Document wreMKr9Mn4vxRoBnq8JGy70N4

V\D+ flA~e_ J~ "~s;-k~~ rto (C>V)~'--+- GS ~Y\~ {' ' l +o 6(?_ t\ V\Je. w ~ ',v----.. --\0 ,-1 C, ~ ' e.,~--{-1r'"\ . O V'\ {h c:_ e L4 ~ I Y\~V"\ t)C)-J, BuchananIngersoll ,~.. Rooney PC Edward G. Hild Principal _Government Relations l700 K Street. N.W.. Suite 300 Washington, DC 20006-3807 T 202 452 5480 F 202 452 7989 M 202 714 0348 edward.hild@bipc.com www.bipc.com Buchanan Ingersoll ~ Rooney PC Terrence Heubert Senior Advisor Government Relations 1700 K Street. N.W., Suite 300 Washington, DC 20006-3807 T 202 452 6041 : F 202 452 7989 M 202 494 8761 terrence.heubert@bipc.com www.bipc.com PennEast Pipeline Project Background and Required Federal Authorizations 1. Project Background The PennEast Pipeline Project involves the constructio n and operation of an approximately 120-mile, primaril y 36-inch diameter underground pipeline extending from receipt points in Luzerne County, Pennsylvania, to various delivery points along the system with a terminus near Pennington, Mercer County, New Jersey. PennEast will have capacity to transport approximately 1. l billion cubic feet of natural gas per day on a year-round basis and will provide service to numerous shi ppers who, in turn, provide critical natural gas supplies to major Northeast utilities such as UGI Utilities, New Jersey Natural , Elizabethtown Gas, South Jersey Gas, PSEG Power, and ConEd. PennEast will also serve major producers in the Marcellus Shale area by providing a much needed outlet for the ir production, and independent power generators that have proposed to connect to the PennEast system. PennEast will reduce energy costs and support thousands of jobs by constructing the infrastructure necessary to deliver clean-burning, American natural gas. o Reduce Energy Costs: PennEast will solve supply constraints by delivering lower cost natural gas produced in the Marcellus S hale region to utilities and other end users serving homes and businesses in Pennsylvania. New Jersey. New York and adjacent states. o Job Creation: All phases of the Project lifecycle will generate economic benefits. Design and Co11structio11: A Drexel Un iversity study estimates over $ 1.6 billion in economic benefits, 12,160 jobs supported from the investment, and $740 million in labor income generated from design and construction. Ongoing Regional Benefits: Combined with an estimated $893 mill ion of potential annual energy savings, PennEast represents a potential 011goi11g annual economic benefit of $ 1.2 1 billion and 8.041 jobs to the region. Other Industry Benefits: The Project also will support jobs in numerous industries. The Project will create hundreds of architectural and engineering jobs, as well as positive employment impact in industries other than construction, including: food services, landscaping, legal services, and real estate. The approximate capital cost estimate for the Proj ect is $ 1 billion. The projected in-service date for the Project is the second half of 20 18. 2. Federal Energy Regulatory Commission (FERC) Certificate Authorization Appl ication for a Certificate of Public Convenience and Necessity under the Natural Gas Act (NGA) filed with FERC on September 24, 20 15, after spending approximately I year in FERC's pre-fi ling process. Requested Order Date - August 1, 2016. Expected Order Date- Summer o f 2017. 3 . National Environmental Policy Act (NEPA) and Other Federal Authorizations Under the NGA, FERC is the lead agency for coordinating federal authorizations and for the NEPA process (primary responsibi lity for preparing the environmental impact s tatement) for applications to construct natural gas pipeline facilit ies pursuant S ection 7 of the NGA. Multiple federal authorizations are necessary fo r the cons truction and operation o f the Project (for example, state water quality certifications under Section 40 I of the Clean Water Act (CWA), permits under Sections 402 and 404 of the CWA, Section 408 permission to cross civil works under the River & Harbors Act, air permit under the Clean Air Act, and cons ultations under Section 7 of Endangered Species Act and Section I06 of the National Historic Preservation Act). 4. Current Procedural Status FERC issued the Final Env ironmental Impact Statement on April 7. 2017. FERC's s tated deadline for other federal authorizations is July 6, 2017. 2 Overview of Federal-State Approval Authorities for Interstate Natural Gas Pipelines Under the Natural Gas Act and Clean Water Act This memorandum provides a brief overview of the roles of federal and state agencies in the system of cooperative federalism established by the 2005 Energy Policy Act Amendments (EPAct 2005) to the federal Natural Gas Act (NGA) for the review and approval of new interstate natural gas transmission pipelines. FERC Certificate Process New interstate natural gas pipelines are subject to the approval of the Federal Energy Regulatory Commission (FERC). Under Section 7 of the NGA, FERC issues Certificates of Public Convenience & Necessity (Certificates). The issuance of a Certificate preempts any other conflicting state or local requirements. A Certificate is a determination by the FERC that a project is needed to serve the public interest. In making this public interest determination, the FERC balances the public benefits against the potential adverse consequences of a new pipeline. Adverse effects may include increased rates for preexisting customers, degradation in service, unfair competition , or negative impact on the environment or landowners' property. Public benefits may include meeting unserved demand, eliminating bottlenecks, access to new supplies, lower costs to consumers, providing new interconnects that improve the interstate grid, providing competitive alternatives, increasing electric reliability, or advancing clean air objectives. FERC's Environmental Impact Study In determining whether a proposed new pipeline will have a negative impact on the environment, the FERC conducts an environmental impact study (EIS) pursuant to the National Environmental Policy Act (NEPA). NEPA requires that before a federal agency may undertake a major federal action significantly affecting the quality of the human environment-including the FERC decision to issue a Certificate authorizing the construction of a new natural gas pipelineit must study the environmental impact of the project, any adverse environmental effects which cannot be avoided, and alternatives to the project. The NGA designates the FERC as the lead agency for preparing the EIS for any new interstate natural gas pipeline. Other federal agencies, including the Environmental Protection Agency (EPA), and state agencies with environmental permitting authority delegated under federal laws, typically participate in the review process as cooperating agencies. Other Federal Environmental Authorizations In addition to the requirements of NEPA, construction of a new interstate pipeline may not proceed without other ''federal authorizations." 15 U.S.C. 717n. These are authorizations required under Federal law with respect to an application for a Certificate, including any permits, special use authorizations, certifications, opinions, or other approvals as may be required under Federal environmental laws. The most pertinent federal authorizations for new interstate natural gas pipelines are state water quality certifications under Section 401 of the Clean Water Act (CWA), wetlands permits under Section 404 of the CWA, and air permits under Sections 165 and 173 of the Clean Air Act (CAA). Concurrent, Expedited Review It long has been the policy of the federal government, implemented through federal legislation, federal regulations, federal guidance documents, and a succession of Executive Orders by Republican and Democratic Administrations, alike, to expedite environmental reviews and approvals of energy infrastructure projects, including new interstate natural gas pipelines needed to ensure an adequate supply of natural gas to meet the essential national and regional economic needs. In 2001 , President Bush issued Executive Order 13212, Actions to Expedite Energy-Related Projects, which sought to expedite the approval of energy-related projects and to ensure that federal agencies set and adhere to timelines for the completion of environmental reviews. President Bush's EO 13212 created an lnteragency Task Force that includes EPA. EPA and other members of the Task Force are required to monitor and assist other federal agencies in their efforts to expedite their review of permits or similar actions, as necessary, to accelerate the completion of energy-related projects, increase energy production and conservation, and improve transmission of energy. EPA and other members of the Task Force are required to monitor and assist agencies in setting up appropriate mechanisms to coordinate Federal, State, tribal , and local permitting in geographic areas where increased permitting activity is expected. In 2002, the eleven Federal agencies with some level of responsibility for approving interstate natural gas pipelines, including the EPA, entered into an interagency agreement to implement EO 13212. lnteragency Agreement on Early Coordination of Required Environmental and Historic PreseNation Reviews Conducted With the Issuance of Authorizations to Construct and Operate Interstate Natural Gas Pipelines Certificated by the Federal Energy Regulatory Commission (2002 MOA). The 2002 MOA directs EPA and participating agencies to expedite the environmental permitting and review for natural gas pipeline projects and to work with applicants and other stakeholders, as appropriate, before complete applications for the necessary authorizations are filed, to identify and resolve issues as quickly as possible. In 2005, the Congress codified the duty of federal and state agencies responsible for issuing federal authorizations necessary for the construction of interstate natural gas pipelines to cooperate with the FERC and to expedite their approvals coincident with the FERG NEPA process. Since states are delegated authority under federal environmental laws to issue certain federal authorizations, such as CWA 401 state water quality certificates and in a few cases CWA 404 wetlands permits, FERC is required to coordinate with the states on their issuance of these federal authorizations and to establish a schedule for the states to complete their Federal authorizations. The new law designates the FERG as the lead agency for the purposes of complying with the NEPA, coordinating all applicable Federal authorizations, and establishing a mandatory schedule for Federal and State agencies to complete the federal authorizations. The EPAct 2005 directs that the FERG shall, "in establishing the schedule...ensure expeditious completion of all such proceedings and comply with applicable schedules established by Federal law." 15 U.S.C. 717n(c). Thus, EPAct 2005 imposes mandatory obligations upon Federal and State agencies with responsibility for issuing "Federal authorizations" necessary for FERC to exercise its Certificate authority under Section 7(c) of the NGA. A "state agency considering an aspect of an application for Federal authorization shall cooperate with the FERC and comply with the deadlines established by the FERG." 15 U.S.C. 717n(b)(2) (emphasis supplied). Accordingly, the overriding purpose of EPAct 2005 was to expedite the review and approval of interstate natural gas infrastructure by (i) codifying the existing federal inter-agency agreement under EO 13212, (ii) bringing state agencies squarely into the duty to expedite approvals for federal authorizations, and (iii) vesting FERG with the authority to set deadlines for federal and state agencies to act on applications for federal authorizations. See Oversight Hearing to Review The Permitting of Energy Projects, before the United States Senate Committee on 2 Environment and Public Works, S. Hrg. 109-856, May 25, 2005, pp. 7-10, Statement of J. Mark Robinson, Director Office of Energy Projects, Federal Energy Regulatory Commission. These mandatory provisions of the EPAct 2005 codified a duty of federal and state agencies responsible for issuing federal authorizations necessary for the construction of interstate natural gas pipelines to cooperate with the FERC and to expedite their approvals, coincident with the FERC NEPA process. In 2006, the FERC issued regulations implementing EPAct 2005. The regulations provide that states must make a final decision on an application for a Federal authorization, including a CWA 401 water quality certificate or in the case of the two states with delegated wetlands authority, the CWA 404 permit, no later than 90 days after the FERG issues the EIS, unless an alternative schedule is provided under Federal law. 18 C.F.R. 157.22. The FERC defines "schedule established by Federal law'' as schedules specified either in the United States Code or in the Code of Federal Regulations. 71 Fed. Reg. 62914, note 12 (Oct. 27, 2006). For example, CWA 401 provides that a state must act on an applicant's request for a water quality certificate "within a reasonable period of time (which shall not exceed one year) after receipt of such request." In 2012, President Obama issued Executive Order 13604 Improving Performance of Federal Permitting and Review of Infrastructure Projects, which reaffirmed the federal policy and directed federal agencies to coordinate early with state agencies to avoid duplication of effort and delays, and to allow for concurrent rather than sequential reviews of infrastructure projects, including natural gas pipelines and electric transmission lines. In 2017, President Trump reaffirmed in Executive Order Expediting Environmental Reviews for Infrastructure Projects (January 24, 2017) the longstanding federal policy of expediting the review and approval of energy infrastructure projects. EO 13766 reaffirms the policy of the executive branch to streamline and expedite in a manner consistent with the law environmental reviews and approvals for all infrastructure projects, including natural gas pipelines. Judicial Review of Inconsistent State Decision-making The failure of a federal or state agency to take action on a permit required under Federal law, in accordance with the FERC's schedule "shall be considered inconsistent with Federal law." 15 U.S.C. 717r(d)(2). In the event a federal or state agency fails to complete a proceeding for an approval that is required for a Federal authorization in accordance with the FERC's schedule, the applicant may pursue remedies under section 19(d) of the NGA, 15 U.S.C. 717r. This provision authorizes an applicant to file a civil action with the applicable Federal Circuit Court of Appeals. If the state agency with the authority to issue the federal authorization improperly conditions or denies the federal authorization, the applicant can file a civil action with the Federal Circuit Court of Appeals where the project is located. If the state agency unreasonably delays taking an action on the application, then the applicant can file a civil action with the Federal Circuit Court of Appeals for the District of Columbia for the review of an alleged failure to act by the state agency. In either case, if the Court finds that such order or action is inconsistent with the Federal law governing such permit and would prevent the construction, expansion, or operation of the facility, the Court shall remand the proceeding to the agency to take appropriate action consistent with the order of the Court. If the Court remands the order or action to the Federal or State agency, the Court shall set a reasonable schedule and deadline for the agency to act on remand. 3 1\e_ Se.x\"'1 e.- R v--\ <e.~ L(/,.""21'-1..._)-e___ c~~\v--~~ ~ ~ --\\\0 ~~v~~.\- \}'JO...") ~P"\~\'1~~\ \""' -\'v-\ e O\""~}o-J> N ORTH AMERICAN EMISSION CONTROL AREA REALIGNMENT The U.S. Environmental Protection Agency (EPA) and the Government of Canada have recently established a North American Emission Control Area (ECA) of 200 nautical miles around the contiguous U.S. and Canadian coasts, including the inland waters of the Great Lakes and St. Lawrence River. Among other requirements, the ECA mandates reductions in sulfur emissions for all vessels operating within the ECA-zone by limiting the sulfur content of fuel to 1% on A ugust 1, 2012 and 0.1 % as of January 1, 201 5. The goal of the North American ECA is to reduce emissions from ships that might be harmful to human health and coastal environments - an objective that the marine industry and the broader industrial cargo-shipper community fully support as demonstrated by industry's consistent efficiency improvements, major investments in fleet renewal and ability to meet 2012 ECA requirements. Shipping companies are concerned, however, about the cost increases arising from the ECA that have already taken effect in 2012 and , more particularly, the significant increases in fuel costs in order to meet the requirement of 0.1% sulfur-content fuel. Equally concerned are the industrial shippers that depend on inexpensive, efficient and environmentally smart marine transportation who foresee a ballooning of costs so severe they will kill competitiveness and cost jobs. At greatest risk is the movement of bulk commodities (iron ore, gypsum, steel, grain, aggregates, coal, salt, sugar, etc.) along North America's coastal shipping lanes, typically referred to as short-sea shipping1. Unlike the very large, transoceanic vessels that operate in the ECA only 5- 15% of the time and which the EPA did not separately consider, short-sea shipping vessels operate almost entirety within the 200-mile ECA zone, where they often compete with land-based modes of transportation such as rail and trucking. As such , these ships are forced to use the higher cost low sulfur fuel at least 80 to 90% of their operational time. The cost increases for short-sea marine transport are expected to be so severe that significant amounts of freight will be forced off ships and onto shore-based modes of transport (ie. to rail or to less safe, already congested roadways) which are less efficient, higher emitting modes, thus resulting in increased emissions and worse environmental outcomes. Furthermore, important new research2 which uses EPA-approved meteorological modeling conclusively shows that the smaller, lower horsepower, short-sea ships used in the coastal trades have virtually no impact on the east and west coasts of North America at or beyond 50 nautical miles, even when using a sulfur content fuel as high as the current global average of 2.6%. Nevertheless, the sulfur content fuel mandates of the ECA need not change. Rather, it is the boundary at which the maximum 0.1% sulfur content fuel requirement applies that needs to change to respect the unique operating realities and efficiencies of short-sea shipping. It is therefore proposed that the North American ECA be modified so that, smaller, short-sea shipping vessels under 20,000 horsepower be required to use 0.1% sulfur content fuel , not within 200 nautical miles but rather within 50 nautical miles from shore, and that from 51-200 nautical miles they continue to use maximum 1% sulfur content fuel. By modifying the ECA requirements as proposed, the U.S. and Canadian governments can actually yield better environmental outcomes and continue to allow short-sea shipping to provide its inherent economic advantages along the North American coasts rather than risking the economic hardship and adverse unintended outcomes of the ECA. 1 More broadly, short-sea shipping, also referred to by the U.S. Maritime Administration as the "M arine Highway," is the movement of people and cargo on water routes that do not cross an ocean that could also be served by truck or rail. 2 Modeling the A ir Quality Impacts of Short-Sea Shipping Emissions and Implications for the North American Emission Control Area, Dr. Ranajit Sahu and Dr. H. Andrew Gray, April 2012. Maritime Industrial Transportation A lliance E mission Control Area Facts & Issues Ma ritime Industrial Transportation Alliance (MlTA) represents a broad coalition of American and Canadian companies that rely on efficient, safe, environmentally smart ma ritime transportation to de li ver product. MITA m embers serve a ran ge of industries, including: mining, steel-making, construction, power generation and agriculture. Facts A bout the orth American E mission Control Area (ECA) Required F uel ot Readily Available: Ultra-low Sulfur Intermediate Fuel Oil (IFO) (0.1 % s ulfur) is required under the EC/\ as of Januar y 1, 2015 for ALL vessels regardless of s ize, out to 200 autical Miles. This suphur reduction is on top of a 2012 EPA regulation that reduced U. standard levels to 1% . The World standard of sulfur content is 3.5%. Fuel suppliers in the United States and Canada do not produce ultra-low sulfur IFO. As a result, fuel prem.iums in orth American poits range from 34% - 40% more than standard TFO. rn some places, fue l prices are double. Impact: Making America Uncompetitive Twenty to twenty-fi ve percent cost increases of Short Sea Shipping is hurting Ametican industry. National Gypsum: The increased gyps um import costs requires N ational Gypsum to re-think their dry-wall manufacturing model, impacting 500 employees at plants in Georgia, Loiusianna, Maryland, New Hampshire and Vermont. Westwego, LA Impact Because of ECA implimentatio n, transportation costs on raw materi als have increased 22% since December. Forcing the company into one of two choices: Options A: Move from 3 shifts 7 days a week to 1 or 2 shifts 5 days a week. Result: 30-60 jobs impacted Options B : Close the faci lity. Result: 140 jobs impacted Eagle Rock Aggregates: Cali fornia-based Eagle Rock Aggregates entered into a lease lo develop a m arine dist.J.ibution te rminal within the Port of Long Beach. Imports 3 m illion tons of aggregate annual ly into the greater Los Angeles to support constructio n ofroads, bridges & other infrastructurc. San Diego, Ca li fornia Impact Planned sister fac ility in San Diego, designed to buttress a regional aggregate sho11age, stalled because of the ECA's 20% cargo ra te increases o Result: Uncreated jobs Cost to the U.S. Economy Higher Cost of Building Materials: ECA cargo increases adds $8.39 million to the price tag of each 100 miles of interstate.1 New Potential Infrastructure Costs Modal shift will kill short sea shipping industry. Unintended consequence, 7.1 million additional truck trips per year along with all the related pollution which is more than 400% greater than 2014 marine polution outputs. Increased reliance on trucks would cause incremental traffic delays to other vehicles would costing between $346 and $380 million. $4.6 billion in additional highway maintenance costs2 Increased reliance on rail would cause Public delays at rail crossings Estimated annual impact of $46 million.3 For relevance to this issue - in the Marine Corridor Mexico/USA/Canada on both coasts more cargo moves via Short Sea Ships than do all the tons moved in the St. Lawrence Seaway system. These " Coastal tons" currently move without any Federal Government Infrastructure requirements. Modal Shift is Strife with Consequences: a. 2011 San Diego Aggregate Supply Study SANDAG study exa:n1ined regional aggregate resources and the modes of the transportation used to deliver construction aggregates. Marine transportation is the most fuel efficient and least emitting transportation option4 This conclusion was based on fuel sulfur and emissions data before the ECA took effect. 1 California Department of Conservation 2012 Aggregate Sustainabili ty in California R eport, Page 18. 2 E nvironmental and Social Impacts of Marine Transport in the Great Lakes and Seaway Region 20 13, Page 14 3 Define, Defend, Promote, 20 13, Page 23 4 SANDAG Study, Table 4-4, Page 4-l 0 Page 12 IDill l11111tc1 @JJuirmuu Qtnmmitt.e nu IDrttnnpnrtattnn atto JJnfra.atrttctur.e 311.:. 11lnuJJ.e nf filepr.es.eututtue.n 3lln.t,4t119tun, IDQJ. 20515 Niclt JI. i!M1ull, 3HJ iUnttl\iug :ffi~111bc1 Chrlsto1>l1rr r. Ht'rl rl\mJSt:Uf Directcr October 16, 2013 Jnmes Jl. Zoltt, Democ-1-at Sta!IU!rcctor The Honorable Regina A. McCarthy Administrator United States Environmental Protection Agency William Jefferson Clinton Federal Building 1200 Pennsylvania Avenue, NW Washington, DC 20460 Dear Administrator McCarthy: In August, new rules went into effect requiring the use of lower sulfur fuels or scrubbers in the North American Emission Control Area (ECA). The ECA consists largely ofthe United States and Canadian Exclusive Economic Zones, excluding the Arctic. Further reductions in sulfur emissions will go in to effect in the ECA in 2015. The use of lower sulfur fuels will increase vessel operating costs, and your agency has shown a willingness to work with vessel operators on a number ofmethods ofmeeting lower sulfur emission standards, including the installation ofLNG-powered engines or scrubbers. Some operators will change their routes to avoid operating in the ECA wherever possible. Unfo1tunately, the Environmental Protection Agency (EPA) has been unwilling to allow vessels with smaller horsepower engines that operate in the short sea trade between the United States and Canada to achieve the goal oflower landside pollution by using lower sulfur fuel only within 50 miles of shore. I urge you to reconsider that position. Most vessels in the U.S.