Attachment
C.
Demonstration
that
the
SO,
Milestones
Provide
Greater
Reasonable
Progress
than
BART
A.
BackFround
On
July
1,
1999
the
Environmental
Protection
Agency
(
EPA)
published
regulations
to
address
regional
haze
visibility
impairment.
The
new
regulations
require
States
to
address
Best
Available
Retrofit
Technology
(
BART)
requirements
for
regional
haze
visibility
impairment.
The
nine
Grand
Canyon
Visibility
Transport
Region
States
have
the
option
to
address
this
requirement
as
part
of
an
overall
strategy
of
emission
reductions
developed
by
the
Grand
Canyon
Commission,
including
the
establishment
of
regional
sulfur
dioxide
(
S02)
milestones.

§
309(
f)(
l)(
I)
of
the
regional
haze
rule
establishes
the
requirements
for
regional
milestones
to
meet
the
stationary
source
obligations
for
the
first
long­
term
planning
period.
The
rule
states,
 
The
emission
reduction
milestones
must
be
shown
to
provide
for
greater
reasonable
progress
than
would
be
achieved
by
application
of
best
available
retrofit
technology
(
BART)
pursuant
to
section
51.308(
e)(
2)
and
would
be
approvable
in
lieu
of
BART. 
The
requirements
for
BART
are
described
in
greater
detail
in
section
51.308(
e)(
2)
as
follows:

 
A
State
may
opt
to
implement
an
emissions
trading
program
or
other
alternative
measure
rather
than
to
require
sources
subject
to
BART
to
install,
operate,
and
maintain
BART.
To
do
so,
the
State
must
demonstrate
that
this
emissions
trading
program
or
other
alternative
measure
will
achieve
greater
reasonable
progress
than
would
be
achieved
through
the
installation
and
operation
of
BART.
To
make
this
demonstration,
the
State
must
submit
an
implementation
plan
containing
the
following
plan
elements
and
include
documentation
for
all
required
analyses:

(
I)
A
demonstration
that
the
emissions
trading
program
or
other
alternative
measure
will
achieve
greater
reasonable
progress
than
would
have
resulted
fiom
the
installation
and
operation
of
BART
at
all
sources
subject
to
BART
in
the
State.
This
demonstration
must
be
based
on
the
following:

(
A)
A
list
of
all
BART­
eligible
sources
within
the
State.

(
B)
An
analysis
of
the
best
system
of
continuous
emission
control
technology
available
and
associated
emission
reductions
achievable
for
each
source
within
the
State
subject
to
BART.
In
this
analysis,
the
State
must
take
into
consideration
the
technology
available,
the
costs
of
compliance,
the
energy
and
nonair
quality
environmental
impacts
of
compliance,
any
pollution
control
equipment
in
use
at
the
source,
and
the
remaining
useful
life
of
the
source.
The
best
system
of
continuous
emission
control
technology
and
the
above
factors
may
be
determined
on
a
source
category
basis.
The
State
may
elect
to
consider
both
source­
specific
and
category­
wide
information,
as
appropriate,
in
conducting
its
analysis.

(
C)
An
analysis
of
the
degree
of
visibility
improvement
that
would
be
achieved
in
each
mandatory
Class
I
Federal
area
as
a
result
of
the
emission
reductions
achievable
fkom
all
such
sources
subject
to
BART
located
within
the
region
that
contributes
to
visibility
impairment
in
the
Class
I
area,
based
on
the
analysis
conducted
under
section
51.308(
e)(
2)(
I)(
B). 

In
order
to
address
these
BART
requirements,
the
WRAP
used
the
following
process:

Develop
a
list
of
BART­
eligible
sources
for
the
region.
0
Estimate
emission
reductions
that
could
be
made
by
BART­
eligible
sources
through
 
appropriate
retrofit
technology .
#
Estimate
baseline
emissions
in
the
year
2018.
a
Evaluate
the
visibility
improvement
that
could
occur
in
the
region
if
the
 
appropriate
retrofit
technology 
emission
reductions
were
implemented.
#
Evaluate
additional
factors
that
would
contribute
to
 
greater
reasonable
progress 
than
regional
haze
BART
0
Establish
2018
SO,
emissions
milestone
Each
of
these
steps
is
addressed
in
greater
detail
in
the
following
sections
of
this
report.
This
process
was
developed
through
the
best
efforts
of
the
WRAP
through
a
stakeholder
based
process
and
is
based
on
the
WRAP Sreading
of
the
regional
haze
rule
language
and
preamble.
It
is
important
to
note
that
EPA
guidance
for
determining
regional
haze
BART
is
under
development
and
so
the
WRAP
had
to
make
a
number
of
assumptions
about
the
analysis.

B.
List
of
BART­
eligible
sources.

Each
of
the
nine
Transport
Region
States
developed
a
preliminary
list
of
BART­
eligible
sources
for
SO,.
EPA
identified
BART­
eligible
sources
on
tribal
lands.
EPA
guidance
for
regional
haze
BART
is
still
under
development
which
leaves
many
unanswered
applicability
questions.
The
WRAP
developed
a
draft
methodology
that
was
used
to
identify
all
of
the
BART­
eligible
sources
in
the
region.
When
final
guidance
is
issued,
the
Transport
Region
States
and
Tribes
recognize
that
changes
to
their
initial
lists
of
BART­
eligible
sources
may
be
necessary,
however
the
WRAP
believes
that
all
sources
that
emit
significant
levels
of
SO,
have
been
identified.
The
preliminary
list
compiled
by
the
states
is
included
as
Attachment
D
to
the
Annex.
The
draft
methodology
used
the
following
assumptions:

0
Where
appropriate,
BART­
eligible
sources
were
identified
on
a
unit­
by­
unit
basis.
Only
individual
units
that
met
the
BART
criteria
were
included
on
the
list.
For
e­
2
? 

a.

?

i
Q
01
r;]
l
some
sources,
such
as
copper
smelters,
this
approach
did
not
work
because
the
units
were
so
inter­
related.
In
those
cases
the
entire
source
was
examined
to
determine
if
it
was
BART­
eligible.
Pollutants
were
treated
independently.
Therefore,
only
units
that
qualified
as
BART­
eligible
for
SO,
were
included
on
the
list.
Modifications
during
the
15­
yearBART
wiqdow
were
not
considered,
unless
the
modification
qualified
as
reconstruction
for
that
unit.
Units
were
not
considered
BART­
eligible
if
the
only
modification
that
was
made
during
the
15­
year
window
was
the
installation
of
pollution
control
equipment.
BART­
eligible
sources
that
had,
were
in
the
process
of,
or
were
slated
to
have­
new
emissions
controls
installed
(
Navajo
Generating
Station,
Page,
Arizona;
Hayden
Generating
Station,
Hayden,
Colorado;
Mojave
Generating
Station,
Laughlin,
Nevada)
were
not
included
in
the
spreadsheet
that
was
used
to
calculate
the
BART
level
emission
reductions.
In
addition,
BART­
eligible
sources
that
will
be
controlled
as
part
of
the
voluntary
reductions
for
the
Front
Range
power
plants
in
Colorado
were
not
included
in
the
spreadsheet
(
Cherokee
Generating
Station
in
Denver
and
Valmont
Generating
Station
in
Boulder).
Emission
reductions
fiom
these
sources
were
treated
as
downward
adjustments
to
the
baseline.

