REPORT
OF
THE
GRAND
CANYON
VISIBILITY
TRANSPORT
COMMISSION
TO
THE
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
June
1996
i
EXECUTIVE
SUMMARY
The
Colorado
Plateau's
national
parks
and
wilderness
areas
provide
a
unique,
panoramic
visual
experience
for
people
from
around
the
world.
This
experience
depends
on
maintaining
high
visual
air
quality
in
the
region,
which
is
threatened
by
haze
resulting
from
projected
growth
over
the
next
fifty
years.
Congress
has
set
a
national
goal
of
remedying
existing
human­
caused
visibility
impairment,
and
preventing
future
impairment,
at
these
national
parks
and
wilderness
areas.
Congress
recognized
that
not
all
haze
is
humancaused
and
that
haze
is
a
regional
issue.
Congress
created
the
Grand
Canyon
Visibility
Transport
Commission
in
1991
to
advise
the
U.
S.
Environmental
Protection
Agency
on
strategies
for
protecting
visual
air
quality
at
national
parks
and
wilderness
areas
on
the
Colorado
Plateau.
The
Commission
established
a
Public
Advisory
Committee
(
PAC)
to
obtain
broad
input
as
it
formulated
these
strategies.

The
Commission
conducted
an
extensive
review
of
scientific,
technical,
and
other
information
with
assistance
from
a
range
of
governmental,
business,
tribal,
and
environmental
interests.
It
developed
more
comprehensive
databases,
and
new
computer
modules
to
analyze
these
data
and
model
future
air
quality.
The
Commission
significantly
advanced
understanding
of
regional
haze,
but
limitations
and
uncertainties
remain.
Based
on
that
information
and
its
own
deliberations,
the
PAC
developed
a
set
of
emissions
management
recommendations
for
the
Commission
with
a
full
understanding
of
progress
and
limitations
in
available
knowledge.
These
recommendations
are
aimed
at
protecting
clear
days
and
reducing
dirty
days
at
national
parks
and
wilderness
areas
on
the
Colorado
Plateau.
Following
a
series
of
public
meetings
in
April
1996,
the
PAC
and
Operations
Committee
conducted
a
final
review
and
approval
of
these
recommendations
and
forwarded
them
to
the
Commission
for
action.
The
Commission
formally
considered
the
PAC
and
Operations
Committee
reports
on
June
10,
1996
and
approved
them
as
the
Commissions
report
to
the
Environmental
Protection
Agency.
The
EPA
should
use
the
Commission's
recommendations
as
guidance
for
developing
national
strategies
and/
or
rulemaking.
Implementation
of
all
specific
program
components
will
remain
the
responsibility
of
tribes,
states
and
their
political
subdivisions,
and,
in
some
cases,
federal
agencies.

Some
of
the
Commission's
recommendations
ask
the
EPA
to
take
specific
actions
or
institute
particular
programs,
in
cooperation
with
the
tribes,
states
and
federal
agencies
as
implementing
bodies.
Other
recommendations
provide
a
range
of
potential
policy
or
strategy
options
for
consideration
by
the
EPA
and
implementing
entities.
As
the
EPA
develops
policies
and
takes
actions
based
on
this
report,
this
distinction
between
"
actions"
and
"
options"
should
be
maintained
with
diligence.
That
is,
recommendations
intended
as
policy
options
should
not
become
mandated
actions
or
regulatory
programs.

The
primary
recommendations
include:

$
Air
Pollution
Prevention.
Air
pollution
prevention
and
reduction
of
per
capita
pollution
is
a
high
priority
for
the
Commission.
The
Commission
recommends
policies
based
on
ii
energy
conservation,
increased
energy
efficiency
and
promotion
of
the
use
of
renewable
resources
for
energy
production.

$
Clean
Air
Corridors.
Clean
air
corridors
are
key
sources
of
clear
air
at
Class
I
areas,
and
the
Commission
recommends
careful
tracking
of
emissions
growth
that
may
affect
air
quality
in
these
corridors.

$
Stationary
Sources.
For
stationary
sources,
the
Commission
recommends
closely
monitoring
the
impacts
of
current
requirements
under
the
Clean
Air
Act
and
ongoing
source
attribution
studies.
Regional
targets
for
SO2
emissions
from
stationary
sources
will
be
set,
starting
in
2000.
If
these
targets
are
exceeded,
this
would
trigger
a
regulatory
program,
probably
including
a
regional
cap
and
market­
based
trading.
During
the
next
year,
participants
in
the
Commission's
process
will
develop
a
detailed
plan
for
an
emissions
cap
and
market
trading
program.

$
Areas
In
And
Near
Parks.
The
Commission's
research
and
modeling
show
that
a
host
of
identified
sources
adjacent
to
parks
and
wilderness
areas,
including
large
urban
areas,
have
significant
visibility
impacts.
However,
the
Commission
lacks
sufficient
data
regarding
the
visibility
impacts
of
emissions
from
some
areas
in
and
near
parks
and
wilderness
areas.
In
general,
the
models
used
by
the
Commission
are
not
readily
applicable
to
such
areas.
Pending
further
studies
of
these
areas,
the
Commission
recommends
that
local,
state,
tribal,
federal,
and
private
parties
cooperatively
develop
strategies,
expand
data
collection,
and
improve
modeling
for
reducing
or
preventing
visibility
impairment
in
areas
within
and
adjacent
to
parks
and
wilderness
areas.

$
Mobile
Sources.
The
Commission
recognizes
that
mobile
source
emissions
are
projected
to
decrease
through
about
2005
due
to
improved
control
technologies.
The
Commission
recommends
capping
emissions
at
the
lowest
level
achieved
and
establishing
a
regional
emissions
budget,
and
also
endorses
national
strategies
aimed
at
further
reducing
tailpipe
emissions,
including
the
so­
called
49­
state
low
emission
vehicle,
or
49­
state
LEV.

$
Road
Dust.
The
Commission's
technical
assessment
indicates
that
road
dust
is
a
large
contributor
to
visibility
impairment
on
the
Colorado
Plateau.
As
such,
it
requires
urgent
attention.
However,
due
to
considerable
skepticism
regarding
the
modeled
contribution
of
road
dust
to
visibility
impairment,
the
Commission
recommends
further
study
in
order
to
resolve
the
uncertainties
regarding
both
near­
field
and
distant
effects
of
road
dust,
prior
to
taking
remedial
action.
Since
this
emissions
source
is
potentially
such
a
significant
contributor,
the
Commission
feels
that
it
deserves
high
priority
attention
and,
if
warranted,
additional
emissions
management
actions.

$
Emissions
from
Mexico.
Mexican
sources
are
also
shown
to
be
significant
contributors,
particularly
of
SO2
emissions.
However,
data
gaps
and
jurisdictional
issues
make
this
a
difficult
issue
for
the
Commission
to
address
directly.
The
Commission
recommendations
call
for
continued
binational
collaboration
to
work
on
this
problem,
as
well
as
additional
efforts
to
complete
emissions
inventories
and
increase
monitoring
capacities.
These
matters
should
receive
high
priority
for
regional
and
national
action.
iii
$
Fire.
The
Commission
recognizes
that
fire
plays
a
significant
role
in
visibility
on
the
Plateau.
In
fact,
land
managers
propose
aggressive
prescribed
fire
programs
aimed
at
correcting
the
buildup
of
biomass
due
to
decades
of
fire
suppression.
Therefore,
prescribed
fire
and
wildfire
levels
are
projected
to
increase
significantly
during
the
studied
period.
The
Commission
recommends
the
implementation
of
programs
to
minimize
emissions
and
visibility
impacts
from
prescribed
fire,
as
well
as
to
educate
the
public.

$
Future
Regional
Coordinating
Entity.
Finally,
the
Commission
believes
there
is
a
need
for
an
entity
like
the
Commission
to
oversee,
promote,
and
support
many
of
the
recommendations
in
this
report.
To
support
that
entity,
the
Commission
has
developed
a
set
of
recommendations
addressing
the
future
administrative,
technical
and
funding
needs
of
the
Commission
or
a
new
regional
entity
and
has
asked
the
Operations
Committee
to
complete
detailed
plans
by
September,
1996.
The
Commission
strongly
urges
the
EPA
and
Congress
to
provide
funding
for
these
vital
functions
and
give
them
a
priority
reflective
of
the
national
importance
of
the
Class
I
areas
on
the
Colorado
Plateau.

To
the
maximum
extent
feasible,
Commission
recommendations
calling
for
additional
exploration
and
study,
etc.
(
necessary
for
filling
information
gaps
and
for
resolving
certain
policy
issues)
should
be
accomplished
by
the
year
2000.
Until
such
time
as
future
organizational
arrangements
have
been
determined,
all
tasks
which
are
not
assigned
to
any
particular
existing
entity
should
be
performed
by
or
under
the
auspices
of
the
Operations
Committee.

The
Commission
believes
that
reasonable
progress
toward
the
national
visibility
goal
is
achieved
to
the
extent
that
current
Clean
Air
Act
requirements,
existing
laws
and
regulations,
and
the
Commission's
recommendations
result
in
a
significant
near­
term
decrease
in
emissions
that
contribute
to
visibility
impairment
and
ensure
long­
term
protection
of
visibility.
For
example
by
2000­
2010,
pollutants
from
stationary
and
mobile
sources
are
expected
to
be
reduced
by
30%
from
the
1990
levels.
1
1
Sulphur
dioxide
(
SO2)
for
stationary
sources
and
nitrogen
oxides
(
NOx)
and
volatile
organic
compounds
(
VOC)
for
mobile
sourc
iv
v
vi
TABLE
OF
CONTENTS
EXECUTIVE
SUMMARY
...........................................................................................
i
GLOSSARY
........................................................................................
vii
SECTION
I:
INTRODUCTION
................................................................................
1
SECTION
II:
PROCESS
FOR
DEVELOPING
PAC
RECOMMENDATIONS........
5
SECTION
III:
EMISSION
MANAGEMENT
RECOMMENDATIONS
............................................
26
Guiding
Principles..............................................................................
26
Air
Pollution
Prevention
....................................................................
28
Stationary
Sources.............................................................................
32
Mobile
Sources
..................................................................................
38
Area
Sources......................................................................................
46
Clean
Air
Corridors
............................................................................
51
Emissions
Within
and
Near
Class
I
Areas
........................................
53
Transboundary
Emissions
from
Mexico
............................................
56
Future
Scientific
and
Technical
Needs
............................................
59
SECTION
IV:
TRIBAL
PERSPECTIVES
AND
POSITIONS
REGARDING
RECOMMENDATIONS.....................................................................
66
SECTION
V:
FUTURE
ADMINISTRATIVE
NEEDS...............................................
74
SECTION
VI:
ANALYSIS
OF
RECOMMENDATIONS
...........................................
78
vii
viii
GLOSSARY
OF
TERMS
USED
IN
THIS
REPORT
Within
each
definition,
terms
defined
elsewhere
in
this
glossary
are
printed
in
italics.

Aerosol:
Solid
particles
or
liquid
droplets
that
are
small
enough
to
be
suspended
in
the
air.
Aerosols
cause
most
of
the
light
extinction
responsible
for
haze
on
the
Colorado
Plateau.

Area
source:
Many
small
sources
of
air
pollution
in
which
the
contribution
of
each
source
is
relatively
small,
but
combined
may
be
a
significant
source
of
air
pollution.
A
city
can
be
an
area
source
(
although
large
facilities
within
the
city
could
release
enough
air
pollution
to
warrant
their
analysis
individually
as
a
point
source).

BART:
Best
Available
Retrofit
Technology,
a
process
under
the
CAA
to
evaluate
the
need
and,
if
warranted,
install
the
most
effective
pollution
controls
on
an
already
existing
air
pollution
source.

BFS/
Baseline
Forecast
Scenario:
A
computer
model
used
by
the
Grand
Canyon
Visibility
Transport
Commission
to
estimate
future
haze­
causing
pollution
and
economics.
The
GCVTC
based
this
scenario
on
current
technologies,
existing
laws,
and
a
variety
of
assumptions
about
how
quickly
various
kinds
of
pollution
sources
will
be
retired
and
the
type
of
facilities
that
will
replace
them.
It
is
an
extension
of
current
policies,
and
allows
comparisons
with
other
air
pollution
management
scenarios
the
GCVTC
may
propose.

CAA/
CAAA:
The
Clean
Air
Act,
and
the
Clean
Air
Act
Amendments.
National
air
pollution
control
is
based
on
the
Clean
Air
Act,
passed
in
1970.
Congress
amended
the
Clean
Air
Act
in
1977
(
adding
many
visibility
sections
that
the
GCVTC
is
addressing),
and
in
1990
(
when
it
required
creation
of
the
GCVTC,
assigned
tribal
governments
power
under
the
CAA
similar
to
those
of
the
states).

Class
I
site/
area:
In
1977,
Congress
identified
158
national
parks,
wilderness
areas,
international
parks
and
other
areas
that
were
to
receive
the
most
stringent
protection
from
increases
in
air
pollution.
It
also
set
a
visibility
goal
for
these
areas
to
protect
them
from
future
human­
caused
haze,
and
to
eliminate
existing
human­
caused
haze,
and
required
reasonable
progress
toward
that
goal.

Colorado
Plateau:
A
high,
semi­
arid
tableland
in
southeast
Utah,
northern
Arizona,
northwest
New
Mexico,
and
western
Colorado.
The
unique
erosional
forms
of
the
Plateau
are
world
famous.

CNG:
Compressed
Natural
Gas,
a
relatively
clean­
burning
fossil
fuel.

EC/
OC:
Elemental
Carbon
(
such
as
soot,
often
the
result
of
fire
and
diesel
engines)
and
Organic
Carbon
(
carbon
combined
with
other
elements
to
form
complex
compounds,
often
given
off
by
plants
and
most
human
activities).
ix
Fine
mass
particulates:
Aerosols
that
are
smaller
than
2.5
micrometers
in
diameter.
(
A
micrometer
is
one
millionth
of
a
meter,
a
human
hair
is
about
70
micrometers
in
diameter.)

GCVTC:
The
Grand
Canyon
Visibility
Transport
Commission,
composed
of
the
governors
of
eight
western
states
(
AZ,
CA,
CO,
NM,
NV,
OR,
UT,
WY),
five
tribes
(
Acoma,
Hopi,
Hualapai,
Navajo),
four
federal
land
managers
(
Bureau
of
Land
Management,
U.
S.
Fish
and
Wildlife
Service,
U.
S.
Forest
Service,
National
Park
Service),
the
Columbia
River
Inter­
Tribal
Fish
Commission,
and
the
Environmental
Protection
Agency.
The
states
and
tribes
vote,
the
other
GCVTC
members
do
not.
The
Commission
was
established
to
recommend
methods
to
preserve
and
improve
visibility
on
the
Colorado
Plateau.
Congress
required
establishment
of
the
GCVTC
through
the
Clean
Air
Act
Amendments
of
1990.

HC:
Hydrocarbons.
A
group
of
chemicals
containing
hydrogen
and
carbon
that
often
contribute
to
air
pollution
as
OC's
or
VOC's.
They
are
involved
in
forming
ozone,
and
some
hydrocarbons
are
toxic.
Term
often
used
interchangeably
with
VOCs.

Hopi
Point:
An
important
air
quality
monitoring
site
on
the
South
Rim
of
the
Grand
Canyon
in
Grand
Canyon
National
Park.

IAS:
Integrated
Assessment
System,
a
computer
model
created
by
the
GCVTC
to
generate
information
about
future
visibility
and
economic
trends
under
a
variety
of
pollution
control
scenarios.

IMPROVE:
Interagency
Monitoring
of
Protected
Visual
Environments,
a
group
of
federal
agencies
using
a
common
set
of
standards
to
monitor
visibility
across
the
United
States.
Other
nations
have
also
adopted
portions
or
all
of
the
IMPROVE
monitoring
techniques.

Inverse
megameters,
Mm­
1:
A
measurement
unit
used
for
light
extinction,
the
higher
the
value,
the
hazier
the
air
is.

LEV/
ZEV:
Low
Emission
Vehicle/
Zero
Emission
Vehicle,
motor
vehicle
classifications
referring
to
their
tailpipe
release
of
air
pollution.
Today's
ZEV's
are
generally
battery­
powered,
but
may
use
hydrogen
fuel
cells
and
other
energy
sources
in
the
future.

Light
extinction:
The
"
loss"
of
light
as
it
travels
through
the
air.
Light
can
be
truly
lost
by
being
absorbed
by
gases
and
aerosols
in
the
air.
Light
can
also
be
"
lost"
as
it
scatters
off
gases
and
aerosols.

LNG:
Liquefied
Natural
Gas,
a
relatively
clean­
burning
fossil
fuel.

LPG:
Liquefied
Petroleum
Gas,
a
relatively
clean­
burning
fossil
fuel
such
as
propane.
x
Mm­
1:
Inverse
megameters,
a
measurement
unit
used
for
light
extinction,
the
higher
the
value,
the
hazier
the
air
is.

MMA:
Maximum
Management
Alternative,
an
IAS
computer
model
used
to
estimate
the
maximum
visibility
improvements
possible
regardless
of
the
cost
of
the
pollution
controls
used.
The
MMA
was
used
for
comparisons,
rather
than
as
a
policy
option.

Mobile
source:
A
pollution
source
that
moves.
Mobile
sources
are
often
divided
into
road
sources,
including
cars,
trucks,
buses,
and
motorcycles,
and
non­
road
sources
like
trains,
planes,
boats,
lawnmowers,
etc.

Modeling:
The
use
of
a
computer
to
mimic
reality
and
predict
the
future
behavior
of
the
subject
under
study.
Models
of
complex
subjects
like
visibility
are
often
limited
by
the
raw
data
available
and
the
capacity
of
the
computer
itself.
The
GCVTC's
IAS
is
a
computer
model
of
regional
air
quality
for
the
Colorado
Plateau
and
uses
information
from
throughout
western
North
America.

NAAQS:
National
Ambient
Air
Quality
Standards,
levels
of
air
pollution
set
by
the
U.
S.
Environmental
Protection
Agency
to
protect
public
health
and
welfare.
Standards
are
set
for
ozone
(
O3),
carbon
monoxide
(
CO),
sulfur
dioxide
(
SO2),
nitrogen
dioxide
(
NO2),
lead
(
Pb),
and
particulates
(
solid
aerosols).

Non­
attainment
area:
A
geographic
region
where
concentrations
of
a
particular
air
pollutant
exceed
the
NAAQS.
A
particular
location
may
be
non­
attainment
for
more
than
one
pollutant.

NOx:
A
mixture
of
nitrogen
dioxide
and
other
nitrogen
oxide
gases.
Nitrogen
is
the
most
common
gas
in
the
atmosphere.
In
high
temperature
and/
or
high
pressure
burning
(
as
in
an
engine),
the
air's
nitrogen
is
broken
down
and
combined
with
oxygen,
forming
unstable
or
reactive
NOx
gases.
Nitrogen
dioxide
(
NO2)
is
yellowish
brown,
and
thus
contributes
directly
to
haze.
All
the
NOx
gases
react
in
the
air
to
form
hazecausing
aerosols
and
smog.

NPS:
National
Park
Service,
a
federal
agency
charged
with
protecting
the
natural
and
cultural
resources
and
the
processes
that
create
and
sustain
them,
in
the
National
Park
System.

New
Source
Review:
A
review
of
a
new
facility
that
has
the
potential
to
emit
air
pollutants
in
amounts
specified
by
law.
The
review
is
done
to
establish
the
impact
of
the
pollution,
and
the
options
available
to
control
that
pollution.

OC:
Organic
Carbon,
complex
carbon­
containing
compounds
often
emitted
by
plants
and
many
human
activities.
OC2.5
is
organic
carbon
of
2.5
micrometers
of
less.
xi
PAC:
Public
Advisory
Committee,
established
by
the
GCVTC
to
represent
a
broad
range
of
public
interests.
Members
are
drawn
from
all
levels
of
government,
business,
industry,
environmental
organizations,
academia,
and
private
citizens.
The
GCVTC
Commissioners
charged
the
PAC
with
developing
consensus
recommendations
for
managing
visibility.

Particulates:
Solid
material
small
enough
to
remain
suspended
in
the
air.

PM2.5:
Aerosols
with
a
diameter
smaller
than
2.5
micrometers,
the
most
effective
size
range
to
create
haze
(
a
micrometer,
or
micron,
is
one
millionth
of
a
meter,
an
inch
is
25,400
micrometers
long).

PM10:
Aerosols
with
a
diameter
smaller
than
10
micrometers,
on
which
the
EPA
has
based
current
NAAQS.
Larger
aerosols
in
this
size
range
(
larger
than
2.5
micrometers)
are
less
effective
in
creating
haze
than
the
smaller
ones.
In
addition
to
creating
haze,
higher
concentrations
of
PM10
can
also
cause
irritation
of
the
throat
and
lungs,
cancers,
and
early
death.

Point
source:
A
specific
source
of
air
pollution.

Prescribed
fire:
Fires
in
wildland
areas
that
are
allowed
to
burn
under
prescribed
conditions.
The
"
prescription"
reflects
ecosystem
management
goals,
ability
to
control
the
fire,
and
air
quality
concerns.

Prescribed
natural
fire:
A
fire
started
by
natural
processes
(
usually
lightning)
and
allowed
to
burn
as
long
as
it
meets
prescribed
fire
conditions.

PSD:
Prevention
of
Significant
Deterioration.
A
program
established
under
the
Clean
Air
Act
Amendments
of
1977,
whose
goal
is
to
prevent
major
increases
in
air
pollution
in
areas
with
cleaner
air.
The
program
sets
the
tightest
limits
on
pollution
increases
from
large
point
sources
in
Class
I
areas.

Rayleigh
or
Rayleigh
Scattering:
The
natural
scattering
of
light
caused
by
nitrogen
and
oxygen
in
the
atmosphere
which
makes
the
sky
look
blue.
Also
called
"
blue
sky."

Reasonable
progress:
Reasonable
progress
refers
to
progress
in
reducing
humancaused
haze
in
Class
I
areas
under
the
national
visibility
goal.
The
Clean
Air
Act
indicates
that
"
reasonable"
should
consider
the
cost
of
reducing
air
pollution
emissions,
the
time
necessary,
the
energy
and
non­
air
quality
environmental
impacts
of
reducing
emissions,
and
the
remaining
useful
life
of
any
existing
air
pollution
source
considered
for
these
reductions.
The
GCVTC
Public
Advisory
Committee
has
developed
the
following
definition:
"
Reasonable
progress
towards
the
national
visibility
goal
is
achieving
continuous
emission
reductions
necessary
to
reduce
existing
impairment
and
attain
steady
improvement
of
visibility
in
mandatory
Class
I
areas,
and
managing
emissions
growth
so
as
to
prevent
perceptible
degradation
of
clean
air
days."
xii
Re­
entrained
dust/
road
dust:
Fine
and
coarse
dust
stirred
up
from
paved
or
dirt
surfaces
by
the
passage
of
vehicles.
The
dust
may
include
soil
particles,
tire
rubber,
soot,
and
other
materials.

Regional
cap:
A
limit
on
the
amount
of
specific
air
pollutants
that
can
be
released
in
a
defined
geographic
area,
or
a
limit
on
the
amount
of
a
specific
air
pollutant
that
is
allowed
to
be
in
the
air
in
a
defined
geographic
area.

ROG:
Reactive
Organic
Gases,
typically
hydrocarbons
(
HC),
but
include
oxygenated
hydrocarbons.

SIP/
TIP:
State
Implementation
Plan/
Tribal
Implementation
Plan,
plans
devised
by
states
and
tribes
to
carry
out
their
responsibilities
under
the
Clean
Air
Act.
SIP's
and
TIP's
must
be
approved
by
the
U.
S.
Environmental
Protection
Agency
and
include
public
review.

SO2,
SOx,
sulfates:
Compounds
composed
of
oxygen
and
sulfur.
Burning
fuels,
manufacturing
paper,
or
smelting
rock
containing
sulfur
produces
sulfur
dioxide
gas
(
SO2)
which
is
converted
in
the
air
to
other
sulfur
oxides
(
SOx)
or
haze­
causing
aerosols
(
sulfates).

Source:
Where
air
pollutants
are
released.
Sources
are
usually
classified
as
point,
mobile,
or
area
sources.

Source
attribution:
Determining
how
much
a
single
source
contributes
to
air
pollution.

Stationary
source:
An
air
pollution
source
that
remains
in
one
place
(
generally
a
business
or
industrial
facility).

Species:
A
term
used
to
refer
to
types
of
pollutants.

TIP/
SIP:
Tribal
Implementation
Plan/
State
Implementation
Plan,
plans
devised
by
states
and
tribes
to
meet
requirements
of
the
Clean
Air
Act
as
defined
by
the
U.
S.
Environmental
Protection
Agency.

Trading
program:
In
air
quality
management,
a
plan
under
which
some
limit
is
set
on
the
amount
of
an
air
pollutant
that
can
be
released
into
the
air.
If
a
facility
releases
less
than
its
limit,
it
may
trade
or
sell
the
ability
to
release
"
unused"
amount
of
air
pollutant
to
another
facility,
so
the
second
facility
can
release
more
than
the
limit.
xiii
Transfer
coefficient:
In
computer
modeling
of
air
quality,
a
geographic
area
is
divided
into
"
cells."
Transfer
coefficients
are
mathematical
formulas
that
tell
the
computer
how
much
air
pollution
to
"
move"
from
one
cell
to
another.
Determining
a
transfer
coefficient
requires
the
computer
model
designer
to
consider
wind
directions,
chemical
changes
to
the
air
pollutants
as
they
travel,
loss
of
pollutants
from
the
air,
and
other
factors.

Transmissometer:
A
device
that
measures
light
extinction
by
shining
a
light
beam
of
known
brightness
through
the
air
and
measuring
how
much
is
lost
when
the
beam
reaches
a
receiver,
usually
about
4
miles
away.

Urban
plume/
plume
blight:
An
urban
plume
is
the
"
cloud"
(
either
visible
or
invisible)
of
air
pollution
blown
downwind
of
an
urban
area.
Plume
blight
is
a
distinct
band
or
layer
of
visible
air
pollution,
often
from
a
single
pollution
source.

Visibility
impairment:
The
loss
of
clarity
in
the
air
that
results
when
gases
or
aerosols
scatter
and
absorb
light.
We
usually
see
visibility
impairment
as
a
general
haze
or
a
distinct
plume.

VMT:
Vehicle
Miles
Traveled.
This
number
is
a
measure
of
vehicle
usage
and
is
used
to
calculate
the
air
pollution
produced
by
mobile
sources,
such
as
passenger
cars,
tailpipe
emissions
and
or
road
dust.

VOC:
Volatile
Organic
Compound.
A
carbon­
containing
material
that
evaporates,
such
as
gasoline,
some
paints,
solvents,
dry
cleaning
fluids,
and
the
like.
VOC's
contribute
to
ozone
formation
and
may
form
OC
aerosols.
1
I.
INTRODUCTION
The
Colorado
Plateau
is
a
spectacular
landscape
of
massive
landforms,
unique
geology,
and
vivid
colors.
People
from
around
the
world
have
experienced
these
wonders
at
Grand
Canyon,
Canyonlands,
Bryce
Canyon,
Zion,
and
other
national
parks
and
wilderness
areas
on
the
Plateau.
The
panorama
is
a
visual
experience,
and
air
quality
is
the
key
to
full
enjoyment.
On
hazy
days,
when
visibility
is
reduced,
the
human
eye
perceives
a
loss
of
color,
contrast,
and
detail
in
the
landscape.
That
loss
of
visibility
diminishes
the
unique
experience
of
nature's
work
on
the
Plateau.
(
See
pictures
at
the
end
of
this
Section
which
illustrate
variations
in
visibility
at
selected
sites.)

Visibility
and
visual
air
quality
are
daily
issues
for
the
inhabitants
of
the
Colorado
Plateau,
including
Indian
tribes.
They
experience,
on
an
almost
daily
basis,
the
variations
in
visibility
at
national
parks
on
the
Plateau.
The
Colorado
Plateau
has
some
of
the
best
visual
air
quality
in
the
United
States.
Paradoxically,
this
means
that
reduced
visual
air
quality
that
might
go
unnoticed
in
other
parts
of
the
United
States
is
starkly
apparent
on
the
Plateau.
Visual
air
quality
in
the
West
is
quite
sensitive
to
relatively
small
increases
in
pollutants.

