nearly 450,000 acres to burn. Although ADEQ approved close to 80 percent of the requested acreage, the actual number of acres burned was about 200,000. The fuel types burned in 1999 were: broadcast slash (32%), ponderosa pine (22%), grass (20%), slash piles (14%), brush (10%), and pinyon juniper (2%). As shown with these two years, proportions, however, vary from one year to another. Combining acres burned for 1994 through 1999, shows the percentage of acres burned by F/SLMs agencies: U.S. Forest Service (49%), Bureau of Indian Affairs (30%), National Park Service (7%), Bureau of Land Management (7%), U.S. Fish and Wildlife (6%), Arizona State Land Department (1%), and other (1%). E. Potential Impact of Article 15 Because this rule involves forest and range management burning by federal and state land managers, private persons, political subdivisions of the state, and small businesses will not bear any direct incremental costs from the final rule changes. However, because the rule requires both better tracking of emissions, better management of smoke, and public education and notification, benefits are expected to accrue to the public, particularly to populations living close to the burns. Specifically, there is potential for incremental benefits arising from better planning and implementation of measures which increase burn efficiency, prevent wildfires, improve visibility, and reduce smoke impacts to both the general public and more sensitive segments of the population. F/SLMs currently pay for two full-time positions to work with ADEQ at an estimated annual value of $120,000 at ADEQ. Office space and equipment are provided by ADEQ. ADEQ currently supports one fulltime position for the smoke management program. Although implementing this amended rule may require minimally increased planning and evaluation time, ADEQ does not expect to need additional employees to handle the workload. This increased workload, together with administrative costs associated with making burn information publicly available and conducting public awareness programs, are all that comprise the incremental impact to ADEQ. Thus, ADEQ judges that the costs to the agency are minimal. The incremental impact of the changes to Article 15 is based on the rule=s new requirements, and are 602ART15NFRMGRRC120903.DOC 12/9/03 11 expected to result in minimal economic impact to F/SLMs and ADEQ. For example, F/SLMs will have to provide more information about their prescribed burns, including emission reduction techniques and nonburning alternatives. They will also be encouraged to attend annual meetings for program evaluation and the establishment of annual emissions goals, and will be looked to for the development of long-term projections of future prescribed fire and wildland fire use activities. The information provided by F/SLMS will be used by ADEQ to assess visibility impairment and other air quality concerns. Additional compliance costs include those associated with the incorporation of additional emission reduction and smoke management techniques. Together, these rule changes are expected to improve the state=s smoke management program, which could lead to improvements in air quality through reduction and better management of burns. Evidence shows that exposure to criteria pollutants, either to individual pollutants such as particulate matter (PM), or collectively to a variety of pollutants, is associated with increased mortality. The positive correlation is most closely related to ambient air concentrations of PM. Human health effects of PM, for example, include premature mortality, bronchitis, new asthma cases and exacerbated asthma in existing individuals, increased hospital admissions, lower and upper respiratory illness, shortness of breath, respiratory symptoms, restricted activity days, and lost days of work. Other health effects ascribed to exposure to PM include changes in pulmonary function, chronic respiratory diseases (other than chronic bronchitis), morphological changes, neonatal mortality, cancer, altered host defense mechanisms, and non-asthma respiratory emergency room visits. Estimated economic values have been assigned to death and other adverse health effects. For example, a statistical death has been estimated to cost $6.3 million (in year 2000 dollars), chronic bronchitis due to PM costs $260,000 per patient, mortality life years lost is valued at $293,000 per each life year, and work days lost due to PM is worth about $83 per day. (EPA, The Benefits and Costs of the Clean Air Act 1990-2010, Office of Air and Radiation, Office of Policy, November 1999, Table 5-1.) F. Reduction of Impacts to Small Businesses for R18-2-602 and Article 15 These rules create minimal increased compliance costs for ADEQ to administer the open burning and prescribed forestry burning programs. ADEQ considered each of the methods prescribed in A.R.S. ' 41-1035 for reducing the impact on small businesses. Likewise, it considered each of the methods prescribed in A.R.S. ' 41-1055(B)(5)(c). For example, A.R.S. ' 41-1035 requires agencies implementing rules to reduce the impacts on small businesses by using certain methods where legal and feasible. Methods that may be used include the following: (1) exempt them from any or all rule requirements, (2) establish performance standards which could replace more costly design or operational requirements, or (3) institute reduced compliance or 602ART15NFRMGRRC120903.DOC 12/9/03 12 reporting requirements. ADEQ cannot provide additional regulatory relief for small businesses applying for open burning permits. As the agency does not charge fees for open burning permits, ADEQ expects that R18-2-602's reporting requirement (on forms developed by ADEQ) will create minimal economic impacts to individual persons or small businesses. The rule procedures have been kept as simple and straightforward as possible. Article 15 does not directly impact small businesses as it applies primarily to public entities. 10. A description of the changes between the proposed rules, including supplemental notices, and final rules (if applicable): In response to comments, and to improve clarity, conciseness, and understandability, ADEQ has made the following changes to the proposed rule: ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES R18-2-602. A. Unlawful Open Burning In addition to the definitions contained in A.R.S. ' 49-501, in this Section: 1. AAgricultural Burning burning@ means burning of vegetative materials related to the production producing and harvesting of crops and raising of animals for the purpose of marketing for profit, or providing a livelihood, but does not including include the burning of household waste or prohibited materials. Burning may be conducted A person may conduct agricultural burns in fields, piles, ditch banks, fence rows, or canal laterals for purposes such as weed control, waste disposal, disease and pest prevention, or site preparation. 2. AApproved waste burner@ means an incinerator constructed of fire resistant material with a cover or screen which that is closed when in use having and has openings in the sides or top no greater than one inch in diameter. 3. AClass I Area@ means any one of the Arizona mandatory federal class I areas defined in A.R.S. ' 49-401.01. 4. AConstruction burning@ means burning of wood or vegetative material from land clearing, site preparation, or fabrication, erection, installation, demolition, or modification of any buildings or other land improvements, but does not including include the burning of household waste or prohibited materials material. 5. ADangerous material@ is means any substance or combination of substances that is capable 602ART15NFRMGRRC120903.DOC 12/9/03 13 of causing bodily harm or property loss unless neutralized, consumed, or otherwise disposed of in a controlled and safe manner. 6. ADelegated authority@ means any of the following: a. A county, city, town, air pollution control district, or fire district that has been delegated authority to issue open burning permits by the Director under A.R.S. ' 49-501(E); or b. A private fire protection service provider that has been assigned authority to issue open burning permits by one of the authorities in subsection (a). 7. ADirector@ means the Director of the Department of Environmental Quality, or his designee. 8. AEmission reduction techniques@ are means techniques methods for controlling emissions from open outdoor fires to minimize the amount of emissions output per unit or of area burned. 9. AFlue,@ as used in this subsection Section, means any duct or passage for air or combustion gases, such as a stack or chimney. 10. AHousehold waste@means any solid waste including garbage, rubbish, and sanitary waste from a septic tanks tank that is generated from households including single and multiple family residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas, but does not including include construction debris, landscaping rubble, or demolition debris. 11. AIndependent authority to permit fires@ means the authority of a county to permit fires by a rule adopted pursuant to under Arizona Revised Statutes, Title 49, Chapter 3, Article 3, and includes only Maricopa, Pima, and Pinal counties. have independent authority to permit fires. 12. AOpen outdoor fire or open burning@ means the combustion of material of any type outdoors, and in the open, where the products of combustion are not directed through a flue. Open outdoor fires include agricultural, residential, prescribed, and construction burning, and fires using air curtain destructors. Purposes for fires can include prevention of a fire hazard, instruction in the methods of fighting fires, watershed rehabilitation, disease and pest prevention. 13. AProhibited materials@ means nonpaper garbage from the processing, storage, service, or consumption of food; chemically treated wood; lead-painted wood; linoleum flooring, or composite counter-tops; tires; explosives or ammunition; oleanders; asphalt shingles; tar 602ART15NFRMGRRC120903.DOC 12/9/03 14 paper; plastic and rubber products, including bottles for household chemicals; plastic grocery and retail bags; waste petroleum products, such as waste crankcase oil, transmission oil, and oil filters; transformer oils; asbestos; batteries; anti-freeze; aerosol spray cans; electrical wire insulation; thermal insulation; polyester products; hazardous waste products such as paints, pesticides, cleaners and solvents, stains and varnishes, and other flammable liquids; plastic pesticide bags and containers; and hazardous material containers including those that contained lead, cadmium, mercury, or arsenic compounds. 14. AResidential burning@ means open burning of vegetative materials conducted by or for the occupants of residential dwellings, but does not including include burning of household waste or prohibited materials material. 15. B. APrescribed burning@ has the same meaning as in R18-2-1501. Unlawful open burning. Notwithstanding any other rule in this Chapter, it is unlawful for any a person to shall not ignite, cause to be ignited, permit to be ignited, or suffer, allow, or maintain any open outdoor fire in a county without independent authority to permit fires except as provided in A.R.S. ' 49-501 and this Section. C. Open outdoor fires exempt from a permit. The following fires do not require an open burning permit from the Director or a delegated authority: 1. Fires used only for: a. Cooking of food;, b. Providing warmth for human beings;, c. Recreational purposes;, d. Branding of animals;, e. Orchard heaters for the purpose of frost protection in farming or nursery operations;, and f. 2. The proper disposal of flags under 4 U.S.C. ' 8. Any fire set or permitted by any public officer in the performance of official duty, if such the fire is set or permission given for the following purpose of: a. Fire Control of an active wildfire; or b. Instruction in the method of fighting fires, except that the person setting these fires must comply with the reporting requirements of subsection (D)(3)(f). 3. Fires Fire set by or permitted by the Director of Department of Agriculture for the purpose of disease and pest prevention in an organized, area-wide control of an epidemics or 602ART15NFRMGRRC120903.DOC 12/9/03 15 infestations infestation affecting livestock or crops. 4. Prescribed burns set by or assisted by the federal government or any of its departments, agencies or agents, or the state or any of its agencies, departments, or political subdivisions, pursuant to regulated under Article 15 of this Chapter. D. Open outdoor fires requiring a permit. 1. The following open outdoor fires are allowed with an open burning permit from the Director or a delegated authority: a. Construction burning; b. Agricultural burning; c. Residential burning; d. Prescribed burns conducted on private lands without the assistance of a federal or state land manager as defined under R18-2-1501; e. Any fire set or permitted by a public officer in the performance of official duty, if such the fire is set or permission given for the purpose of weed abatement, the prevention of a fire hazard, or instruction in the methods of fighting fires, unless such the fire is exempt from the permit requirement under subsection (C)(3); 2. f. Open outdoor fires of dangerous material under subsection (E); and g. Open outdoor fires of household waste under subsection (F).; and h. Open outdoor fires that use an air curtain destructor, as defined in R18-2-101. A person conducting an open outdoor fire in a county without independent authority to permit fires shall obtain a permit from the Director or a delegated authority unless exempted under subsection (C). Permits may be issued for a period not to exceed one year. A person shall obtain a permit by completing an ADEQ-approved application form. 3. Open outdoor fire permits issued under this Section shall include: a. A list of the materials that the permittee may be burned burn under the permit; b. A means of contacting the person permittee authorized by the permit to set an open fire in the event that an order to extinguish the open outdoor fire is issued by the Director or the delegated authority; c. A requirement that burns be conducted during the following periods, unless otherwise waived or directed by the Director on a specific day basis: i. Year round: start ignition ignite fire no earlier than 1one hour after sunrise; and ii. Year round: extinguish fire must be extinguished no later than 2two hours 602ART15NFRMGRRC120903.DOC 12/9/03 16 before sunset. d. A requirement that the permittee conduct all open burning shall be conducted only during atmospheric conditions which that: i. Prevent dispersion of smoke into populated areas; ii. Prevent visibility impairment on traveled roads or at airports that results in a safety hazard; e. iii. Do not create a public nuisance or adversely affect public safety; iv. Do not cause an adverse impact to visibility in a Class I area; and v. Do not cause uncontrollable spreading of the fire; A listing list of the types of actions emission reduction techniques that the permittee shall be utilized use to minimize fire emissions; including any emission reduction techniques; f. A reporting requirement that the permittee shall be met meet by providing the following information in a format provided by the Director for each date open burning occurred, on either a daily basis on the day of the fire, or in an annual basis in a report to the Director or delegated authority due on March 31 for the previous calendar year: i. The date of the burn; ii. The type and quantity of fuel burned for each date open burning occurred; iii. The fire type, such as pile or windrow pit, for each date open burning occurred; and iv. For each date open burning occurred, the legal location, to the nearest section, or latitude and longitude, to the nearest degree minute, or street address for residential burns. g. A requirement that the person conducting the open burn notify the local fire-fighting agency, or private fire protection service provider, if the service provider is a delegated authority, before burning. or If none neither is in existence, the person conducting the burn shall notify the state forester., prior to commencement of open burning; h. A requirement that the permittee start each open outdoor fire be started using items that do not cause the production of black smoke; i. A requirement that the permittee attend the fire shall be attended at all times until it is completely extinguished; 602ART15NFRMGRRC120903.DOC 12/9/03 17 j. A requirement that the permittee provide fire extinguishing equipment must be onsite for the duration of the burn; k. A requirement that the permittee ensure that a burning pit, burning pile, or approved waste burner be at least 50 feet from any structure; l. A requirement that the burner must permittee have a copy of the burn permit on-site during open burning; m. A requirement that the permittee not conduct no open burning shall be conducted when an air stagnation advisory, as issued by the National Weather Service, is in effect in the area of the burn or during periods when smoke can be expected to accumulate to the extent that it will significantly impair visibility in Class I areas; n. A requirement that the permittee not conduct no open burning shall be conducted when any stage air pollution episode is declared under R18-2-220. o. A statement that the Director, or any other public officer may order that the burn be extinguished or prohibit burning during periods of inadequate smoke dispersion, excessive visibility impairment, or during periods of extreme fire danger; and p. A copy list of the activities prohibited and the criminal penalties provided under A.R.S. ' 13-1706. 4. The Director or a delegated authority shall not issue an open burning permit under this Section: a. That would allow the burning of prohibited materials other than under a permit for the burning of dangerous materials; b. If the applicant has applied for a permit under this Section to burn a dangerous materials material which are is also hazardous waste under 40 CFR 261, but does not have a permit for the burning to burn of hazardous waste under 40 CFR 264, or is not an interim status facility allowed to burn hazardous waste under 40 CFR 265; or c. If the burning would occur at a solid waste facility in violation of 40 CFR 258.24 and the Director has not issued a variance approval under A.R.S. ' 49-763.01(A). E. Open outdoor fires of dangerous material. A fires fire set for the disposal of a dangerous materials material are is allowed by the provisions of this Section, when the materials material are is too dangerous to store and transport, as permitted in writing by and the Director has issued a permit for the fire. A permits permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The Director shall permit fires set for the disposal of dangerous materials shall be permitted only when there is no safe alternative method of 602ART15NFRMGRRC120903.DOC 12/9/03 18 disposal exists, and when the burning of such the materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts that will endanger health or safety. F. Open outdoor fires of household waste. An open outdoor fires fire for the disposal of household waste are is allowed by provisions of this Section when permitted in writing by the Director or a delegated authority. Permits A permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The applicant shall conduct open outdoor fires of household waste shall be burned in an approved waste burner and shall either: 1. Burn household waste generated on-site on farms or ranches of 40 acres or more where no household waste collection or disposal service is available; or 2. Burn household waste generated on-site where no household waste collection and disposal service is available and where the nearest other dwelling unit is at least 500 feet away. G. Permits issued by a delegated authority. The Director may delegate authority for the issuance of open burning permits to a county, city, town, air pollution control district, or fire district. A delegated authority may not issue a permit for its own open burning activity. Authority The Director shall not delegate authority for issuance of permits to burn dangerous material under subsection (E). shall be retained by the Director and not delegated. A county, city, town, air pollution control district, or fire district with delegated authority from the Director may assign that authority to one or more private fire protection service providers that perform fire protection services within the county, city, town, air pollution control district, or fire district. A private fire protection provider shall not directly or indirectly condition the issuance of open burning permits on the applicant being a customer. Permits issued under this subsection shall comply with the requirements in subsection (D)(3) and be in a format prescribed by the Director. Each delegated authority shall: 1. Maintain a copy of each permit issued for the previous five years available for inspection by the Director; 2. For each permit currently issued, have a means of contacting the person authorized by the permit to set an open fire in the event that if an order for extinguishing of to extinguish open burning is issued; and 3. Annually submit to the Director by May 15 a record of daily burn activity, excluding household waste burn permits, on a form provided by the Director for the previous calendar year containing the information required in subsections (D)(3)(e) and (D)(3)(f). H. The Director shall hold an annual public meeting for interested parties to review operations of the open outdoor fire program and discuss emission reduction techniques. 602ART15NFRMGRRC120903.DOC 12/9/03 19 I. Nothing in this Section is intended to permit any practice which that is a violation of any statute, ordinance, rule, or regulation. ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS R18-2-1501. Definitions In addition to the definitions contained in A.R.S. ' 49-501 and R18-2-101, in this Article: 1. AActivity fuels@ means those fuels created by human activities such as thinning or logging. 1.2. "ADEQ" means the Department of Environmental Quality. 2.3. AAnnual emissions goal@ means the annual establishment in cooperation with the F/SLM=s, under R18-2-1503(G), of a planned quantifiable value of emissions reduction from prescribed fires and fuels management activities. 3.4. ABurn plan@ means the ADEQ form that includes information on the conditions under which the a burn will occur with details of the burn and smoke management prescriptions. 4.5. "Burn prescription" means, with regard to a burn project, the pre-determined area, fuel, and weather conditions required to attain planned resource management objectives. 5.6. "Burn project" means an active or planned prescribed burn, including a wildland fire use incident. 6.7. "Duff" means forest floor material consisting of decomposing needles and other natural materials. 7.8. AEmission reduction techniques (ERT)@ means techniques methods for controlling emissions from prescribed fires to minimize the amount of emission output per unit of area burned. 8.9. AFederal land manager (FLM)@ means any department, agency, or agent of the federal government, including the following: 9.10. a. United States Forest Service, b. United States Fish and Wildlife Service, c. National Park Service, d. Bureau of Land Management, e. Bureau of Reclamation, f. Department of Defense, g. Bureau of Indian Affairs, and h. Natural Resources Conservation Service. "F/SLM" means a federal land manager or a state land manager. 10.11. "Local fire management officer" means a person designated by a F/SLM as responsible for fire management in a local district or area. 602ART15NFRMGRRC120903.DOC 12/9/03 20 11.12. "Mop-up" means the act of extinguishing or removing burning material from a prescribed fire to reduce smoke impacts. 12.13. "National Wildfire Coordinating Group" means the national inter-agency group of federal and state land managers that shares similar wildfire suppression programs and that has established standardized inter-agency training courses and qualifications for fire management positions. 13.14. ANon-burning alternatives to fire@ are means techniques that replace fire for at least five years as a means to treat activity fuels created to achieve a particular land management objective (e.g., reduction of fuel-loading, manipulation of fuels, enhancement of wildlife habitat, and ecosystem restoration, etc.). These alternatives are not used in conjunction with fire. Techniques used in conjunction with fire are referred to as emission reduction techniques (ERTs). 14.15. "Planned resource management objectives" means public interest goals in support of land management agency objectives including silviculture, wildlife habitat management, grazing enhancement, fire hazard reduction, wilderness management, cultural scene maintenance, weed abatement, watershed rehabilitation, vegetative manipulation, and disease and pest prevention. 15.16. "Prescribed burning" means the controlled application of fire to wildland fuels that are in either a natural or modified state, under certain burn prescription conditions and smoke management prescription conditions that have been specified by the land manager in charge of or assisting the burn, to attain planned resource management objectives. Prescribed burning does not include a fire set or permitted by a public officer to provide instruction in fire fighting methods, or construction or residential burning under R18-2-602. 16.17. "Prescribed fire manager" means a person designated by a F/SLM as responsible for prescribed burning for that land manager. 17.18. "Smoke management prescription" means the predetermined meteorological conditions that affect smoke transport and dispersion under which a burn could occur without adversely affecting public health and welfare. 18.19. ASmoke management techniques@ (SMT) means management and dispersion practices used during a prescribed burn or wildland fire use incident which affect the direction, duration, height, or density of smoke. 19.20. "Smoke management unit" means any of the geographic areas defined by ADEQ whose area is based on primary watershed boundaries and whose outlines are outline is determined by diurnal windflow patterns that allow smoke to follow predictable drainage patterns. A map of the state divided into the smoke management units is on file with ADEQ. 20.21. "State land manager (SLM)" means any department, agency, or political subdivision of the state 602ART15NFRMGRRC120903.DOC 12/9/03 21 government including the following: a. State Land Department, b. Department of Transportation, c. Department of Game and Fish, and d. Parks Department. 21.22. "Wildfire" means an unplanned wildland fire subject to appropriate control measures. Wildfires include those incidents where suppression may be limited for safety, economic, or resource limitations concerns. 22.23. AWildland fire use@ means a wildland fire that is ignited by natural causes, such as lightning, that and is subsequently managed using the same controls and for the same planned resource management objectives as prescribed burning. R18-2-1502. A. Applicability A F/SLM that is conducting or assisting a prescribed burn shall follow the requirements of this Article. B. A private or municipal burner with whom ADEQ has entered into a memorandum of agreement shall follow the requirements of this Article. C. The provisions of this Article apply to all areas of the state except Indian Trust lands. All federallymanaged lands and all state lands, parks, and forests are under the jurisdiction of ADEQ in matters relating to air pollution from prescribed burning. D. Notwithstanding subsection (B) (C), ADEQ and any Indian tribe may enter into a memorandum of agreement to implement this Article. E. ADEQ and any private or municipal prescribed burner may enter into a memorandum of agreement to implement this Article. R18-2-1503. A. Annual Registration, Program Evaluation and Planning Each F/SLM shall register annually with ADEQ on a form prescribed by ADEQ, all planned burn projects, including areas planned for wildland fire use. B. Each planned year extends from January 1 of the registration year to December 31 of the same year. Each F/SLM shall use best efforts to register before December 31 and no later than January 31 of each year. C. A F/SLM shall include the following information on the registration form: 602ART15NFRMGRRC120903.DOC 12/9/03 22 1. The F/SLM's name, address, and business telephone number; 2. The name, address, and business telephone number of an air quality representative who will provide technical support to ADEQ for decisions regarding prescribed burning. The same air quality representative may be selected by more than one F/SLM; 3. All prescribed burn projects and potential wildland fire use areas planned for the next year; 4. By prescribed burn project, Maximum project and annual acres to be burned, maximum daily acres to be burned, fuel types within project area, and planned use of emission reduction techniques to support the annual emissions goal for each prescribed burn project; 5. By prescribed burn project, Planned use of any smoke management techniques for each prescribed burn project; 6. By area planned for wildland fire use, Maximum project and annual acres projected to be burned, maximum daily acres projected to be burned, and a map of the anticipated project area, fuel types and loading within the planned area for an area the F/SLM anticipates for wildland fire use; 7. A list of all burn projects that were completed during the previous year; 8. By area to be treated using non-burning alternatives to fire, Project area for treatment, treatment type, fuel types to be treated, and activity fuel loading to support the annual emissions goal for areas to be treated using non-burning alternatives to fire; and 9. The area treated using non-burning alternatives to fire utilized during the previous year including the number of acres, the specific types of alternatives utilized, and the location of these areas. D. After consultation with the F/SLM, ADEQ may request additional information for registration of prescribed burns and wildland fire use to support regional coordination of smoke management, annual emission goal setting utilizing using ERTs, and non-burning alternatives to fire. E. A F/SLM may amend a registration at any time with a written submission to ADEQ. F. ADEQ shall accept accepts a facsimile or other electronic methods as a means of complying with the deadline for registration. If an electronic means are is used, the F/SLM shall deliver the original paper registration form to ADEQ for its records. ADEQ shall acknowledge in writing the receipt of each registration. G. ADEQ shall hold an annual a meeting after January 31 and prior to before April 1 of each year between ADEQ and F/SLM=s for program evaluation to evaluate the program and to cooperatively establish the annual emission goal. The annual emission goal shall be developed to minimize prescribed fire emissions to the maximum extent feasible using emission reduction techniques and 602ART15NFRMGRRC120903.DOC 12/9/03 23 alternatives to burning subject to economic, technical, and safety feasibility criteria, and consistent with land management objectives. H. At least once every five years, ADEQ shall request long-term projections of future prescribed fire and wildland fire use activity from the F/SLMs to support planning for visibility impairment and assessment of other air quality concerns by ADEQ. R18-2-1504. Prescribed Burn Plan Each F/SLM planning a prescribed burn, shall complete and submit to ADEQ the "Burn Plan" form supplied by ADEQ no later than 14 days before the date on which the F/SLM requests permission to burn. The information supplied on the Burn Plan Form are considered ADEQ shall consider the information supplied on the Burn Plan Form as binding conditions under which the burn shall be conducted. A Burn Plans shall be maintained by ADEQ until notification from the F/SLM of the completion of the burn project. Revisions to the Burn Plan for a burn project shall be submitted in writing no later than 14 days before the date on which the F/SLM requests permission to burn. To facilitate the Daily Burn authorization process under R18-2-1505, the F/SLM shall include on the Burn Plan form: 1. An emergency telephone number that is answered 24 hours a day, seven days a week; 2. Burn prescription; 3. Smoke management prescription; 4. The number of acres to be burned, the quantity and type of fuel, type of burn, and the ignition technique to be used; 5. The land management objective or purpose for the burn such as restoration or maintenance of ecological function and indicators of fire resiliency; 6. A map depicting the potential impact of the smoke unless waived either verbally orally or in writing by ADEQ. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the burn site, with smoke-sensitive areas delineated. The map shall use the appropriate scale to show the impacts of the smoke adequately; 7. Modeling of smoke impacts unless waived either verbally orally or in writing by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulates, a carbon monoxide non-attainment area, or other smoke-sensitive area. In consultation with the F/SLM, ADEQ shall provide guidelines on modeling; 8. The name of the official submitting the Burn Plan on behalf of the F/SLM; and 602ART15NFRMGRRC120903.DOC 12/9/03 24 9. After consultation with the F/SLM, any other information to support the Burn Plan needed by ADEQ to assist in the Daily Burn authorization process for smoke management purposes or assessment of contribution to visibility impairment of Class I areas. R18-2-1505. A. Prescribed Burn Requests and Authorization Each F/SLM planning a prescribed burn, shall complete and submit to ADEQ the "Daily Burn Request" form supplied by ADEQ. The Daily Burn Request form shall include: 1. The contact information of the F/SLM conducting the burn; 2. Each day of the burn; 3. The area to be burned on that the day for which the Burn Request is submitted, with reference to the Burn Plan, including size, legal location to the section and latitude/ and longitude to the minute; 4. Projected smoke impacts; and 5. Any local conditions or circumstances known to the F/SLM that, if conveyed to ADEQ, could impact the Daily Burn authorization process. B. After consultation with the F/SLM, ADEQ may request additional information related to the burn, meteorological, smoke dispersion, or air quality conditions to supplement the Daily Burn Request form and to aid in the Daily Burn authorization process. C. The F/SLM shall submit the Daily Burn Request form to ADEQ as expeditiously as practicable, but no later than 2 p.m. of the business day preceding the burn. An original form, a facsimile, or an electronic information transfer are acceptable submittals. D. An F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ, as follows: 1. ADEQ shall approve, approve with conditions, or disapprove a burn on the same business day as the Burn Request submittal. 2. If ADEQ fails to address a Burn Request by 10 p.m. of the business day on which the request was is submitted, the Burn Request is approved by default after the burner makes a good faith effort to contact ADEQ to confirm that the Burn Request was received. 3. ADEQ may communicate its decision by verbal, written, or electronic means. ADEQ shall provide a written or electronic reply if requested by the F/SLM. E. If weather conditions cease to conform to those in the smoke management prescription of either the Burn Plan or an Approval with Conditions, the F/SLM shall take appropriate action to reduce further smoke impacts, ensure safe and appropriate fire control, and notify the public when necessary. After consultation with ADEQ, the smoke management prescription or burn plan may be modified. 602ART15NFRMGRRC120903.DOC 12/9/03 25 F. The F/SLM is responsible for shall ensure that there is appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a prescribed fire. R18-2-1506. Smoke Dispersion Evaluation ADEQ shall approve, approve with conditions, or disapprove a Daily Burn Request submitted pursuant to under R18-2-1505, by using the following factors for each smoke management unit: 1. Analysis of the emissions from burns in progress and residual emissions from previous burns on a day-to-day basis; 2. Analysis of emissions from active wildland fire use incidents, and active multiple-day burns, and consideration of potential long-term emissions estimates; 3. Analysis of the emissions from wildfires greater than 100 acres and consideration of their potential long-term growth; 4. Local burn conditions; 5. Burn prescription and smoke management prescription from the applicable Burn Plan; 6. Existing and predicted local air quality; 7. Local and synoptic meteorological conditions; 8. Type and location of areas to be burned; 9. Protection of the national visibility goal for Class I Areas pursuant to under ' 169A(a)(1) of the Act and 40 CFR 51.309; 10. Assessment of duration and intensity of smoke emissions to minimize cumulative impacts; and 11. Minimization of smoke impacts in Class I Areas, areas that are non-attainment for particulate matter, carbon monoxide non-attainment areas, or other smoke-sensitive areas.; and 12. R18-2-1507. A. Protection of the National Ambient Air Quality Standards. Prescribed Burn Accomplishment; Wildfire Reporting Each F/SLM conducting a prescribed burn shall complete and submit to ADEQ the "Burn Accomplishment" form supplied by ADEQ. For each burn approval, the F/SLM shall submit a Burn Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burning burn. The F/SLM shall include the following information on the Burn Accomplishment form: 1. Any known conditions or circumstances that could impact the Daily Burn decision process; 2. The date, location, fuel type, fuel loading, and acreage accomplishments; 3. The ERTs and SMTs described in R18-2-1509 and R18-2-1510, respectively, and may 602ART15NFRMGRRC120903.DOC 12/9/03 26 include any further ERTs and SMTs that become available, that the F/SLM used to reduce emissions or manage the smoke from the burn. B. The F/SLM shall submit the Burn Accomplishment form as an original form, a facsimile, or an electronic information transfer. C. ADEQ shall maintain a record of Burn Requests, Burn Approvals/Conditional Approvals/Denials and Burn Accomplishments for 5 five years. D. The F/SLM in whose jurisdiction a wildfire occurs shall make available to ADEQ no later than the day after the activity all required information for wildfire incidents that burned more than 100 acres per day in timber or slash fuels or 300 acres per day in brush or grass fuels. For each day of a wildfire incident that exceeded exceeds the daily activity threshold, the F/SLM shall provide the location, an estimate of predominant fuel type and quantity consumed, and an estimate of the area blackened that day. R18-2-1508. Wildland Fire Use: Plan, Authorization, Monitoring; Inter-agency Consultation; Status Reporting A. In order for ADEQ to participate in the wildland fire use decision-making process, the F/SLM shall notify ADEQ as soon as practicable of any wildland fire use incident projected to attain or attaining a size of 50 acres of timber fuel or 250 acres of brush or grass fuel. B. For each wildland fire use incident that has been declared as such by the F/SLM, the F/SLM shall complete and submit to ADEQ a Wildland Fire Use Burn Plan in a format approved by ADEQ in cooperation with the F/SLM. The F/SLM shall submit the Wildland Fire Use Burn Plan to ADEQ as soon as practicable but no later than 72 hours after the wildland fire use incident is declared or under consideration for such designation. The F/SLM shall include the following information in the Wildland Fire Use Burn Plan: 1. An emergency telephone number that is answered 24 hours a day seven days a week; 2. Anticipated burn prescription; 3. Anticipated smoke management prescription; 4. The estimated daily number of acres, quantity, and type of fuel to be burned; 5. The anticipated maximum allowable perimeter or size with map; 6. Information on the condition of the area to be burned, such as whether it is in maintenance or restoration, its ecological function or , and other indicators of fire resiliency; 7. The anticipated duration of the wildland fire use incident; 602ART15NFRMGRRC120903.DOC 12/9/03 27 8. The anticipated long-range weather trends for the site; 9. A map depicting the potential impact of the smoke. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the wildland fire use incident, with smoke-sensitive areas delineated. Mapping is mandatory unless waived either verbally orally or in writing by ADEQ. The map shall use the appropriate scale to show the impacts of the smoke adequately; and 10. Modeling or monitoring of smoke impacts, if requested by ADEQ after consultation with the F/SLM. C. ADEQ shall approve or disapprove a Wildland Fire Use Burn Plan within 3 three hours of receipt. ADEQ shall consult directly with the requesting F/SLM before disapproving a Wildland Fire Use Burn Plan. If ADEQ fails to address the Wildland Fire Use Burn Plan within the time allotted, the Plan is approved by default under the condition that the F/SLM makes a good faith effort to contact ADEQ to confirm that the Plan was received. Approval by ADEQ of a Wildland Fire Use Burn Plan shall be is binding upon ADEQ for the duration of the wildland fire use incident, unless smoke from the incident creates a threat to public health or welfare. If a threat to public health or welfare is created, ADEQ shall consult with the F/SLM regarding the situation and develop a joint action plan for reducing further smoke impacts. D. The F/SLM shall submit a Daily Status Report for each wildland fire use incident to ADEQ for each day of the burn that the fire burns more than 100 acres in timber or slash fuels or 300 acres in brush or grass fuels. The F/SLM shall include a synopsis of smoke behavior, future daily anticipated growth, and location of the activity of the wildland fire use incident in the Daily Status Report. E. The F/SLM shall consult with ADEQ prior to initiating man-made human-made ignition on the wildland fire use incident when greater than 250 acres is anticipated to be burned by the ignition. Emergency man-made human-made ignition on the incident for protection of public or fire-fighter safety does not require consultation with ADEQ regardless of the size of the area to be burned. F. The F/SLM is responsible for shall ensure that there is appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a wildland fire use incident. R18-2-1509. A. Emission Reduction Techniques Each F/SLM conducting a prescribed burn shall implement as many Emission Reduction Techniques as are feasible subject to economic, technical, and safety feasibility criteria, and land management objectives. 602ART15NFRMGRRC120903.DOC 12/9/03 28 B. Emission reduction techniques include : 1. Reducing biomass to be burned by use of techniques such as yarding or consolidation of unmerchandisable material, multi-product timber sales, or public firewood access, when economically feasible; 2. Reducing biomass to be burned by fuel exclusion practices such as preventing the fire from consuming dead snags or dead and downed woody material through lining, application of fire-retardant foam, or water; 3. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires of high fuel density areas such as logging slash decks; 4. Burning only fuels essential to meet resource management objectives; 5. Minimizing consumption and smoldering by burning under conditions of high fuel moisture of duff and litter; 6. Minimizing fuel consumption and smoldering by burning under conditions of high fuel moisture of large woody fuels; 7. Minimizing soil content when slash piles are constructed by using brush blades on materialmoving equipment and by constructing piles under dry soil conditions or by using hand piling methods; 8. Burning fuels in piles; 9. Using a backing fire in grass fuels; 10. Burning fuels with an air curtain destructor, as defined in R18-2-101, operated pursuant according to manufacturer specifications and meeting applicable State state or local opacity requirements; 11. Extinguishing or mopping-up of smoldering fuels; 12. Chunking of piles and other consolidations of burning material to enhance flaming, and fuel consumption, and to minimize smoke production; 13. Burn Burning before litter fall; 14. Burn Burning before green-up of fuels; 15. Burn Burning before recently cut large fuels cure in areas with activity; and 16. Burn Burning just prior to before precipitation to reduce fuel smoldering and consumption. R18-2-1510. A. Smoke Management Techniques Each F/SLM conducting a prescribed burn shall implement as many Smoke Management Techniques as are feasible subject to economic, technical, and safety feasibility criteria, and land management 602ART15NFRMGRRC120903.DOC 12/9/03 29 objectives. B. Smoke Management Techniques management techniques include: 1. Burning from March 15 through September 15, when meteorological conditions allow for good smoke dispersion; 2. Igniting burns under good-to-excellent ventilation conditions; 3. Suspending operations under poor smoke dispersion conditions; 4. Considering smoke impacts on local community activities and land users; 5. Burning piles when other burns are not feasible, such as when snow or rain is present; 6. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires with short duration impacts; 7. Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; 8. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; 9. When allowing public firewood access, provide Providing information on the adverse impacts of using green or wet wood as fuel when public firewood access is allowed; 10. Implementing maintenance burning in a periodic rotation to shorten prescribed fire duration and to reduce excessive fuel accumulations which that could result in excessive smoke production in a wildfire; and 11. Using wildland fire-use strategies to shift smoke into more favorable smoke dispersion seasons. R18-2-1511. A. Monitoring ADEQ may require a F/SLM to monitor air quality before or during a prescribed burn or a wildland fire use incident if necessary to assess smoke impacts. Air quality monitoring may be conducted using both federal and non-federal reference method as well as other techniques. B. ADEQ may require a F/SLM to monitor weather before or during a prescribed burn or a wildland fire use incident, if necessary to predict or assess smoke impacts. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or area-representative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ. An F/SLM planning to make a change to any long-term established remote automated weather station shall give ADEQ notice and an opportunity to comment before making the any change to a long-term established remote automated weather station. 602ART15NFRMGRRC120903.DOC 12/9/03 30 C. A F/SLM shall employ the following types of monitoring, unless waived by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulate matter, carbon monoxide, or ozone, or other smoke-sensitive area: 1. Smoke plume measurements, using a format supplied by ADEQ; and 2. The release of pilot balloons (PIBALs) at the burn site to verify needed wind speed, direction, and stability. In lieu Instead of pilot balloons, a test burn at the burn site may be used for specific prescribed burns on a case-by-case basis as approved by ADEQ, to verify needed wind speed, direction, and stability. D. An F/SLM shall make monitoring information required pursuant to under subsection (C) available to ADEQ on the business day following the burn ignition. E. The F/SLM shall keep on file for 1 one year following the burn date any monitoring information required pursuant under to this Section. R18-2-1512. A. Burner Qualifications All burn projects shall be conducted by personnel trained in prescribed fire and smoke management techniques as required by the F/SLM in charge of the burn and established by National Wildfire Coordinating Group training qualifications. B. A Prescribed Fire Boss or other local Fire Management Officer of the F/SLM having jurisdiction over prescribed burns shall have smoke management training obtained through one of the following: 1. Successful completion of a National Wildfire Coordinating Group or F/SLM-equivalent course addressing smoke management; or 2. R18-2-1513. A. Attendance at an ADEQ-approved smoke management workshop. Public Notification and Awareness Program; Regional Coordination The Director shall conduct a public education and awareness program in cooperation with F/SLMs and other interested parties to inform the general public of the smoke management program described by this Article. The program shall include smoke impacts from prescribed fires and the role of prescribed fire in natural ecosystems. B. ADEQ shall make annual registration, prescribed burn approval, and wildfire and wildland fire use activity information readily available to the public and to facilitate regional coordination efforts and public notification. 602ART15NFRMGRRC120903.DOC 12/9/03 31 R18-2-1514. A. Surveillance and Enforcement An F/SLM conducting a prescribed burn shall permit ADEQ to enter and inspect burn sites unannounced to verify the accuracy of the Daily Burn Request, Burn Plan, or Accomplishment data as well as matching burn approval with actual conditions, smoke dispersion, and air quality impacts. On-ground site inspection procedures and aerial surveillance shall be coordinated by ADEQ and the F/SLM for safety purposes. B. ADEQ may use remote automated weather station data if necessary to verify current and previous meteorological conditions at or near the burn site. C. ADEQ may audit burn accomplishment data, smoke dispersion measurements, or weather measurements from previously conducted burns, if necessary to verify conformity with, or deviation from, procedures and authorizations approved by ADEQ. D. Deviation from procedures and authorizations approved by ADEQ constitute a violation of this Article. Violations may require containment or mop-up of any active burns and may also require, in the Director's discretion, a 5 five-day moratorium on ignitions by the responsible F/SLM. Violations of this Article are also subject to a civil penalty of not more than $10,000 per day per violation pursuant to under A.R.S. ' 49-463. R18-2-1515. A. Forms; Electronic Copies; Information Transfers ADEQ shall make available on paper and in electronically-readable format any form required to be developed by ADEQ and completed by a F/SLM. B. After consultation with the an F/SLM, ADEQ may require each the F/SLM to provide data in a manner that facilitates electronic transfers of information. 11. A summary of the comments made regarding the rule and the agency response to them: Comment #1: A large number of commenters focused on the proposed requirement that fires set for the purpose of training firefighters now be permitted. In the current rule, fires set for training purposes are excepted from the permit requirement. Commenters felt that requiring permits for such fires was an unnecessary and impracticable interference in their operations. Response #1: ADEQ had proposed to require that fires set for training purposes be permitted in an effort to 602ART15NFRMGRRC120903.DOC 12/9/03 32 better track and report emissions data from such fires through the notice requirement included in fire permits (R18-2-602(D)(3)(f)). However, ADEQ agrees that requiring fire officers to apply to ADEQ or a delegated authority could be impracticable; the data can be adequately tracked with a similar notice requirement while still exempting such fires from the actual permit requirement. ADEQ will add language to R18-2-602(C)(2), the subsection which enumerates those fires exempted from the permit requirement, to read A. . . if such fire is set or permission given for the purpose of fire control of an active wildfire, or instruction in the methods of fighting fires,@ with the inclusion of a notice requirement similar to the one in subsection (D)(3)(f). It should be noted that this notice requirement can be satisfied by an annual report to the Director or delegated authority; it is not required that each individual training fire be reported. Comment #2: One commenter suggested that subsection (G), which deals with permits issued by a delegated authority, be changed. Specifically, there is a provision in that subsection which prohibits delegated authorities from issuing permits to themselves. Commenter suggested adding a sentence (APermits issued by a delegated authority for the purpose of instruction in the methods of fire fighting are excepted from the provisions of this rule.@) excepting training fires from this prohibition. Response #2: Exempting training fires from the permit requirement, generally, makes it unnecessary to add an exception to subsection (G). Comment #3: One commenter objected to subsection (G), claiming it was unenforceable and would create administrative and practical difficulties. Commenter asked, Aif an agency is not responsible enough to control its own fires and training then why should they be allowed to issue permits to the public?@ Response #3: ADEQ does not intend to prevent a delegated authority from issuing any permits, just permits from themselves to themselves. ADEQ thinks it is appropriate to oversee permits to delegated authorities, both to avoid potential conflicts of interest as well as better track emissions data. It should be noted that a number of commenters think that these permits are issued on a fire-by-fire basis. In fact, open burning permits have a term of up to one year, and can cover multiple burn projects. Comment #4: One commenter asked if any of the model fire codes, or the National Fire Protection Agency Standards were consulted when drafting these rules. 602ART15NFRMGRRC120903.DOC 12/9/03 33 Response #4: No. ADEQ has reviewed the National Fire Protection Agency Standards and the NFPA 1 Uniform Fire Code, 2003 Edition, to determine their relevance to air quality and whether their consideration might improve the proposed rules. ADEQ found that these documents deal with fire safety, fire-fighting and fire preparedness issues. These areas fall outside the scope of this rule. ADEQ=s fire rules deal with the control of emissions and the tracking of emissions related data, rather than the actual control of fires themselves. Comment #5: One commenter requested clarification on the difference between subsection (C)(3), fires set for the Apurpose of disease and pest prevention in organized, area-wide control of epidemics or infestations . . .@ which are exempt from permit requirements, and subsection (D)(1)(e) fires set for the Apurpose of weed abatement, the prevention of a fire hazard . . .@ which are subject to permit requirements. Response #5: Fires described in (C)(3) would be fires authorized by the Director of the Department of Agriculture in an emergency in order to prevent the spread of disease or pest infestation. In such a situation, time constraints may make the normal permitting procedure ineffective. Representatives from the Department of Agriculture were included in the Fire Emissions Work Group. They indicated that they needed this authority so that they might effectively deal with such an emergency. It should be noted that there has been no need, up to the present time, for this authority to be exercised. Fires under (D)(1)(e), however, are not likely to be emergency in nature, and such burners should go through the normal permitting procedure. Comment #6: Commenter proposed changing (D)(3)(c) so that it reads A[a] requirement that burns be conducted during the following periods, unless otherwise waived or directed by the Director or delegated authority on a specific day basis@. The provision limits fires from one hour after sunrise to 2 hours before sunset. Response #6: ADEQ thinks it is appropriate that the Director retain authority in this matter. Atmospheric conditions change just before sunset, usually minimizing smoke dispersion. For this reason, most burns should be conducted during the day. There are circumstances where nighttime, or extended daytime, burns might be appropriate, but ADEQ thinks that authority to make that decision should, in general, remain centralized with the Director. Comment #7: Commenter noted that R18-2-602(D)(3)(f) is in reference to a reporting requirement, and asks 602ART15NFRMGRRC120903.DOC 12/9/03 34 if the report form will be available to the delegated authority or will each applicant be responsible for providing this information. Response #7: The most likely scenario is that the burner will be required by his or her permit to notify the permitting authority of their burn, either on a daily or annual basis. The delegated authority would then take down the pertinent information on the form provided by ADEQ for this purpose, and report that information to ADEQ, under subsection (G)(3), in an annual report to the Director. Comment #8: Commenter suggested that, in (D)(3)(g) Aa notation should be made that the applicant contact the local fire jurisdiction to determine what local open burning requirements have been established, to obtain a local permit if required, and to follow all local adopted fire code requirements.@ Response #8: ADEQ thinks that this issue is adequately addressed by R18-2-602(I) which states that A[n]othing in this Section is intended to permit any practice which is a violation of any statute, ordinance, rule, or regulation.@ Comment #9: Commenter pointed out that ADEQ=s preamble to the proposed rule was inaccurate. The preamble suggested that a permit exemption for air curtain destructors was considered, under the federal regional haze rule, in order to remove an administrative barrier to certain types of burning. In fact, the regional haze rule requires removal of administrative barriers for alternatives to burning. Response #9: ADEQ has retained and clarified the referenced paragraph in the preamble. The preamble now distinguishes between alternatives to burning and burning with a method that has lower emissions, but notes that removing an administrative barrier to either could be beneficial. Comment #10: Commenter noted that subsection (D)(1)(a) allows construction burning, with a permit. (A)(4) defines Aconstruction burning@ as including materials from Ademolition or modification of any buildings@ but precludes burning of Aprohibited materials.@ (A)(13) defines Aprohibited materials@ to include a number of common building materials, but that the list is not exhaustive and does not include other potentially harmful materials such as linoleum flooring, lead-painted wood, and composite counter-tops. He suggested adding such materials to (A)(13). Additionally, he suggested requiring a separate permit for the burning of building materials, as does Pinal County. Such a permit requires an on-site inspection before the 602ART15NFRMGRRC120903.DOC 12/9/03 35 permit is issued. Response #10: ADEQ thinks that onsite inspections are an inefficient use of limited resources. However, the list of prohibited materials in R18-2-602(A)(13) can be expanded to include those items that commenter suggested. Comment #11: Commenter noted that under subsection (D)(3)(g) permittees should know to make daily notifications of burning activity to the Alocal fire-fighting agency,@ or to the State Forester. He thought it unclear whether Alocal fire-fighting agency@ includes private fee-for-service firefighting corporations or is limited to municipal fire departments and local fire districts. Private for-profit services operate outside of jurisdictional limits and it is unclear how Aoperational bounds@ of such services would be defined for the purposes of informing permittees whom to notify. Response #11: ADEQ will clarify, in the rule, that private fee-for-service fire-fighting corporations are considered Alocal fire-fighting agencies,@ for the purpose of fulfilling notice requirements, when such private services are delegated authorities as defined in R18-2-602(A)(6). In the absence of such a delegated authority, permittees would be required to notify the state forester, as indicated by subsection (D)(3)(g). Comment #12: Commenter noted that subsection (F) allows the permitting of household waste burning. Commenter thinks that such burning inevitably leads to nuisance and suggested that statutory authority to allow it does not equal legislative mandate, and therefore suggested that subsection (F) be deleted. Response #12: ADEQ thinks it better to deal with the issue of household waste on an individual basis. Writing household waste entirely out of the rule would not allow for such individual assessment of each such burn. If the burning is likely to cause a nuisance, the application for that burn permit can be denied. Such nuisance is more likely to be an issue in urban counties than it would in rural. Therefore, ADEQ will retain subsection (F) in the rule of statewide application. Those counties with more urban development such as Maricopa, Pima and Pinal, which have independent authority to permit fires, may prohibit such burning if they so choose, as is the case with the Maricopa county rules. Comment #13: Commenter asserted that 40 CFR 51.308 and 51.309, the Regional Haze rule, refers to prescribed burning, which does not include fire-fighting training. Commenter listed a number of reasons how 602ART15NFRMGRRC120903.DOC 12/9/03 36 sections 308 and 309 do not apply to fires set for training purposes and stated that those fires should continue to be exempt from permit requirements. Response #13: Without addressing the issue of whether or not 40 CFR 51.308 and 309 do apply to fires set for the purpose of conducting fire-fighting training, ADEQ has decided to exempt such fires from the open burning permit requirement, while retaining the notice requirements that would allow ADEQ to track the relevant emissions data. Comment #14: Commenter stated that the limitations, in subsection (D)(3)(c), set on the hours when permitted burns may be conducted unreasonably limit such fires to daylight hours. They claimed that in order to properly train their fire-fighters to combat fires arising from aircraft incidents, training must be conducted both day and night. Response #14: Since ADEQ has decided to exempt fires set for training purposes from the permit requirement, subsection (D)(3)(c) no longer applies to such fires. Comment #15: Commenter listed several practical problems that would make training difficult if they are required to apply for a permit from ADEQ for each training exercise. Response #15: These issues should be adequately addressed by ADEQ=s decision to continue to exempt training fires from the permit requirement. While ADEQ will retain a notice requirement to allow for the tracking and monitoring of necessary emissions data, it should be noted that this requirement can be filled by the filing of an annual report; it is unnecessary to report on a fire-by-fire basis. Comment #16: Commenter expressed concern that the requirements of Article 15 relating to Burn Plans, Authorizations, and Accomplishment Forms will be a burdensome addition to his paperwork when conducting his own range management burns on his privately owned land. Commenter was uncertain of what the actual burden was on a private landowner. Response #16: Under R18-2-1502, the provisions of this Article do not apply to private landowners conducting burns unless they enter into a memorandum of agreement with ADEQ. Private landowners conducting burns would be governed by the provisions of R18-2-602, Unlawful Open Burning. However, 602ART15NFRMGRRC120903.DOC 12/9/03 37 when a private landowner conducts a range management burn in cooperation with a State or Federal Land Manager, that Land Manager, not the private landowner, would be covered by the provisions of Article 15, Forest and Range Management Burns. Comment #17: Commenter was concerned with the language used in R18-2-1503(C)(6) A[b]y area planned for wildland fire use, . . . and annual acres to be burned . . .@ etc. (emphasis added). Commenter noted that wildland fires cannot, by virtue of their very nature, be planned, and asked if there is more appropriate language that might be used. Response #17: ADEQ recognizes that wildland fires, or wildfires, cannot be accurately predicted. However, a wildland fire use, as defined in this rule, is a pre-planned event, and a wildland fire use may only take place in an area planned for it. The purpose of R18-2-1503(C)(6) is to get an estimate of the area, fuel types and acreage that may be burned in a wildland fire use incident. ADEQ has clarified some language but kept the phrase Aplanned area.@ Comment #18: Commenter wondered how one should properly coordinate prescribed burning activities on federal land with adjacent private landowners. Response #18: ADEQ considers this to be an operational issue not addressed in the scope of these rules, but is better dealt with at a practical level between the appropriate Land Manager and the private landowner. Comment #19: Commenter asked if there is a definition of Anuisance@ for R18-2-602(D)(3)(d)(iii). Response #19: The definition of Anuisance@ appropriate to this section is to be found in A. R. S. ' 13-2917, Public Nuisance; Abatement; Classification. Comment #20: Commenter asked whether the reporting requirement of R18-2-602(D)(3)(f) falls on the permit applicant or the delegated authority. Response # 20: While the specific forms dealing with these requirements are still being designed, the permit applicant would, under R18-2-602(D)(3)(g) notify the local fire-fighting agency or state forester of the burn. That official would, at that time, collect the necessary data to meet the reporting requirement of (D)(3)(f) which would then be reported to the Director or delegated authority in their daily or annual report. 602ART15NFRMGRRC120903.DOC 12/9/03 38 Comment #21: Commenter suggested that it be clarified that fires using air curtain destructors are required to be permitted. Response #21: Fires using air curtain destructors will be added to R18-2-602(D), Open Outdoor Fires Requiring a Permit, under subsection (D)(1). Comment #22: Commenter expressed some confusion over whether, under R18-2-602(C)(4) all fires set by the federal government or any of its departments, agencies or agents, etc., are exempt from the permit open outdoor fire permit requirement. Response #22: Only those fires set by the federal government that would be regulated under Article 15, Forest and Range Management Burns, would be exempt from the requirements of R18-2-602, Unlawful Open Fires. ADEQ will change the language of subsection (C)(4) to better reflect the intention that such fires are to be governed by either the open burning rule, or the range management rules. Comment #23: Commenter was concerned with the inclusion of Awindrows@ in R18-2-602(D)(3)(f)(iii) as an example of the fire types to be included in the permit reporting requirement. He suggested that such fires are dangerously unstable and would like mention of them to be removed from rule. Response #23: ADEQ has removed Awindrow@ as an example and substituted Apit@ in subsection (D)(3)(f)(iii). 