New Mexico Pilot Dust Regional Haze State Implementation Plan for the Salt Creek Wilderness Area
Prepared By The State of New Mexico Environment Department Air Quality Bureau
EXECUTIVE SUMMARY
In the summer of 2002, the Western Regional Air Partnership (WRAP) Oversight Committees established a Dust Emissions Joint Forum (DEJF). The Forum concentrates on improving how dust emissions are estimated and assists in the development of tools to help states develop the dust related portion of their State Implementation Plans (SIP) required by the Regional Haze Rule.
To further assist states in the develop of their SIPs for dust, WRAP awarded grant funding to the State of New Mexico in 2005, to utilize and critique the tools developed by the forum for one of the Class I areas in New Mexico. The Class I area chosen for the Pilot Study is the Salt Creek Wilderness Class I area located in southeastern New Mexico near the City of Roswell, NM. The Salt Creek Class I area was chosen due to its marked increase in monitored coarse mass emissions, the major component of dust, for the site's 20% worst visibility days.
The tools evaluated for the Pilot Study include:
• Causes of Dust Analysis; • Fugitive Dust Emissions from Wind Erosion; • Fugitive Dust Handbook; • Dust Definition and Categorization Policy; • CMAQ Modeling for Fugitive Emissions; and • Weight of Evidence Checklist.
Along with the tools developed by WRAP for dust, supplemental projects based on the work done by WRAP were developed specifically for the Salt Creek area. The supplemental projects include:
• Identification of Source Areas Affecting Dust Concentrations at the Salt Creek, New Mexico; and • Application of the WRAP's Draft Definition and Categorization of Dust to the Salt Creek Class I Area, A Case Study.
As part of the Pilot Study, New Mexico was also charged with developing a template that states could use in developing the dust portion of their SIPs for Regional Haze. The template developed by the State of New Mexico for this study is only intended to be an example of how a SIP for dust might look like using the tools developed by the DEJF. The following study is by no means intended to represent the State of New Mexico's SIP submittal to the U.S. Environmental Projection Agency (EPA) for Regional Haze and should only be used at a state's own discretion.
ACRONYMS
AP-42 – Compilation of Air Pollutant Emission Factors Bext – measured light extinction BLM – Bureau of Land Management CAA - Clean Air Act CFR - Code of Federal Regulations CM – coarse mass CMAQ – congestion mitigation and air quality CODA – Causes of Dust Analysis COHA – Causes of Haze Assessment DV - deciviews DEJF – Dust Emissions Joint Forum EDMS – Emissions Data Management System EPA - U. S. Environmental Protection Agency GCVTC – Grand Canyon Visibility Transport Commission IMPROVE – Interagency Monitoring of Protected Visual Environments Mm-1 - inverse megameters MOA – memoranda of agreement NEAP – Natural Events Action Plan NEI – National Emissions Inventories NMED – New Mexico Environment Department NMAC – New Mexico Administrative Code NRCS – Natural Resources Conservation Services OBS - observed PM10 – particulate matter 10 microns in size and less PM2.5 – particulate matter 2.5 microns in size and less RACM – reasonably available control measures RMC – Regional Modeling Center RPG – Reasonable Progress Goal RPM – range management plan SACR – Salt Creek Wilderness Class I area SIP - State Implementation Plan SO2 - Sulfur Dioxide SOIL – fine soil TCEQ – Texas Commission on Environmental Quality TSS – Technical Support System USDA – United States Department of Agriculture VIEWS – Visibility Information Exchange Web System WEG – wind erodibility group WESTAR – Western States Air Resources WS4 – wind speeds >26 miles per hour WRAP – Western Regional Air Partnership
This is only a study developed for WRAP by the State of New Mexico. ii This is not intended to be New Mexico's Regional Haze State Implementation Plan.
TABLE OF CONTENTS EXECUTIVE SUMMARY ...... I ACRONYMS...... II INTRODUCTION ...... 1 REGIONAL HAZE RULE...... 1 STATE IMPLEMENTATION PLANNING REQUIREMENTS FOR 40 CFR §51.309 ...... 2 STATE IMPLEMENTATION PLANNING REQUIREMENTS FOR 40 CFR §51.308 ...... 2 VISIBILITY IN NEW MEXICO...... 3 NEW MEXICO 2003 SIP SUBMITTAL ...... 4 NEW MEXICO DUST STATE IMPLEMENTATION PLAN PILOT STUDY...... 6 OVERVIEW...... 6 PURPOSE OF PROJECT...... 7 Analysis of Tools...... 7 Template and Protocol...... 8 Conceptual Model ...... 9 SIP TEMPLATE/PROTOCOL ...... 9 Visibility Conditions ...... 9 Reasonable Progress Goals...... 12 Long Term Strategies ...... 13 Sources and Control Strategies...... 21 Monitoring Strategy and Emission Inventory ...... 37 CONCLUSIONS...... 39 DUST DEFINITION...... 39 FINE FRACTION OF FUGITIVE DUST...... 40 CAUSES OF DUST REGIONAL ANALYSIS/NEW MEXICO PILOT STUDY...... 40 CMAQ MODELING FOR FUGITIVE EMISSIONS...... 40 FUGITIVE DUST EMISSIONS FROM WIND EROSION ...... 41 FUGITIVE DUST HANDBOOK...... 41 WEIGHT OF EVIDENCE...... 42 OVERALL RECOMMENDATIONS ...... 42
FIGURES AND TABLES
FIGURE 1: VISIBILITY IMPAIRMENT IN BANDELIER NATIONAL PARK, NEW MEXICO ...... 4 TABLE 1: SUMMARY OF 309 SIP SUBMITTAL FOR NEW MEXICO ...... 4 FIGURE 2: STATE MAP OF NEW MEXICO...... 6 FIGURE 3: SALT CREEK WILDERNESS AREA...... 7 FIGURE 4: CURRENT AND DEFAULT NATURAL CONDITIONS FOR THE 20% BEST AND WORST VISIBILITY DAYS AT SACR...... 10 FIGURE 5: BASELINE CONDITIONS FOR THE 20% BEST AND WORST VISIBILITY DAYS AT SACR...... 10 FIGURE 6: BASELINE AND DEFAULT NATURAL DUST LIGHT EXTINCTION FOR SACR ...... 11 FIGURE 7: SOURCE CONTRIBUTIONS TO LIGHT EXTINCTION FOR 2002 ...... 11 FIGURE 8: UNIFORM RATE OF PROGRESS FOR VISIBILITY IN SACR ...... 12 FIGURE 9: UNIFORM RATE OF PROGRESS FOR DUST LIGHT EXTINCTION IN SACR...... 13 FIGURE 10: UPWIND TRANSPORT FROM NORTHERN TEXAS...... 15 FIGURE 11: UPWIND TRANSPORT FROM WESTERN AND NORTHERN TEXAS...... 15 FIGURE 12: WEG FOR WESTERN REGION OF TEXAS ...... 16 FIGURE 13: PREVAILING WIND DIRECTIONS FOR SACR...... 16 TABLE 2: AREA EMISSION INVENTORY FOR CIUDAD JUAREZ, MEXICO ...... 17 FIGURE 14: PERCENTAGE OF PM10 AREA SOURCE IN CIUDAD JUAREZ, MEXICO...... 18 FIGURE 15: PERCENTAGE OF PM2.5 AREA SOURCE IN CIUDAD JUAREZ, MEXICO...... 18
This is only a study developed for WRAP by the State of New Mexico. iii This is not intended to be New Mexico's Regional Haze State Implementation Plan.
FIGURE 16: AREA PM10 SOURCES FOR NORTHERN MEXICO...... 19 FIGURE 17: AREA PM2.5 SOURCES FOR NORTHERN MEXICO...... 19 TABLE 3: DUST SOURCES AND EMISSIONS FOR SACR...... 21 TABLE 4: SIGNIFICANT CONTRIBUTORS TO VISIBILITY IMPAIRMENT AT SACR ...... 22 FIGURE 18: SPATIAL DISTRIBUTION OF WINDBLOWN DUST INDEX FOR SALT CREEK WILDERNESS (2001-2003, SPRING, TRAJECTORY SPEED > 20 MILES/HOUR)...... 22 TABLE 5: CONTROL AND MITIGATION OPTIONS ...... 23 FIGURE 19: LAND TYPES FOR OIL AND GAS DEVELOPMENT IN CHAVEZ COUNTY ...... 25 FIGURE 20: SURFACE MANAGEMENT RESPONSIBILITY FOR SOUTHEAST NEW MEXICO ...... 26 TABLE 6: DUST CONTROL TECHNIQUES AND EFFICIENCIES ...... 28 TABLE 7: SUMMARY OF 2018 EMISSION REDUCTIONS ...... 29 TABLE 8: SUMMARY OF THE DEMONSTRATION OF MEETING 2018 REASONABLE PROGRESS GOALS...... 29 FIGURE 21: CMAQ MODELED 2002 DATA AND OBSERVED DATA ...... 30 FIGURE 22: TIME SERIES PLOTS FOR COARSE MASS AT SACR...... 31 FIGURE 23: TIME SERIES PLOTS FOR FINE SOIL AT SACR ...... 32 FIGURE 24: WINDBLOWN EMISSIONS FOR NEW MEXICO ...... 33 FIGURE 25: WINDBLOWN PM10 EMISSIONS FROM SHRUBLANDS ...... 33 TABLE 9: ALTERNATIVE DEMONSTRATION OF REASONABLE PROGRESS FOR 2018...... 35 TABLE 10: PRIMARY DUST EVENT TYPES IDENTIFIED FOR SACR 20% WORST VISIBILITY DAYS ...... 35 FIGURE 26: MEASURES LIGHT EXTINCTION FOR 20% WORST AND BEST VISIBILITY DAY...... 36 FIGURE 27: DUST SOURCES THAT AFFECT VISIBILITY AT SACR ...... 36
This is only a study developed for WRAP by the State of New Mexico. iv This is not intended to be New Mexico's Regional Haze State Implementation Plan.