Research
shows
that
visual
air
quality
in
the
West
experienced
a
significant
decline
due
to
emissions
from
industrial
activity
from
the
1940s
to
the
1970s.
Visibility­
impairing
emissions
began
to
decline
in
the
1970s
following
enactment
of
the
federal
Clear
Air
Act.
Visual
air
quality
at
national
parks
and
wilderness
areas
on
the
Colorado
Plateau
has
not
appeared
to
change
since
reliable
monitoring
data
became
available
in
the
1980s.
However,
all
the
projections
point
to
continued
population
and
economic
growth
in
the
region
into
the
next
century.
This
growth
is
a
potential
threat
to
air
quality,
and
poses
a
challenge
to
states,
tribes,
and
the
federal
government.

The
National
Visibility
Goal
Under
Federal
Law
Congress
set
a
national
goal
of
remedying
existing
visibility
impairment,
and
preventing
future
impairment,
from
manmade
pollution
at
158
national
parks
and
wilderness
areas
across
the
United
States
as
part
of
the
Clean
Air
Act
Amendments
in
1977.
This
group
includes
sixteen
parks
and
wilderness
areas
on
the
Colorado
Plateau,
as
well
as
others
in
the
Western
United
States.

Congress
adopted
two
main
strategies
to
make
progress
towards
the
national
visibility
goal:
Prevention
of
Significant
Deterioration
(
PSD),
which
focuses
on
new
or
modified
major
sources
that
exceed
specified
emission
thresholds;
and
a
Visibility
Protection
Program
directed
at
existing
sources
of
emissions
that
impair
visibility.
2
1.
The
PSD
Program
The
PSD
program
designates
three
classes
of
areas,
with
those
designated
Class
I
having
the
most
pristine
air
and
receiving
the
greatest
protection
under
the
federal
statute.
Mandatory
federal
Class
I
areas
include
all
national
parks,
all
national
wilderness
areas
and
national
memorial
parks
over
5,000
acres,
and
all
national
parks
over
6,000
acres
in
existence
in
1977.
In
addition,
states
and
tribes
can
designate
Class
I
areas.
Most
Class
I
areas
are
located
west
of
the
Mississippi
River.

Prior
to
either
construction
of
a
major
new
source
or
major
modification
of
an
existing
source,
the
PSD
program
requires
application
to
the
Environmental
Protection
Agency
(
EPA)
or
the
state
for
a
permit.
The
permit
is
issued
only
if
emissions
from
the
new
or
modified
major
source
will
not
exceed,
or
contribute
to
the
exceeding
of,
maximum
allowable
increments
under
the
CAA.

2.
The
Visibility
Protection
Program
Under
the
Visibility
Protection
Program,
states
and
tribes
must
demonstrate
to
the
EPA
in
their
State/
Tribal
Implementation
Plans
(
SIPs/
TIPs)
that
they
will
make
"
reasonable
progress"
toward
achieving
the
national
visibility
goal
established
by
Congress
in
1977.
The
EPA
issued
its
first
regulations
under
the
program
in
1980.
These
regulations
did
not
include
a
tribal
component.
The
first
explicit
consideration
of
tribal
lands
with
respect
to
air
quality
regulations
occurred
in
the
1990
Amendments
to
the
CAA.
These
regulations
are
known
as
plume
blight
regulations
and
focus
on
a
source
or
small
group
of
sources
to
which
visibility
impairment
at
a
Class
I
area
can
be
"
reasonably
attributed."
The
EPA
regulations
require
such
sources
to
adopt
the
best
available
retrofit
technology,
or
BART,
to
reduce
emissions
reasonably
attributed
to
them.

The
next
phase
of
the
EPA's
regulations
under
the
Visibility
Protection
Program
focuses
on
widespread,
regionally
homogeneous
haze
from
a
multitude
of
sources
that
impairs
visibility
over
a
large
area.
These
regulations
are
still
under
development.

Regional
Haze
Haze
and
visibility
problems
do
not
respect
state
and
tribal
boundaries.
Congress
addressed
this
issue
when
it
amended
the
CAA
again
in
1990
and
authorized
the
EPA
to
establish
visibility
transport
regions
as
a
way
to
combat
regional
haze.
Congress
also
specifically
ordered
the
EPA
to
establish
a
visibility
transport
region
for
Grand
Canyon
National
Park,
and
to
create
a
Grand
Canyon
Visibility
Transport
Commission
(
hereafter
referred
to
as
the
GCVTC
or
the
Commission).
The
EPA
established
the
Commission
in
November
1991.

Tribal
Authority
Under
the
Clean
Air
Act
Tribes
have
always
had
the
inherent
right
to
regulate
air
quality
on
tribal
lands.
Under
the
1990
Clean
Air
Act
Amendments
(
CAAA),
the
EPA
may
delegate
authority
to
Indian
tribes
3
to
regulate
air
quality.
For
example,
tribes,
like
states,
can
prepare
permitting
programs
under
Title
V
of
the
CAAA,
and
establish
Tribal
Implementation
Plans
(
TIPs)
and
submit
those
programs
to
the
EPA
for
approval.
Tribal
regulation
of
air
quality
on
the
Colorado
Plateau
and
across
the
Transport
Region
requires
full
consideration
of
tribal
interests
and
the
active
participation
of
Indian
tribes
on
the
GCVTC.

The
Commission's
Mandate
and
Structure
The
Grand
Canyon
visibility
Transport
Region
includes
nine
states
and
211
tribal
lands
2
.
The
states
are:
Arizona,
California,
Colorado,
Idaho,
Nevada,
New
Mexico,
Oregon,
Utah,
and
Wyoming.
Idaho
has
chosen
not
to
participate
in
the
Commission.
The
GCVTC
comprises:

$
The
Governors
or
their
designees
of
each
of
the
states
in
the
Transport
Region
(
with
the
exception
of
Idaho);

$
The
leaders
of
four
Indian
tribes
(
Navajo,
Hopi,
Hualapai,
and
Acoma
Pueblo)
or
their
designees;
and
$
The
EPA
and
federal
land
managers
from
the
National
Park
Service,
Bureau
of
Land
Management,
Fish
&
Wildlife
Service,
and
Forest
Service,
and
the
Columbia
River
Inter­
Tribal
Fish
Commission,
as
ex
officio
members.

Congress
specified
that
the
GCVTC
should
assess
scientific,
technical,
and
other
information
related
to
adverse
visual
air
quality
impacts
from
potential
or
projected
emissions
growth
from
sources
located
in
the
Transport
Region.
The
Commission
adopted
a
work
plan
and
created
a
committee
structure
in
order
to
carry
out
its
tasks.
Technical
committees
drew
upon
expert
resources
in
government,
private
industry,
academia,
and
environmental
groups.

The
Commission's
broad
task
is
to
report
to
the
EPA
on
what
measures,
if
any,
are
appropriate
to
address
visual
air
quality
on
the
Colorado
Plateau.
This
report
must
address
three
areas:

1.
The
establishment
of
"
clean
air
corridors"
and
whether
additional
restrictions
on
emissions
in
these
corridors
are
appropriate
to
protect
visibility
at
Class
I
areas
on
the
Colorado
Plateau.

2.
The
imposition
of
CAA
requirements
affecting
construction
of
new,
major
stationary
sources
or
major
modifications
to
existing
sources
in
clean
air
corridors.

3.
Regulations
to
address
long­
range
strategies
for
regional
haze
that
impairs
visibility
in
Class
I
areas
on
the
Colorado
Plateau.

2
A
list
of
federally
recognized
tribes,
organized
by
geographic
area,
is
included
as
available
from
the
Bureau
of
Indian
Affair
e
National
Tribal
Environmental
Council.
4
The
Commission
created
structures
based
on
principles
of
broad
public
input
and
consensus
in
order
to
carry
out
its
mandate,
including
establishment
of
a
Public
Advisory
Committee
(
PAC).
PAC
members
were
drawn
from
government
at
the
federal,
tribal,
state,
and
local
levels;
business
and
industry;
educational
institutions;
and
environmental
advocacy
groups.

Each
Commissioner
appointed
up
to
five
members
to
the
PAC
representing
a
broad
range
of
the
public,
including
government,
business,
industry,
environmental
organizations,
academia
and
private
citizens.
The
PAC's
tasks
were
to
develop
consensus
recommendations
for
the
Commission,
to
serve
as
a
sounding
board
for
the
Commission
for
social
and
economic
issues
affecting
visibility,
and
to
provide
a
balanced
representation
of
views
on
the
value
and
impacts
of
protecting
visibility
on
the
Colorado
Plateau.
The
PAC
relied
on
the
extensive
scientific
and
technical
work
of
the
other
GCVTC
committees
to
prepare
its
recommendations.
These
other
committees
include
the
Operations
Committee
and
committees
which
report
to
it:
the
Alternatives
Assessment
Committee,
the
Technical
Committee,
and
the
Communications
Committee.

Following
a
series
of
public
meetings
in
April
1996,
the
PAC
and
Operations
Committee
conducted
a
final
review
and
approval
of
these
recommendations
in
May.
The
Commission
formally
considered
the
PAC
and
Operations
Committee
reports
on
June
10,
1996
and
approved
the
recommendations
to
be
forwarded
to
the
EPA
for
action.
Tribal
perspectives
on
the
Commission
process
and
recommendations
are
elaborated
in
Section
IV
of
this
report.

Photographic
Illustration
of
the
Problem
The
following
four
pages
contain
color
photographs
which
illustrate
the
appearance
of
the
average
20%
best
and
worst
days
and
an
average
day
at
four
of
the
National
Parks
and
Wilderness
areas
on
the
Colorado
Plateau.
A
depiction
of
the
average
of
the
20%
worst
or
best
days
means
that
10%
of
the
days
of
the
year
can
be
expected
to
be
worse
or
better,
respectively.
Please
be
aware
of
the
limitations
of
reproduced
photographs.
They
do
not
completely
capture
the
detail
and
color
of
the
originals.
Note
that
the
identification
is
incorrect
for
the
location
of
the
Grand
Canyon
photographs;
the
photographs
were
taken
from
Desert
View.
5
II.
PROCESS
FOR
DEVELOPING
EMISSIONS
MANAGEMENT
RECOMMENDATIONS
STAGES
IN
THE
COMMISSION'S
STUDY
PROCESS
An
understanding
of
the
Commission's
research
and
modeling
process
provides
the
context
for
its
recommendations.
There
were
six
phases
of
the
Commission's
work:

1.
Development
of
an
emissions
inventory
for
the
Transport
Region.

2.
Development
of
a
technical
basis
for
assessing
visibility
impacts
from
changes
in
emissions.

3.
Development
of
criteria
to
evaluate
options.

4.
Development
of
emission
management
options.

5.
Development
of
scenarios
based
on
varying
levels
of
emission
management
options,
including
a
baseline
or
"
current
law"
scenario.

6.
Development
of
a
computer­
based
Integrated
Assessment
System
(
IAS)
to
compare
evaluate
costs
and
visibility
impacts
of
different
scenarios.

The
first
step
in
the
process
was
creating
an
inventory
of
emissions
for
each
state
on
the
Commission,
neighboring
states
(
Idaho,
Montana,
Washington,
and
Texas),
northern
Mexico
and
western
Canada.
This
inventory
uses
1990
as
its
base
year,
and
includes
all
major
stationary
sources
throughout
the
Transport
Region,
and
mobile
and
area
sources
summarized
at
a
county
level.
It
covers
key
gaseous
(
sulfur
dioxide,
nitrogen
oxides,
and
reactive
organic
gases/
ROG)
and
aerosol
(
organic
carbon,
elemental
carbon,
and
fine
and
coarse
particles)
emissions.
Data
specific
to
tribal
lands
have
not
been
checked
for
adequacy
or
accuracy.
Figure
II­
1
provides
a
graphic
presentation
of
key
elements
of
the
emissions
inventory.

Based
on
this
inventory,
the
Commission
then
developed
a
series
of
emission
management
scenarios
and
a
method
for
assessing
the
visibility
and
cost
impacts
of
those
scenarios.
The
Commission
used
three
main
emission
management
frameworks:
a
regional
emission
cap;
a
visibility
standard
for
the
Colorado
Plateau;
and
standardized
control
technology
and
process
requirements.
These
frameworks
were
refined
into
a
series
of
scenarios
that
were
evaluated
under
the
Integrated
Assessment
System,
or
IAS.
The
scenarios
included
a
baseline
or
lower
bound,
which
projected
effects
of
applying
existing
laws
and
regulatory
programs;
an
upper
bound
which
included
maximum
application
of
controls
on
emissions
6
irrespective
of
costs;
and
several
different
intermediate
goals.
Each
scenario
reflected
different
combinations
of
options
and
goals
for
improving
visibility.
7
Figure
II­
1:
Emissions
Inventory
8
The
Commission's
committees
also
developed
technical
tools
for
understanding
the
effect
of
different
emission
sources
on
visibility
at
Class
I
sites,
principally
the
Grand
Canyon.
These
tools
include
transfer
coefficients
that
explain
the
relationship
between
pollution
sources
in
various
locations
and
visibility
at
specific
Class
I
sites.
These
coefficients
have
been
refined
continuously
to
assist
the
Commission
in
its
understanding
of
visibility
impacts.

VISIBILITY
ON
THE
COLORADO
PLATEAU
The
starting
point
for
understanding
the
Commission's
analytical
process
is
visibility.
In
simple
terms,
visibility
depends
on
three
factors:
Rayleigh
scattering,
other
natural
impairment,
and
human­
caused
impairment.
Nitrogen
and
oxygen
in
the
atmosphere
cause
the
sky
to
look
blue;
this
is
Rayleigh
scattering.
Other
natural
sources,
such
as
volcanoes,
wind­
blown
dust,
smoke
from
wildfires,
and
emissions
from
trees
and
plants
also
cause
visibility
impacts
by
scattering
and
absorbing
sunlight.
Human
activities,
from
industrial
manufacturing
to
farming,
also
impair
visibility.
Visibility
varies
depending
on
natural
effects
(
including
weather)
and
their
interactions
with
human­
caused
emissions.

Note:
All
of
the
figures
which
follow
in
this
section
have
been
generated
using
the
Commission's
Integrated
Assessment
System
(
IAS).
These
figures
all
include
future
projections.
Projections
for
2040
are
less
reliable
than
projections
for
2000.

Figure
II­
6
shows
the
relative
visibility
impairment
from
natural
and
human
causes
at
four
Class
I
areas
on
the
Colorado
Plateau:
Hopi
Point,
Mesa
Verde,
Bryce
Canyon,
and
Canyonlands.
Values
are
shown
as
an
annual
average
beginning
in
1990
and
continuing
to
2040,
and
also
as
an
average
for
the
20%
of
days
during
the
year
when
visibility
is
worst.
Visibility
impairment
or
light
extinction
caused
by
light
scattering
and
absorption
that
impairs
visibility
is
stated
in
"
inverse
megameters,"
represented
as
"
Mm
­
1
."
Figure
II­
6
shows
that
natural
causes
account
for
approximately
15
Mm
­
1
to
17
Mm
­
1
of
visibility
impairment
at
these
four
areas
on
average.
The
remaining
visibility
impairment
at
each
area
is
caused
by
human
activities.
This
portion
of
total
visibility
impairment
is
considered
manageable
by
the
Commission,
and
is
the
focus
for
its
recommendations.

For
ease
of
comparison,
light
extinction
can
be
converted
to
the
theoretical
distance
at
which
a
human
eye
could
see
a
large
dark
horizon
feature,
such
as
a
tree­
covered
mountain.
As
extinction
increases,
the
distance
one
can
see
decreases.
For
example,
if
there
is
only
blue
sky
or
Rayleigh
scattering
(
10
Mm
­
1
),
one
could
theoretically
see
a
horizon
feature
245
miles
distant.
If
light
extinction
is
doubled
to
20
Mm
­
1
due
to
natural
and/
or
human
caused
aerosols,
visibility
would
be
reduced
to
about
120
miles.

Figure
II­
2
Figure
II­
2
shows
annual
average
light
extinction
for
one
Class
I
area:
Hopi
Point
in
Grand
Canyon
National
Park
for
1990,
2000,
2010,
and
2040.
The
dark
portion
of
each
vertical
bar
is
the
portion
of
light
extinction
caused
by
Rayleigh
scattering
or
blue
sky.
This
totals
approximately
10
Mm
­
1
.
The
remaining
portion
of
light
extinction
is
caused
by
natural
and
9
human­
caused
aerosols.
This
total
ranges
from
24
Mm
­
1
to
25
Mm
­
1
.
The
corresponding
distance
for
visibility
is
only
about
90
miles.
Figure
II­
2
shows
that
natural
and
humancaused
particles
account
for
the
majority
of
light
extinction
at
Hopi
Point.

Figure
II­
3
Figure
II­
3
shows
the
relative
contributions
of
natural
and
human­
caused
particles
to
visibility
impairment
at
Hopi
Point.
For
a
complete
discussion
of
the
development
of
the
data
underlying
these
figures,
please
refer
to
the
GCVTC
Report,
Options
for
Western
Vistas.
Note
that
the
sources
identified
have
not
been
distinguished
by
location.
Specifically,
the
relative
contribution
to
visibility
impairment
from
"
local"
versus
"
regional"
sources
has
not
been
identified.
Natural
particles
account
for
approximately
5.4
Mm
­
1
of
light
extinction
on
an
annual
average
basis
from
1990
through
2040.
Human­
caused
particles
are
responsible
for
approximately
9
Mm
­
1
of
light
extinction
at
Hopi
Point,
roughly
double
the
amount
caused
by
natural
particles.
In
terms
of
visible
distance,
human­
caused
particles
reduce
visibility
at
Hopi
Point
by
about
66
miles
on
an
annual
average
basis.

Figure
II­
4
Using
its
emissions
inventory
and
other
data,
the
Commission
has
identified
the
major
sources
of
human­
caused
light
extinction
at
Hopi
Point.
This
information
is
shown
in
Figure
II­
4
for
the
period
1990
to
2040,
on
an
annual
average
basis.
Each
source
of
emissions
is
listed
on
the
right
side
of
Figure
II­
4,
along
with
its
corresponding
pattern
shown
in
the
vertical
bars.
Figure
II­
4
shows
that
light
extinction
caused
by
emissions
from
utilities
is
projected
to
decline
by
approximately
1
Mm
­
1
.
This
decline
is
due
to
emissions
reductions.
Light
extinction
caused
by
mobile
sources
is
projected
to
decline
until
approximately
2005,
and
then
increase
through
2040.
The
same
is
true
for
road
dust.
However,
as
noted
on
page
46,
there
is
considerable
uncertainty
surrounding
the
predictions
about
road
dust.

Figure
II­
5
Visibility
varies
from
day
to
day
at
Class
I
sites
on
the
Colorado
Plateau.
Figure
II­
5
shows
the
relative
contributions
of
different
human­
caused
particles
to
light
extinction
on
the
20%
of
"
worst"
days
at
Hopi
Point.

A
comparison
of
Figure
II­
5
with
Figure
II­
4
indicates
that
there
is
approximately
60%
more
light
extinction
caused
by
human
sources
on
the
average
of
"
worst"
days
(
approximately
17
Mm
­
1
)
than
the
annual
average
(
approximately
9
Mm
­
1
).

Figure
II­
6
(
4
pages)

Figure
II­
6
compares
light
extinction
from
natural
and
human
causes
at
four
Class
I
areas
on
the
Colorado
Plateau:
Hopi
Point,
Mesa
Verde,
Bryce
Canyon,
and
Canyonlands.
Values
are
shown
as
an
annual
average
beginning
in
1990
and
continuing
to
2040,
and
also
as
an
average
for
the
20%
of
days
during
the
year
(
71
days)
when
visibility
is
worst.
On
each
graph,
the
bottom
layer
represents
Rayleigh
scattering
and
other
natural
causes
10
of
light
extinction.
The
additional
layers
represent
light
extinction
caused
by
various
human
sources:
stationary,
area,
mobile,
and
Mexico.
The
scale
on
the
right
of
each
graph
shows
visibility
in
distance.

Figure
II­
6
shows
that
natural
causes
account
for
approximately
15
Mm
­
1
to
17
Mm
­
1
of
visibility
impairment
at
these
four
areas
on
average.
The
remaining
visibility
impairment
at
each
area
is
caused
by
humans.
This
portion
of
total
visibility
impairment
is
considered
manageable
by
the
Commission,
and
is
the
focus
for
its
recommendations.

THE
BASELINE
FORECAST
SCENARIO,
BASED
ON
CURRENT
LAW
The
Commission
needed
a
way
to
evaluate
how
its
recommendations
would
affect
visibility
beyond
current
law
and
programs,
and
developed
a
baseline
or
"
current
law"
scenario
to
meet
that
need.
The
Commission
refers
to
this
scenario
as
the
Baseline
Forecast
Scenario
(
BFS).

The
Baseline
Forecast
Scenario
is
the
best
possible
estimate
of
future
visibility
impairment
at
Class
I
areas
on
the
Colorado
Plateau,
assuming
current
law
is
enforced,
with
no
additional
actions
to
protect
visibility.

The
Baseline
Forecast
Scenario
is
built
on
the
following
assumptions:

$
Emissions
growth
or
decline
is
based
on
changes
in
economic
demand
in
the
region
$
Sources
retire
at
a
specific
age
$
New
sources
are
a
mixture
of
new
technology
and
assumed
control
levels
$
State
Implementation
Plans
under
the
Clean
Air
Act
for
attainment
by
2010
are
included,
and
emissions
growth
is
permitted
after
that
time
based
on
economic
growth
$
There
is
no
growth
in
unpaved
road
dust
beyond
1990
$
Emissions
from
Mexico
are
held
constant
Because
visibility
is
highly
variable,
the
Baseline
Forecast
Scenario
analyzes
the
average
of
the
"
best"
and
"
worst"
20%
of
days,
as
well
as
annual
averages.
11
12
13
14
15
Figure
II­
6
16
Figure
II­
6
17
Figure
II­
6
18
Figure
II­
6
19
Figure
II­
7
20
Figure
II­
7
21
Figure
II­
7
Figure
II­
7
shows
current
and
predicted
visibility
impairment
through
2040
under
the
Baseline
Forecast
Scenario
at
the
same
four
Class
I
areas
discussed
above:
Hopi
Point,
Mesa
Verde,
Bryce
Canyon,
and
Canyonlands.
For
each
of
the
four
areas,
the
top
line
shows
visibility
on
the
"
worst"
days,
the
middle
line
shows
the
annual
average
visibility;
and
the
bottom
line
shows
visibility
on
the
"
best"
days.

Figure
II­
7
shows
the
wide
difference
in
air
quality
on
the
"
best"
and
"
worst"
days.
There
is
virtually
no
human­
caused
impairment
on
the
"
best"
days
at
these
four
parks
through
2040.
On
the
"
worst"
days,
visibility
impairment
is
more
than
doubled,
and
most
of
that
increase
is
caused
by
human
sources.
This
is
particularly
significant
because
the
human
eye
is
more
sensitive
to
changes
in
the
"
worst"
visibility
conditions
than
the
"
best"
conditions.

PAC
INTERACTIONS
IN
DEVELOPING
CONSENSUS
RECOMMENDATIONS
Members
of
the
PAC
represented
diverse
interests
from
throughout
the
West.
Given
the
divergent
perspectives
and
concrete
interests,
the
struggle
to
consensus
was
difficult
at
times,
but
PAC
members
maintained
a
cordial
atmosphere
of
collaboration
in
their
search
for
good
policy.
The
resulting
policy
recommendations
do
not
represent
what
any
one
group
would
have
advocated
on
its
own.
The
recommendations
embody
concessions,
compromises
and
creative
solutions
which
all
members
of
the
PAC
support.

The
PAC
assisted
in
gathering
public
input
at
different
phases
of
this
process
to
refine
emission
management
options
and
evaluation
criteria.
In
November
1995,
the
PAC
received
a
contractor's
report
entitled
Options
for
Improving
Western
Vistas.
That
report
summarized
the
work
of
the
Commission's
committees
to
that
point
and
discussed
the
results
of
Integrated
Assessment
System
modeling.
Based
on
that
report
and
other
technical
information,
and
with
continuing
input
from
the
Commission's
committees
and
the
general
public,
the
PAC
developed
consensus
recommendations
for
consideration
by
the
Commission.
It
should
be
noted
that
there
is
a
significant
divergence
among
the
scenarios
analyzed
in
the
technical
assessment
process
and
the
recommendations
included
herein.
To
the
extent
that
the
recommendations
diverge
from
the
Commission's
analyses,
they
reflect
the
input
from
the
public
and
deliberations
of
the
PAC.

The
Commission
sought
broad
public
input
to
develop
its
emission
management
options
and
evaluation
criteria.
Beginning
in
April
1993
and
continuing
until
November
1995,
the
Commission
held
several
series
of
public
workshops
and
meetings
across
the
Transport
Region
to
provide
information
and
receive
feedback.
Public
comments
were
discussed
at
PAC
meetings
and
incorporated
into
the
PAC's
recommendations
to
the
Commission.

CRITERIA
FOR
ASSESSMENT
OF
EMISSIONS
MANAGEMENT
OPTIONS
The
Commission
developed
six
criteria
for
assessing
different
emission
management
strategies:
22
1.
effectiveness
in
achieving
visibility
goals
2.
economic
effects
3.
social
effects
4.
environmental
effects
in
addition
to
visibility
5.
equity,
and
6.
administrative
ease
and
effectiveness
The
purpose
of
these
criteria
is
to
ensure
that
all
significant
impacts
of
different
emission
management
strategies
are
considered
in
making
recommendations
for
the
future.

Most
of
the
available
scientific
and
technical
informationCemissions
budgets,
emission
management
options,
scenarios,
criteria,
and
transfer
coefficientsCis
brought
together
in
the
Integrated
Assessment
System
(
IAS).
The
Commission's
goal
in
designing
the
IAS
was
to
enable
a
user
to
select
different
combinations
of
emission
reduction
strategies
applied
to
sources
within
the
Transport
Region
to
yield
desired
visibility
conditions
at
any
one
of
sixteen
Class
I
sites
on
the
Colorado
Plateau
over
the
next
forty
years
(
2000,
2010,
2020,
2030,
and
2040).
Development
of
the
IAS
was
a
major
task,
and
work
continues
to
expand
its
capabilities.
Most
of
the
modeling
output
to
date
is
based
on
visibility
at
a
single
Class
I
site,
Hopi
Point
in
Grand
Canyon
National
Park.

TECHNICAL
FOUNDATION
FOR
THE
COMMISSION'S
RECOMMENDATIONS
Introduction
In
order
to
fulfill
its
mandate,
the
Commission
needed
a
reliable
picture
of
the
impacts
of
regional
haze
on
visibility
at
sixteen
Class
I
areas
on
the
Colorado
Plateau,
and
a
way
to
assess
the
changes
in
visibility
and
costs
associated
with
different
options
for
managing
emissions.
Meeting
these
needs
was
not
simply
a
matter
of
gathering
existing
data
and
running
it
through
a
basic
computer
model.
The
Commission
needed
new
information
and
new
analytical
tools,
and
its
technical
committees
and
outside
consultants
have
done
groundbreaking
work
to
meet
these
needs
in
only
a
few
years.
This
work
has
significantly
improved
understanding
of
visibility
impairment
in
the
Transport
Region,
and
provides
the
technical
foundation
for
the
Commission's
recommendations.

It
is
important
to
understand
that
this
technical
work,
while
representing
a
significant
advance
in
knowledge,
is
not
yet
complete.
The
large
size
and
complex
terrain
of
the
Transport
Region,
the
time,
funding,
and
other
resources
available
for
work,
significant
data
gaps,
and
the
amount
of
information
that
could
be
modeled
with
current
technology
were
important
limiting
factors.
As
a
result,
the
Commission's
technical
data
and
findings,
discussed
below,
are
characterized
by
varying
degrees
of
uncertainty.
In
particular,
the
modeling
has,
to
date,
given
a
limited
picture
of
the
regional,
and
particularly
sub­
regional,
including
tribal,
dynamics
of
both
emissions
and
economics.
Nevertheless,
the
Commission
has
sufficient
confidence
in
its
overall
understanding
of
the
causes
of
regional
haze
and
its
effects
on
visibility
to
make
the
recommendations
presented
in
Section
III.
23
Important
Technical
Data
Findings
The
following
are
some
of
the
results
and
technical
findings
from
the
Commission's
work
to
date
which
form
a
basis
for
policy
recommendations.

