Phase II Allowances Allocations and an Assessment of the Allowance Market in the West

Title IV of the Clean Air Act Amendments of 1990 establishes a unique “market-based“ approach to reduce national electric utility sulfur dioxide (SO₂) emissions during the next century by about 10 million tons/year below the corresponding level in 1980. This program is designed to provide utility operators with the flexibility to achieve the applicable SO₂ emissions limitations (total tons) using the most cost-effective approach. However, in reality, it is unlikely that many utility operators would have such operational flexibility, especially in the case of plants located in the Western United States. This is due to the fact that these sources may also be subject to other more stringent provisions of the Act, such as to protect public health and visibility, which override the Title IV provisions.

This paper examines the Phase II allowance allocations for the utility units located in the 11 western states and assesses the potential impacts of the current federal/state air quality regulatory programs on the allowance market in the West. This analysis shows that, even after accounting for the projected population growth and the accompanying growth in electric power demand during the next decade, the West should have a surplus of allowances, especially if new regulations are initiated to further reduce SO₂ emissions, mainly for the purpose of improving visibility in Western Class I areas.     

Supply Curves for Using Powder River Basin Coal to Reduce Sulfur Emissions

Abstract

Supply curves were prepared for coal-fired power plants in the contiguous United States switching to Wyoming's Powder River Basin (PRB) low-sulfur coal. Up to 625 plants, representing ～44% of the nameplate capacity of all coal-fired plants, could switch. If all switched, more than $8.8 billion additional capital would be required and the cost of electricity would increase by up to $5.9 billion per year, depending on levels of plant derating. Coal switching would result in sulfur dioxide (SO₂) emissions reduction of 4.5 million t/yr. Increase in cost of electricity would be in the range of 0.31-0.73 cents per kilowatt-hour. Average cost of S emissions reduction could be as high as $1298 per t of SO₂. Up to 367 plants, or 59% of selected plants with 32% of 44% nameplate capacity, could have marginal cost in excess of $1000 per t of SO₂. Up to 73 plants would appear to benefit from both a lowering of the annual cost and a lowering of SO₂ emissions by switching to the PRB coal.     

Cost-Effective Reduction of NOx Emissions from Electricity Generation

ABSTRACT

This paper analyzes the benefits and costs of policies to reduce NO_x emissions from electricity generation in the United States. Because emissions of NOx contribute to the high concentration of atmospheric ozone in the eastern states associated with health hazards, the U.S. Environmental Protection Agency (EPA) has called on eastern states to formulate state implementation plans (SIPs) for reducing NO_x emissions. Our analysis considers three NO_x reduction scenarios: a summer seasonal cap in the eastern states covered by EPA's NO_x SIP Call, an annual cap in the same SIP Call region, and a national annual cap. All scenarios allow for emissions trading. Although EPA's current policy is to implement a seasonal cap in the SIP Call region, this analysis indicates that an annual cap in the SIP Call region would yield about $400 million more in net benefits (benefits less costs) than would a seasonal policy, based on particulate-related health effects only. An annual cap in the SIP Call region is also the policy that is most likely to achieve benefits in excess of costs. Consideration of omissions from this accounting, including the potential benefits from reductions in ozone concentrations, strengthens the finding that an annual program offers greater net benefits than does a seasonal program.     

1990 Thermal Remediation Industry Contractor Survey

The treatment of soil contaminated with organics and inorganics is becoming a major industry in the United States and Europe. The soil cleanup bill for the United States could run as high as $200 to $300 billion over the next 30 to 40 years. European soil cleanup costs could run as high as $130 billion.¹

The types of sites in the United States that will require soil treatment can be broken down into the following categories: ? CERCLA (Superfund) Actions

? RCRA Corrective Actions

? RCRA Closures

? Underground Storage Tanks

? Real Estate Transfers

? Spill Clean-ups.

The cleanup of sites in each of these categories, with the exception of the Real Estate Transfer category, is being driven by different sets of Federal regulations. Real Estate Transfer type regulations were first instituted in New Jersey and have now been promulgated in a number of other states.