B
C.
Appropriate
Retrofit
Technology
Estimates
The
next
step
in
the
process
was
the
identification
of
appropriate
retrofit
technologies
for
the
BART­
eligible
sources.
BART
has
traditionally
been
developed
through
a
case­
by­
case
analysis
that
considers
the
unique
situation
of
the
source,
including
costs
and
the
impacts
that
the
source
has
on
a
particular
mandatory
Class
I
area.
As
provided
in
the
following
passage,
the
regional
haze
rule
provides
flexibility
to
states
in
developing,
for
comparative
purposes,
a
method
for
calculating
the
emission
reductions
that
would
result
fkom
the
installation
of
source­
specific
BART:

To
compare
the
emissions
reductions
and
visibility
improvement
that
would
result
fkom
the
application
of
source
specific
BART
to
that
resulting
from
implementation
of
alternative
measures,
such
as
a
regional
emissions
trading
program,
the
state
must
estimate
the
emissions
reductions
that
would
result
from
the
use
of
BART­
level
controls.
To
do
this,
the
states
could
undertake
a
source
specific
review
of
the
sources
in
the
state
subject
to
BART
or
it
could
use
a
modified
approach
that
simplifies
analysis...
the
states
accordinglyhave
flexibilityin
developing
a
method
to
determine
the
emissions
reductions
that
could
be
achieved
through
the
application
of
BART.'

The
WRAP
recognized
that
a
case­
by­
case
analysis
of
potential
controls
for
each
of
the
BART­
eligible
sources
in
the
region
would
be
very
resource
intensive
and
require
more
time
than
allotted
for
the
development
of
the
Annex.
Because
the
goal
was
to
use
these
estimates
to
1
40
CFR
part
51,
page
35742
(
July
1,1999).

c­
3
\
establish
a
regional
emission
cap,
the
individual
BART
reductions
were
less
important
than
the
overall
regional
number.
The
WRAP
therefore
approached
the
analysis
at
the
regional
level,
using
a
more
simplified
analysis,
as
provided
for
in
the
regional
haze
rule.

The
WRAP
used
the
following
assumptions
to
estimate
the
regional
emission
reductions
due
to
appropriate
retrofit
controls
on
the
BART­
eligible
sources
in
the
region.
It
should
be
noted
that
the
WRAP
methodology
was
only
used
to
obtain
a
regional
estimate
for
BART­
level
emission
reductions
to
calculate
the
2018
milestone.
It
was
not
intended
to
be
a
source­
by­
source
BART
analysis.

c]
r
Appropriate
retrofit
technologies
were
estimated
for
source
categories
rather
than
individual
sources.
a
Emission
reductions
were
estimated
at
the
regional
level.
a
All
estimates
of
the
level
of
control
constitute
an
assumed
average
for
that
industry
sector
in
the
WRAP
region.
a
The
BART
factors,
including
cost,
energy
and
non­
air
environmental
impact,
existing
pollution
controls,
and
remaining
usell
life
were
addressed
in
a
broad
way
through
the
identification
of
technologies
that
were
currently
being
used
as
retrofits
in
the
region.
Some
consideration
of
the
techmcal
feasibility
of
installing
control
equipment
at
particular
sources
(
site
constraints,
special
conditions,
etc.)
was
considered.
However,
a
comprehensive
analysis
was
not
completed
for
individual
sources.
Instead,
the
MTF
looked
at
ranges
of
potential
retrofit
controls
and
established
a
level
that
was
expected
to
be
valid
as
a
regional
average.

Table
1
outlines
the
estimated
appropriate
retrofit
technology
for
specific
source
categories
in
the
region.

c­
4
Source
Category
Copper
Smelters
Refineries
Lime
Plants
and
Cement
Kilns
Utility
Boilers
Industrial
Boilers
Pulp
and
Paper
TABLE
1
Retrofit
Technologies
or
Percentage
Reduction
Due
to
the
uniqueness
of
the
existing
smelters,
retrofit
technology
analysis
must
be
performed
on
a
smelter­
by­
smelter
basis.
Currently,
the
Hidalgo
smelter
is
the
only
BART­
eligible
source
on
the
list
in
this
category.
A
double­
contact
acid
plat
will
be
considered
the
appropriateretrofit
control
equipment
(
all
smeltersin
the
region
are
currently
equipped
with
double­
contact
acid
plants).
On
August
2
1,2000
New
Mexico
completed
anengineeringanalysis
that
verified
earlier
determinations
by
the
MTF
that
the
fhgitive
SO,
capture
system
at
Hidalgo
satisfiesBART
at
96%
overall
capture.

There
are
three
sources
of
SO,
emissions
at
the
refiery
level:

Descriution
Assumed
Average
Control
Level
SRU
(
pollution
control
for
fuel
98%
control
or
the
equivalent
of
3­
stage
Claus
gas
combustion
units)
units
(
most
already
have
th~
sin
place).

Catalytic
crackers
90%
control.
States
will
query
these
sources
as
to
whether
or
not
they
have
had
to
comply
with
subpart
J
with
low
sulh
catalyst
or
hydro­
treating,
which
would
amount
to
90%
control.
If
not
already
subject
to
part
J,
then
90%
control
will
be
required.

Flares
no
additionalcontrols
0
(
Approximately
70%
of
refinery
emissions
come
from
Claus
unit,
25%
from
cat
crackers
if
uncontrolled,
and
remaining
5%
from
all
other
sources)

No
additional
reduction.
Approximately
50%
control
inherent
in
the
process.
Additional
SO,
controls
are
not
typically
applied
tO
these
kinds
of
sources.

Technology
determination
dependent
upon
current
level
of
control.

Descrintion
Assumed
Average
Level
of
Control
Uncontrolled
units
85%
Units
controlled
at
less
than
70%
Treat
as
uncontrolled(
see
above).
Units
controlled
between
70430%
Increase
reductionsby
5%
(
i.
e.,
if
a
unit
is
at
72%,
would
be
assumed
to
control
to
77%).
Units
controlled
greater
than
80%
No
additionalreductions.

Same
as
utility
boilers.