-Canadian sho1t-sea shipping trade are powered by engines with less than 20,000 horsepower and carry low value commodities, including aggregates, gypsum, grain, salt, iron ore, and coal. Due to their size and route, vessels operate almost exclusively in the ECA. J understand that no scientific rationale was prepared that established a relationship between the emissions from these vessels and shoreside sulfur dioxide levels. I also understand that industry has submitted studies to EPA showing that the use of low sulfur fuels only when operating within 50 miles of shore, rather than in the entire ECA, shows no net changes in landside sulfur dioxide levels. I urge you to review these studies. Increased costs for the minimum 0.1 % sulfur content fuel that will be required in 2015 will be particularly hard for short-sea shipping operating predominantly within the ECA to absorb. Such increases may lead to a modal shift where cargo moves offthe water and on to trucks and rail. Given that every short-sea ship taken out ofservice is equal to approximately 2,000 heavy trucks, I am concerned such a shift would lead to new environmental challenges and infrastructure concerns. Beyond the negative environmental impact and infrastructure implications of inducing modal s_hift from sea to surface, imposing increased fuel costs on sho1t-sea shipping in the ECA also tlueatens the competitiveness of American industry and manufacturing as many of the U.S. industries. For example, gypsum is currently mined and produced by our hade partners in Canada and Mexico and shipped to American manufacturers in California, New Hampshire, and Maryland. Increases in short-sea shipping freight rates could increase the use of Chinese or European wallboard in American. Applying the lower sulfur fuel standards to vessels with engines smaller than 20,000 horsepower only when those vessels are operating within 50 miles of shore would lead to significant cost savings, and increase the competitiveness ofU.S. products and exports. If the use of higher sulfur fuel results in no additional shoreside sulfur reductions, then I urge you to apply the lower sulfur fuel standards to these vessels only when they are operating within 50 miles of shore. These vessels operate almost exclusively within the 200 mile ECA, and bring American industry commodities that are vital building blocks for the U.S. economy. We should not discourage this trade. It appears the implementation of a 50 mile rule for ce1tain vessels may preserve the intent ofthe ECA, but not disrupt an established transportation system that is critical to our nation's economy. I strongly urge you to review this proposal. I look forward to your reply. uncan Hunter Chairman Subcommittee on Coast Guard and Maritime Transportation UA..SU. CTOit VNDTINCMAETNt~T INFO RMATIO N G PO 114TH CONGRESS } 2d Session SENATE Calendar No. 521 R EPORT 114-281 DEPARTMENT OF THE INTERIOR, ENVIRONMENT, AND RELATED AGENCIES APPROPRIATIONS BILL, 2017 JUNE 16, 2016.- Ordered to be printed Ms. MURl<OWSJG, from the Committee on Appropriations, s ubmitted the followi ng REPORT (To accompany S. 3068] The Committee on Appropriations reports the bill (S. 3068) making appropriations for the Department of the Interior, environment, and related agencies for the fiscal year ending September 30, 2017, and for other purposes, reports favorably thereon and recommends t hat the bill do pass. Total obligational authority, fiscal year 2017 Total of bill as reported to the Senate .... ................ $32,762,011,000 Amount of 2016 a pprop1iations ............................... 32,925,579,000 Amount of 20 17 budget estimate ............................ 33,176,164,000 Bill as recommended to Senate compared to- 2016 appropriations ....................................... ... - 163,568,000 2017 budget estimate ........................................ - 414,153,000 20-423 PDF 68 recently completed a preliminary step. As growers need additional modes of action to most effectively deal with this pest, the Committee notes its strong interest in a timely completion of the registration for this new mode of action. Ecolabels for Federal Procurement.- Multiple forest certification programs have been recognized throughout the Federal Government as supporting the use of sustainable products in building construction and other uses. The Committee urges EPA to add additional forest certification standards that have been recognized by other Federal programs, including USDA's BioPreferred Program, to its Interim Recommendations under Executive Order 13693. The Committee urges EPA to report back on progress on implementation of the Committee's recommendation within 60 days of enactment. Glyphosate Reregistration.-The Committee is aware that the Agency is currently in the process of reviewing the registration for glyphosate, which is a very important crop protection tool for America's farmers. Furthermore, glyphosate has been used for decades and, when properly applied, has been found to present a low r isk to humans and wildlife by regulatory bodies around the world, including Australia, Canada, the European Union, Japan, and by the Joint FAO/WHO Meeting on Pesticide Residues. The Committee urges the Agency to complete its reregistration of glyphosate expeditiously. Grant Guidelines.-The Committee is extremely concerned about reports that an Agency grant was used to support an anti-agriculture advocacy campaign. The campaign, funded in part by Federal funding, included biUboards and a Web site that explicitly accused the agriculture industry as being a primary polluter of local waterways and urged increased regulation of agriculture. The use of Federal funds for such advocacy is inapproptiate and may be in violation of Federal lobbying prohibitions. In response to this, the Agency must ensure there is sufficient oversight and training in place to avoid similar misuse of grant funds in the future. To achieve this goal, within 90 days of enactment, the Agency is directed to update its grant policies, training, and guidelines to ensure Federal funds are not used in this manner, including an update of the mechanism by which the Agency tracks the use of its grants, and to provide the Committee with a copy of its updated grant policies, training, and guidelines. Fuel Standards.-The Committee supports efforts to reduce pollution from marine vessels that may be harmful to human health and coastal environments. While that is the case, t he Committee is concerned the mandate for fuel with a sulfur content of 0.1% in the North American Emission Control Area is having a disproportionately negative impact on vessels which have engines that generate less than 32,000 horsepower. This impact may cause some shippers to shift from marine based transport to less efficient, higher emitting modes. In an effort to avoid negative environmental consequences and modal shifting, the Committee directs the Agency to consider exempting vessels with engines that generate less than 32,000 horsepower and operate more than 50 miles from the coastline. Within 180 days of enactment of this act, the Agency 69 should provide the Committee with a report detailing their deci- s ion. Interagency Consultations.-Several provisions of the Federal In- secticide, Fungicide and Rodenticide Act [FIFRA] require the Agency and the United States Department of Agriculture !USDA] to coordinate activities related the products regulated under the law. USDA has a robust history of collecting and analyzing data related to agricultural economics and the environmental impacts of farm- ing tools and practices, including crop protection and pest management. However, there have been recent instances in which the USDA has not been consulted or informed of key regulatory actions and decisions by the EPA as prescribed by FIFRA. In two of these cases USDA has publicly commented on their exclusion from the process. Consequently, the Committee directs the Administrator of the EPA to consult with the Secretary of the Department of Agriculture on economic analyses, rules and other regulatory actions that impact products currently approved under FIFRA. Lead Test Kit.-In 2008, EPA adopted the Lead Renovation, Repair and Painting rule which included criteria by which the Agency could certify a test kit that contractors could use onsite to comply with the rule. The Committee is concerned t hat 8 years later, no kit has been developed that meets these standards. The Committee is concerned that this action is not adequate and is concerned that progress is not being made to identify a solution to this issue. If no solution is reached by the end of the fiscal year, EPA should reopen the rule a nd determine whether it is possible to include an opt-out provision until a test kit is certified that can comply with the rule. Methane.-The Committee is concerned about the Agency's efforts to regulate methane from existing petroleum and gas sources. Over the past decade, the United States added more than 86,000 new petroleum and natural wells, dwing which methane emissions from petroleum and natural gas systems fell by 11 percent. Based on the data suggesting that methane emissions are declining, t he Committee believes that States are adequately regulating methane emissions. National Ambient Air Quality Standards.-The Committee remains concerned about potentially, overlapping implementation schedules related to the 2008 and 2015 standards for ground-level ozone. Because the Agency did not publish implementing regulations for the 2008 standard of 75 parts per billion [ppb] until February 2015 and then r evised t he standard to 70 ppb in October 2015, States now face the prospect of implementing two n ational ambient air quality standards for ozone simultaneously. Based on Agency data, the Committee expects a number of counties to be in non-attainment with both the 2008 standard and the 2015 standard. Additionally, Agency data suggests that a number of marginal non-attainment counties will meet the 2015 standard by 2025 due to other air regulations. In an effort to find the most sensible path to reduce ground level ozone, some flexibility must be granted to States that face the burden of implementing these potentially overlapping standards. Within 90 days of the date of enactment of this act, the Agency is directed to provide the Committee with a report examining the potential for administrative options to enable States 114TH CONGRESS } 2d Session SENATE Cale ndar No. 501 { REPORT 114-264 DEPARTMENT OF HOMELAND SECURITY APPROPRIATIONS BILL, 2017 MAY 26, 2016.-Ordered lo be printed Mr. HoEVEN, from the Committee on Appropriations, submitted the following REPORT fTo accompany S. 3001] The Committee on Appropriations reports the bill (S. 3001) making appropriations for t he Department of Homeland Security for t he fiscal year ending September 30, 2017, and for other purposes, reports favorably thereon and recommends that the bill do pass. Total obligational authority, fiscal year 2017 Total of bill as reported to the Senate 12 3 6 ... ........ $49,739,632,000 Amount of 2016 a ppropria tions 4 5 .... 49,431,955,000 Amount of 2017 budget estimate 1 26 .............. ... .... 48,999,303,000 Bill as recommended to Senate compared to- 2016 approp,iations ............ .............................. + 307,677,000 2017 budget estimate ........................................ + 740,329,000 1 Commiltee recommendation includes $1,231,574,000 in rescissions compared to $'120,000,000 in proposed cancellations. 2 Includes a permanent indefinite appropriation of $176,000,000 for the Coast Guard healthcare fund contribution. 3 lncludes $162,692,000 for t he Coast Guard for the cost of overseas contingency operations. 4 Includes rescissions totaling $1,506,152,000 pursuant to Public Law 114-1 13. Includes permanent indefinite a ppropriation of $169,306,000 for the Coast Guard healthcare fund contribution. Includes $160,002,000 for the Coast Guard for the cost of overseas contingency operations. 5 Includes $6,712,953,000 for the FEMA Disaster Relief Fund designated by the Congress as disaster relief pursuant to Public Law 112-25. 6 Includes $6,709,000,000 for the FEMA Disaster Relief Fund des ignated by the Congress as disaster relief pursuant to Public Law 112-25. 20-241 PDF 79 PUGET SOUND FEDERAL CAUCUS The Committee commends the Thirteenth Coast Guard District for signing t he Puget Sound Federal Caucus Memorandum of Understanding [MOUJ on April 21, 2014. The recovery and cleanup of Puget Sound is essential to our Nation's economy and continued coordination and sharing of expertise among Federal partners is critical to furthering current efforts. The Committee directs t he Thirteenth Coast Guard District to work with its counterparts in the Puget Sound F ederal Caucus to renew and strengthen the MOU prior to its expiration on March 27, 2017. COAST GUARD BAND The Committee is concerned that the Coast Guard is planning to expend unnecessary funds to move th e Coast Guard Band from the Coast Gua rd Academy Campus in New London, Connecticut to Washington, DC and t herefore directs that no funds provided in t his act shall be expended for t he relocation of the Coast Guard Band from its current home. MARINE ENVIRONMENT PROTECTION The Coast Guard, jointly and cooperatively with the Environmental Protection Agency, is charged with enforcing the International Ma ritime Organization's Marine Pollution [MARPOL) convention focused on preventing different forms of marine pollution, including oil, noxious liquid substances, h armful substances, waste water, garbage, and emissions of sulfur oxide and nitrogen oxide at sea. In accordance with MARPOL Annex VI Regulation 13, all vessels entering the North America n and Caribbean Emission Control Areas [ECA] as of J anuary 1, 2015, are required to u se Ultra-low (0.1%) SuJiur Intermediate Fuel Oil [IFO]. The Committee remains concerned about potential modal shifts related to ECAs and directs the Coast Guard to provide an update to the briefing, mandated in House Report 114-215, on ECA-related enforcement actions, fuel availability, waivers, and exemptions for ECA compliance. The Committee is concerned that despite issuing a final rule on Ballast Water Discharge Standards in 2012, the Coast Gua rd has yet to a pprove a single Ballast Water Management System [BWMSJ. This is particularly challenging for BWMS vendors who must s ubmit to lengthy, expensive testing at in dependent laboratories or seek to have existing test data validated also through independent laboratory review. In seeking to validate t he results of certain BWMS technology it is clear that testing protocols have not necessarily kept pace. The lack of comprehensive protocols to test BWMS technologies, some of which are widely accepted in other water treatment industries, is causing t he industry harm in the maritime sector and must be addressed. To continue the development of more appropriate testing methods, t he Committee directs the Coast Guard, in conjunction with t he Environmental P rotection Agency, to reexamine t he applicability of the most probable number method for evaluat ing t he efficacy of certain treatment technologies. UA.SUGTOllVoUml:cNAMT[INDT~ INl'OtlMATION CPO 114TH CONGRESS } { R EPORT 1st Session HOUSE OF REPRESENTATIVES 114-215 DEPARTMENT OF HOMELAND SECURITY APPROPRIATIONS BILL, 2016 JULY 21, 2015.- Committed to the Committee of the 'Whole House on the State of the Union a nd ordered to be printed Mr. CARTER of Texas, from the Committee on Appz_-opriations, submitted t he following REPORT together with MINORITY VIEWS [To acc.ompany H.R. 3128] The Committee on Appropriations submits the following re port in explanation of the accompanying bill making appropriations for the Department of Homeland Security for the fiscal year ending September 30, 2016. INDEX TO BILL ANO REPORT TITLE I- DEPARTMENTAL MANAGEMENT AND OPERATIONS Office of the Secretary and Executive Management ........................ Office of tho Under Secretary for Managomont ............................... Office of the ChiefFinancial Officer .................................................. Office of the Chief Information Officer .............................................. Analysis and Operations .................................................................... Office of Inspect.or General ................................................................. TITLE II--SECURITY, ENFORCEMENT, AND INVESTIGATIONS U.S. Customs and Border Protection ................................................. Salaries a nd Expenses ................................................................. Aut.omalion Modernizat ion ......................................................... Border Security Fencing, Infrastructure, a nd Technology ....... Air and Marine Operations ......................................................... Construction and Facilities Management .................................. U.S. Immigration and Customs Enforcement ................................... Salaries and Expenses ................................................................. Aut.omaLion Modernization ......................................................... Construction ................................................................................. 95-508 Peg numb,er Bill R,port 2 5 3 10 4 16 4 18 5 19 5 21 6 22 6 23 7 31 8 32 8 33 9 36 10 37 10 37 14 45 14 46 58 each denied request. The report shall also include the number of service members served by the Special Victim Counsel program. Fishing Safety Training Section 309 of the Coast Guard R.eauthorization Act of 2014 (Public Law 113-281) authorizes competitive grant funding for Fis hing Safety Training and Fishing Safety Research grants programs that support collaborative training a nd research into emerging and useful technologies to enhance safety on fishing vessels. The Com.mjttee directs the Coast Guard to provide, ,vithin 90 days after the date of enactment of this Act, a plan for carrying out a pilot for a t raining program, potentially involving an expansion of the Coast Guard's current collaboration with the National Ins titute for Occupational Safety and Health related to data on commercial fishing safety. Although no s pecific funding is provided for implemen t ing a pilot training program, the Coas t Gua rd is encouraged to use funds recovered from prior obligations for th.is purpose. MAR!Tfl\1E POLLUTION CONTROL The Coast Guard, jointly and cooperatively with the EPA, is charged with enforcing U.S. laws, international conventions, and regulations of the International Maritime Organization (IMO). The IMO's Marine Pollution (MARPOL) convention focuses on preventing different forms of ma rine pollution, including oil, noxious liquid substances, harmful s ubs tances, waste water, garbage, and emissions of sulfur oxide and nitrogen oxide at sea. In accordance with MARPOL Annex VI Regulation 13, a ll vessels entering the North American and Caribbean Emission Control Areas (ECA) as of January 1, 2015, are required to use Ultra-low (0.1%) Sulfur Intermediate Fuel Oil (IFO). In response to concerns that t he availability of this type of fuel in U.S. ports is limited, the Committee directs the Coast Guard to provide a briefing, not later than 90 days afte r t he e nactme nt of this Act, on the following: a) the number of ECA-related enforcement actions taken since January 1, 2015; b) the number of fuel non-availability reports received since January 1, 2015; and c) the number of vessels th at received waivers, exemptions, or other special consideration for ECA compliance, including application and expiration dates. Coast Guard Auxiliary Uniforms The Committee is aware t hat members of the U.S. Coast Guard Auxiliary are not eligible for reimbursement for the cost of uniforms they are required to wear while performing official duties. The Committee encourages t he Coast Gua rd to examine the feasibility, rationale, a nd cost to t he Coast Guard of providing such reimbursements and to report to the Committee on the results. Small Response Boats The Coast Gua rd has a long-standing requirement to replace aging and obsolete small response boats and awarded a competitive contract to replace these important watercraft. The Committee notes, however, that the Coast Guard is not procuring enough ~ MARITIME INDU STRI AL TRANSPORTATION A LLI ANCE North American ECA must be amended to help rather than hurt the economy and the environment Summa ry The U.S. Environmental Protection Agency (EPA) and the Government of Canada have recently established a North American Emission Control Area (ECA) of 200 nautical miles around the contiguous U.S. and Canadian coasts, including the inland waters of the Great Lakes and St. Lawrence River. Among other requirements, the ECA mandates reductions in sulfur emissions for all vessels operating within the ECA-zone by limiting the sulfur content of fuel to 1% on August 1, 2012 and 0.1 % as of January 1, 2015. The goal of the North American ECA is to reduce emissions from ships that might be harmful to human health and coastal environments - an objective that the marine industry and the broader industrial cargo-shipper community fully support as demonstrated by industry's consistent efficiency improvements, major investments in fleet renewal and ability to meet 2012 ECA requirements. Shipping companies are concerned, however, about the cost increases arising from the ECA that have already taken effect in 2012 and , more particularly, the significant increases in fuel costs to come in order to meet the requirement of 0.1% sulfur-content fuel by 2015. Equally concerned are the industrial shippers that depend on inexpensive, efficient and environmentally smart marine transportation who foresee a ballooning of costs so severe they will kill competitiveness and cost jobs. At greatest risk is the movement of bulk commodities (iron ore, gypsum, steel, grain, aggregates, coal, salt, sugar, etc.) along North America's coastal shipping lanes, typically referred to as short-sea shipping1 . Unlike the very large, transoceanic vessels that operate in the ECA only 5-15% of the time and which the EPA did not separately consider, short-sea shipping vessels operate almost entirely within the 200-mile ECA zone, where they often compete with land-based modes of transportation such as rail and trucking. As such, these ships are forced to use the higher cost low sulfur fuel at least 80 to 90% of their operational time. The cost increases for short-sea marine transport are expected to be so severe that significant amounts of freight will be forced off ships and onto shore-based modes of transport (ie. to rail or to less safe, already congested roadways) which are less efficient, higher emitting modes, thus resulting in increased emissions and worse environmental outcomes. Furthermore, important new research2 which uses EPA-approved meteorological modeling conclusively shows that the smaller, lower horsepower, short-sea ships used in the coastal trades have virtually no impact on the east and west coasts of North America at or beyond 50 nautical miles, even when using a sulfur content fuel as high as the current global average of 2.6%. Nevertheless, the sulfur content fuel mandates of the ECA need not change. Rather, it is the boundary at which the maximum 0.1 % sulfur content fuel requirement applies that needs to change to respect the unique operating realities and efficiencies of short-sea sh ipping. It is therefore proposed that the North American ECA be modified so that in 2015, smaller, short-sea shipping vessels under 20,000 horsepower be required to use 0.1% sulfur content f uel, not within 200 nautical miles but rather within 50 nautical miles from shore, and that from 50-200 nautical miles they continue to use maximum 1% sulfur content fuel. By modifying the ECA requirements in 2015 as proposed, the U.S. and Canadian governments can actually yield better environmental outcomes and continue to allow short-sea shipping to provide it's inherent economic advantages along the North American coasts rather than risking the economic hardship and adverse environmental outcomes most certainly forthcoming if the current ECA regulation comes into effect in 2015. 