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Colorado Regional Haze SIP Colorado Regional Haze SIP Reasonable Progress AnalysisReasonable Progress Analysis
Rocky Mountain National Park Longs Peak – 14,259’Colorado’s 15th Tallest
Curt TaipaleColorado DPHE - APCD
Topics
• Analysis Context• UP vs RP
– What is reasonable?• Preliminary 2018 Modeling Results for Colorado• RP Analysis for Rocky Mountain NP
– Sulfate & Nitrate PSAT– Boundary Conditions & International impacts– Organic Carbon– Elemental Carbon– Fine Soil– Coarse Mass
• Final Thoughts
Page 2
Analysis Context• Time is short – SIPs are due in December
– Ideally, today’s Reasonable Progress analysis should be based on final BART modeling for the whole WRAP region
– Realistically, it’s too late to implement additional controls beyond BART • In lieu of these limitations, Colorado plans “State Share” analysis for
determining RP on the dominant man-caused species of visibility impairing pollutants – sulfate & nitrate– Assumes that each state is working on emission reduction strategies that
benefit all impacted Class I Areas– Some CIAs w/high out-of-state impacts may not benefit from this approach
• Can be addressed through interstate collaboration• OC addressed with limited PSAT; EC, CM & fine soil can be addressed
through a more basic analysis using weighted emission potential (WEP), emission inventory (EI), positive matrix factorization (PMF) and Emissions Trace (ET)
• Analysis focused on Worst Days– Assume 2018 model projections are adequate for estimating maintenance
of Best Days– Future IMPROVE monitoring will validate this assumption
Page 3
Uniform Progress vs Reasonable Progress
• For Colorado, we will assume the overall 2018 UP goal in Haze Index metric (deciviews) is 14/60ths or about 23% – UP is a goal that is defined by the 60-year glide slope
• UP not necessarily equal to Reasonable Progress• RP is unique to each CIA (or IMPROVE monitor), and/or component of
visibility extinction.
Start Year
Planning Period
RH SIP Submittal Year*
RH SIP Horizon Year
Planning Period [years]
Percent Reduction Goal
1st 2008 2018 14 23.3%2nd 2018 2028 10 16.7%3rd 2028 2038 10 16.7%4th 2038 2048 10 16.7%5th 2048 2058 10 16.7%6th 2058 2064 6 10.0%
Total: 60 100.0%
*Plans submitted toward the end of year are counted in the following year and 5-year plan updates not included.
Regional Haze State Implementation Plan Schedule
2004
Page 4
Species-Specific Approach to RPPage 5
URP depends on metric• In the Haze Index (deciview) metric, the URP goal is 23.3%, but in the
Extinction (1/Mm) metric, the species-specific URP goal is different for each component of extinction due to the non-linear relationship & site-specific Rayleigh
HI = 10ln(bext/10)Relationship between Haze Index & Extinction
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Haze Index [deciview]
Ext
inct
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[1/M
m] Delta = 30.8% @ 10 Rayleigh
Delta = 23% Delta = 23%
Delta = 18.7% @ 10 Rayleigh
Page 6
Measure Progress from Glide Slope• In the extinction metric, 23% is not the goal for each species, 2018
modeling progress is measured against the URP point on glide slope.• Non-linearity between extinction and HI is addressed by the curve of the
extinction glide slope.• For ROMO, the corresponding 2018 extinction reduction is about 28%
Page 7
Preliminary 2018 Modeling Results(three RRFs methods averaged)
Page 8
Rocky Mountain National Park• 265,000 acres on the
Continental Divide• 2.5 million visitors/year• 1st area in US with
critical load – 1.5 kg N/ha/yr (wet nitrogen deposition)
Page 9
Rocky Mountain National Park –BD/WD Composition
Page 10
Highest Sulfate & Nitrate in Colorado
ROMO – Best Days• 64 FR 35766 requires the RP goal for each CIA: “.. ensure no
degradation in visibility for the least impaired days ..”• Is a glide slope analysis necessary?