Sulk
sources
are
recovery
furnaces
and
boilers.
Boiler
discussions
covered
with
industrial
boilers.
Recovery
furnaces:
No
additional
reduction.
Low
emissionscoupled
withlack
of
more
than
one
example
of
scrubbing.

c­
5
The
technology
assumptions
listed
above
were
incorporated
into
a
spreadsheet
(
Allstat7.
xls)
to
estimate
the
regional
emission
reductions
due
to
appropriate
retrofit
technologies.
The
spreadsheet
used
the
following
assumptions:

#
Existing
utility
generating
units
operating
at
an
average
capacity
factor
of
less
than
85%
of
nameplate
capacity
during
1999were
assumed
to
increase
their
capacity
factor
to
a
maximum
level
of
85%
of
nameplate
capacity
by
2018.
Utility
units
operating
at
a
capacity
factor
higher
than
85%
during
1999
were
assumed
to
continue
operating
at
that
level.
#
All
other
source
categories
were
assumed
to
continue
operating
at
their
current
level
of
actual
emissions,
based
on
an
average
of
1996­
1998
emissions.
#
The
BART­
eligible
units
were
assumed
to
reduce
actual
emissions
by
the
applying
the
control
efficiency
listed
in
Table
1
for
each
specific
source
category.
c1
The
total
emission
reductions
were
then
added
to
obtain
a
regional
estimate.
The
individual
source
estimates
were
only
calculated
as
part
of
the
regional
estimate,
and
are
not
intended
to
be
used
as
a
BART
estimate
for
those
individual
sources.

The
analysis
described
above
led
to
an
estimated
emission
reduction
of
168,176
tons
SO,
due
to
the
application
of
appropriate
control
technologies.
For
the
purposes
of
this
discussion,
this
number
will
be
rounded
to
168,000
tons.

D.
Baseline
Inventory
for
2018
As
part
of
the
process
of
developing
the
end­
point
for
this
program,
an
inventory
of
expected
actual
emissions
in
2018
was
estimatec!.
The
baseline
inventory
was
calculated
separately
for
utilities
and
non­
utilities
using
the
following
methods
and
assumptions:

1.
Utilities.
1999
emissions
data
that
were
submitted
to
EPA
for
the
acid
rain
program
were
used
as
the
base
inventory
for
the
utility
projections
to
2018.
In
addition,
data
for
several
small
power
plants
that
were
not
in
the
acid
rain
data
base
were
added
to
the
inventory
list.
The
1999
inventory
was
then
grown
to
account
for
increased
capacity
utilization
as
described
below.
Known
emission
reductions
that
have
already
been
agreed
to
by
the
Public
Service
Company
of
Colorado
(
a
number
of
power
plants
along
the
Front
Range
that
will
be
controlled
in
2003)
and
by
the
Mojave
Generating
Station
in
Nevada
(
controls
will
be
installed
by
2006)
were
subtracted
from
the
emission
projections.

a.
Capacity
Factor.
Western
utilities
are
increasing
their
utilization
to
meet
increasing
electricity
demand.
In
addition,
deregulation
of
the
power
industry
is
expected
to
further
increase
utilization
of
existing
plants
because
it
will
be
more
cost­
effective
to
achieve
peak
performance
from
existing
plants
than
to
expend
the
capital
to
build
new
plants.
Even
though
utilization
is
increasing,
it
is
not
C­
6
realistic
to
estimate
that
plants
will
consistently
operate
at
100%
capacity
because
units
will
require
maintenance
throughout
the
year.
In
addition,
power
demand
fluctuatesthroughout
the
year,
and
full
utilization
may
not
be
needed
every
day
of
the
year.

The
WRAP
has
assumed
that
all
coal
fired
power
plants
in
the
west
will
be
operating
at
an
average
of
85%
of
nameplate
capacity
in
the
year
2018.
Any
new
growth
in
demand,
beyond
this
capacity
factor
assumption,
is
assumed
to
be
met
by
new
power
generation
at
an
approximate
control
efficiencyof
98%
for
SO,.

b.
Retirement
Adjustment
for
Colorado
Front
Range
Power
Plants.
Public
Service
Company
of
Colorado
(
PSCO)
has
made
a
voluntary
agreement
with
the
State
of
Colorado
to
control
a
number
of
Front
Range
power
plants
by
the
year
2003.
Several
of
the
plants
that
will
install
controls
are
assumed
to
retire
before
the
year
2018
according
to
the
assumptions
of
the
model.
It
is
no
longer
realistic
to
assume
that
these
plants
will
retire,
because
the
capital
investment
in
the
plants
will
extend
their
lifetime.
Therefore,
a
4,000
ton
adjustment
was
made
to
the
inventory
to
account
 or
the
continued
operation
of
these
plants.

2.
Co­
generation
Facilities.
1998
inventory
data
provided
by
the
nine
transport
region
states
were
used
as
the
base
inventory
for
future
year
projections.
It
was
assumed
that
emissions
from
these
sources
would
remain
constant
through
the
year
2018
(
no
growth
or
retirements
would
occur).

3.
Smelters.
1998inventory
data
provided
by
the
nine
transport
region
states
were
used
as
the
base
inventory
for
fbture
year
projections.
There
are
two
smelters
that
were
operating
in
1998
that
have
temporarily
suspended
operations
due
to
economic
conditions.
For
this
reason,
the
inventory
was
projected
both
with
these
smelters
in
operation,
and
without.
The
milestones
developed
by
the
WRAP
contain
provisions
for
an
automatic
adjustment
if
one
or
both
of
the
smelters
come
back
on
line.
The
2018
inventory
for
smelters
in
the
region
if
neither
smelter
resumes
operation
is
assumed
to
be
48,000
tons.
This
inventory
number
assumes
that
emissions
fkom
smelters
would
remain
constant
(
no
growth
or
retirements
would
occur).
The
2018
inventory
if
both
smelters
resume
operation
is
assumed
to
be
78,000
tons.
This
estimate
assumes
that
there
will
be
additional
retirement
of
emissions
fkom
the
smelter
sector,
equivalent
to
the
estimates
made
by
the
Integrated
Assessment
System
(
IAS)
used
by
the
Grand
Canyon
Visibility
Transport
Commission
for
the
year
2020.

4.
Olther
sources.
1998
inventory
data
provided
by
the
nine
transport
region
states
were
used
as
the
base
inventory
for
kture
year
projections.
The
growth
and
retirement
assumptions
developed
for
the
IASwere
used
to
project
these
emissions
to
the
year
2018.
The
IAS
did
not
assume
any
increase
in
capacity
for
existing
sources,
instead,
their
emissions
were
retired
at
a
set
percentage
per
year.
Any
increase
in
demand
for
the
c­
7
­­
%

hr­*&
&+&'
hLfl+
A
d$&
a,.&*

sector's
product,
as
predicted
by
the
REMI
economic
model,
was
assumed
to
be
met
by
new
sources,
operatbg
at
a
controlled
emission
rate.
The
growth
and
retirement
rates,
as
well
as
the
control
efficiency
for
new
sources,
vary
between
sectors.

5.
2018
Baseline
Inventory
of
Projected
Actual
Emissions
(
rounded
to
nearest
1,000)
?
?