1 More broadly, short-sea shipping, also referred to by the U.S. Maritime Administration as the "Marine Highway," is the movement of people and cargo on water routes that do not cross an ocean that could also be served by truck or rail. 2 Modeling the Air Quality Impacts of Shorl-Sea S/Jipping Emissions and Implications for t/Je Norlh American Emission Control Area, Dr. Ranajit Sahu and Dr. H. Andrew Gray, April 2012. MITA EGA Brief, p. 2 About the Maritime Industrial Transportation Alliance (MITA) MARITIME INDUSTRIAL TRANSPORTATION ALLIANCE MITA represents a broad coalition of North American companies that rely on efficient, safe, environmentally smart marine transportation to deliver products and materiel that serve people all over the world. Besides shipping companies, MITA includes cargo shippers in major industrial sectors including mining, steel-making, construction, power generation and agriculture. MITA's advocacy on marine and transportation issues extends to North American governments and agencies and occasionally to international bodies such as the International Maritime Organization. Marine transportation is vital to our prosperity by enabling efficient trade within North America and around the world. As the safest, most efficient and environmentally smart method of carrying bulk freight, the increased use of marine transportation alleviates highway congestion, reduces greenhouse gas emissions and is a vital catalyst to overall economic prosperity. Contact: Stephen J. Brooks President Maritime Industrial Transportation Alliance 152 Conant Street Beverly, MA U.S.A. 01915 E: sbrooks.mita@icloud.com MITA ECA Brief, p . 3 I. Bac kg ro und On March 27, 2009, the U.S. and Canada submitted a formal joint proposal to the International Maritime Organization (IMO) for the establishment of a North American Emission Control Area (ECA). The proposal was accepted at the 60th session of the IMO Marine Environment Protection Committee (MEPC) on March 26, 2010. The ECA extends 200 nautical miles (nm)3 from the coasts of the United States and Canada, yet excludes Alaska and the Arctic. On August 1, 2012, the North American ECA came into effect, mandating that all vessels operating within the 200nm zone off the east and west coasts of the United States and Canada use fuel containing no more than 1% sulfur. This fuel sulfur restriction will be further reduced to 0.1 % beginning on January 1, 2015. In the United States, the U.S. Environmental Protection Agency (EPA) promulgated ECA requirements under authority provided by the Act to Prevent Pollution from Ships, 33 U.S.C. 1901-1915, to implement Regulation 14 of Annex VI to the International Convention on the Prevention of Pollution from Ships (1973178) (MARPOL Annex VI). In Canada, Transport Canada has proceeded under authority of the Canada Shipping Act to implement the ECA provisions through formal regulatory approval, first published in Canada Gazette I, July 21 , 2012, as Regulations Amending the Vessel Pollution and Dangerous Chemicals Regulations. With respect to the U.S. and Canada's rationale for seeking and establishing a North American ECA, the aims and objectives, also articulated in IMO's MARPOL Annex IV, include: To control NOx, SOx, and PM in order to reduce "ambient concentrations of air pollution in cities and coastal areas around the world ." (Annex VI, App. Ill 1.2. ) To restrict such forms of pollution because they can contribute to "premature death, cardiopulmonary disease, lung cancer, chronic respiratory ailments, acidification and eutrophication." (Id.) The criteria for designating an ECA include an assessment of emissions from ships operating in the proposed area that contribute to ambient concentrations of air pollution causing human health or adverse environmental impacts in the coastal areas described above. (Id. 3.1.4.) Other criteria include an assessment of meteorological conditions in the proposed ECA, nature of ship traffic (including patterns and density), measures to address land-based sources of emissions in the coastal regions, and costs of reducing emissions from ships relative to landbased controls. (Id. 3.1.5-.8) It is clear that the U.S. and Canada's overriding goal for the North American ECA is to reduce emissions from ships that might be harmful to human health and coastal environments, objectives which industry supports. But as demonstrated in this brief, particularly for a class of relatively smaller, lower horsepower ships operating under what is commonly referred to as short-sea shipping, the ECA as proposed will not only needlessly hurt American and Canadian economies, it will likely result in diminished environmental outcomes. II. The ECA will needlessly hurt the economy In analyzing the emissions from ships to justify its application to the IMO for the ECA, the U.S. EPA and Canada took a blanket approach and did not extract for separate analysis the short-sea shipping sector from the roughly 50,000 vessel inventory many of which operate with extremely large engines and emission footprints, quite unlike short-sea ships. Indeed, they did not look at, study or otherwise take into account the relatively small number of short-sea vessels that are smaller with smaller horsepower engines and which transport vital bulk raw materials up and down along the North American coasts in the supply and support of North American industry. 3 One nautical mile is equivalent to 1.15 statute miles or 1.852 kilometres. 200 nautical miles is therefore equivalent to 230 statute miles or 370.4 kilometres. MITA EGA Brief, p. 4 These smaller, specialized, innovative, mostly self-unloading ships - plying waters in the trade typically referred to as short-sea shipping4 - not only have uniquely different engine and horsepower characteristics (less than 20,000 horsepower), they have markedly different efficiency and emission footprints. Most importantly in terms of economics, these short-sea shipping vessels uniquely operate almost their entire service lives (80-90%) within the 200nm area now classified as an ECA zone, where they often compete with land-based modes of transportation such as rail and trucking. As such, these ships are forced to use the higher cost low sulfur fuel during most of their operational time. In stark contrast, transoceanic vessels only operate approximately 5-15% of the time5 within ECAs and are thus significantly less burdened with the higher fuel costs. The result is that vessels in the short-sea shipping trade are being disproportionately disadvantaged with higher fuel and operating costs. While this cost increase under the current ECA (2012 = 1% sulfur-content fuel) is certainly proving challenging, the cost increases are expected to balloon when the 0.1% su lfur-content fuel restriction takes effect in 2015, assuming such fuel eventually becomes available. With a blanket analysis of the global fleet of predominantly very large ships operating a small fraction of their time in the ECA without land-based (truck/rail) competitors, the U.S. EPA and Canada have rationalized that ECA cost increases will simply be passed on to customers and consumers by way of higher prices: "For the vast majority of goods currently moved by ship, there are no close transportation alternatives. Therefore ship owners are expected to be able to pass all or nearly all of the additional costs associated with complying with the ECA NOx and fuel sulphur control measures to the purchasers of marine transportation services. These increases in transportation costs ultimately would be passed on in the form of slightly higher prices for the goods being shipped."6 Unfortunately, the effect of those cost increases won't be quite so easily transferable for the short-sea shipping sector. On the contrary, the impact of the 2015 ECA on short-sea shipping is expected to result in a 50-80% increase in fuel costs, which will: Significantly increase manufacturing and production costs to U.S. and Canadian industrial sectors, translating into lower competitiveness, lost jobs, even more downward economic pressures; Lead to a shift in sourcing of bulk materials away from U.S. and Canada towards offshore countries, (S. America, China, etc.) where quality and health and safety standards for material like gypsum, aggregates, salt, iron ore, etc. may be less stringent. Ill. The ECA will needlessly hurt the environment A. The Purpose of the EGA is to protect human health and the coastal environment The IMO's MARPOL Annex VI is concerned with the reduction of emissions in order to avert the public health, welfare, and environmental harms to which such emissions contribute. As this is a treaty for the global shipping industry, the particular emissions of concern are those from marine vessels. Nothing in the treaty, however, precludes any nation from considering the emission reductions in the aggregate as they impact its citizens' health and welfare, or its sensitive coastal, marine, or terrestrial environments. Indeed, with specific reference to ECAs, Annex VI notes that the purpose for which these areas of heightened vessel emission control may be established is to minimize "adverse impacts on human health and the environment" and to reduce "ambient concentrations of air pollution in cities and coastal areas around the world."7 Nations "which have ships navigating in the area are encouraged to bring to the Organization any concerns regarding the operation of the area."8 In short, Annex VI does not require nations to adhere strictly with the Regulation 14 fuel standards if doing so would result in greater air pollution within its territory. More broadly, short-sea shipping, also referred to by the U.S. Maritime Administration as the "Marine Highway," is the movement of people and cargo on water routes that do not cross an ocean that could also be served by truck or rail. s BP Marine, 2015 and Beyond, London. September 13, 201 2. Proposal to Designate an Emission Control Area for Nitrogen Oxides, Sulphur Oxides and Particulate Ma ller Submitted by the United States and Canada, International Maritime Organization, Marine Environment Protection Committee, 2 April 2009, p. 7. 7 Id. Regulation 1(8) & Annex VI, App. Ill 1.2. 6 Annex VI, A pp. Ill 5.1. MITA EGA Brief, p. S B. Marine Transportation is an Environmentally Preferable Form of Transportation Shipping has long been recognized as the most efficient form of transportation boasting an ability to move more ton-miles per gallon of fuel than any other mode. According to the U.S. Maritime Administration's (MARAD) 2011 Report to Congress, while trucks, on average, can carry one ton of freight for approximately 155 miles on a gallon of diesel fuel (i.e., 155 ton-miles of freight per gallon, equivalent to 842 BTU per ton-mile}, rail achieves 413 ton-miles of freight per gallon (316 BTU per ton-mile), and a tug-and-barge operation can get as much as 576 ton-miles of freight to a gallon of fuel (227 BTU per tonmile).9 Additionally, self-propelled oceangoing vessels, such as short-sea ships, have significant energy efficiencies over land-based modes beyond those achieved by tug and barge. The image below represents a separate analysis by the short-sea shipping company CSLI which shows the same trends. CSL/ Vessel Ton-miles pergallon "From an environmental perspective ... short sea shipping can offer air quality improvement, reduce traffic and mitigate noise pollution ... marine shipping tends to have lower environmental and social impacts than land transport."10 America's Marine Highway offers the potential of significantly enhancing the environmental sustainability of the nation's transportation system. In particular, water transportation is often the most energy-efficient means of moving cargo between two points, with corresponding reductions per ton-mile in greenhouse gas (GHG) emissions. Similarly, with appropriate technology and regulation, water transportation is an environmentally-friendly transportation mode that can reduce noise and air pollution and have minimal impacts on water quality.11 Short-sea shipping, therefore, offers an efficient alternative to surface transportation (i.e., via roads or rail) that reduces associated transportation emissions. As a result, a shift from marine transportation to other modes of transportation over routes comprising the North American Marine Highway and associated land routes will have a net adverse impact not only on aggregate NOx, SOx, and PM emissions sought to be addressed by the EGA, but also other important pollutants, such as GHGs. C. The 0.1% Sulfur Marine Diesel Rule Will Cause a Modal Shift to More Polluting Land- Based Transportation Alternatives Vessels serving short-sea shipping routes operate extensively within the EGA. By contrast, transoceanic vessels on ly operate in the ECA for a small fraction of their total voyage. Thus, U.S. Maritime Administration, Reporl to Congress, America's Marine Highway, at 22 (April 2011 } (hereinafter "MarAd Report to C ong ress"). 10 Transport Canada, Making Connections: S/Jort Sea Shipping in Canada, at 1 (2006). 11 MarAd Report to Congress at 21 . MITA ECA Brief, p. 6 transoceanic operations are able to take advantage of lower cost residual and intermediate fuel oils that simply are not allowable by short-sea ships. These vessels that are engaged in North American short-sea shipping - typically Panamax size and smaller, generally not exceeding 20,000 propulsion horsepower - will face higher average fuel costs per ton-mile traveled compared to transoceanic carriers. As a result, unless exemptions are made for short-sea vessels, the unit increase in costs will make use of the marine highway more expensive relative to land-based forms of transportation, which also have higher per-ton mile emissions. The difference between the cost of 1.0% and 0.1% marine distillate fuel is significant. Studies show that the cost per ton of 0.1% sulfur fuel ranges from 56.7% to 67.4% higher than that for 1.0% marine distillate fuel. For example: A May 2011 study by the California Air Resources Board found that the global average price per ton of 1.0% sulfur IFO and 0.1% marine gas oil was $569 compared to $892.12 That is a difference of 56.7%. A late 2010 report by the European Marine Safety Agency (EMSA) showed the price differential between these two types of low sulfur fuels to have been 67.4% in 2010. 13 EMSA projected that this differential would decline to about 56% in 2015, but then rise again to 62.5% in 2020. All these studies arrive at a price differential above 50 percent for the switch to the lower sulfur fuels currently set for 2015. Given the significant increases in fuel costs, the higher relative costs of shipping freight via the marine highway will either reduce margins making certain routes unprofitable or make transport costs by surface modes more attractive. In either event, assuming that demand for those bulk materials currently transported by ship remains unaffected by the relative increase in cost, it is reasonable to expect a modal shift to land-based transportation alternatives. More importantly, the modal shift caused by applying the 0.1% sulfur content standard to smaller vessels active in the short sea shipping trades within the North American ECA - specifically within the U.S. and between the U.S. and Canada - will result in the unintended consequence of increasing overall CO2, CO, hydrocarbons, SOx, NOx, and fine PM emissions. The U.S. has recognized that any use of surface transportation in lieu of maritime shipping would greatly undermine efforts to curb overall emission of harmful hazardous and greenhouse gas (GHG) emissions. Stated another way, "[t]he greater use of water transportation could generali reduce emissions of carbon dioxide (CO2), an important GHG relative to other transportation modes." 4 Maritime shipping "is often the most energyefficient means of moving cargo between two points ... [and] an environmentally-friendly transportation mode that can reduce noise and air pollution and have minimal impacts on water quality."15 Allowing such modal shifts to occur will undermine international and domestic goals with respect to environmental and human health. D. Research Shows that Emissions From Vessels With Engines of 20,000 hp or Less, Using 1.0% Sulfur Fuel Have Negligible Impact on Coastal and Terrestrial Air Quality A recent study entitled, Modeling the Air Quality Impacts of Short-Sea Shipping Emissions and the Implication for the North American EGA , shows that applying ECA standards to short-sea ships (i.e. with 20,000 horsepower engines or less) 200 miles from shore is not warranted to either prevent, reduce, or control air pollution from SOx emissions. The study analyzed short-sea ship emissions using the highly credible, EPA-approved CALPUFF and CALMET meteorological modeling. 12 California Air Resources Board, Proposed Amendments To The Regulations Fuel Sulfur And Other Operational Requirements For Ocean-Going Vessels Within California Waters And 24 Nautical Miles Of The California Baseline." at V-7 \May 2011 ). available at http://www.arb.ca.gov/regact/2011 /ogv11/ogv11 isor.pdf. 3 European Marine Safety Agency, Technical R eport, The 0.1% sulfur in f uel requirement as from 1 January 2015 in SECAs - An assessment of available impact studies and alternative means ofcompliance, at 7 (Dec. 13, 2010), available at www.cbss.org. 1 MarAd Rep ort to Congress, at 24. 15 Id. at 21 . See also ECA Proposal at 60 ("[S]hips provide the most efficient method to transport these [world) goods on a ton- mile basis."). MITA ECA Brief, p. 7 Twelve ships were selected to represent the "typical" short-sea shipping vessel (from a propulsion horsepower perspective and therefore emissions basis). The study analyzed the impact of "worst case" short-sea shipping vessels' emissions data on shore air quality. The study results show that the smaller short-sea shipping vessels (with corresponding lower horsepower propulsion systems) using fuel with 2.6% sulfur content, have virtually no environmental impact on the East or West Coasts of North America beyond 50 miles. The study demonstrates that SO2 concentrations along the coasts drop off dramatically as the distance from the ship to shore increased. Based on the modeling analysis, "the outward extent of the ECA could be much smaller (of the order of 50 miles or smaller), while still not adversely impacting coastal air quality." (See figure below). In conclusion, the "study undisputedly supports a performance-based ECA reduction to 50 miles for smaller ships comprising the short-sea shipping d e m o g raphic. "1 6 1.40000 - r - - - - - - - - - - -- - -- - -- - - - 1.20000 --+-- - - - -- - - - - - -- - -- - - - 1 -+- Narragansett 1.00000 "ti - - - - - -- -- - - - -- - -- - - - - Sandy Hook o.soooo - , - -- - -- -- - - - -- - -- -- - -a-Cape May ~ Cape Henry 0.60000 -r-. 11- - - - - - -- - -- -- -- - -- - - - -:+-- Cape Lookout 0.40000 0.20000 1-- - - -- - - - - - - - - - - - - -.- -+- cape Romai Savannah n _ _ _ _ _ _ _ _ _ _ _ _ _ __ __ _ - Jacksonville - -Cape Canaveral 0 50 100 150 200 250 300 350 400 -0.20000 ~ - - -- -- - -- - - - - - - -- - - East Coast Offshore S02 Dispersion, y-axis = micrograms/m3 of S02, x -axis= distance from shore, EPA 1-hr S02 NAAQS = 196 microgramslm3 Short-sea ships, therefore, can meet the EPA National Ambient Air Quality Standards (NAAQS) for sulfur by using a 1% sulfur fuel and also not impact the coastal environment nor communities in doing so 50 miles from shore. Requiring short-sea vessels to use 0.1% sulfur-content fuel within 50 nautical miles of the North American coasts instead of within 200 nautical miles, would align with the ECA designation authority under MARPOL Annex V I as well as current efforts under Annex VI and the U.S. Clean Air Act to reduce overall emissions while further reducing sulfur emissions. Given the net benefits it provides the U.S. and Canada in terms of improved air quality and public health and welfare outcomes, such consideration for short-sea vessels is preferable to the status quo. This finding is supported both by the likelihood of a shift in cargo transport to forms of transportation that emit higher levels of pollutants per ton-mile of goods transported, as well as by demonstrable scientific evidence showing that maintaining the 1.0% fuel standard for smaller coastal vessels w ill not have any adverse environmental impact on coastal communities, the coastal environment, or North America more generally. 16 Id. a t 7. MITA ECA Brief, p. 8 IV. Precedents for ECA Exemptions Currently, there are two exemptions from the marine fuel standards otherwise applicable to the ECA via Regulation 14, and codified at 40 C.F. R. 1043.60(b): i. The first applies to "vessels propelled by steam turbine engines or reciprocating steam engines (also known as steamships), provided they were propelled by steam engines and operated within the Great Lakes before October 30, 2009 and continue to operate exclusively within the Great Lakes." Id. 1043.90(a). This "Great Lakes exemption" may also be extended to other vessels operating exclusively within that region upon a showing of, among other things, "serious economic hardship." Id. (b). These exemptions were developed in response to congressional language in the Conference Report for Department of Interior, Environment, and Related Agencies Appropriations Act, 2010 and concerns raised by the Great Lakes shipping industry. 17 ii. The second exemption may be applied, upon request, to "historic steamships ... for operation in U.S. internal waters." Id. 1043.60(f). In addition , the United States has petitioned the MEPC for an amendment to Regulation 14 that would waive the sulfur fuel content requirements for existing steamships "that are powered by propulsion boilers that were not originally designed for continued operation on marine distillate fuel ... or natural gas."18 This request for consideration is founded solely on serious prudential considerations, including the fact that ships propelled by steam boilers could be susceptible to explosion if converted to marine distillate fuel. In its conclusion, the United States noted that "propulsion steam boilers face significant and unique challenges and the need to comply with the fuel sulphur limits for ECA may introduce unintended safety concerns" and "may result in increased emissions in the long run if these steamships are retained in the fleet longer than intended."19 V. Conclusion The Maritime Industrial Transportation Alliance supports the objectives of the North American ECA and believes that equivalent positive environmental outcomes can be achieved while safeguarding the existing economic impact, benefits and strategic objectives of short-sea shipping. By taking a blanket approach to ship traffic and emissions inventory measurements - without separately analyzing and considering the relatively small short-sea shipping sector - the ECA as it stands will disproportionately impact short-sea shipping and its large industrial base of customers by saddling it with exorbitantly higher costs leading to a shift in sourcing of material off North American coasts, lost jobs and even greater economic hardship for North America's industrial sector. In terms of environmental outcomes, the ECA, as it applies to the unique, innovative short-sea shipping sector, runs contrary to the objectives of the U.S. and Canada when they originally went forward to the IMO with their ECA application. Through rigorous analysis using the same meteorological modeling relied upon by the U.S. EPA, Dr. Ranajit Sahu and Dr. Andrew Gray demonstrate that applying a maximum 0.1% sulfur-content fuel standard to short-sea vessels operating more than 50nm from shore has virtually zero positive environmental benefit to human health nor the coastal environment. In other words, in 2015 short-sea shipping companies and the broader industrial economy will be forced to incur tens to hundreds of millions of dollars in added fuel, operational, logistical and related costs - and incur the resulting dire economic consequences - all for the sake of complying with ECA regulations that offer no marginal environmental benefit. There is a way, however, for the North American ECA to improve environmental outcomes while safeguarding the existing economic impact, benefits and strategic objectives of short-sea shipping. The North American ECA must be amended, as follows: Effective January 1, 2015, for vessels of 20,000 propu lsion horsepower (14,9 13 kW) or less, the outward extent of the ECA be set at 50 nautical miles from the coastline of Canada and the United 17 See 75 Fed. Reg. 22896, 22935-36 (April 30, 2010). ,e See MEPC 61nt6 (July 19, 2010). 