12. Any other matter prescribed by statute that are applicable to the specific agency or to any other specific rule or class of rules: Not applicable 13. Incorporations by reference and their location in the rules: Not applicable 14. Was this rule previously made as an emergency rule? No 602ART15NFRMGRRC120903.DOC 12/9/03 39 15. The full text of the rules follows: 602ART15NFRMGRRC120903.DOC 12/9/03 40 TITLE 18. ENVIRONMENTAL QUALITY CHAPTER 2. DEPARTMENT OF ENVIRONMENTAL QUALITYAIR POLLUTION CONTROL ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES Section R18-2-602. Unlawful Open Burning ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS Section R18-2-1501. Definitions R18-2-1502. Applicability R18-2-1503. Annual Registration, Program Evaluation and Planning for Prescribed Burns R18-2-1504. Prescribed Burn Plan Contents R18-2-1505. Prescribed Burn Requests and Authorization R18-2-1506. Smoke Dispersion Evaluation R18-2-1507. Prescribed Burn Accomplishment; ADEQ Recordkeeping; Wildfire Reporting R18-2-1508. Prescribed Natural Fires; Wildland Fire Use: Plan;, Authorization;, Monitoring; Interagency Consultation; Status Reporting R18-2-1509. Emission Reduction Techniques; BMP R18-2-1510. Smoke Management Techniques R18-2-1510 R18-2-1511. Monitoring R18-2-1511 R18-2-1512. Burner Qualifications R18-2-1512 R18-2-1513. Public Notification and Awareness Program; Regional Coordination R18-2-1514. Oversight R18-2-1514. Surveillance and Enforcement R18-2-1515. Forms; Electronic Copies; Information Transfers 602ART15NFRMGRRC120903.DOC 12/9/03 41 ARTICLE 6. EMISSIONS FROM EXISTING AND NEW NONPOINT SOURCES R18-2-602. A. Unlawful Open Burning Notwithstanding the provisions of any other rule in this Chapter, it is unlawful for any person to ignite, cause to be ignited, permit to be ignited, or suffer, allow or maintain any open outdoor fire. B. "Open outdoor fire," as used in this rule, means any combustion of combustible material of any type outdoors, in the open where the products of combustion are not directed through a flue. "Flue," as used in this rule, means any duct or passage for air, gases or the like, such as a stack or chimney. C. The following fires are excepted from the provisions of this rule: 1. Fires used only for cooking of food or for providing warmth for human beings or for recreational purposes or the branding of animals or the use of orchard heaters for the purpose of frost protection in farming or nursery operations. 2. Any fire set or permitted by any public officer in the performance of official duty, if such fire is set or permission given for the purpose of weed abatement, the prevention of a fire hazard, or instruction in the methods of fighting fires. 3. Fires set by or permitted by the state entomologist or county agricultural agents of the county for the purpose of disease and pest prevention. 4. Fires set by or permitted by the federal government or any of its departments, agencies or agents, the state or any of its agencies, departments or political subdivisions, for the purpose of watershed rehabilitation or control through vegetative manipulation. D. Permission for the setting of any fire given by a public officer in the performance of official duty under subsections (C)(2), (3), or (4) shall be given, in writing, and a copy of such written permission shall be transmitted immediately to the Director of the Department of Environmental Quality and the control officer, if any, of the county, district or region in which such fire is allowed. The setting of any such fire shall be constructed in a manner and at such time as approved by the Director, unless doing so would defeat the purpose of the exemption. E. The following fires may be excepted from the provisions of this Section when permitted in writing by the Director of the Department of Environmental Quality or the control officer of the county, district or region in which such fire is allowed: 1. Fires set for the disposal of dangerous materials where there is no safe alternative method of disposal. a. "Dangerous material" is any substance or combination of substances which is able or 602ART15NFRMGRRC120903.DOC 12/9/03 42 likely to inflict bodily harm or property loss unless neutralized, consumed or otherwise disposed of in a controlled and safe manner. b. Fires set for the disposal of dangerous materials shall be permitted only when there is no safe alternative method of disposal, and when the burning of such materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts which will endanger health or safety. 2. Open outdoor fires for the disposal of ordinary household trash in an approved waste burner in nonurban areas of less than 100 well spread out dwelling units per square mile where no refuse collection and disposal service is available. a. An "approved waste burner" is an incinerator constructed of fire resistant material with a cover or screen which is closed when in use having openings in the sides or top no greater than 1 inch in diameter. b. Open burning of the following materials is forbidden: Garbage resulting from the processing, storage, service or consumption of food; asphalt shingles; tar paper; plastic and rubber products (such as waste crankcase oil, transmission oil and oil filters); transformer oils; and hazardous material containers including those that contained inorganic pesticides, lead, cadmium, mercury, or arsenic compounds. F. The Director of the Department of Environmental Quality or the air pollution control officer, if any, of the county, district, or region may delegate the authority for the issuance of allowable open burning permits to responsible local officers. Such permits shall contain conditions limiting the manner and the time of the setting of such fires as specified in the Arizona Guidelines for Open Burning and shall contain a provision that all burning be extinguished at the discretion of the Director or his authorized representative during periods of inadequate atmospheric smoke dispersion, periods of excessive visibility impairment which could adversely affect public safety, or periods when smoke is blown into populated areas so as to create a public nuisance. Any local officer delegated the authority for issuance of open burning permits shall maintain a copy of all currently effective permits issued including a means of contacting the person authorized by the permit to set an open fire in the event that an order for extinguishing of open burning is issued. G. Nothing in this rule is intended to permit any practice which is a violation of any statute, ordinance, rule or regulation. A. In addition to the definitions contained in A.R.S. ' 49-501, in this Section: 1. AAgricultural burning@ means burning vegetative materials related to producing and harvesting crops and raising animals for the purpose of marketing for profit, or providing a 602ART15NFRMGRRC120903.DOC 12/9/03 43 livelihood, but does not include burning of household waste or prohibited materials. A person may conduct agricultural burns in fields, piles, ditch banks, fence rows, or canal laterals for purposes such as weed control, waste disposal, disease and pest prevention, or site preparation. 2. AApproved waste burner@ means an incinerator constructed of fire resistant material with a cover or screen that is closed when in use, and has openings in the sides or top no greater than one inch in diameter. 3. AClass I Area@ means any one of the Arizona mandatory federal class I areas defined in A.R.S. ' 49-401.01. 4. AConstruction burning@ means burning wood or vegetative material from land clearing, site preparation, or fabrication, erection, installation, demolition, or modification of any buildings or other land improvements, but does not include burning household waste or prohibited material. 5. ADangerous material@ means any substance or combination of substances that is capable of causing bodily harm or property loss unless neutralized, consumed, or otherwise disposed of in a controlled and safe manner. 6. ADelegated authority@ means any of the following: a. A county, city, town, air pollution control district, or fire district that has been delegated authority to issue open burning permits by the Director under A.R.S. ' 49-501(E); or b. A private fire protection service provider that has been assigned authority to issue open burning permits by one of the authorities in subsection (A)(6)(a). 7. ADirector@ means the Director of the Department of Environmental Quality, or designee. 8. AEmission reduction techniques@ means methods for controlling emissions from open outdoor fires to minimize the amount of emissions output per unit of area burned. 9. AFlue,@ as used in this Section, means any duct or passage for air or combustion gases, such as a stack or chimney. 10. AHousehold waste@means any solid waste including garbage, rubbish, and sanitary waste from a septic tank that is generated from households including single and multiple family residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day-use recreation areas, but does not include construction debris, landscaping rubble, or demolition debris. 602ART15NFRMGRRC120903.DOC 12/9/03 44 11. AIndependent authority to permit fires@ means the authority of a county to permit fires by a rule adopted under Arizona Revised Statutes, Title 49, Chapter 3, Article 3, and includes only Maricopa, Pima, and Pinal counties. 12. AOpen outdoor fire or open burning@ means the combustion of material of any type, outdoors and in the open, where the products of combustion are not directed through a flue. Open outdoor fires include agricultural, residential, prescribed, and construction burning, and fires using air curtain destructors. 13. AProhibited materials@ means nonpaper garbage from the processing, storage, service, or consumption of food; chemically treated wood; lead-painted wood; linoleum flooring, and composite counter-tops; tires; explosives or ammunition; oleanders; asphalt shingles; tar paper; plastic and rubber products, including bottles for household chemicals; plastic grocery and retail bags; waste petroleum products, such as waste crankcase oil, transmission oil, and oil filters; transformer oils; asbestos; batteries; anti-freeze; aerosol spray cans; electrical wire insulation; thermal insulation; polyester products; hazardous waste products such as paints, pesticides, cleaners and solvents, stains and varnishes, and other flammable liquids; plastic pesticide bags and containers; and hazardous material containers including those that contained lead, cadmium, mercury, or arsenic compounds. 14. AResidential burning@ means open burning of vegetative materials conducted by or for the occupants of residential dwellings, but does not include burning household waste or prohibited material. 15. B. APrescribed burning@ has the same meaning as in R18-2-1501. Unlawful open burning. Notwithstanding any other rule in this Chapter, a person shall not ignite, cause to be ignited, permit to be ignited, allow, or maintain any open outdoor fire in a county without independent authority to permit fires except as provided in A.R.S. ' 49-501 and this Section. C. Open outdoor fires exempt from a permit. The following fires do not require an open burning permit from the Director or a delegated authority: 1. Fires used only for: a. Cooking of food, b. Providing warmth for human beings, c. Recreational purposes, d. Branding of animals, e. Orchard heaters for the purpose of frost protection in farming or nursery operations, 602ART15NFRMGRRC120903.DOC 12/9/03 45 and f. 2. The proper disposal of flags under 4 U.S.C. ' 8. Any fire set or permitted by any public officer in the performance of official duty, if the fire is set or permission given for the following purpose: a. Control of an active wildfire; or b. Instruction in the method of fighting fires, except that the person setting these fires must comply with the reporting requirements of subsection (D)(3)(f). 3. Fire set by or permitted by the Director of Department of Agriculture for the purpose of disease and pest prevention in an organized, area-wide control of an epidemic or infestation affecting livestock or crops. 4. Prescribed burns set by or assisted by the federal government or any of its departments, agencies, or agents, or the state or any of its agencies, departments, or political subdivisions, regulated under Article 15 of this Chapter. D. Open outdoor fires requiring a permit. 1. The following open outdoor fires are allowed with an open burning permit from the Director or a delegated authority: a. Construction burning; b. Agricultural burning; c. Residential burning; d. Prescribed burns conducted on private lands without the assistance of a federal or state land manager as defined under R18-2-1501; e. Any fire set or permitted by a public officer in the performance of official duty, if the fire is set or permission given for the purpose of weed abatement, or the prevention of a fire hazard, unless the fire is exempt from the permit requirement under subsection (C)(3); 2. f. Open outdoor fires of dangerous material under subsection (E); g. Open outdoor fires of household waste under subsection (F); and h. Open outdoor fires that use an air curtain destructor, as defined in R18-2-101. A person conducting an open outdoor fire in a county without independent authority to permit fires shall obtain a permit from the Director or a delegated authority unless exempted under subsection (C). Permits may be issued for a period not to exceed one year. A person shall obtain a permit by completing an ADEQ-approved application form. 3. Open outdoor fire permits issued under this Section shall include: 602ART15NFRMGRRC120903.DOC 12/9/03 46 a. A list of the materials that the permittee may burn under the permit; b. A means of contacting the permittee authorized by the permit to set an open fire in the event that an order to extinguish the open outdoor fire is issued by the Director or the delegated authority; c. A requirement that burns be conducted during the following periods, unless otherwise waived or directed by the Director on a specific day basis: d. i. Year round: ignite fire no earlier than one hour after sunrise; and ii. Year round: extinguish fire no later than two hours before sunset. A requirement that the permittee conduct all open burning only during atmospheric conditions that: i. Prevent dispersion of smoke into populated areas; ii. Prevent visibility impairment on traveled roads or at airports that result in a safety hazard; e. iii. Do not create a public nuisance or adversely affect public safety; iv. Do not cause an adverse impact to visibility in a Class I area; and v. Do not cause uncontrollable spreading of the fire; A list of the types of emission reduction techniques that the permittee shall use to minimize fire emissions. f. A reporting requirement that the permittee shall meet by providing the following information in a format provided by the Director for each date open burning occurred, on either a daily basis on the day of the fire, or an annual basis in a report to the Director or delegated authority due on March 31 for the previous calendar year: i. The date of each burn; ii. The type and quantity of fuel burned for each date open burning occurred; iii. The fire type, such as pile or pit, for each date open burning occurred; and iv. For each date open burning occurred, the legal location, to the nearest section, or latitude and longitude, to the nearest degree minute, or street address for residential burns. g. A requirement that the person conducting the open burn notify the local fire-fighting agency or private fire protection service provider, if the service provider is a delegated authority, before burning. If neither is in existence, the person conducting the burn shall notify the state forester. 602ART15NFRMGRRC120903.DOC 12/9/03 47 h. A requirement that the permittee start each open outdoor fire using items that do not cause the production of black smoke; i. A requirement that the permittee attend the fire at all times until it is completely extinguished; j. A requirement that the permittee provide fire extinguishing equipment on-site for the duration of the burn; k. A requirement that the permittee ensure that a burning pit, burning pile, or approved waste burner be at least 50 feet from any structure; l. A requirement that the permittee have a copy of the burn permit on-site during open burning; m. A requirement that the permittee not conduct open burning when an air stagnation advisory, as issued by the National Weather Service, is in effect in the area of the burn or during periods when smoke can be expected to accumulate to the extent that it will significantly impair visibility in Class I areas; n. A requirement that the permittee not conduct open burning when any stage air pollution episode is declared under R18-2-220. o. A statement that the Director, or any other public officer, may order that the burn be extinguished or prohibit burning during periods of inadequate smoke dispersion, excessive visibility impairment, or extreme fire danger; and p. A list of the activities prohibited and the criminal penalties provided under A.R.S. ' 13-1706. 4. The Director or a delegated authority shall not issue an open burning permit under this Section: a. That would allow burning prohibited materials other than under a permit for the burning of dangerous materials; b. If the applicant has applied for a permit under this Section to burn a dangerous material which is also hazardous waste under 40 CFR 261, but does not have a permit to burn hazardous waste under 40 CFR 264, or is not an interim status facility allowed to burn hazardous waste under 40 CFR 265; or c. If the burning would occur at a solid waste facility in violation of 40 CFR 258.24 and the Director has not issued a variance under A.R.S. ' 49-763.01. E. Open outdoor fires of dangerous material. A fire set for the disposal of a dangerous material is allowed by the provisions of this Section, when the material is too dangerous to store and transport, 602ART15NFRMGRRC120903.DOC 12/9/03 48 and the Director has issued a permit for the fire. A permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The Director shall permit fires for the disposal of dangerous materials only when no safe alternative method of disposal exists, and burning the materials does not result in the emission of hazardous or toxic substances either directly or as a product of combustion in amounts that will endanger health or safety. F. Open outdoor fires of household waste. An open outdoor fire for the disposal of household waste is allowed by provisions of this Section when permitted in writing by the Director or a delegated authority. A permit issued under this subsection shall contain all provisions in subsection (D)(3) except for subsections (D)(3)(e) and (D)(3)(f). The permittee shall conduct open outdoor fires of household waste in an approved waste burner and shall either: 1. Burn household waste generated on-site on farms or ranches of 40 acres or more where no household waste collection or disposal service is available; or 2. Burn household waste generated on-site where no household waste collection and disposal service is available and where the nearest other dwelling unit is at least 500 feet away. G. Permits issued by a delegated authority. The Director may delegate authority for the issuance of open burning permits to a county, city, town, air pollution control district, or fire district. A delegated authority may not issue a permit for its own open burning activity. The Director shall not delegate authority to issue permits to burn dangerous material under subsection (E). A county, city, town, air pollution control district, or fire district with delegated authority from the Director may assign that authority to one or more private fire protection service providers that perform fire protection services within the county, city, town, air pollution control district, or fire district. A private fire protection provider shall not directly or indirectly condition the issuance of open burning permits on the applicant being a customer. Permits issued under this subsection shall comply with the requirements in subsection (D)(3) and be in a format prescribed by the Director. Each delegated authority shall: 1. Maintain a copy of each permit issued for the previous five years available for inspection by the Director; 2. For each permit currently issued, have a means of contacting the person authorized by the permit to set an open fire if an order to extinguish open burning is issued; and 3. Annually submit to the Director by May 15 a record of daily burn activity, excluding household waste burn permits, on a form provided by the Director for the previous calendar year containing the information required in subsections (D)(3)(e) and (D)(3)(f). H. The Director shall hold an annual public meeting for interested parties to review operations of the 602ART15NFRMGRRC120903.DOC 12/9/03 49 open outdoor fire program and discuss emission reduction techniques. I. Nothing in this Section is intended to permit any practice that is a violation of any statute, ordinance, rule, or regulation. ARTICLE 15. FOREST AND RANGE MANAGEMENT BURNS R18-2-1501. Definitions In addition to the definitions contained in A.R.S. ' 49-501 and R18-2-101, in this Article: 1. AActivity fuels@ means those fuels created by human activities such as thinning or logging. 1.2. "ADEQ" means the Department of Environmental Quality. 3. AAnnual emissions goal@ means the annual establishment in cooperation with the F/SLM=s, under R18-2-1503(G), of a planned quantifiable value of emissions reduction from prescribed fires and fuels management activities. 2. "BMP" means best management practices as described in R18-2-1509. 4. ABurn plan@ means the ADEQ form that includes information on the conditions under which a burn will occur with details of the burn and smoke management prescriptions. 3.5. "Burn prescription" means, with regard to a burn project, the pre-determined area, intensity of heat, and rate of spread fuel, and weather conditions required to attain planned resource management objectives. 4.6. "Burn project" means an active or planned prescribed burn, including a prescribed natural fire wildland fire use incident. 5. "Class I Area" means a mandatory area designated pursuant to Section 169A of the Clean Air Act Amendments of 1990. 6.7. "Duff" means forest floor material consisting of decomposing needles and other natural materials. 8. AEmission reduction techniques (ERT)@ means methods for controlling emissions from prescribed fires to minimize the amount of emission output per unit of area burned. 7.9. AFederal land manager (FLM)@ means any department, agency, or agent of the federal government, including the following: a. United States Forest Service, b. United States Fish and Wildlife Service, c. National Park Service, d. Bureau of Land Management, e. Bureau of Reclamation, 602ART15NFRMGRRC120903.DOC 12/9/03 50 f. Department of Defense, g. Bureau of Indian Affairs, and h. United States Soil Conservation Service. Natural Resources Conservation Service. 8.10. "F/SLM" means a federal land manager or a state land manager. 9.11. "Local fire management officer" means a person designated by a F/SLM as responsible for fire management in a local district or area. 10.12. "Mop-up" means the act of extinguishing or removing burning material from a prescribed fire to reduce smoke impacts. 11.13. "National Wildfire Coordinating Group" means the national inter-agency group of federal and state land managers that shares similar wildfire suppression programs and has established standardized inter-agency training courses and qualifications for fire management positions. 14. ANon-burning alternatives to fire@ means techniques that replace fire for at least five years as a means to treat activity fuels created to achieve a particular land management objective (e.g., reduction of fuel-loading, manipulation of fuels, enhancement of wildlife habitat, and ecosystem restoration). These alternatives are not used in conjunction with fire. Techniques used in conjunction with fire are referred to as emission reduction techniques (ERTs). 12.15. "Planned resource management objectives" means public interest goals in support of land management agency objectives including silviculture, wildlife habitat management, grazing enhancement, fire hazard reduction, wilderness management, cultural scene maintenance, weed abatement, watershed rehabilitation, vegetative manipulation, and disease and pest prevention. 13.16. "Prescribed burning" means the controlled application of fire to wildland fuels that are in either a natural or modified state, under certain burn prescription conditions and smoke management prescription conditions that have been specified by the land manager in charge of or assisting the burn, to attain planned resource management objectives. Prescribed burning includes does not include a fire set or permitted by a public officer to provide instruction in fire fighting methods, or construction or residential burning under R18-2-602. A prescribed fire may be ignited either by a trained fire specialist or by natural causes such as lightning. 14.17. "Prescribed fire manager" means a person designated by a F/SLM as responsible for prescribed burning for that land manager. 15. "Prescribed natural fire" means a wildland fire that is ignited by natural causes such as lightning rather than by a trained fire specialist, that is subsequently allowed to continue burning using the same controls and for the same planned resource management objectives as prescribed burning. 16.18. "Smoke management prescription" means the predetermined meteorological conditions that affect 602ART15NFRMGRRC120903.DOC 12/9/03 51 smoke transport and dispersion under which a burn could occur without adversely affecting public health and welfare. 19. ASmoke management techniques@ (SMT) means management and dispersion practices used during a prescribed burn or wildland fire use incident which affect the direction, duration, height, or density of smoke. 17.20. "Smoke management unit" means any of 11 the geographic areas defined by ADEQ whose area is based on primary watershed boundaries and whose outlines are outline is determined by diurnal windflow patterns that allow smoke to follow predictable drainage patterns. A map of the state divided into 11 the smoke management units is on file with ADEQ. 18.21. "State land manager (SLM)" means any department, agency, or political subdivision of the state government that is responsible for wildland management including the following: a. State Land Department, b. Department of Transportation, c. Department of Game and Fish, and d. Parks Department. 19.22. "Wildfire" means a an unplanned wildland fire subject to appropriate control measures that does not meet resource management objectives and that may threaten life, property, public health, or the ecosystem. Wildfires include those incidents where suppression may be limited for safety, economic, or resource concerns. 20. "Wildland" means an area in which development is essentially non-existent, except for pipelines, power lines, roads, railroads, or other transportation or conveyance facilities. 23. AWildland fire use@ means a wildland fire that is ignited by natural causes, such as lightning, and is managed using the same controls and for the same planned resource management objectives as prescribed burning. R18-2-1502. A. Applicability A F/SLM that is conducting or assisting a prescribed burn shall follow the requirements of this Article. B. A private or municipal burner with whom ADEQ has entered into a memorandum of agreement shall follow the requirements of this Article. B.C. The provisions of this Article apply to all areas of the state except Indian Trust lands. All federallymanaged lands and all state lands, parks, and forests are under the jurisdiction of ADEQ in matters 602ART15NFRMGRRC120903.DOC 12/9/03 52 relating to air pollution from prescribed burning. C.D. Notwithstanding subsection (B) (C), ADEQ and any Indian tribe may enter into a memorandum of agreement to implement this Article. E. ADEQ and any private or municipal prescribed burner may enter into a memorandum of agreement to implement this Article. R18-2-1503. A. Annual Registration, Program Evaluation and Planning for Prescribed Burns Each F/SLM shall register annually with ADEQ, on a form prescribed by ADEQ, all planned burn projects, including areas considered for potential prescribed natural fires planned for wildland fire use, for the following year. C.B. Each planned year extends from August January 1 of the registration year to July December 31 of the same following year. Each F/SLM shall use best efforts to register before August December 31 and no later than January 31 of each year. B.C. A F/SLM shall provide include the following information on the registration form: 1. The F/SLM's name, address, and business telephone number; 2. The name, address, and business telephone number of an air quality representative who will provide technical support to ADEQ for decisions regarding prescribed burning. The same air quality representative may be selected by more than one F/SLM or Indian tribe; 3. All prescribed burn projects and potential prescribed natural fire wildland fire use areas planned for the next year; and 4. Maximum project and annual acres to be burned, maximum daily acres to be burned, fuel types within project area, and planned use of emission reduction techniques to support the annual emissions goal for each prescribed burn project; 5. Planned use of any smoke management techniques for each prescribed burn project; 6. Maximum project and annual acres projected to be burned, maximum daily acres projected to be burned, and a map of the anticipated project area, fuel types and loading within the planned area for an area the F/SLM anticipates for wildland fire use; 4.7. A list of all burn projects that were completed during the previous year; 8. Project area for treatment, treatment type, fuel types to be treated, and activity fuel loading to support the annual emissions goal for areas to be treated using non-burning alternatives to fire; and 9. The area treated using non-burning alternatives to fire during the previous year including the number of acres, the specific types of alternatives utilized, and the location of these areas. 602ART15NFRMGRRC120903.DOC 12/9/03 53 D. After consultation with the F/SLM, ADEQ may request additional information related to tracking burn projects for registration of prescribed burns and wildland fire use to support regional coordination of smoke management, annual emission goal setting using ERTs, and non-burning alternatives to fire. E. A F/SLM may amend a registration at any time with a written submission to ADEQ. ADEQ shall approve a new prescribed burn even if the F/SLM has failed to amend a registration if the F/SLM has complied with the other provisions of this Article. F. ADEQ shall accept accepts a facsimile or other electronic method as a means of complying with the deadline for registration. If an electronic means is used a facsimile is submitted, the F/SLM shall deliver the original paper registration form to ADEQ for its records. ADEQ shall acknowledge in writing the receipt of each registration. If ADEQ and the F/SLMs jointly develop an electronic filing and reporting system, the original paper form may be waived, and ADEQ shall notify all F/SLMs of this change. G. No later than 14 days before a F/SLM requests permission to proceed with a registered burn project other than a prescribed natural fire, the F/SLM shall submit a Burn Plan to ADEQ, as described in R18-2-1504. A Burn Plan for a prescribed natural fire shall be submitted as prescribed by R18-21508. G. ADEQ shall hold a meeting after January 31 and before April 1 of each year between ADEQ and F/SLM=s to evaluate the program and cooperatively establish the annual emission goal. The annual emission goal shall be developed to minimize prescribed fire emissions to the maximum extent feasible using emission reduction techniques and alternatives to burning subject to economic, technical, and safety feasibility criteria, and consistent with land management objectives. H. At least once every five years, ADEQ shall request long-term projections of future prescribed fire and wildland fire use activity from the F/SLMs to support planning for visibility impairment and assessment of other air quality concerns by ADEQ. R18-2-1504. A. Prescribed Burn Plan Contents Each F/SLM planning a prescribed burn other than a prescribed natural fire, shall complete and submit to ADEQ the "Burn Plan" form supplied by ADEQ no later than 14 days before the date on which the F/SLM requests permission to burn. ADEQ shall consider the information supplied on the Burn Plan Form as binding conditions under which the burn shall be conducted. A Burn Plan shall be maintained by ADEQ until notification from the F/SLM of the completion of the burn project. 602ART15NFRMGRRC120903.DOC 12/9/03 54 Revisions to the Burn Plan for a burn project shall be submitted in writing no later than 14 days before the date on which the F/SLM requests permission to burn. The F/SLM shall provide the following information on the "Burn Plan" form To facilitate the Daily Burn authorization process under R18-2-1505, the F/SLM shall include on the Burn Plan form: 1. An emergency telephone number that is answered 24 hours a day, seven days a week; 2. Burn prescription; 3. Smoke management prescription; 4. The number of acres to be burned, the quantity and type of fuel, type of burn, and the ignition technique to be used; 5. The land management objective or purpose for the burn such as restoration or maintenance of ecological function and indicators of fire resiliency; 5.6. A map depicting the potential impact of the smoke unless waived either orally or in writing by ADEQ. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the burn site, with smokesensitive areas delineated. The map shall use the appropriate scale to show the impacts of the smoke adequately; 6.7. Modeling of smoke impacts unless waived either orally or in writing by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulates, a carbon monoxide nonattainment area, or other smoke-sensitive area. Air quality modeling for these areas is mandatory unless waived either verbally or in writing by ADEQ. In consultation with the F/SLM, ADEQ shall provide guidelines on modeling; 7.8. The name of the official submitting the Burn Plan on behalf of the F/SLM; and 8.9. After consultation with the F/SLM, any other information to support the Burn Plan needed by ADEQ to assist in the Daily Burn authorization process for smoke management purposes or assessment of contribution to visibility impairment of Class I areas. B. A Burn Plan shall be submitted for a prescribed natural fire as prescribed by R18-2-1508. R18-2-1505. A. Prescribed Burn Requests and Authorization Each F/SLM planning a prescribed burn, other than a prescribed natural fire, shall complete and submit to ADEQ the "Daily Burn Request" form supplied by ADEQ. The F/SLM shall include the following information on the Daily Burn Request form shall include: 1. The contact information of the F/SLM conducting the burn; 602ART15NFRMGRRC120903.DOC 12/9/03 55 2. Each day of the burn; 2.3. The area to be burned per on the day for which the Burn Request is submitted, with reference to the Burn Plan, including size, and legal location to the section, and latitude and longitude to the minute; 4. Projected smoke impacts; and 3.5. Any local conditions or circumstances known to the F/SLM that, if conveyed to ADEQ, could impact the Daily Burn authorization process. B. After consultation with the F/SLM, ADEQ may request additional information related to the burn, meteorological, smoke dispersion, or air quality conditions to supplement the Daily Burn Request form and to aid in the Daily Burn authorization process. This information may include same day onsite and area meteorological, smoke dispersion, or air quality measurements. C. The F/SLM shall submit the Daily Burn Request form to ADEQ as expeditiously as practicable, but no later than 2 p.m. of the business day preceding the burn. An original form, a facsimile, or an electronic information transfer are acceptable submittals. D. An F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ, as follows: 1.D. ADEQ shall approve, approve with conditions, or disapprove a burn on the same business day as the Burn Request submittal. 2. If ADEQ fails to address a Burn Request by 10 p.m. of the business day on which the request is submitted, the Burn Request is approved by default after the burner makes a good faith effort to contact ADEQ to confirm that the Burn Request was received. 3. ADEQ may communicate its decision by verbal, written, or electronic means. ADEQ shall provide a written or electronic reply if requested by the F/SLM. If ADEQ does not communicate its decision, or a confirmation that the Burn Request was received, by 10 p.m., the burn is deemed approved. E. Except as provided in subsection (D), an F/SLM shall not ignite a prescribed burn without receiving the approval of ADEQ. F.E. If weather conditions cease to conform to those in the smoke management prescription of either the Burn Plan or an Approval with Conditions, the F/SLM shall cease ignitions and take appropriate action to reduce further smoke impacts, ensure safe and appropriate fire control, and notify the public when necessary., unless after After consultation with ADEQ, the smoke management prescription or burn plan may be is modified. F. The F/SLM shall ensure that there is appropriate signage and notification to protect public safety on 602ART15NFRMGRRC120903.DOC 12/9/03 56 transportation corridors including roadways and airports during a prescribed fire. G. Burn authorization for prescribed natural fires shall be as prescribed by R18-2-1508. H. The F/SLM in whose jurisdiction a wildfire occurs shall report all wildfires greater than 100 acres on a daily basis to ADEQ. The F/SLM shall include in the report the location, estimated control date, and estimated incident size of each wildfire. The F/SLM shall provide information on projected smoke and air quality impacts and on estimated control size upon request by ADEQ. R18-2-1506. Smoke Dispersion Evaluation ADEQ shall approve, approve with conditions, or disapprove a Daily Burn Request submitted pursuant to under R18-2-1505, by using the following factors for each smoke management unit: 1. Analysis of the emissions from burns in progress and residual emissions from previous burns on a day-to-day basis; 2. Analysis of emissions from active prescribed natural fires wildland fire use incidents, and active multiple-day burns, and consideration of potential long-term emissions estimates; 3. Analysis of the emissions from wildfires greater than 100 acres and consideration of their potential long-term growth; 4. Local burn conditions; 5. Burn prescription and smoke management prescription from the applicable Burn Plan; 6. Existing and predicted local air quality; 7. Local and synoptic meteorological conditions; 8. Type and location of areas to be burned; 9. Protection of the national visibility goal for Class I Areas pursuant to under ' 169A(a)(1) of the Act and 40 CFR 51.309; and 10. Assessment of duration and intensity of smoke emissions to minimize cumulative impacts; 10.11. Minimization of smoke impacts in Class I Areas, roads or highways, airports, areas that are non-attainment for particulate matter, carbon monoxide non-attainment areas, or other smoke-sensitive areas.; and 12. R18-2-1507. A. Protection of the National Ambient Air Quality Standards. Prescribed Burn Accomplishment; ADEQ Recordkeeping; Wildfire Reporting Each F/SLM conducting a prescribed burn shall complete and submit to ADEQ the "Burn Accomplishment" form supplied by ADEQ. For each burn approval, the F/SLM shall submit a Burn 602ART15NFRMGRRC120903.DOC 12/9/03 57 Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burn. The F/SLM shall include the following information on the Burn Accomplishment form: 1. Any known conditions or circumstances that could impact the Daily Burn decision process; 2. The subsequent date, location, fuel type, fuel loading, and acreage accomplishments; 3. The BMP ERTs and SMTs for emission reduction described in R18-2-1509 and R18-2-1510, respectively, and may include any further ERTs and SMTs that become available, that the F/SLM used to reduce emissions or manage the smoke from the burn. B. For each burn approval, the F/SLM shall submit a Burn Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burning. C.B. The F/SLM shall submit the Burn Accomplishment form as an original form, a facsimile, or an electronic information transfer. D.C. ADEQ shall maintain a record of Burn Requests, Burn Approvals/Conditional Approvals/Denials and Burn Accomplishments for 5 five years. D. The F/SLM in whose jurisdiction a wildfire occurs shall make available to ADEQ no later than the day after the activity all required information for wildfire incidents that burned more than 100 acres per day in timber or slash fuels or 300 acres per day in brush or grass fuels. For each day of a wildfire incident that exceeds the daily activity threshold, the F/SLM shall provide the location, an estimate of predominant fuel type and quantity consumed, and an estimate of the area blackened that day. R18-2-1508. Prescribed Natural Fires; Wildland Fire Use: Plan;, Authorization;, Monitoring; Inter- agency Consultation; Status Reporting A. In order for ADEQ to participate in the wildland fire use decision-making process, the A F/SLM shall notify ADEQ as soon as practicable of any potential wildland fire use incident prescribed natural fire when it is projected to attain or attaining a size of 50 acres of timber fuel or 250 acres of brush or grass fuel. B. For each wildland fire use incident prescribed natural fire that has been declared as such by the F/SLM, the F/SLM shall complete and submit to ADEQ a Wildland Fire Use Burn prescribed natural fire Plan in a format approved by ADEQ in cooperation with the F/SLM. The F/SLM shall submit the Wildland Fire Use Burn prescribed natural fire Plan to ADEQ as soon as practicable but no later than 72 hours after the wildland fire use incident prescribed natural fire is declared or under consideration for such designation 1st observed. The F/SLM shall include the following information in the 602ART15NFRMGRRC120903.DOC 12/9/03 58 Wildland Fire Use Burn prescribed natural fire Plan: 1. An emergency telephone number that is answered 24 hours a day, seven days a week; 2. Anticipated burn prescription and anticipated emissions; 3. Anticipated smoke management prescription; 3.4. The estimated daily anticipated growth in the number of acres, quantity, and type of fuel to be potentially burned; 4.5. The anticipated maximum allowable perimeter or size with map; 5.6. The type or types of fuel involved; Information on the condition of the area to be burned, such as whether it is in maintenance or restoration, its ecological function, and other indicators of fire resiliency; 6.7. The anticipated duration of the wildland fire use incident prescribed natural fire; 7.8. The anticipated long-range weather trends for the site onsite; 8.9. A map depicting the potential impact of the smoke. The potential impact shall be determined by mapping both the daytime and nighttime smoke path and down-drainage flow for 15 miles from the wildland fire use incident burn site, with smoke-sensitive areas delineated. Mapping is mandatory unless waived either orally or in writing by ADEQ. The map shall use the appropriate scale to show the impacts of the smoke adequately; The map shall use the standard agency scale for that F/SLM; and 9.10. Modeling or monitoring of smoke impacts, if requested by ADEQ after consultation with the F/SLM. C. ADEQ shall approve or disapprove a Wildland Fire Use Burn prescribed natural fire Plan within 3 three hours of receipt. ADEQ shall consult directly with the requesting F/SLM before disapproving a Wildland Fire Use Burn prescribed natural fire Plan. If ADEQ fails to address the Wildland Fire Use Burn Plan within the time allotted, the Plan is approved by default under the condition that the F/SLM makes a good faith effort to contact ADEQ to confirm that the Plan was received. If ADEQ fails to respond to the submittal of the prescribed natural fire Plan, approval of the prescribed natural fire may be assumed by the F/SLM. Approval by ADEQ of a Wildland Fire Use Burn prescribed natural fire Plan shall be is binding upon ADEQ for the duration of the wildland fire use incident prescribed natural fire project, unless smoke from the incident prescribed natural fire creates a threat to public health or welfare. If a threat to public health or welfare is created, ADEQ shall consult with the F/SLM regarding the situation and the development of develop a joint action plan for reducing further smoke impacts. D. The F/SLM shall submit a Daily Status Report for each wildland fire use incident prescribed natural 602ART15NFRMGRRC120903.DOC 12/9/03 59 fire to ADEQ for each day of the burn that the fire burns more than 100 acres in timber or slash fuels or 300 acres in brush or grass fuels perimeter increases. The F/SLM shall include a synopsis of smoke behavior, future daily anticipated growth, and location of the activity of the wildland fire use incident prescribed natural fire in the Daily Status Report. E. The F/SLM shall consult with ADEQ prior to initiating human-made ignition on the wildland fire use incident when greater than 250 acres is anticipated to be burned by the ignition. Emergency humanmade ignition on the incident for protection of public or fire-fighter safety does not require consultation with ADEQ regardless of the size of the area to be burned. F. The F/SLM shall ensure that there is appropriate signage and notification to protect public safety on transportation corridors including roadways and airports during a wildland fire use incident. R18-2-1509. A. Emission Reduction Techniques; BMP Each F/SLM conducting a prescribed burn shall implement as many Emission Reduction Techniques BMP for emission reduction as are feasible subject to economic, technical, and safety feasibility criteria, and land management objectives. for the specific burn and shall include the BMP in the Burn Accomplishment submitted pursuant to R18-2-1507. B. The following measures are considered Emission Reduction Techniques include BMP: 1. Reducing biomass to be burned by use of techniques such as yarding or consolidation of unmerchandisable material, multi-product timber sales, or public firewood access, when economically feasible. When allowing public firewood access, provide information on the adverse impacts of using green or wet wood as fuel; 2. Burning in seasons characterized by meteorological conditions that allow for good smoke dispersion, especially March 15 through September 15; 2. Reducing biomass to be burned by fuel exclusion practices such as preventing the fire from consuming dead snags or dead and downed woody material through lining, application of fire-retardant foam, or water; 3. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires of high fuel density areas such as logging slash decks with short duration impacts; 4. Igniting burns under good-to-excellent ventilation conditions and suspending operations under poor smoke dispersion conditions; 5. Considering smoke impacts on local community activities and land users; 6.4. Burning only fuels essential fuels to meet resource management objectives; 7.5. Minimizing duff consumption and smoldering by burning under conditions of high through 602ART15NFRMGRRC120903.DOC 12/9/03 60 fuel moisture of duff and litter considerations; 6. Minimizing fuel consumption and smoldering by burning under conditions of high fuel moisture of large woody fuels; 8.7. Minimizing dirt soil content when slash piles are constructed by using brush blades on material-moving equipment and by constructing piles under dry soil conditions or by using hand piling methods; 8. Burning fuels in piles; 9. Burning piles when other burns are not feasible, such as when snow or rain is present; 9. Using a backing fire in grass fuels; 10. Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; 10. Burning fuels with an air curtain destructor, as defined in R18-2-101, operated according to manufacturer specifications and meeting applicable state or local opacity requirements; 11. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; 11. Extinguishing or mopping-up of smoldering fuels; 12. Using chunking Chunking of piles and other consolidations of burning material to enhance flaming and fuel consumption, and to minimize smoke production; 13. Implementing maintenance burning in a periodic rotation mimicking natural fire cycles to reduce excessive fuel accumulations and subsequent excessive smoke production through smoldering or wildfire; 13. Burning before litter fall; 14. Using prescribed natural fires and unplanned ignitions; and 14. Burning before green-up of fuels; 15. Managing smoke impacts as follows: a. Limiting smoke impacts to roads, highways, and airports to the amounts, frequencies, and durations consistent with any guidance provided by highway and airport personnel; 15. b. Using appropriate signing if smoke will impact any roadways; c. Notifying control towers if smoke will intrude in any air traffic control zone; d. Determining nighttime impacts and taking appropriate precautions; and e. Contacting appropriate authorities as needed regarding smoke or visibility impacts. Burning before recently cut large fuels cure in areas with activity; and 602ART15NFRMGRRC120903.DOC 12/9/03 61 16. R18-2-1510. A. Burning just before precipitation to reduce fuel smoldering and consumption. Smoke Management Techniques Each F/SLM conducting a prescribed burn shall implement as many Smoke Management Techniques as are feasible subject to economic, technical, and safety feasibility criteria, and land management objectives. B. Smoke management techniques include: 1. Burning from March 15 through September 15, when meteorological conditions allow for good smoke dispersion; 2. Igniting burns under good-to-excellent ventilation conditions; 3. Suspending operations under poor smoke dispersion conditions; 4. Considering smoke impacts on local community activities and land users; 5. Burning piles when other burns are not feasible, such as when snow or rain is present; 6. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires with short duration impacts; 7. Using all opportunities that meet the burn prescription and all burn locations to spread smoke impacts over a broader time period and geographic area; 8. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit completed by 3 p.m. to prevent trapping smoke in inversions or diurnal windflow patterns; 9. Providing information on the adverse impacts of using green or wet wood as fuel when public firewood access is allowed; 10. Implementing maintenance burning in a periodic rotation to shorten prescribed fire duration and to reduce excessive fuel accumulations that could result in excessive smoke production in a wildfire; and 11. Using wildland fire-use strategies to shift smoke into more favorable smoke dispersion seasons. R18-2-1510. R18-2-1511. A. Monitoring ADEQ may require a F/SLM to monitor weather and air quality before or during a prescribed burn or a excluding wildland fire use incident prescribed natural fires, which are governed by R18-2-1508, if necessary to accurately predict assess smoke impacts. Air quality monitoring may be conducted using both federal and non-federal reference method as well as other techniques. B. ADEQ may require a F/SLM to monitor weather before or during a prescribed burn or a wildland fire 602ART15NFRMGRRC120903.DOC 12/9/03 62 use incident, if necessary to predict or assess smoke impacts. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or area-representative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ. An F/SLM shall give ADEQ notice and an opportunity to comment before making any change to a long-term established remote automated weather station. B.C. A F/SLM shall employ the following types of monitoring, unless waived by ADEQ, for burns greater than 250 acres per day, or greater than 50 acres per day if the burn is within 15 miles of a Class I Area, an area that is non-attainment for particulate matter, a carbon monoxide, or ozone nonattainment area, or other smoke-sensitive area: 1. Smoke plume measurements, using a format supplied by ADEQ; and 1.2. The release of pilot balloons (PIBALs) at the burn site to verify needed wind speed, direction, or and stability.; and 2. Smoke plume measurements, using a format supplied by ADEQ. Instead of pilot balloons, a test burn at the burn site may be used for specific prescribed burns on a case-by-case basis as approved by ADEQ, to verify needed wind speed, direction, and stability. C.D. A An F/SLM shall make monitoring information required pursuant to under subsection (B)(C) available to ADEQ on the business day following the burn ignition. D. After consultation with the F/SLM, ADEQ may also require the F/SLM to establish burn site or arearepresentative remote automated weather stations or their equivalent, having telemetry that allows retrieval on a real-time basis by ADEQ, if necessary to accurately predict smoke impacts. E. The F/SLM shall keep on file for 1 one year following the burn date any monitoring information required pursuant to under this Section. R18-2-1511. R18-2-1512. A. Burner Qualifications All burns burn projects shall be conducted by personnel trained in prescribed fire and smoke management techniques to the minimum level as required by the F/SLM in charge of the burn and established by National Wildfire Coordinating Group training qualifications. B. A Prescribed Fire Manager Boss or other local Fire Management Officer of the F/SLM having jurisdiction over prescribed burns shall have smoke management training obtained through one of the following: 1. Successful completion of a National Wildfire Coordinating Group or F/SLM-equivalent course dedicated to addressing smoke management; or 602ART15NFRMGRRC120903.DOC 12/9/03 63 2. Attendance at an ADEQ-approved smoke management workshop. R18-2-1512. R18-2-1513. A. Public Notification and Awareness Program; Regional Coordination At the Director's discretion, The Director shall conduct a public education and awareness program may be conducted by ADEQ in cooperation with F/SLMs and other interested parties to inform the general public of the smoke management program described by this Article. If conducted, the The program shall include smoke impacts from prescribed fires and the role of prescribed fire in natural ecosystems. B. ADEQ shall make annual registration, prescribed burn approval, and wildfire and wildland fire use activity information readily available to the public and to facilitate regional coordination efforts and public notification. R18-2-1514. A. Oversight An F/SLM planning to make a change to any long-term established remote automated weather station shall give ADEQ notice and an opportunity to comment before making the change. B. On or before August 15 of each year, each F/SLM shall submit to ADEQ a report generally describing each of the following: 1. The emissions reductions for each project from the previous year as a result of using BMP. Emissions reductions may be estimated using methods and emission factors developed jointly by ADEQ and F/SLMs; 2. The smoke management cost estimates for each active project from the previous year including estimates for monitoring, training, applying emission reduction techniques, research, and compliance with the requirements of this Article; and 3. Any research on or development of innovative techniques for emission reductions. R18-2-1513. R18-2-1514. A. Surveillance and Enforcement An F/SLM conducting a prescribed burn shall permit ADEQ to enter and inspect burn sites unannounced to verify the accuracy of the Daily Burn Request, Burn Plan, or Accomplishment data described pursuant to R18-2-1505 as well as matching burn approval with actual conditions, and smoke dispersion, and air quality impacts. On-ground site inspection procedures and aerial surveillance shall be coordinated by ADEQ and the F/SLM for safety purposes. B. ADEQ may use remote automated weather station data if necessary to verify current and previous 602ART15NFRMGRRC120903.DOC 12/9/03 64 meteorological conditions at or near the burn site. C. ADEQ may audit burn accomplishment data, smoke dispersion measurements, or weather measurements from previously conducted burns, if necessary to verify conformity with, or deviation from, procedures and authorizations approved by ADEQ. D. Deviation from procedures and authorizations approved by ADEQ constitute a violation of this Article. Violations may require containment or mop-up of any active burns and may also require, in the Director's discretion, a 5 five-day moratorium on ignitions by the responsible F/SLM. Violations of this Article are also subject to a civil penalty of not more than $10,000 per day per violation pursuant to under A.R.S. ' 49-463. R18-2-1515. A. Forms; Electronic Copies; Information Transfers ADEQ shall make available on paper and in electronically-readable format any form required to be developed by ADEQ and completed by a F/SLM. B. After consultation with the an F/SLM, ADEQ may require each the F/SLM to provide data in a manner that allows for and facilitates electronic transfers of information. 602ART15NFRMGRRC120903.DOC 12/9/03 65 Appendix A-10e. WRAP “Policy on Fire Tracking Systems” Appendix A-10 –Fire Programs Arizona Regional Haze SIP WRAP POLICY FIRE TRACKING SYSTEMS APPROVED BY CONSENSUS: WESTERN REGIONAL AIR PARTNERSHIP – APRIL 2, 2003 APPROVED BY CONSENSUS: FIRE EMISSIONS JOINT FORUM – DECEMBER 19, 2002 PREPARED BY: FIRE TRACKING SYSTEMS TASK TEAM OF THE FIRE EMISSIONS JOINT FORUM APRIL 2, 2003 Executive Summary The Western Regional Air Partnership (WRAP) is charged with developing technical and policy tools to assist states (or the delegated regulatory authority) and tribes with implementing the Regional Haze Rule (Rule). The WRAP Policy on Fire Tracking Systems (WRAP FTS Policy) has been developed over a sixmonth period through a stakeholder-based consensus process to assist the WRAP region states and tribes in addressing emissions from fire sources. In this Policy, the WRAP seeks to provide a consistent framework that states and tribes can use to efficiently develop their individual implementation plans, long-term strategies, and periodic progress reports. The WRAP recognizes states’ and tribes’ authority and responsibility to develop, adopt and implement their regional haze implementation plans, and recognizes the Rule as the principal document on which states and tribes should rely. The Rule requires states to develop implementation plans (SIPs) for addressing regional haze in the Nation’s 156 mandatory Class I areas. Additionally, the Rule requires effective management of fire sources. The Rule provides two pathways for western states to follow as they implement the requirements of the Rule: 1) develop their regional haze implementation plans per the nationally applicable provisions of Section 308, or 2) Transport Region States may choose to incorporate the Grand Canyon Visibility Transport Commission (GCVTC) Recommendations into their regional haze implementation plans under Section 309 of the Rule. It is the position of the WRAP FTS Policy that it is necessary to track fire activity information in the WRAP region using a fire tracking system, which will also provide the information essential to create a fire emissions inventory. The WRAP FTS Policy identifies seven essential components of a fire tracking system that represent the minimum spatial and temporal fire activity information necessary to consistently calculate emissions and to meet the requirements of the Rule. The resulting emissions will be used in modeling exercises to assess fire impacts to regional haze. An emissions inventory and tracking system for fire are specific requirements under Section 309 and a broader requisite under Section 308 of the Rule. The fire tracking system and WRAP emissions inventory system are regional approaches to the data gathering and tracking initiatives, which are specifically encouraged in the Rule. Therefore, the WRAP is advancing the WRAP FTS Policy for states and tribes under both Sections 308 and 309 to meet the requirements of the Rule. Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to assume the regional haze requirements outlined in the Rule may, according to the Tribal Authority Rule (TAR), seek approval under 40 CFR 49 to be “treated in the same manner as States.” The intent of this Policy is to assist both states and tribes with the development of their regional haze implementation plans (SIPs/TIPs), and therefore, tribes are included in all references to states, except where specific requirements and/or deadlines of the Rule are cited. i Most fire emissions inventory and tracking efforts established to date in the WRAP region have been developed in conjunction with smoke management programs to address public health and nuisance concerns. Fortunately, fire emissions inventory and tracking efforts regardless of the purpose, have some common elements. It is anticipated that the fire tracking system and WRAP emissions inventory system outlined herein will integrate well with current and future fire emissions inventory and tracking efforts. The WRAP FTS Policy document is comprised of four major sections. Section 1 is the five WRAP FTS Policy Statements. Section 2 provides overall background for the WRAP FTS Policy, including a discussion of the regulatory environment and details of the Rule that are germane to the WRAP FTS Policy. Section 3 is an annotation of each of the five policy statements, further explaining and defining them, and a description of the seven essential fire tracking system components. Finally, Section 4 Appendices include: A) a glossary of terms, B) a website references listing, and C) supporting information on fire tracking systems. ii TABLE OF CONTENTS Page EXECUTIVE SUMMARY i 1. POLICY STATEMENTS 1 2. BACKGROUND 2.1. Clean Air Act and Grand Canyon Visibility Transport Commission 2.2. Western Regional Air Partnership 2.3. Regional Haze Rule 2.3.1. Section 309 2.3.2. Section 308 1 1 2 2 3 4 3. ANNOTATED POLICY 3.1. Introduction 3.2. Fire Activity Information 3.2.1. Fire Tracking System 3.2.2. Emissions Inventory 3.2.3. Applicability 3.3. Essential Components of a Fire Tracking System 3.3.1. Essential Component 1. Date of Burn 3.3.2. Essential Component 2. Burn Location 3.3.3. Essential Component 3. Area of Burn 3.3.4. Essential Component 4. Fuel Type 3.3.5. Essential Component 5. Pre-Burn Fuel Loading 3.3.6. Essential Component 6. Type of Burn 3.3.7. Essential Component 7. “Anthropogenic” or “Natural” Classification 3.4. Annual Emission Goals 3.5. Fire Emissions Projection 3.6. Collaborative Development 4 4 5 5 6 7 8 9 9 9 10 10 10 10 4. APPENDICES Appendix A. Glossary Appendix B. Website References Appendix C. Supporting Information 13 13 18 20 iii 10 11 12 1. Policy Statements A. Fire activity information for all fire types is needed in the WRAP region. A fire tracking system that captures this information will form the basis of a fire emissions inventory compiled annually, which is needed to support Regional Haze Rule requirements. B. A fire tracking system includes the following seven essential components that are necessary in order to consistently calculate emissions and to uniformly assess impacts to regional haze: 1. Date of Burn 2. Burn Location 3. Area of Burn 4. Fuel Type 5. Pre-Burn Fuel Loading 6. Type of Burn 7. “Anthropogenic” or “Natural” Classification C. A fire tracking system should include additional components as needed to support the development and implementation of annual emission goals and other control measures. D. A fire tracking system should include a component that addresses the projection of fire emissions, which is necessary to meet the requirements of the Regional Haze Rule. E. The development of fire tracking systems by states and tribes will be done collaboratively with state, tribal, local and federal land management agencies, and private parties. 2. Background 2.1. Clean Air Act and Grand Canyon Visibility Transport Commission In 1990, Congress amended the Clean Air Act (CAA), and as part of these amendments created the Grand Canyon Visibility Transport Commission (GCVTC).1 The GCVTC was charged with assessing the current scientific information on visibility impacts and making recommendations for addressing regional haze in the western United States. The GCVTC signed and submitted more than 70 recommendations to the Environmental Protection Agency in a report dated June 1996 that indicated that visibility impairment was caused by a wide variety of sources and pollutants, including fire on a episodic basis, and that a comprehensive strategy was needed to remedy regional haze. The second of the GCVTC Recommendations Regarding Fire describes the need for a consistent region-wide emissions tracking system for prescribed fire, wildfire, and agricultural burning.2 1 The Grand Canyon Visibility Transport Commission (GCVTC) was composed of the governors of eight western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and Navajo), four Federal land management agencies (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. 