xvEPA
            United States
            Environmental Protection
            Agency
            Air And Radiation
            (6204J)
EPA430-R-95-001
February 1995
Acid Deposition Standard
Feasibility Study
Report To Congress

Draft For Public Comment

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                                   ACKNOWLEDGMENTS
The development of this Acid Deposition Standard
Feasibility Study involved the  cooperative efforts
of individuals  within  the  U.S.  Environmental
Protection Agency (EPA), especially the Office of
Air and Radiation's Acid Rain Division and the
Office of  Research  and Development's  Effects
Research  Laboratory  in  Corvallis, Oregon,  and
Atmospheric  Research Exposure and Assessment
Laboratory in Research Triangle Park, North Caro-
lina. Many individuals at EPA, particularly in the
Office  of Air Quality Planning  and Standards,
contributed useful  comments to  this report. EPA
also acknowledges The Cadmus  Group, Inc., for
their assistance  in preparing this  report  under
Contract Number 68-D2-0168.
                                               in

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                                        TABLE OF CONTENTS
Acknowledgments	Hi

List of Exhibits	vii

List of Acronyms and Abbreviations	xi

Executive Summary	xiii

1  Introduction	1

   What acid deposition levels are necessary
   to protect sensitive regions?	2

   What degree of protection is provided by
   Title IV?   What  is the residual  risk? What
   additional emissions limitations  would be
   required to protect sensitive regions?	3
   How would an acid deposition standard(s)
   be  implemented?  What are the different
   implementation approaches? What are the
   feasibility  and  effectiveness  relative  to
   other approaches?	
2  Environmental Goals .
.4

.7
   2.1  Introduction	7

   2.2  Basic Relationships in Surface Water
        Acidification and Recovery	8
        2.2.1  Relationship of  Base Cations,
               Sulfur,  and Nitrogen in Envi-
               ronmental Acidification	10
        2.2.2  Episodic Acidification	12
        2.2.3  Cumulative Loading Effects	13
        2.2.4  Recovery of Acidified Ecosys-
               tems	14

   2.3  Characterizing  Resources  at  Risk
        from Acidic Deposition	15
        2.3.1  Defining Sensitive Resources	15
        2.3.2  Identifying Resources at Risk	17

   2.4  Identification  of Resource  and Re-
        gional Priorities	18
        2.4.1  United States	18
        2.4.2  Identification   of   Sensitive
               Aquatic  Resources  in  Other
               North American Regions	21
        2.4.3  Canada	24

   2.5  Assessing Protection Needs and Re-
        source Responses in the Control of
        Acidic Deposition	25
        2.5.1  Model Application	25
        2.5.2 Direct/Delayed Response Pro-
              ject	25
        2.5.3 Nitrogen Bounding Study	31
        2.5.4 Overview of International and
              State Acidic  Deposition Crite-
              ria and Standards	42
        2.5.5 Spatial and Temporal Issues in
              Development of a Standard	46

   2.6  Controlling  Sulfur  and Nitrogen  to
        Reduce Surface Water Acidification	47

3  Source-Receptor Relationships and  Depo-
   sition Reductions under  alternative  Emis-
   sions Scenarios	49

   3.1  Introduction	49

   3.2  The Regional Acid Deposition  Model
        (RADM)	50
        3.2.1 Emissions  and  Atmospheric
              Chemistry	53
        3.2.2 Modeling Source-Receptor Re-
              lationships and Source Attribu-
              tion	55
        3.2.3 Transport,    Chemistry,   and
              Source-Receptor Relationships	57
        3.2.4 Confidence in Results	59

   3.3  Source Attribution	59
        3.3.1  Changes from 1985 to 2010	59
        3.3.2 Regional  Emissions  Distribu-
              tion in 2010	60

   3.4  Emissions Reductions Scenarios	62

   3.5  Deposition Reductions under Various
        National  Emissions Reductions  Sce-
        narios	66
        3.5.1  Impact   of   SO2  Allowance
              Trading on Sulfur Deposition	66
        3.5.2 Effect of Additional SO2  Emis-
              sions  Reductions  on  Sulfur
              Deposition	68
        3.5.3 Decrease in  Total  Nitrogen
              Deposition from Decreases  in
              NOX Emissions	69

   3.6  Emissions  Reductions  Strategies  to
        Achieve   Geographically  Targeted
        Sulfur Deposition Loads	72

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
4  Potential  Benefits of an Acid  Deposition
   Standard on Visibility, Human Health, Ma-
   terial, and Cultural Resources	79

   4.1  Introduction	79

   4.2  Relationship of Visibility  to  Acidic
        Deposition	79
        4.2.1  Visibility Impairment	79
        4.2.2  Visibility Protection Laws and
               Class I Areas	80
        4.2.3  Visibility Metrics and the Pro-
               jected Impact of 1990CAAA
               on Visibility	80
        4.2,4  Potential Impact of an Acid
               Deposition  Standard on Visi-
               bility	83

   4.3  Relationship of  Human  Health  to
        Acidic Deposition	83

   4.4  Relationship of  Materials  Damage
        and Cultural   Resources  to  Acidic
        Deposition	85
        4.4.1  Acidic  Deposition  Effects on
               Materials and Structures	85
        4.4.2  Material Life-Cycle and Dam-
               age Estimates	86

5  Implementation Issues	89

   5.1  Introduction	89

   5.2  Targeted Approach	89
        5.2.1  Description  of  Targeted  Ap-
               proach	89
        5.2.2  Integration with Title IV	90
        5.2.3  Impediments to  Implementa-
              tion 	90

   5.3  Emissions-Based Approach	91
        5.3.1  Description   of   Emissions-
               Based Approach	91
         5.3.2  Integration with Title IV	91
         5.3.3  Impediments to  Implementa-
               tion	91

   5.4   Economic Impacts	91
         5.4.1  2010  CAAA  Scenario  (with
               Trading)	92
         5.4.2  50 Percent Utility SO2 Reduc-
               tion Scenario	92
         5.4.3  50 Percent Utility and Indus-
               trial SO2 Reduction Scenario	95
         5.4.4  Geographically  Targeted Re-
               duction Scenario	95
         5.4.5  NOX   Reductions-50   Percent
               Utility and Industrial	95
         5.4.6  Summary  of   Economic  Im-
               pacts	97

   5.6   Conclusions	98
6  Integration and Conclusions	99

   6.1   Introduction	99
   6.2   Establishing  Effective  Environmental
         Coals	99

   6.3   Projected   Environmental    Conse-
         quences of Acidic Deposition Reduc-
         tion Scenarios	101
   6.4   Feasibility of Establishing and Imple-
         menting an Acid Deposition Standard	104

Appendices
   A  Summary of Selected NAPAP Reports	A-1

   B  Selected  Plots  from  EPA's  Nitrogen
      Bounding Study	B-1

   C  Range  of Influence of  Emissions  from
      RADM Tagged Subregions	C-1
   D  Summary of  Public Comments  Re-
      ceived	D-1
                                                    VI

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                                       LIST OF EXHIBITS
 1. Empirically   determined   relationship
    between ANC and pH for three sensi-
    tive  regions, including cross-regional
    mean and standard deviation	
 2. Principal watershed and surface water
    characteristics that  influence  resource
    sensitivity to acidification	17

 3. Critical pH for selected taxa in  lakes
    and streams	21

 4. MAGIC	26

 5. Study  regions  included  in  the Di-
    rect/Delayed  Response Project and the
    Nitrogen Bounding Study	27

 6. Target  populations  included  in the
    NSWS, DDRP, and NBS Studies	29

 7. Impact of CAAA on sensitive surface
    waters: NBS model projections for Year
    2040	32
 8. NBS model  projections for year 2040
    percentage of target  population Adi-
    rondack lakes with ANC^O u,eq/l	
.33
 9. NBS model  projections for year 2040
    percentage   of   target    population
    mid-Appalachian  streams  with
    50 u.eq/1
.34
10. NBS model  projections for year 2040
    percentage of target population South-
    ern Blue Ridge streams with ANC550
    u.eq/1	35

11. Interpreting NBS plots	36

12. Time to watershed nitrogen saturation	37

13. Summary  of NBS  results: Range of
    minimum  (background deposition) to
    maximum (implementation of CAAA)
    percentages  of acidic and sensitive tar-
    get waters 	38

14. Surface water responsiveness to reduc-
    tions in deposition beyond the CAAA:
    Detectible improvements  in long-term
    ANC by 2040	39

15. LRTAP	44

16. Physical and chemical processes con-
    tributing to acidic deposition	51

17. The RADM modeling domain	52
 18. Map of annual sulfur emissions density
     in 1985 (tons/year)	55

 19. Tagged RADM subregions	56

 20. Proportion of annual sulfur deposition
     contributed  by RADM Subregion  15
     (OH/WV/PA border region)	57

 21. Percentage cumulative range  of influ-
     ence   of   RADM   Subregion    15
     (OH/WV/PA border region)	57

22a. Source-receptor  relationships  in  the
     Northeast:  Cumulative percent sulfur
     deposition	58

22b. Source-receptor  relationships  in  the
     lower Ohio Valley: Cumulative percent
     sulfur deposition	58

22c. Source-receptor  relationships  in  the
     Southeast:  Cumulative percent sulfur
     deposition	58

 23. Percent  contribution  to sulfur emis-
     sions of 53 tagged RADM regions	60

 24. Percent  reduction  in  tagged  regions
     from  1985 to 2010 as a  function of
     relative contribution of each region to
     all tagged emissions	60

 25. Percentage  of  tagged emissions  by
     tagged regions for 1985 and 2010	61

 26. Contribution  of  top-10 SO2  emitting
     regions to sulfur deposition in  sensitive
     regions	61

 27. Comparison of proximate  and major
     emitting regions to sulfur deposition in
     sensitive areas in 2010	62

 28. Estimated U.S. SO2 emissions with and
     without Title IV from 1980 to 2015	63

 29. Predicted  SO2  utility  emissions  from
     1990 to 2010	65

 30. SO2 emissions in the U.S.  RADM do-
     main (eastern United States)	66

 31. Annual  average RADM   total  sulfur
     deposition (kg-S/ha): 1980	66

 32. Annual average RADM-predicted total
     sulfur deposition (kg-S^a): post-2010
     full CAAA implementation	67

 33. Percentage reductions  in sulfur deposi-
     tion from CAAA implementation	67
                                                VII

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
34. Impact of trading on sulfur deposition
    in sensitive regions	
 35. difference  in Annual average  RADM
     total sulfur deposition (kg-S/ha) in 2010
     between post-2010  full  implementa-
     tion and no trading scenarios	...
 36. RADM-predicted annual average total
     sulfur deposition (kg-S/ha) in 2010 un-
     der additional utility SO2 emissions re-
     duction scenario	
 37. RADM-predicted  annual average total
     sulfur deposition (kg-S/ha) in 2010 un-
     der additional utility and industrial SO2
     emissions reduction scenario	
 38. Percentage reductions in sulfur deposi-
     tion  from post-2010 full implementa-
     tion  - under additional  utility SO2 re-
     duction scenario	
 39. Percentage reductions in sulfur deposi-
     tion  from post-2010 full implementa-
     tion under additional utility and indus-
     trial SO2 reduction scenario	
 40. Sulfur deposition to sensitive regions
     under various emissions scenarios	
 41.  Percent reductions in sulfur deposition
     to sensitive regions  from  1980  levels
     under various emissions scenarios	
 42.  Estimated U.S. NOX emissions with and
     without Title IV from 1980 to 2015.
 43.  Percent contribution of utility sources
     to nitrogen deposition in 1990	

 44.  Percent  contribution   of  industrial
     sources to nitrogen deposition in 1990..

 45.  Percent contribution of mobile sources
     to nitrogen deposition in 1990	

 46.  Annual average  RADM total nitrogen
     deposition (kg-N/ha) in  1990	
 47.  RADM-predicted annual  average total
     nitrogen  deposition  (kg-N/ha)  under
     utility and industrial  NOX  emissions
     reductions scenario	
48.  Percentage  reductions  in  nitrogen
     deposition under utility and industrial
     NOX emissions reductions scenario.
.67




.68




.70




.70




.70




.70


.71



.71


.71


.72


.72


,72


,73




,73



.73
4y.  Nitrogen deposition to  sensitive  re-
     gions  under base case and additional
     utility and  industrial  NOX emissions
     reduction scenario	
 50.  Selection of maintenance loads.
,73

,75
                                                      51 a. Geographically targeted additional util-
                                                           ity SO2 reduction in contiguous RADM
                                                           subregions	
                                                                                                  .76
                                                     51 b. Geographically targeted additional util-
                                                          ity  SO2  reduction  in major RADM
                                                          subregions contributing  to deposition
                                                          (not contiguous)	
                                                                                                   .76
                                                      52. Map  of extent of  contiguous geo-
                                                          graphic regions for achieving targeted
                                                          deposition  loads  equivalent  to addi-
                                                          tional  nationwide  utility SO2  reduc-
                                                          tions 	77

                                                     53a. Geographically targeted additional util-
                                                          ity and industrial SO2 reduction in con-
                                                          tiguous RADM subregions	78
                                                     53b. Geographically targeted additional util-
                                                          ity and industrial SO2 reduction in ma-
                                                          jor  RADM subregions contributing to
                                                          deposition (not contiguous)	
                                                                                                   .78
                                                      54. Extent  of contiguous geographic  re-
                                                          gions for achieving targeted deposition
                                                          loads equivalent to additional nation-
                                                          wide utility and industrial SO2 reduc-
                                                          tions 	

                                                      55. Geographically  targeted   reductions
                                                          with a  maintenance load of 5 kg-S/ha
                                                          in major RADM subregions contribut-
                                                          ing to deposition (not contiguous)	
                                                      56. Anthropogenic Contributions to Visibil-
                                                          ity Impairment	
                                                      57. Annual average visual range (km) pro-
                                                          jected  for  2010  without  Title  IV:
                                                          50th-percentile visibility	
                                                      58.  Annual average visual range (km) pro-
                                                          jected for 2010 with Title IV, including
                                                          trading: 50th-percentile visibility	
                                                      59. Annual average improvement in  50th-
                                                          percentile visibility (dv)  from 1980 to
                                                          2010 with Title IV, including trading	

                                                      60. Specific provisions of Titles I, II, and IV..

                                                      61. Average annual visual range estimates
                                                          for representative Class  I areas  in the
                                                          Southwest	,
                                                      62.  Percent  increase in visual range from
                                                          1985 to 2010 with full  CAAA  imple-
                                                          mentation	
                                                      63.  Percent  increase in visual range from
                                                          1985 to 2010 with additional SO2 re-
                                                          duction beyond CAAA	
                                                       64.  Relationship of acidic deposition proc-
                                                           esses to health effects	
.78




.78


.79



.81



.81



.81

.82



.83



.83



.84


.84
                                                 VIII

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                                                                                       LIST OF EXHIBITS
 65. Percentage of metal corrosion  attrib-
     uted to atmospheric factors	86

 66. 2010 annual  costs and SO2 emissions
     by Census region: CAAA scenario	93

 67. 2010 annual  costs and SO2 emissions
     by Census region: CAAA scenario ver-
     sus additional 50 percent utility emis-
     sions reduction scenario	94

 68. 2010 annual  costs and SO2 emissions
     by Census region: CAAA scenario ver-
     sus additional 50 percent utility and
     industrial emissions reduction scenario	96
69a. Annual  costs of  geographically  tar-
     geted reductions equivalent to nation-
     wide  50%   utility   SO2   reduction
     (contiguous RADM subregions)	
        69b. Annual costs of  geographically tar-
             geted reductions equivalent to nation-
             wide 50% utility SC>2 reduction: Major
             RADM   subregions  contributing   to
             deposition (not contiguous)	
.97
         70. Summary of costs of various emissions
             reductions scenarios	
.98
         71. Year 2040 NBS projections for Adiron-
             dack lakes	102

         72. Year 2040 NBS  projections  for mid-
             Appalachian streams	103

         73. Year 2040 NBS projections for South-
             ern Blue Ridge Province streams	103
.97
                                                  IX

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                                     LIST OF ACRONYMS
ADIR      Adirondack Mountain region
ADOM     Acid Deposition and Oxidants Model
ALim       inorganic monomeric aluminum
ANC       acid neutralizing capacity
AQRV     Air Quality Related Values
BACT      best available control technology
BEA       Bureau of Economic Affairs
Btu        British thermal unit
Ca2+       calcium
CAA       Clean Air Act
CAAA     Clean Air Act Amendments
CCE       Coordination Center for Effects
CCT       Clean Coal Technology
CEUM     Coal and Electric Utilities Model
Cl"         chlorine
cm         centimeter
CO        carbon monoxide
DDRP     Direct Delayed Response Project
DOE       Department of Energy
DOI       Department of the Interior
dv         deciview
EMEFS     Eulerian Model Evaluation Field Study
EPA       U.S. Environmental Protection Agency
FIP         Federal Implementation Plan
H+         hydrogen ion
H2O2      hydrogen peroxide
ha         hectare
H2SO4     sulfuric acid
HCHO     formaldehyde
HNO3     nitric acid
IMPROVE  Interagency  Monitoring  of   Protected
           Visual Environments
kg         kilogram
km         kilometer
LNB       low-NOx burner
LRTAP     Long-Range Transboundary Air Pollution
LTM       Long-Term Monitoring
m          meter
M-APP     mid-Appalachian region
Mg2+
mi
MM4
N
NAAQS
NADB
NAPAP

NAS
NBS
NH3
NH4+
NO
NO2
NO3-
NOX
NRC
NSPS
NSS
NSWS
NURF
NYSDEC

03
PAN
PM10
ppm parts
PSD
RADM
RIA
S
SBRP
SCR
SIP
SNCR
S02
scv-
  magnesium
  mile
  Mesoscale Model
  nitrogen
  National Ambient Air Quality Standard
  National Allowance Data Base
  National Acid  Precipitation  Assessment
  Program
  National Academy of Sciences
  Nitrogen Bounding Study
  ammonia
  ammonium ion
  nitric oxide
  nitrogen dioxide
  nitrate
  nitrogen oxide
  National Research Council
  New Source Performance Standard
  National Stream Survey
  National Surface Water Survey
  National Unit Reference File
  New   York   State   Department   of
  Environmental Conservation
  ozone
  peroxyacetyl nitrate
  paniculate  matter   smaller  than  10
  micrometers
  phosphate
per million
  prevention of significant deterioration
  Regional Acid Deposition Model
  Regulatory Impact Analysis
  sulfur
  Southern Blue Ridge Province region
  selective catalytic reduction
  State Implementation Plan
  selective non-catalytic reduction
  sulfur dioxide
  sulfate
                                                XI

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
SOMA     Sulfur Oxide Management Area             ueq/l       microequivalents per liter
SOS/T     state-of-science/technology                ug/l        micrograms per liter
SOX        sulfur oxide                              H™         micrometer
UNECE     United Nations Economic Commission      4DDA      four-dimensional data assimilation
           for Europe
yr         year
                                                XII

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                                    EXECUTIVE SUMMARY
Scientific evidence  has shown that  atmospheric
deposition of sulfur  and nitrogen compounds can
adversely affect ecosystems. Observed effects in-
clude acidification of surface waters  and damage
to high-elevation red spruce forests in the  United
States. Title IV of the Clean Air Act Amendments
of 1990  (CAAA or the Act)  addresses the problem
of adverse effects on ecosystems from acidic rain
by mandating reductions in emissions of sulfur and
nitrogen  oxides  the major  precursors of  acidic
deposition. Coupled with Titles I  and II of the Act
which address  new and existing stationary and
mobile sources of sulfur and nitrogen oxides, im-
plementation of Title  IV is expected to provide
significant benefits to the United States and Can-
ada, including decreases in the acidity of  lakes and
streams,  concomitant improvements in fish popu-
lation diversity and  health,  decreases in  soil deg-
radation  and forest stress, improvements in  visibil-
ity  (especially to scenic vistas), decreases in dam-
age to materials and cultural resources, and a re-
duction in adverse human health  effects.  Congress
included Section 404  in Title  IV (Appendix B  of
the Act) which requires the  Environmental  Protec-
tion Agency (EPA or the Agency) to provide a re-
port to Congress on the feasibility and  effective-
ness of an acid deposition standard to protect sen-
sitive and critically sensitive aquatic and terrestrial
resources. Specifically, Congress listed six areas to
be addressed in the report:

  » Identification of sensitive and critically sen-
     sitive aquatic and terrestrial resources  in
     the  U.S. and Canada  which  may  be af-
     fected by  the  deposition of acidic com-
     pounds;

  » Description and specification of a numeric
     value for an acid deposition standard suffi-
     cient to protect such resources;

  » Description of  the use of such standard or
     standards in other Nations or by any of the
     several States in acidic deposition control
     programs;

  * Description of measures that  would be
     needed to integrate such standard or  stan-
     dards with the control program required by
     Title IV of the Clean Air Act;
  * Description of the state of knowledge with
     respect  to  source-receptor  relationships
     necessary to develop a control program on
     such standard or standards and additional
     research  that is on-going  or  would be
     needed to make such a control program
     feasible;

  * Description of impediments to implemen-
     tation of such control  program and the
     cost-effectiveness of deposition standards
     compared to other  control strategies in-
     cluding ambient air quality standards, new
     source performance standards and the re-
     quirements of Title IV of the Clean Air Act.

This report fulfills  the requirement of Section 404
by integrating  state-of-the-art ecological effects  re-
search,  emissions  and  source-receptor modeling
work, and evaluation of implementation and cost
issues to address the six areas and other issues  re-
lated to the feasibility of establishing and imple-
menting an acid deposition standard or standards.

RESOURCES MOST AT RISK FROM ACIDIC
DEPOSITION
The natural resources most  at  risk  from acidic
deposition are aquatic systems and  high-elevation
red spruce forests in the eastern United States and
Canada. Although  many surface waters in western
North America are equally or more sensitive than
aquatic systems in the East, deposition levels in the
West are sufficiently  low that the risk of chronic
acidification to these resources is low at present
and is expected to remain low in the foreseeable
future.  Research conducted under the auspices of
the  National  Acid Precipitation  Assessment Pro-
gram (NAPAP)  concluded  that  regions  in  the
United States  most at risk from continued acidic
deposition  are located  along the  Appalachian
Mountain chain stretching from the Adirondacks in
New York to the Southern Blue Ridge in Georgia.
Target populations of Adirondack lakes, mid-Appa-
lachian streams, and Southern Blue  Ridge  streams,
for which model projections can be  reasonably ex-
trapolated,  were selected for  detailed analysis in
this study because they represent areas that receive
fairly high  levels  of  acidic deposition, have  the
best historical  data, and have been  studied exten-
sively by scientists.
                                                XIII

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
CAAA PROVIDES CLEAR BENEFITS TO
SURFACE WATERS
Modeling  analysis indicates  that sulfur
deposition reductions mandated by Title
IV of the Act will have clear benefits to
sensitive  surface waters. Exhibits  HI I
show  the percent  of target  lakes or
streams in each sensitive region pro-
jected  to  be  chronically  acidic  (acid
neutralizing capacity [ANC]<0 u.eq/1) by
2040 with and without implementation
of the Act. The scenarios are described
according  to the extent and  rate of ni-
trogen  impact  on that given  watershed.
(See footnote below.)* In each  modeled
region, the proportion of targeted acidic
and sensitive surface waters would have
been  higher, in some cases significantly,
without the sulfur  dioxide  (SO2)  re-
ductions and nitrogen oxide  controls in
the CAAA.

FURTHER REDUCTIONS MAY  BE
NECESSARY FOR FULL PROTECTION
Scientific analysis indicates that nitrogen
as well as sulfur deposition plays an im-
portant role in chronic  and  episodic
acidification  of surface waters  and full
protection  may not be realized without
additional  reductions in nitrogen as well
as sulfur deposition.  Model projections
indicate that maintaining the  proportion
of chronically  acidic target surface wa-
ters in the Adirondacks near proportions
observed in 1984 may require reducing
anthropogenic  sulfur and  nitrogen depo-
sition  by 40   to  50 percent or more
below  levels   achieved  by  the CAAA
(assuming   100  years   to   nitrogen
saturation).  In  the   mid-Appalachians,
implementation  of  the  CAAA should
maintain    1985    proportions    of
chronically acidic target streams if the time to ni-
trogen  saturation is  250  years or longer; more
    EXHIBIT I. PERCENT OF TARGETED ADIRONDACK LAKES PROJECTED
        TO BE CHRONICALLY ACIDIC (ANCSO U.EQ/L) IN 2040
           PERCENT OF TARGET POPULATION ADIRONDACK
             LAKES OBSERVED ACIDIC IN 1984 = 19%
               TARGET POPULATION = 700 LAKES
Nitrogen Saturation
Model Projections
Never
250 years
100 years
50 years
Percent of Targeted Waters Pro-
jected to be Acidic in 2040
Without CAAA
25%
23%
36%
50%
With CAAA
11%
15%
26%
43%
   EXHIBIT II. PERCENT OF TARGETED MID-APPALACHIAN STREAMS PRO-
     JECTED TO BE CHRONICALLY ACIDIC (ANC<0 JIEQ/L) IN 2040
         PERCENT OF TARGET POPULATION MID-APPALACHIAN
             STREAMS OBSERVED ACIDIC IN 1985 = 4%
             TARGET POPULATION = 4,300 STREAMS
Nitrogen Saturation
Model Projections
Never
250 years
1 00 years
50 years
Percent of Targeted Waters Pro-
jected to be Acidic in 2040
Without CAAA
8%
21%
23%
33%
With CAAA
0%
4%
5%
9%
  EXHIBIT III. PERCENT OF TARGETED SOUTHERN BLUE RIDGE PROVINCE
STREAMS PROJECTED TO BE CHRONICALLY ACIDIC (ANC<0 U.EQ/L) IN 2040
     PERCENT OF TARGET POPULATION SOUTHERN BLUE RIDGE PROV-
          INCE STREAMS OBSERVED ACIDIC IN 1985 = 0%
             TARGET POPULATION = 1,300 STREAMS
Nitrogen Saturation
Model Projections
Never
250 years
1 00 years
50 years
Percent of Targeted Waters Pro-
jected to be Acidic in 2040
Without CAAA
0%
1%
2%
13%
With CAAA
0%
0%
0%
4%
  Nitrogen saturation is a measure of the capacity of
  biological processes in  a  watershed to incorporate
  nitrogen into organic matter. As this capacity is used
  up, nitrogen losses from watersheds increase, princi-
  pally in the form of nitrate leaching. The time to ni-
  trogen  saturation can vary  among  regions due to
  differences in  temperature,  moisture,  length  of
  growing season, soil fertility, forest age, and historic
  nitrogen deposition. Currently, uncertainty regarding
  times to nitrogen watershed saturation in each sensi-
  tive region is significant.
          rapid nitrogen saturation  (in  the range  of 100
          years)  may require reductions in anthropogenic
          sulfur and nitrogen deposition by 25 percent be-
          low levels achieved  by the CAAA. With  imple-
          mentation of the CAAA,  no chronically  acidic
          streams are  expected within  the Southern  Blue
          Ridge target population. Another useful  measure is
          the sensitivity of a  lake or stream to becoming
          acidic (i.e., ANC<50 u.eq/1).   Use of this measure
          (as described in Chapter  2) also indicated that
          further deposition reductions may  be necessary for
          full protection of target sensitive surface waters.
                                                 XIV

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                                                                                EXECUTIVE SUMMARY
ACIDIC DEPOSITION AND EPISODIC ACIDI-
FICATION
Episodic acidification occurs when pulses of acidic
waters enter lakes and streams during stormwater
runoff and spring snowmelt. Both sulfates and ni-
trates  originating from  atmospheric  deposition
contribute significantly to episodic  acidification
events.  Rapid,  acutely toxic  changes  in  surface
water chemistry often  occur at the most biologi-
cally significant time of year (i.e., during spawning
and  reproduction). Significantly more  lakes and
streams  become  episodically acidic  than  are
chronically acidic. Recent analyses have shown
that  for the worst episode  that may occur during
any year, the number of lakes or streams that were
acidic during that episode in  the  Adirondacks  is
approximately 3.5 times the number found to  be
chronically acidic. Thus, for the Adirondacks, ap-
proximately 70  percent  of the target  population
lakes are  at risk  of episodic acidification at least
once during each year. For the mid-Appalachian
streams, approximately 30 percent of the target
population stream reaches  are likely to be acidic
during the worst episode. This is  roughly 7 times
the number of chronically acidic stream  reaches.
Due to data limitations,  comparable analyses are
not  possible for  streams  in  the  Southern  Blue
Ridge. Lower levels of acidic deposition will lower
the number and  severity of acidic and toxic epi-
sodes driven by sulfate  and  nitrate.

EMISSIONS TRADING is COST-EFFECTIVE AND
MAINTAINS ENVIRONMENTAL  BENEFITS
A  recently released General  Accounting Office
report  estimated that  the  allowance   trading
program will  reduce  control  costs  by over 40
percent and up  to 70 percent  if the  trading
program is used to the fullest extent, t Atmospheric
modeling  of  sulfur deposition projects no more
than a 10 percent difference in deposition in 2010
with and without trading. Over most of the eastern
United  States, the difference in deposition is less
than  5 percent,   and   there  is   no  difference
projected  for eastern Canada.  Exhibit IV is a map
that shows the projected annual average difference
in  sulfur  deposition   between trading  and  no
trading over the eastern United States and Canada.
Variations in deposition of less  than 10 percent are
not projected to result in  measurable  ecological
impacts. Therefore, while  the allowance trading
t U.S. General  Accounting Office.  December. 1994.
  Air  Pollution  Allowance  Trading   Offers   an
  Opportunity  to Reduce  Emissions at Less  Cost.
  Washington, DC.
program is expected to reduce costs of control, it is
not projected to have a measurable negative envi-
ronmental impact.

SULFUR EMISSIONS AND DEPOSITION LEVELS
Exhibit V compares deposition levels produced by
several  sulfur dioxide  emissions scenarios.  The
additional  reduction scenarios were chosen to
illustrate the effect of further emissions reductions
and   to   serve   as   examples   for cost   and
implementation analyses; they do not represent a
reduction necessary to  meet any particular target
load.  In comparison with  1980 deposition levels,
implementation  of the  CAAA  is  projected to
reduce deposition  by 30 to 40 percent  by 2010.
Exhibit  VI  shows  the  projected  percentage  de-
crease in sulfur  deposition  between 1980  and
2010  with  full  implementation of Title  IV. If an
additional 50 percent reduction  in utility and in-
dustrial sulfur dioxide emissions beyond the CAAA
were to occur, then sulfur deposition would be re-
duced by about 60 percent compared to 1980.

NATIONAL OR TARGETED EMISSIONS RE-
DUCTIONS
To achieve an acid deposition standard for a  par-
ticular sensitive area, some have suggested target-
ing emissions reductions, rather than reducing na-
tional emissions.  By 2010, Title IV will produce
the largest emissions reductions in the  highest
emitting  regions (i.e., Ohio,  Indiana, West  Vir-
ginia, and  western Pennsylvania). An analysis of
geographically targeted emissions reductions using
the Regional  Acid  Deposition  Model  (RADM)
shows that to achieve  deposition reductions  be-
yond the CAAA (equivalent to those achieved by a
50 percent SO2  emissions  reduction) in sensitive
receptor regions, zones targeted for emissions re-
ductions would need to include 6 to 11 states  and
require  source-  (region-) specific,  sulfur dioxide
reductions  of  about 95  percent.  To  achieve
deposition  loadings  in  all  3 sensitive receptor
regions  equivalent to that produced by  an  ap-
proximate 50 percent reduction  in sulfur dioxide
emissions,  both   geographically  targeted   and
national  emissions reductions strategies  would
require about the same total emissions reductions
at about the same total cost. Thus, relative to na-
tional emissions reductions, there is no economic
or  environmental advantage to  geographically
targeting regions for emissions reductions.
                                                xv

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
       EXHIBIT IV. ANNUAL AVERAGE RADM TOTAL SULFUR DEPOSITION (KC-S/HA) IN 2010: DIFFERENCE
            IN DEPOSITION BETWEEN IMPLEMENTATION OF THE CAAA WITH AND WITHOUT TRADING
                                                                  -0.80  TO -1.16
                                                                  -0.50  TO -0.80
                                                                  -0.20  TO -0.50
                                                                  -0.20  TO 0.20
                                                                  0.20 TO  0.50
                                                                  0.50 TO  0.90
                                                                  0.90 TO  1.53
       EXHIBIT V. SULFUR DEPOSITION TO SENSITIVE REGIONS UNDER VARIOUS SO2 EMISSIONS SCENARIOS
Emissions Scenario
1980
1985
2010 after CAAA implementation
CAAA plus additional 50% utility SO? reduction
CAAA plus additional 50% utility and industrial SO? reduction
Annual Avera
Adirondacks
11
9,8
6.9
5.5
4.7
Be Deposition Level (kg-S/ha)
Mid-Appalachi-
ans
19
17
11
8.1
6.9
Southern
Blue Ridge
14
13
9.7
6.8
5.5
                                              XVI

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                                                                                EXECUTIVE SUMMARY
    EXHIBIT VI. PERCENTAGE REDUCTIONS IN SUL-
       FUR DEPOSITION FROM 1980 TO 2010
       FROM IMPLEMENTATION OF THE CAAA
       AND CANADIAN ACID RAIN PROGRAM
IMPLEMENTING AN ACID DEPOSITION
STANDARD
In order to determine the effectiveness of an  acid
deposition standard for protecting  sensitive re-
sources, it is necessary to describe how the stan-
dard would be implemented.

The study describes two basic approaches to using
an acid deposition standard. Under the first ap-
proach, EPA would set a  standard or standards,
either  using existing authority  or seeking further
authority from Congress to set such standards and
provide deadlines for their attainment. Then, simi-
lar to Title I, states would determine source-spe-
cific limits using source-receptor models and tech-
nical and cost analyses, incorporate those limits in
State  Implementation  Plans  (SIPs),  and  enforce
them. If one or more states failed to do the above,
EPA would promulgate a  Federal Implementation
Plan (FIP).

Under the second  approach, Congress would di-
rect EPA to set a deposition standard or standards
and to determine the national  (or regional) emis-
sions levels for sulfur dioxide and nitrogen oxides
that would meet those standards. Congress would
then set an emissions  cap and allowance alloca-
tions for nitrogen oxides and, if necessary, adjust
the cap for sulfur dioxide in Title IV, and provide a
timetable for meeting the new caps. EPA would
use Title IV provisions to implement the emissions
program.

To provide a rough comparison of the cost-effec-
tiveness of the two approaches for  sulfur reduc-
tions, estimates were made of the cost of achieving
the same reduction in sulfur deposition from utility
sources at the three sensitive areas under each ap-
proach. Total compliance costs were similar, al-
though the national emissions  reduction approach
resulted in slightly larger and more widespread
emissions  reductions which may provide  greater
ancillary benefits for human health  and visibility
protection. The costs of further emissions reduc-
tions characterized in  this report could  lead  to
costs that  are more than double those of the cur-
rent acid  rain control  program,  but the  benefits
would  be in multiple effects areas.

FEASIBILITY AND EFFECTIVENESS OF AN ACID
DEPOSITION STANDARD
The purpose of this study was to provide Congress
with a  report on the feasibility  and effectiveness of
an acid deposition standard or  standards to protect
sensitive aquatic  and terrestrial  resources. Based
on current scientific understanding of the effects of
sulfur and nitrogen on aquatic resources, it would
be feasible to set sulfur and  nitrogen  deposition
standards to protect aquatic resources,  but uncer-
tainty remains high as to the  impact of nitrogen.
Further research could  lower  that uncertainty. It
would  also be helpful to have guidance from Con-
gress or the public on the degree of protection de-
sired, e.g., to protect every aquatic resource from
any adverse effect, or to protect 95 percent of sen-
sitive resources from chronic anthropogenic acidi-
fication.

The effectiveness of an acid deposition standard
depends heavily on the approach used to imple-
ment it. Although the two basic  approaches dis-
cussed  in this report could have similar  compli-
ance costs and effects on  aquatic resources, the
national market-based  emissions reduction ap-
proach  could have greater benefits for   human
health  and visibility, is more compatible with the
existing Title IV,  and  is more  likely  to  be imple-
mented. The  likelihood of achieving  deposition
reductions is viewed as a critical  factor  in judging
effectiveness.
                                               XVII

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                                        CHAPTER 1

                                     INTRODUCTION
Title IV of the Clean Air Act Amendments of 1990
(CAAA  or the Act) addresses the problem  of ad-
verse effects on ecosystems from  acid rain  by
mandating reductions in emissions of sulfur and ni-
trogen oxides—the major precursors of acid rain.
Coupled with Titles I and II of the Act, which ad-
dress new  and  existing  stationary and  mobile
sources of sulfur and nitrogen oxides, implementa-
tion of  Title IV is expected to provide significant
benefits to the United States and Canada. Those
benefits include decreases in the acidity of lakes
and streams, concomitant improvements in fish
population diversity and health, decreases  in soil
degradation  and forest  stress,  improvements  in
visibility (especially to scenic vistas), decreases  in
damage to material!; and cultural resources, and a
reduction in adverse human health effects. Con-
gress included Section 404 in Title IV (Appendix B
of the Act) which requires the U.S.  Environmental
Protection Agency (EPA or the Agency) to provide
a report to  Congress  on the feasibility and effec-
tiveness of an acid deposition standard to protect
sensitive and critically sensitive aquatic and terres-
trial resources. Specifically, Congress listed six ar-
eas to be addressed in the report:

   * Identification of sensitive and critically sen-
     sitive  aquatic and terrestrial  resources in
     the U.S. and Canada  which  may be af-
     fected  by the deposition  of acidic  com-
     pounds;

   * Description and specification of a numeric
     value for an acid deposition standard suffi-
     cient to protect such resources;

   * Description of the use of such  standards or
     standards in other Nations or by any of the
     several States  in acidic deposition control
     programs;

   * Description  of  measures  that would be
     needed to integrate such standard or stan-
     dards with the control program required by
     Title IV of the Clean Air Act;

   * Description of the state of knowledge with
     respect to  source-receptor  relationships
     necessary to develop a control program on
     such standard or standards and additional
     research  that is  on-going or  would be
     needed to make such a control program
     feasible;

  * Description of impediments to implemen-
     tation  of such control  program  and  the
     cost-effectiveness  of deposition  standards
     compared to  other control strategies  in-
     cluding ambient air quality standards, new
     source performance standards and the re-
     quirements of Title IV of the Clean Air Act.

To  achieve  significant  reductions in  emissions of
sulfur and nitrogen oxides, Title IV targets  emis-
sions from electric utilities—the major source of
sulfur dioxide (SO2) emissions and a major source
of nitrogen oxide  (NOX) emissions. Annual  emis-
sions of SO2 are to be reduced by 10 million tons
from 1980 levels  through  an innovative market-
based allowance trading program. The program es-
tablished an SO2 allowance trading system that al-
lows utilities to minimize the cost of complying
with SO2 emissions reduction requirements, while
maintaining a cap  on SO2 emissions from utilities.
The trading  program encourages energy conserva-
tion and technological  innovation, which should
yield pollution  prevention benefits and minimize
compliance  costs.

Annual  allowances for SO2 emissions  have been
allocated  to affected utility units based  on their
historic  emissions  and  fuel  use. Each allowance
permits  a  utility to emit 1  ton of SO2. Each unit
must hold a  sufficient number of allowances at the
end of the year to cover its emissions for that year.
Emissions  reductions will be implemented for 263
units  under Phase I beginning in 1995  and for
approximately 2,200 units affected under Phase II
in 2000. Utilities may buy, sell, trade,  or save al-
lowances for future use.  When the program is fully
implemented in 2010,  nationwide emissions of
SO2 from affected utilities (i.e., units generating
over 25 MW) will  be capped at  8.95 million tons
per year. In addition, nationwide emissions of SO2
from industrial sources are capped at 5.6 million
tons per year. These emissions are not included in
the allowance trading  program, but some  indus-

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
trial sources may be allowed to elect to participate
in the program under rules currently being devel-
oped by EPA.

Title IV also specifies that standards be set for NOX
emissions from utility boilers, with the goal of re-
ducing nationwide emissions  by 2 million tons
from 1980 levels. Unlike the  SO2  program, the
NOX program  does not use a tradable allowance
system and does  not cap emissions, but instead
calls for  low-NOx  burner  technology to  reduce
emissions.

Concerns exist regarding how  allowance trading
will affect protection of sensitive aquatic and ter-
restrial resources.  Some critics argue that the cau-
tious nature of the electric utility industry and lo-
cal pressure in high-sulfur coal regions to continue
use of regional coals to preserve local  economies
will not allow trading to  achieve  economically
meaningful benefits. Others argue that extensive
trading could result in a geographic distribution of
emissions that would  prevent achieving the Act's
goal of reducing the effects of acidic  deposition in
sensitive areas and that emissions levels resulting
in no adverse effects are necessary for protection.

The process for determining the degree of protec-
tion afforded by Title IV to sensitive  and critically
sensitive aquatic and terrestrial resources is com-
plicated  by a number  of scientific and technical
uncertainties. For  example,  there are gaps in eco-
logical effects  research, particularly  regarding ni-
trogen cycling  and retention  in forested  water-
sheds. The scientific community is  still learning
how multiple impacts of sulfur and nitrogen acidic
deposition affect ecosystems. In  addition, meteoro-
logical variability, uncertainties in emissions in-
ventories,  and the  complexity  of  atmospheric
chemistry limit the ability to relate specific ecosys-
tem damage to specific point sources.

The  purpose of this study  is to  integrate state-of-
the-art ecological  effects research, emissions  and
source-receptor modeling work, and implementa-
tion and cost issues to consider the feasibility of
setting and implementing a standard  to protect
aquatic and terrestrial resources from  the effects of
acidic deposition.  This report  addresses  three
broad themes:

  1.  What acidic deposition levels are necessary
     to protect sensitive regions?

  2.  What degree of protection is provided by
     Title IV? What is  the  residual  risk? What
     additional emissions limitations would be
     required to protect sensitive regions?

  3. How would an acid deposition standard(s)
     be implemented? What are the  different
     implementation approaches? What are their
     relative feasibility and effectiveness?

A common thread running through each is uncer-
tainty in (1) data and models, (2) future ecosystem
behavior, and (3) future economic and policy deci-
sions that may influence decisions regarding feasi-
bility.

WHAT ACIDIC DEPOSITION LEVELS ARE NEC-
ESSARY TO PROTECT SENSITIVE REGIONS?
The report outlined in Section 404 (Appendix B) of
the Act requires identification of sensitive aquatic
and terrestrial resources and description of the na-
ture and numerical value for  a deposition standard
that would  protect these resources. This  report
identifies sensitive resources and describes options
for and the nature of a protective goal (i.e., deposi-
tion standard);  scientific  uncertainties  associated
with the response of  specific sensitive  regions to
acidic deposition, however, make designation of a
numerical value  for  a deposition standard  that
would protect each sensitive  region difficult at this
time. Chapter 2 of this feasibility study brings to-
gether  the  most  current  scientific understanding
regarding the relationship between acidic deposi-
tion and ecological effects, specifically effects on
watersheds.  The information  comes from research
conducted by EPA's Office of Research and De-
velopment, peer-reviewed literature, and efforts to
define appropriate acid deposition standards in the
United States and other countries. Best understood
from the scientific point of view is the relationship
between acidic deposition of sulfur and  its effects
on stream and lake ecosystems. Effects of nitrogen
deposition on aquatic systems and of  combined
sulfur and  nitrogen deposition on  terrestrial  sys-
tems are less clear and poorly quantified for re-
sources in the United States.'

Regions of North America differ in their sensitivity
to acidic deposition (i.e., ability of a watershed to
buffer acidity) and in the amount of acidic deposi-
tion they receive. Some parts  of the eastern United
States are highly sensitive and chronically or epi-
sodically  receive  damaging  concentrations  of
acidic deposition. Other sensitive regions, such as
the western United States, are  unlikely to suffer
adverse chronic  effects  at current or  projected
rates of acidic  deposition. Certain  high-elevation
western lakes, however, are subject to episodes of

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                                                                           CHAPTER 1:  INTRODUCTION
acidic deposition.  Chapter 2  identifies sensitive
aquatic and terrestrial resources in specific regions
of the  United  States and describes  the  effects
caused  by  acidic  deposition  in  each region.
Aquatic  resources  of concern  include fish  and
other species, as well as the water quality of lakes
and   streams.  Terrestrial  resources of primary
concern include trees and forest soils.

The  relative  contributions and importance  of  sul-
fur- and nitrogen-containing compounds to the ef-
fects  of  acidic  deposition differ among regions.
The  importance of  each group of compounds de-
pends on its relative deposition level and  on the
capacity of individual watersheds to retain  depos-
ited  nitrogen and sulfur. Sulfur appears to  be the
principal  cause of  ongoing,  chronic acidification
of aquatic systems within most affected areas in
eastern  North America.  The importance of nitro-
gen deposition, however, cannot be overlooked for
several  reasons: visibility in  many areas  of  the
West is degraded  more  by  nitrogen than  sulfur
deposition; nitrogen, as well as sulfur,  produces
episodic surface water  acidification effects, espe-
cially during spring snowmelts; and some water-
sheds in the Northeast  may be  approaching the
limit of their ability to sequester nitrogen, leading
to increased acidification from  nitrogen deposi-
tion.

Chapter 2 assesses these issues by analyzing avail-
able scientific data within a risk-based context  and
produces a set of environmental goals. The analy-
ses concentrate on the three regions in the  United
States most extensively  characterized: the Adiron-
dacks, the mid-Appalachians, and  the  Southern
Blue Ridge Province, each of which is subject to
deposition from sources in the East.  Knowledge of
current and historic differences in deposition levels
and watershed sensitivities in these three regions
makes it possible to discern differences in ongoing
effects and remaining risk for each. Risks for other
regions of the United States  and Canada are also
described, but in a  more qualitative sense. Effects-
based (critical and target  load) control strategies
and approaches adopted by  Europe, Canada,  and
several  states in the United States are also  dis-
cussed. The importance  of considering the effects
of nitrogen deposition on both eutrophication of
estuarine bodies1 and acidification of surface  wa-
ters is also discussed. (Note  that an effects-based
analysis and development of an acid deposition
standard or standards does not necessarily imply
emissions reductions associated with  implementa-
tion of a standard or target loads.)

Although this report focuses on aquatic and terres-
trial systems at risk, acidic deposition and its pre-
cursor emissions  also can adversely affect visibil-
ity,  human  health,  and  materials.  Decreasing
acidic deposition can  also provide benefits  in
these areas.  Visibility,  especially in the  eastern
United States, is markedly degraded by sulfate par-
ticles in the atmosphere.  Human health effects
from  exposure to  SO2,  NO2, and  ozone (O3,
formed  by chemical reactions involving  nitrogen
dioxide) are well  known, and effects from particu-
late matter, including acidic  aerosols,  are docu-
mented as well. Damage to materials and cultural
resources by acidic deposition  has  been  docu-
mented by  the National  Acid Precipitation  As-
sessment Program (NAPAP).2 Visibility degradation
has been addressed more fully in another Report to
Congress3 and  is covered  under Section 169 A of
the Act. Also, primary National Ambient Air Qual-
ity Standards (NAAQS) have  been established to
protect  the public health from adverse effects of
criteria pollutants, including SO2, NO2, paniculate
matter (including sulfates  and nitrates), and O3.
Nevertheless, any control program or standard es-
tablished  to  reduce acidic deposition will also
provide benefits in these other related areas. Chap-
ter 4  of this report summarizes  these  potential
benefits to visibility, human health, and materials.

WHAT DECREE OF PROTECTION is PROVIDED BY
TITLE IV? WHAT is THE RESIDUAL RISK? WHAT
ADDITIONAL EMISSIONS LIMITATIONS WOULD BE
REQUIRED TO PROTECT SENSITIVE REGIONS?
The complex relationship between  emissions and
deposition depends on  a great number of physical,
chemical, and biological processes. Acidic deposi-
tion results from  a complex series of interactions
among chemicals in the atmosphere. Airborne sul-
fur and nitrogen  species can be transported hun-
dreds of kilometers by meteorological forces. Dur-
ing transport these species can remain unchanged
or react with other atmospheric pollutants, such as
1 U.S.  Environmental Protection  Agency. May 1994.
  Deposition of Air Pollutants to the Great Waters. First
  Report to Congress. EPA-453/R-93-055.
2 Irving, P.M., ed.  1991  Acidic  Deposition: State of
  Science and Technology. Summary Report.  National
  Acid Precipitation Assessment Program. Washington,
  DC.
3 Office of Air Quality Planning and Standards.  Octo-
  ber 1993.  Effects of the 1990 Clean Air Act Amend-
  ments on Visibility in Class I Areas: An EPA  Report
  to Congress.  U.S. Environmental Protection Agency,
  Washington, DC.

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 volatile organic compounds (VOCs), to form new
 compounds, some of which are acidic. These pol-
 lutants  are then deposited to the earth through
 either wet or dry deposition.  To understand the
 environmental  impact of the Act and to develop
 and analyze strategies to reduce the  effects of
 acidic deposition, the relationship between emis-
 sions and deposition (i.e., the source-receptor rela-
 tionship) should be addressed not only in the pre-
 sent, but also in the future.

 SO2 and  NOX  reduction mandates established by
 Title IV  provide  for a  nationwide decrease  in
 acidic deposition precursors.  Geographic or re-
 gional restrictions do not exist. The market-based
 allowance trading program promotes  the most
 cost-effective strategy for achieving SO2 reduc-
 tions, rather than requiring a specific type of con-
 trol  on  certain  sources. Variation in sensitivity to
 acidic deposition among geographic regions raises
 the question of whether targeted  or regional stan-
 dards are  needed to protect  sensitive  resources.
 Before such a  question can be answered, deter-
 mining  the level of protection that will  be pro-
 vided by full implementation  of  Title IV  in 2010
 and in subsequent years is necessary.

 To answer questions regarding the effectiveness of
 Title IV  in protecting sensitive  areas (i.e., the re-
 sidual risk after implementation of Title IV) and the
 impact  of additional control,  several  alternative
 emissions scenarios are developed in Chapter 3:

  * A scenario that achieves the  SO2 emissions
     reductions mandated by the Act,

  * A scenario to assess the environmental im-
     pact of trading SO2 allowances, and

  * Scenarios  that  achieve additional  reduc-
     tions of SO2 and NOX emissions from utili-
     ties and industrial  sources  beyond  those
     required by the Act.

The  Regional Acid Deposition  Model (RADM)4 is
used to translate each emissions scenario to depo-
sition values for the eastern United States. Deposi-
tion  of sulfur and nitrogen species are then com-
pared for each  scenario, with particular emphasis
on the three key sensitive areas—the Adirondacks,
  Chang, J.S.,  P.B. Middleton, W.R,  Stockwell, C.J.
  Walcek, J.E. Pleim, H.H. Lansford, F.S. Binkowski, S.
  Madronich,   N.L.  Seaman,  and  D.R.   Stauffer.
  December 1990.  The Regional Acid Deposition
  Model and  Engineering  Model.   NAPAP SOS/T
  Report 4.  In: Acidic Deposition: State of Science and
  Technology. National Acid Precipitation Assessment
  Program.
the  mid-Appalachians,  and  the Southern  Blue
Ridge Province.

HOW WOULD AN ACID DEPOSITION STAN-
DARD(S) BE IMPLEMENTED? WHAT ARE THE
DIFFERENT IMPLEMENTATION APPROACHES?
WHAT ARE THE FEASIBILITY AND EFFECTIVENESS
RELATIVE TO OTHER APPROACHES?
In Chapter 5, two broad approaches are reviewed
for degree of protection, geographic coverage, im-
plementation difficulty, and cost.  The approaches
follow the emissions reductions scenarios modeled
in Chapter 3. The two broad implementation ap-
proaches are (1) a national, emissions-oriented,
market-based approach and (2) a regional,  stan-
dard-oriented, source-  (region-)  specific limit ap-
proach.  Control of both  utility  and  industrial
sources is assessed.

A variety of factors should be considered in im-
plementing an  acid deposition  standard. To  be
successful, an implementation approach must have
clear goals and must provide certainty as to the re-
sponsibilities  of the regulated  community,  EPA,
and  states.  Chapter  5  identifies- and describes the
factors that may affect implementation of a  stan-
dard under both national and regional approaches.
Four general categories of factors are considered:

   *  STATUTORY AUTHORITY: A first step  in assess-
     ing  the  feasibility of  an acid deposition
     standard is determining whether EPA has
     authority to implement a  standard under
     the  existing  CAAA. Is existing  authority
     adequate, or would Congress need to pro-
     vide additional authority necessary to im-
     plement an acid deposition  standard  or
     standards?

   *  ADMINISTRATION/COMPLIANCE: How enforce-
     able and administratively complex are al-
     ternative   regulatory   approaches?   How
     would the approach be  administered and
     enforced? Would new administrative enti-
     ties be needed? What  level of federal and
     state resources would be needed?

   *  INTERACTION AND  INTEGRATION WITH OTHER
     ENVIRONMENTAL PROGRAMS: An acid deposi-
     tion standard may impose additional limits
     on SO2  and NOX emissions from  point,
     area, and/or mobile sources. Existing fed-
     eral, state,  and local regulations (including
     the Title IV Acid Rain Program, Title I Am-
     bient Air Standards,  and Title  II  Mobile
     Source regulations at the federal level) ad-

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                                                                   CHAPTER 1:  INTRODUCTION
dress emissions from these sources. What            munity, as well as the  national  and local
effect would implementation of an acid            economies?
deposition  standard  have on  these  and
other environmental programs?                  Chapter 6 integrates analyses of  eny.ronmental
                                             goals, emissions reductions,  and implementation
Economic Impacts: What would be the       issues and provides conclusions concerning  the
costs and economic impacts of an acid       feasibility of developing and  implementing a stan^
deposition standard to the regulated com-       dard or standards for acidic deposition.