1 g See MEPC 61nt61J 17. MITA EGA Brief, p. 9 States for use of 0.1 % sulfur fuel and from between 50 nautical miles to 200 nautical miles from the coastline for the use of 1.0% sulfur fuel. MODELING THE AIR QUALITY IMPACTS OF SHORT-SEA SHIPPING EMISSIONS and IMPLICATIONS FOR THE NORTH AMERICAN EMISSION CONTROL AREA (ECA) Prepared by Dr. Ranajit (Ron) Sahu and Dr. H. Andrew Gray Consultants April 2012 TARLR OF CONTENTS f.,XECUTfVE SUM1'vlARY ....................................... ........................................ I I. INTRODUCTIOT\: ........................................................................................... 15 IT. METEOROLOGlCAL MODELING tCALMET) .... ...................................... 18 m. D ISPERSION MODELING ............................................................................22 TV. ~IODEL RESULTS......................................................................................... 26 V. EMISSION CALCULATIONS....................................................................... 34 V I. THE SULFUR DIOXIDE STANDARD.........................................................39 Vil. CONCLUSIONS .............................................................................................40 Vill. REFERENCES ................................................................................................41 APPENDICES A RF,SUMES EXECUTIVE SUMl\1ARY Shipping has long been recognized as the most efficient form or transponation boasting an ability to move more lon-miJes per gallon of fuel than any other mode. Nevertheless, a<; responsible owners, our clients, CSL, T ransport Desgagnes and other short sea ship owners recognize the value of further rt!ducing the carbon fool print as wel l as the emis~ions of other pollutants a,;sociated with mm"ine transport. On their behalf, we have analyzed important current provisions of the North American Emission Control Area (ECA), designed lo reduce air pollution. Based 0 11 our technical analysis, we disagree with portions of the ECA. As c11rrenlly drafted. the ECA isn' I fully effective or sustainable to smaller/cleaner operating ships. Although well intended, Oaws in current marine air pollution regulations are jeopardizing an important component of the maritime community in the Shorl Sea Shipping sector. The pending scheme to align vessels with North American air quality gonls does not consider the short sea shipping niche which is challenged by a "one size fits all" ECA employed through Annex VI of lhe Convention to Prevent Pollution from Ships (MARPOL). As currently written and accepted, the North American ECA extends 200 nautical miles off U1e East and West coasts of the United Stmes and Canada within which ships must use L% sulfur fuel starting August I. 2012. Additionally, this fuel sulfur level will be rurther reduced lo 0.1 % in 2015 which will challenge coastal shippers in bolh fue l availability und its cost. Based on supply issues, studies have shown that future, compliant. North American marine fuel prices could nearly double in 2015. The anticipated increuse in 2015 fuel CO);lS wi ll hamper mmine competition and cou ld c:al1se a modal :.hifl from energy efficient short sea ships lo higher emitling ')hare-based modes (rail and truck). Such a shift will have the unintended cons~quence of creating more air pol111tion closer to population ccnterc;. More e ffort should be made 10 align the environmental goals of the ECA with the U.S. Marilimc Administration's 2010 Marine Highway Program which seeks to 'use the waterways to re lieve landside congestion and attain other benefits that waterborne transportal ion can ol'fer in the form of reduced greenhouse gas emissions und energy savings." While the 200 uautical mile ECA direclJy conflicts with the transportation goals of the Marine Highway Program, a 50 mile ECA, us we hnve proposed in this study, could achieve both the environmental goals of MARPOL whHe reducing land based congestion. An informal coalition or S hort .Sea S hipping led by CS L lnl ~rnationa l was formed in 2011 to better understand the impacts of the ECA anrl seek responsible and !>uslmnable -;olutions. Thf: Coalition~ s ignificant industrial mteresl!, inc lude Martin Marietla. Polari!., Vulica Shipping. U.S. Gypsum. and Transport Desgagnes to name a few. In an efforl to he,;t unden;tand the air quality issue, 1hr. Coalition commissioned Dr. Ranajit Sahu to formally study low horsepower ships as a demographic of the larger maritime commun ity for which the !:.CA was designed. This report Mocleli11g rht! J\ir Quality Impacts of S'1,,rt Sea Shippillf!. J:,'missimzs and rhe fmplir.afion for the North Anwri('(ln ECA Study ,Lnalyzes short-sea ship emi1ssions us.ing the;- ~amr CALPUFF and meteorological modeling used by the U.S. Environmental Pwrection Agency in _justifying the cunenl 200 nautical mile EC/\. Additionally, 12 ::.hjps wefl~ ~elected co repri!senl the "typical" ~11011 ~ea s hipping ve."sel (frflm a propulsion horsepower pcrsp~ctive and therefore emissions bc1sis). The !',ludy analyzes tile impact of ''worsl case'" ~ho11 sea shipping ves~e1~ emissions <lata o n s hore air qualjty. The study indicates tha l the smaller ships (with t.:orresponding lower horsepower propulsion systems) used in short sea trades, have virtually no environmental impact on the East or West Coast'> of North America beyond 50 miles. More specifica lly. the re-;ults indicate Lhal ships fi tted with propulsion -;ystems o f 20 ,000 ht1rsc power (14,91 3 kW) or less liad oo (or negligible) air qualhy impact on lhe coasts even when using rue! wilh a :-.ulfur content of 2 .6% at 50 mi les and beyonJ. Collectively. a..'- committed environmental stewards, CSL, Groupe Desgagne<; and the S hort Sea Shipping Coalition continue to seek to reduce their carbon footprint; as r;uch they fully supporl the EC/\. They disagree. however. with :i "blanket'" approach to developing lhc ECA boundurks. Specifically. a.-; 1ht1s study llemonslr-dtes, we don' t believe that 200 nautical mi k:s is an appropriate ECA boundary for all vessels. nor do we ft'el that il has been scientifically justified. V.'e urge policy makers 10 revir;it the ECA boundary extent and reduce lhe 200 nautical mile ECA to 50 miles l'or 0.1 % '>till'ur fuels (in 2015) for lower emitting ships tha t meet air quality 2 performance standards. This revision wil l align with scientifically based ciata which achieves the c;ame environmental protection goaJs. REGULATORY BACKGROUND MARPOL Annex VI seeks Lo minimize airborne emissions from ships including Sulfur Oxide!(SO);), Nitrogen Oxides (NO~). Ozone Depicting Substanc~. Particulate Maller (PM), and Volatile Organic Compounds. A. MARPOL Annex VI 1997: Annex. V1 (Regulations for Lhe Prcvenlion of Air Pollution from Ships) was added to the MARPOL Convention. 2005: The requirements of Annex Yl intcrnalionally entered into force on May 19. Among the various technical and operational emission reducing measures outlined in Annex VI is the option for member stales to establish ECAs in their tlomestic waters. 2005: Canada domestically ratified Annex Vl aJiowing domestic enforcement anc.J the eligibility to apply for any ECA. 2008: The United Stales ratified Annex Vl. 2009: Annex Vl entered into force domeslicnlly on January 8, making the United States eligible to domestically enforce the Annex and also to apply for an ECA. In the United Stales, Annex VI is applied via the Act to Prevent Pollution from Ships, 33 USC. 1901 cl seq., (APPS). o 2010: The rntemational Maritime Organization (IMO) approved a joint application by the United States and Canada for the creation of an ECA via Marine Environment Protection commillee (1\/IEPC) 59/6/5 entitled 'Proposal to Designate an Emissio11 Control Area for Nitrogen Oxides, Sulfur Oxides, and Particulate Maller: 3 B. Emission Contrnl Areas (ECA) The Non b /\rncrri;an ECA i~ dc,;1gneci lo reduce air pollutiun from ~hippmg beyond the :-.cope required for most portions of the globe. Stnct I % ~ulrtrr in fuel requirements will take effei;I in 1he new 200 naut irnl mile No1th American EC'A I'm Augu.<.t L :?.01.l. Titc ruel c;ulrur reduc tion in Augu~t 2012 will no doubt rt'rrn~ent an inc:rer1se in fuel prices. However. as an indu,;;try, this is likely to he :i .c;usrninablc increase-: in operational cost. The aduecl fuel co-.L will l)c retlected io corresponding L:argo rnlc incrt>ases llJ c;w;tomers but is nnt -.;xf)l.:cted tn cau:;e a major modal shift. Next , h0wever, the CCA fuel c;ulfur limil is mandated to be not m0re than 0.1% starling in 2015. By compari1-nn. a world-wicfo fuel ~ulfur limit pf 0.51:,. takes effect in the year 2020. Also. by comparison, the U.S. adopted an ECA for the Puerto Rico Caribbean Sea area in July 20 11 with a geographical area of appro,imately -1-0 x 50 nautical miles. The U.S. used very !:>imilar environmental and health staLisLic~ lo juslify lhe 50 nautical mile ECA for this region as it <lid when jlstifying the 200 nautical mile North Americ.-in ECA on both coasts 0f lhe United Slates and Canada. SHOUT SEA SHTPPTNG Somel11nes refcrrt>cl to i.n the IJ.S. a5 lhe ''Marine Highwa~,: Short Sea Shipping is; the mcweml!nl or pcoph! and cargo on water r0ute,; that do not cross an (ICean Ihat could also be served by truck or rail. Due to it" coastal nature. North Amerkan Shorl Sea Shipping is commonly comprised 01' Panaim,x si1.e ves-.els (and smaller), typically not cxcr.edmg 20,000 propulsion horsepower. Short Sea Shipping is an important compC'nCnl 0f the gl0bal Mralegy to improve air quality by reducing lan<l based congc<,tion and subsequent air pollution from less efficient truck ancl rail carriers. 4 A. Short Sea Shipping Coalition The Short Sen Shipping Coalition was founded by CSL in 201 1 lo promote the environmental benefits or Ihe short sea trade. The coalit ion is comprised of industry leaders who depend on short sea shipping us well as short sea providers and non-government agencies. The coalition promotes tough performance based afr emission standards for smaller and efficient ve5~els in the shorl sea track B. Short Sea Shipping Environmental Value We believe, the inherent environmental value in transporting people and cargo via sh.ip has been undervalued by policy makers in the creation of the North American ECA. When compared to land based options the environmental benefits arc obvious. According to Maritime Administration's 2011 Report to Congress: 1 "Trucks, on average, can carry one ton of freight for approximately 155 miles on a gallon of diesel fuel (i.e., 155 ton-miles of freight per gallon - equivalent to 842 British Thennal Units (BTU) per ton-mile); RaH achieves 413 ton-miles of freight per gallon (i.e. , 316 BTU per ton-mile): and a tug-and-barge operation can get as much a~ 576 ton-miles of freight to a gallon or fue l (227 BTU per ton-mile)." Additionally, self-propelled oceangoing vessels, such as r-:hon sea ships, can have significant energy efticiencies over land-based modes beyond those achieved by tug and barge. 1 America's Marine HighwHy Report 10 Congrc.~s; Muri1imc Adminis1ra1io11. April 201 t pa.gc 22 5 Whi le the aforementioned was offered in the Maritime Administration's 201 I Report to Congress, the below image represents a separate anaJysis by CSL which shows the same trends. > -. ~ .. . MARINE TRANSPORTATION . .. IS 'ALMOST 7X MORE EFFICIENT THAN TRUCK 1132 .__ __ _ ______ ------- CSL Vesse l Ton-miles per gallon " lnternationaJ shipping is currently estimated to have cmilled 870 million tons of CO2 in 2007, no more than about 2.7% of the global total of that year." 2 "From an environmental perspective...short sea shipping can offer air quality improvement, reduce traffic and mitigate noise pollution... marine shipping tends to have lower environmental and social impacts than land transport."3 "America's Marine Highway offers the potential of significantly enhancing the environmental s ustainabi Iity of the nation's transportation system. In particular, water transportation is often the most e nergy-efficient means of moving cargo between two points, with corresponding reductions per ton-mile in greenhouse gas (GHG) emissions. Similarly, with appropriate technology and regu lation, water transportation is an environmentally-friendly transportation mode that can reduce noise and air pollution and have minimal impacts on waler quality. -1 According lo the Maritime Administration's report to Congress delivered in April 2011, water transp011ation " is available to bring significant freight congestion relief along certain corridors. 2 Second IMO GHG Study; 2009, page 3 3 Making Connections: Short Sc:t Shipping in Canada; Transport Canada, 2006 page I 1 America's Marine Hig hway Report 10 Congress; Mnritime Administratio n, April 2011 page 21 6 A study for U.S. Department of Transportation estimated that there were a Lolal of approximately 78.2 mjlJion trailer loads of highway and rail intermodal cargo that moved between origins and destinations 500 miles aparl along the United Stales contiguous coasts in 2003. ThL,; long-haul coastal Lruck and intermodal traffic accounted for 15 percent of Lota! 527 mi llion trailer loads of United States intercity truck and intermoclal mil traffic in 2003." 5 Examining the range of typical CO2 efficiencies for various loaded cargo carriers; bulk ships produce :m average of 2.7 gm.ms of C01 per ton-mile while trains rc1nge from I0- J 19 grams per ton-mile . Trucks, by comparison, are the most inefficient of the transportat ion options ranging from 80-181 grams of CO2 per ton-mile (data excerpted).i; C. S hort Sea S hipping Economic Value Based on an October 18, '201 I study titled: "The Economics of lhe Great Lakes - St. Lawrence Seaway System," 7 Short Sea Shipping on the Great L akes alone contributes to: o $33.6 Billion in economic activity; 227,000 United Slates and Canadian jobs; and $4.6 Billion United States and Canadian tax. revenue. CHALLENGES TO SHORT SEA SHIPPlNG Short Sea Shipping is Lhc marine segment most impacted by the pending 200 nautical mile North American ECA. The Short Sea Shipping Coalition, under the leadership of CSL International and Transport Desgagncs, sponsored this detailed independent dispersion study applying the same parameters, melrological data, and CALPUFF modeling used by EPA. The study specifically uses emission data from CSL's North American fleet to best represent the short sea segment o f the marine transportation system. This study unclisputedly supports a performancebased ECA reduction to 50 miles for smaller ships comprising the Short Sea Shipping demographic. 5 Ibid, page 12 6 MEPC 59/INF. IO ANNEX; April, 2009 1The Economic:; or Lhc Great Lal.cs - St. Lawrence Seaway System; Marli11c /\ssociatcs. Oc1oln!r 18, 2011 , Page 5. 7 Without a change in the ECA boundaries, the impact on the inherently "green" short sea shipping segment will be far g reater than for ships engaging in trans-ocean voyages. Short sea shipping routes tend to be more Goastal and, in many cases, almost e ntirely within the ECA, while transocean vessels will only operate in the ECA for a small fraction of their total voyage. The 2012 fuel price impacts, for CSL as an example, while sustainable, will sti ll be measured in millions of dollars. Whe n the 2015 sulfur limits take e ffect, fue l cost increases for CSL and its customers could easily cause a modal shift to land transportation. Typical No11h American Short Sea Routes A. Air Quality fn this study, in addition to the green-house has emissions discussed above, we focused on sulfur dioxide (S02), Lhc major pollutant whose emissions will be affected by the fuel sulfur requirements in the ECA. 8  Tlze S02 S1a11clartl: The U.S. EPA has promulgated various National Ambient Air Quality Standards (NAAQS)8 and thereby defined acceptable levels of major air pollutants. including for SO2 in the ambient air to which lhe public has general access. The purpose of the NAAQS is to protect 1he public health, including tbe health of sensilive" populations such as astbmalics, children, and the elderly. Tbe S01 NAAQS was recently (June 2010) modified to add a I-hour average standard of 75 parts per billion (ppb). This corresponds to a concentration 0f 196 micrograms per cubic meter. It is currently the most stringent SO2 standard in the U.S. Our analysis conservatively predicts that SO2 concentrations arc well below the numerical value of the I-hour SO2 NAAQS even when ships are at port. Moreover, this prediction is based on applying a fue l sulfur level Clf 2.6%, which, as staled obove, is expected to drop to L% fuel sulfur level in August 2012. The study also indicates that SO~ concenln.Hions al0ng the coasts drop off dramatically as lhc distance from the ship to shore increases. Thus, based on the modeling analysis. the outward extent of the ECA could be much smaller (of the order of 50 miles or smaller), while still not .idversely impacting coastal air qua.lit.y. The largest ship (in terms of rating) used in the study for tbe easlern u0main has an engine size of approximately 12000 kW. Thus, for a 12000 kW engine, the maximum hourly SO2 emissions using 2.6% sulfur in fuel is 9.9 1 * 12000/1000 = 120.6 kg/hr. The S01 emission rate using 1% sulfur in l\1el is 3.81 * I 2000/1000 = 46.4 kg/hr. The calcu lated SO2 rates above are also conservative in that the engine load is typically 75% of ils maximum power during a voyage (as opposed to 100% assumed in the study}, and which is even lower as the ship approaches po1t. While .in port, engine power may bt! a small fraction (20% to 40%) of its m:1ximum power. Tims, the actual S02emission rate~ would be 20% to 75% of the rate:; cakulated in the study or in range of 24 kg/hr - 95 kg/hr for a l2000 kW ship with 2.6% sulfur in fuel ,md in the range of 9 kg/hr - 35 kg/hr for Lhis :;ame l2000 kW ship with J% sulfur in fuel. ~ Sec ht1p://www.cpa.gov/air/cri1cria.lllml. 9 Similarly, the largest ship s tudied in the western domain is raLed around 11500 kW. Using the same Lypes of calculalions above, the range of SO2 emissio ns from a s hip of this size will be 23 kg/hr - 9 1 kg/hr (maximum of 114 kg/hr) with 2.6 % sulfur in fuel and in the range of 8.6 kg/hr 34 kg/hr (maximum of 44 kg/hr) with l % sulfur in fuel. Using the hig hest expected S02 e missio n rate discussed above of 120.6 kg/hr (for the larges t ship, at maximum power, emilling al exactly the meteorologicaJ conditions that would provide the highest impact, and assuming a fue l sulfur content of 2.6%), the highest modeled port I-hour S02 concentration would be 1.1 56* 120.6 = J39.4 micrograms/cubic meter: far lower than even the numerical value of the EPA SO2 NAAQS of 196. The results demonstrate how insignificant the impact of these short-sea ships is on coastal air quality. 1.40000 1.20000 1.00000 I r~ 0.80000 0.60000 ' 0.40000 0.20000 0.00000 . II -0.20000 ~ L. - 50 100 ~ .... 150 200 -+- Narragansett - Sandy Hook -.lr-Cc'.lpe May - .Cape Henry -+-Cape Lookout - cape llom.:iin - , -Savannah - -Jc'.lcksonvillc - wi-::-.-t::-,Q--, 250 300 350 400 Cape Canaveral East Coast Offshore SO2 Dispersion 10 CREATING A "WIN-WIN" The anticipated significanl fuel cost increase in 20 IS may trigger a modal shift causing an uninlended increase in land based congestion and emissions which can be avoided by reducing the 20 LS ECA Lo 50 miles for 0.1 % ,;ulfur fuels in 20 I5 for smaller ships. A reduction in the ECA boundary for the 0.1 % sulfur fuels in 201 5 will deliver the same environmental benefits suggested while supporting an industry which is already a greener alternative. The flexibilily in fuel options will assure economic sustainability Lo those company's already under strain from the cnrrent recession. A. Maximize the i.\.farine Highway Progl'am The North American ECA, as currently defined, stands as an obstacle to reaJizing the environmental and economic potential of the M,u-ine l-ligbway Program. ''Between 1980-2003 the tons per mile moved by inter-city truck increased by 128%. Also during this period, vehicle miles jn the United States have increas~d t,y 50% creat ing more road congestion and noise than ever before." 9 Marine transportation is credited with removing over 60.000 trucks from congested urban roads or southern Ontario and Quebec.10 Considering an average long haul truck can carry 26 tons of cargo and a Handy Size short sea vessel can carry a puy Joad of over 50,000 tons, the short sea trade ri::moves 1,923 trucks from American and Canadian roads, easing congestion and the emissions Ibey produce. Similarly. the same ship would remove 8J9 rail cars, assuming a capacity of about 61 tons per rai l car. Enhanced Short Sea Shipping will: Remove low efficiency trucks From the road: 11 /\mcricas Morine Highway Report IQ Congress; M:mtimc Administration, /\pril 201 I (lilg.! 16 10 Making ConnecLinns: Shorl Sea Shipping in Canada: Transport Canada. 2006 pngc 5 11  Le..,sen higher emitting rail volume; and Improve social bcncfit'i including reduced road cong1,;:.tin11 and noi~e. All while mainlaining the improved marine air quality standanls called for in Annex VJ. PRECEDENCE FOR EFFECTIVE ALTER.1'\IATIVES There have been ~evcrol c,ther examples of recent praclir:!I ~olution-. ~nlertainru by Lhe EPJ\, Transpnrl C'anucla ..ind Environment Canad::i in achieving mutual clean air goah-. A. Steamship Exemption Following the adoption of Annex VJ and the creation nf Lhe ECA, the United State.'- recognized, the un.iq11c- challenge:-. faced hy older steam ship,. Th~ older ves::;cls' 0hsolcte technology proved 10 be incompatibk with using ultra low c;ul fu r nrnrinr dist illate fuel!.. Thus, the l 1niled Srate'i formall y excmph.!<l lhe enti r\! demographic or steam ships from the ECA requirements until 2020. The United S1::i1cs' submission 11 to the GvJO w;is udopted al the 62"'-' se~sion of the Marine, Environmental Pr0tection Committee in July of 201 1. B. CTrcat Lakes Steamship Repowe Jm:cntive Program or Again. as the envi ronmental and economic rcalilie~ the North American ECA continued to be assessed. the EPA recogni7,ed the environmental advanlnges ul' waiving the lower sulfur l'ucl requirements for Great Lake~ 5tcam ships [lhat were] repowercJ with more efficient modern dic~el propubion. i: ln Janumy of 2012. the EPA amended Tille 40 C'nde of Federal Regulalinm, Part. 1()43 fl' incentiviz~ G reat Lake.., steamship owners " t0 rep0wer those !-leamships with cleaner mnrinc diesel engines. The -;irnplific<l program wi ll aul.()malicaJly permit the use of re-;idunl r11el. through December 3 l. 2025, in a c;teamshir if it ha<: be:en repowered with a l.:Crtificcl Tier 2 r)I' laler marine d.ie.\el engine. provided lbe slellrnship wa~ operaLed e){clusively ori the Great Lakes and wn~ in service on OcLober JO, 2009:' ~ C. FleeI' Averaging 11 MEPC <1 l nt(,; U.S., July J9, 2010 I'.! Federal Rcg1slcr Tl FR 2472; U.S. EPA. January 18. 20 I1. 12 Transport Canada, in an effort lo ease devastating impucls to Canadian Great Lakes ship owners, proposed a Fleet Averaging Program which provides an alternative to improving air quaLity. The Fleet Averaging Program requires Canadian Great Lakes vessels to g radually reduce their fuel sulfur content from 201 2-2020. The program permits a company's fleet of vessels to collectively meet pre-established annual fuel sulfur targets through the use of lower sulfur fueJ s. exhaust gc1s treatment, or a combination of measures. Tram.port Canada will oversee and monitor the industry to assure compliance. By 2020, each ship must individually meet the ECA 0.1 % fuel su lfur contenl standard. RECOMMENDATION As responsible carriers, our client CSL and the S hort Sea S hipping Coalition proudly support and promote the Norch Americm1 ECA as a valuable tool to reduce maritime contributions to global e missions. Neverthe less, as c urrently designed, portions of the North American ECA do not consider the value of Short Sea Shipping in lhe greater environmental picture. Moreover, the impact of the current ECA 's flaws could inadvertenlly reduce air quality through modal shift. If lcfl uncorrected, Lhe anticipated fuel prices in 2015 will significantly raise cargo rates without gaining any environmental benefit. Our clients seek l0 alig n the 2015 ECA to a sustainable size while exceeding air quality goals set by the EPA and Environment Canada through a performance based approach. Our stucly indicates that vessels of 20,000 horsepower, arc l:apable of meeting and exceeding desired air gua lity goals when using fuel with sulfur content of 2.6% al a d istance of 50 miles. Therefore, we recommend: a 200 nautical mile ECA for 1% sulfur fuels effective August l, 2012 (as currently accepted): a 50 nautical niilc ECA for 0.1% sulfur fuels for vessels of less than '20,000 horsepower (14,913 kW); and a mechanism lo indemnify vessel owners who are unable lo purclrnse low sulfur (0. 