1. 1 Navy/Marine Corps Mobile Source Emissions Growth Projection and SIP Planning Presented by: Mike Huber, NRSW Massie Hatch, URS 7 April 2004

2. 2 Agenda n Background n General Conformity Impacts n Purpose and Benefits of Growth Projection and State Implementation Plan (SIP) Planning n Challenges n Steps Taken n Lessons Learned

3. 3 Background n General Conformity regulations (40 Code of Federal Regulations [CFR] Part 51 Subpart W and Part 93) require federal agencies to demonstrate conformity with local SIP PRIOR to commencing action n Conformity applies in non-attainment or maintenance areas n Conformity affects non-permitted emission units (e.g., mobile sources, area sources)

4. 4 Conformity Triggers n BRAC actions n Consolidated training missions n New weapons systems (MV-22, JSF) n Other major actions that trigger National Environmental Policy Act (NEPA)

5. 5 Conformity Impacts n If project emissions exceed conformity de minimis level, a detailed conformity determination is required n Mitigation measures may need to be implemented: – the project might need to be staggered, reduced, or delayed; and/or – costly Emission Reduction Credits (ERCs) may need to be provided n Limits expansion capability and usefulness of many bases (could negatively impact Base mission) – ERCs cost $100,000/ton for NO x in San Diego and are difficult to acquire

6. 6 Conformity and SIPs n If emissions are already accounted for in the SIP, conformity is demonstrated n Not easy to do, SIPs are written 5 to 10 years in advance n Historically, the military has had limited involvement in SIP development n Without data from military, districts tend to forecast ZERO growth for installations

7. 7 Purpose n Calculate accurate baseline data for military mobile sources n Project emissions growth through Year 2015 and incorporate that growth budget into the SIP to facilitate fielding new weapons systems or potentially expanding operations n DoN must still comply with NEPA and other laws and regulations that prohibit pre-decisional actions n Final decisions are only made after NEPA and other applicable requirements are met

8. 8 Benefits n Military- Projected growth in the SIP facilitates conformity n Districts - Military data make the SIPs more accurate – The current military data in most SIPs are based on incomplete, inaccurate, and/or outdated estimates

9. 9 Challenges n Timing may be critical; SIPs are only revised every few years - plan accordingly n Baseline data for mobile sources are not generally available n Growth information is difficult to collect – No process exists to provide data on new weapons systems to local air managers n Depending on progress toward attainment, some SIPs might not be able to accommodate much growth

10. 10 Steps Taken n NRSW POAM developed in December 2000 n Multi-service team met with CARB in January 2001 n NRSW hired URS to provide support n Initiated contact with local Air Pollution Control Districts and met with EPA Region IX – SDCAPCD, SCAQMD, VCAPCD, ICAPCD, SJVAPCD, and SVAPCD-all VERY receptive to initiative – EPA, CARB, and all Districts contacted were supportive of the idea and eager to receive data n Marine Corps SD installations joined the effort in September 2001

11. 11 Steps Taken, continued n NRSW/MC proposed methodology to SDCAPCD in January 2002 n SDCAPCD provided helpful input and support- methodology approved with minimal comments n Meanwhile, San Diego attained 1-hr ozone standards and began preparing an ozone maintenance plan n NRSW/MC had a 4-week window to provide baseline and growth data n Projected growth through Year 2015

12. 12 Baseline and Growth Data n Baseline and Growth data provided for the following source categories: – aircraft; – vessels (zero to three nautical miles); – Ground Support and Tactical Support Equipment (GSE/TSE); and – tactical vehicles. n Baseline emissions relied heavily on existing planning documents for significant operations (e.g., past inventories/studies, current conformity efforts)

13. 13 Growth Projected n Sources of information: – Navy/MC Headquarters – Strategic planning documents – New Homeland Defense requirements n Emphasized that all future growth is “potential” and emissions are only estimates n Emissions growth expected for NO x only; CO and VOCs decreased for potential new weapon systems n Estimated 2.7% annual, cumulative, and compounded emission increase for potential new weapon systems and operational changes

14. 14 Growth, continued n In addition, negotiated a growth of 4.4% for unanticipated projects (e.g., BRAC, National Security) n Total growth projected through 2015: 4154 ton/yr of NO x (11.4 tons/day) n SD Maintenance Plan (MP) can accommodate the growth because of anticipated significant decline in vehicle emissions n NRSW/MC can have access to the entire growth as soon as the MP is approved n Internal DON system needed to track projects and amount of SIP budget used

15. 15 Other Progress to Date n NALF SCI: negotiated 1% annual growth n NAS Lemoore: negotiated 850 tons of NO x and 356 tons of VOC growth n NBVC: submitted 4.4% annual NO x growth factor to VCAPCD n NAWS China Lake: Searles Valley APCD has incorporated growth factor n NAF El Centro: Has begun discussion with ICAPCD; developed baseline

16. 16 Lessons Learned n Key to success: Cooperative effort with regulatory agency n Make contact with the local air agency ASAP to determine SIP schedule- They need data two years before the SIP update is due n The new 8-hr standards present an opportunity n Calculate accurate mobile source baseline as a one-time investment n Collect as much growth data as possible by getting the right people involved n Ask for reasonable growth based on strong backup data

17. 17 Points of Contact n NRSW: Jose Casora (619-524-6502) Jose.Casora@navy.mil n NRSW: Mike Huber (619-524-6264) Michael.Huber@navy.mil n URS: Massie Hatch (714-433-7710) massie_hatch@urscorp.com