WPC 2 BPZ Courier 10cpi#|whx6X@8;X@HP LaserJet IIIPostScriptHPLASIII.PRSx  @,\,LWX@2 <F ZV0X#|wHP LaserJet IIIPostScriptHPLASIII.PRSXN\  P,\,LWXPXN\  PXP(9 Z 6Times New Roman RegularXXN\  PXP&O Z 6Times New Roman RegularX2e:- :X "m+O6^;C]ddCCCdCCCCddddddddddCCȲY~~vCN~sk~CCCddCYdYdYCdd88d8ddddJN8ddddYYdYdCdddddCddddddddd8YYYYYY~Y~Y~Y~YC8C8C8C8ddddddddddYddddsdYYYYYYYd~Y~Y~Y~YdddddddC8C8C8C8oNd~8~8~8<|8dtddddJJJkNlLkNkN~8~8dddddddYXYd~8dJkN~8dddddCddCCCWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNdddCYQQddddddFddddFCChhd44ddzzdddvooChdF"Ȑdhd岲dCCȐzȲxCddodȐȅdCdYdsȐ]ȐȐȧzȐUvŐdȐYYCCCCΐz~ozoY~NYdYC8YooYdYzsdzdd~YYzozzzzNd88YYYzYzzzzCCdddddddzzzzzzzzzzzzzzzzzzzNNNNNNNdddddddddddddddddddd888888888888YYYYYYYYYYYYYYYYYYYzzzzzzzzzzzzzzzzzzzzCs~CzdYCCG Times (Scalable)CG Times Bold (Scalable)"m+O6^;C]ddCCCdCCCCddddddddddCCȲdxN`xoȐCCCddCdoYoYFdo8Co8odooYNCodddYddddCdddddCddddddddo8dddddϐYYYYYN8N8N8N8oddddooooddddddxodddYYYYoYYYYddddddoN8N8N8N8r`o888N8ooodd┐YYYoNoNoNoNCCooooooȐdYYYo8oYoNCddodoCddCCCWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNdddCdUUddddddFddddFCCssd44ddzzddd~ooCsdF"Ȑdsd岲dCCȐzȲxCddodȐȅdCdYdsȐ`ȐȐȮzȐUvŐdȐddCCCCΐzozoYNYYYN8YooYdYzzdzddYYzozzzzNY88YYYzYzzzzCCdddddddzzzzzzzzzzzzzzzzzzzNNNNNNNYYYYYYYYYYYYYYYYYYYY888888888888YYYYYYYYYYYYYYYYYYYzzzzzzzzzzzzzzzzzzzzCzNzdYCl 8wC;,[hXw P7XP7zC;,sXz_ p^7XG@ZY[XPS"JH|.> Jus u&OH}GHG[XPSQR JJ/r;Jt_r Jt JAGDZY[XËJ- JtH|>2 XX #XN\  P[hXP#     PROPOSED RECOMMENDATIONS !&OF THE GRAND CANYON  VISIBILITY TRANSPORT COMMISSION *X pPublic Advisory Committee $Final Report &JMay 1996 *X "EXECUTIVE SUMMARY *X The Colorado Plateau's national parks and wilderness areas provide a unique, panoramic visual experience for people from around the world. This experience depends on maintaining high visual air quality in the region, which is threatened by haze resulting from projected growth over the next fifty years. Congress has set a national goal of remedying existing human-caused visibility impairment, and preventing future impairment, at these national parks and wilderness areas. Congress recognized that not all haze is human-caused and that haze is a regional issue. Congress created the Grand Canyon Visibility Transport Commission in 1991 to advise the U.S. Environmental Protection Agency on strategies for protecting visual air quality at national parks and wilderness areas on the Colorado Plateau. The Commission established a Public Advisory Committee (PAC) to obtain broad input as it formulated these strategies. The Commission conducted an extensive review of scientific, technical, and other information with assistance from a range of governmental, business, tribal, and environmental interests. It developed more comprehensive databases, and new computer modules to analyze these data and model future air quality. The Commission significantly advanced understanding of regional haze, but limitations and uncertainties remain. The PAC has developed a set of emissions management recommendations for the Commission with a full understanding of progress and limitations in available knowledge. These recommendations are aimed at protecting clear days and reducing dirty days at national parks and wilderness areas on the Colorado Plateau. For the purposes of this report, the recommendations are written as proposed Commission positions. Following a series of public meetings in April 1996, the PAC and Operations Committee conducted a final review and approval of these recommendations. The Commission will formally consider the PAC report in June. If the recommendations are approved, they will be forwarded to the EPA for action. The primary recommendations include: Air Pollution Prevention. Air pollution prevention and reduction of per capita pollution is a high priority for the Commission. The Commission recommends policies based on energy conservation, increased energy efficiency and promotion of the use of renewable resources for energy production. #'0*((Ԍ Clean Air Corridors. Clean air corridors are key sources of clear air at Class I areas, and the Commission recommends careful tracking of emissions growth that may affect air quality in these corridors. Stationary Sources. For stationary sources, the Commission recommends closely monitoring the impacts of current requirements under the Clean Air Act and ongoing source attribution studies. Regional targets for SO2 emissions from stationary sources will be set, starting in 2000. If these targets are exceeded, this would trigger a regulatory program, probably including a regional cap and market-based trading. During the next year, participants in the Commission's process will develop a detailed plan for an emissions cap and market trading program. Areas In And Near Parks. The Commission's research and modeling show that a host of identified sources adjacent to parks and wilderness areas, including large urban areas, have significant visibility impacts. However, the Commission lacks sufficient data regarding the visibility impacts of emissions from some areas in and near parks and wilderness areas. In general, the models used by the Commission are not readily applicable to such areas. Pending further studies of these areas, the Commission recommends that local, state, tribal, federal, and private parties cooperatively develop strategies, expand data collection, and improve modeling for reducing or preventing visibility impairment in areas within and adjacent to parks and wilderness areas. Mobile Sources. The Commission recognizes that mobile source emissions are projected to decrease through about 2005 due to improved control technologies. The Commission recommends capping emissions at the lowest level achieved and establishing a regional emissions budget, and also endorses national strategies aimed at further reducing tailpipe emissions, including the so-called 49-state low emission vehicle, or 49-state LEV. Fire. The Commission recognizes that fire plays a significant role in visibility on the Plateau. In fact, land managers propose aggressive prescribed fire programs aimed at correcting the buildup of biomass due to decades of fire suppression. Therefore, prescribed fire and wildfire levels are projected to increase significantly during the studied period. The Commission recommends the implementation of programs to minimize emissions and visibility impacts from prescribed fire, as well as to educate the public. Finally, the Commission believes there is a need for an entity like the Commission to oversee, promote, and support many of the recommendations in this report. To support that entity, the Commission has developed a set of recommendations addressing the future administrative, technical and funding needs of the Commission or a new regional entity. The Commission believes that reasonable progress toward the national visibility goal is achieved to the extent that current Clean Air Act requirements, existing laws and regulations, and the Commission's recommendations result in a significant near-term decrease in emissions that contribute to visibility#'0*(( impairment and ensure long-term protection of visibility. For example by 2000-2010, pollutants from stationary and mobile sources are expected to be reduced by 30% from the 1990 levels. 0*(( !TABLE OF CONTENTS *X X` hp x (#%'0*,.8135@8:0*(( AIR QUALITY MONITORING 1. Continue and expand the number of monitoring sites and frequency of sampling. The current IMPROVE monitoring network only measures aerosol samples twice a week and at only a few Class I sites. Thus, five-sevenths of the time, the chemical make-up of the particulates contributing to visibility impairment is unknown. Consideration should be given to expanding the coverage or redeployment of resources in the IMPROVE network to enhance completeness of the data set, including on tribal lands. In addition, background surveillance sites could be established at intermediate locations between the Class I areas and large regional sources (metropolitan areas) to provide a better understanding of the intermediate course of atmospheric chemistry and transport. Monitoring should be maintained at existing sites in order to allow for long-term trend analysis. 2. Establish three essential components. The three fundamental components of a future visibility monitoring program should be: 1) light extinction measurements from transmissometers; 2) aerosol chemistry measurements from fine/coarse-mass-particulate samplers; and 3) meteorological measurements of wind speed, direction, temperature, and humidity. Tribal lands would be particularly appropriate sites for tracking and monitoring case studies. ?0*(( MODELING Both sophisticated and reduced form models are needed. Once these methods and data are in hand, any simulation can be prepared. In other words, the two types of issues placed before the GCVTC of subregional or region-wide issues can be assessed with equal facility. 