2 Grand Canyon Visibility Transport Commission, Recommendations for Improving Western Vistas, Report to the 1 2.2. Western Regional Air Partnership The Western Regional Air Partnership (WRAP) was established in 1997 as the successor organization to the GCVTC. The WRAP is a voluntary organization comprised of western governors, tribal leaders and federal agencies,3 and is charged “to identify regional or common air management issues, develop and implement strategies to address these issues, and formulate and advance western regional policy positions on air quality.”4 These policies and technical tools are developed through inclusive, stakeholder-based processes and approved by consensus of the WRAP. WRAP participants include state air quality agencies, tribes, federal/state/private land managers, the EPA, environmental groups, industry, academia and other interested parties. There are over 400 tribes within the WRAP region. The large number of tribes limits the participation of all of them in WRAP activities, and accordingly, in the development of this Policy. Therefore, the tribal representatives involved in the development of this Policy may not represent all tribal concerns. 2.3. Regional Haze Rule Following the issuance of the GCVTC Report, the EPA issued the Regional Haze Rule5 (Rule) in July 1999 to improve visibility in 156 national parks and wilderness areas across the country. The Rule outlines the requirements for states and tribes to address regional haze in these mandatory Class I areas. EPA incorporated all of the GCVTC Recommendations into Section 309 of the Rule, which may be used by some of the WRAP states/tribes. The remaining WRAP states must, and tribes may, utilize the nationally applicable Section 308 provisions of the Rule. Under Sections 308 and 309 of the Rule, states must, while tribes may, address visibility impairment in mandatory Class I areas due to emissions from all sources, including fire activities, which is made possible by an inventory of emissions of pollutants that contribute to visibility impairment. Further, the Preamble to the Rule calls for the tracking of pollutant emissions to supplement the tracking of monitored visibility changes for use in periodically reviewing the progress toward the natural visibility goal.6 In regard to the requirements for periodic progress reports, both Sections 308 and 309 of the Rule call for: U.S. EPA, June 10, 1996 (hereafter referred to as “GCVTC Report”), p. 48. 3 The WRAP membership is comprised of the governors of thirteen western states and thirteen western tribes. The current WRAP members include the States of AK, AZ, CA, CO, ID, MT, ND, NM, OR, SD, UT, WA, and WY and the Tribal Nations of Pueblo of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the Department of the Interior, the Department of Agriculture, and the Environmental Protection Agency. 4 WRAP Charter, Purpose, p. 1. 5 Published in the Federal Register on July 1, 1999, 64 FR 35714. 6 64 FR 35725-35726. 2 An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and activities within the State. Emissions changes should be identified by type of source or activity. The analysis must be based on the most recent updated emissions inventory, with estimates projected forward as necessary and appropriate, to account for emissions changes during the applicable 5-year period.7 Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to assume the regional haze requirements outlined in the Rule may, according to the CAA, seek approval to be treated in the same manner as states, under the Tribal Authority Rule (TAR), 40 CFR 49.8 In these cases, EPA still recognizes that “unlike States, tribes are not required by the TAR to adopt and implement CAA plans or programs, thus tribes are not subject to mandatory deadlines for submittal of implementation plans.”9 Although provision for flexibility in the submission of programs and implementation plans for tribes is made under TAR, EPA does “encourage tribes choosing to develop implementation plans to make every effort to submit by the deadlines to ensure that the plans [TIPs] are integrated with and coordinated with regional planning efforts.”10 EPA recognizes the WRAP as the Regional Planning Organization that is developing the necessary policy and technical tools to implement the Rule in the WRAP region. A WRAP policy, once approved, represents the WRAP's consensus position on the best means for states and tribes to implement the portion of the Rule at issue. The WRAP recognizes states’ and tribes’ authority and responsibility to develop, adopt and implement their regional haze state and tribal implementation plans, and the seminal guidance to do this is the Rule.11 2.3.1. Section 309 Section 309 of the Rule specifically calls for: [a] statewide inventory and emissions tracking system (spatial and temporal) of VOC, NOX, elemental and organic carbon, and fine particle emissions from fire. 12 Under Section 309, states must, while tribes may, incorporate a fire tracking system and a mechanism to generate the required emissions inventory, based on fire activity information, into their SIPs/TIPs. Further, this is one step of several that will afford states/tribes the demonstration of reasonable further progress through 2018,13 as required by the Rule. The fire tracking system will provide information critical to the implementation of other requirements under Section 30914, including the development of an enhanced smoke management program, the establishment of annual emission goals, and the projection of fire emissions. 7 64 FR 35769, §51.308 (g) (4) and 64 FR 35772, §51.309 (d) (10) (i) (D). 64 FR 35759. 9 64 FR 35758. 10 64 FR 35759. 11 WRAP Charter, p.1. 12 64 FR 35771, §51.309 (d) (6) (ii). 13 64 FR 35769, §51.309 (a). 14 64 FR 35771, §51.309 (d) (6). 8 3 2.3.2. Section 308 Although Section 308 of the Rule does not explicitly address the emissions inventory and tracking necessary for programs related to fire, Section 308 of the Rule does assert that the SIP/TIP must provide for: A statewide inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I area. The inventory must include emissions for a baseline year, emissions for the most recent year for which data are available, and estimates of future projected emissions. The State must also include a commitment to update the inventory periodically.15 In addition, Section 308 of the Rule states that in establishing its long-term strategy for regional haze, The State must document the technical basis, including modeling, monitoring and emissions information, on which the State is relying to determine its apportionment of emission reduction obligations necessary for achieving reasonable progress in each mandatory Class I Federal area it affects.16 And: The State must identify all anthropogenic sources of visibility impairment considered by the State in developing its long-term strategy [for regional haze]. The State should consider major and minor stationary sources, mobile sources, and area sources.17 These Rule citations support the need for a fire tracking system that will facilitate the development of a fire emissions inventory and the establishment of long-term strategies for states under Section 308. 3. Annotated Policy 3.1. Introduction The WRAP FTS Policy is the result of the WRAP region-wide multi-state/multi-tribe planning and coordination effort. This effort is consistent with the direction provided by EPA in the Preamble to the Rule that encourages states to work together to establish common approaches for emissions inventory development and tracking.18 15 64 FR 35767, §51.308 (d) (4) (v). 64 FR 35767, §51.308 (d) (3) (iii), emphasis added. 17 64 FR 35767, §51.308 (d) (3) (iv). Fire is considered an area source. 18 64 FR 35720. 16 4 The intent of the WRAP FTS Policy is to assist states (or the delegated authority) and tribes to address emissions inventory and tracking associated with fire in a way that is adequate for implementation plan development, long-term strategies, and periodic progress reports. The WRAP FTS Policy identifies for states and tribes in the WRAP region the essential fire activity information necessary to consistently calculate emissions and to meet the requirements of the Rule. The resulting emissions will be used in modeling exercises to assess fire impacts to regional haze. Most states/tribes in the WRAP region track fire and its subsequent emissions differently and few, if any, states/tribes address all fire sources. Consequently, fire sources in the WRAP region are tracked and inventoried at various and inconsistent levels, from daily burn activity and emissions information to annual emissions summaries, to no tracking. This variability is a proven obstacle to inter-jurisdictional analysis of fire impacts on visibility within the WRAP region.19 In addition, transport of fire emissions beyond the WRAP region emphasizes the need for the development and consistent application of a fire tracking system and subsequent emissions inventory mechanism that is predictable and flexible while meeting the requirements of the Rule. The WRAP FTS Policy has been developed to embody appropriate regulatory and policy requirements and to provide a predictable framework for fire tracking systems that can be reasonably implemented by states and tribes. The WRAP believes that states maintain the ultimate responsibility for the implementation of the fire tracking system. Tribes, or EPA on their behalf, may choose to utilize fire tracking systems as a reasonably severable element in their implementation plans. The WRAP recognizes states/tribes authority and responsibility to develop, adopt and implement their regional haze state and tribal implementation plans. The WRAP further recognizes that the implementation plans will be revisited and revised, per the schedule specified in the Rule, giving opportunities to refine individual fire tracking systems and subsequent emission inventories to reflect technical advances and policy updates. 3.2. Fire Activity Information Policy Statement A: Fire activity information for all fire types is needed in the WRAP region. A fire tracking system that captures this information will form the basis of a fire emissions inventory compiled annually, which is needed to support Regional Haze Rule requirements. 3.2.1. Fire Tracking System A tracking system for fire is a specific requirement under Section 309 and will be needed to support general requirements under Section 308 of the Rule. A consistent fire tracking system based on fire activity information is essential in order to consistently calculate emissions. The resulting emissions will be used in subsequent regional modeling and visibility monitoring data 19 This is the result of the findings of the WRAP’s 1996 fire emission inventory development and modeling efforts, which were challenged by the dramatic variability in fire activity information found across the WRAP region, and consequently was one of the sources of uncertainty in the resulting emission inventory. 5 analyses. Therefore, the WRAP FTS Policy is for states and tribes in the WRAP region to track fire activity information in their respective jurisdiction using a fire tracking system, which will also provide the information essential to create a fire emissions inventory. The ability of a state or tribe to implement a fire tracking system with known fire activity information for all fire sources may require legislative or governmental changes to existing rules, or removal of exemptions from regulation and/or tracking of specific fire sources. Therefore, the WRAP FTS Policy allows for the consideration of direct data collection as well as indirect estimation techniques, where they satisfy the minimum spatial and temporal information necessary to support emissions inventories and modeling for the WRAP region. In addition, the WRAP recognizes that progressive implementation may be necessary to attain a level of data collection that will ensure comparability between the tracking of fire activity information and monitored visibility changes. See Appendix C for general guidance on data collection, and the Fire Emissions Joint Forum (FEJF) of the WRAP will be exploring viable data collection methods at a later date. 3.2.2. Emissions Inventory Information from the fire tracking system will provide the basis for an emissions inventory, which is a requirement of the Rule under Section 309 and will be necessary under Section 308. In reporting and tracking emissions from fire within the State, States may use information from regional data gathering and tracking initiatives.20 In keeping with the Rule’s Preamble discussion of regional planning organizations and the role of regional planning in such matters as emission tracking and inventory development, the WRAP is developing a regional emissions inventory system.21 States/tribes may utilize the WRAP emissions inventory system as their emissions inventory mechanism. Fire emissions will be calculated using the WRAP regional emissions inventory system based on fire activity data supplied by the respective jurisdiction. States/tribes may choose to calculate fire emissions internally within their jurisdiction. Both the fire tracking system and the WRAP emissions inventory system are regional approaches that are specifically encouraged in the Rule. Further, these systems will support the fire emissions inventory and modeling needs for regional haze and ambient air quality standards such as those for ozone and particulate matter. The WRAP’s regional emissions tracking and forecasting system for point, area, biogenic, mobile, and fire sources will result in a complete inventory of all emissions of visibility impairing pollutants (i.e., PM10, PM2.5, SOx, NOx, VOC, ROC, elemental carbon, ammonia) for all sources within the WRAP region. The emission inventories will be both temporally and spatially resolved and will include emissions from both man-made and natural sources. This effort will facilitate the technical and planning efforts of the WRAP states and tribes by compiling the emission inventories necessary for regional modeling efforts to analyze visibility impacts and meet Rule requirements. 20 21 64 FR 35771, §51.309 (d) (6) (ii). 64 FR 35720. 6 Stationary Source Milestones and Clean Air Corridors as cited in the Rule will require emissions to be compiled annually by the WRAP. As fire activity and subsequent emissions are highly variable in terms of strength, impact, location and timing, the WRAP FTS Policy specifies that states will and tribes may provide fire activity information to the WRAP on an annual basis. 3.2.3. Applicability In keeping with the GCVTC Recommendations, the Rule, the WRAP Policy for Categorizing Fire Emissions, and recommendations in the Interim Air Quality Policy on Wildland and Prescribed Fires (EPA Interim Policy)22, the WRAP FTS Policy applies equitably across all land types and fire sources. The WRAP FTS Policy calls for the tracking of fire sources on both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of the fire. All fire sources are included in the WRAP FTS Policy because it is recognized that all fires (prescribed fire, wildfire, and agricultural burning) have an effect on air quality and contribute to regional haze.23 Fire sources were among those specifically acknowledged in the GCVTC Report as contributors to visibility impairment on an episodic basis: All types of fire (prescribed fire and agricultural burning) must be addressed equitably as part of a visibility protection strategy.24 The use of fire by agriculture is well documented and the Agricultural Air Quality Task Force (AAQTF) has recognized that agricultural burning has the potential to impact visibility in mandatory Class I Federal areas.25 However, the extent of fire use is not well known in some areas, and is the cause of uncertainty as to the contribution of agricultural burning sources on regional haze. Accordingly, the AAQTF’s Air Quality Policy on Agricultural Burning, Recommendation to the U.S. Department of Agriculture states that “…the contribution from agriculture, specifically the impact of burning practices on regional air quality, must be accurately assessed in relative proportion to the region’s total emissions.”26 Section 118(a) of the Clean Air Act requires that all entities, federal and non-federal, be subject to the same requirements, authorities and processes, and the Rule is clear that all sources, facilities, and property are to be treated equitably.27 Additionally, stakeholder input garnered in the development process of the WRAP Policy for Categorizing Fire Emissions supported consistent consideration of fire between Sections 308 and 309 of the Rule. The WRAP FTS Policy, therefore, will be applicable and useful to all states and tribes in the WRAP region. 22 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998 (hereafter referred to as “EPA Interim Policy”). 23 GCVTC Report, p. 47. 24 Ibid. 25 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the U.S. Department of Agriculture, November 10, 1999 (hereafter referred to as “AAQTF’s Air Quality Policy Recommendation”), Section IV, E. 26 AAQTF’s Air Quality Policy Recommendation, Section VII. 27 64 FR 35748. 7 The WRAP FTS Policy does not apply to Native American cultural non-vegetative burning for traditional, religious, or ceremonial purposes (e.g., cremation, and sweat lodge fires).28 In addition, the WRAP FTS Policy does not apply to open burning activities on residential, commercial, or industrial property (e.g., backyard burning, garbage incineration, residential wood combustion, and construction debris). However, the WRAP recognizes that the unique air quality circumstances of a state or tribe may require emissions tracking information for these fire source sectors. In addition, these sources may be quantified as area sources within populated areas in other emissions inventory efforts by states, tribes or the WRAP. 3.3. Essential Components of a Fire Tracking System Policy Statement B: A fire tracking system includes the following seven essential components that are necessary in order to consistently calculate emissions and to uniformly assess impacts to regional haze: 1. Date of Burn 2. Burn Location 3. Area of Burn 4. Fuel Type 5. Pre-Burn Fuel Loading 6. Type of Burn 7. “Anthropogenic” or “Natural” Classification The seven essential components of a fire tracking system identified in this Policy have been selected as the minimum spatial and temporal information to be collected consistently and universally across the WRAP region to ensure comparability between and within states and tribes, and across the WRAP region. The seven essential components are based, in part, upon careful review and consideration of the EPA’s Prescribed Burning Background Document and Technical Information Document for Prescribed Burning Best Available Control Measures29 and the National Wildfire Coordination Group’s Smoke Management Guide for Prescribed and Wildland Fire 2001 Edition.30 The seven essential components have also been developed based on the experience gained through the FEJF’s 1996 and 2018 fire emissions inventory preparation efforts.31 32 The fire tracking system’s essential component data will provide the basis for calculating the emissions for fire through the use of an emissions calculation mechanism, such as the WRAP emissions inventory system described above, to integrate the appropriate emissions factors and emission calculation techniques. In order to consistently calculate emissions and ensure the 28 WRAP Policy for Categorizing Fire Emissions, November 15, 2001 (hereafter referred to as “WRAP Fire Categorization Policy”), p. 24. 29 U.S. EPA, Office of Air Quality Planning and Standards, Prescribed Burning Background Document and Technical Information Document for Prescribed Burning Best Available Control Measures, EPA-450/2-92-003, September 1992. 30 National Wildfire Coordination Group, Smoke Management Guide for Prescribed and Wildland Fire, PMS 420-2, NFES 1279, December 2001 (hereafter referred to as “NWCG Smoke Management Guide”). 31 WRAP Report: 1996 Fire Emissions Inventory (DRAFT). 32 WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and Agricultural Burning (DRAFT). 8 comparability of the subsequent regional modeling analysis and analysis of visibility monitoring data, states/tribes should utilize identical emission factors and calculation techniques in concert with the essential fire activity information as described in this Policy.33 The FEJF will develop further guidance, beyond that contained in the FTS Policy, for states/tribes to establish quality assurance methods, and the procedure and format for the submittal of fire tracking system information. There are differences among states and tribes with regard to air quality issues, non-attainment areas, emissions information, fire source sectors, and state legislative or tribal governmental requirements. As a result, a state or tribe may choose to augment the seven essential components with additional information. Appendix C elaborates on additional fire activity and tracking information that a state or tribe may consider useful when developing its fire tracking system. The essential component information described in this FTS Policy will be necessary to accomplish the emissions inventory task as cited in the Rule. However, the WRAP recognizes that the unique air quality circumstances of states/tribes may call for excluding some fires from tracking by the establishment of a de minimus level, based on number of acres, tons of fuel, or tons of emissions. The spatial and temporal variability of fire and the significance of visibility impacts is highly dependent upon a number of factors such as size, fuel consumption, meteorology, climate and proximity to a Class I area.34 The WRAP FTS Policy does not prescribe a de minimus level to exclude fires from tracking. States or tribes may wish to establish de minimus levels, which should be defined in the SIP/TIP and be based on a source-impact relationship. The FEJF will be assessing potential de minimus levels based on source/impact relationships to assist states and tribes in this endeavor. 3.3.1. Essential Component 1. Date of Burn It is critical that the temporal resolution of the fire activity information be attributed to a specific day for each specific burn in order to correlate with “best” and “worst” day visibility monitoring data.35 3.3.2. Essential Component 2. Burn Location It is important that the spatial resolution of the fire activity be attributed to a specific location to allow for source/visibility impact relationships to be established. 3.3.3. Essential Component 3. Area of Burn The level of accuracy of the emission inventory will depend, most significantly, on the ability to estimate the area burned (i.e., blackened acres).36 33 See footnote 19. For example, a small agricultural burn (e.g., <2,500 acres at 4 tons/acre consumption or 50 tons PM10) within 50 kilometers upwind of a Class I area could have a greater visibility impact than a large wildland prescribed fire (e.g., >833 acres at 20 tons/acre consumption or 250 tons PM10) within 100 kilometers downwind of a Class I area. 35 64 FR 35734. 36 Peterson, Janice L. 1987. Analysis and reduction of the errors of predicting prescribed burn emissions. Thesis. Seattle: University of Washington. 70p. 34 9 3.3.4. Essential Component 4. Fuel Type Emissions from fire are highly dependent upon the fuel or cover type (e.g., ponderosa pine, juniper, orchard residue, rice straw). It is crucial to provide the predominant fuel or cover type that is burned so that the appropriate emissions factor can be selected to calculate fire emissions. The fuel type will also help refine fuel consumption estimation. 3.3.5. Essential Component 5. Pre-Burn Fuel Loading The pre-burn fuel loading represents the amount of fuel present at the burn location. For the preparation of the fire emissions inventories, the accuracy of the pre-burn fuel-loading component is vital. The more accurate the pre-burn fuel loading and characteristics of the fuel load (e.g., size class information), the more refined the subsequent emissions estimates will be. 3.3.6. Essential Component 6. Type of Burn Type of burn represents the predominant configuration of the fuel burned (e.g., pile, windrow, broadcast, underburn). It is important to provide the type of burn so that the appropriate emissions factor can be selected. Type of burn can also provide information for calculating fuel consumption. 3.3.7. Essential Component 7. “Anthropogenic” or “Natural” Classification The “anthropogenic” or “natural” classification is to be determined per the WRAP Policy for Categorizing Fire Emissions.37 The WRAP will be analyzing daily visibility monitoring data annually for Class I areas and reporting on the causes of haze on an annual basis. This analysis will apportion fire emissions to natural visibility conditions and anthropogenic visibility impairment based on a fire’s “anthropogenic” or “natural” classification. The apportionment will enable states and tribes to address natural reductions of visibility from fire as well as to identify those fire emissions that need to be controlled to achieve reasonable progress. 3.4. Annual Emission Goals Policy Statement C: A fire tracking system should include additional components as needed to support the development and implementation of annual emission goals and other control measures. Section 309 of the Rule calls for states to establish “annual emission goals for fire, excluding wildfire, that will minimize emission increases from fire to the maximum extent feasible.”38 The WRAP Policy on Annual Emission Goals for Fire (WRAP AEG Policy) emphasizes the use of emission reduction techniques (ERTs) as the basis of annual emission goals. States/tribes may need to include additional components in their fire tracking system, beyond the listed essential components, that they deem necessary to support the implementation of annual emission goals 37 38 WRAP Fire Categorization Policy, p. 8. 64 FR 35771, §51.309 (6) (v). 10 and other control measures. The tracking of additional components such as the ERT used, emission reductions achieved or other information (e.g., fuel moisture) should be tracked at the same temporal and spatial resolution of the essential components to allow for regional modeling. The FEJF will develop guidance on additional components to support the implementation of annual emission goals and other control measures per the WRAP AEG Policy. In addition, subsequent guidance to Appendix D of the WRAP AEG Policy will be developed by the FEJF to summarize ERT options for common vegetation and crop types for both prescribed fires on wildland and agricultural burning. 3.5. Fire Emissions Projection Policy Statement D: A fire tracking system should include a component that addresses the projection of fire emissions, which is necessary to meet the requirements of the Regional Haze Rule. When developing long-term strategies that will meet the reasonable progress requirements for both Sections 30839 and 30940, states and tribes must consider the anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions. Fire is an area source. Periodic progress reports are required under both Sections 308 and 309, that specifically cite the need for future projected emissions.41 Fire projections information also supports the Section 309 requirement for fire programs within a state to evaluate the degree of visibility impairment from smoke for both planning and operational purposes.42 Additionally, Section 308 of the Rule asserts that implementation plans must provide for estimates of future projected emissions.43 Therefore, a projected estimate of fire emissions from all fire source sectors will serve as the basis for the projection of visibility conditions due to fire for the most impaired and least impaired days, and will facilitate planning. Since the use of fire for resource management is expected to increase substantially, especially on Federal lands, State/Tribal air quality managers will need information to develop potential annual or seasonal air pollutant emissions estimates for SIP/TIP planning.44 The fire emissions projection component of a fire tracking system may be developed in a variety of ways to address the Rule requirements for future projected emissions from fire. Fire emission projection may be determined by surveys,45 use of growth factors, multipliers or other techniques. 39 64 FR 35767, §51.308 (d) (3) (v) (G). 64 FR 35770, §51.309 (d) (2) and 64 FR 35773, §51.309 (g) (2). 41 64 FR 35769, §51.308 (g) (4) and 64 FR 35772, §51.309 (d) (10) (i) (D). 42 64 FR 35771, §51.309 (d) (6) (i). 43 64 FR 35767, §51.308 (d) (4) (v). 44 EPA Interim Policy, p. 28. 45 WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and Agricultural Burning (DRAFT), Appendix A, pp. 61-96. 40 11 The WRAP Policy on Enhanced Smoke Management Programs for Visibility includes the consideration of regional coordination as a necessary element in an enhanced smoke management program. A fire emissions projection component for the fire tracking system can provide information critical to the implementation of that element. Inclusion of one-year projected estimates of fire emissions on an annual basis can facilitate operational smoke management and regional coordination. One-year projected estimates may also be useful to estimate a preliminary annual emission goal. The addition of five-year projected estimates of fire emissions into a fire tracking system will aid in regional planning as required by the Rule, as well as in the demonstration of reasonable progress over the periods addressed by the long-term strategy and progress reports. Five-year projected estimates of fire emissions would need to be submitted to support the periodic progress report schedule (i.e., every five years). Neither of these projections should be construed as a limit.46 The FEJF will develop guidance on the fire emissions projection component to meet the various regulatory needs identified above and to work in concert with the WRAP emissions inventory system. 3.6. Collaborative Development Policy Statement E: The development of fire tracking systems by states and tribes will be done collaboratively with state, tribal, local and federal land management agencies, and private parties. In developing a fire tracking system, states and tribes will use a collaborative process, as per the GCVTC Report, which includes state, tribal and federal land management agencies and private parties. Cooperation and collaboration between air regulatory agencies and fire managers is necessary to design an effective and appropriate emission inventory system.47 There are several efforts underway within federal land management agencies and also within EPA to develop fire tracking systems. State collaboration with these efforts may lead to greater efficiency and less need to develop their own individual fire tracking systems for wildland fire. The use of a collaborative process to develop a fire tracking system and subsequent emissions inventory may promote economic efficiency by identifying mechanisms and infrastructure opportunities to avoid the duplication of time and effort. Regional haze SIPs/TIPs will be revisited and revised, per the schedule specified in the Rule, thereby providing opportunities to refine the fire tracking system. Future refinements to the fire tracking system may reflect policy changes and/or technical advances pertinent to mechanism, infrastructure, and data collection options. The collaborative process will help to bring these changes and advances to the forefront for use in revising the fire tracking system. 46 For clarification on emission limits as they apply to fire, see the WRAP Policy on Annual Emission Goals for Fire. 47 NWCG Smoke Management Guide, p. 189. 12 4. APPENDICES APPENDIX A. GLOSSARY This glossary is intended to provide readers with several operating definitions to facilitate a consistent review of this Policy. However, this glossary is not intended to be a complete list of all terms and acronyms. 16 Class I Areas on the Colorado Plateau - The Grand Canyon Visibility Transport Commission Report specified 16 mandatory Class I areas on the Colorado Plateau that were adopted into Section 309 of the Regional Haze Rule. The 16 Class I areas are: Grand Canyon National Park, Sycamore Canyon Wilderness, Petrified Forest National Park, Mount Baldy Wilderness, San Pedro Parks Wilderness, Mesa Verde National Park, Weminuche Wilderness, Black Canyon of the Gunnison Wilderness, West Elk Wilderness, Maroon Bells Wilderness, Flat Tops Wilderness, Arches National Park, Canyonlands National Park, Capital Reef National Park, Bryce Canyon National Park, and Zion National Park. 2064 Natural Conditions Goal# - The ultimate goal of the regional haze program is the absence of visibility impairment due to human-caused emissions. AAQTF - Agricultural Air Quality Task Force. A task force to address agricultural air quality issues established by the Chief of the Natural Resources Conservation Service. Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific objectives (i.e., managed to achieve resource benefits) on agricultural land. Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on which crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included with wildland for the purposes of the Fire Emissions Joint Forum work. Alternatives to Burning - See Non-Burning Alternatives to Fire definition below. Anthropogenic Emissions Source Classification (“anthropogenic”)# - A categorization that designates which fire emissions contribute to visibility impairment in a Federal Class I area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064 natural conditions goal for each Federal Class I area in the WRAP region. This classification includes natural and human-caused ignitions. Area Source - A source category of air pollution that generally extends over a large area. Prescribed burning, field burning, home heating, and open burning are examples of area sources. Class I Area - See Mandatory Class I Area and Non-Mandatory Class I Area. * Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1. # Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15, 2001, Appendix A. 13 Ecosystem Maintenance# - A prescribed fire or wildfire managed for resource benefits, in an ecosystem that is currently in an ecologically functional and fire resilient condition, that is utilized to mimic the natural role of fire. Ecosystem Restoration# - The re-establishment of natural vegetation that may be accomplished through the reduction of unwanted and/or unnatural levels of biomass, which may have accumulated due to management action. Prescribed fires, wildfires managed for resource benefits and mechanical treatments may be utilized to restore an ecosystem to an ecologically functional and fire resilient condition. Emission Factor - A representative value that attempts to relate the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant. These factors are usually expressed as the weight of pollutant divided by a unit weight, volume, distance, or duration of the activity emitting the pollutant (e.g., pounds of particulate matter emitted per ton of biomass burned). Emissions Forum - The Emissions Forum is responsible for the oversight of the assembly and quality assurance of the emissions inventories and forecasts to be utilized by the WRAP forums and oversees the development of a comprehensive emissions tracking and forecasting system. Emission Inventory - A listing, by source, of the amount of air pollutants discharged into the atmosphere. Federal Class I area - See Mandatory Class I Area. FEJF - Fire Emissions Joint Forum. The Fire Emissions Joint Forum’s mission is to address both policy and technical issues while developing programs and tools relating to prescribed fire and air quality for the Western Regional Air Partnership and related Western Regional Air Partnership forums. Fire* - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire. GCVTC - Grand Canyon Visibility Transport Commission. The GCVTC was authorized under Section 169B(f) of the Clean Air Act and composed of the governors of eight western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and Navajo), four Federal land management agencies (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 Commission was established to recommend methods to preserve and improve visibility on the Colorado Plateau, and submitted Recommendations to EPA in June 1996. # Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15, 2001, Appendix A. * Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1. 14 Land Managers* - When this term appears, it refers inclusively to Federal, state, tribal, and private land managers. Mandatory Class I Area - In 1977, Congress identified 156 national parks (over 6,000 acres), wilderness areas and national memorial parks (over 5,000 acres), and international parks in existence before August of 1977 that were to receive the most stringent protection from increases in air pollution. Congress also set a visibility goal for these areas to protect them from future human-caused haze, and to eliminate existing human-caused haze, and required reasonable progress toward that goal. NAAQS - National Ambient Air Quality Standards. Natural Emissions Source Classification (“natural”)# - A categorization that designates which fire emissions can result in a natural reduction of visibility for each Federal Class I area in the WRAP region. This classification includes natural and human-caused ignitions. Natural Visibility Goal - See 2064 Natural Conditions Goal. Non-Burning Alternatives to Fire## - Techniques that replace fire as a means to achieve a particular land management objective (e.g., reduction of fuel-loading, manipulation of fuels, enhancement of wildlife habitat, eco-system restoration, etc.) In this Policy, nonburning alternatives do not include techniques used in conjunction with fire. Techniques used in conjunction with fire are referred to as ERTs. Non-Mandatory Class I Area - Class I areas designated by states or tribes, but are not deemed mandatory by the Clean Air Act. As of January 2002, Class I areas designated by tribes include: Fort Peck Reservation in Montana, Northern Cheyenne Reservation in Montana, Flathead Reservation in Montana, Yavapai-Apache Reservation in Arizona (Class I status under litigation), and Spokane Reservation in Washington. Pasture Land# - Grazing lands comprised of introduced or domesticated native forage species that are used primarily for the production of livestock. They receive periodic renovation and/or cultural treatments such as tillage, fertilization, mowing, weed control, and may be irrigated. They are not in rotation with crops (Natural Resources Conservation Service National Range and Pasture Handbook, 1997). Point Source - A source of pollution that is point-like in nature. An example is the smokestack of a coal-fired power plant or smelter. Prescribed Fire* - Any fire ignited by management actions to meet specific objectives (i.e., managed to achieve resource benefits). * Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1. # Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15, 2001, Appendix A. ## Glossary Definition from WRAP Policy on Annual Emission Goals for Fire, Appendix A. 15 Rangeland# - Land on which the historic climax plant community is predominantly grasses, grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or artificially when routine management of that vegetation is accomplished mainly through manipulation of ecological principles. Rangeland includes natural grasslands, savannas, shrub lands, most deserts, tundra, alpine communities, coastal marshes and wet meadows (Natural Resources Conservation Service National Range and Pasture Handbook, 1997). Regional Planning Organization - An organization that will first evaluate technical information on regional haze and related issues to better understand how their states and tribes impact national park and wilderness areas (Federal Class I areas) across the country. The organization will then pursue the development of regional strategies to reduce emissions of particulate matter and other pollutants leading to regional haze. The five Regional Planning Organizations that receive funding from EPA to address regional haze and related issues are: Central States Regional Air Partnership (CENRAP) for the central states, Midwest Regional Planning Organization for the mid-western states, Ozone Transport Commission (OTC) for the northeastern states, Visibility Improvement State and Tribal Association of the Southeast (VISTAS), and Western Regional Air Partnership (WRAP) for the western states. Rule - Regional Haze Rule. Regulations published in the Federal Register on July 1, 1999 (64 FR 35714) that require states to establish goals for improving visibility and to develop longterm strategies for reducing emissions of pollutants that cause visibility impairment. Silviculture# - The theory and practice of controlling forest establishment, composition, and growth. The art of producing and tending a forest. SIP - State Implementation Plan. Plans devised by states to carry out their responsibilities under the Clean Air Act. SIPs must be approved by the U.S. Environmental Protection Agency and include public review. Smoke Effects* - The effects on visibility (both plume blight and regional haze), public nuisance, and the health-based NAAQS due to emissions from fire. TIP - Tribal Implementation Plan. Plans devised by tribes to carry out their responsibilities under the Clean Air Act. TIPs must be approved by the U.S. Environmental Protection Agency and include public review. Transport Region State - One of nine states that make up the Grand Canyon Visibility Transport Region: Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming. Wildfire* - Any unwanted, non-structural fire. # Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15, 2001, Appendix A. * Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1. 16 Wildfire Managed for Resource Objectives# – The management of naturally ignited fires, regardless of land type or ownership, to accomplish specific, pre-stated resource management objectives in predefined geographic areas with or without a plan in place. This term is considered to be analogous with the terms Wildland Fire Managed for Resource Benefits and Prescribed Natural Fire that are used in regulations and policies regarding Federal wildlands. Wildland* - An area where development is generally limited to roads, railroads, power lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less frequently than once in 10 years), is not fallow, and is not in the USDA Conservation Reserve Program (CRP). The land may be neglected altogether or managed for such purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is not “agricultural land” as operationally defined above. Silvicultural land and rangelands (per the FEJF charge), woodlots, and private timberlands will be included with wildlands for the purposes of the FEJF work. Wildland Fire# - All types of fire (see definition of fire above), except fire on agricultural land. Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire* - These terms both have current use in regulations and policies. They are considered to be synonymous and are used interchangeably in this [FEJF] workplan. These terms refer to the management of naturally ignited fires to accomplish specific, pre-stated resource management objectives in predefined geographic areas outlined in the fire management plan. WRAP Region - The WRAP region includes over 400 tribes and the states of Alaska, Arizona, California, Colorado, Idaho, Montana, North Dakota, New Mexico, Oregon, South Dakota, Utah, Washington, and Wyoming. WRAP - Western Regional Air Partnership. The WRAP is a collaborative effort of tribal governments, state governments and Federal agencies to promote and monitor implementation of Recommendations from the Grand Canyon Visibility Transport Commission. The WRAP may also address other common western regional air quality issues as raised by its membership. The activities of the WRAP are conducted by a network of committees and forums, composed of WRAP members and stakeholders who represent a wide range of social, cultural, economic, geographic and technical viewpoints. The WRAP membership is comprised of the governors of thirteen western states and thirteen western tribes. The current WRAP members include the States of AK, AZ, CA, CO, ID, MT, ND, NM, OR, SD, UT, WA, and WY and the Tribal Nations of Pueblo of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the Department of the Interior, the Department of Agriculture, and the Environmental Protection Agency. # Operating Definitions from WRAP Policy for Categorizing Fire Emissions, November 15, 2001, Appendix A. * Operating Definitions from the WRAP FEJF Workplan, February 25, 1999, Section 1.1. 17 APPENDIX B. WEBSITE REFERENCES This appendix is intended to provide readers with several website addresses that were used to locate supporting information for the development of this Policy. — Western Regional Air Partnership (WRAP) website (http://www.wrapair.org) — U.S. Environmental Protection Agency’s, Office of Air Quality Planning and Standards, Visibility website (http://www.epa.gov/oar/visibility) — Agricultural Air Quality Task Force website (http://fargo.nserl.purdue.edu/faca) — GCVTC Recommendations for Improving Western Vistas, June 10, 1996 (http://www.wrapair.org) Go to the About WRAP link, Go to the GCVTC link — Regional Haze Rule, 40 CFR Part 51, July 1, 1999 (http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf) — Tribal Authority Rule, 63 FR 7253, February 12, 1998 (http://www.epa.gov/fedrgstr/EPA-AIR/1998/February/Day-12/a3451.htm) — Western Regional Air Partnership Charter, Revised November 29, 2001 (http://www.wrapair.org/about/index.html) Go to the Charter link — WRAP, Fire Emissions Joint Forum Charge, July 29, 1998 (http://www.wrapair.org/forums/fejf/index.html) Go to the FEJF Charge link — Workplan, WRAP – Fire Emissions Joint Forum, February 25, 1999 (http://www.wrapair.org/forums/fejf/index.html) Go to the FEJF Workplan link — Policy for Categorizing Fire Emissions, Approved by Consensus by the Western Regional Air Partnership, November 15, 2001 (http://www.wrapair.org/forums/fejf/index.html) Go to the Natural Background link — WRAP Policy on Enhanced Smoke Management Programs for Visibility, Approved by Consensus by the Western Regional Air Partnership, November 13, 2002 (http://www.wrapair.org/forums/fejf/index.html) Go to the Enhanced Smoke Mgmt. Programs link — WRAP Policy on Annual Emission Goals for Fire, Approved by Consensus by the Western Regional Air Partnership, April 2, 2003 (http://www.wrapair.org/forums/fejf/index.html) Go to the Annual Emission Goal link 18 — WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and Agricultural Burning (DRAFT) (http://www.wrapair.org/forums/fejf/index.html) Go to the Emissions link — WRAP Report: 1996 Fire Emissions Inventory (DRAFT) (http://www.wrapair.org/forums/fejf/index.html) Go to the Emissions link — WRAP Report: Non-Burning Management Alternatives on Agricultural Lands in the Western United States, Final, May 15, 2002 (http://www.wrapair.org/forums/fejf/index.html) Go to the Non-Burning Alt. on Agricultural Lands link — WRAP Report: Comprehensive Manual on Non-Burning Alternatives (DRAFT) (http://www.wrapair.org/forums/fejf/index.html) Go to the Non-Burning Alt. on Wildlands link — U.S. EPA, Interim Air Quality Policy on Wildland and Prescribed Burning, April 23, 1998 (http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf) — U.S. EPA, Prescribed Burning Background Document and Technical Information Document for Prescribed Burning Best Available Control Measures, September 1992 (http://www.epa.gov/cgi-bin/claritgw?op-Display&document=clserv:epacinb:1681;&rank=4&template=epa) — National Wildfire Coordination Group, Smoke Management Guide for Prescribed and Wildland Fire, PMS 420-2, NFES 1279, December 2001. (http://www.nwcg.gov/pms/pubs/SMG-72.pdf) — Smoke Management Program Surveys 1) Wildland Smoke Management Program Survey, January 26, 2001 2) Boulder Wildland Smoke Management Program Survey, February 2, 2001 3) Agricultural Burning Smoke Management Program Survey, March 30, 2001 4) Institute for Tribal Environmental Professionals (ITEP) Tribal Smoke Management Program Survey, An Assessment of Tribal Air Quality Data and Programs in the Western United States, September 2001 (http://www.wrapair.org/forums/fejf/index.html) Go to the Basic Smoke Mgmt. Programs link 19 APPENDIX C. SUPPORTING INFORMATION This appendix is intended to provide readers with supporting information on fire tracking systems, but does not specifically address all sections of the WRAP FTS Policy. 1. Essential Components The FEJF will develop further guidance, beyond that contained in the FTS Policy, for states/tribes to establish quality assurance methods, and the procedure and format for the submittal of fire tracking system information. The following is supporting information on the fire tracking system essential components. 1.1. Essential Component 1. Date of Burn For the purposes of the fire tracking system, the date of burn represents the fire activity (i.e., area burned) on any specific day for each burn. For a multiple day burn, multiple entries should correspond to the fire activity on each given day. 1.2. Essential Component 2. Burn Location For each burn, the location should be provided to the nearest mile. 1.3. Essential Component 3. Area of Burn Blackened acres should be determined post-burn. In a pile burn, the area burned should be represented by the pile dimensions as well as the number of piles consumed. 1.4. Essential Component 4. Fuel Type The appropriate emissions factor choice can become complicated when the fire consumes multiple fuel or cover types (e.g., grass and sage). Therefore, for the purposes of the fire tracking system, the fuel type would optimally represent the predominant fuel or cover type consumed in the fire. If additional fuel types beyond the predominant type for a given burn are included in the fire tracking system, the area burned for each fuel type would need to be clearly delineated to allow for subsequent emissions calculations. 1.5. Essential Component 5. Pre-burn Fuel Loading The pre-burn fuel loading should be expressed as the weight of fuel per unit area in tons per acre. The consumption of the fuel will be calculated as part of the WRAP emissions inventory system in order to reduce the propagation of field estimation errors. 1.6. Essential Component 6. Type of Burn Type of burn represents the predominant configuration of the fuel burned (e.g., pile, windrow, broadcast, underburn). If available, identification of pile type (i.e., hand-piled or machine-piled) will enhance the quality of the subsequent emissions calculation. Determining the Type of Burn 20 can be complicated when a burn project includes multiple fuel configurations. For the purposes of the fire tracking system, the predominant burn type should be reported. If additional fuel configurations for a given burn are provided in addition to the predominant fire type, each type of burn should have an area burned and fuel type to allow for subsequent emissions calculations. 1.7. Essential Component 7. “Anthropogenic” or “Natural” Classification The “anthropogenic” or “natural” classification applies as it is defined by the WRAP Policy for Categorizing Fire Emissions, which was developed to clarify the complex relationship between what is considered a natural source of fire and what is considered a human-caused source, as acknowledged in the Rule.48 The appropriate classification is typically determined prior to the initiation of the fire.49 2. Optional Components To support the integration of the fire tracking system with other policy and technical tools being developed by the WRAP, there are four optional components of a fire tracking system that states/tribes should consider in the development of their fire tracking system. The four optional components include Daily Tracking, Fuel Consumption, Non-Burning Alternatives and Additional Fire Tracking Information. 2.1. Daily Tracking Smoke management is a key component in both Sections 30850 and 30951 of the Rule to address visibility impacts from fire. To meet the smoke management requirements for Section 309, and potentially as a tool for Section 308, the WRAP has developed its Policy on Enhanced Smoke Management Programs for Visibility (WRAP ESMP Policy). The WRAP ESMP Policy recognizes that the more intensive levels of smoke management necessitate daily inter- and intra-jurisdictional coordination for approved burns. These types of smoke management programs may rely upon real-time meteorological data and daily fire activity information available to cross-jurisdictional authorities, as well as a permitting system to avoid cumulative smoke impacts and to assist in regional coordination. To provide information critical to the implementation of daily tracking, it is recommended that the pre- and post-burn information be collected on a daily basis for the essential components, as identified in this Policy. Additional daily tracking components, such as burner contact information, may need to be identified by states/tribes to satisfy the information necessary for daily coordination. 48 64 FR 35735. WRAP Fire Categorization Policy, p. 12. 50 64 FR 35767, §51.308 (d) (3) (v) (E). 51 64 FR 35771, §51.309 (d) (6) (i) and §51.309 (d) (6) (iv). 49 21 2.2. Fuel Consumption Pre-burn fuel loading is a key component for the calculation of fire emissions, which can be refined to a large extent based on the fuel that is actually consumed by the fire (i.e., fuel consumption). The quantity of fuel actually burned in a fire will depend on the pre-burn fuel loading and fuel moisture condition, the type of fuel, climatic and meteorological factors, and the intensity of the fire. Accuracy and precision is improved with fuel consumption estimates; however, this parameter can be difficult to estimate. For example, in wildlands the fuel consumed is often not confined to the fuels on the surface, but may include vegetation canopies and/or organic soil layers. These fuels may dominate the mass of the fuel consumed, but have often been neglected in biomass burning inventories. Information that specifies the quantity (i.e., percentage) of the pre-burn fuel load consumed by the fire will enhance the accuracy of the emissions estimate and can be provided in the fire tracking system as an optional component labeled Fuel Consumption. Inaccuracy in Fuel Consumption can lead to the assumption that all of the pre-burn fuel load is consumed, resulting in higher than actual emissions. A number of different options are available to develop the fuel consumption information necessary to calculate fire emissions. Fuel consumption can be determined through 1) expert opinion, 2) empirical models, 3) computer simulations (e.g., Consume52), or 4) other on-site measurements. Field estimates do not always provide precise estimates. When available, the most accurate methods to determine fuel consumption are the use of computer simulations. Ocular estimates are an option, but are not preferred due to field variability. 2.3 Non-Burning Alternatives Consistent with the WRAP Policy on Annual Emission Goals for Fire, non-burning alternatives are techniques that replace fire as a means to achieve a particular land management objective. These techniques could be tracked in a fire tracking system, although the temporal scale will not coincide with the listed essential components. Information may be available from some burners to track parameters such as the area where non-burning alternatives were used, the fuels that were addressed and the specific technique(s) applied. Determining an acceptable method for calculating emissions averted through the use of the non-burning alternatives would most appropriately be developed collaboratively. 2.4. Additional Fire Tracking Information There are differences among states and tribes with regard to air quality issues, emissions information, fire source sectors, and state legislative or tribal governmental requirements. As a result, a state or tribe may select various degrees of fire tracking information; this may include additional parameters for different fire source sectors and/or smoke effects (i.e., plume blight, regional haze, public nuisance, and health-based NAAQS), depending upon their projected or actual impacts. 52 Pacific Northwest Research Station, Forestry Sciences Laboratory, Consume Software, Version 2.1. 22 Additional fire tracking information that a state or tribe may consider adding to a fire tracking system includes, but is not limited to, a) fuel moisture, b) purpose of burn, c) plume rise, and d) burn identification code. 3. Data Collection Methods The ability of a state/tribe to implement the fire tracking system with known essential post-burn activity information for all fire sources may require legislative or governmental changes to existing rules or removal of exemptions from regulation, and/or new tracking of specific fire sources. Therefore, consistent with the WRAP’s Charter, the FTS Policy allows for the consideration of direct data collection as well as indirect estimation techniques, where they satisfy the minimum spatial and temporal information necessary to support emissions inventories and modeling for the WRAP region. There are many ways to obtain the necessary data from a category of fires. Primary activity data may be collected by the manager responsible for fire operations and forwarded to a data collection point, or an agent of the permitting or regulating authority may collect the data. Data might be collected for each operation, or a statistical sample gathered from each category of fire, as defined by unique combinations of essential information components. The information might be observed directly, or inferred from relevant parameters that can be collected more easily or more accurately than direct observations. The FEJF will be exploring viable data collection methods at a later date. 3.1. Direct Data Collection Direct data collection methods cover a wide range, from something as simple as an individual burner tracking the information in a log book to something as complex as a centralized burn authority tracking the information in a database. The burner should ensure that the data and information submitted to the oversight authority via direct data collection methods is accurate, timely, and complete. According to EPA’s Interim Policy, “Federal land management agencies currently collect data on wildland and prescribed fires, however, no standard reporting format is followed.”53 The data collected by land management agencies is usually limited to the time and approximate location of the fire, fire perimeter area, and a qualitative description of fuels at the point of ignition. The WRAP’s 1996 fire emissions inventory preparation effort demonstrated that the data collected by land management agencies for wildland and prescribed fires is insufficient to support the development of a consistent emissions inventory. Although current land management agency data collection efforts do not consistently track all of the essential components identified herein, the feasibility of modifying the current tracking system to maximize economic efficiency and meet the needs of both land management and regulatory agencies should be evaluated. The modification of current land management agency data collection efforts may prove to be the most effective and economically efficient method for the tracking of wildland and prescribed fires in the WRAP region. 53 EPA Interim Policy, p. 29. 23 3.2. Indirect Estimation Direct data collection methods have historically been the primary means of data collection for fire tracking systems. However, emerging technologies may potentially allow for some of the fire tracking system essential component information to be addressed via indirect estimation techniques. Indirect estimation techniques have varying degrees of complexity and accuracy, and range from an annual burner survey for a particular fire source sector, to statistical methods, to daily remote sensing. Remote sensing might be considered for areas or fire sectors where no previous tracking for fire sources has been established. 