– Rule requires maintenance not improvement of best days
• 2018 modeling below 2000-2004 best days baseline of 2.29 dv• Thus - maintenance of best days is forecast for 2018
Page 11
Rocky Mountain National Park Species-Specific Uniform Progress & 2018 (plan02c) Modeling for Worst Days
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Years
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/Mm
]
Sulfate-Baseline Sulfate-GlideslopeNitrate-Baseline Nitrate-GlideslopeOC-Baseline OC-GlideslopeEC-Baseline EC-GlideslopeSoil-Baseline Soil-GlideslopeCoarse-Baseline Coarse-GlideslopeSulfate-Modeled: -14.9% Nitrate-Modeled: -13.0%OC-Modeled: -7.6% EC-Modeled: -32.3%Soil-Modeled: +89.9 Coarse-Modeled: Flat
Preliminary 2018 Modeling –Species-Specific for Worst Days
Page 12
Preliminary 2018 Modeling –Haze Index for Worst Days
Page 13
Rocky Mountain National Park Haze Index Uniform Progress & Preliminary 2018 Modeling for 20% Worst Days
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2000 2001 2002 2003 2004 2008 2013 2018 2023 2028 2033 2038 2043 2048 2053 2058 2064
Years
Haz
e In
dex
[dec
ivie
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Specific Days RRF (EPA)
Quarterly RRF
Monthly RRF
Rocky Mountain NP –Uniform Progress Analysis
• In HI, the modeled reduction is around 13%, so we’d like an additional 10% reduction to make the 23% UP goal.
• More sulfate & nitrate reductions expected in next model run– Not all Colorado BART is included
• Additional reductions in SO2 and NOx will be in place by 2018• Biggest: Pawnee (505 MW) ≈ 13,500 tpy SO2
– Do we need additional emission reductions beyond BART? • Won’t know for sure until all CO BART controls are modeled• PSAT provides some clues on progress towards Colorado share
Page 14
PSAT for Sulfate and Nitrate
• For sulfate & nitrate in 2018, the overall reductions ≈ 50%– Colorado will rely on other contributing states to do their part– Need another ↓ 20%-33% to just meet the UP goal
• Colorado Share: ↓ 80% SO4 and ↓ 67% NO3 – Does Colorado need to do more?– CO BART modeling will provide more reductions in SO4 & NO3– Will they be enough?
• Let’s look at other contributors.
Page 15
4-Highest Sulfate & Nitrate Contributors at ROMO
• We see that Boundary Conditions are the highest contributor for SO4 and 2nd for NO3 at Rocky in 2018.
• Across Colorado, BCs are the highest sulfate contributor for all our CIAs and in the top 3 for nitrate.
Page 16
Technique to address BCs
• Colorado may be unique, high BC impacts at our CIAsmay be due to Colorado’s close proximity to the center of the model domain and our relatively clean air compared to the rest of the world.
• We can’t control the BC emissions entering from the edge of the modeling domain.
• BC Options– Control them – Can’t– Ignore them – Not, they are too big!– Remove them from the analysis – Yes!
• How do we do that?
Page 17
Boundary Conditions/International (BCI) Visibility Impacts
• The PSAT BC visibility impacts are estimated by looking at the extinction difference (or delta) between 2018 CMAQ modeling and 2018 uniform rate of progress.
• We see that BCs represent 0.35 [1/Mm] of sulfate & nitrate extinction on the worst days at Rocky Mountain
• If we add in the international impacts of Canada, Mexico and Pacific Ocean the resultant extinction is 0.49 [1/Mm]
• This Boundary Condition/International (BCI) extinction is beyond the control of Colorado or any other State.
• Thus, Colorado will be removing BCI extinction estimates for SO4 & NO3 from the 2018 PSAT modeling.