INTRODUCTION
In 2005, the State of New Mexico was awarded grant funding from the Western Regional Air Partnership (WRAP) to develop a State Implementation Plan (SIP) Pilot Study on visibility impairment caused by dust in one of New Mexico's Class I areas. The purpose of this study was to utilize the Regional Haze SIP planning tools developed for establishing the impact of dust on visibility in Class I areas. Along with utilizing the tools, New Mexico was also charged with determining the effectiveness of the WRAP tools and ascertaining if any changes were needed. The Pilot Study will be available to other states to use as a template in developing the dust portion of their Haze SIPs. This study is not intended to be New Mexico's submittal to the U.S. Environmental Protection Agency (EPA) for Regional Haze. This is merely an exercise in utilizing the tools developed by WRAP for the dust portion of a Regional Haze SIP.
Regional Haze Rule In 1977, Congress amended the 1970 Clean Air Act (CAA) and declared the national visibility goal, which is as follows:
The prevention of any future, and the remedying of any existing, impairment in visibility in mandatory class I areas which impairment results from anthropogenic air pollution.
In accordance with requirements contained in the CAA, the EPA in 1980 promulgated its first visibility protection regulation [40 CFR 51.300 through 307]. Known as Phase I visibility protection, states were required to develop plans to address visibility impairment in mandatory federal Class I areas that is reasonably attributable to single sources or small groups of sources. Class I areas are those designated as areas of special national or regional value from a natural, scenic, recreational, and/or historic perspective. In response to this regulation, New Mexico developed and submitted to EPA a Phase I, Part I visibility SIP in 1986 and a Phase I, Part II visibility SIP in 1992. The Phase I SIP was divided into two parts as a result of litigation following the promulgation of the federal regulation.
The Environmental Protection Agency adopted the Regional Haze Rule in 1999. This rule is intended to improve visibility in all Class I areas over the next 60 years. It focuses on improving Class I area visibility on the haziest days (the worst 20%) and ensuring no degradation on the clearest days (the best 20%). For the first time, states will be required to work together to improve visibility through interstate planning and implementation of regional strategies. States must revise their SIPs as part of this process.
New Mexico is one of nine Western States that has two options for implementing this rule. The other states are: Arizona, Colorado, Oregon, Utah, Wyoming, Idaho, Nevada and California. These states were part of a four-year regional haze study conducted by the Grand Canyon Visibility Transport Commission (GCVTC). In 1996 the GCVTC concluded this study, and recommended a comprehensive set of strategies to improve regional haze in the Grand Canyon and surrounding Class I areas of the Colorado Plateau. These strategies went through an extensive stakeholder-consensus process, and were later incorporated into Section 309 of the Regional Haze Rule by EPA. The nine states have the option of adopting these strategies, which
This is only a study developed for WRAP by the State of New Mexico. 1 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
would apply until 2018. New Mexico's SIP implements the GCVTC strategies for protecting the 16 Class I areas of the Colorado Plateau.
State Implementation Planning Requirements for 40 CFR §51.309 For those states that submit under the Section 309 option of the Regional Haze Rule, an assessment of reasonable progress is required for the remaining Class I areas that are not on the Colorado Plateau. Additional strategies may be required above and beyond those established by the GCVTC for the remaining Class I areas. The SIP requirements for Section 309 include the following. • Implementation of Measures • Summary of Emission Reductions • Current visibility conditions for the most impaired and least impaired days • Difference between current visibility conditions for the most impaired and least impaired days and baseline visibility conditions • Change in visibility impairment for the most impaired and least impaired days over the past 5 years • Tracking the change over the past 5 years in emissions of pollutants • Limited or impeded progress over last five years from anthropogenic sources • Assessment of the current implementation plan elements and strategies • Review of the State's visibility monitoring strategy
State Implementation Planning Requirements for 40 CFR §51.308 Section 308 requires states to develop new regional haze strategies, and make a reasonable progress demonstration. All Class I areas that are not located on the Colorado Plateau are required to comply with the requirements of Section 308, which includes Class I areas in States that originally choose the 309 option. The SIP requirements of Section 308 include the following.
VISIBILITY CONDITIONS (40 CFR §51.308(d)(2)): • Establish current/baseline visibility conditions; • Determine natural background visibility conditions; • Project visibility conditions in 2018 (based on existing and known control programs); and • Calculate number of deciviews (dv) by which baseline conditions exceed natural conditions.
REASONABLE PROGRESS GOAL (40 CFR §51.308(d)(1)): • Establish uniform rate of progress (glide path) from current to natural conditions in 2064; • Determine visibility conditions in 2018 (based on existing, known and planned controls); • Reconsider other sources and controls if appropriate; • Set a reasonable progress goal; and • Explain relation of reasonable progress goals (RPG) to uniform rate of progress.
This is only a study developed for WRAP by the State of New Mexico. 2 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
LONG-TERM STRATEGY (40 CFR §51.308(d)(3)): • Identify Class I areas for which more than one state is “reasonably anticipated to contribute to visibility impairment”; • Identify states which have an obligation to reduce emissions in those Class I areas; • Agree on state apportionment of emission reduction obligations; • Coordinate emission management strategies to achieve RPG; and • Include in SIP all measures necessary to obtain share of emission reductions.
SOURCES AND CONTROL STRATEGIES (40 CFR §51.308(d)(3)(V)): • Identify man-made sources of haze; • Identify which sources have control options; • Develop control measures; • Evaluate sources to control; • Determine what measures are reasonable; and • Include emission reductions due to ongoing programs.
Visibility in New Mexico While New Mexico's residents and visitors frequently enjoy good visibility, air pollutants interfering with light transmission can impose limitations on aesthetic appreciation of scenery. Visibility is the term used to characterize physical limitations in the atmosphere that affect our ability to see clearly. Human caused pollution of varied concentrations and sizes in the atmosphere can impair or reduce visibility. Widespread visibility impairment caused by pollutants from a variety of sources and activities over a broad geographic area is known as regional haze. State Regional Haze SIPs must be compiled in accordance with the requirements of Title 40 of the Code of Federal Regulations, Part 51, Section 309 or Section 308 (40 CFR §51.309).
Good visibility is essential to the enjoyment of national parks and scenic areas. Regional haze is air pollution that is transported long distances and reduces the visibility in these areas. Across the country, regional haze has decreased visibility from 140 miles to 35-90 miles in the West, and from 90 miles to 15-25 miles in the East. The source of this haze is a combination of industry, motor vehicles, agricultural and forestry burning, and windblown dust. Particles and gases released into the atmosphere either scatter or absorb light. Light scattering and absorption reduces the amount of light the human eye receives from a viewed object and diminishes resolution and contrast. The effects include degradation of color, flattening or blurring of textures, and blocking of landscapes, resulting in the reduction or loss of aesthetic value. Visibility impairment can occur across state and international borders and at locations far from pollution sources. Figure 1 shows the degradation of visibility in Bandelier National Park located in northern New Mexico.
This is only a study developed for WRAP by the State of New Mexico. 3 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 1: Visibility Impairment in Bandelier National Park, New Mexico
Bandelier National Park, New Mexico Bandelier National Park, New Mexico Visual range 370 km Visual Range 90 km
New Mexico 2003 SIP Submittal For the initial Regional Haze SIP submitted to EPA in December of 2003, New Mexico chose the 309 option of the Regional Haze Rule (40 CFR §51.309.) The Regional Haze Rule’s Section 309 incorporates the recommendations of the GCVTC, which were developed through a consensus-based process that involved states, tribes, EPA, federal land managers, industry, citizens and environmental groups from the west. New Mexico was an active participant in the process, as were New Mexico tribal governments, industry representatives and environmental groups. The State of New Mexico has chosen to pursue the path outlined in Section 309 in addressing regional haze. The 309 option allows eligible states such as New Mexico the opportunity to use pre-identified and comprehensive strategies to meet the Regional Haze Rule out to the year 2018. After that date, Section 308 applies. It should be noted that Section 309 does not require a reasonable progress demonstration, as the GCVTC strategies have been determined to make reasonable progress for the Class I areas on the Colorado Plateau out to the year 2018.
The following table summarizes the 2003 SIP submittal from New Mexico to EPA.
Table 1: Summary of 309 SIP Submittal for New Mexico Projection of visibility Projected visibility improvement for each of the Class I areas on the improvement Colorado Plateau (San Pedro Parks Wilderness in New Mexico) Clean Air Corridors Emission growth either inside or outside of the Clean Air Corridor are not shown to be contributing to impairment within the Clean Air Corridor
Stationary Sources of SO2 This section includes milestones for sulfur dioxide emissions along with a backstop market cap and trade program for sulfur dioxide emissions from specific sources. Mobile Sources Federal programs (such as low sulfur diesel, vehicle emission standards, etc.) lead to decreasing mobile source emissions throughout the planning period.
This is only a study developed for WRAP by the State of New Mexico. 4 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Programs Related to Fire New Mexico has developed a smoke management regulation (20.2.65 NMAC) that is responsive to the WRAP Enhanced Smoke Management Programs for Visibility Policy.