&.
AN
­
a\
4
Jh
'
i
LJ=­
Utility
Emissions
421,000*
r+
L
Front
Range
Retirement
Adjustment
4,000
+

iLJ&
L'i@*
imp
Co­
Gen
Units
8,000
4L.
M~
dJ
\
rc
,4n­'"\~
Smelter
Emissions
48,000
,
a\*
JdVI
bd*
Other
Source
Emissions
141.000
622,000
n/
sJz
:
e
G­­­
lD.
2018
Inventory
with
Estimated
Emission
Reductions.
The
emission
reductions
estimated
i
for
appropriate
control
technologies
applied
to
BART­
eligible
sources
were
then
subtracted
from
5@
the
2018
baseline.

1.
CEMs
Bias.
The
federal
acid
rain
program
requires
coal­
fired
utilities
to
monitor
SO,
emissions
using
continuous
emission
monitors
(
CEMs).
These
monitors
measure
SO,
concentration
at
a
point
in
the
stack,
and
also
measure
the
volume
of
the
gas
stream
passing
through
the
stack.
The
combination
of
the
two
measurements
provides
total
mass
emissions
from
the
stack
in
tondyear.
Prior
to
the
use
of
CEMs,
utilities
calculated
their
emissions
using
a
mass­
balance
methodology.
The
sulfur
content
of
the
coal
was
measured,
and
then
total
SO,
emissions
were
determined
by
tracking
the
amount
of
coal
burned.

Two
sources
of
bias
result
in
8n
over­
estimation
of
emissions
as
compared
to
a
mass­
balance
estimation.

a
If
two­
dimensional
probes
are
used
to
measure
the
volume
of
gas
passing
through
the
stack,
gas
volume
will,
on
average,
be
over­
estimated.

4.

#
If
a
CEMS
malfunctions,
the
rules
require
the
use
of
a
high­
bias
estimate
in
the
place
of
missing
data.

The
bias
varies
from
plant
to
plant
depending
on
the
specific
configuration
of
the
stack,
and
other
variables.
:

In
mid­
1999,
EPA
published
a
new
flow
measurement
technique
that
could
be
used
for
CEMs
under
the
acid
rain
program.
This
new
technique
is
voluntary,
and
it
is
not
known
how
many
sources
will
install
the
equipment
(
it
is
significantly
more
expensive
than
the
existing
equipment).
The
new
flow
measurement
technique
is
expected
to
reduce
the
CEM
bias,
but
bias
will
never
be
completely
eliminated
because
of
the
way
emissions
are
I­

C­
s
?
required
to
be
counted
when
data
are
missing.

The
WRAP
recognized
that
current
CEM
measurements
are
biased
high,
and
that
compliance
measurements
to
future
milestones
will
be
made
with
CEMs
that
have
less
bias
than
those
that
were
in
use
in
the
1999
base
inventory
that
was
used
for
projecting
future
utility
emissions.
However,
it
is
difficult
to
estimate
how
many
sources
will
install
the
new
measurement
devices,
and
how
much
CEM
bias
will
still
remain
after
these
changes.
Utility
emissions
in
the
yeas
2018
are
predicted
to
be
approximately
269,000
tons
(
afier
the
emission
reductions
due
to
appropriate
control
technology
applied
to
BART­
eligible
sources).
Therefore
the
WRAP
assumed
an
adjustment
of
10,000
tons
to
account
for
the
CEMs
bias.

The
WRAP
also
acknowledges
thatCEMs
are
the
 
gold
standard 
for
determining
compliance
with
the
federal
Acid
Rain
Program
requirements.
A
protocol
will
be
developed
to
make
appropriate
adjustments
to
the
operation
of
this
component
of
the
regional
haze
program
for
participating
states
and
Tribes
as
improvements
in
CEMs
technology
and
procedures
are
implemented.
This
protocol
is
necessary
to
prevent
a
system
of
dual
book­
keeping
and
to
maintain
the
integrity
of
compliance
with
both
the
federal
Acid
Rain
Program
and
this
proposed
backstop
cap­
and­
trade
program.
The
CEPvIs
adjustment
protocol
is
discussed
in
more
detail
in
the
Annex.

2.
Operational
headroom
and
uncertainty.
The
GCVTC
agreements
and
recommendations
contain
two
tenets
that
have
uniquely
informed
the
establishment
of
operational
headroom
and
uncertainty
under
the
market
trading
program.
First,
the
Commission
recommended
that
the
market
trading
program
 
contain
specific
provisions
to
encourage
and
reward
early
emission
reductions,
including
reductions
achieved
before
2000. 
2
The
GCVTC
committed
to
achieve
a
13%
reduction
in
SO2
emissions
fiom
stationary
sources
by
the
year
2000.
The
GCVTC
also
recognized
that
there
was
a
good
possibility
that
actual
emission
reductions
would
be
greater
than
this
13%
goal.
A
general
plan
was
derived
to
give
some
early
reductions
credit
to
the
region
and
some
to
the
environment.
The
emission
reductions
that
were
greater
than
13%
were
to
be
split,
with
?
4going
to
the
environment
(
through
the
establishment
of
milestones)
and
the
other
?
4prloviding
headr~
om.~

The
 
WRAP
currently
expects
that
emissions
in
the
region
will
show
greater
reductions
than
the
13%
commitment
of
the
GCVTC.
The
WRAP
has
sought
to
preserve
the
Comission s
approach
to
early
reductions
by
setting
aside
as
headroom
some
intermediate
portion
of
the
expected
reductions
in
excess
of
13%.

 
Recommendations
for
Improving
Western
Vistas
at
33
(
June
1996)
(
emphasis
added).

c­
9
I
Second,
the
Commission
recommended
allocations
to
tribes
that
are
of
practical
benefit.'
This
recognized
the
concern
that
"
tribes,
by
and
large,
have
not
contributed
to
the
visibility
problem
in
the
region"
and
that
"[
tlribal
economies
are
much
less
developed
than
those
of
states,
and
tribes
must
have
the
opportunity
to
progress
to
reach
some
degree
of
parity
with
states
in
this
regard.'
I5
The
tribes
specifically
recommended
that
if
an
emission
trading
strategy
is
adopted
to
achieve
SO2
reductions
fi­
om
stationary
sources
that
allocations
be
based
on
considerations
of
equity
rather
than
historical
emissions:

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.
6
Accordingly,
the
market
trading
program
proposed
by
the
WRAP
contains
a
20,000
allocation
to
tribes.

These
two
considerations
­
to
reward
emission
reductions
occurring
between
1990
and
2000,
and
to
provide
an
equitable
allocation
to
the
tribes
­
originate
from
the
GCVTC
recommendations.
They
reff
ect
distinct
policy
concerns
of
the
Commission
that
are
unique
to
the
program
under
section
309
of
the
regional
haze
rule
incorporating
the
Commission's
recommendations.

In
addition,
because
the
baseline
emissions
inventory
is
a
projection
of
actual
emissions,
uncertainty
exists
in
the
projection
method
including,
for
example,
fluctuations
in
weather
and
changing
economic
conditions.

There
are
inherent
uncertainties
in
the
inventory
calculation
that
need
to
be
recognized.