24 Appendix A-10f. WRAP report “Nonburning Alternatives for Vegetation and Fuel Management” Appendix A-10 –Fire Programs Arizona Regional Haze SIP Summary Past practices of fire suppression in the western United States have resulted in the overaccumulation of timber and undergrowth in forest and rangeland habitats. This overaccumulation of biomass has caused a degradation of forest habitat, wildlife habitat, forest health, and biodiversity; has reduced watershed water quality and quantity; has led to spiraling costs of fire suppression and elevated risks to both public and firefighters; and has increased the occurrence of catastrophic wildfires. For several decades, prescribed burning has been the preferred method for addressing fuel load management; however, it also results some adverse impacts. Specifically, in the context of this document, prescribed fire produces emissions that contribute to the increasing air quality problems in the western United States. In response to this problem, Congress in 1991 created the Grand Canyon Visibility Transport Commission (GCVTC) 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 GCVTC conducted an extensive review of information relating to the problem, collaborating with governmental, business, tribal, and environmental interests and, in June 1996, approved its final report to the EPA. The report made more than 70 recommendations for improving visibility in 16 national parks and wilderness areas on the Colorado Plateau. The Western Governor’s Association (WGA), in conjunction with federal, state, tribal, and local entities, formed a voluntary organization of western states, tribes, and federal agencies. The purpose of the Western Regional Air Partnership (WRAP) is to build on the work of the GCVTC in developing and planning programs that can contribute to reducing emissions and improving visibility throughout the West. Participating states are Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. Participating tribal nations include Pueblos of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Jicarilla Apache Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Representatives of other tribes participate on WRAP forums and committees. Participating federal agencies are the Department of the Interior (National Park Service and U.S. Fish and Wildlife Service), the Department of Agriculture (U.S. Forest Service), and the EPA. The WRAP is composed of a planning group, a technical group, and several forums tasked with the development of technical and policy options for specific Nonburning Alternatives for Vegetation and Fuel Management November 2002 1 J&S 01-562 Summary areas of interest. The Fire Emission Joint Forum (FEJF) is responsible for making recommendations on strategies and methods to manage emissions from prescribed fire. Among the many tasks with which FEJF was charged was the responsibility of investigating the appropriate use of nonburning alternatives to prescribed fire on wildlands. The use of alternatives to prescribed burning, when such alternatives are feasible, result in fewer emissions than burning. However, practices vary widely from state to state, obstacles are numerous, and there is limited awareness of the existence of viable alternatives to burning. Accordingly, WGA retained Jones & Stokes to conduct a series of interviews with landowners, land managers, and stakeholder group members to examine the use of nonburning alternatives on wildlands. Information developed during the course of the interviews was used to: ! identify nonburning alternatives, ! establish criteria for the use of nonburning alternatives, ! identify barriers to the use of nonburning alternatives, ! investigate approaches to overcome these barriers, ! examine current accountability mechanisms, and ! develop recommendations to promote the use of nonburning alternatives. This document represents the compilation of the work done during the course of the interviews and other data collection. The objectives of this document are: (1) to provide landowners and land managers with a comprehensive reference document that describes alternatives to prescribed burning; (2) to provide decision makers with the tools necessary to develop cogent nonburning strategies for vegetation and fuel load management; and (3) to assist air quality regulators, environmental organizations, and the general public in understanding the environmental, economic, and practical advantages of nonburning alternatives. Nonburning Alternatives for Vegetation and Fuel Management November 2002 2 J&S 01-562 Chapter 1 Introduction The 2000 fire season was the worst in 50 years. The scale and intensity of the 2000 fire season capped a decade that was characterized by a dramatic rise in the number of large wildland fires, the costs associated with fire suppression, and the values at risk in the wildland-urban interface. In the 2000 fire season, approximately 123,000 fires burned more than 8.4 million acres. More than $2 billion from federal accounts was spent suppressing wildland fires. This amount does not include state and local firefighting suppression costs; direct and indirect economic losses to communities; loss of private, state, and federal resources; or damage to ecosystems. In August 2000, President Clinton directed the Secretaries of Agriculture and the Interior to develop a response to severe wildland fires, reduce fire impacts on rural communities, and ensure sufficient firefighting capacity in the future. Congress in turn mandated implementation of a National Fire Plan (NFP) through legislation and appropriations. The NFP addresses conditions that have evolved over many decades and cannot, consequently, be reversed in a single year; these conditions will require consistent and ongoing future management efforts. The NFP is a long-term commitment based on cooperation and communication among federal agencies, states, local governments, tribes, and other interested parties. The 2002 fire season was the second worst season in the past 50 years; approximately 6.7 million acres burned in more than 68,000 fires. Colorado, Arizona, and Oregon all suffered the largest fires recorded in the past century. Early in the season, about 45% of the country reported moderate to extreme drought conditions; nearly 50% remained in conditions of moderate to extreme drought as the season ended. Clearly, with the worst and second-worst seasons in half a century occurring only 2 years apart, the problem of catastrophic wildfire is becoming increasingly critical. Fire in the West For thousands of years, periodic fires, ignited by lightning or Native Americans, shaped the ecosystems of the western United States; forests and other western ecosystems supported an abundance of fire-tolerant or fire-adapted species. The historical fire regimes exerted profound influence on the accumulation of fuels, Nonburning Alternatives for Vegetation and Fuel Management November 2002 3 J&S 01-562 Chapter 1 Introduction nutrient cycling, patterns of vegetation growth, and distribution of natural communities. Because of the range of these influences, the fire-suppression activities of the twentieth century have had widespread effects, particularly on those systems that were most adapted to or dependent upon their historical fire regimes. Fire suppression can lead to marked changes in stand density. The increase of small- and medium-size classes of shade-tolerant and fire-sensitive species that can result from suppression is of particular concern. This change produces an increase in the amount and continuity of live fuels near the forest floor that can act as ladder fuels (i.e., fuels that can conduct fire from ground-level or surface fuels into the forest canopy). Moreover, harvest practices of the twentieth century have typically removed the larger overstory trees, accelerating growth in the dense understory and increasing the homogeneity of the fuel structure. The lack of fire has also caused dead fuels on the forest floor to accumulate in excess of their presuppression levels.1 In general, today’s typical forest stand is denser, contains more ladder fuels, and has a higher surface fuel load than historic forest stands. Contemporary forests contain a greater abundance of species that would historically have been excluded by fire (i.e., nonclimax or invasive species). Nonforest ecosystems have been similarly modified by fire suppression activities. Restoring the Balance Only in the past few decades has it become widely understood that the historical practice of fire suppression has had costly and potentially catastrophic repercussions. This new awareness has prompted a strong movement towards the use of prescribed burning, the intent of which is to reduce the risk of catastrophic wildfire and to restore wildland conditions to a more natural fire regime. However, because of the cumulative impacts of prescribed burning on air qualityalready compromised by automotive and industrial emissionsas well as on other environmental resources, there is a strong case to be made for the use of nonburning alternatives that have the potential to achieve many of the same results as prescribed burning but without the adverse effects. Under the auspices of WGA, WRAP, and FEFJ, Jones & Stokes has prepared this manual to foster a greater understanding of the benefits and mechanics of nonburning alternatives. Early in the process, it became clear that a great many answers to the complex issues involved in vegetation and fuel load management already exist, and that the judicious compilation of available knowledge and resources could provide a user-friendly roadmap to the arduous undertaking of developing site-appropriate strategies. Accordingly, Jones & Stokes conducted extensive interviews with a wide array of individuals involved in vegetation, fuel 1 Sierra Nevada Ecosystem Project, Final Report to Congress, vol. II, Assessments and Scientific Basis for Management Options (Davis: University of California, Centers for Water and Wildland Resources, 1996). Nonburning Alternatives for Vegetation and Fuel Management November 2002 4 J&S 01-562 Chapter 1 Introduction load, and land management. Interviewees included federal land managers, state land managers, tribal land managers, researchers, timber industry representatives, and environmental interest group representatives. How to Use This Manual Because of the enormous complexity of the issues involved and the rather daunting variability of conditions throughout the western United States, it was not possible to create an exhaustive “how-to” manual that would address all the contingencies that might face decision makers. Accordingly, this document has been developed to address the categories of considerations that decision makers are likely to confront, the range of options available for development of nonburning fuel management strategies, and the approaches to finding the best solutions to each land manager’s particular situation. It must be understood that every situation is unique, and that a “one-size-fits-all” approach to development of a strategy for management of fuel loads is never appropriate. It is therefore the intent of this manual to provide decision makers (e.g., resource managers, landowners) with the tools to reach an informed decision. Chapter 2 (Vegetation Management: To Burn or Not To Burn) considers the scope of variables that must be weighed in developing a vegetation or fuel load management strategy. Chapter 3 (Nonburning Alternatives: Variables, Criteria, and Definitions) provides an overview of the concepts and vocabulary of vegetation and fuel load management, and summarizes the options available for nonburning treatment programs. Chapter 4 (Getting to Work: How to Build a Nonburning Strategy) guides the decision maker through the technical and nontechnical considerations one must navigate in designing a vegetation or fuel load management program. Chapter 5 (Conclusions and Recommendations) explores means by which the increased acceptance of nonburning alternatives might be promoted. Appendix A presents a sample worksheet for evaluating the options that might be appropriate for any given set of circumstances, as well as an example of the chain of reasoning used to develop a similar site-specific evaluation tool. Other appendices provide [. . . .] Nonburning Alternatives for Vegetation and Fuel Management November 2002 5 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn The Rationale for Treatment As discussed in Chapter 1 (Introduction), the need for management activities to correct the results a century of fire suppression is clear. In considering the approach to developing management strategies, it might be useful to review the concept of fire and fire management in its broadest theoretical context. Fire in the most basic sense is a chemical reaction, involving the rapid oxidation of combustible material and characterized by the release of energy in the form of heat and light. The familiar diagram known as the fire triangle [Figure 2-1; Fire Triangle] illustrates the three components essential to the oxidation process we know as fire: fuel, heat, and oxygen. In the context of wildland fire, fuel is in reality the only one of these components over which humans can hope to exert any meaningful control. The characteristics of the fuel, considered in the context of topography and climate, determine the manner in which fire is likely to ignite, develop, and spread. This process of ignition, development, and movement through the habitat is termed fire behavior. The approach to reduction of fire risk through management activities involves implementing actions that will modify the behavior of fire. The attributes of fuel that management activities can effectively address are, for all intents and purposes, limited to the quantity and arrangement of the fuel load. On the most basic level, vegetation and fuel load management entails disarranging or reducing the quantity of the fuel load to impede fire’s ability to pass through the habitat. Continuity of the fuel load can be disrupted vertically or horizontally; firebreaks can be created; fuel can be removed off site. The optimum strategy is governed by numerous variables, and the body of knowledge concerning fire ecology and fire management is continually expanding. The mechanics of fuel load management are discussed in greater detail in Chapter 3 (Nonburning Alternatives: Variables, Criteria, and Definitions) and Chapter 4 (Getting to Work: How to Build a Nonburning Strategy). Nonburning Alternatives for Vegetation and Fuel Management November 2002 6 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn Development of a reasonable vegetation and fuel load management strategy must be predicated upon an understanding of the desired future condition. The desired future condition, in turn, requires an understanding of the disparity between historic conditions (i.e., the conditions that existed before fire suppression activities or other land use practices altered the vegetative conditions of the area under consideration) and current conditions. The management strategy, then, is the roadmap for moving from current conditions to the desired future condition. Typically, the objective of the management strategy is either to restore forest health or to protect human life and property. While these objectives frequently overlap, such is not always the case. Restoration of forest health generally entails returning the habitat to its historic fire regime, defined by the natural patterns of frequency, predictability, seasonality, intensity, duration, and scale with which fire historically passed through the habitat. Protection of human life and property is frequently addressed by restoring the historic fire regime; however, some habitats are naturally subject to severe fire regimes. In such cases, additional treatment may be necessary to attain the desired future condition. Fire regimes have been classified into five groups; these are summarized in Table 1. Table 1. Fire Regimes Classification Fire Return Interval Severity Example Habitats Group I 0–35 years Low Ponderosa pine, other long needle pine species, and dry site Douglas-fir Group II 0–35 years Stand replacement Drier grasslands, tall grass prairie, and some Pacific chaparral ecosystems Group III 35–100+ years Mixed Interior dry site shrub communities such as sagebrush and chaparral ecosystems Group IV 35–100+ years Stand replacement Lodgepole pine and jack pine Group V >200 years Stand replacement Temperate rain forest, boreal forest, and high elevation conifer species A corollary descriptor of fire conditions describes a fire regime’s extent of deviation from historic conditions. These condition classes also measure general wildfire risk; however, it is important to understand that the criterion of fire risk is based upon the loss of key components of the ecosystem. For example, a habitat with a naturally severe (i.e., stand-replacing) fire regime, while potentially posing a serious risk to human property, might be considered to have Nonburning Alternatives for Vegetation and Fuel Management November 2002 7 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn low risk because the ecosystem is adapted to fire and would be likely to reestablish in accordance with historic patterns. ! Condition Class 1: Fire regimes in this condition class are mostly within historical ranges. Vegetation composition and structure are intact. The risk of losing key components of the ecosystem from fire is low. ! Condition Class 2: Fire regimes in this condition class have been moderately altered from their historic range, either by increasing or decreasing the fire frequency. The risk of losing key components of the ecosystem from fire is moderate. ! Condition Class 3: Fire regimes in this condition class have been significantly altered from their historical return intervals. Vegetation composition, structure, and diversity have been significantly altered. The risk of losing key components of the ecosystem from fire is high. As mentioned above, treatment of a habitat may be appropriate to restore a habitat’s health as well as to protect human resources. Accordingly, areas in any of the condition classes may be suitable candidates for treatment. Conditions that indicate the need for treatment may be divided into two broad categories ! An ecosystem in which the fire regime has been altered, increasing the risk of fire that could result in loss of ecosystem elements as well as in destruction of human life or property. ! An ecosystem in which the fire regime is naturally severe and requires treatment to protect human life or property. When an ecosystem has been altered from its historic regime, efforts to restore that regime are indicated; in other words, the management objective is to modify a condition class 2 or 3 ecosystem into a condition class 1 system. If ecosystem health is the object, such a strategy is considered to be a restoration activity. However, whether or not the fire regime has been altered, risk of wildfire must be addressed in areas near human resources. In the case of condition class 1 habitats (presumably those with naturally severe fire regimes), the treatment would assume a different strategic character than a restoration activity; for example, treatment might entail creation of fire breaks or home protection zones. An Overview of Prescribed Burning If one accepts the proposition that the restoration of natural fire regimes is a legitimate management objective for the preponderance of western wildlands, then it is important to understand the distinction between prescribed burning and natural fire. Although prescribed burning has been widely used in recent decades as a vegetation and fuel load management tool, and despite the acknowledged virtue of prescribed burning to restore natural fire regimes, the mechanisms of Nonburning Alternatives for Vegetation and Fuel Management November 2002 8 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn prescribed burning and natural fire are widely divergent. For instance, naturally occurring wildfires tend to occur during fire season (i.e., summer through fall), while prescribed burning is generally implemented under precisely those conditions that would most likely preclude the spread of a naturally occurring fire. This difference in timing is a necessary precaution against the risk of escape; indeed, the disparity between natural and prescribed fire is intimately linked with the fact that it is the unnatural conditions created by past management decisions that necessitates treatment in the first place. It should be borne in mind throughout the ensuing discussions that those areas that are most difficult to treat are the areas in greatest need of treatment. The Functions of Fire Naturally occurring fire in western ecosystems serves several ecosystem functions. Fire can eliminate invasions of species from outside the ecosystem, thin vegetation to facilitate establishment of young plants, eliminate fuel loads before they attain potentially catastrophic proportions, and recycle nutrients. Fire is an integral component of many western habitat types. Prescribed fire can accomplish many of the same functions as naturally occurring fire; however, as discussed above, the context of prescribed fire differs from that of naturally occurring fire. Because of its controlled nature, prescribed fire does not entirely duplicate the ecological function of fire in the west, nor does it necessarily address all hazardous fuel conditions. As suggested by the interviews and literature reviews conducted for preparation of this document, the reasons for implementing prescribed burning can be assigned to three broad categories: hazardous fuels reduction, habitat management, and ecological restoration. The functions listed below are those that land managers are most likely to cite for using prescribed fire. ! Reduction of fine fuels. ! Reduction of surface fuel loading. ! Mortality of ladder fuels. ! Release of nutrients. ! Improvement of wildlife habitat through stimulating regrowth and seeding. ! Control of some invasive species, pests, and diseases. Use of prescribed fire in wildlands falls into two broad categories. ! Nonburning Alternatives for Vegetation and Fuel Management Vegetation management. Objectives include the reintroduction of fire into fire-adapted ecosystems, stimulation of regrowth of species desired for browse, creation of openings for early successional species, control of invasive species, and nutrient recycling. November 2002 9 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn ! Fuels management. Objectives include cleaning up post-silvicultural residues, maintenance or creation of fuel breaks to protect resources, and preventing losses from catastrophic wildfire. These objectives are not mutually exclusive, and often several objectives can be achieved through a single treatment strategy. For example, treatments designed to make natural stands of forestland more fire resistant can facilitate the return of fire into the ecosystem while protecting houses or other adjacent resources. Challenges to Burning Because fire is such an integral component of many western ecosystems, and because a key objective of many vegetation and fuel management programs is to restore habitats to an approximation of the ecosystem’s natural fire regime, it is often assumed that prescribed burning is the most natural method to achieve such an objective. However, as mentioned above, the conditions under which prescribed burns are implemented differ significantly from the conditions under which naturally occurring fires enter the ecosystem. For example, naturally occurring fires are likeliest during the summer or fall under conditions of low humidity, high temperatures and, frequently, high winds; prescribed burns, to the contrary, are generally implemented under carefully monitored conditions of specific levels of fuel moisture, higher atmospheric humidity, moderate temperatures, and relatively low winds to minimize the risk of escape. Despite the virtues of prescribed burning for vegetation and fuel load management activities, it must be recognized that fire carries negative impacts and risks as well. Disadvantages of burning include: ! smoke and other emissions that contribute to air quality problems and visibility impacts, ! potential loss of resources from escapes, and ! loss of material that might otherwise be utilizable. Some of these impacts violate the regulatory requirements of the Clean Air Act, while others entail risk to resources and to the safety of landowners and firefighters. Moreover, there are logistic disadvantages to the use of burning, many of which can be avoided by the use of nonburning alternatives. Air Quality The Clean Air Act (CAA) of 1970 established national ambient air quality standards (NAAQS) for six pollutants, known as criteria pollutants: carbon monoxide (CO), ozone, particulate matter with a diameter less than 10 microns (inhalable particulate matter or PM10), nitrogen oxides (NOx), sulfur dioxide (SO2), and lead. Most standards were set to protect public health; however, for Nonburning Alternatives for Vegetation and Fuel Management November 2002 10 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn some pollutants, standards are based on other values, such as protection of crops, protection of materials, and avoidance of nuisance conditions. Except for ozone, NAAQS represent short-term (24 hours or less) concentrations that may be exceeded no more than once per year and annual concentrations that may never be exceeded. NAAQS for ozone may be exceeded no more than 3 days in 3 years. In July 1997, EPA promulgated a NAAQS for PM2.5, making it the seventh criteria pollutant. EPA asserts that these fine and ultrafine particles are closely related to significant adverse health effects. Accordingly, EPA has established a 24-hour average limit of 65 micrograms per cubic meter and an annual average limit of 15 micrograms per cubic meter. Controls for PM2.5 will probably not be established until 2005−2008. The smoke released by wildland fires contains large quantities of fine particulate matter, as well as many of the same chemical constituents found in urban smog. Wildfire smoke also contains organic compounds, known as polycyclic aromatic hydrocarbons, some of which are toxic and potentially carcinogenic. Because fine particles are readily inhaled and retained in the lungs, and because wildfires release fine and medium (i.e., <2.5 micron and 2.5−10 micron) particles, these emissions represent a potential to human health and the environment. Moreover, authorities estimate that every 1,000 acres that burn in a wildfire generate a quantity of fine particulate emission equivalent to that produced by all the motor vehicles in southern California in a day. Accordingly, the contribution of prescribed burning to preexisting air quality conditions can be seen to be significant. Risk of Escape Fire by its very nature is characterized by an inherent lack of control. This is of particular concern when using fire as a vegetation or fuel load management tool (remember: those areas that are most difficult to treat are the areas in greatest need of treatment). While this characteristic of unpredictability can contribute to results that mimic natural processes, it can also have serious consequences in the real world of land ownership boundaries, adjacent infrastructure, unnatural fuel load conditions, and political and financial liabilities. The difficulty of confining fire to a prescribed area bears an associated risk; the degree of this risk is influenced by the nature of adjacent resources that might be susceptible to damage or loss, as well as by the kinds of conditions that influence fire behavior (e.g., weather, topography, fuel characteristics). In recent years several large wildfires have begun as prescribed burns, but upon escaping control they destroyed infrastructure, natural resources, watersheds, and people’s homes. In addition to the costs of these losses, a huge amount of money was expended in fighting the fires. Financial liability can fall in many directions depending on Nonburning Alternatives for Vegetation and Fuel Management November 2002 11 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn location and jurisdiction; whoever must bear the cost, it is clear that escape of prescribed fire carries the potential for serious calamity. Loss of Materials Burning of material that might be used as a source of fiber for pulp, particleboard, or energy generation may not be the most efficient or judicious use of our natural resources. The demand for wood and wood products is becoming increasingly difficult to satisfy due to limitations of timber harvest activities on National Forest System lands. Additionally, the use of such submerchantable material might also offset the demand for material that is traditionally derived from large, merchantable trees harvested on public as well as private lands. Logistic Disadvantages Because of concerns associated with the risks of escape, prescribed burning is necessarily constrained by rigorous conditions. For instance, burn plans specify very precise parameters of humidity, wind conditions, temperature, and moisture content of both live and dead fuel within which the burn may be implemented. These parameters, as well as regulatory restrictions, can narrow the window of feasibility for a particular burn plan to as little as several days in an entire season. If for some reason those days are precluded, the window might close until the next season. As such opportunities are missed, fuel conditions can continue to worsen. Furthermore, the local air quality management agency may impose stringent requirements to ensure acceptable levels of emissions. For example, the presence of a stable air mass, which is the safest condition under which to initiate a burn, is also the least desirable condition for air quality concerns. Constraints such as these can combine and overlap to frustrate the most well-conceived projects. It should be remembered that many areas in greatest need of treatment are areas of condition class 2 or 3; in such areas the vegetation structure and composition have been so modified that fire cannot likely be introduced under uncontrolled conditions. By definition, areas of these condition classes are at risk of losing ecosystem components in the event of fire. Consequently, treatment necessitates a managed burn that is coolerthat is, less intensethan a naturally occurring fire would be. While such a managed burn poses less risk of escape than a naturally occurring fire would pose, it is also unlikely to achieve the desired future condition of the treatment area; to the contrary, such a burn is an intermediate step, presumably establishing conditions that would permit a subsequent entry, or entries, with fire to attain the desired condition. Each entry entails repeated risk of escape as well as additional emissions of pollutants. Nonburning Alternatives for Vegetation and Fuel Management November 2002 12 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn Evaluating Nonburning Alternatives In view of the disadvantages to prescribed burning discussed above, there are strong arguments to be made in favor of a careful evaluation of nonburning alternatives when developing a vegetation or fuel load management strategy. Specific nonburning alternatives are discussed in greater detail in Chapter 3 (Nonburning Alternatives: Variables, Criteria, and Definitions); for the purpose of the current discussion, nonburning alternatives can be broadly defined as treatments employing manual, mechanical, chemical, or animal (i.e., managed livestock grazing) methods to address management of vegetation or fuel loads. Nonburning alternatives must, if they are to be satisfactory treatments, mimic at least some of the effects for the achievement of which prescribed burning is typically implemented. Table 1-2 shows a comparison between the effects of potential nonburning alternatives and the effects of prescribed fire. In assessing nonburning treatments and the relative reasonableness of various alternatives, one must consider a spectrum of criteria to evaluate the potential impacts on fuels, the environment, and society. Often, an initially promising idea can have unforeseen consequences. The practice of fire suppression is a case in point: for many years, fires were suppressed with the objective of protecting forest resources. However, as current understanding teaches, this practice has instead produced an increase in catastrophic wildfire, thereby threatening the very resources it was intended to protect. Accordingly, it is important to evaluate the reasonableness of potential nonburning alternatives. Reasonableness can be taken to reflect the likelihood of a treatment to achieve desired results; the relative absence of risk that unanticipated adverse effects will ensue; and the alternative’s conformance to practical, technical, political, and economic constraints. A variety of criteria can be applied during the evaluation process. This document emphasizes those criteria that identify generalized effects of specific treatment types. Criteria that can be evaluated only when considering sitespecific information are not useful for the generic assessment of reasonableness that falls within the purview of this document. For example, potential impacts on wildlife, while extremely important to consider, are far too site-specific to address generally. All treatment types impact wildlife habitat; the degree and character of the impact, however, varies with existing conditions, desired future conditions, and the community of species that occurs on the target site. A myriad of factors must be considered in developing any vegetation or fuel load management strategy. This document adopts a simple division of the issues that land managers must address; however, as in all activities involving resource management, it is important to remember that the different issue areas are interconnected and that systems of organization are merely tools for the convenient processing and assimilation of information. The four issue areas used in this manual are: Nonburning Alternatives for Vegetation and Fuel Management November 2002 13 J&S 01-562 Chapter 2 Vegetation Management: To Burn or Not To Burn ! technical considerations, ! environmental considerations, ! economic considerations, and ! sociopolitical considerations. The evaluation of nonburning alternatives should include a comparison of the effects of the nonburning treatment method under consideration with the effects that would be achieved through the use of burning. Finding Innovative Solutions The interviews conducted in preparation of this report suggested three broad trends regarding the choice of prescribed burning versus that of nonburning alternatives. Respondents inclined towards burning when cost was the determining factor; nonburning alternatives gained support in situations where burning could not be conducted safely, such as in the urban-wildland interface and in areas where pretreatment activities must be carried out prior to burning. Another consideration was the potential marketability of materials on the site. Traditionally, vegetation and fuel load management has been accomplished by one of two methods: harvesting and burning. Each method has gained staunch adherents and dedicated opponents; consequently, the entire issue has become tangled in emotional response and highly charged rhetoric. Nevertheless, it is generally understood that action must be taken to address a problem that has been a century and more in the making and that is becoming yearly more critical. It will be necessary for groups on all sides of the issue to suspend their preconceptions and examine possible alternatives objectively if the fuel load crisis is to be addressed in a safe and timely manner. It must be borne in mind that the situation as it exists in much of the western wildland habitats is not a natural situation; it will, consequently, require decisive actions to correct it. However, with creative thinking, good will, and clear intentions, there is no reason that all parties concerned cannot arrive at mutually acceptable approaches to address acknowledged problems. Nonburning Alternatives for Vegetation and Fuel Management November 2002 14 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions The task of restoring natural communities to a semblance of historic conditions is one that cannot be accomplished by the simple reintroduction of fire into the ecosystem. In many western ecosystems, in fact, such a reintroduction is no longer an option due to the overaccumulation of fuel loads. While it is important to recognize that fire is an integral component of ecosystems in the western United States, it is equally important to recognize the merits of nonburning alternatives to address vegetation and fuel load management issues. At the same time, it must be emphasized that implementation of a nonburning alternative does not preclude subsequent use of burning; indeed, prescribed burns are often predicated on preliminary nonburning pretreatments. The need to reduce fuels increases every year, and proper use of mechanical equipment or other nonburning alternatives can be instrumental in reducing the impact of wildfires in the west. Many of these alternatives have a broader window of opportunity and a much lower level of associated risk than prescribed fire. In developing the appropriate strategy for any proposed treatment area, it is necessary to proceed through a multilayered evaluation of the issue areas introduced in the previous chapter. Moreover, it is critical to establish the criteria by which one must evaluate various treatment options in order to make an informed decision. Again, it must be emphasized that every situation is unique and that superficially similar treatment areas may be subject to markedly differing constraints. Preparation of a worksheet or checklist similar to that presented in Appendix A should assist decision makers in reaching an informed decision regarding the most appropriate treatment method for the area under consideration. Technical Considerations Technical considerations entail the activities that can be conducted within the parameters of physical conditions (e.g., topography, habitat type, fuel conditions), regardless of other considerations. For example, if the terrain is too Nonburning Alternatives for Vegetation and Fuel Management November 2002 15 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions steeply sloped to use heavy equipment safely, then the range of treatment options that depends on the use of such equipment is clearly excluded. When options have been screened on the basis of feasibility, it is important to consider the effects that the various treatment options will have on fuels and fire behavior. The evaluation of nonburning alternatives should address: ! changes to be made to the fuel structure; ! whether the treated area will exhibit increased resistance to fire; ! a comparison between the anticipated results of the nonburning alternative with the results of prescribed burning. Land managers should become conversant with the habitat types in their areas of responsibility, as well as with the basic concepts and common terminology relating to fuel structure and characteristics. Only with a basic working knowledge of the technical aspects of fuel load management can reasonable strategies be developed. Physical Conditions Habitat Types As Map 1 shows, the western United States is a complex amalgam of vegetative communities. These communities have evolved in response to varied characteristics of topography, climate, soil conditions, hydrologic regime, and other physiographic as well anthropogenic conditions. Each community is characterized by a suite of fuel conditions and fire-related traits and responses. For the purposes of the generalized approach of this document, many of these communities can be grouped into broad categories that share common fuel characteristics and types of resources that can be exploited for similar uses. Map 2 shows the simplified categories that this document uses to address the issues of vegetation and fuel load management. The habitat categories that might be candidates for vegetation and fuel load management strategies are: ! grassland, ! shrubland, and ! forested habitat. These three habitat categories can be roughly correlated with appropriate equipment types and material resources with utilization potential. As has been discussed elsewhere, site-specific characteristics will have to be addressed in some detail for each proposed treatment project. Nonburning Alternatives for Vegetation and Fuel Management November 2002 16 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Grassland: The dominant fuel type and predominant carrier of fire is grass or forbs. This category includes many oak woodland and savanna communities; because these communities generally exhibit no vertical continuity of fuels, fire is usually limited to surface grasses. Shrubland: The primary carrier of fire in these vegetation types is a fairly contiguous shrub layer. Fire behavior tends to be more intense than in grassland habitats because the vegetation is typically characterized by greater height and density, larger diameter stems, and (frequently) higher levels of volatility resulting from resins and oils. Surface fuels are limited because the shrubs’ density inhibits growth of other plants and the vegetation type does not produce large quantities of litter. Some trees can be present, but not usually in sufficient density to inhibit the growth or continuity of the shrubs. Forested habitat: The primary carrier of fire in this vegetation type is litter from the trees in the form of needles/leaves and dead branches. Younger trees, shrubs, or low branch growth can provide vertical continuity of fuels. In the case of severe wildfire, dense canopies can become carriers. [2 Sets of photos showing historical changes in fuel conditions] [1 photo of excessive fuel load in grass] [2 photos of excessive fuel loads in shrub] [3 photos of excessive fuel loads in forest] Fuels Fuels can be defined as both living and dead vegetation that is available to burn during a fire. The difference between vegetation type and fuel is that while a vegetation community is defined by species composition, a fuel type is determined by how a given area will burn. The manner in which a given area will respond to fire is a function of the continuity of living and dead vegetation, the height and layers of vegetation, the volume and availability of different sizes of fuels, and weather conditions. Three categories of fuels are critical in understanding fire behavior and the theory of vegetation and fuel load management: ! surface fuels, ! ladder fuels, and ! aerial fuels. Nonburning Alternatives for Vegetation and Fuel Management November 2002 17 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions The role of each category in fire behavior must be understood, and the treatment selected must be appropriate to the category or categories of fuels that represent the primary risk in the treatment area. Surface fuels are those fuels that are in contact with the surface of the ground. They can, depending upon the particular vegetation community, extend up to 5 feet above the ground. Surface fuels include detritus such as fallen leaves or needles, twigs, bark, cones and small branches, heavier branchwood, and downed logs. Surface fuels can also include understory growth such as grasses, forbs, low and medium shrubs, and tree seedlings. These fuels are important because they are the primary carrier of fire. Their specific characteristics influence such aspects of fire behavior as rate of spread, flame length, and residence time. Ladder fuels include taller surface fuels. These fuels generally lie between 5 and 15 feet above the ground. They provide vertical continuity between vegetation layers, conducting fire from surface fuels into the crowns of shrubs or trees. Ladder fuels can initiate and spread crown fires, which lead to increased resource damage, pose high levels of risk, and are very difficult to contain. Aerial fuels include both live and dead material in the forest or shrubland canopy. These fuels are typically more than 15 feet above the surface. They include tree branches, twigs and cones, snags, moss, and high brush. Aerial fuels are the fuels available for supporting a crown fire. All fuel types have characteristics that are important to evaluate when developing the most appropriate strategy for any given area. These characteristics include fuel volume, fuel size, arrangement and continuity of fuels, and fuel compactness. Fuel volume is the quantity of a given fuel type, typically measured in tons per acre. This measure is meaningful only if is contextualized; for instance, it can be compared with a historical or natural condition, or a desired target volume. Fuel size affects the rate of spread and residence time of fire. The size of the material determines the speed of ignition and rate of consumption. For example, in selecting kindling for a cooking fire, smaller, lighter materials are used to start the fire and to generate enough heat to ignite the larger, longer-lasting material. Fuels are normally categorized into two size classes: fine and heavy. Fine fuels are generally those less than ¼ inch in diameter; these include grasses, pine needles, twigs, and smaller branches. Heavy fuels have larger diameters, are more difficult to ignite, and are consumed much more slowly. In general, fine fuels determine how easily a fire ignites and how fast it spreads, and heavy fuels determine how long the fire persists in a given area (residence time). Arrangement and continuity describe how fuels lie in relation to one another on both horizontal and vertical axes. On the horizontal axis, conditions are described as patchy or uniform. On the vertical axis, conditions are described in terms of the presence and condition of ladder fuels. Uniform distribution of fuels Nonburning Alternatives for Vegetation and Fuel Management November 2002 18 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions facilitates a complete, rapid burn. Laddering creates conditions for fire to spread into the crowns, where it can move faster and be more difficult to control. Fuel compactness generally refers to surface fuels. Fire burns more rapidly in loosely compacted fuels because of the availability of oxygen. Compacted fuels, such as piled logging debris or duff, burn more slowly due to lack of available oxygen. Topography Topography is the relief of the proposed treatment area. It describes the angle of slopes, the narrowness of canyons, and the elevational variations within a given area. Topography affects fire behavior in several ways; it can influence regional airflow patterns, and fire itself can respond to steep slopes because of heat’s propensity to rise. Moreover, the character of the terrain serves as a criterion to evaluate the reasonableness of treatment options. For instance, slopes steeper than 40% are considered (in the context of this document) too steep to use mechanical equipment safely; accordingly, mechanical treatment must be excluded as a treatment option. Accessibility Accessibility generally addresses the existence of roads in or near the treatment area as well as the degree to which the area admits movement within it. Roads are necessary for transportation of mechanical equipment, workers, and any materials that may be transported offsite for utilization or disposal. While presence of a road system does not automatically qualify a mechanical treatment option as reasonable, the absence of roads generally precludes mechanical treatment as a viable option. Moreover, particularly rugged terrain or extremely dense vegetation must be considered in determining whether specific kinds of equipment, or even work crews, can navigate the treatment area. Theory of Fuel Load Management The fundamental objective in developing a vegetation and fuel load management strategy is to modify the behavior of fire that may enter the proposed treatment area. As discussed in Chapter 2 (Vegetation Management: To Burn or Not To Burn), the fuels can be modified by either removing them or redistributing them. Initial activities are generally directed towards the surface and ladder fuels, because these are the fuel types where fires typically ignite and spread. Treatment of surface fuels can reduce risk of ignition, particularly in areas of high levels of human use or where the surface fuels exhibit a high degree of continuity. Treatment of ladder fuels helps to decrease the risk of a more Nonburning Alternatives for Vegetation and Fuel Management November 2002 19 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions dangerous crown fire. However, the sequence and methods of treatment are wholly dependent on site-specific conditions. In any case, the initial target of any treatment program will typically be the fine fuels, because these pose the highest risk for ignition and spread of fire. Whether material is modified and left on site or removed depends upon site-specific conditions, both technical and financial; however, it should be borne in mind that fuels left on site remain fuels, and may require additional treatment to achieve the desired future condition. For example, if ladder fuels require aggressive treatment and are cut and scattered on site, they are merely transformed into surface fuels. Depending on the preexisting conditions, additional treatment might be required to alleviate the resultant excessive surface load. Treatment Options Four categories of treatment options are available: manual/hand, mechanical, grazing, and chemical. These four categories are not mutually exclusive, and treatments frequently entail a combination of methods. Each category includes specific techniques appropriate to various conditions and situations. Manual/Hand Hand work involves picking up and moving limbs and brush, as well as cutting downed and standing materials using hand tools or chainsaws. The required levels of skill range from unskilled to skilled (e.g., the ability to use a chainsaw safely). Manual methods usually entail a fairly large crew. Constraints on manual methods are: fuel size (up to 9 inches in diameter); accessibility of the site (e.g., slope, density of understory, rocks, safety); limited opportunity to utilize materials; slow production rate (defined as the acreage that is treated per unit of timefor example, acres per day); and needs (support, safety, sanitation) of personnel. Manual worklifting, cutting, and carrying forest materialsis generally limited to materials of roughly 9 inches or less in diameter. Larger materials can be handled, but efficiency, production rate, and safety decrease rapidly as size increases. If the fuels requiring treatment exceed the 9-inch-diameter threshold, hand work is not a good option. Although hand crews are not subject to the same constraints of access and mobility as mechanical equipment, such constraints must nevertheless be considered. Steeper slopes become decreasingly efficient and increasingly hazardous. Density of vegetation can impede access to the work site and movement within it. Nonburning Alternatives for Vegetation and Fuel Management November 2002 20 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Hand work rarely generates material for utilization. It is difficult and inefficient to carry material to a location where it can be transported off site. Firewood is often collected manually, but most other types of utilization require machinery to enter the area being treated. Hand treatments usually address rearrangement as opposed to removal of fuels. While this can be an effective treatment in certain conditions, it is typically a short-term solution. Alternatively, it can be used as a primary treatment that is followed by burning to consume residual material; the site is subsequently managed by prescribed maintenance burns. Production rate is determined by the structure of the fuels being treated; for example, a dense stand takes much longer to treat than an open stand. Moreover, a fairly large workforce is required to treat areas in excess of a few acres; a larger workforce, if it is to be efficient, requires close coordination and a structured organization system. Advantages of hand work include the low level of ground disturbance, the ability to work on steeper slopes than is feasible for many kinds of mechanical equipment, and the ability to treat sensitive habitats such as riparian areas. Cut and Scatter Hand crews cut and scatter material to change the vertical and horizontal continuity of the fuel load. This technique increases the surface fuel load by redistributing ladder fuels onto the ground surface. It is appropriate where stand density is generally low and existing surface fuels are shallow. An upper depth limit for scattered material is generally prescribed. Pile Cut material can be piled either by hand or using mechanical equipment. As in the cut and scatter method, the fuel load is redistributed rather than reduced. Piling of materials disrupts horizontal continuity to a greater degree than does scattering; it is frequently used as a secondary treatment for material left from a primary treatment method. Piling can be used in denser stand conditions than can scattering because the piles can be situated to avoid fuel loading problems. Because continuity of the surface load is disrupted, increased surface loading is of less concern than it is with the scatter method. However, there are drawbacks to the piling of cut material: piled material decomposes more slowly than scattered material, piling can be quite labor intensive, and dense stand conditions can result in a high number of piles. Nonburning Alternatives for Vegetation and Fuel Management November 2002 21 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Mechanical Mechanical treatments employ equipment as the primary method of modifying or removing fuels. Mechanical treatments include mowing and masticating as well as traditional harvest operations. A common feature of mechanical treatments is the need for access. Generally, treatment areas must be within approximately ¼ mile of an existing road system. In general, mechanical equipment consists of two components: the prime mover and the head. The prime mover is the power source and carrier; it can be rubber tired, rubber tracked, steel tracked, or stationary. The head is attached to the prime mover; heads can be fixed mounted, limited movement mounted, or attached to an articulating arm. A wide variety of permutations are available for use on different kinds of terrain and to address different fuel types and structures; a detailed catalogue of specific equipment types is provided in Appendix __. In recent years the array of equipment available for vegetation and fuel load management has expanded dramatically. Many innovative methods and designs have evolved from technology that was developed for the logging and heavy construction industries. For example, an excavator developed for heavy construction is often employed as the prime mover for a head designed to shred or chip large-diameter fuels. Pile Material can be piled mechanically as well as by hand. See the discussion above for a description of this technique’s advantages and disadvantages. Fuel Modification In this suite of techniques, machinery is used to process the material into smaller pieces that can then be redistributed on the ground surface or removed from the site. Because materials processed in this fashion can be much more densely packed than materials that are scattered by hand or piled, the available oxygen supply is reduced, thereby inhibiting spread of fire and flame height. Fuel modification falls into three broad categories. The first, Masticate/Mow, involves the reduction of material on site and in place; such material is intended to be left. The second, Chip/Grind, involves a piece of equipment into which material is placed for processing, and from which material is discharged through a chute. Chip/grind methods are more appropriate for biomass removal because the system lends itself to placing processed material directly into a conveyance vehicle. The third, Crush, involves crushing and compaction of smaller materials (e.g., brush, slash, small trees) on site. Nonburning Alternatives for Vegetation and Fuel Management November 2002 22 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Masticate/Mow Mastication involves the processing of standing or downed material where it occurs; generally a blade or other mechanism is applied to the fuel. This approach is suitable for denser stand conditions than is scattering or piling, and the redistributed fuel load decomposes more rapidly than scattered or piled materials. It is most appropriate for treating both green and dead ladder fuels and the higher surface fuels; however, it should be borne in mind that mastication is generally constrained from operating with a foot or two from the ground. Like other mechanical treatments, mastication is restricted to areas with suitable access and slopes less than 40%. The distribution of masticated material may inhibit plant growth. The effects of fire on areas that have been treated with mastication are not well documented; it is possible that such areas may be subject to increased residence time if fire does occur. Mowing is primarily appropriate to treat grassland and light shrubland habitats. It is grouped with mastication because, like mastication, mowing processes the vegetation material on site and in place. Chip/Grind Chipping/grinding, like mastication, reduces materials into small pieces. However, as mentioned above, in this group of methods, material is placed into a piece of equipment and discharged, often through a chute; because of this feature, material can be processed more selectively and transported off site for either disposal or utilization. Chipping/grinding can be employed in conjunction with other treatment methods, both manual and mechanical, that create smaller materials as a byproduct (e.g., tree removal, hand cut and pile). It is the method of choice when utilization of biomass is an option. Crush Crushing is another form of mastication; this technique is useful primarily in shrubland habitats dominated by brittle species, such as some of the manzanitas. Some specialized applications have been developed facilitating treatment on steep slopes, making this option particularly suited for habitat types that occur in arid and semi-arid portions of southern California. Tree Removal Numerous approaches to tree removal have been developed as the timber industry has evolved to operate in a variety of habitats and under myriad political and economic constraints. This document addresses three broad categories of tree removal for possible inclusion in development of nonburning fuel management strategies: bole removal, whole tree yarding, and cut-to-length logging. Bole Removal This is traditional harvesting. Trees can be felled either by hand or mechanically; the bole is then removed by a variety of mechanical systems, depending on the Nonburning Alternatives for Vegetation and Fuel Management November 2002 23 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions conditions, and transported off site for processing. Bole removal eliminates the vertical continuity of the fuel load, but increases surface fuels with the addition of leaf/needle and limb materials. Overall biomass is reduced. Bole removal, because of its dependence on mechanical equipment, is restricted to areas near roads and on relatively shallow slopes. Moreover, this technique removes that portion of the forest structure that is at least risk from fire, while leaving the components normally addressed by fuel management programs (i.e., leaf/needle and limb material). However, a wide variety secondary treatments can succeed bole removal as fuel management activities. The critical point is that the subsequent treatments determine the efficacy of bole removal as a component of a fuel management activity. Accordingly, although bole removal in and of itself can in some instances be employed to accomplish specific fuel management objectives (e.g., creation of firebreaks, home protection, disruption of canopy continuity), it is not generally accepted as a vegetation or fuel load management technique, and is not addressed as such in this document. Whole Tree Yarding Trees can be felled either by hand or mechanically; the entire tree is then brought intact to a staging area, where it is processed into a variety of products. This method removes the vertical continuity of the fuel load, removes biomass, and adds very little to the surface fuel load; moreover, the removal of leaf/needle and limb material is more important than bole removal in the context of fire behavior. Material more than 9 inches in diameter can be utilized. However, because branch scarification resulting from removal of larger diameter materials (e.g., >18−24 inches, depending on species) can damage soils and adversely affect water quality, this technique is only appropriate for trees of moderate diameter (e.g., 9 to approximately 18 inches). Cut-to-Length Logging Cut-to-length logging utilizes specialized equipment to cut and process entire trees on site in the forest. While much of the biomass either remains onsite or must be addressed through secondary treatments, an important advantage of this technique is its efficacy in treating material of very small diameter. Moreover, the nature of the equipment renders it less likely to inflict ground damage in treatment areas, and the removal of small, dense trees can be conducted to improve health and vigor of remaining trees. While cut-to-length logging is more expensive than whole tree yarding, it is suitable for stand conditions that preclude use of the latter method. Chemical Chemical treatments entail the application of herbicides. It should be emphasized that chemical treatments do not remove fuels, but either kill existing vegetation or inhibit growth. In general, chemicals are appropriate to treat flashy, understory growth such as the weedy vegetation under power transmission lines or along railroad rights-of-way. Alternatively, chemical treatments can be used in conjunction with other treatment types, including Nonburning Alternatives for Vegetation and Fuel Management November 2002 24 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions prescribed burning, to extend the period between necessary management activities. A widely-used chemical treatment in vegetation and fuel management programs is called brown-and-burn. In this technique, pesticides are used to kill target species of understory vegetation, converting live fuel to dead fuel. The chemical treatment can be applied in spring, when nontarget species remain green, thereby facilitating a prescribed burn to remove the vegetation that has been rendered flammable. However, because this technique is properly a preburning procedure, it cannot be considered a nonburning alternative. The utility of the growth-inhibiting function of chemical treatment types is exemplified in the maintenance of defensible fuel profile zones (DFPZs). DFPZs are shaded firebreaks, typically along ridgetops, where mechanical or manual treatments have been applied to reduce fuel loads and create an area where, in the event of a wildfire, the decreased fuel load will retard the spread of the fire and fire crews can work at containment and control of blaze. Periodic chemical treatments could be used to maintain the desired fuel characteristics within the DFPZ, obviating mechanical or prescribed burning treatments for many years. The drawbacks to chemical treatment methods include very stringent regulatory requirements, the possibility of adverse impacts on water quality, destruction of species that are not target species, toxicity levels, and negative public opinion. Because chemical treatments have limited efficacy in directly addressing existing fuel load management problems, they are not discussed further in this document. However, under certain site-specific conditions they remain potentially useful options. Grazing Grazing involves the use of livestockprimarily cattle and goatsto manage the growth and composition of brush and grasses. While it is of limited utility in forested habitats, it can be an effective technique in rural residential areas, in the urban-wildland interface, and in selected grassland and shrubland habitats. Moreover, research has shown that in some habitats, carefully managed grazing programs can be used to restore degraded ecosystems to historical conditions. For example, in dry rangeland areas, grazing has been used to convert nonnative annual grassland habitat to perennial bunchgrass communities. While the applications of grazing are limited within the scope of habitats addressed in this document, it is nevertheless a technique that enjoys little political resistance and requires a minimum of financial investment. Nonburning Alternatives for Vegetation and Fuel Management November 2002 25 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Environmental Considerations The primary goals of promoting nonburning alternatives for wildland regions are to avoid the environmental impacts of burning on visibility and air quality and to eliminate the risk of escapes, which can threaten human life and property as well as natural resources. While nonburning alternatives may achieve the desired results in terms of air quality, attention must be given to other environmental impacts. For example, use of heavy equipment on sensitive soils can result in soil compaction, and the resultant erosion can lead to ecosystem damage as well as degradation of water quality. Consideration of such potential impacts should constitute part of any analysis of alternatives. The criteria by which to evaluate potential environmental impacts are frequently too site-specific to fall within the scope of this document. However, environmental impacts should be examined in the context of the resource areas listed below. It should be borne in mind that any given criterion might be decisive in a given situation; in a different situation, however, the same criterion might be irrelevant. ! Adverse impacts on air quality. Although a primary motivation for selecting nonburning over burning treatment options is the vast reduction of adverse impacts on air quality, it must nevertheless be understood that even nonburning alternatives may create some adverse effects. For instance, mechanical equipment produces vehicular emissions, and the movement of heavy equipment can give rise to fugitive dust emissions. These effects should be considered during any environmental review process necessary to approve a vegetation and fuel management plan. ! Soil compaction. Soil compaction is of particular concern when conducting mechanical treatments. Passage of heavy equipment can compact soils; compaction can impede permeability, which in turn can reduce groundwater recharge and increase surface runoff. Moreover, the removal of air spaces in the soil can impair the soil’s ability to support root development. ! Water quality degradation. Soil compaction can increase runoff, posing potential threats to water quality. Additionally, removal of vegetative growth can, by eliminating demand for surface and shallow subsurface water, also increase surface runoff. Increased surface runoff can exacerbate erosion, degrade riparian habitats, and discharge damaging quantities of sediment into watercourses. ! Removal of nutrients from site. An important component of any ecosystem is the recycling of nutrients back into the soil. In fire-adapted habitats, periodic naturally occurring fire is a significant mechanism of nutrient recyling; the complex processes of decay and deterioration are also important. Prescribed burning can mimic the role of naturally occurring fire in nutrient recycling; however, nonburning alternatives that remove substantial quantities of biomass can interrupt this cycle. It is important to Nonburning Alternatives for Vegetation and Fuel Management November 2002 26 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions consider the impacts of various treatment options on nutrient recycling when developing a vegetation or fuel management strategy. ! Undesirable impacts on wildlife habitat. Many materials that constitute potentially problematic fuels can also serve as important components of wildlife habitat. For example, snags provide breeding habitat for a variety of species; surface vegetation provides cover for birds, mammals, reptiles, amphibians, and invertebrates; and surface litter can provide an important substrate for small vertebrates and invertebrates. Although any habitat modification can adversely affect wildlife habitat, well-designed vegetation and fuel management programs should, in the long term, have generally beneficial effects on habitats on the landscape scale. ! Threatened and endangered species. While it must be accepted that any habitat modification will affect plant and wildlife habitat, particular care must be given to habitat that supports or that could support threatened or endangered species. In some cases, even seemingly insignificant modifications can have far-reaching effects on certain species. A careful review should be made of special-status species that could occur in the treatment area, and a thorough evaluation of the impacts of alternative treatments on such species should be conducted. ! Augmented spread of undesirable species. Many invasive plant species exploit areas of soil disturbance; such areas can be created by implementation of various treatment methods, especially mechanical methods. Additionally, equipment can transport seeds of invasive species on tires and treads. Practices and procedures incorporated into the vegetation and fuel management plan can reduce the effects of this impact. ! Augmented disease/pest impacts. The process of cutting trees and brush precipitates vegetative production of pheromones that serve as attractants to pests such as woodboring beetles. An influx of such pests can cause damage to remaining vegetation, particularly if stands have been compromised by earlier conditions. This potential impact must be carefully addressed in the development of a vegetation and fuel management strategy. ! Adverse impacts on cultural resources. The potential of inflicting adverse impacts on cultural resources is largely associated with mechanical treatment optionsthat is, the risk of mechanical equipment crushing resources that may be present on or immediately beneath the surface. The environmental review process to which most treatment plans (particularly those on public lands) are subject should address the likelihood of such resources being present in the treatment area. Economic Considerations Conventional wisdom suggests that, as a rule, nonburning alternatives are more expensive than burning. While there are arguments both to support and to refute this contention, there is another perspective that is perhaps more pressing to Nonburning Alternatives for Vegetation and Fuel Management November 2002 27 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions consider: namely, that the fuel load crisis facing western wildlands is far too acute to relegate to the marketplace. The management actions that are the subject of this report comprise a response to conditions that have resulted from more than a century of unfortunate management decisions. The condition of the western wildlands will not dissipate if left to its own devices, and each year that passes without significant action to address the problem increases the extent and risk of catastrophic wildlife. While any revenues that can be generated from vegetation and fuel management activities should be welcomed as offsets to the costs, the driving intent of such programs should not be financial but rather should be based upon the desired future conditions of the wildland habitats subject to the management actions. In examining the question of burning versus nonburning treatments, several financial considerations come to light. First is the direct cost of the treatment method; as stated above, it is generally accepted that burning is less expensive than nonburning alternatives. Second, though, one should consider the indirect costs; for example, the societal costs of impaired air quality in increased health care expenditures, reduced tourist revenues, and resource loss. Third, and perhaps most compelling, is the risk of escape which, as has been discussed previously, can lead to catastrophic and unanticipated costs. However, such a discussion is beyond the scope of this document, and would likely require intensive data collection and analysis. Accordingly, this report focuses on those financial considerations associated with fuel treatment. These considerations are cost per unit of production, production rate, labor requirements, skill requirements, risks of collateral damage, and the potential generation of revenue from materials produced through the treatment method selected. Because nonburning alternatives may be more expensive and logistically complex than burning, they can present greater challenges in securing financing. The potential of an alternative to generate revenues, the availability of funding mechanisms, and access to professional advice and guidance should be examined during development of the most appropriate fuel management strategy. After