1. Develop a comprehensive, sophisticated model. A comprehensive model must be able to match its predictions of air pollution and visual air quality with actual observations of both factors. This model should generate output at least on a twelve-hour basis using emissions and meteorological observations on this time scale. To reproduce the observations on a space and time basis, there is a need for accurate emissions data over the entire modeling area, reliable wind fields, cloud and other climatological data, and samplings of pollutants and visual air quality, as well as dependable algorithms for the physics and chemistry of transport and the transformation of pollutants during transport and deposition. This model is likely to be sufficiently complicated that it would have to be run on a sophisticated computer. To the extent that interpretation of fine grid geography or of urban plumes is necessary to match the data, this capability should be included. The model must also be able to accurately model both near-field (within about 30 miles) and far-field effects. 2. Develop a "Reduced Form Model." A second type of model will be needed for assessing the effects of control options on emissions and visual air quality. This would be a reduced form model (RFM) that can be installed on a personal computer and run in seconds to minutes to convert emissions into estimates of ambient fine particle loadings and visual air quality. This model should relate emissions of various species from the source regions of the entire study area to data collected at receptor sites in the Class I areas of interest. The RFM needs to be able to replicate the predictions of the more comprehensive model. Therefore, the transfer coefficients should be constructed by the comprehen sive model for use in the RFM. 3. Assess impacts of new sources. The existing visibility protection program requires a review of visibility impairment from new or modified major stationary sources to prevent adverse impact on visibility in nearby Class I areas as part of the source permitting process. This is currently done following guidance issued by the Inter-Agency Workgroup for Air Quality Modeling. This review is needed to prevent future attributable impairment. To assess regional impacts, new sources should be incorporated as part of the #'@0*((Ԍ process to address "reasonable progress." As noted above, EPA should develop appropriate guidance on new, large-scale regional models which will be able to incorporate all source impacts. 4. Obtain improved meteorological data. Large-scale regional models are highly dependent on input of meteorological data. The wide separation between locations that measure winds aloft (i.e., National Weather Service balloon stations) contributes a high degree of uncertainty to the results of the modeling. Consideration should be given to expanding the network of sites that collect upper air soundings. In addition, local meteorological data at the Class I areas are needed to identify potential local source impacts. The coordination of region-wide intermittent control systems (such as region-wide smoke management) will necessitate an expansion in the meteorological data collection network in order for such a system to be effective.  A0*(( ASSESSMENT TOOLS AND METHODOLOGY 1. Undertake more detailed economic studies. More detailed economic studies are needed in order to determine more accurately the costs of controls and, of more importance, to understand the effects, both positive and negative, past and future, that these costs have on the local and regional economies and their growth. Potential economic effects needing more study include: economic benefits of cleaner air (such as to tourism), impacts of costs on companies and individuals that pay them (for instance, effects on profits, competitiveness and disposable income), and the feedback of control expendi tures into other industries in the region (such as pollution controls, parts and services and electricity production to operate controls). 2. Develop better assessment tools and methods. In order to provide an objective analysis of the effects of emissions management strategies for regional haze, specific components of research and development are needed, including: a) expanded and improved inventory of control options and costs for use in assessments; b) establishment of a mechanism to aggregate sources into assess- ment groups consistent with the spacial distribution of air quality modeling and economic assessment regions; c) improved econometric analysis tools and techniques to characterize more accurately subregional, including tribal, impacts; and d) upgraded methodological approaches for performing secondary assessments.7B0*(( SECTION IV: TRIBAL PERSPECTIVES AND POSITION REGARDING RECOMMENDATIONS Introduction The following section provides background regarding tribal participation in the Commission process and the legal framework for tribal relationships with states and the federal government. Tribal participants in the process have also provided their unique perspectives on the Commission's recommendations, commenting on how those recommendations may affect tribal lands and peoples. In large part, the tribal participants support the guiding principles set forth in Section III of this report and agree with the Commission's recommendations, as discussed in more detail below. In some instances, however, the tribal participants wish to highlight certain points made in this report or provide a distinct perspective and emphasis arising from tribal experience. These views are also set forth in this section. The Tribal Environment It is the philosophy of most Indian tribes that the quality of life of their members is intimately related to the quality of their environment, and that people and nature should be in harmony and balance. Vistas are important to tribes in spiritual and cultural ways but they are also important for economic reasons. The pristine and visible beauty of their homelands are often the reason for tourist visitations. These visitations support tourism and many cottage industries on the reservations and provide revenue for tribal governments. As "harmony" requires, tribes also recognize that tribal populations are increasing and tribal governments must address the needs of their developing nations. Tribes are working to develop their economic infrastructure so that they can achieve self-sufficiency and provide for their people, including revenues for tribal governments. Tribal governments provide community services, such as road maintenance, water, environmental protection, education, health care, day care and other social services. As in any community, the demand for these services is expected to grow with the population, and tribes desire to grow economically to support these demands. In order to achieve these goals, tribes cannot be unfairly burdened by regional or federal regulations. Any recommendations must ensure that emission control burdens do not fall disproportionately upon tribes. It must be remembered that tribes, by and large, have not contributed to the visibility problem in the region, precisely because of the lack of economic development in Indian country. Therefore, what is fair for states may not necessarily be fair for tribes. Tribal economies are much less developed than those of states, and tribes must have the opportunity to progress to reach some degree of parity with states in this regard. Further, economic and cultural differences may magnify the effects of recommended emission controls. "C0*(( Acknowledgements Tribal government approval and support of the Commission's recommendations is reserved to individual tribal government discretion. This reservation is not intended to represent rejection of efforts to arrive at consensus-based policy recommendations. Rather, it is based upon the legal and historic status of tribes as individual tribal nations; as sovereigns, tribal governments have the prerogative to deal directly with the federal government and may choose to do so in regard to western visibility protection and improvement. Whatever actions tribal governments ultimately choose to direct or pursue, they nevertheless have found value in working within the GCVTC process and have directed tribal representatives to learn from the GCVTC deliberations and contribute to the best of their abilities toward achieving a good that will benefit all people in the West. A number of tribes have been represented on the Commission and on the various committees established by the Commission. Although these "tribal participants," as they are called in this report, do not represent all 211 tribes in the Transport Region, as individual participants in the GCVTC process they have joined together and reached consensus on a number of issues, as reflected in this report. When this report presents tribal positions on the Commission's recommendations, therefore, it is presenting the views of these tribal participants. Co-Management Principles The Grand Canyon Visibility Transport Region, as defined by the EPA, includes 211 tribes. Therefore, visibility improvement and protection strategies ultimately adopted by the EPA must be selected and implemented not only in light of statutory requirements of reasonable progress toward visibility, but also in light of certain basic principles of Indian law. The GCVTC recognizes and respects that the federal and tribal governments have a unique government-to-government relationship that is built on historic legal principles. The Commission's recommendations must be considered, not in terms of a federal-state framework, but in terms of a federal-state-tribal framework. These principles of Indian law and their ramifications for the Commission are set