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                                           CHAPTER 2
                                   ENVIRONMENTAL COALS
2.1  INTRODUCTION
Title IV of the 1990 Clean Air Act Amendments
(CAAA) addresses the problem of adverse effects to
environmental resources from acidic deposition by
mandating nationwide  reductions in emissions of
sulfur  and  nitrogen  oxides from  electric  utility
generating units, the major contributor to  acidic
deposition.  While  reductions  in  total emissions
will benefit many aquatic and terrestrial resources,
Congress  mandated a study of  whether more spe-
cific acid deposition standards may be appropri-
ate. Under Section  404 (Appendix B) of the CAAA,
EPA must assess the feasibility and effectiveness of
establishing an acid deposition standard, or stan-
dards,  to  protect sensitive  aquatic and  terrestrial
resources.  This  chapter addresses three specific
Section 404 requirements:

   * Identification of the sensitive and critically
     sensitive aquatic and terrestrial resources in
     the United States  and Canada which may
     be affected by the deposition of  acidic
     compounds;

   * Description of the nature and numerical
     value of a deposition standard or standards
     that  would be sufficient to protect such re-
     sources;

   » Description of the use of such standard or
     standards in other Nations or by any of the
     several States  in acidic deposition  control
     programs.

Section 2.2  of this  report reviews  surface  water
acidification  and  recovery processes.  The two
most common measures of surface water acidifica-
tion are pH and acid neutralizing capacity (ANC).
Low ANC is a common indicator of sensitivity to
acidification; other parameters,  including pH, dis-
solved aluminum, and sensitive species, also pro-
vide useful information on resource health.  At-
mospheric deposition of sulfur and nitrogen com-
pounds that form acids is the principal cause of
surface water acidification effects. Most recent  at-
tention has focused on the effects and control of
sulfur deposition (Section 2.2.1). While many stud-
ies have focused primarily on long-term acidifica-
tion processes, recent EPA research supports the
contention that short-term acidification caused  by
rainstorms and snowmelt may often be the initial
cause of many of the most severe acidification ef-
fects in streams. Consideration of acid deposition
standards may take into account implications to
both the long- and short-term  acidification proc-
esses (Section 2.2.2). Recent  research also  indi-
cates that acidification effects caused  by nitrogen
deposition are  increasingly important  in some ar-
eas. The increasing degree of nitrogen saturation in
some watersheds  is leading  to long-term  and
short-term increases in  nitrate concentration  and
concomitant acidification of some  surface waters
(Section 2.2.3). Section 2.2.4 notes  that a number
of studies indicate that surface water acidification
can  be  reversed by  reducing emissions and, at
least temporarily, by practices such as  liming (e.g.,
the application of powdered limestone);  however,
restoration of ecological systems to their  predistur-
bance conditions may not be possible.

Section  2.3 introduces a risk-based approach to as-
sessing  the need for an acid deposition  standard.
Alternative approaches for defining resource sensi-
tivities are reviewed, and environmental and land-
use characteristics affecting these sensitivities are
described (Section 2.3.1).  Section  2.3.2  empha-
sizes that using a risk-based approach  requires as-
sessing  four  central concerns: (1) sensitivities of
potentially affected resources; (2) factors extrinsic
to selected resources that may alter their sensitivi-
ties;  (3) geographic  location of  the selected  re-
sources; and (4) exposure intensity, duration,  and
timing of acidic deposition at the  selected loca-
tions.

Section  2.4  addresses the  first Congressional  re-
quirement listed above. Section 2.4.1  emphasizes
that  assessments of the need for acid deposition
standards should  focus  primarily  on  potential
benefits to  sensitive  aquatic  resources   in
six regions of the eastern half of the United States
and to sensitive stands of red spruce at high eleva-
tions in two  of those regions.  An  EPA-sponsored
literature review confirmed that  the potential ef-
fects of nitrogen deposition is an increasing con-
cern  in the  western   United  States  as  well
(Section 2.4.2).  In  the  area of  Canada roughly
south of James Bay and east of the Manitoba-On-
tario border,  resource concerns similar  to concerns

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
for  the  eastern United States are  emphasized
(Section 2.4.3).

Section 2.5 addresses the  second  Congressional
requirement by describing the potential need to
protect acid-sensitive resources and the potential
benefits derived from additional control of acidic
deposition. Simulation modeling is the best avail-
able way  to  project future ecological  effects of
possible changes  in deposition  rates.  This  ap-
proach  is  not  without  limitations,  however,  as
results  carry considerable  uncertainty (Section
2.5.1).  Two major  EPA effects modeling  studies
have been completed. The first study, conducted
under the  National  Acid Precipitation Assessment
Program (NAPAP), projected the impact of sulfur
deposition on long-term soil  and  surface water
acidification, with consequent loss of aquatic habi-
tat for sensitive fish species,  in three broad geo-
graphical regions of the  eastern United States. Ad-
verse effects were projected to continue unless sul-
fur deposition was reduced, and sufficient  reduc-
tions in  sulfur deposition were projected to likely
reverse these effects  (Section 2.5.2). The second
major EPA modeling study illustrated the role that
nitrogen deposition  may  play as  an  important
cause of soil and water acidification, and  its im-
portance was projected as  likely to increase in fu-
ture  years  unless   deposition  rates  decreased
(Section 2.5.3). This study  also  projected that the
1990 CAAA would  provide clear benefits to sur-
face water  in three sensitive regions of the eastern
United States. The accuracy of the model projec-
tions is highly uncertain, however, largely because
researchers lack precise  estimates of how long it
takes a sensitive watershed to  become saturated
with deposited nitrogen.

In addressing the third Congressional requirement,
Section 2.5.4  reviews various  acidic deposition
criteria  and standards that  have been developed
internationally and by individual states, many  of
which are  being revised as additional and more
accurate information becomes available. This sec-
tion is not, however, a  comprehensive  list of all
state or international efforts. Important ecological
and geographical concerns that  raise  questions
about whether the application of deposition stan-
dards should take into account regional and sea-
sonal conditions are discussed in Section 2.5.5. Fi-
nally, assessments of the need and options for de-
veloping deposition standards address concerns re-
lated to  both  sulfur  and  nitrogen deposition
(Section 2.6).
2.2 BASIC RELATIONSHIPS IN SURFACE WATER
     ACIDIFICATION AND RECOVERY
Understanding the need for and feasibility of es-
tablishing  acid  deposition standards and under-
standing the sensitivities of resources to acidifica-
tion, requires  a knowledge of  how environments
assimilate  atmospherically  deposited  acids  and
acid-forming chemical  compounds.  This  knowl-
edge  is  key to assessing whether surface water
acidification  effects are occurring in  a  region,
when these effects began, how extensive the ef-
fects are and may become, and the critical periods
when these effects may be most severe. This  sec-
tion briefly reviews  the  process  of surface water
acidification, important considerations in identify-
ing at-risk resources, episodic acidification,  and
useful information for setting regional and resource
priorities for acidic deposition  controls. The  sec-
tion concludes with a brief discussion  of the re-
sponses of acidified ecosystems  to reductions in
acidic  deposition  levels. First,  a few common
terms and concepts, key to understanding surface
water acidification processes, are introduced.

The common  measure of acid-base conditions in
solutions is the pH scale. On this scale, neutrality
(i.e., neither acidic nor basic)  occurs at pH  7.0;
acidic  conditions  have  lower  values  (pH<7.0),
while basic (also termed alkaline) conditions have
higher values  (pH>7.0).  The most acidic condi-
tions occur near pH 0.0 and  the most alkaline
conditions  occur near pH  14.0.  On this  scale,
each full unit decrease in pH (e.g., from  7.0 to  6.0)
represents a ten-fold increase in acidity  and  in the
concentration of hydrogen ions that cause acidity.

Some surface waters are naturally acidic. This is
largely due to  (1) carbon dioxide from the atmos-
phere dissolving to form carbonic acid and (2) or-
ganic acids produced by the decay of dead plant
materials. Waters in some bog lakes, for example,
can have natural pH levels below 5.0.  Similarly,
pure rain water and distilled water in equilibrium
with atmospheric concentrations of carbon dioxide
naturally have pH  levels near 5.6. Dissolution of
natural  organic  acids from the  atmosphere  into
rain water  has been found to increase  rain  water
acidity and lower pH to  near 5.2 in some pristine
open ocean areas.

The natural tendency of some surface waters to be
acidic is countered by common, alkaline minerals
such as limestone that dissolve into them. This  dis-
solution  neutralizes the  acidity,  often  producing
slightly  alkaline conditions (alkalinization).  The
dissolution of many minerals not only neutralizes

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                                                                   CHAPTER 2:  ENVIRONMENTAL GOALS
acidic conditions in waters, it produces a buffering
capacity that enables  these waters to maintain
near-ambient pH conditions, while allowing their
mass of dissolved acids to vary within certain lim-
its. Additional buffering capacity can be produced
by solutions of weak  acids, including carbonic
acid and many organic acids. The extent of acid-
base  buffering within any natural water is deter-
mined by the specific  combinations of dissolved
materials.

In total, the  interaction of these natural acidifica-
tion, alkalinization, and buffering processes causes
the pH in most surface waters to range from about
6.5 to 8.0.  Much  of the concern about  surface
water acidification  focuses on the effects that may
occur with  decreases of 0.5 to 2.0 pH  units or
more (i.e., increasing acid concentrations  in the
environment by 500 to 10,000 percent or more).

Acid neutralizing  capacity (ANC)  is the  term
commonly used to describe the concentration of
dissolved  compounds present in fresh water that
collectively tend to neutralize water pH,  creating
less acidic and more alkaline conditions. Greater
ANC generally correlates with  greater buffer ca-
pacity in the water. In  most fresh waters ANC is
determined primarily by concentrations of carbon-
ate and bicarbonate, which generally dissolve into
concentrations of bicarbonates,  carbonates,  and
hydroxides in water. The total capacity of a  sur-
face water to neutralize acidity can include other
chemical  and biological processes—the most im-
portant of which are the biologically  mediated
processes of  sulfate (SO42-) and nitrate (NO3~) re-
duction.

Surface waters  with  higher ANC  are  generally
more resistant to acidification and have higher pH
levels.  That  is,  lakes  and  streams with  ANCs
greater than 200 microequivalents per liter (ueq/l)
have significantly moderated  potential for pH fluc-
tuations  below  6.0.  Also,   they generally have
minimal development of acidic water qualities that
can  be stressful, or even  toxic, to  aquatic  organ-
isms. In turn, waters with  ANCs of 50 ueq/l or less
tend  to be  the most sensitive to severe  and
long-term pH depressions below 6.0, which  can
produce the  most severe effects on aquatic  life.
The  general  empirical  relationship between pH
and  ANC was determined during EPA's Nitrogen
Bounding Study (NBS) (see Section 2.5.3) for three
regions in the eastern United  States that contain
sensitive ecological resources (Exhibit 1). This ex-
hibit shows, for  example,  that an  ANC of 50 ueq/l
correlates  approximately  to  a pH of 6.5  across
these regions.
              EXHIBIT 1. EMPIRICALLY DETERMINED RELATIONSHIP BETWEEN ANC AND pH FOR THREE
               SENSITIVE REGIONS, INCLUDING CROSS-REGIONAL MEAN AND STANDARD DEVIATION
ANC
(ueq/l)
-10
0
10
40
50
60
Empirical pH for Sensitive Regions
Adirondacks
4.96
5.28
5.69
6.31
6.41
6.50
Mid-
Appalachians
4.98
5.30
5.72
6.36
6.47
6.55
Southern
Blue Ridge
4.95
5.27
5.78
6.53
6.65
6.73
Mean pH
4.96
5.28
5.73
6.40
6.51
6.59
Standard
Deviation
0.02
0.02
0.05
0.12
0.12
0.12
the water from  calcium carbonate (the predomi-
nant chemical constituent of limestone, for exam-
ple). Concentrations  of borates, phosphates,  sili-
cates, sulfides, and organic anions can also con-
tribute to total ANC in surface water.  In earlier lit-
erature, the term alkalinity was often used in place
of ANC.5 In most recent literature, however, alka-
linity is used primarily in discussing total dissolved
   Drever, J.I.  1982. Geochemistry of Natural Waters.
   Prentice-Hall, Inc., Englewood Cliffs, Nj.
Acidic deposition can lead to two kinds of acidifi-
cation processes. First, over the  longer term, the
fundamental  character of soil and water chemis-
tries can shift to chronically acidic conditions due
to the input and accumulation of deposited acidic
ions.  Such conditions can produce adverse envi-
ronmental  effects  which  may  be  long-term,
chronically  toxic,  and  lethal.   Second,  acutely
acidic conditions can rapidly develop during peri-
ods leading to,  accompanying,  or following  epi-
sodic events, which primarily  accompany  dis-
charges  of  storm  and  snowmelt  water  runoff.

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 Pulses of  highly  acidic water flushing  into and
 through soils, streams, and lakes often expose soil
 and aquatic biota to short-term, acutely  toxic, le-
 thal chemical conditions.

 When considering acidification effects, it  is impor-
 tant to recognize that the earliest adverse  effects to
 biological  components  of an  aquatic ecosystem
 commonly accompany early episodic acidification
 events. For acid-sensitive fish species, for  example,
 these events often cause complete spawning or re-
 cruitment  failures.  As chronic acidification  be-
 comes  more pronounced, such  effects  become
 more frequent and may result in further impacts to
 overall species richness. In contrast, for systems
 recovering from acidification,  this  sequence re-
 verses as occasions of episodic effects become less
 and less frequent, until acidification effects appar-
 ently end.

 As more fully discussed in several of the following
 sections, available information  indicates  that sur-
 face  waters  with  ANCs<50 ueq/l  include  the
 aquatic resources most sensitive to potential effects
 from episodic acidification. Thus, ANC  is a very
 important  response variable for use  in evaluating
 acidification-related  changes in  surface waters,
 particularly streams. As such, ANC is a primary fo-
 cus of discussion throughout this chapter.  The next
 four subsections review potential chemical rela-
 tionships,  episodic  acidification,  cumulative ef-
 fects, and  recovery processes associated  with soil
 and water acidification.  Biological  implications
 are discussed in reviewing of identification of re-
 source priorities. Additional issues are summarized
 in Appendix A, Summary of NAPAP reports.

 2.2.1  Relationship of Base Cations, Sulfur,
       and Nitrogen in Surface Water
       Acidification
 Acidic deposition increases total loads of hydrogen
 ions (H+) and acidic anions (primarily SO42' and
 NO3") in watersheds. A vast majority of these de-
 posited ions interact within the  watersheds, ex-
 changing with and displacing ions of other chemi-
 cal species  from  watershed  receptors  primarily
through soil weathering and chemical equilibrium
 processes in soil waters. Most watershed ions ex-
 changed for deposited ions enter  soil water solu-
tions  and  subsequently drain  into  streams and
 lakes.

 In a report that provided  much of the  basis for
 EPA's modeling research on watershed responses
to acidic deposition, the National Academy of Sci-
ences (NAS)  identified two geochemical processes
as  the  dominant  watershed  factors  mediating
long-term surface water acidification.6 The first is
the  rate at which watershed  sources exchange
base cations, especially calcium (Ca2*) and  mag-
nesium (Mg2+), for H+ through neutralization and
buffering processes. Essentially all base  cations
within a watershed are supplied initially through
the relatively slow  process of mineral weathering,
while  much more  rapid supplies  of base cations
can  be available  through  exchange processes
within  soil solutions and by  soil biota. Acidic
deposition can accelerate each of these processes.

The  second dominant factor that NAS identified as
affecting acidification is the capacity of a water-
shed to retain deposited  sulfur-containing  com-
pounds.  This process is important because a vast
majority of atmospherically deposited sulfur is in
the form of SO42" or other inorganic sulfur-contain-
ing compounds that rapidly oxidize to SO42'. The
process of SO42- adsorption by soils directly affects
the mobility of SO42- in watersheds and, thus, the
mobility of assorted base cations  and acidic cat-
ions (e.g., H+ and aluminum, AI3+).

The  NAS report concluded that the external proc-
ess of  acidic ion deposition balanced against in-
ternal watershed processes of base cation supply
(i.e., acid assimilation) and SO42' adsorption (i.e.,
anion mobility) critically determine the rates and
degrees  of long-term  acidification of  soil  and
water.  The production of base cations and internal
retention of sulfur in watersheds can decrease as
available supplies  of base cations and SO42~  ad-
sorption  abilities are depleted. Surface waters in
watersheds with insufficiently available base cat-
ion supplies and minimal  net annual sulfur reten-
tion  tend to be at greater risk from acidic deposi-
tion.

EPA  initiated the Direct Delayed Response Project
(DDRP) (see Section 2.5.2) to help understand how
these factors interact and affect environmental re-
sponses to acidic deposition. This project primarily
addressed the question of whether watersheds tend
to acidify immediately in proportion to the inten-
sity of deposition (i.e., "direct" acidification) or lag
6 National Academy of Sciences.  1984.  Add Deposi-
  tion: Processes of Lake Acidification, Summary of a
  Discussion. National Research Council Commission
  on Physical Sciences, Mathematics, and Resources.
  Environmental Studies Board, Panel on Processes  of
  Lake Acidification. National Academy Press,  Wash-
  ington, DC. 11 pp.
                                                 10

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                                                                    CHAPTER 2: ENVIRONMENTAL GOALS
in time due to internal watershed processes (i.e.,
"delayed" acidification).

Unquestionably,  watershed processes regulating
base cation exchange and retention of atmospheri-
cally deposited sulfur are two primary controls on
surface water acidification  rates that must be un-
derstood  to allow projection  of potential  acidic
deposition effects. More recent research shows,  in
addition,  that direct projection  of  surface water
acidification rates from acidic deposition also de-
pends  upon, and continues to be limited by, major
uncertainties regarding  the capacities of  water-
sheds to assimilate nitrogen deposition. That is, al-
though NO3~ is often  an important acid  anion  in
acidic deposition, nitrogen is also an essential nu-
trient  in  high  demand  by  many physiological
processes within organisms. Its frequent scarcity in
many environments, relative to other essential nu-
trients, often limits plant growth and other biologi-
cal activities. Thus, because nitrogen is a fertilizer
that often quickly incorporates into organisms, the
ANC of soils and surface waters is relatively un-
changed.  Consequently, only a  generally limited
past concern and a narrowly defined  research ef-
fort has been focused on  ecological effects associ-
ated with nitrogen deposition in watershed acidifi-
cation.

An expanding body of recent  research, however,
shows  that  nitrogen deposition is  an important
component and an increasing cause of present and
future acidification in some environments. Specifi-
cally, there are limits to the amount of  nitrogen
that can be incorporated into organic matter by
biological  processes  in  watersheds.  When these
processes are saturated (i.e., when nitrogen is no
longer the limiting nutrient  for biological produc-
tion and growth),  nitrogen losses from watersheds
will increase, principally in the form of NCy
leaching.  Excess  NO3"  in watersheds  can lead  to
depletion  of base cations and surface water acidi-
fication through the same processes as those  in-
volving excess SO42~. For example, European for-
ests apparently are becoming nitrogen saturated,
and the need for specific additional emissions con-
trols to protect European forests and surface waters
from the detrimental effects of excessive  nitrogen
deposition are being evaluated.7
Further, data  from Long-Term Monitoring (LTM)
sites in the northeastern United States strongly in-
dicate a  regional decrease in lake  and stream
water SO42~ through 1989 (the end of the period of
record assessed), suggesting that  sulfur deposition
is declining. A concurrent, general increase in lake
and stream water NO3~ concentrations was found
primarily  in the Adirondack  and Catskill Moun-
tains,  suggesting that  these watersheds  may be
moving toward watershed nitrogen saturation. Sur-
face water  NO3- concentrations did not  show
marked trends for most other areas  of the North-
east. Over this same period in the Northeast, both
pH and ANC  tended to increase, but these trends
are weaker than those found for SO42' and  NO3"
deposition. For  Adirondack lakes,  in  fact,  there
appears to be  a possible trend of  decreasing ANC.
Coupling these possible regional  ANC trends with
the apparent trends for SO42- and NO3" indicates
that surface water acidification effects may be be-
coming more  closely tied to  NO3"  deposition in
the Adirondacks and, possibly, other regions of the
Northeast. Research is continuing to evaluate more
completely this potential  shift in surface water
acidification relationships.

Of additional  concern  are episodes  of storm flow
or snowmelt runoff that can expose  organisms to
short-term, acutely lethal, acidic water.8  Episodic
events (described in detail in the following  section)
occurring  during spring snowmelt often tend  to be
the most acidic and contain the highest concentra-
tions of inorganic monomeric  aluminum, which is
highly toxic to fish.9 NO3~ tends to  be more mo-
bile in watershed soils at this time of the year be-
cause  most plants are  dormant. This fact and  the
prevailing cold  temperatures through winter and
early spring tend to promote increasing NO3~  ac-
cumulations in soil and overlying snowpack.  Espe-
cially  during these periods, snowmelt and storm
7 Sullivan, T.J.  1993.  Whole-ecosystem nitrogen ef-
  fects research in Europe.  Environmental Science and
  Technology 27(8): 1482-1486.
8 Wigington, P.J., Jr., J.P. Baker, D.R. DeWalle, W.A.
  Kretser, P.S. Murdoch, H.A. Simonin, J. Van Sickle,
  M.K.  McDowell,  D.V.  Peck,  and  W.R.  Barchet.
  1993.   Episodic  Acidification  of Streams in  the
  Northeastern United States:  Chemical and Biologi-
  cal  Results  of  the Episodic  Response  Project.
  EPA/600/R-93/190.  Office of Research and Devel-
  opment,  U.S.  Environmental  Protection  Agency,
  Washington, DC.
9 Baker, J.P., and S.W. Christensen.  1991.  Effects of
  acidification  on biological communities in aquatic
  ecosystems.  Pages 83-106 in D.F. Charles (editor).
  Acidic Deposition and Aquatic Ecosystems  -  Re-
  gional Case  Studies.   Springer-Verlag, New York,
  NY.
                                                 11

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 water runoff can flush NO3" through the watershed
 at flow rates that exceed the assimilative capacity
 of terrestrial plants to capture the rapidly passing
 nutrients. Cold water temperatures  also slow the
 ability of aquatic organisms  to  incorporate the
 newly added NO3".  As a result,  NO3~  can be a
 significant seasonal cause of episodic acidification
 in surface waters in some regions, often  occurring
 at the most biologically significant time  of year
 (i.e., during spawning and reproduction).

 2.2.2  Episodic Acidification
 This report primarily focuses on chronic effects to
 surface waters associated with long-term exposure
 to acidic deposition, because much past research
 has  emphasized processes leading to  long-term
 chronic  acidification. In  surface waters  that have
 not  completed processes leading to  chronic acidi-
 fication  or are  in the process of recovering from
 chronic  acidification, the largest impacts of acidic
 deposition most commonly accompany episodic
 acidification.  Episodic  acidification  (temporary
 loss of ANC) can  occur when pulses of  low-ANC
 or acidic waters enter streams and lakes  as the re-
 sult  of rainstorms  or  snowmelt. Acid anions (i.e.,
 sulfate and nitrate) that  reach surface waters dur-
 ing  these events  may originate from immediate
 deposition or,  more  likely, may be the result of
 prior atmospheric  deposition  (i.e.,  the previous
 year) that has cycled within the watershed and is
 flushed from the  system during the  high storm
 flows. Accompanying  the acid  anions  during
 leaching are  acids or toxic aluminum compounds
 leached from soils. Both  sulfates and nitrates origi-
 nating from atmospheric deposition may contrib-
 ute  significantly to  such episodic  acidification
 events. Episodic acidification can cause lakes and
 streams that have positive ANC during most of the
 year to become acidic (ANCSO p.eq/1) and have
 high toxic aluminum  concentrations  for periods of
 hours to days.

 The  most severe episodes of acidification occur in
 the  spring. The National Surface  Water  Survey
 (NSWS) (described in Section 2.4), however, sur-
 veyed  lakes  in  the Adirondacks during the fall.
 Significantly, more lakes and streams become epi-
 sodically acidic than  are chronically acidic. Most
 recent estimates indicate that for the worst episode
that  may occur during any year,  the number of
 lakes or streams that  were acidic during that epi-
 sode in  the Adirondacks is  approximately  3.5
times the number found to be chronically acidic.
Thus, for the Adirondacks, approximately 70 per-
cent of the target  population  lakes are at risk of
 episodic acidification at least once during each
 year. For the mid-Appalachian streams, approxi-
 mately 30 percent of the target population stream
 reaches are likely to  be acidic during the worst
 episode. This is roughtly 7 times the  number of
 chronically  acidic stream  reaches.  Due  to data
 limitations, comparable anlayses  are not possible
 for streams in the Southern  Blue Ridge. Lower lev-
 els of acidic deposition will lower the number and
 severity of acidic and toxic  episodes driven by sul-
 fate and nitrate.

 EPA recently completed its  Episodic Response Pro-
 ject.™ Major conclusions  from  that project in-
 clude:

   » Acidic deposition episodes,  evidenced by
     stream water containing elevated SO42' and
     NO3- concentrations during  the episodes,
     were a  common occurrence in the  study
     streams  of all three  regions  investigated
     (i.e.,   the   Adirondack   and   Catskill
     Mountains of New York and the Northern
     Appalachian Plateau of Pennsylvania).

   *  Acidic episodes were  common in  streams
     of  each  region  wherever and whenever
     ANC values were 50 ueq/l or less immedi-
     ately before the episode. When acidic epi-
     sodes occurred, they were accompanied by
     depressed pH levels and elevated concen-
     trations of inorganic monomeric aluminum
     (AW-
   *  Elevated concentrations of SO42' in Penn-
     sylvania streams  and  of NO3"  in  Catskill
     and Adirondack streams augmented natural
     processes during episodes to produce lower
     ANC and pH and  higher Alini levels than
     would have occurred due to natural proc-
     esses alone.

   *  Even when SO42' and NO3" concentrations
     did not markedly increase during episodes,
     elevated baseline concentrations of SO42-
     in all regions and of NO3~ in  the  Catskill
     and Adirondack streams lowered minimum
10 Wigington, P.J., Jr., J.P. Baker, D.R. DeWalle, W.A.
  Kretser, P.S. Murdoch, H.A. Sinonin, J. Van Sickle,
  M.K. McDowell,  D.V.  Peck, and W.R.  Barchet.
  1993.  Episodic  Acidification  of Streams in  the
  Northeastern United States:  Chemical and Biologi-
  cal Results  of the Episodic  Response  Project.
  EPA/600/R-93/190. Office of Research and Devel-
  opment,  U.S.  Environmental Protection  Agency,
  Washington, DC.
                                                12

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                                                                    CHAPTER 2:  ENVIRONMENTAL GOALS
     ANC and  pH  below  levels naturally ex-
     pected during episodes.

   * Fish in all three regions studied, exposed to
     low pH and high Alim over longer periods
     of episodic exposure had higher short-term
     mortality   rates   and  showed   greater
     long-term adverse population-level  effects.
     Time-weighted median Alim concentration
     was the single best predictor of brook trout
     mortality found during these studies. Fur-
     thermore, it was concluded that stream as-
     sessments based solely on  chemical meas-
     ures during low flow do not accurately pre-
     dict the status of fish communities in small
     streams.

   * The ability of fish to avoid episodic acidic
     water conditions by moving to less affected
     waters only partially mitigated the adverse
     effects in small streams.  Such behavioral
     adaptations were not  sufficient to  sustain
     fish  density or biomass at the levels ex-
     pected in the absence of acidic episodes.

   * Brook trout density and biomass were not
     different    between    chronically   acidic
     streams and  streams with  episodes where
     ANC decreased to less than 0 ueq/l. Differ-
     ences did exist, however,  between streams
     with higher  ANC with and without epi-
     sodes.

This last  point  supports the hypothesis  that epi-
sodic acidification can be the primary cause of ad-
verse effects to  brook trout (and other ecological
components) in  acid-sensitive streams (i.e., ANC<
50 ueq/l). These episodic effects potentially equal
those seen  in chronically acidic streams (ANC<
0 ueq/l).  Indeed,  effects  from  severe   episodic
acidification (i.e., events  leading to ANC<0 ueq/l
in surface waters)  are likely the first source of bio-
logical  damage to most aquatic populations and
communities inhabiting waters that have become
chronically acidified. The continuing adverse eco-
logical  effects  from episodic events often blend
with and become indistinguishable from all other
effects accompanying chronic acidification.

The findings  of  this  study and other  analyses
clearly point to  the importance of considering po-
tential  effects  of  both  long-term  chronic and
short-term episodic acidification when considering
the effectiveness of an acid deposition standard or
standards.
For most  regions of North  America  at  risk from
acidic deposition, the effects from nitrogen deposi-
tion on  aquatic systems are more likely to remain
primarily episodic in nature, except when water-
sheds move toward nitrogen saturation, and nitro-
gen increasingly becomes a direct cause of both
episodic and chronic acidification. Currently, data
available for most regions are inadequate to exten-
sively assess episodic  effects  related  to  nitrogen
deposition or to assess the potential for and rate of
watershed nitrogen  saturation. Furthermore, while
available data on episodic  acidification  may  in-
crease,  because of  the difficulty, expense,  and
often  the  risk involved in collecting  data during
episodic events (e.g., intensive spring  sampling in
high-elevation snowmelt areas), data bases for as-
sessing  episodic effects are not likely to become
comprehensive.  Clearly,  both  SO42~  and  NO3"
deposition  can have major influences in surface
water acidification processes. Evaluating the effec-
tiveness of and options for acid deposition  stan-
dards should include simultaneous consideration
of both acidification causes.

2.2.3  Cumulative Loading  Effects
Deposited sulfur and nitrogen can be incorporated
into watersheds over the long term through a vari-
ety of physical, chemical,  and biological proc-
esses. Current evidence suggests that the principal
dynamic mechanism of concern  with regard to
watershed sulfur retention is physical/chemical in
nature (i.e., adsorption of inorganic  sulfate).  On
the other hand,  the principal  dynamic storage
mechanism  of  nitrogen retention  in  watersheds
appears to be biological in nature. Non-biological
removal mechanisms also may  incorporate some
nitrogen into long-term storage within some water-
sheds, but this process is poorly understood.

Overall, the dynamics of sulfur  adsorption  and
desorption and  nitrogen retention over landscapes
of different scales (watersheds  to regions) can vary
significantly. Considerable  uncertainty  exists in
understanding these dynamics. Despite this uncer-
tainty, available results strongly indicate that time
is critical  in defining sensitivities  of  resources to
inputs of both sulfur and nitrogen. While most wa-
tersheds can assimilate considerable quantities of
both chemicals without significant adverse effects,
their assimilative capacities are finite. Watershed
assimilative capacities vary  with how rapidly  de-
posited  chemicals are  assimilated and the time
over  which  repeated deposition  events impair
these abilities.  In other words,  there  are varying
deposition frequencies, rates, and  durations when
                                                 13

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
watershed assimilative capacities reach saturation.
This is sometimes called steady state,  the point
when the output (loss) of a substance from a wa-
tershed (e.g., sulfur leaving  a watershed in  the
form of SO42' in stream flows) equals  its input
(e.g., as sulfur-containing compounds in deposi-
tion) on an annual basis.

Although sulfur deposition over the long  term can
lead to equilibrium  or steady state  in watersheds,
similar steady-state conditions for nitrogen deposi-
tion are likely to be much less common. This is
because nitrogen uptake dynamics are  affected
much  more  by biological changes within water-
sheds, such as forest cutting and regrowth as well
as natural vegetative succession. Consequently, as-
sessing the  history  of both  sulfur and  nitrogen
deposition is important in assessing long-term ef-
fects attributable to  cumulative loadings by acidic
deposition.

A resource's  or region's current sensitivity to acidic
deposition, therefore,  needs to  be  evaluated with
respect to the historical deposition patterns and re-
sponses. Many regions with  ample buffering  ca-
pacity and remaining sulfur and nitrogen adsorp-
tion capacities may benefit  little from future de-
creases in  acidic deposition. Other regions facing
imminent depletion of their buffering or adsorption
capacities, however, would likely  be highly re-
sponsive  to  decreasing  deposition  rates.  The
DDRP,  discussed in  Section 2.5.2, provides a use-
ful  beginning for understanding underlying rela-
tionships and defining remaining uncertainty about
post-deposition dynamics of  atmospheric sulfur
deposition in watersheds within three regions  of
the eastern United States. The Nitrogen Bounding
Study (NBS), discussed in Section 2.5.3,  provides
additional  useful  results  to  improve  our  under-
standing of the influence  of nitrogen saturation on
watershed  processes affected by combined sulfur
and nitrogen deposition within the three regions
studied in the DDRP.

2.2.4   Recovery of Acidified Ecosystems
Acidified ecosystems can show signs  of  recovery
following reductions  in  acidic  deposition rates.
Benefits have  been  demonstrated  in  (1) regions
where major local source emissions have been re-
duced, (2) experimental aquatic and terrestrial sys-
tems where applied  doses of acids  have  been re-
duced or ended,  (3)  limed watersheds and surface
waters,  and (4) model projections. Varying degrees
of  successful  recovery  in communities of mi-
crobes,  algae, higher plants,  invertebrates, fish,
and amphibians were noted in the 1990  NAPAP
studies.11  Degrees  of ecological  recovery,  how-
ever, did vary among the species,  groups, and
studies reviewed.

Recovery rates depend primarily on three  factors:
(1) rates of reduction in emissions and deposition
of  SO42'  and  NO3";  (2) ongoing  acid retention
processes in  terrestrial  environments,  including
sulfate adsorption and base cation weathering; and
(3) time lags caused by delayed biological  process
responses. In some  instances, significant lags  are
involved  or irreversible changes  have  occurred.
The influence of such lags accompanying  slow,
gradual chemical improvements  are well  illus-
trated in a series of studies of Ontario lakes follow-
ing  reduced emissions  from  the Sudbury area
smelters.12

Mitigation strategies that attempt to restore  ecosys-
tems without reducing deposition (e.g., liming)  are
only partially successful in restoring water quality
and recovering biological  populations.  In fact,
rarely will distressed  ecosystems return to their
predisturbance condition after the cause of the dis-
turbance has been removed, because the complex
ecological interrelationships among predisturbance
species are rarely the same following disturbance
of the system and its recovery. When natural evo-
lutionary and successional regimes of predisturbed
systems are disrupted, competition  for nutrients
and other habitat resources and predatory relation-
ships among species in  recovering  systems have
subtle to substantive differences from their predis-
turbance  relationships. Thus,  restoration  to the
"predisturbance condition" is not always possible,
nor is it necessarily an appropriate goal.13 Altema:
tively,  rehabilitating or rejuvenating selected  at-
11 Baker,  J.P., D.P. Bernard,  S.W. Christensen,  M.J.
  Sale, J. Freda, K. Heltcher, D. Marmorek, L. Rowe, P.
  Scanlon, C. Suter, W.  Warren-Hicks, and P. Wei-
  bourn.  1990.  Biological Effects of Changes  in Sur-
  face Water Acid-base Chemistry. NAPAP Report 13.
  In:  Volume II,  National Acid  Precipitation Assess-
  ment Program,  Acidic Deposition:   State of Science
  and  Technology.   Superintendent of Documents,
  Washington, DC.
12 Keller,  W., J.R. Piblado,  and J.  Carbone 1992.
  Chemical responses of  acidic lakes in the Sudbury,
  Ontario area to reduced smelter  emissions, 1931-
  1989.  Canadian Journal of Fisheries and Aquatic
  Sciences 49 (Suppl. 1):25-32.
13 Cairns, J., Jr. 1989.  Restoring damaged ecosystems:
  Is predisturbance condition a viable option?  Envi-
  ronmental Professional 11:152-159.
                                                 14

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                                                                    CHAPTER 2:  ENVIRONMENTAL GOALS
tributes or functions may be all that is required for
restoration to be deemed successful.

A recent review  and assessment concluded that
uncertainty  remains  concerning the definition  of
appropriate measures of reversibility and recovery
for acidified ecosystems.14 Differences  exist par-
ticularly  between setting  goals based on hu-
man-centered objectives (e.g., fish production for
human use) versus more intangible ecological and
conservation purposes.  Further, assessment of eco-
system recovery following deposition reductions
can be obscured by other environmental perturba-
tions  such as climate change and modified land-
use practices.

2.3 CHARACTERIZING RESOURCES AT RISK FROM
     ACIDIC DEPOSITION
Relationships of resources to acidic deposition de-
pend on  two characteristics: resource  sensitivity
and acidic  deposition  exposure rates. Simultane-
ously  considering regional distributions of both
characteristics allows assessments of risk potentials
produced by acidic deposition over discrete geo-
graphic regions. This approach helps to  define re-
gional needs for and effectiveness of acid deposi-
tion standards. In this process, sensitivity is an in-
herent attribute of an individual resource that in-
creases its susceptibility to likely adverse  effects
due to acidic deposition. Exposure is determined
by the deposition intensity, frequency, duration,
and specific times that  acidic deposition falls into
an area. Risk is the probability that exposure to po-
tentially hazardous environmental conditions pro-
duced by acidic deposition will  exceed the toler-
ance  level for a sensitive resource  and cause an
adverse effect. For any  sensitive resource to be at
high risk  from any hazardous substance or envi-
ronmental condition, it  must have a high probabil-
ity of being sufficiently exposed to the  substance
or condition, such that  its inherent ability to toler-
ate the change will be exceeded and adverse ef-
fects will likely result.  Because environmental re-
sources have ranges of sensitivities and risks to po-
tential  effects  caused  by  acidic deposition,  re-
sources having  equivalent  sensitivities  can have
14 Dise, N, W. Ahlf, C. Brahmer, BJ. Cosby, J. Fott, M.
   Hauns,  I.  Juttner, K. Kreutzer,  C.G. Raddum, and
   R.F. Wright.  1994.  Group Report:  Are Chemical
   and Biological Changes Reversible?  Pages 275-381
   in C.E.W. Steinberg and R.F. Wright (editors). Acidi-
   fication of Freshwater Ecosystems: Implications for
   the Future.  J. Wiley and Sons, New York, NY.
different risk potentials for adverse effects depend-
ing on where they are located.

The next two subsections review in more detail the
concepts of  resource sensitivity  and risk  as they
apply  to acidic deposition. Understanding these
concepts is essential for determining

   * Locations containing  sensitive resources at
     risk,

   * Which sensitive resources may be the app-
     ropriate primary focus of protection,

   * Appropriate environmental  assessment in-
     dicators, and

   * The extent of protection afforded.

2.3.1   Defining Sensitive Resources
There  are different types  of sensitivities to acidic
deposition,  and a resource can  be insensitive to
one effect while being sensitive to others. For ex-
ample, a region with highly alkaline surface waters
may saturate with nitrogen.  This  saturation could
lead to no  change in surface water acidity,  but
could  lead to significant  increases in eutrophica-
tion downstream. Consequently, the term sensitive
can be imprecise and confusing.  It can be used to
describe different scales of resolution for different
resource units (e.g.,  extent of  landscape areas,
water  chemistry characteristics, or species group-
ings), and different degrees of resource sensitivi-
ties. Also, each use has different scientific and pol-
icy implications. Such differences affect each  po-
tential criterion used  in determining acid deposi-
tion standards. Thus, when  considering potential
resource effects and risks, it is important to care-
fully define  the  specific  ecosystem components
within the region and specific  concerns regarding
the sensitivity being addressed.

An early MAS  report  indicated  that  lakes and
streams with ANCs of 200 ueq/l  or less are sensi-
tive and subject to damage at  moderate acidic
deposition   rates,  whereas  surface  waters with
ANCs  of 40 ueq/l or less are critically sensitive to
such effects.15 Although ANC  is  an important re-
sponse indicator of potential surface water sensi-
tivity,  it is not the only relevant response indicator
of  sensitivity. For example, the  presence  or  ab-
sence  of acid-sensitive fish, invertebrates, algae,
15 National Academy of Sciences.  1983.  Acid Depo-
   sition:   Atmospheric  Processes in Eastern  North
   America. National Academy Press.
                                                 15

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 and higher plant species are other relevant indica-
 tors of potential sensitivity and acidification prob-
 lems in  lakes and streams. Further, knowing the
 ANC of surface or ground waters provides little in-
 dication of the actual sensitivity of neighboring ter-
 restrial  resources.  For example,  injury  to  red
 spruce foliage  attributable to  acidic  deposition
 typically has little direct relationship to the ANC of
 neighboring soils or waters.  Consequently, when
 there is a need to assess potential  effects of acidic
 deposition on terrestrial resources or ecosystems,
 assessments  should consider other parameters or
 indicators of sensitivity in addition  to ANC.

 Because numerous natural phenomena and proc-
 esses  influence the sensitivity and  potential  risk
 status of resources, interpretation and projection of
 receptor  responses  to acidification are difficult.
 Factors that should be carefully evaluated when
 assessing needs for acid deposition standards  in-
 clude naturally occurring  organic acidic systems,
 annual and seasonal variabilities in precipitation,
 and related climatic variability. Land and resource
 use  (e.g., changes in fishing  pressure,  point and
 nonpoint nutrient discharges,  mining runoff, and
 other  watershed activities) also potentially  con-
 found interpretation of acidification sensitivity and
 effects. The  types  of  effects  caused by many of.
 these factors are summarized in Exhibit 2. The list,
 although  incomplete,  shows that  a considerable
 matrix of factors interact to determine the potential
 sensitivity  of individual  surface  waters,  water-
 sheds, and the  natural  resources they contain.
 These interactions cause differences in sensitivity
 and  responses  to  acidic  deposition  among  re-
 sources within individual  watersheds and  among
 adjacent watersheds. Many factors summarized in
the exhibit are discussed in greater detail in subse-
quent sections.

 Exhibit 2 also suggests  a focus on  potential acidic
deposition effects  linked  to  terrestrial  soils and
 aquatic resources. Such a focus is not  surprising,
because  most acidic deposition eventually flows
through soils and  into aquatic systems.  Responses
by these resources to  acidic deposition are clear,
well understood, and  in many  cases well docu-
 mented.  Therefore, most of the  following discus-
sion concentrates on concerns associated with en-
vironmental changes in soils,  lakes, and streams.
Wherever possible, however, discussion is punctu-
 ated with summaries and highlights of potential  re-
 lationships of acidic deposition to  other terrestrial
 resources.
Our accumulated knowledge indicates that sensi-
tive resources can be defined over multiple ranges
of temporal, geographic, geochemical, and bio-
logical  categories and scales.  Also,  aquatic re-
sources can be  sensitive to episodic short-term
acidification,  chronic long-term  acidification,  or
both. Fundamental factors  and  attributes  associ-
ated with differences in sensitivity include:

   « ANC of surface and ground waters;

   • Supply of base cations from bedrock and
     soil particle weathering;

   • Supply of base cations and buffering by soil
     solutions;

   * Physical and chemical adsorption, desorp-
     tion, and reduction of sulfate;

   • Biological assimilation  of  nitrogen within
     watersheds; and

   » Ability of sensitive  resident organisms  to
     modify physiological processes or behavior
     patterns or otherwise escape in response to
     habitat changes  attributable to  acidifica-
     tion.

Thus, although considering levels of  ANC in as-
sessing sensitive resources is important, consider-
ing the presence and possible implications of other
indicators of  potential sensitivity (including the
occurrence of  threatened and endangered species)
is often equally important. Appropriate definitions
of sensitivity may therefore vary with  precise pol-
icy questions being asked. When the primary con-
cern is protecting water quality in  sensitive surface
waters, ANC often can be a useful response indi-
cator. If concern is broadened to include the sensi-
tivity of all natural resources, the approach used to
classify sensitivities also should be expanded.

In congressional  discussions regarding the man-
date for an  acid deposition standard  study, Con-
gress  followed the example  of  the  NAS  report
noted above in distinguishing between resources
that are "sensitive" and those that are "critically se-
nsitive" to the effects  of acidic  deposition. Re-
source sensitivity occurs on a continuum. Conse-
quently, rather than refining assessments in the fol-
lowing sections to distinguish among responses for
subcategories of sensitive resources (i.e, sensitive
versus critically sensitive), it is  more  valuable to
assess the degree to which  sensitive resources, in
general, are exposed to different levels of risk from
                                                  16

-------
                                                                    CHAPTER 2: ENVIRONMENTAL GOALS
                    EXHIBIT 2. PRINCIPAL WATERSHED AND SURFACE WATER CHARACTERISTICS
                         THAT INFLUENCE RESOURCE SENSITIVITY TO ACIDIFICATION3
Category
Bedrock geology
Soils:
Buffering capacity
Depth
SO42' adsorption
SO42- reduction
NO3- retention
Topography
Watershed to surface water
area ratio
Lake flushing rate
Watershed vegetation and land use:
Dominant vegetation
Cultural influence
Forest management
Water quality:
Alkalinity/ANC
SO42- reduction
Trophic status
Humic substances
Sphagnum moss
Climate/meteorology.
Precipitation
Snow accumulation
Growing season
Alkaline dusts
Increased Sensitivity
Resistant to weathering
(metamorphic, igneous)

Lower potential
Shallower
Lower potential
Lower potential
Lower potential
Steep-sloped
Lower

Higher
Coniferous
Forested
Reforestation
Lower (< 200 ueq/l)
Lower potential
Highly oligotrophic
Lowest concentrations
Present
Higher
Higher
Shorter
Lower
Decreased Sensitivity
Easily weathered
(sedimentary, calcite containing)

Higher potential
Deeper
Higher potential
Higher potential
Higher potential
Shallow-sloped
Higher

Lower
Deciduous
Agriculture, municipal
Deforestation
Higher (> 200 ueq/l)
Higher potential
Less oligotrophic to eutrophic
Higher concentrations
Absent
Lower
Lower
Longer
Higher
    a  Modified from Marcus, M.D., B.R. Parkhurst, and F.E. Payne. 1983. An Assessment of the Relationship
      among Acidifying Depositions, Surface Water Acidification, and Fish Populations in North America.
      EA-3127, Volume 1, Final Report. Electric Power Research Institute,  Palo Alto, CA.
acidic deposition across different geographic ar-
eas. As such, the term critically sensitive resource
is  not used in  this report. Much of the following
discussion does, however, focus  on sensitivities
and responses for surface waters projected by EPA
model analyses for lakes and streams having ANCs
of 50 ueq/l or  less, a value that approximates the
ANC  value of 40 ueq/l considered  by MAS and
Congress to distinguish between their two sensitiv-
ity groupings of concern. Therefore, discussions in
the following section regarding acidification  rela-
tionships in lakes and streams with ANCs<50 ueq/l
can   generally  be  interpreted  as  applying  to
"critically sensitive" resources.
2.3.2  Identifying Resources at Risk
Sensitivity, as noted above,  is only one determi-
nant of potential risk. For a resource to be at risk, it
must be sensitive to a potential stressor and must
have an actual or reasonable possibility of expo-
sure to  the stressor in a magnitude sufficient to
cause an  adverse effect.16 Sensitive resources are
at low risk when located where acidic deposition
16 Risk Assessment Forum. 1992.  Framework for Eco-
  logical Risk Assessment.  EPA/630/R-92/001.  U.S.
  Environmental Protection Agency, Washington, DC.
                                                 17

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 loads are currently below and are projected to re-
 main below thresholds likely to cause adverse ef-
 fects.  For example,  NAPAP studies  reviewed in
 Appendix A generally indicate that many surface
 waters in western North America are likely to be
 more sensitive to adverse effects from  acidic depo-
 sition  than  are similar resources in eastern  North
 America. Because current deposition  levels  in the
 West are generally below thresholds that produce
 long-term surface  water  acidification,  however,
 the  present  risk to these resources from chronic
 acidification  is low.  If the  intensity of western
 deposition increases, adverse chronic  acidification
 effects in the West might exceed those in the East.
 Consequently, the potential for high future risk to
 sensitive western resources remains a concern.

 Risk assessment, therefore, must address not only
 whether a location now receives sufficient acidic
 deposition to produce adverse effects,  but also the
 likelihood that the intensity and composition of the
 deposition  may  change  in  the future, thereby
 changing future exposure and potential risks to re-
 ceptor resources. Consequently, it is necessary to
 determine what residual risks to sensitive  resources
 remain after implementing emissions  controls re-
 quired by the CAAA, where these risks may be lo-
 cated,  and  their significance. For example, EPA
 modeling analyses indicate the degree to which
 sensitive resources will be protected when current
 Title IV requirements are fully implemented (i.e.,
 emissions reductions of 10 million tons  SO2 and
 2 million  tons NOX).  But,  how might  sensitive re-
 sources benefit from further decreases in deposi-
 tion  rates or implementation of a deposition stan-
 dard? How might these benefits change with vary-
 ing  additional reductions  of sulfur  or  nitrogen
 deposition?  How do possible changes in  sulfur or
 nitrogen retention within  watersheds  affect these
 possible relationships? The DDRP and  NBS, as dis-
 cussed  in Sections 2.5.2 and 2.5.3, begin  to an-
 swer these questions.

 Resources potentially sensitive to and  at  risk from
 acidic  deposition occupy vast expanses of water-
 sheds and forests, multitudes of lakes, and miles of
 streams in regions scattered across North  America.
 A  complete  census  of  these resources would be
 prohibitively time consuming and costly. Instead,
 assessments  of locations containing sensitive re-
 sources must depend on statistically based surveys,
 using proven  methods to characterize populations
 within  an estimated probability of error.  Regional
 and resource priorities for an acid deposition stan-
 dard or standards should  be based on such sur-
veys. Information  summarized  in Section 2.4 re-
views survey results useful in targeting geographic
regions at risk and identifying sensitive resources.

2.4 IDENTIFICATION OF RESOURCE AND
     REGIONAL PRIORITIES
2.4.1  United States
Scientific information from the extensive research
efforts supported and reviewed by NAPAP directly
apply to setting  needs and priorities for protecting
resources and regions sensitive to acidic deposi-
tion. Appendix A summarizes the major conclu-
sions from 10 of NAPAP's State  of  Science and
Technology reports. This section synthesizes gen-
eral findings from these  reports.17 Also summa-
rized here is additional information from more re-
cent research regarding  identification of regions
sensitive to the effects of acidic deposition  in the
United States18 and Canada.19

The NAPAP studies, which provide much  of the
best information currently available for the United
States, contain  clear  implications for identifying
resources most at risk from atmospheric deposition
of acidic compounds. Of all effects to environ-
mental resources from acidic deposition, the scien-
tific community best understands changes in lakes,
streams,  rivers, and soil chemistries. The rate and
extent  of acidic deposition effects  on  other  re-
sources are less clear.

  1. SOIL CHEMISTRY  EFFECTS:  In the   eastern
     United States,  concentrations of sulfur in
     soils generally follow trends in sulfur depo-
     sition. In some regions, soil concentrations
     of calcium  and  magnesium  are inversely
     related to sulfur deposition loads resulting
     in soil nutrient depletion. Further, a recent
     study suggests that most calcium and mag-
     nesium in the soil of the  spruce-fir ecosys-
     tem in the Northeast was lost 20-40 years
17 This review is primarily drawn from conclusions pre-
  sented by P.M. Irving (editor). 1991. Acidic Depo-
  sition: State of the Science and Technology - Sum-
  mary  Report of the U.S.  National Acid Precipitation
  Assessment Program.  National Acid Precipitation
  Assessment Program, Washington, DC.
18 The primary  source for this additional summary in-
  formation is  NAPAP.  1992.   Report to Congress.
  National  Acid Precipitation Assessment Program,
  Washington,  DC.
19 Brydges, T.C. 1991.  Critical loads, reversibility and
  irreversibility of damage  to ecosystems.  Pages 245-
  260 in Electricity and the Environment, International
  Atomic Energy Agency, Vienna, Austria.
                                                 18

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                                                                   CHAPTER 2: ENVIRONMENTAL GOALS
     ago  due  to  acidic  deposition,  when
     deposition  rates were increasing  rapidly.
     While  control  studies quantitatively  link
     changes  in soil chemistries to tree  and
     other plant responses, similar studies  link-
     ing acidic deposition effects on  soils to ac-
     tual  plant effects in nature remain incon-
     clusive.20 Many important studies are  con-
     tinuing, however. The most apparent influ-
     ence of  soil  chemistry responses attribut-
     able  to acidic deposition are seen in effects
     on surface waters (see Item  3, below).

  2.  FOREST AND AGRICULTURE CROP EFFECTS: De-
     veloping evidence indicates  that  acidic
     cloud water,  in combination  with other
     stresses, likely increases winter  injury, and
     reduces tree vigor  and growth,  and causes
     crown damage and death to high-elevation
     red spruce forests in the United  States, par-
     ticularly  in the northern Appalachians and
     high-elevation  regions of  the   Northeast.
     Evidence of acidic deposition involvement
     in the decline of red spruce in the southern
     Appalachians  is less  substantial. Involve-
     ment of acidic deposition in the decline of
     sugar maples in parts of the northeastern
     United States and  eastern Canada  has not
     been demonstrated but cannot be ruled out
     on the  basis  of available information.  Re-
     cent  information, in fact, indicates an ap-
     parent  improvement in sugar  maple  tree
     health since  1988,  with no visible effects
     from sulfate deposition, with the exception
     of  observed decline in health  of the  On-
     tario maple.21 The vast majority of forests
     in the United States and  Canada have not
     declined. Within forested  regions,  acidic
     deposition primarily exerts  its stress on nu-
     trient cycling. Some evidence suggest that
     lichen  communities and chemistries  may
     be useful early  indicators of forest health
     effects.  Ambient acidic deposition levels
     have not been shown to be responsible for
     agricultural crop yield reductions.
20 Brandt, C.J.   1994.  Acidic Deposition and Forest
  Soils: Potential Changes in Nutrient Cycles and Ef-
  fects on  Tree Growth.   Report to Watershed Re-
  sponse Program, Environmental Research Laboratory,
  U.S. Environmental  Protection Agency, Corvallis,
  OR.
21 U.S. EPA.  1994.  U.S. Canada Air Quality Agree-
  ment Progress Report.
3. SURFACE  WATER  ACIDIFICATION:  Numerous
   lines  of  evidence  support the  fact  that
   acidic deposition can  acidify surface  wa-
   ters and  that  acidification attributable to
   acidic deposition has occurred in sensitive
   aquatic systems during  this century  (see
   Appendix A).  Most  sensitive  lakes  and
   streams in the  United  States—especially
   those that have current ANCs of 50 ueq/l or
   more—probably  have not experienced re-
   cent chronic declines in  pH or ANC asso-
   ciated with acidic deposition.