The eventual cleanup cost for the Superfund sites will be close to $200 billion. Estimated costs for the industrial sector Superfund are $25 to $50 billion and the estimated cost for the Department of Energy sites is over $150 billion.2 An early RCRA Corrective Action cleanup estimate is $25 billion.3 This estimate may well be low, however, since the permitting, cleanup and delisting criteria are still not clearly defined. The EPA’s RCRA Corrective Action cost estimate is $7.4 billion. However, the Office of Management and Budget feels that this estimate is low.⁴

The potential magnitude of the cleanup costs has resulted in the development and implementation of many technologies for the decontamination of soils. Of the available remedial technologies, thermal treatment has perhaps had the most field testing. The purpose of this paper is to focus on the full scale site remediations which have been or are being conducted using thermal processing equipment. Projects which have been completed, are on-going, or have been contracted for, through January of 1990 are described.     

Cost-effective reduction of NOx emissions from electricity generation.

This paper analyzes the benefits and costs of policies to reduce NOx emissions from electricity generation in the United States. Because emissions of NO contribute to the high concentration of atmospheric ozone in the eastern states associated with health hazards, the U.S. Environmental Protection Agency (EPA) has called on eastern states to formulate state implementation plans (SIPs) for reducing NOx emissions. Our analysis considers three NOx reduction scenarios: a summer seasonal cap in the eastern states covered by EPA's NOx SIP Call, an annual cap in the same SIP Call region, and a national annual cap. All scenarios allow for emissions trading. Although EPA's current policy is to implement a seasonal cap in the SIP Call region, this analysis indicates that an annual cap in the SIP Call region would yield about $400 million more in net benefits (benefits less costs) than would a seasonal policy, based on particulate-related health effects only. An annual cap in the SIP Call region is also the policy that is most likely to achieve benefits in excess of costs. Consideration of omissions from this accounting, including the potential benefits from reductions in ozone concentrations, strengthens the finding that an annual program offers greater net benefits than does a seasonal program.     

Assessing the impact of the acid deposition control program

A goal of the acidic deposition control program in the United States has been to link emissions control policies, such as those mandated under Title IV of the US Clean Air Act Amendments (CAAA) of 1990, to improvements in air and water quality. Recently, several researchers have reported trends in the time series of pollutant data in an effort to evaluate the effectiveness of the CAAA in reducing the acidic deposition problem. It is well known that pollutant concentrations are highly influenced by meteorological and climatic variations. Also, spatial and temporal inhomogeneities in time series of pollutant concentrations, induced by differences in the data collection, reduction, and reporting practices, can significantly affect the trend estimates. We present a method to discern breaks or discontinuities in the time series of pollutants stemming from emission reductions in the presence of meteorological and climatological variability. Using data from a few sites, this paper illustrates that linear trend estimates of concentrations of SO₂, aerosol SO₄²⁻, and precipitation-weighted SO₄²⁻ and NO₃⁻ can be biased because of such complex features embedded in pollutant time series.     

Product Gudie/1987

A computer program has been written to determine the cost of building and operating wet scrubbers on individual coal fired utilities in the states where emissions are likely to affect the acid rain problem in the eastern United States. The program differs from many other estimates since it calculates the cost for each of 831 individual sites. The capital costs for installing scrubbers on the top fifty sulfur oxide emitting plants will be about $20 billion. This will result in an increase in the cost of electricity on an average of 0.88 cents/kWh and a reduction of sulfur oxide emissions from 1980 of 7,100,000 tons per year. An additional reduction of at least 1,000,000 tons per year can be obtained by requiring all plants burning oil to burn low sulfur oil. These figures assume utilities will use least emissions dispatching and will use local coals containing at least 3.5 percent sulfur. The use of local coals should result in a further saving of at least 0.2 cents/kWh. This should make available a large supply of low sulfur coal which could reduce emissions of sulfur oxides by up to 1,000,000 tons per year. The SO₂ reductions will be continued for at least the next thirteen years and have a very significant effect through the year 2010.     

Examining Impacts of Visibility and PM Strategies before Implementation

ABSTRACT

One of the major challenges facing the world today is defining paths to sustainable futures. Part of the challenge is developing a national energy strategy that promotes an adequate energy supply for the United States, while enhancing environmental quality and maintaining U.S. competitiveness in the world economy. To assist in this challenge, we have developed a screening technique to analyze the effectiveness of different proposed emissions reduction strategies. The technique, referred to as the visibility assessment screening technique (VAST), is designed to examine possible impacts on visibility of emission changes of sulfur oxides, nitrogen oxides, volatile organic compounds (i.e., SO₂, NO_x, and VOC) and fine and coarse particulate matter (PM). The influence of relative humidity, natural aerosols, and the chemical interconnections among sulfur and nitrogen components of aerosols in determining the effectiveness of Clean Air Act Amendment and other projected energy-related emissions changes on eastern and western visibility are explored.