Page 18
BC CAN MEX PO Total2018 Modeling SO4 [1/Mm] 1.988 0.274 0.304 0.193
2018 URP Extinction SO4 [1/Mm] 1.725 0.238 0.264 0.167SO4 Delta Extinction [1/Mm] 0.262 0.036 0.040 0.025 0.364
2018 Modeling NO3 [1/Mm] 0.740 0.189 0.000 0.0692018 URP Extinction NO3 [1/Mm] 0.649 0.166 0.000 0.060
NO3 Delta Extinction [1/Mm] 0.091 0.023 0.000 0.008 0.1230.354 0.060 0.040 0.034 0.487
Source Region
Rocky Mountain National ParkSulfate & Nitrate Boundary Condition/International (BCI) Impacts on 20% Worst Days
Sulfate BCI delta extinctionPage 19
Sulfate BCI extinction held to URPPage 20
Nitrate BCI delta extinctionPage 21
Nitrate BCI extinction held to URPPage 22
Removing BCI from the 2018 Modeling
• Sulfate BCI deduction (0.364 1/Mm) from CMAQ 2018 modeling – Overall progress towards 2018 goal improves from 54% to 72% (+18%)
• Nitrate BCI deduction (0.123 1/Mm) from CMAQ 2018 modeling– Overall progress towards 2018 goal improves from 49% to 60% (+11%)
• Is it fair to remove the BCI impacts from the 2018 modeling?– In the context of truly improving visibility at a CIA –probably not.– For CIAs close to UP and on the cusp of triggering additional State
controls, this analysis properly accounts for impacts beyond the control of a state.
– Further, “Is it fair to require more reductions from other sources to compensate for BCI impacts?” – maybe not in the 1st planning period
Page 23
ROMO Sulfate RP• Overall, SO4 is 28% short of 2018 URP
– Colorado anticipates that SO2 emission reductions from WY (7.7% Impact) and CEN (7.2% Impact) will provide improved progress in 2018.
– It is unreasonable for Colorado to provide additional SO2 reductions beyond CO share.
• Colorado share of SO4 reductions fall short of CO UP goal by 20%, thus additional sulfate controls may be warranted. – New 2018 CMAQ modeling (done in May 07?) of CO BART will likely
provide additional reductions (moderate) in sulfate impacts at the Park– Existing modeling analysis shows some CO BART SO2 reductions that
occurred early under the Metro VERA, and consent decrees on Craig & Hayden
– Until CO BART is modeled, Division staff is hesitant to suggest additional sulfate controls.
• Will CO BART SO2 reductions yield a ROMO SO4 ↓ >20% ? - maybe– If CO BART modeling falls short, the timing of quantifying the benefits of
additional SO2 controls, would likely occur after the RH SIP submittal date.
• Intuitively, we suspect coal-fired boilers and IC engines are the major source of most of the SO2 at ROMO but are there other uncontrolled or under-controlled source categories?– lets looks at the Sulfate ET - Whats that?
Page 24
ROMO 2018 Sulfate Emissions TracePage 25
ROMO Nitrate RP • Overall, NO3 is 40% short of 2018 URP
– Colorado anticipates that NOx emission reductions from WY (11.0%) and UT (5.9%) will provide improved progress in 2018.
– It is unreasonable for Colorado to provide additional NOx reductions beyond CO share.
• Colorado share of NO3 reductions fall short of CO UP goal by 33%, thus additional nitrate controls are likely warranted– New 2018 CMAQ modeling of CO BART will provide some minor
reductions in nitrate impacts at the Park but probably not near enough to make CO NO3 UP
– Top 100 under controlled or uncontrolled point sources (largest contributor) nearby the Park will be evaluated for controls
– Timing of quantifying the benefits of additional NOx controls, would likely occur after the RH SIP submittal date.