Inherent
measurement
uncertainties.
CEMs
are
calibrated
daily
to
a
relative
accuracy
of
20%
using
calibration
gases.
Fluctuations
in
measurements
can
occur
due
to
the
measurement
techniques
that
are
not
indicative
of
actual
changes
in
emissions.
Pluses
and
minuses
will
cancel
out
to
a
certain
degree,
but
some
consideration
of
these
fluctuations
is
needed.

Projections.
Projections
of
future
"
actual"
emissions
are
based
on
the
best
information
available,
but
are
inherently
uncertain.
This
uncertainty
increases
further
out
in
time.
Growth
rates
may
be
underestimated,
impacts
of
new
'
Id.
at
35.

51d.
at
66­
67.

'
Id.
at
71.
3
c­
10
technologies
or
regulatory
requirements
may
have
unexpected
effects,
etc.

The
WRAP
recognizes
that
there
are
some
competing
uncertainties
that
the
future
"
actual"
emissions
may
be
over­
predicted.
However,
in
light
of
the
Commission's
specific
recommendation
to
reward
early
reductions
occurring
between
1990
and
2000,
the
WRAP
specifically
set
aside
15,000tons
in
2018
for
uncertaintyheadroom
in
addition
to
the
allocation
described
above
for
tribes.
The
15,000
tons
represents
2%
of
the
current
SO2
emissions
inventory
(
652,000
tons)^
encompassedwithin
the
trading
program.

The
WRAP
also
believes
the
likelihood
exists
that
the
hll
complement
of
emissions
set
aside
for
uncertainty
and
headroom
will
not
be
utilized.
All
sources
in
the
region
operate
below
their
allowable
emissions
to
ensure
that
they
are
in
compliance
with
emission
limits.
The
regional
milestones
are
comparable
to
allowable
emissions
because
an
exceedance
of
the
milestone
will
trigger
regulatory
consequences.
Individual
sources
will
be
tracking
their
emissions,
as
well
as
the
overall
regional
emissions,
and
the
possibility
of
avoiding
a
regulatory
program
will
provide
a
powerful
incentive
for
sources
to
keep
emissions
below
the
cap,
This
will
also
provide
a
disincentive
for
keeping
regional
emissions
close
to
the
cap,
because
that
will
increase
the
risk
that
an
unexpected
event
(
such
as
increased
production
fkom
one
sector)
will
trigger
the
regulatory
program.
The
incentive
to
operate
below
the
cap
should
be
especially
powerful
in
2018
when
individual
sources
will
face
penalties
if
the
cap
is
exceeded
and
a
source
has
emitted
SO2
in
excess
of
its
allowances.

3.
2018
SO,
Milestone
Calculation
2018
Baseline
622,000
Appropriate
Technology
Emission
Reductions
­
168,000
CEM
Bias
adjustment
­
10,000
Uncertainty/
Headroom
35.000
Total
479,000
=
480,000
In
thie
event
the
suspended
smelters
commence
operation
or
the
production
from
those
facilities
is
shifted
to
other
smelters,
as
much
as
30,000
tons
may
be
added
to
this
milestone.

c­
11
1
E.
Visibility
Improvement
Section
169A
of
the
Clean
Air
Act
lists
a
number
of
factors
that
must
be
considered
as
part
of
the
BART
determination.
These
factors
are
addressed
in
the
regronal
haze
rule
in
a
two­
step
process.
First,
an
analysis
of
the
best
system
of
continuous
emission
control
technology
available
is
performed,
considering
the
statutory
factors
of
cost
of
compliance,
the
energy
and
non­
air
quality
environmental
impacts
of
compliance,
any
pollution
control
equipment
in
use
at
the
source,
and
the
remaining
useful
life
of
the
source.
Second,
an
analysis
of
the
degree
of
visibility
improvement
that
would
be
achieved
in
each
mandatory
Class
I
federal
area
as
a
result
of
the
emission
reductions
achievable
from
all
sources
subject
to
BART
located
within
the
region.
The
preamble
to
the
regional
haze
rule
indicates
that
the
visibility
analysis
should
be
conducted
using
the
cumulative
emission
reductions
fkom
all
BART­
eligible
sources
in
the
transport
region,
not
the
impact
of
individual
sources.
The
preamble
also
indicates
that
the
States
and
Tribes
should
use
this
estimated
degree
of
visibility
improvement
in
determining
the
appropriate
BART
emission
limitations
for
specific
sou~
ces.~

When
defining
the
visibility
impact,
the
regional
haze
rule
identifies
the
deciview
metric
as
the
appropriate
measure
of
visibility
impairment,
and
improvement.
The
regional
haze
rule
preamble
discusses
the
value
of
measuring
visibility
using
a
metric
that
takes
into
account
both
measurement
of
physical
changes
(
i.
e.,
changes
in
air
quality)
and
human
perception.'
A
one
deciview
change
in
haziness
is
a
small
but
noticeable
change
in
haziness
under
most
circumstances
when
viewing
scenes
in
Mandatory
Class
I
areas.
g
The
preamble
also
recognizes
that
in
some
cases
a
visibility
change
of
less
than
one
deciview
is
perceptible,
while
under
other
conditions
a
change
of
more
than
one
deciview
might
be
required
in
order
for
the
change
to
be
perceptible.
lo
The
Regional
Haze
Rule
requires
the
assessment
of
reasonable
progress
in
terms
of
average
annual
visibility
improvement
overall,
and
for
each
of
the
20%
of
the
days
in
a
year
with
the
best
and
the
worst
visibility
(
the
first
and
last
quintiles).
Regional
haze
is
the
product
of
a
wide
variety
of
sources,
generally
associated
with
area
sources
and
long­
range
transport
of
emissions.
Regional
haze
is,
therefore,
best
assessed
using
averages,
and
addressed
by
strategies
that
reduce
emissions
on
a
region­
wide
scale.

In
keeping
with
this
requirement,
the
WRAP
conducted
modeling
of
the
degree
of
visibility
improvement
that
would
occur
on
average
and
for
the
20%
best
and
worst
visibility
days.
The
64
FR
35741
'
64
FR
35726
64
FR
35725
lo
64
FR
35726­
35727
'

3

..

i
c­
12
WRAP
used
the
transfer
coefficients
developed
as
part
of
the
Integrated
Assessment
System
(
US)
and
used
by
the
Grand
Canyon
Visibility
Transport
Commission.
This
modeling
has
1imitation.
swhich
must
be
considered
when
interpreting
the
results.

The
IAS
models
were
designed
to
assess
regional
transport
of
emissions,
and
therefore
only
offers
limited
insight
into
the
impact
of
local
emission
sources.
The
models
are
best
at
demonstrating
the
relative
effects
of
changes
in
regional
emissions
on
visibility.
One
other
important
limitation
involves
the
number
of
receptors
where
pollution
data
were
available.
The
GCVTC
c.
ollecteddata
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
fiom
one
receptor,
Hopi
Point
in
Grand
Canyon
National
Park.

