1. Significance of Mobile Source Emissions for the Purposes of Section 309 of the Regional Haze Rule Patrick Cummins Western Governors’ Association WRAP Board Meeting Portland, OR April 2, 2003

2. Section 309 Requires: “A determination whether mobile source emissions in any areas of the state contribute significantly to visibility impairment in any of the 16 Class I areas, based on the statewide inventory of current and projected mobile source emissions.” [§309(d)(5)(ii)]

3. 309 Requirements If mobile source emissions contribute significantly, state must establish an emissions budget that restricts emissions to their projected lowest level and implement measures to achieve the budget. [§309(d)(5)(iii)] These mobile source provisions of Section 309 are based on GCVTC recommendations.  GCVTC modeling showed mobile emissions reaching a low point in 2005, then increasing.

4. Since the GCVTC Final Report... New engine standards for cars, trucks, and buses New fuel sulfur standards for gasoline and on-road diesel fuel New engine standards for some non-road sources  All the above recommended by the GCVTC and/or WRAP New emission models

5. Current Projections (2003 - 2018) Future stds for non-road engines may reduce NOx & PM by 90% and SO2 by 99% Without such standards, emissions from non-road sources will continue to be an issue

6. Update 309 Mobile Source Provisions? Current situation very different from when GCVTC made its recommendations EPA has indicated willingness to update 309 on an expedited basis Approach may be to eliminate 309(d)(5)(ii) and (iii) and instead require a showing of continuous emission reductions for the period 2003 – 2018.

7. Update 309 Mobile Source Provisions? If total emissions (on-road + non-road) of any pollutant do not continuously decline:  State would submit SIP by 12/31/08 containing long-term strategy to achieve continuous decline to the extent practicable, considering economic and technological reasonableness and applicable state authority.

8. Arizona Statute – May 2002 Arizona may submit a 309 plan only if the plan contains a determination that mobile source emissions do not contribute significantly to visibility impairment at any of the 16 Class I areas.

9. SO2 An approach other than “continuous reduction” needed for SO2. Current regulations will dramatically reduce sulfur in on-road gasoline and diesel (15 ppm) EPA’s forthcoming proposal for heavy-duty non-road mobile sources is expected to include a 15 ppm standard. Once 15 ppm is reached (approx. 2008), growth leads to a small increase.

10. SO 2 Emissions (tpy)

11. Current Projections (2018) Non-Road Land-Based @ 15 ppm S Non-Road Planes, Trains, and Ships On-Road Total Non-Road

12. Options for SO2 Option #1  Require a demonstration that 2018 mobile source SO2 emissions are at least 75% lower than 2003  On-road plus non-road, excluding planes, trains & ships  Non-road diesel must come down to 15 ppm  EPA’s proposed rule will indicate direction, but will not be finalized by the time 309 plans are due  If EPA’s final rule (2004) does not significantly reduce non-road, states would have to address in plan revision (also as part of 308)

13. Options for SO2 (cont.) Objections to Option #1  State and industry objections to including a requirement that relies on proposed federal rule  Concern that lack of federal action could lead to “boutique” fuels  Environmental groups concerned that language re “applicable state authority” could lead to inaction at state level if federal standard is not adopted

14. Options for SO2 (cont.) Option #2  Require a demonstration that 2018 mobile source SO2 emissions are no higher than 2003  Can be shown with current regulations

15. Other Options Do not pursue updates to Section 309 States use WRAP’s technical information and analysis to address mobile source provisions as they exist today. Other ideas??