• Through stakeholder process, Division will develop RH-RP regulation that will establish process for deciding controls/sources
• Intuitively, we suspect coal-fired boilers, IC engines and mobile sources are the major sources of most of the NOx at ROMO but arethere other uncontrolled or under controlled source categories?– lets looks at the Nitrate ET
Page 26
ROMO 2018 Nitrate Emissions TracePage 27
Top Colorado NOx Point Sources
• BART controlled sources highlighted in green
• Closest big non-BART NOx source– Rawhide (285 MW) has LNB w/OFA
Page 28
ROMO Organic Carbon
Wild Basin Area of Rocky Mountain National Park, Thunder Lake (Photo courtesy of NPS)
Page 29
Organic Carbon RP Analysis
• PSAT modeling allows for some limited analysis of OC under organic aerosol tracer for three species– AORGA: Secondary Organic Aerosol (SOA) Biogenic – AORGB: SOA Anthropogenic– AORGPA: Primary Organic Aerosol (POA) Anthro & Biogenic – Limitations: Source regions unknown – can’t use “State Share”
analysis tool• Analysis Approach
– Use PSAT to identify amount of extinction attributed to biogenic– Use Positive Matrix Factorization (PMF) to further confirm portion
attributable to smoke– Use Weighted Emissions Potential (WEP) tools to identify source
regions & type emissions contributing to POA & VOC (forms SOA)– Use POA & VOC emission inventories (plan 02 & base 18) to
determine contributing sources & changes in anthropogenic portion
– Use OC ET to confirm sources
Page 30
OC PSAT for Worst Days in 02b, 02c & 18b
• Modeled 2018 OC shows ↓ 27% (we need 100%), far short of OC UP goal (see slide 15)
• Based on OC PSAT for worst days, OC occurs over three seasons
• Not much seasonal variation
Page 31
OC PSAT for 2018 Worst Days
• How much OC is controllable?• Since there isn’t much seasonal variation in
worst days, all seasons averaged– 71% AORGB (SOA Biogenic – in green)
• Likely VOCs from vegetation & wildfire smoke– Check PMF to see how much is smoke
• Wildfire is a necessary part of forest ecology • Thus, AORGB is not controllable
– 5% AORGA (SOA Anthropogenic – in red)• Mostly point, area, mobile
– Check VOC Emission Inventory for 02c & 18b– AORGA contribution to OC is very small
– 24% AORGPA (POA Biogenic/Anthro – in blue)• Mostly area & mobile, some biogenic
– Check POA Emission Inventory for 02c & 18b– Look at OC Emissions Trace
Page 32
Positive Matrix Factorization (PMF)
• PMF indicates that smoke is a significant contributor (44%) to OC impairment on the worst days at ROMO during the baseline period
Page 33
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MG
MN NI
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Smoke Profile
Statewide & FR VOC Emission Changes
• Bar chart indicates sharp contrast between statewide & FR biogenic VOC• In Front Range, area, point & mobile sources contribute 53% of the VOC
emissions that could form SOA anthropogenic (5% of total OC)• By 2018, FR area sources ↑ by 40% but mobile ↓ significantly• Lets look at the OC WEP to see the source regions impacting ROMO
Page 34
OC Weighted Emissions Potential (WEP) Map
• Realize the WEP tool doesn’t consider complex chemistry or deposition• OC WEP map indicates that the Front Range is the dominant source of anthro OC• VOC WEP Bar Chart indicates that Colorado biogenics are the biggest source of
VOC (source of OC SOA), with anthropogenic sources (point, area & mobile) contributing a very little to OC SOA– Thus, even huge reductions in anthro VOC emissions would have little effect on ↓OC
SOA
Page 35
POA Weighted Emissions Potential (WEP)• Remaining OC contributor is AORGPA- Primary Biogenic & Anthro
– Primary Organic Aerosol (POA) emissions are the source of AORGPA
• We see that Colorado area sources & anthro fire are the largest contributors to POA
Sources and Areas of Potential Organic Carbon Emissions Influence2018 Projections for Rocky Mountain National Park, CO
20% Worst Visibility Days
4.7 2.7
71.9
0.7 0.4 0.3 0.7 0.1 1.5 0.23.5
0.8 2.5 0.2
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Biogenic Natural Fire Point Area WRAP Area O&G Off-Shore On-Road Mobile Off-Road Mobile Road Dust Fugitive Dust WB Dust Anthro Fire
Page 36
Statewide & FR POA Emission Changes• 2018 POA emissions from natural/biogenic sources are insignificant <3%• 2018 POA emissions from anthro sources (area, mobile & Rx fire) about 96%
– We see FR area sources ↑ 4% by 2018, but mobile ↓ >26%
• Let’s look at the OC ET to put all this in perspective
Page 37
ROMO 2018 OC Emissions Trace• POA is not inventoried in Colorado, thus area source POA is likely modeled
– How do we evaluate potential emission controls on such a category? Can’t• Additional VOC controls on point & area sources would yield little ↓ OC SOA• Division recommends that additional VOC or POA emission controls are not
reasonable, thus OC RP is satisfied
Page 38
ROMO Elemental Carbon
Page 39
ROMO 2018 EC for Worst Days• Modeled 2018 EC shows ↓ 127% which exceeds UP goal (see slide 15)• Is this reduction reasonable progress?
