colorado regional haze sip reasonable progress analysis rocky mountain national park longs peak –...

Colorado Regional Haze SIP Colorado Regional Haze SIP Reasonable Progress AnalysisReasonable Progress Analysis

Rocky Mountain National Park Longs Peak – 14,259’Colorado’s 15th Tallest

Curt TaipaleColorado DPHE - APCD

Topics

• Analysis Context• UP vs RP

– What is reasonable?

• Preliminary 2018 Modeling Results for Colorado

• RP Analysis for Rocky Mountain NP– Sulfate & Nitrate PSAT– Boundary Conditions & International impacts– Organic Carbon– Elemental Carbon– Fine Soil– Coarse Mass

• Final Thoughts

Analysis Context

• Time is short – SIPs are due in December– Ideally, today’s Reasonable Progress analysis should be based on

final BART modeling for the whole WRAP region– Realistically, it’s too late to implement additional controls beyond

BART • In lieu of these limitations, Colorado plans “State Share”

analysis for determining RP on the dominant man-caused species of visibility impairing pollutants – sulfate & nitrate– Assumes that each state is working on emission reduction

strategies that benefit all impacted Class I Areas– Some CIAs w/high out-of-state impacts may not benefit from this

approach• Can be addressed through interstate collaboration

• OC addressed with limited PSAT; EC, CM & fine soil can be addressed through a more basic analysis using weighted emission potential (WEP), emission inventory (EI), positive matrix factorization (PMF) and Emissions Trace (ET)

• Analysis focused on Worst Days– Assume 2018 model projections are adequate for estimating

maintenance of Best Days– Future IMPROVE monitoring will validate this assumption

Uniform Progress vs Reasonable Progress

• For Colorado, we will assume the overall 2018 UP goal in Haze Index metric (deciviews) is 14/60ths or about 23% – UP is a goal that is defined by the 60-year glide slope

• UP not necessarily equal to Reasonable Progress• RP is unique to each CIA (or IMPROVE monitor), and/or

component of visibility extinction.

Start Year

Planning Period

RH SIP Submittal Year*

RH SIP Horizon Year

Planning Period [years]

Percent Reduction Goal

1st 2008 2018 14 23.3%2nd 2018 2028 10 16.7%3rd 2028 2038 10 16.7%4th 2038 2048 10 16.7%5th 2048 2058 10 16.7%6th 2058 2064 6 10.0%

Total: 60 100.0%

*Plans submitted toward the end of year are counted in the following year and 5-year plan updates not included.

Regional Haze State Implementation Plan Schedule

2004

Species-Specific Approach to RP

URP depends on metric• In the Haze Index (deciview) metric, the URP goal is 23.3%,

but in the Extinction (1/Mm) metric, the species-specific URP goal is different for each component of extinction due to the non-linear relationship & site-specific Rayleigh

HI = 10ln(bext/10)

Relationship between Haze Index & Extinction

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Delta = 23% Delta = 23%

Delta = 18.7% @ 10 Rayleigh

Measure Progress from Glide Slope

• In the extinction metric, 23% is not the goal for each species, 2018 modeling progress is measured against the URP point on glide slope.

• Non-linearity between extinction and HI is addressed by the curve of the extinction glide slope.

• For ROMO, the corresponding 2018 extinction reduction is about 28%

Preliminary 2018 Modeling Results

(three RRFs methods averaged)

Rocky Mountain National Park• 265,000 acres on the

Continental Divide• 2.5 million

visitors/year• 1st area in US with

critical load – 1.5 kg N/ha/yr (wet nitrogen deposition)

Rocky Mountain National Park –BD/WD Composition

Highest Sulfate & Nitrate in Colorado

ROMO – Best Days• 64 FR 35766 requires the RP goal for each CIA: “.. ensure

no degradation in visibility for the least impaired days ..”• Is a glide slope analysis necessary?

– Rule requires maintenance not improvement of best days

• 2018 modeling below 2000-2004 best days baseline of 2.29 dv

• Thus - maintenance of best days is forecast for 2018

Rocky Mountain National Park Species-Specific Uniform Progress & 2018 (plan02c) Modeling for Worst Days

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Preliminary 2018 Modeling – Species-Specific for Worst Days

Preliminary 2018 Modeling – Haze Index for Worst Days

Rocky Mountain National Park Haze Index Uniform Progress & Preliminary 2018 Modeling for 20% Worst Days

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Quarterly RRF

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Rocky Mountain NP – Uniform Progress Analysis

• In HI, the modeled reduction is around 13%, so we’d like an additional 10% reduction to make the 23% UP goal.

