Response to WRAP Air Managers Committee Memo “Request for Cost Estimates” April 6, 2009 WESTAR Council

Purpose of AMC memo (November 25, 2008) 1)Understand the funding needed to maintain the most critical ongoing systems for implementation of regional haze requirements; 2)Understand what additional funding would be needed to conduct periodic monitoring, emissions, modeling and other analyses required by the regional haze rule; and 3)Estimate costs to carry out additional regional technical analyses or assessments, assuming that full funding is provided for items 1) and 2).

Color-coding for funding categories in AMC Memo Base 1 Funding for Operation and Maintenance of Critical Systems Base 2 Funding for Regional Haze – Periodic Assessments Additional Funding for Other Regional Technical Analyses  Assumes Base 1 + Base 2 funding

Scope of “Other Regional Technical Analyses” Multi-state or regional-scale analyses Ozone, e.g., inventory development and refinement for ozone precursors, monitoring data analysis and gap assessment, air quality modeling, etc. Mercury (Hg), e.g., Hg emissions inventory development and refinement, monitoring data analysis and gap assessment, necessary fate and transport analyses, etc. Ammonia/Nitrogen (deposition) modeling and analysis, e.g., emissions inventory development and refinement, monitoring data analysis and gap assessment, necessary fate and transport information, etc.

Schedule and Process December ’08 - January ‘09 From AMC memo, Technical Oversight Committee reviewed: – Workplan document format and level of detail –List of proposed projects by Forum and WorkGroup January - February ‘09: Multiple calls of each Forum and WorkGroup to review drafts of proposed projects and costs –Sent to hundreds across all Forum and WorkGroup distribution lists –Reviewed by dozens of participants in each Forum and WorkGroup call

Schedule and Process, continued March 11-12: TOC-hosted Workplan Review meeting  30+ participants March 31 st - Final Draft Workplan released April 6-8: Review at WESTAR Meeting April 20 th - Review on Air Managers Committee call (100 PM Mountain time) WRAP Board call

Results Workplan covers technical work needed for –Maintenance/needed development of technical systems –Regional haze implementation for required 2012 SIP check-in analyses, sets stage for 2018 SIPs –Leverages regional haze work for other air quality technical analyses and planning for Ozone and PM NAAQS, Nitrogen and Mercury deposition –Supports and enables regional and national air quality projects with extramural funding

Examples of Results for States to Use #1 Low-cost/maximum utility for RHR implementation –EDMS operations, trends from RHR 2002 base year + EDMS-based portal for air quality planners - cross- referencing state, tribal, local, and national control effectiveness to historic and projected future emissions $115,000/year –Oil & Gas emissions tracking tools + control analyses $85,000 in 2010, $25,000 in 2011 –Implementation WG: “Area of Influence” analysis + controls/costs for “sources beyond BART” $75,000 in 2010, $125,000 in 2011 –Fire emissions tracking + emissions averted by smoke management $125,000 in 2010, $150,000 in 2011

Examples of Results for States to Use #2 Medium-cost & high utility for both RHR implementation & Additional Technical Analyses –VIEWS operations for RHR, add Ozone, PM, Nitrogen, Mercury data, & trends from RHR baseline + “what if emissions or air quality changes upwind” tools $300,000 in 2010, $225,000 in 2011 –Coordinated monitoring plan, methods, & data $175,000/year –New base & revised projection years’ emission inventories for 2012/13 planning milestones $450,000 in 2010, $400,000 in 2011 –Improve mobile sources emissions estimates for O&G basins $175,000

Examples of Results for States to Use #3 High-cost & regionally complete, optimized utility, & application for RHR implementation & Additional Technical Analyses –Next generation of Regional Modeling Center – emissions, meteorology, air quality, & source apportionment results for RHR, Ozone, PM, Nitrogen & Mercury delivered via tools on the VIEWS/TSS (for 2012/13 planning milestones) $1.35 million/year –Staff, travel & meetings, overhead, et cetera $655,000/year

Cost Estimates Base I Annual Funding – On-going System Maintenance and Operation $335,000 Base II Annual Funding, Regional Haze – Periodic Assessments $3,090,000$2,900,000 Regional Haze Subtotal $3,425,000$3,235,000 Additional Regional Technical Assessments, assuming full funding is provided for Base 1 & Base 2) a.Ozone Annual Funding $1,065,000$965,000 a.Mercury Annual Funding 50,000 a.NOx/Nitrate/Nitrogen Annual FundingIncl. in Ozone Additional Regional Technical Assessments subtotal $1,115,000$1,015,000 Regional Haze + Additional Technical Assessments total $4,540,000$4,250,000

Thanks for your attention -