Although
the
IAS
has
limitations,
it
was
the
only
tool
that
could
realistically
be
used
in
the
short
time
frame
that
was
provided
to
develop
an
Annex
to
the
Grand
Canyon
Visibility
Transport
Commission
report.
Prior
to
the
development
of
the
IAS,
little
was
understood
about
the
contribution
of
various
emission
sources
to
regional
haze.
The
GCVTC
expended
considerable
time
and
energy
developing
the
tools
that
are
used
today
to
evaluate
the
sources
of
regional
haze.
The
WRAP
intends
to
keep
refining
and
improving
the
technical
tools
that
are
available
to
better
inform
policy
decisions.

The
visibility
modeling
measured
the
degree
of
visibility
improvement
that
would
occur
at
each
of
the
16
Class
I
areas
due
to
four
different
emission
reduction
scenarios
and
in
comparison
to
the
absence
of
any
regional
haze
program
(
i.
e.,
as
compared
to
the
baseline
emissions
inventory).
The
four
scenarios
were
developed
to
show
the
changes
in
visibility
that
would
occur
due
to
increasingky
stringent
emission
reductions.
Table
2
presents
the
visibility
improvements
for
the
scenario
that
best
matches
the
original
WRAP
estimate
of
SO,
reductions
associated
with
the
application
of
controls
on
BART­
eligible
sources,
at
155,000
tons,
as
modeled
by
ICF
intheir
economic
impacts
study.

When
comparing
the
results
of
the
visibility
analysis
for
the
 
Command
and
Control 
scenario
to
the
 
MTF 
scenario,
it
is
important
to
recognize
the
following
facts:

a
The
emission
inventory
for
the
 
Command
and
Control 
scenaSio
was
developed
as
part
of
the
economic
impacts
study
by
ICF
to
compare
the
cost
of
achieving
various
levels
of
emission
reduction
using
a
market
approach
with
the
cost
of
achieving
similar
reductions
using
a
source­
specific
command
and
control
program.

Both
the
Command
and
Control
and
MTF
scenarios
started
with
the
same
baseline
emissions
inventory
for
2018
(
648,000
tons) .

 
Note
that
the
baseline
inventory
used
by
ICF
is
different
from
that
used
by
the
MTF.
This
is
an
artifact
of
the
way
the
economic
model
was
implemented.
The
important
consideratioin
is
that
the
same
baseline
is
used
to
assess
the
differences
among
the
options.
For
C­
13
For
the
Command
and
Control
scenario,
ICF
applied
the
MTF
BART
assumptions
to
this
inventory
and
calculated
139,000
tons
of
emissions
reductions
in
2018.
These
reductions
were
subtracted
from
the
baseline,
yielding
an
inventory
of
509,000
tons.

For
the
MTF
scenario,
ICF
subtracted
the
MTF s
best
estimate
of
BART
reductions
at
the
time
(
155,000
tons)
and
added
back
35,000
tons
for
headrooduncertainty,
consistent
with
the
GCVTC
recommendations
discussed
in
section
D.
2.,
above.
This
yielded
an
inventory
of
528,000
tons.

Rounding
to
the
nearest
tenth
of
a
deciview
­­
a
level
of
accuracy
beyond
which
the
results
cannot
be
compared
with
any
confidence
­­
the
average
visibility
benefit
of
the
MTF
scenario
equals
that
of
the
Command
and
Control
scenario
­­
0.1
dv.

The
use
of
the
 
Command
and
Control 
scenario
as
a
surrogate
for
comparing
the
visibility
benefits
of
the
Annex
to
a
true
 
BART 
scenario
is
limited
because
it
does
not
recognize
the
overall
air
quality
benefits
of
the
emissions
caps.
Some
of
the
air
quality
benefits
of
the
emissions
caps
as
compared
to
a
source­
by­
sourceBART
approach
are
described
in
SectionF,
beginning
on
page
D­
17.
These
benefits
include
setting
caps
that
limit
increased
utilization
and
emission
rates
at
BART
and
non­
BART
sources,
setting
caps
based
on
the
assumption
that
47,000
tons
of
emissions
from
existing
non­
utilityhon­
smelter
sources
will
be
retired
between
1998
and
2018,
and
setting
caps
based
on
the
assumption
that
new
source
growth
will
be
limited
to
27,000
tons
between
2003
and
2018.
While
the
 
Command
and
Control 
scenario
used
for
the
visibility
modeling
has
these
same
assumptions
included,
in
actuality
these
benefits
would
not
accrue
to
a
BART
program
under
Section
308
of
the
Regional
Haze
Rule.
For
these
reasons
,
the
use
of
the
 
COWXUI~
and
Control 
scenario
as
a
surrogate
for
comparing
the
benefits
of
the
Annex
to
a
true
BART
scenario
is
of
limited
value.

As
can
be
seen,
the
maximum
visibility
improvement
expected
f?
om
installation
of
appropriate
control
technology
for
SO,
on
BART­
eligible
sources
in
the
Western
United
States,
amounts
to
about
one
third
of
a
deciview,
which
is
not
perceptible
to
the
average
person.

Table
3
provides
the
results
of
the
visibility
modeling
for
an
approximation
of
the
four
2018
milestones
offered
for
public
comment
in
May
2000.
The
modeling
distinguishes
among
the
milestones
based
on
the
estimated
BART
level
emissions
reductions.

These
visibility
results
show
that,
even
under
the
most
aggressive
emissions
reduction
scenario,
no
perceptible
change
in
visibility
will
accrue.
Further,
the
visibility
improvements
of
all
of
the
different
approaches
would
be
indistinguishable
for
regional
haze
purposes.
This
is
not
intended
to
imply
that
the
lack
ofperceptible
visibility
improvement
is
ajustification
for
taking
no
details,
refer
to
the
ICF
final
report,
Economic
Impacts
of
Implementing
a
ReGonal
SO,
Emissions
Cap
for
Stationarv
Sources
in
the
Western
United
States
(
September
2000).

C­
14
­­
action
to
<
reduceSO,
emissionsfrom
stationary
sources.
To
the
contrary,
it
emphasizes
the
need
to
develop
a
comprehensive
plan
that
reduces
visibility
impairing
emissions
from
all
types
of
sources
if
the
goals
of
Subpart
C
of
Title
I
of
the
Clean
Air
Act
are
to
be
achieved
in
the
West.

Table
2
Modeled
Visibility
Improvement
in
2018:
Command
and
Control
Scenario
Deciview
Improvement
Class
I
Area
Davs
Davs
Average
Arches
National
Park
0.17
0.28
0.22
Brvce
Canvon
0.02
0.16
0.08
Black
Canyon
of
the
Gunnison
0.08
0.08
0.10
l~
GG&
Ezj
Canyonlands
Cmitol
Reef
Flat
Tops
tHopi
Point
Maroon
Bells
t
Mesa
Verde
National
Park
Mt.
Baldy
Petrified
Forest
SanPedro
Parks
Sycamore
Canyon
Wleminuche
Wilderness
West
Elk
Zion
National
Park
0.16
0.26
0.21
0.06
0.21
0.13
0.09
0.23
­
0.16
0.03
0.15
0.09
0.10
0.07
0.10
0.09
0.35
0.19
0.04
0.20
0.12
0.07
0.14
0.11
0.08
0.32
0.21
0.05
0.08
0.07
0.06
0.34
0.18
0.10
0.07
0.10
0.02
0.10
0.06
Averacre
0.08
0.19
0.13
Min
0.02
0.07
0.06
Max
0.17
0.35
0.22
1
C­
15
F.
Other
Considerations
There
are
a
number
of
other
considerations
that
must
be
taken
into
account
in
the
overall
determination
as
to
whether
or
not
the
2018
milestone
developed
by
the
WRAP
achieves
greater
'

reasonable
progress
than
would
be
achieved
by
the
application
of
BART.