forth below. Tribal Sovereignty It is a basic principle of Indian law that tribes have inherent sovereignty over tribal lands, or "Indian country." Moreover, if a tribe does not assert its jurisdiction in a particular instance, then the federal government may have jurisdiction in the tribe s place, but a state government could not. As a result, emission management strategies will be implemented within Indian country by tribal governments or, failing that, by the federal government, but not by state governments. !D0*(( Federal Trust Responsibility The Courts have found that the federal government bears a trust responsibility toward American Indian tribes. This imposes fiduciary duties on the conduct of federal agencies toward Indian tribes and their natural resources. The trust relationship therefore presents a second basis, in addition to the principle of tribal sovereignty, for the EPA and other federal agencies involved in the GCVTC process to ensure that tribal interests are protected in any regulatory scheme. Tribal Self-Determination As acknowledged by Congress in the Indian Self-Determination and Education Assistance Act, there must be "effective and meaningful participation by the Indian people in the planning, conduct and administration" of programs affecting Indian people [25 U.S.C.  450a(b)]. These principles are also embedded in the EPA policy for the Administration of Environmental Programs on Indian Reservations (November 8, 1984) in which the EPA states that it will "view Tribal Governments as the appropriate non-Federal parties for making decisions and carrying out program responsibilities affecting Indian reservations, their environments, and the health and welfare of the reservation populace." Each tribe is the decision-maker for its own future and is responsible for ensuring that the needs and rights of its people are met and protected. Tribal concerns must be taken into account in formulating recommendations. Tribal Impacts Reports and Studies Tribal participants feel that the report Impact Projections of Emission Management Scenarios on Western Tribal Lands (January 1996), was inadequate and provided only very general conclusions. The various studies undertaken did not adequately evaluate and describe the unique economic structures and demographic patterns of Indian tribes, nor their unique cultures and aspirations. Also, the studies very narrowly focused on straight line economic cost/benefit analysis. Other values are important to tribes: quality of life, freedom of religion and choice in lifestyle, to name a few. Future studies should address these important areas of concerns so that the tribes, and those concerned about impacts on tribes, will be able to more fully evaluate management option impacts. Tribes were greatly disappointed that secondary assessment studies were not fully carried out. Little or no work was done to identify impacts on health and welfare, land and water uses, solid and hazardous waste disposal, threatened and endangered species, and terrestrial and aquatic ecosystems. This information would have been of great interest to the tribes and probably many others.h$E0*(( Program Implementation Tribal governments have the responsibility to develop, implement, and manage programs within Indian country. If a tribe chooses not to establish a program, then the federal government has the trust responsibility to establish a program. Thus if the EPA promulgates a rule based on a control technology scenario, for example, tribes must have the option of implementing the rule within Indian country or prompting federal implementation of the rule within Indian country. Similarly, a market trading scenario in which there was separate tribal participation or federal participation on behalf of the tribes could be legitimate. Many tribes are just beginning to develop environmental programs, and these programs receive very minimal funding from the EPA, if any. Tribal governments also lack the tax base available to states to help fund environmental programs independently. Therefore, tribal implementation of visibility programs will require policy development support, technical assistance, and program funding. In the implementation of an emissions trading program, special consideration for tribes is necessary. Given that many tribal lands are "underdeveloped," tribes should be allocated some additional share of trading credits to allow for future development, much as "clean" states were under the acid rain trading program. Tribes, states, local governments and federal agencies must find innovative ways to support implementation of regional haze programs. Memoranda of Understanding or Memoranda of Agreement, and/or other state/tribal/federal agreements, could be utilized to share resources, expertise and responsibility.F0*(( TRIBAL PARTICIPANTS' POSITIONS ON COMMISSION RECOMMENDATIONS As discussed above, the tribal participants for the most part concur in the Commission's recommendations set forth in this report. Specifically, the tribal participants agree with all six of the assessment criteria listed on page 20-21 of this report, although the tribal participants feel that the criteria were not uniformly applied. The tribal participants also have certain additional recommendations and perspectives which are presented below. Air Pollution Prevention Some of the most pristine, and yet the most threatened, ecosystems are found within the lands of indigenous peoples. The lack of many basic necessities, such as sustainable employment and adequate housing, creates the need for immediate economic develop ment. Coupled with this is the lack of environmental protection infrastructure to manage and check efforts to develop economic opportunities which are proceeding without consideration for the traditional Indian commitment to resource conservation. Tribal communities, like others in the Transport Region, have the opportunity to take a proactive approach to pollution prevention and to avoid the mistakes of the past which have resulted in environmental degradation. Future initiatives should make sure that growth planning and development is coupled with environmental mitigation. In the first subsection of Section III of this report, various pollution prevention recommendations are offered, including economic incentives for pollution prevention efforts, encouragement of zero and near-zero emitting technologies, and development of alternative (i.e., renewable) power sources. The importance of these recommendations is indicated by the prominence they receive in the Executive Summary of this report (they are listed as the first recommendation). Tribal participants support this recommendation wholeheartedly. However, the extent to which deployment of renewable energy will improve visibility is not, nor can it be, stated with certainty, based on the modeling outputs available. The modeling of renewable energy control scenarios is of paramount importance, particularly to western tribes. A significant number of tribes (33) are actively pursuing development of renewable energy and end-use efficiency technology applications. These development options involve remote electrification, bulk power generation, improving reservation economic conditions and reducing the emissions associated with fossil fuel generation. The Energy Policy Act of 1992 has intensified tribal interest in renewables by authorizing the Department of Energy to provide grants to tribes to evaluate the feasibility of renewable energy development. The fact that western reservations are prominent within prime solar and wind energy resource areas and a number are situated in major electricity transmission corridors has focussed Congressional and tribal attention on joint ventures and other strategies for securing investment capital to build and operate bulk renewable electric generation capacity. Clearly, apart from the income obtained through wholesale power sales, renewable energy development will have great added value to tribal governments in the form of revenues from payments for accrued "air credits," and wages from jobs in a vertically integrated electric power industry.:&G0*(( Tribal participants support the recommendations to establish goals for bringing renewable power on line, but modeling efforts clearly need to be expanded to include the impacts of this recommendation. More specific details should underlie this recommendation, including goals, incentives and a timeline for adding renewables to the resource mix. Stationary Sources Tribal participants are concerned that PSD and the current visibility program ( 169A) under the Clean Air Act insufficiently address the national goals of preventing and remedying visibility impairment in Class I areas caused by human-induced air pollution. Government Accounting Office estimates indicate that sources accounting for up to 90% of pollutants emitted near five Class I areas are exempt from PSD requirements, which apply only to new sources. Existing sources and small new sources are ignored by PSD. In addition,  169A (existing sources) concentrates only on visible plumes, rather than regional haze, and very few existing sources have been required to implement BART controls. Tribal participants in the Commission process support the stationary source recommendations presented in Section III of this report with the following additional concerns and recommendations: 1. All uncontrolled and undercontrolled stationary sources should be subject to equivalent emission standards as controlled sources. 