• More sulfate & nitrate reductions expected in next model run– Not all Colorado BART is included

• Additional reductions in SO2 and NOx will be in place by 2018• Biggest: Pawnee (505 MW) 13,500 tpy SO2

– Do we need additional emission reductions beyond BART? • Won’t know for sure until all CO BART controls are modeled• PSAT provides some clues on progress towards Colorado share

PSAT for Sulfate and Nitrate

• For sulfate & nitrate in 2018, the overall reductions 50%– Colorado will rely on other contributing states to do their

part– Need another 20%-33% to just meet the UP goal

• Colorado Share: 80% SO4 and 67% NO3 – Does Colorado need to do more?– CO BART modeling will provide more reductions in SO4 &

NO3– Will they be enough?

• Let’s look at other contributors.

4-Highest Sulfate & Nitrate Contributors at ROMO

• We see that Boundary Conditions are the highest contributor for SO4 and 2nd for NO3 at Rocky in 2018.

• Across Colorado, BCs are the highest sulfate contributor for all our CIAs and in the top 3 for nitrate.

Technique to address BCs

• Colorado may be unique, high BC impacts at our CIAs may be due to Colorado’s close proximity to the center of the model domain and our relatively clean air compared to the rest of the world.

• We can’t control the BC emissions entering from the edge of the modeling domain.

• BC Options– Control them – Can’t– Ignore them – Not, they are too big!– Remove them from the analysis – Yes!

• How do we do that?

Boundary Conditions/International (BCI)

Visibility Impacts• The PSAT BC visibility impacts are estimated by looking at the extinction difference (or delta) between 2018 CMAQ modeling and 2018 uniform rate of progress.

• We see that BCs represent 0.35 [1/Mm] of sulfate & nitrate extinction on the worst days at Rocky Mountain

• If we add in the international impacts of Canada, Mexico and Pacific Ocean the resultant extinction is 0.49 [1/Mm]

• This Boundary Condition/International (BCI) extinction is beyond the control of Colorado or any other State.

• Thus, Colorado will be removing BCI extinction estimates for SO4 & NO3 from the 2018 PSAT modeling.

BC CAN MEX PO Total2018 Modeling SO4 [1/Mm] 1.988 0.274 0.304 0.193

2018 URP Extinction SO4 [1/Mm] 1.725 0.238 0.264 0.167SO4 Delta Extinction [1/Mm] 0.262 0.036 0.040 0.025 0.364

2018 Modeling NO3 [1/Mm] 0.740 0.189 0.000 0.0692018 URP Extinction NO3 [1/Mm] 0.649 0.166 0.000 0.060

NO3 Delta Extinction [1/Mm] 0.091 0.023 0.000 0.008 0.1230.354 0.060 0.040 0.034 0.487

Source Region

Rocky Mountain National ParkSulfate & Nitrate Boundary Condition/International (BCI) Impacts on 20% Worst Days

Sulfate BCI delta extinction

Sulfate BCI extinction held to URP

Nitrate BCI delta extinction

Nitrate BCI extinction held to URP

Removing BCI from the 2018 Modeling

• Sulfate BCI deduction (0.364 1/Mm) from CMAQ 2018 modeling – Overall progress towards 2018 goal improves from 54% to 72% (+18%)

• Nitrate BCI deduction (0.123 1/Mm) from CMAQ 2018 modeling– Overall progress towards 2018 goal improves from 49% to 60% (+11%)

• Is it fair to remove the BCI impacts from the 2018 modeling?– In the context of truly improving visibility at a CIA –probably not.– For CIAs close to UP and on the cusp of triggering additional State

controls, this analysis properly accounts for impacts beyond the control of a state.

– Further, “Is it fair to require more reductions from other sources to compensate for BCI impacts?” – maybe not in the 1st planning period

ROMO Sulfate RP• Overall, SO4 is 28% short of 2018 URP

– Colorado anticipates that SO2 emission reductions from WY (7.7% Impact) and CEN (7.2% Impact) will provide improved progress in 2018.

– It is unreasonable for Colorado to provide additional SO2 reductions beyond CO share.