4. REGIONS CONTAINING SENSITIVE SURFACE WA-
   TERS:  The National Surface Water Survey
   (NSWS) conducted under the auspices of
   NAPAP in 1984-85, identified six "high-in-
   terest areas" containing most of the surface
   waters surveyed (95 percent of the lakes
   and 84 percent of the stream reaches)  that
   were  chronically acidified  as indicated by
   concentrations of  inorganic  anions,  pre-
   dominately SO42-, NO3-, and Ch. These
   areas include the  southwest Adirondack
   Mountains,  New   England,   mid-Appala-
   chian  Region,  Atlantic  Coastal   Plain,
   northern  Florida  Highlands, and low-silica
   lakes   in  the  eastern  Upper   Midwest.
   Historical evidence  supports  the  premise
   that   acidic  deposition   undoubtedly  is
   related to surface water acidification in the
   Adirondacks,  the  Pocono/Catskill   subre-
   gion,  mid-Appalachians,  eastern portion of
   the Upper  Midwest, the New Jersey Pine
   Barrens, and, to a lesser extent, the Florida
   panhandle.  (Other  areas  of  the Mid-
   Atlantic Coastal Plain appear to be affected
   more by organic acidification and land-use
   activities such as  acid mine  drainage.)
   Chronic acidification of western  lakes from
   acidic deposition appears not to have oc-
   curred. The following subsections further
   describe  several  of the regions containing
   sensitive surface waters.

5. CHARACTERISTICS   OF   WATERSHEDS  CON-
   TAINING SENSITIVE SURFACE WATERS:  Surface
   waters most sensitive to acidic  deposition
   are often  located  in  watersheds  having
   shallow acidic soils  with rapid,  shallow
   subsurface flows. Acidic  lakes and  streams
   tend to occur in smaller watersheds and, in
   regions where significant elevation gradi-
   ents exist,  at  the  higher elevations (e.g.,
   watersheds less than 30 km2 and elevations
   greater than 300 m in the mid-Appalachian
                                                19

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
     region and the Pocono/Catskill  subregion).
     It must be noted, however, that these rela-
     tionships are derived from  studies empha-
     sizing watershed responses to sulfate depo-
     sition. Other, primarily biological, relation-
     ships exist where deposition of acidifying
     nitrogen  compounds  are  a significant  or
     predominant concern.

  6. RESPONSES BY SENSITIVE AQUATIC SPECIES AND
     ECOSYSTEMS: Acid-sensitive species occur in
     all major groups of aquatic organisms, but
     most is known about responses by fish and
     aquatic invertebrates.  In general, sensitive
     aquatic species inhabiting  surface  waters
     that   have  low  calcium  concentrations
     (<100-150 ueq/l) begin to  be affected by
     acidification processes as pH decreases be-
     low  about 6.0-6.5 (Exhibit 3) and as inor-
     ganic  monomeric aluminum  concentra-
     tions increase  above  30-50 ug/l.  These
     changes  affect these species first by de-
     creasing their ability to survive, reproduce,
     or compete  in acidic surface waters. Such
     responses can  eliminate  affected  species
     and  reduce species richness (i.e., the num-
     ber  of species  living within  a  surface
     water). Such changes typically occur first
     in affected surface waters  during episodic
     runoff events  (i.e., when  storm water  or
     snowmelt runoff causes short-term flushes
     of acutely toxic water chemistries to enter
     receiving  waters).  System-level  processes
     such as composition, nutrient cycling, oxy-
     gen  usage,  and photosynthetic rate are
     fairly robust and are affected only at rela-
     tively high levels of acidity (e.g., chronic
     pH less than 5.0-5.5).22

These findings  lead to several working conclusions
regarding  sensitive resources and regions at poten-
tially greatest  risk  from  acidification,  and  the
maximum degree of protection that may be neces-
sary. It is  on these resources, regions, and protec-
tion goals that  considerations should focus regard-
ing potential necessity and benefits of acid deposi-
tion standards:

  1. SENSITIVE RESOURCES OF PRIMARY CONCERN:
     Considering  that the natural resources most
     sensitive to acidic deposition would exhibit
22 Schindler, D.W.   1987.   Detecting Ecosystem  Re-
  sponses to Anthropogenic Stress.  Canadian Journal
  of Fisheries and Aquatic Sciences 44(Suppl.):6-25.
   the strongest  responses  and  provide the
   most conclusive evidence of  effects, it  is
   reasonable to conclude that the natural re-
   sources most sensitive to acidic deposition
   are aquatic systems and high-elevation red
   spruce forests. Therefore,  possible  future
   acid deposition standards focused on pro-
   tecting sensitive aquatic resources in the
   eastern United States and red spruce forests
   in the northern Appalachians and high-ele-
   vation regions of the Northeast should pro-
   vide adequate protection for most sensitive
   natural resources at risk. Protection of sens-
   itive aquatic resources should particularly
   focus on lakes and streams located where
   watersheds  are  smaller,   have  shallow
   acidic soils with rapid, shallow subsurface
   flows, and are at higher elevations.

2. REGIONAL PRIORITIES FOR PROTECTION:  In the
   eastern United States, the 1990 CAAA and
   any future acidic  deposition  controls are
   most likely to reduce the threats of acidic
   deposition  to  surface  water resources  in
   these regions: Adirondack  Mountains, Po-
   cono     and     Catskill     Mountains,
   mid-Appalachian   Region,  the  Southern
   Blue Ridge Province, New Jersey Pine Bar-
   rens, northern Wisconsin and Michigan's
   Upper  Peninsula,  and, possibly, northern
   Florida.  The first  three regions apparently
   are now at continuing  risk from acidifica-
   tion effects. Other regions  with sensitive
   resources  should   be monitored and as-
   sessed  to  evaluate whether  continuing
   acidic  deposition   will  affect those re-
   sources.  These  areas   include  parts  of
   Maine, New Hampshire,  Vermont, Massa-
   chusetts,  Connecticut,  and  Rhode Island;
   northern  Minnesota; parts  of the  Ozark
   Mountains,  Ouachitas  Mountains,   the
   Carolina   Piedmont,   and  the  Atlantic
   Coastal  Plain;  and parts  of  the  Rocky
   Mountains, Sierra Nevada Mountains, and
   Cascade Mountains.

3. PROTECTION GOALS FOR AQUATIC SPECIES: The
   biological effects of inorganic monomeric
   aluminum associated with acidic deposi-
   tion are minimized as  the level of acidic
   deposition is decreased and pH  and ANC
   levels in sensitive waters are kept relatively
   high. Based on studies  of sensitive aquatic
   species, to protect  aquatic resources  in se-
   nsitive  watersheds  from  the effects  of
   long-term, chronic  acidification, a general
                                                 20

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                                                               CHAPTER 2: ENVIRONMENTAL GOALS
                EXHIBIT 3. CRITICAL pH FOR SELECTED TAXA IN LAKES AND STREAMS*^
                                       Critical pH Levels for Selected Aquatic Organisms
                                            ao          5.5          5.0          45
                                                                                            4.0
    Yellow Perch

    Brook Trout

    Lake Trout

    Smallmouth Bass

    Rainbow Trout

    Common Shiner

    American Toad*

    Wood Frog-

    Leopard Frog*

    Spotted Salamander*

    Crayfish'*

    Mayfly-

    Clam"

    Snail"
From National Acid Precipitation Assessment Program. 1991.  7990 Integrated Assessment Report.  NAPAP Of-
fice of the Director, Washington, DC.
Solid symbols for each type of organism are placed in favorable pH ranges; shaded symbols are placed in less
favorable ranges. No symbol is placed in pH ranges that generally do not support populations of a particular
type of organism.
Embryonic life stages.
Selected species.
goal is to maintain the pH of sensitive lakes
above pH 6.0-6.5  and  inorganic mono-
meric aluminum below 30-50 ug/l. To pro-
tect these resources from the potential  ef-
fects  of  episodic,  acute acidification, sur-
face water ANC should be maintained at or
above 50 ueq/l.  No single water quality
goal,  however, addresses all needs to pro-
tect  sensitive   surface  water  resources.
Goals to protect  aquatic  resources may
also address site-specific needs to  maintain
sensitive aquatic species, species of special
concern  (e.g., listed threatened or endan-
gered species),  and species  richness  in
these sensitive surface  waters.  This  effort
certainly must include recognition that  pH
levels less than 6.0 and  ANC  less than
50 ueq/l  occur  in  some naturally  acidic
surface waters,  and that levels of pH less
than 6.0 can occur naturally in some loca-
tions  accompanying periods of  episodic
stormwater and  snowmelt runoff.  The spe-
     cific environmental objectives of any acid
     deposition standard  should accommodate
     the  ranges of chemical qualities occurring
     in natural waters. Furthermore, they should
     protect those special biological communi-
     ties  evolved to inhabit naturally acidic sur-
     face waters.

2.4.2  Identification of Sensitive Aquatic
       Resources in Other North American
       Regions
Most of  this chapter  reports quantitative  results
based on EPA model analyses for three case study
regions:  the Northeast (including  the  Adirondack
Mountains), the mid-Appalachian  Region, and the
Southern  Blue Ridge  Province.  Similar  model
analyses  were not performed for other sensitive re-
gions of  North America due  to data  and budget
limitations. Instead, and in addition to the  results
of the NAPAP National Surface Water Survey, EPA
supported a recent report that reviewed  the re-
                                            21

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
sponses of aquatic resources to acidic deposition
in four other regions of North America identified
in previous studies as holding sensitive aquatic re-
sources: the mountainous western United States,
upper midwestern  United  States,  and  northern
Florida.23  That  review  addressed  effects from
acidic deposition, specifically sensitive aquatic re-
sources in each region. The approach incorporated
key results available from past research  and as-
sessment efforts in North America  and Europe. The
major conclusions derived during this review that
specifically related to the four regions assessed are
presented below. (Some conclusions from this re-
view regarding general deposition  and response re-
lationships duplicate the  findings  of  other studies
reported above and are not repeated in  this sec-
tion.)

Western United States
   * Most low-ANC lakes in the West are con-
     fined primarily to glaciated,  higher  eleva-
     tion,  mountainous regions.  These  water-
     bodies can be  generally consolidated into
     five lake populations, based  on  their loca-
     tions  within  similar geomorphic   units:
     (Dthe Sierra Nevada in California;  (2) the
     Cascade Mountains  in California, Oregon,
     and Washington; (3) the Idaho Batholith  in
     Idaho  and  Montana;  (4) the   mountain
     ranges  of northwestern  Wyoming;  and
     (5) the Rocky Mountains in Colorado.

   * Results of the NSWS indicate that although
     no  lakes in this  region are  chronically
     acidic, many lakes were found to have very
     low  ANC (i.e., 17  percent have  ANC<
     50 ueq/l), and  should be considered sus-
     ceptible  to acidification,  particularly epi-
     sodic acidification.

   * Watersheds in the alpine areas of these five
     regions  generally  include broad expanses
     of exposed bedrock, which is often  highly
     resistant  to weathering, and  contain little
     soil or vegetative cover to neutralize  acidic
     inputs. Consequently, these regions include
     a significant portion of the region's aquatic
23 Sullivan, T.J., and J.M.  Eilers.  1994. Assessment of
  Deposition Levels of Sulfur and Nitrogen Required to
  Protect Aquatic Resources in Selected Sensitive Re-
  gions of North America.   Final Report.  Environ-
  mental Research Laboratory-Corvallis, U.S. Environ-
  mental Protection Agency, Corvallis, OR.
   resources that are the  most sensitive  to
   acidic deposition.

* Natural characteristics of these watersheds
   particularly predispose the surface  waters
   they  contain  to  episodic  acidification ef-
   fects: (1) low-water retention  capacities of
   most watersheds; (2) ultra-low  concentra-
   tions of base  cations;  (3) low ANC  in sur-
   face waters throughout the year; (4) large
   snowpack  accumulations and  substantial
   base   cation   dilution   during   runoff;
   (5) frequent,  periodic,  heavy rain  storms
   with high runoff events; and (6) short water
   retention times and high  flushing rates for
   most lake basins.

* Nitrate concentrations  in  the majority  of
   the western lakes are virtually undetectable
   during the fall. The NSWS samples, how-
   ever, revealed that a  relatively large num-
   ber of lakes in northwestern Wyoming, Si-
   erra Nevada,  and Colorado Rockies con-
   tained high concentrations of NO3~. These
   concentrations were sufficiently  high to in-
   dicate that many watersheds in these re-
   gions may have little remaining capacity to
   assimilate excess NO3" deposition.

• No extant data suggest that  lakes  in the
   West have experienced  chronic acidifica-
   tion. It is likely, however, that episodic ef-
   fects  have occurred in some lakes under
   some current  deposition regimes and that
   deposition  concentrations of NO3" espe-
   cially have caused small,  chronic losses of
   ANC in  some high-elevation watersheds.
   As previously  described, both  nitrogen and
   sulfur have the  potential to contribute  to
   episodic acidification.

*  Fish population data,  although  very  lim-
   ited, do not indicate a significant effect due
   to acidification. However, trout species na-
   tive to Western lakes such as rainbow trout
   and  cutthroat trout  are considered  more
   sensitive to low pH and elevated aluminum
   than brook trout native to eastern lakes and
   streams.

*  Although  potentially  difficult  based  on
   wide ranges  in precipitation volume, an
   event-based deposition standard may be a
   consideration to adequately address the po-
   tential effects of episodic acidification  in
   the  West.  Another  consideration  which
   combines concerns for both total mass and
                                                 22

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                                                                   CHAPTER 2:  ENVIRONMENTAL GOALS
     maximum concentration of pollutants de-
     posited,  is  an acid  deposition  standard
     which  establishes  limits  based on the
     maximum allowable annual-weighted pol-
     lutant concentrations or based on total an-
     nually deposited chemical mass loading.

Upper Midwestern United States
  * The  Upper  Midwest  is  characterized by
     numerous lakes created by repeated glacia-
     tion, little topographic relief, deep glacial
     overburden, and  rarely exposed  bedrock.
     In this region the primary aquatic resources
     sensitive  to  acidic deposition  are seepage
     lakes with low base cation concentrations
     that receive nearly all of their water inputs
     as precipitation directly onto the lake sur-
     face. These lakes have generally long water
     retention times, which provide opportuni-
     ties for in-lake SO42" reduction and  NO3~
     assimilation processes to neutralize  most
     acidic inputs and to prevent the concentra-
     tion of SO42' through evaporation.

  * The Upper Midwest has a large population
     of low-ANC lakes, but relatively few acidic
     (ANC<0 ueq/l)  lakes.  Paleolimnological
     evidence suggests that some of these lakes,
     particularly in Michigan's Upper Peninsula,
     have  developed  low ANC  or become
     acidic, consistent with  historic trends for
     sulfur deposition since preindustrial times.
     It should be noted  that land use changes
     and other human disturbances in the wa-
     tersheds have exerted greater influences on
     the  acid-base chemistry in more sensitive
     lakes of this region than has acidic deposi-
     tion.24

  * The NSWS indicated that 19 percent of the
     lakes  in  this  region  have ANC<50 ueq/l
     (only 3 percent of that figure is ANC<0).
     Historical data are too limited to determine
     the degree to which acidic deposition has
     impacted  fish populations in this region
     such as  yellow perch, bass,  and others.
     However, lakes with low  pH in northeast-
     ern Wisconsin and upper Michigan support
24 Sullivan, T.J.  1990.  Historical Changes in Surface
  Water Acid-Base Chemistry in Response to Acidic
  Deposition.  SOS/Til,  National Acid Precipitation
  Assessment Program, Washington, DC. 212 pp.
    fewer fish species than expected for their
    size and lake type.

  * Concentrations of  inorganic  nitrogen  are
    uniformly low in surface waters throughout
    this region. Most nitrogen  is efficiently re-
    tained by terrestrial and aquatic organisms.
    Snowmelt has not been shown to provide
    any significant influx of NO3- to these lakes
    because most snowmelt water percolates
    through  the soil  prior to  entering surface
    waters, allowing terrestrial  organisms to as-
    similate the deposited nitrogen. Therefore,
    the  key concern for this region is chronic,
    sulfur-driven acidification.  If recent trends
    of decreasing sulfur deposition in the Up-
    per  Midwest were to reverse, lakes with
    ANCs near zero in this region could be ex-
    pected to acidify.

Northern Florida
  • Florida lakes are located on marine sands
    overlying   carbonate  bedrock;   where
    groundwater interacts  with  the  deeper
    aquifer,  surface water can be highly alka-
    line. Lakes that receive input waters only
    from shallow aquifers in highly weathered
    sands, however,  can be quite acidic and
    sensitive  to acidic  deposition.   In fact,
    northern Florida contains one of the largest
    populations of  acidic lakes in the United
    States. Seventy-five percent of the Panhan-
    dle  lakes are acidic,  as are  26 percent of
    the lakes in the northern peninsula.

  * The NSWS determined that approximately
    60 percent of the acidic  lakes in Florida,
    primarily in the northcentral peninsula,  are
    acidic due to acidic deposition. Subsequent
    scientific study however,  suggest that  the
    role of the natural sulfate bearing ground
    water, significant land use changes in  the
    region,  and marine  sources  likely have
    greater effects on the acidic water chemis-
    tries of these systems than was previously
    estimated. Therefore,  the extent of possible
    water quality changes due to acidic deposi-
    tion  alone in  Florida  cannot   now  be
    quantified,  but  is  likely  lower  than  the
    NSWS estimate. The best evidence that
    acidic deposition  effects have altered  the
    surface water chemistry exists for the Trail
    Ridge  region   in   northeastern   Florida.
    Available data currently indicate  that there
    has been no widespread biological damage
                                                23

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
     due to acidic deposition within the sens-
     itive regions studies in northern Florida.

 2.4.3   Canada
 The area of Canada considered to be at greatest
 risk from  acidification (i.e.,  the  region  having
 minimal ability to neutralize incoming acids and
 receiving elevated deposition  of potentially  acid-
 forming chemicals), includes the region east of the
 Manitoba-Ontario border and roughly south of 52°
 N latitude (near the southern limit of James Bay).25
 (Known threats to  forests  in this regions, as  sum-
 marized by NAPAP, were reviewed earlier in this
 section.)   This    area    contains   more   than
 700,000 lakes    covering   about   160,000km2
 (excluding the Great Lakes). Extrapolation of sur-
 vey information indicates that  14,000 lakes are
 presently acidic. Modeling projections for eastern
 Canada indicate  that  at  least  an additional
 10,000 to 40,000 lakes would become chronically
 acidic at 1985 deposition  levels, as watershed in-
 put-output budgets reach equilibrium over  time
 with concentrations of atmospherically deposited
 acid-forming ions.

 Four  important  relationships primarily influence
the surface water chemistry  of these  Canadian
 lakes and their potential sensitivity to acidification:

  1. Because of the predominance of silicate
     bedrock,  thin  overburden,   and  generally
     high precipitation volumes  (approximately
     100 cm/yr or  greater),  nearly  all lakes  in
     eastern  Canada   can  be   hydrologically
     characterized   as  drainage  lakes.26  (The
     acidification processes that dominate seep-
     age lakes  in the upper Midwest and Florida
     lack importance in most Canadian lakes.)

  2. Most glacially deposited soil covering east-
     ern Canada has essentially no  capacity for
     SO42' adsorption. Because there appears to
     be  no  significant  geological  sources  of
25 Information presented in this section regarding sen-
  sitive aquatic resources  in Canada, unless otherwise
  cited, comes from the  summary of Jefferies, D.S.
  1991.  Southeastern Canada:  An Overview of the
  Effects of Acidic Deposition on Aquatic Resources.
  Pages  273-286 in D,F, Charles (editor).   Acidic
  Deposition and Aquatic Ecosystems - Regional Case
  Studies. Springer-Verlag, New York, NY.
26 Drainage lakes are lakes with  permanent surface
  water inlets and,  usually, outlets.  Seepage lakes are
  lakes with no permanent surface water inlets or out-
  lets.
     SO42- in this region, limited adsorption ca-
     pacity indicates that existing SO42- levels
     are principally controlled by atmospheric
     inputs. Note that most glacially deposited
     soil covering eastern Canada is similar to
     the soils in the northeast United States (i.e.,
     Adirondacks) in that they have very limited
     SO42- adsorption capacity, and acidifica-
     tion is primarily controlled by atmospheric
     inputs in both regions. 27

  3. Base cation  production of principally  Ca2*
     and Mg2+  by primary weathering or cation
     exchange  in the surrounding terrestrial wa-
     tershed provide most of the ANC of all Ca-
     nadian lakes. Thus, the variable mineralogy
     in glacial overburden surrounding the lakes
     dominates control of subregional variability
     in sensitivity to acidification.

  4. Organic acid anions appear to be impor-
     tant in some waters, particularly in the ex-
     tensive  wetland  areas of Nova  Scotia,
     Newfoundland,  Labrador,  and  northwest-
     ern Ontario; the occurrence of these ani-
     ons,  however,  are  generally  not the pri-
     mary cause of acidity in all lakes with ANC
     of 0 ueq/l or less and pH less than 6.0.

Almost all known  acidification related losses of
lake trout (Salvelinus fontinalis), smallmouth bass
(Micropterus dolomieui), and walleye (Stizostedion
vitreum) in Ontario surface waters have occurred
in the  Sudbury area and  are related to emissions
from the Sudbury area smelters; complete or bio-
logically significant reversal of acidic conditions in
these waters, however, may depend on continued
reductions  in emissions  over  a wider region.28
Concern also continues  regarding probable epi-
sodic influence of  acidic deposition  on Atlantic
salmon in tributary  streams along  the Atlantic
coast from Maine northward.29
27 Sullivan, T.J. 1990. Historical Changes in Surface
  Water Acid-Base Chemistry in Response to Acidic
  Deposition. SOS/T 11, National Acid Precipitation
  Assessment Program, Washington, DC. 212 pp.
28 Keller, W.   1992.  Introduction and overview to
  aquatic acidification studies in the Sudbury, Ontario,
  Canada, area.  Canadian Journal of Fisheries  and
  Aquatic Sciences 49(Suppl. 1 ):3-7.
29 Lacroix, G.L.  1989.  Ecological and physiological
  responses of Atlantic salmon in acidic organic rivers
  of Nova Scotia, Canada.  Water, Air, and Soil Pollu-
  tion 46:375-386.
                                                 24

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                                                                   CHAPTER 2:  ENVIRONMENTAL GOALS
2.5  ASSESSING PROTECTION NEEDS AND
     RESOURCE RESPONSES IN THE CONTROL OF
     ACIDIC DEPOSITION
Determining the potential for future benefits from
additional control of acidic deposition involves as-
sessing changes over broad geographical and eco-
logical scales. Projecting potential future relation-
ships is best done using models to simulate possi-
ble future scenarios. Simulation models  are,  in
fact, conceptualizations of the way things "work."
Due to the very simple character of their control-
ling process, some models can be very precise and
can be verified repeatedly by comparisons of pro-
jections to subsequent observations (e.g., projec-
tions of solar eclipses). In contrast, models of wa-
tersheds  and of surface water  responses to  envi-
ronmental  perturbations (e.g.,  acidic deposition)
are much more difficult to design and test.

This section briefly reviews the use and constraints
of simulation  models. It presents detailed results
from two major EPA modeling  studies and an  ex-
tensive  literature review aimed at increasing  the
understanding  of how  acid-sensitive  soil  and
aquatic resources are affected by both sulfur and
nitrogen deposition.  International and state effects-
based efforts to regulate acidic deposition are also
described.  Findings  from  a recent EPA investiga-
tion, previously described in Section 2.2.2, show
the key involvement of rainstorm and  snowmelt
events in lake and  stream acidification and  are
summarized here as well.

2.5.1  Model Application
MAGIC (Model for Acidification of Groundwater
in Catchments) is currently the model of choice for
assessing  many watershed  processes  associated
with acidic deposition (Exhibit  4). It  provided  the
primary analytical basis for EPA's DDRP and  the
NBS,  as summarized in the next two subsections.
MAGIC  has been  tested  more  than  any other
acidic deposition effects model. Results from these
tests (including some still underway) indicate that
MAGIC correctly projects the direction of change
of watershed responses and accurately projects the
magnitudes of rates of change for surface water
ANC and pH. MAGIC reasonably represents sulfur
retention within watersheds  and the  generation
and  leaching of  cations from watersheds,  two
functions generally acknowledged to be the most
important of the modeled processes.

In recognizing that all models have strengths and
weaknesses, it is obviously unreasonable to expect
that MAGIC (or any other watershed acidification
model)  will  predict accurately exact values  of
ANC or pH for any individual lake or stream in the
distant future (e.g., 50 years or more) under condi-
tions of significant dynamic  change. Rather, the
appropriate use of MAGIC and other such models
is to project the direction and magnitude of possi-
ble chemical changes and to  compare the relative
potential effects of different scenarios  of acidic
deposition. MAGIC appears to be reasonably well
suited for such tasks.  In reviewing model projec-
tions from these two studies on potential effects at-
tributable to future sulfur and nitrogen deposition,
it remains important to keep in  mind the associ-
ated uncertainties that are highlighted  in the fol-
lowing sections.

2.5.2  Direct/Delayed Response Project
As introduced in Section 2.2.1, a 1984  NAS panel
identified two geochemical processes as the domi-
nant watershed   factors affecting  or  mediating
long-term surface water acidification: (1) the rates
at  which  a watershed  supplies  base  cations
through neutralization  and buffering processes  in
response to its assimilation of deposited acids, and
(2) the capacity of a watershed to retain deposited
sulfur-containing compounds. (This NAS report in-
cluded minimum concern regarding effects from
nitrogen  deposition).  The capabilities of water-
sheds  to perform these processes decrease over
time.  Consequently, based  largely on  the NAS
conclusions,  defining  needs  to  protect  various
aquatic and terrestrial  resources from acidic depo-
sition depended on  whether acidification  is imme-
diately proportional to the intensity of the deposi-
tion (i.e., "direct") or lags  in time (i.e., "delayed")
through such watershed processes.

The DDRP was  designed to begin assessing the
state and influence of these processes. The  man-
date of  the  DDRP was to make  comparative re-
gional  projections of  the  future effects  of sulfur
deposition on long-term surface water chemistry in
the eastern United States, based on the best avail-
able data and most widely accepted hypotheses of
the acidification  process  related to atmospheric
deposition.

Two principal reports produced by the DDRP as-
sessed potential long-term effects of sulfur deposi-
tion on lake and  stream water  chemistry in the
eastern  United States.  The first report focused on
analysis of  lake  resources in the Northeast and
stream resources in the Southern Blue Ridge Prov-
                                                25

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                           EXHIBIT 4. MAGIC
   MAGIC is a lumped parameter model of intermediate complexity that was originally developed to project
   long-term effects (i.e., decades to centuries) caused by acid deposition on surface water chemistry. The
   model uses a minimum number of critical chemical and hydrological processes in watersheds to simulate
   soil solution and surface water chemistry, and to project average monthly or annual concentrations of acid-
   base chemistry in surface water. MAGIC was  introduced in a pair of 1985  articles by B.J. Cosby,  G.M.
   Hornberger, J.N. Galloway, and R.F. Wright:

      * Time scales of catchment acidification: A quantitative model for estimating freshwater acidification.
        Environmental Science and Technology 19:1144-1149; and

      * Modeling the effects of acid deposition: Assessment of a lumped parameter model of soil water and
        stream water chemistry. Wafer Resources Research 21:51 -63.

   Church et al. (see footnote 30) summarize various studies using MAGIC. Recent modifications of the model
   are summarized by Sullivan, T.J., B.J. Cosby, C.T. Driscoll, H.F.  Hemond, D.F. Charles, S.A. Norton, and
   J.M. Eilers (1993. The influence of naturally occurring organic  acids on model estimates of  lake water
   acidification  using the  Model  of  Acidification  of Groundwater  in   Catchments  (MAGIC). Report
   DOE/ER/30196-3. U.S. Department of Energy, Washington, DC).

   MAGIC has been tested  more than any other acidic deposition effects model. Those tests indicate that its
   projections are reasonably reliable:

      * Individual  process formulations in the model have been tested against laboratory experiments with
        soils.

      * Model hindcasts (i.e., backward predictions) of historical lake chemistries in the Adirondacks have
        been made and compared with values inferred from lake sediment records.

      * Numerous predictions of the effects from whole-watershed  manipulations have been compared to
        observed effects.

   The MAGIC model, as all models,  illustrates problems associated with uncertainty, parameterization, and
   validation.  For  example, MAGIC currently does  not explicitly represent detailed cycling or processes
   affecting the rate of nitrogen uptake and release. In fact, processes (and their governing factors) that control
   the transition of a watershed to a  state of nitrogen saturation are poorly known and, as yet, not represented
   in  any complete or tested watershed  model. Better nitrogen models to address the  questions are being
   developed, however. The Nitrogen Bounding Study developed for this report used a series of four scenarios
   for time-to-nitrogen-saturation to "bound" the possibilities. The  NBS represents the first  time  a  nitrogen
   component has been added and effectively used with the MAGIC  model for assessments at regional scales.

   In analyses completed for the  DDRP and the NBS, it is impossible to know precisely what deposition levels
   will be over the next 50 years or more. Therefore, the NBS approach assessed a range of deposition levels to
   evaluate potential effects of possible sulfur  and nitrogen deposition  combinations. This approach indicates
   why model runs are more correctly termed "projections"  rather  than  "predictions." The latter  implies an
   exact knowledge of model inputs and system dynamics. The NBS projects watershed acidification responses
   for possible alternative acidic deposition rates in the year 2040.
ince (SBRP).30 The second report addressed poten-
tial stream  chemistry effects  in  the mid-Appala-
chian  Region,  and  summarized and  integrated
30 Church,  M.R.,  K.W. Thornton, P.W. Shaffer, D.L.
  Stevens, B.P. Rochelle, C.R. Holdren, M.G. Johnson,
  J.J.  Lee,  R.S. Turner, D.L. Cassell, D.A.  Lammers,
  W.G. Campbell, C.I. Liff, C.C. Brandt,  L.H. Liegel,
  C.D. Bishop,  D.C. Mortenson, S.M. Pierson,  and
  D.D. Schmoyer.  1989.  Direct/Delayed Response
  Project:  Future Effects of Long-term Sulfur Deposi-
  tion on Surface Wafer Chemistry in  the  Northeast
  and Southern  Blue  Ridge  Province.   EPA/600/3-
  89/026a-d. U.S. Environmental Protection Agency,
  Washington, DC.  887 pp.
conclusions from the three  regional  analyses.31
Exhibit 5  shows the  locations  of three  study
regions. General characteristics and sizes of target
31 Church, M.R., P.W.  Shaffer, K.W. Thornton,  D.L.
  Cassell, C.I.  Liff, M.G. Johnson, D.A. Lammers, J.J.
  Lee, G.R. Holdren, J.S. Kern, L.H. Liegel, S.M.  Pier-
  son, D.L. Stevens, B.P. Rochelle,  and R.S. Turner.
  1992.  Direct/Delayed Response Project:  Future Ef-
  fects  of Long-term  Sulfur  Deposition  on Stream
  Chemistry in the Mid-Appalachian  Region  of the
  Eastern United States.  EPA/600/R-92/186.  U.S. En-
  vironmental  Protection Agency, Washington,  DC.
  384 pp.
                                                  26

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                                   CHAPTER 2: ENVIRONMENTAL GOALS
EXHIBITS. STUDY REGIONS INCLUDED IN THE DIRECT/DELAYED
 RESPONSE PROJECT AND THE NITROGEN BOUNDING STUDY
                       Northeast-
             Adi rondacks
                                                       achi an
                                                       on
                                      Southern Bl ue Ridge
                                             Provi nee
                    27

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 surface water populations for all regions included
 as  part of the  NSWS  and the  DDRP and NBS
 studies are presented for comparison in Exhibit 6.
 Specific characteristics of the three  DDRP study
 areas and their  surface waters are summarized in
 the following.

 Northeast32
 This region includes  lakes potentially sensitive to
 acidic deposition over the near-  to long-term  and
 covers an area extending from northeast Pennsyl-
 vania and northern New Jersey through the entire
 State of Maine (Exhibit 5). Bedrock and  surface
 physiographic characteristics  in  these subregions
 help to limit supplies  of base cations draining from
 these glaciated and predominately forested water-
 sheds. Seepage lakes  are uncommon, representing
 only 7 percent of the  lakes classified by hydrologic
 type, but seepage  lakes  also generally had  the
 lowest values of ANC and pH of any lake  type in
 this  region. Although the NSWS included lakes
 with areas only between 4 and 2,000 ha (see Ex-
 hibit 6), there may be from one to four times as
 many lakes with areas less than 4 ha in the North-
 east.  Because of their smaller sizes  and  higher
 rates of water turnover, such lakes are likely to be
 more highly susceptible to acidic deposition  ef-
 fects.  Concentrations of  nutrients   (i.e.,  NO3",
 NH4+, and PO43+) were low for most of lakes sam-
 pled in this region.

 This region includes the highest dissolved concen-
 tration of SO42' observed during the NSWS. Acidic
 lakes were also characterized by high concentra-
tions of extractable aluminum.

 The Adirondack subregion,  including Adirondack
 State Park, which was emphasized during the NBS
 (see  Section 2.5.3), has the highest number and
 percentage of acidic (ANC<0 ueq/l) lakes (14 per-
 cent) found for any NSWS subregion, except Flor-
 ida. Approximately half of  the  Adirondack lakes
 having pH 5.0 were organic acid  dark-water lakes,
while the remainder were clear water acid lakes.
This indicates that inorganic ions, including min-
 eral acids, were likely the primary cause of their
 acidity. Both pH and ANC tended to decrease as
the lake elevation increased, a relationship not ob-
served in other NSWS subregions of the Northeast.
Drainage  lakes were the most common type of
lake (77 percent of  the  target population). Most
lakes with areas of less than 4 ha in the Adirond-
acks are  more boglike and more  strongly influ-
enced  by  organic acidity, compared to the larger
lakes in this subregion.

Mid-Appalachian Region33
This region included most stream  reaches potenti-
ally sensitive to acidic deposition within the area
from central  and  eastern  Pennsylvania through
western Maryland  and Virginia and into eastern
West Virginia (Exhibit 5). This  DDRP study region
included the mountainous physiographic provinces
of the Mid-Atlantic  Appalachian Mountains, in-
cluding the northern Blue Ridge Mountains, Valley
and  Ridge Province, and  Appalachian  Plateau.
This area  includes Shenandoah National Park in
Virginia. Much of the area extends over bedrock
that  is  relatively resistant to weathering.  Rates of
sulfur  deposition in  the mid-Appalachians  are
much greater than in the Northeast or SBRP.

Based  on the  National Stream  Survey   (NSS)
streams acidified by acidic  deposition  (ANC<0
ueq/l) accounted for 4 percent  of the target  stream
length  in this  region;  18 percent  of the upstream
ends and  7 percent of the downstream ends had
ANC<50 ueq/l. These estimates excluded streams
acidified  by  mine drainage (e.g.,  coal  mining).
Mine drainage was responsible for acidifying four
times as  many  downstream  reaches as  acidic
deposition.

More than 99 percent of  the acidic  target streams
(ANC<0 ueq/l) within the mid-Appalachians were
located in  watersheds with at least 85 percent for-
est cover.  Many more streams with very low ANC
(<50 ueq/l) are found in these forested areas, com-
pared to those in mixed forest  or open areas. This
situation probably is not due to the fact that forests
control ANC and acidic levels; rather, most re-
maining forested areas that were  never clear cut
lie in the less-weatherable, less-fertile uplands un-
suitable for agriculture. Areas where  forests were
32 This summary is  primarily drawn  from Linthurst,
  R.A., D.H.  Landers, J.M. Eilers, D.F.  Brakke, W.S.
  Overton, E. P.  Meier, and R.E. Crowe.  1986.  Char-
  acteristics of Lakes in the Eastern United States, Vol-
  ume I:  Population Descriptions and Physico-Chemi-
  cal Relationships.  EPA/600/4-86/007a.  U.S. Envi-
  ronmental Protection Agency, Las Vegas, NV.
33 This summary is primarily drawn from Herlihy, A.T.,
  P.R. Kaufmann, M.R. Church, P.J. Wigington, Jr., J.R.
  Webb, and M.J. Sale.  1993.   The effects of  acidic
  deposition on Streams in the Appalachian Mountain
  and Piedmont Regions  of the Mid-Atlantic United
  States. Water Resources Research 29(8):2687-2703.
                                                28

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                                                                  CHAPTER 2:  ENVIRONMENTAL GOALS
             EXHIBIT 6. TARGET POPULATIONS INCLUDED IN THE NSWS, DDRP, AND NBS STUDIES
   Target population refers to the number of systems for which
   model projections can be reasonably extrapolated. Studied tar-
   get populations of surface waters generally became refined and
   smaller in each  of these successive studies, allowing acidic
   deposition research  efforts to focus increasingly  on  relation-
   ships in more sensitive surface waters (see figure—not drawn to
   scale). As a consequence of narrowing research efforts, propor-
   tions of sensitive surface waters and the magnitude of the po-
   tential response to acidic deposition by these respective target
   populations tend to increase through subsequent studies. Gen-
   eral characteristics of these target populations are presented be-
   low.

   As part of the NSWS,  the Eastern  Lake Survey (ELS) includes lakes between 4 ha (10 acres) and
   2,000 ha (5,000 acres) in size that have ANC<400 ueq/l,  excluding non-freshwater lakes (i.e., small
   ocean bays and  estuaries); broad waters with apparent flows  (reservoirs were included,  however);
   marshes or swamps; and water-bodies surrounded  by urban, industrial, or agricultural activities (i.e.,
   lakes with extensive cultural disturbance  in their watersheds). In turn,  the National Stream  Survey
   (NSS) included target stream reaches in sensitive regions not sampled during the National Lake Survey
   (NLS)  that had  drainage  areas  <155km2 (<60 mi2) and showed as "blue line"  streams on
   1:250,000-scale U.S. Geological  Survey topographic maps. Such streams were judged to be large
   enough to be important for fish habitat, yet small enough  to be susceptible to potential effects  of
   acidic deposition. At least 50 percent of the stream reach had to be within the designated region to be
   included. Among the stream reaches excluded from the target population were, for example, reaches
   affected by gross pollution (e.g., mine or oil-field  drainage), highly urbanized development, or tidal
   influence.
   DDRP target lakes in the Northeast included a subset of NLS target lakes by excluding lakes <1.5 m
   deep. DDRP target stream reaches included a subset of the  NSS target reaches by excluding streams
   with ANC>200 ueq/l in the mid-Appalachian region (Southern Blue Ridge Province streams had no
   additional  restriction on ANC); drainage areas >3,000 ha (>7,400 acres); and all watersheds in the
   Southern Piedmont Regions and Coastal Plain and north of the maximum extent of glaciation.

   NBS target lake and stream popluations represent a sensitive subset of the lakes and streams within the
   three regions:
     «  ADIRONDACK LAKES: About 700 lakes,  approximately 45 percent of the lakes in the Adirondack
        region meeting ELS sampling requirements
     *  MID-APPALACHIAN STREAMS: About 4,300 stream reaches, approximately 17 percent of the re-
        gion's total stream reaches
     *  SOUTHERN BLUE RIDGE PROVINCE STREAMS: About 1,300  stream reaches, approximately 65 per-
        cent of the region's stream reaches meeting the sampling requirements described above

   The target populations used in the NBS therefore,  represent the best available data for case studies of
   sensitive regions in the United States.
historically  cleared  for  agriculture  predominate
along the more-weatherable, more-fertile valleys.

Southern Blue Ridge Province
This region includes potentially sensitive stream
reaches in  the extreme western portions of North
Carolina, South Carolina, eastern Tennessee, and
northern Georgia  (Exhibit 5).34 The SBRP includes
34 This summary for the Sourthern Blue Ridge Province
  is primarily drawn from Elwood, J.W., M.J. Sale, P.R.
  Kaufman, and G.F. Cada.  1991.  The Southern Blue
                                     (continued)
                                                29

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 a steep mountainous region characterized by high
 rainfall,  highly weathered base-poor  soils,  and
 relatively  unreactive  bedrock.  Target  surface
 waters of this  region contain some of  the lowest
 concentrations of dissolved  solids of any region
 sampled in the United States, and among the high-
 est deposition  rates for H+, SO42-, and  NO3~. This
 area  includes  the Great  Smoky Mountains  Na-
 tional Park. Although no acidic streams (ANC<0 u
 eq/l)  were found during the NSS, statistical analy-
 sis  of the results from this study indicated that a
 small number  representing less than 1  percent of
 the streams in  the region may be acidic or be af-
 fected acidic episodes. Also,  a separate non-ran-
 dom  survey during 1982-1984 found 3  percent of
 the small streams in the region  to  be  acidic;  no
 larger acidic streams were reported in this study.35

 Watershed retention of SO42' and NO3" is the ma-
 jor  process  generating  ANC  in drainage lakes
 within this region, exceeding base cation mobili-
 zation in importance. Sulfur and nitrogen retention
 capacities are  generally similar and provide rela-
 tively consistent sources of ANC across the region.
 The primary cause  of  ANC differences in these
 streams appears to be different rates of  acidic cat-
 ion  mobilization  from the region's watersheds.
 Dissolved organic carbon concentrations are typi-
 cally low and do not appear to provide significant
 contributions to stream acidity.

 Concentrations of SO42- have increased at an an-
 nual  rate  of approximately  1 ueq/l during  the
 10 years prior to 1993 in selected streams draining
 both high- and  low-elevation watersheds. Over the
 same period both ANC and base cation concentra-
 tions  declined, indicating that base cation mobili-
 zation is not keeping pace with acidic deposition.
 Despite this, no adverse biological  effects from
 acidic deposition on streams and lakes  have been
 conclusively demonstrated for the SBRP.

The  DDRP  projected changes in  target surface
water chemistry for one  or two sulfur  deposition
 scenarios, while  holding  nitrogen deposition and
 retention constant, using up to three  watershed
  Ridge Province.  Pages 319-364 in D. F.  Charles
  (editor). Acidic Deposition and Aquatic Ecosystems
  Regional Case Studies. Springer-Verlas. New York,
  NY.
35 Winger, P.V., P.]. Lasier, M. Hudy, D.L. Fowler, and
  M.J. Van Den Avyle, 1987. Sensitivity of high-eleva-
  tion streams in the Southern Blue Ridge Province to
  acidic deposition. Water Resources Bulletin  23:379-
  386.
models. Model projections were compared among
the three DDRP regions.

Results for the Northeast indicated that these target
lakes would likely respond  relatively rapidly to
changes  in  sulfur deposition, because  Northeast
watersheds appear, on average, to be near sulfur
steady state. That is, annual loads of atmospheric
sulfur  deposited  into  most watersheds  approxi-
mately equal loads discharged  with  waters drain-
ing from the watersheds.  Remaining sulfur reten-
tion capacities of Northeast soils appear to be gen-
erally  limited. In contrast, DDRP projected that at
either  current or increased sulfur deposition load-
ings, it might take 150-200 years, on average, be-
fore SBRP watersheds attain sulfur  steady state.
That is,  sulfur  retention  potentials appear much
greater in the SBRP than in the Northeast.

Watersheds  in  the  mid-Appalachians have sulfur
retention characteristics similar  to some Northeast
and some SBRP watersheds. As such, they appear
to represent a  transition  region where some sys-
tems  will  likely  respond  relatively rapidly  to
changes  in sulfur deposition rates, whereas other
systems may respond more slowly. Projections of
times necessary to reach sulfur steady state aver-
aged about 50 years for the mid-Appalachians wa-
tersheds. Further, in contrast to the  lack of cur-
rently acidic SBRP streams, about 4 percent of the
DDRP target population  stream reaches  in  the
mid-Appalachians  are now chronically  acidic.
Acidic sulfur deposition  appears to  be the most
likely  cause  of  surface  water   acidity   in
mid-Appalachian  streams;  sulfate  from  atmos-
pheric sources  dominates the  strong acid anion
component in these streams.

Results of the DDRP model projections for the tar-
get populations in each of the three  regions stud-
ied and for  the sulfur deposition scenarios mod-
eled for purposes of the  NAPAP 1990 Integrated
Assessment Report can be summarized as follows.
For lakes in the Northeast, the 1990 CAAA was
projected to reduce  the loss of habitat for sensitive
fish species between 1990 and 2030 by 16 percent
to 18 percent from  that which was  projected  to
occur  without  the  CAAA. The results  also  pro-
jected  that  a  decrease  in  sulfur deposition  of
30 percent from 1985 levels would lead to in-
creases in lake ANC and decreases in the numbers
of chronically and episodically acidic lakes in the
Northeast through  the last year  of the  DDRP
model  projection, 2030.
                                                30

-------
                                                                  CHAPTER 2: ENVIRONMENTAL GOALS
The  DDRP model projections for the SBRP indi-
cated that continued sulfur deposition at 1985 lev-
els for 50 years would increase stream sulfur con-
centrations and decrease stream ANC, with the re-
sult  that a small percentage of the DDRP target
population stream reaches might become chroni-
cally acidic in 50  years.  There might also be a
slight increase in the  number  of stream reaches
susceptible to acidic episodes.

In the mid-Appalachians at the  1985 rate of sulfur
deposition, the DDRP  model projected that in 50
years the proportion of target acidic (ANC<0 ueq/l)
stream reaches would  increase  between 3 percent
and  11 percent. This scenario also is projected to
double, from 25 percent to  54  percent,  the target
population of stream reaches that have an  ANC
less  than 50 ueq/l.  This would also double  the
number of stream reaches potentially susceptible
to acidic episodes. Models of a deposition scenario
involving a 50 percent decrease from 1985 sulfur
deposition rates projected that increases in stream
ANC would occur in  50 years across the DDRP
target population (although  statistically significant
changes  in the  number of acidic  reaches or
reaches with ANC less than  50  ueq/l were not ex-
pected).

2.5.3  Nitrogen Bounding Study
Evidence and concern  regarding long-term surface
water acidification associated with nitrogen depo-
sition and NO3~  leaching from watersheds is in-
creasing  as some watersheds  appear  to be  ap-
proaching nitrogen saturation (see Section 2.2.1).
The  relative importance of  nitrogen deposition is
also  becoming more apparent  as adverse effects
from sulfur deposition are apparently easing in re-
sponse to the  1990  CAAA and earlier SO2 emis-
sions reductions.

Exhibit 7 presents NBS model projections of per-
centages of acidic  and sensitive  surface waters
(ANC<0 ueq/l  and ANC<50  ueq/l) in three regions
of the eastern United States in the year 2040 under
three scenarios: (1) without the  1990 CAAA (sulfur
deposition held constant at 1993 levels and a 1
percent annual increase in nitrogen deposition af-
ter the year 2000); (2) without the 1990 CAAA sul-
fur reductions (sulfur deposition held constant at
1993  levels)   but   with  the  nitrogen  controls
(nitrogen deposition  held constant at 1985 levels);
and  (3) with  implementation of the CAAA sulfur
and  nitrogen  controls  (nitrogen deposition  held
constant at 1985 levels). Results  of these  three
scenarios illustrate the proportion of surface waters
that would likely have been acidic or sensitive to
becoming acidic had there been no CAAA. These
modeling projections are subject to the uncertain-
ties described previously. As such,  they indicate
approximate proportions of the surface water tar-
get populations projected to have ANC<0 or 50 u.
eq/l  for the indicated deposition scenarios.  The
scenario depicting no sulfur reductions and  a 1
percent annual increase in nitrogen deposition is
intended to be representative of a situation without
CAAA reductions (no sulfur reductions and a con-
tinuing increase in nitrogen deposition). The  ex-
hibit shows that the reduction  in sulfur deposition
levels resulting from the 1990 CAAA are projected
to provide clear benefits in improving ANC and re-
ducing acid stress in the lakes and streams of the
three regions that hold a major proportion of sens-
itive aquatic resources in the eastern United States.

EPA  designed the NBS to begin providing a more
complete understanding of potential effects attrib-
utable to nitrogen deposition during surface water
acidification.36 This study examined the combined
effects on surface water chemistry due to potential
changes in the deposition rates of total sulfur and
total nitrogen, and due to possible alternative rates
of nitrogen saturation within watersheds. Projected
surface water chemistry for two target years (2015
and 2040) were assessed, with  the assumption that
emissions reductions mandated by the 1990 CAAA
(the  permanent 10 million  tons of SO2 and  the
temporary 2 million tons of NOX) were fully  im-
plemented.

The  study evaluated target populations of surface
waters in  three regions: lakes in the Adirondack
Region and stream reaches in  the mid-Appalachi-
ans and the Southern Blue Ridge. Target popula-
tions of waters modeled are described in Exhibit 6.
The NBS model projections were completed using
a  modification of  the MAGIC model (see  Ex-
hibit 4). The  primary input data came from  the
NSWS, DDRP studies, and updated deposition in-
formation  from  the  EPA atmospheric  modeling
studies discussed in Chapter 3. The  NBS results
represent responses for proportions of NBS mod-
eled systems; they do not represent responses for
either all surface waters or for all NSWS sampled
surface waters in the modeled regions.
36 Van Sickle, J., and M.R. Church.  1995.  Methods for
   Estimating the Relative Effects of Sulfur and Nitrogen
   Deposition on Surface Water Chemistry. U.S. Envi-
   ronmental Research Laboratory, Corvallis, OR.
                                                31

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
      EXHIBIT 7. IMPACT OF CAAA ON SENSITIVE SURFACE WATERS: NBS MODEL PROJECTIONS FOR YEAR 2040

               PROPORTIONS OF TARGET POPULATION SURFACE WATERS IN TWO ANC CATEGORIES
                    FOR THREE DEPOSITION SCENARIOS (SEE TEXT FOR ADDITIONAL DETAILS)
Region
ADIR
M-APP
SBRP
Criterion
ANCSO ueq/l
ANC<50 ueq/l
ANC^O ueq/l
ANC<50 ueq/l
ANC^O ueq/l
ANC£50 (jeq/l
Deposition Scenario
w/o CAAA: 1% N increase*3
w/o CAAA: Constant Nc
CAAAd
w/o CAAA: 1 % N increase1"
w/o CAAA: Constant Nc
CAAAd
w/o CAAA: 1 % N increase6
w/o CAAA: Constant Nc
CAAAd
w/o CAAA: 1% N increase1"
w/o CAAA: Constant Nc
CAAAd
w/o CAAA: 1 % N increase1"
w/o CAAA: Constant Nc
CAAAd
w/o CAAA: 1 % N increase1"
w/o CAAA: Constant Nc
CAAAd
Observed
Proportion*
19
55
4
27
0
6
Proportions (Percentages) at Modeled
Times to Watershed Nitrogen Saturation
50 years
52
50
43
77
74
67
42
33
9
76
67
41
14
13
4
31
20
16
100 years
39
36
26
59
58
57
28
23
5
66
54
37
7
2
0
22
17
16
250 years
23
23
15
55
55
54
23
21
4
65
48
28
2
1
0
17
15
14
Never
24
25
11
55
55
54
21
8
0
49
38
23
0
0
0
15
15
11
a Observed in 1984 in Adirondacks and 1985 in Mid-Appalachians and Southern Blue Ridge.
b Sulfur deposition held constant at 1993 levels; nitrogen deposition increases 1% per year after 2000.
c Sulfur deposition held constant at 1993 levels; nitrogen deposition held constant at 1985 levels.
d Reflects only decreases in sulfur deposition from implementation of Title IV; nitrogen deposition held constant at
  1985 levels.
The NBS study is the most recent major study hav-
ing important implications for considering the fea-
sibility of aquatics-based acid deposition standards
in the United  States. Therefore, it is  valuable to
understand clearly the nature of the results prod-
uced by this study. Exhibits 8-10 present 3 of over
60 similar sets of four plots presenting NBS model
results.  These sets of  plots show modeled  re-
sponses for percentages of the target population of
Adirondack Region lakes projected to meet the cri-
terion of ANC of 0 ueq/l  or  less in the year 2040
and the percentages of target populations of mid-
Appalachians and SBRP stream reaches projected
to meet the criterion of ANC of 50  ueq/l or less in
year 2040, Exhibit 11 provides guidance for inter-
pretation  of  the NBS  plots presented  in Exhib-
its 8-10 and in Appendix B.