2. An emissions cap should be set for SO2. 3. A better inventory and better modeling should be developed for PM. 4. If a cap is established for a particular pollutants, minor sources on tribal lands should be inventoried since they may not currently appear in state inventories. 5. FERC data should be used as a basis for forecasts of future electric utility emissions and for recommendations regarding emission reduction goals. This will also enable the Commission to identify opportunities for early retirement of high-emitting facilities. 6. The effects of increased wholesale and retail competition in the utility industry must be taken into account in predicting future emission levels. H0*(( Moreover, if an emission trading strategy is adopted, tribal participants recommend the following: 1. Tribes must be involved in the development of the trading scenario. 2. Credits should not be based on historical emissions, but should be based on equitable factors, including the need to preserve opportunities for economic development on tribal lands. In general, these lands are currently lacking in economic bases and have not contributed to the visibility problems. 3. Whatever body administers the trading program must be representative of all of the groups involved. 4. The cap should be defined by region, not by state. Mobile Source Controls As programs are initiated, participating governments should receive compliance assurance assistance and equitable funding to administer their respective programs. In addition, tribal communities would benefit immensely from educational programs explaining the need for controls and demonstrating vehicle maintenance methods for minimizing vehicle emissions. Tribal participants are concerned about mobile source emissions from federal vehicles on or near Indian lands, especially sites run by the Departments of Defense and Energy. Federal air traffic in these areas is of particular concern. Area Sources There are major gaps in delineating accurately the contribution of tribal land sources to visibility impairment. Very few air quality monitoring programs have been placed in or near tribal lands. To more accurately inventory emissions sources, monitoring capability should be significantly improved on and near tribal lands. Wood Burning Many rural Indian homes rely on wood-burning stoves as the sole source for cooking \ and residential heating. Programs should include a sole-source heating/cooking and ceremonial burning exemption from visibility and other air quality regulations on tribal lands.h$I0*(( Dirt Roads There are numerous dirt roads within Indian country. If paving is required as a visibility protection measure, financial assistance will be needed. In addition, non-paving options should be considered. Forest Management Practices Many tribal lands include forest lands which the tribes often manage with prescribed fire. Although fire can contribute significantly to visibility impairment, tribal participants recognize that fire is an important management tool. Tribal participants recommend that the various jurisdictions (federal, tribal, state, etc.) develop and implement time, place and manner constraints that minimize visibility impairments. In addition, forest land managers need to take into consideration the needs of tribal communities in their practice of religion and traditional cultural activities. Some of these activities may be protected under the provisions of the American Indian Religious Freedom Act. The availability of and access to areas where traditional medicines and spiritual foods are located should not be diminished by fire manage- ment practices. Clean Air Corridor Controls Tribes should not be penalized for having clean air and little economic development. Therefore, no inequitable restrictions should be imposed on tribal and other corridor residents and/or economic growth. Future Scientific and Technical Needs There is a need for the development of comprehensive emission inventories on and near tribal lands. These inventories may be used to provide more accurate data for future studies, and to prioritize regulatory development. Tribal participants recommend that the EPA assist tribes in this effort. In future tribal population and socio-economic studies, the data collection process should be designed to work more closely with tribes. Future modeling tools need to be able to accommodate political subdivisions smaller than large counties. The REMI model (or an alternate model) needs to be adapted to tribal situations. The distinctive characteristics of tribal lands deserve special attention. Given the diversity of tribal populations and land bases, the broad-based regional and state level impact analyses do not provide sufficient and accurate data. Also, the unique economic structure and demographics of tribal peoples may be missed in the broader regional analysis. Q%J0*(( Tribes need to be meaningfully involved in the development and implementation of future technical studies and in accommodating the special needs of tribes in various study methods and tools. Tribes will need the services of their own experts to help with these efforts, and will need financial assistance to obtain such experts. Future Administrative Needs Indian tribes have rarely been asked to participate in region-wide policy development such as that undertaken by the Commission. Although not all tribes have been involved, the tribal participants agree in principle that the work of an administrative body on air quality issues should continue.1K0*(( SECTION V. FUTURE ADMINISTRATIVE NEEDS Background The Grand Canyon Visibility Transport Commission represents an experiment in regional policy development through cooperative partnership among state, tribal and federal governmental entities. The Commission has also engaged a broad range of interested parties from industry, environmental organizations, academics, technical experts, elected officials, and various citizens' organizations. Throughout this process, the Commission has provided a means for cooperative development of improved scientific information and for intergovernmental consideration of policy recommendations. The following recommendations regarding future administrative needs draw on this experience. RECOMMENDATIONS FOR FUTURE ADMINISTRATIVE STRUCTURES 1. Continue a regional air quality body, similar to the Commission. The implementation and ongoing review of regional haze management strategies will require the work of an entity similar to the present Commission, most likely in a streamlined structure, based on the evaluation performed in recommendation #4 below. The Commission therefore recommends that the functions of the GCVTC should continue, in order to further develop this important partnership and perform vital policy and implementation functions as outlined in #3 below. The name GCVTC focuses disproportionately on the Grand Canyon and should be changed to reflect the larger geographic entity it serves. The primary role of the Commission, or its successor, will continue to be coordination and monitoring in order to recommend policies to the appropriate entities. States, tribes and federal agencies will undertake implementation actions. An equitable body of state, tribal and federal representatives should convene, as necessary but at least annually, for the purpose of: a) discussing visibility and other air quality issues, including public health concerns, and coordinating data collection efforts, and b) making recommendations to the EPA on reasonable progress and other air quality issues. 2. Integrate efforts of an administrative body with other regional air quality needs and planning efforts. It is expected that the EPA will soon undertake new air quality initiatives that also require regional approaches. The participating entities should explore expanding the scope and structure of a successor body to address regional haze and other fine #'L0*((Ԍ particulate impacts on visibility and health throughout the Western United States. (If the mandate is expanded the name of the successor body should reflect the new mission.) 3. Establish functions of a successor body. After it makes its initial recommendations to the EPA, the Commission or its successor should, through its subgroups, perform functions including, but not limited to, the following: a) tracking and providing feedback to the EPA on EPA's interpretation and implementation of Commission recommendations; b) facilitating coordinated implementation of inter-jurisdictional mecha- nisms for addressing regional haze, including monitoring activities; c) tracking implementation of programs for addressing regional haze to ensure equity; d) assessing emissions and visibility data to determine if reasonable progress is being made towards the national visibility goal, and recommending adjustments to regional haze management strate gies, as necessary; e) promoting the development of innovative, cost-effective mecha- nisms for addressing regional haze; f) coordinating research and development efforts on visibility and airborne particulate assessment methodologies in the West to ensure that such efforts are focussed on concerns relevant to policy formulation; g) providing a forum for interested parties to offer input on the develop- ment of regional haze policies; h) promoting and supporting educational programs furthering visibility (or expanded air quality) goals, in public schools, in higher educa- tion and to the general public; i) supporting energy-conservation measures; and j) promoting outreach and communications programs for tribal communities in order to address the remoteness and educational needs of most Indian reservations.