The effectiveness of these strategies on particulate matter impacts and potentially on ozone is also noted.     

The benefits of lower ozone due to air pollution emission reductions (2002–2011) in the Eastern United States during extreme heat

ABSTRACT

Using the Community Multiscale Air Quality (CMAQ) model and the Benefits Mapping and Analysis Program – Community Edition (BenMAP-CE) tool, we estimate the benefits of anthropogenic emission reductions between 2002 and 2011 in the Eastern United States (US) with respect to surface ozone concentrations and ozone-related health and economic impacts, during a month of extreme heat, July 2011. Based on CMAQ simulations using emissions appropriate for 2002 and 2011, we estimate that emission reductions since 2002 likely prevented 10– 15 ozone exceedance days (using the 2011 maximum 8-hr average ozone standard of 75 ppbv) throughout the Ohio River Valley and 5– 10 ozone exceedance days throughout the Washington, DC – Baltimore, MD metropolitan area during this extremely hot month. CMAQ results were fed into the BenMAP-CE tool to determine the health and health-related economic benefits of anthropogenic emission reductions between 2002 and 2011. We estimate that the concomitant health benefits from the ozone reductions were significant for this anomalous month: 160–800 mortalities (95% confidence interval (CI): 70–1,010) were avoided in July 2011 in the Eastern U.S, saving an estimated $1.3–$6.6 billion (CI: $174 million–$15.5 billion). Additionally, we estimate that emission reductions resulted in 950 (CI: 90–2,350) less hospital admissions from respiratory symptoms, 370 (CI: 180–580) less hospital admissions for pneumonia, 570 (CI: 0–1650) less Emergency Room (ER) visits from asthma symptoms, 922,020 (CI: 469,960–1,370,050) less minor restricted activity days (MRADs), and 430,240 (CI: ?280,350–963,190) less symptoms of asthma exacerbation during July 2011.

Implications: We estimate the benefits of air pollution emission reductions on surface ozone concentrations and ozone-related impacts on human health and the economy between 2002 and 2011 during an extremely hot month, July 2011, in the eastern United States (US) using the CMAQ and BenMAP-CE models. Results suggest that, during July 2011, emission reductions prevented 10-15 ozone exceedance days in the Ohio River Valley and 5-10 ozone exceedance days in the Mid Atlantic; saved 160-800 lives in the Eastern US, saving $1.3 - $6.5 billion; and resulted in 950 less hospital admissions for respiratory symptoms, 370 less hospital admissions for pneumonia, 570 less Emergency Room visits for asthma symptoms, 922,020 less minor restricted activity days, and 430,240 less symptoms of asthma exacerbation.     

The midlatitude North American background aerosol and global aerosol variation

Protocols for the particulate matter (PM) National Ambient Air Quality Standards (NAAQS), and the Regional Haze Rule (RHR) give two complementary definitions for "natural" background airborne particle concentrations in the United States. The definition for the NAAQS derives largely from reported annual averages, whereas the definition for the RHR takes into account the frequency of occurrence of a range of visibility conditions estimated using fine particle composition. These definitions are simple, static representations of background or "unmanageable" aerosol conditions in the United States. An accumulation of data from rural-remote sites representing global conditions indicates that the airborne particle concentrations are highly variable. Observational campaigns show weather-related variations, including incidents of regional or intercontinental transport of pollution that influence background aerosol levels over midlatitude North America. Defining a background in North America based on long-term observations relies mainly on the remote-rural IMPROVE network in the United States, with a few additional measurements from Canada. Examination of the frequency of occurrence of mass concentrations and particle components provides insight not only about annual median conditions but also the variability of apparent background conditions. The results of this analysis suggest that a more elaborate approach to defining an unmanageable background could improve the present approach taken for information input into the U.S. regulatory process. An approach interpreting the continental gradients in fine PM (PM2.5) concentrations and composition may be warranted.     