Paved and Unpaved Road Dust emissions are not a significant contributor to visibility Dust impairment within the Colorado Plateau 16 Class I areas. Pollution Prevention Programs and policies within New Mexico related to renewable energy and energy efficiency are described. New Mexico's anticipated contribution to the pollution prevention goals are outlined. Additional New Mexico has not identified any other recommendations in the Recommendations Grand Canyon Visibility Transport Commission Report to implement in New Mexico at this time. Periodic Revisions New Mexico will submit period revisions to this SIP every five years as required by the Regional Haze Rule. State Planning and New Mexico has participated in the WRAP and will continue to Interstate Coordination participate in the WRAP. In addition, New Mexico participates with the Joint Advisory Council on US/Mexico border issues. Geographic Enhancement As New Mexico does not have an approved SIP for reasonably attributable visibility impairment at this time, New Mexico is deferring the geographic enhancement option until a later date. Reasonable Progress for New Mexico intends to follow Section 309(g)(2) for the eight Additional Class I Areas additional Class I areas in New Mexico.
This is only a study developed for WRAP by the State of New Mexico. 5 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
NEW MEXICO DUST STATE IMPLEMENTATION PLAN PILOT STUDY
Overview Salt Creek Wilderness Area (SACR) was chosen for the Pilot Study due to the location's marked increase in coarse material on the 20% worst days for visibility. This region of the state has also historically had air quality issues with coarse particulate matter, particularly from high wind events.
Figure 2: State Map of New Mexico
Salt Creek
Source: NMED
This is only a study developed for WRAP by the State of New Mexico. 6 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
The Salt Creek Wilderness area is located in the southeastern region of New Mexico, near the City of Roswell. The wilderness area is part of the Bitter Lake National Wildlife Refuge. There are approximately 9,621 acres in the Bitter Lake National Wildlife Refuge. The predominate vegetative cover for SACR is native grasses and shrubbery. The Class I area is characterized by dry creek beds, sand dunes, and gypsum sinkholes.
Figure 3: Salt Creek Wilderness Area
Source: Salt Creek Site Visit March 2006
Purpose of Project
Analysis of Tools The purpose of the Pilot Study is to test and demonstrate how various WRAP technical and policy products can be utilized to address the contribution of dust to regional haze at Class I areas in the WRAP region. Strengths and weaknesses of the WRAP products are identified so that needed adjustments can be made before state and tribal implementation plans are finalized in 2007. Results will be shared with other WRAP members to inform their planning and assessment processes. The WRAP products evaluated in the study include the following:
• Causes of Dust Analysis (Desert Research Institute) – Assessment of the principal causes of dust-resultant haze at Interagency Monitoring of Protected Visual Environments (IMPROVE) sites in the Western United States;
• Fugitive Dust Emissions from Wind Erosion (ENVIRON and the University of California at Riverside) – The modeling methods and results for obtaining a 12-km resolution 2002 wind blown dust emissions inventory for the WRAP region, as well as an inventory for adjacent regions;
• Fugitive Dust Handbook (Countess Environmental and Midwest Research Institute) – The handbook addresses the estimation of uncontrolled fugitive dust emissions and This is only a study developed for WRAP by the State of New Mexico. 7 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
emission reductions achieved by demonstrated control techniques for thirteen major fugitive dust source categories: agricultural tilling, construction and demolition, materials handling, paved roads, unpaved roads, agricultural harvesting, mineral products industry, abrasive blasting, livestock husbandry, and miscellaneous sources, as well as windblown dust emissions from agricultural fields, material storage piles, and exposed open areas;
• Dust Definition and Categorization Policy (ENVIRON) –A definition of fugitive dust, including the distinction between anthropogenic and natural sources;
• CMAQ Modeling for Fugitive Emissions – Identification, evaluation, the performance of, and application of mathematical air quality modeling planning tools which are used to quantify the effects of alternative emission management options upon the air quality of the western United States; and
• Weight of Evidence Checklist - Incorporates all available regional and local data analyses which bear on specific Class I areas. A check list of available analyses and other resources which states and tribes are encouraged to use to understand visibility in their Class I areas.
Along with the tools developed by WRAP for dust, supplemental projects based on the work done by WRAP were developed specifically for the SACR. The supplemental projects include the following.
• Identification of Source Areas Affecting Dust Concentrations at the Salt Creek, New Mexico – A continuation of the Causes of Dust Analysis developed by DRI; and
• Application of the WRAP's Draft Definition and Categorization of Dust to the Salt Creek Class I Area, A Case Study – Case study for the Dust Definition developed by ENVIRON. The project also includes a localized emission inventory for the Class I area.
Template and Protocol The purpose of the Pilot Study is to not only utilize and critique the tools developed by WRAP, but to also provide a SIP template for other states to use in their SIP development process. The template language used for the Pilot Study was taken from the Regional Haze State Implementation Plan Templates developed by Western States Air Resources (WESTAR) Council. To further assist states in the SIP development process, for each section under the SIP template there is protocol information that explains what information was used to develop that particular section. The information in the protocol section includes tools developed by WRAP and other resources used in the Salt Creek dust SIP template development process. The template language in the following sections is not intended to be the Regional Haze SIP submittal for the State of New Mexico. This portion of the study was developed as a resource guide to show how the WRAP tools developed by the Dust Forum would be utilized in the dust portion of the Regional Haze SIP process.
This is only a study developed for WRAP by the State of New Mexico. 8 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Conceptual Model As part of the Pilot Study SIP development, portions of the conceptual model developed by ENVIRON in the Dust Definition project were incorporated into the Regional Haze Rule SIP requirements. These portions of the conceptual model help to clarify Section 51.308(d)(3)(iv) of the Regional Haze Rule requiring the identification of anthropogenic dust sources. The Dust Definition conceptual model provides guidance on identifying dust sources, determining high priority dust sources, identifying which sources have potential controls/mitigation, and determining available data resources and methods. The Case Study developed for SACR using the Dust Definition gives an example as to how the model for a Class I area is developed and used. See Appendix A for the Salt Creek Dust Definition Case Study.
SIP Template/Protocol The following is the SIP template created for the Pilot Study. The information provided in italics is the protocol used for developing the SIP template. The template is broken down into the following categories required under 40 CFR §51.308(b) through (e) of the Regional Haze Rule: • Visibility Conditions; • Reasonable Progress; • Long Term Strategies; and • Sources and Control Strategies.
Visibility Conditions Pursuant to the requirements of 40 CFR §51.308(d)(1) for determining reasonable progress, an analysis must be completed including a comparison of baseline conditions to natural conditions. The State of New Mexico has established the baseline/current and natural conditions for SACR.
Baseline/Current and Natural Conditions Natural background represents the visibility goal for this area to be reached in 2064, visibility representative of the conditions before man impacted this area. The Salt Creek Class I area has an established Natural Background of 1.86 deciviews (dv) for the cleanest 20 % of the days and for the 20 % worst visibility days were 6.98 dv. This is based on on-site data at the SACR IMPROVE monitoring. A five year average (2000 to 2004) was calculated in accordance with published EPA guidance documents. The deciview visibility for these worst and best days are based on calculations and data developed by WRAP. Figure 4 shows the current and default natural conditions for SACR.
This is only a study developed for WRAP by the State of New Mexico. 9 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 4: Current and Default Natural Conditions for the 20% Best and Worst Visibility Days at SACR
Source: WRAP Technical Support System
The Salt Creek Class I area has a Baseline visibility of 7.84 dv for the 20% best visibility days and 18.0 dv for the 20% worst visibility days for this first SIP submittal. These best and worst 20 % conditions are also calculated using EPA guidelines.
Figure 5: Baseline Conditions for the 20% Best and Worst Visibility Days at SACR
Source: WRAP Technical Support System This is only a study developed for WRAP by the State of New Mexico. 10 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Dust Light Extinction The predominate source of visibility impairment in the SACR is dust, which consists of coarse mass and fine soil. The baseline coarse mass light extinction (bext) for Salt Creek is 11.47 inverse megameters (Mm-1). For fine soil it is 3.4 Mm-1. The default natural dust light extinction is 1.8 Mm-1 for coarse mass and 0.5 for fine soil (Figure 6). Figure 7 shows that the Salt Creek light extinction from coarse mass is 24.2% and fine soil is 4.1% of the total light extinction for the 20% worst days and 25.5% and 4.2% for the 20% best.
Figure 6: Baseline and Default Natural Dust Light Extinction for SACR
Source: WRAP Technical Support System
Figure 7: Source Contributions to Light Extinction for 2002
Source: WRAP Technical Support System
This is only a study developed for WRAP by the State of New Mexico. 11 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
PROTOCOL:
Baseline conditions can be determined through EPA Guidance for Tracking Progress under the Regional Haze Rule or WRAP Technical Support System (TSS). Natural conditions for a Class I Area can be determined from EPA Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program or the TSS web site. Light extinction for coarse mass can also be determined through the TSS web site and/or Causes of Haze Assessment web site (COHA). Monitoring data for Class I areas is available on the Visibility Information Exchange Web System (VIEWS) or the TSS web site. For this study the EPA Guidance for Tracking Progress under the Regional Haze Rule, Estimating Natural Visibility Conditions Under the Regional Haze Program, TSS and VIEWS were used to determine baseline and natural conditions.
Reasonable Progress Goals
Establish Uniform Rate of Progress Salt Creek must show a visibility improvement of 2.578 dv to ensure improved visibility for the most impaired days, and no degradation for the least impaired days over the period of this implementation plan, i.e., from the date of approval until July 31, 2018. Progress will be reported to the EPA every five years in accordance with 40 CFR §51.308(g). This reasonable progress goal is based on an analysis of visibility conditions, including a comparison of baseline conditions to natural visibility conditions, which shows that 11.05 dv of improvement is necessary by the year 2064 to achieve natural visibility conditions. The uniform rate of improvement is .184 dv per year. Considering that rate over the time period of this SIP, an improvement of 2.578 dv would result by the year 2018.
Figure 8: Uniform Rate of Progress for Visibility in SACR
Source: Wrap Technical Support System
This is only a study developed for WRAP by the State of New Mexico. 12 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 9 shows the uniform rate of progress for dust light extinction needed in SACR. The glide path shows a needed visibility improvement of 0.208 Mm-1 for coarse mass and 0.052 Mm-1 for fine soil to meet reasonable progress goals.