$
The
most
comprehensive
inventory
to
date
of
emissions
across
the
Transport
Region.
The
Commission
gathered
1990
data
from
a
variety
of
sources
to
create
the
most
comprehensive
inventory
yet
of
emissions
for
the
Transport
Region.
This
inventory
is
the
cornerstone
for
most
emissions
forecasting
by
the
Integrated
Assessment
System
model.

$
The
Commission's
current
modeling
shows
improvements
in
visibility,
under
existing
regulations
and
programs,
through
the
year
2000.
After
that,
predicted
gains
in
visibility
are
offset
by
increases
in
economic
activity
related
to
population
increases.

$
Regional
phenomena
can
contribute
to
visibility
impairment.
The
Commission's
air
quality
monitoring
data
and
modeling
show
that
a
part
of
the
haze
problem
can
be
caused
by
long­
range
transport
of
emissions.
Visibility
at
Class
I
sites
on
the
Colorado
Plateau
is
affected
by
pollutants
that
have
travelled
long
distances,
i.
e.,
more
than
approximately
100
miles.
These
pollutants
often
cross
the
boundaries
of
several
states
within
the
Transport
Region.
Some
centrally
located
emission
sources
are
frequent
contributors
to
visibility
impairment
at
multiple
receptor
sites
across
the
Transport
Region,
regardless
of
wind
direction.
In
addition,
Clean
Air
Corridors
are
a
regional
phenomenon
of
clear
air
transport
from
low
emission
areas
located
to
the
north.

$
There
is
also
a
local
aspect
to
the
haze
problem
on
the
Colorado
Plateau.
Emissions
from
sources
located
roughly
under
100
miles
away
can
affect
visibility
at
Class
I
sites.
These
local­
source
emissions
are
less
diluted
than
emissions
that
travel
long
distances.
The
Commission
has
an
improved
understanding
of
the
conditions
that
lead
to
local
source
impacts
on
visibility.
For
example,
local
emissions
can
build
up
during
windless
periods,
and
are
subject
to
being
trapped
above
low­
lying
terrain
during
temperature
inversions.
Also,
urban
areas
(
Las
Vegas
and
Salt
Lake
City)
have
been
studied
and
may
have
significant
3
impacts
on
visibility
at
the
Grand
Canyon
and
Canyonlands,
respectively.

The
Commission's
current
analyses
suggest
that
visibility
impairment
caused
by
local
sources
may
be
much
greater
than
predicted
by
prior
studies.
If
correct,
these
new
3
In
numerous
places,
this
report
refers
to
"
significant"
contributions
to
visibility
impairment
and
"
significant"
decreases
or
increase
issions,
but
"
significant"
is
not
defined.
"
Significant"
will
be
defined
in
the
context
of
developing
implementation
plans
with
rticipation
by
the
affected
parties.
24
analyses
have
significant
implications
for
reducing
current
visibility
impairment.
In
light
of
their
conflict
with
prior
studies,
the
Commission's
results
should
be
treated
with
caution.
Years
of
technical
work
may
be
necessary
before
the
relative
visibility
impacts
of
local
sources
can
be
confirmed.

$
The
relative
visibility
effects
of
regional
and
local
emissions
are
variable,
but
local
emissions
have
a
greater
impact
per
ton
emitted.
Seasons,
weather
conditions,
and
terrain
elevations
influence
the
relative
visibility
impacts
of
regional
and
local
emissions.
Both
emission
types
contribute
to
visibility
impairment
much
of
the
year,
and
either
type
can
be
the
dominant
cause
of
impairment
on
any
particular
day
regardless
of
the
season
or
the
location
of
a
receptor.
There
is
little
doubt,
however,
that
local
emissions
have
a
greater
visibility
impact
per
ton
emitted
than
emissions
from
distant
sources.

$
Wildfire
and
prescribed
fire
play
an
important
role
in
visibility
on
the
Colorado
Plateau.
During
coming
years,
land
managers
are
projecting
significant
increases
in
prescribed
fire
in
order
to
reduce
the
effects
of
wildfire
resulting
from
past
decades
of
fire
suppression.
Therefore,
prescribed
fire
has
the
potential
for
outweighing
visibility
improvements
on
an
episodic
basis.

$
Emissions
from
Mexico
are
significant
and
growing,
particularly
contributing
to
the
SO2
emission
budget.
Without
control
strategies
for
Mexican
sources,
they
will
have
continuing
and
growing
adverse
visibility
effects.

$
Visibility
effects
are
a
combination
of
emissions
and
meteorology
and
other
uncontrollable
factors,
such
as
wildfire.
Meteorology
and
wildfire
can
vary
significantly
from
year
to
year.
Therefore,
in
assessing
the
visibility
gains
from
an
emissions
management
strategy,
measurements
of
visibility
from
any
one
year
may
not
show
improvements.
Data
trends
from
multiple
years
are
needed.
In
the
short
term,
gains
or
losses
in
visibility
may
be
better
represented
by
the
emissions
inventory
than
from
monitoring
data
at
Class
I
sites.

$
Source
areas
with
large
transfer
coefficients
merit
particular
attention.
The
Commission
developed
transfer
coefficients
for
95
source
areas
across
the
Transport
Region
as
a
tool
to
model
changes
in
visibility.
In
the
simplest
sense,
each
source
area's
transfer
coefficients
represent
the
mathematical
relationship
between
emissions
in
that
source
area
and
aerosol
concentrations
at
a
specific
Class
I
receptor.
The
Integrated
Assessment
System
model
indicates
that
emissions
reductions
will
yield
the
greatest
visibility
improvements
if
they
occur
in
source
areas
having
"
large"
transfer
coefficients
and
large
emissions.
Source
areas
having
large
transfer
coefficients
but
low
emissions
merit
increased
attention
in
emissions
planning.
Finally,
for
any
specific
reduction
in
emissions,
source
areas
with
large
transfer
coefficients
will
yield
the
largest
improvements
in
visibility
at
Class
I
sites.
25
Summary
of
Data
and
Model
Limitations
The
Commission's
technical
models
are
designed
primarily
to
assess
the
regional
impacts
of
pollutant
transport,
i.
e.,
to
give
a
picture
of
how
pollutants
travel
across
the
nine­
state
Transport
Region.
The
meteorological
and
air
quality
models
simulate
regional
scale
phenomenaCsuch
as
windCreasonably
well.
The
models
are
best
at
demonstrating
the
relative
effects
of
regional
emissions
on
visibility.
As
a
result,
the
Commission
has
a
reliable
understanding
of
the
relative
significance
of
most
regional
sources.
For
example,
information
shows
that
Southern
California
is
the
largest
regional
source
of
visibilityimpairing
particles
in
the
Transport
Region.

Because
the
Integrated
Assessment
System
models
were
designed
with
a
regional
transport
focus,
they
offer
only
limited
insights
into
(
1)
the
absolute
contributions
to
visibility
impairment
from
"
local"
sources
located
under
approximately
100
miles
of
Class
I
sites,
and
(
2)
the
visibility
impacts
of
local
sources
relative
to
regional
sources.
The
Integrated
Assessment
System
permits
qualitative
understanding
of
local
source
influences,
but
does
not
permit
quantitative
understanding.
In
particular,
the
Integrated
Assessment
System
model
is
not
designed
to
be
used
for
local
source
attribution.
Accordingly,
further
study
on
local
sources
should
be
undertaken
prior
to
enactment
of
recommendations
for
emissions
controls
on
specific
local
sources.

There
are
several
reasons
for
the
limitations
in
the
Integrated
Assessment
System
model
concerning
local
source
impacts
on
visibility.

$
Most
of
the
modeling
was
done
using
coarse
grid
cells
measuring
thirty
miles
on
each
side.
Modeling
the
transport
and
dispersion
of
pollutants
between
adjacent
cells
did
not
reflect
the
actual
physics
of
such
activity.
The
Commission
used
a
fine
grid
(
six
mile)
for
several
major
sources
for
a
limited
period
of
the
modeled
year.
While
this
approach
should
improve
the
model's
performance,
data
and
time
limitations
made
it
impractical
as
a
substitute
for
all
of
the
coarse­
grid
analysis.

$
While
the
Commission's
model
reliably
simulates
the
effects
of
meteorological
factors
on
pollutant
transport,
it
does
not
simulate
effects
caused
by
"
smaller"
terrain
features
such
as
the
Grand
Canyon.

$
The
model's
projected
visibility
impacts
are
scaled
to
reflect
actual
measurements.
This
means
that
an
inaccurate
projection
of
local
influence
on
visibility
causes
a
distortion
of
the
regional
influence.

$
The
model's
projections
of
pollutant
concentrations
at
Class
I
areas
are
generally
in
the
form
of
seasonal
and
annual
averages,
and
the
20%
best
and
worst
days.
Day­
to­
day
variations
in
pollutant
concentrations
are
not
projected.
This
is
a
significant
limitation
because
visibility
changes
are
instantaneous,
occurring
within
hours
depending
on
meteorology.
26
$
In
addition,
uncertainties
in
the
emission
inventory,
meteorology,
atmospheric
chemistry
and
transport
modeling
methods,
and
background
assumptions
contribute
to
uncertainties
in
the
modeled
relative
contributions
of
sources
in
the
region.
Although
these
have
not
been
quantified,
they
could
have
a
significant
effect
on
the
model
results.

One
other
important
limitation
involves
the
number
of
receptors
where
pollution
data
were
available.
The
Commission
collected
data
from
only
six
receptors,
and
ultimately
scaled
its
modeling
for
only
four
of
these:
Hopi
Point,
Mesa
Verde,
Canyonlands,
and
Bryce
Canyon.
The
most
detailed
information
came
from
one
receptor,
Hopi
Point
in
Grand
Canyon
National
Park.
As
a
result,
the
Commission
has
a
reliable
understanding
of
visibility
impacts
at
Hopi
Point.
However,
this
single
receptor
does
not
provide
a
comprehensive
picture
for
the
entire
Grand
Canyon,
let
alone
the
other
15
Class
I
sites
on
the
Colorado
Plateau.

Even
with
these
limitations,
however,
the
Commission's
models
and
its
technical
data
and
findings
provide
an
adequate
foundation
for
the
recommendations
presented
in
the
next
section.
27
SECTION
III:
EMISSIONS
MANAGEMENT
RECOMMENDATIONS
GUIDING
PRINCIPLES
In
developing
the
set
of
recommendations
that
follow,
the
Commission
has
been
guided
by
several
general
principles.

Achieve
Reasonable
Progress
Toward
the
National
Visibility
Goal
The
overall
goal
of
the
Commission's
recommendations
is
to
improve
visibility
on
the
worst
days
and
to
preserve
existing
visibility
on
the
best
days,
at
Class
I
areas
on
the
Colorado
Plateau.
Reasonable
progress
towards
the
national
visibility
goal
is
achieving
continuous
emission
reductions
necessary
to
reduce
existing
impairment
and
attain
steady
improvement
of
visibility
in
mandatory
Class
I
areas
and
managing
emissions
growth
so
as
to
prevent
perceptible
degradation
of
clean
air
days.

Address
All
Important
Sources
of
Visibility
Impairing
Emissions
The
recommendations
are
designed
to
address
all
important
sources
of
visibility
impairing
emissions.

Apply
Emissions
Control
Measures
Equitably
The
Commission
has
sought
to
distribute
the
burden
of
improving
visibility
in
an
equitable
manner.
No
single
source
or
geographic
region
should
be
unfairly
required
to
bear
costs
or
limit
expansion
while
others
are
not.
The
Commission
recognizes
that
equity
considerations
require
that
past
emissions
reductions,
current
levels
of
control,
technical
feasibility,
cost
of
controls,
the
time
necessary
for
compliance,
the
energy
and
non­
air
quality
environmental
impacts,
the
remaining
useful
life
of
existing
emissions
sources,
and
other
relevant
equity
factors
must
be
considered
in
achieving
reasonable
progress.

Prevent
Future
Visibility
Impairment
by
Protecting
Clear
Days
Key
strategies,
imbedded
in
many
of
the
recommendations,
are
aimed
at
protecting
the
present
sources
of
clear
days
at
Class
I
sites
on
the
Colorado
Plateau.

Remedy
Existing
Impairment
by
Reducing
Present
Levels
of
Emissions
Present
emissions
that
cause
visibility
impairment
must
be
reduced
significantly
in
order
to
improve
visibility.
28
Take
a
Regional
Approach
Strategies
for
both
preventing
future
impairment
and
remedying
existing
impairment
demand
regional
approaches
that
can
be
applied,
in
a
coordinated
manner,
by
tribes,
states,
and
federal
authorities
throughout
the
Transport
Region.
Such
strategies
should
be
developed
in
concert
with
existing
cooperative
efforts
to
assess
and
manage
air
quality
within
the
region.

Assume
that
Existing
Federal,
Tribal
and
State
Laws
Will
Remain
in
Force
The
recommendations
assume
that
state,
tribal
and
federal
air
quality
laws,
programs,
and
regulations
will
remain
in
force
for
the
foreseeable
future.

Consider
Costs
and
Benefits
of
Emission
Control
Measures
The
Commission
has
been
guided
in
most
cases
by
estimates
of
the
costs
and
improvements
to
visibility
associated
with
various
strategies
for
controlling
emissions.

Develop
Action
Plans
for
All
Recommendations
The
responsible
entities
should
develop
detailed
plans
for
implementing
Commission
recommendations.

Provide
Funding
Specific
funding
sources
should
be
identified
for
implementing
the
Commission's
recommendations.

Consider
Social,
Cultural
and
Environmental
Factors
In
analyzing
the
potential
impacts
of
recommendations,
social,
cultural
and
environmental
costs
and
benefits
should
be
considered.

Note:
For
tribal
perspectives
and
commentary
on
the
recomme
29
AIR
POLLUTION
PREVENTION
Background:
Pollution
Prevention
as
Key
to
Protection
of
Western
Vistas
The
spectacular
scenery
of
national
parks
and
wilderness
area
on
the
Colorado
Plateau
is
an
important
part
of
our
Nation's
natural
heritage.
We
have
a
legal
and
moral
obligation
to
protect
this
national
resource
for
future
generations.
Visibility
in
this
region
is
extremely
sensitive
to
even
small
increases
and
decreases
in
air
pollution.

As
the
population
and
economy
of
the
West
grow,
the
only
way
to
prevent
further
degradation
of
this
national
resourceCas
well
as
the
air
we
share
generally
throughout
the
WestCis
to
combine
cost­
effective
pollution
control
strategies
with
a
greater
emphasis
on
air
pollution
prevention,
including
low
or
zero
emissions
technologies
and
energy
conservation.
Because
so
much
of
the
Transport
Region
is
relatively
undeveloped,
including
tribal
lands,
regional
stakeholders
have
the
opportunity
to
take
a
proactive
approach
to
pollution
prevention.
In
fact,
given
expected
growth
in
the
Transport
Region,
it
provides
an
excellent
place
to
experiment
with
an
incentive­
based
approach
to
managing
not
only
air
quality
but
other
environmental
effects
of
growth.

As
demand
for
more
power
increases,
and
the
region's
power
production
base
evolves,
there
is
a
tremendous
opportunity
to
realize
substantial
benefits
from
energy
efficiency,
as
well
as
to
integrate
cleaner,
sustainable
energy
technologies
into
all
aspects
of
our
society.
The
West
enjoys
high
potential
for
renewable
energy
production,
especially
electrical
energy
generation
employing
solar
and
wind
power.
The
relative
cost
of
renewables
is
declining
over
time.
Based
on
forecasts
of
electrical
energy
consumption
in
the
Transport
Region
by
the
Western
Systems
Coordinating
Council,
renewables
could
supply
18,000
gigawatt
hours
of
energy
annually
by
2002.
Others
have
suggested
that
this
potential
could
be
much
higher
(
approaching
50,000
gigawatt
hours
annually)
from
renewables
(
geothermal,
solar
and
wind)
by
2002.
These
latter
targets
would
still
only
comprise
approximately
10%
of
region­
wide
power
consumption.
A
recent
study
by
the
Land
and
Water
Fund
of
the
Rockies
(
How
the
West
Can
Win,
1996)
suggests
that
renewable
energy
could
comprise
19%
of
regional
power
needs,
by
adding
additional
capacity
by
2015.
The
study
also
concludes
that
as
much
as
40%
of
projected
power
needs
in
2015
could
be
met
by
improved
energy
efficiency
alone..

Based
on
estimates
of
renewable
energy
potential,
achieving
the
above
goals
for
renewables
and
efficiency
could
result
in
substantial
emissions
reductions,
which
could
translate
into
visibility
improvements,
as
well
as
secondary
environmental
and
economic
benefits.
Although
the
Commission
did
not
have
the
resources
necessary
to
model
or
completely
quantify
the
effects
of
its
recommendations
in
this
area,
it
is
convinced
that,
if
30
implemented,
they
have
the
potential
to
become
some
of
the
most
successful
and
costeffective
contributions
to
improved
visibility.

Hastening
the
utilization
of
renewables
requires
new
and
increased
investments,
assisted
by
economic
incentives.
Huge
economic
and
environmental
benefits
from
improving
energy
efficiency
gains
are
also
possible
with
adequate
commitment
and
investment,
since
investment
in
energy
efficiency
is
the
most
cost­
effective
resource
option.

RECOMMENDATIONS
REGARDING
AIR
POLLUTION
PREVENTION
1.
Place
a
high
priority
on
pollution
prevention.

Supporting
pollution
prevention,
education
about
pollution
prevention,
and
innovative
ways
of
reducing
per
capita
pollution
is
one
of
the
Commission's
highest
priorities.

2.
Model
the
effects
of
renewable
energy
and
pollution
prevention.

Potential
emissions
reductions,
visibility
improvements,
cost
savings,
and
secondary
benefits
associated
with
renewables,
energy
efficiency,
and
pollution
prevention
should
be
part
of
future
modeling
work.

3.
Develop
economic
incentives
for
pollution
prevention
efforts.

Economic
incentives
are
a
powerful
tool
for
effecting
change.
The
Commission
supports
creation
of
incentives
that
encourage
low­
emission
industries
to
locate
in
the
Transport
Region,
retooling
of
industries
to
reduce
emissions
and
increase
their
efficient
use
of
energy,
the
development
of
energy
production
based
on
renewable
resources,
and
providing
consumers
with
opportunities
to
reduce
their
individual
contributions
to
air
pollution.
The
Commission
recommends
that
federal
power
management
suppliers
be
given
incentives
to
increase
renewable
energy
generation
and
pollution
prevention
actions,
and
that
public
utility
commissions
continue
to
influence
retail
power
markets
to
encourage
efficiency
and
investments
in
renewables.

4.
Encourage
zero
and
near­
zero
emitting
technologies.

The
Commission
encourages
zero
and
near­
zero
emitting
technologies
through
incentives,
education
and
information
exchange,
such
as
a
clearinghouse.
Opportunities
should
be
explored
to
promote
economic
development
and
job
creation
through
the
development
and
deployment
of
such
technologies.

5.
Provide
incentives
for
actions
beyond
compliance.

Incentives
should
also
be
provided
to
reward
efforts
that
go
beyond
compliance
and/
or
achieve
early
compliance
with
air
pollution­
related
requirements.
31
6.
Consider
charging
emission
fees.

A
variety
of
market
approaches
should
be
analyzed.
Emission
fees
could
be
charged
for
pollution
emitted
into
the
air
to
encourage
people
and
industry
to
reduce
pollution
in
the
most
efficient
manner
possible.
Revenues
could
be
used
to
substitute
for
taxes
on
property
or
income
or
to
provide
financial
assistance
to
those
industries
or
communities
wishing
to
implement
pollution
prevention
projects.
Emission
fee
caps
that
exist
in
some
states
should
be
analyzed.

7.
Support
development
of
renewable
energy
sources.

The
Commission
promotes
the
transition
to
power
production
based
on
renewable
resources
such
as
wind,
solar,
biomass,
and
geothermal
resources
and
supports
the
establishment
and
tracking
of
annual
goals
for
increases
in
renewable
power
generation
in
the
Transport
Region
that
fosters
the
sustained,
orderly
development
of
renewables
in
the
region.
Specific
areas
should
be
identified
where
renewables
have
the
potential
to
supply
power
where
it
is
now
lacking
and
where
renewables
are
most
cost­
effective.
Encouraging
development
of
renewables
has
particularly
high
potential
for
tribal
lands
(
see
page
69).
The
goal
of
the
states
in
the
Transport
Region
should
be
to
achieve
annual
additions
in
order
that
renewables
will
comprise
10%
of
the
regional
power
needs
by
2005
and
20%
by
2015.

Progress
towards
this
goal
should
be
evaluated
every
five
years,
in
conjunction
with
regular
reviews
of
emissions
reductions
and
progress
toward
the
national
visibility
goal.
Incentives
provided
by
tribal,
state
and
federal
governments
may
be
necessary
to
achieve
this
goal.
In
the
interests
of
equity,
the
Commission
recommends
that
spending
and
investment
in
energy
research
and
development
should
be
equalized
among
fossil
fuel­
based
and
renewable
energy
programs.
The
EPA
should
coordinate
with
the
Department
of
Energy
to
achieve
funding
for
the
range
of
pollution
prevention
programs
authorized
by
the
Energy
Policy
Act
and
administered
by
the
Department
of
Energy's
Center
of
Excellence
for
Sustainable
Development.
All
new
power
generation
projects
should
include
a
percentage
of
renewables
associated
with
them,
in
order
to
help
achieve
regional
renewable
energy
portfolio
goals.

8.
Promote
energy
conservation.

The
Commission
supports
the
continued
development
and
implementation
of
national
energy
efficiency
standards
for
motors,
appliances
and
lighting
and
recommends
the
national
adoption
of
California
energy
efficiency
standards.
The
Commission
also
supports
the
construction
of
energy
efficient
buildings,
both
residential
and
commercial,
and
proposes
the
reinstatement
of
incentives
for
building
energy
efficient
structures
similar
to
those
in
place
during
the
early
1970s.
The
Commission
also
suggests
the
continuation
of
demand­
side
management
programs,
despite
current
funding
restrictions.
The
Commission
recommends
that
continuing
attention
32
be
paid
to
maintaining
the
role
of
energy
conservation
within
the
changing
electric
power
industry
markets.
Energy
conservation
programs
should
be
preserved
and
expanded
through
such
mechanisms
as
"
system
benefit
charges"
paid
at
the
distribution
level,
rather
than
in
the
commodity
electricity
rate.
This
approach
would
be
equitable
and
would
not
disadvantage
utilities
in
relation
to
their
competitors.

9.
Promote
education
and
public
outreach
efforts
on
preventing
pollution.

The
Commission
encourages
the
integration
of
pollution­
prevention
and
renewable
energy
concepts
in
elementary,
secondary,
higher
and
continuing
education
programs
and
in
public
environmental
education
efforts.
Teaching
by
first­
hand
example,
through
the
incorporation
of
energy
efficient
technologies
at
school
facilities
is
encouraged.

10.
Introduce
product
labeling.

The
Commission
recommends
a
market­
based
approach
to
pollution
prevention
and
energy
conservation
and
efficiency
through
"
green
pricing."
The
EPA,
the
Federal
Energy
Regulatory
Commission
and
the
states
should
institute
labeling,
on
a
voluntary
basis
at
first,
but
potentially
based
on
national
standards,
that
provides
consumers
with
information
about
the
pollution
potential,
energy
requirements
and
relative
efficiency
of
products.
Voluntary
product
labeling
can
be
beneficial
to
businesses
by
providing
more
consumer
information
and
improving
product
attractiveness
in
the
marketplace.
Such
approaches
could
begin
with
a
limited
scope,
such
as
providing
information
to
consumers
about
the
characteristics
of
their
sources
of
electric
power
generation.

11.
Promote
the
use
of
clean
fuels.

The
Commission
also
supports
the
regional
use
of
cleaner­
burning
fuels,
including
reformulated
gasoline
and
diesel
and
extending
towards
natural
gas,
electricity
and
hydrogen.
33
STATIONARY
SOURCES
Background
Emissions
from
stationary
sources
throughout
the
Transport
Region
contribute
in
varying
degrees
to
light
extinction
in
Class
I
Areas.
The
extent
to
which
these
sources
produce
pollutants
that
impair
visibility
is
a
function
of
the
size
of
the
source
and
its
location
in
relation
to
the
protected
areas.
The
GCVTC
analytical
work
addressed
three
species
of
pollutants
that
are
significantly
produced
by
stationary
sources:
sulfates,
nitrates
and
organic
compounds.
This
section
of
the
recommendations
proposes
a
program
to
deal
with
all
species,
but
focuses
on
sulfates,
which
are
the
most
significant
contributor
to
visibility
impairment
of
the
three.

Because
of
the
significance
of
the
role
sulfates
have
played
in
the
Commission's
studies
and
analyses
related
to
visibility,
more
information
is
available
related
to
sulfates
and
their
relationship
to
light
extinction.
Additionally,
because
SO2,
the
dominant
precursor
to
sulfates,
is
associated
with
a
relatively
small
number
of
large
sources,
trends
in
emissions
can
be
forecasted
with
a
relatively
high
degree
of
certainty.
Moreover,
the
Commission
is
aware
of
efforts
to
restructure
the
utility
industry
and
should
monitor
its
impact
on
regional
visibility.

The
stationary
source
proposal
envisions
relying
on
the
implementation
of
current
programs
through
the
year
2000
before
the
implementation
of
a
new
regulatory
program.
Current
programs
include
those
mandated
by
the
federal
Clean
Air
Act
and
by
states
and
tribes
that
have
resulted
in
or
are
expected
to
result
in
the
installation
of
significant
emission
control
technologies
with
associated
emission
reductions.
The
Baseline
Forecast
Scenario
conservatively
estimated
only
a
6%
reduction
(
13%
in
the
Transport
Region)
in
the
emissions
of
sulphur
dioxide
(
SO2)
through
the
year
2000.
However,
implementation
of
current
programs
could
result
in
greater
reductions
in
SO2
emissions
in
the
short
term.
In
particular,
a
number
of
open
issues
with
a
bearing
on
the
visibility
problem
could
be
resolved
prior
to
2000.
These
include
the
Asource
attribution@
studies
at
the
Centralia,
Mohave
and
Hayden
power
plants,
greater
than
expected
emission
reductions
in
the
copper
smelting
industry,
and
the
imposition
of
lower
fuel
sulfur
standards.
With
these
additional
reductions
not
anticipated
by
the
Baseline
Forecast
Scenario,
it
is
estimated
that
actual
SO2
reductions
could
be
closer
to
20­
30%.

A
major
component
of
this
proposal
is
that,
if
a
regulatory
program
is
deemed
necessary,
it
may
be
an
incentive­
based
trading
program
(
e.
g.,
including,
but
not
limited
to,
a
markettrading
program.)
It
is
the
intent
of
this
recommendation
that
any
trading
program
include
as
many
source
categories
and
species
of
pollutants
as
is
feasible
and
technically
defensible.
This
preference
for
a
Acomprehensive@
market
is
based
upon
the
expectation
that
a
comprehensive
program
would
be
more
effective
at
improving
visibility
and
would
34
yield
more
cost­
effective
emission
reduction
strategies
for
the
region
as
a
whole.
However,
the
Commission
recognizes
that
the
inclusion
of
multiple
pollutants
and
sources,
as
well
as
inter­
pollutant/
sector
trading,
raises
a
number
of
complex
issues
(
e.
g.,
emission
inventories,
validity
of
reductions,
etc.)
that
would
need
to
be
addressed
before
multiple
sources
or
pollutants
could
be
included.

The
Commission
also
recommends
that
any
incentive
program
contain
specific
provisions
to
encourage
and
reward
early
emission
reductions,
including
reductions
achieved
before
2000.
The
Commission
recognizes
the
potential
impact
this
will
have
on
less­
developed
areas,
including
Indian
lands.
Also,
the
program
should
include
incentives
for
emission
reduction
measures
that
go
beyond
pollution
controls
(
e.
g.,
investment
in
renewable
energy
and
energy
conservation
measures.)

RECOMMENDATIONS
REGARDING
STATIONARY
SOURCES
The
objectives
of
the
approach
outlined
below
are:

$
to
achieve
significant
reductions
in
sulfur
dioxide
emissions
in
the
near
term;

$
to
ensure
reasonable
progress
toward
the
national
goal
through
continuing
decreases
in
sulfur
dioxide
emissions
over
the
long
term;
and
$
to
avoid
increases
of
other
visibility­
reducing
pollutants
within
the
Transport
Region
as
a
whole
from
stationary
sources.