• Colorado share of SO4 reductions fall short of CO UP goal by 20%, thus additional sulfate controls may be warranted. – New 2018 CMAQ modeling (done in May 07?) of CO BART will likely

provide additional reductions (moderate) in sulfate impacts at the Park

– Existing modeling analysis shows some CO BART SO2 reductions that occurred early under the Metro VERA, and consent decrees on Craig & Hayden

– Until CO BART is modeled, Division staff is hesitant to suggest additional sulfate controls.

• Will CO BART SO2 reductions yield a ROMO SO4 >20% ? - maybe– If CO BART modeling falls short, the timing of quantifying the

benefits of additional SO2 controls, would likely occur after the RH SIP submittal date.

• Intuitively, we suspect coal-fired boilers and IC engines are the major source of most of the SO2 at ROMO but are there other uncontrolled or under-controlled source categories?– lets looks at the Sulfate ET - Whats that?

ROMO 2018 Sulfate Emissions Trace

ROMO Nitrate RP • Overall, NO3 is 40% short of 2018 URP

– Colorado anticipates that NOx emission reductions from WY (11.0%) and UT (5.9%) will provide improved progress in 2018.

– It is unreasonable for Colorado to provide additional NOx reductions beyond CO share.

• Colorado share of NO3 reductions fall short of CO UP goal by 33%, thus additional nitrate controls are likely warranted– New 2018 CMAQ modeling of CO BART will provide some minor

reductions in nitrate impacts at the Park but probably not near enough to make CO NO3 UP

– Top 100 under controlled or uncontrolled point sources (largest contributor) nearby the Park will be evaluated for controls

– Timing of quantifying the benefits of additional NOx controls, would likely occur after the RH SIP submittal date.

• Through stakeholder process, Division will develop RH-RP regulation that will establish process for deciding controls/sources

• Intuitively, we suspect coal-fired boilers, IC engines and mobile sources are the major sources of most of the NOx at ROMO but are there other uncontrolled or under controlled source categories?– lets looks at the Nitrate ET

ROMO 2018 Nitrate Emissions Trace

Top Colorado NOx

Point Sources• BART controlled sources

highlighted in green• Closest big non-BART NOx

source– Rawhide (285 MW) has LNB

w/OFA

ROMO Organic Carbon

Wild Basin Area of Rocky Mountain National Park, Thunder Lake (Photo courtesy of NPS)

Organic Carbon RP Analysis

• PSAT modeling allows for some limited analysis of OC under organic aerosol tracer for three species– AORGA: Secondary Organic Aerosol (SOA) Biogenic – AORGB: SOA Anthropogenic– AORGPA: Primary Organic Aerosol (POA) Anthro & Biogenic – Limitations: Source regions unknown – can’t use “State Share”

analysis tool

• Analysis Approach– Use PSAT to identify amount of extinction attributed to

biogenic– Use Positive Matrix Factorization (PMF) to further confirm

portion attributable to smoke– Use Weighted Emissions Potential (WEP) tools to identify

source regions & type emissions contributing to POA & VOC (forms SOA)

– Use POA & VOC emission inventories (plan 02 & base 18) to determine contributing sources & changes in anthropogenic portion

– Use OC ET to confirm sources

OC PSAT for Worst Days in 02b, 02c & 18b

• Modeled 2018 OC shows 27% (we need 100%), far short of OC UP goal (see slide 15)

• Based on OC PSAT for worst days, OC occurs over three seasons

• Not much seasonal variation

OC PSAT for 2018 Worst Days

• How much OC is controllable?• Since there isn’t much seasonal variation

in worst days, all seasons averaged– 71% AORGB (SOA Biogenic – in green)

• Likely VOCs from vegetation & wildfire smoke– Check PMF to see how much is smoke

• Wildfire is a necessary part of forest ecology • Thus, AORGB is not controllable

– 5% AORGA (SOA Anthropogenic – in red)• Mostly point, area, mobile

– Check VOC Emission Inventory for 02c & 18b– AORGA contribution to OC is very small

– 24% AORGPA (POA Biogenic/Anthro – in blue)• Mostly area & mobile, some biogenic

– Check POA Emission Inventory for 02c & 18b– Look at OC Emissions Trace

Positive Matrix Factorization (PMF)

• PMF indicates that smoke is a significant contributor (44%) to OC impairment on the worst days at ROMO during the baseline period