Times  to  watershed nitrogen saturation in these
systems remain a major uncertainty. Some model-
ing and empirical analyses  (for example, at Hub-
bard Brook  in  New Hampshire  and the Harvard
Forest in Massachusetts) indicate rather long times
to nitrogen saturation, while other results from the
experimentally  manipulated  watersheds of  Bear
Brook in Maine and Fernow in West Virginia indi-
cate shorter  response  times to increased nitrogen
additions. Also, nitrate concentrations  have  no-
ticeably increased recently  in some surface waters
draining the Catskills, Adirondacks, and the high-
est elevation spruce stands in the Great  Smoky
Mountains,  suggesting that some  watersheds in
these regions are moving toward or have reached
nitrogen saturation.  Consequently,  evaluating cur-
rent trends for  nitrogen saturation  on a regional
basis remains very difficult. To accommodate this
uncertainty,  the NBS  model projections assumed
constant  rates  of nitrogen  assimilation  (i.e., no
change  from present)  and  included scenarios of
time to watershed nitrogen saturation of 50, 100,
and 250 years. Additional considerations regarding
                                                 32

-------
                                                                    CHAPTER 2:  ENVIRONMENTAL GOALS
                         EXHIBIT 8. NBS MODEL PROJECTIONS FOR YEAR 2040 PERCENTAGE
                        OF TARGET POPULATION ADIRONDACK LAKES WITH ANC^O U.EQ/L
I
o
      12  -

      10  -

       8  -
8    e -I
a.    o -
o
Q
       4 -
 o
I
 «    2 -
£
      0 -
               6%
                                     8
                                             10
             Total Sulfur Deposition (kg S/ha/yr)
            (Assumes nitrogen saturation @ 50 yr)
                                                         12 -

                                                     J  10 -

                                                     I   8-
                                                     o.
                                                      4)
                                                      Q
                                                      o
                z
                I
                                                          6  -

                                                          4  -

                                                          2  -

                                                          0  -
                                                                  3.4%
                                                               i
                                                               0
                                                                                           8
                                                             r
                                                            10
                                                                 Total Sulfur Deposition (kg S/ha/yr)
                                                               (Assumes nitrogen saturation @ 100 yr)
 CD
 O
Q
 0>
I
    12  -

    10  -

     8  -

     6  -

     4  -

     2 -

     0 -
              0%
           i
          0
                 i
                2
                       i
                       4
                              i
                              6
8
10
            Total Sulfur Deposition (kg S/ha/yr)
          (Assumes nitrogen saturation @ 250 yr)
                                                         12 -

                                                         10 -

                                                          8 -
                                                     8    R -i
                                                     Q.    0 ~
                                                    o
                                                    8s
                                                     £
                                                     "o
                                                          4 -

                                                          2 -

                                                          0 -
                                                                  0%
8
 i
10
                                                                Total Sulfur Deposition (kg S/ha/yr)
                                                                (Assumes nitrogen uptake constant)
                                                  33

-------
  ACID DEPOSITION STANDARD FEASIBILITY STUDY
                    EXHIBIT 9. NBS MODEL PROJECTIONS FOR YEAR 2040 PERCENTAGE OF TAR-
                      GET POPULATION MID-APPALACHIAN STREAMS WITH ANC< 50 U.EQ/L
      14 H

 1   12 H
 3  10 H

 I    8H
 i
I
       6 -


       4 -


       2 -

       0 -
             5.3%
                                    8
                                          i
                                         10
             Total Sulfur Deposition (kg S/ha/yr)
           (Assumes nitrogen saturation @ 50 yr)
      14 -

      12 -

 j|   10 -


 1     8

 |    6H
 O

 I    4H

 I     2-
       0 -
                                                            4.8%
                                                                                   8
                                          10
                                                                 Total Sulfur Deposition (kg S/ha/yr)
                                                               (Assumes nitrogen saturation @ 100 yr)
     14 H

•&   12 H

8»   10 H
o
o
o°
8  -


6  -


4  -


2  -


0  -
            4.6%
                                   8
                                          I
                                         10
            Total Sulfur Deposition (kg S/ha/yr)
          (Assumes nitrogen saturation @ 250 yr)
                                                         14 -

                                                    I  ,2-

                                                    .§»  10 -

                                                    I    SH
Q    6 -

§
O    A. ™
^    "*
3Z
2

5    2 H
                                                          0  -
                                                                 3.9%
                                                          i
                                                         0
                 i
                2
6.     8
                                                                                             10
                                                                 Total Sulfur Deposition (kg S/ha/yr)
                                                                 (Assumes nitrogen uptake constant)
                                                34

-------
                                                                     CHAPTER 2: ENVIRONMENTAL GOALS
                      EXHIBIT 10. NBS MODEL PROJECTIONS FOR YEAR 2040 PERCENTAGE OF TAR-
                      GET POPULATION SOUTHERN BLUE RIDGE STREAMS WITH ANC<50

  
                             a
                                                          12 -
                                                          10  -
                                                           6  -
                                                           4  -
                                         3.8%
                                                               T       i	1	r
                                                                                           8
                                                                                           10
                                                           Total Sulfur Deposition (kg S/ha/yr)
                                                         (Assumes nitrogen saturation @ 100 yr)
 o>
 o
 0>
O
 0>
"
•s
12  -

10  -

 8  -

 6  -

 4  -

 2  -

 0 -
             3.4%
                                      8
                                      10
            Total Sulfur Deposition (kg S/ha/yr)
          (Assumes nitrogen saturation @ 250 yr)
                                               I
                                               o>
                                               O
                                               I
                                                          12 H
                                                          10 H
                                  6

                                  4

                                  2 -

                                  0 -
                                      I
                                      0
                                                            2%
                                                                2
I
8
 i
10
                                                           Total Sulfur Deposition (kg S/ha/yr)
                                                           (Assumes nitrogen uptake constant)
                                                    35

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                  EXHIBIT 11.  INTERPRETING NBS PLOTS
   To illustrate interpretation of the NBS plots, the four individual plots in Exhibit 8 show projected per-
   centages of NBS target population lakes in the Adirondack Mountains with ANC of 0 ueq/l or less,
   where watershed nitrogen saturation is assumed to occur at 50, 100, and 250 years, as well as where
   watershed assimilation rates for nitrogen remain  constant at recently estimated rates (i.e., watershed
   nitrogen saturation will never occur).  Response contours for each plot show how percentages of target
   waters are projected to vary with changes in total sulfur and nitrogen deposition throughout the mod-
   eled ranges of deposition. These ranges begin at projected background deposition rates for sulfur and
   nitrogen (1 kg S/ha/yr and 4 kg N/ha/yr) and extend to their maximum modeled concentrations for
   2040 (7.5 kg S/ha/yr and 11.3 kg N/ha/yr),  i.e., the  rates projected to accompany implementing the
   1990 CAAA (see Chapter 3). Thus, for the upper right plot of Exhibit 8, which shows projections based
   on an assumed 100 years to nitrogen saturation, the model projects that approximately 26 percent of
   the target Adirondack lakes may be acidic (ANC 0 ueq/l) at year 2040 for modeled sulfur and nitrogen
   deposition rates projected to accompany implementation of the 1990 CAAA. With only background
   deposition of sulfur and nitrogen, 3.4 percent of these target lakes are projected to be acidic at 2040.
   Several general observations apply to these plots:

     *  The slopes of contour lines in each plot reflect the relative importance of sulfur and nitrogen in
        causing the projected response relationships. Nearly vertically plotted response contours indi-
        cate that the  projected ANC response is attributable primarily to sulfur deposition.  Nearly
        horizontal plotted  response contours indicate the plotted ANC response is attributable primar-
        ily to nitrogen deposition. A forty-five  degree diagonal contour indicates equal  contributions
        by both sulfur and nitrogen depositions.
     •  Changes in the spacing between individual response contours within  each plot appears to be
        attributable to patterns in sample weighting during model projections, rather than due to some
        intrinsic character  of the deposition-response relationships.

     *  The density of response contours across the  modeled deposition ranges for each plot directly
        relates to the  potential average responsiveness by target water-bodies to potential changes in
        sulfur and nitrogen deposition rates on the specified water quality classification variable mod-
        eled (e.g., ANC<0 ueq/l).  Therefore, plots with a high density of contour lines depict a high
        level of responsiveness to changes in deposition.
possible  regional difference  in times to nitrogen
saturation are presented in Exhibit 12.

For these plots,  deposition rates of sulfur and ni-
trogen were assumed to be those projected to ac-
company implementation of the 1990 CAAA to the
year 2010. At that time, different sulfur and nitro-
gen deposition  scenarios were defined  and mod-
eled.  Some modeled  scenarios maintained  the
2010 deposition  rates, while  some  alternative
modeled scenarios declined to background deposi-
tion rates. Rates  for still other scenarios reduced to
levels between these extremes. (Background depo-
sition rates include only natural, agricultural fertil-
izer, and domestic livestock sources.)  Each mod-
eled deposition  rate was then assumed to remain
constant  at the modeled 2020 rate until the  year
2040, the end of the model projection period.
Sets  of plots similar  to those shown in  Exhib-
its 8-10 have been produced through this study
projecting year 2040  proportions  of  NBS target
surface waters within  each of the three modeled
regions meeting five  evaluation  criteria:  ANCS
0 ueq/l, ANCS50 ueq/l, pH<5.0, pH<5.5, and pH<
6.0. Similar plots for all four water chemistry crite-
ria were also produced for the year 2015. All other
NBS plots showing results  of  both ANC and  pH
projections are presented in Appendix B.

Because of uncertainties associated with the com-
plex chemical relationships modeled in MAGIC's
derivations for pH, ANC projections  are  consid-
ered to be more reliable than those for pH. As pre-
viously described,  ANC is an  important indicator
of sensitivity to  acidification  (see Section 2.3.1).
Furthermore, projected water quality changes are
                                                36

-------
                                                                CHAPTER 2:  ENVIRONMENTAL GOALS
    EXHIBIT 12. TIME TO WATERSHED NITROGEN SATURATION
Present scientific knowledge does not allow quantifying the
time to nitrogen saturation for any of the three study regions
considered in the NBS, and no scientific consensus exists re-
garding actual  times to nitrogen saturation for watersheds
within these three regions or any  others regions.  Indeed,
NBS  investigators and most of this project's technical  re-
viewers deem  it scientifically  premature to define specific
times to saturation for any region.  Yet, it is reasonable to
suggest that times to saturation do vary among  regions. This
variation  is due primarily to differences in  temperature,
moisture,  soil fertility, primary production rates, decomposi-
tion rates, forest age, and the accumulation of plant biomass,
along with different histories of  nitrogen deposition among
the regions.  Further, given historic  and current  nitrogen
deposition rates in these three regions, it is reasonable to as-
sume that forested watersheds would eventually reach nitro-
gen saturation  (barring major disturbances such as logging,
major fires, blow downs, and insect infestations).

As  a  speculative example, watersheds in the  Adirondacks
have  cooler annual  temperatures, shorter growing  seasons,
lower inherent productivity potentials,  restrictive  logging
practices  and fire control  policies, very mature old-growth
forest stands, and long histories of elevated deposition rates
of sulfur and nitrogen. Consequently, watersheds in these ar-
eas may include those having the shortest remaining times to
nitrogen saturation.  It has been suggested that saturation
times in this region may average less than 100 years; some
even  suggest the range of 25 to 75 years. In  comparison,
moving to  a   more southerly region,  watersheds  in  the
Mid-Appalachians have generally warmer annual tempera-
tures, longer growing seasons, less  restrictive forestry prac-
tices, and greater inherent productivity potentials, while also
having high nitrogen deposition rates. Watersheds in this re-
gion may  have  somewhat longer remaining times to nitrogen
saturation. Finally, watersheds in the Southern Blue Ridge
Province have even warmer annual temperatures, longer av-
erage growing  seasons, relatively the greatest productivity
potentials, the fastest decomposition rates, historically lower
nitrogen deposition rates, much  smaller pools  of soil nitro-
gen, and generally very low stream nitrogen concentrations.
Here, the remaining time to  watershed nitrogen  may  be
greater still.  Some areas in this region such as those found in
the Great Smoky Mountains National Park also include ma-
ture old-growth forests and other forests which have sus-
tained previous damage (i.e., insect damage). Time to nitro-
gen saturation  would likely be shorter in these areas. Esti-
mated times to  watershed nitrogen saturation for each region
are uncertain, but the relative ranking of these times is likely
appropriate across the three broad regions modeled.
likely to be highly transient in nature
for the year 2015,  largely  because
potential benefits from  implementa-
tion of 1990 CAAA requirements will
still be accruing at that time. There-
fore, this section focuses primarily on
projected  ANC changes   in  the
year 2040. For those  also interested
in projected changes in pH, the ANC
changes discussed can be related to
corresponding pH changes using the
empirical   relationships   between
these  variables  presented   in  Ex-
hibit 1: on average, across the  three
NBS regions, ANC<0 ueq/l and ANC
<50 ueq/l approximate  pH<5.3 and
pH<6.5,  respectively. NBS plot pro-
jection for pH changes are presented
in Appendix B.

Summary of NBS Results
Exhibit 13 summarizes the observed
and modeled percentages of surface
waters in  each  NBS  region target
population for  both  ANC  criteria.
The observed   values  were  those
measured during the 1984 NSWS
studies in the Adirondacks and the

1985 studies  in the  other  two re-
gions. For example,  19 percent of the
target lakes in the Adirondacks used
during the NBS were observed  to be
acidic  (ANC<0 ueq/l)  during  the
1984 NSWS. Note, however, that the
target   population   of   the   NBS
modeling included generally  more
sensitive subsets of target population
surface waters than were included in
the NSWS (see Exhibit 6).

The modeled  projections  summa-
rized in  Exhibit 13  indicate  propor-
tions of  surface waters  in  the two
ANC categories by  the  year 2040
under  the assumed times of  50 to
250 years and  never for watershed
nitrogen  saturation  for each region.
This  range  brackets the modeled
times for watershed  nitrogen satura-
tion occurring across the three  NBS
regions for  proportions  of waters
within each ANC category. The per-
centages  presented  encompass the
range of NBS results for modeled
                                             37

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
           EXHIBIT 13. SUMMARY OF NBS RESULTS: RANGE OF MINIMUM (BACKGROUND DEPOSITION) TO
          MAXIMUM (IMPLEMENTATION OF CAAA) PERCENTAGES OF ACIDIC AND SENSITIVE TARGET WATERS

Acidic (ANC<0 peq/l)
Observed*
Projected 2040, nitrogen saturation in 50 yr
Projected 2040, nitrogen saturation in 100 yr
Projected 2040, nitrogen saturation in 250 yr
Projected 2040, nitrogen saturation never
Sensitive (ANC<50 ueq/l)
Observed3
Projected 2040, nitrogen saturation in 50 yr
Projected 2040, nitrogen saturation in 100 yr
Projected 2040, nitrogen saturation in 250 yr
Projected 2040, nitrogen saturation never
Percentage of Target Waters
Adirondacks
19
6-43
3-26
0-15
0-11
55
53-67
51-57
44-54
44-54
Mid-
Appalachians
4
0-9
0-5
0-4
0-0
27
5-41
5-37
5-28
4-23
Southern
Blue Ridge
0
0-4
0-0
0-0
0-0
6
4-16
4-16
3-14
2-11
       a Observed 1984 for Adirondack lakes and 1985 for mid-Appalachian and Southern Blue Ridge streams.
minimum (background)  and modeled  maximum
(projected 1990 CAAA deposition) rates for both
total sulfur and nitrogen. For example, with an as-
sumed time  to  watershed nitrogen saturation  of
100 years, the upper right plot of Exhibit 8 shows
that background total sulfur and nitrogen deposi-
tion in the Adirondacks is projected to result in
3.4 percent  of the target lakes  having ANC  of
0 ueq/l or  less  in  the  year 2040. Similarly, the
maximum deposition for both anions likely  under
implementation of the 1990 CAAA are projected
to result in about 26 percent of the target lakes in
this water  quality  class. Also,  under this  same
range of deposition scenarios,  when the time to
watershed nitrogen  saturation is assumed to equal
250 years, the lower  left plot in  Exhibit 8 shows
that the model projects that between 0 percent and
15 percent of these same target Adirondack lakes
will  have ANCs of  0 ueq/l  or  less.  Exhibit 13
shows these two ranges and summarizes all other
similar NBS  projections for ANC by the year 2040
for all three modeled regions.

The  numerical ranges in the  model projections
presented in  Exhibit 13 provide an indication  of
the extent of uncertainty associated with each set
of model projections for each region. For example,
with the modeled  rates  of  sulfur and nitrogen
deposition expected to accompany  implementa-
tion of the 1990 CAAA, the percentage of  target
lakes in the Adirondacks with ANCs of 0 ueq/l or
less would likely range from about 15 percent to
43 percent, depending on whether the true time to
watershed  nitrogen  saturation  is  nearer  250 or
50 years, respectively. As discussed previously, a
variety of sources of variability and uncertainty af-
fect the overall uncertainty of these model projec-
tions. If these sources were included in an overall
evaluation  of  uncertainty,  the  associated  uncer-
tainty could be greater, with projections of future
responses  by  target   waterbody   populations
potentially  falling beyond either end  of all mod-
eled ranges presented in  Exhibit 13. Therefore,
while the NBS projections of change represent the
best currently  available techniques for projecting
environmental   changes  associated  with  acidic
deposition, the projections are best used as indica-
tors of general  direction and magnitude of possible
water quality changes associated with changes  in
total sulfur  and total nitrogen deposition rates  (See
Exhibit 6).

As noted in Exhibit 11,  the density  of contours
across the modeled deposition ranges in NBS plots
for ANC, including those in Exhibits 8-10, appears
to relate to  the potential average responsiveness  of
target waterbpdies to potential changes in deposi-
tion  rates.  (Vertical  and horizontal contours indi-
cate a strong  role of sulfur or nitrogen,  respec-
tively.)  Based  on this relationship,   all  regional
plots for alternative projected times to watershed
nitrogen saturation were  categorized  into one  of
three generalized levels of projected response  sen-
sitivities. These categories provide   a  basis for
evaluating  the  relative confidence that reducing
sulfur or nitrogen depositions below levels  pro-
jected to accompany the 1990 CAAA would  pro-
duce detectable improvements in ANC within the
                                                38

-------
                                                                    CHAPTER 2:  ENVIRONMENTAL GOALS
NBS target surface waters. Exhibit 14 presents the
results of the surface water responsiveness catego-
rization for the three modeled regions. The follow-
ing summary of regional relationships  to  acidic
deposition rates is drawn from Exhibits 13 and 14
and from the  individual plots for all three NBS
study regions.
Regional Summaries37
Adirondack Region
ROLES OF SULFUR, NITROGEN AND NATURAL ACIDITY:
For the NBS target population of Adirondack lakes,
after implementation of the  1990  CAAA, sulfur
deposition appears to continue to be the primary
cause of  the  present  chronically  acidic  surface
                 EXHIBIT 14. SURFACE WATER RESPONSIVENESS TO REDUCTIONS IN DEPOSITION BE-
                 YOND THE CAAA: DETECTIBLE IMPROVEMENTS IN LONG-TERM ANC BY 2040a-b
Region
ADIR
M-APP
SBRP
Deposition
Parameter
Reduced
Sulfur
""Sulfur
Nitrogen
Nitrogen
Sulfur
Sulfur
Nitrogen
Nitrogen
Sulfur
Sulfur
Nitrogen
Nitrogen
Criterion
(ANC)
<0jieq/l
<50 u.eq/1
<0jieq/l
<50 tieq/l
<0jiec|/l
<50 u.eq/1
<0jieq/l
<50 ueq/l
<0 u.eq/1
<50 neq/l
<0 u.eq/1
<50 u.eq/1
Estimated Time to Watershed Nitrogen Saturation
50 Years
A
•
A
A
O
A
•
A
O
O
O
•
100 Years
A
O
A
O
O
A
O
A
0
•
O
•
250 Years
A
•
O
O
0
A
O
A
0
A
O
O
Never
A
•
O
O
O
A
O
A
O
•
O
O
        a Key to symbols:

          O Additional decrease in acidic deposition of any magnitude below 1990 CAAA requirements is
             unlikely to produce improved conditions.
          • Additional decrease in acidic deposition of at least 50% below 1990 CAAA requirements may
             produce improved conditions. Lesser reduction in deposition is  unlikely to produce improved
             conditions.
          A Additional decrease in acidic deposition of at least  50% below 1990 CAAA requirements is
             likely to produce improved conditions. Lesser reduction in deposition may produce improved
             conditions.
        b Improved conditions is defined as decreases by greater than 5% of the target population (e.g., from
          30% to 24%) meeting the specified criterion (e.g., ANC<50 ueq/l), assuming the specified time as
          the region average for watershed N saturation. Reduced deposition may lead to environmental im-
          provement which does not meet the definition of "improved conditions" described above.
Because the strongest scientific data  collected on
acidity in the eastern lakes and streams come from
the  1984  NSWS,  the water  quality  conditions
found in that survey serve as a model for protec-
tive goals used in this report.
water chemistry when longer modeled times to ni-
trogen saturation  (>250 years) are assumed. Nitro-
gen and sulfur deposition are projected  to share
relatively equal future roles  in affecting  modeled
ANC when watershed nitrogen saturations are as-
                                                     37 Most of this discussion was developed from  evalu-
                                                       ations of  results from the National Surface  Water
                                                       Survey and model  projections from  the Nitrogen
                                                       Bounding Study.
                                                 39

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 sumed  to occur  within  100 years.  And,  when
 50 years is assumed as the time to nitrogen satura-
 tion, the future importance of nitrogen deposition
 as a direct cause of surface water acidification is
 projected to be greater.

 Proportions of ANC<50 ueq/l lakes in this region
 are projected  as likely to show very small changes
 due to deposition  reductions by  the year  2040.
 This relatively small potential for change indicates
 that this  region has  a high proportion of lakes
 which naturally have ANCs of 50 ueq/l or less
 without the influence of acidic  deposition.  These
 lakes will continue to have low ANC levels regard-
 less of acidic deposition rates. This condition is not
 detrimental in itself, but makes these waters highly
 sensitive to adverse  effects from  episodic acidic
 events.

 CHRONIC ACIDIFICATION: Under an assumed time to
 watershed nitrogen saturation of 50 years and un-
 der the deposition  reductions projected from 1990
 CAAA implementation, the  proportion of chroni-
 cally acidic (ANC<0 ueq/l) Adirondack target lakes
 is projected to increase by  about 50 percent  in
 2015  and may double by 2040, relative to 1984
 proportions. Assuming 100 years to nitrogen satu-
 ration, NBS modeling projects  that with  imple-
 mentation of the 1990 CAAA, proportions of ANC
 <0 ueq/l  lakes in the NBS target population may
 increase from  19 percent in 1984 to 26 percent in
 2040.  These  increased proportions appear due
 largely to the increased effects of nitrogen deposi-
 tion. If, however, the time to nitrogen  saturation
 equals or exceeds 250 years, the model projects a
 slight reduction in the proportion of acidic lakes in
 2040 with the implementation of the 1990 CAAA
 (i.e., from 19  percent to 15 percent or  less). The
 uncertainty regarding time to watershed nitrogen
 saturation remains an  important consideration.

 EPISODIC ACIDIFICATION:38 Two parallel  but  inde-
 pendent estimates place the number of Adirondack
 lakes within the NBS target population that may
 become acidic (i.e.,  ANC<0 ueq/l) during snow-
 melt or heavy storm flow  events at least once per
year at about 3.5 times the number of chronically
acidic  lakes.  The 1984 proportion of NBS target
population lakes estimated to be  at risk of episodic
acidification at least once per year is 73 percent,
compared to 19 percent estimated to be chroni-
cally acidic. Because episodes  are driven princi-
pally by  deposition acidity, reductions in  acidic
38 Also see Section 2.2.2 on episodic acidification.
deposition rates for either sulfur, nitrogen, or both
can be expected to significantly reduce the occur-

rence of acidic episodes in the target population of
Adirondack  lakes. This would be expected  to oc-
cur at a more rapid rate than the reduction in pro-
portions of chronically acidic lakes because depo-
sition reductions  are  likely to  have the greatest
immediate influence in reducing the mass of acids
and acid anions deposited by major storms.

RESPONSIVENESS TO DEPOSITION REDUCTIONS: Model-
ing results for the NBS target population of Adir-
ondack lakes  indicate a  reasonable expectation
that additional reductions  in  sulfur  deposition
rates, beyond  those projected to accompany the
1990 CAAA,  would  likely  produce  detectable
long-term  improvements in ANC, regardless of the
time to nitrogen saturation for the NBS target wa-
tersheds. It  is  also reasonable to expect that  re-
duced  nitrogen deposition would produce detect-
able ANC changes in  these lakes, but primarily if
times to nitrogen  saturation for  these watersheds
average 100 years or less.

While  considerable uncertainty regarding time to
watershed nitrogen saturation exists, if the average
time for Adirondack watersheds to reach nitrogen
saturation  is close to 100 years or less,  the model
predicts that maintaining the proportion of chroni-
cally acidic (ANC<0 u.eq/1) target population Adir-
ondack lakes near their 1984 proportions in 2040
may require reducing anthropogenic sulfur and  ni-
trogen  deposition  by 40-50 percent or more  be-
low the reductions projected to accompany the
1990 CAAA. The model projects that reductions in
sulfur and nitrogen deposition  of about 4.5  kg-
S/ha/yr and 7.5 kg-N/ha/yr, are projected as neces-
sary to maintain  proportions of sensitive  lakes
(ANC<50 ueq/l) near their 1984 levels (i.e, 55 per-
cent) if the time to watershed nitrogen saturation
approaches 50 years or less. If the time to satura-
tion actually is 100 years or longer, the model pro-
jects that deposition reductions accompanying the
1990 CAAA will allow proportions of Adirondack
lakes with ANCS50 u.eq/1 to maintain  their  ap-
proximate 1984 levels to the end of the projection
interval at the year 2040.

Mid-Appalachian Region
ROLES OF SULFUR AND NITROGEN: For the NBS target
population of  mid-Appalachians stream reaches
assessed, model  projections  indicate that  sulfur
and nitrogen deposition appear about equally im-
portant in  surface water acidification processes for
this region (Exhibit 9).
                                                40

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                                                                  CHAPTER 2:  ENVIRONMENTAL GOALS
CHRONIC ACIDIFICATION:  As progressively  shorter
times to watershed  nitrogen saturation are as-
sumed,  adverse effects associated with nitrogen
deposition  are projected to  increase,  essentially
offsetting reduced proportions resulting from im-
plementation of the  1990 CAAA sulfur reductions
in mid-Appalachians target  streams.  Under as-
sumptions of 250 years or less as the time to wa-
tershed  nitrogen saturation, no net change  in the
proportion of acidic (ANC<0 ueq/l) streams in the
NBS target population is projected to accompany
implementation of the 1990 CAAA.

EPISODIC ACIDIFICATION: The estimated  number of
mid-Appalachians stream reaches in  the NBS tar-
get population  that are episodically acidic (ANC<
0 ueq/l) at least once per year under  1985 deposi-
tion  levels is approximately six times the number
estimated  to be chronically acidic (i.e., approxi-
mately  23 percent of the target stream reaches
likely experience acidic episodes). Reducing depo-
sition of sulfur, nitrogen, or both would  be ex-
pected to reduce the number of episodically acidic
stream  reaches in the  mid-Appalachians  target
population  faster  than the rate of reduction for
chronically  acidic reaches, for reasons similar to
those concluded for Adirondack lakes, above.

RESPONSIVENESS TO DEPOSITION REDUCTIONS: Poten-
tial benefits from  additional  deposition reduction
beyond  the 1990 CAAA is projected to have bene-
fits for the target population  of mid-Appalachians
stream reaches having ANCs of 50 ueq/l or less,
regardless of the time to  nitrogen saturation. The
nature of these benefits should be viewed not so
much as potentially  reducing chronically  acidic
conditions in these target streams (although this  is
likely), but as potentially reducing the susceptibil-
ity of sensitive streams to episodic acute acidifica-
tion  effects  (i.e.,  decreasing the proportion of
stream segments with ANC less than 50 ueq/l).

The 1985 Eastern Stream Survey found 27 percent
of the NBS target streams  in the mid-Appalachians
had ANCs of 50 ueq/l or less. NBS projections in-
dicate that if the average time to watershed nitro-
gen saturation approximates 250 years or greater,
implementation of the 1990 CAAA  would likely
result in target stream reaches  maintaining their
1985 proportions of chronically  acidic (ANC<0  ji
eq/l)  as well as sensitive (ANC<50 u.eq/1) stream
reaches in the year 2040. If, instead,  average time
to watershed  nitrogen  saturation  approximates
100 years or less, the model projects that reducing
either sulfur  or  nitrogen deposition  by  about
25 percent below  projected CAAA reductions, or
some lesser combined  deposition  reduction  for
both chemicals, could be necessary to maintain
proportions  of  target  stream  reaches  in  the
year 2040 near their 1985 conditions. That is, the
deposition rates may have to be reduced by about
3.5 kg-S/ha/yr  or 3 kg-N/ha/yr, or some combina-
tion leading to reduced deposition for both  acidify-
ing chemicals, if the time to nitrogen saturation
approximates 100 years  to maintain 1985  propor-
tions.

Southern Blue Ridge Province
ROLES OF SULFUR AND NITROGEN: In the  SBRP, like
the mid-Appalachians, projected deposition effects
after implementation  of the  1990 CAAA appear
about equally  attributable to sulfur and nitrogen
deposition. This is probably due to the relatively
high remaining potentials for SO42~ adsorption in
soils and NO3~ retention  in  watersheds of the
SBRP. NBS  modeling results project a relatively
minor response to deposition changes  during the
period modeled;  more  discernible  water quality
changes related to either sulfur or nitrogen deposi-
tion may occur after the year 2040.

CHRONIC ACIDIFICATION: Generally, the  NBS target
population of  stream reaches in  this region  pres-
ently appears to be little affected by chronic  acid-
ity. Six percent of the NSWS stream reaches in this
region  had ANC of 50 ueq/l or less.  Under the
1990 CAAA and under all four assumptions of time
to watershed nitrogen saturation,  the acid chemis-
try in most target stream reaches are projected to
change generally little by 2040 from 1985 condi-
tions. A marked exception  to this pattern is that,
even with CAAA implementation,  the  proportion
of target stream reaches  with ANCs  of 50 ueq/l or
less are projected to approximately double, reach-
ing 11 percent to 16 percent by  2040, under the
modeled times to nitrogen saturation of 250  years
or greater. In turn, if nitrogen saturation occurs at
about 50 years, about 4  percent of stream  reaches
might become acidic (ANC<0 ueq/l) where  none
previously had been acidic.

EPISODIC ACIDIFICATION: Potential changes in epi-
sodic effects within the SBRP were  not modeled
during the NBS because appropriate model cali-
bration data were lacking, and therefore, no avail-
able numeric estimates exist for the percentage of
stream reaches in this NBS target population that
may become episodically acidic by either 2015 or
2040.  Nevertheless,  as  the number  of stream
reaches in the  SBRP target population with chronic
ANC of 50 ueq/l or less increases, the possibility of
                                                41

-------
 ACID DEPOSITION STANDARD.FEASIBILITY STUDY
 episodically acidic  conditions  increases substan-
 tially and can be reasonably expected to occur in
 these target streams prior to (and at greater per-
 centages  than)  the  occurrence  of chronically
 acidic conditions.

 RESPONSIVENESS TO DEPOSITION REDUCTIONS: Model
 projections indicate that deposition reductions ac-
 companying the  CAAA would likely prevent long-
 term  acidification  (ANC<0  ueq/l)  of  sensitive
 streams at least until 2040, if the time to nitrogen
 saturation is 100  years or longer. Modeling projec-
 tions also indicate  that  additional reductions in
 sulfur or nitrogen deposition in  the SBRP, beyond
 those  expected to accompany  the CAAA, could
 reduce the  proportion of  target stream  reaches
 with ANCs of 50 ueq/l or less. If the time to water-
 shed nitrogen saturation  in  this  region  is  near
 250 years  or longer, the NBS  modeling projects
 that sulfur deposition would need to be reduced by
 about  an  additional 25 percent to maintain  the
 ANCs  in the target stream reaches near their 1985
 conditions. Whereas, if the time to watershed ni-
 trogen saturation is nearer 100 years  or less, a
 65 percent total decrease in both sulfur and nitro-
 gen  deposition beyond the CAAA is projected as
 necessary to maintain  ANC in these target stream
 reaches  near their  1985  conditions  in the year
 2040. NBS projections for this potential time to ni-
 trogen saturation (100 years or  less)  indicate that
 deposition may have to be reduced  below 4 kg-
 S/ha/yr and below  5 kg-N/ha/yr to maintain  pro-
 portions  of  stream  reaches in  the  SBRP target
 population with ANC<50 ueq/l at 1985 values.

 Implications for an Acid Deposition Standard
The  potential  sensitivities  of  target aquatic  re-
sources, their potential responses, and time course
of responses to changes in acidic deposition rates
as well as the relative current and potential roles
of sulfur and nitrogen clearly differ among regions.
This strongly supports  the development of a  site-
specific deposition standard or target load.

The  acidifying  effects   of  nitrogen  deposition
should be considered when evaluating options and
potential needs for acid deposition standards. Spe-
cifically,  NBS modeling indicates that  nitrogen
deposition appears to produce  important conse-
quences for the future acidification rates of surface
waters. Additionally, for many watersheds the ef-
fect of nitrogen deposition could be a greater con-
cern than are the  effects of sulfur deposition alone.

The  wide-ranging projections of possible benefits
associated with implementation  of the 1990 CAAA
for each of these regions illustrate the need to im-
prove the ability to quantify watershed  nitrogen
saturation rates. Until  watershed  nitrogen satura-
tion is  better understood, significant  uncertainty
will continue to accompany surface water benefits
analyses of  potential reductions in sulfur and  ni-
trogen deposition. Despite the uncertainty, how-
ever, it is useful to recognize that any reductions
in nitrogen deposition would not only reduce total
acidic deposition rates, but also reduce the actual
times to watershed nitrogen saturation. This proc-
ess is similar to the ongoing process whereby  re-
ductions in sulfur deposition  due  to the 1990
CAAA  are likely extending times  for water sulfur
saturation within watersheds.

2.5.4  Overview of International and State
       Acidic Deposition Criteria and
       Standards
International consideration of ecologically based
standards to address air pollution  problems origi-
nated in the mid-1960s. Driven primarily by the
acid rain debate over the next 30 years, the origi-
nal concept of using concentration-based  criteria
gave way to using uniform  maximum allowable
mass deposition rates,  with  20 kg-wet  SO42Yha/yr
(6.7 kg-S/ha/yr) being the first widely  recognized
interim  target  load.   Subsequently,  site-specific
critical loads were increasingly emphasized. Their
development is generally attributed to Swedish  re-
search efforts in the late 1960s.39

Critical loads are estimates of the maximum pol-
lutant loadings that environmental resources can
absorb on a sustained  basis without experiencing
measurable degradation. Only inherent ecological
properties are included in site-specific critical load
determinations. Steps involved in defining and im-
plementing   critical   loads   usually   include
(1) resource  identification  and  characterization,
(2) identification of regions or functional subre-
gions,  (3) characterization of deposition  within
subregions, (4) definition of assessment endpoint(s)
(see below), (5) selection and application of mod-
els, and  (6)  mapping projected environmental  re-
sponses.40
39 Nilsson, j. and P, Crennfelt (editors).  1988.  Critical
  Loads for Sulphur and Nitrogen Report from a Work-
  shop Held at Skokoster, Sweden, 19-24 March 1988,
  UN/ECE and Nordic Council of Ministers.
40 Strickland, T.C., G.R. Holdren, Jr., P.L. Ringold, D.
  Bernard, K.  Smythe, and W. Fallen.  1993.  A Na-
  tional Critical  Loads  Framework  for Atmospheric
                                     (continued)
                                                 42

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                                                                   CHAPTER 2: ENVIRONMENTAL GOALS
Target loads differ from critical loads in that their
definitions incorporate social, policy, economic,
and related  considerations along with scientific
findings. An example of a target load would be an
acidic deposition level adequate to  maintain pro-
portions of ANC<50 ueq/l  waters at or below the
proportions found during the 1984-85 NSWS for
one or  more of the surveyed regions. (This exam-
ple is illustrated in Section 3.6.) Other possible
target loads could include, for example, a deposi-
tion level to produce a specified percentage reduc-
tion in  the 1984-85 proportions of ANC<50 ueq/l
waters.

Assessment endpoints are formal expressions of the
environmental  value(s) to be protected. They can
include  thresholds  for  "deleterious  conditions"
(commonly some adverse ecological condition)
that a standard would attempt to prevent. Assess-
ment endpoints should  be biologically  relevant,
operationally definable,  accessible  to prediction
and measurement, and sensitive to the pollutant(s)
of concern. From a policy  perspective, assessment
endpoints also  should  be socially relevant; that is,
they should be environmental characteristics mu-
tually understood and valued by the public and by
decision makers (e.g.,  populations of crops, trees,
fish, birds, or mammals). When the most appropri-
ate sensitive species or other endpoint used is not
socially valued, then their link to valued species or
other valued environmental attributes should  be
explicitly demonstrated to simplify understanding
of why using such an endpoint is  useful.  Using
endpoints that have social relevancy helps to unify
scientific and social concerns in commonly shared
objectives.

The first and still dominant ecological assessment
endpoint used  for critical and target load estima-
tion is  freshwater aquatic responses,  most com-
monly manifested as changes in pH or ANC.  Of
particular interest here is that pH or  ANC changes
themselves are often a relatively minor  concern,
but the influence of such changes  on biological
species is of considerable importance. Therein is a
defining attribute of how  the concept of critical
loads has developed in  its international  use, i.e.,
critical  loads of chemicals (e.g.,  SO42' and  NO3")
are surrogates  for biological  concerns.  The  key
biological concern most  often focused upon is fish
viability.
A critical load value can be viewed as a single,
especially  important point along a  continuous
range of values representing an ecological loss or
damage function. Viewing a critical load as part of
an ecological  loss function is especially important
because  that view has shaped much of the Euro-
pean debate over the appropriate and scientifically
defensible uses of critical loads in acid rain control
policy development. Further, these loss functions
are particularly important when it is recognized (as
it has  been in Europe, Canada,  and the United
States) that significant numbers of highly sensitive
receptor locations have associated critical loads
that likely cannot be met, even with widespread
and high levels of acidic deposition reduction em-
ploying the limits of technological feasibility. Loss
functions provide a mechanism to aggregate eco-
logical  damage across regions  and integrate  a
quantitative understanding of acidic deposition to
ecological  damage  relationships. Without these
functions, more qualitative, often  highly subjec-
tive, aggregation approaches  are used  to  place
critical  load concepts  into policy-relevant  con-
texts.  The results of such  approaches  most often
are termed target loads, as described above.

Most  countries of western Europe have  adopted
the system for estimating critical  loads developed
by the Coordination Center for Effects (CCE) of the
United Nations Economic Commission for Europe
(UNECE) under the auspices of the UNECE Con-
vention on Long-Range Transboundary  Air Pollu-
tion  (LRTAP)  (Exhibit  15). A recently  published
manual presents improved  methods that are being
widely applied across Europe  for  mapping  both
critical  loads  to  protect sensitive  resources and
critical levels of allowable atmospheric concentra-
tions of acidic pollutants.41 In  this system, critical
loads  are developed for  individual cells of the
mapping grid based on the potential sensitivity to
acidification of forest soils and  surface waters.
Critical loads for sulfur, nitrogen,  and total acidity
have been mapped  across  Europe. Although a va-
riety of models were used, nearly  all countries that
participated in the  European mapping  effort em-
ployed  the  simple  mass  balance  steady-state
method  as the underlying approach to estimate
critical loads. Several countries also used dynamic
models and other methods. In the CCE  approach,
  Deposition Effects Assessment:  I. Method Summary.
  Environmental Management 17:329-324.
41 Task Force on Mapping.  1993.  Manual on Mapping
  Critical Levels/Loads.   Coordination Center for Ef-
  fects, U.N.  Economic Commission for Europe.  Ber-
  lin, Germany.
                                                43

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
                EXHIBIT 15. LRTAP
   In 1981, the United States became party to
   the  UNECE  Convention  on  Long-Range
   Transboundary Air Pollution (LRTAP). Signa-
   tory countries  include most  western Euro-
   pean  countries, several  newly Independent
   States, Canada, and the United States. The
   Convention symbolizes a formal recognition
   on  the  part of signatory countries that the
   transboundary flow of air pollution is an im-
   portant  issue that merits formal international
   cooperation. In 1985, the first Sulfur Proto-
   col under the Convention  committed those
   countries who signed to a 30 percent reduc-
   tion in emissions of sulfur dioxide from 1980
   levels. (The United States did not sign based
   on significant sulfur dioxide emission reduc-
   tion efforts already undertaken in the 1970s.)
   Soon  thereafter, emissions  reductions based
   on achievement of critical loads became the
   focus of efforts under LRTAP.  In 1994, most
   countries signed the Second Sulfur Protocol
   requiring mapping of critical loads for all af-
   fected countries. It  is the expectation that
   this effort will  lead to emission  reductions
   based on the critical loads. A Nitrogen Ox-
   ide Protocol was  signed in  1988  by most
   countries, including the  United States. The
   NOX Protocol outlined steps to reduce  na-
   tional annual NOX emissions. It also initi-
   ated research  and  cooperative  efforts  on
   critical loads for nitrogen.
the indicator used to estimate critical loads for for-
est soils (using the simple mass balance steady-
state model) is the concentration of aluminum in
the soil solution required to maintain pH above
4.0. Some countries varied the basis for their map-
ping procedures based on  the availability of the
data collected by the individual .countries, and the
regional and national concerns regarding the sensi-
tivity of specific sensitive resources. The majority
of critical load values in  Europe reflect the sensi-
tivity of forest soils. Critical loads in Finland,  Nor-
way,  Sweden,  Switzerland,  and  several of the
newly  Independent States reflect forests  and sur-
face waters.42
The single  most  important technical  attribute
around which European activities on acid deposi-
tion standards have revolved is associated with de-
fining the spatial  resolution  used. Interestingly, the
early decision to use a  150 km by 150 km square
grid as the fundamental spatial assessment unit for
acidic deposition control strategies had no direct
connection to spatial levels of resolution deemed
appropriate for critical load  estimation.  In fact, the
grid was  in  place  well before the critical  loads
concept achieved common usage. This relatively
coarse grid size, however, often allows for signifi-
cant spatial variation in environmental types and
designated critical  load alternatives within indi-
vidual cells.  This leads to  difficult questions re-
garding spatial estimation of specific critical  loads
appropriate for supporting  deposition-based con-
trol  policy  and measurement  of maintenance
and/or exceedance levels.

To provide a reasonable level of protection  for
more sensitive ecological resources within  each
grid cell, the European  approach uses cumulative
distributions  of  critical  load values and selects
from this distribution a  non-exceedance  level for
each cell.  Under this approach two loadings  are
calculated: one that would protect 95  percent of
sensitive ecological resources within the grid (i.e.,
the 5-percentile load), and one that would protect
99 percent of the resources (i.e., the 1-percentile
load). This procedure reconciles some of the basic
problems that arise  when point estimates  are used
to represent regional concerns.  But the approach
still holds difficulties related largely to the process
of selecting appropriate critical load values from
the resulting  distribution functions. Specifically, it
is sometimes difficult to  determine the rationale by
which  individual  critical load values are selected
among the different cells. Qualitative considerat-
ions, which often stem  from political agreements,
also have a role in this  process.43 Despite the dif-
ferent  sensitivities  of various ecosystems,  most
critical loads developed in  Europe are very low
when compared  to  present deposition. This has
given some countries the impetus to seek greater
emissions  reductions than were already planned.
Thus, most of the reductions of sulfur emissions
42 Coordination Center for Effects,  National Institute of
  Public Health and  Environmental Protection. 1991.
                                      (continued)
  Mapping Critical Loads for Europe. CCE Technical
  Report No.  1.   U.N. Economic Commission for
  Europe, Bilthoven, Netherlands.
43 Henriksen, A., and  D.F. Brakke.  1988.   Sulfate
  deposition to surface waters.  Environmental Science
  and Technology 22(1 ):8-14.
                                                 44

-------
                                                                   CHAPTER 2: ENVIRONMENTAL GOALS
under the second Sulfur Protocol fall in the range
of 50-80 percent. The  European community as a
whole is projecting emissions decreases of over 60
percent by the year 200 compared to 1980 levels.
The four  European countries that signed the sec-
ond Sulfur Protocol and their commitments to  re-
ductions (relative to 1980) are:44

   * France:          74% by 2000; 78% by 2010

   « Germany:        83% by 2000; 87% by 2005

   * Italy.            65% by 2000; 73% by 2005

   « United Kingdom:  50% by 2000; 80% by 2010

The French reductions translate into an emissions
level of approximately 825,000 tons of sulfur diox-
ide; emissions  reductions in the other three coun-
tries are around 1.1 million tons. These emissions
reductions will occur in an area that is in general
much less energy intensive than in the two North
American  members of LRTAP (the  United  States
and Canada),  so it is  difficult to argue that the
Europeans are simply getting easy, low-cost reduc-
tions. Taken together, these four European indus-
trialized  countries represent  a  population  very
close to that of the United States. By  2010, their
emissions of sulfur dioxide will be less than 5 mil-
lion tons, while the United States is projected to
have emissions of  around 15  million short tons.
Canada committed to reducing its emissions by 46
percent within a Sulfur Oxide Management Area
(SOMA), which represents a targeted approach to
the acidification problem in Eastern Canada. Can-
ada's population is about 10 percent  that of the
United States; it is committed to a national cap of
3.2 million metric tons (about 3.5  million short
tons) in the year 2000.

Canada adopted 6.7 kg-S/ha/yr (wet deposition) in
the early  1980s as  what would now be termed a
target load. This value was based on available data
indicating that  loss of sport fish would occur at pH
less than 5.3, and this loss would produce signifi-
cant economic and social impacts. This target load
was not, however, intended to protect extremely
sensitive areas. Canadian policy makers concluded
that additional research was  necessary to  deter-
mine appropriate loading limits to completely pro-
tect all sensitive Canadian ecological resources.
The target load was used as a goal in developing
the Canadian acid rain control  program  and in
discussions with the United States on transbound-
ary air pollution. As a  result of current U.S.  and
Canadian acid rain control programs, most areas
of Canada are expected to reach the 6.7 kg-S/ha/yr
target.

Subsequently, in 1990, critical  loads  for water-
sheds in eastern Canada  were  calculated using
steady-state water chemistry models that projected
sulfur deposition necessary to maintain 95 percent
of the lakes at pH 6.0 or greater.45 Included in this
approach were allowances for maintaining condi-
tions in naturally acidic surface waters. Resulting
critical load estimates ranged from less than 2.7 to
more than 6.7 kg-wet  S/ha/yr,  with  the variation
primarily dependent on geological characteristics.
The eastern region of Canada, including the Atlan-
tic provinces, Labrador, and eastern  Quebec,  was
determined to require the lowest critical loads  (less
than 2.7 kg-S/ha/yr),  which are  close  to back-
ground deposition levels. Critical loads  estimated
for Quebec ranged from 3 to  more than  6.7 kg-
S/ha/yr, and  for Ontario they ranged from 2.7 to
more than 6.7 kg-S/ha/yr. In a separate  analysis, a
simple mass balance approach  was used to deter-
mine that  a loading of  5 to  6.7 kg-S/ha/yr  wet
deposition  would  maintain  surface  water  pH
greater than 5.3 on an annual  basis in watersheds
that have lakes with ANCs of 200 ueq/l or greater
in regions of low runoff.

Using the initial Canadian effort as an  example,
the New England states and  New York adopted
Canada's first target  load  of  6.7 kg-S/ha/yr  (wet
deposition) as a level adequate to protect  moder-
ately sensitive ecological resources from additional
damage caused by acidic deposition.46 This level
was not viewed, however, as adequate to  protect
the most sensitive resources within these regions.
44 United Nations Economic Commission for Europe.
  1994.  Protocol to the 1979 Convention on Long-
  Range Transboundary Air Pollution on Further Re-
  duction of Sulphur Emissions.  ECE/EB,AIR/40.  Ge-
  neva.
45 Federal/Provincial  Research and  Monitoring Coor-
   dination Committee.  1990.   The 1990 Canadian
   Long-Range  Transport of Air  Pollutants and Acid
   Deposition Assessment Report.  8 parts. Research
   and Monitoring Coordination Committee, Canada.
46 New England Governor's Conference.  1985.  His-
   tory and the  Development of the New England Posi-
   tion on Acid Rain.  New England Governor's Confer-
   ence, Inc.
   New York State Department of Environmental Con-
   servation (NYSDEC). 1985. A Policy for New York
   State to Reduce Sulfur Dioxide Emissions: The Sulfur
   Deposition Control Program.   Final Environmental
   Impact Statement.  NYSDEC, Albany, NY.
                                                45

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 Maryland  developed  critical loads based on the
 sensitivity of individual streams to acidification.47
 This effort included as its overall goal an assess-
 ment of the extent to which the state could meet
 or surpass its ecological objectives  to  minimize
 potential  acidic  deposition  effects. Calculated
 critical loads for areas within Maryland ranged by
 region from less than 8 to more than 64 kg-S/ha/yr.
 These loads were developed using (1) two models
 (PROFILE  and MAGIC), (2) pH  limits required to
 protect the most sensitive life stages  of biological
 indicator  species,  and  (3) a complex of specific
 physical,  chemical,  and biological  factors  that
 potentially affect soil  and water chemistries. Acid
 sensitivities for three indicator fish  species  were
 used across the different regions assessed:  blue-
 back herring (pH=6.2), smallmouth bass  (pH=5.8),
 and brook trout  (pH=5.75). The assessment  re-
 vealed that critical loads at several sensitive recep-
 tor locations could not be  met for any  plausible
 emissions  control scenario.  These locations  were
 thus deemed possible  candidates for site-specific
 mitigation measures, principally stream liming.

 Minnesota is the only  state with an established
 deposition standard for  sensitive areas.48 Sensitive
 areas are  defined based on lake ANC,  with the
 state's deposition standard of 3.7 kg-S^a/yr (wet
 deposition) established to  protect  lakes whose
 ANC is  less than 40 ueq/l. The standard was de-
 rived using regression techniques to relate deposi-
 tion SO42' concentrations and acidity to the ability
 of sensitive Minnesota lakes (ANC<40 ueq/l) to as-
 similate  additional acid loadings.  This deposition
 standard may also be viewed as equivalent to the
 critical load for this region because maps of  sens-
 itive soils  show that  the majority of areas  with
 potentially the most  sensitive soils correspond to
those regions with sensitive lakes.

 In contrast to regions east of the Mississippi River,
deposition of nitrogen has long been  viewed as a
 more significant problem than deposition  of SO2 in
 much of .the western  United States. For  example,
 NO3- approximately  equals  SO42' deposition in
some areas  of  California.  Consequently,  critical
47 Sverdrup,  H., P. Warfvinge, M. Rabenhorst, A. Jan-
  icki, R, Morgan, and M. Bowman.  1992.  Critical
  Loads  and Steady-State Chemistry  for Streams  in
  Maryland. Environmental Pollution 77': 195-203.
48 Minnesota Pollution Control Agency. 1985.  State-
  ment of Need and Reasonableness: Proposed Acid
  Deposition Standard and Control Plan.  State of Min-
  nesota Pollution Control Agency, St. Paul, MN.
 loads for nitrogen deposition have been estimated
 for California,49 but similar loads for sulfur  have
 not. Studies show that loadings of 10 to 20kg-
 N/ha/yr  would  likely  protect  California forests.
 Critical loadings recommended to protect sensitive
 California   resources  ranged  from 5 to  45 kg-
 N/ha/yr, depending on the  region. Other state ef-
 forts are currently underway.

 2.5.5   Spatial and Temporal Issues in
        Development of a Standard
 Information discussed in Sections 2.3, 2.4, 2.5.2,
 and 2.5.3  clearly demonstrate  that regions  of
 North America differ  in both their potential sensi-
 tivity and risk to adverse effects caused by sulfur
 and nitrogen deposition. These differences provide
 a strong scientific justification for setting different
 standards that recognize  variations among  and
 within sensitive regions. Regions covered by any
 individual  standard would be larger than   most
 states and undoubtedly smaller than the nation as
 a whole. It is also clear that appropriate and scien-
 tifically justifiable environmental goals could differ
 across areas within individual states.

 Sensitive resources tend to cluster within relatively
 easily defined geographic areas often associated
 with specific mountain ranges and other areas hav-
 ing relatively unique geologic attributes. Potential
 protection requirements for ecological resources in
 sensitive regions can  be identified, categorized,
 and aggregated across several  levels of  organiza-
tion. These include regions,  landscapes,  ecosys-
tems, communities, populations,  and individual
 site-specific measures  (e.g., critical stream habitat
for  a  listed endangered fish species). In general,
the smaller the  area  of concern, the greater the
precision required in establishing the  basis for
standards  and  in determining  the  boundaries
where  standards would apply.  Under  a  critical
 loads approach, appropriate ecological  rationales
would need to be developed for whatever scale is
targeted for protection by a standard. Furthermore,
there is significant variation in  spatial scale of ex-
posure (i.e., wet and dry deposition) on a regional
 as well  as site-specific level. Deposition and  effe-
 cts  monitoring (further described  in the  following
49 Takemoto, B.K., M. Bergen, N. Motallebi, M. Muel-
  ler, H. Margolis, and S. Prasad.  1992.  The Atmos-
  pheric Acidity Protection Program: Annual Report to
  the Governor and Legislature. Draft report. State of
  California Air Resources  Board, Research Division,
  Sacramento, CA.
                                                 46

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                                                                   CHAPTER 2: ENVIRONMENTAL GOALS
chapter) is an essential component in the standard
setting and implementing process.