#'M0*(( 4. Evaluate and review Commission structures. In order to create efficient, effective and sustainable long-term structures, an evaluation of the Commission's present and past functioning should be conducted. Such a review should examine the composition of the Commission, operational structures, and management arrangements, and should generate recommendations regarding future functional arrangements. To ensure neutrality in the evaluation, the review should be conducted by an independent outside source. Following such an evaluation, each participating governmental entity will be consulted about whether and how it will take part in future activities. During the period through its report to the EPA in the spring of 1996, the Commis sion has functioned with governors or other high-level state, tribal and federal leaders serving as Commissioners. If the Commission becomes an ongoing body, consideration should be given to whether other federal, state and tribal officials may be the most appropriate appointees as Commissioners. Any future management or administrative structures should consist of an equitable body of federal, state and tribal representatives. Public participation in future efforts should be ensured through the use and creation of publicly accessible working groups. 5. Develop ongoing funding mechanisms. In order to estimate the resources, human and financial, that will be necessary to sustain this work (e.g., basic administrative functions, specific research and monitoring activities), a projected five-year budget for future operations should be developed by June 10, 1996. The EPA should provide ongoing financial support for the basic administrative functions of the Commission or its successor. Work should continue in cooperation with the EPA to support efforts to secure such funding. In the course of evaluating all current Commission functions (see #4 above), the benefits and feasibility of additional sources of funds for specific activities should be explored, including: a) visibility surcharges on entrance fees for Class I areas within the Colorado Plateau; b) dedicated air permit or emission fees; and c) redistribution of existing air pollution control funds. Equitable funding should be made available to tribal, state and federal officials to support participation in ongoing data collections and modeling efforts. Note: For tribal perspectives and commentary on these recommendations, see Section IV.#'N0*(( SECTION VI: ANALYSIS OF THE COMMISSION'S RECOMMENDATIONS Introduction This section presents the Commission's analysis of the likely effects associated with its recommendations. The analysis attempts to address these key questions: 1. How will the Commission's recommendations affect visibility at Class I sites in the Transport Region? 2. What are the likely economic effects, both direct and indirect, of the Commission's recommendations? 3. What are the likely environmental, social, equity, and administrative effects of the Commission's recommendations? The analysis is divided into two main parts. The first is a summary, using graphs and charts, of likely visibility effects associated with the Commission's recommendations, where effects are known. Such effects are not, in all cases, known. The second part is a detailed discussion of the Commission's recommendations in light of the evaluation criteria identified in Section II of this report. Visibility Gains from the Commission's Recommendations The overall goal of the Commission's recommendations is to improve visibility on the worst days and to preserve existing visibility on the best days, at Class I areas on the Colorado Plateau. The recommendations focus on reducing emissions from sources that presently contribute to visibility impairment and are likely to do so in the future. The Baseline Forecast Scenario described in Section II (page 9) projects the way in which current federal, state, and tribal laws and programs are likely to affect visibility at Class I areas on the Colorado Plateau through 2040. The Commission used this "current law" scenario to evaluate the additional improvements in visibility that its recommendations are likely to achieve in order to meet the national visibility goal. Figure VI-1 consists of two graphs. The first, labeled Figure VI-1A: "Visibility Range Determined by the Integrated Assessment System", represents the range of estimated visibility conditions between the baseline forecast assumptions and a maximum emissions management alternative in the Integrated Assessment System. The darkly shaded area on the graph represents the difference between the estimated visibility conditions resulting from current air quality programs and the maximum improvement from emissions control actions that were included within the Integrated Assessment System. #O0*(( One limitation of the Integrated Assessment System is that several source categories were not characterized as incorporating cleaner emissions technologies over time as is likely under current and future air quality management programs. To address this shortcoming, the Commission developed a "bounding" estimate of the upper limit visibility conditions that could result from making adjustments to the Integrated Assessment System baseline assumptions for both growth of certain sources and future controlled emissions from certain sources. The second graph labeled Figure VI-1B: "Visibility Range Expected from Recommendations", reflects this approach. The darkly shaded area of this graph represents the difference between holding visibility constant from the year 2000 to a maximum potential improvement from changes in the Integrated Assessment System baseline assumptions and future source control levels. To define the maximum source control, certain source categories were assumed to reduce their contribution to extinction over time in a way similar to Integrated Assessment System source categories that had technological improvements of approximately 74% reduction from 1990 levels of impact. This probably results in an overprediction of the likely effect, however it is a reasonable estimate of the maximum effect for this bounding exercise. The Integrated Assessment System source categories that were adjusted for this estimate are: industrial/commercial fuels, non-road diesel, industrial processes, solvent use, a portion of other point sources, and other area sources. The estimate also reflects a change in the baseline assumptions for paved road dust in the Integrated Assessment System. This graph assumes small growth in paved road dust from increased vehicle miles traveled to the year 2000 and then a leveling off. This was based on uncertainty of the current contribution of road dust to light extinction. Overall, the graph reflects the Commission's belief that, under its definition of "reasonable progress," most source categories will improve efficiency and reduce emissions over time. The emissions reductions and associated visibility change plotted in this graph would be tracked and checked by monitoring long-term trends. The lightly shaded region on the bottom of both graphs in Figure VI-1 represents the "background" light extinction from natural causes (e.g., windblown dust). On average, this amount of extinction represents the best annual average extinction possible if all the effects of human-caused impairment are addressed. Currently approximately 20% of the days have this visibility level. This is approximately equivalent to the best visibility conditions pictured in the Introduction and plotted in Figure II-7. Human activities that were not included in the Integrated Assessment System options for control are approximately 2 Mm-1 above this "background" level. While the improvement in extinction associated with the recommendations in the second graph in Figure VI-1 may appear small, they will correspond to much larger changes on some days. While these graphs show effects only at Hopi Point, the Commission's recommendations are likely to result in approximately the same range of visibility benefits at other Class I areas. Figure VI-1A Figure VI-1B"P0*(( ANALYSIS OF SPECIFIC COMMISSION RECOMMENDATIONS Introduction This section reviews in greater detail the likely effects of the Commission's recommendations in light of the evaluation criteria described in Section II. The Commission has divided its six criteria into two groups: visibility benefits and economic effects in one group, and social, environmental, equity, and administrative effects in another. The first part of this section is an overview of the Commission's efforts to develop rough cost estimates for its recommendations. The second part of this section discusses specific Commission recommendations. Visibility and costs are