Visibility Coordinator’s Report WESTAR council April 9, 2003 Don Arkell

Overview-WRAP Status Finishing work on 309 Transition from 309 to 308 MOU/Model Rule under review- There is some discussion of whether MOU is necessary—It is not needed as a legal, enforceable mechanism to tie the program together It is important for participating states and tribes to work together to implement a common program Possible to do this through other existing mechanisms within WRAP STIP II is under review – Working with outside reviewers to get this review accomplished. Prospects are that this will continue in some manner even after the document is in use by states Strategic Plan is in final stages. Announced that the WRAP will be funded at $4.2 million for the coming year (2004) Finishing work on 309 MOU/Model Rule STIP-II Modeling – Stationary sources, Fire emissions Mobile sources – Significance, or ?? Transition from 309 to 308 2003-2008 Strategic Plan 2004 Funding at $4.2 million

Major Issues: Stationary Sources-MOU/Model Rule Allocations established by formula in Annex Non-utility floor allocations are completed. Utility allocations still not determined, though issues are identified with respect to equity, distribution to states and tribes. Early reduction bonus credits Renewable energy credits RAVI-Source-specific remedy for impairment Issues: How to interface with milestones Uniform procedures SIP must contain a RAVI program 2018 Milestone compliance Penalty authority by states $5,000 Backstop beyond 2018 SIP/TIP template may resolve Monitoring protocols, NOx/PM, Tracking System specs. For backstop trading MOBILE SOURCES “Significance” has never been resolved. The sense is that since MS are no longer though to “bottom out” (Except for SO2) the requirement of 51.309(d)(5)(ii) and (iii) should be updated by replacing the requirements for “significance” and “budgets” with another scheme to hold MS emissions to their minimum levels. Original thought was to require demonstration of continuous decline through 2018. Problem is that SO2 will not continue to decline after a 15ppm S standard is implemented for non-road diesel fuel (except for trains, planes and ships). SO2 would have to be handled differently. First thought was to demonstrate a 75% drop in SO2 (assuming new federal non-road S standards are promulgated) . Objections included basing a strategy on a rule that is not adopted, “boutique” fuels, concern that states would be let off the hook if feds didn’t act. There was also some basic discomfort with separating out SO2 from the other MS pollutants. The WRAP opted to pursue with EPA the idea of demonstrating a net reduction between 2003 and 2018 for all MS pollutants. Advantage is that it doesn’t depend on new federal rules, and preserves the idea of the GCVTC that MS should be held at the lowest level. Non-road will be the largest share of total mobile source emissions after the current fuel and tier II emission standards are fully implemented. Stationary Sources-MOU/Model Rule Allocation Scheme RAVI 2018 Milestone Compliance Mobile Source “Significance” EPA willing to work on rule change Replace §51.309(d)(5)(ii), and (iii)(A) Demonstrate net decrease (no %) 2003-2018

Major Issues: Response to American Corngrowers… EPA is moving forward with re-proposal, to include both a new rule and guidance Proposal is scheduled for April ’04 – final April ’05 Nothing in the proposal will affect 309 EPA has forwarded its draft legislation to DOT to include in the TEA reauthorization package. The language would require PM fine SIPs and Regional Haze SIPs to be due at the same time – Three years after PM fine designations, or about November, ’07. Response to American Corngrowers… BART regulation and guidance Does not affect 309 proposal April 2004, Final April 2005 TEA-21 reauthorization to include same submittal dates for PMfine, RH SIP’s November, 2007

2003-2008 Strategic Plan

Core of Strategic Plan Two-phased approach, Dec 07

Core of Strategic Plan Apportionment Phase I Phase II Results Two phases: The first is a “dry run” to: a) Provide some experience running the models on data, including emission, air quality, other studies. b) This will also provide states with an understanding of apportionment of sources they will likely be dealing with, Identification of which Class I areas they should include in their SIPs and the reasonable rates of progress for each one. The second phase will use real baseline (2002) data, and go through the exercise again, apportion emission reductions by state. (STATES WILL APPORTION AMONG THEIR SOURCES) Apportionment Phase I Phase II Apportion Emission Reductions By state / tribe By source category and sub-state areas if appropriate Reconcile and Synthesize Results Develop Control Strategies

Planning Timeline

WRAP Activities State Critical Path ID BART-eligible sources   State Critical Path Critical Path from 2003 through 2007 2. WRAP activities start with (a) modeling to determine rate of progress to natural conditions for all Class I areas; (b) Determining which Class I areas need to be addressed in each SIP. 3. Perform an initial technical analysis, based on 1996 emissions-rough estimate of source contribution in each Class I area, give states an idea of which sources they will need to address, state share of reductions needed, and provide states the tools needed to develop lists of potential control strategies. 4. By mid 2004, States will need to pull together an actual EI for 2002 as input for modeling 2002 and 2018 base case, which will increase confidence of state contributions. 5. WRAP will complete base-case modeling in late 2005. 6. States will select control strategies for modeling to help demonstrate RFP. 7. WRAP will complete Causes of Haze report, which will refine the source apportionment. 8. WRAP will complete the “all controls” modeling, based on the selected control strategies, and will refine the technical basis for emission reduction apportionment among states and tribes. 9. States will have all the information needed to proceed to finalize their control strategies, adopt necessary statutory and regulatory authority, public hearings, etc. to adopt their SIPs 10. The WRAP board will sign off on regional strategies, reasonable progress goals around the end of 2006. 11. The TSD should be completed by mid-2007. 2003 2004 2005 2006 2007 ID BART-eligible sources ID BART sources subject to BART Determine BART Adopt statutes and/or rules Provide 2002 emissions, activity and demographic data Develop list of potential control strategies Select control strategies Finalize control strategies Submittal to EPA   Determine which Class I areas addressed BART Reductions Analysis Causes of Haze Report Apportioned Emission Reduction obligation by state Establish Uniform Rate of Progress TSD Complete Control Strategy Modeling including BART Complete base case modeling, evaluation, source apportionment (2002 +2018) Initial technical assessment –apportion source contribution, etc. using 1996 EI WRAP endorsement WRAP Activities

Questions?