WESTAR Workshop

November 2005

Understanding the Critical Loads Approach

PSD program was intended to protect against effects that may occur notwithstanding attainment of NAAQS

preserve, protect and enhance the air quality in national parks, national wilderness areas, national monuments, national seashores, and other areas of special national or regional natural, recreational, scenic, or historic value.”

Independent and complimentary FLM mandates to conserve natural and cultural resources “unimpaired” for the enjoyment of future generations.

Protecting Clean Air and Air Quality Related Values: PSD and Other Mandates

Success is …Success is …

Economic growth occurring without Economic growth occurring without compromising clean air, especially in compromising clean air, especially in national parks and wilderness areasnational parks and wilderness areas

Effective protection of air quality and Effective protection of air quality and resources affected by air quality in Class I resources affected by air quality in Class I and II areasand II areas

Is It Working?Is It Working?

Technology-forcing requirements have limited pollution Technology-forcing requirements have limited pollution increasesincreasesFLMs knowledge of how air pollution affects resources FLMs knowledge of how air pollution affects resources has increased signifcantly, but is far from completehas increased signifcantly, but is far from completeEfforts to MANAGE the clean air resource are primarily Efforts to MANAGE the clean air resource are primarily limited to NSRlimited to NSR““Periodic” review of increment consumption hasn’t Periodic” review of increment consumption hasn’t occurred in most states occurred in most states Air quality in many Class I areas is deteriorating and Air quality in many Class I areas is deteriorating and scenic and natural resources are experiencing adverse scenic and natural resources are experiencing adverse effectseffectsFramework doesn’t fit the problems occurringFramework doesn’t fit the problems occurring

Im proving Trend, p<=0.05

Im proving Trend, 0.05<p<=0.15

Degrading Trend, 0.05<p<=0.15

Degrading Trend, p<=0.05

No Trend

Trends in Haze Index (Deciview) on Haziest Days, 1995-2004FY2005 Annual Performance Report for NPS Government Performance and Results Act (GPRA)

Air Quality Goal Ia3

10/28/2005

Acadia

Badlands

Bandelier

Big Bend

Bryce Canyon

Canyonlands

Chiricahua

Crater Lake

Gila Cliff

Glacier

Great Bas in

Grand Canyon

Great Sand Dunes

Great Sm oky Mtns

Guadalupe Mtns

Lassen Volcanic

Mam m oth CaveMesa Verde

Mount Rainier

Petrified Fores t

Pinnacles

Redwood

Rocky Mountain

Sequoia Shenandoah

Tonto

Washington

Yellows tone

Yosem ite

Denali

Improving Trend, p<=0.05

Improving Trend, 0.05<p<=0.15

Degrading Trend, 0.05<p<=0.15

Degrading Trend, p<=0.05

No Trend

Trends in Haze Index (Deciview) on Clearest Days, 1995-2004FY2005 Annual Performance Report for NPS Government Performance and Results Act (GPRA)

