Work Items for §309 SIPs WESTAR Fall Technical Conference September 19, 2002 Tom Moore & Brian Finneran

Work Items for §309 SIPs –Presentation Objectives From the Fall Technical Conference, review status of §309 SIP-relevant work items for: –WRAP –States –Model SIP project –EPA

WRAP Work Items for §309 SIPs Status of §309 SIP-relevant work products –Master list of federal/tribal/state/local control programs’ assumptions included in WRAP emissions inventories –CAC comprehensive emissions tracking strategy - EI updates sufficient to meet requirement? –Is <25% significance level needed closer to Plateau? (e.g.15%) – pending for WRAP IOC –Tracking spillover emissions from outside the CAC – Probably needs modeling analysis – CAC workgroup to address –Criteria for identifying additional measures if needed – CAC workgroup could develop a process/general criteria for how to review additional measures needed

WRAP Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –MTF 2000 SO 2 emissions inventory report –NO x & PM modeling sensitivity analysis – tech memo, followed by MTF NO x and PM report –MTF SO 2 emissions and allowances tracking specifications –Model Rule/SIP –SO 2 allocation guidelines –Monitoring protocols –Critical mass of states to participate in market? MTF to report on economic analysis report –Further work on trading program for regional haze and effect on reasonably attributable impacts in Class I areas? - MTF to review

WRAP Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –Status of WRAP mobile source & road dust EIs –From WRAP mobile and road dust EIs, “regional” significance finding If mobile significant, need for affected state(s) or tribe(s) to enter data in a regional tracking system to report annual mobile emissions (VOC, SO 2, NO x, EC, OC, and PM 2.5 ) Road dust unlikely to be judged significant – Status report on other mobile GCVTC strategies: Regional and local mobile control programs Guidance for emissions reductions from existing non-road mobile sources “Smart growth” toolkit and workshop

WRAP Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –Fire Status of 1996 and 2018 Fire EIs Specifications for tracking of fire emissions and applications of fire emissions reduction techniques (ERTs); States/tribes need to report these data, to calculate a periodic regional fire EI for emissions and air quality/visibility modeling –Additional Recommendations Need to tabulate GCVTC recommendations modeled/not modeled

WRAP Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –Pollution Prevention/Renewable Energy: Emission changes to be modeled in late 2002 “All Regional Control Strategies” simulation - projections of EERE visibility improvement need to be dealt with explicitly Checklist of Pollution Prevention/Renewable Energy programs for states to use in showing in their SIPs what is active in each state –List of GCVTC recommendations actually included in WRAP analyses –Renewable/alternative fuel use in transportation sector – could be P2 programs –Address the beyond and early compliance provisions –Resolve requirements outlined in d8I and d8vi – seem to be redundant provisions

WRAP Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –Pollution Prevention/Renewable Energy, continued: Accounting for federal programs (e.g. Energy Star) – can states rely on these in SIP? Clarification needed from P2 forum about what SIP-ready products they are providing to states and guidance on how to incorporate the SIP-ready products into SIPs. Need clarification on what additional P2 work states must complete themselves

WRAP Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –Reasonable Progress for Additional Class I Areas Presumptive glide path analysis for Class I areas (to be provided by WRAP in October) Analysis of effect of all §309 regional control strategies combined for comparison with presumptive glide path (WRAP to provide early 2003)

States’ Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –What additional information is critical for states to make the 308/309 decision? –What do states need to do in 2003 SIP to make a decision to commit to 309 for additional areas? –Stationary Sources/Geographic Enhancements State authorizing legislation for stationary source trading program, if needed State Rule for Stationary Source Trading Program Modify existing inventory rules to require major sources to submit an annual inventory 1996 EI method in TSD (WRAP TSD, supplemented by state) Show any changes in inventory and methods (state to provide) Floor allocation established (provided by State, WRAP guidelines) MOA with federal land managers and tribes on RAVI certification

States’ Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –Fire Programs States must determine if existing authority to implement an SMP States must determine if existing authority to coordinate SMP across state/tribal boundaries. States need to enter data into the tracking system – resources State may need to revise forms to request information – resources States must determine if existing authority to implement agricultural burning SMP –Pollution Prevention To claim credit, States must identify the EEREs occurring in their own state Developing state specific contributions to expected regional improvements/benefits

Model SIP Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –Ensure EPA coordination in review of Model SIP and TSD for approvability –Ensure status updates are available to states as the Model SIP is being developed –Much work needs to be done on Pollution Prevention. –Closure on remaining unanswered WRAP questions to EPA

EPA Work Items for §309 SIPs Status of §309 SIP-relevant work products, continued –EPA Questions What if CAC state does not participate under §309? How to address CAC emissions from tribal lands? How does EPA intend to approve the regional TSD for use by states and tribes, and identify additional state- specific elements that will be required? What is EPA plan to ensure consistent SIP review across EPA regions?