Figure 9: Uniform Rate of Progress for Dust Light Extinction in SACR
Source: Wrap Technical Support System
Protocol:
Reasonable progress goal (RPG) and rate of progress (ROP) can be determined through EPA Guidance for Tracking Progress under the Regional Haze Rule or through the WRAP TSS. To determine the RPG and ROP the natural and baseline conditions must be used. IMPROVE monitoring data is available on VIEWS and TSS. For this study the EPA Guidance for Tracking Progress under the Regional Haze Rule, TSS web site, and VIEWS web site were used.
Long Term Strategies
Section 51.308(d)(3) requires the states to submit a long-term strategy that addresses regional haze visibility impairment for each mandatory Class I Federal area within and outside the state which may be affected by emissions from within the state. For the Salt Creek Class I area, based on site visits, emission inventories, modeling and monitoring data, it was determined that the dust from local and regional anthropogenic sources are the major source of visibility impairment.
Coordination with Other States and Countries New Mexico has completed consultation with other states and tribes. New Mexico has participated in the WRAP process that developed technical information necessary for
This is only a study developed for WRAP by the State of New Mexico. 13 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
development of coordinated strategies. New Mexico then coordinated with Texas on detailed modeling that was used to develop the state’s long-term strategy. Strategy development considered the impacts of the state’s emissions on Class I areas within and outside the state. New Mexico coordinates with Mexico through the Joint Advisory Committee.
Share of emission reductions Section 51.308(d)(3)(ii) requires New Mexico to demonstrate that its implementation plan includes all measures necessary to obtain its fair share of emission reductions needed to meet reasonable progress goals.
Modeling referenced in the Documentation of Modeling, Monitoring, and Emission Inventory Section below demonstrates that the state’s long-term strategy when coordinated with other state’s strategies is sufficient to meet reasonable further progress goals. All measures reflected in the modeling have been incorporated in the state’s long-term strategy. In the Sources and Control Strategy Section below provides information on these measures.
Contributions from Other States and Countries As a means of identifying the primary causes of dust measured in the WRAP region, the Causes of Dust Analysis (CODA) was developed for the western United States (U.S.). From the Causes of Dust Analysis, a separate study was developed for SACR. Both studies showed, through back trajectory analysis, that Salt Creek is impacted to a degree by wind blown dust from both Texas and Mexico.
A. Contributions from Texas From the back trajectory analysis, it appears that Salt Creek might be affected by portions of the western and panhandle regions of Texas (Figures 10 and 11). The counties include Andrews, Loving, and Winkler in the western portion and Briscoe, Motley, Hall, Conley, Collingsworth, Wheeler, Grey, Hemphill, Cochran, Lamb, Yoacum, Bailey, and Hoakley in the northeastern region of Texas. These areas appear to be predominately grasslands, shrublands, and croplands.
This is only a study developed for WRAP by the State of New Mexico. 14 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 10: Upwind Transport from Northern Texas
Source: DRI Causes of Dust Study (New Mexico Pilot Study)
Figure 11: Upwind Transport from Western and Northern Texas
Source: DRI Causes of Dust Study (New Mexico Pilot Study)
The Wind Erodibility Group (WEG) from the United State Department of Agriculture (USDA) Natural Resources Conservation Services (NRCS) was used to determine if these areas could be This is only a study developed for WRAP by the State of New Mexico. 15 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
contributors through high wind events. Under the WEG, the lower the number is the more erodible the soil is, 1 being the most erosible and 8 being the least. The following graphic shows the WEG for Loving County, Texas. This WEG is fairly indicative of what is seen in the western and northern region of the state regarding erodibility, although the northeastern region of the state tends to be less erodible than the soils in the western region. See Appendix B for the other contributing counties in Texas.
Figure 12: WEG for Western Region of Texas
Source: NRCS
B. Contributions from Mexico The trajectory analysis showed that Salt Creek could potentially be affected by air masses passing through northern Mexico and Baja California. Dust concentrations associated with strong winds (WS4, surface winds > 26 miles/hour) were determined from the south/southwest and the north/northeast corridors.
Figure 13: Prevailing Wind Directions for SACR
Source: DRI Causes of Dust Study (New Mexico Pilot Study)
B.1. Emissions from Ciudad Juarez In 2003, the Texas Commission of Environmental Quality (TCEQ) developed an area source emission inventory for Ciudad Juarez, Chihuahua, Mexico. Ciudad Juarez is located on the This is only a study developed for WRAP by the State of New Mexico. 16 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
U.S./Mexico Border south of Texas and New Mexico. Past emission inventory studies have shown that Juarez contributes significant amounts of air pollution to the north affecting both Texas and New Mexico. The inventory developed by TCEQ in 2003 was only for area source pollution in Ciudad Juarez. Table 2 and Figure 14 show which sources were inventoried in Ciudad Juarez for particulate matter and what those emissions are.
Table 2: Area Emission Inventory for Ciudad Juarez, Mexico
Source Category PM10 TPY PM2.5 TPY Brick Kilns 269.8 269.8 Open Burning 193.5 177.2 Fertilizers N/A N/A Pesticides N/A N/A Agricultural Burning 18.0 17.0 Agricultural Tilling 581.1 128.8 Feedlots and Dairies 1,011.6 151.7 Livestock N/A N/A Structural Fires 0.3 0.3 Wind Erosion 3,687.8 817.6 Fuel Combustion – Comm. 18.2 12.1 Fuel Combustion – Res 3,843.8 3,701.5 Construction 77.4 16.1 Consumer Solvents N/A N/A Domestic Ammonia N/A N/A Paved Roads 3,689.6 882.3 Unpaved Roads 14,981.2 2,189.6 Border Crossings Total 28,372.3 8364 Source: TCEQ
This is only a study developed for WRAP by the State of New Mexico. 17 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 14: Percentage of PM10 Area Source in Ciudad Juarez, Mexico
Source: Development of an Area Source Emission Inventory for Ciudad Juarez, Chihuahua, Mexico
Unpaved road dust is responsible for the majority of PM10 emissions in Ciudad Juarez, followed by wind erosion and paved road dust (each 13% of the total). Residential fuel combustion (mainly wood) emits the most PM2.5 emissions (44% of the total), followed by unpaved road dust (26%). Paved road dust and wind erosion are responsible for 11% and 10%, respectively, of the total PM2.5 emissions from area wide sources.
Figure 15: Percentage of PM2.5 Area Source in Ciudad Juarez, Mexico
PM2.5
Brick Kilns Other 3% Wind Ero s io n 6% 10%
Unpaved Roads 26%
Fuel Combustion Paved Roads – Residential 11% 44%
Source: Development of an Area Source Emission Inventory for Ciudad Juarez, Chihuahua, Mexico
This is only a study developed for WRAP by the State of New Mexico. 18 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
B.2. Emission from Northern Mexico From the back trajectory analysis it appears that the two states in Mexico that could potentially contribute to visibility impairment in SACR are Chihuahua and Baja California. A National Emission Inventory (NEI) was developed for Northern Mexico in 2004 for the inventory year of 1999. To determine Chihuahua and Baja California's contribution to dust in the Mexico NEI, 1999, it was established that the two states combined contributed 35% of the PM10 and 34% of the PM2.5 emissions from the area sources inventoried. From the area sources inventoried, unpaved and paved road dust are the most significant contributors to PM10 and PM2.5 emissions.
Figure 16: Area PM10 Sources for Northern Mexico
1% 1% 1% 2%
Open burning – Waste Agricultural burning 38% Wood- Fuel combustion Agricultural tilling 57% Paved road dust Unpaved road dust
Source: Mexico National Emission Inventory, 1999
Figure 17: Area PM2.5 Sources for Northern Mexico
3% 4% 5% 2% Open burning – Waste 42% Agricultural burning Wood- Fuel combustion Agricultural tilling Paved road dust Unpaved road dust 44%
Source: Mexico National Emission Inventory, 1999
PROTOCOL: This is only a study developed for WRAP by the State of New Mexico. 19 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
The WRAP tools available to for determining the impacts from other states include Assessment of the Principal Causes of Dust-Resultant Haze at IMPROVE Sites in the Western United States and the Weight of Evidence Checklist on the TSS web site. To determine impacts from Texas and Mexico, New Mexico used the Assessment of the Principal Causes of Dust-Resultant Haze at IMPROVE Sites in the Western United States by Desert Research Institute(DRI). Along with the Assessment of the Principal Causes of Dust, DRI also developed a supplemental study for Salt Creek called the New Mexico Pilot Study. Other resource tools used include the Mexico National Emission Inventory, 1999; Development of an Area Source Emission Inventory for Ciudad Juarez, Chihuahua, Mexico; 2001 Air Emission Inventory: Guadalupe National Park, Texas; and the Natural Resources Conservation Services Web Soil Survey .
Documentation of Modeling, Monitoring, and Emission Inventory States are required under Section 51.308(d)(3)(iii) of the Regional Haze Rule to document the technical basis for the state’s apportionment of emission reductions necessary to meet reasonable progress goals in each Class I area affected by the state’s emissions. The technical analyses developed by the WRAP demonstrate that the state’s emission reductions, when coordinated with those of other states, are sufficient to achieve the reasonable progress goals in Salt Creek.
The demonstration of attainment of reasonable progress goals relies on the use of monitored and modeled data to determine whether visibility is improved on days when it is usually poor and does not deteriorate on days when it is usually good. Current visibility is estimated from monitored components of PM2.5 and PM10. Models are used in a relative sense to estimate how current concentrations respond to emission reduction measures. Current concentrations of particulate matter components are adjusted by the relative modeled response to estimate concentrations at the end the first implementation period in 2018. Future visibility is estimated from estimated component concentrations of fine and coarse particulate matter at the end of the first implementation period. The difference between present visibility and future estimated visibility is compared with the reasonable progress goal to determine if the goal is met.