Air Quality Goal Ia3

10/28/2005

Acadia

Badlands

Bandelier

Big Bend

Bryce CanyonCanyonlands

Chiricahua

Crater Lake

Gila Cliff

Glacier

Great Bas in

Grand Canyon

Great Sand Dunes

Great Smoky Mtns

Guadalupe Mtns

Lassen Volcanic

Mammoth CaveMesa Verde

Mount Rainier

Petrified Fores t

Pinnacles

Redwood

Rocky Mountain

Sequoia

Shenandoah

Tonto

Washington

Yellowstone

Yosem ite

Denali

Improving Trend, p<=0.05

Improving Trend, 0.05<p<=0.15

Degrading Trend, 0.05<p<=0.15

Degrading Trend, p<=0.05

No Trend

Trends in Ammonium Nitrate Particulate Concentrations on Haziest Days, 1995-2004

11/02/2005

Acadia

Badlands

Bandelier

Big Bend

Bryce Canyon

Bridger

Brigantine

Canyonlands

Chassahowitzka

Chiricahua

Columbia River

Crater Lake

Dolly Sods

Gila Cliff

Glacier

Great Bas in

Grand Canyon

Great Sand Dunes

Great Sm oky Mtns

Guadalupe Mtns

JarbidgeLassen Volcanic

Lye Brook

Mam m oth Cave

Mesa Verde

Moosehorn

Mount Rainier

Mt. Zirkel

Okefenokee

Petrified Fores t

Pinnacles

Redwood

Cape Rom ain

Rocky Mountain

San Gorgonio

Sequoia

Shenandoah

Shining Rock

Snoqualm ie Pass

Three Sis ters

Tonto

Upper Buffalo

Washington

Weminuche

Yellowstone

Yosem ite

Denali

Im proving Trend, p<=0.05

Im proving Trend, 0.05<p<=0.15

Degrading Trend, 0.05<p<=0.15

Degrading Trend, p<=0.05

No Trend

Trends in NO3 Concentrations in Precipitation, 1995-2004FY2005 Annual Performance Report for NPS Government Performance and Results Act (GPRA)

Air Quality Goal Ia3

10/12/2005

Acadia

Bandelier

Big Bend

Bryce Canyon

Buffalo

Canyonlands

Capulin Volcano

Craters of the Moon

Everglades

Gila Cliff

Glacier

Great Bas in

Grand Canyon Great Sm oky Mtns

Guadalupe Mtns

Indiana Dunes

Is le Royale

Little Bighorn

Mesa Verde

Mount Rainier

North CascadesOlym pic

Organ Pipe

Rocky Mountain

Shenandoah

Virgin Is lands

Yellows tone

Yosem ite

Denali

Im proving Trend, p<=0.05

Im proving Trend, 0.05<p<=0.15

Degrading Trend, 0.05<p<=0.15

Degrading Trend, p<=0.05

No Trend

Trends in NH4 Concentrations in Precipitation, 1995-2004FY2005 Annual Performance Report for NPS Government Performance and Results Act (GPRA)

Air Quality Goal Ia3

10/12/2005

Acadia

Bandelier

Big Bend

Bryce Canyon

Buffalo

Canyonlands

Capulin Volcano

Craters of the Moon

Everglades

Gila Cliff

Glacier

Great Bas in

Grand Canyon Great Sm oky Mtns

Guadalupe Mtns

Indiana Dunes

Is le Royale

Little Bighorn

Mesa Verde

Mount Rainier

North CascadesOlym pic

Organ Pipe

Rocky Mountain

Shenandoah

Virgin Is lands

Yellowstone

Yosem ite

Denali

EFFECTS OF ATMOPSHERIC EFFECTS OF ATMOPSHERIC DEPOSITIONDEPOSITION

Forms: Wet (rain, snow), dry and clouds Forms: Wet (rain, snow), dry and clouds Acidifies soils and surface watersAcidifies soils and surface watersChanges soil processesChanges soil processesCan cause eutrophication (nitrogen only)Can cause eutrophication (nitrogen only)Causes shifts in plant community composition and Causes shifts in plant community composition and diversity (nitrogen only)diversity (nitrogen only)– Increase in native or exotic grasses, other invasive plants Increase in native or exotic grasses, other invasive plants – Altered fire cycles (due to greater fuel loads caused by N Altered fire cycles (due to greater fuel loads caused by N

fertilization)fertilization)– Increased susceptibility to pests and other stressesIncreased susceptibility to pests and other stresses

Increases availability of aluminum (which can be toxic to Increases availability of aluminum (which can be toxic to plants and animals)plants and animals)

Purposes of PSD Program More Purposes of PSD Program More Likely to be Achieved thru…Likely to be Achieved thru…

More attention to cumulative impacts on More attention to cumulative impacts on ENVIRONMENTENVIRONMENT– improved partnership between FLM & States, improved partnership between FLM & States,

including shared recognition of value of including shared recognition of value of assessing and addressing cumulative impacts assessing and addressing cumulative impacts on AQRVs on AQRVs

More direct link between regulatory More direct link between regulatory framework and desired outcome framework and desired outcome

“Critical loads” define desired condition: “The quantitative estimate of an exposure to one or more pollutants below which significant harmful effects on specified sensitive elements of the environment do not occur according to present knowledge.” (Nilsson and Grennfelt 1988)

“Target loads” to track progress: The level of exposure to one or more pollutants that results in an acceptable level of resource protection; may be based on political, economic, or temporal considerations.