– What are the sources of EC?– Lets look to see if much more can be done?
• We see that 2018 EC (in black) appears to higher during the summer
Page 40
ROMO PMF for EC• PMF indicates all categories (except dust) contribute to EC
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Page 41
Nitrate Rich-Secondary Profile
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Mobile Profile
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Sulfate Rich-Secondary/Coal Combustion Profile
Sources and Areas of Potential Elemental Carbon Emissions Influence2018 Projections for Rocky Mountain National Park, CO
20% Worst Visibility Days
3.8 3.6
72.5
0.7 0.4 0.6 0.7 0.1 1.1 0.23.6 0.5 3.6 0.7
6.40.2 0.9 0.4
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Biogenic Natural Fire Point Area WRAP Area O&G Off-Shore
On-Road Mobile Off-Road Mobile Road Dust Fugitive Dust WB Dust Anthro Fire
ROMO EC WEP for 2018 Worst Days• Remember the WEP analysis doesn’t consider complex chemistry or
deposition• EC WEP indicates that Area, On & Off-Road Mobile sources are the
largest contributors– Highest EC concentrations are from Denver metro area
Page 42
FR & Statewide PEC Emission Changes
• Colorado area & mobile sources comprise over 97% of FR PEC emissions• WRAP Area source pivot table doesn’t track EC emissions
Page 43
Area Source Pivot
ROMO 2018 EC Emissions Trace• Overall PEC emissions ↓ 51% from Plan02c to Base18b• On & Off-road mobile sources ↓ 75% & ↓ 55% respectively and are largely
regulated under the federal rules– Other than VMT reductions, State would need to request EPA approval for CA fuel &
emission standards for on/off-road mobile sources –a lengthy & costly process
• Area sources ↑5%, Colorado doesn’t inventory EC emissions, thus area source EC is likely modeled– Not sure a 4-factor RP analysis can be done on modeled number
• Based on the analysis, the Division recommends that additional controls for EC are not reasonable, thus EC RP is satisfied
Page 44
ROMO Soil (PM Fine)
Page 45
ROMO 2018 Modeled Soil Projections
• Modeled 2018 Soil ↑ 344% (slide 15)– Soil glide slope is pretty flat, thus any small change is exaggerated– Let’s look at the change in PM Fine emissions from plan02c to plan18b
Page 46
FR & Statewide Soil (PM Fine) Emissions• For 2018, statewide soil emissions ↑ 9% but FR ↑ 32%• Based on relative contribution, we see fugitives change the most• Let’s look at Fine PM WEP
Page 47
Sources and Areas of Potential Fine PM Emissions Influence2018 Projections for Rocky Mountain National Park, CO
20% Worst Visibility Days
4.0 3.5
43.2
1.8 1.8 1.8 2.4 0.7 1.5 1.66.1
1.26.2
0.5
18.3
0.53.5 1.2
0
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Arizon
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fornia
Colorad
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Idaho
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Nevad
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Mex
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h Dako
ta
Oregon
South D
akota
UtahWash
ington
Wyoming
Pacific
Offs
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CENRAPEas
tern US
Mexico
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Biogenic Natural Fire Point Area WRAP Area O&G Off-Shore On-Road Mobile Off-Road Mobile Road Dust Fugitive Dust WB Dust Anthro Fire
ROMO 2018 Soil WEP for Worst Days• WEP shows soil sources are widely scattered statewide with the
highest concentrations in FR corridor• Windblown & fugitive dust comprise about 51% of Colorado impact• Colorado area & on-road mobile sources about 47%
Page 48
ROMO 2018 PM Fine Emissions Trace
• What makes up on-road, area, fugitive and windblown dust?– Windblown– On-road Mobile– Ag tilling – Residential wood burning – Road construction– Industrial/Commercial Construction