Extending the Kolmogorov–Zurbenko Filter: Application to Ozone,Particulate Matter,and Meteorological Trends

Abstract

Tropospheric ozone (O₃) and particulate matter (PM) are pollutants of great concern to air quality managers. Federal standards for these pollutants have been promulgated in recent years because of the known adverse effects of the pollutants on human health, the environment, and visibility. Local meteorological conditions exert a strong influence over day‐to‐day variations in pollutant concentrations; therefore, the meteorological signal must be removed in order for air quality planners and managers to examine underlying emissions-related trends and make better air quality management decisions for the future. Although the Kolmogorov–Zurbenko (KZ) filter has been widely used for this type of trend separation in O₃ studies in the eastern United States, this article aims to extend the method in three key ways. First, whereas the KZ filter is known as a useful tool for O₃ analysis, this study also evaluates its effectiveness when applied to PM. Second, the method was applied to Tucson, AZ, a city in the semi‐arid southwestern United States (Southwest), to evaluate the appropriateness of the method in a region with weaker synoptic weather controls on air quality than the eastern United States. Third, additional forms of output were developed and tailored to be more applicable to decision-makers’ needs through a partnership between academic researchers and air quality planners and managers. Results of the study indicate that the KZ filter is a useful method for examining emissions‐related PM trends, resulting in small, but potentially significant, differences after adjustment. For the Tucson situation with weaker synoptic controls, the KZ method identified mixing height as a more important variable than has been found in other cities.     

High Resolution Characterization of Ozone Data for Sites Located in Forested Areas of the United States

Eight years of ambient monitoring data (1978-1985) were used to characterize O₃ concentrations in eight forested areas of the United States. The analysis focused on the annual number of occurrences of hourly averaged O₃ concentrations ≥0.07, 0.08, and 0.10 ppm during the growing season (April-October) as well as during the early (April-June) and late (July-October) portions of the growing season. On the average, within those areas studied, elevated O₃ concentrations occurred more often in the Piedmont/Mountain/Ridge-Valley and Ohio River Valley areas than elsewhere. In the eastern United States, 1978, 1980, and 1983 were generally the years with the most occurrences of elevated O₃ concentrations. In these years, the later part (July-October) of the growing season experienced more elevated concentrations than the earlier part. The results presented in this analysis were used to develop recommendations for future O₃ effects research with respect to forested areas and related exposure regimes.     

Photochemical model performance for PM2.5 sulfate,nitrate, ammonium,and precursor species SO2, HNO3, and NH3 at background monitor locations in the central and eastern United States

Health studies have shown premature death is statistically associated with exposure to particulate matter <2.5 μm in diameter (PM2.5). The United States Environmental Protection Agency requires all States with PM2.5 non-attainment counties or with sources contributing to visibility impairment at Class I areas to submit an emissions control plan. These emission control plans will likely focus on reducing emissions of sulfur oxides and nitrogen oxides, which form two of the largest chemical components of PM2.5 in the eastern United States: ammonium sulfate and ammonium nitrate. Emission control strategies are simulated using three-dimensional Eulerian photochemical transport models.A monitor study was established using one urban (Detroit) and nine rural locations in the central and eastern United States to simultaneously measure PM2.5 sulfate ion (SO₄²⁻), nitrate ion (NO₃⁻), ammonium ion (NH₄⁺), and precursor species sulfur dioxide (SO₂), nitric acid (HNO₃), and ammonia (NH₃). This monitor study provides a unique opportunity to assess how well the modeling system predicts the spatial and temporal variability of important precursor species and co-located PM2.5 ions, which is not well characterized in the central and eastern United States.The modeling system performs well at estimating the PM2.5 species, but does not perform quite as well for the precursor species. Ammonia is under-predicted in the coldest months, nitric acid tends to be over-predicted in the summer months, and sulfur dioxide appears to be systematically over-predicted. Several indicators of PM2.5 ammonium sulfate and ammonium nitrate formation and chemical composition are estimated with the ambient data and photochemical model output. PM2.5 sulfate ion is usually not fully neutralized to ammonium sulfate in ambient measurements and is usually fully neutralized in model estimates. The model and ambient estimates agree that the ammonia study monitors tend to be nitric acid limited for PM2.5 nitrate formation. Regulatory strategies in this part of the country should focus on reductions in NO_X rather than ammonia to control PM2.5 ammonium nitrate.     