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Statewide & FR VOC Emission Changes

• Bar chart indicates sharp contrast between statewide & FR biogenic VOC

• In Front Range, area, point & mobile sources contribute 53% of the VOC emissions that could form SOA anthropogenic (5% of total OC)

• By 2018, FR area sources by 40% but mobile significantly• Lets look at the OC WEP to see the source regions impacting

ROMO

OC Weighted Emissions Potential (WEP) Map

• Realize the WEP tool doesn’t consider complex chemistry or deposition• OC WEP map indicates that the Front Range is the dominant source of anthro

OC• VOC WEP Bar Chart indicates that Colorado biogenics are the biggest source

of VOC (source of OC SOA), with anthropogenic sources (point, area & mobile) contributing a very little to OC SOA– Thus, even huge reductions in anthro VOC emissions would have little effect on OC

SOA

POA Weighted Emissions Potential (WEP)

• Remaining OC contributor is AORGPA- Primary Biogenic & Anthro– Primary Organic Aerosol (POA) emissions are the source of AORGPA

• We see that Colorado area sources & anthro fire are the largest contributors to POA

Sources and Areas of Potential Organic Carbon Emissions Influence2018 Projections for Rocky Mountain National Park, CO

20% Worst Visibility Days

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Statewide & FR POA Emission Changes

• 2018 POA emissions from natural/biogenic sources are insignificant <3%

• 2018 POA emissions from anthro sources (area, mobile & Rx fire) about 96%– We see FR area sources 4% by 2018, but mobile >26%

• Let’s look at the OC ET to put all this in perspective

ROMO 2018 OC Emissions Trace• POA is not inventoried in Colorado, thus area source POA is likely

modeled– How do we evaluate potential emission controls on such a category? Can’t

• Additional VOC controls on point & area sources would yield little OC SOA

• Division recommends that additional VOC or POA emission controls are not reasonable, thus OC RP is satisfied

ROMO Elemental Carbon

ROMO 2018 EC for Worst Days

• Modeled 2018 EC shows 127% which exceeds UP goal (see slide 15)

• Is this reduction reasonable progress?– What are the sources of EC?– Lets look to see if much more can be done?

• We see that 2018 EC (in black) appears to higher during the summer

ROMO PMF for EC• PMF indicates all categories (except dust) contribute

to EC

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Sulfate Rich-Secondary/Coal Combustion Profile

Sources and Areas of Potential Elemental Carbon Emissions Influence2018 Projections for Rocky Mountain National Park, CO


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On-Road Mobile Off-Road Mobile Road Dust Fugitive Dust WB Dust Anthro Fire

ROMO EC WEP for 2018 Worst Days• Remember the WEP analysis doesn’t consider complex

chemistry or deposition• EC WEP indicates that Area, On & Off-Road Mobile sources are

the largest contributors– Highest EC concentrations are from Denver metro area

FR & Statewide PEC Emission Changes

• Colorado area & mobile sources comprise over 97% of FR PEC emissions

• WRAP Area source pivot table doesn’t track EC emissions

Area Source Pivot

ROMO 2018 EC Emissions Trace• Overall PEC emissions 51% from Plan02c to Base18b• On & Off-road mobile sources 75% & 55% respectively and are

largely regulated under the federal rules– Other than VMT reductions, State would need to request EPA approval for CA

fuel & emission standards for on/off-road mobile sources –a lengthy & costly process

• Area sources 5%, Colorado doesn’t inventory EC emissions, thus area source EC is likely modeled– Not sure a 4-factor RP analysis can be done on modeled number

• Based on the analysis, the Division recommends that additional controls for EC are not reasonable, thus EC RP is satisfied

ROMO Soil (PM Fine)

http://www.summitpost.org/images/original/196276.jpg

ROMO 2018 Modeled Soil Projections

• Modeled 2018 Soil 344% (slide 15)– Soil glide slope is pretty flat, thus any small change is

exaggerated– Let’s look at the change in PM Fine emissions from plan02c to

plan18b

FR & Statewide Soil (PM Fine) Emissions• For 2018, statewide soil emissions 9% but FR 32%• Based on relative contribution, we see fugitives change the

most• Let’s look at Fine PM WEP

Sources and Areas of Potential Fine PM Emissions Influence2018 Projections for Rocky Mountain National Park, CO