Critical Load Approach Links Air Critical Load Approach Links Air Quality Management to Ecological Quality Management to Ecological

EffectsEffects

Scientific Approaches to Develop Scientific Approaches to Develop Critical LoadsCritical Loads

NPS research on sensitive receptors and NPS research on sensitive receptors and endpoints ongoing at:endpoints ongoing at:– Rocky Mountain NP, Glacier NP, Yellowstone NP, Rocky Mountain NP, Glacier NP, Yellowstone NP,

Grand Teton NP, Great Sand Dunes NPGrand Teton NP, Great Sand Dunes NP– Shenandoah NP, Great Smoky Mountains NPShenandoah NP, Great Smoky Mountains NP– Mount Rainier NP, North CascadesMount Rainier NP, North Cascades– Big Bend NP, Joshua Tree NPBig Bend NP, Joshua Tree NP

Modeling being tested at: Modeling being tested at: – Rocky Mountain, Great Smoky, Mt Rainier, Acadia Rocky Mountain, Great Smoky, Mt Rainier, Acadia

and Joshua Treeand Joshua Tree

Other FLMs also conducting empirical studies Other FLMs also conducting empirical studies and modeling to establish critical loads and modeling to establish critical loads

Increased communication and collaboration between land Increased communication and collaboration between land managers and scientists on resource management needs, managers and scientists on resource management needs, sensitive resources, relevant indicators and endpoints to meet sensitive resources, relevant indicators and endpoints to meet resource protection goals. resource protection goals.

Identify/refine appropriate models for estimating critical loads Identify/refine appropriate models for estimating critical loads in both aquatic and terrestrial ecosystemsin both aquatic and terrestrial ecosystems

Using critical loads as a resource management tool and performance Using critical loads as a resource management tool and performance measuremeasure– Defining desired conditionsDefining desired conditions– Assessing current conditions and tracking progress Assessing current conditions and tracking progress

Explore opportunities for using critical loads in air regulatory Explore opportunities for using critical loads in air regulatory planning processes at the national, state, and local level thru a planning processes at the national, state, and local level thru a ccooperative conservation approachooperative conservation approach– ““EPA recognizes that a State may choose to utilize a critical load EPA recognizes that a State may choose to utilize a critical load

concept as part of its air quality management approach to meet its concept as part of its air quality management approach to meet its broader air quality goals.” EPA NOx Increment Rule (2005)broader air quality goals.” EPA NOx Increment Rule (2005)

FLM Future DirectionsFLM Future Directions

WESTAR PSD New WESTAR PSD New FrameworkFramework

Ira Domsky, Deputy DirectorIra Domsky, Deputy Director

Air Quality Division, Arizona DEQAir Quality Division, Arizona DEQ

November 15, 2005November 15, 2005

OverviewOverview

Review of guiding principlesReview of guiding principles

March 31-April 1, 2005 WorkshopMarch 31-April 1, 2005 Workshop

The path forwardThe path forward

Major issues related to critical loadsMajor issues related to critical loads

Guiding PrinciplesGuiding Principles

Achieve the purposes of the PSD programAchieve the purposes of the PSD program– Protect public health and welfareProtect public health and welfare– Preserve, protect and enhance air quality in Preserve, protect and enhance air quality in

Class I and other areas of natural and Class I and other areas of natural and recreational significancerecreational significance