Marginal PM25: Nonlinear Aerosol Mass Response to Sulfate Reductions in the Eastern United States

ABSTRACT

Reductions in airborne sulfate concentration may cause inorganic fine particulate matter (PM₂₅) to respond nonlinearly, as nitric acid gas may transfer to the aerosol phase. Where this occurs, reductions in sulfur dioxide (SO₂) emissions will be much less effective than expected at reducing PM_2.5. As a measure of the efficacy of reductions in sulfate concentration on PM , we define marginal PM_2.5 as the local change in PM_2.5 resulting from a small change in sulfate concentration. Using seasonal-average conditions and assuming thermodynamic equilibrium, we find that the conditions for PM_2.5 to respond nonlinearly to sulfate reductions are common in the eastern United States in winter, occurring at half of the sites considered, and uncommon in summer, due primarily to the influence of temperature. Accounting for diurnal and intraseasonal variability, we find that seasonal-average conditions provide a reasonable indicator of the time-averaged PM_2.5 response. These results indicate that reductions in sulfate concentration may be up to 50% less effective at reducing the annual-average PM_2.5 than if the role of nitric acid is neglected. Further, large reductions in sulfate will also cause an increase in aerosol nitrate in many regions that are the most acidic.     

An Operational Assessment of the Application of the Relative Reduction Factors in the Demonstration of Attainment of the 8-Hr Ozone National Ambient Air Quality Standard

Abstract

The U.S. Environmental Protection Agency in 1997 revised the 1-hr ozone (O₃) National Ambient Air Quality Standard (NAAQS) to one based on an 8-hr average, resulting in potential nonattainment status for substantial portions of the eastern United States. The regulatory process provides for the development of a state implementation plan that includes a demonstration that the projected future O₃ concentrations will be at or below the NAAQS based on photochemical modeling and analytical techniques.

In this study, four photochemical modeling systems, based on two photochemical models, Community Model for Air Quality and the Comprehensive Air Quality Model with extensions, and two emissions processing models, Sparse Matrix Optimization Kernel for Emissions and Emissions Modeling System, were applied to the eastern United States, with emphasis on the northeastern Ozone Transport Region in terms of their response to oxides of nitrogen and volatile organic carbon-focused controls on the estimated design values. With the 8-hr O₃ NAAQS set as a bright-line test, it was found that a given area could be termed as being in or out of attainment of the NAAQS depending upon the modeling system. This suggests the need to provide an estimate of model-to-model uncertainty in the relative reduction factor (RRF) for a better understanding of the uncertainty in projecting the status of an area's attainment. Results indicate that the model-to-model differences considered in this study introduce an uncertainty of the future estimated design value of ～3–5 ppb.     

An Ex Post Cost-Benefit Analysis of the Nitrogen Dioxide Air Pollution Control Program in Tokyo

ABSTRACT

The benefits and costs of past nitrogen dioxide (NO₂) control policies were calculated for Tokyo, Japan, using environmental, economic, political, demographic, and medical data from 1973 to 1994. The benefits of NO₂ control were estimated as medical expenses and lost work time due to hypothetical no-control air concentrations of NO₂. Direct costs were calculated as annualized capital expenditures and 1 year's operating costs for regulated industries plus governmental agency expenses. The major findings were as follows:

(1) Using Tokyo's average medical cost of pollution-related illness, the best net estimate of the avoided medical costs due to incidence of phlegm and sputum in adults was 730 billion yen ($6.08 billion; 1 U.S. dollar = 120 yen).

(2) The best net estimate of the avoided medical costs due to incidence of lower respiratory illness in children was 93 billion yen ($775 million).

(3) Using Tokyo's average duration of pollution-related illness and average wages, the best net estimate of the avoided costs of lost wages in workers was 760 billion yen ($6.33 billion).

(4) The best net estimate of the avoided costs of lost wages in mothers caring for their sick children was 100 billion yen ($833 million).

(5) Using Tokyo-specific data, the best net costs were estimated as 280 billion yen ($2.33 billion).

(6) Using human health and productivity benefits, and annualized capital cost and operating cost estimates, the best net benefits-to-costs ratio was 6:1 (upper limit 44:1; lower limit 0.3:1). Benefit calculations were sensitive to assumptions of mobile source emissions and certain health impacts that were not included. Cost calculations were highly dependent on assumptions of flue gas volume and fuel use. For comparative purposes, we identified other studies for air pollution-related illness. Assumptions that formed the basis for most of the inputs in the present study, such as duration of illness, medical treatment costs, per person illness in children, and lost wages for working mothers, were similar to those recommended in the literature. Lost wages in sick workers and per capita illness incidence in adults were higher than numbers reported elsewhere. Further advances in cost-benefit analysis (CBA) procedures to evaluate the economic effectiveness of NO₂ controls in Tokyo are recommended to estimate impacts and values for additional human health benefits, ecosystem health and productivity effects, and nonliving system effects, as well as benefits of ancillary reductions in other pollutants. The present study suggests that Tokyo's past NO₂ control policies in total were economically quite effective.     

