The Western Regional Air Partnership (WRAP)

WRAP formed in 1997 as the successor organization to Grand Canyon Visibility Transport Commission (GCVTC)

– Partnership of states, tribes, and federal agencies

– Make decision through consensus

– Stakeholders are active in a wide variety of subcommittees – technical & policy

WRAP membership includes 13 states with equal membership on the Board for tribes in the region

– Staffed and administered by Western Governors’ Association and National Tribal Environmental Council

WRAP’s primary purpose is to develop technical tools and programs to help members reduce haze and comply with the federal regional haze rule

Other air quality issues raised by WRAP members may also be addressed

Federal Regional Haze Rule

Final rule published July 1, 1999 to protect visibility at 156 Class I areas (national parks and wilderness areas) nationwide

– 119 of these Class I areas are in the West

Goal is to achieve natural conditions by 2064

State plans demonstrating reasonable progress toward the goal of natural conditions at each area are due to EPA by December 2007

Plans must show improvement on 20% worst days through 2018 (first planning period) and no degradation on 20% best days

Plans must implement Best Available Retrofit Technology (BART) or an alternative program for certain industrial sources, including power plants, built between 1962 and 1977

Sources of Haze in the West

NOx and SO2 emissions from industrial sources– Power plants, refineries, oil and gas, etc.

Mobile Sources– On and off road, gas and diesel

Fire– Wildfire and prescribed fire (wildland and ag land)

Dust– Windblown, construction, mining, and agriculture

The Grand Canyon Visibility Transport Commission (GCVTC)

GCVTC examined “regional haze” at 16 Class I areas on the Colorado Plateau

Issued final report and recommendations in 1996

– 50 – 70 % reduction in industrial source SO2 emissions from 1990 levels by 2040

– Renewable energy goals: 10% by 2005 and 20% by 2015

– Enhanced smoke management programs for fire

– New federal standards for mobile source emissions

– State and local strategies to reduce dust

WRAP is charged with implementing the Commission recommendations

Section 309 Regional Haze Plans

EPA’s Regional Haze Rule provided an option for 9 Western states to satisfy some of the rule requirements by implementing the GCVTC recommendations

Rule required ...

– WRAP to submit an Annex to the GCVTC report by October 1, 2000 containing details of SO2 program

– Plans implementing all of the recommendations had to be submitted to EPA by December 31, 2003

Five states submitted Section 309 plans

– AZ, NM, OR, UT, and WY

– Account for 75% of the SO2 emissions in the 9-state region

– These are the first plans ever completed to address regional haze

WRAP’s SO2 Annex

Developed by WRAP’s “Market Trading Forum”, which included state, tribal, federal, industry, and environmental representatives

Adopted by consensus of WRAP Board in September 2000

Sets declining SO2 milestones for 2003, 2008, 2013, and 2018– Covers all sources >100 tpy– Consistent with GCVTC goal of 50% to 70% reduction by 2040– Satisfies regional haze SO2 BART requirement for covered sources

Reductions achieved through voluntary actions with a backstop cap and trade program if goals are not met

– Compliance costs reduced by 40% relative to command-and-control

Contains provisions designed to provide economic equity to tribes

– 20,000 tons per year for tribes if trading program is triggered

Annex Milestones

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Air Pollution Prevention Strategies

GCVTC recommended...– Promotion of energy efficiency– 10% of region’s electricity from renewable sources by 2005 and

20% by 2015 Further analysis and plan development provided by the

WRAP’s “Air Pollution Prevention Forum” Highest-rated renewable energy policy options

– Renewable portfolio standard– Systems benefit charge– Green pricing– Tax incentives

Air Pollution Prevention

Highest-rated efficiency options– Rate payer-financed demand-side

management program– Tax incentives, efficiency

standards, rate reform, etc. Tribal-specific analyses and

recommendations also provided Forum analyzed economic impacts

of implementing the GCVTC goalsgiven best options identified above

Forum efforts contributed to the development of the Western Renewable Energy Generation Information System (WREGIS)

Annual Levelized Production Costs

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Air Pollution Prevention

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RPS recently considered RPS passed

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Certificates-based Other

Renewable Portfolio Standards Green Pricing Programs

Conclusions

In a relatively short time, the WRAP has become an effective means of building consensus and practical solutions to western air quality issues

– Programs tailored to Western needs that make real environmental progress while balancing energy and economic considerations

State resources (staff time, etc.) are utilized more efficiently and conflicts are minimized through a collaborative, regional process

Prospective

Air quality issues other than regional haze are of interest– Suite of NOx impacts including nitrogen

deposition and rural ozone– Regional market-based approaches for GHGs

Air quality is a component of energy policy– Air pollution often tertiary with respect to other

natural resource, environmental and quality of life concerns

– Institutions for energy policy largely separate from those for air pollution control

www.wrapair.orgwww.wrapair.org/forums/ap2/docs.html