Beyond these considerations regarding differences
in the spatial scale are important considerations
regarding the temporal scale. For example, the po-
tential for exposure to, and risk from, acidic condi-
tions is often highest during the spring due to the
mobilization  of  the winter  accumulations  of
deposited acids and the activation of seasonal bio-
logical  growth  process.  Also,  the  sensitivity of
many resources changes over time.  For example,
the most sensitive life stages of  many fish species
are hatching eggs and newly hatched fry. The pe-
riods of greatest sensitivity for  many species are
spring and fall when most fish species hatch. Simi-
larly,  spring  budding  periods  for  flowers  and
leaves and initial root growth by seedlings are par-
ticularly  sensitive  periods for many  terrestrial
plants. In contrast, many resources have low sensi-
tivity during the winter, when their biological ac-
tivity is  low. Patterns in weather variations may
change from year to year and would also have to
be considered in a standard-setting process. Op-
tions that could be evaluated for appropriate aver-
aging periods which accommodate temporal issues
include single-event  loadings, seasonal loadings,
total  annual loadings,  average annual loadings,
10-year  average  loadings  and 50-year  average
loadings. The timing of a standard, therefore, ulti-
mately  has significant  implications for develop-
ment and  implementation of an acid deposition
standard.

Determining appropriate averaging  periods must
also  include consideration of possible temporally
delayed  effects.  For example,  the  chemistry of
spring meltwaters may better reflect accumulated
winter deposition than springtime deposition. Such
processes could indicate the need in some regions
for  more stringent  winter deposition standards.
Such standards might aim to minimize over-winter
accumulations of  strong-acid  anions  in  snow
packs, thereby minimizing the potential acidity of
spring meltwaters and their potential adverse effe-
cts on receiving  waters. Likewise, in those areas
where episodic pulses of nitrogen  are the primary
concern, temporal considerations may best be fo-
cused on a particular pollutant. Consideration of
effects that are cumulative in nature and potential-
ly significantly delayed in time is a  complex yet
critical component in the development of an acid
deposition standard.
2.6  CONTROLLING SULFUR AND NITROGEN TO
     REDUCE SURFACE WATER ACIDIFICATION
Atmospheric deposition  of  sulfur- and  nitrogen-
containing compounds, primarily SO42~ and NO3",
contributes to the acidic deposition  problem, as
reviewed  in  Section 2.2.1. The  relative  contribu-
tion  of sulfur and  nitrogen to this problem differs
among regions,  depending  not  only on  external
differences in the deposition  rates of these chemi-
cals, but also on differences among the capacity of
receptor watersheds to retain sulfur and nitrogen,
as discussed in Sections 2.2.1,  2.5.2,  and 2.5.3.
Such differences have led  some authorities (e.g.,
those in California) to date to focus  solely on the
need to  control  nitrogen  deposition  (see Sec-
tion 2.5.4) while others have focused primarily on
sulfur.

For most regions of North America affected by and
at risk from  chronic  effects  of acidic deposition,
the principal present  concern is sulfur deposition.
As more fully discussed in  Sections 2.2.1, 2.5.2,
and 2.5.3, sulfur deposition appears to be the pri-
mary cause of long-term chronic acidification in
all affected sensitive areas. The NBS illustrates that
for the near term sulfur deposition is  likely to rem-
ain the overriding acidification  problem  in most
sensitive areas  of  eastern  North America. This
likely will remain  the case until  annual retention
of nitrogen decreases sufficiently and the full po-
tential  acidifying influence of nitrogen deposition
commences.  At these times, sulfur  and  nitrogen
are projected to  have approximately equal roles in
surface water acidification.  Thus, for most areas,
where  current or  near-term  needs for  additional
acidic deposition control are  projected, and where
watershed nitrogen saturation is  not  likely immi-
nent, the greatest potential benefits will come pri-
marily from control of sulfur emissions and deposi-
tion.

A significant and  growing body of scientific  re-
search indicates, however, that nitrogen deposition
is a major and important contributor to the acidic
deposition problem.  First, many  areas of the West
are more  affected  by nitrogen deposition than by
sulfur deposition.  Second,  as briefly reviewed in
Section 2.2.1, nitrogen (in the form of nitrate an-
ion)  frequently has been found to be a  significant
contributor to episodic events in streams and lakes
in some parts of the Northeast.50 In these areas, as
50 This does not imply that sulfur deposition is not often
  a key component of episodic acidification, because
  sulfur has often been found to be the primary cause
                                      (continued)
                                                47

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
adverse effects  accompanying chronic acidificat-
ion due to sulfur deposition are reduced, overall
adverse effects due to episodic acidification would
likely continue to impair the water quality in many
of these surface waters, but the extent of these eff-
ects would likely be reduced because reducing the
chronic sulfur effects also decreases potential epi-
sodic effects as well. Third, some watersheds of
the Northeast (e.g., in the Catskill Mountains of
New York)  and  the mid-Appalachians  may be
moving toward  nitrogen  saturation. For these re-
gions,  nitrogen deposition is now or would likely
become a more direct cause of chronically acidic
conditions  in  sensitive  waters,  with  potential
adverse effects caused by acidic sulfur and nitro-
gen deposition becoming approximately equal and
directly additive. In fact, additional limits on nitro-
gen deposition would likely  produce a  two-fold
potential benefit by both reducing acidic deposi-
tion rates and lengthening average times to water-
shed nitrogen saturation. These benefits would ef-
fectively allow a greater  mass of NO3" to be de-
posited over longer periods without significantly
increasing surface water acidification processes.

Scientific  uncertainties  regarding  regional  rates
and differences  in processes  affecting watershed
assimilation of  acid-forming  sulfur and  nitrogen
compounds preclude defining either  national or
regional protection levels below which deposition
of either chemical would produce no adverse im-
pact.  Available  information  does indicate,  how-
ever, that additional deposition reduction through-
out the  range of potential  reductions in  sulfur
and/or nitrogen  depositions down to background
deposition loads would likely reduce regional pro-
portions of chronically acidic surface waters (ANC
<0 ueq/l) or proportions of surface waters potenti-
ally most sensitive to episodic effects  (ANC<50
ueq/l) or proportions  of both groups. The magni-
tude of these  potential benefits to each group of
surface waters varies considerably by region. NBS
projections  indicate  for  some regional surface
water  groupings  that  potential   benefits  may
amount to a few percentage points shift in propor-
tions of acidic or sensitive surface waters benefit-
ing, while for other groupings in other regions po-
tential  benefits from deposition reductions  could
benefit 20 percent or more of the acidic or  sens-
itive waters. Note, however, that even a few per-
centage points may  mean  many lakes or stream
reaches. Now, however,  even a sound qualitative
ranking of these differences  awaits  resolution of
key  scientific  unknowns,  exemplified  by  the
marked uncertainty associated with quantifying re-
gional differences in  their remaining times to wa-
tershed nitrogen saturation.
  of episodic acidification  in areas both  within and
  outside  the  Northeast.   For example, see  A.K.
  O'Brien,  K.C.   Rice,  M.M.  Kennedy,   and  O.P.
  Bricker.  1993.  Comparison of episodic acidification
  of mid-Atlantic  upland and coastal plain streams.
  Water Resources Research 29(91:3029-3039.
                                                 48

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                                          CHAPTER 3

                 SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSITION
                 REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
3.1 INTRODUCTION
Acidic deposition results from a complex series of
interactions among chemical compounds present
in the atmosphere. The two most important groups
of chemicals are sulfur- and nitrogen-containing
compounds. These  chemicals are emitted to the
atmosphere  from  natural  and  anthropogenic
sources, with anthropogenic sources dominating.
Natural sources include vegetative emissions, geo-
thermal activities, forest fires, lightning, soil, and
salt-water organisms. Anthropogenic sources in-
clude  point sources  such  as  utilities, industrial
boilers  and  other  industrial  processes,   mobile
sources including automobiles,  trucks, and  off-
highway vehicles, and area sources such as resi-
dential boilers which  are too small and numerous
to track individually.

Sulfur and nitrogen compounds in the atmosphere
can be transported hundreds to thousands of kilo-
meters by meteorological forces. During transport
sulfur dioxide (SO2) and nitrogen oxides (NOX), the
primary emissions of these species, are oxidized in
the air or in cloud-water to form other, secondary
compounds. The great majority of these com-
pounds, particularly sulfate and nitrate, are acidic.
The oxidizers, such as the hydroxyl radical, hydro-
gen peroxide,  and ozone are produced by reac-
tions of volatile organic compounds (VOC) and
NOX. The sulfur and nitrogen pollutants  are depos-
ited to the earth by either dry or wet deposition.
Dry deposition occurs when particles settle out of
the air onto the earth or when gases or fine parti-
cles directly impact land, plants, or water, or when
plant stomata take up gases, such as SO2. In wet
deposition, pollutants are removed from the at-
mosphere by rain or snow. Fine particles or secon-
dary aerosols formed by these same processes scat-
ter or absorb visible light and thus impair visibility.
When  inhaled these secondary aerosols and their
gaseous precursors can also cause adverse human
health  effects. Potential benefits to visibility,  hu-
man health, materials, and cultural resources from
controlling  acidic  deposition  are  discussed  in
Chapter 4.
The complex relationship between emissions and
deposition depends on a large number of physical,
chemical, and biological processes. To understand
the environmental impact of the CAAA and to de-
velop and analyze strategies to reduce the effects
of acidic deposition,  the  relationship  between
emissions and deposition must be understood not
only for the present, but also for future years. To
predict deposition  a model  must be able to de-
scribe the  transformation  of anthropogenic and
biogenic emissions  by atmospheric processes to
wet and dry deposition. The goal of deposition
modeling is to simulate the source-receptor  rela-
tionships that translate emissions into deposition
values in space and over time. An understanding
of these complex interactions is  necessary to de-
velop a comprehensive approach to achieving the
environmental goals discussed in Chapter 2.

This chapter  addresses the following requirement
of Section  404 (Appendix  B) of  Title  IV of the
CAAA:

  * Description of the state of knowledge with
    respect  to source-receptor  relationships
    necessary to develop a control program on
    such standard  or standards and additional
    research  that  is  on-going  or would be
    needed  to make such a control program
    feasible

Section  3.2 describes state-of-the-art  atmospheric
modeling techniques, the uncertainties associated
with predictive modeling, precursor emissions and
emissions inventories, and deposition species. This
section describes RADM, the atmospheric model
used for this study, and examines its use in model-
ing of acidic deposition  and the results of its
evaluation.

Section  3.3 presents RADM  results that explore
and define source-receptor relationships.  Relation-
ships prior  to implementation of the  1990 CAAA
are compared and contrasted to those expected af-
ter full implementation  of the Act in 2010. The
model discussion is followed in Section  3.4 by  a
description  of the inventories used to evaluate al-
ternative emissions control scenarios.
                                               49

-------
 ACID DEPOSITION FEASIBILITY STUDY
 In Section 3.5, source-receptor relationships from
 RADM are used to assess the environmental  im-
 pact of the CAAA and to predict deposition values
 for acidic sulfur and nitrogen under various alter-
 native emissions scenarios for the year 2010. Emis-
 sions scenarios analyzed include full implementa-
 tion of Title IV with trading, full implementation of
 Title IV without trading, national reductions in util-
 ity and industrial  SO2  emissions beyond Title IV,
 and national reductions in  utility  and industrial
 NOX emissions beyond Title  IV.  Regionally  tar-
 geted  emissions reductions for SO2 are examined
 in Section 3.6.

 3.2  THE REGIONAL ACID DEPOSITION MODEL
 RADM has been developed over the past 10 years
 under the auspices of the National Acid Precipita-
 tion Assessment Program (NAPAP) to address pol-
 icy  and  technical issues associated with acidic
 deposition. The model  is designed to  provide  a
 scientific basis for predicting changes in deposition
 resulting  from changes in precursor emissions, to
 predict the influence of emissions sources in one
 region on acidic  deposition  in  other geographic
 regions, and  to predict the levels of acidic deposi-
 tion in certain sensitive receptor regions.

 A key requirement for the model selected  for NA-
 PAP was  the ability to assess changes in sulfate in
 response  to projected changes in SO2 emissions.
 Based on knowledge gained from models  and ex-
 perimental  measurements,  a  reduction  in  SO2
 emissions is expected to lead to a less than equiva-
 lent  reduction  in  sulfate deposition.  This non-
 equivalency  between  emissions reductions and
decreases in  deposition  is due to the  nonuniform
spatial distribution of emissions reductions and the
complexities  of atmospheric chemistry.  While
simpler models can  predict  the nonequivalency
due  to spatial  nonuniformities, a complex model
such as  RADM is  needed to calculate  the addi-
tional affects of atmospheric chemistry on deposi-
tion.

The  development,  application, and evaluation of
 RADM has been documented extensively  by NA-
     51,52,53 RADM continues  to  undergo periodic
peer    reviews,   evaluations,   and   improve-
ments.54'55-56 Understanding and modeling acidic
deposition requires  consideration  of a complex
range of physical and chemical processes and their
interactions, including:

   * The emissions of  precursor chemicals that
     produce  and  regulate acidity  in  atmos-
     pheric deposition;

   * The meteorological processes that transport
     and mix emitted species in space and time;

   • The physical and  chemical  transformations
     that alter the physical phases and chemical
     properties of emitted  species;

   * The meteorological factors and properties
     of the Earth's surface that  lead  to deposi-
     tion of acidic substances.

RADM is an Eulerian model in  which concentra-
tions of gaseous and particulate species are calcu-
lated  for  specific fixed positions in space (grid
cells) as a function of time. The concentration of a
specific pollutant in a grid cell at a specified time
is determined by: the emissions input rate; the
transport of that species by wind into and  out of
the grid in three dimensions; movement by turbu-
lent motion of the atmosphere; chemical reactions
that either produce or deplete the  chemical; the
change in  concentration due to vertical transport
by  clouds; aqueous  chemical  transformation and
51  Renne, D., et al. December 1989. Models Planned
   for Use in the NAPAP Integrated Assessment. Sec-
   tion 4: Atmospheric Models. National Acid Precipi-
   tation Assessment Program.
52  Chang, J.S.,  P.B.  Middleton, W.R.  Stockwell, C.J.
   Walcek, J.E.  Pleim,  H.H. Lansford,  F.S. Binkowski,
                                      (continued)
   S. Madronich, N.L. Seaman, and D.R. Stauffer. De-
   cember 1990. The Regional Acid Deposition Model
   and Engineering Model. SOS/T Report 4.  In: Acidic
   Deposition: State of Science and Technology. Na-
   tional Acid Precipitation Assessment Program.
53 Dennis,  R.L., W.R.  Barchet, T.L.  Clark, and S.K.
   Seilkop.  September  1990.  Evaluation  of Regional
   Acid Deposition Models (Part I). SOS/T Report 5. In:
   Acidic Deposition: State of Science and Technology.
   National Acid Precipitation Assessment Program.
54 Dennis,  R.L., J.N. McHenry,  W.R. Barchet, F.S.
   Binkowski, and   D.W.  Byun. 1993.  Correcting
   RADM's sulfate underprediction: Discovery and cor-
   rection of model errors and testing the corrections
   through comparisons against field data. Atmospheric
   Environment 27A(6):975-997.
55 McHenry, J.N., and R.L. Dennis. 1994.  The  relative
   importance of oxidation pathways and clouds to at-
   mospheric ambient sulfate production as predicted
   by the Regional Acid Deposition Model. Journal of
   Applied Meteorology 33 (7): 890-905.
56 External Review Panel  report on RADM evaluation
   for the Eulerian Model Evaluation  Field Study Pro-
   gram.
                                                 50

-------
                                              CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                 TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
scavenging; and removal by dry deposition. These
physical and chemical process are depicted in Ex-
hibit 16.
sional data assimilation (4DDA) to produce  the
most accurate recreation of past weather.57 An ag-
gregation technique, described fully by Dennis et
             EXHIBIT 16. PHYSICAL AND CHEMICAL PROCESSES CONTRIBUTING TO ACIDIC DEPOSITION
                    SOURCES
                       NO,
/
/
voc
'.'
1 ' /
1 / '
/
/ Gaseous
Pollutants


Atmosphere
l^__^ §
[*»• Dry Deposition
}
Depo
Ui
\/
Pollutants
Cloud Wat
and
Precipitatu
Wet
sition , ,
M. 1 A M.
\

Particulate
Pollutants.
in
Atmosphere
/ B
o
«7S

O
in o.
er §
Dn §
\
* __-•
. 	
                                           Natural
                RECEPTORS
The version of RADM used for NAPAP and for the
analyses presented in this report covers an area of
2,800 by 3,040 km east of central Texas and south
of James Bay, Canada to the southern tip of Flor-
ida. RADM divides this area into 80 by 80 km grid
cells.  For sulfur deposition modeling the distance
from ground  level to 16 km in  altitude was re-
solved into 6 vertical layers; for nitrogen deposi-
tion 15 layers were used. The RADM domain, pic-
tured in Exhibit 17, consists of 35 by 38 horizontal
grid cells. The model is run with either 7,980 or
19,950 cells depending upon whether 6 or 15 ver-
tical layers are employed. For each grid cell, pre-
dictions are generated at dynamically determined
time-steps of seconds to minutes and are output
hourly by RADM with 41 chemical species being
transported. Hourly wet  and dry deposition values
are also generated for each surface cell for 12 spe-
cies (6 wet and 6 dry).

The meteorological fields used to drive the RADM
are from  the Pennsylvania  State University-Na-
tional Center for Atmospheric Research Mesoscale
Model (MM4). The MM4 is  run  using 4-dimen-
al.,53 developed during NAPAP is used to develop
annual estimates  of  acidic deposition. Meteoro-
logical cases with similar wind flow patterns were
grouped by applying cluster analysis to classify the
wind flow patterns from 1982 to 1985, resulting in
19  sampling groups, or  strata.  Meteorological
cases were randomly selected from each stratum;
the number selected was based on the number of
wind flow patterns in that stratum relative to the
number of patterns in each of  the other strata,  to
approximate proportionate  sampling. A total of 30
cases  were used  in  the current aggregation ap-
proach. Deposition  results for these cases were
weighted according  to  the strata  sampling fre-
quencies to form annual averages.
57 Seaman,  N.L.,  and D.R. Stauffer. 1989. Develop-
   ment of Four-Dimensional Data Assimilation for
   Regional Dynamic Modeling Studies. Final Report to
   the U.S. Environmental Protection Agency, Contract
   CR-814068-01, the Pennsylvania State  University,
   102 pp.
                                               51

-------
 ACID DEPOSITION FEASIBILITY STUDY
                               EXHIBIT 17. THE RADM MODELING DOMAIN
Development and  implementation of  an acidic
deposition control strategy requires an understand-
ing of the interaction among emissions of several
chemical species, the spatial and temporal patterns
of those emissions, and atmospheric transport of
those species to regions where deposition occurs.
It is important, therefore, to understand the uncer-
tainty and reliability of model predictions. The fol-
lowing subsections  briefly  describe the key input
and functional  components upon which RADM
predictions are based. The discussion on emissions
and atmospheric chemistry explains why certain
emissions are important, distinguishes anthropo-
genic  (controllable)  from  natural  (background
sources), and describes why detailed spatially and
temporally  resolved  emissions  inventories  are
needed to accurately  predict deposition. Subsec-
tions 3.2.2 and 3.2.3 describe the development of
source-receptor relationships and how these rela-
tionships can be used to identify emissions sources
responsible for deposition, whether proximate or
hundreds of kilometers distant. The reliability and
                                                52

-------
                                               CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                 TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
confidence of the scientific community in using
modeling results for decision-making is discussed
in subsection 3.2.4.

3.2.1  Emissions and Atmospheric Chemistry
The  principal  acids in deposition  are  sulfuric
(H2SO4) and  nitric (HNO3) acids. Thus, emissions
of compounds containing sulfur and nitrogen have
received primary  emphasis in acidic  deposition
control  strategies.  However, emissions of  VOCs
and their oxidation products are extremely impor-
tant  because they are involved in  reactions that
produce the oxidizing species that lead to forma-
tion of sulfuric and nitric acids in the atmosphere.
Key  environmentally important species predicted
by RADM are:

   *  AMBIENT CONCENTRATIONS: SO2, NO, NO2,
     HN03, 03, H2O2, NH3, PAN, HCHO, CO,
     aerosol SO42'
WET DEPOSITION: SO42-,  NO3-  as  HNO
NH3, H+
                                           3,
  * DRY  DEPOSITION: SO2,  SO42-, HNO3,  O3,
     NO2

The RADM chemistry component consists of 140
reactions among 60 species, 40 of which are or-
ganic compounds. Chemical decomposition by so-
lar  radiation (photolysis) is included in the  model
chemistry as are aqueous-phase reactions  which
occur in clouds. These latter reactions are particu-
larly  important in sulfuric  acid formation.  The
chemically  derived   nonequivalency  between
emissions reduction and  deposition  decreases is
due in part to local depletion  of hydrogen  perox-
ide, a compound produced by atmospheric  photo-
chemical (involving sunlight) reactions that is im-
portant in the oxidation of aqueous-phase SO2 to
sulfate.58 This nonlinear oxidant limitation  affects
only  wet  deposition of  sulfate. Details  of  the
RADM chemistry are described in NAPAP State of
Science and Technology Report 4.52

Inputs to RADM include hourly emissions of SO2,
sulfate,  nitric oxide (NO),  nitrogen dioxide  (NO2),
ammonia  (NH3), carbon monoxide (CO), particu-
58 McHenry, J.N., and R.L.  Dennis. 1994. Cloud and
   chemistry pathway characterization of the nonlinear
   response of sulfur deposition and sulfate air concen-
   trations to changes in SO2 Emissions in the RADM.
   In Atmospheric Chemistry Extended Abstracts. AMS
   Conference  held January  1994,  Nashville,  TN.
   pp. 203-208.
late matter, and 15 classes of VOCs from natural
and anthropogenic sources.  Emissions inventories
used for RADM were derived from the 1985  NA-
PAP Emissions Inventory, the most comprehensive,
highest quality air  emissions inventory  ever as-
sembled. (RADM inputs have since been updated
to include more recent  sector-specific inventories
such as the National Allowance Data Base devel-
oped under the Acid Rain Program for utility emis-
sions.) The basis and key assumptions for the 1985
NAPAP Emissions Inventory are described below.
A detailed  description of this inventory and  the
data processing for use in RADM are described in
NAPAP State of Science  and  Technology  Re-
port 1.59

Natural Emissions Sources
Natural emissions of acidic precursor species, or-
ganic matter, and alkaline materials (dust) are  gen-
erated by vegetative matter,  microbes, geothermal
activity, natural combustion (such  as forest fires),
lightning, and salt-water organisms. These sources,
in contrast to anthropogenic sources, are widely
distributed, small,  sporadic, and subject to large
seasonal  and  weather-related  variations. Total
VOC  emissions from biogenic sources  are  esti-
mated  to be of the same order of magnitude as
VOC  emissions  from  anthropogenic  sources.60
Principal   biogenic  sources  are  trees,  shrubs,
grasses, agricultural crops, decaying leaf litter, and
vegetation in fresh and salt water. Some  biogenic
compounds  are very reactive in the atmosphere;
others are relatively inert. Emissions for individual
grid cells and specific VOCs or VOC classes are
calculated   from  estimates  of   biomass   data
(vegetation type, species, land-use coverage,  and
leaf area index),  adjusted for seasonal variation,
temperature, solar intensity, soil conditions includ-
ing moisture, and elevation.

Natural emissions of  SO2,  sulfates, and  nitrogen
oxide have been found  to be less  important than
anthropogenic sources. Natural emissions of sulfur,
which are not well understood, are estimated to be
about 6 percent of anthropogenic emissions and
                                              59 Placet,  M.,  R.E.  Battye,  and  F.C. Fehsenfeld.  De-
                                                 cember 1990.  Emissions Involved in Acidic Depo-
                                                 sition Processes. SOS/T Report 1.  In: Acidic Deposi-
                                                 tion: State of Science and Technology. Volume  I.
                                                 National Acid Precipitation Assessment Program.
                                              60  Novak, J.H.,  and  T.E.  Pierce.  1993.   Natural
                                                 Emissions of Oxidant Precursors.  In Water, Air, and
                                                 Soil Pollution. Vol.  67, pp. 57-77.
                                                53

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ACID DEPOSITION FEASIBILITY STUDY
are not included in the inventory. Natural emis-
sions of  nitrogen  compounds,  which  are also
poorly characterized, are estimated to be 1 to  2
percent of total nitrogen emissions. The 1985 NA-
PAP  inventory does include nitrogen  emissions
from  soil because these emissions have been stud-
ied, although large uncertainties in estimates still
exist. Lightning-generated  NOX may be  episodi-
cally important, but is not understood well enough
to  be included. Alkaline  dust  emissions  (from
sources such  as erosion and  unpaved roads)  are
also not included in the inventory. The  principal
natural source of ammonia, an important nitrogen-
containing atmospheric reactant, is animal excre-
ment, from feedlots, farm animals, and wildlife;
however,  the  paucity of data on wildlife densities
does  not  allow this source to be estimated with
any degree of reliability.  "Natural" emissions  of
ammonia  are included in the inventory, but the es-
timates  have  a large degree of uncertainty. Am-
monia is considered in RADM simulations because
it is an  important contributor to nitrogen deposi-
tion and affects rainwater pH and the production
of secondary sulfate and nitrate aerosols.

Anthropogenic Emissions Sources
Acidic deposition  precursor species and  reactive
atmospheric  chemicals  are generated by energy
production,  industrial processes, mobile sources,
and waste disposal. Major sources (such as power
plants) that  emit large quantities of pollutants  at
specific, well-defined locations are called "point
sources." Small emissions sources such as residen-
tial  boilers and mobile  sources  are grouped to-
gether as "area sources." In general, emissions from
point sources are reported to EPA by states,  while
EPA calculates emissions from area sources. The
RADM model includes  a species allocation mod-
ule61 which accounts for the small  amount of pri-
mary  sulfate (about 1 percent of SO2 emissions)
that is emitted with SO2. This primary sulfate is
negligible in comparison to sulfate formed in the
atmosphere. Similarly, the allocation module splits
NOX emissions into a 5:95 ratio of NO2 to NO. As
is the case with  biogenic  VOC  emissions,  some
VOC  species are very reactive in the atmosphere,
others are not. The model calculates VOC species
or classes by grid ceil based on  source category.
Major emissions source categories in the United
States and their contribution to total emissions of
each  pollutant in the year 1992 are summarized
below for SO2, NOX, and VOC.62

   * SO2
      • Electric Utility Fuel Combustion (69.7%)
      • Industrial Fuel Combustion (13.6%)
      • Metals Processing (3.8%)
      » Highway Vehicles (3.5%)
      • Other Fuel Combustion (2.6%)
      » All Other Sources (6.8%)

   * NOX
      • Electric Utility Fuel Combustion (32.3%)
      • Highway Vehicles (32.3%)
      » Industrial Fuel Combustion (15.2%)
      • Off-Highway Vehicles (12.3%)
      » Other Fuel Combustion (3.2%)
      » All Other Sources (4.7%)

   » VOC
     » Highway Vehicles (26.8%)
     » Solvent Utilization (26.7%)
     • Waste Disposal and Recycling (10.2%)
     » Off-Highway Vehicles (9.4%)
     » Storage and Transport (8%)
     » All Other Sources (18.9%)

Temporal and Spatial Allocation of Emissions
Data
To create modeling  inventories the annual inven-
tories must be resolved spatially, temporally, and
by chemical species.  Allocation of  emissions to
grid cells for point sources is relatively straightfor-
ward. The geographic (latitude-longitude) location
of each  point source  determines  its  grid  cell
placement.  Since area sources are too small to be
included individually  in  the  annual  inventory,
emissions from these sources are calculated by
multiplying an emissions factor by an activity pa-
rameter which reflects the operating  rate of each
source. The activity  parameter is determined from
surrogates such as population (number of gasoline
service stations), housing (residential fuel combus-
tion),  and agricultural land area (ammonia fertil-
izer  application).  A process was  developed by
61  Walters, R., and M. Saeger. 1990. The NAPAP Emis-
   sions Inventor/: Development of Species Allocation
   Factors.  EPA-600/7-89-01 Of.  U.S.  Environmental
   Protection Agency, Research Triangle Park, NC.
62 Office of Air Quality Planning and Standards. Octo-
   ber 1993. National Air Pollutant Emissions Trends,
   1900-1992. EPA Report  No. 454/R-93-032. U.S.
   Environmental Protection Agency. Research Triangle
   Park, NC.
                                                54

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                                               CHAPTER 3:  SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                  TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
EPA53 to apportion area source emissions to indi-
vidual grid cells from county-level data using these
surrogate  parameters. Exhibit 18 is a density map
of SO2 emissions for the RADM region.

        EXHIBIT 18. MAP OF ANNUAL SULFUR
      EMISSIONS DENSITY IN 1985 (TONS/YEAR)
                            43000 • 160000
                                       >160000
Day- and hour-specific gridded emissions are cre-
ated for each of the 30 RADM aggregation cases.
Temporal allocation  factors were developed for
NAPAP64 that provide day-specific estimates based
on  tabulation  of  representative relative diurnal
emissions patterns by day of the week and by sea-
son for each source. Where emissions strongly re-
spond  to temperature and other meteorological
conditions, the day-specific meteorology is used in
the emissions  estimation procedure.  Examples in-
clude  volatile  organics  that   evaporate  easily,
sources for  which ambient conditions affect per-
formance and  hence  emissions, such as mobile
sources, and sources for which temperature affects
biological processes,  such as biogenic emissions,
Plume rise from major industrial  and utility sources
63 Modica, L, and D.R. Dulleba. April 1990. The 1985
   NAPAP Emissions Inventory: Development of Spatial
   Allocation Factors.  EPA Report No. 600/7-89-01 Ob.
   Air and Energy Research Laboratory, U.S.  Environ-
   mental  Protection Agency,  Research Triangle Park,
   NC.
64 Fratt, D., D.F. Mudgett, and R.A. Walters. 1990. The
   1985 NAPAP Emissions Inventory:  Development of
   Temporal Allocation Factors. EPA Report No. 600/7-
   89-01 Od.  U.S.  Environmental Protection  Agency,
   Research Triangle Park, NC.
is also computed hourly, based on the hourly me-
teorology of each day.

3.2.2  Modeling Source-Receptor Relation-
       ships and Source Attribution
Eulerian, or fixed-grid models, are very suitable for
representing the full, complex nonlinearity of the
photochemistry involved in the oxidation  of pri-
mary emitted species to acidic  substances. The
gas- and aqueous-phase oxidation of sulfur  is non-
linear; the nonlinearity comes from  competition
for  scarce oxidizers, such  as hydrogen peroxide.
The most accurate modeling of source-receptor re-
lationships must maintain the overall  competition
for  oxidants  represented by the concentrations
produced by all the SO2 emissions, while tracking
the particular emissions from the  SO2 sources of
interest.  In  other  words,  the influence  of SO2
sources cannot be studied individually, but must
be  considered altogether. This is because, for  a
nonlinear system, the sum of the deposition from
individual point source emissions  is not expected
to be the same as the total  deposition  from all
point emissions computed simultaneously.

Eulerian models have not historically been used to
study source-receptor  relationships. The  Tagged
Species Engineering Model65 was developed under
NAPAP to study such  relationships.  The Tagged
Species Model gives the Eulerian RADM modeling
system the capability  to  identify, for assessment
purposes,  the concentration and deposition fields
attributable to specified SO2 emissions source re-
gions in the presence of  the full concentration
fields.  The Tagged Model preserves  the  oxidant
competition across space and time. A tagging con-
cept is applied in which additional, identical mass
conservation  equations are solved  for a portion of
the sulfur concentration field that originates from
specific geographical   locations  within  the  full
modeling  domain. This allows tagged concentra-
tion fields and tagged wet and dry deposition to be
identified and tracked in the model separate from,
yet as portions of, the total sulfur chemical envi-
ronment that is nonlinear and that produces the
complete concentration and deposition fields. Ex-
hibit 19 shows  the tagged RADM  regions created
for  the Engineering  Model and their geographical
65 McHenry, J.N.,  F.S.  Binkowski,  R.L. Dennis, J.S.
   Chang, and  D. Hopkins. 1992. The tagged species
   engineering   model  (TSEM).  Atmospheric  Envi-
   ronment 26A(8):1427-1443.
                                                55

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ACID DEPOSITION FEASIBILITY STUDY
                                  EXHIBIT 19. TAGGED RADM SUBREGIONS"
                 a Geographical description of numbered subregions:
                    1    Montreal Area                  28
                    2    NH/MA Border                  29
                    3    NYC/CT                        30
                    4    Southeast NY                   31
                    5    Southern Tier NY                32
                    6    Niagara Area                   33
                    7    Detroit Area                    34
                    8    Central/Southern NJ              35
                    9    Eastern PA                      36
                   10    Southern PA/MD                37
                   11    Central PA                      38
                   12    Northwest PA                   39
                   13    Southwest PA/Northern WV       40
                   14    Cleveland Area                  41
                   15    OH/WV/PA Border               42
                   16    Northewest OH/Eastern IN        43
                   17    Chicago Area                   44
                   18    Eastern VA                      45
                   19    Western VA/Eastern WV          46
                   20    OH/WV/KY Border               47
                   21    KY/WV/VA Border               48
                   22    Cincinnati Area                  49
                   23    Central KY                      50
                   24    Central IL/IN Border             51
                   25    Southwest IN/KY Border          52
                   26    St. Louis Area                   53
                   27    Northeast NC
Northwest NC
Blue Ridge Area
NC/TN/GA Border
Central TN
Central TN/KY Border
Central TN/AL Border
IL/MO/TN Border
Memphis Area
Southeast SC
Central SC/NC Border
Northeast GA
Northeast AL/Northwest GA Border
Western AL
Mobile Area
Baton Rouge Area
Northeast TX
Lake Ontario/NY Shore
Adirondacks
VT/NH
Southeast NC
Southeast GA
Southern AL/GA Border
Northern MS
Norther FL Pennisula
FL Panhandle
Southern MS
                                                     56

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                                              CHAPTER 3:  SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                 TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
description.  The use of the Tagged Model in this
study represents the first  extensive use of a Eule-
rian model to study source-receptor relationships.

3.2.3  Transport, Chemistry, and Source-Re-
       ceptor Relationships
The lifetime in the atmosphere of the sulfur diox-
ide from an emissions source is several days. The
main  loss mechanisms are the  incorporation  of
SO2 and sulfate in clouds and the subsequent wet
deposition  and dry deposition  of these  species.
Thus, SO2  is transported  over many hundreds  of
kilometers before concentrations from a source are
substantially reduced by  wet and dry deposition.
As a result, the deposition at any one receptor area
is  coming from a very large number of  sources,
spread over a  large geographic  area. Source re-
sponsibility cannot be determined, therefore, from
monitoring data. Too much is mixed together. Al-
though rough estimates of source-type responsibil-
ity can be developed with source apportionment
techniques using unique chemical  "fingerprints,"
all assessments of source responsibility or source
attribution require the use of an air quality model.

Calculations from the Tagged Species Model illus-
trate the distances  over which SO2  emissions
sources can have an influence. A map of the com-
puted proportion  of total  annual  sulfur deposition
contributed by the Ohio/West Virginia/Pennsylva-
nia source subregion (RADM Subregion 15) along
the upper  Ohio  River Valley  is  shown  in Ex-
hibit 20.  Exhibit 21 shows the distance covered to
deposit increasing fractions of the total deposition
in the eastern United States. The subregion's range
of  influence is more than  1,000 km. Typically, the
range of influence of a sub-region extends out  to
between  500 and  1,200 km. The Tagged Species
Model  analyses indicate  that about two-thirds  of
the total  sulfur  deposition  from  major  sources
along the Ohio River Valley occurs within 500 to
700 km.  For the southern source regions, the dis-
tance to deposit about two-thirds of a source's spa-
tially integrated deposition is somewhat less, about
300 to 500 km. The difference in  scale of influ-
ence is primarily due to meteorology.

A number of meteorological factors influence the
existence of dominant transport directions and de-
termine how a group of SO2 emissions sources in-
fluence nearby regions.  Key factors are the posi-
tion of the jet stream, which moves storms across
the upper Mid-West; the influence of the Appala-
       EXHIBIT 20. PROPORTION OF ANNUAL
    SULFUR DEPOSITION CONTRIBUTED BY RADM
   SUBREGION 15 (OHAW/PA BORDER REGION)
                               \
                                •4,.
    EXHIBIT 21. PERCENTAGE CUMULATIVE RANGE
      OF INFLUENCE OF RADM SUBREGION 15
          (OH/WV/PA BORDER REGION)
chian Mountains on winds and  rainfall patterns;
the Bermuda  highs  (stagnation) that  move Ohio
River Valley  emissions in a clockwise direction;
and  the  ocean  and  Gulf Coast  weather  that
produces lighter winds and more convective  con-
ditions, including a typically large proportion of
                                               57

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ACID DEPOSITION FEASIBILITY STUDY
convective clouds across the southern states. As a
result, source-receptor relationships are skewed to
the  northeast  (Exhibit 22a)  starting  in northern
West Virginia and show a predominantly northerly
to  easterly quadrant  of flow  along  the  lower
Ohio River  Valley (Exhibit 22b),  yet are  nearly
symmetrical  in the Southeast (Exhibit 22c). Thus,
the patterns  and ranges of source influence can
vary. Models, such as those in the RADM system,
help to interpret and explain the deposition at re-
ceptors of interest.

An alternative  approach to determining efficient
and cost-effective strategies to achieve deposition
targets relies on the use of optimization models.66
An optimization model for acidic deposition could
simultaneously minimize SO2 removal cost and
average exceedance of target deposition rates over
the receptor model domain.67 Such a  model could
calculate costs and emissions reductions necessary
to achieve a  regionally averaged target load com-
parable to the average annual  deposition  level
calculated by RADM. This model was investigated
for this report but not used because of the compu-


          EXHIBIT 22A. SOURCE-RECEPTOR
        RELATIONSHIPS IN THE NORTHEAST:
      CUMULATIVE PERCENT SULFUR DEPOSITION
66 Streets, D.G., D.A. Hanson,, and L.D. Carter. 1984.
   Targeted strategies for control of acidic deposition.
   Journal of the Air  Pollution  Control  Association
   34(12):1187-1197.
67 Ellis,  J.H. 1988. Multiobjective mathematical pro-
   gramming models for acid  rain control. European
   Journal of Operational Research 35(3):365-377.
          EXHIBIT 22s. SOURCE-RECEPTOR
     RELATIONSHIPS IN THE LOWER OHIO VALLEY:
     CUMULATIVE PERCENT SULFUR DEPOSITION
 EXHIBIT 22c. SOURCE-RECEPTOR RELATIONSHIPS IN THE
SOUTHEAST: CUMULATIVE PERCENT SULFUR DEPOSITION
tational difficulty  in  combining  the  nonlinear
RADM   transfer  coefficients  into   a   linear
programming optimization  model.  Although an
optimization  model  could have been  employed
using linear transfer  coefficients, at  the time this
report  was  being  developed, no  linear  transfer
coefficients that  approximated the  RADM transfer
coefficients were available.  Optimization models
are,  however, used  extensively when  important
                                                58

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                                               CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                  TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
critical or target load decisions have already been
made (e.g., in  European countries). Development
of  linear  transfer  coefficients   consistent  with
RADM are beyond the scope of this study.

3.2.4  Confidence in Results
The United States and Canada have been cooper-
ating  in  a bi-national Eulerian Model Evaluation
Field  Study (EMEFS) and model evaluation  since
1985.53 U.S. data collection for EMEFS was con-
ducted under the auspices of NAPAP.  Phase 1 of
the evaluation of the two advanced  acidic deposi-
tion models ADOM (Acid Deposition  and Oxi-
dants Model) and RADM (Regional Acid Deposi-
tion Model) has been completed and described.68
Phase 1 was primarily based on 1988 EMEFS data.
Improvements to RADM resulted and uncertainty
analyses regarding the scientific assumptions in the
model were prepared that went beyond the earlier
NAPAP results  (outlined  in reference 3). Phase 2,
the final phase of the evaluation, has been  com-
pleted and  is based on the 1990 EMEFS data as
well as  data of  high diagnostic value from the
1988 period. A cooperative effort in  the evaluation
of the advanced  models will continue  under the
U.S.-Canada Air Quality Agreement.

At the end of Phase 1 and Phase 2,  the evaluation
results were subjected to extensive external peer
review.   The review focused  on how well the
evaluation had followed the preset protocol, the
resulting credibility of the models, and the appro-
priateness of model applications.  The review panel
members determined they would have confidence
in the ability of the models to represent (1) total
sulfur loading of the atmosphere, suggesting that
the emissions inventory  and  average  lifetimes of
sulfur species are roughly correct; (2) annual sulfur
deposition, although there is some  seasonal bias,
with deposition being underestimated  in summer
and overestimated in winter; and (3) total nitrogen
loading of the atmosphere, suggesting that the  ni-
trogen budget  and average  lifetime  of nitrogen
species is roughly correct.

From  the  Phase  1  review, the  external  review
panel felt that the models could be used for esti-
mating annual  deposition of sulfur  and nitrogen.
68 Pacific Northwest Laboratories. 1991. The Eulerian
   Model Evaluation Field Study. Interim report PNL-
   7914. Prepared for the U.S. Environmental Protec-
   tion  Agency,  Research  Triangle  Park,  NC.  IAG
   DW89933040-01, 81  pp.
The reviewers concluded that, while both models
were  adequate for  the study of large-scale  and
long-distance  source-receptor  relationships,  the
models are so complex that their application to the
problem of source-receptor relationships might be
more  limited. A valuable application would be for
the complex models to serve as a check on the ac-
curacy of the simpler, but much faster, Lagrangian
methods or on the  source-receptor matrices  pro-
duced by the Lagrangian methods. Regarding non-
linearities  in  the sulfur deposition,  the  reviewers
agreed that they may be of the order of 10 percent
to 15  percent. However, they noted there is no ob-
servational means of fully testing the validity of the
model estimates of the relatively modest nonlinear
effects. The panel concluded that a great deal had
been  accomplished  and significant  improvements
had been  made in the models during the  evalu-
ation  process. The protocol and evaluation have
been  essential in winning scientific support for the
models, and the models have shown evidence of
converging towards  operational use. This process,
however, is more advanced for sulfur than for ap-
plications involving nitrogen.69

As part of the model evaluation process,  bounding
studies were performed to assess the risk that the
predicted changes in air concentrations and depo-
sition  would  be sensitive to uncertainties  in the
scientific descriptions  in RADM.   The  bounded
range of RADM predictions  is roughly 10 percent
around the best estimate of  deposition change.
There is greater confidence in the  upper bound,
but less in the lower bound  because it is affected
by our lack of complete understanding of the non-
linear processing  affecting  sulfur deposition.  The
narrow range would suggest that there is little risk
that the model will misguide users regarding the
predicted  change  in  sulfur deposition,  despite
shortcomings uncovered in the model evaluation.
This appraisal of the  bounding results may change
if significant new insight or knowledge develops in
the future.

3.3  SOURCE ATTRIBUTION
3.3.1   Changes from 1985 to 2010
Fifty-three tagged regions were identified  in Ex-
hibit 19 for  which  the major  point source  SO2
emissions  (utility  and  major industry) have been
69 U.S. Environmental Protection Agency. 1994. Pro-
   gress  Report  for  the  U.S.-Canada  Air  Quality
   Agreement.
                                                59

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 ACID DEPOSITION FEASIBILITY STUDY
 explicitly tracked, using the RADM Tagged Spe-
 cies Engineering Model. These regions account for
 84 percent of the major point source emissions in
 the United States during 1985  and 76 percent in
 2010. Exhibit 23 shows the percentage contribu-
 tions of the 53  tagged regions to U.S. major point
 SO2 emissions  in the RADM domain, to total U.S.
 SO2 emissions  in the RADM domain, and to all
the top 10 in 1985 are still in the top 10 in 2010.
But, the top  10 emitters are responsible for  a
smaller fraction of the deposition in the sensitive
regions in 2010 than they were in 1985. The frac-
tion of the total deposition attributable to the top
10 emitters goes down by 32 percent,  24 percent,
and 52 percent for the Adirondacks, the mid-Ap-
palachians, and the Southern Blue Ridge, respec-
             EXHIBIT 23. PERCENT CONTRIBUTION TO SULFUR EMISSIONS OF 53 TAGGED RADM REGIONS
Year
1985
2010
Year
1985
2010
RADM SO2 Emissions Data
53 Regions: Percent of
U.S. Major Point Sources
83.6%
75.7%
53-Region Total
Tagged Emissions
15,420,000 tons
9,265,000 tons
53 Regions: Percent
of Total U.S. Sources
74.8%
63.6%
Total Major U.S.
Point Emissions
1 8,452,000 tons
12,245,000 tons
53 Regions: Percent of Total
North American Sources
66.6%
54.3%
Total Emissions from
All U.S. Sources
20,323,000 tons
14,557,000 tons
 North American SO2 emissions in the Northeast,
 respectively. Thus, although the 53 tagged regions
 accounted for three-quarters of the 1985 total SO2
 emissions, by 2010, after implementation of the
 1990  CAAA,  they  will  account  for  about
 60 percent of the U.S. emissions  of SO2 from  all
 sources.

 The  listing of emissions  by tagged-source region
 shows that emissions per unit area are being lev-
 eled out by Title  IV. This is shown in Exhibits 24
 and 25.  Exhibit 24 quantifies this by comparing the
 percent  reduction between 1985  and 2010 as a
 function of the 1985 SO2  emissions contributed by
 each of the 53 regions. The top 8  emitting regions
 in 1985 will have the largest percent reductions by
 2010, around 50 to 60 percent. A major fraction of
 the regions, those with emissions between 100,000
 and 450,000  tons/year, have their SO2 emissions
 reduced  between 10 and  50 percent,  forming a
 second tier of reductions. Emissions from most of
 the smallest emitting regions (<100,000 tons/year)
 actually  increase (negative percent  change)  be-
tween 1985  and 2010, thereby increasing in  im-
 portance  in  analyses regarding additional emis-
 sions reductions beyond the CAAA. The result is a
 modest leveling out of responsibility for the emis-
 sions, as shown in Exhibit 25.

 Exhibit 26 shows  the  percentage  contributions of
the top  10 emitting regions of 1985 and 2010 to
deposition in the three sensitive  regions. Eight of
lively. The change is largest for the Southern Blue
Ridge, resulting in the top 10 emitting regions be-
ing responsible for only 16 percent of  the sulfur
deposition in 2010.

     EXHIBIT 24. PERCENT REDUCTION IN TAGGED
    REGIONS FROM 1985 TO 2010 AS A FUNCTION
        OF RELATIVE CONTRIBUTION OF EACH
        REGION TO ALL TAGGED EMISSIONS

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           Percent Reduction from 1985 to 2010
                 .• 53 Emissions Regions
3.3.2  Regional Emissions Distribution in
       2010
With greater emissions reductions coming from the
heavier-polluting regions, the relative importance of
                                               60

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                                               CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                  TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
            EXHIBIT 25. PERCENTAGE OF TAGGED EMISSIONS BY TAGGED REGIONS FOR 1985 AND 2010
    10.0
     0.0
                            13  15  17  19  21  23  25  27  29  31  33  35  37  39 41  43  45  47  49 51  53

                                          Region in Rank Order
                                              201°
    ! 985
                          EXHIBIT 26. CONTRIBUTION OF TOP-! 0 SO2 EMITTING
                          REGIONS TO SULFUR DEPOSITION IN SENSITIVE REGIONS
Year
1985
2010
Top-1 0 SO2 Emitting Regions3
1 5,26,39,1 3,22,20,25,32,7,24
1 5,1 3,22,20,51 ,26,25,39,7,1 7
Adirondacks
30.2%
20.6%
Mid-
Appalachians
49.4%
37.3%
Southern
Blue Ridge
30.8%
16.1%
         a See Exhibit 19 for geographical descriptions of RADM subregions.
long-range transport is expected to decrease in
2010 compared to  1985.  The  character of the
source contributions in 2010 is  important to any
analyses of further  emissions control  to reduce
deposition. Two aspects stand out: first, in the mid-
Appalachians and Southern Blue Ridge significant
contributions  to  sulfur deposition  come  from
sources near the sensitive aquatic regions; second,
the  local  versus  long-range character  of  the
sources of deposition changes when moving south
from the Adirondacks to the mid-Appalachians and
the Southern Blue Ridge. The importance of the
top emitting regions decreases as one moves north
or south away from the mid-Appalachians. This re-
sults from a combination of meteorology (transport
directions), proximity to  large emissions sources,
and the pattern of emissions in 2010.

Exhibit 27 shows that, as one moves from the Adi-
rondacks to the mid-Appalachians  and Southern
Blue Ridge, emissions sources near sensitive areas
are responsible for  a  greater percentage of deposi-
tion  relative to the contributions from the top 10
emissions regions.  This can be seen by noting the
contribution to deposition from source regions as
one moves from row  A to row D. For the Adirond-
acks, the 10 regions contributing the most to depo-
sition are responsible for about 3.5 times more
deposition than do nearby sources (row D versus
                                               61

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 ACID DEPOSITION FEASIBILITY STUDY
                       EXHIBIT 27. COMPARISON OF PROXIMATE AND MAJOR EMITTING
                       REGIONS TO SULFUR DEPOSITION IN SENSITIVE AREAS IN 2010
Geographic Source of Deposition
A. Sources local to sensitive region
B. Sources local and contiguous to sensitive
regions
C. Sources from top-1 0 deposition contributing
regions (utilities only)
D. Sources from top-1 0 deposition contributing
regions (utilities plus industry)
Adirondacks
3.7%
7.8%
20.0%
28.0%
Mid-
Appalachians
24.0%
28.0%
37.0%
46.0%
Southern
Blue Ridge
12.0%
26.0%
34.0%
41.0%
 row B). In the mid-Appalachians and the Southern
 Blue  Ridge the top  emitting regions contribute
 only 60 percent more deposition than do nearby
 regions. In these two  receptor regions several of
 the regions contributing large amounts of deposi-
 tion are either local or contiguous to the receptor
 regions. The  importance of the contribution from
 the top emitting regions (primarily located along
 the Ohio  River Valley) to the deposition  in the
 sensitive regions, and hence, the importance of
 long-range transport, decreases as one moves from
 north to south. This source attribution  insight  is
 used in Section 3.6 to analyze a regionally tar-
 geted emissions reduction  approach to  achieving
 deposition reductions of sulfur.

 3.4  EMISSIONS REDUCTIONS SCENARIOS
 This section describes emissions scenarios created
 to evaluate the impact of Title IV on sensitive re-
 gions and the environmental impact of additional
 emissions  reductions beyond those mandated by
 Title IV. This analysis concentrates on emissions of
 SO2 and deposition of sulfur because Title IV fo-
 cuses on SO2 emissions and because emissions in-
ventories  and  source-receptor relationships  are
 better characterized for sulfur than for nitrogen,
the other key pollutant  contributing to  acidic
deposition. A scoping analysis of nitrogen  deposi-
tion  is included.  The  scenarios  are used in  this
chapter to compare deposition levels in sensitive
 regions. Cost and economic impacts of sulfur re-
ductions scenarios are presented in Chapter 5, Im-
plementation.

Two sets of scenarios for SO2 emissions in 2010
 (the year Title IV will  be fully  implemented) were
developed. The first was created to evaluate the
environmental impacts (i.e., changes in deposition)
resulting from the trading of SO2 emissions allow-
ances. The second represents additional SO2 emis-
sions reductions beyond those mandated by Title
IV. The environmental  impacts of these scenarios
are compared to the pre-CAAA case (1980). One
scenario was developed  to  compare  NOX  re-
ductions with 1990 baseline emissions levels. Base
years for SO2 and NOX emissions were selected
based on the availability of data at the time of this
analysis.

Emissions for each scenario were projected  from
existing EPA emissions inventories.  The National
Allowance Data Base (NADB) was used as the ba-
sis for electric utility SO2 emissions  estimates and
projections.  EPA developed the NADB to allocate
and  track SO2 allowances issued under Title  IV.
The  NADB was prepared  by  updating the utility
emissions data base (the 1985 National  Unit Ref-
erence File or NURF) included in the 1985 NAPAP
Emissions Inventory. The basis for non-utility SO2
emissions estimates is the 1985 NAPAP Emissions
Inventory  for Canadian and U.S. emissions. The
basis for NOX emissions estimates for utilities and
industrial sources is EPA's  1990 Interim Emissions
Inventory.70 As with the NADB, the 1990  Interim
Inventory  was developed  by  updating the 1985
NAPAP Emissions Inventory. The 1985  inventory
was  updated for 1990 using industry growth rates,
EPA's Mobile 4.1 model for mobile sources, and
by adding electric utility units that became opera-
tional  between  1985 and 1990. The 1980 SO2
emissions inventory used to calculate  1980 sulfur
70 U.S. Environmental  Protection Agency. June 1992.
   Regional Oxidant Modeling—Emissions  Inventory
   Development and Emission Control Scenarios.
   U.S. Environmental  Protection Agency, May 1989.
   Regional Ozone Modeling  for Northeast  Trans-
   port—Development of Base  Year Anthropogenic
   Emissions Inventory.
                                               62

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                                              CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                 TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
deposition  was developed for EPA's retrospective
cost/benefit analysis of the CAA conducted pursu-
ant to section 812 of the 1990 Amendments. This
inventory was constructed by backcasting emis-
sions from the 1985 NAPAP emissions inventory.