considering the types of fuels present and the treatment options available, the land managers must then consider funding sources and access to technical assistance or expertise. Costs of Treatment As discussed above, the direct costs of nonburning alternatives tend to exceed those of prescribed burning. Hand crews can be less expensive than other options, but they tend to be most useful in treating rather restricted areas. The cost of mechanical treatments vary widely; regional availability of equipment and personnel can vary tremendously depending upon a given area’s economic base. Techniques such as mastication that require specialized equipment and produce no utilizable material tend to be the most costly, but even conventional tree Nonburning Alternatives for Vegetation and Fuel Management November 2002 28 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions removal techniques can be prohibitively expensive if it is necessary to transport equipment and personnel from out of state. Infrastructure Conditions Infrastructure essentially refers to existing facilities, equipment, labor, and transportation that might be available to implement a desired treatment option. Accordingly, the economic implications of infrastructural constraints are sitespecific; if the treatment area is in a region that traditionally supportsor until recently did supporta forest products industry, then the infrastructure will likely be available to support mechanical nonburning alternatives. Perhaps the most critical consideration in this context is the cost of transporting either labor and equipment to the treatment area or generated materials to the facilities necessary to process them. This is discussed at greater length in Chapter 4 (Getting to Work: How to Build a Nonburning Strategy). Utilization Definition of Utilization Vegetation management activities associated with fuel reduction can result in the generation of usable materials, which in turn can be sold for profit. For the purposes of this document, utilization refers to the use of materials that are generated by treatment activities. When evaluating the feasibility of utilization as a component of a treatment option, it is necessary to consider the costs of generating the material and transporting it off site, the cost of remanufacturing the material into a form that generates revenue, and the potential of selling the product to the end user. Another consideration can be additional support outside of market interactions, generally referred to as subsidies or price supports; these can be used to offset costs when market prices do not equal production costs. The feasibility of utilization is determined by these costs and by market conditions such as industry capacity, capitalization, and labor. This document addresses the utilization process from the generation of raw material to its sale to the remanufacturer. Utilization Benefits As has already been discussed, the primary objective of any vegetation or fuel management program should be achievement of the desired future condition. However, when the appropriate treatment option is likely to produce utilizable material, or when production of such material might be the decisive factor in selecting between alternative methods, then such potential should be considered Nonburning Alternatives for Vegetation and Fuel Management November 2002 29 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions in the decision-making process. Utilization can be undertaken to generate profit or to offset the cost of the treatment program. ! Profitable transactions occur when (a) useful materials are generated and (b) the resultant transactions cover all extraction and transportation fees and produce a margin of profit for the landowner/manager. Profitable transactions are generally market driven. ! Cost offset transactions reduce the cost of treatment that is undertaken to attain condition goals rather than to generate profit. When generation of useful material is not the primary motivation, cost offset transactions can be important to implementing the necessary fuels management program. Such transactions can comprise a combination of product sales, cost sharing, price supports, and grants that provide monies to offset the costs of extraction and transportation not covered by market transactions. In addition to useful products generated directly by fuel reduction activities, indirect benefits, such as increased revenue from recreation (e.g., camping, hunting, fishing), can result from fuel reduction activities. However, because such indirect benefits are difficult to describe and quantify and are generally very case- or site-specific, they are beyond the scope of this document. Types of Products Generated Products that may be generated by nonburning treatment activities can be broadly divided into two categories: industrial and nonindustrial. Industrial products are those that are available in large quanitities, consistently, or over large geographical areas. Nonindustrial products are generally associated with lifestyle-related or aesthetic enterprises; these tend to be used in producing specialty or value-added products. Industrial Products Below is a general list of industrial products than can be generated by some vegetation and fuel load management programs. ! ! Nonburning Alternatives for Vegetation and Fuel Management Whole logs " lumber of varying grades " molding and finish pieces " engineered wood products (e.g., glued laminates, finger jointed material) " peeled veneers (e.g., finish veneers, plywood) Round wood November 2002 30 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions ! ! ! " fencing material " vertical support elements (poles) " beams, joists, and truss elements Cord wood " firewood " low-grade fencing material " pulp for paper " extractive products (e.g., mineral spirits, alcohol) Clean chips " high BTU combustible uses (steam generation for power) " engineered wood products (e.g., flake board, oriented strand board) " pulp for paper " extractive products (e.g., mineral spirits, alcohol, sugars) Dirty chips " lower BTU combustible uses (e.g., drying operations, heating) " mulch " animal bedding Energy-related products include firewood, fuel for drying kilns, and fuel for cogeneration plants. Energy products typically yield the lowest return of the spectrum of forest products that can be produced by vegetation and fuel management programs. In general, market decisions are based on site-specific and regional market conditions. Nonindustrial Products Nonindustrial products typically entail a high value-added component because of the skill required to create them, the inherent attractiveness of the material used, or limited availability. Examples include musical instruments, turned wood products, specialty cooking woods or charcoals, canes and walking sticks, and basket materials. While they generally do not produce industrial-scale benefits, these products may cumulatively provide substantial incentive because of the high value added; moreover, they offer some intriguing opportunities for creative entrepreneurial undertakings, particularly in areas that have suffered economic depression as a result of the flagging timber industry. Nonburning Alternatives for Vegetation and Fuel Management November 2002 31 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Utilization Constraints Although useful material may be generated by vegetation management activities, there are often constraints to successful utilization. For instance, lack of demand or global competition can depress prices beyond the threshold of practicality. The material recovered may not meet industry standards in either the quality or quantity required to warrant commercial exploitation. The infrastructure necessary to extract, transport, or process recovered materials may be lacking due to mill closures, suppression of the lumber industry, or a shortage of skilled labor. Regulatory requirements can create costly and time-consuming constraints to pursuit of management activities. These issues are discussed in greater detail in Chapter 4 (Getting to Work: How to Build a Nonburning Strategy). Funding Sources and Fuel Management Programs Because nonburning alternatives may be more expensive than burning, greater effort may be necessary to secure funding to implement them. Potential sources of funding for nonburning alternatives generally fall into two categories: utilization earnings and program grants. Utilization has been discussed above. Program grant monies are acquired by applying to agencies or nonprofit organizations for financial assistance with fuel reduction efforts. The NFP, the most notable grantmaking program associated with vegetation and fuel load management, has significantly changed the nature of fuel management funding. The NFP has in the last few years greatly increased the amount of funding available for firefighting, restoration, hazardous fuels reduction, and community assistance. This availability of funds has in turn increased the number of fuel management projects currently being implemented in the western United States and nationwide. The USDA Forest Service and the Department of the Interior are currently in the second year of implementing the NFP. Congress provides substantial support, as evidenced by more than $2.26 billion allocated for the NFP in the Interior and Related Agencies Appropriations Act for fiscal year 2002. This amount includes $1,590,712,000 for the Forest Service and $678,421,000 for the Department of the Interior. The NFP facilitates collaboration of federal, state, tribal, and local governmental and nongovernmental representatives for the purpose of improving the management of wildland fire and hazardous fuels, as well as meeting the need for ecosystem restoration and rehabilitation on federal and adjacent state, tribal, and private forest and rangelands. The NFP’s 10-year comprehensive strategy outlines a new collaborative framework to facilitate implementation of proactive and protective measures that are appropriate to reduce the risk of wildland fire to communities and the environment. Nonburning Alternatives for Vegetation and Fuel Management November 2002 32 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions While NFP funds dominate fuel management funding options, other sources are available. Appendix B provides a partial list of funding sources available for fuel management efforts. Many programs dedicated to fuel management and other fire-related issues have evolved in recent years, both independently and as a result of the NFP. In addition to national programs such as the NFP and Firewise, many western states have instituted programs to assist private landowners and public land managers in managing and reducing fuel levels. Some communities have also initiated programs to manage local resources (e.g., Kootenai County, Idaho). National, state, and local fuel management programs offer assistance to fuels managers in a multitude of ways. Fuels management programs may provide technical assistance to land managers. Program representatives can impart knowledge and guidance in project design, financing, and implementation. Appendix C provides a partial list fuels management programs currently operating in the western states. This list was compiled from interviews with state representatives and from internet research. The list is not exhaustive; rather, it is representative of the array of national, state and local programs available to land managers. Labor Sources The availability of labor sources to perform fuel management work is an element of project implementation that should be considered following the identification of fuel conditions and treatment options. Landowners and land managers should assess the availability of manual and specialized laborers. Certain treatments, such as hand piling, require unskilled manual labor by a relatively large work force. Other treatments require specialized skills in operating machinery or equipment. Some areas may suffer a shortage of available labor; others may have a surplus due to an expanding pool of unemployed loggers or other laborers. In some cases, land managers may need to hire out-of-state contractors to perform fuel reduction and removal activities. Appendix D provides a list of some labor sources available in western states. While some states may currently rely on only a few of these sources for fuel management labor, all of them should be considered by landowners and land managers when seeking new labor. Land managers of new and future projects are encouraged to consider all potential labor options and to investigate which are available in their local areas. Nonburning Alternatives for Vegetation and Fuel Management November 2002 33 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Nonprofit Organizations Nonprofit organizations can often provide support to landowners and land managers in planning and implementing projects. For example, local university extension programs may offer technical assistance and professional expertise in developing fuel management projects. Some nonprofit organizations may provide volunteers to participate in labor-intensive activities such as hand piling. There are also opportunities for partnering with nonprofits to secure project financing and to share the responsibility for project implementation and success. Appendix E provides a partial list of nonprofit organizations throughout the western United States that could have an interest in fuel management projects. In addition to the obvious practical advantages, obtaining nonprofit participation can help to involve the local community in project planning, thus aiding in building popular support for the project. Sociopolitical Considerations Social and/or cultural considerations can play a critical role in developing a viable nonburning strategy. Some alternatives may have implications for certain groups, such as small landowners or residents of tribal land. Others are likely to provoke heated responses from certain community groups. Community groups that are predisposed in opposition to a particular type of treatment may have the organizational and financial resources to prevent or delay implementation. Even when the decision maker has evaluated a treatment option in the context of technical feasibility, environmental appropriateness, and affordability, another suite of potential constraints remain to be addressed. These less concrete but no less real sociopolitical considerations can include: ! Health and safety concerns ! Tribal concerns ! Social justice ! Resistance by resource agencies ! Resistance by environmental groups ! Resistance by industry groups ! Resistance by community groups ! Regulatory constraints Nonburning Alternatives for Vegetation and Fuel Management November 2002 34 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions Barriers to Nonburning Alternatives There are numerous barriers that may discourage or prohibit the use of nonburning alternatives to manage fuels in the west. Table XX in Appendix XX lists barriers that were identified by respondents to the interviews conducted during preparation of this report. For this discussion, these barriers have been categorized in accordance with the four issue areas used throughout this document. 1. Technical Constraints. These barriers include inhibited access to project areas due to topographical or climatic conditions or the absence of roads; proximity to residential or other developed areas; and lack of available infrastructure, equipment, or labor. 2. Environmental Constraints. These barriers include presence of sensitive natural resources and the potential impacts of fuel treatments on these resources (e.g., sensitive soils, sensitive vegetation communities, presence of threatened or endangered species, water quality concerns); the potential for introduction or spread of invasive nonnative plant species or pathogenic organisms; and the presence of cultural resources. 3. Economic Constraints. These barriers include lack of funding to perform fuels management treatments; lack of markets for utilization of material; cost of equipment and labor; cost of transporting utilizable material; and the need to generate profit from activity (required by some jurisdictions). 4. Sociopolitical Constraints. These barriers include public opposition to specific treatment types; institutional resistance to new approaches; lack of available staff at relevant resource agencies; regulatory requirements; and non-statutory administrative obstacles to nonburning alternatives (discussed further below. In its 1996 report to the EPA, the GCVTC provided emission management recommendations for area sources, including recommendations regarding fire. One of these recommendations suggested that the federal land management agencies and their state, tribal, local, and private counterparts should identify and remove non-statutory administrative barriers to emission reduction strategies by the year 2000, to the maximum extent feasible. The majority of activities on wildlands are regulated by agencies that plan, approve, and implement projects within an administrative framework. The administrative framework includes statutory and non-statutory barriers. Statutory barriers are laws, codes, and regulations. Non-statutory barriers are internal policies defined in an agency’s handbooks and manuals or formalized in approved land use or resource management plans or environmental documents. Non-statutory administrative barriers may be influenced by social, economic, cultural, or political factors. Non-statutory administrative barriers can include requirements for compliance with best management practices (BMPs), mitigation measures incorporated into Nonburning Alternatives for Vegetation and Fuel Management November 2002 35 J&S 01-562 Chapter 3 Nonburning Alternatives: Variables, Criteria, and Definitions National Environmental Policy Act (NEPA) documents or memoranda of agreement (MOAs), and policy-level decisions identified in resource and land management plans. For example, a BMP for use of mechanical equipment on the Plumas National Forest in northern California specifies a slope limitation beyond which use of mechanical equipment is prohibited. However, as new equipment is developed, it might become advantageous to allow mechanical treatments outside the parameters of the BMP, particularly under specific fuel conditions. In another example, BMPs incorporated into the MOA between the USDA Forest Service and the Tahoe Regional Planning Agency prohibit the use of mechanical equipment within the 100-year floodplain. However, if fuel load considerations warrant such work, it might be advantageous to suspend such prohibitions to reduce the greater risk of catastrophic wildfire. In conclusion, it should be emphasized that despite the many barriers that currently exist, there is great opportunity in the growing field of nonburning alternatives. Many of these barriers can be overcome by the simple expedient of communication and education; others may require adjustments to the administrative and regulatory framework within which fuel management programs must operate. In any case, the increasing degradation of air quality and the continuing crisis of overaccumulated fuel loads clearly warrant concerted efforts in promoting the development and implementation of nonburning alternatives to prescribed burning. Nonburning Alternatives for Vegetation and Fuel Management November 2002 36 J&S 01-562 Chapter 4 Getting to Work: How to Build a Nonburning Strategy Developing Alternatives There is, as has been asserted elsewhere in this document, no “one-size-fits-all” approach to developing a vegetation and fuel load management strategy. In assessing the array of nonburning alternatives and designing a program, the land manager must evaluate the categories of considerations described in the preceding chapter in light of regional and site-specific conditions. This chapter discusses in greater detail the chains of reasoning that one might follow in proceeding through the analysis of possible alternatives. Technical Feasibility When beginning to develop a strategy for vegetation or fuel load management, the land manager must first consider what is technically feasible. Clearly, there is no virtue in navigating the sociopolitical hurdles for activities that either cannot be conducted or will not achieve the desired results. The first step in determining the appropriate methodology is to understand the fundamental relationship between vegetation structure and the various types of treatment options available. Methodology and Vegetation Structure Every methodology, burning and nonburning, is constrained by parameters which, in turn, are associated with the physical conditions of the proposed treatment area. To assist in the decision-making process, the authors have developed a conceptual model that illustrates the relationships of various treatment types with vegetation structure and with one another. This model simplifies the description of vegetation into two components: volume/density (measured in tons per acre) and average stem diameter. For analytical purposes, volume/density is represented on the x-axis of a simple Nonburning Alternatives for Vegetation and Fuel Management November 2002 37 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy graph, and stem diameter on the y-axis. It should be understood that the figures illustrating this model are merely schematic, and are not intended to accurately depict real-world situations. Similarly, the designation of average stem diameter is a conceptual descriptor; for real-world application, the model must be adjusted to take into account relative densities of various diameters in the context of the specific vegetation types to be treated. Although there are many exceptions, this model suffices to describe the spectrum of vegetation structures. For instance, grassland habitat measures very low on both stem diameter and on volume/density; it is, accordingly, represented in Figure 4-1 as Prairie. A grazed field might be represented at a still lower volume, whereas a pampas of shoulder-high grasses would be depicted higher on the graph. Shrublands exhibit higher stem diameter, although sparse habitats supporting small shrubs might contain less volume/density than a tallgrass prairie. Forested habitats might exhibit dense stands of small-diameter trees (e.g., lodgepole pine) or sparse stands of large-diameter trees (e.g., eastside Sierran pine). The graphs reflect a schematic representation of the parameters within which treatment types are typically selected. It should be understood that the graphically depicted limitations are not absolute, but can be artificially forced beyond normal bounds. For instance, the lower limit of harvesting is determined by the economic feasibility of carrying out operations within a certain range of density and diameter of materials. It should not be inferred that tree removal cannot be implemented under conditions of lesser diameter or volume; rather, the implication is that such an operation would not be profitable and would, consequently, require a source of funding beyond the revenue generated by extracted materials. Traditional Treatments Burning The two vegetation management strategies traditionally employed on wildlands are harvesting and burning. Harvesting is associated with commodity production; burning is not. The conceptual model can be used to plot the boundaries of desirable, effective, and efficient conditions for each of these strategies. The plot for burning (Figure 4-2) shows that burning is an effective and controllable method for almost all volumes of small-diameter vegetation arrangements. As stem diameter increases (e.g., ~4−10 inches), the volume for which burning is a reasonable method decreases. This is because fire behavior intensifies; the fire is likelier to escape control and, as temperatures increase, may cause undesirable levels of mortality in the vegetative structure. However, fire regains practicality with further increase of stem diameter because substantially larger stems are likely to survive fire, particularly in more open stands. The upper limit for fire is primarily defined by controllability and potential resource Nonburning Alternatives for Vegetation and Fuel Management November 2002 38 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy damage, although some areas outside the plot reflect conditions under which burning would be either inefficient or unnecessary. As mentioned above, it would be possible to implement a burning program above the area delimited on the graph; such a program, however, would necessitate artificial modification of one or more parameters. For example, a burning program under such conditions would likely require multiple entries, with primary treatments being conducted under such restrictive circumstances that only minimal treatment would be accomplished. Subsequent burns would be necessary to achieve desired final conditions, and each burn would extend the time required to accomplish the goals, increase the risk of escape, and further contribute to air quality impacts. Because the upper limit of the burning plot is essentially a function of risk, this boundary is, in a sense, a “soft” one. Especially in matters as difficult to quantify as natural systems and fire, risk is by its very nature a particularly subjective descriptor. Risk that is acceptable to a land manager might be out of the question to a small landowner. Moreover, a vegetation structure that would be too dangerous to burn under certain weather conditions could be reasonable to burn under others. Such variability and subjectivity can suggest that burning is a reasonable treatment for virtually all vegetation conditionsat least under certain circumstances. Such a perception can have dangerous implications. Land managers might, by waiting for a certain set of conditions, decide to use prescribed fire on vegetation structures for which such treatment would normally not be indicated. The decision might be driven by short-term financial considerations and could, consequently, have unfortunate results. The requisite conditions could so minimize the effects of fire that only limited benefits would be realized. Alternatively, while waiting for the optimum conditions to align, habitat conditions could alter enough that unwanted resource damage could occur; in extreme cases, such changes could lead to escape. Also, as discussed in Chapter 2 (Vegetation Management: To Burn or Not To Burn), the constraints on requisite conditions could be so restrictive that the burn window might never open. Harvesting The plot for harvesting (Figure 4-3) is bounded by financial considerations. The bottom threshold represents the volume/density of material below which the mobilization of equipment and labor becomes economically unfeasible. The left boundary represents the weak market for small-diameter materials and, to a lesser extent, the limitations of equipment and technology for harvesting such materials. The plot illustrates that as diameters increase, the overall volume/density of the material can decrease; this reflects the fact that very large trees have more value per unit of volume than smaller trees. Accordingly, if the land manager chooses to implement a harvesting program on forestland of low volume/density, the financial equation must be modified: the material must have higher than normal Nonburning Alternatives for Vegetation and Fuel Management November 2002 39 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy value, cost of extraction must be lower, or supplemental funding must be secured. It should be noted that the left boundarythat reflecting a threshold of smaller diameter stemshas shifted towards the left over the last few decades. This is because the demand for wood and wood products has increased even as the number of available large trees has decreased; at the same time, mills that had been designed for large diameter logs have been retooled to accommodate smaller diameter materials. New harvesting equipment has also facilitated the shift. The Burn/Harvest Disconnect Figure 4-4 overlays the plots depicting harvesting and burning. Cursory examination reveals a significant gap in the range of vegetation structures suitable for treatment by the two traditional methods; in many cases, the vegetative structures represented by this gap are those most in need of treatment. The unavoidable implication of this gap is that either the limits of the traditional treatment paradigms must be forced to encompass the deficit, or a nontraditional paradigm must be developed to address those conditions beyond the bounds of traditional methodologies. Mastication and Biomass Removal Mastication Mastication in its simpler forms is far from a new concept. Mowing of grass and even larger shrubs has been used to manage vegetation in situations ranging from lawns and gardens to railroad rights-of-way. Only recently, however, has mastication been applied to forest habitats. The boundaries of mastication (Figure 4-5), and the factors those boundaries represent, are quite different than those of burning or harvesting. As in the case of harvesting, there is no risk factor limiting the level of volume/density for which mastication is appropriate. Mastication is suitable for even the finest fuels; the upper (right) limit of stem diameter corresponds almost precisely with the lower limit for harvesting. There are two reasons for this correspondence: first, the equipment used for mastication is not designed for large-diameter trees; second, larger trees have greater value when either left in the environment or harvested for market. Because mastication is a treatment option that is not intended to address market considerations, there is no lower limit of volume/density. Biomass Removal Biomass removal can be similar to mastication except that the material is removed from the site to be disposed or utilized. It can entail creation of chipping or mulching as well as whole tree yarding and, as discussed earlier, it entails a different suite of equipment. Depending on the particular type of biomass removal selected for the specific site, the boundaries can be the same as Nonburning Alternatives for Vegetation and Fuel Management November 2002 40 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy those for mastication (Figure 4-5) or can reflect whole tree yarding (Figure 4-6), which accommodates much higher stem diameters than mastication. The critical difference between mastication and biomass removal is that the material generated by mastication remains on site, whereas the material generated by biomass removal is transported from the site for disposal or utilization. If whole tree yarding is the selected method of biomass removal, and if the treatment is undertaken as a commercial venture, then the boundaries to left and bottom are roughly congruent with the boundaries depicted for harvesting. However, the upper limit of stem diameters is lower, because very large trees cannot be removed intact without causing severe scarification to soils. Site-Specific Considerations The general nature of the foregoing discussion, once again, should be used as a filter through which to evaluate available options. Specific project design must begin with site-specific conditions that have been previously discussed: topography, habitat type, fuel load conditions, road accessibility, and existing infrastructure. In the second part of this chapter, Assessing the Alternatives, a framework is provided for eliminating inappropriate techniques and making the most informed selection of those that remain. Environmental Feasibility When the field of possibilities has been narrowed, the land manager must consider the environmental impacts associated with treatment options that have been found to be technically feasible. Because the environmental considerations are so intimately connected with the location and character of the project site, it is impossible to address them in other than a very general fashion in this document. The treatment area should be thoroughly reviewed (through both literature reviews and field surveys, as appropriate) to inventory any sensitive resources that might be present on or adjacent to it; the proposed activities should then be evaluated to identify impacts that could result. Clearly, if listed species or other sensitive resources are identified, specific regulatory constraints can come into play; these must be addressed in keeping with the requirements of the jurisdiction that has authority over the site as well as with federal regulatory requirements (e.g., the Endangered Species Act, the Clean Water Act, the Migratory Bird Treaty Act). In some respects, the regulatory constraints might be more easily navigated than other environmental influences. As has been stated previously, any vegetation or fuel management program will have environmental effects. Some of these will inevitably be adverse effectsat least from certain perspectives. For instance, Nonburning Alternatives for Vegetation and Fuel Management November 2002 41 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy any mechanical treatment is likely to result in some degree of soil compaction. The land manager must objectively weigh both the short- and long-term impacts and benefits and be willing to make sometimes difficult decisions. Do the shortterm impacts of soil compaction and the temporary degradation of local water quality that might result from excess surface runoff outweigh the impact on air quality that would result from prescribed burning? Does the temporary loss of nesting habitat for raptor species outweigh the risk of catastrophic wildfire? In some instances the answer will be virtually self-evident; in others the decision might be driven not by clinical scientific analysis but by local political considerations. With this in mind, it should be pointed out that environmental have driven the preponderance of the changes in land management in recent decades. Environmental regulation has profoundly altered the timber industry; environmental concerns have also precipitated many of the technological modifications that have increased the range of treatment options discussed in this document. For instance, a shift from wheeled to tracked vehicles has been fostered by concerns over soil compaction (tracked vehicles are less damaging because the vehicle’s weight is more widely distributed than that of wheeled vehicles). In all cases, the land manager must carefully evaluate the options, their relative costs and benefits, and the strategy that may be necessary to promote the desired program. The environmental feasibility is inextricably linked with sociopolitical considerations; this is discussed further in Sociopolitical Feasibility below. Economic Feasibility The cost of implementing nonburning alternatives is the single most challenging financial consideration to overcome; the previous chapter discussed potential funding mechanisms and fuel management programs, and Appendices _ and _ provide lists of these sources and programs. However, in cases where there is reason to consider utilization as a means to fund or offset the cost of treatment, it is necessary to examine barriers related to industry infrastructure. In many areas of the western United States, adequate industry infrastructure is no longer available. Mills were at one time abundant throughout the country; now, however, only certain areas remain capable of processing forest products. Mill closures over the last several decades dismantled infrastructure beyond the loss of the mills themselves. Once a mill closes down the equipment is sold, industry experts relocate, associated businesses fail, and the community’s ability to reengage in the processing of forest products is severely compromised. Additionally, mechanical equipment used for treatment activities is likely to be sold or relocated to regions where the industry is still viable. The location of a project area is perhaps the most critical variable in assessing the cost of undertaking the project. The proximity of a treatment site to processing Nonburning Alternatives for Vegetation and Fuel Management November 2002 42 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy facilities can determine the feasibility of utilizing materials generated by nonburning alternatives. Presence of a pulp mill or cement plant (cement plants represent a potential market for dirty chips) within 100 miles of a project site can encourage the use nonburning methods because generated materials can be readily sold. In areas such as the Pacific Northwest where numerous mills still exist, the utilization of materials tends to be relatively affordable and practical. On the other hand, if processing facilities are not reasonably accessible, the cost of transporting the material can exceed the revenue generated by its sale. Moreover, in regions where mills have been retired or where the forest products industry has never become established, land managers can be forced to hire contractors from as far as two states away to carry out nonburning treatment activities. The cost of nonburning alternatives soars when material must be transported great distances or when contractors must be recruited from outside the region. One hopeful solution to the financial quandary is the cogeneration industry, which could provide a viable market for biomass removed from treatment areas. Cogeneration entails combustion of biomass to produce both electricity and heat; cogeneration plants are typically designed and built close to the source of fuel and the site where the energy and heat will be consumed. Unfortunately, this industry is still in its infancy; accordingly, it is currently a reasonable option only in certain areas. Other biomass utilization technologies, such as biomass gasification and the production of ethanol, also suggest a promising future, not only in increasing the economic feasibility of nonburning alternatives but also in further reducing air quality impacts. Sociopolitical Feasibility The sociopolitical hurdle should probably be the last one crossed, because the outreach, education, and negotiations involved in crossing it would all be wasted if the selected nonburning alternative were found to be impractical or infeasible for some more prosaic reason (e.g., technical constraints or presence of a highprofile endangered species). Nonetheless, the sociopolitical considerations are quite serious, and many projects meet their demise because the proponents fail to pay sufficient heed to the human factor. Public Management Barriers The tendency of agencies to endorse only those fuel management methods with which they have experience and knowledge inherently limits the options customarily utilized. A public resource agency that has always used fire to manage fuel loads and that has no desire or incentive to do otherwise is likely to continue to use fire and to neglect the use of nonburning alternatives. At the same time, many agency staffpersons with a knowledge of specific management techniques (e.g., timber sales) have retired or left the field. This emigration of Nonburning Alternatives for Vegetation and Fuel Management November 2002 43 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy traditional expertise leaves in place a new generation of land managers who endorse land management philosophies that deemphasize the commodification of resources. Many natural resource agencies lack the funds and staff to treat all the areas and fuels requiring treatment. The shortage of personnel, equipment, and expertise may discourage resource managers from considering more expensive or laborintensive nonburning alternatives. This shortage of resources forces some natural resource managers to select which areas will be treated and which will be neglected. Some jurisdictions are constrained by such restrictive operational mandates that deviation from the status quo is virtually impossible. For example, the Montana Department of Natural Resources and Conservation is charged with generating profit from management of the state’s natural resources; these profits are an integral funding source for Montana schools. This primary agency goal drives all decision-making and management actions. In turn, the fuel management alternative that is least expensive or that generates the greatest profit is and has to be the technique employed. The interviews conducted during the preparation of this document suggested that vegetation and fuel management programs undertaken on private lands are subject to minimal regulatory requirements unless some commodity is to be generated. If a commodity is to be generated, some administrative process is likely to be required; however, this process varies greatly from state to state. On public land, however, the planning and documentation efforts are frequently the most time-consuming portion of any treatment project. The costs of these efforts can weigh heavily in the selection of treatment type; even, sometimes, to the extent of outweighing considerations of ecological outcomes and levels of risk. Because so much habitat in need of treatment lies on federal lands, NEPA is the regulatory mechanism most frequently addressed by land managers. The interviews indicated that while prescribed burning treatments can generally be implemented with preparation of an environmental assessment (EA) or can even be eligible for categorical exclusion (i.e., a designation exempting projects from the NEPA review process), nonburning treatments usually require at least an EA, if not an environmental impact statement (EIS). Moreover, the general level of evaluation in EAs prepared for nonburning treatments tends to be considerably higher than that in EAs prepared for prescribed burns. In addition to the increased efforts for NEPA compliance associated with nonburning alternatives, the nonburning alternatives are more likely to be appealed by opponents of the proposed action, causing additional delays and increased costs. These NEPA-related considerations, while anecdotal, have several implications. They support the likelihood of many agencies to be predisposed in favor of prescribed burning over nonburning alternatives. Furthermore, many EAs limit Nonburning Alternatives for Vegetation and Fuel Management November 2002 44 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy the alternatives analysis required by NEPA to a comparison of the Proposed Action and the No-Action Alternative. This is an important point, because it is in the EA that the purpose and need statement for a Proposed Action is developed. The purpose and need statement can be articulated to limit the scope of alternatives that must be analyzed. If the scope of the EA is narrowed in this manner, potentially feasible nonburning alternatives can be eliminated altogether from the public discourse that is part of the NEPA process. Public Opinion Barriers Public opinion regarding fuel treatments varies widely and can be influenced by a myriad of factors. In New Mexico, for instance, the public had long supported fire as the fuel treatment method of choice. In the summer of 2000, the Cerro Grande wildfire, which was caused by the escape of a prescribed burn, swept across the Bandolier National Monument in the Jemez Mountains. Following this event, public opinion shifted in support of nonburning alternatives. Public opinion is highly localized and can vary widely within a relatively small geographic area. Numerous conflicting opinions may be expressed within the same state, region, or municipality. Public opinion on fuel treatments and their respective effects, particularly those effects related to aesthetics, can exert tremendous influence on the selection process. For example, some communities may resent the presence of cattle grazing on fuels, while other communities find the visual results of mechanical treatment unacceptable. Trends among public attitudes, particularly on a small geographic scale, are difficult to predict; it is therefore advisable to assess the opinions and sensibilities of the local community prior to any fuels management project. When possible, inclusion of the local community in the decision-making process helps to ensure popular support. Perception, of course, is critical to bridging the gaps between various stakeholder groups in the arena of public opinion. For example, the most environmentally beneficial treatment in a particular situation might be a tree-thinning operation that will, if effectively implemented, increase forest health, reduce the risk of catastrophic wildfire, result in minimal air quality impacts, and potentially generate some revenue to fund the operation wholly or in part. However, such an operation uses similar equipment and techniques to traditional harvest operations, which can be perceived to be environmentally irresponsible. Such perceptual barriers present challenges, but also offer opportunities for innovative collaborative efforts. Environmental Groups Local environmental groups can be highly visible and influential in dictating the fuel management methods used in a given area, particularly on public lands. Nonburning Alternatives for Vegetation and Fuel Management November 2002 45 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy Such local groups can often be brought into a participatory role through proper outreach and communication efforts. However, fuel management projects that have been developed through such a collaborative process can nevertheless be jeopardized by opposition from outside environmental efforts, particularly those initiated by national organizations headquartered elsewhere. These groups may convey their opinions through the scoping process and public comment requirement specified by NEPA. They may express their opposition through the courts, bringing lawsuits or appeals to delay or kill projects. Legal involvement is frequently initiated long after project development, and can severely limit fuel management options and impede implementation. Often, the level of resistance from national environmental organizations is closely correlated with the visibility and political sensitivity of a given project. Such resistance, when it obstructs projects that have been developed through successful collaboration of stakeholders at the local level, is particularly disheartening because it increases the level of frustration and disenfranchises the participants. In some cases, such reversals can reopen philosophical or ideological rifts that have begun to heal through the advent of a successful local collaboration. Assessing the Alternatives For the purposes of this discussion, it is understood that the primary goal of any vegetation or fuel load management action is to treat as many high-priority acres as possible with a minimum of onsite emissions. In examining the constraints on specific treatment options, the following discussion focuses on forested habitats. Once again, because of the very generic nature of this document, the authors have chosen to adopt a convention likely to enjoy the widest applicability. Because the preponderance of areas requiring treatment in the western states lie in forested habitats; because the widest variety treatment methods are potentially suitable to such habitats; and because the more controversial treatment methodsi.e., harvesting and tree removalare specific to those habitats, shrubland and grassland are excluded from this discussion. Similarly, because grazing and chemical treatment options have rather restricted applications, they, too, have been excluded. Overcoming Obstacles This analysis compares burning with four categories of nonburning alternatives: hand work, mastication, tree removal, and biomass removal. The graphic comparison in Figure 4-8 is, like the other figures in this chapter, a conceptual illustration of relationships and not a representation of quantitative data. Rather, the figure illustrates conclusions based on the professional experience of the authors and on the collation of the results of the interviews conducted in the preparation of this document. The analysis compares the treatment types in the context of five key obstacles: Nonburning Alternatives for Vegetation and Fuel Management November 2002 46 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy ! Gross capitalization: the full amount of expenditures that have to be made before any fuel is treated. This includes equipment and facilities acquisition, staffing, marketing, and planning. ! Post-treatment fuel residue: the fuel that remains on site after the treatment action has been completed. This should be evaluated in the context of the residual fuel’s conditions and arrangement. ! Administrative resistance: the level of resistance exhibited by resource agencies. Administrative resistance can also involve the level of environmental documentation that is required for a particular treatment project. ! Production inefficiency: the amount of money/labor required to treat a unit measure of habitat. ! Interest group resistance: the level of resistance exhibited by particular interest groups (e.g., environmental and community groups). Figure 4-8 illustrates the relative weight of these five obstacles in the context of various treatment options. In selecting an approach, one should determine which technique is most appropriate for achieving the desired future conditions and which has the greatest potential to be implemented. Hand treatments require the least gross capital investment, but are also the least efficient of the nonburning treatment options. They tend to leave high levels of post-treatment fuel residues. Though time-consuming and relatively unproductive, hand treatments face very little interest group opposition or administrative challenge. Mastication requires specialized equipment that is often less common and more expensive than traditional logging equipment. However, transportation and road systems are not as critical for mastication operations. Additionally, there is no need for markets or the associated infrastructure (e.g., processing facilities, transportation system) necessary to exploit them. These factors combine to limit the gross capitalization requirement for mastication. Because it creates limited environmental impacts, mastication encounters little resistance from the environmental and administrative sectors. Mastication experiences only moderate production inefficiency and produces moderate amounts of posttreatment fuel residue. Tree removal also requires specialized equipment, much of which is readily available and consequently more affordable than mastication equipment. The gross capitalization requirement is higher than that for mastication, however, because of the dependence upon a comprehensive transportation system (i.e., roads and available logging trucks). Moreover, tree removal produces the highest level of post-treatment fuel residue of any treatment option. Perhaps the greatest hindrance to tree removal is environmental and administrative resistance. Some interest groups are strongly opposed to tree removal and the perceived Nonburning Alternatives for Vegetation and Fuel Management November 2002 47 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy commodification of public lands. Regulatory compliance requirements and other administrative barriers are significant for tree removal operations. Biomass removal requires very specialized equipment and operational skills, a well-developed transportation network, and a market for generated materials. This industry, contrasted with both standard tree removal and hand treatments, is in its infancy, suggesting that, to achieve a substantial level of efficiency, development would be necessary on a whole-industry scale. Such expansion would result in a very high gross capitalization requirement; this could, for the present, effectively eliminate biomass removal as a regionally applicable approach to solving the fuels problem. Comparing Effectiveness The effectiveness of nonburning treatment techniques can be compared by examining a common goal of land managers: the reduction of fine fuels. A principal indicator of elevated fire risk is the availability of large quantities of fine fuels in particular arrangements. Hand operations are typically used in treating fine fuels; these operations change the arrangement by moving large quantities of surface and lower ladder fuels closer to the ground surface; hand treatments do not, however, actually reduce the volume. Mastication (including crushing and mowing,) does not reduce volume, but alters the vegetation structure even more radically than does hand treatment. The use of vehicles to grind the masticated material into the soil surface enhances this effect. Chipping and grinding, particularly when conducted in concert with biomass removal, transports significant quantities of fine fuels either to a central location or completely off site. Whole-tree yarding, although properly considered a tree removal technique, achieves the same end. Logging operations are generally focused on extraction of commercial materials and not on treatment of fine fuels. Slash operations (as a post-silvicultural treatment) can include hand lopping; however, the intent is rather to comply with regulatory requirements than to perform fuel treatments, and these operations are not as effective as operations in which fine fuels reduction is the monitored success indicator. Figure 4-8 shows that mastication/mowing operations may offer the greatest potential for success in the context of both desired future conditions and likelihood of implementation. However, mastication requires an industry that is still in development and does not yet generate useful materials. It is possible that mastication could be the best first step towards other more market-driven methods such as biomass removal. Consideration should be given to developing Nonburning Alternatives for Vegetation and Fuel Management November 2002 48 J&S 01-562 Chapter 4 Getting Started: How to Build a Nonburning Strategy a subsidized program that effectively builds industry capacity and aids landowners/managers in offsetting planning elements of the gross capitalization element. Making the Decision [Diagrammatic representations of the decision-making process are in development. These figures and explanatory narrative will be inserted here for the next iteration of this document. We’ve experimented with a number of options and have finally focused on an approach that seems both clear and userfriendly; again, as we’ve emphasized, because there is no “one-size-fits-all” solution to fuel load management, it is also not possible to develop an exhaustive ‘decision tree’ that addresses the spectrum of variables and site-specific kinds of issues with which land managers must grapple. Accordingly, we are creating a schematic depiction of the sequence and relationships of issue areas; this will be followed by a matrix evaluating the advantages and drawbacks of a range of mechanical treatment types.] Nonburning Alternatives for Vegetation and Fuel Management November 2002 49 J&S 01-562 Chapter 5 Conclusions and Recommendations Discussion Clearly, there is a need to address with determination the fuel load crisis that has developed in the western United States through a century of fire suppression policies. No less pressing are concerns over the deteriorating air quality that plague urban areas and wildlands alike. Although the promotion of nonburning alternatives cannot alone resolve these issues, the reduction of prescribed burning where nonburning alternatives will adequately address the fuel load situation can certainly contribute to advances in both areas. The investigations conducted during the preparation of this document suggest several salient points. 1. A sound range of nonburning alternatives to prescribed burning currently exists, and emerging technologies await exploitation. While there are obstacles to implementation of many of these alternatives, few of the obstacles are insurmountable; indeed, the greatest challenge is that of stepping beyond the confines of conventional wisdom to explore innovative and creative solutions. 2. Perceived regulatory and administrative barriers to use of nonburning alternatives, while very real, can perhaps be more readily overcome through education and training on the part of land managers and air quality management officials than through an assault on the existing regulatory infrastructure. For example, as discussed in the preceding chapters, the NEPA process can be initiated in such a fashion that nonburning alternatives are excluded from the onset. However, with a relatively cursory amount of training, proponents of nonburning alternatives could be instructed to use the existing procedural requirements of the NEPA review process to ensure that such alternatives are addressed. 3. Very limited accountability mechanisms are in place to promote the use or ensure the consideration of nonburning alternatives. This has been partially addressed in item 2 above; but the issue of accountability is also tied to the fact that traditional treatment programs are evaluated on the basis of numbers of acres treatedand in many cases, treated can be considered as synonymous with burned. Such mechanisms obviously preclude consideration of nonburning alternatives. Situations of this sort, however, are more appropriately addressed at the level of agency policy or land Nonburning Alternatives for Vegetation and Fuel Management November 2002 50 J&S 01-562 Chapter 5 Conclusions and Recommendations management plan development (e.g., individual forest plans, resource management plans) than at the level of legislative action (e.g., NEPA). 4. Because many of the obstacles to nonburning alternatives are economic, there is a substantial need to develop technologies to encourage use of these alternatives. While capitalization costs may in some cases be high, these costs should be weighed not only against the costs of prescribed burning, but also against the potential savings and revenues that could be realized by development of new industries that produce energy, reduce air quality impacts, create job opportunities, and reduce dependence on imports of fossil fuels. 5. Despite the advantages of nonburning alternatives in the context of air quality impacts, it is evident that prescribed fire will remain a critical component of many vegetation and fuel load management programs. Accordingly, the object should be not to replace burning with nonburning alternatives, but to design programs to include a greater proportion of nonburning techniques, such that air quality impacts are substantially reduced. Air quality and risk of wildfire are subject to influences far beyond wildland management policies. The energy industry, transportation policy, regional economics, technology, environmental protection, and social justice are all interconnected with both issues and the decisions that are made to address them. Consequently, communities and decision makers should look beyond the immediate boundaries of vegetation and fuel load management programs for comprehensive solutions to the problems. Finally, the increased acceptance of nonburning alternatives is dependent upon a change of mindset. Resource agencies, industry groups, environmental groups, and community groups must all be willing to reassess their preconceptions if significant progress is to be made in combating the dual problem of air quality and fire risk. Recommendations A number of recommendations emerged from the process the authors followed in preparing this report. Although some of these recommendations arguably lie outside the initial scope of this document, they have nevertheless been included because the authors feel them to be germane to the matter at hand. Because the recommendations in many cases cross the organizational structure followed in previous chapters, that structure has been forgone for this discussion. ! Nonburning Alternatives for Vegetation and Fuel Management Promote consideration of nonburning alternatives within agencies. This should be undertaken at the agency policy or land management plan level. For instance, every federal agency as its own set of guidelines for NEPA November 2002 51 J&S 01-562 Chapter 5 Conclusions and Recommendations compliance; proponents of nonburning alternatives could suggest relevant agencies to adopt measures requiring consideration of nonburning alternatives in the process of developing vegetation and fuel load management plans. ! Promote proactive participation in the NEPA review process. The WRAP could disseminate educational materials to proponents of nonburning alternatives to enable them to engage in the NEPA scoping and review process early on. Where appropriate, the purpose and need portion of the project description should be broadened such that nonburning alternatives are not precluded. ! Initiate an outreach and education program. This is a two-pronged recommendation. One area of outreach should be directed to the public, promoting acceptance of nonburning alternatives as environmentally responsible; this program should emphasize that protection of air quality, like protection of wildland habitat, is a critical component of responsible environmental stewardship. A parallel outreach program should be developed for resource agency staff to promote acceptance of nonburning alternatives and to encourage inclusion of such alternatives in analyses conducted during development of planning documents. ! Provide administrative and economic support to development of infrastructure. If nonburning alternatives are to be successful, additional infrastructure will be necessary. As discussed above, this infrastructure need not be a recapitulation of traditional timber industry infrastructure; indeed, the political climate precludes such a course of action. Rather, attention should be paid to promoting the development of local and regional biomass utilization programs. Such programs offer intriguing opportunities for entrepreneurial innovation; economic redevelopment of depressed rural communities (particularly those impacted by the contraction of the timber industry); reduction of dependence on imports of fossil fuels; reduction of increasing waste disposal problems; and reduction of air quality impacts. ! Encourage nonindustrial utilization programs. In concert with the preceding item, opportunities for development of value-added enterprises abound. In the Pacific Northwest, where traditional logging communities have suffered mill closures and high unemployment, innovative value-added businesses have offered examples of the potential of this approach. For instance, a small company on Vancouver Island produces spruce and cedar guitar tops. The company anticipates gross revenues of $Canadian 1 million in 2002. It provides 14 year-round jobs utilizing 3,600 cubic meters of timber annuallyan amount that would support 2.5 mill workers in the industrial timber business. Moreover, leftover material that is unsuitable for guitar tops is used by another local business to craft gift boxes for exporting smoked salmon. In another example, homesteaders in a forested region of northern California Nonburning Alternatives for Vegetation and Fuel Management November 2002 52 J&S 01-562 Chapter 5 Conclusions and Recommendations cut limbs and small trees both to reduce the risk of wildfire and to provide themselves with firewood. However, realizing that much of the hardwood left behind by the previous harvest operations could have intrinsic commercial value of its own, they created a small-scale logging and milling system. Harvesting hardwood trees on the basis of promoting forest health, they market hardwood to local craftspeople, who create value-added products. Their harvest techniques, employing pickup trucks, portable sawmills, and preexisting logging roads, reduce the risk of catastrophic wildfire, minimize air quality impacts, promote forest health, and contribute to the local economy. Programs such as these, while in themselves not able to address vast tracts of wildlands in need of treatment, can certainly contribute to the promotion of nonburning alternatives. Perhaps more importantly, they can help to bridge the gap between traditional forest practices and those who are unconditionally opposed to any form of commodification of forest products. ! Develop a comprehensive vegetation and fuel management manual. This report fundamentally addresses and promotes nonburning alternatives. However, as has been discussed above, prescribed burning is not likely to be removed from the repertoire of treatment options. With that in mind, it is recommended that the contents of this be expanded, or combined with existing materials, to provide a comprehensive guide to program development. Such a manual would begin with the earliest planning stages and would include prescribed burning techniques, but would emphasize incorporation of emission reduction techniques. It must be emphasized that many of the nonburning alternatives described in the previous chapters can in fact be considered emission reduction techniques, because they are frequently used as parts of larger programs that also entail prescribed burning. A Final Word In conclusion, perhaps the most important lesson to learn from the forest management issues that confront us is that single solutions rarely suffice. The present crisis developed because those involved in making management decisions failed to understand the complexity of the natural systems they were attempting to manage, and because they did not consider the myriad consequences of their actions. So, too, we must bear in mind that a great deal remains to be discovered about the mechanics of ecosystems, the interrelationships of seemingly disparate occurrences, and the unanticipated consequences of solutions we undertake. It is imperative, therefore, as both fuel load and air pollution conditions continue to worsen, that we consider a range of solutions as broad and interconnected as the factors that gave rise to the problems in the first place. Nonburning Alternatives for Vegetation and Fuel Management November 2002 53 J&S 01-562 Comparison of Administrative Resistance Among Treatment Types Burn Comparison of Post-treatment Fuel Residue Among Burn Treatment Types Hand Hand Mastication Mastication Tree Removal Biomass Removal Tree Removal Biomass Removal Comparison of Gross Capitalization Requirements Burn Among Treatment Types Comparison of Production Inefficiency Among Treatment Types Burn Hand Hand Mastication Mastication Tree Removal Biomass Removal Tree Removal Biomass Removal Comparison of Interest Group Resistance Among Treatment Types Burn Hand Mastication Tree Removal Biomass Removal Appendix A-10g. WRAP report “Burning Management Alternatives on Agricultural Lands in the Western United States” Appendix A-10 –Fire Programs Arizona Regional Haze SIP Eastern Research Group, Inc. Non-Burning Management Alternatives on Agricultural Lands in the Western United States Volume I: Agricultural Crop Production and Residue Burning in the Western United States FINAL Prepared for: The Fire Emissions Joint Forum of the Western Regional Air Partnership May 15, 2002 ERG No.: 3261.00.005.001 NON-BURNING MANAGEMENT ALTERNATIVES ON AGRICULTURAL LANDS IN THE WESTERN UNITED STATES VOLUME I: AGRICULTURAL CROP PRODUCTION AND RESIDUE BURNING IN THE WESTERN UNITED STATES FINAL Prepared for: The Fire Emissions Joint Forum of the Western Regional Air Partnership Prepared by: Eastern Research Group, Inc. (ERG) 8950 Cal Center Drive, Suite 260 Sacramento, California 95826 and Enviro-Tech Communications P.O. Box 593 Folsom, California 95763 May 15, 2002 DISCLAIMER This document was developed for the Fire Emissions Joint Forum (FEJF) of the Western Regional Air Partnership (WRAP) by Eastern Research Group, Inc., (ERG) and Enviro-Tech Communications. Although the contents of this report have undergone extensive review by the FEJF, the opinions, findings, and conclusions expressed represent those of ERG and EnviroTech Communications and not necessarily those of the members of the FEJF. TABLE OF CONTENTS Section Page EXECUTIVE SUMMARY....................................................................................................... ES-1 1.0 INTRODUCTION............................................................................................................1-1 1.1 1.2 1.3 2.0 CROP PRODUCTION IN THE 15 WESTERN STATES ..............................................2-1 2.1 2.2 2.3 2.4 2.5 3.0 Study Objectives ..................................................................................................1-1 Data Collection Methodology ..............................................................................1-3 Document Organization .......................................................................................1-3 Sources of Crop Production Data.........................................................................2-1 2.1.1 National Agricultural Statistics Service Database ...................................2-1 2.1.2 State Agricultural Statistics and Reports..................................................2-3 2.1.3 1997 Census of Agriculture......................................................................2-3 Crop Production Data Compilation and Gap Filling............................................2-3 QA/QC Procedures...............................................................................................2-5 2.3.1 Reality Checks: Compare Data to Standard Reference Value ..............2-10 2.3.2 Peer Review: Checklist or Written Comments by Reviewer ................2-10 2.3.3 Sample Calculations: Replication of One Set of Calculations..............2-12 2.3.4 Computerized Checks: Electronic Methods of Checking .....................2-12 2.3.5 Independent Audits: Systematic Evaluation to Determine Quality ......2-12 2.3.6 Extended Peer Review: Local Knowledge............................................2-13 Results of Compiled Crop Data .........................................................................2-13 Development of the Geographic Database.........................................................2-16 AGRICULTURAL BURNING ACTIVITY IN THE 15 WESTERN STATES .............3-1 3.1 3.2 3.3 3.4 Sources of Agricultural Burning Data..................................................................3-1 Agricultural Burning Data Compilation and Gap Filling.....................................3-2 3.2.1 Sources of Agricultural Burning Data......................................................3-2 3.2.2 Database Development.............................................................................3-6 3.2.3 Residue Loading Factors..........................................................................3-8 3.2.4 Percent Burned By Crop ........................................................................3-11 3.2.5 Comparison to USDA Air Quality Task Force Study............................3-13 QA/QC Procedure ..............................................................................................3-15 3.3.1 Reality Checks: Compare Data to Standard Reference Value ..............3-15 3.3.2 Extended Peer Review by FEJF and Other Stakeholders ......................3-16 3.3.3 Sample Calculations and Computerized Checks....................................3-16 3.3.4 Independent Audit by Emissions Inventory Contractor.........................3-17 Results of Agricultural Burn Activity Data........................................................3-17 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 i TABLE OF CONTENTS - CONTINUED Section 4.0 CONCLUSIONS AND RECOMMENDATIONS...........................................................4-1 4.1 4.2 5.0 Page Conclusions ..........................................................................................................4-1 Recommendations ................................................................................................4-2 REFERENCES.................................................................................................................5-1 APPENDIX A: CROP PRODUCTION DATA APPENDIX B: CROP PRODUCTION MAPS APPENDIX C: AGRICULTURAL RESIDUE BURN ACTIVITY DATA AND CROP BURN AVERAGES APPENDIX D: AGRICULTURAL RESIDUE BURN ACTIVITY MAPS APPENDIX E: RELEVANT VOLUME II TABLES Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ii FIGURES AND TABLES Figures Page Figure 2-1 Top 5 Crops Harvested in the 15 Western States...............................................2-19 Figure 3-1 Agricultural Burn Activity in the Western United States ..................................3-21 Tables Page Table ES-1 Average Percentage of Acres Harvested that are Burned for Selected Crops in the Western United States ............................................................................. ES-4 Table 2-1 Crops Harvested During 1996/1997 in the 15 Western States.............................2-6 Table 2-2 Sources of Data for Crops Harvested During 1996/1997 in the 15 Western States .................................................................................................2-8 Table 2-3 Summary of QA/QC Methods Used to Evaluate Crop Production Data ...........2-11 Table 2-4 Summary of Crop Production of the Top 10 Crops Within the 15 Western States for 1996/1997 (Acres Harvested) ............................................................2-14 Table 3-1 Summary of Agricultural Burning Data Collected for the Western States ..........3-3 Table 3-2 Description of the Agricultural Burning Database for the Western States ..........3-7 Table 3-3 Residue Loading Factors for Crops Burned in the Western States ......................3-9 Table 3-4 Average Percentage of Acres Harvested that are Burned for Selected Crops In the Western United States..............................................................................3-12 Table 3-5 Summary of Agricultural Residues Burned within the Western States for Various Years (1996-1999) (Tons)...............................................................3-18 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 iii ACRONYMS A_BURN acres burned AH acres harvested AK Alaska AQTF Air Quality Task Force Avg average Avg_Crop Crop average percentage burned Avg_State State average percentage burned by crop AZ Arizona BAL bales BU bushels CA California CA_Lake Lake County, California CA_SJV San Joaquin Valley, California CA_South_Coast South Coast Air Basin, California CASS California Agricultural Statistics Service CDFA California Department of Food and Agriculture CO Colorado CoFips County-Federal Information Processing Standards COMM commodity CRP Conservation Reserve Program CWT hundredweight (100 pounds) EI emissions inventory e-mail electronic mail ERG Eastern Research Group, Inc. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 iv ETC Enviro-Tech Communications FEJF Fire Emissions Joint Forum FIPS Federal Information Processing Standards FSA Farm Service Agency GIS geographical information system HI Hawaii ID Idaho KBG Kentucky bluegrass MT Montana NASS National Agricultural Statistics Service ND North Dakota NM New Mexico NRCS Natural Resources Conservation Service NV Nevada OR Oregon PEDB Published Estimates Data Base QA/QC quality assurance/quality control R_BURN residue burned (tons) RES residue (tons) RL residue loading (tons/acre) SD South Dakota SJVUAPCD San Joaquin Valley Unified Air Pollution Control District StFips State-Federal Information Processing Standards U.S. EPA United States Environmental Protection Agency USDA United States Department of Agriculture Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 v UT Utah WA Washington WESTAR Western States Air Resources Council WGA Western Governors’ Association WRAP Western Regional Air Partnership WY Wyoming YR_HAR year harvested Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 vi EXECUTIVE SUMMARY The Western Regional Air Partnership and its Fire Emissions Joint Forum (WRAP/FEJF) sponsored this project to investigate the alternatives to agricultural burning. The geographical scope of the project includes the 15 Western states of Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, North Dakota, New Mexico, Nevada, Oregon, South Dakota, Utah, Washington, Wyoming, and the tribal lands within these states. The objectives of this project were designed to facilitate the development of crop production and agricultural burning activity data to support analysis of alternatives to burning, and they include: • Development of a crop production database and an agricultural burning activity database; • Identification of the “universe” of potential non-burning management alternatives; • Design of a methodology to assess the impacts of alternatives (e.g., agronomic, environmental, economic, etc.); • Identification of existing and potential accountability mechanisms for tracking if, and which, non-burning alternatives are used by federal, state, local, and tribal entities, and potential barriers to their implementation; and • Development of a plan for implementing alternatives in the 15 Western states. This analysis was supported by a three-tiered approach to research. The three tiers of sources included: (1) federal agencies such as the U.S. Department of Agriculture (USDA) and the National Agricultural Statistics Service (NASS); (2) agencies such as the University Agricultural Extension Services and state air agencies; and (3) private consortiums such as growers, producers, distributors, and information clearinghouses. The results of this project are documented in two reports under the title “NonBurning Management Alternatives on Agricultural Lands in the Western United States,” Volume I and Volume II. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-1 Volume I: Agricultural Crop Production and Residue Burning in the Western United States The goal of the crop production database was to compile acres harvested by crop at the county level for all major crops harvested and/or crops known to be burned in each of the 15 Western states. The crop production database was developed from three main sources of information: 1. The NASS database; 2. State agricultural statistics data and reports; and 3. The 1997 Census of Agriculture. Also, the Farm Service Agency (FSA) website was used to obtain information on lands included in the Conservation Reserve Program (CRP). Although the target year for these data was 1996, it was necessary to include 1997 data when 1996 data were missing for crops that were known to be burned. The crop database underwent an extensive quality assurance/quality control (QA/QC) process to ensure that at least 90 percent of the acres harvested of major (i.e., top 10) crops and 100 percent of all crops burned were accounted for in the database. In total, over 50 different crops were grown in the 15 Western states which amounted to nearly 77,000,000 acres harvested in a single year during the 1996/1997 timeframe. The resulting county-level data were mapped using a geographical information system (GIS) (see Appendix B). The agricultural burning database was developed for purposes of identifying the extent of burning in the Western states, and to assist with the emissions inventory being developed by the WRAP/FEJF. The burning database was compiled from three types of data representing various geographical areas within the 15 Western states region: • Burn permits issued or other mechanisms for determining actual burn activity; • Emissions inventory estimates; • Anecdotal information from surveys sponsored by the WRAP/FEJF, the Western States Air Resources Council (WESTAR); and • Data resulting from peer review of the draft agricultural burn activity database prepared for this project. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-2 Although a significant amount of data were obtained, burning was known to occur in certain counties and states for which data were unavailable. A gap filling technique was developed to provide estimates of acres and residues (tonnage) burned at the county level for those unaccounted areas (i.e., North Dakota, New Mexico, and South Dakota). Table ES-1 shows the results of the overall database in terms of average percentage of acres burned by crop. The resulting county-level data were mapped using GIS (see Appendix D). Although the data that were collected and compiled were subject to specific QA/QC procedures, some of the data and results have inherent uncertainty. These uncertainties are due to such factors as use of “as is” data sets provided by the various sources and an inconsistent definition of “agricultural burning” within these data sets. Also, the gap filling averages used to provide missing data in some states cannot accurately depict actual burn activity that occurred in those states. Even for some areas where gap filling was not used, information originally provided for the draft database was revised with significantly different information obtained during the peer review process (e.g., Utah). While it can be concluded that the peer review process worked in this case, this result is illustrative of the need for a coordinated, systematic process to collect agricultural burning data, establish data quality objectives, and resolve conflicting data. The researchers and peer reviewers contributing to the final agricultural burn activity database made the following recommendations pertaining to future improvements of this database: 1. Develop a mechanism (e.g., program, regulation, etc.) whereby the relevant state, county, tribal, agricultural, and stakeholder entities establish data quality objectives, define data sources, and compile data on a regular basis to estimate the extent of agricultural burning in the Western United States. Also, this mechanism should provide a consistent definition of the residue types to be included in the agricultural burning category. 2. Conduct research to identify and/or calculate specific yield-based RL factors for each geographical zone or area; and 3. Incorporate the impact of irrigated and nonirrigated land agricultural practices. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-3 Table ES-1. Average Percentage of Acres Harvested that are Burned for Selected Crops in the Western United States Crop Wheat Rice Corn Barley Sugarcane Orchards (Trees, Bushes, Vines) Grasses and Seeds CRP Acres Harvested1 31,619,000 500,000 5,766,000 5,696,900 42,900 2,497,767 899,976 2 286,174 Acres Burned 905,756 254,706 10,668 137,872 30,000 530,100 394,077 28,917 Overall Average Percentage of Acres Burned 2.9% 50.9% 0.2% 2.4% 69.9% 21.2% 43.8% 10.1% Notes: 1 Acres harvested and burned are for the 15 Western states, excluding Nevada because burning in that state was not identified for specific crops . 2 Value represents number of acres in the Conservation Reserve Program (CRP). Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-4 Volume II: Non-Burning Management Alternatives and Implementation Plan Strategies The majority of information collected and reviewed in this study suggests that states, local agencies, tribal communities, and fire control experts agree that the development and use of non-burning alternatives is desirable. However, identification, development, and use of these alternatives throughout the 15 Western states and tribal communities appears to be in the fundamental research stages. This fact, in combination with the lack in most states of formal requirements to implement non-burning alternatives, made identification and characterization of alternatives a difficult task. Over 20 different non-burning alternatives were identified in the following categories: 1. Leave residues in place either with or without infield residue treatment (e.g., cut, mulch, and drop in place; soil incorporation); 2. Improved management practices and scientific advancements in horticulture (e.g., genetic selection for disease/pest resistance or less fuel residual); 3. Alternative land use (i.e., conservation tillage; land conversion to nonagricultural use; and plant crops with residues that do not need to be burned); and 4. Residue collection and hauling for use offsite (e.g., haul to waste or landfill facility; haul to ethanol production facility). In order to determine the reasonableness, or feasibility, of implementing nonburning management alternatives, it is important to assess the impacts they have on agriculture, the environment, and other aspects of society. In this study, the impacts to non-burning alternatives were defined and criteria were established for assessing their effects and determining the feasibility of implementation. The range of impacts due to implementation of non-burning alternatives included: • Agronomic impacts—what happens to the agricultural production unit when an alternative is implemented, what the grower must do on the land and how does that change affect the productivity of the land; • Environmental impacts—what effect does the alternative have on visibility, air quality, water quality, wildlife, and other vegetation; Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-5 • Health and safety impacts—what hazards do alternatives present in the workplace when implemented; • Energy impacts—what are the impacts due to use of agricultural waste to produce energy; • Economic impacts—what is the cost of implementation considering the difference in cost of agricultural operations between the traditional burning operation and the new alternative approach; • Social and equity issues—beyond cost considerations, how are the growers, tribal communities, and other groups, affected by non-burning alternatives, and what is the equity of controlling some burning/crops and not others; and • Political issues—when promotion of non-burning alternatives tends to antagonize farmers and agricultural interest groups. Criteria were developed to evaluate each potential impact relative to a particular crop/alternative combination. A rating scheme using feasibility factors was developed that can be applied to the potential impacts relevant to each alternative being evaluated (e.g., 0 = No impact; 1 = Some impact/problem; 2 = Definite problem; and 3 = Major problem). High ratings indicate worse impacts relative to low ratings. This methodology is demonstrated in two case studies (for rice straw and grass seed) in order to show how to quantify some impacts (e.g., costeffectiveness) and apply feasibility factors. As an example, the results showed for rice straw that the average feasibility factors for the non-burning alternatives ranged from 1.1 (least negative impact) for alternatives such as Cut/Collect and Haul to Ethanol Production Facility, to 2.1 (most negative impact) for Land Conversion to Non-Agriculture. Accountability mechanisms are procedures used for tracking if, and to what extent, non-burning alternatives are used by local, state, tribal, or federal entities. In-place mechanisms are categorized and discussed. How the mechanisms support or promote the use of non-burning management alternatives is described in the implementation section (Section 7.0 of Volume II). The information gathered on accountability mechanisms came from state, county, local, and tribal environmental authorities representing all 15 Western states. The 17 different accountability mechanisms were identified in the following categories: a. Accountability initiated at the state or regional level (i.e., exemption or inclusion of agricultural burning in regulations); Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-6 b. Accountability at the state or local level that supports active regulation of agricultural burning activities (e.g., existing regulations or rules addressing agricultural burning activities); c. Accountability at a programmatic level that supports a formal approval and/or permitting process (e.g., smoke management programs); d. Mechanisms that encourage accountability at the local level and provide information for applying non-burning alternatives to current agricultural burning practices (e.g., fuel types burned, emissions tracking); and e. Mechanisms that facilitate and encourage the use of non-burning alternatives (e.g., pre-burn permits, financial assistance). The presence, or in some cases absence, of accountability mechanisms appears to be an indicator of whether non-burning alternatives will be used in the Western states. In general, for states with aggressive mandates to reduce agricultural burning such as Washington, Oregon, and California, many accountability mechanisms are in place. These states also have the largest number of non-burning alternatives in use. An important finding, which served to complicate the identification and interpretation of information on accountability mechanisms, was the inconsistent definition of “agricultural burning” in the 15 Western states. For example, in some areas irrigation ditch, fenceline, and weed or land clearing for range land improvement is included in regulations covering agricultural burning; in other areas these are not addressed. Non-statutory administrative barriers are those situations, circumstances, activities, or factors that serve to minimize, deter, or prevent the active use of non-burning alternatives. Eighteen barriers that fall into the following four categories were identified: • Economic challenges including labor costs; increased liability; disposal, storage, packaging, or transport costs; availability and/or willingness of investors to provide capital for new technologies or non-traditional methods; market return; crop yield, quality, and production rates; • Geographical limits due to climate or topography; • Political, cultural, or religious practices including activities that center around agriculture/harvest activities or tribal ceremonies; historical promises of land as a lure to relocate; • Public acceptance of a practice or program result (which may be closely tied to aesthetics); and Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-7 • Aesthetics including visual, olfactory, and auditory impacts, but possibly nuisance due to plant debris or dust in or near homes and businesses. A strategy for increasing the development and use of non-burning alternatives is described as applicable to the 15 Western states. A detailed discussion lays out the critical elements of an effective implementation plan, including items such as developing a strategic plan, allocating resources, and providing consistent program implementation. Based on the results of this study and the suggested guidelines, recommendations were made for developing an successful non-burning alternatives program at the state, local, and tribal level: 1. Air quality or environmental program entities should conduct a focused review to identify the nature and extent to which agricultural burning contributes to air quality problems in the state, or local, or tribal area. A starting point for this review could be the evaluation of agricultural burning activity such as that presented in Section 3.0 of Volume II. A key element of this review that should be included is a careful consideration of the definition of “agricultural burning”. This is important so that accurate comparisons can be made between other state, local or tribal programs. 2. If agricultural burning does not contribute significantly to local or statewide air quality problems which fall under the jurisdiction of the state, local or tribal entity, it is still recommended that the focused program assessment also take into account, to the greatest extent possible, the potential impacts agricultural burning may have on interstate regional air quality. 3. If agricultural burning is not found to be a significant source of air pollution for a given state, local region, tribal entity, or interstate region, it may not be necessary to continue with non-burning alternatives program development. 4. If agricultural burning is found to make a significant contribution to air quality problems on either a local, state, tribal community, or regional level, then the air quality or environmental agencies in authority in the affected areas and the areas contributing to the problems should work together to define solutions and develop non-burning alternatives programs. This will help to ensure success on a regional level. 5. If agricultural burning is found to be a significant source of air pollution for a given state, local region, tribal entity or interstate region, or if a given entity desires to more effectively implement non-burning alternatives, then an overall air quality review should be conducted to determine how to integrate agricultural burning. One goal of this review would be to determine which of the accountability mechanisms identified in Section Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-8 5.0 of Volume II are in place and how they are being used. Table 5-2 of Volume II can be used to determine specific accountability mechanisms and tailor the agricultural burning program. 6. For those states, local regions, and tribal entities desiring to more effectively address the use of non-burning alternatives in general, it is recommended that a list of effective and economically viable non-burning alternatives be developed (ideally including non-burning alternatives for use by crop, by season, and by region or area). Table 2-1 of Volume II (listing of non-burning alternatives by crop) can be used to identify specific alternatives. The criteria, methodology, and case studies described in Sections 3.0 and 4.0 of Volume II can be used to determine feasibility. 7. It is further recommended that a list, or in some cases multiple lists, of feasible non-burning alternatives should be maintained and updated periodically by the participating lead public or private entity. The list(s) should be made available using a variety of common effective communication strategies, methods, and technologies. 8. If non-burning alternatives have not been previously identified or have not been characterized for practical use an area, it is recommended that air quality and environmental entities work closely with university and agricultural extension scientists, affected agricultural community stakeholders, and interested members of the public to identify and characterize non-burning alternatives for specific use in their state or region. 9. WRAP member states should form a technical working group or task force to systematically identify and review the current use of non-burning alternatives and to make recommendations, if desired, on how and where the use of these non-burning alternatives may be improved or enhanced in other states, local regions, and tribal communities. 10. WRAP member states should work together to begin to address ancillary non-emission related program implementation issues, such as assisting the affected agricultural community and local business developers with postresidue removal product development, manufacturing, distribution, and marketing. Although this often falls outside the traditional charter of most state air quality and environmental programs, it does not fall outside the realm of services offered by other state agencies, boards and environmental departments. Some states have taken steps to assist in the research and development stages but their efforts have not extended to distribution and marketing. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-9 11. It is highly recommended that the results of this and any of the above mentioned program efforts be carried out in close coordination with a well defined stakeholder outreach, education and communication program. The agency roles and responsibilities associated with the identification, development, and implementation of non-burning alternatives are not clearly identified for any of the 15 Western states. It is recommended that as non-burning alternatives programs are reviewed and developed in the future, that the air quality or environmental agency responsible for developing the non-burning alternatives program (see Recommendation 4 above) be the agency responsible for monitoring and implementation. Regional approaches to defining responsibility for non-burning alternatives programs are also needed. This is in response to instances such as the relocation of grass seed companies within the last five years from Washington and Oregon to Wyoming where there are relatively less stringent air quality regulations. A well designed, closely coordinated, and consistently implemented stakeholder involvement, outreach, and communication effort is essential to the success of any non-burning alternatives program. Stakeholder involvement is not only an important way to encourage the use of non-burning alternatives, it will be key in developing future alternatives to infield burning of agricultural residues. A number of directions for further research and information development are recommended for the Western states and tribal communities in order to increase knowledge and encourage use of feasible non-burning management alternatives: • Better characterization of agricultural burning activities in the 15 Western states and tribal communities, including development of a consistent definition for “agricultural burning”; • More thorough collection and evaluation of agricultural burning activity data (e.g., daily acres burned by county, permits records, etc.) by regulatory agencies and stakeholders; • More thorough assessment of the air quality impacts from agricultural burning; • On-going investigation into effective non-burning alternatives; Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-10 • Effective inclusion of stakeholders in the identification and implementation of non-burning alternatives; and • Development of a well designed, consistently implemented stakeholder outreach, education, and communication programs that address local, state, tribal, and regional issues pertaining non-burning alternative program implementation. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 ES-11 1.0 INTRODUCTION Air emissions from burning agricultural residue, primarily consisting of fine particulate matter (CARB, 1996), can impact visibility in Class I areas located near burns, as well as those Class I areas located far away through regional transport. The Western Regional Air Partnership (WRAP) and its Fire Emissions Joint Forum (FEJF) sponsored this study to assess the non-burning alternatives to infield burning of agricultural residues, including their impacts on the environment, economy, health and safety, society, politics, and on the business and productivity of the agricultural industry. This study was performed under the Western Governors’ Association (WGA) Contract 30203-31 by Eastern Research Group, Inc. (ERG) and Enviro-Tech Communications (ETC). In the context of this study, “agricultural burning” is defined as the burning of organic crop residue consisting of field crops, wood, and leaves. Also, the burning of ditch banks adjacent to, or associated with, crop production are included in this evaluation of alternatives to agricultural burning. The geographical scope of the project includes the 15 Western states of Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, North Dakota, New Mexico, Nevada, Oregon, South Dakota, Utah, Washington, and Wyoming, as well as tribal lands in these states. The temporal scope of the data collected for this project was 1996, chosen to coincide with the WRAP base year emissions inventory effort. However, as described herein, it was necessary to use data from 1997 or other years in some cases when 1996 data were not available. This use of various years of data is an important limitation of the results of this project. There is no assurance that 1996 crop production acreage, for example, is indicative of 2001 acreage due to factors such as increasing urbanization and regulatory impacts. Also, crop rotations will impact year-to-year variations. 1.1 Study Objectives The objectives of this study are diverse. They are designed to facilitate development of crop production and agricultural burning activity data to support analysis of the alternatives to burning—which is the main objective of this study. Also, these data are used for Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 1-1 estimating emissions from agriculture burning under another project. The specific objectives of this study are as follows: 1. Identification of crops grown and the extent to which residue is disposed of through burning for the 15 Western states. The goal is to develop county-level estimates of acres harvested and acres (or residues) burned by crop for each of the 15 Western states. 2. Display of the crop and residue burned data using a geographical information system (GIS). The goal is to illustrate the level of crop production (acres harvested) and agricultural burning (acres or residues burned in tons) within the 15 Western states. The GIS maps provide a useful means to compare burning activity county-to-county, and to ensure that all available data are included and that gap-filling procedures provide accurate results. 3. Identification of potential alternatives to agricultural burning and characterization of their agronomic, environmental, health and safety, social, economic, and political impacts. A three-tiered approach to collecting information on the potential impacts to non-burning alternatives is employed. The three tiers include: (1) federal agencies such as the United State Department of Agriculture (USDA); (2) state agencies such as the University Agricultural Extension Services; and (3) private consortiums such as growers, producers, distributors, and information clearinghouses. 4. Development of criteria for selecting reasonable non-burning alternatives, cost-abatement curves (i.e., cost of alternative by crop), and examples of how to apply the criteria and cost-abatement curves (i.e., case studies) to evaluate alternatives. The goal is to develop a global methodology that can be used to assess the reasonableness of non-burning alternatives; thereby, minimizing the need for region-and crop-specific assessment when possible. 5. Identification of existing and potential accountability mechanisms for tracking if, and which, non-burning alternatives are used by federal, state, local, and tribal entities. The goal is to describe the specific mechanisms, mainly statutory and currently in-place (e.g., required burn permits, available financial incentives, agricultural burning exemptions, etc.), that support, promote, or hinder the implementation of non-burning alternatives. 6. Identification of existing and potential barriers to the use of non-burning alternatives including non-statutory barriers (e.g., public acceptance, cultural practices, etc.) and recommendations on how these can be overcome. This objective presents the “flip-side” of Objective 5 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 1-2 (accountability mechanisms) in order to understand the current limitations (i.e., non-regulatory) to new program development and implementation of non-burning alternatives. 7. 1.2 Development of a plan for implementing a non-burning program based on the analysis, findings, and recommendations developed in this study. The goal of the implementation plan is to give the WRAP/FEJF a “course of action” for implementing the recommendations developed under this project. The plan recommends agency responsibilities for implementation, and methods for disseminating information to stakeholders such as private landowners and others who will ultimately be responsible for implementing non-burning strategies. Data Collection Methodology Data were collected for this project based on a three-tiered approach. The first-tier sources were expected to have the highest quality data; the second-tier sources were expected to have readily available data; and, the third-tier sources were anticipated to provide additional crop-, state-, or regional-specific information pertaining to the identification and use of nonburning management alternatives. The primary data sources used in this project were as follows: • Tier 1 sources included the Farms Services Agency (FSA), Economic Research Service, National Agricultural Statistics Service (NASS), USDA within each state, several state Natural Resources Conservation Service (NRCS) offices, Federal Agricultural Research Centers; • Tier 2 sources included land grant universities, joint agency working groups and task forces (e.g., California Advisory Committee on Alternatives to Rice Straw Burning), State Agricultural Research Centers, University Agricultural Extension Services, divisions or departments of pesticide management; and • Tier 3 sources included various private consortiums, farmers, distributors, professional agricultural organizations, and information clearinghouses. Specific data sources are discussed as they pertain to crop production and residue burning, and identification and implementation of non-burning management practices. 1.3 Document Organization This document is organized into two volumes that address all of the objectives of the project. Earlier in-progress work was reported in three draft reports–the Task 1 Draft Report Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 1-3 which addressed Objectives 1, 2, and 3; the Task 2 and Task 3 Draft Report which addressed Objectives 4, 5, and (partially) 6; and, a Draft Final report which provided a complete initial analysis addressing all objectives. A detailed description of the content of the final Volume I and Volume II reports, and how the study objectives are addressed within each report is as follows: • Volume I: Agricultural Crop Production and Residue Burning in the Western United States:  Section 1.0 describes the project background and objectives. This section also explains the data collection methodology and organization and content of the Volume I and Volume II reports.  Section 2.0 describes the development and results of the crop production database (Objectives 1 and 2). This section quantifies the level of crop production in each of the 15 Western states, including the number of acres harvested by crop and county. The results are presented in various tables and maps. A detailed quality assurance/quality control (QA/QC) procedure ensures the accuracy of the results.  Section 3.0 describes the development and results of the agricultural burning database (Objectives 1 and 2). This section explains the data collection and compilation procedure used to compile the burn activity data (e.g., acres and residues [tons] burned by crop and county). Also, since only limited data on actual burn activity is available in the 15 Western states, a gap-filling procedure is employed to provide estimates in states/counties where burning is known to occur, but records on specific quantities are not tracked. The results are presented in various tables and maps.  Section 4.0 provides relevant conclusions and recommendations pertaining to the crop production and agricultural burning databases.  Section 5.0 lists the references used in the development of Volume I, including reports, journal articles, websites, and personal communication.  Appendix A contains a listing of the crop production data (i.e., acres harvested by crop, county, state).  Appendix B contains the crop production GIS maps for each state. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 1-4 •  Appendix C contains listings of the agricultural burning activity data (i.e., residues burned [tons] by crop, county, state).  Appendix D contains the agricultural burning activity GIS maps for each state.  Appendix E contains relevant tables from Volume II. Volume II: Non-Burning Management Alternatives and Implementation Plan Strategies:  Section 1.0 describes the project background and objectives. This section also explains the data collection methodology and organization and content of the Volume I and Volume II reports.  Section 2.0 describes the “universe” of non-burning alternatives which are in-use, or have been used in the past in the 15 Western states (Objective 3). The alternatives are listed in a table based on applicable crop and by category (i.e., leave in place, scientific improvements, alternative land use, cut or collection and haul).  Section 3.0 presents a methodology for assessing the impacts of non-burning alternatives (Objective 4). First, the different types of potential impacts are described (i.e., agronomic, environmental, health and safety, energy, economics, social and equity issues, and political). Criteria are presented to assist in evaluating the relative feasibility of implementing alternatives (e.g., agronomic–soil compression, increased water use; economic–not cost-effective, substantial farm stress, etc.). A table shows available sources of information and expected outcomes of the analysis for each of the impacts. A methodology that can be used to evaluate these impacts for various crops/alternatives is described.  Section 4.0 contains two case studies that illustrate the methodology developed to analyze the impacts of non-burning alternatives (Objective 4). Impacts of non-burning alternatives for two significant crops (rice and grass seed) are described. The criteria developed in Section 3.0 are used to evaluate the impacts. Cost curves display the economic impacts of implementing nonburning alternatives.  Section 5.0 presents the accountability mechanisms currently in place, or practiced in the past for implementing and tracking progress of alternatives to agricultural burning (Objective 5). A table lists the 17 mechanisms identified through an extensive research effort, along with the state/county where each mechanism is employed. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 1-5  Section 6.0 describes the non-statutory administrative barriers currently existing at the state level for each of the 15 Western states (Objective 6). Where they exist, county- and local-level barriers are discussed, along with barriers affecting tribal communities’ ability to implement non-burning alternatives.  Section 7.0 provides a summary of strategies for increasing the development and use of non-burning management alternatives on agricultural lands in the 15 Western states (Objective 7). A summary of the overall results of the entire project is presented along with conclusions and recommendations for future work. The contents for each section of a “state-specific” implementation plan are described, strategies to address stakeholder involvement are given, and suggestions for further research and information development are made.  Section 8.0 lists the references used in the development of Volume II, including reports, journal articles, websites, and personal communication.  Appendix A contains a detailed listing of the participants (i.e., name, affiliation, phone, fax, e-mail) contacted as part of the informal survey conducted for this study.  Appendix B gives a project case study (Alaska Agriculture Project, Delta Junction) that presents realistic information on the success and challenges encountered when developing and implementing a non-burning program in the West.  Appendix C contains relevant tables from Volume I. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 1-6 2.0 CROP PRODUCTION IN THE 15 WESTERN STATES Information on the amount, type, and location of crops grown in the 15 Western states forms the foundation for quantifying the amount of agricultural burning that occurs, and provides the basis for an analysis of the alternatives to burning and their impacts. Quantification of crop production is followed by identification and quantification of residues, or fuels subject to agricultural burning. This section describes the sources of information used to develop the database of crop production statistics, how they were compiled and checked, and the results of the compilation. 2.1 Sources of Crop Production Data The three sources of data used to compile a crop production database for the 15 Western states are described next. In general, all of these sources rely on surveys from a sample of farms and ranches within their geographical jurisdiction that result in county-level statistics. Crop production on tribal lands is included in these county-level statistics. 2.1.1 National Agricultural Statistics Service Database The NASS database was the first data source to be reviewed and compiled. The NASS is under the administrative jurisdiction of the USDA. The NASS annual county data for 1996 were downloaded from the NASS “Published Estimates Data Base” (PEDB) (NASS, 1996a). The county-level data in the PEDB are based on surveys from a sample of farms and ranches. Surveys are conducted in a variety of ways including mailed questionnaires, telephone interviews, face-to-face interviews, and field observations. The types of information that were obtained from the PEDB for use in the project included: • Commodity (crop type); • Year (1996); • State name; • County name; • State Federal Information Processing Standards (FIPS) code; Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-1 • District code (i.e., three-digit code for state-defined regions comprising multiple counties); • County FIPS code; • Harvested acres; • Planted acres; • Yield (quantity of crop produced per acre); • Yield units (e.g., BU = bushels, CWT = hundred weight, BAL = bales, etc.); • Production (Harvested acres x Yield); and • Production units (generally the same as yield units). Priority was given to collecting complete data for harvested acres. No attempt was made to search for and fill data gaps for planted acres, yield, and production since these data are not as relevant to this study as are harvested acres. The NASS data were chosen to provide the foundation for the crop database for several reasons. First, the NASS data were available for 1996 (target year for the database chosen to support WRAP emissions inventory efforts) and at the county level (level of spatial resolution desired for this study). Second, the NASS data covered the major crops grown in each state (i.e., wheat, barley, oats, rye, corn, rice, cotton, hay, and some vegetables and orchard crops). Third, the NASS data are available electronically thus making them easier to compile than other data sets that must be entered into electronic format from hard-copy reports. The NASS data provided a comprehensive “starting point” for the development of the crop production database. When crops were missing from the NASS data (i.e., crops known to be burned in certain states such as orchard crops in California and grasses and seeds in Oregon, Washington and Idaho), then other data were used to supplement the NASS data for these specific crops. These other data sources are described next. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-2 2.1.2 State Agricultural Statistics and Reports State agricultural statistics data and reports for 1996 were obtained from state links provided on the NASS website (NASS, 1996b). The state statistics and reports served as a secondary data source for identifying data on crops known to be burned which were not reported by NASS. Additional data for California were obtained from “1996 Agricultural Commissioners’ Data Report” (CDFA, 1997) and the reports link found on the California Agricultural Statistics Service (CASS) website (CASS, 1996). The state total production quantities for each crop from the state data were compared to the NASS state totals to help identify incorrect data or errors that may have occurred during data download or manipulation. (This quality assurance step is discussed in detail in Section 2.3.) 2.1.3 1997 Census of Agriculture The 1997 Census of Agriculture was reviewed (NASS, 1999). The NASS compiles the agricultural census every five years, with 1997 being the most recent year available. The census contains information on the market value of agricultural products sold, farms by market value, land use, selected crops harvested, and production expenses. The census data provided county-level crop data for crops not found in the PEDB or the state statistics publications; however, the census data were least preferred because they represented 1997 instead of 1996, which is the target year for this study. 2.2 Crop Production Data Compilation and Gap Filling Crop data were collected by downloading electronic files and obtaining hard-copy reports from the NASS and state agricultural services. The steps for collecting crop data, along with filling data gaps were as follows: 1. Crop data for 1996 were downloaded from the NASS website for all crops, at the county level, for each of the 15 states. 2. Microsoft Excel spreadsheets were developed from the NASS data for each state. 3. In some cases, crop totals were reported as “combined counties” totals. In these cases, the “combined counties” data were disaggregated to the county level according to the following procedure: Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-3 a. When a district contained some county-level data and a “combined counties” total, then the harvested/planted/production quantities were distributed over the counties with no production shown. However, if distribution would have resulted in 100 or fewer acres harvested for a given county, then the harvested/planted/production quantities were added to these totals for the county in the combined county’s district with the largest number of harvested acres. b. When a district contained only “combined counties” total (i.e., no county-level data were shown), then the harvested/planted/ production quantities were distributed evenly over all counties in the district. However, if distribution would have resulted in 100 or fewer acres harvested for a given county, then the quantities were distributed evenly over the two, three, or four counties adjacent to counties in neighboring districts having the largest number of harvested acres. c. Recalculated yields (e.g., bushel/acre, tons/acres) whenever production quantities were distributed. 4. Data from the individual states’ databases and/or hard-copy reports were compared to the NASS data to identify missing crops or incorrect values. 5. Data from the 1997 Agricultural Census were used in the absence of 1996 data to fill in data on missing crops for each state that may not have been collected by the NASS or states. 6. Although not technically considered a “harvested crop,” information on the acreage planted under the Conservation Reserve Program (CRP) was included. The CRP is a program that provides funding for planting permanent vegetation on idle, highly erodible farmland. The CRP is administered by the Commodity Credit Corporation through the FSA. It is supported by the NRCS, Cooperative State Research and Education Extension Service, state forestry agencies, and the local Soil and Water Conservation Districts. The CRP acres by state and county in 1996 were obtained from the FSA (FSA, 1996) and were added to the crop production database. 7. Crop residues known to have been burned since 1996 were identified from surveys made by the Western States Air Resources Council (WESTAR) and the WRAP/FEJF (WESTAR, 1999; WRAP, 2001a). 8. Spreadsheets were imported into a single Microsoft Access 1997 (hereafter Access) database for use with GIS software for mapping. (Details on the geographic database are described in Section 2.5.) Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-4 The following issue should be noted with regard to the individual wheat categories (i.e., all, winter, spring, and durum) and hay categories (i.e., all, alfalfa, and other) contained in the compiled database. The total of wheat/winter, wheat/spring, and wheat/durum acreage may not sum to the wheat/all acreage for a given county. This anomaly is due to the combined effect of two factors. First, some of the NASS data could not be reconciled on the county level. Second, data for “combined counties” were disaggregated to specific counties. The same situation applies to hay. Although the wheat and hay types may not sum to the wheat/all or hay/all at the county-level, they do sum at the district- and state-level. This issue was discussed with the WRAP/FEJF Project Manager and it was agreed that it was adequate to have reconciliation at the district-level (Jenkins, 2001). Table 2-1 shows the universe of crop production data collected for each of the 15 Western states. Table 2-2 shows the sources of the data used for each crop for each state according to the compilation procedure described above. 2.3 QA/QC Procedures The QA/QC procedure was developed based on the United States Environmental Protection Agency’s (U.S. EPA’s) QA/QC document (EIIP, 1997). The purpose of this procedure is to ensure that the following data quality objectives for the crop database for the 15 Western states are met: • To account for the major crops grown in each state, at the county level for 1996. Metric: collect county-level data for the top 10 crops (based on total acres harvested) in each state. For states with fewer than 10 crop types (e.g., Alaska and Hawaii), collect data for all of the crops comprising 90% of all acres harvested. • To account for all crops subject to agricultural burning in each state, at the county level for 1996. Metric: Collect county-level data for all crops that are subject to agricultural burning. • To account for acres harvested and production quantities for crops meeting data quantity objectives 1 and 2. Metric: Acres harvested quantities compare across alternative data sources within ±15% accuracy. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-5 Table 2-1. Crops Harvested During 1996/1997 in the 15 Western States Crop Types AK AZ Field Crops Barley a a Beans, Dry Edible Canola Corn for Grain a Corn for Silage a Cotton, Upland and American a Pima Flaxseed Hay, All a a Hay, Alfalfa a a Hay, All Other a a Hops Lentils Oats a Peas, Dry Edible Proso Millet Rice Rye Safflower Sorghum a Soybeans Wheat, All a Wheat, Durum a Wheat, Other Spring Wheat, Winter All a Orchard Crops Almond Apple a Apricot Avocado Cherry Citrus a Fig Filbert Grape a Kiwi Macadamia Nut Nectarine Olive Peach a Pear a Pecan Persimmon Pistachio Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 CA CO HI ID MT ND NM NV OR SD UT WA WY a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a 2-6 a a a a a a a Table 2-1. Continued Crop Types Plum and Prune Walnut Fruits and Vegetables Asparagus Blueberries Pineapple Other1 Grasses and Seeds Alfalfa, Seed KBG, Seed Other, Seed2 Other CRP Coffee Mint Peanuts Potatoes Sugarcane Sugarbeets Sunflowers AK AZ CA CO HI ID MT ND NM NV OR SD UT WA WY a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a a Sources: See Table 2-2 1 Fruits and vegetables “other” = cabbage, carrots, lettuce, tomatoes, green peas, sweet corn, snap beans, dry onions, melons 2 Grasses and Seeds “other” = bermuda, fescue, red clover, ryegrass CRP = Conservation Reserve Program KBG = Kentucky bluegrass Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-7 a Table 2-2. Sources of Data for Crops Harvested During 1996/1997 in the 15 Western States Crop Types AK AZ CA CO HI ID MT ND NM NV OR SD UT WA WY Field Crops Barley 1 1 1 1 1 1 1 1 1 1 1 1 1 Beans, Dry Edible 1 1 1 1 1 1 1 1 Canola 4 Corn for Grain 1 1 1 1 1 1 1 1 1 1 1 1 Corn for Silage 1 1 1 1 1 1 1 1 1 1 1 Cotton, Upland and 1 1 1 American Pima Flaxseed 1 1 Hay, All 4 1 4 1 1 1 1 1 1 1 1 1 1 1 1 Hay, Alfalfa 4 1 4 1 1 1 1 1 1 1 1 1 1 1 1 Hay, All Other 4 1 4 1 1 1 1 1 1 1 1 1 1 1 1 Hops 1 Lentils 4 Oats 1 1 1 1 1 1 1 1 1 1 1 Peas, Dry Edible 3 4 4 Proso Millet 4 4 Rice 1 Rye 1 1 Safflower 3 Sorghum 1 3 1 1 1 Soybeans 1 1 Wheat, All 1 1 1 1 1 1 1 1 1 1 1 1 1 Wheat, Durum 1 1 1 1 1 Wheat, Other Spring 1 1 1 1 1 1 1 1 1 1 1 Wheat, Winter All Orchard Crops Almond 2 Apple 4 3 4 4 4 2 Apricot 3 Avocado 3 Cherry 3 4 4 4 Citrus 4 3 Fig 3 Filbert 3 Grape 2 3 4 4 Kiwi 3 Macadamia Nut 2 Nectarine 3 Olive 3 Peach 4 3 4 4 4 Pear 4 3 4 4 Pecan 3 4 Persimmon 3 Pistachio 2 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-8 Table 2-2. Continued Crop Types AK AZ CA CO HI ID MT ND NM NV OR SD UT WA WY Plum and Prune 3 4 Walnut 2 4 Fruits and Vegetables Asparagus 3 4 Blueberries 4 Pineapple 2 Other 1 4 3 2 4 4 1 4 4 Grasses and Seeds Alfalfa, Seed 4 3 4 4 4 4 4 4 4 4 4 KBG, Seed 4 4 4 4 Other, Seed 4 3 4 4 4 4 4 4 4 4 Other CRP 5 5 5 5 5 5 5 5 5 5 Coffee 2 Mint 4 4 Peanuts 3 1 Potatoes 1 1 1 1 1 1 1 1 1 4 1 4 Sugarcane 1 Sugarbeets 1 1 1 1 1 1 1 1 Sunflowers 1 1 1 Data Sources: 1 = 1996 NASS Published Estimates Database (NASS, 1996a) 2 = State statistics database (NASS, 1996b) 3 = Other state data and reports (CASS, 1996; CDFA, 1997) 4 = 1997 Agricultural Census (NASS, 1999) 5 = Conservation Reserve Program (FSA, 1996) Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-9 The applicable functions of the types of QA/QC methods employed are shown in Table 2-3. The QA/QC methods shown on Table 2-3 were employed both before and after the crop production spreadsheets were converted into Access. A description of how these methods were used to evaluate the crop data are presented below. 2.3.1 Reality Checks: Compare Data to Standard Reference Value The crop data compiled from the 1996 NASS were compared to the 1996 data in the state agricultural statistics annual reports. None of the data for crops reported in NASS were more than ±15% different from state data; thus, no changes were made. For each state, Table 28 of the 1997 Agricultural Census (NASS, 1999) (i.e., “Specified Crops by Acres Harvested”) was used to rank the top 10 crops based on acres harvested during 1997. These data were compared to the NASS data to ensure that the top 10 crops for each state were consistent between 1996 and 1997. If any top 10 crops were missing, then data were obtained based on the following data sources (in order of preference): • State agricultural statistics reports for 1996; • Other references for 1996; and • 1997 Census of Agriculture. The WESTAR agricultural burning survey and FEJF agricultural burning survey (WESTAR, 1999; WRAP, 2001a) were reviewed to determine the types of crops burned since 1996. 2.3.2 Peer Review: Checklist or Written Comments by Reviewer Notes were kept on the data sources used to compile each state’s crop data, gap filling techniques, and corrected errors. Notes were made on hard copies of the draft crop data spreadsheets for future review. A complete listing of data sources used is shown on Table 2-2. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-10 Table 2-3. Summary of QA/QC Methods Used to Evaluate Crop Production Data Method Reality checks Peer Review Sample Calculations Computerized Checks Independent Audits Validation Ensure Ensure Ensure Validity Ensure Ensure Completeness Reasonableness of Data and Mathematical Accuracy of of Data of Data Assumptions Correctness Data ü ü ü ü ü ü ü ü ü ü ü ü ü ü ü ü ü ü Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-11 ü To ensure the completeness and reasonableness of the data collected (i.e., top 10 crops in each state and all crops that could potentially be burned), the database was distributed to members of the FEJF for review of their respective states. A “Peer Reviewers Checklist” was provided to facilitate consistent and useful comments from the reviewers. Checklists were completed and returned by state personnel from the states of Alaska, Arizona, California, Idaho, Oregon, Utah, and Wyoming. Some crop information for the states of Arizona (i.e., harvested acres for apples, citrus, cotton, grapes, hay, peaches, and pears) and Utah (i.e., harvested acres for apples, beans, cherries, peaches, and potatoes) were changed. 2.3.3 Sample Calculations: Replication of One Set of Calculations Generally, calculations related to the crop data were not performed; however, some simple calculations were performed to ensure mathematical correctness and accuracy of data. For example, county-level crop data were summed to ensure that county totals sum to district and state totals reported in the data sources. 2.3.4 Computerized Checks: Electronic Methods of Checking Completeness and consistency checks were performed on the crop data. These were conducted on specific data elements as follows: 2.3.5 • County and state names and FIPS codes were checked against those included in the GIS database to ensure consistency of spelling and codes; • Tables indexing crop names were developed and compared to ensure consistency in crop names among states; and • After spreadsheets were imported into one database, the totals for acres harvested and production quantity were summed to ensure these totals matched the “State Total” data for each crop by county. Independent Audits: Systematic Evaluation to Determine Quality The WRAP/FEJF Project Manager conducted an independent audit of the crop database in order to: • Evaluate the effectiveness of the technical and quality assurance procedures used to develop the data; Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-12 • Help ensure the completeness and accuracy of the data; • Determine whether data quality objectives were met; and • Determine the need for additional QA/QC measures. Based on the review by the WRAP/FEJF Project Manager, data were added for acres of land included in the Conservation Reserve Program in 1996 (FSA, 1996). 2.3.6 Extended Peer Review: Local Knowledge Validation of the crop data can be conducted in two ways: 1. The crop data could be compared to actual field observations. However, this is not a feasible exercise given the time and budget constraints of this study. 2. The knowledge possessed by many of the state representatives on the FEJF could be used in lieu of actual field observations to: a. Ensure the major crops are accounted for; b. Ensure the crops that could potentially be burned are accounted for; and c. Provide additional reality checks on the values of acres harvested, acres planted, production, and the location of the crops by county. The review shown in the second step–an extended peer review–was conducted by FEJF and states’ representatives. The changes resulting from comments received by the reviewers in Arizona and Utah are described above in Section 2.3.2. 2.4 Results of Compiled Crop Data Table 2-4 shows the number of acres harvested for the top 10 crops (i.e., largest number of harvested acres) within each of the states. The crops shown on Table 2-4 are grouped by the categories of “Cereals and Grains,” “Orchard Crops,” “Grasses and Seeds,” and “Other.” Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-13 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 Table 2-4. Summary of Crop Production of the Top 10 Crops Within the 15 Western States for 1996/1997 (Acres Harvested) 2-14 Crops AK AZ Grains and Hay Barley 6,900 54,000 Corn; for 40,000 Grain Corn; for Silage Hay; Alfalfa 3,801 160,000 Hay; All 20,222 19,000 Other Oats 700 Proso Millet Rice Sorghum 45,000 Wheat; All 178,000 Orchard Almonds Apples Citrus 38,823 Grapes Pecans Grasses and Seeds Seeds; Alfalfa Seeds; Other Other Fruits and 343 28,800 Vegetables Beans; Dry Edible Coffee Cotton; 314,000 Upland Cotton; 40,300 American Pima Lentils Macadamia Nuts Mint Peanuts Peas; Dry Edible Pineapple CA CO HI ID MT 92,000 890,000 730,000 1,150,000 15,000 275,000 90,000 68,000 39,000 944,056 754,717 860,000 650,000 1,000,000 280,000 1,700,000 900,000 50,000 ND 2,600,000 600,000 NM NV OR 5,000 150,000 37,000 84,000 380,000 UT 145,000 3,650,000 100,000 20,000 320,000 40,000 460,000 610,000 2,500,000 1,800,000 545,000 160,000 35,000 360,000 9,000 920,000 145,000 3,854,000 44,000 1,700,000 250,000 250,000 1,200,000 100,000 230,000 SD WA WY TOTAL 440,000 120,000 120,000 50,000 5,592,900 5,506,000 33,000 909,000 490,000 310,000 32,000 125,765 500,000 260,000 688,000 2,268,000 1,560,000 225,000 6,360,000 12,515,000 110,000 19,000 620,000 11,482,857 600,000 7,353,939 185,000 2,745,000 866,700 125,765 500,000 675,000 236,000 31,638,000 400,692 400,692 154,930 322,690 721,505 23,188 154,930 284,790 721,505 23,188 11,731 11,731 513,246 777,358 13,120 125,000 38,375 93,000 4,415 513,246 6,695 189,269 570,000 31,000 5,400 995,000 1,058,375 824,201 5,400 1,364,000 55,000 41,900 65,540 20,200 20,200 45,221 16,500 71,507 20,000 126,975 45,221 16,500 198,482 20,000 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 Table 2-4. Continued Crops Potatoes Soybeans Sugarbeets Sugarcane Sunflower Total AK 630 AZ CA CO HI TOTAL 642,629 845,000 2,670,000 3,515,000 184,000 57,500 56,800 298,300 42,900 42,900 107,000 1,165,000 690,000 1,962,000 32,596 917,923 6,341,118 5,467,765 101,620 4,399,507 10,271,500 21,575,000 946,063 527,145 2,831,467 16,134,000 1,069,895 4,737,174 1,778,800 76,918,791 Data Sources: 1996 NASS Published Estimates Data Base (NASS, 1996a) State statistics databases (NASS, 1996b) Other state data and reports (CASS, 1996; CDFA, 1997) 1997 Agricultural Census (NASS, 1999) ID 413,000 MT ND NM NV 6,999 OR 61,000 SD UT 4,200 WA 161,000 WY 2-15 These categories, which are different than those shown in Table 2-1, are used to facilitate development of fuel categories to be used in later analyses. Table A-1 in Appendix A shows state crop production data in terms of acres harvested for all crops for which data were collected. As Table 2-4 shows, the greatest production of crops in terms of acres harvested is in the “cereals and grains” category, with hay and wheat varieties comprising the most acres. Although orchard crops and grasses and seeds make up a relatively smaller portion of the top 10 crops harvested, these are important crops to consider with regard to non-burning alternatives since their residues are widely burned in the West. The states of North Dakota, South Dakota, and Montana have the most acres harvested, primarily wheat. Although California ranks fourth in terms of top 10 crops harvested, it is an important state with regard to the individual top 10 crops harvested because their residues are widely burned (e.g., residues from orchard crops, especially almonds and walnuts). The procedure used to compile the crop production database resulted in a comprehensive set of data depicting agricultural production during 1996/1997. For purposes of facilitating analysis of burn activity and alternatives to burning, this database is felt to be the best available. Also, having undergone qualitative and quantitative review, these data are also supported by the state agencies responsible for compiling and using these data. A limitation of these data is that they represent a combination of 1996 and 1997 activity (although for the most part, they are for 1996), depending on the state and crop grown; thus, these data should not be used to compare activity between states for the same crops. There is no assurance that 1996 crop production is similar to 1997 crop production within a given county due to factors such as increasing urbanization and crop rotation. 