1% sulfur) fue l due lo regional unavailability. 13 Thi!- alternative dovc-taib-. with the ManUme Admin istration,; 2010 Manne: Highway program and Transpon Canada'$ &horl sea shipping iniliar ives and will be\l c;crve Lhc coastal environment hy comprehensively improving air quality while rec-1l1cing risk, hazard and inconvenience of over-use.cl wad and rail -;yslc!lllS. 14 l. INTRODUCTION TO THE ANALYSIS The United States Environmental Protection Agency (U.S. EPA) has proposed lhe creation of an emission control area (ECA) for nitrogen oxides (NOx), sulfur dloxidc (SO2), and particulate maller (PM) (U.S. EPA 2009). The proposal would designate an ECA in which emissions from vessel aciivity would be reduced via lowered fue l sulfur content and other con trol measures. Presently, the extent of the ECA is 200 nautical miles13 from Lhc coast. However, when establishing the distance from the sho reline to include as the ECA domain, it i!'- useful to examine the expected a ir quality impacts that wou ld occur due to shipping activity at varying distances from the shoreline. Based on guidance provided by Dr. Ranajil (Ron) Sabu,14 in consultation with Canada S teamship Lines Inc. (CSU ) and Transpon Desganges Inc. 15, an atmosphe ric dispersion modeling study was conduc ted by Dr. Ai1drew Gray 16 to determine the air quality impacts (specifical ly for sulfur dioxide or S0 2) al shoreline receptors due to emissions from a class of oceangoing vessels name ly short-sea shipping 17 vessels that make voyages that are generally parallel of the east and west coasts of the North American continent, transporting various materials in and out of Canadian and U.S. ports.18 Hypothe tical emission sowces representing a typical vessel were place,d at several locations a long east-west lines ex.tending outward from several ports along the east and west coasts of the United States. Dispersion modeling was used to esti mate the maximum hourly SO 2 concentration impacts from each of the modeled sources at hundreds of receptors localed along the coastlines. The model resulls provide an indication of the distance at 13 I uauLical mi!c is l.852 kilom,.!lcrs. Thus, the 200 naulical mile ECA extends tu .1pprux1ma1cly 370 kilometers from each coast. fC'llowing the contour of the coast. All dbtances in this report will be noted rn kilometers since that is the customar y unit ofdistuncc usccl in <lispcrsion modeling unalyses. 11 The resume for Dr. Sahu is provided i n Appendix A lO 1his report. or ,:, CSL! nnd Transport Dcsg,1gnes Inc. arc key short shipping carriers nloug hoth coasts the North American conlincnl. 16Ti1c resume for Dr. Gray is provitlcll in Appendix A lo lhis rcporl. 17 This s tudy a niilyzcs lhc impnct of the ECA on short-sea shipping vessels. Short-sea s hipping refers to voyngcs made by small ships (on u vessel dead weight 10 11 (DWT or engine horsepower bnsis) 1ha1 make port calls a long numerous pons on llu.: cost oml west coaslS C'f Norih Arncric;i. As such, they 1r.mspnr1 c.irgo in tlirect cornpe lition lo shore-based counter parts such as r~1il or trucks. It is well cslahlishc<l that on a pcr-gal1011 of fuel used basis, short- ~ea s hipping is far more dlicicnt in transporting cargos Urnu :my other la nd-based mod~, such as road (trucks) m mil. Voyogcs tend to be generally paralle l to the co.\Sl.s ond nl distances thal arc relatively close to the coasts. rn , By their nature, short-sea shipping vessels spend s ubstantia lly more lime within the ECA domain as currcm e nvis io ned. TJ1js is in marked contra.st Lo other vessels such as large, lrnns-contincnt.11 vessels or even cruise ships, which approach each consl iu n gcnemJly pcrpcmlicular manner. and whose voyages witJ1in the ECA domain arc 1hcroforc a rdalively small fraction o f their total voyage dista nce or lime, 15 which the impacts become small re lative to the impacls from sources located at the shoreline (i.e., in port). All modeling, as is cw,tomary, was done u,ing "unit' e mission mies from the source (i.e.. the ship) since predicted conct-n1ration~ vary linearly with the emissions. Later, selected (i.e., maximum) model-preJictcd concentration re-,ullc; werl' converted to predicted maximum emi'>!,ion impacts, using t:xpccted maximum emi~si0n ral~5 from the ~hip 115ing maximnm current sulfu r levels (around 2.5% sulfur) in lhe fuel. The mode.Jing approach included the uc:c 0f ;i snphisticat,~d 5palially-res0Jve d meteorological data5ct, de veloped using th1.; Fifth Generation Penn SI.ate/NCAR i\-lesoscale ;'vfodel (ivIM"5). which was input lo the CALMET model adiagno~l.it: thre<':-dimcnsional mctcowlogicaJ model (used by the U.S. Environmental Protecliun Agency (BPA)This was followed by application of the CALPUFF dispersion mncld lo simulate the fote nf SO1 emissions from oce,mgoing vessels;. CALPUFF is a multi-layer, mulli-spel'.ics non-steady-state Gaussian pllff disper!'-ion model that simulates the effect:,. of lime- and !space-varying meteorological conditions on pollutant transport, transfom1ation and removal. CALPUFF cun be applied reliably on scale:-: of a few meters lo severnl hundreds of kilometers. ll include~ algorithm'i for :-ub-grid scale effects such us te rrain impingement, as well as longer-range- effect-:; -;uch m, pollutant rl!rnoval due m wet scavenging and dry deposition (Scire ct al., 2001aJ. Some or CALPUFF's non-steady-state rc,1lure~ include lhc moders ahilily to handle tram.port in complex. temun, stagnant and light wind flow conditions. hnriwnta.l and vertical wind shear, nocturnal temperature inversions, and recirculation tlows. The CALPUFF model consider'> the 5patiul variability in surface conditions (elevation, surface roughness, land use lype. veg.elation. etc.), ~. well as the spatial and lernporal variability in mctcoroJogkal condition~. In Apri l 2003, the U.S. EPA revised their Guideline on /\ir Qualiry Mpdcls to include the CALPUFF modeling system as the preferred a ir quality molleli.ng tool for assessing long-range transport of pollutants and their impacts on Federal Class l areas and on a case-by-case basis for certain near-flelJ applicalinns involving complex meteorological conditions (U.S. EPA, 2003). Further details or the CALPllFF modeling system. including the scientific l'ormulation, extensive peer--revic w'i, model validation studies, and reguhitory r.t:i.tus can be found elsewhere (Scire el al. , 200la,b1. 16 The remainder of this reporl describes the model ing application. includ ing meLeorological data processing using Lhc MM5 data and CALMET, dispersion modeling us ing CALPUFF, and poslprocessing using CALPOST. Mode l results are then briefly examined. Next, the maximum modeled impact is compared, in a very conservative fas hion, to the most stringent (i.e., I-hour) SO2 U.S. National Ambienl Air Quality Standard (NAAQS). The study shows that, even with numerous conservalive assumptions (namely the use of fuel sulfllr level of 2.6%, which il- expected to drop to I% fuel sulfur level, and lhe selection of lhe " worst-case" or largest ships) predicted SO2 concentrations are well below the numerical value of the l-hour SO2 NAAQS even w hen ships are at port. We also show that these concentrations along each coast drop off dramatically as the distance from the ship to !>hore increases. Thus, hased on lhe modeling analysis, the outwaJ'd extent ol' the ECA could be much smaller (ot' the order of 50 miles or smaller), while still not adversely impacting shore-based receptors. This would a llow short-sea shipping to continue Lo economically operate outside a properly designated ECA, using l % s ulfur fuels for most of their voyage durations, thereby providing a crit ical parallel path of tJ1e transport of numerous goods that would otherwise be shifted over to land-based modes such as rail or trucks, which would have far greater impacts on receptors a11d population centers. 17 11. METEOROLOGICAL MODELING iCALMETJ Output data from lhe Fifth Generatjon Pr.on Stale/NCA.R Me::.oscale Model (MM5) was utili1:ed lO rrovide the iniLial conclilion" for the CALMET diagnosli(; meteorological model. MM5 is a tbree-dimcm,ionaJ pro~nostic weather model mainwined by the National Center for Atmospheric Rcse:.irch tNCAR). The model includes four-dim~nsionnl iliita assimilation (FDDA), wbereby the resulti ng meteorological fields are forced to be c<:msi:-tcnl with ,;;urface and upper mr ob:-ervatiom; and satellite data, while maintaining dynamic baJance al t11i: same time. The MM5 results using FDDA represent a high resolution verrically-resolved griclded f-et or meteorological fields, including wind speed and direction, atmospheric pressure anJ temperature (Dudhia et al. . '.:.003). The 2001 -2003 Mi\15 data c;;et19 (Sahu 201 la) include!. hourly winds and other meteorological data c1t ..::ach o f 34 vertical layers for the entire continental United States on a 36 by 36 km horizontal grid system that follows a Lambert Conformal map projection. The central reforcnce point for the mapping projection (a point where the hori:zonral and vertical grid lin\!S mo true north-south and east-west) was at latitude 40N and longitude 97->w, with standard parallels at 33N and 45"N latitudes. The entire domain for which MMS data were available for this study is f..hown in Figure I. Subsets were extracted from the naticmnl MM5 data set for modeling the impact!> or uff-1'-hore shipping emissions along Lhe east.em and western coasts of the United States. The selected eastern moc.lel ing domain i!> a 900 km x 2.520 km rnctangle. as shown in FigLre 2a. following the same Lambert Conformal map projection as the MM5 data set. The CALMET c0mputatiunal grid for the eastern CALPUFF !.imubtion!'- conlains 28,000 (100 x ?.801 9 km horizontal grid cel ls wilhin the 900 km x: 2.520 km n1ou~ling domain !:-hown in Figure 2.i. Each lioriwnlal grid t:ell is divided into 11 t;Omputatinnal vertical layers, !>O the total number of compulHti<Jnal cell~ within the nwdel is 308,000 ( 100 x 280 x 11 ). rN 19 This 1s a widcty 1,1~,.;cl data sel for modeling application~ n111llero11s nir qual11y ~011n:cs. Ry mnc.Jding for three rull ycnrs of n1ctcornlog1cul data. variability in mcccorolo~ical conditicin~ is cxpcl'tctl to be folly captured hy 1he anolysis. 13 Figure 1. MMS Modeling Domain The selected easlern modeling domain is a 900 km x 2,520 km rectangle, as shown in Figure 2a, following the same Lambert Conformal map projection as the MMS data set. The CALMET computational grid for the eastern CALPUFF simulations contains 28,000 (100 x 280) 9 km horizontal grid cells within the 900 km by 2,520 km modeling domain shown in Figure 2a. Each horizontal grid cell is divided into 11 computalionaJ vertical layers, so the total number of computational cells within lhc model is 308,000 ( 100 x 280 x 11). The selected western modeling domain is a 792 km x 2,808 km rectangle, as shown in Figure 2b, also fo llowing the same Lambert Conformal map projection as lhe MM5 data set. The CALMET computational grid for the western CALPUFF simulations contains 27,456(88x3 12) 9 km horizontal grid cells within the 792 km by 2,808 km modeling domain shown in F igure 2b. Each horizontal grid cell is divided into l l computational vertical layers, thus the total number of computational cells within the model is 302,0 l 6 (88 x 3 12 x 11). 19 Figure 2b. Western Domain Figure 2a. Eastern Domain Figure 2. Eastern and western modeling domains The CALMET meteorological model (version 6.326, July 9, 2008; Scire ct al., 2000b), part of the CALPUFF modeling system, was used to prepare the meteorological data necessary for CALPVFF execution. The CALMET model combined the vertically-resolved MMS data (specified horizontally every 36 km) with fine-scale ten-ain effects, lo develop three-dimensional wind fields on the 9 km computational grid. No additional surface or upper-air data were necessary (i.e., NOOBS=2). In addition to the Lime-varying wind fields, other meteorological data are needed to cl1cu-acterize atmospheric conditions. Using the MMS model output data, CALMET generated a set of time-varying micrometeorological parameters (hourly 3dimcnsional temperature fields, and hourly gridded stability class, surface friction velocity, mixing height, Monin-Obukhov length, convect ive velocity scale, air density, short-wave solar radiation, surface relative humidity and temperature, precipitation type, and precipitation rate) for input to CALPUFF. 20 In addition to meteorological input data, CALMET requires a number of geophysical data sets, including terrain elevation, land use type, smface characteristics (roughness length, albedo, Bowen ratio. soil heat flux parameter, and vegetation leaf area intlexl und anthropogenic heat flux. Gridded te1Tai11 elevation data for the eastern and weslem offshore modeling domains were obtained from the Global 30 Arc-Second Elevation Data Set (GTOPO30) distributed by the U.S. Geological Survey (USGS, 1997). Four "tiles" of the global daca set, representing the area north of the equator, between 60W and 140W longitude were obtained to provide elevation data for the lwo modeling domains. Elevations in GTOPO30 are regulurly spaced at approximately I km horizontal intervals. The TERREL preprocessing program was used to extract the required elevation data from the GTOPO30 data for use in CALMET. The No1th America Lund Cover O1aracterisLics Data Base (Version 2.0) is parl of a global land cover characterislics data ba'ie containing a number of land use classifications, and includes the USGS Land Use/Land Cover (LULC) System. The Lambert Conformal LULC data set for North Ameril:a (USGS, l999), consisting of gridded fractional land use data, was re-mapped into the 14 default CALM ET land use categories on rJ1e gridded modeling domain. These data were then used lo develop gridded fields of the surface parameters (roughness length, albedo, etc.) and anthropogenic he.it flux which are required inputs 10 CALMET. ln the process of allocacing the raw LULC data to the modeling domain (using the CTGPROC progrnm), at least 68 "hits" were recorded in each of the 9 km x 9 km grid cells, providing confirmation tlmt the land use and land cover characteristics are weU represented statistically wiU1in each computational grid cell. The CALMET model produced complete sets of hourly tllree-dim~nsional wind fields and other micromeleorological data on tbe 9 km x 9 km gridded eastern nnd western modeling domains, as shown in Figures 2a and 2b for lhe years 200 I, 2002 ,ind 2003. These data were then usecJ as inpm co the CALPUFF dispersion model. 21 III. DISPERSION MODELING (CALPUl 'F) The CALPUFF dispersion model was used to estimate the air quality (concentration) impacts due Lo a number of identical stationary sources. placed along approximate east-west lines, ex.tending outward from a number of selected porLs. The modeled ports in the eastern domain are, from north to south. 'Providence, RI (Narragansett); Sandy Hook, N J; Cape May, NJ: C.ape Henry. VA: Cape Lookout, NC: Cape Romain. SC: Savannah. GA; Jacksonville. FL: .and Cape Canaveral, FL. A source was located at each pDrl. Additional sources were placed every 40 km ex.tending eastward out to 360 km from ead1 port (with the exception of Narragansett, for which sources only extend out to 280 km). Thi!- is shown in Figure 3a. The modeled ports in the western domain are. fro11J north to south. Vancouver, BC (located near Pt. Renfrew at the mouth of the Juan de Fuca Strait); Porlland, OR (locate<l near Astoria at the mouth of the Columbia River); Bay Area, CA (lol.'.aled at the "Golden Gate" - the western etlge of San Francisco Bay); Los Angeles, CA lHa rbor); San Diego, CA; and Ensenada, MX. Additional sources were placed every 40 km on approximate east-west lines ex.tending westward out to 360 km from each port (with the exception of the Bay Area, for which sources only extend out to 240 km). T his is shown in Figure 3b. The e missions and stack characteristics for all modeled sources were identical. T he SO2 emissions rate for each source was set to a unit rate ( I kg/hr). The stack parameters were for a " Lypical" vessel and were obtained hy averaging s tack d ata from various different vessels (Sahu 201 lbl. as shown in Table l.20 In l1,1rn, Dr. Sahu obtained these parameters from 20 For the sLx vessels (labeled A through F), tor whic h all required stuck data were avuilabh.:, additional mr1del runs were later pci:forme<l using these vesscl-spccil'ic stack parameters lo examine the sensitivity of the model results lo the selection o l' stack parameters. Addi1i011al dernils for lhesc vessels, denmns1ruting their relatively small size (,is compared 10 the lmgCT lrnns-occanic cargo/tanker or cruise ships) is provided in Appt:ndix B. 22 Table 1. Vessel Stack Characteristics Vessel A CSL Atlas Stack Height (m) 29.4 Stacie Diameter (m) 1.3 Exit Velocity Exit Temp (mis) (deg C) 12.8 6 13 B SheiJa Ann 28.1 0.8 27.3 566 C CSL Acadian 29.0 1.6 7.9 593 D CSL Argosy 29.9 1.35 10.6 533 E Eastern Power 25.24 1.1 13.3 563 Average used for 28.1 1.23 14.4 575 modeline F Cape Vessel 37.0 I.I 27.6 623 Generic Figure 3b. Western Modeled Sources Figure 3a. Eastern Modeled Sources llarraganscll Sundy tlook *Washington Cape Muv Cape llcnry Cape Lookoul Cupe Romoi11 Sav,rnnah Jacksonville Cape Canaveral Figure 3. Modeled Source Lines.21 Emission sources (i.e., the ship) were placed at 40 km intervals a long each of the red east-west lines extending from each port) 21 As noted earlier, except for Naraganseu in the eastern domai n and the Bay Arca in the western domai n, all of the other pon cast-west lines extend to 360 km from lhe coast. This is approximately the same distance as the ECA 23 Rccc.ptnrs were placed along bNh coa~tlincs22 ~paced approxim:.itcly every 8 Ln 10 km (the innx1111um dislancc between any two ad_jac-enl recc.plors i~ 13 kml. There ,-vcre 272 receptors placed between Glouce~ler, MA and Jupiter. t-=L along the eaM coast, accounting for a cumulative db.Lance (from rece ptor to receptor) of '2.655 km. Along lhe west coast 348 receptors were plnced from northern Vancouver island, BC. c;outhwarrl 10 Sm1 Quintin (Baja California). The c um11lat ivc distance for th..: west coas1 receptors ;._ ~,910 km. Them w,,s a receptor placed at c-ach port (coinciding wiU1 the \Qcation of the mode led source al each port). The elevation al l'ach receptor height was determined by interpolating the GTOPO30 elevation data set using the.: TERREL preprocessor. Thc. CALPUFF disp~rsion model (version 6.262. 25 July 2008; Sdre et al., 2000a) was run using ll1e ourput l'rom lhc CALMET meteorological mciuel. CALPUFF was run separately for each source, locaLetl e ither at one of the modeled ports, or aJong Lhe ca'it-west lines extending out Lo sea from each pcwl. The model was nrn in an inert mode, i.e., lite atmospheric chemistry module within CALl'UFF that accounts for the oxidation an<l conversion of SO2 to sulfate was turned off.2J The model's output consisted of hourly cst.imatt'-'i of ambieal SO2 concentrations at each c.:oi1stal receptor due to the emissions from each source. Upon completio11 of lhe CALPUFF modeling, the predicted hourly S02 concentrations were surnmari1.cd using the CALPOST postprocessor. CALPOST was used to determine the maximum one-hour average SO2 conceAlration for the e ntire model ye;1r :.1L each receptor (and also tbe 99th percentile, w hich corresponds to the 41h highest daily maximum one-how- average), for each of the niodeled source~. domuin. The N,1mga11scll and B:i.y Are.-i lines wcr.: lruacah::d since mctcorolug,cal Jalu b.:yond what 1s 'ihown by 1hc vcrtic~ l red hncs ,n Figun:s 3a and 3b. was nol available. !'. Mcdcl 1cs1runs wcri.: performed using inland r.:ccplors. II wns ,,bscrvetl 1hn1 the concentration irnpact.s dropped r,ff rapidly a). 1hc rcr.cprc>rs moved further inland, 10.:h,tivc Co the impact :11rhc c11<.1S1linc. Reccprnn: placed along rhc co.1~11inc would therc rorc be expecled lo caprure lhc penk impacl!- frum c:i1:h modeled coas1al or off'..shore sc,nrcc. Therefore ;11lrli11onal inlund receptors were not used. lJ The oxu,Jmion of SO2 in the atmosphere is a rdalivi.:ly sl11w proct~s. typically acc0un1ing Lor the conversion of, :11 mnst, a courli.: percent per day (especially over rhe ocean). Uy ignr,ri11g the SO! ch.:misuy wit.hin !he CALPUPF or 1110<lcl. the rc!-ul!ing pn:dicted SO2 concenlralitins arc vc1y sli,!!hlly nvcrcstimatcd. anti therefore represent cn11sr:rva1ivc estimates Lhe air quality impacts associnlcd with rhc c111issi1'11s from the 111odeled ~ourccs. 24 The CALPUFF model was run for a full year (200 I) for all sources along all source lines. as shown in Figure 3. Additional model runs were performed lo examine the impacts for two addil.ional years (2002 and 2003) for one of the source lines (Cape Henry). 25 IV. MODEL RESULTS T he CALPUFF model was used to estimate hourly average S0 2 concentrations at each coastal receptor due to a constant unit (1 kg/hr) of S02 emissions from each modeled source. The model results for lhe individual sources located along each source line were plotted together in order to compare the relative impacts fro m shipping sources as they move further out to sea. Example plots for a subset o f Lhe modeled ports (and the sources extending outward to 240 km away from each port) c1re shown in Figures 4 through 9 (the value in parentheses following each port name indicates the receptor number that is co-located at the port). 1.0000 - 0.1000 M -mE :::L 0.0100 0 C 0 0 0.0010 Narrangansett Sources 0.0001 0 17 34 51 68 N/S Receptor 0 km 40 km 80 km x 120 km x 160 km ~ 200 km 240 km Figure 4. Peak 1-hr S02 Concentrations for Sources along Narragansett Line (36) 26 Cape Henry Sources 1.0000 M 0.1000 . 0) .:: 0.0100 (.) C 0 u 0.0010 0.0001 85 1 0 km 40 km 102 119 136 153 N/S Receptor I 80 km x 120 km x 160 km + 200 km 240 km Figure S. Peak 1-hr SO2 Concentrations for Sources along Cape Henry Line (U0) 1.0000 Savannah Sources M 0.1000 . 0) .:: 0.0100 (.) C: 0 <.> 0.0010 0 .0001 170 187 204 221 238 N/S Receptor 0 km 40 km 80 km x 120 km x 160 km + 200 km 240km 1 Figure 6. Peak 1-hr SO2 Concentrations for Sources along Savannah Line (210) 27 Portland Sources 1.0000 -M' 0.1000 E 0) 2; 0 .0100 0 C 0 o 0.0010 0.0001 29 58 87 11 6 N/S Receptor I 0 km 40 km 80 km x 120 km :r 160 km + 200 km 240 km Figure 7. Peak 1-hr S0 2 Concentrations for Sources along Portland Line (71) Bay Area Sources 1.0000 'M 0.1000 .E._ 0) 2; 0.0100 0 C 0 <.> 0.0010 , 0 .0001 145 174 203 N/S Receptor 232 1 0 km 40 km 80 km x 120 km "' 160 km .. 200 km 240 km Figure 8. Peak 1-hr S02 Concentrations for Sources along Bay Area Line (204) 28 1.0000 M 0.1000 -eEn 3 0.0100 0 C 0 0 0.0010 Los Angeles Sources 0.0001 232 261 290 3 19 N/S Receptor o km 40 km 80 km x 120 km x 160 km + 200 km 240 km Figure 9. Peak 1-hr SO2 Concentrations for Sources along Los Angeles Line (282) As can be seen in Figures 4-9, the peak modeled impacts were at or near the port (at the o rigin of each source line). The peak impacts decrease dramatically for receptors up or down the coast located away from each port (origin of source line). Depending on the shape of the coastline, the impacts reduce approximately two orders of magnitude relative to the peak impacts (at or near the port) as one moves to recepto rs located about 140 to 200 km away from the port. As each ship moves further away from the port (out to sea), the peak impact also decreases rapidly. Figures 10 and 11 show the peak (maximum) modeled hourly S(h concentrations for each modeled source, normalized (divided) by the peak hourly concentration for the source located at the port, as a function of the distance from the port. 29 Maximum SO2 Concentrations 1.0 0.8 0 C u0 0.6 "C Q) .ce.!:a.::.! 0.4 z 0 0.2 -Narragansett - Sandy Hook Cape fl..1ay - Cape Henry - Cape Lookout - Cape Romain - Savannah - Jacksonville - Cape Canaveral 0.0 0 40 80 120 160 200 240 280 320 360 Distance from Port (km) Figure 10. Normalized Peak 1-hr SO2 Concentrations for Eastern Sources For the eastern modeled sources (Figure I0), the maximum impact (highesl one-hour average S02 concentration) for a source located 40 km from port (other than for Naragansell) is between 4 and 13 percent of the impact from the same source localed at the porl. AL 80 km away from the port, the concentration impact is predicted to be between about 2 to 5 percent of the impact from a s inu lar source located at the coastal port. At 120 km from the port, the impact drops to between I and 3 percent; at 160 km, the impact was less than 2 percent, and at 200 km from tJ1e port, the impacts were one percent (or less) of the impact from s imilar ships located at the ports.24 24 The h igher impm;l and the shape of the curve in Figure 10 for Naraganscll is easily explained. The coastline near Naraganseu curves directly eastw.ircJ so lhal sources located further out from this porl on the cast-west source line we re, in fact, fairly c lose 10 receptors located along the shore lines o f Rhode rs land anc.l Massachusells. That is why the impac t (at the coast) a long this source line out tu about 160 km is larger than for all o ther source lines. /\ similar feature exists for the Vancouver source in the western domain, which is localed in the Juan de Fuca S1rai1 and has coastal receptors loc.1Lcd lo the west of the port on Lhe Olympic Pcnnisula. The shape of the coastline and resullllnl proximity of the shore receptors also explains the s mall "spike" in concenlra1ion seen in the Naragunsctt curve in Fig ures IO and 12 ( later). 