– Assess and manage interstate impactsAssess and manage interstate impacts– Comply with spirit and requirements of PSD Comply with spirit and requirements of PSD

permitting processes permitting processes

Guiding PrinciplesGuiding Principles

Look beyond existing law, if warrantedLook beyond existing law, if warrantedImprovement to environment and Improvement to environment and efficiencyefficiencyEvaluate feasibility and balance competing Evaluate feasibility and balance competing valuesvaluesHarmonize with and complement other Harmonize with and complement other regulatory requirementsregulatory requirementsIncorporate new knowledge and Incorporate new knowledge and technologies and analytical toolstechnologies and analytical tools

March 31 – April 1 2005 March 31 – April 1 2005 Workshop AttendeesWorkshop Attendees

Nearly all statesNearly all states

EPAEPA

NPS for FLMsNPS for FLMs

WESTAR staff and contractorWESTAR staff and contractor

Issue MappingIssue Mapping

Procedure used for all topic areasProcedure used for all topic areas

– Brainstorm and record – questions, questions, Brainstorm and record – questions, questions,

questionsquestions

– CategorizationCategorization

– OrganizationOrganization

Develop action planDevelop action plan

Categories of IssuesCategories of Issues

Methods, analysis and goalsMethods, analysis and goalsRolesRolesProgram designProgram designImplementation approach – cap & tradeImplementation approach – cap & tradeResourcesResourcesPolitical feasibilityPolitical feasibilityImpacts on sources/equityImpacts on sources/equityEnvironmental benefits/impactsEnvironmental benefits/impacts

Major ThemesMajor Themes

Mandatory Class I area AQRVsMandatory Class I area AQRVs– Effects based AQRV protection (e.g., critical Effects based AQRV protection (e.g., critical

loads)loads)

Non-mandatory Class I, Class II/III areasNon-mandatory Class I, Class II/III areas– 2 options2 options

Change focus from short-term to annualChange focus from short-term to annual

Alternative without incrementsAlternative without increments

– Approach dependent on outcome of Class I Approach dependent on outcome of Class I processprocess

Major ThemesMajor Themes

Baseline emissions inventory improvementBaseline emissions inventory improvement– 2 options2 options

Secure, stable baseline inventoriesSecure, stable baseline inventories

Reset baseline datesReset baseline dates

CaveatsCaveats

Process for defining specifics for new Process for defining specifics for new

frameworks will take at least 18 months frameworks will take at least 18 months

Follow-through is essentialFollow-through is essential

Time the roll-out to assure positive Time the roll-out to assure positive

outcomeoutcome

Critical Loads Related IssuesCritical Loads Related Issues

Time frame for development of critical Time frame for development of critical

loads (CLs)loads (CLs)

What pollutants should be assessed?What pollutants should be assessed?

Will CLs replace increments?Will CLs replace increments?

If so, how will transition work?If so, how will transition work?

Can surrogates be developed (e.g., visibi-Can surrogates be developed (e.g., visibi-

lity thresholds, weight of evidence)?lity thresholds, weight of evidence)?

Critical Loads Related IssuesCritical Loads Related Issues

Stopping point for assessmentStopping point for assessment

Incorporation of new scienceIncorporation of new science

Will CLs be “bright line” standards?Will CLs be “bright line” standards?

Handling of source apportionment and Handling of source apportionment and

setting of emissions goals/limitationssetting of emissions goals/limitations

Dealing with short-term v. long-term Dealing with short-term v. long-term

impactsimpacts

Critical Loads Related IssuesCritical Loads Related Issues

Development of “research program”Development of “research program”

Implementation time frames for problem Implementation time frames for problem

identification and responsesidentification and responses

Can nonattainment area plan be a model?Can nonattainment area plan be a model?

Integration into permitting programsIntegration into permitting programs

Dealing with potentially competing AQRVsDealing with potentially competing AQRVs

Critical Loads Related IssuesCritical Loads Related Issues

Program evaluationProgram evaluation

Addressing background levels and natural Addressing background levels and natural

eventsevents

Institutional relationships – Federal, State, Institutional relationships – Federal, State, Tribal, RPOTribal, RPO

Role of cap-and-trade programs and their Role of cap-and-trade programs and their implementationimplementation