The WRAP technical information on current visibility conditions for SACR is found in Appendix C. WRAP technical information on current and projected inventories and on regional modeling are found in the Appendices D, E, and K. The Appendices also include the technical report on long-term strategy modeling performed by New Mexico and Texas to demonstrate meeting reasonable progress goals. This is ongoing. No additional information is currently available on this effort.
A baseline inventory for each Class I Area must be developed as a means of establishing long- term strategies. For the Salt Creek Wilderness Area, New Mexico used a combination of the 2003 Emission Data Management System (EDMS) inventory and a local/regional emission inventory developed for the Salt Creek area as its baseline inventory. See Appendices C, D, E and K for monitoring, emission inventory, and modeling data.
PROTOCOL:
For the documentation of monitoring, modeling, and emission inventory data for dust, the following WRAP resources were used. For monitoring data, Excel databases were downloaded This is only a study developed for WRAP by the State of New Mexico. 20 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
from the VIEWS Annual Summary section. For modeling data, the modeling results available under the Visibility Modeling section of the WRAP Regional Modeling Center (RMC) were used. Emission inventory data was downloaded from the WRAP In and Near Emissions web site and the Salt Creek local/regional emission inventory. Other options for monitoring data include the COHA web site, the TSS web site, and Interagency Monitoring of Protected Visual Environments (IMPROVE) web site. For modeling data, information is also available at the TSS web site. Other Information on emission inventory data is available on the TSS web site and from the WRAP Emission Data Management System.
Sources and Control Strategies
Identification and Characterization of Dust Sources Section 51.308(d)(3)(iv) requires that states identify all anthropogenic sources of visibility impairment considered by the state in developing its long-term strategy. For this particular study, New Mexico identified and characterized what sources of dust affect visibility in SACR. To identify what sources of dust are contributing to visibility impairment in Salt Creek, a local area emission inventory for dust was developed. This inventory expanded on the information developed in the Near Emissions study conducted by WRAP (see Appendix D). The inventory is based on a 100 kilometer (km) buffer around SACR. The inventory includes portions of Chaves, Curry, De Baca, Eddy, Guadalupe, Lea, Lincoln, Otero, and Roosevelt Counties. The purpose of the inventory is to determine emissions and which contributing dust sources are anthropogenic and which are natural. See Appendix D for the complete area source dust emission inventory. Along with the local area source inventory, a case study (see Appendix A) was developed using the Definition of Dust created by the WRAP. Table 3 lists and characterizes those dust sources determined to impact visibility in SACR.
Table 3: Dust Sources and Emissions for SACR Source PM10 *PM2.5 PM10 *PM2.5 Fugitive Dust Fugitive Dust Windblown Windblown Emissions Emissions Emissions Dust Dust Emissions (tons/yr) (tons/yr) (tons/yr) (tons/yr)
Mining 876.0 87.6 N/A N/A Oil and Gas N/A N/A 1,645.0 164.5 Unpaved Roads 274.4 27.4 588.0 58.8 Paved Roads 322.5 32.3 N/A N/A Construction Activities 1,827.0 182.7 630.35 63.04 Agriculture 2,026.0 202.6 63.0 6.3 Industrial Sources 138.5 13.85 N/A N/A Undisturbed N/A N/A 19,109.0 1,910.9 Shrublands/Grasslands Total 5,464.4 546.5 22,035.35 2,203.54 * PM2.5=0.1(PM10)
Identify High Priority Dust Sources To develop long term strategies for dust sources in a Class I Area, dust sources must be prioritized to determine which sources are the most significant. Table 4 identifies those sources This is only a study developed for WRAP by the State of New Mexico. 21 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
that are considered significant contributors to dust emissions in Salt Creek and by what means visibility impairment occurs. Appendix A contains the source categories and rankings for each dust source. The Causes of Dust Analysis developed for SACR (Appendix F) determined that windblown dust events account for 94% of the 20% worst visibility days at SACR. The above emission inventory shows that fugitive emissions from significant sources do account for a portion of the visibility impairment at SACR, but a majority of the visibility impairment is the result of high wind events that the area normally experiences during the spring months of March- May. Figure 18 shows a back trajectory analysis done for windblown dust during the spring months from 2001-2003.
Table 4: Significant Contributors to Visibility Impairment at SACR Source Category Means of Visibility Impairment Undisturbed Natural Windblown Shrublands/Grasslands Open Land/ Cattle Grazing Natural/Anthropogenic Windblown Oil and Gas Anthropogenic Windblown/Mechanical Unpaved Roads Anthropogenic Windblown/Mechanical Construction Anthropogenic Windblown/Mechanical Agriculture Anthropogenic Windblown/Mechanical Mining Anthropogenic Windblown/Mechanical
Figure 18: Spatial distribution of Windblown Dust Index for Salt Creek Wilderness (2001- 2003, Spring, Trajectory speed > 20 miles/hour)
Source: DRI Causes of Dust Study (New Mexico Pilot Study)
This is only a study developed for WRAP by the State of New Mexico. 22 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Identify Which Sources Have Controls or Mitigations As a means of establishing strategies, a state must determine which of the sources identified are controllable or have mitigation options. This will narrow which sources can be controlled and which ones really cannot, especially those sources that are deemed both natural and anthropogenic in nature. The following table lists those sources that can be controlled, what control or mitigation options are available, and the status of their implementation.
Table 5: Control and Mitigation Options Sources Control/Mitigation Options Status Construction • Local Dust Control Ordinance • Future • State-wide Dust Control • Future Regulation Oil and Gas • Dust Control Plan • Future Exploration • Reclamation Requirements • Existing • Memorandum of Understanding • Future with Federal Land Managers • State-wide Dust Control • Future Regulation Unpaved Roads • Local Dust Control Ordinance • Future • State-wide Dust Control • Future Regulation Agricultural • Natural Resources Conservation • Existing Service Best Available Control Methods • Memorandum of Understanding • Future • State-wide Dust Control • Future Regulation Mining • Permit Requirements • Existing • State-wide Dust Control • Future Regulation
Identify Available Data Resources and Methods New Mexico evaluated monitoring and emission inventory information provided by WRAP to identify what available data resources and methods were available to develop its long-term strategy.
PROTOCOL:
Identification of dust sources can be determine through the use of the following WRAP tools: Dust Definition; Fugitive Dust Emissions from Windblown Erosion; Stationary and Area Source Pivot Tables; In and Near Emissions; and EDMS. Other resources for identification of dust sources include site visits; use of aerial photography, i.e. Google Earth; and local/regional emission inventories. For this study the Dust Definition; Fugitive Dust Emissions from Windblown Erosion; site visits; and the Salt Creek local/regional emission inventory were used. To identify high priority dust sources the resources used for this study include the Dust Definition; site visits; and the local/regional emission inventory. In determining which dust This is only a study developed for WRAP by the State of New Mexico. 23 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
sources have control or mitigation options the WRAP tools available include the Dust Definition and the Fugitive Dust Handbook. Other resources used for this study include the Doña Ana County Natural Events Action Plan; California State Bill SB 656 List of Air District Measures that Reduce Particulate Matter; Best Management Practices for Oil and Gas Development on Federal Lands, and New Mexico Permit Requirements for Aggregate Mining.
Emission Reductions Due to Ongoing Air Pollution Control Programs Section 51.308(d)(3)(v)(A) of the Regional Haze rule requires states to consider emission reductions from ongoing pollution control programs. For the state of New Mexico, some of these programs include state, federal, and local programs that are currently in place to control the erosion of soil and particulate emissions generated by high wind events.
A. Natural Events Action Plans Several counties in the southern region of New Mexico have exceeded the National Ambient Air Quality Standard for PM10. Most, if not all, of the exceedances of the PM10 standard were caused by high wind events during the spring months. Four counties in New Mexico currently have a Natural Events Action Plan (NEAP) in place to control man-made sources of wind blown dust, including Chaves County. The NEAP for Chaves County has been submitted to the EPA, but the reasonably available control measures (RACM) are still currently being developed and should be in place by the spring of 2008. The RACM that are planned for Chaves County include a county-wide and city-wide, for Roswell, NM only, dust control ordinance that will target soil disturbance due to construction, unpaved parking lots, unpaved roads, vacant lands, and weed eradication. Other types of RACM include memoranda of agreement (MOA) with the New Mexico Department of Transportation, the Bureau of Land Management (BLM), and White Sands Missile Range. Appendix G contains examples of dust control ordinances and MOAs that have been used for wind erosion in other communities in New Mexico.
B. Reclamation of Oil and Gas Exploration in Chaves County Within Chaves County there are a total of 6,054 current oil and gas wells. These wells are found on three different land types: federal lands, state lands, and private lands. Figure 20 shows the land ownership for Southeast New Mexico. Presently, there are oil and gas reclamation requirements for wells located on federal and state land, but not private. Of these wells located in Chaves County, 80% are located on either federal or state lands.