30 Maximum S02 Concentrations 1.0 0.8 0 C 0 0 "C 0.6 Cl) e.m!::! ... 0.4 z 0 0.2 -Vancouver - Portland Bay Area - Los Angeles -San Diego - Ensenada 0.0 0 40 80 120 160 200 240 280 320 360 Distance from Port (km) Figure 11. Normalized Peak 1-hr S02 Concentrations for Western Sources The maximum impacl (highest one-hour average S0 2concentration) for a western source located 40 km from port (other than Vancouver; see footnote 12 ) is predicted by the mode l to be between 2 and 6 percent of the impact from the same source located at the port (Figure 11). AL 80 km away from the port, the concentration impact is predicted to be less than 2 percent of the impact from a similar source located at the coastal port. At 120 km from the port, the impacts were one percent (or less) of the impacts from s imilar ships located at the western ports. The average of the lop ten peak hourly average concentration impacts (the ten nearby receptors that experienced the highest peak hourly average concentration impacts from each modeled source) were computed for each source along each source line. This "lop-ten" spatial average represents the overall concentration impact along a stretch of coastline extending approximately 40 lo 50 km both north and south of the port. These top-Len concentration averages are shown in Figures L2 and 13, normalized by the top-ten average concentration for the source located al the port (origin of the source line), as a fun ction of the distance from the port. 31 Average of Top T en S02 Concentrations 1.0 0.8 0 C u0 0.6 al !:! 'iij E... 0.4 z 0 0.2 0.0 - - 0 40 80 120 160 200 240 280 320 360 Distance from Port (km) Narragansett Sandy Hook Cape May Cape Henry Cape Lookout Cape Romain Savannah Jacksonville Cape Canaveral Figure 12. Normalized "Top Ten" I-hr SO2 Concentrations for Eastern Sources The CA LPUFF model results indicate that a source located 120 km from an eastern port (other than for Nairngansctt) w ill have an overall impact at the IO "highest" receptor locations that is between 2 and 7 percent of the concentration that would be contributed by a similar source located al Lhe port (Figure 12). For a source located 120 km from a western port (other thun Vancouver), the concentraLion impacts at the ten most highly-impacted receptors are predicted by the mode l to be less than 2 percent of the impacts of a s imilar source located at the port (Figure I3). 32 Averag e of Top Ten SO2 Concentrations 1.0 0.8 0 C 0 (.) 0.6 "O Q) ~m .E.. 0.4 z 0 0.2 - Vancouver - Portland I Bay Area , - Los Angeles 1\ I - SanOiego - Ensenada 1 0.0 0 40 80 120 160 200 240 280 320 360 Distance from Port (km) Figure 13. Normalized "Top Ten" 1-hr SO2 Concentrations fo r Western Sources The results of the modeling exercise described in this re port (SO2 concentration impacts at coastal receptors due to unit emission sources) can be superimposed onto typical shjpping travel patterns to estimate the expected impacts along the coastline from individual ships or shipping fleets. The results For all model tuns are available in MS EXCEL spreadsheets25, including the maximum one-hour SO2 concentrations and the 4111 highest hourly SO2 concentrations at every model receptor due to e missions from each modeled source for 200 I . Model results arc also available for additional sensiti vity model runs that were performed using sources on the Cape Henry source line (examining the effects of various vessel characteristics, and for the additional model years 2002 and 2003). 25 Computer files ussociah.:d with this project, including the results spreadsheets (transfer coefficients) arc available upon request. 33 V. EMTSSl ON CALCULATIONS A5 noted earlier, aJl of the modeled concentration'- were prcdic.:tccl as'iunting a "unit'. emission race of I kg/hr of SO? emissions from the ~hip. This is customary since predicled concentrations -;cale directly with ma~s emission rate. Table 2c1 hdow ~hOW!s the max.imum 1-hour conccntralicllls (i.e., over the 200 1-2003 model Lime period) a l ~uch port for each of the eastern domuin lines, ai-. a functio n of ship distance from thl! coast. The suggested revised ECA extent of 50 miles corresponds roughly lo the 80 km row in the table. For example, assumjng an emission rate of l kg/hr. the S0 1 concentration is 0.89 microgram~ per cubic meter at the port wh en the ship is at Nuragaru;eLt. When the ship moves Lo 40 km aw.iy from the port, the impact at the port of Naragansetl drops Lo 0.0509 micrClgrams pl.!r cubic meter un<l ~o OD. Ship Distance from Coast Sandy Cape Cape Ca[)\! Cap~ Cape (km) 0 40 80 Narraguus~l t"' Hook 0 . 89 3 0 1.0250 0.0509 0 .0 3 8 4 0.0 162 0.0165 May 0.7684 0.0738 0.0251 Henry 0.7 181 0 .0 4 8 2 0.0 151 Lookoul 0.5145 0 .0395 0.0090 Roma i n 1.0230 0 .0 48 2 0 . 0 15 9 s~vannah 0.5493 0.0536 0.01 50 Jacksonvi lle 0.8701 0.0499 0.01 57. Canaveral . 1.1 560 . 0.0 455 - -- 0.0 168 120 0 . 00 R4 0.0069 0.0156 0.0095 0.003Q 0.0094 0.0059 0.0090 0.0070 160 0 .0 03 7 0.0037 0.0134 0.0049 0.0031 0.0058 0.0045 0.0057 0.0053 200 0 .0 0 4 5 0.0063 0.0052 0.0038 0.0018 0.0036 0.0023 0.002 1 0.0034 240 0 .0 0 2 9 0.0030 0.0035 0.00 1l 0.00 16 0.0022 0.0020 0.001 6 0.0028 280 0.0015 0.0029 0.0022 0.0008 0.001 2 0.00 12 0.00 18 0.00 19 0.001 l 320 0.0021 0.0012 0.0005 0.0010 0.0008 0.00 12 0.0008 0.0009 360 0.0013 0.0011 0.0004 0.0006 0.0005 0.0007 0.0005 0.0007 -! As <.11scusscu t::u her in rhc 1cxt, the 1mpac1S shown arc 111 lhc port Sh2-h1ly higher 1rnpac1~ occur at other llmn ponlo~ntions given 1hc shupc ur rhc c11a~t- linc for Nnrngnnscll. 34 Table 2u. Summary of 1-hour maximum predictecl conccnfr~tion of SO2 (using an emission rate of l kg/hr) at each eastern domain port for various ship locations. Table 2b below shows simi lar model concentrations for the western domain. Distance from Coast (km) Bay Vancouver=~ Portland Area Los San Angeles Diego Ensanada 0 0.0358 0.8778 1.1380 3.6790 3.9400 3.4640 40 0.5903 0.039 1 0.0436 0.0481 0.0669 0.0299 30 0.0313 0.0l22 0.0121 0.0168 0.0156 0.0088 120 0.0123 0.0055 0.0054 0.0103 0.0077 0.0058 160 0.0055 0.0038 0.0040 0.0050 0.0050 0.0036 200 0.0034 0.0026 0.0025 0.0022 0.0035 0.0020 240 0.0028 0.0018 0.0023 0.0017 0.0028 0.0020 280 0.002 1 0.0009 0.0017 0.0023 O.00L7 320 0.00 19 0.0011 0.0013 0.0018 0.0017 360 0.0009 0.0013 0.0009 0.0012 0.0016 *As discussi.:d earlier in lhl lc.\t. Ju~ l\l the shape of the coastlini.: al Vancouver, maximum impacts can occur nl locations other limn the port. Data shown urc the maximum impacts. Tab)e 2b. Summary of I-hour maximum predicted concentration of S02 (using an emission rate of 1 kg/hr) at each western domain porl for various ship locations. As discussed, it is evident that, in general, as the ship moves farther i.\Way from the porl, the impacts at the port diminish rapidly. When Lhe ship is localed al port, the concenuations d iminish rnpidly along the coast as well. We also see from the Tables 2a and 2b, 1hat the maximum impacts can occur at some of the western domain porls, as compared to the eastern domain ports. keeping in mind the :;ame I kg/hr emission rate used in all of these calculations. However, it should be kept in mind, that of the modeled ships, the larger ships (and therefore those with the gre,11esl emissions) voyage along the ea'itern domain. 35 Rmher 1han conduct emission calculations for every instance. some example emission calcul.tlions arc offe red. Fir5L the 5tudy calculated lhc S0 2 emission rate expected from each \hip. Thi.s w<ts r1one using the same approach u<;ed by l11c U.S. EPA (EPA 2009).26 Assuming a brake-speci t"ic fuel cons1Jmption rate of 195 grams/kWh lor slow-sp1. ed diesel a\ m,ed l:>y EPA and consi!:tem with vessel -;peeds in this instance. and :i mall.imum fuel sulfur content of 2.6%. lhc SO:i c111ission factor i~ calculated to be: S0 1 E1ni~<;io11 r,1ctur (grams/kWh) -= (195)':'(64/.,2Y:,(0.97753)"'"10.Q26) = 9.9 1grams/kWh Using a r11el ~ulfur content of 1%, the S0 2 emission foe-tor, u:-:int, Lhe ::.am1. equation above, is 3.8 1 grams/kWh. Next. ~in<.:c ti.le maximum engine rate for each ship's main engine, (in kW) as shown in Appendix B is knuwn. it is straightforward to calculalc the maximum hourly SO2 emissions from ~ach ship as follows Max imum S02 Emission Rate (kgllu) = S02 Emission Factor (groms/kWh) :, Maximum Engine Ratin~ (kW)/1000 (grams/kg). Of the various s bips considered in tbis shorl-sca shipping impuC"I analysis, the largesl sh ip (in 1erms of rating) for the eastern domain has an l.'nginc sizt' of approxi mately l2000 kW. Tbui;, for a 12000 kW engine. Lhe maximum hourly SO2 emissions arc: S02 Emission Rate (@ 2.6% S in fuel) = 9.91 .,, l2000/ I000 = 120.ti kg/hr SO;, Emis,;inn R.-1te (@ I% S infuel) = .~.S l ,: 12000/1000 =46.41'g/hr. IL should be kept in mind that rhe S02 rares calculincd above- arc also conservative in the sense thal none of tht: engines operates at its rated maximum power. T yp1<.:aJ ly, the engine load is 75% of maximum power during cruise mode, diminishing to much lower le vels as the ship approaches port. At port, engine power may be a small fraction (20% lo 40%) of maximum power. Thus, 26 Sc-c cqunti1111 2-1 nn page 17 or U.S. EPA 2009. 16 aclual S02 emission rates would be 20% Lo 75% of the rates calculated above or in range of 24 kg/hr - 95 kg/hr for a I2000 kW ship with 2.6% S in fuel and in the range of 9 kg/hr - 35 kg/hr for this same 12000 kW shi p wilh J% S io fuel. Similarly, of the ships considered in the analysis, the biggest ship voyaging in the western domain is rated around 11500 kW. Using the same types of calculations above, the range of S02 emissions from a ship of this size will be 23 k.g/hr - 9 l kg/hr (maximum of 114 kg/hr) wilh 2.6 % S in fuel and in the range of 8.6 kg/hr - 34 kg/hr (maximum of 44 leg/hr) with l % S in fuel. Combining these expected maximum S02 emission rates with the modeled concentrations, we can determine the following: For the eastern domain, the highest modeled port concentration (Cape Canaveral) was l. 156 microgram/cubic meter per kg/hr. Further, when a ship is located at 80 km (or 50 mile) from any of the ports, the maximum predicted concentration at the closest coast is 0.025 micrograms/cubic meter per kg/hr at Cape May. Using the nighest expected S01 emission rate discl1ssed above of 120.6 kg/hr (for the biggest ship, at max_imum power, emitting at exactly the meteorological conditions that would provide lhe highest impact, and based in using a high S content of 2.6% in the fuel), the highest modeled port I-hour S02 c.:om:cntration would be 1.156'!: 120.6 = 139.4 micrograms/cubic meter. 01' course. with the other rates discussed above (i.e., al various loads. al l % S in fuel, etc.) the expected maximum I-hour S02 concentration would be much l9wer. Similarly, using the high~sl expected S02 emission rate of 120.6 kg/hr, lhc highest shore impact when the largest ship is located at 80 km or 50 miles from shore is 0.025".' 120.6 = 3 micrograms/cubic meter. Again, impacts would be much smaller using lower lo:1d factors anti lower S content in the fuel. For the western domain. tbe highest moclelecl port concentrnt1on (San rnego) was 3.94 micrograms/cubic meter per kg/hr. And, when u ship is located al the 80 km (or 50 mile) distance from any of the ports, the maximum predicted concentration al the closest coast is 0.03 37 micrograms/cubic meter per kg/hr near Vancouv~r. Jn this ioc;tanc:e, the pre:-ence of the largest ship, operating al full power with a S content of 2.6o/c localed al 50 miles from shore would result in a mc1ximum I -hour S02 concentration o f 0.0:F 114 = 3.42 micrograms/cubic meter. 38 VI. THR SULFUR DIOXIDE STANDARD U11der authority provided by the Clean Air Act, lhe U.S. EPA has promulgated various NAAQS27 and thereby defined acceptable levels ot' major air pollutants, including S02 in lhe ambient air to which the public has general access. The purpose of the NAAQS is to protect the public health, induding tJ1e health of "sensitive" populations such as asthmatics, children, and the e lderly. The S02 NAAQS was recently (June 20J O) modified to adLI u L-huur average standard o f 75 parts per billion (ppb). Th.is cotTesponds lo a concentration of 196 micrograms per cubic meter. It is c urrently the most s!Jingeot S{h standard in the U.S. Although the study wi ll compare the predicted results of the modeling described above with tJ1is numerical value (i.e., to 196 micrograms per cubic meter). a one-time exccedance of this value, by itself, docs not constitute an excecdance of the stanJard. Rather. the form of the I-hour S02 NAAQS requires that the 99th percentile of the I-hour daily maximum concentrations averaged over 3 years be below this numerical value. 21 Sec h11p://www.cpa.gov/air/cri1cria.html. 39 V U. CONCLUSIONS Comparing the maximum predicted model I-hour SO~ concenlraLions as dic;cussed above witb even lhe numerical val ue of lhe l-hour S02 NAAQS (i.e.. clisregurding the fonn of the standard U1al requires IJ1c 9Y1h percentile of duily ! - hour maximums averaged over 3 years). we see lhal even und~r lhe worst case (with clear conservativenes~ relating LO engine Joad. meteorological conditions. max.irnum S content in fuel, l'tc.) for the e::tSll'rn domain. lhe predicted concentration ,-,f 139.'I microg rams pe r cubii.: meter is much lower lhnn lhc 196 n,icrograms per c ubic meter in lht: standard. A lthough sti ll conservativ~ (with regard lo engine load, S-conrent etc.), the comparison of the highc,;t ~hore I-hour cnncentrat ions - whether for the eastern (3 microgram.., per cubic meter) or the wc.<-tern domain (3A2 micrograms per cubic meter), with the standard ( 196 micrograms per t:ubic ml!lcn shows how insignificanr the impat:t of these c;hort-sea ship<; is on shoreconcentrations. Based on the above analysis. we conclude 1bal the ECA boundary should be reduced lo al least 50 mile-; frum lhe coasts (or to even smaller distani:-ec:. which would differ on each c0asr), without causing any adverse impacts of SO:: \!missions on tile land. 40 VIIl. REFERENCES Dudhia, J., D. G ill, K. Manning, A. Borgeois, W. Wang, and C. Bruyere. 200 3. PSU/NCAR l'vlesoscale Modeling System Tutorial Class Notes and User's Guide: MMS Modeling System Version 3. Mesoseale and Microscale Meteorology Division, Na1ional Center for Atmospheric Research, Boulder. CO. Sahu. R. 20 I Ia. Personal communicalioo. CALMMS output riles; national dataset for 200J - 2003 transmitted on computer hard drive (31 May 20I I ). Sahu, R. 2011 b. Personal communication. Provided ( via email) vessel stack data (spreadsheet) (2 1 Nov 2011). Scire, J .S., D.G. Stsimaitis, and R.J. Yamarlino, 2000a. A User's Guide for U1e CALPUFF Dispe rsion Model (Version 5). Earth Tech, Inc., Concord. MA. http://src.com/calpuff/download/CALPUFF_UsersGuicle.pdf Scire, J.S., F.R. Robe, M.E. Femau, and R.J. Yamartino. 2000\J. A User's Guide for the CALMET Meteorological Model (Version 5). Earth Tech, Inc., Concord, MA. http://src.com/culpu fl'/download/CALMET_ UsersGuide.pd f U.S. Geological Survey. 1997. Global 30 Arc-Scccmd Elevation Data Set (GTOPO30). Earth Resources Observation and Science (EROS) Data Cenler, Sioux Fall. SD. http://eros.usgs.gov/Find_Data/Products_and_ Data_Availab1e/GTOP030 U.S. Gcologic;al Survey. 1999. The North America Lanu Cover Charac.:teristics Data Base (Version 2.0). Earlh Resources Observation and Science (EROS) Data Center, Sioux Falls, SO. http://eclc2.usgs.gov/glcc/na_ im.php U.S. Environmental ProtecLion Age ncy. 2003. Revision to the Guideline on Air Quulity Models: Adoption of a Preferred Long Range Tninsporl Model and Other Revisions. Federal Register, 68: 18439- 18482 ( 15 April 2003). 4J U.S. Environmental Protection Agency. 2009. Proposal lo Designate an Emission Control Area for Nitrogen Oxides. Sulfur Oxides and Particulate Matter. Technical Support Document. Assessment and Standards Division. Office of Transportalion and Air Quality. E PA-420-R-09007. (April 2009). 42 APPENDIX A - RESUMES H/\N/\,IJT (HON) SAIIIJ, l'h. P, QJi:P, CC:M 1Ncv11!1a) f .01'\/Slll;J ,\ N r, CN\/lll()NMEl\i'l',\I. ,\,'W Et-1 1:1;v l"iM11'S 3 1l Nori h Sr11q l' lacc l\lh;1111hrn, CA 1Jl ll01 Phom:: 626 -3!12-U00 I l"-mnil (preferred): snl111ro11@c:ir lh li11l,.11cl f.,-.; 1Eftlt::N<:r Sll~.lfil!U'. Dr Sahu 1111~ 1>wr rwc111y one yc,-irs or cxptric.'ncc in the l'h:kls 111' rnvircm111t111al. 11wchamcnl, a11d chc111ili:I cngi11C\"l'i11g indudin~.: prvgrom ,111d projcll mnn;i~cmcnl scrviLc!i; dc~i~n 1111d spccilitulion of p1,11,,,,.:,:1 Ll'llll 111 cqu1p11wnt: soil, nml gn111mlwatc1 rc1111uiation: co1111J11,ti1111 l'J1g1111tri11g cvnlu.11,on,; cncrg_y slucli,.".; 111111ti1111'1fi,1 cnviH11111wnt,1I 1c~ul111ory 1,.u111pli:111cc (involvint ~,:11111<s ,111d regululi->ns such a, lhc h:d,r,11 L'A,\ n11d lb l\f11l'IHh111!11t~. ('11,111 Waler /\ct. rsc/\. IU. Ill\, Cl :RCI.,\. S/\1{/\, 0::::111\. ~WPA ~ wl'II ,1:; v::riou~ rdot;;-cl stale st,11111,:1); t11111~11or111tio11 Jir quality impm:1 :1nalysb; muh1n10.:din 1,.0111pliunc<.: .1uui1,:, 11whinctlia pl'n11i11111g {i111:h1drr1i; r,il' q11.ilily N~IUf~I) p.:rtnit1i11g. 1illc V pennitti11g, NPDES pcnnil!i11g for i11du~1t 111I nml .~lorrn w,Hl'f tli~chnrp.e!-, RCR/\ perm1ui113, cic.J. 11111lti111c<lm/muhi pathway human hcuhh risk nssessments for lo.-.ic~: air displ'rsion 111olleli11g; and rcg11lntC'ry strntl!gy or cfcvclopmcnt nnd sup1,nn including ncgoiintion co11sc111ngrccmcnts nnu orders. He has ,,ver 11i11ctcc11 years o r projcc1 rn:tnagcn,cnt c.xperil!ncc ancl has s11ccusc;fully managed and l'Xcc111cu 11umcro11s projcc:ts in this lime pcrior.J. J'his includes l,nsk ancl applicd rc~cnrch projects, dc~ign projcc1s, rcg,ulaiory rn111plia11cc pr~iccls, p,:r111i11i11g, projccls, c11crgy s1udic~. risk :1sscs~111c11t pr~i::cts, uml l'r~1cc1~ i11vulvin1t lhl' l'n11111111nic::11ion o l'cnvironn1l.'nt:1I data 0111.I infornrnti,rn to the p11hlk. Notably, h1' hns ;11.:n~~1111ty 111.111,1!!,d ;1 111111pkx suils ;111d !!r,1111111',all'f rc111nlia1iu11 pr,,jccl wnh II value ul' uvcr :-;1JO nillio11 i11vu1vi11~ ~1111,; d1ar.i111:ri.,;ati1n, dcvdopml' ll uw l 1111rlc-111.:11111il'11 11 1h, rc1111:di.11iun s1r..111:g,y. 1,:g11la1ur~' and pul.Jlic i1111ra1.:1io11~ and oilier 1hallrn~c:.,. Ile has 11111\idcd 1:on,ullin1> scrv1l~s h1 n11mcru11s private sector, rrnlil11: ,cct111 and public 1111crcst gn111p ..:l,cnt,;, IIi~ 11111jor i.:lirn1s ovtr the p11~1 ~Cvln1cc11 >'1:;1r; int:ludc v11rio11s ~lccl 111ills, pc1rolc11111 rdincrics, <'l!lllC:111 C\>1Hpa11ic$, aerospnce companies. pnw.:r gcncnllion fncilitics. lawn und gardon cquipmrnl manuti1i.:l1irl.'I'$, :;p;i munulhcturc:rs, chcntirnl distribution fnci lili('s, nml v11rio11s c111i1ics in tlw p11hli~ Sllclor i11clucli11g EPA, the US ncpt. ur Justice, Cnlifornio nrsc. vnrious 1111111icipulilics, etc.). Or. Snhu lms pcrli>1111ecl p1ujrcts in l)Vcr 411stntcs. n11mcro11s loc11l j11ri:.dictions 1111d lntcrnationnlly I >r. Sahu~ cxprricncc 111cl11ucs variou~ projcc1s 111 rdation tn indus1rial wa~tc waler n~ well as storm w:1tcr pollu1io11 compl iance i11cl1clt ol>tni11i11~ .1pprup1i;,1,: permit; (such :1s point ,0111r.i: NPt>ES pcn11its) us wcII dndop11wnt ,1r pl::11~. 11s~c$Sin~nt ol rrnwiiiatil'J11 1rd111ologic:s. ul:'vdop1m:11l or 11wnitoring rcpons. :111.I n:i;11!;1111ry illll'l':IClllllb. 111 a,ldi1i1111 tu ro11st1h111~. Dr. S:1hu has t:1ught nnd tontinm~ lO tcall 11111111:n,1~ course~ i11 several ~uu11lcn1 Lnli liirnia 1111i1 l'l"Silk~ i11d111ling lJClt\ {t111 1wll111io11), UC' l{ivcP,1d\l (air 110lhniun, process h,1z:ird a1wly,is). and t.oyuln Mnry1n11u11t l.l11lv~r~il)' {riir pollution, risk usws~n1i:111. haz:11do11~ wu~le 111:u1ai,:c111c111) lbr llit p:1~1 ,cvcnlccn years. l11 lhis lillll' l'Criud he ha, al,o 1n11gh1 al ( ':1hcch. his 11l111a mnlCr m,cl :ii US<.' (air pol1111i1111) 1111d Cal Stnt<: f-11 llcrfc,11 (lrnnspnrtnlion and uir quality). l)r. Sahu h,1~ an<I continue, 10 provillc .:11pcrt wi111cs~ services In a 11111f\lJ1r or rnvil'l)mncntul nrcu,,li,cussl!d nho\'l' i11 both s1ntr :111<1 Federal cc,11r1~ us well n~ l)(!fon nd111ini~m11ivc llldic~ (pl<:aso ~c, A1111cx A/. E.'O'l'.IOJ'.NC."E Hl:c.:nrw 2000-prcsc111 ln<lcpl'rHlcnt Con~11l1i1111. Providing II vuricty or pnvutc scc1or (111cJ11stri11l companies, kmd development companies, low lirms, etc.) p\lblic sector (such ns 1hc US Deportment or Juslicc) and public inlcrosl group clients wilh project nrnnngcmcnt, nir cpmlily consulting, waste remediation nnd management consulting, as well us regulatory 11ml cngi11ecri11g supporl consulting services. 11)95-2000 Pnrsons ES, /\ssocialc, Scuinr Project Ma nagcl' anti Dcpnl'lmc ut Mn nugc r for Air Qunlity/Gcoscicnccs/fla;,;nrdous Woste Grol1ps, Pasudcnn. Responsible for the management of a group of' npproximately 24 nir q,mfity nml cnvironme111ul profossionuls, 15 gcosl.'ic11ce, and IO hmmrdous wnslc pror1:ssicmal~ providing rull-scrvicc cons111li11g, pmjcc1 management, regulatory co111pli.111cc aml 1\/li dcsi!!,n assist,mcc in :ill r1rcas. l'an;uns ES, Man;iger ror Air Sonrcc Tc.sling Sl'rvh.'l'S. l{csponsil>lc lor the 111anagcmc111 of8 imlividuals in the area ol',lir source tcstint,: and nir n.;gulatory pcrmiuing prujccls located in Uakcrslicld, California. 1992-1995 l.:nginccring-Scil:ncc, Inc. Principal Engineer mul Senior Project Mnnngcr in the nir q11.1lity dcpurlmcnt. Hcsponsil.Jililics i11cl11dcd multimedia rcgul:1tory compfiam:c and permitting {including Jm;,.11rdous nnd nucfcnr nrntcrinls), .iir pollution engineering (emissions from s1111io11.uy uml mobile sources, control or critcriu and air toxics, dispersion mmlt:ling, risk ilsscs~mcnl, visibility uoalysis, odor mialysis), supervisory limctions and p1ojccl mnnngcmcnt. 1990-199~ lingincc:ring-Scicnce, Inc. l'rincipnl f.ngincl'r nnd l'roJcct M:111agcr in the nir qunlity dcp.1r1111c111. Rcspon!iibi)itics included pcr111iui11g, lmcking rcgulntnry issues, tcchnienl analysis, and supervisory functions on numerous nir, Wi1lcr, nnd huznrdous wustc projcl:ts. Rcspo11sibili1ies als::i include clicnl and ugcncy interfacing, project cost and schedule rnntrol, and report in!!, to intcrnnl nntl cxtcrnnl uppcr mu1mgl~mcnt regarding project stntus. 1989- I990 Kinetics Tcdrnology International, Corp. Dcvcdup mcnl Engineer. Involved in thermal engineering R&D ancl project work related to low-NOx ci:rmnic rndim11 burners, fired hcntl'r NOx rcd11c1ion, SCR design, und fired heater rc1rolit1ing. 1988- 1989 Heal Transfer Research, Inc. Research E11gi11clT. Involved in the design of fired heaters. hcnl cxchnngcrs, air coolers, and other 11011-lircd cquipment. Also did r.::scarch in the area ofhcnt cxclrnngcr tube vilmllions. 1':l>l!l ',\TlOI\" 19tM-1 988 19~;1 1978- l983 Ph.D., Mcrhanical Enginlcring, Cnlitbrnin l11stitutc ol'Tcchnology (t'nltcd1), Pnsadcna, CA. M. S., Mcchrmicril Engineering, C'nltech, P11s11don:t, CA. B. Tech (Honors), Mcchanicul Engincl,ring, Indian ln~tiwtc ol"Tcchmilugy (ll'l') Kharagpur, lndin Cahcch "Thennmlynami1.,s." Tcathing /\ssistm1l. C:nlilorniu Institute ufT1.1.:hnolugy, 1983, 19lH "Air Poll11tiu11 Control,'' Te.iching l\ssista11l. Californiu lnslillttc ;>l'Tcchnology, 1985, "C,1lt1.:t:h Sc:i:ondary and I ligh St:houl Saturdc1y Program," - laugh! various 111utl11:111:11ics (nlg1.h111 through cuh:ulus) 11nd sdcnce (physics nnd chemistry) courses to high si:hool s tudcnls, 1983-1989. "Ilent Tra11slc1." 1:1ug,l11 this cmmc in 1hc lall a11d Wi111u lcnns 111 I1l91- I1J1Vi in the L>ivislon or l:ngi11cni11g ;111tl ,\pplicd Science. ..l'h1:r111t'ldy11:1mics nntl I!cat Trnnsfer," Fall ancl \Vi111cr Tenn:: of 19%-1997. Ll.C. l(ivcrsidc, Extension 1 ol.:ic u1HI lla:t.urduus Air Contaminants." University or C.iliforni;i Ex1c11siv11 Progr,1111. Ri \rt-sick. C,tlili>rnin. Vnnous ycnrs since 1992. "l1rcycn1,on <111cl l\'l:111agcmc11111r l\cc i<lcnlnl l\ir l:mi~s i<1ns," Univcrsity ot'Calili1rnia Extc11si11n l'rogn1111, Hivcrsidc-, Cillifurni.i. V;iriou~ ycm-s s i111:c 1992 "/\ir 1'11ll11ti111 Conti ol Systems and Strnll.:gic~... l.lnivc1~11y of Califo1 ,,,u I:xtc11sion l'ru~ram. Riw,~idc, C.1ll fo1111a, i:;,11nnw, I1N2 -IJJ. ';;11111111~, 199.l- I'JIJ<l. ":\ ir l'ulluti\\11 C;dn,lati11n~," Univcrsily 111' C.tlilhrui.1 1:.x1c11~io11 I'1 ug,r,1111. Hivc1 ~,de. ( nli lornia. Pall l 'J1)J .