Page 49
ROMO 2018 PM Fine Emission Sources
• Windblown 0% change – modeled from land use & soil texture– Windblown is largely uncontrollable, thus no controls are considered reasonable
• On-road Mobile ↑ 54% - PM Fine is from vehicle exhaust and re-entrained dust which is a function of silt loading, vehicle speed & VMT– Metro area has a diesel vehicle inspection program for particulates– Metro area encourages vehicle trip reductions through mass transit and silt
loading is addressed by municipal street sweeping programs, use of liquid deicers or coarse anti-skid materials and permit controls on construction track-out
– Portion attributed to unpaved roads is not known– Additional controls could include expanding the diesel vehicle program area,
expanding the use of street sweeping & use of liquid deicers, and paving busy unpaved roads in close proximity to ROMO
• Ag Tilling - for most agricultural crops, tilling is a necessity and largelyuncontrollable– NRCS soil management plans address susceptible soils– State Ag Dept. encourages ag best management practices (no till, soil
conservation etc.),– Additional controls not considered reasonable
Page 50
ROMO 2018 PM Fine Emission Sources -Continued
• Residential Wood Burning– Wood-fired stoves must meet EPA certifications statewide, woodburning is
limited during winter in Denver metro area and since 1990’s, new homes must have NG fueled fireplaces throughout metro area
– Additional controls could include expanding the new home woodburning exclusion area
• Road construction and Industrial/Commercial Construction– Division issues dust mitigation permits on all construction activities disturbing
more than 25 acres.– Additional controls could include tightening dust permit control requirements or
↓ permit threshold
Page 51
ROMO 2018 Soil Reasonable Progress Summary
• Did we make reasonable Soil progress at ROMO?• No, 2018 PM Fine emissions statewide ↑ 2,977 tpy (↑9%) and
in Front Range ↑ 2,585 tpy (↑32%) – 2018 Point, Area, On-Road Mobile & Fugitives all increased – 2018 Off-Road Mobile, Anthro Fire & Road Dust all decreased
• Can we do more?– Division will evaluate additional controls such as:
• Expanding the Diesel Vehicle Inspection Control Area• Expanding the use of liquid MgCl deicers & street sweeping• Paving busy unpaved roads in close proximity to ROMO • Tightening land development permit control requirements• Reducing acreage threshold on land development permits statewide• Expanding the new home woodburning exclusion area to northern Colorado
Page 52
The WallThe Wall-- ROMO Coarse MassROMO Coarse Mass
Page 53
Coarse Mass CMAQ modeling
• For all IMPROVE sites, CMAQ v4.5 under-predicts for all months by 20-150%• For ROMO baseline worst days, CM seems highest during spring/summer/fall
(Apr- For Oct) which corresponds to a CMAQ monthly error bias > -90%.• Even a modeler would say this is not good
– We need to use another analysis technique
Page 54
ROMO 2018 Coarse Mass Projections
• CMAQ model holds 2018 CM modeling projections at baseline value• CM needs about 0.9 [1/Mm] of visibility improvement needed by 2064
– Without CMAQ modeling, we must use emission inventories and WEP tools to see were we are going
Page 55
FR & Statewide Coarse Mass (CM) Emissions
• For 2018, statewide fugitive dust emissions ↑ 63% but FR ↑210%– FR fugitives comprise 49% of dust emissions, windblown is 20%
Page 56
ROMO 2018 CM WEP• 2018 CM WEP map shows that in addition to the FR, CM sources on the
west slope & eastern plains contribute significantly to ROMO• WEP indicates that CO point, fugitives, windblown & road dust are the
major contributors to CM with some WB impacts from CENRAP• Let’s look at the CM ET
Page 57
ROMO 2018 CM Emissions Trace• What makes up point, fugitives, windblown and road dust?