The
Commission
believes
these
objectives
are
best
achieved
by
relying
on
diligent
implementation
of
current
regulatory
requirements
in
the
short
term
while
working
to
develop
an
incentive­
based
approach
to
ensure
long­
term
protection.

The
following
specific
recommendations
are
presented
with
the
recognition
that
the
tribal
participants
support
these
recommendations
and
have
offered
additional
concerns
and
recommendations
in
Section
IV
of
this
report.

1.
Implement
existing
Clean
Air
Act
requirements
through
the
year
2000.

Implementation
of
existing
Clean
Air
Act
requirements
is
expected
to
result
in
a
significant
decrease
in
sulfur
dioxide
emissions
and
their
contribution
to
light
extinction
in
the
short
term
(
1990­
2000).
Because
some
of
these
reductions
are
associated
with
the
installation
of
SO2
control
equipment
currently
under
construction
they
can
be
projected
with
a
very
high
degree
of
confidence
(
e.
g.,
a
6%
reduction
in
the
total
SO2
emissions
inventory
resulting
from
emissions
reductions
at
the
Navajo
Generating
Station).
In
addition
to
these
known
reductions,
the
rate
of
SO2
emissions
decline
will
be
influenced
by
ongoing
source
attribution
studies
and
decisions
similar
to
"
best
available
retrofit
technology"
in
the
Transport
Region,
as
well
as
other
factors
mentioned
above.
By
the
year
2000,
the
amount
of
SO2
35
emissions
reductions
achieved
(
or
represented
by
enforceable
commitments)
could
be
in
the
range
of
20­
30%.
These
pending
matters
may
also
affect
the
amount
and
rate
of
SO2
emission
reductions
that
will
occur
after
the
year
2000.
States
and
tribes
are
encouraged
to
review
the
visibility
impacts
at
Class
I
sites
on
the
Colorado
Plateau
of
uncontrolled
pollution
sources
and
make
expeditious
determinations
regarding
the
need
for
additional
pollution
controls
pursuant
to
the
Clean
Air
Act.
To
the
extent
decisions
are
made
to
require
additional
emission
reductions
at
existing
facilities,
the
Commission
supports
the
adoption
of
the
best,
most
cost­
effective
strategies.

22.
Establish
stationary
source
emission
targets4
as
regulatory
triggers.

a)
An
SO2
emissions
target
for
stationary
sources
will
be
established
effective
in
the
year
2000.
The
level
of
the
target
would
be
calculated
by
(
1)
determining
the
amount
of
emission
reductions
that
has
actually
been
achieved
(
or
legally
committed
to)
between
1990
and
2000;
(
2)
comparing
the
actual
reduction
to
the
13%
reduction
from
1990
actual
emission
levels
that
was
projected
by
the
Baseline
Forecast
Scenario;
(
3)
assuming
the
actual
reduction
is
higher
than
the
projected
reduction,
set
the
emissions
target
at
a
level
midway
between
the
projected
and
actual,
unless
any
affected
party
convinces
the
Commission
or
its
successor
that
a
different
distribution
is
needed
(
e.
g.,
emissions
growth
in
undeveloped
areas,
operational
flexibility
needs,
deteriorating
visibility).
As
part
of
this
calculation,
the
1990
emissions
inventory
will
be
compared
to
the
reported
emissions
to
1995/
1996
data
now
available
from
sources
(
all
utilities
and
many
stationary
sources
have
Continuous
Emission
Monitors).

b)
An
ultimate
SO2
emissions
target
for
the
visibility
Transport
Region
will
be
established
for
the
year
2040
that
locks
in
the
50­
70%
reduction
in
SO2
emissions
projected
by
the
Baseline
Forecast
Scenario.
5
Interim
targets
may
also
be
needed
to
ensure
steady
and
continuing
emission
reductions
and
to
promote
investment
in
pollution
prevention
(
in
accordance
with
five
year
review
periods
as
described
in
#
4
below).

4
These
"
targets"
are
intended
as
firm
limitations
on
emissions
and
have
the
same
effect
as
a
"
cap."
However,
we
are
reserving
rm
"
cap"
to
refer
to
the
limits
set
under
a
regulatory
program
which
would
be
triggered
if
the
"
targets"
are
exceeded.

5
For
example,
the
utility
industry
is
committed
to
achieving
the
current
baseline
projections
of
73%
reductions
in
SO2
emissions
fr
ility
sources
by
2040.
All
projected
percentage
reductions
in
SO2
emissions
within
the
Transport
Region
will
need
to
be
verified
by
dated
assessment
of
the
Baseline
Forecast
Scenario
in
the
year
2000.
Some
stationary
source
categories
require
additional
deta
alysis
in
order
to
produce
more
reliable
projections.
For
this
reason,
the
percentage
reductions
in
stationary
sources
as
a
whole
pressed
here
as
a
range.
36
c)
Various
emissions
management
options
for
stationary
source
NOx
and
PM
will
be
explored,
including
considering
the
establishment
of
emission
targets,
in
order
to
avoid
any
net
increase
in
these
pollutants
from
stationary
sources
within
the
region
as
a
whole
and
to
provide
a
foundation
for
future
incorporation
into
a
multi­
pollutant
and
possibly
multi­
source
market­
based
program.

3.
Develop
a
plan
for
allocating
trading
credits
under
a
regulatory
program
emissions
cap.

a)
Development
of
an
equitable
plan
for
allocating
the
trading
credits
among
existing
and
future
sources
will
be
accelerated.
The
Commission
expects
that
the
targets
will
be
met
based
on
existing
commitments
and
other
actions
that
are
likely
to
be
required
because
of
ongoing
source
attribution
studies.
However,
in
order
to
create
economic
incentives
for
early
reductions
as
well
as
to
provide
flexibility
and
certainty
to
sources
in
planning
future
actions,
participants
in
the
Commission's
process
are
committed
to
designing
the
plan
before
the
EPA
takes
final
action
on
the
Commission's
recommendations
so
that
the
elements
of
that
program
can
be
incorporated
into
the
federal
regulatory
program.
(
The
estimated
date
for
completing
development
of
the
program
is
June,
1997).
A
number
of
factors
will
be
considered
in
developing
the
program,
including
measures
to:

$
prevent
new
sources
from
causing
the
target
to
be
exceeded;

$
account
for
sources
which
achieve
emission
reductions
early
or
have
achieved
maximum
control
efficiency;

$
ensure
that
all
allocations
to
tribal
lands,
rural
areas
and
relatively
undeveloped
areas
(
e.
g.,
clean
air
corridors)
are
of
practical
benefit;
and
$
account
for
the
effects
of
increases
or
decreases
of
emissions
on
visibility.

b)
In
order
to
generate
information
for
development
and
implementation
of
the
incentive­
based
program,
owners
and
operators
of
existing
facilities
located
within
the
Transport
Region
should:
(
1)
by
1997,
notify
states
and
tribes
of
existing
or
planned
pollution
control
or
prevention
measures;
and
(
2)
report
biannually
on
efforts
that
are
being
made
to
manage
their
emissions
or
engage
in
other
transactions
to
voluntarily
meet
their
emissions
reductions
responsibility
per
the
trading
credit
allocation
scheme.
These
plans
37
would
not
be
incorporated
as
enforceable
permit
conditions
or
SIP
revisions
except
as
noted
below.

4.
Review
compliance
with
targets
and
establish
incentives.

Progress
in
complying
with
the
emissions
target(
s)
would
be
assessed
in
the
year
2000
and
at
five­
year
intervals
thereafter.

a)
In
2000,
or
any
subsequent
five­
year
review
period,
if
the
regional
target
in
effect
at
that
period
has
not
been
exceeded
no
additional
regulatory
program
will
be
required.
6
Any
source
that
has
contributed
significantly
to
achieving
the
needed
reductions
by
going
beyond
compliance
or
achieving
early
reductions
will
be
rewarded.
For
instance,
the
following
rewards
could
be
included:

$
an
exemption
from
any
interim
target
requirements
that
might
be
established;

$
streamlined
treatment
in
the
permitting
process;

$
ability
to
bank
emissions;
or
$
bonus
allowances
if
credits
are
used
to
achieve
development
on
tribal
lands
or
other
areas
that
are
relatively
undeveloped.
Incentives
will
be
further
developed
and
included
in
the
design
of
the
program.

b)
In
2000,
or
at
any
subsequent
five­
year
review
period,
if
the
regional
emissions
target
has
been
exceeded
7
,
a
regulatory
program
(
most
likely
an
emissions
cap
and
incentive­
based
market
trading
program)
will
be
implemented.
Any
source
that
is
exceeding
the
emission
allocation
presented
in
the
plan
will
have
no
more
than
five
years
to
come
into
compliance
and
any
reductions
achieved
will
be
discounted.
Other
disincentives
will
be
developed
and
included
in
the
design
of
the
program.

6
Reductions
actually
achieved
or
subject
to
legally
enforceable
commitments
will
be
included
in
determining
whether
the
cap
en
exceeded.

7
See
footnote
above.
38
5.
Complete
source
attribution
studies.

The
Commission
strongly
encourages
the
EPA
to
complete,
within
one
year,
the
source
attribution
study
currently
underway
at
the
Mohave
Power
Project.
Further,
the
Commission
strongly
encourages
the
EPA
to
take
action
consistent
with
the
results
of
that
study
within
twelve
months
of
its
completion.
The
Commission
supports
the
commitment
by
the
Mohave
Power
Project
to
maintain
voluntarily
its
emissions
at
or
below
current
levels
(
e.
g.,
an
average
of
the
past
two
year's
emission
levels).

6.
Develop
an
improved
monitoring
and
accounting
system.

A
major
deficiency
in
the
technical
analysis
associated
with
the
GCVTC
activities
has
been
the
lack
of
adequate
and
reliable
monitoring
data.
In
order
for
any
visibility
policy
to
be
effective,
there
must
be
an
adequate
benchmark
of
existing
conditions
against
which
to
measure
progress.
To
obtain
a
better
understanding
of
visibility
throughout
the
Colorado
Plateau,
Class
I
areas
other
than
Hopi
Point
in
the
Grand
Canyon
need
to
be
included
as
receptors
in
visibility
modeling
and
additional
monitoring
sites
should
be
established.

Emissions
in
the
Transport
Region
provide
another
benchmark
against
which
to
measure
progress.
An
accurate
and
credible
emissions
accounting
method
will
be
essential
in
determining
compliance
with
the
emissions
targets
or
caps.
Shortcomings
in
the
emissions
inventory
need
to
be
remedied,
and
a
method
for
routinely
tracking
emissions
needs
to
be
developed.

It
is
critical
that
the
emissions
monitoring
and
tracking
system
be
developed
quickly
so
that
emission
reductions
achieved
between
now
and
the
year
2000
can
be
recorded
and
so
that
those
areas
that
are
presently
lower­
emitting
can
receive
appropriate
credit.
If
an
incentive­
based
regulatory
program
is
implemented
after
the
year
2000,
early
emission
reductions
achieved
before
the
year
2000
should
be
awarded
credit,
provided
established
criteria
are
satisfied.
39
MOBILE
SOURCES
Background:

Emissions
from
mobile
sourcesCincluding
both
light­
and
heavy­
duty
vehicles,
marine
vessels,
trains,
and
airplanesCcontribute
to
visibility
degradation
on
the
Colorado
Plateau.
Although
the
relative
contribution
of
mobile
source
emissions
is
generally
not
as
large
as
the
contributions
of
some
other
sources,
direct
emissions
and
re­
entrained
road
dust
from
motor
vehicles
contribute
significantly
to
urban
plumes
that
are
transported
across
the
Colorado
Plateau.
Emissions
from
an
automobile
manufactured
today
are
substantially
lowerCbetter
than
90%
lower,
on
a
per­
vehicle­
mile
traveled
basisCthan
emissions
from
one
manufactured
thirty
years
ago,
in
large
part
due
to
the
Federal
Motor
Vehicle
Emission
Control
Program
in
the
Clean
Air
Act
and
the
California
motor
vehicle
emissions
control
program.
However,
the
number
of
vehicles
and
the
total
vehicle
miles
traveled
have
increased
dramatically.
This
trend
is
expected
to
continue.
And
while
NOx
and
PM
emissions
from
heavy­
duty
on­
road
diesel
engines
have
been
reduced
70%
and
95%,
respectively,
since
the
early
1970'
s,
emissions
from
interstate
and
cross­
border
truck
traffic
and
urban
delivery
and
transportation
vehicles
continue
to
contribute
significantly
to
total
emissions.

Reducing
total
mobile
source
emissions
is
an
essential
part
of
any
long­
term
emissions
management
program
to
protect
visibility
in
the
western
United
States
generally
and
on
the
Colorado
Plateau
specifically.
Further
reductions
can
be
achieved
through
a
combination
of
national,
regional
and
local
actions.

RECOMMENDATIONS
REGARDING
MOBILE
SOURCES
1.
Adopt
an
emission
management
objective
and
establish
a
regional
emissions
budget.

The
objective
of
the
recommended
strategies
described
below
is
to
reduce
emissions
of
VOC,
NOx,
elemental
carbon,
and
fine
particulates
from
the
mobile
source
sector
and
then
hold
them
constant.
To
the
extent
that
mobile
source
emissions
contribute
significantly
to
visibility
impairment
in
the
Class
I
areas
of
the
Colorado
Plateau,
an
emissions
budget
should
be
established
for
any
area
with
a
significant
contribution,
beginning
in
the
approximate
year
in
which
emissions
are
projected
to
reach
a
minimum,
or
2005.
The
emissions
budget
should
serve
as
a
regional
planning
objective
and
performance
indicator.
40
2.
Develop
a
system
for
tracking
emissions.

In
order
to
periodically
assess
progress,
a
system
for
tracking
emissions
will
need
to
be
developed.
That
protocol
should
take
into
account
the
relatively
rural
nature
of
much
of
the
area
within
the
Transport
Region
and
not
impose
unnecessary
burdens
on
small
communities,
including
tribal
lands,
with
air
quality
better
than
national
ambient
air
quality
standards.
National
and
regional
initiatives
should
ensure
compliance
with
the
regional
emissions
budget.

3.
Suggest
targeted
local
actions.

In
addition
to
national
and
regional
strategies,
targeted
local
actions
are
needed
to
reduce
mobile
source
emissions
within
the
Colorado
Plateau's
Class
I
areas,
in
adjacent
communities,
and
in
major
urban
areas
that
contribute
significantly
to
visibility
impairment.
If
the
strategies
described
below
and
elsewhere
in
this
report
do
not
keep
emissions
within
the
emissions
budget,
options
for
expanding
and
increasing
the
accountability
of
the
relevant
authorities
will
need
to
be
considered
and
implemented.

Recommended
National
Strategies
Introduction
to
Recommended
National
Strategies
Most
of
the
mobile
source­
related
emissions
reductions
achieved
to
date
have
been
brought
about
by
increasingly
stringent
tailpipe
and
evaporative
emissions
standards.
Further
progress
in
reducing
mobile
source
emissions
outside
of
California
can
only
be
achieved
through
action
on
a
national
level.
Although
it
would
be
difficult
to
justify
a
national­
scale
program
based
strictly
on
the
impact
on
the
Colorado
Plateau,
there
are
numerous
initiatives
and
proposals
to
address
urban
ozone
non­
attainment
problems
already
being
considered
for
national
implementation
that
would
benefit
air
quality
in
the
Colorado
Plateau's
Class
I
areas.
The
EPA
should
ensure
the
coordination
of
the
Commission's
efforts
related
to
national
standards
and
programs
with
other
regional
organizations
(
e.
g.,
Ozone
Transport
Commission/
Ozone
Transport
Assessment
Group),
because
there
may
be
synergies
or
conflicts
among
technologies
or
fuels
aimed
at
different
air
quality
goals.

The
Commission
promotes
the
following
initiatives
on
a
national
level:

1.
Adopt
49­
state
LEV
standards.

The
Commission
supports
adoption
of
the
nationwide
Low
Emission
Vehicle
standards
(
49­
state
LEV),
beginning
in
2001,
and
adoption
of
federal
Tier
II
41
standards
in
2004
8
,
if
determined
to
be
more
effective.
In
the
time
frame
to
2040,
the
Commission
supports
the
promotion
of
ultra­
low
and
zero­
emission
vehicles.

2.
Support
development
of
heavy­
duty
vehicle
standards.

The
Commission
supports
the
EPA's
current
proposal
to
further
reduce
NOx
and
particulate
emissions
from
new
on­
road,
heavy­
duty
vehicles
by
at
least
50%,
compared
to
the
1998
requirements
contained
in
the
1990
Clean
Air
Act
Amendments
while
maintaining
current
stringent
PM
emission
limits.
9
The
Commission
requests
the
EPA
to
pursue
additional
PM
reductions
from
on­
road
vehicles.

3.
Negotiate
and
adopt
off­
road
vehicle
standards.

The
Commission
requests
that
the
EPA
continue
to
pursue
the
adoption
of
additional
engine
emission
standards
for
new
off­
road
vehicles
(
heavy­
duty,
construction­
type)
that
provide
reasonably
achievable
reductions.

4.
Promote
broader
application
of
cleaner
fuels.

The
Commission
requests
that
the
EPA
explore
broader
application
of
and
additional
reductions
in
the
sulfur
content
of
both
gasoline
and
diesel
fuel.
The
Commission
also
supports
the
promotion
of
cleaner
burning
fuels
as
discussed
in
Recommendation
#
11
on
page
31.

5.
Pursue
strategies
for
diesel
locomotives,
boats,
airplanes
and
federal
vehicles.

The
Commission
requests
that
the
EPA
pursue
fuel
standards
and
control
strategies
for
diesel
locomotives,
marine
vessels/
pleasure
craft,
airplanes
and
federal
vehicles.
States
and
tribes
are
preempted
from
controlling
most
emissions
from
these
sources.
Emissions
from
these
categories
are
relatively
uncontrolled
compared
to
other
mobile
sources
(
e.
g.,
light­
duty
cars
and
trucks)
and
will
continue
to
increase
with
population
and
economic
growth.
In
particular,
the
EPA
should:

a)
promulgate
national
NOx,
HC
and
PM
standards
for
"
captive
fleet"
marine
vessels
and
work
with
the
International
Maritime
Organization
to
reduce
emissions
through
international
standards;

8
In
March
1996,
the
California
Air
Resources
Board
confirmed
an
agreement
with
the
largest
automobile
manufacturers
to
tionwide
only
cars
and
light
trucks
which
meet
standards
equivalent
to
California's
Low
Emission
Vehicle
(
LEV)
standards,
beginnin
01.
This
action
was
part
of
a
larger
agreement
in
which
these
manufacturers
were
given
greater
flexibility
in
introducing
Zero
Emiss
hicles
(
ZEVs)
prior
to
2003
in
California.

9
The
heavy
duty
engine
manufacturers,
the
U.
S.
EPA
and
the
California
ARB
signed
a
statement
of
principles
in
July
19
mmitting
to
the
introduction
of
a
NOx
standard
of
2.0
grams
per
brake­
horsepower
hour
by
2004,
compared
to
the
1998
CAAA
requ
ent
of
4.0.
42
b)
finalize
the
proposed
HC
standards
for
recreational
boats
and
personal
watercraft;

c)
adopt
NOx
standards
for
new
and
remanufactured
diesel
locomotive
engines;

d)
strengthen
existing
national
HC
standards
for
aircraft
engines;

e)
adopt
stringent
national
NOx
standards
for
aircraft
engines;
and
f)
pursue
emission
control
strategies,
such
as
alternative
clean
fuels,
for
all
federal
fleets.

6.
Support
improved
control
of
evaporative
emissions
The
Commission
supports
requirements
for
effective
refueling
vapor
recovery
systems
that
capture
evaporative
emissions.

Recommended
Regional
Strategies
Introduction
to
Recommended
Regional
Strategies
To
the
extent
that
mobile
source
emissions
from
certain
areas
are
found
to
contribute
significantly
to
visibility
impairment
in
the
Class
I
areas
of
the
Colorado
Plateau,
an
emissions
budget
should
be
established,
beginning
in
the
approximate
year
in
which
emissions
are
projected
to
reach
a
minimum,
or
2005.
As
mentioned
above,
a
protocol
for
inventorying
and
tracking
emissions
will
need
to
be
developed.
The
adoption
of
more
stringent
national
standards
as
noted
above
would
help
maintain
compliance
with
the
regional
mobile
source
budget.
In
addition,
the
Commissioners
promote
incentives
for
the
use
of
clean
fuels
on
a
wide
basis.
Economic
pricing
strategies
should
also
be
analyzed
for
implementation
on
a
regional
scale.
The
analysis
should
include
an
examination
of
the
extent
to
which
certain
populations
(
for
instance,
rural
communities,
low­
income
groups
or
tribes)
may
be
disproportionately
affected.
In
the
event
that
inequities
are
identified,
alternative
strategies
should
be
developed
to
address
the
particular
needs
of
those
populations.
The
initiatives
which
follow
should
be
pursued.

1.
Establish
clean
fuel
demonstration
zones.

The
feasibility
of
providing
incentives
for
clean
fuel
demonstration
zones
or
corridors
for
heavy­
duty
trucks
and
buses
should
be
assessed
by
1998.
For
example,
and
at
a
minimum,
incentives
for
converting
vehicles
used
for
mass
transportation
and
delivery
within
national
parks
on
the
Colorado
Plateau,
as
well
as
in
nearby
urban
areas,
to
CNG,
LNG,
LPG
or
alcohol­
based
fuels
should
be
provided.
In
addition,
the
Western
states
should
cooperatively:
43
a)
explore
the
feasibility
of
establishing
alternative
fuel
corridors
in
urban
areas
and
along
major
trucking
routes
(
e.
g.,
I­
15,
I­
5,
I­
80,
and
I­
40);
10
and
b)
conduct
an
analysis
comparing
the
relative
emissions
from
trucks
and
trains
(
including
tailpipe/
stack
emissions
as
well
as
road
dust,
tire
wear,
etc.).

2.
Analyze
pricing
and
incentive
approaches.

A
regional
analysis
of
economic
pricing
and
incentive
approaches
should
be
conducted
by
1998,
including
an
analysis
of
equity
effects
of
such
approaches,
that
could
be
used
to
reduce
reliance
on
vehicle
use
and
better
internalize
the
true
cost
of
operating
motor
vehicles.
If
such
programs
were
implemented
and
generated
revenue,
these
funds
could
be
rebated
to
drivers
(
for
instance,
as
a
credit
against
state
income
or
property
taxes),
used
to
develop
multi­
modal
transportation
options,
or
used
to
help
maintain
the
existing
highway
infrastructure
The
Commission
supports
states
that
are
implementing
programs
to
curtail
visible
emissions
and
encourage
region­
wide
adoption
of
these
programs.

3.
Explore
an
inspection
program
for
heavy­
duty
vehicles.

Truck
traffic
contributes
to
regional
visibility
impairment,
including
haze
in
the
Class
I
areas
in
the
Colorado
Plateau.
The
Commission
supports
development
of
options
and
opportunities
for
implementing
an
emissions
inspection
programs
for
heavyduty
on­
road
vehicles
that
routinely
travel
the
highways
in
the
Transport
Region.
Within
the
limitations
of
existing
interstate
commerce
regulations
and
the
North
American
Free
Trade
Agreement,
the
states
and
tribes
could
explore
programs
to
assure
compliance
with
in­
use
emission
requirements,
including
vehicles
involved
in
cross­
border
transport.

4.
Promote
vehicle
maintenance.

The
Commission
also
encourages
local
authorities
to
mount
public
education
campaigns
to
inform
citizens
of
the
air
quality
advantages
of
maintaining
their
vehicles
properly.
It
is
critical
for
control
of
mobile
source
emissions
that
all
components
of
a
vehicle's
emissions
control
system
be
maintained
according
to
the
manufacturer's
specifications
as
detailed
in
the
owner's
manual.
Such
a
public
education
effort
could
be
coupled
with
implementation
of
a
mechanics'
training
10
A
privately­
initiated
effort
is
already
under
way
to
establish
LNG
fuel
stations
along
the
I­
15
corridor
from
Salt
Lake
City
to
eorge,
Utah
and
along
the
I­
15,
I­
5
and
I­
80
corridors
between
Salt
Lake
City,
Los
Angeles
and
Sacramento.
Efforts
are
also
under
w
Southern
California
for
electric
vehicles
and
hydrogen
corridors.
The
Commission
supports
these
and
similar
efforts.
If
tablishment
of
a
regional
mobile
source
emissions
budget
leads
to
development
of
a
market­
based
program,
the
Commission
sho
pport
the
awarding
of
emissions
reduction
credits
to
private
entities
involved
in
these
types
of
efforts.
44
and
certification
program
and
state­
of­
the­
art
vehicle
inspection
and
maintenance
programs.

Recommended
Local
Strategies
Introduction
to
Recommended
Local
Strategies
Decisions
as
to
how
to
achieve
emissions
objectives
are
best
made
at
the
local
or
metropolitan
level.
However,
the
Commission
recognizes
that
mobile
source
emissions
from
some
areas
have
a
disproportionate
impact
on
visibility
in
the
Colorado
Plateau
Class
I
areas.
Strategies
for
addressing
mobile
source
emissions
within
Class
I
areas
and
in
adjacent
communities
are
discussed
elsewhere
in
this
report.
In
addition,
major
metropolitan
areas
located
near
the
Colorado
Plateau
must
be
encouraged
to
take
actions
to
reduce
in­
use
vehicle
emissions.
The
types
of
programs
described
below
would
be
targeted
initially
at
these
areas,
but
consideration
should
be
given
to
extending
their
application
on
a
broader
scale
to
achieve
regional
air
quality
objectives.
Any
such
extension
would
be
preceded
by
an
analysis
of
the
equity
effects
associated
with
these
types
of
programs
in
non­
urban
areas.

1.
Promote
incentives
for
innovative
and
effective
approaches.

The
Commission
challenges
states
and
tribes
with
major
urban
areas
to
develop
funding
and
other
incentive­
based
schemes
that
give
priority
to
allocating
discretionary
funding
to
transportation
projects
that
are
consistent
with
the
goal
of
reducing
reliance
on
single­
occupant
vehicles.
For
example,
governors
could
exercise
fiscal
discretion
(
e.
g.,
preferential
allocation
of
state
highway/
transit,
open
space,
economic
development/
enterprise
zone
funds
or
rebates
of
state
fees)
to
reward
communities
that
find
appropriate
or
innovative
ways
of
reducing
reliance
on
single­
occupant
vehicles.
Examples
include
land
use
ordinances
that
favor
development
in
existing
transit/
transportation
corridors,
high
density
development
needed
to
ensure
the
viability
of
mass
transit,
and
co­
located
residential,
business
and
commercial
development
to
support
non­
vehicular
modes
of
transportation.
If
possible,
this
incentive­
based
approach
with
state
funds
could
be
coupled
with
a
similar
preferential
allocation
of
discretionary
federal
funding
to
states
and
tribes
that
develop
appropriate
approaches.

2.
Encourage
better
integration
of
transportation,
land
use
and
air
quality
planning.

In
order
to
avoid
incremental
degradation
of
visual
air
quality
as
the
population
and
economy
of
the
West
continue
to
grow,
the
Commission
encourages
sustainable
community
and
economic
development
by:

a)
promoting
multi­
modal
transportation
options
through
both
public
and
private
investments;
45
b)
encouraging
local,
state
and
tribal
governments
to
reduce
or
eliminate
entry
and
rate
regulations
in
the
transit
industry
as
a
means
of
fostering
greater
competition;

c)
establishing
a
clearinghouse
for
information
about
sustainable
communities
and
methods
for
integrating
multi­
modal
transportation
systems
with
land
use
planning;
and
d)
sponsoring
conferences
on
transportation,
land
and
air
quality
issues
generally
(
e.
g.,
to
showcase
various
communities'
efforts),
and
transportation
alternatives
within
and
between
Class
I
areas
in
the
Colorado
Plateau
specifically.

