Issues on Ozone Planning in the Western United States Prepared by the WESTAR Planning Committee for the Fall Business Meeting, Tempe, AZ October 31, 2011

Ozone – ppm, 3/12/08 What We Know About the Areas Affected* 52 areas are currently estimated to exceed the ppm, 43 of which would be “marginal” 22 areas are in the WEST 17 areas are in CA (10 “marginal” and 7 either “moderate” or higher) 4 areas in WY, NV, AZ, CO “marginal” plus UT * Based on 9/22/2011 Gina McCarthy Memo to Air Division Directors and State Updates

What We Think We Know About Timing 120-Day Letters – Fall of 2011 Classification Rule – Late 2011 Designations/Classifications by June 2012* Implementation Rule Proposal – Spring 2012 Implementation Rule Final – End of 2012 Proposed Ozone NAAQS October 2013 Final Ozone NAAQS July 2014 Show Attainment of 2008 Std. by June 2015 for Marginal Areas *Pending legal challenges

What We Know About Marginal Ozone Nonattainment SIP Requirements Reasonably Available Control Technology 172(c)(1) Vehicle Inspection and Maintenance for MSAs Greater Than 200, (a)(2)(B) Emission Inventories 172(c)(3), 182(a)(1) New Source Review Requirements for Nonattainment Areas 172(c)(4) and (5), 182(a)(2)(C) Infrastructure SIP 172(c)(7) Periodic Inventories Every Three Years 182(a)(3)(A) Emission Statements 182(a)(3)(B) VOC Offset Ratio 1.1 to 1 182(a)(4)

Infrastructure SIPs for 2008 Ozone Were due 3/12/11 and have become important Section 110(a)(1) requires states to submit new SIPs for the implementation, maintenance, and enforcement of new NAAQS Section 110(a)(2) lists the elements new SIPs must contain Section 110(a)(2)(D)(i) addresses interstate transport (difficult for individual states to do) All states, regardless of attainment status, do 110(a)(1) & (2) SIPs

Met this requirement for the 1997 ozone standard by relying on CAIR modeling. Regional Office advice is to sit tight and wait for CSAPR II to address this. CSAPR I (East Coast) addresses transport for 1997 standard. Contribution determination is broken down into two parts. – 1) threshold for contribution (this was 1% in CSAPR I) – 2) then after “contribution significance” determination – address controls based on air quality and cost of control

What We Don’t Know…. Don’t have a schedule for when the infrastructure SIPs are due. Don’t have a regional modeling demonstration that shows us if we have transport issues and no schedule for CSAPR II. Don’t have an implementation rule for 2008 ozone. Do have a lot of concern about how this will unfold in the West.

Western Regional Technical Analyses of Ozone Background and Source Attribution Regional Products to assist States with Ozone Planning October 31, 2011

3-year Average 4 th Highest 8-Hour Ozone value by County AQS Federal Reference Method data from the monitoring site in each County with the highest Ozone values

4 th Highest 8-Hour Ozone value by County for 2011 (available as of 10/11/2011) AQS Federal Reference Method data from the monitoring site in each County with the highest Ozone values

WestJumpAQMS Background Ozone and Source Apportionment (12-km grid cell is ~55 square miles and a 4-km grid cell is ~6 square miles)

CAMx Particulate Source Apportionment Technology (gridded emissions/met in photochemical model with virtual tags of source categories and regions) CMAQ Ozone Transport “Zero-Out” Sensitivity Study Ozone Source Apportionment Monthly Mean Results Tong, D. Q. and Mauzerall, D. L. Summertime State-Level Source-Receptor Relationships between Nitrogen Oxides Emissions and Surface Ozone Concentrations over the Continental United States. Environmental Science & Technology, Volume 42, Number 21, WRAP regional haze CAMx PSAT modeling, WRAP TSS, 2007

Assessment of Smoke’s Contribution to Ozone Develops best available regional fire emissions inventory for air quality planning Provides analytical results and technical tools for Federal Land Managers (FLM) to participate more fully in ozone air quality planning efforts Improves understanding of Ozone exceptional events

2011 Harvard Study on Policy Relevant Background Ozone Pollution Influence from Sources Outside the United States

4-km Impact Assessment Domains (IAD) to model one-way air quality impacts using CAMx/CMAQ photochemical grid modeling 16

4-km Detailed Source Apportionment Domains (DSAD - solid line boxes) to model two-way air quality effects using CAMx/CMAQ photochemical grid modeling 17