<).I, Wimer 1993-<>:I. F:ill l 'J9<1-95. ''l' rucc~~ Salcty M:ll1agc111cnt,'' Univi:rsity olT,1lifo1 11ir1 i,,x1c11,ion l'rugrnm. l(ivcr:;ick. C:1lif0rnh1. VuriNtSycnrs since 1992-'.:!(l I0 "Proc1!s~ Safo1y M:11H1gc111cnt,'' Ilnivcrsi1y ol'Cnlilornia Ex1cnsio11 Progmm. lli\c1sidc, ('[llili>niia, 111 SCI\QM11. ~pring 1993-94. "Adv,11cc1I Ilaz:ird l\n.1lysis - A Spcci,,I Conr~t li.1r Ll~PCs," Unhcrsily ol'Culilo111in Exl-.?nsior, Pr(1grnm, ll ,v.:1'!-idc, C'ulifornin, tunght 01 Sun Dic~o. Calilbrui:1, Spring I993- I()(),1. "/\dv:mccd l la;,.;1rtlP11s Waste Mam1gemcnl" Uuiv.:rsily ufCalifomiu l.:x1c11sio11 l'n1gram, Rivc13ick, Californin. 2005. Loyola ,'vlary1111111111 U1;iwrsitv "1'1111d:in11.:111:ds 1>1' Air Pollution - Rcgul,llions, C:omrols 11nd F11gi11c1ri11~," Loyola Mary111uun l Univ~r,ity. Dept. of Civil Engineering. Vnrious years sl111:c 1993. "1\ir PPlhlion Cunirol,'' Loyola Murymuunl IlrtiVl'rsity. l)cpl. orCivil E11gi11ccri11g, Fall 1994. ''Enviromucnlal H,sl, As~cssmcnt," Loyola M,nymou11t Univcrsi1.y, ncpl. ,,1c;\'il Engineering, Varions years since 1998. Jla/.urdous Wnsh lkmcdiation" l.oyola Mnry11101ml University, Dcpl. n l Civil Enginrcring. 'v urions _Yl!"dl'!; ~i11cc 2(10(1. lJ111wrsit.)'. uf Southern Cnliflrniu "/Iir l'1ll111io11 ('0111rnl:1," Un,vcrsil)' or Snuthrn, California, Dcpl ulT ivil b1ginlc1 ing, hill I993, Pall 111,1 I "/\1r l '11ll111i11i l-t1mlan1111u1h," Uniwrsil)' ol S011th<:rn Cnlilu1111a l>cpl. o l'( ivil l.nginl'c rini;. Winh:r I' Jl), I IJ11ivcrsi1~ 1f' California, Los /\Q.WC:> "i\ir Poll111io11 Fund;11ncn1als: University off'nliforniu, l.os Angele~, l>,,;pt. ul'C'ivil anti Enviwnml!ntnl Enl,\it1ccring, Spring 1994. Sprin~ 1999. Spri11!_! :WlJU. ~prnu_: 'LUUJ. ~piing 2UllC, Spring 2Ull7. Spring 200s, Spring 2009. l..l)l<;ffi!1tip_m1I l'rnu,rams "l~nviront11l111:il l'lttnning and tvi:iragcmcnt,'" 5 w~e~ procn1111 for visitill!:', Chinese dclcga1io11, J9Q,J. 1w{iro1111!..'11\al 1'h11111i11g ,111d Ma11ng\'.lnc: nt," I duy pr1.1grn111 liir vi~ilin':!, l<u~~i:1111klcga1io11. 199~. "J\i1 l'11llvti1111 l'lanning. aud Ma1rn3c111cn1." 11-'P. LICH, 'i1mng l1JW, "Envir11111111:nt:il Issues and t\ir Pollution," lEP, UC'R, October 1996. P UOFESSION1\ I. AFFll.l,\T lONS ANI> IIONOltS l'rcsidcut or India Gold Medal, IIT l<hnmgpur, lmliii, I !/HJ. Member or1hc Ahcnm1ivcs Assessment rommillcc of the Grnnil Cnnyun Visihility Tmnspor1 Ccmmi:;sion, cs1nbl1shc<I hy 1hc Clean Ait J\c1 Amendments of' I 91)0, 19?2-prc~~nl. ,\111cricn11 Such.:1y ur Mechanical l~nginccrs: Los Anr.clcs Section E-.ccutivc Cummillcc, I lent Tronsfcr Divi~illn, 1111<.I Fuels illld Co111l>ustiu11 TcchnolC1gy l)ivision, 1987-pn;scnl. AIr nntl Wnstc Marmgcmcnt Association, West Coast Section, 1989-prr.scm. P HOl'ESSIONJ\ I. Cl-:ltT ll'IC '.1\TIONS EIT, California(// XE088J05), 1993, J{l.:A I, Cnliforni:1(/107438), 2000. Cc11ilicd Jlcrmilling Professional, South C'o:1st AQMD (/IC8320), sinr.c 1993. ()El'. lnslilntc or Pn,fc~sio11.1l E11viron111cnlt1l Pm1.:ticc, ~inn :WOO, C:l.ivl, Stale ol'l-lc\'ada (//EM- I699). Expir;11io11 I0/07/2111 1. l' t >III.IC,\TIONS ( P,\ltTI.\ I. LIST) "Physical l'm1><:rtics mid Oxidation Rates of Churs from Bit11111inous Conls." with Y.A. L.}vcndis, JU;, Fl.1g:m 1111d G.IC Gavnln~. Fuel, 67, 275-283 ( 1988), "Char Cumlrnstion: M<::isun:mcnt :iud 1\11.ilysis ur Particle Temperature Histories," with R.C. Flagan, G.R Gavalns ;111d l'.S. Northrop, Cumb. Sci. 7i:d1. 60, 215-2'.\0 ( 1988). "011 the Co111bustiv11 ur Bituminous Coal Clmrs," PhD Thesis, Culi lbmla lu~titutc ur Technology ( 1988). "Op:ic:il l'yromctry: /\ l1owcrr111 Tool for Conl Coml>ustion l>ing11us1il:s," .I. Coal Q1101i1y, 8, 17-22 ( 11)89), "Posl-lg11iti1111 Trilnsic111s in the Comlmstion of Singll Char l'nrliclcs,'' wilh Y .1\ . Lcvc11dis, ll.C.Flngnn 1111!1 Ci.It G:walns, F11d, 68, 841>-!!55 ( 1989). "A Mudcl for Single Pnrticlc Combustion or llil111ni11011s Cunl Char." Proc. 1\SME Nntionnl llcnt Trauslcr Co11fcrc11cc, l'hil:1dclphi.i. HTD-Vol, 106, 505-5 13 ( 1989). "l>iscrch: Si11111l111io11 ur Ccnosphcrir Cool-Char Co111h11stio11," wilh ll.C. Fl11gn11 nnd G.R.Gnvnlas. cm11i111.r1. r:t,1111,. 77. 337-3'-16 ( 1989). ''l):irticlc IVkasur..:ml'nts in Coal Coml>ustion," with R.C. flaga11, in "Comh11stlo11 I\-Jcns11rc111cnts" (ed. N. Chi!_\icr). llcmisphcn: P11l>lishi11g C'urp. ( I IJ1J I). 'Truss l.i11l,i11g in l'or.: :-itruc1urcs ilnd Its Effect 011 Rcm:livil>," with <.i.lt Oavala:. in prcpnfiltion. "N,11111~,1 Frcq111:11rn:i. uuil Mode Shapcs or S1might rubes," l'ropric1.11y Rcptlrl for Ile.it Trnnsfcr l{rsc:irrh lns1h11tc, i\lhambrn, CA { ICJ90). "Upl in111I Tube Luyouts for Kamui SI.-Scrics Exchangers," with K. Ishihara, Pruprh:tary Report for Kamui C.:omp,111y Limited, Tokyo, Jnpm1 (1990). "Irm1 l'roci:~s Hi:ah\r Conceptual Oc$ign," Proprictnry lt crun for Ih:at Trnnslcr llcscurch lns1i1u1c, /\lh~mhrn, CA ( 1990). ' 11\s)'111ptolil: l'hcory or l'rnnsunic Wind Tunnel Wall lntc,-rerc11ce." wilh NJ>. Malmulh und 011lcrs, /\rnoltl Engineering lJ..:-vclopmcnl Center, Air lon:e Syskm~ Commnml . IJS/\f' ( 1990). ''(ins Radiation in a Fil'ccl I lcnter ('011vcc1io11Section," Propriclilry Report lbr 1-lcut Trunsfc:r Research lns1i1u1~, College Sln1iu11, TX ( 1990). "I lcal Trnnsfor nnd rrcssmc Dmp in N'I IW llc<1l Exch,111tcr-;,' Prupriewry Rcpor1 li11 IIC'ot Trnn~lcr Research lns1i1u1c, CollegcSu11ion, l'X il!J9 I). ''NOx Control nnll l'hcn nal Design," Thcnnnl E11gi11ccring Tct:11 Briel~. ( 199.<l). From 1'11chasc of Landmark :nvironmcntal lnsu1~111C(.' to Rcmcdhniun: Casr Scud)' in lfondcrsnn, Ncv,ula,'' with Ruh i11 r. 13ain und Jill Quillin. prcsc11lc<l at the A()MA A111111al Mcclin, Florida. 2001. ..., he Jun,s /\rt Contribution to <llohal Wanning, Acid Rain anti J'oxic l\ir Cu111runinn111s," with Ch.irks W. 13ohliud. pr<";Cnll:il at :he t\(JM/\ Annual Mcc1i11g, Florida, 2001 l'IIESENT,\TIUN-; ( l'AU l"IAL I.ISi') ''Pore !-1t11c,1urc :ind Coml>nsrion Kinetics . lntcrprc1atio11 or !:iinglc Particle Temperature-Time Histories,'' with P.S. Nmthm p, R.C. Flag.in und G.R. Gavala~, prcsc111c<l 111 llw AIC'hE /\111111111 Mecling. Ne,,~ York ( 1987). ''Mc11su1r111c111 11f rrrnpcrolur,-Timc 1-listoric~ ol Burning Singll Cmtl Char l'nrriclc~," wilh ICC. r-1:igmi, prcscnrctl nl lh" American Fl11mc Research Cotnmiucc Foll l111crnt11ional Symposium, Piltsburgh, ( 1988). or "l'hysical Characll'rizntion :i C'enospheric Coal Ch:ir Ournctl nl l ligh l'c111pcr:11urcs." wilh l~.C. ur f' lngan and G .R. Ciav,ilas, presented al lhe Fall lvlccting the Wcstc'rn S1atcs Secrion of the Comlmstw11 l11s1i1111t, Laguna Bl'ach. Cnlilomia ( 1988). "Control ol' Nllrogcn 0.-.i<lr E111issio11s in fios Firc:<I l lcu1cr~ . l'h< Hc1ron1 h:pcric11cc," with G. l'. or Crocl' 11ml IC PakI, prc,scnl<'d at the l111cmatio11al Confcrcn,~ on 1"'.11viwn111cn1al Conlrol Co1nhustio11 l'rm:csst:s (J11in1ly ~ponsorcd by the Aml!ricun l'la111c Re~ci\rch ('ommiHN' ,111d the .lr1pa11 Fl:1111\' Rcsi:arch Clm111i11cc), llonC'lul11, Ilow.iii ( I9!J I). "/\ir Tl1xic~ Pust, Present nml l11c r-utun:," pr..-sentccl ul lhc Joint AIChE/AAEI~ 13rcnkfnst Meeti ng ul the t\ IChE 1991 A111111nl Meeting, Los Angeles, Calil'ornia, Novembor 17-22 t IlJlJ I). "Air T\1xk~ L.=111i$~ions mul Hisk l111p1wls fron A111ti1111.1biks Using Rcformulntt'.d U.isolincs,'' prCSl'nlcd nt 1hc Third /\nn1111l Current Issues in Air Toxics Conference, Sncrnn,cmo, C.1lifbrnia, November 9- I0 ( 19'.l:!) "/\ir Tnx ics rrom Mobile So11rcis,'' presented nt th.: Environn:cnl,11 llcnllh Scicn..:cs (ESE) Seminar Series, IJCLI\, Los 1\11gclcs, Cnlifornin, November 12, ( 1992). "Ki h1s. Own~. nn<l D11ers Prcsem and r u111re.11 presented nt the Gas Conqmny i\ir Q1mli1y Permit Assis1a11cc Sc111innr, Industry IJill~ Shcr111011, C'ulilbmiu. November :20. ~ 1992). ''Tiu: Design 111lll lmplcnwnrnlion ol' v~,hi<.:lc Scn1ppi11g l'rognnn~," prc~cmcd nt the !!6th Anmml Mcctlng of11te Air :md Wnsll' Mnnagc111c111 Associntion. Dcnvc.r, Colorado, .lune 12, 199.l. ''Air Q11uli1y Planning ,mcl Control in Beijing, China," prcscnlc<l al the 87111 J\nnual Meeting oflhc /\ir ;1n<l Waste /Vlanagcmcnl Assm:inlion, Cincinnali, Ohio, June 19-24, 19(),t. A1mcx A Expcrl Litigation Support I. Mailers lor which Dr. Suhu has have provided depositions und aflidavits/expcrl reports inclutk:: (a) IJcpusilil)ll on behalf of Rocky Mountain Sled Mills, Inc. located in Pueblo, Colorado - dealing with the manufacture of steel in mini-mills im:hu.Jing methods of air pollution control nml BJ\CT in slccl mini-mills and opacity issues nt this steel mini-mill (b) Affidavit for Rocky Mountain Steel Mills, Inc. located in Pueblo Colorado - dealing with the technical uncertainties associated with night-lime opacity measurements in geuernl nnd nt this steel mini-mill. (c) Expcrl reports nnd deposi lions (2/28/2002 and 3/l /2002; 1212/2003 and 12/3/2003; or S/24/2004) on bchnlf of' the US Dcpnrtmc111 Justice in connection with 1hc Ohio I:dison NS R Cuscs. Unit<.'cl St(t/es, er al. v. Ohio F:disu11 C'o.. et al,, C2-99- I I8 1 (S.D. Ohio). (d) Expert reports and depositions (5/23/2002 and 5/24/2002) on behalf' of the US l)eparlmcnt orJustice in connection with the 111inois Power N!:i R Cusc. United St{l(es 11. 11/inois Power Co., el al., 99-833-MJR (S.D. lll.), (e) Expert reports und depositions (11/25/2002 and I1/26/2002) on behalf or lhe US Dcparlmcnl or Justice in connection with the Duke Power NSR Cnsc, U11iled St(t/es, et al. v. D11k.e Energy Corp., I:00-CV-1262 (M.D.N.C.). (I) Expert n:pmts and depositions (I 0/6/2004 nnd I 0/7/2004; 7/10/2006) on bclrnlf'oJ' the US Department of Justice in connection with the 1\mcricm1 Electric Power NSR Casl.'s. U11ilt!cl Swtes. l!l al. ~- .'l1111!rican Hlec/ri<: l'owf!r Senh"<' Corp. , et ul.. C2-99I I82, C'l-99-1250 (S.D. Ohio). (g) /\lfalnvil (Murch 2005) on bdrnlr ol' lite Minnesota Center for Environmcn1al /\clvocacy nnd others in the mplter or the Applic<1tion ol' Ileron Lnkc BioEncrgy LLC to constrm;t nnd upt:rnte an ethanol production foeility - submillcd to the Minnesota Pol lution Control Agency. or (h) Expert reports nncl depositions ( 10/3 1/2005 and I l/l/2005) 011 behalf the US Dcpurtmcnt of Justice in conncclion with the Enst Kentucky Power Coopernlive NSR Case. United States v. East Kentucky l'oll'er Cooperative, Inc., 5:04-ev-00034-KSF (E.D. KY). (i} D1:iposition ( I0/20/2005) on behalf of the US Department of' Justice in conncctirn1 with 1hc Cinergy NSR Cnse. UJ1i!ed Stales, cl c1I. v. Cinergy Corp., et al., IP 99- I693- C-lvl/S (S.D. Incl.), U) Affidavits llnd deposition on behalf of' Basic Mnnagemcnl Inc. (!31\111) Companies in connection with the 13MJ vs, USA remediation cosl recovery Cose. (k) Expert rcpo1 t on bdwtr of Penn ruturc and olhcr; in the C:in1b1 ia Coke plant permit c halkngt in i>l'nn:;ylvunia. 1t) b q ,1.11 report 011 bch:llr of the t\ppal:1chiun ( i:1,tcr li'.r lhi: I.CQlh.>my am.I the Envi ronmi:111 1111d olhcrs in t!ic Wcsli:rn Urccnbri<.r permit challenge in We~I Virgini,1. (111) Expert report, deposition (via telephone on .lanuruy 2(11 2007) 011 bd1c1lr of various Monlnna pl.'litimwrs (Citi'.ccns Awareness Nclwork (C'/\N), W0ancn's Voices for the Emth (W VF) and the Clark Fork Coalitio n (CFC)) in the 11io111pson River Cogc11cr:i1 ion I.LC Perm it No. J 175-04 challenge. (n) E:--pt'rl n:1Mt ,md dcpo5ition (2/2/07) on behal f' or the l\:xus C'lcun Air Citic~ Coalition nt th1. Tcxus State Onicc of /\clministrntivc Ik,1ri11~~ ($O/\H) in the mailer or Ille permit challenges lo TXU Pn,jccl 1\pnllo'._ eight 111.:w pr11p11,cd PR B-lircd PC botln!-. l11l'akd ot :.even IX sites. (u) 1:~pcrl 11:~1i111q11,1 <July 2007) on beh,ill" of the 11.nak Walto11 f.t;11:!11c or America nnd otlw1:-. in wn111.Tlic.111 \.Vith the 11cquisiti<111 or power by X1:d 1:nc-rgy fi11m the prC>poscd or Gns1:C1> nc Power Plant - at the St.lie of Minnc~olu, Ollicc Adminbtrativc Ilcarings for lh\': M inn1:suta PUC (l\l l'UC No. EtJ02/CN-06- 151~; 01\11 Nu. 12-2500-17857-2). (p) Allidnvit (.luly 2007) Comments on the nig C~jun 1 Dron Permit on behalf of the Siena Club - s11bmit1cd to the Louisi,rna D IJQ. {q) Expert repon~ ancl deposition (1 2/11/2007) on behatr oJ' C'ommunwcahh uf Pl!1msylv:mia - l)ept. o f Environmentnl Protection, Stnlt' of Conrn.:cl icut, State of or Nrn YNk, and State New Jersey (Plaintiffs) in con1m:1iu11 \\ith the t\lkgheny 1~11\!rgy NSR l'asc. l'luimij)., 1. Allc:p,lumy H11c:t,1!J' Ille.. ,., 1il, 2:05cv0885 (W.D. Pennsylvanii.1). (r) E:s.p~rt r~purls and pre-filed lestimony before the Utah Ai r Quality 130:ird on behalf of ~icrrn Club in the Sevier Power Plaut pt:rmil chnllcngc. (s) Expert rcrorts and deposition (October 2007) on bl'hall" of MTO Products Inc.. in c onncc1io11 with Gem:rul Power Products. I.LC " M 1'D Proclucls Im:., I:06 CVA 0143 (~.J) . Ohio, Western Division) (l) Exp~rts report and deposition (June 2008) on b1~hul r of Sii!rrn Club and othcrs in the 111:111cr t)fpcrrnil challenges (fillc V: 28.080 1-29 und PSD: 28.0803-PSD) (or the Hig S!\)nc 11 unit. proposed to be lorntcd ncnr Mi lhn11k, South n.ilrntu. \111 1:-pcrl n:ports. ;iflicbvit, and ckpusilio11 (/\ug11~1 15, 2008) 011 bchall tlf 1:urthjusticc in thl' 1n,11tcr ur air pcrn1it c..:lwlkng1. ICT-4(,J I) for the 13nsin Elcc1ric D1y Fork -;t11ti~111. 11mkr cunstructiun 11car Ctilktk. Wyorning bdim: Ilic Envi1\111mcntal Quality Council or tlw Stc1tc of Wyt~ming. tv) Artich1vil/Dct:laration aml Expcrt Report on bdialf or NRDC and the Southern Enviroomcnt:il l.m,v Ceutcr in lhc 1m1Ltcr of the uir permit <:hnllcngc for DukcClif'fi:ilk lJnit 6. under consi1uction in North C:1rolin:1. (w) Donii11ion Wis<. County M/\CT Declaration (At1gus1 2008) (x) l:xpcr1 Report on behalf of Sierra Clul, lbr the.: Gn:l!Jl rncrgy Rr!->uurce Rct:ovcry l'ro,icd. M1\l'T J\n:tlysis (June 13, 20l)8). (y) faperl Rcporl on bclmlf of Sierra Club <111d the Environmental Jnlcgrity Project in the mailer of the air permit challenge for NRG Limestone's pmposed Unit 3 iii TexHs (Pcbnmry 2009). or (z) Expert Report and deposition on behalf MTD Products, Inc., in the matter of Alice lfolmes uml Vcrno11 Holmes v. Home Depot USA, Inc., el ul. (Jun~ 2009, July 2009). (mt) J':.xpcrt Report on behalf or Sicrrn Club and tlw Southern l~nviro11111cn1.1l Law Center in the rna111.:r ol' !he air rcrrnil chullcngc 11.ir Sanlee Cooper's proposed l'ce Dec plant in South Camlin" (/\ugusl 2009). (bb) $tatcmcnts (IV!ay 2008 c1nd September 2009) on behalf or the Minnesoln Center for or Enviromncntal A<lvocucy to the Minnesota Pollution Control Agency in the matter the Minnesota Ha:;:e Stale Implcmenlulion Plans. (cc) Expert Report (August 2009) and Deposition (October 2009) on bebalf of Environmental Defense, in Lhe matter ofpermit challenges to !he proposed Las Bris<'.lS con! fired power plant project ut the Texas Stute Office of Administrative Hearings (SOAJl). (dd) l)cposi1io11 (O\:tober 2009) on bchi1lf or Hnvironmcntal Dclcnsc nncl others, in the 1m:.ttcr ol' i.:halh::ngi;:s to the proposed Colcto Cred; coal /ired power plant pmject at the- Texas State Ollkc or Administrative Hearings (SOAl-1). (October 2009). (cc) Expc1t Report, Rcbut!al Report (S~ptcmbcr 2009) and Deposition (October 2009) on behalf ol' the Sierrn Club, in the matter of chullcngcs to the proposed Medicine Bow Fuel and Power IGL plant in Cheyenne, Wyoming. (ft) Expert report (December 2009), Rebuttal reports (May 2010 and .hme 2010) and depositions (June 2010) on behalf of the US Department ol'.lusticc in connection with the Alabamu Po\.vcr Company NSR Case. United Stales v. A/nbc1111u l'uwer Company, CY-01-l lS- 152-S (Northern Distl'ict of /\labmmt, Southern Division). (gg) !'refiled \csti nw11.v (October 2009) and Deposition (December 2009) 011 bchalJ' or Enviro111m:n1al IJelcnsc and others, in the mnttcr or challenges 10 the proposed White Stalliun Energy Ccnlcr coal tired power plnnl projccl nt the 'l'cxus Slate Ollicc of Administrative Ilcnrings (SOAlI). (hh) Deposition (October 2009) on bchc1lf of Environmental Dcfcnse and others, i11 the mutter of chnllengcs lo the proposed Tennska coal lircd power plunt project at the Texas Stale Office of Administrulive Hearings (SOAlJ). (April 20 I0), (ii) Written Din!cl Testimony (July 2010) and Written Rebuttal Tcslimony (J\ugusl 20 I0) on belmlf of the Stale or New M<.!xico Environment Deparln1ent in the mntter of Proposld Regulation 20.2.350 NMAC - Greenhouse Gas Cap and 7iwl<! or l'rmisions, No. EIB I0-04 (R), to !he Stnle New Mexico, Environmental lmprovcrncnl Board. or 0.i) E:..pcrt report l/\ugust 20 I(l) ancl Rcbutlal Expert Report (October 20 I0) on behalf llw US Department of Justice in conn<::ction with the Louisiuna Gt:ncrnting NSR Case. U11ited States I'. Lo11i~ia1m Generali11g, Ll.C, 09-CY I00-RET-CN (Middle District of Louisiann). (kk) Declarntion (August 20 I0) on l.Jclrnlf of the US EPA nnd US Department of Justice in the muller or DTE Energy Company, Detroit, Ml (Monroe Unit 2). (II_) Expert Report and Deposition (/\ugusl 2010) ns well liS Aflidnvil (September 2010) on behalf of' J<t:ntucky Wutcn,vays Ailiance, Sicrrn Club, and Valley Wntch in 1hc mailer ofchallcngm; to the NPDES permil issued for lhc Trimble County power plant by the Kentucky Energy and Environment Cabinet lo Louisville Uus anc\ Electric, Fill: No. DOW-41106-047. (mm) Fxperl Reporl (August 20 10) anJ Rcbultul Expert Reporl (S~pltrnber 2010) on or brlrnlf of Wilt] Earth Guardians in the maller opacity cx1.:1.:ccJam:cs and monitor uownt ime-at the Public Servic1: Company of Colorado {Xcclrs Cherokee power planl. No. 09-c.:v- 18(12 (D. C'olo. }, (1111) Wrilll'll Direct E:-:pcrt Testimony (August 1010) on lwlwlr o l' ,.-all -I 111c /\lliancc fol' c1 Ckun Envirn111ncnt nnd olhcrs i11 the mailer ur the: PSO Air Pcnni1 fol' Pinnt Washington issued by Georgia l)NR at the Office of Swtc Administrative Hearing, StuI~ ur (ieor~in (OS/\11-BN R-A<J- 1031707-()8-WALK.l: lq . (oo_} Dcpo:a;ition (/\ugusl 2010) on behalfofE11vironme1t1nl Ocfonsc, in the mattcrof'thc remanded permit challenge 10 the proposed Las 13risas cont tired power plant projct.:t al lhc Texas Slate Office ofAdministrative Hearings (SOAH). tPP) Expert Report, Supplemcntul/Rebuttnl Expert Report, ,ind Dcclnrnlions (October 2010) on bdrnlf of New Muxico Environment Dcp.irtmcnt tPlaintiff-Intcrvenor), Gr:md l'nnyM Trust and Sienn Club (Pluintiffs) in 1bc mnllcr of' Publk: Service or Company Nc,~ Mexico (PNM)'s Mercury Report for lhc San Juan Gentraling Station. Cl V 11. NO. I:02-CV-0552 313//\TC (ACl2). US District Coml for the District or New Mexico. (qq) Corrnncnt R~porl (October 2010) on lhe Drafl l't>rmit fsst1cJ by the Kimsus DHE lo or Su111lower Electric (or Holcoml.J Uni! 2. Prepare<l on behalf tht: Sierra Club un<l Eurthjusticc. (rr) Expert Report {October 2010) and Rebuttal Expert Repon (November 20)0) (B/\RT Det<:rminations for PSC'o 1-layJl!n and CSU Marlin Drake units) lo the Colorndo /\ir Q\i,ility Cnmmission on bchal r or (oalition of Environmentul Orgc1ni,.ntions. (!>s) l~;\pcn Rcrnrt (Nuw1nbcr 2010) (HART Dclcrm inntio11s rnr 1riStulc Craig Units. ('~11 Ni~nn l '111L. und PRPA Rawhkk Unit) lo the ColPntdo J\ir l)u:ility Comm ission nn bd1all' nf' l 'oal ilion DI' I:nvirnn111c11tal Organi1.utions. (It) Cnmmcnt Report (Dcl!embcr 2010) on the Pcnnsylvunin l)cportment of Envirnmm:ntnl Protection (PADEP)'s Proposal lo grant Plan Approval for the Wclling,to11 Grne11 E11t.!rgy R~source Recovery Facility on behalf of the Clwsapenke Bay Founclatim1, Group Against Smog and Pollution (GASP), National Park Conservn1ion /\ssociation (NPCA), ancl lhe Sierra CILJb, (uu) Writl(:11 Expert Testimony (Jnnuury 2011) to the Georgia Office of Stntc /\dminisirative Ilcnrings (OSAlI) in the mntlcr or Minor Sourcl.! 1-Ji\Ps status for the propm;e<l l,011~.knr l:11crgy Asslicialcs power plant (OSJ\I I-BNl{-1\Q-1115157-60IIOWELUiJ c111 beIlaII' 1>r the Friends oJ' the Cl1c11talwm;hcc and the Sierra Club), 2. Occasions where Dr. Sahu has provided oral lestimony al trial or 111 similnr prm:ec<lings indude the following: (vv) In Februnry, 2002, provided expert witness testimony on emissions <lnta on bchnlr or Rocky Mountain Steel Mills, Inc. in Denver District Courl. (ww) In February 2003, provided expcrl witness testimony on regulatory framework und emissions calculation methodology issues on behalf of' the lJS Dl'pa11mcnt of Justice in the Ohio Edison NSR Case in the US District Court lbr lhc Southern District of Ohio. (xx) In June 2003, provided expert witness testimony on regulalory framework, emissions calculnlion methodology, and emissions calculntions on behnlf of the US Deparlmcnl or Justice in the Illinois Power NSR Cc1se in the US District Court for Lhe Soulhern District of Illinois. (yy) In /\ugust '.!006, provided expert witness testimony rcg,1rding power plant emissions or mid Bt\CT issues on 11 permit challenge (Western Grcenbri<:r) on bchnll' the 1\pp:-dm:hi:111 Ce11H:r l'or thi: l:i:onomy uml lhl F11virnn111cnl in Wi:st Virginiu. (,.z) In May 2007, provided expert witnc:ss testimony rcgurding power plant emissions nnd 13/\CT issucs on u permi\ challenge (Thompson River C'ogcneralion) on behalr or various Montana petitioners (Citizens Awareness Network (CAN), Women's Voices for the Earth (WYE) and the Clark Pork Coalition (CFC)) before the Montuna Bonni ofEnvironmental Review. (mm) In October 2007, provided expert witness testimony regurding power pion\ emissions nnd 13ACT issues on n pcm1il chollcnge (Sevier Power Plant) on behalf of lhc Sierra Club before the Utah Air Quality 13ourd. (uhb) In August :mos. provi1kd cxpcrl witness testimony regarding power plan! en-.issions nnd 13/\CT issues on n pcrmil cl1t1llc11gc (Big S1011e Unit II) on bchal r orthc Sierra Club and Clean Water before the South Dakota IJoar<l or Minerals and the l:11virnnmc111. (cc.:c) In February 2009, provided expert witness t~stirnony rcgnrding power plant emissions and BACT issues on a permit challenge (Santee Cooper Pee Dec units) on behalf of the Siem, Club uncl the Southern Enviromncntal Law Center before the or South Curol ina Doard Health nnd Environmental Control. (<kid) In February 2009, provided expert witness testimony regarding power plant emissions, BACT issues umJ MACT issues 011 H permit chulh:11gc (NRG Limeslt1nc Unit 3) 011 bd1,lll' or the Skrra Club ancl the Environment:11 Integrity Project before thl' 'l\:xas S\llll'. Ol'licc ul' /\dminis1rn1ivl' l le:.irings (S0/\11) 1\tl111i11is1ru1ive 1.uw Judges. (ccc) In November 2009, provided expert witness testimony regarding power plunt emissions, l3/\CT issues and MACT issues on n permit challenge (Las Brisas Energy Center) un bchnll' of the Environmentnl Dcl'cnsc Fund before lhc l'c1rns Slulc Office of Adm inislralivc Hearings (SOAH) Administrative L11w .fudges. (ffl) In Fcbruury 20 IIJ, provided expert \.Vilncss testimony regarding power plan! emissions, Bt\C'l ' issues aml MACl isstH.:s on a permit challenge (While Stallion I~nergy Center) on bchnl ror the Environmental Dclcnsl' Fund before the 1 cxns 8lalc or~cc ol' Administrutivc I l~trings (SOAI-I) /\dministmtiw Luw Judges. (ggg) In September 20 IO provic.l<!d ornl trial testimony <1 11 bchalr ol' Cornmonwcnlth of or Pennsylvanitt - Dtpl. of Environmentnl l'rotcction, Slate Connccticul, Slc1tc of New York, State of Mmylm1d, and Stale of' New Jersey (l'faintilfs) in conneclion with the Alll'gheny Energy NSR Cnse in US District Court in the Wc!-lcrn Ui~tricl of Pennsylvania. JJ/uim(tl, ,,. Allegheny 1','m,rgy Inc.. t'I u/., 2:05cv0885 (W.D. Pennsylvania). (hhh) 0ml Direct und Rcbullal Expert Teslimony (September 20 I0) on bchulf' of FullLinl! /\ lliancl' !or n Clean Environment and others in the nrnller of the PSD Air or l'crmil for Plan! Washington issul.!d by Georgia DNR at the Ol'fice Stnlt: t\dmi11istrn1ive llcaring, State ol'Ucorgia (OSAII-RJ\R-AQ-1031707-98-WALKER). tiii) Oral Testimony (September 20 10) on uchutr of lhl! Slate of New Mexico Environ111c11t Depnrtmcnl iu the matter of Proposed Regulation 20.2.J50 NMAC' Greenlum.\'C! Oas Cap and Tmde Provisions. No. El8 I0-04 {R), lo 1hc Slale uf New Mexico, Environmcnl:il Improvement Board. @) Oral Testimony (October 20 I0) regnrd ing mcrc\1ry and total PM/PM IO emissions and other issues on u rcmrmded permit ehc1lkngc (Las Brisas Energy Center) on behul f or 1he Envimnrncntal Ocrensc Fund before the Tex.is Stale Ollice or Adrninis1rntive I lcurings (SOAI I) /\dministn-tlivc Law Judges. (kl;k) Oral 1\:s1irnony {Novcmb~r 2010) regnrding BART tor PSCo Iluydcm, CSU Mnrlin Drake unils b~forc lhe Colorado Air-Quality Commi~sion on belrnlf or the Coalition or Environmental Orgu11i7_..11ions. till) Oral Tcsli111011y (December 20 I 0) regarding BART for Tri State Craig Units, CSU Nixon Unil, and PRPA Rnwhiclc Unit) before the Colorado Air Qunlity Commission on b<'halr or the Conlition of Environmcntnl Organiz,11 ions. (nunm} Dcpo::.iliun (December 2010) on behalf ol' the U!:i Ocpnrlmenl ol' Justil:c in l!onncclion with the Louisiauu (.;enernting NSR Crise. United St"le.