Update on Modeling Topics

1. Update on Modeling Topics WESTAR Spring Meeting April 9, 2015 San Francisco, CA Richard A. (Chet) Wayland Director, Air Quality Assessment Division U.S. EPA Office of Air Quality Planning & Standards

2. Ozone Transport Update

3. Addressing Interstate Transport for 2008 Ozone NAAQS: EPA Roadmap Support State Plans (FIP Responsibility) – EPA stands ready to support and assist states Follow CSAPR Framework - update for 2008 ozone NAAQS (1) Identify downwind air quality problems – see Jan 22 memo (2) Identify upwind contributing states – use 1% NAAQS criteria (3) Identify emissions reductions to address significant contributions • NOx reductions from power plants that are cost-effective and achievable by 2017 • May only be partial remedy – approve as SIP strengthening (4) Establish compliance mechanism – seasonal emission budgets Other Factors – 176A petition, litigation on deadlines for acting on submitted SIPs, litigation on issuing findings of failure to submit SIPs, 2015 ozone NAAQS review, and analytical issues

4. Status of 2008 O3 NAAQS Transport Technical Work • On January 22 EPA released an informational memo on interstate transport for the 2008 ozone NAAQS. We also provided ozone transport data based on our preliminary modeling • EPA held a webinar on February 15 to discuss the memo and transport data • The preliminary modeling is based on emissions inventories that we released for comment in Nov 2013 and Jan 2014 • We are working to update our inventories based on these comments • The updated inventories will be used by EPA in a new round of transport modeling • For the preliminary modeling EPA used 2018 as the future analytic year because, at the time the modeling was conducted, this year aligned with the attainment date for moderate nonattainment areas. In view of the recent NRDCvs. EPA decision, we are going to use 2017 as the analytic year for the updated modeling • We plan to share the updated emissions inventories and air quality modeling when they become available this spring/summer

5. EPA-State Workshop on April 8 • Workshop in RTP on April 8, 2015 (10:15am – 4:30pm) • EPA is actively engaged in supporting state efforts to submit transport SIPs for the 2008 ozone NAAQS. • The workshop will facilitate discussions with states on available controls, potential EGU reductions, and EGU budgets at various cost levels • We are finalizing the agenda which will include presentations by States and by EPA 5

6. 176A Petition • We think that Clean Air Act section 110 provides an effective and proven mechanism for addressing regionally transported ozone pollution • Transport SIPs with enforceable requirements to reduce NOX, or a federal backstop, provide appropriate relief to downwind areas that are struggling to meet clean air standards can be a more efficient way than 176A to achieve the same air quality goals. • At this time, EPA is still reviewing the section 176A petition • We are currently updating our ozone transport air quality modeling. • This analysis will support the federal backstop that we are developing and inform our thinking on the section 176A petition.

7. WESTAR Comments on 2011 Platform

8. Topics 1) Fires 2) Oil and Gas Emissions 3) Canada & Mexico Emissions 4) Biogenics (MEGAN w/WRAP improvements) 5) Utility Projections (IPM) 6) Boundary Conditions/trans-Pacific transport 7) Model Evaluation

9. Fires • Comments: We should be using FETS for all fires including ag; we should not use 2011-specific fires in future years; we should have a collaborative process with Western states for better temporal/spatial representation of fires in base and future • Response (Part 1): • FETS is one of the sources of activity and fire type data used as input to SMARTFIRE for wild/prescribed fires, but it is not used for ag fires. We found FETS to be a very useful activity database and hope that we will continue to get FETS data for future NEI cycles. • WRAP Fires: We reviewed WRAP fires and did see differences from the 2011 NEI fires. We are evaluating both approaches to develop a more consistent method. We are conducting a sensitivity run to examine the impacts of including the FETS fires for Canada and Mexico in future versions of our platform • Ag fires: We have incorporated specific comments on the current ag fires approach in 2011NEIv2.

10. Fires • Response (Part 2): • Future years: Predicting future wildfires is difficult. Using fires from a specific year instead of averaged fires in modeling helps us to determine specific areas and times affected by fires that are associated with the meteorology in our modeling • Process/General: We convened a summit on fire emission inventory development in November, 2014. As a result, the National Fire Emissions Inventory (NFEI) workgroup was established and the first call was held on 3/26/15. Future calls will be held approximately monthly and the workgroup will serve as an advisory board for development of the 2014 NFEI.