2.5 Development of the Geographic Database The first step in the development of the geographic database was to import the crop production data. As noted in Section 2.2, Excel spreadsheets containing county-level crop production data (based on data from NASS and state agricultural services) were imported into Access. Before they were imported, a check was performed to ensure that all the Excel spreadsheets had the same fields (those listed in Section 2.1), as well as a field indicating whether data had been disaggregated from a district total or combined-counties total to Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-16 individual counties. After the files were imported, a check was performed to ensure that the number of records present in the Access database was equal to the number of records in the Excel spreadsheets. A field called FIPS was then added to each record in the database, representing a concatenation of the two-digit state FIPS code and the three-digit county FIPS code. The reason for this is because the ArcView GIS software associates each state and county with a 5-digit FIPS code. The addition of the 5-digit FIPS code to the Access database allows each record in the database to be linked to ArcView geographic data files representing the locations of each state and county. Then an Access query was used to compare the state name, county name, and 5-digit FIPS codes used in ArcView to the state name, county name, and 5-digit FIPS codes present in the Access database. Discrepancies were corrected using the U.S. EPA’s master list of FIPS codes (USEPA, 2001a). Additional QA/QC procedures that were performed included the following: • Access queries were used to sum the total acres planted, acres harvested, and production for an individual crop in all the counties within a state and to compare this sum to the record in the database showing the state total acres planted, acres harvested, and production. In cases where discrepancies arose, they were corrected by referring to the source data. • Access queries were used to verify that only one record for each crop type in each individual county was present in the database. In cases where discrepancies arose, they were rectified based on consulting the source data. Printouts from the final crop production database are included in Appendix A. In order to develop maps that would show the top five crops in each state and county, Access was programmed to generate a “GIS crop production summary table” that listed each state and county down the rows and all the available crops for which data was collected across the columns, filling the cells with the number of acres harvested for the appropriate crop in the appropriate county (or state as a whole) with the data present in the Access database. A version of this table (the “GIS Top 5 table”) was created that showed only the acres harvested for the Top 5 crops grown in a county (or state as a whole), leaving the remaining cells blank. This Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-17 second table was imported into ArcView and linked to the program’s geographic data files representing the locations of each state and county based on matching 5-digit FIPS codes. A map showing the top 5 crops in all 15 Western states is included as Figure 2-1. This map uses the “GIS Top 5 table” to generate legends that show the relative number of acres harvested for each state (or county). Also, Appendix A contains maps of each state indicating the number of total acres harvested on the county level. The GIS tables were submitted to the WRAP/FEJF at the close of the project. These tables can be used to ArcView to make changes to the maps as necessary in the future. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-18 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 2-19 3.0 AGRICULTURAL BURNING ACTIVITY IN THE 15 WESTERN STATES An important goal of this project is the development of an agricultural burning database for the 15 Western states. This database provides information on crop residues (total generated and total burned) by county for two purposes: 1. To identify the extent to which agricultural burning occurs, types of crops burned, and the location (i.e., county, state) and time (i.e., month, and day if feasible) when burning occurs in order to facilitate the evaluation of alternatives to burning and their impacts; and 2. To provide county-level (and sub-county level if feasible) data on residue burned by crop for estimating emissions from agricultural burning in the 15 Western states. This section describes the sources of information used to develop the agricultural burning database, and how they were compiled, gap filled, and checked. 3.1 Sources of Agricultural Burning Data The types of data needed to characterize agricultural burning include amount of residue burned and/or number of acres burned, by crop. For purposes of assessing burning and understanding the impacts of alternatives, monthly activity at the county and crop level are needed; however, to assist with emissions inventory development, daily activity and locationspecific data are best. For example, information regarding the day of the burn is most desirable, but the season and/or month of the burn is sufficient. Also, information regarding the address or section (township and range) is best, but county location is sufficient. Obtaining agricultural burning data presented a significant challenge. First, only a few states had organized smoke management programs that track actual burn activity. Some states provided agricultural burning activity data based on information collected for their emissions inventories. Also, anecdotal information was available for a few other states in the form of responses to surveys conducted by the WESTAR and the WRAP/FEJF (WESTAR, 1999; WRAP, 2001a), and an informal survey conducted by the investigators for this nonburning management alternatives project. Comments received during the review of the draft Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-1 database also resulted in new and/or revised estimates of agricultural burning activity in the Western states. As mentioned above, documented agricultural burning activity data exist for only a portion of the 15-state domain, although agricultural burning is known to occur in nearly every state. Thus, it was necessary to devise a data gap filling procedure to provide the necessary data to complete the database. The results of the data compilation and the gap filling techniques are discussed next. 3.2 Agricultural Burning Data Compilation and Gap Filling Agricultural burning data were compiled for the 15 Western states using several steps: • First, actual burn data statistics were obtained as available (i.e., data from states and/or counties that compiled statistics on agricultural burning activity occurring in their jurisdiction). • Second, a draft database was designed whereby the actual data were compiled into a consistent format. Gaps were “filled” to provide missing information. • Third, the draft database was reviewed by the WRAP/FEJF members. From each state, including representatives from NRCS and other statelevel and county-level agricultural, air quality, and fire departments. • Based on comments received, changes were made and the database was finalized. This final database of agricultural burning activity data was provided to the WRAP/FEJF emissions inventory contractor for additional review and incorporation into the emissions inventory being performed under a separate project. All of these steps are described in detail below. 3.2.1 Sources of Agricultural Burning Data Table 3-1 shows the sources and general characteristics of data used to develop the agricultural burning activity database for the Western states. The burning activity data sets generally fall into three categories: data based on permits issued or other mechanisms for determining actual burn activity; data used to develop emissions inventory estimates; and Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-2 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 Table 3-1. Summary of Agricultural Burning Data Collected for the Western States Data Set AZ 1 Type of Data Temporal Resolution Residue Acres Burned Burned (Tons) Year Month Day 2000! ! ! 2001 Spatial Resolution SubState County County Level Level Level Sources(s) Graves, 2002 ! Foster, 2002 ! ! Johnson, 2001 Gabrielson, 2002 Conrad, 2002 Tickes, 2002 ICAPCD, 2001 Relevant Counties (Crops) Graham, Cochise (various) Yuma (citrus, ditches/weeds, jojoba beans) Yuma (citrus) Pinal (ditches/weeds) Pima (ditches/weeds) Yuma (wheat, bermuda) Imperial (various) ! WRAP, 2001a Lake (various) ! Fife, 2002 ! SCAQMD, 2001 Sacramento Valley: Butte, Glenn, Colusa, Placer, Sacramento, Shasta, Sutter, Tehama, Yolo, Solano, Yuba (various) South Coast Air Basin: San Bernardino, Riverside (various) San Joaquin Valley Air Basin: Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus, Tulare, Kern (various) Mesa (wheat) All (sugarcane) All (pineapple) All (various) CA_Imperial ! 1996 ! CA_Lake ! 1997 ! CA_Sac_Valley ! 1996 ! CA_South_Coast ! ! 1996 ! CA_SJV ! ! 1999 ! CO HI ! ! Avg 1996 ! ! ! ! ! ID ! 1996 ! ! ! 1996 ! ! ! 3-3 MT ! ! ! SJVUAPCD, 2001 Sharkoff, 2002 WESTAR, 1999 MacCluer, 2002 WESTAR, 1999; IDEQ, 2001; Riley, 2002 Coeffield, 2002 All (irrigated wheat) Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 Table 3-1. Continued Data Set ND 1 Type of Data Temporal Resolution Residue Acres Burned Burned (Tons) Year Month Day Avg ! NM NV ! ! OR 3-4 SD UT ! WA ! WY ! ! Spatial Resolution SubState County County Level Level Level Sources(s) Relevant Counties (Crops) WRAP, 2001a; McDonald, Pembina, Cavalier, Towner, ! ! 2002; Shaver, 2002 Ramsey, Walsh, Nelson, Grand Forks, Benson, Eddy, Foster, Stutsman, Griggs, Steele, Traill, Barnes, Cass (wheat) WRAP, 2001a; Shaver, All (wheat stubble); Curry ! ! 2002 (wheat stubble) Sergent, 2002 All (unspecified) ! ! Avg ! 1998 ! 1996 ! ! ! Avg ! ! ! 1996 ! ! ! 1999 ! ! ! 1996 ! ! ! ! WRAP, 2001a; ODEQ, 2001 WESTAR, 1999; Stover, 2002; Shaver, 2002 WESTAR, 1999; UDEQ, 2001; Bernards, 2002; Goodrich, 2002 WDOE, 2001a; WDOE, 2001b WESTAR, 1999; Potter, 2002 Grover, 1998 Cunningham, 1998 Spiering, 1998; Shaver, 2002 All (various) All (barley, winter wheat) All (various) All (various) All (various) Big Horn, Hot Springs, Park (alfalfa seeds) Fremont (barley) Park (alfalfa and grass seed) !Data are available. Blanks indicate that data are not available. 1 ”Avg” year means the specific year of burning could not be determined from the information provided. Months of burning for most states were determined as part of an informal survey conducted by Enviro-Tech Communications. See Appendix E (Tables 5-1 and 5-1a) for a summary of results from that survey. See Volume II for more details. information obtained from informal telephone interviews and during the draft database review process. Some data sets were developed based on documentation of actual burning that occurred as tracked by permit records for California (San Joaquin Valley, Imperial County, Sacramento Valley, and South Coast Air Basin), Arizona, and Washington. Other data sets were based on county-level data used to develop emissions inventories for Idaho and Oregon. Data sets that were developed using information obtained from surveys (WESTAR, 1999; WRAP, 2001a) and interviews conducted under this project include: CA_Lake (Lake County, only), HI, and WY. Data sets that were developed from information obtained during the peer review of the draft agricultural burning database prepared under this project include CO, MT, NV, and UT. Data sets developed using gap filling techniques supplemented with anecdotal information obtained during peer review include ND, NM, and SD. The timeframes for the burn data vary from 1996 only, to data for 1996 through 2001. Data for 1996 were preferred because that is the year of the crop production data and the WRAP’s base year emissions inventory. However, in order to provide data for as large of a geographic area as possible, it was necessary to use other years if 1996 data did not exist or were known to be largely incomplete compared to later years. For example, based on conversations with SJVUAPCD it was determined that although 1996 data are available in the CA_SJV data set, 1999 data are much preferred and more complete than the 1996 data due to improvements in data collection and management procedures. In California, the magnitude of agricultural burning appears to have been fairly constant during the years 1996-2000 based on the data sets reporting multiple years. Therefore, mixing years of burn data should not introduce significant error into the resulting emissions calculations. Also, officials in Washington stated that the data for 1999 are probably more indicative of 1996 burn activity contained in their database due to incomplete data in the database for 1996. Even though the survey of burning activity by tribes in the WRAP region provided insight into the types of burning that occurs on tribal lands (i.e., range, agricultural, and wildland), the survey does not provide sufficient detail to allow quantification of burning in terms of acres or residue. The survey results show that of the 76 tribes that conduct prescribed burning, only 45 conduct agricultural burning (WRAP, 2001b). Of the 45 respondents/ Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-5 reservations conducting agricultural burning, the survey categorizes the reasons for burning as weed abatement and ditch and canal clearing. Only one survey respondent mentioned a crop type (i.e., “stubble”). Based on this survey alone, it might be concluded that agricultural burning within reservation boundaries is relatively insignificant compared to agricultural burning outside of reservation boundaries. In Northern Idaho, for example, state officials report that more acres of Kentucky bluegrass are burned within reservation boundaries than are burned outside of reservation boundaries (Riley, 2001). 3.2.2 Database Development A database was designed to provide a consistent format for compiling the existing burning data (i.e., as shown on Table 3-1). Table 3-2 shows the data fields in the agricultural burning database. Database tables were developed and populated with data from the data sets listed in Table 3-1, and data contained in the crop database. Crop data were used to determine county-level burn activity on the basis of crop activity for data sets that contained only state level data (explained below). Lookup tables were developed to appropriately link crop names (from the crop database) to commodity names (in the burn data sets). Several other steps were applied to the data sets shown in Table 3-1 as they were imported into the new database to ensure ensure consistency and maintain the correct level of spatial and temporal resolution. These steps were: • For burn activity data reported on a statewide level (e.g., sugarcane in Hawaii, wheat in Montana), the acres burned were assigned to counties based on the acres harvested of those crops burned. For example, for Montana it was estimated that 1% of the irrigated wheat stubble is burned (Coeffield, 2002). Therefore, these acres burned were distributed over the counties where irrigated wheat was harvested based on the percentage of the harvested acres within each county. • For burn activity data reported for aggregated crops (e.g., cereal grains, orchard prunings, etc.), the acres burned were assigned to counties based on the acres harvested of those crops from the crop database that comprised the aggregated category. For example, the CA_South_Coast (Riverside County) data set included acres burned of “orchards.” These residues were linked to the crop data for the orchard crops grown in Riverside County (i.e., almonds, apples, cherries, persimmons, pistachios). Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-6 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 Table 3-2. Description of the Agricultural Burning Database for the Western States 3-7 COMM YR_HAR STATE StFips COUNTY CoFips AH RL RES A_BURN Year Month Day 1 R_BURN 2 Avg_State 3 Avg_Crop Database Fields Commodity or crop Year harvested State name State FIPS code County name County FIPS code Acres harvested Residue loading Amount of residue Acres burned Year burned Month burned Day burned Residue burned State average % burned by crop Crop average % burned Units/ Format Text YY Text ## Text ### Acres Tons/Acre Tons Acres YY MM DD Tons % % Data Source or Calculation Crop database Crop database Crop database Crop database Crop database Crop database Crop database AP-42, ARB, other AH x RL Actual data Actual data Actual data CA_SJV and WA, only RL x A_BURN A_BURN/AH Average of all Avg_State by crop Notes: 1 R_BURN (residue burned) is reported directly by Oregon; thus, this value is taken as reported and is not calculated according to this procedure for Oregon. 2 Avg_State is calculated based on actual and anecdotal information for the data sets shown in Table 3-1. Each average is weighted according to the total acres of each crop harvested in each county within each data set. In some cases, this average represents a “data set” average if the data set contains information for areas not comprising an entire state (e.g., CA_SJV). 3 Avg_Crop is calculated as a weighted average of the Avg_State amounts from each data set. Each average is weighted according to the total acres of each crop harvested within the geographical area covered by each data set. Italics indicate the data value is calculated. ## = Indicates 2-digit numerical value ### = Indicates 3-digit numerical value Total orchard residue was disaggregated based on the percentage that each crop represented of the total acres harvested of these orchard crops in Riverside County. • For burn activity data reported on an annual basis, anecdotal information was used to assign burning activity to specific months. For example, burning of grass seeds and grain field stubble occurs in the months of July, August, and September, in Oregon (WRAP, 2001a). Therefore, the residues burned were distributed (evenly) over these three months. After all the data sets had been imported and linked with the appropriate data from the crop database, individual tables for each geographic area were imported into Excel spreadsheets for additional processing (e.g., calculating additional averages to be used in gap filling areas where burn data do not exist) and quality checking. 3.2.3 Residue Loading Factors Another important type of data that was used to estimate quantities of residues burned was residue loading factors. Residue loading (RL) factors were matched to specific crops, and residues were calculated (i.e., acres harvested x RL = residue). A summary of these factors, which are based on various studies and research into the yields of residue of specific crops, is shown in Table 3-3. The factors shown on Table 3-3 come from several sources including AP42 (USEPA, 1995), CARB (CARB, 2000), Jenkins and Sumner (1986), and others. As Table 3-3 shows, most of the RL factors chosen for this study are cropspecific, and do not necessarily take into account the differences in yield (which can determine amount of residue generated) based on geographic variability. Also, differences between irrigated (relatively high yield) as compared to non-irrigated land (relatively low yield) are important; these are not evident in the crop-based RL factors shown on Table 3-3. For example, dryland farmers in eastern New Mexico yield 17 to 25 bushels/acre of wheat; in parts of Washington the yield is 90 to 125 bushels/acre. This can make a very big difference in the residues generated (Shaver, 2002). In the case of wheat yields in Colorado, Table 3-3 shows the difference between a Colorado-specific RL (i.e., 4.0 tons/acre for irrigated, spring wheat) as compared to the AP-42 RL (i.e., 1.9 tons/acre) and the New Mexico RL (i.e., 1.5 tons/acre). The Colorado RL was based Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-8 Table 3-3. Residue Loading Factors for Crops Burned in the Western States Fuel Type Grains and Hay Barley Corn, Grain Hay, Alfalfa Hay, All Other Hops Oats Rice Rye Sorghum Wheat Wheat (spring, irrigated) Wheat Orchard Almond Apple Apple Apricot Avocado Cherry Citrus Date Fig Grape Kiwi Nectarine Olive Peach Pear Pecan Persimmon Pistachio Plum and Prune Pomegranate Quince Walnut Orchard Pruning, Unspec. Orchard Removal, Unspec. Grasses and Seeds Seeds, Alfalfa Seeds, KBG Seeds, Other, Unspec. Bermuda States Where Crops are Burned1 Residue Loading (tons/acre)2 CA, ID, OR, SD, UT, WA, WY AZ, CA, OR, WA CA, WA CA, WA WA CA, OR, WA CA CA CA AZ, CA, ID, MT, ND, OR, SD, UT, WA CO NM 1.7 4.2 0.8 0.8 1.9 1.6 3.0 1.9 2.9 1.9 4.0 1.5 CA AZ, WA CA CA CA CA, WA AZ, CA CA CA CA, WA CA CA CA CA, WA CA, WA AZ, CA CA AZ, CA CA, WA CA CA CA AZ, CA, WA CA, UT, WA 1.0 2.3 0.8-1.0 1.8 1.5 1.0 1.0 1.7 1.7 2.5 1.7 1.7 1.7 2.5 2.6 1.7 1.7 1.7 1.2 1.7 1.7 1.2 1.7 15.0 ID, WA, WY ID, WA AZ, CA, WA, WY AZ, CA Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 0.8 2.0 2.0 2.0 3-9 Comments/Sources of Residue Loading Wheat RL Wheat RL Sharkoff, 2002 (CO only) Shaver, 2002 (NM only) Beyer, 20023 (CA only) Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Orchard Pruning, Unspecified RL Jenkins, 2001 IDEQ, 2001 IDEQ, 2001 Assume same as KBG Assume same as KBG Table 3-3. Continued States Where Crops are Burned1 CA, OR Residue Loading Comments/Sources (tons/acre)2 of Residue Loading 2.0 Assume same as KBG Fuel Type Grasses, Unspec. Fruits and Vegetables Asparagus Beans, Dry Edible Berries Canola Mint Other fruits and vegetables CA, WA CA, WA CA, WA WA ID CA, WA 1.5 2.5 1.7 1.3 0.5 1.5 Peanuts Peas, Dry Edible Pineapple Safflower Sugarcane Vegetables, Unspec. CA CA, WA HI CA HI CA 1.2 2.5 Undetermined 1.3 14.0 1.5 Other Agricultural Related Fuels CRP WA 2.6 Ditches, fence line Ditches, fence line Ditches, fence line 1.6 3.2 0.75 CRP KBG RL Unspec. = = = = Safflower RL IDEQ, 2001 Jenkins and Sumner, 1986 (average of all vegetables) Potatoes RL AZ CA, ID, WY UT Midpoint of AP-42 RLs Jenkins and Sumner, 1986 (average of all vegetables) Midpoint of AP-42 RL for grasslands Gabrielson, 2002 (AZ only) Weeds, Unspecified RL Goodrich, 2002 (UT only) Conservation Reserve Program Kentucky bluegrass Residue loading Unspecified Sources: 1 Table 3-1 summarized for sources of information relating to burning of specific crop residues in states. 2 3 AP-42 (USEPA, 1995) except where otherwise noted. This RL was not obtained in time to be included in the calculation of residues burned for CA as reported in the final database. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-10 on an estimated yield of 110 to120 bushels/acre and an estimated straw (residue) of 70 lbs/bushel. This results in residue loading of 4.0 tons/acre (Sharkoff, 2002). Some USDA NRCS offices have compiled location-specific crop yields and average residue production factors that can be used to estimate crop residues for specific geographic areas. Although it was not feasible to conduct this level of research for this study, this type of work could be done to make improvements to the agricultural burning activity database in the future. 3.2.4 Percent Burned By Crop The average percentage of acres burned (of total acres harvested) for wheat and barley was calculated using data for counties and states where burning actually occurred (i.e., 5.2% and 8.0%, respectively). These averages were used to estimate the residues burned in the states/counties where burning of these crops was known to occur, but for which no data were available. The states/counties to which these “gap filling” averages were initially applied within the draft agricultural burning database, included Arizona (Pinal county, only), Colorado, Montana, North Dakota, New Mexico, Nevada (all counties excluding Pershing), and South Dakota. However, based on the information obtained during peer review of the draft database, it was possible to replace most of the gap filled data with information provided by the USDA NRCS and other organizations. Only North Dakota, New Mexico, and South Dakota remain with gap filled data. Also, overall state-level averages were calculated based on total acres burned divided by total acres harvested by crop for each state. Using the state-level percentage acres burned, an overall crop average was calculated for most crops in the agricultural burning database and compared to values provided in a 1997 study by the USDA Air Quality Task Force (AQTF) (USDA, 1997). These averages are shown in Table 3-4. (Acres harvested for Nevada is not included in any average calculation because the burn data were not reported for specific crops). For wheat and barley, the gap filling averages (i.e., 5.2% and 8.0%, respectively) are larger than the overall state-level averages (i.e., 4.2% and 2.3%, respectively) because the state-level averages are based on state-level acres harvested as compared to the gap filling averages which are based on applicable county-level acres harvested. In this manner, the effect Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-11 Table 3-4. Average Percentage of Acres Harvested that are Burned for Selected Crops in the Western United States1 Crop Wheat Rice Corn Barley Sugarcane Orchards (Trees, Bushes, Vines) Grasses and Seeds CRP Acres Harvested 31,619,000 500,000 5,766,000 5,696,900 42,900 2,497,767 899,976 2 286,174 Acres Burned 905,756 254,706 10,668 137,872 30,000 530,100 394,077 28,917 Overall Average Percentage of Acres Burned 2.9% 50.9% 0.2% 2.4% 69.9% 21.2% 43.8% 10.1% Notes: 1 Acres harvested and burned do not include Nevada because burning in that state was not identified for specific crops . 2 Value represents number of acres in the Conservation Reserve Program (CRP). Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-12 of any non-reported burning is not incorporated into the gap filling averages. Spreadsheets containing the data used to calculate both averages are located in Appendix C. 3.2.5 Comparison to USDA Air Quality Task Force Study A comparison was made between the results shown on Table 3-4 and estimated values from a study sponsored by the USDA AQTF (USDA, 1997). The USDA AQTF study provides information on the extent of burning on croplands in the U.S. (plus information on wild fires and prescribed burning). The USDA AQTF document gives percentage of cropland burned by crop for 1992, and estimates quantities for 1997. A comparison of the USDA AQTF findings to the results shown on Table 3-4 is presented below: • Sugarcane:  The USDA AQTF report indicates that 100% of sugarcane acres in Hawaii were burned during 1997.  Table 3-4 shows approximately 70% of sugarcane acres in Hawaii were burned (based on 1996 data). Differences are likely due to different years of data and methods used to compile results. • Orchard Crops (fruits, nuts, grapes, berries, citrus):  The USDA AQTF report indicates that 5% of these orchards were burned in the U.S. during 1997.  Table 3-4 shows that approximately 21% of orchards were burned in the Western states (based on a combination of data from 19961999). Differences are likely due to different years of data and geographical coverage (i.e., entire U.S. as compared to Western states). • Rice:  The USDA AQTF report indicates that 25% of rice acres were burned in California during 1997, and 19% were burned for the total U.S.  Table 3-4 shows that approximately 51% of rice acres were burned in 1996 (entirely in the Sacramento Valley). Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-13 Differences are likely due to different years of data. Note that rice straw burning phase-down goals limited burning to 200,000 acres per year for three years starting September 1998 (Senate Bill 218, Statutes of 1997, Chapter 745, Section 2; California Health and Safety Code, Section 41865). • Small Grains:  The USDA AQTF report indicates that 15% of grain acres were burned in the Pacific Northwest during 1997, and 10% were burned in the rest of the U.S.  Table 3-4 shows that approximately 3% of wheat and barley were burned in the Western states. The state-level averages located in Appendix C show that the state average of wheat burned was 14% in Oregon (1996), 12.7% in Idaho (1996), and 6.4% in Washington (1999). The amount of wheat and barley burned are comparable between the studies. The Oregon and Idaho averages for 1996 (Appendix C) are comparable to the 1997 projection by the USDA AQTF for the Pacific Northwest. The Washington 1999 percentage is more than 50% lower than the USDA AQTF percentage which might indicate less wheat stubble burning in 1999 as compared to 1997. The overall averages for wheat (2.9%) and barley (2.4%) are significantly lower than the USDA AQTF estimate. The relatively low averages for wheat and barley are significantly impacted by burning activity in Colorado, Montana, North Dakota, and South Dakota. The number of estimated (or gap filled) acres burned in these states are fairly small compared to acres harvested. • Grass Seed:  The USDA AQTF report indicates the following percentage of fields burned (no year is given): − Washington, 0%. − Oregon, 50%. − Idaho, 100%. − Rest of U.S., 50%.  Table 3-4 shows that approximately 44% of grass seed acres are burned in the study domain. Respective percentages for Idaho, Oregon, and Washington are 72%, 53%, and 5% (Appendix C). The relative amounts for these states are comparable between the studies. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-14 3.3 QA/QC Procedure A QA/QC procedure was developed for the agricultural burning data to ensure that the following data quality objectives were achieved: • To account for all crop residues that were actually burned within states in the WRAP region based on actual burn data compiled by state/county agencies at the county level for 1996 or other years (1997-2000). Metric: Collect available county-level data for all crops that are subject to agricultural burning that represent at least 90% of the data available. • Develop a procedure to estimate crop residues burned within states in the WRAP region for which data do not exist (i.e., gap filling). Metric: Estimates of crop residues burned compare to estimate by state peer reviewers within ±25% accuracy. It should be reiterated that the baseline data available were for different years (e.g., CA_SJV for 1999, ID for 1996, etc.); thus, the various amounts of acres and/or residues burned, and the averages calculated from these acres and/or residues should not be compared. The use of crop data from one year and burning data for a different year (e.g., CA crop data for 1996 and CA_SJV burn data for 1999, etc.) introduces error into the resulting calculation of average percentage burned. Furthermore, there is no assurance that 1996 crop production reflects acreage subject to burning due to such factors as increased urbanization and regulation, and crop rotation. The QA/QC methods used to evaluate the agricultural burning data, as they were provided by the various agencies and used in this analysis to provide an estimate of the extent of agricultural burning in the 15 Western states, is described next. 3.3.1 Reality Checks: Compare Data to Standard Reference Value The resulting values of acres burned, residues generated, acres and/or residues burned from each of the source data sets were compared against the values in the spreadsheets generated from the database. Total acres or residues for the entire dataset were compared, and discrepancies were corrected in the spreadsheets and database when found. Random checks were done to compare specific county values in the source data sets to the values in the spreadsheets for residue, acres and/or residue burned, and discrepancies were corrected in the spreadsheets and database when found. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-15 3.3.2 Extended Peer Review by FEJF and Other Stakeholders The draft agricultural burning activity database was submitted to the WRAP/FEJF and other stakeholders on February 11, 2002, for a detailed review of methods, ancillary data (e.g., RL factors), and results. The database was actually converted into separate spreadsheets for each state to facilitate this review and make it easier for reviewers to provide comments. As a result of this extended review, extensive comments were received from the following stakeholders and incorporated into the final database, and this final report, as appropriate: 3.3.3 • USDA NRCS in the states of California, Colorado, North Dakota, New Mexico, Nevada, South Dakota, Utah, and Wyoming (Shaver, 2002; Beyer, 2002; Goodrich, 2002; Sharkoff, 2002); • State, county, and local air agencies and fire departments in Arizona, Idaho, Montana, North Dakota, Nevada, South Dakota, Utah, and Wyoming (Tickes, 2002; Johnson, 2002; Graves, 2002; Foster, 2002; Conrad, 2002; Gabrielson, 2002; Coeffield, 2002; McDonald, 2002; Sergent, 2002; Stover, 2002; Bernards, 2002; Grover, 1998; Cunningham, 1998; Spierling, 1998); and • Agricultural business in Hawaii (MacCluer, 2002). Sample Calculations and Computerized Checks Some sample calculations (by hand and using computer software) were performed to ensure mathematical correctness and accuracy of the database and resulting spreadsheets. For example, acres harvested were multiplied by residue loading factors to ensure that the “RES” (residue) amount of selected records were correct. In some cases on the county level, the reported acres burned in the source data set exceeded the acres harvested (i.e., AH < A_BURN). One example of this was for Yuma County, Arizona, where 1,841 acres of “seeds; other” (i.e., all grasses and seeds not including alfalfa and KBG) were harvested in 1997 (NASS, 1999) and 4,700 acres of bermuda grass were reported as having been burned in 1997 (Tickes, 2002). These types of apparent discrepancies (i.e., it is possible that more acres were burned that were harvested due to such factors as crop loss due to disease, drought, etc.) were not resolved; the burn data were assumed to be the accurate measure of burning activity and a comparison to the acres harvested could not be made. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-16 A QA/QC spreadsheet was developed by compiling subtotals of acres harvested (AH) and residue burned (R_BURN) for each crop, and comparing these against the AH values in the crop database and the R_BURN values in the agricultural burning database tables. Accountable differences in AH occurred when not all counties that grew/harvested a crop reported that crop as being burned. Again, the burn data were assumed to be the accurate measure of burning activity. This occurred mainly when the burn records represented daily activity (i.e., CA_SJV and WA data sets), and was corrected by distributing the AH quantities evenly over the daily burn records. 3.3.4 Independent Audit by Emissions Inventory Contractor The WRAP/FEJF emissions inventory (EI) contractor conducted an independent audit of the agricultural burning database and spreadsheets to help ensure the completeness and accuracy of the data related to their EI development. Discrepancies (e.g., missing or incorrect month/day) were corrected. The EI contractor used the corrected agricultural burning data to develop an emissions inventory submitted by them under a separate contract (AS, 2002). 3.4 Results of Agricultural Burn Activity Data Table 3-5 provides a summary of agricultural residues burned by state in the Western U.S. (14 states, not including Alaska which reports no agricultural burning). An overall comparison of states is not valid because these data represent different years; however, data for states with the same years can be compared. The total residues burned, by year and state are as follows (California is not included since it contains a combination of years – 1996, 1997, and 1999): • 1996:  HI: 420,000 tons (all sugarcane residue);  ID: 811,018 tons (mainly wheat and barley residues, and ditches);  MT: 5,055 tons (all wheat residue);  NM: 6,560 tons (all wheat residue); Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-17 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 Table 3-5. Summary of Agricultural Residues Burned within the Western States for Various Years (1996-1999) (Tons)1 3-18 Fuel/Residue Grains and Hay Barley Corn, for Grain Corn, Unspecified Hay, Alfalfa Hay, All Other Oats Rice Rye Wheat, All Wheat, Spring Wheat, Winter All Grasses and Seeds Bermuda Grasses, Propaning Grasses, Stack Burning Seeds, Other Seeds, Alfalfa Seeds, Grasses (Field Burning), Unspecified Seeds, KBG AZ 2000/01 CA 1996/97/99 1,680 889 36,380 15,352 7,213 361 3,944 764,293 124 224,709 CO Avg HI 1996 ID 1996 MT 1996 ND Avg NM 1996/Avg 167,943 2 NV 1998 OR 1996 SD Avg 21,429 14,158 UT 1996 4,671 WA 1999 22,223 3,310 3,060 5,112 2,882 327 1,021 7,902 376,010 5,055 410,145 6,560 244,755 17,379 2,000 84,140 9,400 48,121 63,125 223,869 49,224 3,204 38,205 1,604 6,701 3,014 569,616 394 1,959 542 750 100,000 Sudan Orchard Almond Apple Apricot Avocado Cherry Citrus Fig Grape Nectarine Olive Pruning, Unspecified Pruning, Other WY 1996/97 5,770 74 548 2 310,836 8,071 6,603 1,371 7,511 15,458 12,097 78,860 6,951 8,042 5,570 2,454 879 88 513 458 9,600 2,000 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 Table 3-5. Continued AZ 2000/01 3-19 Fuel/Residue Removal, Unspecified Peach Pear Pecan 7 Pistachio 17 Plum, Prune, Pluot Walnut Other Asparagus Beans 300 Other Peas Safflower Sugarcane Agricultural Related Fuels CRP Ditches, Ditch Banks 1,225 Total 3 31,619 CA 1996/97/99 84,359 22,940 17,748 3,186 24,136 25,152 113,223 CO Avg HI 1996 ID 1996 MT 1996 ND Avg NM 1996/Avg 2 NV 1998 OR 1996 SD Avg UT 1996 11,265 WA 1999 32,024 52 395 WY 1996/97 7 8,819 4,430 3,561 1 6,686 4 21 245 555 495 352 420,000 76,096 25,552 1,898,134 160,013 2,000 420,000 811,018 3,030 5,055 410,145 1 6,560 20,952 890,223 98,298 36,345 480,349 14,660 AK does not conduct agricultural burning as defined under this project; thus only 14 states are shown. Values on this table represent tons of agricultural residue burned as reported by each state or developed with gap-filling/averaging techniques. As such, values for states should not be compared to each other. 2 NV reports 20,952 acres burned; since specific crops are not indicated, residue (tons) cannot be estimated (Sergent, 2002). 3 Sum of individual crops may not be equal total due to rounding. Seeds, Other Pruning, Other Other, Other Wheat, All = = = = All seeds not including alfalfa and Kentucky bluegrass (KBG). Bushberry, kiwi, date, persimmon, pomegranate, quince Other fruits and vegetables, unspecified, sorghum, peanuts, mint, jojoba beans, canola, hops All wheat not including spring and winter, all  OR: 890,223 tons (mainly grass seed field burning, and wheat residue); and  UT: 36,345 tons (mainly wheat, residues, and orchard removal). • 1999: WA: 480,349 tons (mainly wheat and CRP); • Average years (from gap filling):  ND: 410,145 tons (all wheat residue); and  SD: 98,298 tons (mainly wheat residue). Of the states with burning activity data for 1996, ID and OR burned the most residues, with grasses being the main source of residues burned overall (569,616 tons). The Washington residues burned during 1999, in addition to wheat and CRP lands, included barley, orchard removal, and other smaller amounts of grains and hay crops. Gap filling using averages by crop developed from data in areas where burn statistics are available (see Table 3-5) resulted in quantification of residues burned for an “average” year (i.e., it is not possible to assign these quantities to specific years). However, caution should be used when comparing these values to other states having gap filled residue estimates. These gap filled quantities have high levels of uncertainty due to the method used (i.e., combination of anecdotal information to determine counties and crops burned, and average percentages of crops or residues burned developed from data covering multiple years of activity). These gap filled values provide only rough estimates of residues burned. They can be used to alert officials as to the need to track agricultural burning activity in order to reduce uncertainties in these estimates in the future. Two sets of maps depict agricultural burning activity in the 15 Western states. First, Figure 3-1 shows burning activity at the county level. Shading indicates counties where agricultural burning is known to occur. Appendix B contains maps of the individual states where the shading indicates the extent of burning (i.e., tons of residue burned) at the county level. The GIS tables used to generate these maps, were submitted to the WRAP/FEJF at the close of the project. These tables can be used with ArcView to make changes to the maps as necessary in the future. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-20 Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 3-21 4.0 CONCLUSIONS AND RECOMMENDATIONS An extensive data collection and review process was undertaken in order to compile databases of agricultural crop production and residue burning activity in the 15 Western states. The objectives of these databases were to provide information for: 1. Evaluating non-burning management alternatives; and 2. Estimating an air emissions inventory conducted under a separate project (AS, 2002). An indirect objective met by this project was the assessment of data availability (or unavailability) for developing these databases. 4.1 Conclusions The crop production data were fairly accessible, and somewhat consistent in terms of data fields, data quality, and temporal scope. This is due to a structured, systematic process for developing these data by the National Agricultural Statistics Service, state agriculture departments, and other entities. However, identification and compilation of the agricultural burn activity data presented an immense challenge due to the lack of a consistent mechanism for collecting these data on a national, state, local, or tribal level. In fact, in some states where agricultural burning is exempt from regulation, barriers to collection of these data can be created. (A detailed discussion of the accountability mechanisms pertaining to agricultural burning activities and non-burning alternatives is located in Volume II. A copy of Tables 5-2 and 5-2a listing the 17 accountability mechanisms identified in the West is located in Appendix E of this report). In order to provide the data for estimating air emissions, it was necessary to gap fill some missing data for states/counties where burning was known to occur but for which data did not exist. As explained in Section 3.2.4 of this report, averages based on burning activity on a statewide or crop basis were calculated. Then, the averages were used in combination with anecdotal information obtained from other studies (WRAP, 2001a; WESTAR, 1999) to estimate the extent of burning for certain crops in North Dakota, New Mexico, and South Dakota. These averages cannot accurately depict actual burn activity that occurred in those states. Even for Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 4-1 some areas where gap filling was not used, information originally provided for the draft database was revised with significantly different information obtained during the peer review process (e.g., Utah). While it can be concluded that the peer review process worked in this case, this result is illustrative of the need for a coordinated, systematic process to collect agricultural burning data, establish data quality objectives, and resolve conflicting data. Although the data that were collected and compiled were subject to specific QA/QC procedures, some of the data and results have inherent uncertainty due to several factors including the following: 4.2 • The use of permit data sets provided by several state air quality agencies that were accepted “as-is” and were not quality assured as part of this project. For example, data in the CA_SJV data set indicated burn permits had been issued for cotton field burning. Peer review comments indicated that these permits were actually issued for burning of ditch banks or fence lines located adjacent to cotton fields. Although the information in this example was corrected for the final database, other errors of this type may still exist in the final database. Also, the data sets do not contain a consistent set of data defined as “agricultural” residue. For example, it is not clear if ditch bank burning is defined as an agricultural residue in every data set. • The use of crop-specific RL factors that do not take into account geographical variation in residue amounts based on yield or irrigated/nonirrigated agricultural burning practices. Peer review comments indicated that RL factors can vary significantly due to yield, and other factors such as irrigation practices. Although some locallyspecific RL factors were incorporated into the final database (e.g., ditchbanks in Arizona and Utah, wheat in Colorado and New Mexico), the use of crop-specific RLs for most crops was carried forward to the final database. • The use of a combination of calendar year data (i.e., 1996-2001) to depict a single year of burning activity. This was necessary in order to compile a geographically comprehensive set of burn activity data. Recommendations The researchers and peer reviewers contributing to the final database made the following recommendations pertaining to future improvements in the agricultural burning activity database: Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 4-2 1. Develop a mechanism (e.g., program, regulation, etc.) whereby the relevant state, county, tribal, agricultural, and stakeholder entities establish data quality objectives, define data sources, and compile data on a regular basis to estimate the extent of agricultural burning in the Western United States. Also, this mechanism should provide a consistent definition of the residue types to be included in the agricultural burning category (see Volume II for more discussion on this issue). 2. Conduct research to identify and/or calculate specific yield-based RL factors for each geographical zone or area (county, state). 3. Incorporate the impact of irrigated and nonirrigated land agricultural practices. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 4-3 5.0 REFERENCES AS, 2002. “Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire on Wild Lands and Agricultural Burning”; Prepared for the WGA/WRAP Fire Emissions Joint Forum by Air Sciences Inc., Lakewood, Colorado, and Portland, Oregon. April 27. Bernards, F., 2002. Revised estimates of agricultural acres burned for Utah in 1996. Provided by Frances Bernards, Utah Department of Environmental Quality, Salt Lake City. April 15. Beyer, J., 2002. Residue loading factor for apple prunings in California. Provided by John Beyer, USDA Natural Resources Conservation Service, Fresno, California, via telephone call to Paula Fields, ERG. April 16. CARB, 1996. “Atmospheric Pollutant Emission Factors From Open Burning of Agricultural and Forest Biomass by Wind Tunnel Simulations”, Prepared for the California Air Resources Board under Contract #A932-126 by Dr. Bryan Jenkins, University of California Davis. CARB, 2000. “Agricultural Burning Emission Factors”; Technical Memorandum from Dale Shimp, Manager, Emission Inventory Analysis Section, to Beverly Werner, Manager, Regulatory Assistance Section. California Air Resources Board, Sacramento, California. August 17. CASS, 1996. Reports for crops grown in California in 1996. Downloaded 3/20/01 from: http://www.nass.usda.gov/ca/rpts. California Agricultural Statistics Service. CDFA, 1997. “1996 Agricultural Commissioners’ Data Report”, State of California, Department of Food and Agriculture, and the U.S. Department of Agriculture, Sacramento, California. August. Coeffield, J., 2002. Acres burned estimate of irrigated wheat acres (estimated as 1% of total acres) statewide in 1996. Provided by John Coeffield, Montana Department of Environmental Quality via telephone call with Paula Fields, ERG. April 11. Conrad, M., 2002. Burn activity data for weed control based on permit issued Jan 17-April 16, 2001, in Pima county, Arizona. Provided by Mirian Conrad, Pima County Department of Environmental Quality, Tucson, Arizona. March 14. Cunningham, R., 1998. Acres burned of barley for Fremont County, Wyoming, in 1998. Provided by Ron Cunningham, Cooperative Extension Service, University Extension Agent, in response to WESTAR survey administered by Wyoming DEQ. December. EIIP, 1997. “General QA/QC Methods, Final Report”; Prepared for the Quality Assurance Committee, Emissions Inventory Improvement Program by Radian Corporation, Research Triangle Park, North Carolina. June. Fife, 2002. 1996 Acreage Burned by County and Crop for the Sacramento Valley. Database provided by Fife Environmental, Sacramento, California. February. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 5-1 Foster, C., 2002. Burn activity data for citrus, ditch banks, and jojoba beans compiled from burn permits issued in 2001 in Yuma county, Arizona. Provided by Curt Foster, Rural/Metro Fire Department, Yuma, Arizona. March 15. FSA, 1996. Conservation Reserve Program (CRP), Acres by State and County. Downloaded 10/8/01 from http://www.fsa.usda.gov/dafp/cepd/crp.htm. Farm Service Agency. Gabrielson, D., 2002. Burn activity estimates for ditch bank burning in 2001 for Pinal county, Arizona. Prepared by Don Gabrielson, Pinal County Air Quality Control District, Florence, Arizona. March 7. Goodrich, K., 2002. Estimates of acres of ditches/fenceline, orchard removal wheat stubble burned in Utah (all counties except Box Elder) in 1996. Provided by Kerry Goodrich, USDA Natural Resources Conservation Service, Salt Lake City, to Frances Bernards, Utah Department of Environmental Quality, Salt Lake City. March 20. Graves, J., 2002. Burn activity data for various crops compiled from permits issued in 20002001 in Graham and Cochise counties, Arizona. Compiled for the WRAP/FEJF by John Graves, Interagency Smoke Management Program, Phoenix, Arizona. March 15. Grover, J., 1998. Acres burned of alfalfa seed for Big Horn Basin, Wyoming, in 1998. Provided by John Grover, Wyoming Seed Certification Committee, Alfalfa Seed and Leaf Cutter Bee Association, Park County, Wyoming, in response to WESTAR survey administered by Wyoming DEQ. December. ICAPCD, 2001. 1996 Agricultural Burning Data. Provided by the Imperial County Air Pollution Control District, El Centro, California. December 7. IDEQ, 2001. 1996 Fire Activity. Provided by Michael Dubois, Idaho Department of Environmental Quality, Boise, Idaho. April. Jenkins, B.M. and H.R. Summer, 1986. “Harvesting and Handling Agricultural Residues for Energy.” Transactions of the American Society of Agricultural Engineers. Vol. 29, No. 3 pages 824 - 836. Jenkins, B.M., 2001. Dr. Bryan M. Jenkins, University of California, Davis, personal communication. May 24 and October 28. Johnson, L., 2001. Burn activity data for citrus compiled from permits issued in 2001 in Yuma, Arizona. Provided by Linda Johnson, City of Yuma Fire Department. December. MacCluer, L. D., 2002. Acres burned of pineapple residue in Hawaii. Provided by L. Douglas MacCluer, Vice President, Agricultural Business Development, Maui Pineapple Company, Ltd., Haliimaile, Maui, Hawaii. February 1. McDonald, C., 2002. Burn activity estimate for wheat stubble (average year; north of Highway I94 and east of Jamestown). Provided by Chuck McDonald, North Dakota Health Department, Air Quality Division, via telephone call with Paula Fields, ERG. April 10. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 5-2 NASS, 1996a. Published Estimates Data Base. Downloaded 1/29/01 – 2/3/01 from: http://www.nass.usda.gov. “On-Line Data Base” providing data for 1996 crops in each of the 15 Western states. NASS, 1996b. Links to state agricultural statistics data and reports providing data and reports for 1996 and other years crops in each of the 15 Western states. Downloaded 2/15/01 – 4/27/01 from: http://www.nass.usda.gov. NASS, 1999. “1997 Census of Agriculture”. Downloaded for each of 15 Western states for selected crops 4/2/01 – 5/30/01 from: http://www.nass.usda.gov/census/census97. ODEQ, 2001. 1996 Agricultural Field Emissions Summary Table. Provided by Brian Finneran, Oregon Department of Environmental Quality, Portland, Oregon. May. Potter, D., 2002. Comments on draft agricultural burning activity database for Wyoming. Provided by Darla Potter, Wyoming Department of Environmental Quality, Cheyenne, Wyoming. April 12, 2002. Riley, D., 2001. Diane Riley, Idaho Department of Environmental Quality, Boise, Idaho, personal communication. August 2. Riley, D., 2002. Revisions to acres burned for wheat, barley, and Kentucky Blue Grass. Provided by Diane Riley, Idaho Department of Environmental Quality, Boise, Idaho. March 28. SCAC, 1995. “Advisory Committee on Alternatives to Rice Straw Burning Report”, Special California Advisory Committee on Alternatives to Rice Straw Burning. SCAQMD, 2001. 1996 Agricultural Burning Activity Spreadsheets. Provided by South Coast Air Quality Management District, Information Management, Diamond Bar, California. August 7. Sergent, C., 2002. Acres burned for Nevada in 1998. Provided by Chester Sergent, Nevada Division of Environmental Protection, Bureau of Air Quality Planning, Carson City. April 12. Sharkoff, J., 2002. Burn activity estimate for wheat stubble (average year) for Mesa county, Colorado. Provided by James Sharkoff, Agronomist, USDA Natural Resource Conservation Service, Lakewood, Colorado. April 15. Shaver, P., 2002. Comments on draft agricultural burning activity database. Provided by Patrick Shaver, USDA Natural Resources Conservation Service, Corvallis, Oregon. March 7. SJVUAPCD, 2001. 1996 Agricultural Burning Database. Provided by David Jones, San Joaquin Valley Unified Air Pollution Control District, Fresno, California. March. Spiering, K., 1998. Acres burned of grass seed for Park County, Wyoming, in 1998. Provided by Kelly Spiering, Powell, Wyoming, in response to WESTAR survey administered by Wyoming DEQ. December. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 5-3 Stover, A., 2002. Comments on draft agricultural burning activity database for South Dakota. Provided by Alan Stover, South Dakota Department of Environment and Natural Resources via e-mail to Paula Fields, ERG. March 20. Tickes, B., 2002. Burn activity estimates for bermuda and wheat/barley in 2001 for Yuma county, Arizona. Provided by Barry Tickes, Yuma County Cooperative Extension, Yuma, Arizona. March 14. UDEQ, 2001. Utah Fires 1996. Provided by Steven Parkin, Utah Department of Environmental Quality via Mike Ziolko, Oregon Department of Forestry, Salem, Oregon. June. USDA, 1997c. “Burning on Croplands”, Prepared by Dr. Jerry Lemunyon, United States Department of Agriculture Air Quality Task Force, Technical Subcommittee, Bob Odom, Chairman, November 20. USEPA, 1995. “Compilation of Air Pollutants Emission Factors (AP-42), Volume I: Stationary Point and Area Sources, Fifth Edition”, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. January. USEPA, 2001a. State FIPS Code Listing. Downloaded 5/25/01 from: http://www.epa.gov/ enviro/html/codes/state.html. WDOE, 2001a. Washington Agricultural Burning Permitting Database. Provided by Shawn Nolph, Washington State Department of Ecology, Spokane, Washington. May. WDOE, 2001b. 1996-2000 Agricultural Burning Emissions Inventory. Provided by Sally Otterson, Washington State Department of Ecology, Olympia, Washington. June. WESTAR, 1999. “Western States Agricultural Burning Survey”, Western States Air Resources Council, Portland, Oregon. April. WRAP, 2001a. “Agricultural Burning Smoke Management Program Survey, Draft Final Report”; Prepared for the Western Regional Air Partnership by EC/R, Durham, North Carolina. March. WRAP, 2001b. “Tribal Emissions Inventories and Air Quality Data Gathering and Assessment Project, Draft”, Prepared by the Institute for Tribal Environmental Professionals, Northern Arizona University, Flagstaff, Arizona. April. Vol. I: Agricultural Crop Production and Residue Burning, Final - May 2002 5-4 APPENDIX A CROP PRODUCTION DATA State AK AK AK AK AK AK AK Crop(s) Acres Harvested barley 6,900 fruits and vegetables; other 343 hay; alfalfa 3,801 hay; all 24,023 hay; all other 20,222 oats 700 potatoes 630 AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ AZ apples barley citrus corn; for grain corn; for silage cotton; amer. pima cotton; upland fruits and vegetables; other grapes hay; alfalfa hay; all hay; all other peaches pears potatoes seeds; alfalfa seeds; other sorghum wheat; all wheat; durum wheat; winter all 3,772 54,000 38,823 40,000 16,937 40,300 314,000 28,800 6,050 160,000 179,000 19,000 324 43 9,000 2,667 3,556 45,000 178,000 164,000 14,000 CA CA CA CA CA CA CA CA CA CA CA CA CA almonds apples apricots asparagus avocado barley beans; all dry edible cherries citrus corn; for grain corn; for silage cotton; amer. pima cotton; upland 400,692 39,981 21,314 34,121 56,335 190,000 123,000 17,438 284,790 220,000 275,000 164,000 995,000 A-1 State CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA CA Crop(s) Acres Harvested CRP 2,400 figs 14,564 fruits and vegetables; other 777,358 grapes 721,505 hay; alfalfa 944,056 hay; all 1,698,773 hay; all other 754,717 kiwi 5,242 nectarines 36,634 oats 30,000 olives 34,409 peaches 71,823 peanuts 750 pears 21,884 peas; dry edible 697 pecans 1,905 persimmons 2,479 pistachio 65,373 plums and prunes 133,068 rice; all 500,000 safflower 156,801 seeds; alfalfa 53,799 seeds; other 77,499 sorghum 18,855 sugarbeets 82,200 walnuts 168,298 wheat; all 688,000 wheat; durum 138,000 wheat; winter all 550,000 CO CO CO CO CO CO CO CO CO CO CO CO CO CO barley beans; all dry edible corn; for grain corn; for silage CRP hay; alfalfa hay; all hay; all other oats potatoes proso millet seeds; alfalfa seeds; other sorghum A-2 92,000 125,000 890,000 90,000 2,080 860,000 1,510,000 650,000 35,000 87,600 125,765 1,232 6,879 260,000 State CO CO CO CO CO Crop(s) sugarbeets sunflower wheat; all wheat; other spring wheat; winter all HI HI HI HI HI coffee fruits and vegetables; other macadamia nuts pineapple sugarcane ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID ID barley beans; all dry edible corn; for grain corn; for silage CRP hay; alfalfa hay; all hay; all other lentils mint oats peas; dry edible potatoes seeds; alfalfa seeds; kbg seeds; other sugarbeets wheat; all wheat; other spring wheat; winter all 730,000 93,000 40,000 68,000 3,229 1,000,000 1,280,000 280,000 65,540 23,790 25,000 71,507 413,000 31,210 32,796 17,629 184,000 1,560,000 700,000 860,000 MT MT MT MT MT MT MT MT MT MT MT barley beans; all dry edible corn; for grain corn; for silage CRP hay; alfalfa hay; all hay; all other oats potatoes seeds; alfalfa 1,150,000 10,300 15,000 39,000 33,037 1,700,000 2,600,000 900,000 50,000 10,200 13,122 A-3 Acres Harvested 51,100 107,000 2,268,000 68,000 2,200,000 5,400 13,120 20,200 20,000 42,900 State MT MT MT MT MT MT MT Crop(s) seeds; kbg seeds; other sugarbeets wheat; all wheat; durum wheat; other spring wheat; winter all ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND barley beans; all dry edible corn; for grain corn; for silage CRP flaxseed hay; alfalfa hay; all hay; all other oats potatoes rye soybeans sugarbeets sunflower wheat; all wheat; durum wheat; other spring wheat; winter all NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM NM apples corn; for grain corn; for silage cotton; amer. pima cotton; upland CRP fruits and vegetables; other hay; alfalfa hay; all hay; all other peanuts pecans potatoes sorghum wheat; all wheat; winter all A-4 Acres Harvested 259 8,965 57,500 6,360,000 280,000 4,100,000 1,980,000 2,600,000 570,000 600,000 140,000 19,180 77,000 1,700,000 2,900,000 1,200,000 380,000 131,000 16,000 845,000 225,300 1,165,000 12,515,000 2,940,000 9,500,000 75,000 1,192 84,000 44,000 14,000 55,000 3,425 38,375 250,000 350,000 100,000 16,500 23,188 10,300 225,000 110,000 110,000 State Crop(s) Acres Harvested NV NV NV NV NV NV NV NV NV NV barley fruits and vegetables; other hay; alfalfa hay; all hay; all other potatoes seeds; alfalfa wheat; all wheat; other spring wheat; winter all OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR OR apples barley cherries corn; for grain CRP filberts grapes hay; alfalfa hay; all hay; all other mint oats peaches pears plums and prunes potatoes seeds; alfalfa seeds; kbg seeds; other sugarbeets wheat; all wheat; other spring wheat; winter all 6,658 150,000 8,804 37,000 13 26,678 5,800 460,000 1,070,000 610,000 45,221 35,000 705 15,090 1,462 61,000 9,465 18,798 513,246 16,300 920,000 105,000 815,000 SD SD SD SD SD SD SD SD barley corn; for grain corn; for silage CRP flaxseed hay; alfalfa hay; all hay; all other 145,000 3,650,000 320,000 8,071 9,000 2,500,000 4,300,000 1,800,000 A-5 5,000 4,415 250,000 480,000 230,000 6,999 11,731 19,000 10,000 9,000 State SD SD SD SD SD SD SD SD SD SD SD SD Crop(s) oats proso millet rye seeds; alfalfa seeds; other sorghum soybeans sunflower wheat; all wheat; durum wheat; other spring wheat; winter all UT UT UT UT UT UT UT UT UT UT UT UT UT UT UT UT UT UT apples barley beans; all dry edible cherries corn; for grain corn; for silage fruits and vegetables; other hay; alfalfa hay; all hay; all other oats peaches potatoes seeds; alfalfa seeds; other wheat; all wheat; other spring wheat; winter all 3,699 100,000 600 4,010 20,000 40,000 6,695 545,000 705,000 160,000 9,000 1,775 4,200 3,393 3,739 185,000 25,000 160,000 WA WA WA WA WA WA WA WA WA WA WA WA apples asparagus barley beans; all dry edible blueberries canola cherries corn; for grain corn; for silage CRP fruits and vegetables; other grapes 154,930 23,000 440,000 35,000 1,311 12,686 17,700 120,000 50,000 214,073 189,269 35,265 A-6 Acres Harvested 360,000 122,451 36,000 12,136 12,900 145,000 2,670,000 690,000 3,854,000 24,000 2,250,000 1,580,000 State WA WA WA WA WA WA WA WA WA WA WA WA WA WA WA WA WA Crop(s) hay; alfalfa hay; all hay; all other hops oats peaches pears peas; dry edible plums and prunes potatoes seeds; alfalfa seeds; kbg seeds; other sugarbeets wheat; all wheat; other spring wheat; winter all WY WY WY WY WY WY WY WY WY WY WY WY WY WY WY WY barley beans; all dry edible corn; for grain corn; for silage CRP hay; alfalfa hay; all hay; all other oats potatoes seeds; alfalfa seeds; other sugarbeets wheat; all wheat; other spring wheat; winter all A-7 Acres Harvested 490,000 800,000 310,000 30,621 14,000 2,200 23,555 126,975 571 161,000 13,197 45,103 13,693 13,000 2,745,000 395,000 2,350,000 120,000 31,000 50,000 33,000 666 620,000 1,220,000 600,000 32,000 704 3,927 766 56,800 236,000 26,000 210,000 APPENDIX B CROP PRODUCTION MAPS B-1 B-2 B-3 B-4 B-5 B-6 B-7 B-8 B-9 B-10 B-11 B-12 B-13 B-14 B-15 APPENDIX C AGRICULTURAL RESIDUE BURN ACTIVITY DATA AND CROP BURN AVERAGES ARIZONA Residue Name apple trees Crop Name apples County RL (tons/acre) Graham apples Total beans; all dry edible Yuma beans; all dry edible Total citrus citrus Yuma citrus trees citrus Yuma citrus trees citrus Yuma citrus trees, 320 citrus Yuma citrus Total corn stalks corn; for grain Graham corn; for grain Total Mesquite removed for agricultural purposes, ditches weed and ditch abatement, banks-AZ and for fire Cochise prevention Weeds along irrigation ditches ditches and ditch banks-AZ Cochise Weeds along irrigation ditches, mesquite ditches trimmings and ditch banks-AZ Cochise ditches around 62.8 acres ditches and ditch banks-AZ Graham weeds along fenceline ditches and ditch banks-AZ Graham weeds treelimbs and wood along fenceline ditches and and ditches ditch banks-AZ Graham weeds ditches and ditch banks-AZ Pima ditches and ditch banks-AZ ditches and ditch banks-AZ Pinal ditches and ditch banks-AZ ditches and ditch banks-AZ Pinal ditchbanks ditches and ditch banks-AZ Yuma ditches and ditch banks-AZ Total tamaracks along ditches orchard pruning; unspecified Graham orchard pruning; unspecified Total Pecan limbs from orchard pecans Cochise pecans Total Pistachio wood from pruning of orchard pistachio Cochise pistachio Total Bermuda grass seeds; other Yuma seeds; other Total Robosa, Lehmann,s love grass, Mesquite, seeds; Burrowee unspecified Cochise Robosa, Lehmann,s love grass, Mesquite, seeds; Burrowee unspecified Cochise seeds; unspecified Total Wheat stubble wheat; all Yuma wheat; all Total Grand Total Jojoba Plant 2.3 2.5 1 1 1 1 4.2 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.7 1.7 1.7 2 2 2 1.9 A_BURN (acres) 32 32 120 120 320 217 3 8 548 400 400 2 1 1 4 1 3 286 144 295 27 765 1 1 4 4 10 10 4,700 4,700 807 700 1,507 8,080 8,080 16,167 Page 1 of 1 Year Burned 2001 2001 2001 2001 2001 2001 2001 2001 2001 2001 2001 2001 2001 2001 2000 2001 2001 2001 2001 2001 2001 2000 2001 2001 R_BURN (tons) 74 74 300 300 320 217 3 8 548 1,680 1,680 3 1 2 8 1 4 458 231 473 44 1,225 2 2 7 7 17 17 9,400 9,400 1,614 1,400 3,014 15,352 15,352 31,619 Comments Daily A_BURN compiled by ADEQ (J.Graves) A_BURN from C.Foster, Yuma Co. FD A_BURN from L.Johnson, City Yuma FD A_BURN from C.Foster, Yuma Co. FD A_BURN from L.Johnson, City Yuma FD A_BURN from L.Johnson, City Yuma FD Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) A_BURN from M.Conrad, Pima Co. DEQ A_BURN from D.Gabrielson, Pinal Co. AQCD A_BURN from D.Gabrielson, Pinal Co. AQCD A_BURN from C.Foster, Yuma Co. FD Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) A_BURN from B.Tickes, Yuma Co. Extension Agent Daily A_BURN compiled by ADEQ (J.Graves) Daily A_BURN compiled