\ I'. lc111isiam1 Uem.!rnting L.U.', 09-C'VI00-RET-CN (Middle District l)r l.011isia11al. or 1111111) Dcposilion (h.:bruury 2011) 011 hchnlr of' Wild E,ll'lh Ouurdiuns in the mnllcr opncily cxcecdilnccs nnd rnonilor downtime ut the Public Scrvi1.:c Compuoy of Colorad,1 (Xcel)' s Chtrokcl! power plmll. No. 09-cv-l 862 (D. Colo.). tooo) OrnI Expcrl Testimony (February 2011) lo lhc Georgia Office of State Administrative l-lcmings (OSAI I) in the matter of Minor Source IIAPs stntus for the proposed Lo11glcar Energy l\ssocintcs power plant lOS/\H-BNR-/\Q-111 5157-601IOWELl.8) on helrnlfol' lhe rriends ol'thc ChnllttlM>chec and the Sicrrn Club). H. ANDR l~W C l~ A\' 11:DI ICA't'I ON Pl1.D. cnvirun111cn1:1I engineering science, Ca lifornhi lns1itutc of''l'cchnology. Pusadcna, C:-ilili1rni,1. 1986 ivl.S. <.nviro111nc11lal engineering science. Calil'ornh, lnslitulc ol' Tcchnolugy, P,,sadcnu. Culi fi,irnin, 1980 13.S. civil c11ginecring/cnginecri11g and publh; policy, C11r111:gic-Mcllon lJnivcrsity, Piu:.burgh, l'l.:nnsylvania, 1979 fi.:XPJW Jl~NCE Dr, II. A111lrcw <;n,y hos been p1.:rforming research in c1ir pollulinn for over 30 ycms, withi11 aca<.h.:mk:. g1,vernmc11111l. nnd consulting environments. He hns made sig11 ilknn1 r0ntributions in th<.: :1l'cas of airborne particles and visibility. includi ng the Jcvclopmc.nt and application or cu111putcr-ba:.<.:cl nir quality models. His Hreus of expertise arc air pollution control :;trutcgy design and cvnluatinn, compl1ter modeling of lhc otmosphc1T, charactcrizalilln ufambient uir qunl ily nnd uir pL1lll1lunt source emissions. ucrosol mn11iloring and modeling, visibi lity analysis, receptor modeling. stntistical data analysis, mnlhe111aticul progrnm111i11g, numerical methods, and anulysis lifcnvironmental public policy. Dr. Gray is current l y :111 imlepenclcnt contruc:lor focusing on pnrtk11h1tc mnthr ,u,d visibility n:lc11cd rcscurd1 is-;u1:<;. Previu11-; Grny Sky Solutions projcl'ls include usscss1nc11t 01' C lcnn t\ir /\cl and other rcgL1lalio11~ on visibility in Clns:, I (park unJ v.-ildcrncss) .in:ns, dcvdopmc111 of nir pollution l:1,nlrol plans mid cn1ission invt'ntorics for trilrnl l,111ds, review unJ dcvclopmcnl or guidelines l<ll' model ing lnng-range trnnsport impacts 11sin!:-( the C/\1.PUFF model, evnluatinn or par1iculc11c nir ciunlity impacls associntcd with diesd exhaust emissions, air quality munagcmetll plan modding protocol review, 11 nitirul review o l" Clcun /\ir Mcn.:ury Ruic (C'AMR) clocumi.:nts, nnd assessment orthc regionnl nir q1w lily impncts of' powcr plan~ emissions. rvlost recl'ntly, Or. Grny bus been currying nut dispersion modeling studies to dl:'Lcnninc the impacls nssocinlcd wit h mercury emissions in th( Chcs~1pcakc Bay region. l3elorc stn rt inl:! Gray Sky Solutions. Dr. Gr~y was 1he mnnttgcr or the PM 10 and Visibility Pr<1grum al Sy~tcms /\pplicutions lnlcrnutional tSAI / ICF Inc,), Al SA i , Dr. Gray eonducti:.:J or und nwnngc<I u 111ln1hcr vuricd air pollution rcscurch projects. In thr cmly 1990s. Or. Gray dircch:d u lnr.c (ov1..r $ I million) uir-gunlity modeling program lo cletcrmim: the impact of' SO, cmission~ from a ltuge cu,-11-fired power planl on Grand Ca11yo11 sull'at~ nnd visibi lity levels. Ik mc1n;1gccl project'> 10 develop carbon porticlc emission duln lur the Denver area. drs ignl!d u PM 10 111oni1oring u11d modeling progrnm for the El P:iso nre.i. determined the approprinl<.: lrnclcoffs between direel PM 1o emissions nncl emissions of PM 10 precursors, cstirnntcd the visibility uffcct!.l in fudoral Class I arons duo to the 1990 Clen11 Air J\01 l\111L"od1ncnts (results of which W(!rc incorpornted into EPA's 1993 Report Lo (\)ngrcss 011 the cxpe<.:tetl visibility consl!qt1c11Cl!S of the 1990 Clean Air Act Amendments). and provided ossislancc 10 EPA fh :gion VI Il's tribal uir progmms. Other projects include l!rn ission i11vc11111ry devcl11p111e11I li.1r Sucrnntcntu 1111d cnrb,m 111onoxitk nwdding nf' Ph11.:11ix, Ariz1J11n Ill sur rnrl l\!dcnil 11nd rL"gional implcm.:nllttiun plans in 1hosl.! regions. sysH:mntic evalualio11 ni' the lntcragcncy Workgroup 011 Air Quulily Modl'ling \ IW/\QM) rc1.:01111111:11d111io11s for thl' use <.1f MESOPUH 11. :11.;ri1 ic..d asscssn1c111 nl' e:xpos11fl'S In pal'tit:ulHLc dicMI cxhurn,l m Cul i f',,rnia, n11d an e valua1io11 ur P1vb 5 and PM111 uir quuli1y d:tl,t in supprrl of l.PA's rcvh:w 1-/, 1Jm/r1; iv (jray /'(lge 2 l)fthe feclcrnl pnrticulatc mailer nir quality slnndar<ls. Later projects included n study of micrometcorology nncl modcling of low wind speed stable conditions in the Sun Joaquin Valicy (CJ\), an usscssment of the reductions in nationwide nmbicnl purticulutc nitrate expostucs due to mobile source NOx emission reductions, un evc1luation of visibility rn11di1ions in the Southt:rn Appalachian Mountains region, a review of cotton ginning emission foctors, aml n critical review ,md nsscssment o l' thc PM11, Alhii11111c11t Demonstration Pinn lb1 Lhc San Jom1ui11 V:illcy. Dr. Gray was n member of the 111oc.leling subcommillcc lll' the technical commillce ol'thc Grnnd Canyon Visibility Transport Commission. Previous lo his tenure nt SA I, Dr. Gray was responsible for the PM io and visi bility prngrnms at the Smllh Coasl J\ir Quality Management District which involv!.!d directing monitoring, u1111lysis, nnd modeling efforts to support the design of ait pollution control strategies for the South Coast Air Bnsin of California, He developed and npplied Lhc mcthuuulogies for assessing PM 10 co11ccnlratio11s Lhat have continued 10 be used by the District through numerous subsequent uir quality management plan revisions. Dr. Gray uuthorcd portions of the 1989 J\ir Quality Managcmcnt Plan issued by the District lhnt describe;: the results of modeling and dnta an11Jyscs used lo cvnluatc pnrliculate mutter contro l slrutcgics. Dr. Gray was in~tn1111c111al in promoting the clcvclopmcnl and npplicntio11 of' state-of-science models ror prl.'.tlicling particulate mailer conccn1rutions, I lis responsibilities included direction ond oversight or numerous al:!rosol-relutctl contracts, including acvelopmen1 or the SEQUILIB and SI\ FER models, construction ofan ammonia cmis!lion dutobasc, and dtivdopmcnt of sulfate, nitrate und organic chemical meclrnnisms. In udclition, Dr. Grny was responsible for initiating the District's visibility control program. In rcscnrch pl.!rformed al the Colifomin lnslitutc ol"fechnology, Dr. Grny studied control or atmospheric !inti primary cnrbon pmticle concentrations nncl performed computer programming tasks for ucguisition and unol ysis of real-time experimental data. I-le designi.-:d, constructed. nnd opcrnted the firs! lung-term line particle monitoring network in Southern Cali lornhi in the enrly 1980s. He also devclt1pcd and appl ied detcnn inistit.: models to predict suurcc contributions to fine prim.iry c:,rbon pnrtich: concentrations and constructed ol~jcctivc uptimiznt ion proc.cdures for control strategy design. In rcseurch carded out ror the Department t'I' lvlcclrnnicnl Engineering at Cnrncgic-Mcllon University, Dr. Gray developed liiel use data for input to an emission simulation model tor the northcas1crn United Stntcs. Specia lized l'rofcssioual Compctcucc t\ir pollution wntro l s1rn1egy (ksign Atmospheric air quality charnctcriznlion 0 Aerosols nml visibility " Computer modeling and data analysis Oispcrsion mode ling for puniculalc matter :md visibi lity Receptor modeling including Chemical Muss Bulnnee (CMB) nnu factor 11nalysis Annlysis ol'c11virnn111cntal public policy I-/. llndrell' Groy Page J Profcssio1111l Experience Systems Applicnlions lntcrm1tional (SAl)-PM 10 find visibility prog,~111111111nngerparlicipa1ed in and manugcd numerous .~ir quality llll>dcling i1nd analysis projects for public and private sector clients, with emphusis on particulate motlcr :ind visibility rcs~arch Sou!l1 Coast Air Quulity Management District. El Monlt\ California-air {1u:1lily '>pccinlist-clcvclopcd nnd applied air qunlity modeling analyses lo support air pollution control strategy design for the South Coast Air Bnsin of California Calilornin Institute or Technology, Pasadena. Calilc:irniu-rcst'arch us~islmH--l'h. D. c:111<.litlutL' in cnviro11111<.nta l c:11gi11cering scit.nce. Tht>sis: (:(lntrol o r u11110sphcl'ic line r l'imary cmbon p:irticlc conccntiations (thesis ;itlvisors: Dr. Glen Ca~s. Dr. John Seinfeld, and Dr. Richnrd 1:1agnn) Culifomia Institute of Technology, Pusudcnt1, Californin--laborntory HssislRntperforme<l computer progromming tusks for acquisit ion nml analysb of rcnl-timc cxpcrimcntul data ,. l)cpnrtmcnt of rvlechnnical Engineering, C'orncgie-Melli,n Uuivcrsit)'. Pillsburgh. 1>en11sylvc111iu-rcscnrch assistnnl-<levelopcd fw:I ust dalHfor nn l'missirn1s simulation 1m1dcl f'or the northeastern U11itcd Statl.'s. Grant from the lJ.S. Dcpurtn1cnt of Energy for cv:1lunt i1111 or nmionnl energy policy Dcpnnmcnl \JI l'ivil L:11gi11ccring. C.m1cgio-Mcllon Uni\'crnit), l'illsliurgh, Pcnnsylvn11i11- 1.onsullnnt-annlyzed structurul retrofit dt:sign lor Fcrrnri Dino import uutomobile for United Stutes live mph crash lest IIONORS AND AWARDS Hurold Allen Thomas Scholarship Aw,ml, Carm:gic-Mcl1011 University IJnivcr:;ity Honors, Can1egie-Mcllo11 University PROFESSIONAL Aft'FILIATIONS 1\ lr and Waste M:11111g.c111ent /\sso<.:iution /\incrkan /\'i5oci111io11 for /\crnstd Research SELl~l"l'F.D PU BLIC/\TIO NS AN D PRESENTATION S The Deposition or Airborne Mercury withi n !'he Chcsnpcukc nay Region from Coal-fired Power Pln11l Emission i11 Pcnn~ylvimin, in press (20 I0) ~ourcc Contributions to l\t111ospheric Fine Carbon l'nrliclc Conccnlrnl ions (wilh G.R. Cuss), Atmvsplu:ric Emiron111e111, 32:3X05-3825 ( 1998) or "Mnni1ori11g oncl Analysis the Surface Lnycr at I.ow Wind Speeds.in Stuble PBL'sin the St111tlwrn San .loa1.jui11 Valley ofCnlil'orni11'' lWith others). presented nl Ilic /\1m:ricun l\'kl..:01 ulugi~al Soi:icty' s 12th Symposium on Boundary Layers :md Turbulence, Vancouver, Bril ish C.:olumhia (Ju ly 1997) H. Andrew Gray Page4 "Eslimation of Current and ruturc Year NOx lo Nitrate Conversion for Various Regions of the United States" (with A. Kuklin), presented al the 90th Meeting ofthe Air and Wttste Mnnagcment /\ssocintion, Toronto, Ontnrio (June I997) I111cgrntl.'d Monitming S!llcly ( IIVIS) I 995: Clrnructcrizntirn1 l>f' Mii.:rn111t.:tcomlugioal l1hLnu11w11:1: Mixing and Diffu:;it:11 i11 1.uw Wind SrccJ Stable Co11diliuns: St11dy Design und l'rdiminary Results twith others), in /1,fe{l,\'lll'ement uf'fox,, and Rc:latc:cl Air Pol/utants, l\ir and Waste Munagcm cnt /\ssociation, l'it1sburgh, Pennsylvaniu, pp, 4!l4-500 ( 1996) Regional Emissions and Atmospheric Concentrations of Oiesel Engine Particulmc Matter: Los Angeles as a Case Study (with G.R. Cass), in Diesel Exhaust: A Crilical Analysis of Emissions, Exposure, and Heaflh EjJec/s, Health Effects Institute, Cambridge, Massachusetts, pp. 125-137 (1995) ' Asscs:rnn:111 of tin: EO~cts uflhe 1990 Clean Air Act A111l!nd111c111s 011 Visibility in Class r Areas". presented at the 86th Annual Meeting & Exhibition of the Air and Wostc l'Vlanng~mcnt /\ssocintion, Ocnvi:r, Colorado (June 1993) "Solln:~: Conlribulions w /\11110:.;phcrie Cnr bo11 l'nrtich: Conccntrn1io11s" (with others), presented ut the Southern California Air Qun lity Study Oat~ Annlysis Conrcrcncc, Los Angeles, California (foly 1992) "Modeling Wintertime Sulfate Production in the Southwestern United Stales" (wilh M. Ligocki), presented at the AWMA/Ef>A International Specially Conference on PM I0 Stnnc.Jnrds and Nonlraditionnl Particulate Source Controls, Scottsdnle, Arizona (Jmmary 1992) "'Deterministic Modeling for the Nnvojo Gencrnting Sltllion Visibi lity Impairment Study: An Overview.'' presented nt the 84th Meeting ol'thc Air nnd Waste Mnnngcmc:111 Association, V:111~t1uwr. 13ritish Columhi:1 (June 1991) "Receptor :md Dispersion Modeling or Alum inum Smelter Contributions to Elevntcd PM I0 Conccntrnlions" (with R. G. Ireson and A. 13. Hudischcwskyj), presented ut the 84th Meeting or th\\! Air m,d Waste Management Association, Vancouver, British Columbin (June I991) Visibi lity and PM-10 in the South Coast Air Bnsin ofCa lifornh, (with J.C. Marlin), in Visibility and Fine Parficles, Air und Wuste Mmmgemenl Associution, Piusburgh, Pennsylvania, pp. 468-477 ( 1990) Chemical characteristics ol' PM IO i1crosols collcclcd in lhc Los Angeles area (with others),./. Air Po!l111. C'm11rol Assoc., 39: 154-163 ( 1989) /\1111ospht~rk carbon part icles and Lhl' Los /\ngcles visibility problem (with others), 1hwu.w1/ Sci. 1'ed11uJ/. I0: I 18-1 JO ( 1989) Rc1,;cp10r model in~ l'or J>M IO source am>ortionmcnl in the South Const /\i r Bnsin or N. J/11dre111 Grt~I' Poge5 ()w1111i1:11ivc high-resolution gas d1ro1rn11ogn1phy and high-rcsolulion gas chroma10grnphy/11rnss spectrometry nnalyscs of cnrbonoceous line ncroi;ol purticlcs (whh others}. /111. .I. /:11viro11. Anal. Chr!m, 29: 119- 139 ( 1987) 'Develop111e11t of an Objective Ozone Fcm;casl Model fo r the South Cu.ts! 1\ir l.3i:lsin" (with others), presented al tht: 80th Meeting of the Air Pollution Co11trol Association, New York (June 1987) PM IO Mmkling in the S0\1lh Coast t\ ir Basin of California" (with 01h~r,), presented ,11 the 71>th /\nnual Meeting or the Air i>o]lt1lion c~mtrol Associ,1tion, Minnetipol is. Mimicsola ( 1986) C'hanwtcri-;tic:. ,,(' atm11,;phnic nrganic nnd cllmcnlul carbon partkl~ -:om:t!ntrntions in Los A11gc l(s (with nLlll'r<:), /:1111ro11. ,\l'i. rcc1111ul. 20:580-589 (llJ8(1) ..Chcmirnl Spc<'inlion or Extrnctuble Org,111ic Maller in the Fin~ t\crosnl Fraction" (with others). r,rcscntcd ut the 1984 lnlern:itional Chem ical Congress or l'acilic Busin Societies. I lonolulu, Hawaii (1984) "Source Contrihutions to /\tmusphcric C:irbon Particle Con.:entrnlions.. (wilh others). presented 111 Lhc First l11lcrnalionnl Acrns0l Conlcrcncc, Minneapolis, Minnesota ( 1984) Elernelltol and org,mic carbon particle concentrntions: A long term perspective (with others), Sci. Tora/ l:.'nvimn.. J6: 1725 ( 1984) "Mctct,rolugical and Ch,'.micul Potential l'nr Oxidant Formation twilh othcr5), presented at the Conrl'rcncc "" J\ ir QlHtlity Trend.,; i11 thi.> South Coast Air 13:isin. C'alifornia lnslilulc of Tcch11olugy, P11sadl.!11H, Cali fornia ( 1980) Co11tuii1ing recombinant DNA: How ro reduce the risk ofescupc (Wilh others}. N<1r111e, 281 :421-423 ( 1979) OTlIJo:R PUBLICATIONS ' 'Cyprc-ss Creek Power Plant Modeling: J>ollutunt Deposition 10th~ Ch1.s:ipcak1: 13uy 1md Sensit ive Wutcrsheds within the Commonweulth ufVirginiu." prcpart:d on bdinlf of !he Cht:sapcakc Bay Fo1111tl11lkl11, Annapolis, MD (2009 ) ..Virginia City Powl'r Pinn! Modeling," prcpnrcd on hchnlfofthc t'hcsapcakc 13ay h1unda1io11, !\11napulis. MD {2008) "Chcst.;;rticld Puwcr Plan! Modeli ng," prepared 011 behall'ofthe Chesapeake Day Foundutiun, Annapol is, MD (2008) or 'Thu DcposiLio11 Airl,urnc Mercury in Pennsylvania,'' prepared on bchalrofthi; - - -- Io .. , _ . _ , _ , - , . ,,...,., I I. !lmlrew Gray /'(lge 6 ''Air Qunlily Modeling 1111d Visibility Impacts Associated with Sammis Power Pinnt Emissions,'' prepared 0 11 bchulrofrhc Uniled Stales of America, Washington, D.C. (2003) ''Air Qllality Modeling and Visibility Impacts Assooiated with Baldwin Power Plant or or Emissions," prcpnred on behalf' the United States America, Washington, D.C. (2002) Ass~ssmenl ol' Lhe Impacts ofCl cnn /\ ir Act and Other Prov isions on Visibility in Class I Arens" (with others), prepared for 1\mcricnn Petroleum ln:;tituti:, Washington, D.C. ( 1998) ''C'al ili.,rnia l{egional PM IO Air Quality .Study: IYY5 !t1tegrntl!cl tv/011iloring Study Datu Analysis: Time and length Scale.1.fbr Mixing SecondmJ' Aero.mis During Stagnation J>eriod, (wilh others), prepared for California Air Resources Uonrd, Sacrumenlo ( 1997) "San Joaquin Valley Regional PM IO Study: Characterizing Micrometeorologic:a/ Phenomena: tvf;xing and D({fi1sfon in Low Wind Speed Conditions Phase 111: Monitoring and Data Analysis" (with others), prepared for C11lifornia A ir Resources ijo:1rd, Sacrnmenlo (I 997) "Cotton Gin Pnrtil.:ulatc Em ission Factors," prepared for U.S. Environmcntnl Protection /\gcney. Region VIII. Sun Frnncisco. Californiu ( I997) 'lk11elits ul' Mobik S011rcc NOx Related J>arlkulatc Maller Reductions" (with/\. Kuklin), or SYSAPP-96/61, prepared for OHicc Mobile Sources, U.S. Environ111cnt.1I Protection Agency, Ann Arbor, Michigan ( 1996) or ''Evaluation of Existing Information on the Effects Air Pollutants on Visibility in the Southern /\ppalachians" (with D. Kleinhcssclink), SYSAPP-96-951060, prepared for Southern Appalachian Mountains Initiative, Asheville, North Corolinu ( 1996) Statistic.II Support !or Lhc Particulotc Mattcr NAAQS" lwith others), SYSAPP-96-95/039, prepared fi.H' Olfo:<.! or Ai r Quulity Planning and StnmJards, U.S. Enviro11rnc111al Protection Agency, llcscurch Tri:ingle Park, North Cnrolinfl ( 1996) "San Joaqu i11 Volley Regional l'l\1110 Study Support Study 5/\: Clwmctl!rizin.~ Mic:ro111c:"uro/ogica/ l'hcnomena: Mixi1w and Oijji.1sic111 in low lYiml ,\'JJecd Cumlition.1 Plwse 11: Detailed Recommenclutionsfvr Experimental Plans" (with oLhcrs), prcpnrcd {or Cali fornia /\ir Resources Boarcl, Sacramento ( I995) "Snn Joaquin Valley Rcgionnl PM IO Study Support Sludy SA: Chamcterh:ing Mic:romeleurolo~ica/ f'he/lomena: Mixing awl D/[fi1siu11 in /,ow Wind Speed Conditions Phase I: literalure l<eview .an<I Drq/f Progmm Recu111111e11dario11s" (with others), prep.ired for Cnli rurnia Air Resnurccs 130.ircl, Sal:rnmenlo ( 1995) Clnss I Urouping fnr Subscqul.!nt Assessment of l{cgio1wl Haze Rules" (with others). SYSAPP-9il/ 129, prepared !or Air QualiLy Strategics uml Swndurds Divisio11, Office of /\ ir Quality Planning nncl Stunclarcls, U.S. Environmental Protection Agency, llcscarch Triangle l'urk, Nonh Curolinu (1 994) 'Rclrospcctive Analysis of the Impact of the Cle.111 Air Ac! on Urb,m Visibility in 1hc Southwcslcrn United Slates" (with C. Emery and T.E. Stol!ckcnius), SYSAPP-94/108, or prcpnrcd for Oflice of Policy Annlysis und Review, Office Air and Rndintion, U.S. Environment.i i Protcclion Agency, Washington, D.C. (1994) l:I. Andnw Grt(I' Page 7 " Eval11:itio11 tif Ambient Spec k:; Prolilcs. Ambient Versus Mudck:d NfVII IC:NO <and CO:NO, Rati~)~, and Su11n:cRcccp1or /\11alyscs" (with G. Yarwood. M. Ligoc:ki, unJ G. Whitten ), SYSAl'l'-'>1/081. prcpmcd for Of'ficc u!' Mobile Sourcts, U.S. l~nvironmcnwl Prutcction Agency, /\1111 Arbor, Michigun (1994) "Diesel Partil-ulalt' Mal!cr in California: Exposure Assessment" (with M. Ligocki an<l A. Ruse11baum), SYS/\ PJ>-94/077, prcp11rcd for Engine Mnnufocturers /\ssocintion, Chicago, Illinois (1994) "l11terngcncy Wurkgroup on Air Qualily Modeling (IWAQM): /\ssessmcnl of' l'husc l ({ecommcndn!ions Regnrding !he Use of M~SOPUFF 11" (with M. Ligocki and C. Emery), SYS/\PP-94/030. prepared for Sr,urcc RcccplOl' nnd Analy'iis Br:inch, Technicul Scrvkcs or Divi:sio11, Office Air <._)uality Planning and Standards, U.S. Enviro111nen1al Protection Agency, Research Triani;le Park, N0rth C'urolina ( 19911) ''/\nnlysis orthe 1991-1992 Pinc Bend Monitoring Dnta" (with others). SYS/\l'P-94/U07. prcpnred for Mi1111csola l'ollution Control Agency. St. Paul, Minncsotu ( 1994) "Assessment o f' the Effects of !he I990 Clean Air Act Amendments on Visibility in Class I An.:as'' (with utl1ers), SYSAPP-93/162, prepurcd for Ambient Standards l3rm1ch, Of{icc uf Air Quality Plann ing and Standards, U.S. Environmcntul Pn,tcctio11 Agency, Research l'riangll! l'urk, North Carolina ( 1994) "RC'vis~d 13nsc Cnse and Dcmonstralion of /\ttainment lbr Carbon Monoxide for Maricopa or County. Arizona ( with olhcrs). SYS/\Pl'-94-93/l 56s, prcp!lrcd fur M<1ricopn /\s-;ociation <,uvcrn1111:111s. Phncnix. Arizom1 I. 1994) sn1.:rnnicnln Fl 11 200S Modeling lnvi::11lory" (with nlhcrs), S YS/\PP-931}3 7, prcpmi::d !'or Pul'i(ic l:11vi1011111untal Services, North Cnrolina, nnd U.S. Lnvironmcnt:d Protection Agency. lleginn IX, S,111 Tranci~to, California t 1993) "Carbcm Monoxide Modeling in Support of the 1993 State lmplcml!lllnlion Plan for Maricopa County, Arizom1 (with ulhers), SYSAl'P-93/ 156, prepared tor Maricopa Association of' Guvcrn111cnts, Phoenix, Aiizonn (1993) ''Air Quulily Modeling of'Cnrbon Monoxide Cunccnlrntions in Support orthe r-'cdcrnl I mplcmentnlion Pinn for Phoenix, Arizona" (with others), SYS/\PP-93/039. prcpaied for Paeific E11virn11111c11lal Services. North Curolinu. und U.S. l.::nvironmcntnl l'roteclion Agency. R..:gion I X . San 1-'randsco, Calil''ornin ( 1993) Bnst C'm;c Carbon Mnnoxidc Emission Inventory Development for Maricopa County. Arizonn'' (with 01hcr:;), SYS/\PP-93/077. prepared for Murkopa Associution or Gnvcrn1ne11t!:., Phoenix, Arizona ( 1993) "S:icrnmcnto r:J P Modeling 3: Future Emissions Inventory" (with others), SYSAPP-93/036. prepared for Pacific Envimnmentnl Services, Inc., North Curolirn.1 and U.S. [~nvironmcntal Pml~cliun Agency, Sun Prrirn.:iscu (1993) 'Emi.s:;ion.s lnvc11tory Dcvclop111c,nl for \he Tribnl 1\i1 Program" (with M. Cttuslcy und S. Reid). SYSAPP-92/1 116. prcpnred for U.S. E11virnnrnc11\nl Protection Agency. Region VIII. IJl'nvcr. C\,lorndo ( l 1)1)2) II. Andrew Grt~J' l'oge8 "Carbon Pr1rticlc Emissions Inventory fur Denver Brown Cloud II: Development and t\sscssnient" (willi S. B. Reid and L. IC Chinkin), prepared for Colorndo Department of Ilcallh, Denver, Colorndo ( 1992) "Analysis to Determine lhc Approprintc Trndc-ofl' Ratios Between NO~, SOA, 1111d PM I 0 Emissions for the Shell Martinez Refinery'' (with M . Ligocki), SYSAPP-92/006, prepared for Shell Oil Co.. Martinez, California ( 1992) "Moucling Program for PM- IO Slnlc lmplcmcnl<1tiun Pinn Development for tl1t: El Paso/Ciudau .luarcz Airshcll" (with C. Emery and M. Ligocki), SYSA PP-9 1/1 34, prcpurcd for U.S. Environmental Protection Agency, Dnllas Texas ( 1991) "Deterministic Mo{kling for Navajo Ocncrnting Station Visibility Study. Volume I. Technical Report" (with others), SYSAPP-9 l/045a, prepnrcd for Salt River Project, Phoenix, Arizona ( 199 I) "'Deterministic Modeling in the J\nvajo Generating Station Visibility Study"' (with others). SYSA PP-91/004, prqrnred for Sal l River Project, Phoenix, Arizonn (1991) 'Am,lysis o l' Contributions to PM IO Concentrations During Episodic Conditions" (with A. 0. lfodischcwskyj and IC G. Ireson), SYSAPP-90/072, prcpc1rcd lor Kniser Aluminum 1111d Chemical Corporntion ( 1990) "Preparation or Elemental anti Organic Carbon Poniclc Emission lnvcn1orics for the Denver Arco: Work Pion" (with L. R. Chinkin), SYSAf'P.90/068, prcpurcd for Colorndo Department of Hc11lth ( 1990) "Evnluation ol'Conlrol Strategics for PM IOConccntrntions in the South Coast Air 13::isin," Air Qunli1y Managcmcm Plan: 1988 Revision, Appendix V-0. South Coast Air Quality l'vlanagcincnt District, El Monie, Cali furn in ( 1988) "/\1111u11l PM IO Dispersion Model D1:velopmcnt and Applic,llion in the South Co11st t\ir Basin," Air Quality Mnnngcmcnt Plan: 1988 Revision, Appendix V-L. South Coast Air Quality M,mugc,rn:nl l)istrict, El Monte. Calili.,rnin ( 1988) ''l'MI0 MoJding Approach" (with others). 1987 AQMP lhvisiL111 Work ing Poper No. 2. South Const/\ ir Qunlily Management District, El Monte, Californi:.i ( 1986) 'Work!Jlnn Ii)!' Air Qunlity Modeling and Annlysis." 1987 AQMP Revi:;ion Working Paper No. 5, l'la1111i11g 1Jivisi1111, South Coa!il Air (}unlity Mrurngcmcnt District, El Monie, Cnlilorniu (1986) Control uf 1\tmospheric Fine Prinrnry Corbon Particle Conccntrnlions," (EQI. re port No. 23), Ph.D. thesis, Cnli!'ornia ln~titutc of Technology, Pusadcnn, California ( 1986) Policy on l{ccombinanl DN/\ Activities: Rclnxing Guidelines While 1111.:rc:ising Safety," project report, Dcpnrt111c11t or Engineering 11ml Public Policy, Carnegie-Mellon University, Pillsburgh, l'cnnsylvaniu ( 1978) 'Air Pollution Cu111rol Annlyscs for Stulc Implementation Plm1 Revisions in Allegheny County,'' project rcporl. Depnrtment of Engineering anu l'ubl ic Policy, Cnrncgic-Mcllon University, Pittsburgh, l'cnnsylvnnia (1978) //. Andrew Gray Page 9 EMJt.OYM t:NT I I ISTOltY Systems /\pplications ln1crn11lionnl Soulh C'oasf Air Quality Munagemcnl District Colifo1nia lnslifutr ofTcd111ology. Pa-;mk:n:1, ( 'al il"c-rnin lun1lgic-Mcllon U11ivcr!-iil)'. IJcpl of l'vkchnnicnl 1'-.nginccring l'illsburgh, Pl!nnsylvunia Visibilily PrC1grnm Air Quulity Specialist Research /\ssistm11 L:ihorntory /\ssisl:1111 Research Assistant Mnnugcr, l'M1 0 und 1989- 1997 1985-1989 1979-1985 1979 1978-1979