11. Oil and Gas • Comment: EPA oil/gas tools are not sufficient and use numerous default assumptions that tend to overpredict emissions; our projections are not appropriate; we should work collaboratively to develop approaches for modeling and growth • Response (Part 1): • We have worked collaboratively to develop a tool that can be used nationally and accepts all inputs at the county-specific level, which some states have provided and much of which comes from state oil and gas commissions; we acknowledge the tool has some limitations and is not as detailed as the WRAP studies • A November 2014 summit brought together most interested parties at states, RPOs and EPA. There have been ongoing recurring workgroup meetings that discuss primarily base year oil and gas emissions, but are also considering future year characterization as a longer term process • When states submit their own data to EIS, we use it preferentially in the NEI

12. Oil and Gas • Response (Part 2): • We have coordinated with WRAP regarding the selection of oil and gas point sources and have employed a NAICS-based method to identify these sources in the 2011v6.2 platform • We are using speciation profiles from the WRAP studies in our platform • We have updated our projections to utilize the latest available AEO (2014) oil and gas production data with improved spatial resolution to specific oil and gas plays where available  • We have integrated state comments on drilling projections and created a nationally-consistent, AEO-based industrial source projection method for most non-production-related activities, including those at oil and gas facilities • We have included several new control programs such as the oil and gas NSPS, Natural Gas turbines NSPS, process heaters NSPS and RICE NESHAP and NSPS.

13. Canada & Mexico Emissions • Comment: EPA should update the emissions for Canada and Mexico and include emissions projection from these countries in future-year modeling • Response: • Canada: We have incorporated 2010 Canadian emissions, but we do not have any projected Canadian emissions and thus are holding Canadian emissions constant at 2010 levels • Mexico: We have incorporated data from the 2008 Mexico National Emissions Inventory (INEM) and have developed projections to 2018 and 2025 for use in future year modeling scenarios

14. Biogenics • Comments: MEGAN has improved emissions factors and land use over BEIS; we should perform sensitivity testing to determine which gives better performance; we should consider how biogenic emissions change in the future with respect to land use, climate change, fires, and invasive species • Response: • We have developed a new version of BEIS with updated land use, tree species, leaf temperature algorithm, and some new emissions factors, and have incorporated this into the 2011v6.2 modeling platform • We have run model sensitivities with BEIS 3.14 and MEGAN 2.1 and compared with field study measurements in Missouri and California. We found isoprene estimates from MEGAN to be higher than observations. Results of our analyses of MEGAN vs BEIS were presented at the Midwest Modeling Workshop and have been published in ES&T. • To account for future land use changes in biogenic emissions, such land use changes first need to be characterized. We are unaware of such data being available. Incorporating changes to biogenics due to fires, climate change, and invasive species may be considered as part of a longer-term research effort.

15. Utility Projections (IPM) • Comment: The Western grid is independent and dynamic; it is important to consider cost implications for regulatory requirements; renewables are increasing in importance; EPA should accept bottom up input from states; a single representation of the future will be uncertain • Response: • IPM regions (64 in all) provide a fairly detailed representation of generation and transmission. The NEEDS database represents the fleet for all EGUs supplying electricity to the grid • BART, CSAPR, and MATS are modeled (in addition other non-air EGU rules such as the cooling water intake rule and Coal Combustion Residual Rule) in the base case • Renewable Portfolio Standards targets are regularly updated and use the latest AEO information • The latest IPM base case using IPM v5.14 has been posted on the EPA power sector modeling web page • States are encouraged to submit their plant/unit level comments through our website www.epa.gov/powersectormodeling

16. Boundary Conditions • Comments: Long-range, international (e.g., Can/Mex), and stratospheric transport all have roles in North American ozone and we should evaluate global models to determine which provide the best performance for national modeling • Response: • Our multi-year set of GEOSChem data was evaluated, but there was not explicit evaluation for 2011 • Sensitivity modeling with hemispheric CMAQ for boundary conditions is planned • We believe that using the present BCs for the future is appropriate in light of the uncertainties in forecasting global inventories and the relatively near-term time horizon of most regulatory modeling

17. Model Evaluation • Comment: EPA should conduct model performance evaluations on the initial transport modeling and also after the V2-based improvements • Response: • Model evaluation for the preliminary 2011 modeling was performed and released in January as part of the Ozone Transport AQ Modeling TSD. • We will perform a second evaluation with 2011v6.2 platform • We plan to provide our model performance evaluations at appropriate times

18. WESTAR Comments on Ozone, PM2.5 & Regional Haze Modeling Guidance

19. Background • EPA released a new draft version of the ozone/PM2.5/RH modeling guidance in December 2014 • [Draft] Modeling Guidance for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze” • http://www.epa.gov/ttn/scram/guidance/guide/Draft_O3-PM-RH_Modeling_Guidance-2014.pdf • External review comments were due on March 13, 2015 • EPA received one set of comments from Western states (Nevada DEP)

20. Process for Reviewing Comments and Updating the Guidance • The OAQPS modeling guidance team will review the submitted comments during April to identify issues raised • Issues will be prioritized to help determine if/when guidance updates are needed • There may be several incremental guidance updates, depending on the nature of the comments and the timing of related rulemakings • In general, issues related to ozone and the ozone attainment test will be considered first • Any needed ozone related guidance updates will likely occur this summer • PM2.5 updates will be coordinated with the release of the final PM2.5 implementation rule (late 2015-early 2016) • Regional haze modeling updates will be coordinated with the revised Regional Haze Rule and related guidance (mid-2016)