This is only a study developed for WRAP by the State of New Mexico. 24 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 19: Land Types for Oil and Gas Development in Chavez County
39% 41%
Federal Private
State
20%
Source: NMEMNRD
B1. Bureau of Land Management Requirements for Oil and Gas Reclamation Of the 6,054 wells in Chaves County, 41% are located on federal lands managed by BLM. The Roswell BLM Field Office estimates in their 1997 Range Management Plan (RPM) that there will be 184 new wells a year drilled within that region between the time of initiation of the RPM and 2012, which would be a total of 920 new wells between 2007 and 2012. The normal lifespan of a well is 15-30 years, so during the period that these wells are being drilled, older wells will be plugged. For all oil and gas wells located on leased BLM land, operators are required to reclaim the areas that have been disturbed by oil exploration. During the life of the development, all disturbed areas not needed for active support of production operations are required to undergo “interim” reclamation in order to minimize the environmental impacts of development on other resources and uses. At final abandonment, well locations, production facilities, and access roads must undergo “final” reclamation so that the character and productivity of the land and water are restored. The reclamation process involves restoring the original landform or creating a landform that approximates and blends in with the surrounding landform. It also involves salvaging and reusing all available topsoil in a timely manner, re-vegetating disturbed areas to native species, controlling erosion, controlling invasive non-native plants and noxious weeds, and monitoring results. Reclamation measures should begin as soon as possible after the disturbance and continue until successful reclamation is achieved. Appendix H includes the BLM reclamation requirements for oil and gas sites.
B2. New Mexico State Land Office Requirements for Oil and Gas Reclamation There are currently 2,342 oil and gas wells located on state lands in Chaves County. This is 38% of the oil and gas sites in Chaves County. The New Mexico State Land Office requires that all oil and gas operations reclaim surface lands and roadways within one year of permanent abandonment. This includes reseeding, replacement of original top soil, if available, and berming. The State Land Office regulatory requirements for reclamation of oil and gas operations include NMAC 19.2.100—Relating to Oil and Gas Leases and NMAC 19.2.20— This is only a study developed for WRAP by the State of New Mexico. 25 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Relating to Construction, Maintenance and Reclamation of Roads. Both of these regulations can be found in Appendix I.
Figure 20: Surface Management Responsibility for Southeast New Mexico
Mitigation of Impacts from Construction Activities Section 51.308(d)(3)(v)(B) of the regional haze rule requires states to consider measures to mitigate the impacts of construction activities. New Mexico considered the impacts of construction activities by reviewing what control measures are currently used in New Mexico.
A. Natural Events Action Plans One of the major components of the Natural Events Action Plan in Chaves County will be the control of dust from construction activities. The types of construction activities controlled under other NEAPs in New Mexico include the following. • Large lot (> ½ acre) for residential, office, commercial, and industrial construction;
This is only a study developed for WRAP by the State of New Mexico. 26 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
• Cessation of construction operations for disturbed areas; • City and county construction projects; • Unpaved roadways associated with construction activities; • Trucks hauling bulk materials; • Demolition and renovation activities; • Milling, grinding, or cutting of paved or concrete surfaces; and • Pressure blasting.
Mitigation practices currently required under NEAPs in New Mexico include the use of: • Regular wet suppression; • Dust suppressants; • Windbreaks; • Stabilization of disturbed areas; • Ceasing soil disturbing construction activities during high wind events; • Reseeding; • Xeriscaping; • Tree planting; • Traffic controls; • Coverings; • Existing, pre-development grades; and • Retention of natural vegetation.
PROTOCOL:
The resources available for establishing emission reductions due to ongoing air pollution control programs are not going to be available through the existing WRAP tools. For New Mexico, the resources utilized include the Chavez County Natural Events Action Plan; Best Management Practices for Oil and Gas Development on Federal Lands; California State Bill SB 656 List of Air District Measures that Reduce Particulate Matter; State Regulations for Mining and Oil and Gas Development; and State Permitting Requirements.
Dust Emission Reductions for 2018 Section 51.308(d)(3)(v)(C) of the regional haze rule requires states to identify additional dust emission reductions that are needed to meet reasonable progress goals for 2018 when ongoing programs alone are not sufficient to meet the goals.
New Mexico found that current air pollution control programs were not sufficient to meet reasonable progress goals. As a result, New Mexico shall implement the following control measures through the Chaves County Natural Events Action Plan and state permitting requirements:
This is only a study developed for WRAP by the State of New Mexico. 27 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Table 6: Dust Control Techniques and Efficiencies Sources Control Techniques *Efficiency Compliance Schedule Construction • Regular use of wet • 90% 2008 suppression • Dust suppressants • 84% • Windbreaks • 50% • Stabilization of disturbed • 4-88% areas • Ceasing construction • 98% during high wind events Oil and Gas • Regular use of wet • 90% 2008-2009 suppression • Dust suppressants • 84% • Retention of natural • 90% vegetation Unpaved Roads • Regular use of wet • 90% 2008-2010 suppression • Dust suppressants • 84% • Traffic controls • 44% • Paving • 99% Agriculture • Ceasing tilling during high • 98% 2008-2010 wind events • Contour Farming • 15-64%
Mining • Haul Road Dust Control • 15-60% 2008-2010 * Control efficiencies for control techniques obtained from the WRAP Fugitive Dust Handbook and the Handbook for Dust Control in Mining.
PROTOCOL:
In establishing the dust emission reductions for 2018, the anticipated net effect WRAP's Fugitive Dust Handbook can be used to calculate actual uncontrolled emissions and controlled emission reductions. New Mexico used Salt Creek local/regional emission inventory, the Fugitive Dust Handbook; Natural Resource Conservation Service: State of the Land; Dona Ana County Natural Events Action Plan; and the Handbook for Dust Control in Mining.
Enforceability of Emission Limitations and Control Measures Section 51.308(d)(3)(v)(F) requires New Mexico to ensure that emission limitations and control measures used to meet reasonable progress goals are enforceable.
New Mexico has ensured that all emission limitations and control measures used to meet reasonable progress goals are enforceable by embodying these in the Natural Events Action Plan for Chaves County (Appendix J). New Mexico requests EPA approval of these measures.
Anticipated Net Effect (Tools needed for this section had not been completed by the time of this study. Information on available tools can be found in the Protocol Section.)
This is only a study developed for WRAP by the State of New Mexico. 28 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Section 51.308(d)(3)(v)(G) of the Regional Haze rule requires New Mexico to address the net effect on visibility resulting from changes projected in point, area and mobile source emissions by 2018.
The emission inventory for New Mexico projects changes to point, area and mobile source inventories by the end of the first implementation period resulting from population growth; industrial, energy and natural resources development; land management; and air pollution control. The emission source category that will have the largest net effect on visibility is area source coarse mass particulate matter generated by high wind events. A summary of these reductions is given in Table 7 for coarse and fine particulates.
Table 7: Summary of 2018 Emission Reductions Source 2002 Emission Projected 2018 Difference in Category (tons/yr) Emission Reduction Emissions (%) (tons/yr) PM 10 PM 2.5 PM 10 PM 2.5 PM10 PM2.5
Area Source: 1,916.0 191.6 TBD TBD TBD TBD Fugitive Dust Area Source: 14,214 1,421.4 TBD TBD TBD TBD Windblown Dust Area Source: 467.0 46.7 TBD TBD TBD TBD Road Dust Total 16,597 1,659.7 TBD TBD TBD TBD
The net effect of these emission differences on visibility in Class I areas depends upon the state’s long-term strategy and the long-term strategies of other states. The demonstration that reasonable progress goals are met for Class I areas within the state and for Class I areas affected by emissions from the state is summarized in Table 8. Reasonable progress goals are met only when modeling shows improvement on the worst days that meets the goal and no degradation on the best days.
Table 8: Summary of the Demonstration of Meeting 2018 Reasonable Progress Goals Class I 20 % Worst Visibility Days 20% Best Visibility Days Area 2018 Reasonable Demonstration of 2018 Reasonable Demonstration of Progress Goal Reasonable Progress Progress Goal Reasonable Progress (dv) (dv) (dv) (dv) SACR TBD TBD TBD TBD Other C1A Total TBD TBD TBD TBD
Protocol:
The WRAP tools available for determining the anticipated net effects from emission reductions include the Weight of Evidence Checklist on the TSS web site and the WRAP Regional Modeling Center. At this time of this study the tools for this section were not completed. This is only a study developed for WRAP by the State of New Mexico. 29 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Review of Demonstration for Reasonable Progress
To determine reasonable progress for a Class I Area, Congestion Mitigation and Air Quality (CMAQ) modeling is required. To comply with this requirement, WRAP conducted CMAQ modeling for fugitive emissions and windblown emissions for coarse and fine particulates for the 2002 base year and projected 2018.
A. CMAQ Fugitive Emissions Modeling The CMAQ model used by the WRAP region to predict coarse mass (CM) emissions for the base year and projections for 2018 vastly under predicted the emissions for SACR. The CMAQ model performance for the 20% worst fine soil (SOIL) differed from the monitored 20% worst observed data for 2002 by a factor of about 2 and the performance for CM is off by about a factor of 16. Figure 21 shows the modeled performance for 2002 with the observed 2002 data for all pollutants. The column to the left is the observed 2002 data and the column to the right is the modeled 2002. Appendix E shows the CMAQ modeling for SACR.
Figure 21: CMAQ Modeled 2002 Data and Observed Data Worst 20% Obs (left) vs Plan02b (right) at SACR1
100
90
80
70
60 bCM bSOIL bEC 50 bOC bNO3 bEXT (1/Mm) bEXT 40 bSO4
30
20
10
0 2 8 56 83 92 95 110 116 125 131 143 146 155 161 164 218 221 227 248 251 272 344 359 _ _ Avg
Julian Day in Worst 20% group Source: Wrap Technical Support System
B. Fugitive Windblown Dust Emissions Model Due to the high level of visibility impairment from high wind events at SACR, the Fugitive Windblown Dust Emissions and Model Performance document developed by ENVIRON was utilized (Appendix K). The modeling performed for windblown coarse mass, as with the modeling performed for coarse mass, did not perform well. The modeling performance for windblown fine soil performed much better than the coarse mass, similar to the fugitive source modeling performance. Figures 22 and 23 show the time series plots for the windblown dust This is only a study developed for WRAP by the State of New Mexico. 30 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
model in comparison to the IMPROVE observed data and the coarse mass and fine soil fugitive emissions model for 2002.