3.
Establish
mobile
source
emissions
budgets
for
selected
major
urban
areas.

To
the
extent
that
mobile
source
emissions
from
certain
major
urban
areas
are
found
to
contribute
significantly
to
visibility
impairment
in
the
Colorado
Plateau's
Class
I
areas,
the
Commission
requests
that
local
emissions
budgets
be
developed
specifically
for
mobile
sources.
(
Most
areas
are
already
required
to
do
this
under
the
CAAA
for
purposes
of
assuring
conformity
of
transportation
plans
and
programs.)
Methods
for
managing
mobile
source
emissions
budgets
need
to
be
explored
further.
Regardless
of
which
approach
is
taken,
there
must
be
developed
a
credible
and
replicable
way
of
inventorying,
tracking
and
reporting
emissions.

a)
Develop
analytical
criteria
and
accounting
methods
for
implementing
emission
budgets.

If
the
proposed
emission
budgets
allow
an
increase
in
current
emission
levels,
an
analysis
will
be
needed
to
assess
whether
the
budgets
ensure
protection
of
NAAQS,
PSD
increments,
and
visibility
in
downwind
Class
I
areas.
In
this
event,
the
Commission
would
develop
criteria
and
an
analytical
method
for
conducting
such
an
analysis,
and
establish
requirements
for
adjusting
urban
emission
budgets
found
to
be
inadequate
to
protect
downwind
areas,
as
well
as
accounting
and
enforcement
mechanisms

b)
Consider
use
of
pricing
strategies.

The
economic
pricing
analysis
called
for
above
may
indicate
that
the
most
efficient
method
of
complying
with
emissions
budgets
would
be
to
institute
pricing
strategies
for
use
of
roadways
that
internalize
the
cost
of
operating
motor
vehicles
so
that
individuals
have
an
incentive
to
modify
their
travel
behavior.
The
consideration
of
such
pricing
strategies
should
take
into
account
the
possibility
that
incremental
changes
in
price,
in
46
absolute
dollar
terms,
will
have
a
larger
effect
on
rural
areas
and
lowerincome
populations.

c)
Develop
an
accounting
system
for
market­
based
programs.

If
some
sort
of
market­
based
program
is
deemed
appropriate,
accountability
for
complying
with
the
emissions
budget
must
be
clearly
assigned,
with
consequences
attached
to
failure
to
maintain
emission
levels
consistent
with
the
budget.
For
example,
emissions
from
mobile
sources
could
be
aggregated
and
responsibility
for
managing
them
delegated
to
a
private
or
public
"
broker",
or
assigned
to
a
local/
regional
governmental
entity.
Alternatively,
individuals
(
including
businesses,
government
agencies,
etc.)
could
be
given
responsibility
for
managing
emissions
from
vehicles
they
own
or
control.
In
any
event,
if
emissions
trading
were
allowed,
credible
methods
would
be
needed
for
certifying
the
validity
and
value
of
emissions
reductions
at
the
start
of
the
program
and
ensuring
their
permanence
over
time.

4.
Suggest
retiring
high­
emitting
vehicles.

The
Commission
suggests
that
local
authorities
consider
the
advantages
of
retiring
higher
polluting
vehicles
and
develop
incentives
for
citizens
to
upgrade
to
newer,
less
polluting
cars
and
trucks.
47
AREA
SOURCES
DUST
FROM
PAVED
AND
UNPAVED
ROADS
Background:

Chapter
II
of
the
Commissions
November
1995
report,
Options
for
Western
Vistas,
discussed
the
limitations
of
the
Integrated
Assessment
System
results
with
respect
to
paved
and
unpaved
road
dust.
More
recent
modeling
has
shown
that
local
sources
of
road
dust
play
a
more
important
role
than
distant
sources.
The
Commission
has
considered
this
issue
and
has
concluded
that
there
are
good
reasons
to
discount
the
Integrated
Assessment
System's
predictions
about
the
regional
importance
of
this
source
of
emissions
until
more
study
is
completed.
For
example,
the
large
magnitude
of
emissions
projected
for
this
source
are
tied
to
projections
of
future
growth
in
population
and
vehicle­
miles­
traveled,
whereas
road
dust
effects
on
visibility
are
generally
localized,
especially
with
respect
to
large,
coarse
material
which
settles
out
of
the
air
relatively
close
to
roadways.

RECOMMENDATIONS
REGARDING
DUST
FROM
PAVED
AND
UNPAVED
ROADS
Actions
to
address
the
control
or
reduction
of
emissions
related
to
road
dust
are
found
in
the
recommendations
regarding
emissions
"
In
and
Near
Class
I
Areas."
The
Commission
further
recommends
that
voluntary
measures
be
taken
in
local
areas
in
and
near
Class
I
areas
to
control
emissions
of
dust
from
paved
and
unpaved
roads.
Consistent
with
other
Commission
recommendations,
there
is
also
a
recognized
need
to
develop
an
accurate
emissions
inventory
and
an
improved
air
quality
model
for
controlling
or
managing
this
specific
source
sector.
Finally,
if
visibility
impacts
are
validated,
the
Commission
recommends
that
performance
standards
for
road
dust
emissions
be
developed.

Due
to
considerable
skepticism
regarding
the
modeled
contribution
of
road
dust
to
visibility
impairment,
the
Commission
recommends
further
study
in
order
to
resolve
the
uncertainties
regarding
both
near­
field
and
distant
effects
of
road
dust,
prior
to
taking
remedial
action.
Since
this
emissions
source
is
potentially
such
a
significant
contributor,
the
Commission
feels
that
it
deserves
high
priority
attention
and,
if
warranted,
additional
emissions
management
actions.
48
FIRE
Background:
Fire
Emissions
and
Visibility
Fire
has
played
a
major
role
in
the
development
and
maintenance
of
most
ecosystems
in
the
West.
The
long­
term
future
of
the
West
is
dependent
on
healthy
ecosystems
that
are
capable
of
sustaining
natural
processes
and
human
uses.

An
increase
of
accumulated
forest
fuels
in
the
West
has
occurred
because
of
past
land
management
practices,
including
decades
of
fire
suppression.
Evident
ecosystem
changes
include
increasing
tree
densities,
disrupted
nutrient
cycling,
and
altered
forest
structure.
As
a
result,
wildfires
are
becoming
larger
in
size,
unnaturally
destructive,
and
more
dangerous
and
costly
to
control.
In
1994,
wildfire
burned
3.1
million
acres
in
the
West
and
cost
$
1
billion
dollars
in
direct
suppression
costs
while
causing
firefighter
deaths
and
serious
human
health
impacts.
Rectifying
this
problem
will
take
years
and
is
a
basic
responsibility
of
wise
land
stewardship.
Fire
is
an
essential
component
of
most
natural
systems,
and
perpetuation
of
fire
at
a
level
required
to
maintain
ecosystem
processes
is
necessary.
The
natural
role
of
fire
in
the
wildland/
urban
interface
must
also
be
addressed
to
protect
life
and
property.
A
substitute
for
fire
and
its
natural
role
has
not
been
found
in
many
ecosystems.
The
objective
of
future
prescribed
fire
programs
is
to
cooperatively
meet
land
management,
human
health
and
visibility
objectives.

Emissions
from
fire
(
wildfire
and
prescribed
fire)
are
an
important
episodic
contributor
to
visibility­
impairing
aerosols,
including
organic
carbon,
elemental
carbon,
and
particulate
matter
(
PM2.5).
Agricultural
burning
emissions
and
their
effects
have
been
identified
as
a
concern
of
the
GCVTC
but
have
not
been
quantified
due
to
a
lack
of
data.
All
types
of
fire
(
prescribed
fire
and
agricultural
burning)
must
be
addressed
equitably
as
part
of
a
visibility
protection
strategy.
This
may
require
state
legislation
in
some
cases.

Discussion
of
Management
Alternatives
Wildfire
impacts
are
increasingly
uncontrollable
or
unmanageable,
due
to
excessive
fuel
loads,
except
through
the
application
of
prescribed
fire
and/
or
mechanical
means,
such
as
brush
removal
and
logging.
Field
experience
has
shown
that
prescribed
fire
can
reduce
the
size,
frequency,
and
intensity
of
wildfires.
Areas
that
have
been
treated
with
prescribed
fire
demonstrate
much
less
burning
in
the
tops
of
trees
and
a
slowing
of
wildfire
spread.
Prescribed
fire
therefore
promotes
better
fire
control,
predictable
fire
effects
and
allows
for
management
of
emissions
as
compared
to
wildfire.

The
future
use
of
prescribed
fire
and
the
restoration
of
fire
in
its
natural
role
with
natural
fuel
loadings
will
provide
sustainable
ecosystems
where
environmental
and
human
health
impacts
can
be
managed.
This
future
desired
situation
contrasts
with
the
current
adverse
public
health
impacts
and
permanent
damage
to
natural
resources
and
property
from
wildfires.
Wildfires
are
causing
exceedances
of
ambient
air
quality
standards
and
air
quality­
triggered
community
evacuations
with
greater
frequency.
Prescribed
fire
programs
49
will
influence
future
wildfire
in
many
locations
of
the
West.
However,
infrequent
large­
scale
forest
replacement
wildfire
will
still
occur
naturally
in
some
vegetation
types.

Land
managers
employ
emission
reduction
and
smoke
management
techniques
to
reduce
air
quality
impacts
of
prescribed
fire.
Current
smoke
management
techniques
take
into
account
the
timing
and
location
of
burns
so
that
impacts
on
human
health
are
reduced.
These
techniques
can
be
expanded
to
reduce
current
and
future
impacts
on
visibility.
Emission
reduction
techniques
can
also
be
utilized
to
reduce
the
quantity
of
emissions
from
a
prescribed
burn.
The
appropriateness
and
effectiveness
of
emission
reduction
techniques
vary
based
on
vegetation
type,
burn
objectives,
location,
other
environmental
constraints
such
as
water
quality,
and
funding.
Effective
agricultural
smoke
management
programs
have
been
developed
in
some
states
using
similar
measures.

Utilization
of
mechanical
treatments
such
as
logging
or
firewood
sales
to
remove
fuels
will
be
necessary
in
some
areas
prior
to
prescribed
burning.
The
potential
use
of
mechanical
treatments
is
limited,
however,
since
large
areas
of
the
West
are
not
physically
available
due
to
inaccessibility,
slope
or
soil
sensitivity.
Significant
emission
reductions
from
mechanical
treatment
would
only
occur
in
timber
areas.
Administrative
constraints,
such
as
wilderness
or
habitat
protection,
also
impose
limitations.
Approximately
30%
of
the
total
timber
area
has
the
potential
to
be
treated
using
mechanical
methods.
In
areas
where
mechanical
treatments
are
used
alone,
some
level
of
prescribed
fire
treatment
may
still
be
necessary.
Mechanical
treatment
cannot
replace
the
natural
role
of
fire
in
ecosystem
health
and
sustainability
processes.

In
order
to
address
the
fuels
problem
and
ensure
adequate
protection
of
visibility
in
the
West,
funds
will
need
to
be
greatly
increased.
With
the
development
of
increased
prescribed
fire
programs,
it
is
crucial
to
fund
smoke
management
programs
that
protect
public
health
and
visibility,
while
meeting
the
underlying
land
management
objectives.

RECOMMENDATIONS
REGARDING
FIRE
1.
Plan
for
the
visibility
impacts
of
smoke.

The
Commission
recommends
that
the
EPA
require
all
federal,
state,
tribal,
and
private
prescribed
fire
programs
to
incorporate
smoke
effects
in
planning
and
application
by
the
year
2000.

2.
Implement
an
emissions
tracking
system
for
all
fire
activities.

A
consistent
emissions
tracking
system
for
prescribed
fire,
wildfire,
and
agricultural
burning
should
be
implemented
region­
wide.

3.
Improve
integrated
assessment
of
emissions.
50
Federal,
state,
tribal
and
private
land
managers,
in
conjunction
with
relevant
regulatory
agencies
and
interested
parties,
should
improve
the
current
integrated
assessment
of
emissions
from
prescribed
fire,
wildfire
and
agricultural
burning
by
1999.
The
assessment
should:

a)
identify
specific
areas
where
fire
activities
have
or
could
have
an
adverse
impact
on
health
and
visibility;

b)
identify
areas
where
mechanical
treatments
could
substantially
reduce
emissions
and
subsequent
impacts
on
health
and
welfare;

c)
in
the
areas
identified,
assess
the
feasibility
of
biomass
utilization
(
woody
material
use),
market
development,
and
non­
statutory
administrative
barriers
11
;
and
d)
assess
meteorological
information
needs,
air
quality
monitoring
needs,
smoke
dispersion
model
needs,
interstate
planning
needs,
wildfire/
prescribed
fire
trade­
offs
(
economics,
air
quality
and
other
resource
effects),
and
emission
factor
research
(
vegetation/
fuels
and
effects
of
emission
reduction
techniques).

4.
Enhance
smoke
management
programs.

The
Commission
recommends
the
development
and
implementation
of
criteria
and
requirements
for
the
use
of
enhanced
smoke
management
programs
(
including
alternative
management
practices)
and
emission
reduction
strategies
in
the
identified
areas.
Such
programs
should
consider
factors
of
efficiency,
economics,
law,
land
management
objectives,
and
reduction
of
visibility
impacts.
States,
tribes,
state
and
federal
land
management
agencies
and
private
parties
should
create
and
implement
smoke
management
programs
that
address
public
health,
visibility
and
land
management
objectives
by
the
year
2000,
using
the
results
of
the
assessment
listed
in
Recommendation
#
3.

5.
Develop
cooperative
funding
mechanisms.

The
Commission
promotes
the
development
of
cooperative
funding
mechanisms
between
burners
and
regulatory
agencies
to
implement
increased
smoke
management
programs
and
integrated
assessment
costs.

6.
Promote
public
education
programs.

11
In
identifying
areas
where
alternatives
to
burning
are
appropriate,
it
is
not
the
intent
of
the
Commission
to
require
actions
that
consistent
with
applicable
laws
or
regulations.
51
The
Commission
supports
the
creation
of
a
public
education
program
regarding
the
role
of
fire
in
air
quality,
to
be
undertaken
by
land
managers
and
other
interested
governmental
and
private
groups.

7.
Establish
annual
emission
goals
for
fire
programs.

The
Commission
recommends
that
annual
emission
goals
for
all
fire
programs,
where
appropriate,
be
established
by
the
year
2000.
These
goals
will
be
set
to
minimize
emission
increases
from
such
programs
to
the
maximum
extent
feasible.
The
goals
will
be
established
cooperatively
by
states,
tribes,
state
and
federal
land
management
agencies
and
their
private
sector
counterparts.

8.
Remove
administrative
barriers
to
the
use
of
alternatives
to
burning.

The
Commission
recommends
that
the
federal
land
management
agencies
and
their
state,
tribal,
local
and
private
counterparts
identify
and
remove
non­
statutory
administrative
barriers
to
emission
reduction
strategies
by
the
year
2000,
to
the
maximum
extent
feasible.
In
removing
such
barriers,
the
Commission
intends
that
subsequent
actions
will
be
undertaken
consistent
with
applicable
laws
and
regulations.
52
CLEAN
AIR
CORRIDORS
Background
One
finding
of
the
Commission's
process
is
that
clean
air
corridors
exist.
One
such
source
of
clean
air
studied
by
the
Commission
covers
major
portions
of
Nevada,
southern
Utah,
eastern
Oregon
and
southwestern
Idaho.
This
area
provides
clean
air
days
at
Grand
Canyon
National
Park.
Projected
emissions
growth
through
2040
within
the
studied
clean
air
corridor
is
not
expected
to
have
a
perceptible
negative
effect
on
visibility
at
Class
I
sites.
Clean
air
corridors
also
influence
visibility
at
other
Class
I
sites
in
the
Colorado
Plateau,
although
the
precise
relationships
have
not
been
fully
established
at
this
time.
In
order
to
ensure
that
sources
of
clear
air
for
all
Class
I
sites
on
the
Colorado
Plateau
are
protected,
additional
data
collection
and
analysis
will
be
needed.

RECOMMENDATIONS
REGARDING
CLEAN
AIR
CORRIDORS
1.
Do
not
establish
special
targeted
programs
at
present.

The
Commission
considered
whether
special
programs
or
regulations
were
needed
in
clean
air
corridors
in
order
to
protect
the
clean
air
provided
to
Class
I
sites
on
the
Colorado
Plateau.
Given
the
Commission's
findings,
there
is
no
present
need
for
special
targeted
policies
or
regulatory
programs
to
control
emissions
growth
within
clean
air
corridors
beyond
existing
laws
and
programs.
In
addition,
clean
air
corridors
will
be
covered
by
other
regional
initiatives
recommended
elsewhere
in
this
report.

2.
Improve
regional
tracking
and
monitoring.

Because
uncertainties
in
data
and
forward
projections
exist,
a
regional
tracking
and
accounting
system
is
needed
to
make
sure
that
the
frequency
of
clear
days
increases
or
does
not
decrease
at
Class
I
sites
and
that
the
Commission's
present
assumptions
regarding
population
and
economic
growth
and
the
resulting
effects
on
increased
emissions
prove
reliable.
In
addition
to
these
concerns,
a
regional
tracking
and
accounting
system
should:

a)
within
areas
that
are
sources
of
clear
air,
identify
patterns
of
growth
or
specific
sites
of
growth
that
cause
significant
emissions
increases
having
a
negative
impact
on
visibility
at
one
or
more
Class
I
sites
on
the
Colorado
Plateau;
53
b)
in
areas
outside
of
clean
air
corridors,
identify
significant
emissions
growth
that
begins
to
impair
the
quality
of
air
in
the
corridor
and
thereby
reduce
the
frequency
of
clean
air
days
at
Class
I
sites;
and
c)
continue
technical
studies
to
see
whether
other
sources
of
clear
air
exist
and
take
measures,
if
needed,
to
protect
against
future
degradation
of
air
quality
in
these
areas.

3.
Establish
triggers
for
additional
action.

The
occurrence
of
any
of
the
conditions
described
in
paragraph
#
2
above
should
trigger
analysis
of
the
effects
of
increased
emissions
and
the
implementation
of
additional
measures
to
protect
clean
air
days,
if
necessary.
54
EMISSIONS
WITHIN
AND
NEAR
CLASS
I
AREAS
Background
Emissions
from
within
and
near
Class
I
areas
contribute
to
impaired
visibility.
Transportation­
related
emissions
and
other
emissions
from
energy
use
are
of
particular
concern.
Prescribed
fire
emissions
are
also
a
concern
since
land
managers
plan
to
increase
necessary
prescribed
fire
activities
in
order
to
restore
natural
fire
cycles
and
preserve
natural
ecosystems.

National
park
general
management
plans
and
forest
land
management
plans
are
appropriate
ways
to
address
some
contributions
to
visibility
impairment
at
Class
I
areas.
National
Park
Service
(
NPS)
nation­
wide
policy
is
to
mitigate
visibility
impairment
and
other
air
quality
effects
from
in­
park
sources
by
reducing
emissions
and
incorporating
sustainability
concepts
into
all
plans
and
management
decisions.
The
NPS
has
already
implemented
several
innovative
approaches
to
pollution
prevention
in
many
Colorado
Plateau
parks
and
intends
to
do
more.
These
actions
include
more
in­
park
transportation
systems
(
such
as
low­
emission
shuttles),
conversion
of
park
vehicle
fleets
to
cleaner
fuels,
increasing
energy
efficiency,
and
taking
other
steps
at
parks
on
the
Colorado
Plateau.

The
Commission
recognizes
the
importance
of
visibility
issues
related
to
emission
sources
in
and
near
Class
I
areas,
and
supports
funding
for
these
transportation,
energy,
and
other
programs
that
help
improve
visibility.

RECOMMENDATIONS
REGARDING
EMISSIONS
WITHIN
AND
NEAR
CLASS
I
AREAS
1.
Implement
park
and
wilderness
planning
processes.

Federal
land
managers,
through
their
planning
processes,
should
strive
to
limit
and
reduce
visibility
impairing
emissions
within
Class
I
areas.
Land
managers
should
also
use
existing
opportunities,
such
as
the
states=
required
consultation
process
with
federal
land
managers
in
the
review
of
state
visibility
protection
plans
(
discussed
below),
to
inform
the
appropriate
regulatory
authority
regarding
agency
actions
and
strategies
taken
or
planned
within
Colorado
Plateau
Class
I
areas
to
prevent
or
reduce
pollution
emissions
that
affect
visibility.

Specifically,
such
plans
or
actions
would
assure
that:

a)
emissions
growth
from
human­
caused
sources
within
the
Class
I
area
does
not
cause
visibility
to
deteriorate;
55
b)
human­
caused
sources
within
the
Class
I
area
(
or
that
result
from
activities
within
the
area)
that
contribute
to
existing
visibility
impairment
are
mitigated;
and
c)
prescribed
fire
programs
(
excluded
from
1a.
and
b.
above),
after
considering
and
applying
non­
fire
alternatives
whenever
possible,
seek
to
minimize
emissions
and
visibility
impacts
through
smoke
management
and
emissions
reduction
measures.

2.
Develop
strategies
for
nearby
communities
and
activities.

All
significant
sources
or
combinations
of
sources
near
each
Class
I
area
must
be
examined
and
cooperative,
enforceable
management
strategies
developed
and
implemented
among
tribal,
local,
state,
federal,
and
private
interests,
as
necessary,
to
assure
reasonable
progress
toward
no
human­
caused
impact
on
visibility
(
the
national
visibility
goal).
The
development
of
management
strategies
must
take
into
account
such
equity­
related
concerns
as
relative
contribution
to
visibility
impairment
and
whether
any
one
population
(
such
as
lower­
income
groups)
is
unfairly
burdened
by
the
strategies.
Regulatory
and
planning
authorities
have
a
pivotal
role
in
assuring
that
sources
near
Class
I
areas
are
inventoried
and
assessed,
and
that
their
emissions
are
mitigated
with
regard
to
visibility
impacts
on
these
areas.
Existing
planning
and
regulatory
mechanisms
should
be
strengthened
and
funded
to
create
a
systematic
approach
to
address
this
issue.
For
example,
existing
regulatory
requirements
for
long­
term
visibility
strategies
and
their
review
and
revision
no
less
than
every
three
years
should
be
enforced.

To
this
end,
all
land
managers
should:

a)
be
vigilant
and
aggressively
pursue
opportunities
to
participate
in
external
planning
arenas
where
decision­
making
could
have
effects
on
visibility
in
nearby
Class
I
areas;

b)
review
permit
applications
for
new
or
modified
stationary
sources
proposed
for
construction
and
operation
near
Class
I
areas;
and
c)
request
that
the
appropriate
regulatory
authority
(
or
authorities)
propose
emissions
reduction
strategies
for
nearby
sources
that
contribute
to
existing
visibility
impairment,
either
during
development
of
the
visibility
protection
plans
or
during
the
required
periodic
review
of
such
plans.

Regulatory
programs
should
provide
exemptions
for
tribal
ceremonial
practices
and
for
people
who
are
dependent
on
a
single
source
(
wood
or
coal)
of
heating
and
cooking.
56
3.
Apply
existing
regulatory
requirements.

Regulatory
and
planning
authorities
are
already
required
to
develop,
maintain,
and
enforce
visibility
protection
plans
for
mitigating
nearby
source
impacts
on
the
Class
I
areas.
Regulatory
agencies
should
develop
criteria
for
these
plans
that
are
consistent
across
the
Transport
Region.
An
important
element
of
this
activity
is
the
development
and
maintenance
of
an
emissions
inventory,
tracking,
and
reporting
program
for
each
Class
I
area.
The
authorities
must
consult
and
actively
involve
the
respective
Class
I
area
land
manager(
s)
throughout
the
process.

4.
Utilize
other
planning
processes.

Federal
land
managers
and
authorities
in
local
political
subdivisions
and
on
tribal
lands
should
perform
analyses
of
potential
visibility
impacts
to
Class
I
areas
on
the
Colorado
Plateau
and
include
them
in
land
management
plans
for
lands
located
near
these
areas.
57
TRANSBOUNDARY
EMISSIONS
FROM
MEXICO
Background
Pollution
from
stationary,
mobile
and
area­
wide
emission
sources
in
Mexico
contributes
to
visibility
degradation
in
the
Colorado
Plateau's
Class
I
areas.
Expected
economic
development
in
the
border
region
will
likely
exacerbate
transboundary
pollution
transport
unless
steps
are
taken
to
reduce
and
prevent
pollution.
The
Commission
lacks
the
authority
to
address
these
transboundary
pollution
problems
directly,
but
should
support
several
ongoing
efforts
to
develop
emissions
inventories,
establish
binational
institutions
and
bilateral
agreements
to
facilitate
cooperation,
and
create
incentives
for
implementation
of
cost­
effective
air
pollution
abatement
strategies.

RECOMMENDATIONS
REGARDING
EMISSIONS
FROM
MEXICO
Mexican
sources
are
a
significant
contributor,
particularly
of
SO2
emissions.
However,
data
gaps
and
jurisdictional
issues
make
this
a
difficult
issue
for
the
Commission
to
address
directly.
The
recommendations
below
call
for
continued
binational
collaboration
to
work
on
this
problem,
as
well
as
additional
efforts
to
complete
emissions
inventories
and
increase
monitoring
capacities.
The
Commission
feels
that
they
should
receive
high
priority
for
regional
and
national
action.

1.
Develop
a
comprehensive
emissions
inventory.

Characterizing
and
quantifying
emissions
from
sources
in
Mexico
provide
a
necessary
foundation
for
developing
emissions
management
options.
Some
data
exist
as
a
result
of
past
or
ongoing
governmental
efforts.
In
addition,
the
Western
Governors'
Association,
in
cooperation
with
Mexican
government
officials,
is
developing
methodologies
for
preparing
an
emissions
inventory
for
the
entire
border
region.
The
Commission
supports
these
efforts.

2.
Establish
binational
institutions
and
agreements.

The
Commission
urges
the
EPA,
the
U.
S.
State
Department,
and
affected
states
to
make
effective
use
of
opportunities
provided
by
existing
binational
treaties
and
agreements.
For
example,
Annex
V
to
the
1983
La
Paz
Agreement
directs
the
EPA
and
INE
(
the
National
Institute
of
Ecology
of
Mexico)
to
assess
the
causes
of,
and
develop
solutions
to,
air
quality
problems
in
border
sister
cities.
As
a
result,
the
U.
S.
and
Mexican
governments
have
developed
an
environmental
plan
for
the
border
that
is
periodically
revised
(
next
revision:
summer
1996);
the
National
58
Coordinators
meet
regularly
to
discuss
progress;
and
working
groups
composed
of
federal
and
state
officials
(
e.
g.,
the
Border
Air
Working
Group)
have
been
established
to
address
pollution
problems
in
various
media.
The
Border
Governors'
Association
also
examines
environmental
problems
in
the
border
region.
The
Commission
supports
these
activities
and
is
prepared
to
work
cooperatively
with
these
groups
as
necessary/
appropriate.

3.
Develop
community
mechanisms
for
cooperative
transboundary
planning.

While
pollution
transport
from
Mexico
affects
the
West
generally,
local
communities
in
the
border
region
are
most
severely
affected
and
have
the
greatest
need
to
develop
cooperative,
creative
approaches.
Greater
local
involvement
in
decision
making
will
likely
lead
to
more
effective
and
expeditious
pollution
abatement
strategies.
The
Commission
supports
the
designation
of
international
air
quality
management
districts
in
border
cities
and
the
establishment
of
community­
based
binational
committees
charged
with
developing
air
quality
management
plans.
The
U.
S.
and
Mexican
governments
are
currently
negotiating
an
international
agreement
to
institutionalize
such
an
approach
in
the
"
Paso
del
Norte"
region
(
El
Paso,
Texas;
Dona
Ana
County,
New
Mexico;
and
Ciudad
Juarez,
Chihuahua).
The
Commission
supports
this
effort
and
recommends
that
the
respective
federal
governments
consider
expanding
this
type
of
approach
to
other
border
communities

4.
Finance
air
pollution
control
projects.

The
Commission
recommends
that
the
governments
of
the
U.
S.
and
Mexico
utilize
several
new
institutions
established
by
the
North
American
Free
Trade
Agreement
to
improve
air
quality.
Although
there
are
critical
needs
in
the
areas
of
water
supply
and
treatment,
the
Commission
urges
the
Border
Environmental
Cooperation
Commission
(
BECC)
and
the
North
American
Development
Bank
(
NADBANK)
to
apply
available
capital
for
border
infrastructure
projects
to
high
priority
air
pollution
problems
whose
resolution
will
have
marked
effects
on
regional
air
quality
(
e.
g.,
emission
control
technology
on
major
industrial
or
electricity­
generating
facilities).