addressed in connection with each set of recommendations. The remaining four criteria are discussed as a separate group. The Commission's recommendations reflect, but are substantially different from the scenarios developed initially by its technical committees. The Commission represents a range of interests, and its recommendations reflect the real world of give and take among these interests. The Commission could not simply decide to adopt one of its earlier scenarios because Commission members needed to address a range of concerns not reflected in those scenarios. One such example is recommendations supporting pollution prevention and renewable energy. In addition, the Commission's early scenarios could not have anticipated all the different combinations of controls that would be considered. As a result, there is not a perfect fit among the Commission's recommendations, the early scenarios used in modeling, and prior reports to the Commission. Where some or all of a recommendation is not part of an earlier scenario, it is possible only to estimate its visibility benefits or economic costs at this time. An examination of the Commission's recommendations requires a synthesis of its earlier analytical work and new analyses that reflect the control choices recommended by the Commission. The Commission's technical committees have begun this task, and the results of their work are discussed below. Certain points should be kept in mind when looking at modeling results that show visibility effects. One is that data about visibility effects often are stated in terms of an annual average. This average includes effects for "clear" days as well as "dirty" days. Most emissions reductions, however, are directed at improving air quality on dirty days, and using an annual average understates their short-term effect. For example, the effects of emissions reductions achieved in Los Angeles will only be felt 25% of the time on the Colorado Plateau, due to wind patterns. On days when those effects are felt, they will be much greater than the annual average. Another important point is that most of the modeling to date addresses visibility effects at only one receptor: Hopi Point in Grand Canyon National Park. This receptor is not necessarily representative of all Class I sites, but it offered a substantial amount of high- quality data. Hopi Point may have unique localized influences, and it is also influenced by emissions from a combination of directions that may not occur at other Class I areas. To address these potential limitations, the Commission has analyzed three other Class I areas. This broader approach makes more emission source regions relevant to the analysis, but is not a complete substitute for modeling all Class I areas. Q%Q0*(( Preliminary Cost Scenario It is not possible to estimate reliably the economic costs and benefits of the Commission's recommendations at this time. The recommendations are largely conceptual in nature, and the direct and indirect costs and benefits will vary depending on when and how specific strategies are implemented. The Commission has begun work to develop projections of the direct and indirect costs of achieving visibility improvements at Class I areas on the Colorado Plateau. Direct costs are the costs of imposing emission controls to improve visibility. Indirect costs are the additional effects on the region's economy from imposing those controls, including wages, employment, and "feedback" of expenditures into the regional economy. Sources of emissions in the West previously have incurred costs in order to comply with requirements of the federal Clean Air Act, and state and tribal programs covering all aspects of air quality. These costs will continue. The Commission's focus is on any additional costs, beyond those resulting from compliance with current law, that may be associated with improving visibility at Class I areas on the Colorado Plateau. As a first step, the Commission has developed rough estimates of some of the potential costs and benefits associated with emission management options that bear some similarity to its recommendations. These emission management options were designed early in the Commission's process, and do not match the Commission's recommendations. The Commission's rough estimates using these early options show the following: 1. There will be no significant incremental cost associated with the Commission's recommendations in the short term because they reflect diligent implementation of existing programs and new programs likely to be implemented for other reasons. 2. If the full set of recommendations is implemented, including a market-based emissions cap and trading program, the potential range of costs after 2010 under the Commis sion's preliminary rough estimate is from $500 million to $1.8 billion per year. (These cost estimates were generated by the IAS based on optimization runs for 25% and 80% of the Maximum Management Alternative.) This translates roughly into a -0.1% change in gross regional product in peak years, or approximately $10 per person, and an overall increase of jobs in the region of approximately 0.5% through 2040. These rough estimates are only the first step in developing an estimate of costs associated with the Commission's recommendations. They do not reflect any cost savings or economic benefits that may be associated with these emission reductions, such as health care savings and enhanced property values."R0*(( Analysis of Air Pollution Prevention Recommendations Visibility and Cost Effects There currently is no quantitative assessment of the visibility improvements that might result from the Commission's recommendations in this area, or of their likely economic effects. Intuitively, substituting non-emitting or lower emitting technologies likely will result in improved visibility. This includes encouraging "clean" sources of energy in new industries. Several recommendations likely will have direct economic effects. One example is recommendation #3, which supports economic incentives to promote industrial retooling that reduces emissions. Another example is recommendation #6, which suggests the possibility of charging emission fees for air pollution. Analysis of Stationary Source Recommendations Visibility and Cost Effects The recommendations regarding stationary sources involves establishing emission reduction targets for sulfur dioxide consistent with those anticipated under the Baseline Forecast Scenario, which was designed to reflect requirements under current regulations. It is anticipated that the emission reduction targets will be achieved through compliance with current regulations and voluntary and economically driven decision making of sources. Therefore, no additional costs would be incurred to impose controls if the targets are met. The only cost of the program would be the administrative aspects of collecting and analyzing information on to emission trends in the Transport Region. If emission reductions are not achieved through compliance with current regulations and voluntary and economically driven decision making, then a program would be established to enforce more rigid reductions. Earlier studies showed that a regional emissions cap and market trading program is the most cost effective approach to deal with regional haze. However, equity and administrative issues associated with this type of program are complex and need to be dealt with thoroughly in developing a detailed implementation plan. Under this "back stop" program, some costs of controls may be expected, but cannot be quantified at this time. The incorporation of other pollutant species into the stationary source program will have similar emission reduction effects. To the extent that long range targets are established on the basis of expectations under current regulatory requirements, then no additional costs associated with the visibility program would be incurred, other than monitoring and assessment. It is anticipated that annual average light extinction from 1990 through 2040 at Hopi Point would be improved between 0.8 and 1.0 Mm-1, depending on the actual control levels achieved for those stationary sources sectors which have not been analyzed in detail.!S0*(( Analysis of Mobile Source Recommendations Visibility and Cost Effects The Commission's recommendations incorporate national, regional, and local strategies, to address mobile source emissions. In reviewing these recommendations and their projected effects, it is important to bear in mind that the Commission's model appears to understate urban effects, and that mobile sources are a significant part of urban emissions. As a result, it is likely that the model underpredicts mobile source impacts on visibility, primarily tailpipe emissions. Current modeling shows that approximately 30% (3.5 Mm-1) of the annual human-caused light extinction at Hopi Point in the year 2000 is caused by mobile sources (roads, on-road vehicles, off-road vehicles, aviation, marine, and locomotives). Most of this impact (2.5 Mm- 1) is attributed to road dust under current modeling; the balance (1 Mm-1) comes from tailpipe emissions. As part of a national strategy, the Commission recommends supporting the 49-state LEV. A recent study by the AAMA shows that the 49-state LEV is likely to reduce emissions