Figure 22: Time Series Plots for Coarse Mass at SACR
Source: Fugitive Windblown Dust Emissions and Model Performance
This is only a study developed for WRAP by the State of New Mexico. 31 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 23: Time Series Plots for Fine Soil at SACR
Source: Fugitive Windblown Dust Emissions and Model Performance
Although the model did not perform well, the model did provide needed information on source categories that contribute to windblown emissions at SACR. The following bar graph (Figure 24) shows those sources identified in the Windblown Dust Emissions Model as contributing to visibility impairment at SACR. The four major sources modeled for windblown emissions include agricultural lands, grasslands, shrublands, and barren lands. For New Mexico, the model indicated that the predominate source of windblown PM10 is from shrublands, which is also the predominate land type in New Mexico. The windblown PM10 emissions for New Mexico from shrublands are shown in Figure 25.
This is only a study developed for WRAP by the State of New Mexico. 32 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 24: Windblown Emissions for New Mexico
250000
200000
150000
100000
PM10 (tons/yr) 50000
0 Agriculture Grasslands Shrublands Barren land
Source: Fugitive Windblown Dust Emissions and Model Performance
Figure 25: Windblown PM10 Emissions from Shrublands
Source: Fugitive Windblown Dust Emissions and Model Performance
PROTOCOL
To establish Anticipated Net Effect, the WRAP tools available include CMAQ modeling available on the Regional Modeling Center web site; modeling from the TSS web site, Fugitive Dust Emissions from Windblown Erosion; and the Fugitive Dust Handbook. New Mexico used all of
This is only a study developed for WRAP by the State of New Mexico. 33 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
the WRAP tools listed above for the analysis including the Salt Creek local/regional emission inventory.
Alternative Demonstration of Uniform Rate for Salt Creek Reasonable Progress Goals (Not a required section for the Regional Haze Rule, added in for clarity. It can be removed.)
Due to the under prediction of the coarse mass modeling, New Mexico has chosen to use the monitoring and emission inventory data developed for SACR as a means of showing reasonable progress for this SIP submittal. Refined modeling for coarse mass, once available, will be used for future SIP iterations. Table 9 lists the deciviews reduction from dust needed to achieve the 2018 reasonable progress goals for SACR.
Figure 7 shows dust (coarse mass and fine soil) as comprising 28.3% of the light extinction for SACR. The equation below takes the total light extinction reductions needed in SACR for 2018, multiplies that by the percentage of the light extinction comprised by dust and converts that number to deciviews. The aerosol calculation conversion for deciviews and light extinction can be found on the IMPROVE web site.
To determine need dv dust emission improvements to achieve 2018 RPG the following equation based on the aerosol conversion calculations for light extinction to deciviews was used: dv = 10*ln[(Bext reductions needed for 2018/10) * %dust Bext] dv = 10*ln [13 Mm-1/10 *.283] = .847 dv
The SACR emission reductions for 2018 are based on the control techniques that are and will be put in place between now and 2018. To determine the emission reductions from those control efficiencies, the control efficiencies for the control techniques listed in Table 6 were averaged and then a control effectiveness factor of 0.75 was used. The control effectiveness factor comes from NMED's past work with dust control in Doña Ana County. Presently, there is roughly a 75% compliance rate with the current dust control measures in the county. Averaging the control efficiencies in Table 6 with the control effectiveness factor of 0.75 gives a 52% overall control efficiency.
To determine dust emissions reductions for 2018 the following equation was used: dv = 10*ln[(Bext reductions needed for 2018/10) * % reduction from proposed control strategies] dv = 10*ln [13 Mm-1/10 *.52] = 1.35 dv
This is only a study developed for WRAP by the State of New Mexico. 34 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Table 9: Alternative Demonstration of Reasonable Progress for 2018 Class I *Dust *Total Deciview *Dust Source *Dust Area Percentage of Reduction Needed Improvements to Emissions Light Extinction to Achieve 2018 Achieve 2018 Reductions for (%) RPG RPG 2018 (dv) (dv) (dv) SACR 28.3 2.578 .847 1.35 Other C1A Total 28.3 2.578 .847 1.35 * For 20% Worst Visibility Days. Includes Fine Soil and Coarse Mass.
PROTOCOL
To show that Reasonable progress goals will be met, the following WRAP tools are available: CMAQ modeling on the Regional Modeling Center web site and the TSS web site for modeling, monitoring, and emissions data. New Mexico used the following tools to show reasonable progress: emission and monitoring data on the TSS web site, Salt Creek local/regional emission inventory, and the Fugitive Dust Handbook.
Salt Creek Wilderness Area Long Term Strategy for Dust (Weight of Evidence)
The Salt Creek Wilderness area's 20% worst visibility days are primarily affected by dust from high wind events. Most of these high wind events occur during the spring months (March-May) and are normally regional events (Table 10). Many of the 20% worst visibility days that occur at SACR during the other times of the year are also caused by high wind events, but some are the result of upwind transport.
Table 10: Primary Dust Event Types Identified for SACR 20% Worst Visibility Days Class I Local Windblown Windblown Dust Upwind Transport Undetermined Area Dust Events Regional Events Events Events SACR 22% 39% 22% 17% Other C1A Total 22% 39% 22% 17% Source: DRI Causes of Dust Analysis
The areas that are generating dust during the 20% worst visibility days are primarily disturbed lands that have little to no vegetation. The Salt Creek Class I area is impacted by local and transported sources of dust. Figure 26 below, shows that coarse mass is the primary pollutant at SACR in 2002 that caused measured light extinction for the 20% worst and best visibility days.
This is only a study developed for WRAP by the State of New Mexico. 35 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Figure 26: Measures Light Extinction for 20% Worst and Best Visibility Day
Source: WRAP Technical Support System
Locally, the area is affected by naturally occurring wind blown dust; wind blown dust from disturbed lands associated with oil and gas exploration construction activities, mining operations, agricultural operations, and local unpaved roads; road dust; and fugitive dust. The evidence provided from the technical analysis developed by WRAP shows overwhelmingly the need to develop long term strategies to control the wind blown dust from disturbed lands, road dust, and fugitives to improve visibility in the Salt Creek Wilderness Class I area (Figure 26). As stated above, the modeling, monitoring, and emission inventory data developed by WRAP, assisted in providing evidence as to the need to develop long term strategies for dust emissions to improve visibility at Salt Creek. Many of these long term strategies, as stated earlier, are in the process of being implemented through a Natural Events Action Plan for Chaves County. Dust control measures for this plan should be in place by spring of 2008. Although this plan is based on health based requirements rather than visibility requirements, the measures used under this plan should benefit not only human health, but also visibility conditions within Salt Creek.
Figure 27: Dust Sources that Affect Visibility at SACR
1%
5% Windblown Natural
Windblown Disturbed 40% 54% Fugitve Dust
Road Dust
Source: PM10 Emission Inventory for the SACR Pilot Study SIP Project This is only a study developed for WRAP by the State of New Mexico. 36 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
There is also evidence to support that during high wind events, the Salt Creek Wilderness area is impacted by sources in Texas and Mexico. Back trajectory studies developed by WRAP indicate these areas could be potential sources of dust during regional high wind events. The extent of how significant particulate matter transport is towards visibility impairment at SACR is not known at this time, but the affects of transport particulate emissions will continue to be explored in the future. At this time, New Mexico plans to include dust transport from Texas and Mexico as part of the future work for Salt Creek's long term strategy.
PROTOCOL:
To provide the weight of evidence for the long term strategy developed for Salt Creek a combination of all of the WRAP Dust Forum tools were used. The Causes of Dust/New Mexico Pilot Study was used to show were potential dust sources could be within and outside of the state. The Causes of Dust/New Mexico Pilot Study , as well as the Causes of Dust Analysis were important resources in determining if the 20% worst visibility days are caused by mechanical generation, windblown events, Asian dust events, or upwind transport. The Dust Definition provided the needed guidance to determine if the sources that are to be controlled in the long term strategy are anthropogenic, natural, or both and which sources can be controlled in the long term and which can not be. The Fugitive Dust Handbook , Fugitive Dust Emissions from Wind Erosion, and the local/regional emission inventory provided information to help fill in the Salt Creek emission inventory and determine emission reductions. Other resources used in developing the weight of evidence include the TSS web site, NRCS Web Soil Survey, Google Earth, CARB Emission Inventory Documentation; and federal, state and local data.
Monitoring Strategy and Emission Inventory
Monitoring Strategy Section 51.308(d)(4) of the federal regional haze rule requires a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility impairment that is representative of all mandatory Class I areas within the State of New Mexico. New Mexico has developed a monitoring strategy that is representative of the Class I areas and that is coordinated with the monitoring strategy required under Section 51.305 for reasonably attributable visibility impairment. The monitoring strategy relies upon participation in the Interagency Monitoring of Protected Visual Environments (IMPROVE) network.
The state will evaluate the monitoring network periodically and commits to establishing additional monitoring sites or equipment if needed to assess whether reasonable progress goals to address regional haze in each of New Mexico’s mandatory Class I areas. Monitoring data and other information are important in determining the contribution of emissions from within New Mexico on Class I areas inside and outside of New Mexico.
The State of New Mexico will correlate the filter data collected at the coarse particulate matter National Ambient Air Quality site located in Roswell, NM with the IMPROVE monitor site for the Salt Creek Wilderness area. The monitoring data from the Roswell and Salt Creek sites will be used to track emission reductions from the implementation of the planned control strategies.
This is only a study developed for WRAP by the State of New Mexico. 37 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
New Mexico commits to reporting all visibility data for each Class I area annually to EPA. The data will be transmitted by December 31 each year. To the greatest extent possible, data will be reported to EPA in an electronic format.
