Navy/Marine Corps Mobile Source Emissions Growth Projection and SIP Planning

1. Navy/Marine Corps Mobile Source Emissions Growth Projection and SIP Planning Presented by: Mike Huber, NRSW Massie Hatch, URS 7 April 2004

2. Agenda • Background • General Conformity Impacts • Purpose and Benefits of Growth Projection and State Implementation Plan (SIP) Planning • Challenges • Steps Taken • Lessons Learned

3. Background • General Conformity regulations (40 Code of Federal Regulations [CFR] Part 51 Subpart W and Part 93)require federal agencies to demonstrate conformity with local SIP PRIOR to commencing action • Conformity applies in non-attainment or maintenance areas • Conformity affects non-permitted emission units (e.g., mobile sources, area sources)

4. Conformity Triggers • BRAC actions • Consolidated training missions • New weapons systems (MV-22, JSF) • Other major actions that trigger National Environmental Policy Act (NEPA)

5. Conformity Impacts • If project emissions exceed conformity de minimis level, a detailed conformity determination is required • Mitigation measures may need to be implemented: • the project might need to be staggered, reduced, or delayed; and/or • costly Emission Reduction Credits (ERCs) may need to be provided • Limits expansion capability and usefulness of many bases (could negatively impact Base mission) • ERCs cost $100,000/ton for NOx in San Diego and are difficult to acquire

6. Conformity and SIPs • If emissions are already accounted for in the SIP, conformity is demonstrated • Not easy to do, SIPs are written 5 to 10 years in advance • Historically, the military has had limited involvement in SIP development • Without data from military, districts tend to forecast ZERO growth for installations

7. Purpose • Calculate accurate baseline data for military mobile sources • Project emissions growth through Year 2015 and incorporate that growth budgetinto the SIP to facilitate fielding new weapons systems or potentially expanding operations • DoN must still comply with NEPA and other laws and regulations that prohibit pre-decisional actions • Final decisions are only made after NEPA and other applicable requirements are met

8. Benefits • Military- Projected growth in the SIP facilitates conformity • Districts - Military data make the SIPs more accurate • The current military data in most SIPs are based on incomplete, inaccurate, and/or outdated estimates

9. Challenges • Timing may be critical; SIPs are onlyrevised every few years - plan accordingly • Baseline data for mobile sources are not generally available • Growth information is difficult to collect • No process exists to provide data on new weapons systems to local air managers • Depending on progress toward attainment, some SIPs might not be able to accommodate much growth

10. Steps Taken • NRSW POAM developed in December 2000 • Multi-service team met with CARB in January 2001 • NRSW hired URS to provide support • Initiated contact with local Air Pollution Control Districts and met with EPA Region IX • SDCAPCD, SCAQMD, VCAPCD, ICAPCD, SJVAPCD, and SVAPCD-all VERY receptive to initiative • EPA, CARB, and all Districts contacted were supportive of the idea and eager to receive data • Marine Corps SD installations joined the effort in September 2001

11. Steps Taken, continued • NRSW/MC proposed methodology to SDCAPCD in January 2002 • SDCAPCD provided helpful input and support-methodology approved with minimal comments • Meanwhile, San Diego attained 1-hr ozone standards and began preparing an ozone maintenance plan • NRSW/MC had a 4-week window to provide baseline and growth data • Projected growth through Year 2015

12. Baseline and Growth Data • Baseline and Growth data provided for the following source categories: • aircraft; • vessels (zero to three nautical miles); • Ground Support and Tactical Support Equipment (GSE/TSE); and • tactical vehicles. • Baseline emissions relied heavily on existing planning documents for significant operations (e.g., past inventories/studies, current conformity efforts)

13. Growth Projected • Sources of information: • Navy/MC Headquarters • Strategic planning documents • New Homeland Defense requirements • Emphasized that all future growth is “potential” and emissions are only estimates • Emissions growth expected for NOx only; CO and VOCs decreased for potential new weapon systems • Estimated 2.7% annual, cumulative, and compounded emission increase for potential new weapon systems and operational changes

14. Growth, continued • In addition, negotiated a growth of 4.4% for unanticipated projects (e.g., BRAC, National Security) • Total growth projected through 2015: 4154 ton/yr of NOx (11.4 tons/day) • SD Maintenance Plan (MP) can accommodate the growth because of anticipated significant decline in vehicle emissions • NRSW/MC can have access to the entire growth as soon as the MP is approved • Internal DON system neededto track projects and amount of SIP budget used

15. Other Progress to Date • NALF SCI: negotiated 1% annual growth • NAS Lemoore: negotiated 850 tons of NOx and 356 tons of VOC growth • NBVC: submitted 4.4% annual NOx growth factor to VCAPCD • NAWS China Lake: Searles Valley APCD has incorporated growth factor • NAF El Centro: Has begun discussion with ICAPCD; developed baseline

16. Lessons Learned • Key to success: Cooperative effort with regulatory agency • Make contact with the local air agency ASAP to determine SIP schedule- They need data two years before the SIP update is due • The new 8-hr standards present an opportunity • Calculate accurate mobile source baseline as a one-time investment • Collect as much growth data as possible by getting the right people involved • Ask for reasonable growth based on strong backup data

17. Points of Contact • NRSW: Jose Casora (619-524-6502) Jose.Casora@navy.mil • NRSW: Mike Huber (619-524-6264) Michael.Huber@navy.mil • URS: Massie Hatch (714-433-7710) massie_hatch@urscorp.com