Tacoma Clean Air Performance Commitment

1. Tacoma Clean Air Performance Commitment May 2010

2. What is CAPC? • Intended, ultimately, as an alternative to the current SIP process • EPA has demonstration projects underway in two areas: • Tacoma, WA • Omaha, NE/Council Bluffs, IA • CAPC Objectives? • Achieve same or greater environmental improvements as current process, while minimizing process • Create a more flexible/adaptable process, while incorporating measures to ensure accountability • Provide meaningful opportunities for the public to engage in the process

3. Why a CAPC in Tacoma? • EPA recognizes the need to make improvements to the state implementation planning (SIP) process to more efficiently and effectively address air quality challenges • The Tacoma area’s PM2.5 issue is strongly driven by a single source type (i.e. wood smoke) and the impacts of wood smoke are not easily evaluated by air quality models • Many of the potential wood smoke control measures may be voluntary or incentive based and not likely to receive significant SIP credit • The Washington Department of Ecology, the Puyallup Tribe, EPA, and the Agency all have regulatory authority over portions of the nonattainment area

4. Tacoma Nonattainment Area

5. Participants in the CAPC • EPA OAQPS • EPA Region 10 • Washington Department of Ecology • Puyallup Tribe • Puget Sound Clean Air Agency

6. Elements of the CAPC • MOU signed by CAPC parties • Performance agreement that focuses on attaining the NAAQS efficiently and effectively • Targeted local control measures that complement national measures • Establish agreed-upon technical or accountability metrics before the process begins so that all parties are in agreement on the end goal (i.e. how many wood burning appliances can the air shed support) • A community stakeholder process that results in meaningful public involvement and input regarding the SIP control measures (e.g. how to phase out wood burning appliances) • Ultimately, absent clean air, we will need to submit a SIP that contains all the elements necessary for EPA approval

7. Technical Analysis Components • Gather existing technical information on source attribution in the Tacoma area • Determine the capability of the existing grid model to predict PM2.5 concentrations in the Tacoma area - identify potential areas of weakness with the model • Identify and explore other modeling tools to evaluate control measures that would meet the modeling requirements in Appendix W of 40 CFR Part 50 and the PM2.5 Implementation Rule • Agree on types of modeling to be used • Conduct modeling runs on the effectiveness of potential control measures

8. Timeline for the CAPC • March/April 2010 – MOU signed by all CAPC parties • December 2010 - Complete and reach consensus on technical evaluation • January 2011 - Begin comprehensive stakeholder process assuming agreement on the technical approach • September 2011 - Complete comprehensive stakeholder process and document the prioritization of control measures • November 2011 – Incorporate the prioritized control measures into a Performance Agreement that documents how the control measures will be implemented • March 2012 – Complete public hearings on the SIP • July 2012 – Submit an approvable SIP

9. Scope of the Challenge • 150,000 households in nonattainment area • 20,000 have wood stoves (13% of households) • At least a third are uncertified • We doubt many of the certified catalytic stoves function properly • 10,000 have fireplace inserts (7% of households) • 30,000 have open fireplaces (20% of households) • Total of about 60,000 wood burning devices • We’ve spent over $2,000,000 in incentives over the last three years and have upgraded about 1,000 wood stoves and inserts with no discernable change in air quality