5.
Provide
incentives
for
transboundary
investment
in
pollution
control.

The
Commission
encourages
the
EPA
to
explore
the
feasibility
of
allowing
U.
S.
industries
to
earn
emission
reduction
credits
for
investment
in
pollution
control
and
prevention
projects
in
Mexico.
These
might
be
applied
to
existing
Clean
Air
Act
programs
for
nonattainment
areas
or
as
part
of
a
western
regional
emissions
management
program
implemented
to
protect
visibility.
Criteria
and
procedures
for
awarding
appropriate
credits
should
be
developed
to
provide
an
incentive
for
investment
in
transboundary
pollution
control
projects
that
would
have
a
beneficial
impact
on
air
quality
in
border
communities
and
throughout
the
western
United
59
States.
The
ongoing
international
negotiations
directed
at
the
Paso
del
Norte
region
mentioned
above
include
consideration
of
conducting
a
feasibility
analysis
for
an
international
emissions
trading
program.
The
Commission
should
support
this
effort.
Conversely,
the
Commission
supports
disincentives
to
discourage
U.
S.
companies
from
investing
in
facilities
in
Mexico
that
do
not
achieve
pollution
control
levels
comparable
to
those
required
in
the
United
States.

6.
Pursue
pollution
control
projects
at
specific
major
sources
in
Mexico.

The
construction
and
operation
of
major
stationary
sources
in
Mexico
may
be
a
significant
cause
of
long­
distance
pollution
of
Class
I
areas
on
the
Colorado
Plateau.
The
Commission
encourages
the
respective
federal
governments
to
pursue,
through
international
negotiations
and
agreements,
implementation
of
pollution
reduction
strategies
aimed
at
specific
facilities
that
may
be
found
to
have
identifiable
impacts
on
the
Colorado
Plateau.
60
FUTURE
SCIENTIFIC
AND
TECHNICAL
NEEDS
Introduction12
Many
of
the
recommendations
in
this
report
call
directly
for
continued,
expanded
or
improved
collection
of
technical
information
in
order
to
provide
the
basis
for
future
regional
policy
recommendations
and
development
of
appropriate
implementation
strategies
by
tribes,
states
and
federal
agencies.
In
order
to
implement
some
of
the
recommended
programs,
additional
technical
data
will
have
to
be
collected,
interpreted
and
modeled
on
an
ongoing
and
regional
basis.

The
following
sections
of
this
report
and
related
recommendations
include
reference
to
technical
needs:

Stationary
Sources:
In
order
to
track
emissions
targets
and/
or
to
implement
a
regional
cap
and
trading
program,
an
improved
emissions
monitoring
and
accounting
system
will
be
needed.

Mobile
Sources:
The
recommendations
call
for
establishing
mobile
source
emissions
budgets
for
selected
major
urban
areas,
which
will
require
accurate
data
collection.

Area
Sources:
The
recommendations
call
for
improved
modeling
of
road
dust
effects,
setting
up
an
emissions
tracking
system
for
all
fire
activities,
and
improved
integrated
assessment
of
emissions.

Clean
Air
Corridors:
Regional
tracking
and
monitoring
of
emissions
is
needed
in
order
to
make
sure
that
the
Commission's
projections
regarding
the
relative
insensitivity
of
sources
of
clear
air
prove
correct.

Transboundary
Emissions
from
Mexico:
Cooperative
work
with
Mexican
officials
and
corporations
requires
an
accurate
emissions
inventory.

Air
Quality
on
Tribal
Lands:
There
is
a
need
for
more
comprehensive
emissions
inventories
for
areas
on
and
near
tribal
areas
as
well
as
monitoring
of
air
quality
on
tribal
lands.
The
limitations
of
present
models
do
not
permit
modeling
of
impacts
on
tribal
lands.

12
For
a
more
comprehensive
discussion
of
technical
and
scientific
needs,
see
"
Subcommittee
Report
on
the
Future
Needs
of
mmission,"
November
6,
1995,
developed
by
a
subcommittee
of
the
Public
Advisory
Committee.
61
In
general,
four
types
of
initiatives
are
required
to
meet
the
technical
needs
of
future
programs:
improved
emissions
inventories,
expanded
monitoring
of
visual
air
quality,
refined
modeling
capacities,
and
improved
assessment
information
and
methods.

Emissions
Inventory
The
emissions
inventory
developed
by
the
Commission
represents
all
known
emissions
of
visibility­
impairing
pollutants
from
all
known
sources.
Programs
which
call
for
assessment
of
reasonable
progress
toward
the
national
air
quality
goal
based
on
targeted
emission
reductions,
or
on
model­
projected
estimates
of
improvements,
will
require
an
accurate
and
complete
emissions
inventory.
The
current
GCVTC
emissions
inventory
represents
cooperative
work
among
many
in
the
region
and
an
advance
in
comprehensive
data
collection,
but
the
emissions
inventory
process
can
and
should
be
improved.

A
substantial
effort
will
be
needed
to
coordinate
and
update
continuously
the
emissions
inventory
to
reflect
actual
emissions
in
the
region
on
a
year­
by­
year
basis.
In
addition,
any
disparity
in
methods
for
developing
emission
estimates
by
any
entity,
whether
federal,
state
or
tribal,
must
be
adjusted
or
equalized
in
order
to
assure
a
consistent
inventory.
This
will
be
particularly
critical
if
a
regional
trading
program
is
implemented
where
tons
of
emissions
from
one
state
or
tribal
land
may
be
traded
for
tons
of
emissions
from
another.
If
the
emissions
inventory
methodologies
are
different,
then
it
will
be
difficult
to
assess
the
true
impact
of
trading
programs
among
various
jurisdictions.

Air
Quality
Monitoring
Now
that
the
Commission
has
completed
these
recommendations
to
the
EPA,
it
will
be
necessary
to
measure
and
report
on
reasonable
progress
toward
the
goal
of
remedying
existing
and
preventing
future
impairment
of
visibility
in
mandatory
Class
I
areas.
This
implies
that
federal,
state,
tribal,
and
local
air
quality
agencies
must
be
committed
to
a
longterm
monitoring
program.

The
current
federal
visibility
monitoring
program
(
IMPROVE)
distributed
monitoring
sites
to
address
national
needs
at
Class
I
areas
throughout
the
country.
IMPROVE
has
led
to
limited
visual
air
quality
data
collection
in
the
GCVTC
region.
There
are
sixteen
Class
I
areas
on
the
Colorado
Plateau
that
have
been
selected
as
requiring
visibility
protection.
Of
these
sixteen
sites,
limited
monitoring
is
currently
being
done
at
only
six
sites:

$
Bryce
Canyon
National
Park
$
Canyonlands
National
Park
$
Grand
Canyon
National
Park
$
Mesa
Verde
National
Park
$
Petrified
Forest
National
Park
$
Weminuche
National
Wilderness
Area
62
While
these
sites
are
reasonably
representative
of
visual
air
quality
conditions
on
the
central
Colorado
Plateau,
existing
visibility
in
the
vast
majority
of
the
region,
especially
on
tribal
lands,
has
only
been
inferred
from
the
current
IMPROVE
data
set.

Modeling
In
general
terms,
air
quality
models
are
needed
to
convert
emissions
from
all
sources
and
areas
into
an
estimate
of
visibility
impairment
at
the
key
receptors
(
Class
I
sites)
on
the
Colorado
Plateau.
The
Commission's
committees
and
contractors
have
developed
a
model
that
roughly
approximates
how
weather
and
emissions
result
in
air
quality
at
Class
I
sites.
13
Further
development
of
regional
models
is
needed
to
more
accurately
show
the
relationships
among
emissions
sources
and
effects
at
specific
Class
I
sites
under
specific
conditions,
in
order
to
resolve
the
limitations
of
the
present
model.
Further,
future
modeling
efforts
should
assess
expected
wide­
reaching
effects
from
electric
utility
industry
restructuring.

Assessment
Information
and
Methods
The
key
inputs
to
the
IAS
include,
in
addition
to
technical
inputs
described
above,
information
related
to
the
current
levels
of
controls
and
installed
technologies
on
sources,
the
control
options
that
are
available
for
sources
(
including
costs
and
efficiencies),
and
methods
to
project
changes
in
the
future.
These
need
to
be
significantly
improved
to
reduce
uncertainties
in
assessing
or
forecasting
the
effects
of
emissions
management
options.
In
addition,
the
methods
for
evaluating
overall
economic
effects
and
other
secondary
assessment
criteria
must
be
improved.

RECOMMENDATIONS
REGARDING
FUTURE
SCIENTIFIC
AND
TECHNICAL
NEEDS
The
Commission
foresees
that
the
following
regional
scientific
and
technical
work
will
need
to
be
done.
The
tasks
may
be
performed
by
a
combination
of
state,
tribal,
and
federal
organizations,
with
coordination
by
a
regional
body.

EMISSIONS
INVENTORY
1.
Secure
adequate
long­
term
funding.

Emissions
inventories
require
significant
human
and
financial
resources.
Enough
resources
must
be
allocated
to
the
task
from
state
and
federal
sources.

13
The
accomplishments
and
limitations
of
the
present
model
are
discussed
in
Section
II.
63
2.
Develop
and
update
a
regional
emissions
inventory.

A
quality
inventory
must
be
completed
and
then
updated
on
a
regular
basis.
A
complete
plan
should
be
developed
prior
to
the
start
of
data
collection.
All
states,
tribes,
and
federal
agencies
should
follow
this
plan,
so
that
data
collection
methods
are
compatible
for
all
areas
and
sources.

3.
Standardize
comprehensive
data
collection.

Inconsistencies
and
gaps
in
the
emissions
inventory
should
be
addressed,
including
the
following:

a)
current
inconsistencies
in
the
ways
states
collect
and
quantify
emissions
data;

b)
emissions
inventory
information
for
agricultural
activities;

c)
all
data
collection
for
a
single
calendar
year;

d)
a
mechanism
to
accept/
reject/
determine
factors
to
fill
in
data
gaps;

e)
information
regarding
current
levels
of
controls;
and
f)
emissions
inventory
data
specific
to
tribal
lands.

4.
Develop
agreements
on
how
data
will
be
used.

Agreement
should
be
reached
on
how
and
for
what
purposes
the
data
will
be
used.
For
instance,
states,
tribes
and
federal
agencies
should
determine
whether
inventories
and
analyses
developed
for
regional
programs
and
policy
development
can
or
should
be
incorporated
into
national
databases.

5.
Develop
adequate
trained
human
resources.

Agencies
should
be
staffed
to
conduct
and
maintain
emissions
inventories.
In
the
past,
the
EPA
has
not
placed
a
high
priority
on
emissions
inventories
even
though
they
provide
the
basis
for
state
or
tribal
implementation
plans,
rulemaking
and
application
of
Section
169B
of
the
Clean
Air
Act.

6.
Address
the
need
for
micro­
inventories.

A
greater
emphasis
should
be
placed
on
micro­
inventories
of
emissions
for
areas
in
and
near
Class
I
Areas
and
other
areas
of
concern,
such
as
tribal
lands.
Modeling
indicates
that
nearby
sources
may
have
a
greater
impact
on
visibility
than
sources
at
a
greater
distance
on
a
per
ton
basis.
As
such,
comprehensive
micro­
inventories
are
needed
for
the
near­
field
around
Class
I
areas.
Without
them,
it
will
be
impossible
to
64
reliably
identify
that
portion
of
the
contribution
to
visibility
impairment
caused
by
long­
range
transport
of
regional
haze.

7.
Agree
on
an
emissions
forecasting
methodology.

Agreement
should
be
reached
on
the
source
of
information
and
methods
to
be
used
to
forecast
future
emission
changes
related
to
economic
growth
and
anticipated
effects
from
control
programs.

AIR
QUALITY
MONITORING
1.
Continue
and
expand
the
number
of
monitoring
sites
and
frequency
of
sampling.

The
current
IMPROVE
monitoring
network
only
measures
aerosol
samples
twice
a
week
and
at
only
a
few
Class
I
sites.
Thus,
five­
sevenths
of
the
time,
the
chemical
makeup
of
the
particulates
contributing
to
visibility
impairment
is
unknown.
Consideration
should
be
given
to
expanding
the
coverage
or
redeployment
of
resources
in
the
IMPROVE
network
to
enhance
completeness
of
the
data
set,
including
on
tribal
lands.
In
addition,
background
surveillance
sites
could
be
established
at
intermediate
locations
between
the
Class
I
areas
and
large
regional
sources
(
metropolitan
areas)
to
provide
a
better
understanding
of
the
intermediate
course
of
atmospheric
chemistry
and
transport.
Monitoring
should
be
maintained
at
existing
sites
in
order
to
allow
for
long­
term
trend
analysis.

2.
Establish
three
essential
components.

The
three
fundamental
components
of
a
future
visibility
monitoring
program
should
be:
1)
light
extinction
measurements
from
transmissometers;
2)
aerosol
chemistry
measurements
from
fine/
coarse­
mass­
particulate
samplers;
and
3)
meteorological
measurements
of
wind
speed,
direction,
temperature,
and
humidity.
Tribal
lands
would
be
particularly
appropriate
sites
for
tracking
and
monitoring
case
studies.

MODELING
Both
sophisticated
and
reduced
form
models
are
needed.
Once
these
methods
and
data
are
in
hand,
any
simulation
can
be
prepared.
In
other
words,
the
two
types
of
issues
placed
before
the
GCVTC
of
subregional
or
region­
wide
issues
can
be
assessed
with
equal
facility.

1.
Develop
a
comprehensive,
sophisticated
model.

A
comprehensive
model
must
be
able
to
match
its
predictions
of
air
pollution
and
visual
air
quality
with
actual
observations
of
both
factors.
This
model
should
generate
65
output
at
least
on
a
twelve­
hour
basis
using
emissions
and
meteorological
observations
on
this
time
scale.
To
reproduce
the
observations
on
a
space
and
time
basis,
there
is
a
need
for
accurate
emissions
data
over
the
entire
modeling
area,
reliable
wind
fields,
cloud
and
other
climatological
data,
and
samplings
of
pollutants
and
visual
air
quality,
as
well
as
dependable
algorithms
for
the
physics
and
chemistry
of
transport
and
the
transformation
of
pollutants
during
transport
and
deposition.
This
model
is
likely
to
be
sufficiently
complicated
that
it
would
have
to
be
run
on
a
sophisticated
computer.
To
the
extent
that
interpretation
of
fine
grid
geography
or
of
urban
plumes
is
necessary
to
match
the
data,
this
capability
should
be
included.
The
model
must
also
be
able
to
accurately
model
both
near­
field
(
within
about
30
miles)
and
far­
field
effects.

2.
Develop
a
"
Reduced
Form
Model."

A
second
type
of
model
will
be
needed
for
assessing
the
effects
of
control
options
on
emissions
and
visual
air
quality.
This
would
be
a
reduced
form
model
(
RFM)
that
can
be
installed
on
a
personal
computer
and
run
in
seconds
to
minutes
to
convert
emissions
into
estimates
of
ambient
fine
particle
loadings
and
visual
air
quality.
This
model
should
relate
emissions
of
various
species
from
the
source
regions
of
the
entire
study
area
to
data
collected
at
receptor
sites
in
the
Class
I
areas
of
interest.

The
RFM
needs
to
be
able
to
replicate
the
predictions
of
the
more
comprehensive
model.
Therefore,
the
transfer
coefficients
should
be
constructed
by
the
comprehensive
model
for
use
in
the
RFM.

3.
Assess
impacts
of
new
sources.

The
existing
visibility
protection
program
requires
a
review
of
visibility
impairment
from
new
or
modified
major
stationary
sources
to
prevent
adverse
impact
on
visibility
in
nearby
Class
I
areas
as
part
of
the
source
permitting
process.
This
is
currently
done
following
guidance
issued
by
the
Inter­
Agency
Workgroup
for
Air
Quality
Modeling.
This
review
is
needed
to
prevent
future
attributable
impairment.
To
assess
regional
impacts,
new
sources
should
be
incorporated
as
part
of
the
process
to
address
"
reasonable
progress."
As
noted
above,
EPA
should
develop
appropriate
guidance
on
new,
large­
scale
regional
models
which
will
be
able
to
incorporate
all
source
impacts.

4.
Obtain
improved
meteorological
data.

Large­
scale
regional
models
are
highly
dependent
on
input
of
meteorological
data.
The
wide
separation
between
locations
that
measure
winds
aloft
(
i.
e.,
National
Weather
Service
balloon
stations)
contributes
a
high
degree
of
uncertainty
to
the
results
of
the
modeling.
Consideration
should
be
given
to
expanding
the
network
of
sites
that
collect
upper
air
soundings.
In
addition,
local
meteorological
data
at
the
Class
I
areas
are
needed
to
identify
potential
local
source
impacts.
The
coordination
of
region­
wide
intermittent
control
systems
(
such
as
region­
wide
66
smoke
management)
will
necessitate
an
expansion
in
the
meteorological
data
collection
network
in
order
for
such
a
system
to
be
effective.

ASSESSMENT
TOOLS
AND
METHODOLOGY
1.
Undertake
more
detailed
economic
studies.

More
detailed
economic
studies
are
needed
in
order
to
determine
more
accurately
the
costs
of
controls
and,
of
more
importance,
to
understand
the
effects,
both
positive
and
negative,
past
and
future,
that
these
costs
have
on
the
local
and
regional
economies
and
their
growth.
Potential
economic
effects
needing
more
study
include:
economic
benefits
of
cleaner
air
(
such
as
to
tourism),
impacts
of
costs
on
companies
and
individuals
that
pay
them
(
for
instance,
effects
on
profits,
competitiveness
and
disposable
income),
and
the
feedback
of
control
expenditures
into
other
industries
in
the
region
(
such
as
pollution
controls,
parts
and
services
and
electricity
production
to
operate
controls).

2.
Develop
better
assessment
tools
and
methods.

In
order
to
provide
an
objective
analysis
of
the
effects
of
emissions
management
strategies
for
regional
haze,
specific
components
of
research
and
development
are
needed,
including:

a)
expanded
and
improved
inventory
of
control
options
and
costs
for
use
in
assessments;

b)
establishment
of
a
mechanism
to
aggregate
sources
into
assessment
groups
consistent
with
the
spacial
distribution
of
air
quality
modeling
and
economic
assessment
regions;

c)
improved
econometric
analysis
tools
and
techniques
to
characterize
more
accurately
subregional,
including
tribal,
impacts;
and
d)
upgraded
methodological
approaches
for
performing
secondary
assessments.
67
SECTION
IV:
TRIBAL
PERSPECTIVES
AND
POSITION
REGARDING
RECOMMENDATIONS
Introduction
The
following
section
provides
background
regarding
tribal
participation
in
the
Commission
process
and
the
legal
framework
for
tribal
relationships
with
states
and
the
federal
government.
Tribal
participants
in
the
process
have
also
provided
their
unique
perspectives
on
the
Commission's
recommendations,
commenting
on
how
those
recommendations
may
affect
tribal
lands
and
peoples.

In
large
part,
the
tribal
participants
support
the
guiding
principles
set
forth
in
Section
III
of
this
report
and
agree
with
the
Commission's
recommendations,
as
discussed
in
more
detail
below.
In
some
instances,
however,
the
tribal
participants
wish
to
highlight
certain
points
made
in
this
report
or
provide
a
distinct
perspective
and
emphasis
arising
from
tribal
experience.
These
views
are
also
set
forth
in
this
section.

The
Tribal
Environment
It
is
the
philosophy
of
most
Indian
tribes
that
the
quality
of
life
of
their
members
is
intimately
related
to
the
quality
of
their
environment,
and
that
people
and
nature
should
be
in
harmony
and
balance.
Vistas
are
important
to
tribes
in
spiritual
and
cultural
ways
but
they
are
also
important
for
economic
reasons.
The
pristine
and
visible
beauty
of
their
homelands
are
often
the
reason
for
tourist
visitations.
These
visitations
support
tourism
and
many
cottage
industries
on
the
reservations
and
provide
revenue
for
tribal
governments.

As
"
harmony"
requires,
tribes
also
recognize
that
tribal
populations
are
increasing
and
tribal
governments
must
address
the
needs
of
their
developing
nations.
Tribes
are
working
to
develop
their
economic
infrastructure
so
that
they
can
achieve
self­
sufficiency
and
provide
for
their
people,
including
revenues
for
tribal
governments.
Tribal
governments
provide
community
services,
such
as
road
maintenance,
water,
environmental
protection,
education,
health
care,
day
care
and
other
social
services.
As
in
any
community,
the
demand
for
these
services
is
expected
to
grow
with
the
population,
and
tribes
desire
to
grow
economically
to
support
these
demands.

In
order
to
achieve
these
goals,
tribes
cannot
be
unfairly
burdened
by
regional
or
federal
regulations.
Any
recommendations
must
ensure
that
emission
control
burdens
do
not
fall
disproportionately
upon
tribes.
It
must
be
remembered
that
tribes,
by
and
large,
have
not
contributed
to
the
visibility
problem
in
the
region,
precisely
because
of
the
lack
of
economic
development
in
Indian
country.
Therefore,
what
is
fair
for
states
may
not
necessarily
be
fair
for
tribes.
Tribal
economies
are
much
less
developed
than
those
of
states,
and
tribes
must
68
have
the
opportunity
to
progress
to
reach
some
degree
of
parity
with
states
in
this
regard.
Further,
economic
and
cultural
differences
may
magnify
the
effects
of
recommended
emission
controls.

Acknowledgements
Tribal
government
approval
and
support
of
the
Commission's
recommendations
is
reserved
to
individual
tribal
government
discretion.
This
reservation
is
not
intended
to
represent
rejection
of
efforts
to
arrive
at
consensus­
based
policy
recommendations.
Rather,
it
is
based
upon
the
legal
and
historic
status
of
tribes
as
individual
tribal
nations;
as
sovereigns,
tribal
governments
have
the
prerogative
to
deal
directly
with
the
federal
government
and
may
choose
to
do
so
in
regard
to
western
visibility
protection
and
improvement.
Whatever
actions
tribal
governments
ultimately
choose
to
direct
or
pursue,
they
nevertheless
have
found
value
in
working
within
the
GCVTC
process
and
have
directed
tribal
representatives
to
learn
from
the
GCVTC
deliberations
and
contribute
to
the
best
of
their
abilities
toward
achieving
a
good
that
will
benefit
all
people
in
the
West.

A
number
of
tribes
have
been
represented
on
the
Commission
and
on
the
various
committees
established
by
the
Commission.
Although
these
"
tribal
participants,"
as
they
are
called
in
this
report,
do
not
represent
all
211
tribes
in
the
Transport
Region,
as
individual
participants
in
the
GCVTC
process
they
have
joined
together
and
reached
consensus
on
a
number
of
issues,
as
reflected
in
this
report.
When
this
report
presents
tribal
positions
on
the
Commission's
recommendations,
therefore,
it
is
presenting
the
views
of
these
tribal
participants.

Co­
Management
Principles
The
Grand
Canyon
Visibility
Transport
Region,
as
defined
by
the
EPA,
includes
211
tribes.
Therefore,
visibility
improvement
and
protection
strategies
ultimately
adopted
by
the
EPA
must
be
selected
and
implemented
not
only
in
light
of
statutory
requirements
of
reasonable
progress
toward
visibility,
but
also
in
light
of
certain
basic
principles
of
Indian
law.
The
GCVTC
recognizes
and
respects
that
the
federal
and
tribal
governments
have
a
unique
government­
to­
government
relationship
that
is
built
on
historic
legal
principles.
The
Commission's
recommendations
must
be
considered,
not
in
terms
of
a
federal­
state
framework,
but
in
terms
of
a
federal­
state­
tribal
framework.
These
principles
of
Indian
law
and
their
ramifications
for
the
Commission
are
set
forth
below.

Tribal
Sovereignty
It
is
a
basic
principle
of
Indian
law
that
tribes
have
inherent
sovereignty
over
tribal
lands,
or
"
Indian
country."
Moreover,
if
a
tribe
does
not
assert
its
jurisdiction
in
a
particular
instance,
then
the
federal
government
may
have
jurisdiction
in
the
tribe=
s
place,
but
a
state
government
could
not.
As
a
result,
emission
management
strategies
will
be
implemented
within
Indian
country
by
tribal
governments
or,
failing
that,
by
the
federal
government,
but
not
by
state
governments.
69
Federal
Trust
Responsibility
The
Courts
have
found
that
the
federal
government
bears
a
trust
responsibility
toward
American
Indian
tribes.
This
imposes
fiduciary
duties
on
the
conduct
of
federal
agencies
toward
Indian
tribes
and
their
natural
resources.
The
trust
relationship
therefore
presents
a
second
basis,
in
addition
to
the
principle
of
tribal
sovereignty,
for
the
EPA
and
other
federal
agencies
involved
in
the
GCVTC
process
to
ensure
that
tribal
interests
are
protected
in
any
regulatory
scheme.

Tribal
Self­
Determination
As
acknowledged
by
Congress
in
the
Indian
Self­
Determination
and
Education
Assistance
Act,
there
must
be
"
effective
and
meaningful
participation
by
the
Indian
people
in
the
planning,
conduct
and
administration"
of
programs
affecting
Indian
people
[
25
U.
S.
C.
'
450a(
b)].
These
principles
are
also
embedded
in
the
EPA
policy
for
the
Administration
of
Environmental
Programs
on
Indian
Reservations
(
November
8,
1984)
in
which
the
EPA
states
that
it
will
"
view
Tribal
Governments
as
the
appropriate
non­
Federal
parties
for
making
decisions
and
carrying
out
program
responsibilities
affecting
Indian
reservations,
their
environments,
and
the
health
and
welfare
of
the
reservation
populace."
Each
tribe
is
the
decision­
maker
for
its
own
future
and
is
responsible
for
ensuring
that
the
needs
and
rights
of
its
people
are
met
and
protected.
Tribal
concerns
must
be
taken
into
account
in
formulating
recommendations

Tribal
Impacts
Reports
and
Studies
Tribal
participants
feel
that
the
report
Impact
Projections
of
Emission
Management
Scenarios
on
Western
Tribal
Lands
(
January
1996),
was
inadequate
and
provided
only
very
general
conclusions.
The
various
other
studies
undertaken
by
the
Commission
did
not
adequately
evaluate
and
describe
the
unique
economic
structures
and
demographic
patterns
of
Indian
tribes,
nor
their
unique
cultures
and
aspirations.
Also,
the
studies
very
narrowly
focused
on
straight
line
economic
cost/
benefit
analysis.
Other
values
are
important
to
tribes:
quality
of
life,
freedom
of
religion
and
choice
in
lifestyle,
to
name
a
few.
Future
studies
should
address
these
important
areas
of
concerns
so
that
the
tribes,
and
those
concerned
about
impacts
on
tribes,
will
be
able
to
more
fully
evaluate
management
option
impacts.

Tribes
were
greatly
disappointed
that
secondary
assessment
studies
were
not
fully
carried
out.
Little
or
no
work
was
done
to
identify
impacts
on
health
and
welfare,
land
and
water
uses,
solid
and
hazardous
waste
disposal,
threatened
and
endangered
species,
and
terrestrial
and
aquatic
ecosystems.
This
information
would
have
been
of
great
interest
to
the
tribes
and
probably
many
others.

Program
Implementation
Tribal
governments
have
the
responsibility
to
develop,
implement,
and
manage
programs
within
Indian
country.
If
a
tribe
chooses
not
to
establish
a
program,
then
the
federal
70
government
has
the
trust
responsibility
to
establish
a
program.
Thus
if
the
EPA
promulgates
a
rule
based
on
a
control
technology
scenario,
for
example,
tribes
must
have
the
option
of
implementing
the
rule
within
Indian
country
or
prompting
federal
implementation
of
the
rule
within
Indian
country.
Similarly,
a
market
trading
scenario
in
which
there
was
separate
tribal
participation
or
federal
participation
on
behalf
of
the
tribes
could
be
legitimate.

Many
tribes
are
just
beginning
to
develop
environmental
programs,
and
these
programs
receive
very
minimal
funding
from
the
EPA,
if
any.
Tribal
governments
also
lack
the
tax
base
available
to
states
to
help
fund
environmental
programs
independently.
Therefore,
tribal
implementation
of
visibility
programs
will
require
policy
development
support,
technical
assistance,
and
program
funding.