The base year for evaluating the environmental
impacts of the CAAA and the benefits of additional
SO2  emissions reductions  beyond  the  CAAA  is
2010. Utility emissions for 2010  were forecasted
in EPA's 1993 Base Case Analysis,71 which was
developed  to support rulemaking under Title IV.
Existing and planned electric utility boilers identi-
fied in NADB Version 3.11 plus generic plants re-
quired to meet growth in electricity demand were
used as  a  basis for the SO2  forecasts. For EPA's
1993 Base  Case Analysis, electric utility SO2 emis-
sions were projected  from the
NADB   inventory  using  ICF's
Coal and Electric Utilities Model
(CEUM). EPA's analysis assumed
full      implementation     of
allowance  trading (i.e.,  electric
utilities    would   engage   in
allowance  trading in  order to
minimize  the overall  cost  of
reducing SO2  emissions by  10
million tons below 1980 levels).

Projections of 2010  non-utility
SO2 emissions from the 1990 In-
terim Inventory were based on a
straightforward approach devel-
oped by EPA.72 First,  emissions
from the 1990 Interim Inventory
were grown according to the Bu-
reau  of  Economic Affairs (BEA)
industrial earnings growth factor
(i.e.,  by 2-digit  SIC  code  and
state). Next, the grown emissions
were adjusted  to reflect the  re-
tirement of existing sources, new
emissions (assumed to be subject
to   New  Source  Performance
Standards  [NSPS])  to  replace
those lost due to retirement, and
              the application of additional  controls required by
              the CAAA. In total non-utility SO2  emissions did
              not change significantly between 1990 and 2010.

              Projected nationwide total  annual emissions of
              SO2 with and without implementation of Title IV
              are shown in Exhibit 28. The projections are based
              on CEUM predictions of utility emissions with and
              without  Title IV  and predictions  of non-utility
              emissions calculated as  described in the previous
              paragraph. Annual SO2  emissions  decreased by
              about 14 percent between 1980 and 1990. With-
              out Title IV annual emissions would slowly begin
              to increase after 1990 and almost reach 1980 lev-
              els by 2010. Under Title IV SO2 emissions will de-
              crease dramatically after 1990, achieving a 10 mil-
              lion ton reduction from 1980 levels by 2010.
          EXHIBIT 28. ESTIMATED U.S. SO2 EMISSIONS
       WITH AND WITHOUT TITLE IV FROM 1980 TO 2015
   20
s
    18
    16
    14
     1980
2010   2015
71  ICF Resources,  Inc.    February  1994.  Economic
   Analysis of the Title IV Requirements of the 1990
   Clean   Air   Act  Amendments.   Prepared   for
   U.S. Environmental Protection Agency, Office of Air
   and Radiation, Acid Rain Division.
72  U.S. Environmental Protection Agency, May 1993.
   Regional  Interim  Emissions Inventories  (1987-
   1991). Volume I: Development of Methodologies.
              Under Title IV utilities are allowed to defer the use
              of allowances  to future years,  i.e.  bank  allow-
              ances. The Nitrogen Bounding Study, discussed in
              Chapter 2, calculates the aquatic impact of deposi-
              tion  in the year 2040 based on  deposition values
              between 2010  and 2040. EPA has projected SO2
              emissions only  through 2010 because the assump-
                                               63

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ACID DEPOSITION FEASIBILITY STUDY
tions  underlying  the  CEUM are assumed to be
valid only through that year. Exhibit 29 shows na-
tional utility SO2 emissions predicted by CEUM for
the years 1990-2010.  The model predicts that sev-
eral million allowances will be banked in the early
years of the allowance trading program (resulting
in early emissions reductions) for use between the
years 2000 and  2010,  with  almost  1  million
banked allowances used in 2010. Thus, SO2 emis-
sions  in the year  2010 will be almost 1  million
tons higher than in subsequent years. A no-bank-
ing (post 2010 full implementation) scenario was
created for purposes of this analysis to represent
typical emissions for the years 2010 through 2040,
and thus to better reflect deposition modeled in
the Nitrogen Bounding Study.

The emissions inventories for the alternative  sce-
narios  for SO2 in 2010  were developed  for the
RADM  domain (eastern  United States,  see Ex-
hibit 17) as  follows and  are summarized in Ex-
hibit 30:

  * 2010 SCENARIO:  This scenario  represents
     utility  SO2 emissions in 2010 forecast  by
    the CEUM in the 1993  Base Case Analysis
    described  above. Utility emissions in this
    scenario total 9.5 million tons  in 2010. The
    following  two scenarios  were  calculated
    from this inventory.

  * PosT-2010 FULL IMPLEMENTATION SCENARIO:
    Utility SO2 emissions from the 2010 sce-
    nario were reduced to allowance levels in
    2010 (the  8.95 million  ton cap mandated
    by Title IV) by removing emissions banked
    from previous years  (see  Exhibit 29). This
    scenario was developed  to represent full
    implementation of Title  IV after 2010. Util-
    ity emissions in years beyond  2010 should
    remain  near  this level.  Non-utility emis-
    sions were unchanged from the 2010 sce-
    nario.

  * 2010 NO-TRADING SCENARIO: Existing  units
    operating in 2010 were  forecast  to  emit
    SO2 at their  allowance  levels. Allowances
    issued  to  units retiring  before 2010 (0.14
    million) were assigned  to  new units. This
    scenario also assumes (based on the EPA
    2010 Base Case Forecast Without Title IV)
    that oil  and gas-fired  units, which were al-
    located allowances, would have emissions
    that are 0.3 million tons less than  their al-
    lowance allocations.  Of the total of  0.44
    million  tons of allowances, 0.19 million
tons were assumed to be allocated to new
units, leaving 0.25  million tons unused.
Thus total nationwide utility SO2 emissions
in this scenario are 8.95 million tons less
the 0.25 unused allowances or 8.7 million
tons.  Non-utility   emissions  were  un-
changed from the 2010 scenario.

ADDITIONAL    UTILITY   SO2   REDUCTION
SCENARIO (UTILITY SO2 EMISSIONS REDUCED BY
50  PERCENT  FROM THE  POST-2010 FULL IM-
PLEMENTATION SCENARIO): Total electric util-
ity   SO2  emissions  were  reduced  by
50 percent from the Post 2010 Full  Imple-
mentation Scenario. To allocate this reduc-
tion units included in the baseline scenario
able to achieve significant reductions in
SO2 emissions (i.e.,  those  with  emissions
rates forecast to be greater than 0.8 pounds
of SO2 per million British thermal  unit
[Ibs/MMBtu]) were identified.  From this
group, the set of boilers able to most cost-
effectively reduce SO2 were selected based
on  Cadmus' Generic  Retrofit  Scrubbing
Cost Model. The 50 percent utility  reduc-
tion was then  pro-rated by state. Baseline
emissions for the set of  boilers  with SO2
emissions rates greater than 0.8 Ibs/MMBtu
were reduced in proportion to the pro-rated
state reduction.

ADDITIONAL  INDUSTRIAL  SO2  REDUCTION
SCENARIO   (INDUSTRIAL   SO2    EMISSIONS
REDUCED BY 50 PERCENT FROM THE POST-2010
FULL IMPLEMENTATION SCENARIO): SO2 emis-
sions in the RADM domain for  the 2010
projection described above  were  estimated
to total  about 4 million tons. A  2  million
ton  reduction was achieved from industrial
boilers  and  major   process   industries
(categories  projected  to  emit more than
10,000 tons in 2010). As described in more
detail  in Chapter  5,   cost-effectiveness
measures (annual  cost  per  ton of SO2 re-
moved)  were calculated for each sector to
allocate the 2 million ton reduction. Based
on  this  analysis,  industrial  boilers ac-
counted  for  63 percent  and   industrial
sources  37 percent  of the emissions re-
moved.

ADDITIONAL  UTILITY AND INDUSTRIAL  SO2
REDUCTION  SCENARIO  (UTILITY   AND  IN-
DUSTRIAL  SO2   EMISSIONS   REDUCED  BY
50 PERCENT FROM THE POST-2010 FULL IMPLE-
                                               64

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                                      CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                         TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
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 ACID DEPOSITION FEASIBILITY STUDY
                EXHIBIT 30. SO2 EMISSIONS IN THE U.S.
              RADM DOMAIN (EASTERN UNITED STATES)
Scenario
1980
1985NAPAP
2010
Post-2010 full implementation scenario
No Trading
Additional utility SO2 reduction
Additional utility and industrial SO2 reduction
SO2 Emissions
(million tons)
24.8
20.3
14.6
14.0
13.7
9.7
7.8
     MENTATION SCENARIO): Combination of the
     two  previous scenarios. As shown in Sec-
     tion  3.2.1, utility and industrial sources ac-
     count for 87 percent of total nationwide
     SO2  emissions. Thus, a 50 percent reduc-
     tion  in utility and industrial SO2 emissions
     represents a 43.5 percent reduction in total
     SO2  emissions.

   * ADDITIONAL  UTILITY AND INDUSTRIAL  NOX
     REDUCTION  SCENARIO  (UTILITY   AND   IN-
     DUSTRIAL NOX  EMISSIONS REDUCED BY  50
     PERCENT FROM THE  1990 INTERIM EMISSIONS
     INVENTORY):  1990 emissions from each unit
     were reduced by half. As shown in Section
     3.2.1, utility and industrial sources account
     for 47.5 percent of total  nationwide  NOX
     emissions. Thus, a  50 percent reduction in
     utility   and  industrial   NOX  emissions
     represents only a  24 percent  reduction  in
     total  NOX emissions.

3.5  DEPOSITION REDUCTIONS UNDER VARIOUS
     NATIONAL EMISSIONS REDUCTIONS
     SCENARIOS
Total sulfur or nitrogen  deposition  to each 80 by
80 km grid cell in the RADM region was calcu-
lated for each scenario in Exhibit 30.  Sulfur depo-
sition in the units of kilograms of sulfur per hectare
per year (kg-S/ha/yr) is the sum of wet and dry sul-
fate;  nitrogen deposition (in units  of kg-N/ha/yr)
consists of wet and dry  nitrate and wet and dry
ammonia.  This  section is divided into three parts:
sulfur deposition reductions under Title IV and an
analysis of trading;  additional sulfur  deposition
emissions  beyond Title IV; and nitrogen  deposition
reductions.
               3.5.1  Impact of SO2 Allow-
                      ance Trading on Sulfur
                      Deposition
               Exhibit 31 is  a map of the spatial
               distribution of total  sulfur deposi-
               tion in the RADM region for the
               pre-CAAA  year  of  1980.  The
               highest  sulfur deposition  levels,
               more than 20 kg-S/ha/yr, were in
               the industrial  area encompassing
               parts  of  West Virginia, Pennsyl-
               vania, Ohio,  Kentucky,  and  Indi-
               ana and in the mid-Appalachians.
               Deposition   levels  were  about
 20 percent lower  in the Southern  Blue Ridge and
 Pocono Mountains and about 40 percent lower in
 the Adirondacks. Thus, the highest deposition lev-
 els are in or just downwind of the  highest emitting
 areas.

       EXHIBIT 31. ANNUAL AVERAGE RADM
     TOTAL SULFUR DEPOSITION (KG-S/HA): 1980
Exhibit 32 is the same map projected for the post
2010 full implementation scenario. The spatial dis-
tribution of emissions in 2010 is similar to that of
1980. In 2010 deposition  levels in  the Southern
Blue Ridge are  projected to be about 15 percent
lower  and  those  in  the  Adirondacks  about
40 percent lower than in  the industrial mid-West
and mid-Appalachians. Similar spatial distributions
are also found for the 2010  and 2010 no-trading
scenarios. Exhibit 33 is a map of percentage reduc-
tions in sulfur deposition from  1980 to the  post
2010 full implementation scenario. This map again
demonstrates that the largest deposition reductions
                                               66

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                                           CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                              TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
EXHIBIT 32. ANNUAL AVERAGE RADM-PREDICTED
  TOTAL SULFUR DEPOSITION (KG-S/HA): POST-
      201 0 FULL CAAA IMPLEMENTATION
EXHIBIT 33. PERCENTAGE REDUCTIONS IN SULFUR
   DEPOSITION FROM CAAA IMPLEMENTATION
  EXHIBIT 34. IMPACT OF TRADING ON SULFUR DEPOSITION IN SENSITIVE REGIONS
Emissions Scenario
1980
1985 NAPAP
201 0 (with trading)
Post-2010 full implementation
201 0 (without trading)
Annual Average Deposition Level (kg-S/ha)
Adirondacks
11.0
9.8
7.1
6.9
6.8
Mid-
Appalachians
19.0
17.0
12.0
11.0
11.0
Southern
Blue Ridge
14.0
13.0
9.9
9.7
9.2
tions, over 40 percent,  are in the highest emitting
regions.

Exhibit 34 compares annual average sulfur deposi-
tion  for the 2010  (with trading), no-trading, and
post 2010 full  implementation scenarios for the
three sensitive regions analyzed for this report. The
1980 and 1985 deposition values are included for
reference. The most consistent comparison  to as-
sess  the  impact of allowance trading is between
the post 2010 full  implementation and no-trading
scenarios. For the  post 2010 full implementation
scenario  sulfur deposition in the Adirondacks and
mid-Appalachians  is  reduced about 40 percent
from 1980 and reduced about 30 percent in the
Southern Blue Ridge.  The deposition values and
percent reductions  are essentially the same for the
no-trading case in  the  Adirondacks  and the mid-
Appalachians. The lower total RADM-wide SO2
emissions for the  no-trading case  shown  in Ex-
hibit 30 most likely accounts for the 0.1 kg-S/ha
difference in deposition in the Adirondacks.  In the
Southern Blue Ridge the deposition (9.2 kg-S/ha) is
lower and the  percent reduction (34 percent) is
higher for the no-trading case.

A more detailed spatial view of the  differences in
sulfur deposition between  the post 2010 full  im-
plementation and no-trading scenarios for 2010 is
given in the map in Exhibit 35. The areas shaded
diagonally and in solid black depict areas where
projected  regional deposition would be  higher
with trading. The areas shaded with a plaid pattern
are those where projected deposition  would be
lower with trading. The largest increases associ-
ated with trading,  somewhat more  than 1.2  kg-
S/ha or about 10 percent of total deposition, are
near the Southern Blue  Ridge and in  northern Ala-
bama. Most of the increases are 0.2-0.8 kg-S/ha,
less than  10 percent of  the total sulfur deposition.
Note that the allowance trading program cannot
result  in  exceedance  of  a  National  Ambient
                        Air Quality    Standard
                        (NAAQS), and thereby
                        will not create or  inten-
                        sify local  air quality or
                        public health problems,
                        because  sources  must
                        always comply with the
                        requirements  of   the
                        NAAQS as well as the
                                            67

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 ACID DEPOSITION FEASIBILITY STUDY
           EXHIBIT 35. DIFFERENCE IN ANNUAL AVERAGE RADM TOTAL SULFUR DEPOSITION (KG-S/HA)
               IN 2010 BETWEEN POST 2010 FULL IMPLEMENTATION AND NO TRADING SCENARIOS
                                                                      -0.80 TO -1.16

                                                                      -0.50 TO -0.80

                                                                      -0.20 TO -0.50

                                                                      -0.20 TO 0.20

                                                                      0.20 TO  0.50

                                                                      0.50 TO  0.90

                                                                      0.90 TO  1.53
Prevention of Significant Deterioration  Program
(e.g.,  in  National Parks and  Wilderness Areas).
There are a few small regions where deposition is
projected to decrease due to trading. These are in
southern   New England,  southern  Florida,  and
northwestern Tennessee. Exhibit 35 shows that the
lack of a difference in deposition  in  the mid-
Appalachians between post 2010 full implementa-
tion and no-trading scenarios listed in Exhibit 34 is
due to increases  in one area being offset by de-
creases in another. Nonetheless, the modeling es-
timates of the differences in sulfur deposition be-
tween the post 2010 full implementation and no-
trading scenarios indicate that they are expected to
be less than 10 percent,  and in many cases much
less in the sensitive aquatic regions. It is also ap-
parent from Exhibit 35 that trading has virtually no
impact on sulfur deposition in Canada.

3.5.2  Effect of Additional SO2 Emissions  Re-
       ductions on Sulfur Deposition
This  section  presents deposition  values  for the
additional  SO2  reduction  scenarios  described
above and  compares each  to the post 2010 full
implementation scenario.  The additional  reduc-
tions scenarios were chosen to demonstrate the
                                               68

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                                               CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                  TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
magnitude of further emissions reductions and the
spatial distributions associated with each. Exhib-
its 36  and  37  are  sulfur  deposition  maps  for
50 percent additional  utility SO2 reductions, and
50 percent utility plus 50 percent  industrial SO2
reduction scenarios. Exhibits 38 and 39 are maps
of percentage reductions  in sulfur emissions rela-
tive to the post 2010 full  implementation case for
each  scenario. Exhibit 40 summarizes the annual
average deposition to the three sensitive regions
for each scenario, and Exhibit 41 lists the percent-
age decrease  in  sulfur deposition  to each region
relative to 1980.

By comparing the sulfur  deposition maps for the
additional  reductions  scenarios (Exhibits 36 and
37) to the deposition  map for the  post 2010  full
implementation  case  (Exhibit 32),  it is  apparent
that the general  spatial distribution of sulfur depo-
sition remains similar  with the highest deposition
values falling in the  industrial areas of  the mid-
West, the regions with the highest emissions.  Ex-
hibits 38 and 39 show that the percentage reduc-
tions increase as one moves  south,  with the largest
percentage reductions  occurring from the  lower
Ohio  Valley  through  Florida, with significant re-
ductions in central New York State. The reduction
in industrial emissions  has the greatest impact in
the Southern  Blue Ridge and South Atlantic re-
gions.

3.5.3  Decrease in Total Nitrogen Deposi-
       tion from Decreases in NOX Emissions
Nitrogen deposition  is primarily the sum  of wet
and dry deposition of nitrate and ammonia. (There
is also  a  small  contribution from  dry NO2.) As
noted  in  Section 3.2.1,  emissions  estimates  for
ammonia  are highly  uncertain  both in  terms of
magnitude and source. Therefore, RADM replaces
predicted ammonia with observed ammonia depo-
sition.  In deposition  modeling the contribution of
ammonia to nitrogen deposition is treated as back-
ground  along with nitrogen  deposition from oxi-
dized species from natural sources and agricultural
emissions.  Background from  these sources is esti-
mated to be 4, 4.3, and 2.8 kg-N/ha in the Adiron-
dacks,  mid-Appalachians,  and   Southern  Blue
Ridge, respectively.73 Therefore, the scenario ana-
73  Van Sickle, J., M.R.  Church. 1995. Methods for Es-
   timating the Relative Effects of Sulfur and Nitrogen
   Deposition on Surface Water Chemistry. Environ-
   mental Research Laboratory, Corvallis, OR.
lyzed in this  section  focuses  on  anthropogenic
NOX emissions reductions.

Exhibit 42 shows historical and projected nation-
wide total NOX  emissions for the  period 1980 to
2010 with and without implementation of Title IV.
The emissions projections include Title I (i.e., rea-
sonably achievable control technologies) and mo-
tor vehicle NOX reductions mandated by Title II.
The difference in the two projections is the 2 mil-
lion ton  per year  reduction  in utility NOX emis-
sions estimated to come from Title IV. Unlike util-
ity SO2 emissions, NOX emissions  are not capped
by the CAAA.

As shown in  Section  3.2.1, utilities and highway
vehicles  are each  responsible for about one-third
of nationwide emissions of NOX  and industrial
sources for about one-sixth of nationwide  NOX
emissions. Exhibits 43-45 show nitrogen deposi-
tion maps of  the RADM region for each of these
source categories  in  1990.  Deposition  resulting
from utility emissions  is strongly concentrated in
the Ohio Valley and falls away almost uniformly
with distance.  Industrial deposition is concentrated
on the Gulf Coast, reflecting the concentration of
high NOX emitting industry in  that area.  Deposi-
tion from mobile sources is concentrated along the
East Coast as  a result of automobile  emissions in
urban areas. The principal contributors to deposi-
tion in the Southern Blue Ridge and  mid-Appala-
chians   are   utility   and   industrial  emissions.
The Adirondacks  are  affected  about equally by
utility and mobile source emissions.

It is estimated  that under Title II of the Act, mobile
source emissions in 2010 in the eastern half of the
United States will be reduced by about 15 percent
from 1990 levels. Since mobile sources represent
about one-third of total NOX emissions, this reduc-
tion corresponds to a  reduction in  total  NOX of
about 5 percent. Under  Title IV,  NOX emissions
rates from utility boilers will be reduced based on
the degree of  reduction available through the ap-
plication of control technology. EPA estimates that
implementation of these regulations will result in
utility NOX emissions in  2010 which are approxi-
mately 20 percent less than would have existed
without  Title IV.  Implementation  of  Title I  to
achieve the ozone standard in  the Northeast and
other nonattainment areas is expected to involve
significant reductions  in  NOX emissions from util-
ity, industrial, and mobile sources.  These reduc-
tions are likely to be region specific.
                                                69

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ACID DEPOSITION FEASIBILITY STUDY
   EXHIBIT 36. RADM-PREDICTED ANNUAL AVERAGE
      TOTAL SULFUR DEPOSITION (KG-S/HA) IN
       2010 UNDER ADDITIONAL UTILITY SO2
         EMISSIONS REDUCTION SCENARIO
EXHIBIT 37. RADM-PREDICTED ANNUAL AVERAGE
    TOTAL SULFUR DEPOSITION (KG-S/HA) IN
    2010 UNDER ADDITIONAL UTILITY AND
INDUSTRIAL SO2 EMISSIONS REDUCTION SCENARIO
   EXHIBIT 38. PERCENTAGE REDUCTIONS IN SULFUR
DEPOSITION FROM POST-2010 FULL IMPLEMENTATION -
UNDER ADDITIONAL UTILITY SO2 REDUCTION SCENARIO
   EXHIBIT 39. PERCENTAGE REDUCTIONS IN
  SULFUR DEPOSITION FROM POST-2010 FULL
 IMPLEMENTATION UNDER ADDITIONAL UTILITY
 AND INDUSTRIAL SO2 REDUCTION SCENARIO
                                             70

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                                   CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                      TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
EXHIBIT 40. SULFUR DEPOSITION TO SENSITIVE REGIONS UNDER VARIOUS EMISSIONS SCENARIOS
Emissions Scenario
1980
1985 NAPAP
Post-2010 full implementation
CAAA implementation plus additional
utility SO2 reduction
CAAA implementation plus additional
utility and industrial SC>2 reduction
Annual Average Deposition Level (kg-S/ha)
Adirondacks
11.0
9.8
6.9
5.5
4.7
Mid-
Appalachians
19.0
17.0
11.0
8.1
6.9
Southern
Blue Ridge
14.0
13.0
9.7
6.8
5.5
          EXHIBIT 41. PERCENT REDUCTIONS IN SULFUR DEPOSITION TO SENSITIVE
           REGIONS FROM 1980 LEVELS UNDER VARIOUS EMISSIONS SCENARIOS
Emissions Scenario
Post-2010 full implementation
CAAA implementation plus additional
utility SC>2 reduction
CAAA implementation plus additional
utility and industrial SC>2 reduction
Percent Reduction
Adirondacks
39
51
58
Mid-
Appalachians
41
56
63
Southern
Blue Ridge
31
52
60
                  EXHIBIT 42. ESTIMATED U.S. NOX EMISSIONS
                WITH AND WITHOUT TITLE IV FROM 1980 TO 2015
              14
                 1980   1985   1990
1995

Year
2000   2005   2010
                                    71

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ACID DEPOSITION FEASIBILITY STUDY
    EXHIBIT 43. PERCENT CONTRIBUTION OF UTILITY
     SOURCES TO NITROGEN DEPOSITION IN 1990
    EXHIBIT 45. PERCENT CONTRIBUTION OF MOBILE
     SOURCES TO NITROGEN DEPOSITION IN 1990
  EXHIBIT 44. PERCENT CONTRIBUTION OF INDUSTRIAL
     SOURCES TO NITROGEN DEPOSITION IN 1990
A detailed inventory of NOX emissions in the year
2010 suitable for RADM modeling which consid-
ered full implementation (all Titles) CAAA was not
available for this report. As a scoping exercise for
this report two emissions scenarios were used: the
baseline 1990 Interim Inventory and an  inventory
in which NOX emissions from industrial and utility
sources is reduced by 50 percent from 1990 levels.
This reduction inventory, as described  in Section
3.4, corresponds to a 24 percent decrease in total
NOX emissions. Nitrogen deposition from ammo-
nia was assumed to remain constant. Exhibits 46
and 47 are maps of nitrogen deposition from the
1990 Interim Inventory and from the utility and in-
dustrial emissions reduction scenario.   Exhibit 48
is a map of percentage reductions in nitrogen
deposition due to the control scenario.  Exhibit 49
summarizes  nitrogen deposition and  percentage
reductions for the baseline  and control  scenarios.
Percentage reductions are less than for the similar
SO2 scenario for two reasons: ammonia  emissions,
which  account for between one-fifth  and  one-
quarter  of nitrogen  deposition in  the eastern
United States, are assumed to be constant and util-
ity and industrial  sources account for only about
50 percent of total NOX emissions,  whereas these
categories account for 87 percent  of SO2  emis-
sions. The greatest percentage  reduction is found
in the mid-Appalachians, followed by the Southern
Blue Ridge, and then the Adirondacks,  reflecting
the relative  importance of  utility  and  industrial
NOX emissions to deposition in  these regions.

3.6  EMISSIONS REDUCTIONS STRATEGIES TO
     ACHIEVE GEOGRAPHICALLY TARGETED
     SULFUR DEPOSITION LOADS
In the previous section deposition values were pro-
jected for  nationwide emissions control scenarios.
That is, similar to Title  IV, the  reductions resulted
from control  approaches which specified emis-
sions reductions by source  category not by  geo-
graphic  location. This section  describes and ana-
lyzes geographically targeted emissions reductions
to achieving deposition reductions. Analysis of
                                               72

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                                        CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                           TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
EXHIBIT 46. ANNUAL AVERAGE RADM TOTAL
 NITROGEN DEPOSITION (KG-N/HA) IN 1990
  EXHIBIT 47. RADM-PREDICTED ANNUAL
  AVERAGE TOTAL NITROGEN DEPOSITION
(KG-N/HA) UNDER UTILITY AND INDUSTRIAL
  NOX EMISSIONS REDUCTIONS SCENARIO
                     EXHIBIT 48. PERCENTAGE REDUCTIONS IN NITROGEN
                        DEPOSITION UNDER UTILITY AND INDUSTRIAL
                          NOX EMISSIONS REDUCTIONS SCENARIO
           EXHIBIT 49. NITROGEN DEPOSITION TO SENSITIVE REGIONS UNDER BASE CASE AND
            ADDITIONAL UTILITY AND INDUSTRIAL NOX EMISSIONS REDUCTION SCENARIO
Emissions Scenario
1 990 Base Case
Additional utility and industrial NOX
reductions from 1 990 base case
(% reduction from base case in parenthesis)
Annual Avera
Adirondacks
9.5
8.1
(14%)
ge Deposition Level (kg-N/ha)
Mid-
Appalachians
14.3
11.3
(21%)
Southern
Blue Ridge
11.9
9.9
(16%)
                                        73

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ACID DEPOSITION FEASIBILITY STUDY
these reductions relies on RADM source-receptor
relationships to target source regions for emissions
reductions needed to achieve  a  specified target
load.

The assessment of geographically targeted reduc-
tions strategies relies on the ability of the RADM
Tagged Engineering Model to identify the contribu-
tion of emissions from tagged  source  regions to
deposition in selected target regions. This assess-
ment is based on results for the 53 tagged regions
shown in Exhibit 19. To illustrate the potential ap-
plicability of this geographic targeting,  deposition
goals for the three sensitive aquatic regions were
selected  to  be  equal  to the  deposition  levels
achieved by the source-category specific SO2  re-
duction  scenarios  analyzed  in  Section 3.5. The
maintenance  load scenario  is  described in Ex-
hibit 50.

As noted in Section 3.3, implementing Title IV will
result in a higher proportion of sulfur deposition in
sensitive  aquatic  regions coming from  nearby
sources in 2010 than was the case in 1985. At the
same time, the top 10 emitting regions' contribu-
tions to deposition in those areas will decrease in
importance from 1985 to 2010. To assess the fea-
sibility  of defining geographically  targeted emis-
sions reductions for given deposition targets, two
potential  scenarios were selected.  The  first limits
the selection to obtaining the required emissions
reductions from sources near a sensitive region.
The other focuses on securing emissions reductions
from those RADM subregions most responsible for
deposition in a sensitive region.

Exhibit 40 lists the deposition level for each sensi-
tive  aquatic  region   achieved   by   a  further
50 percent reduction  in  utility SO2 emissions be-
yond the  CAAA from utility sources in the United
States and the deposition level achieved by a fur-
ther 50 percent  reduction  in utility and industrial
sources. These deposition  levels were selected to
illustrate target loads  in order to compare nation-
wide and target emissions reductions.  Exhibit 27
shows that  in 2010 after implementation of the
CAAA,  local and contiguous sources will contrib-
ute 7.8 percent of deposition  in the Adirondacks,
28 percent   in    the    mid-Appalachians,  and
26 percent in the Southern Blue  Ridge. Thus, up to
a point it  should be feasible to develop geographi-
cally restricted targeted areas for emissions reduc-
tions in the mid-Appalachians and  the  Southern
Blue Ridge as long as the reductions demanded
are significant, such as 95 percent or greater. Be-
cause of the relatively smaller contribution of local
sources to deposition in  the  Adirondacks, reduc-
tions in emissions from  a large geographic area
would be required to achieve targeted  levels of
deposition.

To achieve the same deposition levels as the sce-
nario defined  by a 50 percent reduction in  utility
SO2 emissions beyond that achieved by the CAAA,
targeted source regions were identified by sequen-
tially removing 95 percent of the SO2 utility emis-
sions (remaining after implementation of Title IV)
from each subregion until the deposition  levels
listed in Exhibit 40 were achieved.  For  the con-
tiguous scenario, emissions were removed starting
at the center of the sensitive region and continued
outward until the deposition goal was reached. For
the  noncontiguous  scenario, emissions  were re-
moved by subregion  in  order  of contribution to
deposition to the sensitive region.

Exhibits 51 a and 51 b show the results of targeted
emissions reductions to achieve the  same deposi-
tion  as the 50 percent additional SO2 utility case.
The  exhibits show that geographically targeted re-
ductions can  be achieved for all of the sensitive
aquatic areas. As anticipated, it  takes  a  larger
number of tagged-regions and greater emissions
reductions to achieve the target for  the  Adirond-
acks than for the other two regions. By comparing
the emissions  reductions required in the contigu-
ous  vs. non-contiguous  scenarios, it is  apparent
that  only in the Southern Blue  Ridge are contigu-
ous reductions more efficient, requiring 25 percent
fewer emissions reductions. This difference for the
Southern Blue Ridge can be attributed to the inclu-
sion of RADM Subregion 51 (Northern Florida),  a
major emitting region, in the non-contiguous re-
ductions. For the other two sensitive regions both
contiguous and non-contiguous reductions rely es-
sentially  on the same  geographic  areas of the
country. It is also interesting to note  that the total
emissions reductions  to  achieve  all  three  target
loads simultaneously are  essentially equal and are
less  (i.e.,  amount  of total emissions  reductions)
than 10 percent  more efficient  than  a nationwide
50 percent reduction in utility SO2 emissions.
                                                 74

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                                             CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
                           EXHIBIT 50. SELECTION OF MAINTENANCE LOADS
Critical load definitions are founded on scientific determinations of quantitative pollutant loadings be-
low which no significant harmful effects occur to critical ecological processes. Critical load definitions
depend solely on inherent ecological properties. Target load definitions differ in that they incorporate
social,  policy, economic,  and  related considerations  along  with  the  scientific observations. An
example of a possible target load would be a decision to regulate acidic deposition at levels adequate
to maintain proportions of ANC<50 ueq/l waters, roughly equivalent to pH>6.5, at or below the pro-
portions found during the 1984-85 National Surface Water Surveys (NSWS) for each of three regions
in the eastern United States discussed  here.  Other possible goals for defining target loads could in-
clude, for example, restricting deposition to produce a reduction in the 1984-85 proportions of ANC<
50 ueq/l waters by a specific percentage or  to  some fixed proportion endpoint. Also,  the definition
could be expanded to include a larger geographical region.

For purposes of illustration, assume that social, policy, economic, scientific considerations led to a se-
lection of the first of the above options as a generally acceptable goal for a target  load: to  limit sulfur
deposition rates sufficiently to maintain proportions of target population surface waters having ANC<
50 ueq/l in these regions through the year 2040 at proportions no greater than those found for the
same subpopulation  by the  1984-85 NSWS.  This maintenance load  also would allow for a possible
restoration of prior ANC levels  and reduction in acidic conditions in some of these waters. The nu-
meric  proportions of target  population waters with ANC<50 ueq/l found in  1984-85 that would be
used to evaluate attainment of this goal in each of the three regions  are <55  percent in the Adirond-
acks, <27 percent in  the Mid Appalachians, and  <6 percent in the Southern Blue Ridge. It is important
to note, however, that the percentages reported  here represent sensitive subpopulations of  the overall
number of surface waters in those regions.

The Nitrogen Bounding Study (NBS) projections, described  in detail in Chapter 2,  can be used to de-
termine sulfur deposition values necessary to attain this goal by locating these  percentages on the NBS
plots shown in Appendix  B. For each  region, projections of sulfur deposition loadings necessary to
maintain the 1984-85 NSWS proportions of ANC<50 ueq/l waters depends on the assumed time to ni-
trogen saturation for that region. For the purposes of this analysis, it has been assumed that nitrogen
deposition rates will remain unchanged for the  1984-2040 period. In considering this approach, it is
critical to recognize that, while the NBS modeling results are the best available information, there are
significant uncertainties in the projected relationships (see Section 2.6.3). Consequently, the magni-
tude of the uncertainties in sulfur deposition maintenance loads used in this analysis cannot be quanti-
fied at this time.

Current scientific uncertainty does not allow  quantifying the time to nitrogen saturation for any of the
three sensitive regions nor for any other regions. However, it  is reasonable to suggest that times to
saturation do vary among regions due to differences in temperature, moisture, soil fertility,  forest age,
history of nitrogen deposition, and other variables. Watersheds in the Northeast have cooler annual
temperatures, snorter growing seasons, and long histories of elevated nitrogen  and sulfur  deposition
levels. Consequently, watersheds in the Adirondacks may include those having the shortest remaining
times to nitrogen saturation. Watersheds in the Mid-Appalachians and Southern Blue Ridge Province
may have longer remaining times to nitrogen saturation.

For illustrative purposes in this analysis, if the time to nitrogen saturation is between 75 and 150  years
in the Mid-Appalachians, and between 200 and 300 years in the SBRP, then a sulfur deposition load of
about 5 kg/ha/yr is projected by the NBS results as potentially maintaining surface waters with ANC<
50 ueq/l at 1984-85  proportions. NBS modeling suggests that for a time to nitrogen saturation for the
Adirondacks of between 25 and 75 years, a greater than  50 percent reduction  in both sulfur and nitro-
gen may be necessary to maintain the 1984 proportion of ANC<50 ueq/l lakes; however, a 5 kg/ha/yr
sulfur load would likely provide some benefits.

This example of a loadings approach (i.e., maintenance load) concentrates only on sulfur deposition,
while nitrogen deposition is held constant. However, NBS results for all three  regions indicate that re-
ducing nitrogen deposition rates is projected to provide likely benefits in reducing proportions of ANC
<0 ueq/l and ANC<50 ueq/l  surface waters that may equal or exceed  the potential  benefits  obtainable
from reducing sulfur deposition  alone. The amount of benefit would  depend on the actual  amount of
reduction in sulfur and nitrogen deposition obtained, and  on the  actual time to  watershed nitrogen
saturation within each region. Any efforts to develop acid deposition standards would likely include
both sulfur and nitrogen.
                                              75

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 ACID DEPOSITION FEASIBILITY STUDY
                           EXHIBIT 51 A. GEOGRAPHICALLY TARGETED ADDITIONAL
                       UTILITY SO2 REDUCTION IN CONTIGUOUS RADM SUBREGIONS

Deposition
Subregions
SO2 Emissions
Reduction (tons)
Sensitive Region
Adirondacks
5.5 kg-S/ha
45,44,5,4,2,3,9,
11,12,14,7,8,10,
13,15,18,19,20,22
3,018,000
Mid-
Appalachians
8.1 kg-S/ha
13,19,28,20,
21,27,15,22
1,952,000
Southern
Blue Ridge
6.8 kg-S/ha
29,30,31,39,38,
37,28,21,23,27,
36,32,33,40
1,508,000
All Three
Receptor
Regions
—

4,526,000a
Nationwide
Utility
—

5,047,000
    a This emissions total was derived without double counting those subregions contributing to deposition in
     more than one receptor region.
               EXHIBIT 51 B. GEOGRAPHICALLY TARGETED ADDITIONAL UTILITY SO2 REDUCTION
              IN MAJOR RADM SUBREGIONS CONTRIBUTING TO DEPOSITION (NOT CONTIGUOUS)


Deposition
Subregions

SO2 Emissions
Reduction (tons)
c
Adirondacks
5.5 kg-S/ha
15,13,22,20,
14,7,10,12,25,
3,9,5,2,17,44
3,160,000
»ensitive Region
Mid-
Appalachians
8.1 kg-S/ha
13,20,15,
22,28,27,10
2,080,000

Southern
Blue Ridge
6.8 kg-S/ha
31,29,39,38,28,
37,40,51,20,22
2,081,000

All Three
Receptor
Regions
—
	

4,658,000a

Nationwide
Utility
—
	

5,047,000
   a This emissions total was derived without double counting those subregions contributing to deposition in
     more than one receptor region.
Exhibit 52 is a map of the geographically targeted
reductions for the  contiguous reductions  for all
three receptor regions. RADM subregions required
for the Adirondacks (indicated by short dashes) ex-
tend from the Canadian border south through Vir-
ginia and Kentucky and from the Eastern seaboard
west to the  middle of Indiana. Source regions for
the mid-Appalachians (solid line)  are  fairly sym-
metric around the region and extent from the mid-
dle of Ohio south through  central  North Carolina
and  west from the  North  Carolina  Coast to  the
middle  of Indiana. For the Southern  Blue Ridge
source regions (longer dashed lines)  include most
of North and South Carolina,  Kentucky, Tennes-
see,  and Alabama and the northern  half of Geor-
gia.  The map shows the striking overlap between
tagged regions required for achievement of the tar-
get load in  the  mid-Appalachians and the other
two  source  regions and the lack  of overlap be-
tween  the Adirondack and  Southern  Blue Ridge
source regions. Achieving the target loads in the
Adirondacks and Southern Blue Ridge would also
achieve the target load in the mid-Appalachians.

A similar analysis was conducted to determine if
the maintenance  loads  developed for illustrative
purposes and loads  defined  by the  deposition
levels  achieved by the  nationwide  50 percent
utility  plus  industrial  SO2  emissions  reduction
could  be  achieved  by  targeting  only  utility
emissions in the 53 tagged subregions. It was only
possible to achieve the deposition  targets in the
mid-Appalachians. It was possible to achieve the
maintenance load in the Adirondacks, but not  in
the mid-Appalachians or the Southern Blue Ridge,
when only considering 95 percent  reductions  of
utility emissions in the targeted regions. Thus, tar-
                                                76

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                                              CHAPTER 3: SOURCE-RECEPTOR RELATIONSHIPS AND DEPOSI-
                                                 TION REDUCTIONS UNDER VARIOUS EMISSIONS SCENARIOS
    EXHIBIT 52. MAP OF EXTENT OF CONTIGUOUS
   GEOGRAPHIC REGIONS FOR ACHIEVING TARGETED
   DEPOSITION LOADS EQUIVALENT TO ADDITIONAL
       NATIONWIDE UTILITY SO2 REDUCTIONS
geting scenarios that included industrial emissions
reductions were then analyzed.

For the 50 percent utility and industry SO2 reduc-
tions  beyond the post 2010 full implementation
scenario, targeted source subregions were identi-
fied by sequentially removing  95 percent of the
SO2  major  source  (utility  plus  large  industrial
sources)  emissions  from each  subregion.  Results
are shown in Exhibits 53a and 53b. It appears fea-
sible  to  have geographically targeted controls  if
reductions  are from both  utility and  industrial
sources. For these targets, there  is little geographic
"efficiency"   between  constraining  the  tagged
subregions to be contiguous or focusing on the re-
gions most responsible  for deposition. Thirty-one
emissions subregions are  included  in the former
case for all three sensitive receptor regions and 29
in the latter. As shown in Exhibit 54 the tagged
subregions  cover the same geographical  expanse
as those involved in utility reduction targeted sce-
nario (compare  Exhibit 52).  The principal  differ-
ence is that the overlap among regions is more ex-
tensive with reductions in some source regions re-
quired to achieve target loads in all three sensitive
regions. Again, emissions reductions from sources
in the western part of the RADM domain are not
required.

For the maintenance load analysis, a 95 percent
reduction in major  source emissions was used. The
results for the case focusing on  emissions  reduc-
tions from regions  most responsible for deposition
are shown in Exhibit 55. Compared to the number
of tagged emissions regions shown in  Exhibit 53b,
the number is somewhat  less for the Adirondacks,
somewhat more  for the Southern Blue Ridge, and
almost 3 times  larger  for the mid-Appalachians.
Nevertheless, the total number of tagged regions is
comparable, 31  for the 50 percent utility plus in-
dustrial source scenario  and 33 for the mainte-
nance load scenario). Two-thirds of the subregions
contributing to the Adirondacks and two-thirds of
the subregions contributing to the Southern Blue
Ridge also are major sources of  deposition in the
mid-Appalachians. (A  similar analysis using only
contiguous  subregions  shows  a  greater than
90 percent  overlap between the  Southern Blue
Ridge and mid-Appalachians). There is no overlap
of the two sets of subregions identified for the Adi-
rondacks and the Southern Blue Ridge. Thus, these
regions could be  individually targeted;  however,
attempting to achieve the maintenance  load  for
the mid-Appalachians may be best done as  part of
a  strategy to achieve it for  all  three sensitive
regions at  the same time. Using a  maintenance
load chosen for  illustrative purposes in this  report,
it  appears  not  to be   very   advantageous to
geographically  target  regions   individually  to
achieve a particular load.
                                                77

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ACID DEPOSITION FEASIBILITY STUDY
                    EXHIBIT 53A. GEOGRAPHICALLY TARGETED ADDITIONAL UTILITY AND
                    INDUSTRIAL SO2 REDUCTION IN CONTIGUOUS RADM SUBREGIONS


Deposition
Subregions



Adirondacks
4.7 kg-S/ha
45,44,5,4,2,3,9,
11,12,14,8,10,13,
15,7,18,20,22
Sensitive Region
Mid- Appalachians
6.9 kg-S/ha
13,19,20,10,
15,28,27,18,22


Southern
Blue Ridge
5.5 kg-S/ha
29,30,31,39,38,
37,28,21,19,36,27,
15,20,22,23,40
                    EXHIBIT 53s. GEOGRAPHICALLY TARGETED ADDITIONAL UTILITY AND
                       INDUSTRIAL SO2 REDUCTION IN MAJOR RADM SUBREGIONS
                          CONTRIBUTING TO DEPOSITION (NOT CONTIGUOUS)


Deposition
Subregions



Adirondacks
4.7 kg-S/ha
15,13,5,14,7,20,
22,44,10,12,45,
17,9,25,26,3
Sensitive Region
Mid- Appalachians
6.9 kg-S/ha
13,20,15,22,19,
28,27,18,10


Southern
Blue Ridge
5.5 kg-S/ha
29,31,39,38,37,
28,40,20,51,27,
21,30,22,15,25
                           EXHIBIT 54. EXTENT OF CONTIGUOUS GEOGRAPHIC
                            REGIONS FOR ACHIEVING TARGETED DEPOSITION
                           LOADS EQUIVALENT TO ADDITIONAL NATIONWIDE
                              UTILITY AND INDUSTRIAL SO2 REDUCTIONS
                      EXHIBIT 55. GEOGRAPHICALLY TARGETED REDUCTIONS WITH A
                    MAINTENANCE LOAD OF 5 KG-S/HA IN MAJOR RADM SUBREGIONS
                          CONTRIBUTING TO DEPOSITION (NOT CONTIGUOUS)


Subregions




Adirondacks
15,13,5,14,7,20,
22,44,10,12,45,17


Sensitive Region
Mid- Appalachians
13,20,15,22,19,28,
27,10,18,31,21,12,
25,14,37,39,29,26,
7,51,34,32,23,9

Southern Blue Ridge
29,31,39,38,37,28,40,
20,51,27,21,30,
22,15,25,41,32,36

                                             78

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                                          CHAPTER 4
           POTENTIAL BENEFITS OF AN ACIDIC DEPOSITION STANDARD ON
        VISIBILITY, HUMAN HEALTH, MATERIAL, AND CULTURAL RESOURCES
4.1  INTRODUCTION
Chapter 2 of this report focused on the effects of
acidic deposition on sensitive aquatic and terres-
trial resources. This chapter describes how an acid
deposition  standard, in this  case  aquatics-based,
could  improve  visibility, protect  human health,
and preserve material resources of functional and
cultural importance.

4.2 RELATIONSHIP OF VISIBILITY TO ACIDIC
     DEPOSITION
In certain areas  of the  United States, visibility is a
significant environmental  indicator of  air quality.
Visibility  impairment  and  subsequent  improve-
ment is therefore a  strong measure of effectiveness
and benefits. This section identifies regions in the
United States subject to visibility degradation and
describes how these areas could benefit from an
acid deposition  standard that, in  this case, is de-
signed to protect sensitive aquatic resources.

4.2.1  Visibility Impairment
Visibility refers to the degree to which the atmos-
phere  is transparent to visible light. Fine particles
in the atmosphere absorb and scatter light, thereby
limiting visual range, decreasing color discrimina-
tion, and obscuring details of distant  objects.  Im-
pairment of visibility depends on  several factors,
especially the size and composition of particles in
the viewing path. Some gases absorb  visible light
and can impair visibility. Visibility is also affected
by the angle of sunlight and so varies with time of
day and season. Humidity can reduce  visibility
when hygroscopic particles absorb water and in-
crease in size;  larger particles scatter  more light.
Thus, natural visibility  in the humid East is gener-
ally poorer than  in the more arid West.

Visibility can be impaired by natural  and anthro-
pogenic sources. Natural sources include fog, pre-
cipitation,  sea   mist,  windblown  dust,  volcanic
emissions, and  forest fires. Visibility impairment
from these sources varies  by season and  meteoro-
logical condition. Anthropogenic sources include
gaseous and particulate emissions from stationary
and  mobile sources. Most visibility impairment
can be traced to one gas, nitrogen  dioxide, and
five particulate substances: sulfates, nitrates,  or-
ganics, elemental  carbon, and soil dust.

The  National  Academy  of Sciences (NAS) esti-
mated the  contribution of  anthropogenic air pol-
lutants to visibility impairment in three areas of the
country:  the  East (i.e., states east of the Missis-
sippi), the Southwest (i.e., California, Nevada, Ari-
zona, New Mexico, Utah, and Colorado), and  the
Northwest   (i.e.,   Oregon,   Washington,   and
Idaho).74 Exhibit 56 summarizes findings for rural
regions in each area. NAS also calculated that  an-
thropogenic sources are  responsible  for seven-
eighths of  the  visibility  impairment in the East,
five-eighths in the Northwest, and three-eights in
the Southwest.
      EXHIBIT 56. ANTHROPOGENIC CONTRIBU-
        TIONS TO VISIBILITY IMPAIRMENT74
Contaminant
Sulfates
Organics
Elemental Carbon
Suspended Dust
N itrates
Nitrogen Dioxide
Percent
East
65
14
11
2
5
3
Southwest
39
18
14
15
9
5
Northwest
33
28
15
7
13
4
The  exhibit clearly indicates that most  visibility
impairment  in the  East  is  caused  by  sulfates
(transformation products of sulfur dioxide, the ma-
jority of which is emitted  from power plants). No
single source category dominates visibility  im-
pairment in the West, although sulfur compounds
play a significant role.  In relatively clean areas of
the West, small  increases in pollutant levels can
markedly  degrade  visibility.  Thus,  visibility in
74 Committee on Haze in National Parks and Wilder-
  ness Areas. 1993.  Protecting Visibility in National
  Parks and  Wilderness Areas.  National  Research
  Council  and  National Academy of Sciences, Wash-
  ington, DC.
                                                79

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ACID DEPOSITION FEASIBILITY STUDY
Class I areas in the West is especially sensitive to
increased levels of pollution.

4.2.2 Visibility Protection Laws and Class I
       Areas
Section 169A of the Clean Air Act (CAA) of 1977
established  as a  national goal "the prevention of
any future and the remedying of any existing im-
pairment of visibility  in  mandatory Class I  areas
which impairment results from man-made air pol-
lution." Class I federal  areas are defined in CAA
Section 162(a) as international parks, national wil-
derness  and  memorial  parks  exceeding  5,000
acres, and national parks exceeding 6,000 acres in
existence in 1977. EPA,  in conjunction with the
Department of the Interior  (DOI),  has designated
158 mandatory Class I areas where visibility is im-
portant.

States that  either have Class I areas or contain
sources that may contribute to visibility impair-
ment of these areas are required to include in their
state implementation plans (SIPs) a long-term strat-
egy for making reasonable progress toward reduc-
ing impairment.  Major stationary  sources reason-
ably expected  to contribute to visibility impair-
ment in  a Class I area  must install best available
retrofit technology.

The prevention of  significant deterioration  (PSD)
provision in Sections 160-169 of  the  CAA also
applies to visibility protection.  The PSD program,
which is directed toward new sources,  requires
that major emitting facilities seeking to locate in
clean-air  areas (i.e., areas  meeting the National
Ambient Air Quality Standard [NAAQS] for  a par-
ticular pollutant)  use best available control tech-
nology (BACT). The source must also comply with
air  quality increments that  specify the maximum
permissible increase in ambient pollutant levels for
SO2, NO2, and particulate matter. Class I areas are
further protected by the designation of Air Quality
Related Values (AQRV) for several parameters, in-
cluding visibility. In addition to complying with
BACT and increment requirements, new sources
must demonstrate that they will not adversely af-
fect an area's AQRV.

When the PSD program was created in 1977, large
national  parks and wildernesses were designated
as Class  I areas to  provide  them with special air
quality protection. Other parks and wilderness ar-
eas have been designated  Class I  in  succeeding
years. About two-thirds  of the current Class I areas
are west  of the Mississippi. Nearly one-quarter are
located in four southwestern  states: Utah,  Colo-
rado, Arizona, and New Mexico. Monitoring visi-
bility conditions at some sites was initiated by the
National Weather Service in  1978. At approxi-
mately 43  other sites, visibility monitoring began
in 1987 and continues under a multi-agency pro-
gram called the  Interagency  Monitoring of Pro-
tected Visual  Environments (IMPROVE).  A  rule-
making effort on regional haze protection recently
initiated by EPA will  further examine visibility im-
pacts on and protection of Class I areas.

4.2.3 Visibility Metrics and the Projected
       Impact of the CAAA on Visibility
No standard or EPA-approved  method for measur-
ing optical air quality exists.  Visibility has been
measured and reported  in several ways. Standard
visual range is based on human perception of a
large black object placed in the sky and is reported
in kilometers or miles. A more scientific measure
of visibility impairment  is light extinction. An ex-
tinction coefficient is proportional to the attenu-
ation of light per unit distance due to absorption
and scattering of light by particles or gases. Extinc-
tion coefficients are a function of particle size and
shape and the gaseous chemicals present. A third,
recently developed measure is the deciview scale
(analogous to the decibel scale for sound), which
provides a  haziness index designed to be linear to
humanly perceived  changes  in visibility caused
solely by  air quality changes. The deciview (dv)
scale is near  zero for pristine  atmospheric condi-
tions  and  increases as visibility degrades; a 1 dv
change  corresponds  to a  10 percent  change  in
light  extinction  and approximates a  minimum,
commonly observable visibility change.

Several  recent visibility  studies have  been  con-
ducted to assess the impact of the CAAA on visibil-
ity  improvement; some analyses  specifically as-
sessed the impact of Title IV.

Eastern United States
A recent analysis  compared standard visual range
with and without Title IV of the CAAA  to assess
economic benefits of improvements in visibility.75
The visual range maps (Exhibits 57 and 58) illus-
75 Chestnut, L.C., R.L. Dennis, and D.A. Latimer. 1994.
  Economic  benefits of  improvements  in  visibility:
  Acid rain  provisions of the 1990  Clean Air  Act
  Amendments.  Presented at Aerosols  and  Atmos-
  pheric  Optics:  Radiation Balance and  Visual Air
                                     (continued)
                                                80

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                                             CHAPTER 4: POTENTIAL BENEFITS OF A STANDARD ON VISIBILITY,
                                                   HUMAN HEALTH, MATERIAL, AND CULTURAL RESOURCES
        EXHIBITS?: ANNUAL AVERAGE VISUAL
     RANGE (KM) PROJECTED FOR 2010 WITHOUT
        TITLE IV: SOTH-PERCENTILE VISIBILITY
  EXHIBIT 58. ANNUAL AVERAGE VISUAL RANGE (KM)
   PROJECTED FOR 2010 WITH TlTLE IV, INCLUDING
        TRADING: SOTH-PERCENTILE VISIBILITY
trate  impressive  changes in visibility associated
with Title IV. Although results are preliminary, the
economic analysis indicates potentially significant
  Quality, Air & Waste Management Association Inter-
  national  Specialty Conference,  Snowbird,  Utah,
  September 30.
monetary benefits to residential areas of 31 eastern
states in the United States and to national parks in
the southeastern United States.