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ROMO 2018 Soil WEP for Worst Days• WEP shows soil sources are widely scattered statewide with

the highest concentrations in FR corridor• Windblown & fugitive dust comprise about 51% of Colorado

impact• Colorado area & on-road mobile sources about 47%

ROMO 2018 PM Fine Emissions Trace

• What makes up on-road, area, fugitive and windblown dust?– Windblown– On-road Mobile – Ag tilling – Residential wood burning – Road construction– Industrial/Commercial Construction

ROMO 2018 PM Fine Emission Sources

• Windblown 0% change – modeled from land use & soil texture– Windblown is largely uncontrollable, thus no controls are considered

reasonable

• On-road Mobile 54% - PM Fine is from vehicle exhaust and re-entrained dust which is a function of silt loading, vehicle speed & VMT– Metro area has a diesel vehicle inspection program for particulates– Metro area encourages vehicle trip reductions through mass transit and silt

loading is addressed by municipal street sweeping programs, use of liquid deicers or coarse anti-skid materials and permit controls on construction track-out

– Portion attributed to unpaved roads is not known– Additional controls could include expanding the diesel vehicle program area,

expanding the use of street sweeping & use of liquid deicers, and paving busy unpaved roads in close proximity to ROMO

• Ag Tilling - for most agricultural crops, tilling is a necessity and largely uncontrollable– NRCS soil management plans address susceptible soils– State Ag Dept. encourages ag best management practices (no till, soil

conservation etc.),– Additional controls not considered reasonable

ROMO 2018 PM Fine Emission Sources -Continued

• Residential Wood Burning – Wood-fired stoves must meet EPA certifications statewide,

woodburning is limited during winter in Denver metro area and since 1990’s, new homes must have NG fueled fireplaces throughout metro area

– Additional controls could include expanding the new home woodburning exclusion area

• Road construction and Industrial/Commercial Construction – Division issues dust mitigation permits on all construction activities

disturbing more than 25 acres.– Additional controls could include tightening dust permit control

requirements or permit threshold

ROMO 2018 Soil Reasonable Progress Summary

• Did we make reasonable Soil progress at ROMO?• No, 2018 PM Fine emissions statewide 2,977 tpy (9%)

and in Front Range 2,585 tpy (32%) – 2018 Point, Area, On-Road Mobile & Fugitives all increased – 2018 Off-Road Mobile, Anthro Fire & Road Dust all

decreased

• Can we do more?– Division will evaluate additional controls such as:

• Expanding the Diesel Vehicle Inspection Control Area• Expanding the use of liquid MgCl deicers & street sweeping• Paving busy unpaved roads in close proximity to ROMO • Tightening land development permit control requirements• Reducing acreage threshold on land development permits statewide• Expanding the new home woodburning exclusion area to northern

Colorado

The Wall- ROMO Coarse MassThe Wall- ROMO Coarse Mass

Coarse Mass CMAQ modeling

• For all IMPROVE sites, CMAQ v4.5 under-predicts for all months by 20-150%

• For ROMO baseline worst days, CM seems highest during spring/summer/fall (Apr- For Oct) which corresponds to a CMAQ monthly error bias > -90%.

• Even a modeler would say this is not good– We need to use another analysis technique

ROMO 2018 Coarse Mass Projections

• CMAQ model holds 2018 CM modeling projections at baseline value

• CM needs about 0.9 [1/Mm] of visibility improvement needed by 2064– Without CMAQ modeling, we must use emission inventories and

WEP tools to see were we are going

FR & Statewide Coarse Mass (CM) Emissions

• For 2018, statewide fugitive dust emissions 63% but FR 210%– FR fugitives comprise 49% of dust emissions, windblown is 20%

ROMO 2018 CM WEP• 2018 CM WEP map shows that in addition to the FR, CM

sources on the west slope & eastern plains contribute significantly to ROMO

• WEP indicates that CO point, fugitives, windblown & road dust are the major contributors to CM with some WB impacts from CENRAP

• Let’s look at the CM ET

ROMO 2018 CM Emissions Trace• What makes up point, fugitives, windblown and road dust?