1.
Remedy
and
Prevention.
When
Congress
established
the
visibility
program
in
1977
it
declared
as
a
national
goal
"
the
prevention
of
any
future,
and
the
remedying
of
any
existing"
anthropogenic
visibility
impairment
in
mandatory
class
I
federal
areas.
l2
BART
is
an
emission
limitation
established
at
a
specific
source
and
is
designed
as
a
remedy
to
impairment
at
specificmandatory
Class
I
areas.
By
contrast,
the
market
trading
program
proposed
by
the
WRAP
serves
the
dual
purpose
of
remedying
existing
impairment
and
preventing
future
impairment
by
requirin
issions
reductions
and
­­­_­__­
mpphgsmissions
for
stationary
sources.
is
prevented
by
capping
emissions
growth
fiom
sources
not
eligible
under
the
BART
requirements,
from
BART
sources
that
are
expected
to
significantly
increase
utilization,
and
from
entirely
new
sources
in
the
region.

2.
Additional
Sources
Included.
The
backstop
trading
program
designed
by
the
WRAP
will
include
all
stationary
sources
with
emissions
higher
than
100
tondyear
of
SO,.
The
W'XP
designed
this
program
as
part
of
an
overall
strategy
to
address
all
sources
of
visibility
impairing
pollutants,
rather
than
focusing
on
a
subset
of
stationary
sources.

2018
SO,
Number
of
Sources
Emissions"
BART­
Eligible
47
201,615
Other
Stationary
Sources
157
4
246,570
"
Note:
The
2018
Emission
estimate
does
not
include
2
shut
down
smelters,
or
a
CEM's
bias
adjustment.
The
estimate
includes
an
emission
reduction
estimate
of
168,000Ji.
om
BART­
eligible
sources.

The
inclusion
of
all
major
SO,
sources
in
the
progrqn
is
necessary
to
create
a
viable
trading
program,
and
also
sewes
a
broader
purpose
to
ensure
that
growth
inemissions
from
non­
BART­
eligible
sources
does
not
undermine
the
progress
that
has
been
achieved.
BART
applied
on
a
case­
by­
case
basis
would
not
affect
these
sources,
and
there
would
be
no
limitation
on
their
future
operations
under
their
existing
permit
conditions.
Because
the
milestones
will
cap
these
sources
at
actual
emissions
(
which
are
less
than
current
allowable
emissions),
the
overall
effect
of
their
inclusion
is
to
provide
greater
reasonable
$?
ogress*
would
have
been
acheved
if
only
BART­
eligible
sources
were
included
in
the
program.

l2
CAA
0
169A(
a)(
l).

C­
17
3.
Cap
on
New
Source
Growth.
The
milestones
designed
by
the
WRAP
will
cap
the
growth
of
SO,
emissions
in
the
west.
These
milestones
include
estimates
for
growth,
but
then
lock
these
estimates
in
as
an
enforceable
emission
cap.
The
WRAP
strategy
is
consistent
with
the
statutory
goal
of
preventing
any
hture
visibility
impairment
that
results
fkom
man­
made
air
pollution.
The
entire
region
is
experiencing
rapid
growth
which
could
erode
the
progress
that
has
been
achieved
in
the
last
two
decades
towards
improving
visibility.
BART
applied
on
a
case­
by­
case
basis
would
have
no
impact
on
future
growth,
and
in
the
long
run
would
not
achieve
the
regional
emission
reductions
that
are
guaranteed
by
the
program.

4.
Actual
vs.
Allowable
Emissions.
The
baseline
emission
projections,
and
assumed
reductions
due
to
the
application
of
appropriate
retrofit
controls
to
BART­
eligible
sources,
are
all
based
on
actual
emissions,
using
either
1998
or
1999
as
the
baseline.
The
use
of
actual
emissions
has
an
effect
in
several
ways.
If
the
BART
process
was
applied
on
a
case­
by­
case
basis
to
individual
soukes,
emission
limitations
would
be
established
based
on
the
maximum
level
of
operation
of
the
unit.
The
 
allowable
emissions 
are
typically
higher
than
actual
emissions,
because
sources
do
not
always
rununder
full
load
conditions,
over
the
Eull
year s
available
time.
In
addition,
the
allowable
emissions
would
account
for
variations
in
the
sulk
content
of
fuel
and
alternative
operating
scenarios.
The
differencebetween
actual
emissions
and
allowable
emissions
is
particularly
large
when
a
source
is
permitted
to
burn
two
different
fuel
types,
such
as
oil
and
natural
gas,
or
when
the
source
is
part
of
a
cyclical
industry
where
production
varies
fi­
om
year
to
year
due
to
the
changing
demand
for
their
product.

The
WRAP S
method
of
emission
projections
allows
for
some
increase
in
capacity
for
the
electric
utility
industry
which
will
partially
address
this
difference
between
actual
and
allowable
emissions.
Even
in
this
case,
the
utilities
are
assumed
to
operate
at
an
average
of
85%
of
nameplate
capacity,
even
though
they
are
permitted
to
operate
at
100%
capacity.
Non­
utility
sources,
on
the
other
hand,
are
assumed
to
retire
at
a
certain
percentage
rate
each
year
with
no
provision
for
emission
growth
from
existing
sources.
Any
growth
that
is
projected
for
those
industries
(
refineries,
pulp
and
paper,
cement,
etc.)
is
assumed
to
be
met
by
new
sources
at
highly
controlled
emission
rates.

