June
29,2001
MEMORANDUM
TO:
Tim
Smith,
EPA­
OAQPS\

FROM:
Patrick
Cummiils,
WRAP
Co­
Project
Manag
_
I
SUBJECT:
Additional
Technical
Support
Documentation
Please
find
enclosed
the
following
additional
technical
support
documents
related
to
the
WRAP
Annex:

1)
Description
of
Methodology
Used
to
Calculate
State
and
Tribal
Opt
WOpt
Budgets
2)
Final
Report
on
Regional
Economic
Impacts
of
Annex
fi­
om
ICF
Consulting
(
replaces
Vol.
IT
of
previous
submittal)

3)
Data
Worksheets
fiom
ICF
Consulting
Detailing
Utility
Emissions
Projections
4)
Informatian
on
Emission
Measurement
Metliods
for
Non­
Utility
Sources.

We
are
in
the
process
of
finalizing
our
revised
visibility
modeling
and
that
report
will
be
sent
in
about
two
weeks.

Please
do
not
hesitate
to
contact
me
with
any
questions
regarding
this
information.
Thank
you
for
your
ongoing
assistance
with
this
effort.

Staffed
by:
Staffed
by:
Western
Governors'Association
National
Tribal
Environmental
Council
1515
Cleveland
Place,
Suite
200
www.
wrapair.
org
2221
Rio
Grande
NW
Dsnver,
CO
80202
Albuquerque,
NM
87104
(
303)
623­
9378
(
505)
242­
2175
Fax
(
303)
534­
7309
Fax
(
505)
242­
2654
Methodology
Used
to
Calculate
State
and
Tribal
Opt
IdOpt
Out
Budgets
Th.
e
state
and
tribal
milestone
adjustments,
and
new
source
set­
aside
adjustments
were
calculated
using
the
same
methodology
that
was
used
to
develop
the
regional
SO,
milestones.
The
biggest
component
of
the
milestone
was
the
projected
emission
inventory
for
the
region,
including
emission
reduction
estimates
due
to
the
application
of
Best
Available
Retrofit
Technology
(
BART)
to
sources
in
the
region.
In
addition,
there
was
an
uncertainty
factor
that
was
included
in
the
milestones
to
account
for
possible
errors
in
the
projections.

The
spreadsheet
titled
 
Opt
in
Opt
out
adjustments.
xls, 
which
can
be
found
in
the
Technical
Support
for
the
SupplementaryAnnex
Submittal
section
of
tbe
Market
Trading
Forum
web
site
(
www.
wrapair.
org),
calculates
the
adjustments
for
each
state
and
tribe.
A
copy
of
this
spreadsheet
is
attached.

There
are
4separate
worksheet
pages
that
are
used
to
calculate
the
adjustments
for
each
of
the
milestone
years,
2003,2008,2013
and
2018.
These
adjustments
are
summarized
in
a
final
chart
titled
 
Milestone
Adjustments
Due
to
States
or
Tribes
Opting
Out
of
the
Regional
Program
Under
309 
that
was
adopted
by
the
WRAP
on
May
23,2001.
The
following
sections
describe
in
detail
the
data
sources,
and
any
assumptions
that
were
made
to
develop
these
individual
milestone
year
adjustments.

Projected
Emissions
from
Existing
Sources
for
2003,2008,2013
and
2018
In
July
and
August,
2000,
two
contractors
completed
stationary
source
emission
inventories
and
emission
projections
through
the
year
2018
for
major
sources
of
SO,
in
the
9­
state
transport
region.
These
inventories
were
used
as
the
basis
for
final
negotiations
of
the
regional
SO,
milestones.

Utility
and
Combined
Heat
and
Power
Source
inventories
were
completed
by
ICF
Consulting.
The
final
results
of
this
contract
are
included
in
the
Technical
Support
Documentation
for
the
Annex,
and
in
a
spreadsheettitled
 
Zmission~
Reconciliation~
4.01 
that
is
included
in
the
Technical
Support
for
the
SupplementaryAnnex
Submittal
(
see
Market
Trading
Forum
web
site,
located
at
IW.
wrapair.
or@.

Non­
Utility
inventories
were
completed
by
Pechan
and
Associates.
The
final
results
of
this
contract
are
included
in
the
Technical
Support
documentation
for
the
Annex,
which
can
also
be
found
on
the
Market
Trading
Forum
web
site.

Both
of
these
emission
inventories,
and
projections
though
2018
were
calculated
at
the
state
level,
and
the
numbers
fi­
omthe
contractors
reports
were.
used
as
the
starting
point
for
the
state
and
tribal
budgets.
The
columns
labeled
Utilities,
Smelters,
CHP,
and
Other
contain
these
imentory
numbers
with
the
following
adjustments:
1.
Several
Tribal
Sources
were
included
in
the
state
inventory
totals.
The
inventories
for
these
sources
were
subtracted
from
the
state
totals,
and
placed
in
a
new
entry
for
the
applicable
tribe.
The
specific
sources
were:

Tribe
Navajo
Nation
Navajo
Nation
Shoshone­
Bannock
Tribes
of
the
Fort
Hall
Reservation
Ute
Indian
Tribe
of
the
Uintah
and
Ouray
Reservation
Wind
River
Reservation
Wind
River
Reservation
Source
State
Four
Corners
Generating
Station
NM
Navajo
GeneratingStation
Az
Astaris
(
formerly
FMC)
ID
Deseret
Generation
and
Transmission,
UT
Bonanza
Plant
Koch
Sulfur
Products
WY
Snyder
Oil
Corp
WY
2.
The
inventory
projections
developed
by
EH
Pechan
and
Associates
for
non­
utilities
were
done
at
the
source
category
level.
Retirement
and
growth
estimates
were
applied
to
the
category
to
obtain
an
overall
projection
number
for
the
years
2003,2008,2013,
and
2018.
The
new
source
growth
estimates
were
subtracted
fiom
Pechan s
inventory
to
obtain
an
estimate
of
emissions
fiom
existing
sources
in
the
region,
including
retirements.
New
source
growth
is
treated
as
a
separate
line
item.