by ADEQ (J.Graves) A_BURN from B.Tickes, Yuma Co. Extension Agent CALIFORNIA Residue Name Crop Name Almond Almond ALMOND PRUNING ALMOND PRUNING ALMOND PRUNING almonds almonds almonds almonds almonds Almonds ALMOND ALMOND Almond ALMOND ALMOND Almond Almond ALMOND Almond almonds almonds almonds almonds almonds almonds almonds almonds almonds almonds almonds Total apples apples apples apples apples apples apples apples apples apples apples apples apples apples apples Total apricots apricots apricots apricots apricots apricots apricots apricots apricots apricots apricots apricots Total asparagus asparagus asparagus asparagus asparagus asparagus Total avocado Apple APPLE APPLE APPLE APPLE APPLE Apple apples Apple apples APPLE APPLE Apple APPLE PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING APRICOT APRICOT APRICOT APRICOT APRICOT Apricot APRICOT APRICOT Apricot APRICOT Apricot PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING ASPARAGUS asparagus ASPARAGUS ASPARAGUS ASPARAGUS AVOCADO PRUNING RL (tons/acre) County Butte COLUSA FRESNO KERN KINGS 1 1 1 1 1 Lake MADERA MERCED Sacramento SAN JOAQUIN STANISLAUS Sutter Tehama TULARE Yolo 1 1 1 1 1 1 1 1 1 1 Butte FRESNO KERN KINGS MADERA MERCED Placer Riverside Sacramento San Bernardino SAN JOAQUIN STANISLAUS Tehama TULARE 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 2.3 FRESNO KERN KINGS MADERA MERCED Sacramento SAN JOAQUIN STANISLAUS Tehama TULARE Yolo 1.8 1.8 1.8 1.8 1.8 1.8 1.8 1.8 1.8 1.8 1.8 FRESNO IMPERIAL KERN SAN JOAQUIN STANISLAUS 1.5 1.5 1.5 1.5 1.5 FRESNO 1.5 A_BURN (acres) 11,411 37 64,478 27,216 2,288 71 37,416 37,433 9 20,131 54,657 103 3,079 4,146 2,183 264,657 2 1,296 128 120 331 91 32 1 164 326 7 219 2,715 72 40 100 120 126 1 254 2,279 4 36 326 3,356 856 4,872 95 30 7 5,860 25 Year Burned 1996 1996 1999 1999 1999 1997 1999 1999 1996 1999 1999 1996 1996 1999 1996 1996 1999 1999 1999 1999 1999 1996 1999 1996 1999 1999 1999 1996 1999 1999 1999 1999 1999 1999 1996 1999 1999 1996 1999 1996 1999 1996 1999 1999 1999 1999 Page 1 of 10 R_BURN (tons) 11,411 37 64,776 40,315 2,536 71 38,427 49,159 9 35,443 56,408 103 3,079 6,881 2,183 310,836 3 3,781 735 288 762 217 74 7 1 18 798 780 16 590 8,071 144 121 180 216 419 1 636 4,203 7 89 587 6,603 1,314 7,307 143 45 11 8,819 38 Comments Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Annual R_BURN provided by SCAQMD Daily A_BURN provided by Fife, 2002 Annual R_BURN provided by SCAQMD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by ICUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD CALIFORNIA Residue Name AVOCADO PRUNING Avocado Avocado AVOCADO PRUNING AVOCADO PRUNING BARLEY BARLEY BARLEY BARLEY BARLEY BARLEY BARLEY Bean BEAN jojoba beans BEAN BEAN BEAN BEAN BEAN BEAN BEAN Berry BUSHBERRY BUSHBERRY BUSHBERRY BUSHBERRY BUSHBERRY BUSHBERRY CHERRY CHERRY CHERRY CHERRY CHERRY CHERRY CHERRY CHERRY Citrus CITRUS CITRUS CITRUS CITRUS Citrus Citrus Citrus PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING Crop Name avocado avocado avocado avocado avocado avocado Total barley barley barley barley barley barley barley barley Total beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible beans; all dry edible Total blueberries blueberries Total bushberry bushberry bushberry bushberry bushberry bushberry bushberry Total cherries cherries cherries cherries cherries cherries cherries cherries cherries Total citrus citrus citrus citrus citrus citrus citrus citrus County KERN Riverside San Bernardino STANISLAUS TULARE RL (tons/acre) 1.5 1.5 1.5 1.5 1.5 FRESNO KERN KINGS MERCED SAN JOAQUIN STANISLAUS TULARE 1.7 1.7 1.7 1.7 1.7 1.7 1.7 COLUSA FRESNO IMPERIAL KERN KINGS MADERA MERCED SAN JOAQUIN STANISLAUS TULARE 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 Placer 1.7 FRESNO MADERA MERCED SAN JOAQUIN STANISLAUS TULARE 1.7 1.7 1.7 1.7 1.7 1.7 FRESNO KERN KINGS MADERA MERCED SAN JOAQUIN STANISLAUS TULARE 1 1 1 1 1 1 1 1 Butte FRESNO KERN MADERA MERCED Placer Riverside Sacramento 1 1 1 1 1 1 1 1 A_BURN (acres) - Year Burned 1999 1999 1999 48 1999 73 1999 146 80 1999 5 1999 31 1999 69 1999 68 1999 184 1999 62 1999 499 15 1996 480 1999 160 1996 507 1999 40 1999 140 1999 130 1999 50 1999 6 1999 240 1999 1,767 14 1996 14 36 1999 4 1999 46 1999 1999 70 1999 1 1999 156 287 1999 25 1999 2 1999 200 1999 1999 2,030 1999 427 1999 172 1999 3,141 4 1996 4,006 1999 731 1999 228 1999 1999 20 1996 1999 1 1996 Page 2 of 10 R_BURN (tons) 1 10 15 74 1,234 1,370 136 9 57 123 146 313 105 889 38 1,201 400 1,272 100 350 327 125 15 602 4,430 24 24 61 7 92 5 157 2 324 288 48 17 200 95 6,211 455 199 7,511 4 5,022 2,612 241 1 20 876 1 Comments Daily A_BURN and/or R_BURN provided by SJVUAPCD Annual R_BURN provided by SCAQMD Annual R_BURN provided by SCAQMD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by ICUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Annual R_BURN provided by SCAQMD Daily A_BURN provided by Fife, 2002 CALIFORNIA Residue Name CITRUS PRUNING CITRUS PRUNING Corn Corn Corn corn CORN Corn CORN CORN Corn CORN Corn Date Brush DITCHBANKS Weeds DITCHBANKS Weeds DITCHBANK & CANAL Weeds BERMS TULES DITCHBANKS Weeds DITCHBANKS Weeds Weeds Brush DITCHBANKS BRUSH PASTURE/CORRAL TREES Weeds FIG FIG FIG FIG FIG FIG FIG FIG PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING OtherVegetable VEGETABLE CROPS Vegetable Crops Grape Crop Name County STANISLAUS TULARE citrus citrus citrus Total corn; for grain Butte corn; for grain COLUSA corn; for grain Glenn corn; for grain IMPERIAL corn; for grain MERCED corn; for grain Sacramento corn; for grain SAN JOAQUIN corn; for grain STANISLAUS corn; for grain Tehama corn; for grain TULARE corn; for grain Yolo corn; for grain Total dates Riverside dates Total ditches and ditch banks Butte ditches and ditch banks Butte ditches and ditch banks Butte ditches and ditch banks COLUSA ditches and ditch banks COLUSA ditches and ditch banks FRESNO ditches and ditch banks Glenn ditches and ditch banks MADERA ditches and ditch banks MERCED ditches and ditch banks Placer ditches and ditch banks Placer ditches and ditch banks Sacramento ditches and ditch banks Sacramento ditches and ditch banks Sutter ditches and ditch banks Tehama ditches and ditch banks Tehama ditches and ditch banks TULARE ditches and ditch banks TULARE ditches and ditch banks Yuba ditches and ditch banks Total figs FRESNO figs KERN figs KINGS figs MADERA figs MERCED figs Sacramento figs STANISLAUS figs TULARE figs Total fruits and vegetables; other Butte fruits and vegetables; other FRESNO fruits and vegetables; other Riverside fruits and vegetables; other Total grapes Butte RL (tons/acre) 1 1 4.2 4.2 4.2 4.2 4.2 4.2 4.2 4.2 4.2 4.2 4.2 A_BURN (acres) 22 3,597 8,607 2 43 937 249 20 1,902 3,292 154 348 5 1,365 8,316 1 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 3.2 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.47 1.47 1.47 2.5 Year Burned 1999 1999 1996 1996 1996 1996 1999 1996 1999 1999 1996 1999 1996 1999 1,577 689 1,002 294 1,578 1 5 1 30 96 146 33 669 111 1,342 10 1 20 384 7,987 480 32 25 4,160 2,101 1 16 6,814 5 5 1996 1996 1996 1996 1996 1999 1996 1999 1999 1996 1996 1996 1996 1996 1996 1996 1999 1999 1996 1999 1999 1999 1999 1999 1996 1999 1999 1996 1999 1999 10 1 1996 Page 3 of 10 R_BURN (tons) 22 6,661 15,459 6 180 3,936 1,046 84 7,988 15,277 645 1,462 23 5,733 36,380 168 168 5,045 2,204 3,205 937 5,050 2 16 2 96 307 467 106 2,141 355 4,294 32 2 64 1,229 25,552 875 56 45 7,153 3,916 1 32 21 12,097 7 7 60 74 3 Comments Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by ICUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Annual R_BURN provided by SCAQMD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Annual R_BURN provided by SCAQMD Daily A_BURN provided by Fife, 2002 CALIFORNIA Residue Name Crop Name County Butte COLUSA FRESNO KERN KINGS RL (tons/acre) 2.5 2.5 2.5 2.5 2.5 Vines Grape GRAPE VINES/CANES GRAPE VINES/CANES GRAPE VINES/CANES grapes grapes grapes grapes grapes Grapes GRAPE GRAPE Grape Grape GRAPE GRAPE Grape GRAPE GRAPE grapes grapes grapes grapes grapes grapes grapes grapes grapes grapes grapes Total hay; alfalfa hay; alfalfa hay; alfalfa hay; alfalfa Lake MADERA MERCED Riverside Sacramento SAN JOAQUIN STANISLAUS Tehama TULARE TULARE 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 FRESNO IMPERIAL KERN KINGS 0.8 0.8 0.8 0.8 hay; alfalfa hay; alfalfa hay; alfalfa hay; alfalfa hay; alfalfa hay; alfalfa hay; alfalfa hay; alfalfa hay; alfalfa Total hay; all other Lake MADERA MERCED Placer SAN JOAQUIN STANISLAUS Tehama TULARE 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 Butte 0.8 hay; all other hay; all other hay; all other Total kiwi kiwi kiwi kiwi kiwi kiwi kiwi kiwi Total nectarines nectarines nectarines nectarines nectarines nectarines nectarines Lake Placer 0.8 0.8 Butte FRESNO MADERA MERCED SAN JOAQUIN STANISLAUS TULARE 1.7 1.7 1.7 1.7 1.7 1.7 1.7 FRESNO KERN KINGS MADERA MERCED SAN JOAQUIN STANISLAUS 1.7 1.7 1.7 1.7 1.7 1.7 1.7 VINES/CANES VINES/CANES VINES/CANES VINES/CANES STUMPS/STAKES VINES/CANES ALFALFA alfalfa ALFALFA ALFALFA hay; alfalfa ALFALFA ALFALFA Alfalfa ALFALFA ALFALFA Alfalfa ALFALFA Hay-Wild hay; other Hay Kiwi KIWI KIWI KIWI KIWI KIWI KIWI PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING NECTARINE NECTARINE NECTARINE NECTARINE NECTARINE NECTARINE NECTARINE PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING A_BURN (acres) 1 8 7,316 5,159 298 Year Burned 1996 1996 1999 1999 1999 2,561 1997 3,940 1999 3,543 1999 1999 69 1996 2,501 1999 1,752 1999 2 1996 2 1999 2,081 1999 29,233 8,245 1999 403 1996 101 1999 7 1999 94 76 6 1 R_BURN (tons) 1 20 18,368 13,651 744 6,403 9,906 8,961 1,152 173 9,261 4,476 5 7 5,732 78,860 6,596 323 90 6 1997 1999 1999 1996 1999 28 1999 28 1996 10 1999 8,998 1 1996 75 61 6 1 3 22 22 8 7,213 1 400 50 451 64 22 5 11 19 83 203 2,129 155 152 44 21 5 28 320 40 361 109 39 9 2 20 32 158 369 3,816 396 265 75 79 9 48 1997 1996 1996 1999 1999 1999 1999 1999 1999 1999 1999 1999 1999 1999 1999 1999 Page 4 of 10 Comments Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Annual R_BURN provided by SCAQMD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by ICUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD CALIFORNIA Residue Name NECTARINE PRUNING Oats OATS OATS Oats OATS OATS OATS OATS Oats OATS Olive Olive OLIVE OLIVE OLIVE OLIVE OLIVE Olive OLIVE OLIVE Olive OLIVE PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING OtherPruning OtherPruning OTHER PRUNINGS OTHER PRUNINGS OTHER PRUNINGS OTHER PRUNINGS X-Mas Trees OtherPruning CHRISTMAS TREES OTHER PRUNINGS OTHER PRUNINGS OtherPruning OTHER PRUNINGS OtherPruning OrchardRemoval ORCHARD REMOVAL VINEYARD REMOVAL ORCHARD REMOVAL ORCHARD REMOVAL ORCHARD REMOVAL OrchardRemoval OrchardRemoval ORCHARD REMOVAL Crop Name nectarines nectarines Total oats oats oats County TULARE RL (tons/acre) 1.7 Butte FRESNO KERN 1.6 1.6 1.6 oats Lake oats MADERA oats MERCED oats SAN JOAQUIN oats STANISLAUS oats Tehama oats TULARE oats Total olives Butte olives COLUSA olives FRESNO olives KERN olives KINGS olives MADERA olives MERCED olives Sacramento olives SAN JOAQUIN olives STANISLAUS olives Tehama olives TULARE olives Total orchard pruning; unspecified Butte orchard pruning; unspecified COLUSA orchard pruning; unspecified FRESNO orchard pruning; unspecified KERN orchard pruning; unspecified MADERA orchard pruning; unspecified MERCED orchard pruning; unspecified Placer orchard pruning; unspecified Sacramento orchard pruning; unspecified SAN JOAQUIN orchard pruning; unspecified SAN JOAQUIN orchard pruning; unspecified STANISLAUS orchard pruning; unspecified Tehama orchard pruning; unspecified TULARE orchard pruning; unspecified Yolo orchard pruning; unspecified Total orchard removal Butte orchard removal FRESNO orchard removal FRESNO orchard removal KERN orchard removal KINGS orchard removal MADERA orchard removal Placer orchard removal Sutter orchard removal TULARE 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 15 15 15 15 15 15 15 15 15 A_BURN (acres) 1,020 3,554 20 83 50 82 255 372 299 802 90 391 2,444 340 5 181 41 119 308 30 2 24 3 2,124 1,085 4,261 229 80 20 7 73 26 98 600 125 623 43 1,013 2,937 207 2,453 30 157 747 1,270 1 100 506 Year Burned 1999 1996 1999 1999 1997 1999 1999 1999 1999 1996 1999 1996 1996 1999 1999 1999 1999 1999 1996 1999 1999 1996 1999 1996 1996 1999 1999 1999 1999 1996 1996 1999 1999 1999 1996 1999 1996 1996 1999 1999 1999 1999 1999 1996 1996 1999 Page 5 of 10 R_BURN (tons) 2,264 6,951 32 137 80 131 408 622 478 1,283 144 628 3,944 577 9 316 70 202 537 55 3 48 5 3,610 2,610 8,042 389 139 36 1 12 285 44 167 12 1,310 319 1,059 75 1,722 5,570 3,105 36,800 450 2,349 11,211 19,055 15 1,500 7,595 Comments Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD CALIFORNIA Residue Name OrchardRemoval onion seed Peach PEACH PEACH PEACH PEACH PEACH Peach Peach PEACH PEACH Peach Peach PEACH Peach PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PEANUTS Pear PEAR PRUNING PEAR PRUNING Pears PEAR PRUNING PEAR PRUNING Pear Pear PEAR PRUNING PEAR PRUNING PEAR PRUNING PEA VINES Pecan Pecan PECAN PECAN PECAN PECAN PECAN PECAN PECAN Pecan PECAN PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING Persimmon PERSIMMON PRUNING PERSIMMON PRUNING Crop Name County orchard removal Yuba orchard removal Total other fruits and vegetables IMPERIAL other fruits and vegetables Total peaches Butte peaches FRESNO peaches KERN peaches KINGS peaches MADERA peaches MERCED peaches Placer peaches Sacramento peaches SAN JOAQUIN peaches STANISLAUS peaches Sutter peaches Tehama peaches TULARE peaches Yuba peaches Total peanuts MERCED peanuts Total pears Butte pears FRESNO pears KERN pears pears pears pears pears pears pears pears pears Total peas; dry edible peas; dry edible Total pecans pecans pecans pecans pecans pecans pecans pecans pecans pecans pecans pecans Total persimmons persimmons persimmons RL (tons/acre) 15 1.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 1.2 2.6 2.6 2.6 Lake MADERA MERCED Placer Sacramento SAN JOAQUIN STANISLAUS TULARE 2.6 2.6 2.6 2.6 2.6 2.6 2.6 2.6 FRESNO 2.5 Butte COLUSA FRESNO KERN KINGS MADERA MERCED SAN JOAQUIN STANISLAUS Tehama TULARE 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 Butte FRESNO KERN 1.7 1.7 1.7 A_BURN (acres) 152 5,624 126 126 175 2,922 420 894 377 631 11 8 112 1,146 139 31 1,394 40 8,299 4 4 13 48 21 5,249 1 1 21 262 19 1,170 6,804 1 1 11 41 648 395 44 53 5 29 138 455 1,819 13 130 1 Year Burned 1996 1996 1996 1999 1999 1999 1999 1999 1996 1996 1999 1999 1996 1996 1999 1996 1999 1996 1999 1999 1997 1999 1999 1996 1996 1999 1999 1999 1999 1996 1996 1999 1999 1999 1999 1999 1999 1999 1996 1999 1996 1999 1999 Page 6 of 10 R_BURN (tons) 2,280 84,359 191 191 438 7,480 1,064 2,356 942 1,678 28 20 454 3,010 348 78 4,947 100 22,940 5 5 34 124 68 13,647 1 3 55 680 74 3 3,061 17,748 1 1 19 71 1,106 673 80 90 13 7 51 235 842 3,186 21 228 2 Comments Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by ICUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD CALIFORNIA Residue Name PERSIMMON PRUNING PERSIMMON PRUNING Persimmon PERSIMMON PRUNING PERSIMMON PRUNING PERSIMMON PRUNING Pistachio PISTACHIO PISTACHIO PISTACHIO PISTACHIO PISTACHIO PISTACHIO PISTACHIO Pistachio PISTACHIO PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING PRUNING Plum Prune Prune PLUM PRUNING PLUOT PRUNING PRUNE PRUNING PLUM PRUNING PRUNE PRUNING PLUM PRUNING PRUNE PRUNING PLUM PRUNING PRUNE PRUNING PLUM PRUNING PRUNE PRUNING Plum Prune PLUM PRUNING PLUOT PRUNING PRUNE PRUNING PLUM PRUNING PRUNE PRUNING Prune Prune PLUM PRUNING PRUNE PRUNING Prune Prune POMEGRANATE POMEGRANATE POMEGRANATE POMEGRANATE POMEGRANATE PRUNING PRUNING PRUNING PRUNING PRUNING Crop Name persimmons persimmons persimmons persimmons persimmons persimmons persimmons Total pistachio pistachio pistachio pistachio pistachio pistachio pistachio pistachio pistachio pistachio pistachio Total plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes plums and prunes Total pomegranates pomegranates pomegranates pomegranates pomegranates County MADERA MERCED Placer SAN JOAQUIN STANISLAUS TULARE RL (tons/acre) 1.7 1.7 1.7 1.7 1.7 1.7 Butte FRESNO KERN KINGS MADERA MERCED SAN JOAQUIN STANISLAUS Tehama TULARE 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 Butte Butte COLUSA FRESNO FRESNO FRESNO KERN KERN KINGS KINGS MADERA MADERA MERCED MERCED Placer Placer SAN JOAQUIN SAN JOAQUIN SAN JOAQUIN STANISLAUS STANISLAUS Sutter Tehama TULARE TULARE Yolo Yuba 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 FRESNO KERN KINGS MADERA MERCED 1.7 1.7 1.7 1.7 1.7 A_BURN (acres) 15 1 6 127 50 342 74 543 793 872 8,638 1,473 41 21 410 12,862 5 1,708 872 2,030 28 1,069 152 70 129 26 113 611 38 258 13 73 3 1 7 4 346 4,821 2,319 1,386 1,751 113 17,943 149 100 22 54 - Year Burned 1999 1999 1996 1999 1999 1999 1996 1999 1999 1999 1999 1999 1999 1999 1996 1999 1996 1996 1996 1999 1999 1999 1999 1999 1999 1999 1999 1999 1999 1999 1996 1996 1999 1999 1999 1999 1999 1996 1996 1999 1999 1996 1996 1999 1999 1999 1999 1999 Page 7 of 10 R_BURN (tons) 26 2 10 5 215 123 631 125 957 1,872 1,530 15,828 2,643 13 75 35 1,060 24,136 6 2,050 1,046 3,427 34 1,300 245 94 171 31 135 739 71 382 16 88 9 1 49 9 2 415 5,785 4,408 2,403 2,101 136 25,152 256 177 37 99 4 Comments Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD CALIFORNIA Residue Name POMEGRANATE PRUNING POMEGRANATE PRUNING QUINCE QUINCE Rice Rice-Wild Rice RICE Rice Rice, wild RICE Rice RICE RICE RICE Rice Rice Rice Rice Rye Safflower Safflower SAFFLOWER SAFFLOWER SAFFLOWER Safflower SAFFLOWER Safflower Safflower Safflower Grass Grass bermuda Clover Grass Grass GRASS SUDAN SORGHUM (MILO) SORGHUM (MILO) Milo sudan SUDAN Crop Name pomegranates pomegranates pomegranates Total quinces quinces quinces Total rice; all rice; all rice; all rice; all rice; all County STANISLAUS TULARE RL (tons/acre) 1.7 1.7 KINGS TULARE 1.7 1.7 Butte Butte COLUSA FRESNO Glenn 3 3 3 3 3 rice; all rice; all rice; all rice; all rice; all rice; all rice; all rice; all rice; all rice; all rice; all Total rye rye Total safflower safflower safflower safflower safflower safflower safflower safflower safflower safflower safflower Total seeds; other seeds; other seeds; other seeds; other seeds; other seeds; other seeds; other seeds; other seeds; other Total sorghum sorghum sorghum sorghum Total sudan sudan Lake MERCED Placer Sacramento SAN JOAQUIN STANISLAUS Sutter Tehama Yolo Yuba 3 3 3 3 3 3 3 3 3 3 Placer 1.9 Butte COLUSA FRESNO KERN KINGS Sacramento SAN JOAQUIN Sutter Tehama Yolo 1.3 1.3 1.3 1.3 1.3 1.3 1.3 1.3 1.3 1.3 Butte COLUSA IMPERIAL Placer Placer Tehama TULARE TULARE 2 2 2 2 2 2 2 2 MERCED SAN JOAQUIN Tehama 2.9 2.9 2.9 IMPERIAL Sacramento 2 2 A_BURN (acres) 1 79 406 3 14 17 45,945 753 53,366 8,578 50,576 60 4,110 6,623 6,631 5,151 3,466 42,112 704 7,737 18,953 254,763 65 65 20 3,839 337 2 6 54 367 301 15 201 5,142 614 130 24,612 40 16 1 1 7 25,421 2 60 62 2,283 595 Year Burned 1999 1999 1999 1999 1996 1996 1996 1999 1996 1997 1999 1996 1996 1999 1999 1996 1996 1996 1996 1996 1996 1996 1999 1999 1999 1996 1999 1996 1996 1996 1996 1996 1996 1996 1996 1996 1999 1999 1999 1999 1996 1996 1996 Page 8 of 10 R_BURN (tons) 2 310 885 5 45 51 137,835 2,259 160,098 25,734 151,727 180 12,330 19,869 19,892 15,456 10,397 126,336 2,111 23,211 56,859 764,293 124 124 26 4,991 438 3 8 70 479 391 20 261 6,686 1,228 260 49,224 80 32 2 2 14 50,842 2 6 174 182 4,566 1,190 Comments Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by ICUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by ICUAPCD Daily A_BURN provided by Fife, 2002 CALIFORNIA Residue Name Walnut Walnut WALNUT PRUNING WALNUT PRUNING WALNUT PRUNING Crop Name sudan Total sugarcane sugarcane Total unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified Total walnuts walnuts walnuts walnuts walnuts orchard removal Walnuts WALNUT WALNUT Walnut Walnut WALNUT WALNUT Walnut Walnut WALNUT Walnut Walnut SUGAR CANE OTHER-MISCELLANEOUS Unspecified FERT/PESTICIDE SACKS ROSE PRUNING Unspecified Unspecified Miscellaneous FLOOD DEBRIS SLASH Miscellaneous PRUNING PRUNING PRUNING PRUNING PRUNING Other Field Crops Wheat Other Field Crops Wheat WHEAT Wheat wheat WHEAT WHEAT WHEAT WHEAT Wheat Other Field Crops Wheat WHEAT WHEAT County FRESNO RL (tons/acre) 14 COLUSA FRESNO KERN KERN KERN MERCED Placer TULARE TULARE Yolo Butte COLUSA FRESNO KERN KINGS 1.2 1.2 1.2 1.2 1.2 walnuts Lake 15 walnuts walnuts walnuts walnuts walnuts walnuts walnuts walnuts walnuts walnuts walnuts walnuts walnuts Total wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all Lake MADERA MERCED Placer Sacramento SAN JOAQUIN STANISLAUS Sutter Tehama TULARE Yolo Yuba 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 Butte Butte COLUSA COLUSA FRESNO Glenn IMPERIAL KERN KINGS MADERA MERCED Placer Sacramento Sacramento SAN JOAQUIN STANISLAUS 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 A_BURN (acres) 2,878 0 0 1,206 2 2,312 3,520 3,044 384 5,055 171 6,027 Year Burned 1999 1996 1999 1999 1999 1999 1999 1996 1999 1999 1996 R_BURN (tons) 5,756 4 4 700 1997 10,500 1996 1996 1996 1996 1999 1996 1996 1999 1999 1999 1999 1996 1996 1996 1999 1999 Page 9 of 10 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 1996 1996 1999 1999 1999 1997 1999 1999 1996 1996 1999 1999 1996 1996 1999 1996 1996 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 25 1 40 3,038 2 5 3 3,114 3,653 461 6,117 318 7,467 6,224 956 1,988 131 1 7,838 13,809 418 3,254 10,884 2,463 45 63,391 109 2,888 1 6,134 1,388 12 71,795 7,145 5,719 1,879 1,476 21 3 1,491 2,917 182 Comments 7,469 1,157 5,914 157 1 25,004 20,659 502 3,905 16,931 2,956 54 113,223 207 5,486 2 11,655 2,637 23 136,395 13,595 10,866 3,570 2,804 40 5 2,832 6,315 346 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" A_BURN data taken from WRAP/ECR (WRAP, 2001) survey which references "1997 Lake Co. AQMD Agricultural and Opening Burning Report" Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by ICUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN and/or R_BURN provided by SJVUAPCD CALIFORNIA Residue Name Wheat Wheat WHEAT Other Field Crops Wheat Other Field Crops Crop Name wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all Total Grand Total County Sutter Tehama TULARE Yolo Yolo Yuba RL (tons/acre) 1.9 1.9 1.9 1.9 1.9 1.9 A_BURN (acres) 414 1,215 8,367 721 3,685 234 117,794 893,405 Year Burned 1996 1996 1999 1996 1996 1996 Page 10 of 10 R_BURN (tons) 787 2,309 16,021 1,369 7,002 445 224,709 1,898,134 Comments Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN and/or R_BURN provided by SJVUAPCD Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 Daily A_BURN provided by Fife, 2002 COLORADO Residue Name wheat; other spring (irrigated) Crop Name wheat; other spring-CO County Mesa RL (tons/acre) 4 A_BURN (acres) Year Burned 500 Avg Page 1 of 1 R_BURN (tons) 2,000 Comments A_BURN and RL per J.Sharkoffl, NRCS in CO. HAWAII Residue Name Crop Name County pineapple pineapple Honolulu pineapple pineapple pineapple Total sugarcane sugarcane sugarcane sugarcane sugarcane Total Grand Total Maui & Kalwao sugarcane sugarcane sugarcane sugarcane Hawaii Honolulu Kauai Maui & Kalwao RL (tons/acre) 14 14 14 14 A_BURN (acres) Year Burned 7,000 1996 6,000 13,000 909 3,357 11,678 14,056 30,000 43,000 1996 1996 1996 1996 1996 Page 1 of 1 R_BURN (tons) Comments RL on pineapple is undetermined; Maui Pineapple Co. indicates 13,000 acres burned/year RL on pineapple is undetermined; Maui Pineapple Co. indicates 13,000 acres burned/year 12,727 46,993 163,496 196,783 420,000 420,000 Annual A_BURN from L.Young, HI Dept of Health Annual A_BURN from L.Young, HI Dept of Health Annual A_BURN from L.Young, HI Dept of Health Annual A_BURN from L.Young, HI Dept of Health IDAHO Residue Name alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed alfalfa seed barley barley barley barley barley barley barley barley barley barley Crop Name seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa Total barley barley barley barley barley barley barley barley barley barley RL (tons/acre) County Ada 0.8 Adams 0.8 Bannock 0.8 Bear Lake 0.8 Bingham 0.8 Blaine 0.8 Boise 0.8 Bonneville 0.8 Butte 0.8 Camas 0.8 Canyon 0.8 Caribou 0.8 Cassia 0.8 Clark 0.8 Custer 0.8 Elmore 0.8 Franklin 0.8 Fremont 0.8 Gem 0.8 Gooding 0.8 Jefferson 0.8 Jerome 0.8 Lemhi 0.8 Lincoln 0.8 Madison 0.8 Minidoka 0.8 Oneida 0.8 Owyhee 0.8 Payette 0.8 Power 0.8 Teton 0.8 Twin Falls 0.8 Valley 0.8 Washington 0.8 Ada Adams Bannock Bear Lake Benewah Bingham Blaine Bonner Bonneville Boundary 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 A_BURN (acres) 202 53 155 263 463 143 18 250 229 370 368 217 445 154 213 310 362 190 121 310 732 329 194 154 154 223 241 389 114 77 135 560 20 218 8,376 501 95 1,353 2,260 663 3,180 2,287 162 8,255 826 Year Burned 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 Page 1 of 5 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 R_BURN (tons) 162 42 124 210 370 114 14 200 183 296 294 174 356 123 170 248 290 152 97 248 586 263 155 123 123 178 193 311 91 62 108 448 16 174 6,701 851 161 2,301 3,842 1,127 5,406 3,888 276 14,034 1,403 Comments Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ IDAHO Residue Name barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley bluegrass bluegrass bluegrass bluegrass bluegrass bluegrass ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank Crop Name barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley barley Total seeds; KBG seeds; KBG seeds; KBG seeds; KBG seeds; KBG seeds; KBG seeds; KBG Total ditches and ditch banks ditches and ditch banks ditches and ditch banks ditches and ditch banks ditches and ditch banks ditches and ditch banks RL (tons/acre) County Butte 1.7 Camas 1.7 Canyon 1.7 Caribou 1.7 Cassia 1.7 Clark 1.7 Clearwater 1.7 Custer 1.7 Elmore 1.7 Franklin 1.7 Fremont 1.7 Gem 1.7 Gooding 1.7 Idaho 1.7 Jefferson 1.7 Jerome 1.7 Kootenai 1.7 Latah 1.7 Lemhi 1.7 Lewis 1.7 Lincoln 1.7 Madison 1.7 Minidoka 1.7 Nez Perce 1.7 Oneida 1.7 Owyhee 1.7 Payette 1.7 Power 1.7 Teton 1.7 Twin Falls 1.7 Washington 1.7 Benewah Idaho Kootenai Latah Lewis Nez Perce 2 2 2 2 2 2 Ada Adams Bannock Bear Lake Benewah Bingham 3.2 3.2 3.2 3.2 3.2 3.2 A_BURN (acres) 2,098 1,326 1,123 10,677 3,519 149 798 433 798 2,625 8,661 338 731 2,883 5,007 2,016 541 3,397 95 3,532 1,150 5,941 4,412 3,302 2,314 961 122 1,326 4,899 3,640 392 98,790 8,886 1,982 26,223 3,439 7,687 1,783 50,000 1,271 441 1,753 962 142 3,156 Year Burned 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 Page 2 of 5 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 R_BURN (tons) 3,566 2,255 1,909 18,152 5,982 253 1,357 736 1,357 4,463 14,724 575 1,242 4,900 8,512 3,428 920 5,774 161 6,005 1,956 10,100 7,500 5,613 3,934 1,633 207 2,255 8,328 6,189 667 167,943 17,771 3,965 52,446 6,877 15,375 3,566 100,000 4,067 1,411 5,610 3,078 454 10,099 Comments Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ IDAHO Residue Name ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank ditchbank mint mint mint mint mint mint RL (tons/acre) Crop Name County ditches and ditch banks Blaine 3.2 ditches and ditch banks Boise 3.2 ditches and ditch banks Bonner 3.2 ditches and ditch banks Bonneville 3.2 ditches and ditch banks Boundary 3.2 ditches and ditch banks Butte 3.2 ditches and ditch banks Camas 3.2 ditches and ditch banks Canyon 3.2 ditches and ditch banks Caribou 3.2 ditches and ditch banks Cassia 3.2 ditches and ditch banks Clark 3.2 ditches and ditch banks Clearwater 3.2 ditches and ditch banks Custer 3.2 ditches and ditch banks Elmore 3.2 ditches and ditch banks Franklin 3.2 ditches and ditch banks Fremont 3.2 ditches and ditch banks Gem 3.2 ditches and ditch banks Gooding 3.2 ditches and ditch banks Idaho 3.2 ditches and ditch banks Jefferson 3.2 ditches and ditch banks Jerome 3.2 ditches and ditch banks Kootenai 3.2 ditches and ditch banks Latah 3.2 ditches and ditch banks Lemhi 3.2 ditches and ditch banks Lewis 3.2 ditches and ditch banks Lincoln 3.2 ditches and ditch banks Madison 3.2 ditches and ditch banks Minidoka 3.2 ditches and ditch banks Nez Perce 3.2 ditches and ditch banks Oneida 3.2 ditches and ditch banks Owyhee 3.2 ditches and ditch banks Payette 3.2 ditches and ditch banks Power 3.2 ditches and ditch banks Shoshone 3.2 ditches and ditch banks Teton 3.2 ditches and ditch banks Twin Falls 3.2 ditches and ditch banks Valley 3.2 ditches and ditch banks Washington 3.2 ditches and ditch banks Total mint Ada 0.5 mint Butte 0.5 mint Canyon 0.5 mint Custer 0.5 mint Owyhee 0.5 mint Payette 0.5 A_BURN (acres) 735 63 125 2,611 126 643 901 2,379 2,218 3,341 613 70 859 1,022 1,469 1,549 489 935 419 1,978 1,479 222 478 981 321 743 1,520 1,690 477 1,778 1,413 648 2,802 2 886 2,745 561 988 50,004 192 11 379 23 23 71 Year Burned 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 Page 3 of 5 1996 1996 1996 1996 1996 1996 R_BURN (tons) 2,352 202 400 8,355 403 2,058 2,883 7,613 7,098 10,691 1,962 224 2,749 3,270 4,701 4,957 1,565 2,992 1,341 6,330 4,733 710 1,530 3,139 1,027 2,378 4,864 5,408 1,526 5,690 4,522 2,074 8,966 6 2,835 8,784 1,795 3,162 160,013 96 6 190 12 12 36 Comments Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ IDAHO Residue Name mint wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat wheat Crop Name mint mint Total wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all Total Grand Total RL (tons/acre) County Washington 0.5 Ada Bannock Bear Lake Benewah Bingham Blaine Bonneville Boundary Butte Camas Canyon Caribou Cassia Clark Clearwater Elmore Franklin Fremont Gem Gooding Idaho Jefferson Jerome Kootenai Latah Lewis Lincoln Madison Minidoka Nez Perce Oneida Owyhee Payette Power Teton Twin Falls Washington 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 A_BURN (acres) 4 703 1,763 6,254 1,154 4,047 19,397 330 9,464 2,207 1,395 406 5,848 5,607 15,210 1,916 926 2,880 2,791 5,379 964 2,093 8,157 6,381 5,480 3,108 11,963 8,411 2,588 6,178 6,698 12,052 5,785 1,256 1,446 17,608 1,142 7,916 1,700 197,900 405,773 Year Burned 1996 Page 4 of 5 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 R_BURN (tons) 2 352 3,350 11,883 2,193 7,689 36,854 627 17,981 4,194 2,651 771 11,112 10,654 28,900 3,640 1,760 5,471 5,303 10,220 1,832 3,977 15,498 12,124 10,413 5,905 22,729 15,980 4,917 11,738 12,726 22,898 10,991 2,386 2,748 33,455 2,169 15,040 3,230 376,010 811,018 Comments Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ Annual A_BURN provided by D.Riley IDEQ MONTANA Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) Comments wheat; all (irrigated) wheat; all Beaverhead 1.9 80 1996 150 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Big Horn 1.9 130 1996 245 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Blaine 1.9 125 1996 235 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Broadwater 1.9 180 1996 340 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Carbon 1.9 25 1996 45 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Cascade 1.9 90 1996 170 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Chouteau 1.9 35 1996 65 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Custer 1.9 50 1996 95 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Daniels 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Dawson 1.9 40 1996 75 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Deerlodge 1.9 15 1996 30 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Fergus 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Flathead 1.9 75 1996 145 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Gallatin 1.9 165 1996 315 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Garfield 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Glacier 1.9 50 1996 100 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Golden Valley 1.9 20 1996 40 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Hill 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Jefferson 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Judith Basin 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Lake 1.9 135 1996 255 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Lewis And Clark 1.9 25 1996 50 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Liberty 1.9 20 1996 40 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Madison 1.9 80 1996 150 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all McCone 1.9 45 1996 85 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Meagher 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Mineral 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Missoula 1.9 15 1996 30 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Musselshell 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Park 1.9 20 1996 40 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Petroleum 1.9 20 1996 40 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Phillips 1.9 55 1996 105 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Pondera 1.9 210 1996 400 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ Page 1 of 2 MONTANA Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) Comments wheat; all (irrigated) wheat; all Powder River 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Powell 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Prairie 1.9 50 1996 95 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Ravalli 1.9 15 1996 30 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Richland 1.9 180 1996 340 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Roosevelt 1.9 40 1996 75 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Rosebud 1.9 45 1996 85 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Sanders 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Sheridan 1.9 30 1996 55 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Stillwater 1.9 15 1996 30 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Sweet Grass 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Teton 1.9 175 1996 330 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Toole 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Treasure 1.9 40 1996 75 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Valley 1.9 175 1996 330 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Wheatland 1.9 10 1996 20 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all Wibaux 1.9 5 1996 10 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ wheat; all (irrigated) wheat; all wheat; all Total Grand Total Yellowstone 1.9 65 2,655 2,655 1996 125 5,055 5,055 Page 2 of 2 A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ Residue Name Crop Name County RL (tons/acre) NORTH_DAKOTA A_BURN Year (acres) Burned R_BURN (tons) wheat; all wheat; all Barnes 1.9 18,855 Avg 35,826 wheat; all wheat; all Benson 1.9 14,976 Avg 28,455 wheat; all wheat; all Cass 1.9 24,066 Avg 45,726 wheat; all wheat; all Cavalier 1.9 22,360 Avg 42,483 wheat; all wheat; all Eddy 1.9 4,623 Avg 8,784 wheat; all wheat; all Foster 1.9 8,164 Avg 15,513 wheat; all wheat; all Grand Forks 1.9 11,742 Avg 22,311 wheat; all wheat; all Griggs 1.9 6,817 Avg 12,954 wheat; all wheat; all Nelson 1.9 10,244 Avg 19,464 wheat; all wheat; all Pembina 1.9 11,370 Avg 21,600 wheat; all wheat; all Ramsey 1.9 13,208 Avg 25,095 wheat; all wheat; all Steele 1.9 8,928 Avg 16,965 wheat; all wheat; all Stutsman 1.9 23,275 Avg 44,223 wheat; all wheat; all Towner 1.9 14,123 Avg 26,835 wheat; all wheat; all Traill 1.9 10,499 Avg 19,947 wheat; all wheat; all Walsh wheat; all Total Grand Total 1.9 12,612 Avg 215,862 215,862 23,964 410,145 410,145 Page 1 of 1 Comments A_BURN based on gapfilling 5.2% of AH are burned. A_BURN based on gapfilling 5.2% of AH are burned. A_BURN based on gapfilling 5.2% of AH are burned. A_BURN based on gapfilling 5.2% of AH are burned. A_BURN based on gapfilling 5.2% of AH are burned. average, average, average, average, average, A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN approx.10-12,000 acres (or 75% of gapfilling avg. 5.2% AH burned). Based on comment from NRCS/District Conservationist A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN approx.10-12,000 acres (or 75% of gapfilling avg. 5.2% AH burned). Based on comment from NRCS/District Conservationist A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN based on gapfilling average, 5.2% of AH are burned. A_BURN approx.10-12,000 acres (or 75% of gapfilling avg. 5.2% AH burned). Based on comment from NRCS/District Conservationist NEW_MEXICO Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) Comments 72 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. 3,752 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. 8 Avg 12 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. 1.5 140 Avg 212 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. Eddy 1.5 4 Avg 8 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. wheat; all Guadalupe 1.5 56 Avg 84 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. wheat; all wheat; all Harding 1.5 16 Avg 24 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. wheat; all wheat; all Lea 1.5 124 Avg 188 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. wheat; all wheat; all Quay 1.5 156 Avg 236 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. wheat; all wheat; all Roosevelt 1.5 764 Avg 1,148 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. wheat; all wheat; all wheat; all Total Grand Total Union 1.5 548 Avg 4,364 4,364 824 6,560 6,560 wheat; all wheat; all Chaves 1.5 wheat; all wheat; all Curry 1.5 wheat; all wheat; all De Baca 1.5 wheat; all wheat; all Dona Ana wheat; all wheat; all wheat; all 48 Avg 2,500 1996 Page 1 of 1 RL per R.Shaw, NRCS (Shaver, 2002); A_BURN based on gap filling avg.,5.2% of AH are burned. NEVADA Residue Name unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified Crop Name unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified Grand Total County Churchill Douglas Elko Eureka Humboldt Lander Lincoln Lyon Pershing Washoe White Pine RL (tons/acre) A_BURN (acres) 195 877 144 765 12,535 150 170 206 5,820 80 10 20,952 Year Burned 1998 1998 1998 1998 1998 1998 1998 1998 1998 1998 1998 R_BURN (tons) A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP A_BURN by county provided by C.Sergent, NDEP Unknown Page 1 o f 1 Comments A_BURN by county provided by C.Sergent, NDEP OREGON Residue Name Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley Barley cereal cereal cereal cereal cereal cereal cereal cereal cereal cereal Oats Oats Oats Oats Oats Oats Oats Oats Oats Oats Oats Oats Oats Oats Oats grain; grain; grain; grain; grain; grain; grain; grain; grain; grain; unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified Crop Name County barley CLACKAMAS barley DOUGLAS barley GILLIAM barley HARNEY barley KLAMATH barley LINN barley MALHEUR barley MARION barley MORROW barley POLK barley SHERMAN barley UMATILLA barley UNION barley WALLOWA barley WASCO barley WHEELER barley YAMHILL barley Total corn; for grain CLACKAMAS corn; for grain GILLIAM corn; for grain KLAMATH corn; for grain LINN corn; for grain MALHEUR corn; for grain MARION corn; for grain MORROW corn; for grain UMATILLA corn; for grain UNION corn; for grain WASCO corn; for grain Total oats CLACKAMAS oats DOUGLAS oats GILLIAM oats HARNEY oats KLAMATH oats LINN oats MALHEUR oats MARION oats POLK oats SHERMAN oats UMATILLA oats UNION oats WALLOWA oats WASCO oats YAMHILL RL (tons/acre) 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 A_BURN (acres) Year Burned 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 4.2 4.2 4.2 4.2 4.2 4.2 4.2 4.2 4.2 4.2 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1.6 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 Page 1 of 3 R_BURN (tons) 18 9 6,183 54 4,176 153 1,179 306 108 9 1,035 4,086 909 2,394 594 9 225 21,429 18 36 27 81 2,700 153 81 1,971 36 9 5,112 288 9 297 18 999 927 81 3,645 126 9 18 45 36 18 1,386 Comments Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ OREGON Residue Name grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; grasses; Wheat Wheat Wheat Wheat Wheat Wheat Wheat Wheat Wheat Wheat Wheat Wheat Wheat unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified (field burning) (propaning) (stack burning) (field burning) (propaning) (stack burning) (field burning) (field burning) (field burning) (field burning) (field burning) (propaning) (stack burning) (field burning) (propaning) (stack burning) (field burning) (propaning) (stack burning) (field burning) (propaning) (stack burning) (field burning) (field burning) (propaning) (stack burning) (field burning) (propaning) (stack burning) Crop Name oats Total seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all County BENTON BENTON BENTON CLACKAMAS CLACKAMAS CLACKAMAS CROOK DOUGLAS HARNEY JEFFERSON LANE LANE LANE LINN LINN LINN MARION MARION MARION POLK POLK POLK UMATILLA UNION UNION WASHINGTON YAMHILL YAMHILL YAMHILL Total BAKER CROOK DESCHUTES GILLIAM JACKSON JEFFERSON KLAMATH MALHEUR MORROW SHERMAN UMATILLA UNION WALLOWA RL (tons/acre) A_BURN (acres) Year Burned 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 Page 2 of 3 R_BURN (tons) 7,902 37,116 45 1,728 9,270 252 594 45 351 36 46,899 31,662 9 2,430 267,897 1,566 4,266 139,836 873 14,004 15,138 36 11,016 1,863 6,597 378 45 12,906 45 4,122 611,025 1,998 342 36 20,682 8,829 85,041 1,143 21,771 3,276 9,252 64,701 10,179 1,683 Comments Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ Annual R_BURN provided by B.Finneran ODEQ OREGON Residue Name Wheat Crop Name wheat; all wheat; all Total Grand Total County WASCO RL (tons/acre) 1.9 A_BURN (acres) Page 3 of 3 Year Burned 1996 R_BURN (tons) 15,822 244,755 890,223 Comments Annual R_BURN provided by B.Finneran ODEQ SOUTH_DAKOTA Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) barley barley Aurora 1.7 176 Avg 299 barley barley Beadle 1.7 88 Avg 150 barley barley Bon Homme 1.7 88 Avg 150 barley barley Brookings 1.7 56 Avg 95 barley barley Brown 1.7 968 Avg 1,646 barley barley Brule 1.7 128 Avg 218 barley barley Campbell 1.7 560 Avg 952 barley barley Charles Mix 1.7 96 Avg 163 barley barley Clark 1.7 64 Avg 109 barley barley Codington 1.7 400 Avg 680 barley barley Davison 1.7 60 Avg 102 barley barley Day 1.7 528 Avg 898 barley barley Deuel 1.7 80 Avg 136 barley barley Douglas 1.7 88 Avg 150 barley barley Edmunds 1.7 608 Avg 1,034 barley barley Faulk 1.7 448 Avg 762 barley barley Hand 1.7 432 Avg 734 barley barley Hanson 1.7 64 Avg 109 barley barley Hughes 1.7 88 Avg 150 barley barley Hutchinson 1.7 48 Avg 82 barley barley Hyde 1.7 208 Avg 354 barley barley Jerauld 1.7 144 Avg 245 barley barley Kingsbury 1.7 56 Avg 95 barley barley Marshall 1.7 208 Avg 354 barley barley McPherson 1.7 816 Avg 1,387 barley barley Miner 1.7 60 Avg 102 barley barley Potter 1.7 416 Avg 707 barley barley Roberts 1.7 656 Avg 1,115 barley barley Sanborn 1.7 56 Avg 95 barley barley Spink 1.7 224 Avg 381 barley barley Turner 1.7 40 Avg 68 barley barley barley Total Walworth 1.7 376 Avg 8,328 639 14,158 Page 1 of 3 Comments A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 8.0% of A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 8.0% of A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 8.0% of A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of A_BURN based on gapfilling avg., 8.0% of AH are burned. A_BURN based on gapfilling avg., 8.0% of AH are burned. A_BURN based on gapfilling avg., 8.0% of AH are burned. A_BURN based on gapfilling avg., 8.0% of AH are burned. A_BURN based on gapfilling avg., 8.0% of AH are burned. A_BURN based on gapfilling avg., 8.0% of AH are burned. A_BURN based on gapfilling avg., 8.0% of AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of gapfilling avg., 8.0% of SOUTH_DAKOTA Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) wheat; winter all wheat; winter all Aurora 1.9 1,492 Avg 2,834 wheat; winter all wheat; winter all Beadle 1.9 2,584 Avg 4,910 wheat; winter all wheat; winter all Bon Homme 1.9 380 Avg 722 wheat; winter all wheat; winter all Brookings 1.9 94 Avg 178 wheat; winter all wheat; winter all Brown 1.9 348 Avg 662 wheat; winter all wheat; winter all Brule 1.9 2,564 Avg 4,872 wheat; winter all wheat; winter all Buffalo 1.9 328 Avg 624 wheat; winter all wheat; winter all Campbell 1.9 510 Avg 970 wheat; winter all wheat; winter all Charles Mix 1.9 2,678 Avg 5,088 wheat; winter all wheat; winter all Clark 1.9 728 Avg 1,384 wheat; winter all wheat; winter all Clay 1.9 62 Avg 118 wheat; winter all wheat; winter all Codington 1.9 124 Avg 236 wheat; winter all wheat; winter all Davison 1.9 1,488 Avg 2,828 wheat; winter all wheat; winter all Day 1.9 182 Avg 346 wheat; winter all wheat; winter all Deuel 1.9 42 Avg 80 wheat; winter all wheat; winter all Douglas 1.9 1,550 Avg 2,946 wheat; winter all wheat; winter all Edmunds 1.9 722 Avg 1,372 wheat; winter all wheat; winter all Faulk 1.9 858 Avg 1,630 wheat; winter all wheat; winter all Grant 1.9 68 Avg 130 wheat; winter all wheat; winter all Hamlin 1.9 120 Avg 228 wheat; winter all wheat; winter all Hand 1.9 3,308 Avg 6,286 wheat; winter all wheat; winter all Hanson 1.9 812 Avg 1,542 wheat; winter all wheat; winter all Hughes 1.9 3,504 Avg 6,658 wheat; winter all wheat; winter all Hutchinson 1.9 1,180 Avg 2,242 wheat; winter all wheat; winter all Hyde 1.9 1,778 Avg 3,378 wheat; winter all wheat; winter all Jerauld 1.9 1,004 Avg 1,908 wheat; winter all wheat; winter all Kingsbury 1.9 890 Avg 1,692 wheat; winter all wheat; winter all Lake 1.9 78 Avg 148 wheat; winter all wheat; winter all Lincoln 1.9 52 Avg 98 wheat; winter all wheat; winter all Marshall 1.9 162 Avg 308 wheat; winter all wheat; winter all McCook 1.9 72 Avg 136 wheat; winter all wheat; winter all McPherson 1.9 166 Avg 316 Page 2 of 3 Comments A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 5.2% of A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 5.2% of A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 5.2% of A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of SOUTH_DAKOTA Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) wheat; winter all wheat; winter all Miner 1.9 162 Avg 308 wheat; winter all wheat; winter all Minnehaha 1.9 10 Avg 20 wheat; winter all wheat; winter all Moody 1.9 10 Avg 20 wheat; winter all wheat; winter all Potter 1.9 3,812 Avg 7,242 wheat; winter all wheat; winter all Roberts 1.9 20 Avg 38 wheat; winter all wheat; winter all Sanborn 1.9 494 Avg 938 wheat; winter all wheat; winter all Spink 1.9 2,116 Avg 4,020 wheat; winter all wheat; winter all Sully 1.9 7,150 Avg 13,586 wheat; winter all wheat; winter all Turner 1.9 16 Avg 30 wheat; winter all wheat; winter all Union 1.9 26 Avg 50 wheat; winter all wheat; winter all Walworth 1.9 500 Avg 950 wheat; winter all wheat; winter all Yankton wheat; winter all Total Grand Total 1.9 36 Avg 44,280 52,608 68 84,140 98,298 Page 3 of 3 Comments A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 5.2% of A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. A_BURN based on AH are burned. gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of gapfilling avg., 5.2% of A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. A_BURN based on gapfilling avg., 5.2% of AH are burned. UTAH Residue Name barley barley barley ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches ditches and and and and and and and and and and and and and and and and and and and and and and and and and and and and and fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline fenceline Crop Name barley barley barley barley Total ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT ditches and ditch banks-UT County Box Elder Cache Weber Beaver Box Elder Cache Carbon Daggett Davis Duchesne Emery Garfield Grand Iron Juab Kane Millard Morgan Piute Rich Salt Lake San Juan Sanpete Sevier Summit Tooele Uintah Utah Wasatch Washingon Wayne Weber Total RL (tons/acre) 1.7 1.7 1.7 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 A_BURN (acres) 1,476 1,170 99 2,745 129 528 372 27 25 75 257 96 67 13 245 91 14 424 36 45 235 46 28 250 153 84 61 192 293 40 46 62 105 4,040 Year Burned 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 1996 R_BURN (tons) 2,511 1,998 162 4,671 97 396 279 20 19 56 193 72 50 10 184 68 10 318 27 34 177 34 21 188 115 63 46 144 219 30 35 46 79 3,030 orchard replacement orchard removal Box Elder 15 108 1996 1,620 orchard replacement orchard removal Cache 15 6 1996 90 orchard replacement orchard removal Carbon 15 3 1996 45 orchard replacement orchard removal Davis 15 16 1996 225 orchard replacement orchard removal Emery 15 2 1996 45 Page 1 of 2 Comments A_BURN provided by Veryl Peterson, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches UTAH Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) Comments orchard replacement orchard removal Garfield 15 3 1996 45 orchard replacement orchard removal Grand 15 3 1996 45 orchard replacement orchard removal Iron 15 3 1996 60 orchard replacement orchard removal Kane 15 6 1996 90 orchard replacement orchard removal Salt Lake 15 6 1996 90 orchard replacement orchard removal San Juan 15 3 1996 45 orchard replacement orchard removal Utah 15 540 1996 8,100 Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches 450 Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches 90 Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches 225 Annual A_BURN provided by K.Goodrich, NRCS (15,000/20years); distributed A_BURN over counties harvesting apples, cherries, peaches orchard replacement orchard replacement orchard replacement wheat wheat wheat orchard removal orchard removal orchard removal orchard removal Total wheat; all wheat; all wheat; all wheat; all Total Grand Total Washington Wayne Weber Box Elder Cache Weber 15 15 15 1.9 1.9 1.9 30 6 15 750 7,560 1,386 198 9,144 16,679 1996 1996 1996 1996 1996 1996 Page 2 of 2 11,265 14,364 2,637 378 17,379 36,345 A_BURN provided by Veryl Peterson, NRCS A_BURN provided by Kerry Goodrich, NRCS A_BURN provided by Kerry Goodrich, NRCS WASHINGTON Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) Comments Daily A_BURN provided in permit database from S.Nolph WDOE orchard (maintainence - no removal) apples apples Total Yakima 2.3 382 382 1999 879 879 asparagus asparagus asparagus Total Franklin 1.5 14 14 1999 21 21 buu - barley - unknown - unknown barley Adams 1.7 263 1999 446 bsu - barley - spring - unknown barley Columbia 1.7 5,509 1999 9,366 buu - barley - unknown - unknown barley Columbia 1.7 799 1999 1,358 bui - barley - unknown - irrigated barley Lincoln 1.7 195 1999 332 buu - barley - unknown - unknown barley Lincoln 1.7 45 1999 77 bwd - barley - winter - dryland barley Lincoln 1.7 20 1999 34 bsu - barley - spring - unknown barley Walla Walla 1.7 466 1999 792 buu - barley - unknown - unknown barley Walla Walla 1.7 200 1999 340 bsu - barley - spring - unknown barley Whitman 1.7 4,914 1999 8,354 buu - barley - unknown - unknown barley Whitman 1.7 201 1999 342 bwu - barley - winter - unknown barley barley Total Whitman 1.7 460 13,072 1999 782 22,223 beans beans; all dry edible Grant 2.5 65 1999 163 legumes beans; all dry edible Lincoln beans; all dry edible Total 2.5 33 98 1999 83 245 canola canola canola Total Lincoln 1.3 12 12 1999 16 16 orchard (maintainence - no removal) cherries cherries Total Yakima 1 88 88 1999 88 88 corn corn; for grain Franklin 4.2 312 1999 1,310 corn corn; for grain corn; for grain Total Franklin 4.2 476 788 1999 1,999 3,310 CRP Adams 2.6 9,573 1999 24,889 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Asotin 2.6 1,347 1999 3,502 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Columbia 2.6 3,366 1999 8,753 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Douglas 2.6 4,490 1999 11,673 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Franklin 2.6 1,342 1999 3,489 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Garfield 2.6 193 1999 502 Daily A_BURN provided in permit database from S.Nolph WDOE pasture CRP Garfield 2.6 40 1999 104 pasture crp - Conservation Reserve Program (CRP) conversion CRP Grant 2.6 70 1999 182 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Lincoln 2.6 5,062 1999 13,161 Daily A_BURN provided in permit database from S.Nolph WDOE pasture CRP Lincoln 2.6 45 1999 117 crp - Conservation conversion crp - Conservation conversion crp - Conservation conversion crp - Conservation conversion crp - Conservation conversion crp - Conservation conversion Reserve Program (CRP) Reserve Program (CRP) Reserve Program (CRP) Reserve Program (CRP) Reserve Program (CRP) Reserve Program (CRP) Page 1 of 6 Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE WASHINGTON Residue Name crp - Conservation Reserve Program (CRP) conversion crp - Conservation Reserve Program (CRP) conversion crp - Conservation Reserve Program (CRP) conversion Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) Comments CRP Stevens 2.6 40 1999 104 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Walla Walla 2.6 292 1999 759 Daily A_BURN provided in permit database from S.Nolph WDOE CRP Whitman 2.6 3,212 1999 8,352 Daily A_BURN provided in permit database from S.Nolph WDOE pasture CRP Whitman 2.6 94 1999 244 pasture CRP CRP Total Yakima 2.6 102 29,268 1999 265 76,096 fruits and vegetables; other Franklin 1.47 3 1999 4 Daily A_BURN provided in permit database from S.Nolph WDOE fruits and vegetables; other Pierce 1.47 17 1999 24 Daily A_BURN provided in permit database from S.Nolph WDOE onions fruits and vegetables; other Walla Walla fruits and vegetables; other Total 1.47 51 71 1999 75 104 grapes grapes grapes Total Yakima 2.5 205 205 1999 513 513 hau - hay - alfalfa - unknown hay; alfalfa Adams 0.8 55 1999 44 hai - hay - alfalfa - irrigated hay; alfalfa Grant 0.8 80 1999 64 hau - hay - alfalfa - unknown hay; alfalfa Grant 0.8 10 1999 8 hai - hay - alfalfa - irrigated hay; alfalfa Lincoln 0.8 58 1999 46 hau - hay - alfalfa - unknown hay; alfalfa hay; alfalfa Total Walla Walla 0.8 3,399 3,602 1999 2,719 2,882 hti - hay - timothy - irrigated hay; all other Kittitas 0.8 51 1999 41 hui - hay - unknown - irrigated hay; all other Kittitas 0.8 120 1999 96 hud - hay - unknown - dryland hay; all other Lincoln 0.8 45 1999 36 htd - hay - timothy - dryland hay; all other Whitman 0.8 73 1999 58 huu - hay - unknown- unknown hay; all other hay; all other Total Whitman 0.8 120 409 1999 96 327 hops hops hops Total Yakima 1.9 229 229 1999 435 435 oats oats Columbia 1.6 628 1999 1,005 oats oats oats Total Franklin 1.6 10 638 1999 16 1,021 christmas trees orchard pruning; unspecifiedPierce orchard pruning; unspecified Total 1.7 270 270 1999 459 459 orchard tree removal orchard removal Chelan 15 232 1999 3,476 orchard tree removal orchard removal Douglas 15 394 1999 5,915 orchard tree removal orchard removal Franklin 15 90 1999 1,346 orchard tree removal orchard removal Garfield 15 40 1999 600 orchard tree removal orchard removal Grant 15 337 1999 5,052 orchard tree removal orchard removal Kittitas 15 20 1999 300 berries - blueberries - raspberries blackberries berries - blueberries - raspberries blackberries Page 2 of 6 Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE WASHINGTON Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) orchard tree removal orchard removal Okanogan 15 5 1999 72 orchard tree removal orchard removal orchard removal Total Yakima 15 1,018 2,135 1999 15,263 32,024 orchard (maintainence - no removal) peaches peaches Total Yakima 2.5 21 21 1999 52 52 orchard (maintainence - no removal) pears pears Total Yakima 2.6 152 152 1999 395 395 peas peas; dry edible Walla Walla 2.5 50 1999 125 peas peas; dry edible peas; dry edible Total Whitman 2.5 148 198 1999 370 495 orchard (maintainence - no removal) plums and prunes plums and prunes Total Yakima 1.2 6 6 1999 7 7 hasi - hay - alfalfa seed - irrigated seeds; alfalfa Franklin 0.8 993 1999 794 hasi - hay - alfalfa seed - irrigated seeds; alfalfa Grant 0.8 326 1999 260 hasu - hay - alfalfa seed - unknown seeds; alfalfa seeds; alfalfa Total Walla Walla 0.8 1,130 2,449 1999 904 1,959 gsbu - grass seed - bluegrass - unknown seeds; KBG Garfield 2 73 1999 146 gsbu - grass seed - bluegrass - unknown seeds; KBG seeds; KBG Total Whitman 2 302 375 1999 604 750 gsbru - grass seed - brome - unknown seeds; other Columbia 2 62 1999 124 turnip - seed seeds; other Franklin 2 25 1999 50 turnip - seed seeds; other Grant 2 3 1999 6 gcd - grass cover - dryland seeds; other seeds; other Total Klickitat 2 107 197 1999 214 394 gsuu - grass seed - unknown - unknown seeds; unspecified Columbia 2 64 1999 128 gsuu - grass seed - unknown - unknown seeds; unspecified Garfield 2 20 1999 40 gsuu - grass seed - unknown - unknown seeds; unspecified Walla Walla 2 59 1999 118 gsuu - grass seed - unknown - unknown seeds; unspecified seeds; unspecified Total Whitman 2 128 271 1999 256 542 spot burning unspecified Adams 298 1999 spot burning unspecified Asotin 60 1999 CAUTION: not listed on internal permit unspecified Columbia 44 1999 CAUTION: not listed on outside permit unspecified Columbia 500 1999 spot burning unspecified Columbia 55 1999 spot burning unspecified Douglas 4 1999 CAUTION: not listed on internal permit unspecified Grant 105 1999 CAUTION: not listed on outside permit unspecified Grant 24 1999 spot burning unspecified Grant 25 1999 spot burning unspecified Lincoln 63 1999 Page 3 of 6 Comments Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE WASHINGTON Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) CAUTION: not listed on outside permit unspecified Snohomish 11 1999 CAUTION: not listed on internal permit unspecified Walla Walla 280 1999 CAUTION: not listed on outside permit unspecified Walla Walla 350 1999 spot burning unspecified Whatcom 10 1999 CAUTION: not listed on internal permit unspecified Whitman 581 1999 CAUTION: not listed on outside permit unspecified Whitman 375 1999 spot burning unspecified Whitman 3,395 1999 spot burning unspecified unspecified Total Yakima 853 7,032 1999 wsu - wheat - spring - unknown wheat; other spring Adams 1.9 52 1999 99 wsd - wheat - spring - dryland wheat; other spring Asotin 1.9 99 1999 188 wsu - wheat - spring - unknown wheat; other spring Columbia 1.9 1,717 1999 3,262 wsu - wheat - spring - unknown wheat; other spring Douglas 1.9 903 1999 1,716 wsi - wheat - spring - irrigated wheat; other spring Franklin 1.9 3,591 1999 6,823 wsi - wheat - spring - irrigated wheat; other spring Grant 1.9 1,613 1999 3,065 wsu - wheat - spring - unknown wheat; other spring Grant 1.9 743 1999 1,412 wsd - wheat - spring - dryland wheat; other spring Lincoln 1.9 105 1999 200 wsi - wheat - spring - irrigated wheat; other spring Lincoln 1.9 457 1999 868 wsu - wheat - spring - unknown wheat; other spring Lincoln 1.9 189 1999 359 wsd - wheat - spring - dryland wheat; other spring Walla Walla 1.9 90 1999 171 wsu - wheat - spring - unknown wheat; other spring Walla Walla 1.9 355 1999 675 wsi - wheat - spring - irrigated wheat; other spring Whitman 1.9 293 1999 557 wsu - wheat - spring - unknown wheat; other spring wheat; other spring Total Whitman 1.9 23,017 33,224 1999 43,732 63,125 wsu - wheat - unknown - unknown wheat; unspecified Adams 1.9 2,219 1999 4,216 wsd - wheat - unknown - dryland wheat; unspecified Asotin 1.9 70 1999 133 wsu - wheat - unknown - unknown wheat; unspecified Asotin 1.9 773 1999 1,468 wsu - wheat - unknown - unknown wheat; unspecified Columbia 1.9 1,488 1999 2,827 wsd - wheat - unknown - dryland wheat; unspecified Douglas 1.9 1,183 1999 2,248 wsu - wheat - unknown - unknown wheat; unspecified Douglas 1.9 1,454 1999 2,762 wsi - wheat - unknown - irrigated wheat; unspecified Franklin 1.9 948 1999 1,801 wsu - wheat - unknown - unknown wheat; unspecified Franklin 1.9 40 1999 76 pre-6/2/1999 value - wheat - dryland wheat; unspecified Grant 1.9 1,081 1999 2,054 pre-6/2/1999 value - wheat - irrigated wheat; unspecified Grant 1.9 65 1999 124 wsi - wheat - unknown - irrigated wheat; unspecified Grant 1.9 20 1999 38 wsu - wheat - unknown - unknown wheat; unspecified Grant 1.9 763 1999 1,450 wsi - wheat - unknown - irrigated wheat; unspecified Lincoln 1.9 25 1999 48 wsu - wheat - unknown - unknown wheat; unspecified Lincoln 1.9 170 1999 323 Page 4 of 6 Comments Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE - Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE WASHINGTON Residue Name Crop Name County RL (tons/acre) A_BURN (acres) Year Burned R_BURN (tons) pre-6/2/1999 value - wheat - dryland wheat; unspecified Okanogan 1.9 10 1999 19 wsu - wheat - unknown - unknown wheat; unspecified Walla Walla 1.9 1,973 1999 3,749 pre-6/2/1999 value - wheat - dryland wheat; unspecified Whitman 1.9 2,450 1999 4,655 wsi - wheat - unknown - irrigated wheat; unspecified Whitman 1.9 80 1999 152 wsu - wheat - unknown - unknown wheat; unspecified Whitman 1.9 10,426 1999 19,808 wsu - wheat - unknown - unknown wheat; unspecified wheat; unspecified Total Yakima 1.9 90 25,327 1999 171 48,121 wwu - wheat - winter - unknown wheat; winter all Adams 1.9 573 1999 1,089 wwd - wheat - winter - dryland wheat; winter all Asotin 1.9 148 1999 280 wwu - wheat - winter - unknown wheat; winter all Asotin 1.9 453 1999 860 wwi - wheat - winter - irrigated wheat; winter all Columbia 1.9 110 1999 209 wwu - wheat - winter - unknown wheat; winter all Columbia 1.9 44,672 1999 84,877 wwi - wheat - winter - irrigated wheat; winter all Douglas 1.9 115 1999 219 wwi - wheat - winter - irrigated wheat; winter all Franklin 1.9 1,809 1999 3,437 wwu - wheat - winter - unknown wheat; winter all Garfield 1.9 288 1999 546 wwi - wheat - winter - irrigated wheat; winter all Grant 1.9 2,061 1999 3,916 wwu - wheat - winter - unknown wheat; winter all Grant 1.9 254 1999 483 wwd - wheat - winter - dryland wheat; winter all Lincoln 1.9 11,980 1999 22,761 wwi - wheat - winter - irrigated wheat; winter all Lincoln 1.9 1,813 1999 3,445 wwu - wheat - winter - unknown wheat; winter all Lincoln 1.9 125 1999 238 wwd - wheat - winter - dryland wheat; winter all Walla Walla 1.9 90 1999 171 wwu - wheat - winter - unknown wheat; winter all Walla Walla 1.9 792 1999 1,505 wwu - wheat - winter - unknown wheat; winter all Whatcom 1.9 60 1999 114 wwi - wheat - winter - irrigated wheat; winter all Whitman 1.9 85 1999 162 wwu - wheat - winter - unknown wheat; winter all wheat; winter all Total Grand Total Whitman 1.9 52,399 117,825 238,356 1999 99,559 223,868 480,349 Page 5 of 6 Comments Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE WYOMING Residue Name barley seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; other Crop Name barley barley Total seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa Total seeds; other seeds; other Total Grand Total County Fremont Big Horn Hot Springs Park Park RL (tons/acre) 1.7 0.8 0.8 0.8 2 A_BURN (acres) 1,800 1,800 8,994 99 2,907 12,000 1,000 1,000 14,800 Year Burned 1998 1998 1998 1998 1998 R_BURN (tons) 3,060 3,060 7,195 79 2,326 9,600 2,000 2,000 14,660 Page 1 of 1 Comments A_BURN from WESTAR, 1999 (from Ron Cunningham, Coop Ext. Service) WESTAR, 1999 (from Fred Hopkin, Pres., WY Alfalfa Seed & Leaf Cutter Bee Asssn. WESTAR, 1999 (from Fred Hopkin, Pres., WY Alfalfa Seed & Leaf Cutter Bee Asssn. WESTAR, 1999 (from Fred Hopkin, Pres., WY Alfalfa Seed & Leaf Cutter Bee Asssn. A_BURN from WESTAR, 1999 (from Kelly Spiering) Averages-Overall State AZ CA CO ID MT ND NM OR SD UT WA WY Total or Average Wheat AH 178,000 A_BURN 8,080 688,000 2,268,000 1,560,000 117,794 500 197,900 6,360,000 12,515,000 110,000 920,000 2,650 215,862 4,364 128,816 3,854,000 185,000 2,745,000 236,000 44,280 9,144 176,366 - 31,619,000 905,756 State AZ CA CO ID MT ND OR SD UT WA WY Total or Average 6,900 54,000 A_BURN 0 - CO ID MT ND NM 2.9% Average Comments 0.0% None burned 0.0% None burned A_BURN counties: Fresno, Tulare, Merced, 0.5% Stanislaus, Kings, San Joaquin, Kern 0.0% None burned 13.5% 0.0% None burned 0.0% None burned 8.4% 5.7% A_BURN based on gap filling 2.7% 3.0% 1.5% 523 98,790 12,614 8,328 2,745 13,072 1,800 5,696,900 137,872 2.4% AH 42,900 A_BURN 30,000 Average 69.9% 42,900 30,000 AH 40,000 220,000 890,000 40,000 15,000 600,000 84,000 A_BURN 8,663 - Sugarcane State AZ CA 1.1% A_BURN based on gap filling (winter wheat, only) 4.9% 6.4% 0.0% None burned 109,000 92,000 730,000 1,150,000 2,600,000 150,000 145,000 100,000 440,000 120,000 State HI Total or Average 0.0% est. of 1% of irrigated wheat is burned 1.7% A_BURN based on gap filling 4.0% A_BURN based on gap filling 14.0% Barley AH AK Average Comments 4.5% A_BURN for Yuma Co. A_BURN counties: Imperial, Colusa, Kern, Kings, Fresno, Madera, Merced, San Joaquin, 17.1% Stanislaus, Tulare. 0.0% A_BURN for Mesa Co. 12.7% Comments 69.9% Only HI burns Corn (for grain) Average 0.0% 3.9% 0.0% 0.0% 0.0% 0.0% 0.0% Comments None burned Glenn, Sacramento, Tehama, Yolo, San Joaquin, None burned None burned None burned None burned None burned Page 1 of 3 Averages-Overall OR SD UT WA WY Total or Average 37,000 3,650,000 20,000 120,000 50,000 1,217 788 - 5,766,000 10,668 State AZ CA ID UT Total or Average Conservation Reserve Program (CRP) Acres in CRP in 1996 2,400 2,080 3,229 33,037 19,180 3,425 13 8,071 214,073 666 A_BURN 28,917 - 286,174 28,917 State AZ CA HI NM OR UT WA Total or Average Comments 765 Yuma and Pinal counties Butte, Colusa, Fresno, Glenn, Madera, Merced, Placer, 7,988 Sacramento, Sutter, Tehama, Tulare, Yuba counties 50,000 4,040 Estimated based on 1% of irrigated crop land 62,793 State WA WY Total or Average 0.2% Ditches and Ditchbanks A_BURN CA CO ID MT ND NM OR SD 3.3% 0.0% None burned 0.0% None burned 0.7% 0.0% None burned Average 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 13.5% 0.0% Comments None None None None None None None None burned burned burned burned burned burned burned burned None burned 10.1% Only WA burned in 1996 Orchards (includes trees, bushes, vines) AH 45,240 A_BURN - 2,097,734 20,200 24,380 65,197 9,484 235,532 523,269 6,831 2,497,767 530,100 State Average Comments 0.0% None burned A_BURN counties include:Butte, Colusa, Sacramento, Sutter, Tehama, Placer, Yolo, Lake, Riverside, San Bernardino, Fresno, Kern, Kings, Madera, Merced, San Joaquin, Stanislaus, 24.9% Tulare 0.0% None burned 0.0% None burned 0.0% None burned 0.0% None burned 2.9% 21.2% Rice AH A_BURN Average Page 2 of 3 Comments Averages-Overall CA Total or Average 500,000 254,706 500,000 254,706 State CA CO ID MT 50.9% Grasses and Seeds AH AZ A_BURN counties include: Butte, Colusa, Glenn, Placer, Sacramento, Sutter, Tehama, Yolo, 50.9% Yuba, Fresno, Merced Stanislaus, San Joaquin 6,223 A_BURN 4,700 Average Comments 75.5% A_BURN (bermuda) includes Yuma Co. 131,298 8,111 81,635 22,346 28,299 58,376 - 21.6% 0.0% 71.5% 0.0% 541,509 25,036 7,132 71,993 4,693 286,410 3,292 13,000 52.9% 0.0% 0.0% 4.6% 277.0% 899,976 394,077 43.8% NV OR SD UT WA WY Total or Average A_BURN counties include: Imperial (bermuda and sudan); Butte, Colusa, Placer, Tehama, Sacramento (grasses, sudan); Tulare (grasses) None burned alfalfa seed, KBG burned None burned Burning occurs, but no A_BURN data are available A_BURN includes field burning and propaning; does not include stack burning (~ 38,200 tons/year) None burned None burned alfalfa seed, KBG, other burned AH