An analysis was conducted for this study to com-
pare current and future perceptible visibility deg-
radation  in the East, assuming implementation of
Title IV in the year 2010. The assessment indicated
a noticeable improvement  in visibility across the
eastern United States (Exhibit 59)  from the 1980
base year,  with most of the change occurring in
the warm seasons.
                                                    EXHIBIT 59. ANNUAL AVERAGE IMPROVEMENT IN SOTH-
                                                    PERCENTILE VISIBILITY (DV) FROM 1980 TO 2010 WITH
                                                              TITLE IV, INCLUDING TRADING
A 1993 EPA Report to Congress presented visibility
improvements to Class I areas that could  be ex-
pected to accompany implementation of the 1990
CAAA.76 The analysis evaluated impacts of  control
provisions for NOX, SO2, and paniculate matter by
assuming implementation of Titles I, II, and IV of
the CAAA.  Exhibit 60 lists  specific provisions of
each title.

Because sulfates dominate visibility impairment in
the East, and no single chemical species dominates
in the Southwest, EPA modeled each region sepa-
76 Office of Air Quality Planning and Standards. Octo-
   ber 1993. Effects of the 1990 Clean Air Act Amend-
   ments on Visibility in Class I Areas: An EPA Report to
   Congress. U.S.  Environmental Protection Agency,
   Washington, DC.
                                                81

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 ACID DEPOSITION FEASIBILITY STUDY
                          EXHIBIT 60. SPECIFIC PROVISIONS OF TITLES I, II, AND IV
  Title I
  Application of reasonably available control technology (RACT) NOX control for ozone-
  moderate areas (or worse) and ozone transport regions
  Enhanced motor vehicle inspection and maintenance (I&M) for areas with conditions
  classed as ozone serious (or worse) and carbon monoxide-moderate (or worse)
  New Source Performance Standards (NSPSs) for NOX
  Title II
» 1995 tailpipe standards for NOX reduction
• Using oxygenated fuels in nonattainment areas for carbon monoxide
 Title IV
  Implementation of Phase I and II SO2 limits, where emissions are based on projections
  from the Coal and Electric Utilities Model for the EPA Regulatory Impact Analysis (RIA)
  Implementation of NOX controls
 rately.  EPA  used the Regional Acid Deposition
 Model  (RADM) post-processor (EM-VIS) to calcu-
 late visibility for each RADM cell  in  1985 and
 2010. The 1985 NAPAP emissions inventory was
 used as the  basis for 1985 values.  For the year
 2010, implementation of Title  IV was assumed, but
 without  SO2   emissions  trading,  because   an
 emissions scenario depicting  trading was unavail-
 able at that time. (Note, however, that the analysis
 of  the  environmental impact of trading allow-
 ances,  described in  Section  3.5.1,  found  only
 minimal differences in deposition due to trading.)
 Reductions in Canadian SO2  emissions predicted
 by  Environment Canada  as part of the 1990 NA-
 PAP Integrated Assessment were also used in the
 2010 modeling.

 Extensive comparisons of percent change in visual
 range were made using annual  average change
 and  90th-percentile  worst  days   (i.e.,   only
 10 percent of  days  have worse  visibility)  and
 10th-percentile best days (i.e., only 10 percent of
 days  have better visibility).  For  50th-percentile
 visibility days (half the days have  better and half
 worse visibility), the percent increase in visual
 range in the East ranged from  10 to 20 percent in
 Florida, New England, and just east of the Missis-
 sippi to 30 to 40 percent in the mid-Appalachians
 and the Ohio Valley. The largest improvement in
 50th-percentile visibility range in Class I areas was
 predicted to  be in Shenandoah  National  Park in
 the mid-Appalachians.

 Western United States
To illustrate the visibility impact on western Class I
 areas in the  1993 Report to Congress,  EPA con-
 ducted  a comprehensive  analysis of changes  in
visual range resulting from implementation of the
 1990 CAAA,  including the development of emis-
                                          sions inventories  for  anthropogenic sources  of
                                          NOX, SOX,  and  particulates  for  1988, a  2005
                                          base-case scenario,  and  a  2005 CAAA-imple-
                                          mented scenario.77 The  1985  NAPAP  emissions
                                          inventory served as the basis for the annual inven-
                                          tories. Electric utility emissions estimates  in the
                                          NAPAP  inventory were  replaced  by  emissions
                                          from  the more up-to-date  National Allowance
                                          Data  Base (NADB).  Emissions estimates for two
                                          large smelters near the border in Mexico were also
                                          included  in  the  inventories.  These  emissions
                                          inventories were  used to model  projected  air
                                          quality changes from 1988 to 2005. (EPA's 1993
                                          Visibility Report to Congress contains a detailed
                                          description  of models  used  and  assumptions
                                          made.)

                                          Comparing emissions for SO2,  NOX, and fine par-
                                          ticulates  revealed  only minor differences  in the
                                          total emissions of each  species between  1988 and
                                          2005. Emissions for the three scenarios by source
                                          category  for SO2  and NOX show that SO2 emis-
                                          sions  are equally distributed among area, utility,
                                          and other point sources (e.g., smelters,  refineries,
                                          and pulp mills). Of the 100,000-ton decrease  in
                                          utility emissions between 1988 and  2005, over
                                          half is a result of scrubbing at the Navaho station.
                                          NOX emissions are primarily attributable to motor
                                          vehicles and area sources.  Mobile sources account
                                          for most  of the  decrease  in  NOX  emissions,
                                          whereas utility emissions increase slightly.
                                         77 Visibility  modeling described here was conducted
                                           before this study was initiated; thus, inventories used
                                           are slightly different from those described in Chapter
                                           3. Differences in the inventories should not signifi-
                                           cantly affect qualitative conclusions, however.
                                                82

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                                            CHAPTER 4: POTENTIAL BENEFITS OF A STANDARD ON VISIBILITY,
                                                  HUMAN HEALTH, MATERIAL, AND CULTURAL RESOURCES
Three-hour average visual range estimates
were  developed for representative Class I
areas  in six geographic  regions:  Central
Coast    (California),   Sierra,   Southern
California, Desert Southwest, Golden Circle
(Arizona),    and    Rockies.   Exhibit 61
summarizes annual visual range estimates
for each inventory scenario calculated from
the 3-hour averages.
EXHIBIT 61. AVERAGE ANNUAL VISUAL RANGE ESTIMATES
FOR REPRESENTATIVE CLASS I AREAS IN THE SOUTHWEST
Exhibit 61 indicates that neither the growth
in emissions  between 1988 and 2005 nor
implementation  of  the  1990 CAAA  at
sources  in the  Southwest  will have an
appreciable effect on visual range in Class I
areas.  The  insensitivity  of predicted  visibility
changes  between the years 1988 and  2005, even
with implementation of  the 1990 CAAA in  the
latter year, is clearly consistent with the  relatively
small  changes  in  SO2,  NOX, and  particulates
during this period.
4.2.4  Potential Impact of an Acidic Deposi-
       tion Standard on Visibility
For this study, visibility in the East was calculated
using the RADM EM-VIS model for two SO2 emis-
sions scenarios described  in Chapter 3. Visible
ranges for the post-2010  full implementation sce-
nario and for the additional utility and industrial
SO2 reduction scenario (approximately 44 percent
decrease in SO2 emissions beyond CAAA reduc-
tions) were calculated for 90th-percentile  worst
days. Maps in Exhibits 62 and 63 show percentage
changes in annual average  visibility for these two
scenarios between 1985 and 2010. To assess the
impact of  changes in visibility  due  only to  de-
creases in ambient sulfate concentration, visibility
impairment from other ambient species remained
constant in the models.

The greatest  improvements in  visual range  be-
tween  1985 and the baseline scenario in 2010 lie
in a band from northern Mississippi to southwest-
ern New York State. Improvements in visibility for
Class I areas  in the  mid-Atlantic region, which in-
cludes  the  Great  Smoky  Mountains  and  the
Shenandoah Valley, range between 30 percent and
more than 40 percent. For  the additional SO2 re-
duction case, improvements in visual  range of
greater than a factor of two are predicted for these
key mid-Atlantic areas. Increases in visual range of
60 to 100 percent (i.e., the ability to  see twice as
far) are predicted for coastal areas and New Eng-
land.
Geographic Region
Central Coast
Sierra
Southern California
Desert Southwest
Golden Circle
Rockies
Representative
Class I Areas(s)
Pinnacles
Yosemite
San Gorgon io
Chiricahua
Grand Canyon
Arches
Rocky Mountain
Bandelier
Visual Range (km)
1988
96
104
68
118
134
116
121
119
2005
CAAA
94
101
66
115
132
115
120
116
  The study conducted by EPA for Class I areas in
  the Southwest demonstrates that no single pollut-
  ant or source category is responsible for  most of
  the visibility impairment in that region. Thus,
  EXHIBIT 62. PERCENT INCREASE IN VISUAL RANGE FROM
   1985 TO 2010 WITH FULL CAAA IMPLEMENTATION
  while an acid deposition  standard could  reduce
  ambient sulfate, nitrate, or NO2 levels, projection
  of potential improvements in visibility for specific
  Class I  areas  would  require  additional  model
  analysis.

  4.3  RELATIONSHIP OF HUMAN HEALTH TO
       ACIDIC DEPOSITION
  Exposure to  SO2,  paniculate matter (including
  acidic aerosols), NO2, and ozone (O3) in ambient
  air can cause adverse health effects. (Ozone is a
                                               83

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ACID DEPOSITION FEASIBILITY STUDY
    EXHIBIT 63. PERCENT INCREASE IN VISUAL RANGE
       FROM 1985 TO 2010 WITH ADDITIONAL
          SO2 REDUCTION BEYOND CAAA
related concern for acidic emissions and deposi-
tion standards because NO2 is a major precursor in
O3 formation.) Possible health  effects  related to
acidic deposition and its precursors are quite com-
plex because of the variety of pollutants, possible
routes of  exposure, and mechanisms involved
(Exhibit 64).

         EXHIBIT 64. RELATIONSHIP OF ACIDIC DEPOSI-
             TION PROCESSES TO HEALTH EFFECTS
                Nitrogen Oxides
                                  VOCs
   Nitrates
  Sulfates
The potential health benefits derived from reduc-
tions in fine particulate mass, SO2, and NOX emis-
sions resulting from Title IV as well as additional
reductions beyond the CAAA have not been mod-
eled for this study. Several health issues are briefly
outlined here, however, because of the  potential
benefit of an acid deposition standard. Current ap-
plicable standards include National Ambient Air
Quality Standards (NAAQS) for SO2, NO2, and O3.
The 10-million ton SO2 emissions reduction from
1980 levels under Title IV is expected to result in
human health  benefits and potentially high mone-
tary savings due to reduced mortality and morbid-
ity  effects associated with SO2 and fine particle
exposures.

The following subsection  summarizes health ef-
fects and potential risks associated with airborne
acidic pollutants. Current  knowledge on possible
future  risks to  human  health  associated with
changes in acidic deposition  rates is summarized
in the second subsection.

Several  respiratory  problems can be caused by
ambient air concentrations  of  SO2, particulate
matter (including acidic aerosols),  NO2, and O3
(separately  and  in combination).  Effects include
chronic  bronchitis,  bronchoconstriction,   other
pulmonary  function  impairments, chest discom-
fort, cough,  lung  inflammation,  increased inci-
dence of infectious  respiratory disease, and in-
creased  mortality  rates.  The elderly,  the very
young,  and individuals  with  pre-existing respira-
      tory  diseases,  such   as  asthma,  are  at
      greatest risk and  would benefit most from
      reductions    in     the     atmospheric
      concentrations of these pollutants.

      Under Sections 108 and 109 of the CAAA,
      EPA  establishes  primary NAAQSs,  which
      protect the most  sensitive segments of  the
      population,  with an  adequate margin  of
      safety. The additional emissions reductions
      achieved  by an  acid  deposition  standard
      would facilitate the attainment and mainte-
      nance of the primary  NAAQS established
      under Sections 108 and 109 of the Act.

      A number of recent epidemiological studies
      have associated  particle  pollution  with
      excess  mortality  and  morbidity  at levels
      below  the existing   24-hour particulate
      matter  NAAQS.  For  example, a  decade-
      long, six-city study  provided evidence of a
strong   association  between  fine  particulates,
including sulfate, and  mortality  in  humans and
also indicated that acidic aerosol concentrations
were directly associated with increased prevalence
                                                84

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                                             CHAPTER 4:  POTENTIAL BENEFITS OF A STANDARD ON VISIBILITY,
                                                   HUMAN HEALTH, MATERIAL, AND CULTURAL RESOURCES
of bronchitis in children.78 Clinical studies suggest
that asthmatics may exhibit sensitivities to  short-
term exposures to acidic aerosols. As a result, the
EPA has  initiated the  review  of the air quality
criteria  and  standards for  particulate  matter,
including  acidic  aerosols.  Additional  research
shows that sulfate aerosols comprise the majority
of acidic aerosols in ambient air and a large share
of total ambient inhalable particulate matter  in the
eastern United States.79

Based on the available data, many in the scientific
community believe that if the  mortality and mor-
bidity effects observed in these studies are causal,
the agent(s) is more likely to be fine particles (<2.5
Urn) than coarse particles (2.5 to 10 Lim). If it is de-
termined, after completion of the ongoing review,
that a new fine particle standard(s) is appropriate,
the associated control  strategies will focus on the
control of the precursors (e.g.,  SO2,  NOX, ammo-
nia, and condensible hydrocarbons) to secondary
fine  particles.  Thus,   the  emissions  reduction
objectives of an acid deposition standard would be
compatible with those of  a potential new fine
particle NAAQS.

Insofar as acidic SO42' trends roughly parallel total
SCVtrends, NAPAP estimated  that between 2000
and 2020, the region generally incorporating the
states of Ohio, Indiana, West Virginia, Pennsylva-
nia, New Jersey,  Maryland, Virginia, North  Caro-
lina, Kentucky, Tennessee,  and northern Georgia
could  experience  the greatest  decrease  in acidic
sulfate levels from implementation of the CAAA.80
The upper Midwest (Michigan and Wisconsin) and
the upper Northeast (Maine and New Hampshire),
which had lower ambient 1-hour sulfate levels, are
estimated to have only slightly improved atmos-
78 D.W. Dockery, C.A. Pope, X. Xu, J.D. Spengler, J.H.
  Ware, M.E. Fay, B.C.  Ferris, and F.E. Speizer. 1993.
  An association between air pollution and mortality
  in six U.S. cities. New England Journal of Medicine
  329:1753-1759.

79 L.C. Chestnut and A.  Patternson. 1994.  Human
  Health Effects Benefits Assessment of the Acid Rain
  Provisions of the 1990 Clean Air Act Amendments.
  (Draft methodology report.)  Prepared  for the Acid
  Rain  Division,  U.S.  Environmental  Protection
  Agency, Washington,  DC. (Currently being prepared
  for peer review.)

80 This section is drawn primarily from  the National
  Acid Precipitation Assessment Program, 1991 (7990
  Integrated Assessment Report. NAPAP  Office of the
  Director, Washington, DC.).
pheric concentrations in the years 2000 and 2020
under  this scenario. Several ongoing  benefit as-
sessments will address the  extent  of monetary
health  benefits associated with implementation of
Title IV.

With respect to NO2, no area of the  United States
presently exceeds the NAAQS of 0.053 ppm, an-
nual average.  The attainment of  the annual stan-
dard also significantly limits the likelihood and
magnitude of  short-term  1-hour peak NO2 levels.
NO2 and its transformation products,  however, are
precursors to O3 formation.  Consequently, reduc-
tions in NO2  or NOX emissions  are key compo-
nents of the O3 control strategies.

4.4  RELATIONSHIP OF MATERIALS DAMAGE AND
     CULTURAL RESOURCES TO ACIDIC
     DEPOSITION
All materials exposed to the outdoor environment
are subject to  degradation  caused  by  natural
weathering  processes  involving  moisture, heat,
oxygen, solar  radiation,  bacteria, and fungi. Ad-
verse effects from these processes can  be acceler-
ated by deposition of wet and dry acidic air pol-
lutants. Several NAPAP reports, including the State
of the Science and Technology Report  No. 19, the
1990 Integrated Assessment  Report, and the 1992
Report to Congress, considered the delivery of wet
and dry deposition to various types of material sur-
faces, particularly in urban areas.

4.4.1  Acidic Deposition Effects on Materials
       and Structures
Research  conducted by  NAPAP and  other  pro-
grams  confirms that certain metals such as galva-
nized steel are corroded (Exhibit 65), surface coat-
ings are degraded,  and  carbonate  stone is dis-
solved by SO2, wet-deposited acids, and  natural
atmospheric acidity from dissolved CO2.  Spotting
of automotive  finishes  can also occur from acidic
deposition.

To illustrate the potential role of acidic deposition,
Exhibit 65   shows   that  an   estimated  31 to
78 percent of  the  dissolution  of  galvanized  steel
and copper continues to be attributable to wet and
dry acidic deposition.  Acidic  deposition can also
accelerate  deterioration  of  stone through three
processes: dissolution and erosion of  material  or
surface features; blackening of the stone surface;
and  cracking,  splintering, and chipping  of  the
stone surface.  One of the most visible and docu-
mented forms of pollutant damage  to limestone
                                                85

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 ACID DEPOSITION FEASIBILITY STUDY
             EXHIBIT 65. PERCENTAGE OF METAL CORROSION ATTRIBUTED TO ATMOSPHERIC FAcroRsa-b
Metal
Study Region
Galvanized Steel
Adirondack Mtns, NY
Washington, DC
Steubenville, OH
Copper
Adirondack Mtns, NY
Washington, DC
Steubenville, OH
Corrosion Rate
(um/yr)
0.62±0.26
1.01 ±0.42
1.47±0.21
0.37±0.14
0.83±0.19
0.88±0.29
Dry Deposition
of Sulfur
6%
52%
56%
10%
38%
57%
Acidity
(hydrogen ion con-
centration)
25%
23%
22%
25%
25%
20%
Other Corrosion
Factors
69%
25%
22%
65%
37%
23%
  a  Source: NAPAP. 1993. 1992 Report to Congress. National Acid Precipitation Assessment Program, Washington,
    DC.
  b  Corrosion rates are mean measurements from NAPAP field sites.
and marble is the accumulation of dark gypsum (a
mineral formed from calcium sulfate and water)
crusts in areas sheltered from rain. Sulfur deposited
onto carbonate stone  (e.g.,  marble)  reacts with
calcite to form a black crust containing a mixture
of gypsum, fly ash particles,  soot, and  biological
growth, all of which  can cause decay deeper into
the stone. Laboratory and field studies show a cor-
relation between dry deposition of SOX and a thin
black accumulation on masonry materials, includ-
ing sandstone, granite, and brick. European studies
show that SO42- and  NO3- concentrations in stone
occur in proportion to atmospheric concentrations
of SO2 and NOX. Erosion rates of stone in Europe,
however, are significantly greater than those found
in North America because of the higher ambient
concentrations of acidic deposition precursors in
Europe.

Rates of  damage  to materials associated with
acidic deposition  depend on  atmospheric  and
structural factors that  influence delivery of the pol-
lutant to  a material's surface, i.e.,  regulate  its
"dose." Wet deposition delivers atmospheric pol-
lutants to  surfaces of  buildings,  structures,  and
other objects primarily through rainfall, snowfall,
fog,  dew,  and frost.  Dry deposition provides a
more constant delivery of pollutants as large parti-
cles fall with gravity and small particles and trace
gases are  delivered  by atmospheric  turbulence.
Pollutants delivered by turbulent processes can po-
tentially damage a greater proportion of material
surfaces than can large particles. Also,  a damp sur-
face provides a much more effective sink for sol-
uble trace gases (e.g., SO2) than does the same sur-
face when dry. Thus, dry deposition can often be
intimately linked with the processes by which ma-
terial surfaces are wetted.

The key effect of concern for cultural materials is
physical damage, often expressed in terms of the
time it takes for the material to lose its  unique
qualities. For construction materials, the key effect
of concern is the expenditure to maintain an ac-
ceptable level  of functionality  and appearance
over the life of the structure.

NAPAP studies reveal that U.S.  regions with the
largest number of cultural and  historical  monu-
ments also often have the highest levels of acidic
deposition, including areas of the Northeast having
long settlement histories and the greatest number
of pre-Civil War buildings and  tombstones.  Most
historic battlefields,  especially  those with com-
memorative monuments, are  located east of the
Mississippi. Also, material  selection  has changed
over time;  more durable materials have replaced
acid-sensitive  marbles,  sandstones,  and  zinc,
which  were  predominantly used prior to large-
scale western expansion and  late  19th-century
population increases. Distributions of acid-sensi-
tive cultural materials are therefore expected to be
less dense west of the Mississippi.

4,4=2  Material Life-Cycle and Damage
       Estimates
Potential acidic deposition-related damage to both
function  (e.g.,  building  material, bridges,   and
automobile and  other exterior coatings)  and cul-
tural value (e.g., historical monuments and sculp-
                                                 86

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                                             CHAPTER 4:  POTENTIAL BENEFITS OF A STANDARD ON VISIBILITY,
                                                   HUMAN HEALTH, MATERIAL, AND CULTURAL RESOURCES
tures) potentially represent a very large overall cost
to society. Acidic deposition control can therefore
be  linked to potentially large  monetary benefits.
Relating acidic deposition-induced physical dam-
age  to  the  shortened  usefulness of materials re-
mains an important area of research. Quantifying
changes in  maintenance and  replacement cycles
attributable to changes in acidic deposition is nec-
essary for estimating the economic consequences
of physical  deterioration. The  complexity of this
linkage  involves three primary areas:

  * Extrapolation  of  laboratory  findings  to
     doses on large structures caused by  ambi-
     ent exposure;

  * Tolerance to decay by acidic deposition,
     which varies with the specific function of
     the material within the structure; and

  * Maintenance  and  replacement  cycles,
     which can be affected by a great many fac-
     tors other than acidic deposition, including
     market factors.

Clearly,  emissions  reductions  can minimize  the
need for or frequency of public and private main-
tenance, repair, and replacement. EPA and NAPAP
are working on approaches to estimate the damage
to materials from acidic deposition. Assessing ma-
terial effects present an array of options for valuing
damages, costs, and benefits of emissions reduc-
tions in  physical terms (e.g., corrosion rates and
reduced service life), market terms (e.g., life-cycle
costing  and shifts in material selection and market
share), and nonmarket terms (e.g., heritage valu-
ation of  damage  to historical monuments and
buildings). Several  efforts have been initiated  to
determine  the  material damage costs  associated
with  acidic deposition; damage to automotive
coatings are highlighted here as one example of
analyses. EPA and NAPAP have begun  to investi-
gate the costs  of damage  to  automotive finishes
and  subsequent savings attributable to CAAA im-
plementation.

Spotting of automotive finishes  can occur from
acidic deposition.  This  effect is most pronounced
on dark finishes and in warmer climates,  because
the rate  of chemical  reactions causing  spotting
increases with temperature. The damage, typically
appearing as irregularly shaped etched  areas, oc-
curs after  evaporation  of  a  moisture  droplet.
Automotive coatings may be damaged by all forms
of acidic deposition, particularly when dry deposi-
tion is mixed with dew or rain. It has been diffi-
cult, however, to quantify the specific contribution
of acidic deposition to paint finish damage relative
to other  forms of  environmental fallout,  the im-
proper application of paint, or  deficient paint for-
mulations.

Although the existence of damage to automotive
coatings  has been  well documented,  there has
been little analysis of the economic costs imposed
by this damage. Such an analysis may include in-
vestigation  of issues such as actions taken to pre-
vent the  negative effects of pollution (i.e., actions
taken  by car  and  truck manufacturers)  and the
market value of a car or truck damaged by  acidic
deposition  (i.e., actions taken by automobile deal-
ers regarding damage  which  has occurred).  The
scoping exercise conducted by EPA and NAPAP
begins to illustrate the potentially large costs asso-
ciated with this type of damage and therefore the
significant benefits of the Acid Rain Program.81 For
example, estimates of annual costs to manufactur-
ers of cars  and trucks  for including acid-resistant
features can be as  high as $400 million. Estimates
of the value of potential annual  residual damage to
cars and trucks in the eastern  United States may
range from  $50 million to over $400 million. Total
annual costs could be $96 million to $850 million.

Additional  materials damage and pollution reduc-
tion benefit efforts are also underway to  determine
the benefits of acidic deposition control on a func-
tional item  such as steel bridges as well  as the po-
tential  benefits of control to  preserve cultural re-
sources of  historical importance. Damage to cul-
tural resources can result in potentially high  repair
and maintenance costs, replacement costs, and the
value placed  on one-of-a-kind resources.  These
and other costs associated with acidic deposition-
induced  damage would  likely  decrease with im-
plementation of an acid deposition standard.
                                                    81 ICF Incorporated. September 30,  1994.  Add Rain
                                                      Program Evaluation: Valuing Potential Reductions in
                                                      Automobile Finish Damages-Scoping Study.
                                                87

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                                          CHAPTER 5

                                  IMPLEMENTATION ISSUES
5.1  INTRODUCTION
In order to determine the effectiveness of an acid
deposition standard for protecting  sensitive  re-
sources, it is necessary to know not only the bene-
fits that would result from a given standard  if it
were achieved, but also to know how the standard
would be implemented.

In Section 404 of the CAAA, two requirements that
Congress laid out for this acid deposition standard
feasibility study dealt with implementation issues.
The statutory language calls for:

   * Description  of the measures  that would
     need to be taken to integrate such standard
     or standards  with  the control program re-
     quired by Title IV of the Clean Air Act; and

   * Description of the impediments to imple-
     mentation of such control program and the
     cost-effectiveness of deposition  standards
     compared to other  control strategies in-
     cluding ambient air quality standards, new
     source performance standards and the re-
     quirements of Title IV of the Clean Air Act.

This chapter describes  two basic approaches to
implementing  an acid deposition standard. Under
the first approach, EPA would set  a  standard or
standards, either using existing authority or seeking
further  authority from Congress to set such stan-
dards and provide deadlines  for their attainment.
Then,  similar  to Title I, states would determine
source-specific limits using source-receptor models
and cost analyses,  incorporate those limits in state
implementation plans (SIPs), and enforce them. If
one or more states failed to do the  above,  EPA
would promulgate a Federal implementation plan
(FIP).

Under the second approach, Congress would di-
rect EPA to set a deposition standard or standards
and to determine the national (or regional) emis-
sions levels for sulfur dioxide and nitrogen oxides
that would meet those standards. Congress would
then set an  emissions cap and allowance  alloca-
tions for nitrogen  oxides and, if necessary,  adjust
the cap for sulfur dioxide in Title IV; and provide a
timetable  for meeting the new caps. EPA would
use Title IV provisions to implement the emissions
programs.

For these two basic approaches, this chapter will:

  * Describe how  each  would  be  imple-
     mented,  including  any  measures  that
     would need to be taken to integrate it with
     Title IV;

  * Describe any impediments to implementa-
     tion, including the need for any additional
     statutory authority; and

  * Discuss their relative cost-effectiveness.

To  provide a rough comparison of the cost-effec-
tiveness of the two approaches for sulfur reduc-
tions, estimates are made of the cost of achieving
the same reduction in sulfur deposition at the three
sensitive areas under each approach. The example
used is based on a 50  percent reduction in na-
tional utility SO2 emissions beyond that required
by the 1990 CAAA (as described  and modeled in
Chapter 3).  The  use of  this example in  no way
suggests that such a reduction is necessary, appro-
priate, or sufficient, but is merely put forth for il-
lustrative purposes.

There are, of course, many variations on these ba-
sic approaches, and probably other ways to realize
the goals of an acid deposition standard. The pur-
pose here is not to provide a complete examina-
tion of  this  issue,  but to show how existing ap-
proaches could be adapted to implement such a
standard and to compare costs.

5.2  TARGETED APPROACH
5.2.1  Description of Targeted Approach
EPA would either set national standards for sulfur
and nitrogen deposition,  or set different  regional
standards for sulfur and nitrogen based on the dif-
ferent sensitivities of different regions to sulfur and
nitrogen. (See 5.2.3 for a discussion  of statutory
authority.) EPA would also  establish deadlines for
the  attainment  of such  standards,  unless  such
deadlines were established  through  new statutory
authority.
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ACID DEPOSITION STANDARD FEASIBILITY STUDY
States  would determine  the  form and level  of
emissions limits for the sources of sulfur and nitro-
gen that they determine relevant to the attainment
of the national acid deposition standards. Their de-
terminations would probably be based on  atmos-
pheric models and technical and cost analyses of
the sources within their jurisdictions.

The process for making these determinations and
incorporating such limits into  SIPs would vary
from state to state. Some  states may wish to pro-
vide flexibility to their sources by allowing various
forms of emissions trading. EPA would need to re-
view each SIP  and determine that it, in conjunc-
tion  with other  relevant  SIPs, would  attain and
maintain  the specific acid deposition standard  or
standards. States would be responsible for collect-
ing emissions information and enforcing limits. If
states failed to carry out these  responsibilities, EPA
would impose  sanctions  and/or prepare and im-
plement a FIP.  EPA would implement such a pro-
gram  through Titles  I,  II,  and  V. The program
would be evaluated through deposition and effects
monitoring.

5.2.2   Integration with  Title IV
Setting an acid  deposition or standards would not,
by itself,  directly  affect other environmental pro-
grams unless it  required emissions reductions. The
specific sources and  level of emissions reductions
would determine the  direct impact on other pro-
grams and usefulness  of coordination and integra-
tion.

If no changes were made to Title IV, the allocation
and transfer of allowances would not be restricted
by state actions to set new emissions  limits, but
sources would not be able to emit more SO2 than
their state limits allow, regardless of how many al-
lowances  they might  hold. This is the same situ-
ation as currently exists, but if more stringent limits
were imposed on a large  number  of sources, the
demand for and  price of allowances would de-
cline.  In fact, taken to extreme if the aggregate ef-
fect of new  source-specific state  limits were to re-
duce utility  SO2 emissions below the current 8.95
million  allowance cap and the SIPs did  not allow
emissions trading, the price of allowances  should
theoretically drop to zero because they  would be
of no use.

Both in setting the level of the standard and in its
implementation,  an acid  deposition standard or
standards  should  be  coordinated and  potentially
integrated with several other  environmental pro-
grams, particularly attainment and maintenance of
primary  and  secondary  National  Ambient  Air
Quality Standards (NAAQS) for SO2, NO2, O3, and
PM10; visibility protection; new source review; and
new source performance standards under Title I of
the CAAA. It would also be useful  to coordinate
acid deposition standard-setting and implementa-
tion with water quality programs, particularly in-
volving eutrophication of estuaries. Substantial re-
ductions  in  SO2  or NOX  could  assist  in the
achievement of the goals of these programs.

5.2.3  Impediments to Implementation
It may be possible to set acid deposition standards
under existing statutory authority.  At this time, no
definitive determination has been made. However,
clear direction from  Congress  in this  area would
certainly  make implementation more feasible and
effective. For example, implementation would be
facilitated by  explicit authority to set deposition
standards,  to set  regionally  different  nitrogen
and/or sulfur standards, to set deadlines for attain-
ment, to require uniform measurement and report-
ing of emissions for sources not already affected by
Title IV,  and to establish  uniform procedures for
interstate trading of NOX emissions. It would prob-
ably not  be possible for sources to conduct effi-
cient interstate trading  of NOX emissions without
federal legislation.

Time and resource issues may be significant if, for
example,  a regionally  targeted  implementation
approach shared some of the same administrative
complexities as the current SIP process to meet the
NAAQS.  For  instance,  the development of state-
specific regulations by states for emissions limita-
tions, followed by EPA review and approval, can
be a resource-intensive and lengthy process. EPA is
currently  working to streamline this process. An-
other concern is  the incomplete  and  sometimes
inconsistent state  emissions  inventory data  upon
which  compliance  and  effectiveness  is deter-
mined. Furthermore,  if a state is not in attainment
of the  NAAQS, it is commonly a long period of
time  until  state-specific  air  quality  levels are
achieved.   Compliance  deadlines  for  certain
NAAQS have been refined and revised with  each
amendment to the CAA.  The uncertainties of this
process are not usually conducive to long-range
planning  and  cost-effective compliance  by the
regulated community.

The 1990 CAAA recognized the role of long-range
pollutant  transport in ozone formation  and author-
ized EPA to create "ozone transport regions" where
nonattainment in  one state may be the result of
                                                90

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                                                                  CHAPTER 5: IMPLEMENTATION ISSUES
emissions in  another  state.  The  newly created
Northeast Ozone Transport Region extends from
Northern Virginia to Maine. The Northeast  Trans-
port Commission is currently developing plans to
achieve attainment of the ozone standard by de-
termining both  local and transport-region  wide
limits on nitrogen oxides emissions. The Commis-
sion is also considering market-based approaches
(e.g., NOX trading within the transport region) to
achieve maximum protection at least cost. This ef-
fort represents a possible variation on the targeted
regional approach.

Implementation  of a targeted approach  for deter-
mining and maintaining acid deposition standards
would require, at a minimum, an enhancement of
existing deposition monitoring and atmospheric
modeling abilities.  Program requirements  would
need to identify pollutants to  be monitored, and
determine standard procedures for measuring wet
and dry deposition, spatial resolution, and tempo-
ral  requirements.   Enhanced  effects monitoring
(i.e., surface water monitoring) would be desirable
to evaluate effectiveness of the standard or stan-
dards.

5.3  EMISSIONS-BASED APPROACH
5.3.1  Description of Emissions-Based Ap-
       proach
Congress would direct EPA to provide (1) a range
of target loads and emissions levels of sulfur and
nitrogen designed to provide a range of ecosystem
protection  (and  other benefits), (2) levels  of na-
tional and  regional sulfur and nitrogen  emissions
that met those target loads, and (3) estimates of the
benefits and costs of meeting those emissions lev-
els.

Taking this information  into  account,  Congress
would amend Title IV of the CAAA by setting an
allowance  cap for  nitrogen, revising the cap for
SO2 (if necessary), including any new source cate-
gories (if  necessary),  allocating  allowances,  and
providing timetables for the achievement  of the
new caps. EPA would  implement through con-
forming changes to the Title IV rules. The program
would be evaluated through deposition and  effects
monitoring.

5.3.2  Integration with Title IV
Depending on any statutory changes  enacted, EPA
would make conforming  changes  to the Title IV
implementing regulations, 40 CFR Parts 72-78. Ti-
tle  IV permitting,  allowance trading,  emissions
monitoring,  penalty provisions and  data systems
would be used to ensure compliance. Since the in-
formation that EPA would provide Congress as in-
put to their deliberations in setting allowance caps
would include all human health and  ecosystem
impacts from sulfur and nitrogen known to EPA at
the time, coordination with standard-setting  and
implementation  of the other air and water  pro-
grams cited above would be greatly facilitated. If
the number of SO2 allowance were lowered, al-
lowance prices would rise.  In certain cases, com-
pliance strategies of affected sources may change.

5.3.3  Impediments to Implementation
New statutory authority would be needed. Title IV
allowance levels for SO2 cannot be changed with-
out Congressional  actions,  and there is currently
no allowance program for NOX.

Administrative  impediments would  be  limited to
any difficulty posed by the statutory changes. Cur-
rently, Title IV does not appear to have any signifi-
cant administrative or compliance  impediments.
Enhanced  effects monitoring (i.e.,  surface water
monitoring) would be desirable  to track the effec-
tiveness of deposition reductions.

5.4  ECONOMIC IMPACTS
If an acid deposition standard involves emissions
reductions and requires stricter SO2 and NOX point
source emissions controls, that standard would re-
sult in direct cost increases to utilities  and indus-
trial sources. The magnitude of cost increases, and
the sectors most affected would vary depending on
the regulatory approach selected, the quantity of
emissions reduced, the sources affected,  and the
timing of the reductions. For the scenarios consid-
ered in this study, at least two comprehensive  sec-
tor  models—one for the electric utility  industry
and one for the industrial sector—would  need to
be  applied  to fully understand  the  wide ranging
impacts that would result from an acid  deposition
standard. While such models exist, budget con-
straints did not allow for their use for  this study.
An  expanded  economic analysis would consider
variations in emissions and the timing of achieving
emissions reductions.

While the use of more precise sector models  may
become necessary if further emissions  reductions
are pursued, the scale of the economic  analysis
presented here is scoping in nature and limited in
its degree of detail. Instead, this study uses:
                                               91

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
   » Analyses of the electric utility sector that
     have already been conducted  by EPA to
     support Title IV.

   * A spreadsheet-based scoping model to esti-
     mate broadly the range of costs associated
     with different regulatory approaches.

 In Chapter 3,  the  impacts of various SO2 control
 strategies on deposition  in sensitive regions were
 evaluated for the year 2010. The costs of the key
 emissions control strategies described in Chapter 3
 are evaluated below. Costs are estimated for the
 following control scenarios for the year 2010.

   * 2010 CAAA Scenario,

   » Additional  50 Percent Utility SO2 Reduc-
     tion Scenario,

   » Additional 50 Percent Utility and Industrial
     SO2 Reduction Scenario, and

   * Geographically Targeted  Utility SO2 Re-
     duction Scenarios.

 The costs of additional utility and industrial NOX
 reductions  are described qualitatively.  With the
 exception of  the  geographically targeted utility
 SO2 reduction scenario, all cost  scenarios are
 based on a national emissions-based approach.

 5.4.1  2010 CAAA Scenario  (With Trading)
 The 2010 scenario with trading described in Chap-
 ter 3 is used as the baseline scenario for compar-
 ing costs of alternative emissions reductions sce-
 narios. The costs of this scenario were developed
 as part of the 1993 EPA Base Case Analysis82 used
to support rulemaking  under Title  IV and have
thus,  been  reviewed extensively.  EPA has esti-
 mated that compliance with Title IV of the 1990
CAAA will cost  electric utilities about 2.2  billion
dollars in the  year 2010 (Exhibit 66).  SO2 emis-
sions forecasts project that SO2 emissions decrease
by about 9.2 million  tons in 2010. This means that
the average cost of reducing SO2 is about $240 per
ton SO2 removed. The marginal SO2 removal cost
(i.e., the cost  of reducing  one additional ton of
SO2)  is  forecast to  be  much  higher,  however,
about $500 per ton SO2 removed.
82 Economic Analysis of the Title IV Requirements of
   the 1990 Clean Air Act Amendments.  1994.  U.S.
   EPA, Office of Air and Radiation, Acid Rain
   Division, February.
With Title IV fully implemented,  electric utility
SO2 emissions are forecast to equal about 9.5 mil-
lion tons in 2010. This is higher than the 8.95 mil-
lion ton SO2 allowance cap that is binding in 2010
because:

It is forecast that about 0.52 million tons of allow-
ances would be "banked" between 1995 and 2009
and used in 2010; and

Units not affected by Title IV  (i.e.,  those with
nameplate capacity less than 25 megawatts) would
emit about 0.05 million tons of SO2 in 2010.

Exhibit 66 shows utility costs  and  SO2 emissions
forecasts in 2010 by U.S. census region. As can be
seen in the exhibit, the majority of SO2 emissions
reductions and compliance costs (about 60 percent
of the U.S. total) are expected to occur in the cen-
tral  United  States  (i.e.,  East  North  Central and
West South Central Census Regions).

5.4.2  50 Percent Utility SO2 Reduction Sce-
       nario
For the 50 Percent Utility SO2 Emissions Reduction
Scenario, the 8.95 million ton  electric utility SO2
emissions cap was cut in half (i.e., set equal to
4.48 million tons SO2). Under  this  scenario, costs
are estimated to increase to  $4.8 billion and SO2
emissions are estimated to decrease  by an addi-
tional 5 million tons in 2010 relative to the CAAA
Scenario (Exhibit 67). The average cost of reducing
SO2 emissions by 5 million tons is about $955 per
ton SO2 removed, which  is almost four times the
average cost of  emissions reductions  forecast in
the CAAA Scenario (i.e., $240 per ton  SO2  re-
moved). The marginal cost  of reduction  is also
much greater than  in  the  CAAA  scenario  (i.e.,
about $1,225 per ton SO2  removed versus $500
per ton SO2 removed).

Costs and unit level SO2 emissions for the 50 per-
cent electric utility reduction scenario were fore-
cast using EPA retrofit scrubber cost  assumptions
and unit level SO2 emissions forecast in the CAAA
Scenario. It was assumed that SO2 emissions  re-
duction  would be achieved  by unscrubbed coal-
fired units not already forecast to  use low sulfur
coal in the CAAA scenario (i.e., unscrubbed units
forecast to have an SO2 emissions rate greater than
0.8 Ibs SO2 per million Btu). Using EPA scrubber
cost assumptions used in  the 1993  Base  Case
Analysis, costs were estimated for achieving the
5.0 million ton SO2 emissions reduction.
                                                92

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                  CHAPTER 5: IMPLEMENTATION ISSUES













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                                                                   CHAPTER 5: IMPLEMENTATION ISSUES
5.4.3  50 Percent Utility and Industrial SO2
       Reduction Scenario
Under this  scenario, the 50  percent utility SO2
emissions reduction  is no different than described
above. However, it is supplemented by a 50 per-
cent reduction from industrial  sources. As a result,
costs are estimated  assuming electric  utility and
industrial sources achieve a total reduction in SO2
emissions of about 7  million tons in 2010 relative
to the CAAA Scenario  (Exhibit 68).  Under the
CAAA Scenario, utility and  industrial sources are
estimated to emit about 9.5 and 4.0 million tons of
SO2 in 2010 respectively. Commercial/institutional
sources are expected to emit an additional  0.2 mil-
lion tons. The cost  of achieving the 50  percent
electric utility and industrial source SO2 emissions
reduction is estimated to be about $6.5  billion
annually. This corresponds  to an average SO2
emissions reduction  cost of  about $926  per ton
SO2 removed. As described  in the previous sec-
tion,  the average  cost of reductions for electric
utilities is about $955 per ton SO2 removed, and
the average cost for  industrial  sources is estimated
to be about $850 per ton  SO2 removed.

5.4.4 Geographically Targeted  Reductions
       Scenario
Costs were calculated for both the contiguous and
noncontiguous geographically targeted reduction
scenarios corresponding  to  the deposition  levels
achieved by the 50 percent nationwide SO2 utility
reduction scenario for all three sensitive receptor
regions and for all three regions together.  These
scenarios were constructed by sequentially remov-
ing 95 percent of utility SO2 emissions (remaining
after  implementation of  the Title IV)  from subre-
gions (either contiguously or in order of contribu-
tion to deposition) until the deposition  loads were
achieved. Ninety-five percent SO2 emissions re-
moval was necessary given the smaller number of
sources from which to draw emissions. Costs were
estimated by applying the EPA retrofit scrubbing
cost assumptions to achieve  95 percent  SO2 re-
moval from utility boilers identified in each subre-
gion. Exhibit 69a provides costs for achieving the
target  deposition loads for  each receptor region
individually and  for  all  three regions simultane-
ously for the contiguous approach.  Exhibit 69b
provides  the same information for the non-con-
tiguous case.

The total tons removed, about 4.6 million tons, the
annual costs, about  $4.6 billion, and the cost-ef-
fectiveness, about $1,000 per ton removed, are es-
sentially identical for the contiguous and non-con-
tiguous  cases.  Thus, no increase in  efficiency
would be gained by choosing the more complex
non-contiguous approach over sequential contigu-
ous geographical targeting.

Costs were  not estimated for the geographically
targeted  utility and industrial  scenario because
specific cost functions for SO2 removal  from indi-
vidual industrial sources were not available. De-
veloping cost functions for  individual  industrial
sources  would require an extensive cost develop-
ment effort beyond this scoping study.

5.4.5  NOX Reductions—50 Percent Utility
       and Industrial
EPA is  currently developing regulations for the
control of NOX emissions from electric utilities af-
fected under Title IV of the CAAA. Regulations for
Group I  boilers in  Phase I were promulgated on
March 22, 1994.83 Regulations for Group II boilers
are under development and  the costs  and emis-
sions reductions expected from  these regulations
were not available  for this report. Preliminary in-
formation on the cost of controlling NOX emissions
from  various types of  electric   utility  boilers is
available, however, from a  recent EPA report.84
These costs vary significantly depending on the
type  of  technology applied, NOX  control effi-
ciency,  and boiler  specific parameters. Some of
the results presented in that  report are described
below.

Title IV of the CAAA requires EPA to set emissions
limits for Group 1  boilers (i.e.,  dry bottom wall-
fired  and tangentially fired boilers) based on the
application of low-NOx burners  (LNB) at affected
electric utility  units.  In the RIA, which  covers
Group 1 boilers, EPA  estimated that NOX  emis-
sions would decrease by about  1.9 million tons
annually and cost about $0.3 billion annually (an
average  cost of  about  $159  per ton  NOX re-
moved).85 The RIA considers a variety of NOX con-
83 See 59 Fed. Reg.  13538-80.  On November 29,
   1994, the U.S. Court of Appeals for the District of
   Columbia circuit vacated regulations and remanded
   them to EPA for further action. Alabama Power Co.
   v. U.S. EPA. No. 941170 (1994).
84 Alternative Control  Techniques Document - NOX
   Emissions from Utility Boilers, March 1994, U.S.
   EPA, Office of Air Quality Planning and Standards,
   EPA-453/R-94-023.
85 Regulatory Impact Analysis  of  NOX  Regulations,
   February 1994, U.S. EPA Office of Atmospheric and
   Indoor Air Programs, Acid Rain Division.
                                                95

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
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                                               96

-------
                                                                   CHAPTER 5:  IMPLEMENTATION ISSUES
          EXHIBIT 69A: ANNUAL COSTS OF GEOGRAPHICALLY TARGETED REDUCTIONS EQUIVALENT TO NATION-
                    WIDE 50% UTILITY SO2 REDUCTION (CONTIGUOUS RADM SUBREGIONS)

Emissions Reduction (tons)
Cost ($ million)
Cost- Effectiveness ($/ton)
Sensitive Region
Adirondacks
3,018,000
3,131
1,037
Mid- Appalachi-
ans
1 ,952,000
2,127
1,089
Southern
Blue Ridge
1,508,000
1,610
1,068
All Three
Receptor Regions
4,526,000
4,741
1,048
      EXHIBIT 69s: ANNUAL COSTS OF GEOGRAPHICALLY TARGETED REDUCTIONS EQUIVALENT TO NATIONWIDE 50%
       UTILITY SO2 REDUCTION: MAJOR RADM SUBREGIONS CONTRIBUTING TO DEPOSITION (NOT CONTIGUOUS)

Emissions Reduction (tons)
Cost ($ million)
Cost-Effectiveness ($/ton)
Sensitive Region
Adirondacks
3,160,000
3,151
997
Mid- Appalachi-
ans
2,079,000
2,193
1,054
Southern
Blue Ridge
2,081,000
1,952
938
All Three
Receptor Regions
4,658,000
4,523
971
trol technologies.86  Applied to pre-New Source
Performance Standard (NSPS)  coal-fired  electric
utility  boilers, these technologies  are capable  of
achieving NOX emissions reductions of about 10 to
60  percent. On  a  boiler operating in  baseload,
these   technologies  are  estimated  to  cost  from
about $100 to $1,000 per ton NOX removed.

To  reduce electric utility NOX emissions by  more
than required by Title IV, it would be necessary to
apply technologies with NOX removal efficiencies
and costs greater than LNB technology.  It would
be necessary for sources would be required to ap-
ply selective catalytic reduction (SCR) or selective
non-catalytic reduction (SNCR) technologies. SCRs
can achieve  NOX   removal efficiencies  ranging
from 75 to 85 percent.  In combination with  LNB
technologies, SCRs can reach removal efficiencies
of 85  to 95 percent. EPA estimates that  a  stand
alone SCR would cost from $810 to $2,490 per ton
NOX  removed at a coal-fired unit operating  in
baseload. In combination  with  LNB technology,
SCR  application could   cost  about $1,300  to
86 The Court held in Alabama Power Co. v. U.S. EPA
   that EPA's definition of low-NOx burner in  the
   March 22, 1994, regulations was too broad.  That
   ruling  does  not  affect the use  of information
   developed  for the RIA in  this  scoping economic
   analysis.
$2,490 per ton NOX removed. These cost would
be expected to decline with the wide-scale appli-
cation of SCR throughout the electric utility indus-
try, based on economies of scale.

As with utility boilers, a wide variety of NOX con-
trol technologies are applicable to industrial boil-
ers. These include LNB technologies, SNCR, and
SCR. It is usually more cost-effective to apply these
technologies to electric utility boilers than to in-
dustrial boilers because electric utility boilers gen-
erally provide more suitable operating conditions
and economies of scale.

5.4.6  Summary of Economic Impacts
Exhibit 70 summarizes the total costs and costs per
ton of SO2 removed for each reduction strategy for
which  costs were developed. The additional 50
percent nationwide SO2 utility reduction  scenario
is a factor of four less cost-effective than the CAAA
baseline. This is not surprising since the allowance
trading program was designed to achieve maxi-
mum cost- effectiveness, and, thus, utility reduc-
tions beyond  that required by the Act would nec-
essarily be less economically attractive. Additional
emissions reductions would  likely  impact the
emissions trading program  and limit the  compli-
ance flexibility inherent in  the current program.
From Exhibit 70 it is apparent that difference  in
                                                97

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                EXHIBIT 70. SUMMARY OF COSTS OF VARIOUS EMISSIONS REDUCTIONS SCENARIOS
Scenario
CAAA baseline
50% utility SO2 removal
Targeted utility SO2 removal
(contiguous)
Targeted utility SO2 removal
(not contiguous)
50% utility and industry SO2
removal
SO2 Removed
(Tons x 1000)
9,166
5,047
4,526
4,658
7,047
Annual Cost
($ Billion)
2.2
4.8
4.7
4.5
6.5
Cost-Effectiveness
($/Ton SO2 Rem.
in 1994 dollars)
240
955
1,048
971
926
costs between the nationwide and geographically
targeted SO2 emissions  reductions strategies to
achieve the same level of deposition are not sig-
nificant. Therefore, there  does not appear to be a
significant cost  advantage to  adopting a  geo-
graphically  targeted  approach  to  achieving the
deposition levels attained by the nationwide 50
percent SO2 utility reduction  scenario.  Interest-
ingly, the 50 percent utility and industrial reduc-
tion scenario is about equal in cost-effectiveness to
the 50 percent utility reduction scenario. This indi-
cates that emissions reductions from major indus-
trial sources would be as cost-effective as addi-
tional utility reductions.

The costs presented in this economic analysis were
based on conventional  SO2  scrubbing and are
scoping in nature/These costs should be viewed as
conservative (i.e., over-stated)  in that within the
time frame  in  which acid deposition standards
could be developed, newer innovative technolo-
gies may  become  available which may be  less
costly  than  conventional  scrubbing,  including
clean coal technologies,  repowering with natural
gas, or increased use of pollution prevention tech-
nologies such as renewal energy and conservation.

If further emissions reductions were mandated by
Congress in order to implement an acid deposition
standard, there may be a greater impetus for the
commercial  deployment  of clean coal technolo-
gies in the U.S. market place as well as other re-
powering or pollution prevention technologies.

5.5  CONCLUSIONS
In this chapter,  the discussion has been focused on
implementation  issues  associated  with an  acid
deposition  standard.  Assuming that a  decision
were made to reduce emissions of sulfur dioxide
and/or nitrogen oxides beyond the current Clean
Air Act to address the acidification of surface wa-
ters  and/or the multiple effects associated  these
pollutants, it is feasible to implement such an ap-
proach. There are different approaches that could
be  taken  and various factors to  be considered
(administrative complexity, resource demands on
the government and regulated industry, costs, in-
teractions with other programs). Based on the mul-
tiple effects of acidic deposition and its sulfur and
nitrogen precursors, it is recommended that if fur-
ther emissions reductions are pursued, they be as
broad as possible; either a national approach or a
regional approach that incorporated a large area of
the country (e.g., east of the Mississippi River).
Furthermore,  Title IV is  an administratively  effi-
cient way to achieve emissions reductions with the
basic infrastructure  already set up under Title IV
being well-suited to incorporate further sulfur di-
oxide and  nitrogen  oxides emissions reductions.
The  costs of further  emissions reductions  charac-
terized in this report could lead to costs that are
more than double those  of the current acid rain
control program, but the timing of those reductions
would affect the costs and the benefits. The bene-
fits would likely be in multiple effects areas. Com-
pliance costs could  be significantly impacted by
the timing of any further emissions reductions. Any
additional reductions which may be required later
rather than earlier may cost less based on cost-sav-
ing technologies demonstrated through clean  coal
technology and  pollution prevention efforts and
based on the replacement of  existing sources by
new, lower emitting sources.
                                                98

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                                        CHAPTER 6

                          INTEGRATION AND CONCLUSIONS
6.1  INTRODUCTION
Section 404 Appendix B of the Clean Air Act di-
rects  EPA  to  assess the feasibility and environ-
mental effectiveness of an acid deposition standard
or standards to protect sensitive ecosystems. This
chapter  summarizes  and  integrates the findings
from the previous chapters  showing how scenarios
for potentially  reducing  acidic  deposition  de-
scribed in  Chapter  3  address environmental goals
defined  in  Chapter  2.  Chapter  4  described
potential  benefits  to  visibility,   human  health,
material,  and  cultural  resources accompanying
additional   reduc-tions  in   acidic  deposition.
Chapter 5 addressed feasibility and effectiveness of
implementing a deposition  standard.

Section 6.2 highlights the conclusions that are key
to establishing effective environmental  goals and
efficient deposition control strategies. Section 6.3
then integrates these findings to show the potential
surface water  benefits from a selection of alterna-
tive emissions reduction scenarios, considering a
range of times to watershed nitrogen saturation.