of NOx and VOC from on-road vehicles below the BFS by at least 35% by 2020. According to the Commission's model, this would translate into only a small annual visibility improvement at Hopi Point. However, more work is required to determine whether the model underestimates this impact. Potential visibility benefits from all other mobile source categories (off-road vehicles, boats, airplanes, locomotives) are approximately 11% of the total mobile source contribution based on current modeling. The Commission has not modeled the visibility effects of its proposed regional and local mobile source initiatives. The same limitation applies to estimates of the costs associated with imposing mobile source controls. Depending on the costs associated with different categories, it may be cost-effective to achieve the relatively small visibility benefits associated with different national strategies noted above. Additional work is required to develop this information. Analysis of Area Sources/Fire Recommendations Visibility and Cost Effects Millions of wildland acres in the Transport Region are at risk from catastrophic wildfire. These areas will burn eventually, and the fires will impair visibility at Class I areas on the Colorado Plateau. The Commission's models indicate that emissions from fire, both wildfire and prescribed fire, is likely to have the single greatest impact on visibility at Class I areas through 2040. Current modeling indicates that, at certain times, increased visibility impairment from fire is likely to exceed the potential visibility improvements associated with other Commission recommendations.#T0*(( The Fire Emissions Project of the Commission found that, historically, fire occurred on approximately 35 million acres annually. This corresponds to an annual visibility impact of 8-13 Mm-1. Current prescribed fire programs across the Transport Region cover approximately 1.2 million acres annually. In 1995, PM2.5 emissions from prescribed fire were estimated to be approximately 75,000 tons per year, less than 1% of total PM2.5 emissions from all sources in the Transport Region. The proposed future prescribed fire programs of land managers would treat approximately 6 million acres annually by the year 2040, increasing the relative contribution to 3% of total PM2.5 emissions in the Transport Region. This projected target is consistent with current land management agency fire policies, but is dependent on available resources and funding. Significant increases in fire on all wildlands will occur, whether by managed prescribed fire or by uncontrolled wildfire, if proposed prescribed fire programs are not implemented. Fire has seasonal impacts on visibility; it is not a constant influence. During certain periods (days or weeks) of intense fire activity, the visibility impacts of prescribed fire may be much greater than the average annual impacts. Most wildfires occur in the summer and fall; prescribed fires are used in the spring, summer, and fall. The clearest days on the Colorado Plateau occur during the winter. As a result, increased fire emissions are likely to make the worst 20% of days even worse, rather than impair visibility on clear days. Both prescribed fire and wildfire activity are dependent on weather conditions, resulting in visibility effects that can fluctuate widely from year to year. Table VI-1 shows the range of visibility impacts that are projected to occur from the use of prescribed fire and wildfire. KU0*(( TABLE VI-1 Annual Average1 Prescribed Fire/Wildfire Visibility Impacts in Mm-1 Year Prescribed Fire Baseline2 Prescribed Fire with Maximum Controls3 Wildfire4 1990-2000 0.3 - 0.5 NA 0.1 - 1.0 2010 1.5 - 2.0 1.4 - 1.7 0.1 - 1.0 2040 1.6 - 2.2 1.4 - 1.9 0.1 - 1.0 NV0*(( 1 Seasonal impacts may be 2-3 times higher than the annual average. 2 Baseline projections in 2010 and 2040 reflect projected prescribed fire programs under current land management policies. Emissions may be overestimated due to fiscal and personnel constraints and National Ambient Air Quality Standards requirements. 3 Prescribed fire emissions can be reduced through smoke reduction measures (mechanical treatment, etc.). These impacts may be further mitigated by managing the timing of burning based on meteorology. 4 Although the Commission believes that increased use of prescribed fire activity will result in long-term reductions of wildfire emissions, the Commission has been unable to quantify this benefit. The Commission's recommendations focused on ways to limit the increased visibility impairment from fire that could occur through 2040. Since land managers will be increasing their use of prescribed fire techniques to reduce wildfires, there is an opportunity to reduce the growth in visibility impairment projected to occur. It is important to bear in mind that fire has highly variable effects on visibility, even on a daily basis. The Commission's model cannot reflect this variability. Even using "optimal" smoke management measures, prescribed fire's contribution to annual visibility impairment at Hopi Point could increase by 400% between 1995 and 2040. The Commission's fire modeling projects that use of optimal smoke management measures could decrease fine particle (PM2.5) emissions from prescribed fires by approximately 15- 20%. This would limit the increased visibility impairment at Class I areas that likely will be caused by prescribed fires through 2040. In practice, land managers consider daily weather conditions to minimize effects from prescribed burning. The Commission's model does not permit an analysis of how these decisions, based on weather conditions, influence smoke impacts. Using "optimal" smoke management and emission reduction measures is projected to cost approximately $500-$2,000 per ton of PM2.5 reduction. Reducing PM2.5 emissions by 15- 20% over projected increases is estimated to cost approximately $65-$75 million annually. Analysis of Clean Air Corridors Recommendations The Commission is not recommending any special programs or regulations for clean air corridors beyond existing law. The basis for this approach is model results showing that projected emissions growth in the studied clean air corridor is not expected to have a perceptible impact on visibility at Class I sites.#W0*(( Analysis of Recommendations Regarding Emissions Within and Near Class I Areas Visibility and Cost Impacts The Commission's recommendations address a range of transportation and energy-related emissions, as well as emissions from prescribed fire, that occur both within and near Class I areas. Particle emissions in and near Class I areas deserve particular attention because they have potential immediate consequences for visibility. Approximately two-thirds of particles measured at Hopi Point consist of fine soil and coarse material (PM2.5 and PM10). Fine soil from sources near and distant from Class I areas accounts for about one-third of the visibility impairment caused by particles. Sources of coarse material have relatively small spheres of influence, i.e., coarse material generally doesn't travel far. As a result, the data from Hopi Point indicate that sources of coarse material located close to Class I areas, such as unpaved roads, are likely to be more important to visual air quality than regional sources. Forest fires burning close to or within Class I areas can also be expected to have significant impacts on visibility, since they emit coarse and fine dust as well as elemental and organic carbon. The Commission recommends improved planning to reduce visibility effects from sources of coarse material and fine dust both within and near Class I areas. The Commission's model does not allow modeling of the potential visibility impacts of this recommendation. The same modeling limitation applies to the recommendation that strategies be developed to limit emissions from local sources. The Commission has not quantified the visibility benefits associated with its recommendations concerning other transportation and energy-related emissions. The Commission has not developed any cost analysis for these recommendations. Analysis of Transboundary Emissions Recommendations Visibility and Cost Effects The Commission's model presently shows that emissions from Mexico result in annual average visibility impacts at Hopi Point of approximately 1.68 Mm-1. Of this amount, approximately 1 Mm-1 is attributed to industrial and residential sources near the U.S.