3.
The
projected
emissions
for
the
Mohave
Generating
Station
in
Nevada
in
2003
are
based
on
an
assumed
fbture
control
level
of
85%.

4.
Emissions
fiom
non­
utility
sources
located
on
tribal
lands
were
assumed
to
remain
constant
ficm
2003
to
2018.
The
regional
category
growth
and
retirement
assumptions
that
were
used
by
Pechan
and
Associates
did
not
make
sense
when
applied
to
individual
sources
or
to
a
very
small
group
of
sources.
This
assumption
will
not
affect
new
source
growth
on
tribal
lands
because
the
milestones
will
be
applied
regionally.

Additional
Calculations
for
2003
The
SO,
emissions
projections
for
existing
sources
were
combined
into
a
regional
subtotal
of
677,858
tons.
The
new
source
growth
estimate
of
9,000
tons,
and
a
tribal
allocation
of
20,000
tons
were
added
to
the
existing
source
projections
to
achieve
a
subtotal
of
706,858
tons.

The
milestone
for
2003is
720,000
tons.
The
subtotal
of
706,858
was
subtracted
from
this
milestone
to
derive
a
regional
uncertainty
estimate.
The
uncertainty
estimate
was
then
prorated
to
each
of
the
states
according
to
the
percentage
of
total
emissions
for
existing
sources
in
each
state
with
the
following
exceptihs:

1.
Emissions
from
two
suspended
smelters
were
subtracted
fiom
the
emission
estimates
for
Arizona
and
New
Mexico
prior
to
the
proration.
This
was
done
so
that
the
milestone
adjustments
for
other
states
would
not
be
affected
by
the
hture
status
of
these
two
sources.
As
outlined
in
the
summary
tzble,
the
adjustment
numbers
for
Arizona
and
New
Mexico
would
be
modified
if
either
of
these
sources
do
not
resume
operation.
.
2.
Tribal
sources
were
not
included
in
the
proration.
As
described
above,
these
sources
were
treated
separately
due
to
problems
with
applying
regional
assumptions
to
individual
sources.

The
new
source
growth
estimate
of
9000
tons
was
also
prorated
to
each
of
the
states
according
to
the
percentage
of
total
existing
emissions
in
each
state.

Additional
calculations
for
2008
The
adjustments
for
2008
were
calculated
in
the
same
manner
as
2003.
The
new
source
growth
estimate
was
increased
to
18,000
tons
(
9,000
tons
every
5
years)
and
then
prorated
as
described
for
the
2003
calculations.

Additional
calculations
for
2013
The
year
2013
contains
an
emission
reduction
 
down
payment 
for
the
estimated
BART
reductions
in
2018.

As
described
for
2013,
the
projected
regional
SO,
emissions
for
existing
sources
of
645,906
tons
was
added
to
the
tribal
allocation
of
20,000
tons
and
the
new
source
growth
estimate
of
27,000
tons
for
a
subtotal
of
692,906.

The
milestone
for
2013
is
655,000.
When
the
subtotal
was
subtracted
&
om
this
milestone,
it
left
a
regional
 
down
payment 
on
BART
of
37,906.
This
down
payment
was
prorated
to
each
of
the
states
according
to
the
utility
BART
estimates
for
each
of
those
states
as
described
below
for
the
2018
adjustments.
Tribal
sources
were
not
included
in
the
proration.
Tribal
sources
were
again
treated
separately
due
to
problems
with
applying
regional
assumptions
to
individual
sources.

Additional
calculations
for
2018
The
regional
emission
reduction
estimates
calculated
in
Allstate8.
xls,
which
was
included
in
the
Technical
Support
Documentation
for
the
Annex,
was
used
to
estimate
BART
reductions.
The
reductions
in
Allstate8.
xls
were
calculated
at
the
source
level,
recognizing
that
these
estimates
were
only
valid
when
applied
regionally
to
an
entire
source
category.
The
source
level
calculations
were
added
up
for
each
state
and
tribe
for
both
utilities
and
non­
utilities.
These
are
listed
in
the
columns
labeled
Utility
BART
and
Other
BART.

The
projected
emissions
from
existing
sources
subtotal
is
634,523
tons
SO,.
Utility
BART
estimates
of
151,795
for
utilities
and
16,120
for
non­
utilities
were
subtracted
fi­
omthis
subtotal
to
achieve
new
regional
subtotal
less
BART
of
466,608.

Thp
trihsl
nllnwtinn
of
20,000
tons
and
the
new
source
allocation
of
27,000
tons
were
added
to
this
subtotal
of
513,608.
The
milestone
for
2018
is
510,000.
The
difference
between
these
two
numbers
is
primarily
a
rounding
adjustment,
and
was
prorated
based
on
the
emission
projection
less
BART
for
each
state.
As
described
above,
these
sources
were
treated
separately
due
to
problems
with
applying
regional
assumptions
to
individual
sources.
.