In
the
implementation
of
an
emissions
trading
program,
special
consideration
for
tribes
is
necessary.
Given
that
many
tribal
lands
are
"
underdeveloped,"
tribes
should
be
allocated
some
additional
share
of
trading
credits
to
allow
for
future
development,
much
as
"
clean"
states
were
under
the
acid
rain
trading
program.

Tribes,
states,
local
governments
and
federal
agencies
must
find
innovative
ways
to
support
implementation
of
regional
haze
programs.
Memoranda
of
Understanding
or
Memoranda
of
Agreement,
and/
or
other
state/
tribal/
federal
agreements,
could
be
utilized
to
share
resources,
expertise
and
responsibility.

TRIBAL
PARTICIPANTS'
POSITIONS
ON
COMMISSION
RECOMMENDATIONS
As
discussed
above,
the
tribal
participants
for
the
most
part
concur
in
the
Commission's
recommendations
set
forth
in
this
report.
Specifically,
the
tribal
participants
agree
with
all
six
of
the
assessment
criteria
listed
on
page
20­
21
of
this
report,
although
the
tribal
participants
feel
that
the
criteria
were
not
uniformly
applied.
The
tribal
participants
also
have
certain
additional
recommendations
and
perspectives
which
are
presented
below.

Air
Pollution
Prevention
Some
of
the
most
pristine,
and
yet
the
most
threatened,
ecosystems
are
found
within
the
lands
of
indigenous
peoples.
The
lack
of
many
basic
necessities,
such
as
sustainable
employment
and
adequate
housing,
creates
the
need
for
immediate
economic
development.
Coupled
with
this
is
the
lack
of
environmental
protection
infrastructure
to
manage
and
check
efforts
to
develop
economic
opportunities
which
are
proceeding
without
consideration
for
the
traditional
Indian
commitment
to
resource
conservation.
Tribal
communities,
like
others
in
the
Transport
Region,
have
the
opportunity
to
take
a
proactive
approach
to
pollution
prevention
and
to
avoid
the
mistakes
of
the
past
which
have
resulted
in
environmental
degradation.
Future
initiatives
should
make
sure
that
growth
planning
and
development
is
coupled
with
environmental
mitigation.
71
In
the
first
subsection
of
Section
III
of
this
report,
various
pollution
prevention
recommendations
are
offered,
including
economic
incentives
for
pollution
prevention
efforts,
encouragement
of
zero
and
near­
zero
emitting
technologies,
and
development
of
alternative
(
i.
e.,
renewable)
power
sources.
The
importance
of
these
recommendations
is
indicated
by
the
prominence
they
receive
in
the
Executive
Summary
of
this
report
(
they
are
listed
as
the
first
recommendation).
Tribal
participants
support
this
recommendation
wholeheartedly.
However,
the
extent
to
which
deployment
of
renewable
energy
will
improve
visibility
is
not,
nor
can
it
be,
stated
with
certainty,
based
on
the
modeling
outputs
available.

The
modeling
of
renewable
energy
control
scenarios
is
of
paramount
importance,
particularly
to
western
tribes.
A
significant
number
of
tribes
(
33)
are
actively
pursuing
development
of
renewable
energy
and
end­
use
efficiency
technology
applications.
These
development
options
involve
remote
electrification,
bulk
power
generation,
improving
reservation
economic
conditions
and
reducing
the
emissions
associated
with
fossil
fuel
generation.
The
Energy
Policy
Act
of
1992
has
intensified
tribal
interest
in
renewables
by
authorizing
the
Department
of
Energy
to
provide
grants
to
tribes
to
evaluate
the
feasibility
of
renewable
energy
development.

The
fact
that
western
reservations
are
prominent
within
prime
solar
and
wind
energy
resource
areas
and
a
number
are
situated
in
major
electricity
transmission
corridors
has
focussed
Congressional
and
tribal
attention
on
joint
ventures
and
other
strategies
for
securing
investment
capital
to
build
and
operate
bulk
renewable
electric
generation
capacity.
Clearly,
apart
from
the
income
obtained
through
wholesale
power
sales,
renewable
energy
development
will
have
great
added
value
to
tribal
governments
in
the
form
of
revenues
from
payments
for
accrued
"
air
credits,"
and
wages
from
jobs
in
a
vertically
integrated
electric
power
industry.

Tribal
participants
support
the
recommendations
to
establish
goals
for
bringing
renewable
power
on
line,
but
modeling
efforts
clearly
need
to
be
expanded
to
include
the
impacts
of
this
recommendation.
More
specific
details
should
underlie
this
recommendation,
including
goals,
incentives
and
a
timeline
for
adding
renewables
to
the
resource
mix.

Stationary
Sources
Tribal
participants
are
concerned
that
PSD
and
the
current
visibility
program
('
169A)
under
the
Clean
Air
Act
insufficiently
address
the
national
goals
of
preventing
and
remedying
visibility
impairment
in
Class
I
areas
caused
by
human­
induced
air
pollution.
Government
Accounting
Office
estimates
indicate
that
sources
accounting
for
up
to
90%
of
pollutants
emitted
near
five
Class
I
areas
are
exempt
from
PSD
requirements,
which
apply
only
to
new
sources.
Existing
sources
and
small
new
sources
are
ignored
by
PSD.
In
addition,
'
169A
(
existing
sources)
concentrates
only
on
visible
plumes,
rather
than
regional
haze,
and
very
few
existing
sources
have
been
required
to
implement
BART
controls.
72
Tribal
participants
in
the
Commission
process
support
the
stationary
source
recommendations
presented
in
Section
III
of
this
report
with
the
following
additional
concerns
and
recommendations:

1.
All
uncontrolled
and
undercontrolled
stationary
sources
should
be
subject
to
equivalent
emission
standards
as
controlled
sources.

2.
An
emissions
cap
should
be
set
for
SO2.

3.
A
better
inventory
and
better
modeling
should
be
developed
for
PM.

4.
If
a
cap
is
established
for
a
particular
pollutants,
minor
sources
on
tribal
lands
should
be
inventoried
since
they
may
not
currently
appear
in
state
inventories.

5.
Data
from
the
Federal
Energy
Regulatory
Commission
should
be
used
as
a
basis
for
forecasts
of
future
electric
utility
emissions
and
for
recommendations
regarding
emission
reduction
goals.
This
will
also
enable
the
Commission
to
identify
opportunities
for
early
retirement
of
high­
emitting
facilities.

6.
The
effects
of
increased
wholesale
and
retail
competition
in
the
utility
industry
must
be
taken
into
account
in
predicting
future
emission
levels.

Moreover,
if
an
emission
trading
strategy
is
adopted,
tribal
participants
recommend
the
following:

1.
Tribes
must
be
involved
in
the
development
of
the
trading
scenario.

2.
Credits
should
not
be
based
on
historical
emissions,
but
should
be
based
on
equitable
factors,
including
the
need
to
preserve
opportunities
for
economic
development
on
tribal
lands.
In
general,
these
lands
are
currently
lacking
in
economic
bases
and
have
not
contributed
to
the
visibility
problems.

3.
Whatever
body
administers
the
trading
program
must
be
representative
of
all
of
the
groups
involved.

4.
The
cap
should
be
defined
by
region,
not
by
state.

Mobile
Source
Controls
As
programs
are
initiated,
participating
governments
should
receive
compliance
assurance
assistance
and
equitable
funding
to
administer
their
respective
programs.
In
addition,
tribal
communities
would
benefit
immensely
from
educational
programs
explaining
the
need
for
controls
and
demonstrating
vehicle
maintenance
methods
for
minimizing
vehicle
emissions.
73
Tribal
participants
are
concerned
about
mobile
source
emissions
from
federal
vehicles
on
or
near
Indian
lands,
especially
sites
run
by
the
Departments
of
Defense
and
Energy.
Federal
air
traffic
in
these
areas
is
of
particular
concern.

Area
Sources
There
are
major
gaps
in
delineating
accurately
the
contribution
of
tribal
land
sources
to
visibility
impairment.
Very
few
air
quality
monitoring
programs
have
been
placed
in
or
near
tribal
lands.
To
more
accurately
inventory
emissions
sources,
monitoring
capability
should
be
significantly
improved
on
and
near
tribal
lands.

Wood
Burning
Many
rural
Indian
homes
rely
on
wood­
burning
stoves
as
the
sole
source
for
cooking
and
residential
heating.
Programs
should
include
a
sole­
source
heating/
cooking
and
ceremonial
burning
exemption
from
visibility
and
other
air
quality
regulations
on
tribal
lands.

Dirt
Roads
There
are
numerous
dirt
roads
within
Indian
country.
If
paving
is
required
as
a
visibility
protection
measure,
financial
assistance
will
be
needed.
In
addition,
non­
paving
options
should
be
considered.

Forest
Management
Practices
Many
tribal
lands
include
forest
lands
which
the
tribes
often
manage
with
prescribed
fire.
Although
fire
can
contribute
significantly
to
visibility
impairment,
tribal
participants
recognize
that
fire
is
an
important
management
tool.
Tribal
participants
recommend
that
the
various
jurisdictions
(
federal,
tribal,
state,
etc.)
develop
and
implement
time,
place
and
manner
constraints
that
minimize
visibility
impairments.

In
addition,
forest
land
managers
need
to
take
into
consideration
the
needs
of
tribal
communities
in
their
practice
of
religion
and
traditional
cultural
activities.
Some
of
these
activities
may
be
protected
under
the
provisions
of
the
American
Indian
Religious
Freedom
Act.
The
availability
of
and
access
to
areas
where
traditional
medicines
and
spiritual
foods
are
located
should
not
be
diminished
by
fire
management
practices.

Clean
Air
Corridor
Controls
Tribes
should
not
be
penalized
for
having
clean
air
and
little
economic
development.
Therefore,
no
inequitable
restrictions
should
be
imposed
on
tribal
and
other
corridor
residents
and/
or
economic
growth.

Future
Scientific
and
Technical
Needs
74
There
is
a
need
for
the
development
of
comprehensive
emission
inventories
on
and
near
tribal
lands.
These
inventories
may
be
used
to
provide
more
accurate
data
for
future
studies,
and
to
prioritize
regulatory
development.
Tribal
participants
recommend
that
the
EPA
assist
tribes
in
this
effort.
In
future
tribal
population
and
socio­
economic
studies,
the
data
collection
process
should
be
designed
to
work
more
closely
with
tribes.

Future
modeling
tools
need
to
be
able
to
accommodate
political
subdivisions
smaller
than
large
counties.
The
economic
modelling
system
needs
to
be
adapted
to
tribal
situations.
The
distinctive
characteristics
of
tribal
lands
deserve
special
attention.
Given
the
diversity
of
tribal
populations
and
land
bases,
the
broad­
based
regional
and
state
level
impact
analyses
do
not
provide
sufficient
and
accurate
data.
Also,
the
unique
economic
structure
and
demographics
of
tribal
peoples
may
be
missed
in
the
broader
regional
analysis.

Tribes
need
to
be
meaningfully
involved
in
the
development
and
implementation
of
future
technical
studies
and
in
accommodating
the
special
needs
of
tribes
in
various
study
methods
and
tools.
Tribes
will
need
the
services
of
their
own
experts
to
help
with
these
efforts,
and
will
need
financial
assistance
to
obtain
such
experts.

Future
Administrative
Needs
Indian
tribes
have
rarely
been
asked
to
participate
in
region­
wide
policy
development
such
as
that
undertaken
by
the
Commission.
Although
not
all
tribes
have
been
involved,
the
tribal
participants
agree
in
principle
that
the
work
of
an
administrative
body
on
air
quality
issues
should
continue.
75
SECTION
V.
FUTURE
ADMINISTRATIVE
NEEDS
Background
The
Grand
Canyon
Visibility
Transport
Commission
represents
an
experiment
in
regional
policy
development
through
cooperative
partnership
among
state,
tribal
and
federal
governmental
entities.
The
Commission
has
also
engaged
a
broad
range
of
interested
parties
from
industry,
environmental
organizations,
academics,
technical
experts,
elected
officials,
and
various
citizens'
organizations.
Throughout
this
process,
the
Commission
has
provided
a
means
for
cooperative
development
of
improved
scientific
information
and
for
intergovernmental
consideration
of
policy
recommendations.
The
following
recommendations
regarding
future
administrative
needs
draw
on
this
experience.

RECOMMENDATIONS
FOR
FUTURE
ADMINISTRATIVE
STRUCTURES
1.
Continue
a
regional
air
quality
entity,
similar
to
the
Commission.

The
implementation
and
ongoing
review
of
regional
haze
management
strategies
will
require
the
work
of
an
entity
similar
to
the
present
Commission,
most
likely
in
a
streamlined
structure,
based
on
the
evaluation
performed
in
recommendation
#
4
below.
The
Commission
therefore
recommends
that
the
functions
of
the
GCVTC
should
continue,
in
order
to
further
develop
this
important
partnership
and
perform
vital
policy
and
implementation
functions
as
outlined
in
#
3
below.

The
name
GCVTC
focuses
disproportionately
on
the
Grand
Canyon
and
should
be
changed
to
reflect
the
larger
geographic
entity
it
serves.
The
primary
role
of
the
Commission,
or
its
successor,
will
continue
to
be
coordination
and
monitoring
in
order
to
recommend
policies
to
the
appropriate
entities.
States,
tribes
and
federal
agencies
will
undertake
implementation
actions.

An
equitable
body
of
state,
tribal
and
federal
representatives
should
convene,
as
necessary
but
at
least
annually,
for
the
purpose
of:
discussing
visibility
and
other
air
quality
issues,
including
public
health
concerns,
and
coordinating
data
collection
efforts,
and
making
recommendations
to
the
EPA
on
reasonable
progress
and
other
air
quality
issues.
76
2.
Integrate
efforts
of
an
administrative
body
with
other
regional
air
quality
needs
and
planning
efforts.

It
is
expected
that
the
EPA
will
soon
undertake
new
air
quality
initiatives
that
also
require
regional
approaches.
The
participating
entities
should
explore
expanding
the
scope
and
structure
of
a
successor
body
to
address
regional
haze
and
other
fine
particulate
impacts
on
visibility
and
health
throughout
the
Western
United
States.
(
If
the
mandate
is
expanded
the
name
of
the
successor
body
should
reflect
the
new
mission.)

3.
Establish
functions
of
a
successor
entity.

After
it
makes
its
initial
recommendations
to
the
EPA,
the
Commission
or
its
successor
should,
through
its
subgroups,
perform
functions
including,
but
not
limited
to,
the
following:

a)
tracking
and
providing
feedback
to
the
EPA
on
EPA's
interpretation
and
implementation
of
Commission
recommendations;

b)
coordinating
implementation
of
inter­
jurisdictional
mechanisms
for
addressing
regional
haze,
including
monitoring
activities;

c)
tracking
implementation
of
programs
for
addressing
regional
haze
to
ensure
equity;

d)
assessing
emissions
and
visibility
data
to
determine
if
reasonable
progress
is
being
made
towards
the
national
visibility
goal,
and
recommending
adjustments
to
regional
haze
management
strategies,
as
necessary;

e)
promoting
the
development
of
innovative,
cost­
effective
mechanisms
for
addressing
regional
haze;

f)
coordinating
research
and
development
efforts
on
visibility
and
airborne
particulate
assessment
methodologies
in
the
West
to
ensure
that
such
efforts
are
focussed
on
concerns
relevant
to
policy
formulation
14
;

g)
providing
a
forum
for
interested
parties
to
offer
input
on
the
development
of
regional
haze
policies;

14
See
Section
III,
Future
Scientific
and
Technical
Needs.
77
h)
promoting
and
supporting
educational
programs
furthering
visibility
(
or
expanded
air
quality)
goals,
in
public
schools,
in
higher
education
and
to
the
general
public;

i)
supporting
energy­
conservation
measures;
and
j)
promoting
outreach
and
communications
programs
for
tribal
communities
in
order
to
address
the
remoteness
and
educational
needs
of
most
Indian
reservations.

4.
Evaluate
and
review
Commission
structures.

In
order
to
create
efficient,
effective
and
sustainable
long­
term
structures,
an
evaluation
of
the
Commission's
present
and
past
functioning
should
be
conducted.
Such
a
review
should
examine
the
composition
of
the
Commission,
operational
structures,
and
management
arrangements,
and
should
generate
recommendations
regarding
future
functional
arrangements.
To
ensure
neutrality
in
the
evaluation,
the
review
should
be
conducted
by
an
independent
outside
source.
Following
such
an
evaluation,
each
participating
governmental
entity
will
be
consulted
about
whether
and
how
it
will
take
part
in
future
activities.

During
the
period
through
its
report
to
the
EPA
in
the
spring
of
1996,
the
Commission
has
functioned
with
governors
or
other
high­
level
state,
tribal
and
federal
leaders
serving
as
Commissioners.
If
the
Commission
becomes
an
ongoing
body,
consideration
should
be
given
to
whether
other
federal,
state
and
tribal
officials
may
be
the
most
appropriate
appointees
as
Commissioners.
Any
future
management
or
administrative
structures
should
consist
of
an
equitable
body
of
federal,
state
and
tribal
representatives.
Public
participation
in
future
efforts
should
be
ensured
through
the
use
and
creation
of
publicly
accessible
working
groups.

5.
Develop
ongoing
funding
mechanisms.

In
order
to
estimate
the
resources,
human
and
financial,
that
will
be
necessary
to
sustain
this
work
(
e.
g.,
basic
administrative
functions,
specific
research
and
monitoring
activities),
a
projected
five­
year
budget
should
be
developed
in
conjunction
with
development
of
a
comprehensive
plan
for
future
operations.

The
EPA
should
provide
ongoing
financial
support
for
the
basic
administrative
functions
of
the
Commission
or
its
successor.
Work
should
continue
in
cooperation
with
the
EPA
to
support
efforts
to
secure
such
funding.
In
the
course
of
evaluating
all
current
Commission
functions
(
see
#
4
above),
the
benefits
and
feasibility
of
additional
sources
of
funds
for
specific
activities
should
be
explored,
including:

a)
visibility
surcharges
on
entrance
fees
for
Class
I
areas
within
the
Colorado
Plateau;
78
b)
dedicated
air
permit
or
emission
fees;
and
c)
redistribution
of
existing
air
pollution
control
funds.

Equitable
funding
should
be
made
available
to
tribal,
state
and
federal
officials
to
support
participation
in
ongoing
data
collections
and
modeling
efforts.

6.
Planning
process
for
future
functions.

The
Commission
is
convinced
that
its
functions
must
continue
in
some
form
in
order
to
ensure
that
regional
haze
management
strategies
which
are
implemented
meet
with
regional
approval.
In
order
to
continue
the
functions
of
the
Commission
without
any
hiatus,
the
Commission
directs
the
Operations
Committee
to:

a)
Follow
up
on
the
Commission=
s
recommendations,
monitor
interpretation
by
EPA
of
the
Commission=
s
recommendations,
seek
funds
for
future
operations,
and
perform
needed
interim
tasks;

b)
Prepare
a
comprehensive
set
of
recommendations
regarding
how
and
in
what
form
to
continue
the
Commission
by
early
September
1996,
building
on
the
recommendations
in
this
section
above.
These
recommendations
will
include
provisions
regarding:

$
the
structure
of
the
Commission
and
any
subsidiary
bodies;

$
the
participation
of
states,
tribes,
and
federal
agencies
on
the
Commission;

$
involvement
of
stakeholder
representatives
in
Commission
processes;

$
administrative
arrangements;

$
the
scope
of
Commission
activities;
and
$
changes
in
the
Commission=
s
by­
laws
needed
to
implement
a
reconstituted
Commission.

By
mid­
September
1996,
the
Operations
Committee
will
distribute
its
detailed
recommendations
as
above
to
the
Commissioners
by
mailed
ballot
for
action.
79
Note:
For
tribal
perspectives
and
commentary
on
these
recommendations,
see
Section
IV.
80
SECTION
VI:
ANALYSIS
OF
THE
COMMISSION'S
RECOMMENDATIONS
Introduction
This
section
presents
the
Commission's
analysis
of
the
likely
effects
associated
with
its
recommendations.
The
analysis
attempts
to
address
these
key
questions:

1.
How
will
the
Commission's
recommendations
affect
visibility
at
Class
I
sites
in
the
Transport
Region?

2.
What
are
the
likely
economic
effects,
both
direct
and
indirect,
of
the
Commission's
recommendations?

3.
What
are
the
likely
environmental,
social,
equity,
and
administrative
effects
of
the
Commission's
recommendations?

The
analysis
is
divided
into
two
main
parts.
The
first
is
a
summary,
using
graphs,
of
likely
visibility
effects
associated
with
the
Commission's
recommendations,
where
effects
are
known.
Such
effects
are
not,
in
all
cases,
known.
The
second
part
is
a
detailed
discussion
of
the
Commission's
recommendations
in
light
of
the
evaluation
criteria
identified
in
Section
II
of
this
report
(
page
20­
21).

Visibility
Gains
from
the
Commission's
Recommendations
The
overall
goal
of
the
Commission's
recommendations
is
to
improve
visibility
on
the
worst
days
and
to
preserve
existing
visibility
on
the
best
days,
at
Class
I
areas
on
the
Colorado
Plateau.
The
recommendations
focus
on
reducing
emissions
from
sources
that
presently
contribute
to
visibility
impairment
and
are
likely
to
do
so
in
the
future.

The
Baseline
Forecast
Scenario
described
in
Section
II
(
page
9)
projects
the
way
in
which
current
federal,
state,
and
tribal
laws
and
programs
are
likely
to
affect
visibility
at
Class
I
areas
on
the
Colorado
Plateau
through
2040.
The
Commission
used
this
"
current
law"
scenario
to
evaluate
the
additional
improvements
in
visibility
that
its
recommendations
are
likely
to
achieve
in
order
to
meet
the
national
visibility
goal.

Figure
VI­
1
consists
of
two
graphs.
The
first,
labeled
Figure
VI­
1A:
"
Visibility
Range
Determined
by
the
Integrated
Assessment
System",
represents
the
range
of
estimated
visibility
conditions
between
the
baseline
forecast
assumptions
and
a
maximum
emissions
management
alternative
in
the
Integrated
Assessment
System.
The
darkly
shaded
area
on
the
graph
represents
the
difference
between
the
estimated
visibility
conditions
resulting
81
from
current
air
quality
programs
and
the
maximum
improvement
from
emissions
control
actions
that
were
included
within
the
Integrated
Assessment
System.

One
limitation
of
the
Integrated
Assessment
System
is
that
several
source
categories
were
not
characterized
as
incorporating
cleaner
emissions
technologies
over
time
as
is
likely
under
current
and
future
air
quality
management
programs.
To
address
this
shortcoming,
the
Commission
developed
a
"
bounding"
estimate
of
the
upper
limit
visibility
conditions
that
could
result
from
making
adjustments
to
the
Integrated
Assessment
System
baseline
assumptions
for
both
growth
of
certain
sources
and
future
controlled
emissions
from
certain
sources.

The
second
graph
labeled
Figure
VI­
1B:
"
Visibility
Range
Expected
from
Recommendations
reflects
this
approach.
The
darkly
shaded
area
of
this
graph
represents
the
difference
between
holding
visibility
constant
from
the
year
2000
to
a
maximum
potential
improvement
from
changes
in
the
Integrated
Assessment
System
baseline
assumptions
and
future
source
control
levels.
To
define
the
maximum
source
control,
certain
source
categories
were
assumed
to
reduce
their
contribution
to
extinction
over
time
in
a
way
similar
to
Integrated
Assessment
System
source
categories
that
had
technological
improvements
of
approximately
74%
reduction
from
1990
levels
of
impact.
This
probably
results
in
an
overprediction
of
the
likely
effect,
however
it
is
a
reasonable
estimate
of
the
maximum
effect
for
this
bounding
exercise.

The
Integrated
Assessment
System
source
categories
that
were
adjusted
for
this
estimate
are:
industrial/
commercial
fuels,
non­
road
diesel,
industrial
processes,
solvent
use,
a
portion
of
other
point
sources,
and
other
area
sources.
The
estimate
also
reflects
a
change
in
the
baseline
assumptions
for
paved
road
dust
in
the
Integrated
Assessment
System.
This
graph
assumes
small
growth
in
paved
road
dust
from
increased
vehicle
miles
traveled
to
the
year
2000
and
then
a
leveling
off.
This
was
based
on
uncertainty
of
the
current
contribution
of
road
dust
to
light
extinction.
Overall,
the
graph
demonstrates
the
Commission's
belief
that,
under
its
definition
of
"
reasonable
progress,"
most
source
categories
will
improve
efficiency
and
reduce
emissions
over
time.
The
emissions
reductions
and
associated
visibility
change
plotted
in
this
graph
would
be
tracked
and
checked
by
monitoring
long­
term
trends.

The
lightly
shaded
region
on
the
bottom
of
both
graphs
in
Figure
VI­
1
represents
the
"
background"
light
extinction
from
natural
causes
(
e.
g.,
windblown
dust).
On
average,
this
amount
of
extinction
represents
the
best
annual
average
extinction
possible
if
all
the
effects
of
human­
caused
impairment
are
addressed.
Currently
approximately
20%
of
the
days
have
this
visibility
level.
This
is
approximately
equivalent
to
the
best
visibility
conditions
pictured
in
the
Introduction
and
plotted
in
Figure
II­
7.
Human
activities
that
were
not
included
in
the
Integrated
Assessment
System
options
for
control
are
approximately
2
Mm
­
1
above
this
"
background"
level.
While
the
improvement
in
extinction
associated
with
the
recommendations
in
the
second
graph
in
Figure
VI­
1
may
appear
small,
they
will
correspond
to
much
larger
changes
on
some
days.
While
these
graphs
show
effects
only
at
Hopi
Point,
the
Commission's
recommendations
are
likely
to
result
in
approximately
the
same
range
of
visibility
benefits
at
other
Class
I
areas.
82
Figure
VI­
1A
83
Figure
VI­
1B
84
ANALYSIS
OF
SPECIFIC
COMMISSION
RECOMMENDATIONS
Introduction
This
section
reviews
in
greater
detail
the
likely
effects
of
the
Commission's
recommendations
in
light
of
the
evaluation
criteria
described
in
Section
II.
The
Commission
has
divided
its
six
criteria
into
two
groups:
visibility
benefits
and
economic
effects
in
one
group,
and
social,
environmental,
equity,
and
administrative
effects
in
another.
The
first
part
of
this
section
is
an
overview
of
the
Commission's
efforts
to
develop
rough
cost
estimates
for
its
recommendations.
The
second
part
of
this
section
discusses
specific
Commission
recommendations.
Visibility
and
costs
are
addressed
in
connection
with
each
set
of
recommendations.
The
remaining
four
criteria
are
discussed
as
a
separate
group.

The
Commission's
recommendations
reflect,
but
are
substantially
different
from
the
scenarios
developed
initially
by
its
technical
committees.
The
Commission
represents
a
range
of
interests,
and
its
recommendations
exhibit
the
real
world
of
give
and
take
among
these
interests.
The
Commission
could
not
simply
decide
to
adopt
one
of
its
earlier
scenarios
because
Commission
members
needed
to
address
a
range
of
concerns
not
reflected
in
those
scenarios.
One
such
example
is
recommendations
supporting
pollution
prevention
and
renewable
energy.
In
addition,
the
Commission's
early
scenarios
could
not
have
anticipated
all
the
different
combinations
of
controls
that
would
be
considered.

As
a
result,
there
is
not
a
perfect
fit
among
the
Commission's
recommendations,
the
early
scenarios
used
in
modeling,
and
prior
reports
to
the
Commission.
Where
some
or
all
of
a
recommendation
is
not
part
of
an
earlier
scenario,
it
is
possible
only
to
estimate
its
visibility
benefits
or
economic
costs
at
this
time.
An
examination
of
the
Commission's
recommendations
requires
a
synthesis
of
its
earlier
analytical
work
and
new
analyses
that
reflect
the
control
choices
recommended
by
the
Commission.
The
results
of
the
work
of
the
Commission's
technical
committees
are
discussed
below.

Certain
points
should
be
kept
in
mind
when
looking
at
modeling
results
that
show
visibility
effects.
One
is
that
data
about
visibility
effects
often
are
stated
in
terms
of
an
annual
average.
This
average
includes
effects
for
"
clear"
days
as
well
as
"
dirty"
days.
Most
emissions
reductions,
however,
are
directed
at
improving
air
quality
on
dirty
days,
and
using
an
annual
average
understates
their
short­
term
effect.
For
example,
the
effects
of
emissions
reductions
achieved
in
Los
Angeles
will
only
be
observed
25%
of
the
time
on
the
Colorado
Plateau,
due
to
wind
patterns.
On
days
when
those
improvements
are
observed,
they
will
be
much
greater
than
the
annual
average.