- Mexico border. Of the remainder, approximately half is attributed to specific stationary sources; the remainder to off-shore shipping emissions that travel across Mexico to the United States. This is approximately 17% of manageable visibility impairment at Hopi Point on an annual average basis. Using an annual average likely understates the impact of these emissions on a given day, because meteorological conditions limit their influence to approximately 25% of the year. It is likely that on certain days the light extinction is much greater. The Commission has not modeled visibility impacts at other Class I areas. "X0*(( Most of the transboundary emissions (about 60%) are SOx, and most come from area sources within Mexico. At least one smelter located within Mexico is projected to be responsible for approximately 14% (0.24 Mm-1) of the annual total transboundary light extinction at Hopi Point. The Commission is aware of reports that this source is scheduled to be shut down within the next few years. A comprehensive emissions inventory will give a clearer picture of the different sources of transboundary emissions. Programs to finance air pollution control projects, to provide incentives for transboundary investment in pollution control, and to retire major emitting sources are likely to have visibility benefits at Hopi Point. However, more work is required on the emissions inventory before these benefits can be quantified. One important issue associated with these emissions is whether they are "manageable" in the same way that emissions from sources located within the United States are manage able. The Commission is unable at this time to estimate the potential costs associated with its recommendations. Analysis of Scientific and Technical Needs Recommendations The Commission has made a number of recommendations that include additional monitoring, data collection and reporting. These activities are the key to implementing many of its other recommendations. It is not practical at this time to estimate the costs associated with these activities. Discussion of Environmental, Social, Equity, and Administrative Effects The Commission's recommendations are a mix of the specific and the general. While analysis of the economic, social, environmental, equity, and administrative impacts of specific recommendations can yield robust conclusions, predicting the effects of general recommendations is at best an uncertain process. This is particularly true for the 211 Indian tribes located on the Colorado Plateau, whose peoples have unique economies and lifestyles. These issues are addressed more fully in Section IV on "Tribal Perspectives" in this report. The Commission's economic model also has certain limitations. The process for evaluating criteria other than costs relies primarily on data from the economic model, which present impacts at the level of a large county. The economic model is not designed to address rural areas with small populations, or Indian tribes, and its output has limited utility at best in assessing impacts for these groups. The Commission's equity concerns include addressing the following questions: Are the sources causing the problem paying for/contributing fairly to the solution? Are sources causing the problem paying for the solution in proportion to their current contribution and current control levels? The Commission's formal assessments have not analyzed whether some income groups will be affected more than others or whether there are ethnic patterns to the outcomes of the recommendations. These issues are of particular concern to areas which are relatively underdeveloped within the Transport Region. h$Y0*(( With respect to equity for rural and underdeveloped areas, including most tribal lands, it is important to note that such areas have not contributed significantly to the regional haze problem. One method for measuring equity is to ensure that all groups contribute fairly to solutions, relative to their role as an emissions source and their economic position (that is, in proportion to the ability to pay). While the Commission has sought to distribute the burden of its recommendation equitably, inadequacies in the primary and secondary assessment process (e.g., lack of emissions data for tribal lands, inability of the economic model to analyze areas smaller than a county, and lack of tribal data inputs to economic modeling) require continued vigilance to guarantee strong application of the equity criterion in all implementation plans and in monitoring the impacts of the Commission's recommendations. With these limitations in mind, the Commission offers its perspective on the so-called "secondary" impacts associated with its recommendations. Tourism. One issue relevant to all the Commission's recommendations is tourism in the region. Research conducted for the Commission shows that national parks in the West are important contributors to the economy as well as the quality of life. National parks in the study generated over 100,000 jobs and almost $5 billion in gross regional product in 1994. Most park visitors come to enjoy the scenery. Any noticeable impairment of visibility could significantly affect park visits and, as a result, the regional economy. However, there currently are no studies that assess the link between air quality and park visits, so stronger conclusions cannot be drawn. Air Pollution Prevention. The Commission's recommendations concerning air pollution prevention illustrate the limitations of projecting effects at this time. The recommendations themselves are general in nature. Because they were not modeled, there presently is no information about the costs and benefits. Nevertheless, there is reason to believe that promoting alternative energy sources would have some economic benefits, in the form of increased investment in alternative technologies and increased employment in the alternative technology sector. Some Indian tribes have invested significant resources in this area, and could benefit economically from expansion of alternative energy technologies and creation of incentives for their use. To the extent there are economic benefits to Indian tribes investing in these technologies, it is reasonable to expect some social benefits. "Clean" technologies would likely have an overall positive impact on the environment of the region. However, a more specific conclusion would require knowledge of the specific technologies under consideration. Stationary Sources. Turning to the recommendations about stationary sources, there are some important concerns. Under a regional cap/trading program, there are fundamental questions about how initial credits will be allocated and how reductions would be timed. If credits are allocated simply on the basis of historical emissions, there are potential equity issues for new emissions sources. This concern has been raised specifically by Indian tribes. There also are significant equity and other issues about how such a program affects sub-regions where companies may sell their credits and move away, or conversely how it would affect areas where industries that acquire pollution credits are located. h$Z0*(( Mobile Sources. To the extent that national strategies, such as the 49-state LEV or low sulfur fuels, are adopted, the average costs of implementation will fall because they are spread over a large area and population. The Commission is aware of the potential equity impacts associated with some of its mobile source recommendations. One example is retiring high-emitting vehicles. These vehicles tend to be owned by persons without the economic means to acquire newer, low-emitting vehicles. This recommendation also poses potential equity issues for Indian tribes. Another example is enhanced inspection and maintenance programs. These can have differential impacts on lower income groups, and raise equity concerns. Area Sources/Fire. The use of prescribed fire has clear significance for the health of ecosystems throughout the West. A better understanding of fire's role in ecosystem health underlies the recommendation supporting the increased use of prescribed fire, along with smoke management techniques. In the long run, this recommendation will result in environmental benefits in the Transport Region. Mechanical treatment will be labor-intensive and may provide significant employment opportunities. Substantial subsidies may be required for some use of the biomass resulting from mechanical treatment programs. Biomass utilization may be possible in some energy markets, and the development of other woody material markets is also possible. There are social and equity issues associated with fire policy. One of these involves Indian tribes that conduct their own timber, agriculture, and habitat management operations. Any policy that restricts the ability of these tribes to develop these operations could have an impact disproportionate to that felt by other groups, such as federal land managers. This issue is discussed further in the section on "Tribal Perspectives." Emissions Within and Near Class I Areas. The Commission's recommendations are likely to affect communities located "within and near" Class I areas. These could be major urban centers, smaller rural communities, or Indian tribes. One potential emissions source in these communities is unpaved roads. Measures to reduce dust could have disproportionate impacts on these communities, and on groups within each community. Paving roads can increase use, thereby causing a range of economic and social impacts. Depending on who paid to pave roads, there could be significant equity impacts as well. Pollutant "plumes" from urban areas also raise equity issues involving who should bear the cost of addressing mobile and area source emissions that are part of these plumes. Transboundary Emissions. Communities located close to the border may be bearing a disproportionate share of the impact from transborder emissions. These same communities probably would reap the greatest benefit from emissions reductions, but may be unable to contribute financially to emission reduction strategies. This issue is also addressed in the section on "Tribal Perspectives."