A reanalysis of fine particulate matter air pollution versus life expectancy in the United States

A reduction in population exposure to fine particulate matter air pollution (PM2.5) has been associated with improvements in life expectancy. This article presents a reanalysis of this relationship and comments on the results from a study on the reduction of ambient air PM_2.5 concentrations versus life expectancy in metropolitan areas of the United States. The results of the reanalysis show that the statistical significance of the correlation is lost after removing one of the metropolitan areas from the regression analysis, suggesting that the results may not be suitable for a meaningful and reliable inference.

Implications: The observed loss of statistical significance in the correlation between the reduction of ambient air PM_2.5 concentrations and life expectancy in metropolitan areas of the United States, after removing one of the metropolitan areas from the regression analysis, may raise concern for the policymakers in decisions regarding further reductions in permitted levels of air pollution emissions.     

Examining impacts of visibility and PM strategies before implementation

One of the major challenges facing the world today is defining paths to sustainable futures. Part of the challenge is developing a national energy strategy that promotes an adequate energy supply for the United States, while enhancing environmental quality and maintaining U.S. competitiveness in the world economy. To assist in this challenge, we have developed a screening technique to analyze the effectiveness of different proposed emissions reduction strategies. The technique, referred to as the visibility assessment screening technique (VAST), is designed to examine possible impacts on visibility of emission changes of sulfur oxides, nitrogen oxides, volatile organic compounds (i.e., SO2, NOx, and VOC) and fine and coarse particulate matter (PM). The influence of relative humidity, natural aerosols, and the chemical interconnections among sulfur and nitrogen components of aerosols in determining the effectiveness of Clean Air Act Amendment and other projected energy-related emissions changes on eastern and western visibility are explored. The effectiveness of these strategies on particulate matter impacts and potentially on ozone is also noted.     

Air pollutant source characterization using the revised regional haze tracking metric and a photochemical grid model and implications for regional haze planning

The 2017 revisions to the Regional Haze Rule clarify that visibility progress at Class I national parks and wilderness areas should be tracked on days with the highest anthropogenic contributions to haze (impairment). We compare the natural and anthropogenic contributions to haze in the western United States in 2011 estimated using the Environmental Protection Agency (EPA) recommended method and using model projections from the Comprehensive Air Quality Model with Extensions (CAMx) and the Particulate Source Apportionment Tool (PSAT). We do so because these two methods will be used by states to demonstrate visibility progress by 2028. If the two methods assume different natural and anthropogenic contributions, the projected benefits of reducing U.S. anthropogenic emissions will differ. The EPA method assumes that episodic elevated carbonaceous aerosols greater than an annual 95th percentile threshold are natural events. For western U.S. IMPROVE monitoring sites reviewed in this paper, CAMx-PSAT confirms these episodes are impacted by carbon from wildfire or prescribed fire events. The EPA method assumes that most of the ammonium sulfate is anthropogenic in origin. At most western sites CAMx-PSAT apportions more of the ammonium sulfate on the most impaired days to global boundary conditions and anthropogenic Canadian, Mexican, and offshore shipping emissions than to U.S. anthropogenic sources. For ammonium nitrate and coarse mass, CAMx-PSAT apportions greater contributions to U.S. anthropogenic sources than the EPA method assigns to total anthropogenic contributions. We conclude that for western IMPROVE sites, the EPA method is effective in selecting days that are likely to be impacted by anthropogenic emissions and that CAMx-PSAT is an effective approach to estimate U.S. source contributions. Improved inventories, particularly international and natural emissions, and further evaluation of global and regional model performance and PSAT attribution methods are recommended to increase confidence in modeled source characterization.

Implications: The western states intend to use the CAMx model to project visibility progress by 2028. Modeled visibility response to changes in U.S. anthropogenic emissions may be less than estimated using the EPA assumptions based on total U.S. and international anthropogenic contributions to visibility impairment. Additional model improvements are needed to better account for contributions to haze from natural and international emissions in current and future modeling years. These improvements will allow more direct comparison of model and EPA estimates of natural and anthropogenic contributions to haze and future visibility progress.