New Mexico has developed procedures to address other elements necessary to assess and report on visibility such as reporting, record keeping, and other measures.
Emission Inventory Section 51.308(d)(4)(v) requires a statewide emission inventory of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I area. As specified in the applicable EPA guidance, the pollutants inventoried by New Mexico include volatile organic compounds, nitrogen oxides, PM2.5, PM10, elemental and organic carbon, ammonia, and sulfur oxides. An inventory was developed for the baseline year 2002 and the most recent year for which data is available 2004. In addition, projections of future emissions have been made for the following years: 2018. The state will update this inventory on a periodic basis, every three years. A summary of the inventory results follows; the complete emission inventory is included in Appendix D of this plan.
This is only a study developed for WRAP by the State of New Mexico. 38 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
CONCLUSIONS
The New Mexico Environment Department was not only tasked with using the tools developed by WRAP for developing a dust SIP for regional haze, but also to critique those tools. Unfortunately, during the time period that the pilot study was conducted, some of the tools to be critiqued were not complete or were unavailable for use. For the SIP template accommodations were made through the use of other available resources and placeholders were added for the tools slated to be available after the completion of the Pilot Study. For those WRAP tools used in the pilot study, the following table outlines the clarity, usefulness, relevancy, and effectiveness of those tools. The rating systems used includes ranging from 1-5 marks, the more marks the higher the rating with 5 marks being the highest and 1 being the lowest.
WRAP Tool Clarity Usefulness Relevancy Effectiveness Dust Definition Dust Definition: Case Study Salt Creek Fine Fraction of Fugitive Dust Causes of Dust Regional Analysis Causes of Dust: New Mexico Pilot Study Fugitive Dust Emissions from Wind Erosion Fugitive Dust Handbook CMAQ Modeling for Fugitive Emissions Weight of Evidence
Dust Definition Overall, the Dust Definition developed by ENVIRON helps establish a framework of sorts for establishing which dust sources could affect a Class I area. Sections of the Dust Definition model were incorporated in the SIP development process used for this Pilot Study. Although a supplemental study for the Salt Creek Wilderness area was conducted by ENVIRON using the Dust Definition, New Mexico felt that it was important to also review and to employ the definition ourselves to see how intuitive the definition was for a state air quality planner. As part of this review, New Mexico used the Saguaro West Case Study by ENVIRON as guidance for use of the Dust Definition. New Mexico found that the model created by ENVIRON was very useful is helping states lay out potential sources and also helped define if those sources were natural or anthropogenic in nature.
The Dust Definition is a good tool to help states get a better handle on dust sources and if sources can potentially be controlled. Although the Dust Definition is useful in some respects, it can also be confusing to follow and could potentially be resource intensive to fully carry out. It This is only a study developed for WRAP by the State of New Mexico. 39 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
was difficult to determine from the case study how the model was set up at first. It would be useful for anyone that plans to use the dust definition to read the Feasibility Analysis developed by ENVIRON for the Dust Definition along with the Saguaro Case Study. New Mexico was also only able to use the definition to a point. Most of the information needed for doing the dust definition model was available through relatively cost efficient means. The final part of the definition, portioning those dust sources that are natural/anthropogenic, could be very resource intensive. If information is not already available for those specific sources for that specific Class I area, emission inventories and or models would be needed to determine source partitioning.
Fine Fraction of Fugitive Dust This resource had probably the most limited use of all the tools and required the least amount of analysis, but was one of the most useful in developing the emission inventory. The new PM10/PM2.5 ratio developed from this study was essential to developing an accurate inventory of emissions for PM2.5.
The only recommendation is making a one page synopsis for the study and the conclusions for states to use. The sheet should be written in laymen's terms to make it a useful resource to use with the public.
Causes of Dust Regional Analysis/New Mexico Pilot Study For New Mexico this study, along with the supplemental study developed by DRI for New Mexico, proved to be quiet helpful in determining the possible dust sources for the 20% worst visibility days. For those areas that currently have visibility impairment due to high wind events or upwind transport, the Causes of Dust Regional Analysis is useful in providing the technical documentation need to justify those conditions under the Regional Haze rule. The supplemental study DRI developed for the Salt Creek area also proved to be very useful in providing back trajectory analysis of possible contributing dust sources for those 20% worst visibility days.
As with the other tools reviewed so far, the Causes of Dust Regional Analysis was somewhat confusing to use at times. The most confusing aspect of the analysis was that acronyms were not always defined, making it difficult for a non-technical person to understand exactly what they were looking at and what the data, tables, or figures represented.
CMAQ Modeling for Fugitive Emissions As with all air dispersion modeling, the results are only as good as the information used in the model. The coarse mass model for the WRAP region is a good example of this. The model predictions for coarse mass were about 16 times lower than the observed data. The fine soil faired much better with about a factor of 2. Due to this discrepancy with the coarse mass modeling, it was very difficult to use to determine reasonable progress for SACR. There was some discussion of using the fine soils to show reasonable progress for SACR, but due to the low fine soil content of dust, it was decided not to use the CMAQ modeling at all. Data improvements are needed for future iterations of the Regional Haze SIPs.
This is only a study developed for WRAP by the State of New Mexico. 40 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
For the current 2007 SIPs, it would be useful if an alternative method could be established to show reasonable progress for dust. For the Pilot Study, the monitoring and emission data for SACR were used to determine reasonable progress. Using this data alone, it was difficult to show how the uniform rate of progress for reasonable progress can be accurately established. It was more a shot in the dark approach of "if we make a 75% reduction in PM10 emissions we are assuming the visibility impairment from dust will improve by a similar rate." Having an established alternative for all WRAP states to use in lieu of the coarse mass modeling would provide a more unified approach to the problem that could be EPA approved before the SIPs are submitted.
Fugitive Dust Emissions from Wind Erosion As with the CMAQ modeling for dust, the modeling for dust emissions from wind erosion also did not perform as expected. There was a substantial margin of error for the wind blown dust model compared to the IMPROVE observed data for the coarse mass and less of a discrepancy for the fine soil. For areas like Salt Creek, determining the wind blown emissions are essential to improving visibility for the Class I area.
The modeling did provide some interesting information on possible source categories for wind erosion that were used in the Pilot Study. As with the fugitive modeling for coarse mass, changes to the model are needed for future iterations of the Regional Haze SIPs. If possible, it would also be good to provide some kind of alternative that states can use instead of the results for the wind blown dust model, as was suggested for the fugitive coarse mass modeling; ideally, something that has approval from EPA for use in the 2007 SIPs.
Fugitive Dust Handbook The Fugitive Dust Handbook synthesizes the AP-42 emission factor process for dust generating sources. The handbook provides the needed information from AP-42 and other sources, and also provides an Excel spreadsheet to help calculate uncontrolled and controlled emissions. The handbook is a nice tool, but was somewhat difficult to use. The handbook itself worked well in providing the necessary chapters from AP-42 and other sources to determine dust emissions, but the Excel spreadsheets were somewhat confusing when trying to use them. An example of this is the Excel spreadsheet for Open Space Wind Blown Dust emissions. Although some of the assumed parameters were relatively easy to determine, some were not, such as the threshold friction velocity. It was also quite confusing that the examples of threshold friction velocity are from coal mining sources, which do not correlate with the soil and land use types that most areas are going to be working with. It took some research to be able to use the spreadsheet and there is some question as to whether it was used correctly. Another issue for the Wind Blown dust emissions was the controlled emissions. The spreadsheet for Open Space Wind Blown Dust emissions uses gravel as a control measure. Once again the assumed parameters for the control measures were difficult to understand. There were questions regarding where this cost information was obtained and if this information is only applicable to a specific location or is this the typical cost for gravel throughout the whole Western US.
Some suggestions for the Handbook would be to more fully explain were data used is found, especially assumed parameters. While much of this information may seem like common knowledge for a technical person, non-technical planners are in need of more information to clearly understand how these resources are to be used and work effectively. This is only a study developed for WRAP by the State of New Mexico. 41 This is not intended to be New Mexico's Regional Haze State Implementation Plan.
Weight of Evidence During the development of the Pilot Study, this tool was not available for use. The tool was partially completed at the end of the Pilot Study and was used for a small portion of the study. From the extent that the Weight of Evidence tool on the TSS web site was used, it appeared to nicely encapsulate the modeling, monitoring, and emissions data available for each Class I area, taking some of the confusion out of using the trends and composition tools available on the TSS web site.
Overall Recommendations The dust tools developed by WRAP for the completion of the 2007 Regional Haze SIPs overall, provided the needed resources to fulfill the regional haze SIP requirements. The CMAQ modeling performed for fugitive and wind blown dust are the only tools that have very limited use for the 2007 SIPs.
One of the major hurdles encountered in developing the New Mexico Pilot Study, for almost all of the tools, was confusion in understanding certain terms and acronyms. A list of all acronyms and technical terms and their definitions would be an enormous help. For the Pilot Study, quite a bit of effort went into just trying to figure out what exactly the information was and what it was supposed to be showing. Providing a list of terms and acronyms would cut down significantly on that research time.
Another suggestion would be to provide a breakdown list that summarizes the databases and tools. There was quite a bit of confusion during this study as to which database/tool should be used for certain sections; it seems the more you dug the more information resources you would find making it difficult to discern which resource you should use. A simple list of what information each resources provides and where that information is would be a very useful tool.
The last recommendation for any tool being developed for SIP development is to provide all basic information in plain English. Most of the SIP planners will be held accountable by the public and political figures for the decisions made in this Regional Haze process, so we will need to be able to understand these tools ourselves to be able to tell the public how these decisions were derived.
This is only a study developed for WRAP by the State of New Mexico. 42 This is not intended to be New Mexico's Regional Haze State Implementation Plan.