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

2. 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
Strategic Plan
2004 Funding at $4.2 million

3. 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 (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 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 %)

4. 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

5. Strategic Plan

6. Core of Strategic Plan
Two-phased approach, Dec 07

7. 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

8. Planning Timeline

9. 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.
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 ( )
Initial technical assessment –apportion source contribution, etc. using 1996 EI
WRAP endorsement
WRAP Activities

10. Questions?