– Point: Mineral Products, Electric Generation, Site Remediation, Primary Metal Production, Solid Waste Disposal, Food & Agriculture

– Others: Ag Tilling, Road Construction, Industrial Construction, Residential Wood Burning & Residential Construction

2018 PM10 from Area Source Pivot Table doesn’t match up w/Emission Inventory

ROMO 2018 CM Emission Sources

• Point Sources 34% • Division issues NSR/PSD permits on all PM10 sources > 2 tpy• Major PM10 (>100 tpy) sources subject to BACT controls• Minor PM10 (<100 tpy) sources subject to RACT controls

– Mineral Products (60%)• 47% Sand & Gravel• 26% Coal Mining & Handling• 7% Stone Quarrying

– Electric Generation (11%) - mostly coal-fired boilers• Major PM10 sources have baghouse controls

– Site Remediation (6%) one source - Rocky Mountain Arsenal– Primary Metal Production (4%)– Solid Waste Disposal (4%) mostly municipal landfills

• Controlled to BACT/BACM levels ?– Food & Agriculture Production (4%)– Miscellaneous Manufacturing (4%)

• Appears point sources >2 tpy are reasonably controlled to BACT/RACT levels

ROMO 2018 CM Emission Sources - Continued

• Windblown 0% change – modeled from land use & soil texture– Windblown is largely uncontrollable, thus no controls are considered

reasonable• Fugitive Dust 63% & Road Dust 44%

– Ag Tilling (?%)- for most crops, tilling is a necessity & largely uncontrollable

• NRCS soil management plans address susceptible soils• State Ag Dept. encourages ag best management practices (no till, soil

conservation etc.),• Additional controls not considered reasonable

– Road Construction (46%)/ Industrial & Commercial Construction (30%) and Residential Construction (6%)

• Division issues dust mitigation permits on all construction activities disturbing more than 25 acres.

• Additional controls could include tightening dust permit control requirements or permit threshold

– Residential wood burning (6%)• Wood-fired stoves must meet EPA certifications statewide, woodburning is

limited during winter in Denver metro area and since 1990’s, new homes must have NG fueled fireplaces throughout Denver metro area

• Additional controls could include expanding the new home woodburning exclusion area

ROMO 2018 CM Reasonable Progress Summary

• Did we make reasonable CM progress at ROMO?• No, 2018 PM10 emissions statewide 41,125 tpy (18%)

and in Front Range 31,305 tpy (70%)– 2018 Point, On-Road Mobile, Road Dust & Fugitives all

increased – 2018 Area, Off-Road Mobile and Anthro Fire all decreased

• Can we do more?– Division will evaluate additional controls such as:

• Tightening land development permit control requirements• Reducing acreage threshold on land development permits statewide• Expanding the new home woodburning exclusion area to northern

Colorado

Final Thoughts

• Pivot tables can be tricky– Different SCC levels can tell you

different things

A view from space

Longs Peak

Estes Park

Allenspark

Rocky Mountain National

Park

NORTH

Extra Slides

Sulfate CMAQ modeling

• CMAQ v4.5 does pretty well in predicting wintertime SO4 but under-predicts in the summer months when concentrations are higher.

• For ROMO baseline worst days, sulfate seems highest during spring/summer (Apr-Aug) but winter/fall seasons periodically appear as significant contributors

• ROMO 2018b sulfate RRF is 0.82

Nitrate CMAQ modeling

• CMAQ v4.5 tends to over-predict nitrate in the winter months and under-predict in the summer months when concentrations are lower.

• For ROMO baseline worst days, nitrate seems highest during winter (Nov-Mar) but spring & summer seasons periodically appear as contributors

• ROMO 2018b nitrate RRF is 0.87

Organic Carbon CMAQ modeling

• CMAQ v4.5 does a really good job in predicting summertime OC but spring & fall OC is over-predicted by 10-20%

• For ROMO baseline worst days, OC seems highest during summer (Jun-Aug) but spring & fall seasons also appear as significant contributors

• ROMO 2018b OC RRF is 0.95

Elemental Carbon CMAQ modeling

• CMAQ v4.5 does a pretty good job in predicting summertime EC but spring & fall EC is under-predicted by 10-20%

• For ROMO baseline worst days, EC seems highest during summer (Jun-Aug) but spring & fall seasons also appear as significant contributors

• ROMO 2018b EC RRF is 0.74

Fine Soil CMAQ modeling

• CMAQ v4.5 under-predicts during the spring/summer/fall months by 10-80% and over predicts in the winter by 10-40%

• For ROMO baseline worst days, soil seems highest during spring/summer/fall (Apr-Oct)

• ROMO 2018b soil RRF is 1.15

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