– Point: Mineral Products, Electric Generation, Site Remediation, Primary Metal Production, Solid Waste Disposal, Food & Agriculture
– Others: Ag Tilling, Road Construction, Industrial Construction, Residential Wood Burning & Residential Construction
Page 58
2018 PM10 from Area Source Pivot Table doesn’t match up w/Emission Inventory
ROMO 2018 CM Emission Sources• Point Sources ↑ 34% • Division issues NSR/PSD permits on all PM10 sources > 2 tpy• Major PM10 (>100 tpy) sources subject to BACT controls• Minor PM10 (<100 tpy) sources subject to RACT controls
– Mineral Products (60%)• 47% Sand & Gravel• 26% Coal Mining & Handling• 7% Stone Quarrying
– Electric Generation (11%) - mostly coal-fired boilers• Major PM10 sources have baghouse controls
– Site Remediation (6%) one source - Rocky Mountain Arsenal– Primary Metal Production (4%)– Solid Waste Disposal (4%) mostly municipal landfills
• Controlled to BACT/BACM levels ?– Food & Agriculture Production (4%)– Miscellaneous Manufacturing (4%)
• Appears point sources >2 tpy are reasonably controlled to BACT/RACT levels
Page 59
ROMO 2018 CM Emission Sources - Continued
• Windblown 0% change – modeled from land use & soil texture– Windblown is largely uncontrollable, thus no controls are considered
reasonable• Fugitive Dust ↑ 63% & Road Dust ↑ 44%
– Ag Tilling (?%)- for most crops, tilling is a necessity & largely uncontrollable• NRCS soil management plans address susceptible soils• State Ag Dept. encourages ag best management practices (no till, soil
conservation etc.),• Additional controls not considered reasonable
– Road Construction (46%)/ Industrial & Commercial Construction (30%) and Residential Construction (6%)
• Division issues dust mitigation permits on all construction activities disturbing more than 25 acres.
• Additional controls could include tightening dust permit control requirements or ↓permit threshold
– Residential wood burning (6%)• Wood-fired stoves must meet EPA certifications statewide, woodburning is limited
during winter in Denver metro area and since 1990’s, new homes must have NG fueled fireplaces throughout Denver metro area
• Additional controls could include expanding the new home woodburning exclusion area
Page 60
ROMO 2018 CM Reasonable Progress Summary
• Did we make reasonable CM progress at ROMO?• No, 2018 PM10 emissions statewide ↑ 41,125 tpy (↑18%) and
in Front Range ↑31,305 tpy (↑70%)– 2018 Point, On-Road Mobile, Road Dust & Fugitives all increased – 2018 Area, Off-Road Mobile and Anthro Fire all decreased
• Can we do more?– Division will evaluate additional controls such as:
• Tightening land development permit control requirements• Reducing acreage threshold on land development permits statewide• Expanding the new home woodburning exclusion area to northern Colorado
Page 61
Final Thoughts
• Pivot tables can be tricky– Different SCC levels can tell you different
things
Page 62
A view from spacePage 63
Longs Peak
Estes Park
Allenspark
Rocky Mountain National
Park
NORTH
Extra Slides
Page 65
Sulfate CMAQ modeling
• CMAQ v4.5 does pretty well in predicting wintertime SO4 but under-predicts in the summer months when concentrations are higher.
• For ROMO baseline worst days, sulfate seems highest during spring/summer (Apr-Aug) but winter/fall seasons periodically appear as significant contributors
• ROMO 2018b sulfate RRF is 0.82
Page 66
Nitrate CMAQ modeling
• CMAQ v4.5 tends to over-predict nitrate in the winter months and under-predict in the summer months when concentrations are lower.
• For ROMO baseline worst days, nitrate seems highest during winter (Nov-Mar) but spring & summer seasons periodically appear as contributors
• ROMO 2018b nitrate RRF is 0.87
Page 67
Organic Carbon CMAQ modeling
• CMAQ v4.5 does a really good job in predicting summertime OC butspring & fall OC is over-predicted by 10-20%
• For ROMO baseline worst days, OC seems highest during summer (Jun-Aug) but spring & fall seasons also appear as significant contributors
• ROMO 2018b OC RRF is 0.95
Page 68
Elemental Carbon CMAQ modeling
• CMAQ v4.5 does a pretty good job in predicting summertime EC butspring & fall EC is under-predicted by 10-20%
• For ROMO baseline worst days, EC seems highest during summer (Jun-Aug) but spring & fall seasons also appear as significant contributors
• ROMO 2018b EC RRF is 0.74
Page 69
Fine Soil CMAQ modeling
• CMAQ v4.5 under-predicts during the spring/summer/fall months by 10-80% and over predicts in the winter by 10-40%
• For ROMO baseline worst days, soil seems highest during spring/summer/fall (Apr-Oct)
• ROMO 2018b soil RRF is 1.15
Page 70