In
addition
to
the
cap
on
growth
of
actual
emissions,
the
difference
between
an
emission
projection
for
future
years,
and
a
regional
emission
cap
must
also
be
considered.
The
milestones
will
act
as
a
regulatory
trigger
that
will
be
converted
into
an
enforceable
emission
cap
if
the
milestones
are
not
met.
This
essentially
creates
a
regional
 
allowable 
emission
level.
When
sources
are
managing
their
operations
they
have
a
large
incentive
to
maintain
headroom
under
any
enforceable
limit
to
ensure
that
they
stay
in
compliance.
This
process
is
expected
to
happen
on
a
voluntary
basis
prior
to
the
program
trigger,
and
will
be
strengthened
if
the
milestones
become
enforceable
emission
caps.
The
net
effect
is
that
compliancewith
the
milestones
should
lead
to
actual
emissions
that
are
below
the
milestone.
The
difference
between
actual
emissions
and
allowable
emissions
is
commonly
referred
to
as
headroom.
.,

C­
18
5.
Mass­
based
Cap
vs.
Rate­
Based
Emission
Limits
for
BART.
Emission
limitations
folr
stationary
sources
(
including
BART
limits)
are
typically
expressed
as
emission
rates
(
Ibs/
how
or
IbsflMMBtu),
while
the
WRAP
milestones
are
expressed
as
total
mass
during
a
given
year
(
tons/
year).
One
effect
of
this
difference
is
that
rate­
based
limits
can
lead
to
higher
emissions
when
production
is
increased
or
when
higher
sulfbr
he1
is
used,
as
explained
in
the
discussion
of
actual
vs.
allowable
emissions
above.
Another
difference
is
that
mass­
based
limits
will
include
excess
emissions
that
may
occur
due
to
malfunctions
or
during
the
start­
up
or
shut­
down
of
emission
units.
A
good
example
of
this
difference
is
the
requirement
in
the
acid
rain
program
that
emissions
must
be
assumed
to
be
the
highest
value
recorded
from
the
past
year
during
the
time
period
that
continuous
emission
monitors
are
not
functioning
on
a
stack.
These
higher
emissions
are
calculated
as
part
of
the
overall
tonsfyear,
and
must
be
accounted
for
under
the
mass­
based
cap
for
the
acid
rain
program.

6.
1990
as
a
baseline
for
Section
309
Regional
Haze
Plans.
The
regional
haze
rule
rec(
ognizedthe
significant
work
that
had
been
completed
by
the
Grand
Canyon
Commission,
and
section
309
ofthe
rule
was
therefore
designed
to
incorporatethe
Coinmission
recommendations.
A
key
element
of
this
section
of
the
rule
is
the
use
of
1990
as
a
baseline
for
measuring
progress.
There
have
been
significant
emission
reductions
in
the
west
since
1990,
and
this
improvement
needs
to
be
considered
when
measuring
the
overall
effects
of
the
Commission's
strategies.
The
Commission
established
a
goal
of
a
13%
reduction
from
1990
emissions.
It
is
anticipated
that
the
actual
emission
reductions
in
the
region
will
be
closer
to
20%.
Emission
reductions
due
to
the
application
of
appropriate
retrofit
technology
on
BART­
eligible
sources
between
1990
and
2018
are
estimated
to
be
28'
7,176tons
of
SO,
(
See
Table
4).
This
estimate
includes
a
reduction
of
119,000
tons
of
SO,
&
om
BART­
eligible
sources
that
have
occurred
or
have
been
legally
committed
to
between
1990and
2000
(
assuming
that
these
plants
are
operating
at
85%
of
nameplate
capacity).
The
2018
milestone
of
510,000
represents
a
regional
emission
reduction
of
around
321,000
tons
of
SO,
&
omthe
1990
baseline
emissions
of
831,000
tons.
This
overall
reduction
due
to
the
milestones
is
approximately
35,000
tons
greater
than
what
has
been
estimated
due
to
the
application
of
appropriate
retrofit
technology
to
BART­
eligible
sources,

C­
19
Table
4
Calculation
of
BART­
Level
Emissions
Reductions
from
the
1990
Baseline
Emissions
1990
1990
1990
level
Emissions
at
Level
of
after
Emissions
Facility
and
Unit
Emissions
Capacity
of
control
85%
capacity
control
Controls
Reductions
Navajo
#
1
20,497
62%
0%
27,952
90%
2,050
18,447
Navajo
#
2
26,101
81%
0%
27,252
90%
2,610
23,491
Navajo
#
3
29,621
90%
36%
29,62
1
90%
2,962
26,659
Hayden
#
1
4,857
77%
0%
5,344
85%
729
4,128
Hayden
#
2
6,420
78%
0%
7,039
85%
963
5,457
Cherokee
#
4
4,689
55%
38%
7,298
85%
703
3,986
Valmont
#
5
3,007
65%
0%
3,924
85%
451
2,556
Mojave
#
1
21,605
56%
0%
32,834,
85%
3,241
18,364­
Mojave
#
2
18,720
68%
0%
23,2971
85%
2,808
15,912
Total
Effected
and
Planned
Emission
Reductions
fiomBART­
eligible
sources
119,000
WRAP
Calculated
BART­
level
reductions
(
rounded
to
nearest
1,000.
from
allstat7.
xls)
168.000
I
TOTAL
I
287,0001
7.
Commission
Strategies
are
a
Total
Package.
The
GCVTC
recommendations
go
well
beyond
stationary
sources,
and
include
strategies
to
address
mobile
sources,
prescribed
fire,
pollution
prevention,
and
emissions
in
and
near
Mandatory
Class
I
areas.
The
reductions
from
these
additional
strategies
have
not
yet
been
quantified,
but
are
expected
to
be
significant.
The
stationary
source
strategies
need
to
be
viewed
as
part
of
this
overall
package.
Visibility
impairment
in
the
west
is
caused
by
multiple
sources
and
pollutants,
and
a
narrow
focus
on
stationary
sources
may
not
achieve
the
same
results
as
a
broad­
based
program.
The
WRAP
is
in
the
process
of
quantifLingthe
effect
of
the
rest
of
the
Commission s
strategies,
and
the
entire
package
will
be
included
in
the
State
and
Tribal
Implementation
Plans
in
2003.

G.
Comparison
of
Trading
vs
Command
and
Control
BARTRequirements.
One
additional
issue
that
must
be
considered
when
determining
if
the
2018
milestone
achieves
greater
reasonable
progress
than
BART
is
the
geographic
location
where
emission
reductions
will
occur.
For
example,
if
all
of
the
emission
reductions
under
a
trading
program
scenario
are
concentrated
.
in
one
small
part
of
the
region,
the
visibility
improvement
may
be
less
than
what
would
be
achieved
if
reductions
occurred
at
specific
locations
under
a
command
and
control
approach.

To
address
this
question,
the
WRAP
modeled
the
improvement
in
visibility
impairment
that
would
occur
under
two
different
scenarios:
a
command­
and­
control
scenario
where
the
emission
reductions
due
to
the
application
of
appropriate
retrofit
controls
on
BART­
eligible
sources
were
assumed
to
occur
at
locations,
and
a
second
scenario
where
least­
cost
modeling
was
used
to
identify
where
these
same
emission
reductions
would
occw
under
a
trading
program.
The
visibility
transfer
coefficients
and
control
cost
assumptions
developed
as
part
of
the
Integrated
Assessment
System
were
used
for
this
analysis.
Tables
2
and
3
provide
the
data
for
the
comparison
of
the
visibility
improvement
associated
with
these
two
approaches
c­
20
The
results
of
this
analysis
showed
that
there
would
be
an
imperceptible
improvement
in
visibility
,
impairmentunder
the
command­
and­
control
scenario.
The
maximum
difference
between
the
two
scenarios
at
any
of
the
16
Class
I
areas
was
only
0.1
deciview.

c­
21