Another
important
point
is
that
most
of
the
modeling
to
date
addresses
visibility
effects
at
only
one
receptor:
Hopi
Point
in
Grand
Canyon
National
Park.
This
receptor
is
not
necessarily
representative
of
all
Class
I
sites,
but
it
offered
a
substantial
amount
of
highquality
data.
Hopi
Point
may
have
unique
localized
influences,
and
it
is
also
influenced
by
emissions
from
a
combination
of
directions
that
may
not
occur
at
other
Class
I
areas.
To
address
these
potential
limitations,
the
Commission
has
analyzed
three
other
Class
I
areas.
85
This
broader
approach
makes
more
emission
source
regions
relevant
to
the
analysis,
but
is
not
a
complete
substitute
for
modeling
all
Class
I
areas.

Preliminary
Cost
Scenario
It
is
not
possible
to
estimate
reliably
the
economic
costs
and
benefits
of
the
Commission's
recommendations
at
this
time.
The
recommendations
are
largely
conceptual
in
nature,
and
the
direct
and
indirect
costs
and
benefits
will
vary
depending
on
when
and
how
specific
strategies
are
implemented.

The
Commission
has
developed
preliminary
rough
projections
of
the
direct
and
indirect
costs
of
achieving
visibility
improvements
at
Class
I
areas
on
the
Colorado
Plateau.
Direct
costs
are
the
costs
of
imposing
emission
controls
to
improve
visibility.
Indirect
costs
are
the
additional
effects
on
the
region's
economy
from
imposing
those
controls,
including
wages,
employment,
and
"
feedback"
of
expenditures
into
the
regional
economy.

Sources
of
emissions
in
the
West
previously
have
incurred
costs
in
order
to
comply
with
requirements
of
the
federal
Clean
Air
Act,
and
state
and
tribal
programs
covering
all
aspects
of
air
quality.
These
costs
will
continue.
The
Commission's
focus
is
on
any
additional
costs,
beyond
those
resulting
from
compliance
with
current
law,
that
may
be
associated
with
improving
visibility
at
Class
I
areas
on
the
Colorado
Plateau.

As
a
first
step,
the
Commission
has
developed
rough
estimates
of
some
of
the
potential
costs
and
benefits
associated
with
emission
management
options
that
bear
some
similarity
to
its
recommendations.
These
emission
management
options
were
designed
early
in
the
Commission's
process,
and
do
not
match
the
Commission's
recommendations.
The
Commission's
rough
estimates
using
these
early
options
show
the
following:

1.
There
will
be
no
significant
incremental
cost
associated
with
the
Commission's
recommendations
in
the
short
term
because
they
reflect
diligent
implementation
of
existing
programs
and
new
programs
likely
to
be
implemented
for
other
reasons.

2.
If
the
full
set
of
recommendations
is
implemented,
including
a
market­
based
emissions
cap
and
trading
program,
the
potential
range
of
costs
after
2010
under
the
Commission's
preliminary
rough
estimate
is
from
$
500
million
to
$
1.8
billion
per
year.
(
These
cost
estimates
were
generated
by
the
IAS
based
on
optimization
runs
for
25%
and
80%
of
the
Maximum
Management
Alternative.)
This
translates
roughly
into
a
0.1%
decrease
in
gross
regional
product
in
peak
years,
or
approximately
$
10
per
person,
and
an
overall
increase
of
jobs
in
the
region
of
approximately
0.5%
through
2040.

These
rough
estimates
are
only
the
first
step
in
developing
an
estimate
of
costs
associated
with
the
Commission's
recommendations.
They
do
not
reflect
any
cost
savings
or
economic
benefits
that
may
be
associated
with
these
emission
reductions,
such
as
health
care
savings
and
enhanced
property
values.
86
Analysis
of
Air
Pollution
Prevention
Recommendations
Visibility
and
Cost
Effects
There
currently
is
no
quantitative
assessment
of
the
visibility
improvements
that
might
result
from
the
Commission's
recommendations
in
this
area,
or
of
their
likely
economic
effects.
Intuitively,
substituting
non­
emitting
or
lower
emitting
technologies
likely
will
result
in
improved
visibility.
This
includes
encouraging
"
clean"
sources
of
energy
in
new
industries.
Several
recommendations
will
probably
have
direct
economic
effects.
One
example
is
recommendation
#
3,
which
supports
economic
incentives
to
promote
industrial
retooling
that
reduces
emissions.
Another
example
is
recommendation
#
6,
which
suggests
the
possibility
of
charging
emission
fees
for
air
pollution.

Analysis
of
Stationary
Source
Recommendations
Visibility
and
Cost
Effects
The
recommendations
regarding
stationary
sources
involves
establishing
emission
reduction
targets
for
sulfur
dioxide
consistent
with
those
anticipated
under
the
Baseline
Forecast
Scenario,
which
was
designed
to
reflect
requirements
under
current
regulations.
It
is
anticipated
that
the
emission
reduction
targets
will
be
achieved
through
compliance
with
current
regulations
and
voluntary
and
economically
driven
decision
making
of
sources.
Therefore,
no
additional
costs
would
be
incurred
to
impose
controls
if
the
targets
are
met.
The
only
cost
of
the
program
would
be
the
administrative
aspects
of
collecting
and
analyzing
information
on
emission
trends
in
the
Transport
Region.

If
emission
reductions
are
not
achieved
through
compliance
with
current
regulations
and
voluntary
and
economically
driven
decision
making,
then
a
program
would
be
established
to
enforce
more
rigid
reductions.
Earlier
studies
showed
that
a
regional
emissions
cap
and
market
trading
program
is
the
most
cost­
effective
approach
to
deal
with
regional
haze.
However,
equity
and
administrative
issues
associated
with
this
type
of
program
are
complex
and
need
to
be
dealt
with
thoroughly
in
developing
a
detailed
implementation
plan.
Under
this
"
back
stop"
program,
some
costs
of
controls
may
be
expected,
but
cannot
be
quantified
at
this
time.

The
incorporation
of
other
pollutant
species
into
the
stationary
source
program
will
have
similar
emission
reduction
effects.
To
the
extent
that
long
range
targets
are
established
on
the
basis
of
expectations
under
current
regulatory
requirements,
then
no
additional
costs
associated
with
the
visibility
program
would
be
incurred,
other
than
monitoring
and
assessment.
It
is
anticipated
that
annual
average
light
extinction
from
1990
through
2040
at
Hopi
Point
would
be
improved
between
0.8
and
1.0
Mm
­
1
,
depending
on
the
actual
control
levels
achieved
for
those
stationary
sources
sectors
which
have
not
been
analyzed
in
detail.
87
Analysis
of
Mobile
Source
Recommendations
Visibility
and
Cost
Effects
The
Commission's
recommendations
incorporate
national,
regional,
and
local
strategies
for
addressing
mobile
source
emissions.
In
reviewing
these
recommendations
and
their
projected
effects,
it
is
important
to
bear
in
mind
that
the
Commission's
model
appears
to
understate
urban
effects
and
that
mobile
sources
are
a
significant
part
of
urban
emissions.
As
a
result,
it
is
likely
that
the
model
underpredicts
mobile
source
impacts
on
visibility,
primarily
from
tailpipe
emissions.

Current
modeling
shows
that
approximately
30%
(
3.5
Mm
­
1
)
of
the
annual
human­
caused
light
extinction
at
Hopi
Point
in
the
year
2000
is
caused
by
mobile
sources
(
roads,
on­
road
vehicles,
off­
road
vehicles,
aviation,
marine,
and
locomotives).
Most
of
this
impact
(
2.5
Mm
­

1
)
is
attributed
to
road
dust
under
current
modeling;
the
balance
(
1
Mm
­
1
)
comes
from
tailpipe
emissions.

As
part
of
a
national
strategy,
the
Commission
recommends
supporting
the
49­
state
LEV.
A
recent
study
by
the
AAMA
shows
that
the
49­
state
LEV
is
likely
to
reduce
emissions
of
NOx
and
VOC
from
on­
road
vehicles
below
the
BFS
by
at
least
35%
by
2020.
According
to
the
Commission's
model,
this
would
translate
into
only
a
small
annual
visibility
improvement
at
Hopi
Point.
However,
more
work
is
required
to
determine
whether
the
model
underestimates
this
impact.

Potential
visibility
benefits
from
all
other
mobile
source
categories
(
off­
road
vehicles,
boats,
airplanes,
locomotives)
are
approximately
11%
of
the
total
mobile
source
contribution
based
on
current
modeling.

The
Commission
has
not
modeled
the
visibility
effects
of
its
proposed
regional
and
local
mobile
source
initiatives.
The
same
limitation
applies
to
estimates
of
the
costs
associated
with
imposing
mobile
source
controls.
Depending
on
the
costs
associated
with
different
categories,
it
may
be
cost­
effective
to
achieve
the
relatively
small
visibility
benefits
associated
with
different
national
strategies
noted
above.
Additional
work
is
required
to
develop
this
information.

Analysis
of
Area
Sources/
Fire
Recommendations
Visibility
and
Cost
Effects
Millions
of
wildland
acres
in
the
Transport
Region
are
at
risk
from
catastrophic
wildfire.
These
areas
will
burn
eventually,
and
the
fires
will
impair
visibility
at
Class
I
areas
on
the
Colorado
Plateau.
The
Commission's
models
indicate
that
emissions
from
fire,
both
wildfire
and
prescribed
fire,
is
likely
to
have
the
single
greatest
impact
on
visibility
at
Class
I
areas
through
2040.
Current
modeling
indicates
that,
at
certain
times,
increased
visibility
impairment
from
fire
is
likely
to
exceed
the
potential
visibility
improvements
associated
with
other
Commission
recommendations.
88
The
Fire
Emissions
Project
of
the
Commission
found
that,
historically,
fire
occurred
on
approximately
35
million
acres
annually.
This
corresponds
to
an
annual
visibility
impact
of
8­
13
Mm
­
1
.
Current
prescribed
fire
programs
across
the
Transport
Region
cover
approximately
1.2
million
acres
annually.
In
1995,
PM2.5
emissions
from
prescribed
fire
were
estimated
to
be
approximately
75,000
tons
per
year,
less
than
1%
of
total
PM2.5
emissions
from
all
sources
in
the
Transport
Region.
The
proposed
future
prescribed
fire
programs
of
land
managers
would
treat
approximately
6
million
acres
annually
by
the
year
2040,
increasing
the
relative
contribution
to
3%
of
total
PM2.5
emissions
in
the
Transport
Region.
This
projected
target
is
consistent
with
current
land
management
agency
fire
policies,
but
is
dependent
on
available
resources
and
funding.
Significant
increases
in
fire
on
all
wildlands
will
occur,
whether
by
managed
prescribed
fire
or
by
uncontrolled
wildfire,
if
proposed
prescribed
fire
programs
are
not
implemented.

Fire
has
seasonal
impacts
on
visibility;
it
is
not
a
constant
influence.
During
certain
periods
(
days
or
weeks)
of
intense
fire
activity,
the
visibility
impacts
of
prescribed
fire
may
be
much
greater
than
the
average
annual
impacts.
Most
wildfires
occur
in
the
summer
and
fall;
prescribed
fires
are
used
in
the
spring,
summer,
and
fall.
The
clearest
days
on
the
Colorado
Plateau
occur
during
the
winter.
As
a
result,
increased
fire
emissions
are
likely
to
make
the
worst
20%
of
days
even
worse,
rather
than
impair
visibility
on
clear
days.
Both
prescribed
fire
and
wildfire
activity
are
dependent
on
weather
conditions,
resulting
in
visibility
effects
that
can
fluctuate
widely
from
year
to
year.
Table
VI­
1
shows
the
range
of
visibility
impacts
that
are
projected
to
occur
from
the
use
of
prescribed
fire
and
wildfire.

TABLE
VI­
1
Annual
Average
1
Prescribed
Fire/
Wildfire
Visibility
Impacts
in
Mm
­
1
Year
Prescribed
Fire
Baseline
2
Prescribed
Fire
with
Maximum
Controls
3
Wildfire
4
1990­
2000
0.3
­
0.5
NA
0.1
­
1.0
2010
1.5
­
2.0
1.4
­
1.7
0.1
­
1.0
2040
1.6
­
2.2
1.4
­
1.9
0.1
­
1.0
1
Seasonal
impacts
may
be
2­
3
times
higher
than
the
annual
average.

2
Baseline
projections
in
2010
and
2040
reflect
projected
prescribed
fire
programs
under
current
land
management
policies.
Emissions
may
be
overestimated
due
to
fiscal
and
personnel
constraints
and
National
Ambient
Air
Quality
Standards
requirements.
89
3
Prescribed
fire
emissions
can
be
reduced
through
smoke
reduction
measures
(
mechanical
treatment,
etc.).
These
impacts
may
be
further
mitigated
by
managing
the
timing
of
burning
based
on
meteorology.

4
Although
the
Commission
believes
that
increased
use
of
prescribed
fire
activity
will
result
in
long­
term
reductions
of
wildfire
emissions,
the
Commission
has
been
unable
to
quantify
this
benefit.

The
Commission's
recommendations
focused
on
ways
to
limit
the
increased
visibility
impairment
from
fire
that
could
occur
through
2040.
Since
land
managers
will
be
increasing
their
use
of
prescribed
fire
techniques
to
reduce
wildfires,
there
is
an
opportunity
to
reduce
the
growth
in
visibility
impairment
projected
to
occur.

It
is
important
to
bear
in
mind
that
fire
has
highly
variable
effects
on
visibility,
even
on
a
daily
basis.
The
Commission's
model
cannot
reflect
this
variability.

Even
using
"
optimal"
smoke
management
measures,
prescribed
fire's
contribution
to
annual
visibility
impairment
at
Hopi
Point
could
increase
by
400%
between
1995
and
2040.
The
Commission's
fire
modeling
projects
that
use
of
optimal
smoke
management
measures
could
decrease
fine
particle
(
PM2.5)
emissions
from
prescribed
fires
by
approximately
15­
20%.
This
would
limit
the
increased
visibility
impairment
at
Class
I
areas
that
likely
will
be
caused
by
prescribed
fires
through
2040.
In
practice,
land
managers
consider
daily
weather
conditions
to
minimize
effects
from
prescribed
burning.
The
Commission's
model
does
not
permit
an
analysis
of
how
these
decisions,
based
on
weather
conditions,
influence
smoke
impacts.

Using
"
optimal"
smoke
management
and
emission
reduction
measures
is
projected
to
cost
approximately
$
500­$
2,000
per
ton
of
PM2.5
reduction.
Reducing
PM2.5
emissions
by
15­
20%
over
projected
increases
is
estimated
to
cost
approximately
$
65­$
75
million
annually.

Analysis
of
Clean
Air
Corridors
Recommendations
The
Commission
is
not
recommending
any
special
programs
or
regulations
for
clean
air
corridors
beyond
existing
law.
The
basis
for
this
approach
is
model
results
showing
that
projected
emissions
growth
in
the
studied
clean
air
corridor
is
not
expected
to
have
a
perceptible
impact
on
visibility
at
Class
I
sites.

Analysis
of
Recommendations
Regarding
Emissions
Within
and
Near
Class
I
Areas
Visibility
and
Cost
Impacts
The
Commission's
recommendations
address
a
range
of
transportation
and
energyrelated
emissions,
as
well
as
emissions
from
prescribed
fire,
that
occur
both
within
and
near
Class
I
areas.

Particle
emissions
in
and
near
Class
I
areas
deserve
particular
attention
because
they
have
potential
immediate
consequences
for
visibility.
Approximately
two­
thirds
of
90
particles
measured
at
Hopi
Point
consist
of
fine
soil
and
coarse
material
(
PM2.5
and
PM10).
Fine
soil
from
sources
near
and
distant
from
Class
I
areas
accounts
for
about
one­
third
of
the
visibility
impairment
caused
by
particles.
Sources
of
coarse
material
have
relatively
small
spheres
of
influence,
i.
e.,
coarse
material
generally
doesn't
travel
far.
As
a
result,
the
data
from
Hopi
Point
indicate
that
sources
of
coarse
material
located
close
to
Class
I
areas,
such
as
unpaved
roads,
are
likely
to
be
more
important
to
visual
air
quality
than
regional
sources.
Forest
fires
burning
close
to
or
within
Class
I
areas
can
also
be
expected
to
have
significant
impacts
on
visibility,
since
they
emit
coarse
and
fine
dust
as
well
as
elemental
and
organic
carbon.

The
Commission
recommends
improved
planning
to
reduce
visibility
effects
from
sources
of
coarse
material
and
fine
dust
both
within
and
near
Class
I
areas.
The
Commission's
model
does
not
allow
modeling
of
the
potential
visibility
impacts
of
this
recommendation.
The
same
modeling
limitation
applies
to
the
recommendation
that
strategies
be
developed
to
limit
emissions
from
local
sources.

The
Commission
has
not
quantified
the
visibility
benefits
associated
with
its
recommendations
concerning
other
transportation
and
energy­
related
emissions.
The
Commission
has
not
developed
any
cost
analysis
for
these
recommendations.

Analysis
of
Transboundary
Emissions
Recommendations
Visibility
and
Cost
Effects
The
Commission's
model
presently
shows
that
emissions
from
Mexico
result
in
annual
average
visibility
impacts
at
Hopi
Point
of
approximately
1.68
Mm
­
1
.
Of
this
amount,
approximately
1
Mm
­
1
is
attributed
to
industrial
and
residential
sources
near
the
U.
S.­
Mexico
border.
Of
the
remainder,
approximately
half
is
attributed
to
specific
stationary
sources;
the
remainder
to
off­
shore
shipping
emissions
that
travel
across
Mexico
to
the
United
States.
This
is
approximately
17%
of
manageable
visibility
impairment
at
Hopi
Point
on
an
annual
average
basis.
Using
an
annual
average
likely
understates
the
impact
of
these
emissions
on
a
given
day,
because
meteorological
conditions
limit
their
influence
to
approximately
25%
of
the
year.
It
is
likely
that
on
certain
days
the
light
extinction
is
much
greater.
The
Commission
has
not
modeled
visibility
impacts
at
other
Class
I
areas.

Most
of
the
transboundary
emissions
(
about
60%)
are
SOx,
and
most
come
from
area
sources
within
Mexico.
At
least
one
smelter
located
within
Mexico
is
projected
to
be
responsible
for
approximately
14%
(
0.24
Mm
­
1
)
of
the
annual
total
transboundary
light
extinction
at
Hopi
Point.
The
Commission
is
aware
of
reports
that
this
source
is
scheduled
to
be
shut
down
within
the
next
few
years.

A
comprehensive
emissions
inventory
will
give
a
clearer
picture
of
the
different
sources
of
transboundary
emissions.
Programs
to
finance
air
pollution
control
projects,
to
provide
incentives
for
transboundary
investment
in
pollution
control,
and
to
retire
major
emitting
sources
are
likely
to
have
visibility
benefits
at
Hopi
Point.
However,
more
work
is
required
on
the
emissions
inventory
before
these
benefits
can
be
quantified.
91
One
important
issue
associated
with
these
emissions
is
whether
they
are
"
manageable"
in
the
same
way
that
emissions
from
sources
located
within
the
United
States
are
manageable.

The
Commission
is
unable
at
this
time
to
estimate
the
potential
costs
associated
with
its
recommendations.

Analysis
of
Scientific
and
Technical
Needs
Recommendations
The
Commission
has
made
a
number
of
recommendations
that
include
additional
monitoring,
data
collection
and
reporting.
These
activities
are
the
key
to
implementing
many
of
its
other
recommendations.
It
is
not
practical
at
this
time
to
estimate
the
costs
associated
with
these
activities.

Discussion
of
Environmental,
Social,
Equity,
and
Administrative
Effects
The
Commission's
recommendations
are
a
mix
of
the
specific
and
the
general.
While
analysis
of
the
economic,
social,
environmental,
equity,
and
administrative
impacts
of
specific
recommendations
can
yield
robust
conclusions,
predicting
the
effects
of
general
recommendations
is
at
best
an
uncertain
process.
This
is
particularly
true
for
the
211
Indian
tribes
located
on
the
Colorado
Plateau,
whose
peoples
have
unique
economies
and
lifestyles.
These
issues
are
addressed
more
fully
in
Section
IV
on
"
Tribal
Perspectives"
in
this
report.
The
Commission's
economic
model
also
has
certain
limitations.
The
process
for
evaluating
criteria
other
than
costs
relies
primarily
on
data
from
the
economic
model,
which
present
impacts
at
the
level
of
a
large
county.
The
economic
model
is
not
designed
to
address
rural
areas
with
small
populations,
or
Indian
tribes,
and
its
output
has
limited
utility
at
best
in
assessing
impacts
for
these
groups.

The
Commission's
equity
concerns
include
addressing
the
following
questions:
Are
the
sources
causing
the
problem
paying
for/
contributing
fairly
to
the
solution?
Are
sources
causing
the
problem
paying
for
the
solution
in
proportion
to
their
current
contribution
and
current
control
levels?
The
Commission's
formal
assessments
have
not
analyzed
whether
some
income
groups
will
be
affected
more
than
others
or
whether
there
are
ethnic
patterns
to
the
outcomes
of
the
recommendations.
These
issues
are
of
particular
concern
to
areas
which
are
relatively
underdeveloped
within
the
Transport
Region.

With
respect
to
equity
for
rural
and
underdeveloped
areas,
including
most
tribal
lands,
it
is
important
to
note
that
such
areas
have
not
contributed
significantly
to
the
regional
haze
problem.
One
method
for
measuring
equity
is
to
ensure
that
all
groups
contribute
fairly
to
solutions,
relative
to
their
role
as
an
emissions
source
and
their
economic
position
(
that
is,
in
proportion
to
the
ability
to
pay).
92
While
the
Commission
has
sought
to
distribute
the
burden
of
its
recommendation
equitably,
inadequacies
in
the
primary
and
secondary
assessment
process
(
e.
g.,
lack
of
emissions
data
for
tribal
lands,
inability
of
the
economic
model
to
analyze
areas
smaller
than
a
county,
and
lack
of
tribal
data
inputs
to
economic
modeling)
require
continued
vigilance
to
guarantee
strong
application
of
the
equity
criterion
in
all
implementation
plans
and
in
monitoring
the
impacts
of
the
Commission's
recommendations.

With
these
limitations
in
mind,
the
Commission
offers
its
perspective
on
the
so­
called
"
secondary"
impacts
associated
with
its
recommendations.

Tourism.
One
issue
relevant
to
all
the
Commission's
recommendations
is
tourism
in
the
region.
Research
conducted
for
the
Commission
shows
that
national
parks
in
the
West
are
important
contributors
to
the
economy
as
well
as
the
quality
of
life.
National
parks
in
the
study
generated
over
100,000
jobs
and
almost
$
5
billion
in
gross
regional
product
in
1994.
Most
park
visitors
come
to
enjoy
the
scenery.
Any
noticeable
impairment
of
visibility
could
significantly
affect
park
visits
and,
as
a
result,
the
regional
economy.
However,
there
currently
are
no
studies
that
assess
the
link
between
air
quality
and
park
visits,
so
stronger
conclusions
cannot
be
drawn.

Air
Pollution
Prevention.
The
Commission's
recommendations
concerning
air
pollution
prevention
illustrate
the
limitations
of
projecting
effects
at
this
time.
The
recommendations
themselves
are
general
in
nature.
Because
they
were
not
modeled,
there
presently
is
no
information
about
the
costs
and
benefits.
Nevertheless,
there
is
reason
to
believe
that
promoting
alternative
energy
sources
would
have
some
economic
benefits,
in
the
form
of
increased
investment
in
alternative
technologies
and
increased
employment
in
the
alternative
technology
sector.
Some
Indian
tribes
have
invested
significant
resources
in
this
area,
and
could
benefit
economically
from
expansion
of
alternative
energy
technologies
and
creation
of
incentives
for
their
use.
To
the
extent
there
are
economic
benefits
to
Indian
tribes
investing
in
these
technologies,
it
is
reasonable
to
expect
some
social
benefits.
"
Clean"
technologies
would
likely
have
an
overall
positive
impact
on
the
environment
of
the
region.
However,
a
more
specific
conclusion
would
require
knowledge
of
the
specific
technologies
under
consideration.

Stationary
Sources.
Turning
to
the
recommendations
about
stationary
sources,
there
are
some
important
concerns.
Under
a
regional
cap/
trading
program,
there
are
fundamental
questions
about
how
initial
credits
will
be
allocated
and
how
reductions
would
be
timed.
If
credits
are
allocated
simply
on
the
basis
of
historical
emissions,
there
are
potential
equity
issues
for
new
emissions
sources.
This
concern
has
been
raised
specifically
by
Indian
tribes.
There
also
are
significant
equity
and
other
issues
about
how
such
a
program
affects
sub­
regions
where
companies
may
sell
their
credits
and
move
away,
or
conversely
how
it
would
affect
areas
where
industries
that
acquire
pollution
credits
are
located.
93
Mobile
Sources.
To
the
extent
that
national
strategies,
such
as
the
49­
state
LEV
or
low
sulfur
fuels,
are
adopted,
the
average
costs
of
implementation
will
decrease
because
they
are
spread
over
a
large
area
and
population.

The
Commission
is
aware
of
the
potential
equity
impacts
associated
with
some
of
its
mobile
source
recommendations.
One
example
is
retiring
high­
emitting
vehicles.
These
vehicles
tend
to
be
owned
by
persons
without
the
economic
means
to
acquire
newer,
low­
emitting
vehicles.
This
recommendation
also
poses
potential
equity
issues
for
Indian
tribes.
Another
example
is
enhanced
inspection
and
maintenance
programs.
These
can
have
differential
impacts
on
lower
income
groups,
and
raise
equity
concerns.

Area
Sources/
Fire.
The
use
of
prescribed
fire
has
clear
significance
for
the
health
of
ecosystems
throughout
the
West.
A
better
understanding
of
fire's
role
in
ecosystem
health
underlies
the
recommendation
supporting
the
increased
use
of
prescribed
fire,
along
with
smoke
management
techniques.
In
the
long
run,
this
recommendation
will
result
in
environmental
benefits
in
the
Transport
Region.

Mechanical
treatment
will
be
labor­
intensive
and
may
provide
significant
employment
opportunities.
Substantial
subsidies
may
be
required
for
some
use
of
the
biomass
resulting
from
mechanical
treatment
programs.
Biomass
utilization
may
be
possible
in
some
energy
markets,
and
the
development
of
other
woody
material
markets
is
also
possible.

There
are
social
and
equity
issues
associated
with
fire
policy.
One
of
these
involves
Indian
tribes
that
conduct
their
own
timber,
agriculture,
and
habitat
management
operations.
Any
policy
that
restricts
the
ability
of
these
tribes
to
develop
these
operations
could
have
an
impact
disproportionate
to
that
felt
by
other
groups,
such
as
federal
land
managers.
This
issue
is
discussed
further
in
the
section
on
"
Tribal
Perspectives."

Emissions
Within
and
Near
Class
I
Areas.
The
Commission's
recommendations
are
likely
to
affect
communities
located
"
within
and
near"
Class
I
areas.
These
could
be
major
urban
centers,
smaller
rural
communities,
or
Indian
tribes.
One
potential
emissions
source
in
these
communities
is
unpaved
roads.
Measures
to
reduce
dust
could
have
disproportionate
impacts
on
these
communities,
and
on
groups
within
each
community.
Paving
roads
can
increase
use,
thereby
causing
a
range
of
economic
and
social
impacts.
Depending
on
who
paid
to
pave
roads,
there
could
be
significant
equity
impacts
as
well.
Pollutant
"
plumes"
from
urban
areas
also
raise
equity
issues
involving
who
should
bear
the
cost
of
addressing
mobile
and
area
source
emissions
that
are
part
of
these
plumes.
94
Transboundary
Emissions.
Communities
located
close
to
the
border
may
be
bearing
a
disproportionate
share
of
the
impact
from
transborder
emissions.
These
same
communities
probably
would
reap
the
greatest
benefit
from
emissions
reductions,
but
may
be
unable
to
contribute
financially
to
emission
reduction
strategies.
This
issue
is
also
addressed
in
the
section
on
"
Tribal
Perspectives."