6.2  ESTABLISHING EFFECTIVE ENVIRONMENTAL
     GOALS
Defining appropriate environmental goals and pro-
jecting future  effectiveness of various control op-
tions  requires  characterizing potential  environ-
mental effects and  benefits over a range of  sulfur
and nitrogen deposition loadings. A regionally spe-
cific  approach   to  determining  a  deposition
standard or standards can provide the basis for
implementation under either regional or national
approach. Resource-specific goals can be used to
determine what emissions  and deposition  reduc-
tions would likely be needed. A regionally specific
environmental goal (i.e., acid deposition standard)
can be  used  to  achieve  effective and efficient
environmental protection of those resources and
ecosystems  most  sensitive  to  adverse effects and
most  likely  to  benefit from  acidic deposition
control.

Establishing appropriate environmental  goals for
an acid deposition  standard or standards requires
selection of appropriate ecological endpoint crite-
ria and indicator measures. Such  measures must
provide information to accurately judge how suc-
cessfully the key ecosystems and resources of con-
cern are being protected. The applicability of these
measures  varies  among  regions  and,  in  some
cases, among individual systems (e.g., watersheds,
lakes, or streams). While the analysis presented in
this chapter focuses on changes in surface water
quality  reflected  by two  ANC measures within
these waters, other endpoints may be equally or
more appropriate for protecting sensitive resources
of local interest, such  as  individual stands of red
spruce forests or populations of listed threatened or
endangered species. Potentially useful  endpoints
can include the "most sensitive" systems or species
within an  environment or some defined index of
ecological structure.

Several  major points and conclusions from the re-
search  and analyses  presented in the  previous
chapters are key to the process of integrating  our
understanding  of  environmental   effects   and
source-receptor  relationships  related  to  acidic
deposition  and  setting effective  environmental
goals. The following points highlight the processes
and relationships described earlier in this report.

  *  CHEMICAL   EMISSIONS  AND   ATMOSPHERIC
     PROCESSES  AFFECTING   DEPOSITION  ACIDITY:
     The principal acids in deposition are sulfu-
     ric (H2SO4) and nitric (HNO3) acids. Thus,
     emissions of compounds  containing sulfur
     and nitrogen have been the primary focus
     in  acidic  deposition  control  strategies.
     Volatile organic  compounds  (VOCs)  and
     their oxidation products are also important
     because they often control reactions  that
     produce the oxidizing species that lead to
     formation of sulfuric  and nitric acids in the
     atmosphere. In total,  production of atmos-
     pheric acids is a complex process, involv-
     ing 140 known reactions among 60 chemi-
     cal species, 40 of which are organic com-
     pounds.
  »  NATURAL EMISSIONS SOURCES: Natural emis-
     sions  of  acid  precursor  species, organic
     matter, and alkaline materials (dust)  are
                                                99

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
     generated by vegetative matter,  soil and
     saltwater microbes, geochemical activity,
     lightning,  and  natural  combustion (e.g.,
     forest fires).  Natural emissions of SO2, sul-
     fates, and nitrogen oxides are significantly
     less important than anthropogenic sources
     in their impact on sensitive ecological re-
     sources.

     ANTHROPOGENIC EMISSIONS SOURCES:  Acidic
     deposition precursor species and reactive
     atmospheric chemicals  are generated by
     energy  production,  industrial processes,
     mobile sources,  and waste disposal.  Cur-
     rent  estimates  indicate that  of the  total
     emissions of SO2, electric utility fuel com-
     bustion  contributes 70  percent, industrial
     fuel combustion contribute 14 percent, and
     the balance comes from other sources. For
     emissions of NOX, both  electric utility fuel
     combustion and highway vehicles each are
     estimated to contribute  32 percent, indus-
     trial fuel combustion provides 15 percent,
     and off-highway vehicles produce 12 per-
     cent, with the balance coming from other
     sources.  Potential  future  needs to effec-
     tively and efficiently further reduce anthro-
     pogenic source emissions  and deposition
     would  likely focus primarily on limiting
     emissions from these major sources.

     CHEMICAL  CAUSES  OF  ACIDIC DEPOSITION
     EFFECTS: Accumulating scientific evidence
     verifies that deposition of acid-forming sul-
     fur and  nitrogen compounds both can be
     significant causes of surface water acidifi-
     cation effects. Although past research and
     control efforts have primarily focused on
     the control of sulfur emissions and deposi-
     tion, recent research indicates that nitrogen
     deposition often may be an  equally and
     sometimes more important cause of some
     surface water acidification  effects. For ex-
     ample,   considerable  evidence  indicates
     that  nitrogen  deposition   is  generally  a
     greater acidification concern in the western
     United  States and that nitrogen deposition
     as well as sulfur deposition can be a sig-
     nificant  contributor to episodic acidifica-
     tion of surface waters in the East.

     WATERSHED NITROGEN SATURATION:  There
     are limits to the amount  of nitrogen that
     can be  sequestered (i.e., in organic matter)
     in watersheds. As these systems approach
     saturation, nitrogen losses from watersheds
  will increase leaching of nitrate. This can
  lead  to  acidification  of  surface  waters.
  Times to nitrogen  saturation vary among
  regions due to differences in temperature,
  moisture, length of growing season, soil
  fertility,  forest  age,  history of  nitrogen
  deposition, and  other variables.  Significant
  variability and uncertainties  remain in de-
  termining the time to nitrogen saturation
  for specific watersheds across regions. Ni-
  trogen saturation is a potentially significant
  concern  that contributes to  the acidifica-
  tion process, even if total saturation never
  occurs.
* MOST SENSITIVE REGIONS  AT RISK:  Based on
  the NAPAP National Surface  Water Survey,
  six regions contain 95 percent of the lakes
  and 84 percent of the stream reaches that
  were chronically acidified [i.e., having an
  acid  neutralization capacity (ANC)  of 0
  ueq/l or less] due to inorganic ions,  pre-
  dominantly  SO42',  NCy,  and  CK These
  areas  include  the southwest Adirondack
  Mountains in New York, New England,
  mid-Appalachian Region, Atlantic  Coastal
  Plain, northern Florida Highlands, and low-
  silica lakes  in the upper  Midwest. Com-
  piled evidence indicates that  acidic deposi-
  tion most likely caused  significant acidifi-
  cation of surface  waters in  the Adirond-
  acks, the Pocono/Catskill subregion, mid-
  Appalachians, eastern upper Midwest, the
  New Jersey  Pine Barrens, and, to a lesser
  extent, northeastern Florida. These regions,
  therefore, require  greatest  consideration
  when determining the need  for protection
  from future acidic deposition  loadings.
* MOST SENSITIVE RESOURCES AT RISK: An acid
  deposition standard or standards intended
  to prevent adverse effects should provide
  adequate protection for the most sensitive
  resources at greatest risk. The predominant
  natural  resources that appear to  be both
  most sensitive to and at greatest potential
  risk from acidic  deposition are aquatic sys-
  tems and high-elevation red spruce forests.
» NATURALLY ACIDIC  SURFACE WATERS:  Evalu-
  ation of  acidic  deposition should  include
  the realization that all regions hold  natu-
  rally acidic surface waters.  For example,
  about  40 to 50 percent  of  the  target
  population  surface  waters  in   the  Adi-
  rondacks with ANC of 50 ueq/l or less (i.e.,
                                                100

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                                                       CHAPTER 6:  INTEGRATION AND CONCLUSIONS
sensitive)  are likely to persist even  with
complete   elimination  of  anthropogenic
acidic deposition. Certain biota evolve to
live  in  naturally acidic systems.  Manage-
ment   and   policy  decisions    should
recognize the existence of these systems
and  consider protecting populations and
communities that have naturally evolved as
part of these ecosystems.

ENVIRONMENTAL GOALS TO PROTECT SENSITIVE
AQUATIC RESOURCES: The biological effects
of inorganic  monomeric aluminum associ-
ated with acidic deposition  are minimized
as the  level of acidic deposition is de-
creased and  pH and ANC levels in sensi-
tive waters are kept relatively high. Based
on laboratory and field studies of sensitive
aquatic species, a general goal is to main-
tain  surface water pH above 6.0. Greatest
protection  of sensitive aquatic  resources
occurs  in  surface  waters  where ANC is
generally maintained above 50 ueq/l.

EPISODIC ACIDIFICATION: Short term acute ef-
fects  occur when pulses of acidic waters
enter lakes or  streams with  storm  runoff
and  snowmelt.  The resulting potentially
acutely toxic changes in  surface  water
chemistry often  occur at the most biologi-
cally significant  time of year. The  projected
number of systems at risk of episodic acidi-
fication is  substantially higher  than the
number of chronically acidic systems.

CRITICAL AND TARGET LOADS: A critical load
is  a  quantitative pollutant  loading below
which no significant harmful effects occur
to ecological processes; a critical load de-
pends solely on  inherent ecological proper-
ties.  A target load may incorporate social,
policy, economic, and other considerations
along with the scientific observations. Pro-
tection  approaches  emphasizing  critical
and target loads are currently used exten-
sively in   most  European  countries  and
Canada. A critical and/or target  load ap-
proach is conceptually similar to the depo-
sition standard approach discussed in this
report for determining the most appropriate
level of protection.

This report does not develop or set critical
or target loads.  It does,  however, provide
the scientific basis  upon which  to deter-
mine critical loads. The  scientific uncer-
tainty  regarding   watershed    nitrogen
     saturation  makes determining a  standard
     difficult at this time.
  *  MONITORING TO  ASSESS  EFFECTIVENESS  AND
     BENEFITS OF CONTROLS: Although the analy-
     ses presented in this report focused on en-
     vironmental goals appropriate for reducing
     regional proportions of surface waters  with
     ANC below 0 ueq/l  and maintaining sur-
     face water ANC above 50 ueq/l, monitor-
     ing to assess the actual effectiveness of any
     emissions or deposition controls should as-
     sess not only the potential benefits of  con-
     trols  on surface  water ANC, but also on
     other resources of concern. Such  concerns
     include possible changes in the stand  con-
     dition within red spruce forests at potential
     risk,  visibility impairment particularly  in
     National Parks, and degradation  of materi-
     als and cultural resources.
  *  REGIONALLY BASED RESEARCH: Outside the
     context of an acid deposition standard, re-
     gionally based ecological knowledge can
     be used to help guide efforts to improve or
     monitor the ecological health of sensitive
     areas.

6.3  PROJECTED ENVIRONMENTAL CONSE-
     QUENCES OF ACIDIC DEPOSITION RE-
     DUCTION SCENARIOS
From the above summary of findings,  the surface
waters in  the  United States  at greatest  apparent
continuing risk from acidic deposition extend from
the  Adirondacks  south  along the  Appalachian
chain  into  northern  Florida.  Past research  has
primarily   focused   on   understanding   acidic
deposition relationships within three representative
case-study regions along  this area,   particularly
lakes in New York's Adirondack  Mountains, acid
sensitive stream reaches in the mid-Appalachian
Region  (portions  of  New  York, New  Jersey,
Pennsylvania,   Maryland,  West  Virginia,   and
Virginia)  and  Southern   Blue  Ridge  Province
(portions  of  North  Carolina,  South Carolina,
Tennessee, and Georgia). These representative re-
gions receive fairly high levels of  acidic deposi-
tion, have the best historical data  and are best un-
derstood by scientists.

Potential benefits of additional sulfur and nitrogen
deposition reductions to the three sensitive aquatic
resource regions were projected using relation-
ships defined  through the   Nitrogen  Bounding
Study (NBS) discussed in Chapter 2 and shown in
Appendix B. Specifically,  the scenarios presented
                                           101

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
in Exhibits 40 and 49 in Chapter 3 that provide for
the maximum reduction in acidic deposition levels
by the year 2010 represent approximately a 44
percent decrease in SO2 emissions from all sources
and a 24 percent decrease  in  projected  NOX
emissions beyond those achieved  by  the 1990
CAAA.   These   deposition   reductions  were
produced by reducing both sulfur and  nitrogen
emissions from utility  and industrial combustion
sources by 50 percent. The NBS projections were
then used to relate the resulting sulfur and nitrogen
deposition   levels  to  probable  proportions  of
surface waters in the two ANC groupings. Because
times to watershed  nitrogen  saturation  are  not
certain  for these three  or  any  other  region,
projections  using  all  four possible  times  for
watersheds to reach  nitrogen saturation modeled
by NBS were prepared.

Exhibits 71-73 present actual  and modeled  pro-
portions of lakes and streams for two ANC group-
ings (ANC<0 ueq/l and ANC<50 ueq/l).  Projected
proportions in both of these ANC categories are
shown for each of the three study regions under
each of four possible times to watershed  nitrogen
saturation for the following six scenarios:
       * Actual 1984 or 1985,

       * NBS projections of surface waters in the
         year 2040 if the 1990 CAAA had not been
         implemented,

       * NBS projections of surface waters in the
         year 2040 with full implementation of the
         1990 CAAA.

       * NBS projections of surface waters in the
         year 2040  with additional reductions in
         utility and industrial emissions of sulfur be-
         yond the CAAA (see Exhibit 40).

       * NBS projections of surface waters in the
         year 2040  with additional reductions in
         utility and industrial emissions of nitrogen
         beyond the CAAA (see Exhibit 48).
       * NBS projections of surface waters in the
         year 2040  with additional reductions in
         utility and industrial emissions of both sul-
         fur and nitrogen beyond the CAAA (see Ex-
         hibits 40 and 49).
                    EXHIBIT 71. YEAR 2040 NBS PROJECTIONS FOR ADIRONDACK LAKES
               50 Yr     lOOYr    250 Yr    Never    50 Yr     100Yr    250 Yr
                                Time to Watershed Nitrogen Saturation
                              • 1984 Base
                              Qw/oCAAA
                              • 1990 CAAA
H CAAA-additional S
I   I CAAA-additional N
• CAAA-additional S+N
                                Never
                                              102

-------
                                              CHAPTER 6: INTEGRATION AND CONCLUSIONS
      EXHIBIT 72. YEAR 2040 NBS PROJECTIONS FOR MID-APPALACHIAN STREAMS
50 Yr    lOOYr    250 Yr    Never    50 Yr     lOOYr    250 Yr
                 Time to Watershed Nitrogen Saturation
                                                                 Never
EXHIBIT 73. YEAR 2040 NBS PROJECTIONS FOR SOUTHERN BLUE RIDGE PROVINCE STREAMS
JU -
aj 25 -
u
as

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
The following points highlight the major relation-
ships shown in the projections for the year 2040.
In reviewing these projections, it  is important to
remember that these projections are for changes in
proportions  representing the NBS modeled sub-
populations  of the "most sensitive surface waters"
within  each  of these regions; these proportions do
not apply to all the surface  waters or some other
subset of surface waters in these regions.

  * The 1990 CAAA markedly reduces the pro-
    portions of surface waters in all three re-
    gions projected  to  be acidic  (i.e., ANC<0
    ueq/l)   by  2040,  relative  to  conditions
    projected without its implementation. This
    is seen  by comparing the second and third
    vertical plotted bars shown for each region
    and across each assessed time to watershed
    nitrogen saturation.
  * The 1990 CAAA markedly reduces the pro-
    portions of stream  reaches in the mid-Ap-
    palachians projected to  become increas-
    ingly sensitive to potential effects from epi-
    sodic acidification (i.e., ANC<50 ueq/l) by
    2040. This benefit is projected to be lesser
    in magnitude for the lakes in the Adirond-
    acks and stream reaches in the Southern
    Blue Ridge.
  • Sensitivities of target aquatic resources and
    their potential  responses  to changes  in
    acidic deposition clearly differ among the
    modeled regions.

  * The benefits  to  sensitive surface  waters
    from sulfur deposition reductions mandated
    by the 1990 CAAA may be lessened due to
    future   increases   in   nitrogen  leaching
    caused  by continuing nitrogen deposition
    and  saturation   of   watersheds  with
    deposited nitrogen. This is  shown by  the
    projected increasing proportion of ANC<0
    ueq/l and ANC<50 ueq/l surface waters at
    shorter   times  to  watershed  nitrogen
    saturation.

  * Uncertainty related to actual times to wa-
    tershed  nitrogen  saturation within these re-
    gions causes  projections of  relationships
    between deposition and ANC responses to
    range by  factors  of  about two or greater.
    Longer times to nitrogen saturation lead to
    fewer   projected   acidic  and  sensitive
    aquatic  systems.
  » Significant uncertainty continues to accom-
    pany the rate of watershed nitrogen satura-
     tion,   contributing   to   uncertainty   in
     projecting  the   impact   of   additional
     reductions in sulfur and nitrogen deposi-
     tion.

   * Any reductions   in  nitrogen   deposition
     would  not only reduce total acidic deposi-
     tion, but would  also  increase  the  actual
     times to watershed nitrogen saturation. This
     is  similar to  sulfur  deposition  reductions
     that  are  now likely extending times  for
     watershed sulfur saturation.

6.4 FEASIBILITY OF ESTABLISHING AND
     IMPLEMENTING AN ACID DEPOSITION
     STANDARD
A variety of factors could affect the implementa-
tion of an acid deposition standard.  The  effect of
these factors on implementation will depend on
the approach  selected. To be successful, an im-
plementation approach must be clear and unambi-
guous, and provide certainty as to the responsibili-
ties of the regulated community, EPA, and states.
Two basic approaches were evaluated in this re-
port.  First,  a  regional targeted  approach would
involve  establishing   deposition  standards  for
specific geographic regions, and require geograph-
ically targeted reductions  in emissions  of  SO2
and/or NOX. EPA would  either set a standard or
standards using existing authority or would seek
additional congressional authority and timetables.
Source-specific limits would be determined  using
source-receptor  models,  and  limits would  be
incorporated into State Implementation Plans  (SIPs)
and  enforced  by  states.  Second,  a  national,
emissions-based approach which would involve
congressional  direction to  EPA to  set  an  acid
deposition standard or standards and  determine
emissions for SO2 and NOX to meet the standards
within a certain time frame. An emissions cap and
allowance allocations would have to be set for
NOX and, as appropriate, adjusted for SO2. The re-
gional approach would be similar to the  SIP pro-
gram used to implement Title I of the Act regard-
ing attainment of  National Ambient Air Quality
Standards (NAAQS) while the national approach is
similar to the current Acid Rain Program.

Two emissions reductions scenarios  were devel-
oped to compare  national  and targeted reduc-
tions—a nationwide 50 percent reduction beyond
the CAAA of SO2  emissions  from utilities and a
geographically  targeted strategy which  removed
95  percent  of utility  SO2  emissions from  geo-
graphically constrained regions.  Both approaches
                                               104

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                                                           CHAPTER 6:  INTEGRATION AND CONCLUSIONS
were analyzed for emissions reduction efficiency
and  cost-effectiveness. The following points high-
light  the findings  and  conclusions from  these
analyses.

  * Geographic targeting  can  be  used  to
     achieve target  loads in each  receptor re-
     gion and in all three regions simultane-
     ously.  Delineation  of  targeted emissions
     reduction areas is  made complex,  how-
     ever, by  potentially large target areas, sig-
     nificant  source-specific emissions  reduc-
     tions  requirements  (i.e., 95  percent SO2
     reductions), and  impairment  to  the cost
     savings of  the  current  Acid Rain Program
     due to regional restrictions on allowance
     trading.
  * The total emissions reductions required to
     achieve the deposition loads in  all three
     receptor regions simultaneously did not dif-
     fer  significantly between the  nationwide
     and targeted approaches.  Costs of control
     and cost-effectiveness  for the  nationwide
     emissions reduction scenario and the geo-
     graphically  targeted  scenario were  ap-
     proximately equal.  (To  assess  the  ap-
     proaches, each scenario was designed  to
     achieve  the same  environmental  goal.)
     There is  no  environmental or  economic
     gain by geographically targeting  source re-
     gions.

  • Title  IV will produce the largest emissions
     reductions  in the  highest  source regions
     (i.e.,  Ohio,  Indiana,  West Virginia, and
     western   Pennsylvania)   making  control
     efforts beyond the  CAAA more effective  if
     focused  on broad  geographic regions, or
     nationally.

  * The cost of additional emissions reductions
     addressed in this report are, at a minimum,
     double the cost of the  current Acid Rain
     Program.  The   benefits,  although  not
     quantified here, would  be in  multiple ef-
     fects  areas such as  human health, visibility,
     and materials, as well as aquatic systems.

Based on scientific understanding of the effects of
sulfur and nitrogen,  it  would be feasible to  set
sulfur and nitrogen deposition standards to protect
aquatic resources.  However, uncertainty regarding
the impact of  nitrogen remains high, making it
difficult to determine the appropriate  level  of a
standard or standards at  this time.
                                                105

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          APPENDIX A




SUMMARY OF SELECTED NAPAP REPORTS

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                                       APPENDIX A

                      SUMMARY OF SELECTED NAPAP REPORTS
INTRODUCTION
This appendix presents a synopsis of major conclu-
sions from 10 of the NAPAP State of Science and
Technology Reviews.  In a few of these summa-
ries, where knowing how the study was designed
and conducted can  help the reader better appreci-
ate the study's key results, background information
on  the study's methods is  presented.  Most  infor-
mation  summarized in this appendix came from
NAPAP's  Summary  Report of the U.S.  National
Acid Precipitation Assessment Program.1   Major
conclusions from these NAPAP studies that  influ-
ence identifying key relationships between acidic
deposition and receptor effects are presented  in
the order that they were presented by the individ-
ual SOS/T report summaries.  Also, not all conclu-
sions from those studies are  presented in  the fol-
lowing sections.  In some case, similar key conclu-
sions appear in  more  than  one report, conse-
quently, they are also repeated in more than one
of the case summaries below.

SOS/T REPORT 9: CURRENT STATUS OF
SURFACE WATER ACID-BASE CHEMISTRY
Phase  I of  the  National  Surface  Water Survey
(NSWS) consisted of three  major  surveys.  The
1984 Eastern Lake  Survey (ELS)  sampled 1,592
lake of  4  ha and larger that  represented an esti-
mated population of 17,953 lakes in the Northeast,
Upper  Midwest, the Southern  Blue Ridge region,
and Florida. The 1985 Western Lake Survey (WLS)
sampled 719 lakes of 1 ha and larger that repre-
sented  an  estimated population of 10,393 lake
throughout the Sierra Nevada, Cascade, and Rocky
Mountain  ranges.   Finally, the  National Stream
Survey (NSS) sampled 500 stream reaches in 1986
that represented an estimated population of 56,000
stream reaches (200,000 km) throughout much  of
the Mid-Atlantic Coastal Plain, mid-Appalachian,
Poconos/Catskills, Interior  Southeast,  and Florida
Regions. A Phase II lake survey (ELS-II) was con-
  Irving, P.M.  1991.  Acidic  Deposition:  State of
  Science and Technology.  Summary Report of the
  National  Acid  Precipitation  Assessment Program.
  Office of  the Director,  National Acid Precipitation
  Assessment Program, Washington, DC.
ducted in 1986 to evaluate seasonal  chemical
variability in Northeast Lakes. Thus, seven major
subregions were sampled during the NSWS:

  *  Northeast Subregion

  *  Mid-Appalachian Subregion

  *  Mid-Atlantic Coastal Plain Subregion

  *  Interior Southeast Subregion

  *  Florida Subregion

  *  Upper Midwest Subregion (northern Michi-
     gan, Wisconsin, and Minnesota)

  *  West Subregion

Several key findings from the NSWS include:

  1.  An estimated 4.2% (1,181) of the National
     Surface Water Survey (NSWS) lakes were
     acidic, defined as having ANC<0 /veq//;
     nearly all were in the East.   These lakes
     had pH levels in the range 5.0 to 5.5.

  2.  Acid lakes tend to be smaller than non-
     acidic lakes.  In the East acidic lakes aver-
     age  12  ha versus 17  ha  for non-acidic
     lakes.

  3.  Nearly 20%  of the NSWS lakes had  an
     ANC of 50 ueq/l or less.

  4.  About 3.0%  of the NSWS  lakes had total
     inorganic monomeric  aluminum  (Alim)
     concentrations of less than 50 ug/l.

  5.  No sampled  lakes were acidic in the Inte-
     rior Southeast or Minnesota, and only one,
     a geothermal spring, was  acidic in the
     West. These results lead to the conclusion
     that there are virtually no  acidic lakes in
     these subregions, within the subpopulation
     of surface waters sampled.

  6.  Based on total stream length with the NSS
     target population, 2.7% (5,506  km) were
     acidic  (ANC<0 ueq/l)  and 12% (23,595
     km) had ANC<50 ueq/l, excluding reaches
     affected by acid mine drainage.
                                              A-1

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                                                          APPENDIX A:  SUMMARY OF NAPAP REPORTS
  7.  For  8% (16,780 km) of the NSS  stream
      length, the pH was 5.5 of less and for 18%
      (35,771 km) the pH was 6.0 or less.

  8.  A greater  percentage of streams reaches
      were  acidic in  their upstream  reaches
      (6.1%) compared  to  their  downstream
      reaches (2.3%)

  9.  Most of the acidic  stream reaches in the
      NSWS target population occurred in the
      mid-Appalachian    and     Mid-Atlantic
      Coastal Plain regions, with smaller length
      totals  in  the  Poconos/Catskill subregion
      and Florida.

  10. Acidic and low pH streams in  the mid-
      Appalachian region  and Poconos/Catskill
      subregions were restricted to watersheds
      smaller than 30 km^ and were  generally
      found  at  elevations higher  than 300  m.
      These  were clearwater systems with a me-
      dian DOC of 1.1 mg/l and Alim of 202
      MB/"-
Based on results from this survey six "high-interest
regions" were identified that contained most of the
acidic lakes and streams  identified in  the NSWS.
While the combined high-interest lakes popula-
tions  included only 26% of the all NSWS lakes,
they included 95% of all  inorganic acidic lakes.
Similarly, 37% of all NSS  upstream reaches were
in the high-interest population, but 84%  of all in-
organic acidic NSS upstream reach ends were in-
cluded.  The six areas targeted were

  * SOUTHWEST   ADIRONDACK    MOUNTAINS:
     Within  this  subpopulation,  38% of the
     lakes were acidic (ANC<0 ueq/l) and 51%
     had closed-system pH of 5.5 or less.  These
     acidic  lakes are typically  rapidly flushed
     drainage lakes in which SO42~ is the domi-
     nant  anion  and  DOC  concentrations
     ranged  3  to  4  mg/l.   Many  had high
     concentrations of inorganic monomeric Al,
     with  36% having Alim greater than  100
     MB/'-
  * NEW  ENGLAND: Within this subpopulation
     4.7% of the NSWS lakes had ANC<0 ueq/l
     and 6.8%  had pH<5.5.  In the Seaboard
     Lowlands area 7.7% of  the NSWS lakes
     were acidic (ANC^O ueq/l).  The majority
     of the  acidic lakes  in this  region were
     dominated by inorganic  acids, but about
     one-fifth, mostly in the Seaboard Lowlands,
     were dominated by organic acids.
FORESTED MID-ATLANTIC HIGHLANDS (A.K.A.,
MID-APPALACHIAN  REGION):  Within   the
stream populations, 11.5% were acidic and
16.7% had closed-system pH<5.5. Among
lakes of this subpopulation, 10% had ANC
<0  ueq/l  and  9%  had  pH<5.5.  Acidic
surface waters of this subpopulation  typi-
cally had  low DOC (stream mean of 1.5
mg/l, lake mean of 2.6 mg/l) and  high
SO42- concentrations (stream mean of 148
ug/l, lake  mean of  122 ug/l).  All acidic
lakes and streams were dominated by  inor-
ganic acids, with SO42~ being the dominant
anion with relatively low NO3' concentra-
tions (mean < 10 ueq/l). Acid streams had
the  highest concentrations  of inorganic
monomeric Al  of all  high  interest areas,
with a mean  Aljm of 202 ug/l. Acid lakes
had a mean Alim of 77 ug/l.

ATLANTIC COASTAL PLAIN: At their upstream
ends, 14% of the NSS stream reaches were
acidic (ANC<0 ueq/l) and 17% had pH of
5.5 or less. Both mineral and organic acids
provided  important contributions  in  the
acid-base  status in these streams.  Among
the acidic streams,  65%  were dominated
by   organic  acids,   while   32%  were
dominated by  inorganic acids.    Acidic
streams in the New Jersey Pine  Barrens
were dominated by  inorganic acids,  but
with considerable influence  by  organic
acids,  and were similar  to organic  acid
dominated streams.   In  the  rest  of  the
region, NSS streams were dominated by
organic acids.    Twenty  acidic  lakes
identified on Cape Code  were dominated
by chloride and had salt water SO42"  con-
centrations of 110 to 175 ueq/l.

NORTHERN FLORIDA HIGHLANDS:  This subre-
gion includes  the Central Lake  District
(Trail Ridge) north of 29°N latitude and the
Panhandle. For this subregion,  63% of the
lakes were  acidic  (ANC<0   ueq/l)  and
52.6% had closed system pH of 5.5 or less.
Most (90%)  of the  acidic  lakes  were
seepage lakes.  Of the acidic  lakes,  80%
were dominated by inorganic  acids,  with
median SO42~  concentrations of 83 ueq/l,
median DOC of 2.4 mg/l, and mean  Alim
concentrations of 39 ug/l.  Acid  streams
had  low ionic concentrations (mean  base
cation of 21 ug/l, SO4" of 16 ueq/l).  Three-
quarters   of   the   acid   streams  were
                                              A-2

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                                                            APPENDIX A: SUMMARY OF N APAP REPORTS
     dominated by inorganic acids, with DOC
     of less that 2 mg/l.

  « LOW-SILICA  LAKES  IN  THE EASTERN  UPPER
     MIDWEST: This subregion  includes lakes in
     northeastern  Wisconsin  and  the Upper
     Peninsula   of  Michigan  having  silica
     concentrations of  less than 1 mg/l.   Of
     these  lakes, 15.9% were acidic  (ANC<0
     ueq/l) and 19.3% had closed-system pH of
     5.5  or less.   Of these acidic  lakes, 80%
     were  seepage  lakes,  with  low  silica
     concentrations reflecting  the lack of well-
     buffered ground  water inputs.   Inorganics
     dominated  the acidity  in  87%  of these
     lakes.  SO42- was  generally the dominant
     anion, with  a mean  concentration  of  69
     ug/l.  DOC concentrations were  relatively
     high  (mean   of  3.9  mg/l),  indicating
     substantial influences by organic acids.  Al
     concentrations were low.

SOS/T REPORT 10: WATERSHED AND LAKE
PROCESSES AFFECTING SURFACE WATER ACID-
BASE CHEMISTRY
  1. Atmospheric deposition is often an impor-
     tant,  yet highly uncertain,  component of
     the acid-base budget in  many watersheds
     and in lakes and streams having low ANC.
     Greatest uncertainty is in regions holding
     high elevation or rough terrain and for the
     processes of particulate and gaseous depo-
     sition. The uncertainty in nitrogen deposi-
     tion is less important to acid-base budgets
     compared with internal fluxes. The uncer-
     tainty in base cation deposition may cause
     large uncertainty  in acid-base budgets in
     some watersheds.

  2. Watersheds having a greater proportion of
     their water flowing through shallow, more
     acidic soils tend to have more acidic and
     lower ANC  surface  waters than water-
     sheds in which  a large proportion of the
     water  flows   through   deeper,  more
     weatherable materials. This conclusion is
     generally valid for baseflow chemistry and
     for episodic changes in acid-base chemis-
     try for  surface waters.   The major path-
     ways for movement of water through wa-
     tersheds are subsurface flows, even during
     most extreme flow  events.  Generally,
     overland flow is rarely observed.

  3. Even  without acidic deposition,  the natu-
     ral  sequence in watershed development is
    one of soil acidification  associated with
    base cation accumulation in biomass (i.e.,
    in vegetation and humus), an increase in
    soil  cation exchange capacity,  and  in-
    creased  leaching  of  soluble or weather-
    able materials from upper soil horizons.

4.  Naturally acidic  lakes and streams domi-
    nated  by organic anions occur predomi-
    nantly in areas where bedrock or uncon-
    solidated sediments are highly resistant to
    weathering.   Most are  in regions with
    large buildups of organic matter (e.g., ar-
    eas  with spodic soils and in  wetlands),
    often in more northern and coastal plain
    regions having low-relief terrain and rela-
    tively poor drainage.

5.  Adsorption-desorption properties of soils
    in the  watershed  regulate export  of  at-
    mospherically deposited SO42" into surface
    waters.   Vegetation  has only a  limited
    capacity to immobilize SO42~, even under
    optimal conditions. Great uncertainty still
    exists  regarding the reversibility of SO42~
    adsorption and critical factors controlling
    desorption. But, at least one documented
    study that examined adsorption-desorption
    across a variety of soils showed that most
    soils exhibited some degree of irreversible
    adsorption.

6.  The extent to which atmospheric nitrogen
    deposition affects the export of NO3- from
    watersheds depends  on  biological  rather
    than geochemical  process in the water-
    shed.   Most forest soils (including those
    that are not currently affected by nitrogen
    deposition leading to increased  nitrogen
    accumulation   and  possible  saturation)
    have the potential to produce and leach
    NO3- to surface waters.

7.  Sulfate deposition  often  causes  an anion
    shift from drainage  water compositions
    dominated by HCO3~ and organic anions
    to one dominated by SO42~.

8.  The relative mix of cations in soil solution
    depends on the mix of cations on soil  ex-
    change sites (i.e., soil base saturation) and
    cation selectivities of the exchange sites.
    In extremely acid soils (i.e., less than 10%
    base saturation), Al and  H+ dominate  the
    cations in solution,  resulting in  reduced
    ANC concentrations  in  drainage waters
    from the watershed; in less acid soils (i.e.,
                                               A-3

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                                                            APPENDIX A: SUMMARY OF N APAP REPORTS
      greater than 20% base saturation), base
      cations dominate and ANC remains unal-
      tered.  Data on soil chemistry and miner-
      alogy,  bedrock  mineralogy, and water
      flow paths are all necessary to predict the
      chemistry of waters draining terrestrial sys-
      tems.

  9.  Water  quality changes that occur when
      soil water rich in CO2 flows into surface
      waters depend on ANC in both waters. If
      SO42" and NO3"  from deposition produce
      negative ANC in the soil  solution, the pH
      effects  observed within the  soil solution
      may be  minimal but the consequential
      change produced by discharge of this low
      pH and high Al soil water to surface water
      may be substantial.

  10. Many  seepage  lakes  (lakes having  no
      stream input) that receive even 5% of their
      total water  input from  groundwater  are
      seldom likely  to be  affected by  acidic
      deposition to their surfaces. That is, ANC
      supplied by  a small proportional volume
      of ground water is often sufficient to neu-
      tralize incident acidic precipitation.  The
      chemistry  of seepage lakes  that  derive
      greater  than  95% of their input from pre-
      cipitation are greatly influenced by incom-
      ing precipitation.

  11. Numerous processes modify the acid-base
      chemistry  of water  entering lakes  and
      streams, including base cation production
      and SO42- and  NO3" retention.   These
      process occur in  all  systems, but  rates for
      these processes vary among  systems. For
      example,  those systems having long resi-
      dence times and relatively deep mean soil
      depths tend to have the greatest influence
      on  acid-base chemistry in their drainage
      waters.  Further, in some lakes, more ANC
      is derived from  in-lake production than
      that generated within the terrestrial water-
      shed.  The most  important in-lake proc-
      esses generating ANC are likely to occur
      in the sediment rather than the water-col-
      umn of acid-sensitive lakes.

SOS/T REPORT 11: HISTORICAL CHANGES IN
SURFACE WATER ACID-BASE CHEMISTRY IN
RESPONSE To ACIDIC DEPOSITION
  1.   The role of acidic deposition as a cause of
      acidic surface waters is supported by nu-
      merous lines of  evidence, including the
    current chemical composition  of  acidic
    surface waters, extensive paleolimnologi-
    cal analyses of bottom sediment deposits,
    the worldwide distribution of acidic sur-
    face  waters, experimental studies,  moni-
    toring and re-survey data, and  principles
    of geochemistry.

2.  Acidification of low pH  and low ANC (<
    50 ueq/l) Adirondack lakes has  been less
    than  previously believed because of con-
    siderable watershed and in-lake neutrali-
    zation of acidic inputs via enhanced base
    cation mobilization.

3.  Outside the Adirondack Mountains, the
    chemistry of drainage lakes and streams in
    several areas  is  consistent with the hy-
    pothesis of acidification of sensitive sys-
    tems  by acidic deposition.   This is most
    notable  for the  Poconos/Catskill  subre-
    gion,  the Mid-Atlantic  Highlands  (i.e.,
    mid-Appalachians), the eastern portion  of
    the Upper Midwest, and the New  Jersey
    Pine Barrens.

4.  The chronic acid-base character of  lakes
    in Maine  has been generally unaffected by
    acidic deposition.   Chemistry  of acidic
    streams in the Mid-Atlantic Coastal  Plain,
    outside the New Jersey  Pine Barrens,  in
    most  cases, suggest acidification due  to
    organic acidity and not acid deposition ef-
    fects.   Chronic acidification of western
    lakes from acidic deposition has not ap-
    parently occurred.

5.  The acid-base character of acidic streams
    in the Florida  Panhandle can be ascribed
    to a combination of organic acidity, ma-
    rine  cation  retention,  and  near  zero
    weathering inputs to  some systems.  For
    some waters, acidic deposition  may also
    have provided minor contributions.

6.  In the Upper  Midwest, the  chemistry  of
    sensitive  (ANC<50 ueq/l, SiO2<1  mg/l)
    seepage lakes exhibit both increasing sen-
    sitivity (lower base cation concentrations)
    and increasing effects from acidic deposi-
    tion across a  longitudinal gradient  from
    west  to east.  In  the Upper  Peninsula  of
    Michigan, 15% of the lakes are of this
    type  and  many  of these are  currently
    acidic because of high SO42- relative  to
    base  cation concentrations.  These lakes
    have  probably been  acidified  by acidic
                                               A-4

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                                                           APPENDIX A:  SUMMARY OF NAPAP REPORTS
     deposition.  Throughout most of the Upper
     Midwest, however, substantial  regional
     acidification of lake water from acidic
     deposition has not occurred.

  7.  Most lakes and streams in the United
     States, especially those that have current
     ANC greater than  about 50 ueq/l, have
     probably not had declines in pH or ANC
     within their recent histories.

SOS/T REPORT 12:  EPISODIC ACIDIFICATION
OF SURFACE WATER ACID-BASE CHEMISTRY
  1.  Episodic acidification  is  the process  by
     which lakes and streams develop short-
     term  decreases in  ANC, usually during
     hydrological events and over time scales
     of hours to weeks.  Episodes are stochastic
     or probabilistic in nature, in terms of oc-
     currence, frequency, intensity,  duration,
     and, to some extent, composition.

  2.  Episodic  acidification  is practically   a
     ubiquitous process  in streams and drain-
     age  lakes.  Presently, data are not avail-
     able that allow rigorous  population  esti-
     mates  of  episodic acidification in  the
     United  States  to  be completed.  Most
     states plus southeastern  Canada, however,
     where monitoring  data have  been  col-
     lected, display characteristics of  episodic
     acidification.

  3.  Episodic acidification is controlled by a
     combination of natural and anthropogenic
     factors.  The relative importance of these
     factors varies among regions and among
     watersheds  within  regions.   There  are
     three primary  natural  process  that can
     produce episodes:  (1) dilution, (2) nitrifi-
     cation, and (3) organic acid production.

  4.  Episodic acidification is not symptomatic
     of human caused chronic acidification.

  5.  The  severity (minimum ANC or highest
     dissolved aluminum) of  episodes is  in-
     creased  by  acidic deposition in some  ar-
     eas.

  6.  While improvements in water chemistry
     during episodes in some lakes and streams
     would  be  expected,   especially in  the
     Northeast and  Mid-Atlantic, this issue has
     not been addressed by scientific investiga-
     tions.   The roles of nitrogen and sulfur
     deposition and of organic acids in causing
     episodic acidification all need to be exam-
     ined.

  7.  Modeling episodic acidification in surface
     waters has been only moderately  success-
     ful,  primarily  because of a lack of data
     and a  lack of understanding of important
     hydrological  flow   and  biogeochemical
     process.

SOS/T REPORT 13: BIOLOGICAL EFFECTS OF
CHANCES IN SURFACE WATER ACID-BASE
CHEMISTRY
  1.  The most important chemical properties of
     surface waters influencing biological re-
     sponses to acid-base chemistry  are pH,
     inorganic monomeric aluminum,  and cal-
     cium.  Decreases  in pH (particularly be-
     low 6.0-6.5) and increases  in the concen-
     tration of inorganic monomeric aluminum
     (above 30-50 ug/l for the  most  sensitive
     organisms) can increasingly cause adverse
     biological effects.   Small changes in cal-
     cium are  particularly important  at low
     calcium concentrations (< 100-150 ueq/l).

  2.  A number of the species that commonly
     occur  in  surface  waters  susceptible  to
     acidic deposition  cannot survive,  repro-
     duce, or compete in acidic waters.  Thus,
     with increasing  acidity, these  "acid-sensi-
     tive" species are eliminated  and  species
     richness (the number of species living in a
     given  lake or  stream)  declines.    These
     changes  in aquatic  community structure
     are found to begin in many surface water
     systems as chronic  pH levels drop below
     the range of about 6.0 to 6.5.  Acid-sensi-
     tive species occur in all major groups of
     aquatic organisms.  Both chronic  and epi-
     sodic acidification  can  affect  aquatic or-
     ganisms, with  chronic  acidification per-
     haps the primary cause of continuing ef-
     fects in acidified lakes and  episodic acidi-
     fication being particularly  important case
     of effects in streams.

  3.  System level processes, such as decompo-
     sition, nutrient cycling, and productivity,
     are fairly robust and affected only at rela-
     tively high levels of acidity (e.g., chronic
     pH<5.0-5.5).

  4.  Relatively  few  studies have  been  con-
     ducted on the  recovery  of  biological
     communities following  reduction  of acid
                                               A-5

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                                                            APPENDIX A: SUMMARY OF NAPAP REPORTS
      inputs.  Based on our current understand-
      ing of  the  processes of biological  re-
      sponse,  decreases in  indicateity would be
      predicted  to  likely allow acid  sensitive
      species  and   species  richness  both to
      increase in acid affected surface waters.

  5.  Laboratory toxicity experiments and field
      surveys  provide and  adequate basis for
      quantifying the relationship, on a regional
      scale, between changes in pH, aluminum,
      and calcium and acidity-induced stress on
      fish  populations.   Thus, toxicity-based
      models, field based  models,  and models
      that combine laboratory and field data can
      be used to evaluate the biological signifi-
      cance of projected changes  in acid-base
      chemistry given alternative deposition and
      emissions scenarios.

  6.  The  loss of  fish  populations  and/or ab-
      sence of fish  species as a result of acid-
      base chemistry changes  has  been docu-
      mented for some lakes and streams in sev-
      eral regions of the United States.  Applica-
      tion of fish response models  suggest that
      the percentage of NSWS waters with acid-
      base chemistry unsuitable for the survival
      of  acid-sensitive fish species range from
      less than 5%  in  areas such as the  Upper
      Midwest to near 60% for upper stream
      reaches  in  the Mid-Atlantic Coastal Plain.
      An estimated 23% of the Adirondack lakes
      and 18% of the mid-Appalachian streams
      classified as potential brook  trout habitat
      currently have acid-base chemistry unsuit-
      able for brook trout survival.

SOS/T REPORT 14:  METHODS FOR PROJECTING
FUTURE CHANCES IN SURFACE WATER ACID-
BASE CHEMISTRY
  1.   The  Direct/Delayed  Response  Project
      (DDRP)  approach utilized the best avail-
      able procedures for projecting the effects
      of sulfur deposition on future changes in
      surface water  acid-base chemistry for tar-
      get populations of lakes in the Northeast,
      Upper Peninsula of Michigan, and Florida
      and streams in the mid-Appalachians and
      Southern Blue Ridge Province.

  2.   Several  models provide credible projec-
      tions of  selected subpopulations of target
      lakes.
  3.  Measurement,   parameter,   input,   and
      population  extrapolation  error  can  be
      quantitatively estimated for model projec-
      tions, but aggregation and model assump-
      tion error can be estimated only qualita-
      tively.  Results from individual watershed
      projects can be  extrapolated through the
      probability sampling frame for regional es-
      timates of population attributes.

  4.  Although there are remaining uncertainties
      with  respect  to structural  error, aggre-
      gation, and long-term projection confirma-
      tion,  model  projections  are the  only
      feasible  approach   for  comparing  the
      effects  of different  illustrative emissions
      control  scenarios on future changes in sur-
      face water acid-base chemistry.

SOS/T REPORT 15: LIMING ACIDIC SURFACE
WATERS
  1.  Liming  can effectively mitigate many of
      the adverse ecological  effects of  surface
      water acidification  independent of reduc-
      tion of acidifying emissions.

  2.  Conventional whole-lake liming is a more
      established mitigation alternative than lim-
      ing running waters and watersheds.

  3.  Liming surface waters commonly results in
      significant   positive  and   predictable
      physiochemical  changes in aquatic  eco-
      systems.

  4.  Liming  generally increases  nutrient  cy-
      cling, decomposition,  and  primary  pro-
      ductivity and results in positive responses
      in fish and other  aquatic biota.

SOS/T REPORT 16: CHANGES IN FOREST
HEALTH AND PRODUCTIVITY IN THE UNITED
STATES AN DC AN AD A
  1.  The vast majority of forests in the United
      States are not affected by decline.

  2.  There is experimental evidence that acid
      deposition and associated pollutants can
      alter the resistance of red spruce to winter
      injury;  through  this  mechanism,  acidic
      deposition  may  have contributed  to  red
      spruce decline at high  elevations in  the
      northern Appalachians.   Evidence of  red
      spruce decline and  pollutant involvement
      in the southern Appalachians is less sub-
      stantial.
                                               A-6

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                                                          APPENDIX A: SUMMARY OF NAPAP REPORTS
3.  Most sugar maple trees and stands in the
    United States and Canada are not affected
    by decline.  Sugar maple declines  are sig-
    nificant problems,  however,  in  Quebec
    and in some parts of Ontario,  Vermont,
    and Massachusetts.   Natural stresses  in-
    cluding nutrient deficiencies and defolia-
    tion by insects  are important factors in
    these  declines.   Involvement of  acidic
    deposition  and/or  ozone as  significant
    contribution or predisposing factors have
    not been demonstrated, but such involve-
    ment cannot be ruled out on the basis of
    available information.

4.  A regional  decline of southern pines has
    not been demonstrated.    The reported
    growth rate reductions in certain classes of
    trees and stands are not fully understood,
    however, and require further investigation.
    The  occurrence  of  reduction  in tree
    growth rates in natural pine stands is an
    expected consequence of  historical land
    use patterns, increases in  stand age and
    competition, and other non-pollutant fac-
    tors.   Available information is not ade-
    quate to determine whether the magnitude
    of reported growth  reduction is greater or
    less than would be expected in the ab-
    sence  of acid deposition and  associated
    pollutants.   Results  of exposure-response
    experiments indicate that ozone at ambi-
    ent concentrations  can alter growth and
    physiology of southern pines seedlings and
    justify  concern about adverse effects of
    ozone on the  health and  productivity of
    southern pine forests.

5.  Compared to ozone  and many non-pollut-
    ant  stress factors,  acidic  deposition ap-
    pears to be a relatively minor factor affect-
    ing the current health and productivity of
    most forest in the United States and Can-
    ada.   Most of these forests are receiving
    acidic depositions at doses that have not
    had a serious  impact  on  health and pro-
    ductivity.   The possibility of  long-term
    (several decades) adverse effects on some
    soils appears realistic.  Sulfate deposition
    increases leaching  losses of nutrient cat-
    ions from many different forest soils and
    over the long term may reduce the fertility
    of  soils with low buffering capacities or
    low mineral weathering rates.
SOS/T REPORT 17: DEVELOPMENT AND USE OF
TREE AND FOREST RESPONSE MODELS
  1.  The models  presented in this report are
     preliminary, and they emphasize our lack
     of knowledge about fundamental tree and
     forest processes.  Nonetheless, considera-
     tion of the dynamics of  implied by what
     we do know of the processes indicate that
     considerable caution is needed in project-
     ing long-term effects from acidic deposi-
     tion and ozone.  In particular, long-term
     dynamics  generated  by synergies, and
     compensations between  mechanisms, can
     produce threshold effects. The possible ex-
     istence of  these threshold  effects implies
     that simple projections will  not  be ade-
     quate to capture  long-term effects of acid
     deposition.  Therefore, the null hypotheses
     of no  long-term effect should not be ac-
     cepted without caution, even  if it appears
     warranted by the current  data and theory.

SOS/T REPORT 18: RESPONSE OF VEGETATION
To ATMOSPHERIC DEPOSITION AND AIR
POLLUTION
  1.  Based  on crop-effects research conducted
     by NAPAP and other research programs,
     acidic precipitation at ambient levels in
     the United States has not been shown to
     be responsible for regional crop yield re-
     duction.

  2.  Ambient fog acidity concentrations are not
     great enough  to reduce the yield of agri-
     cultural crops, but under certain localized
     conditions  may  occasionally be  high
     enough to cause visible injury to plant tis-
     sue and thereby reduce  the marketability
     of sensitive crops.

  3.  Ambient  SO2 concentrations by  them-
     selves are not responsible for regional-
     scale crop yield reductions in the United
     States.

  4.  Nitrogen  dioxide  at  ambient concentra-
     tions is  not  a direct source of regional-
     scale growth or yield reduction in U.S. ag-
     ricultural crops.

  5.  Although pollutant mixtures  (e.g., SO2  +
     O3, or SO2 + NO2) are  of undetermined
     important on  a national  scale, at least in
     some  regions (e.g., Ohio River  Valley),
     ambient air quality  monitoring  suggests
                                             A-7

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                                                           APPENDIX A: SUMMARY OF N APAP REPORTS
    the potential for effects from mixed expo-
    sures.

6.  There is evidence that acidic cloud water
    in combination with other stresses affects
    some high elevation spruce forests in the
    eastern United States.

7.  Long-term changes in the chemistry of
    some sensitive  soils is  expected  from
    acidic  deposition,  but  it  is  uncertain
    whether this will result  in reduced forest
    health, how effects will be manifest, how
    much of the forest  resources will be im-
    pacted, or how long it will take for such
    effects to occur.

8.  There  is  no  conclusive  evidence  that
    acidic precipitation  is a major causal fac-
9.
tor in sugar maple decline, but in limited
areas where nutrient deficiency symptoms
are currently  evident,  acidic  deposition
could further exacerbate their expression.

Ambient SO2  concentrations are  not re-
sponsible for regional-scale growth reduc-
tions in the United States.
10. Nitrogen  dioxide at ambient concentra-
    tions is not  a  direct source  of  regional-
    scale growth reduction  in  forests of the
    United States.

11. The same concern about possible effects
    from  pollutant  mixtures   discussed  for
    crops  (Conclusion 5, above) applies  to
    forests.
                                              A-8

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      APPENDIX B

SELECTED PLOTS FROM EPA's
NITROGEN BOUNDING STUDY

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                                       APPENDIX B

           SELECTED PLOTS FROM EPA'S NITROGEN BOUNDING STUDY
INTRODUCTION
The  Nitrogen Bounding Study (NBS)1  is  one of
several  recent and ongoing studies conducted by
the U.S. Environmental Protection Agency (EPA) to
investigate aquatic and  terrestrial effects of acidic
deposition.  This study  was initiated  to address a
major issue that arose during EPA's completed Di-
rect/Delayed Response Project (DDRP), namely to
investigate the role of nitrogen compounds in the
soil water and  surface  water acidification within
forested watersheds.   Models and analyses  used
during the DDRP focused on sulfur deposition and
its effects on water chemistry, but effects due to ni-
trogen cycling received  much less attention.  That
difference in focus was  due to the general lack of
quantitative knowledge regarding nitrogen trans-
formation processes in soils. In addition, evidence
available when the DDRP was designed and initi-
ated primarily  indicated that  most deposited at-
mospheric nitrogen is taken up and held by biota,
thus making little contribution  to  acidification.
More recent evidence suggests, however, that
some forest  catchments  in the eastern  United
States, for example, can  become nitrogen saturated
and that nitrogen leaching from these systems can
contribute substantially to lake and stream acidifi-
cation,  particular during runoff episodes.  While
several  long-term studies intended to address the
role of nitrogen deposition in surface water acidi-
fication  are under way,  the NBS was intended to
provide  near-term  information  on  which  to
"bound" likely relationships for nitrogen and sulfur
deposition  on  surface-water   acidification  re-
sponses.

The  NBS  evaluated target  populations of  surface
waters in three sensitive geographic regions: lakes
in the Adirondack Region  and stream reaches in
the Mid Appalachian  Region and the Southern
Blue  Ridge Province.   Model projections com-
pleted during the NBS used a  modification of the
Model of  Acidification of Groundwater in Catch-
ments (MAGIC), the model of current  choice for
1 Van Sickle, J.,  M.R. Church.  1995.   Methods for
  Estimating the Relative Effects of Sulfur and Nitrogen
  Deposition  on  Surface Water  Chemistry.    U.S.
  Environmental Research Laboratory, Corvallis, OR.
assessing  many watershed  processes  associated
with acidic deposition.   It  includes a minimum
number  of critical  chemical  and  hydrological
processes occurring in watersheds to simulate soil
solution and surface water chemistry, and to pro-
ject average monthly or annual concentrations of
acid-base chemistry in surface water.    Primary
input data for its use in NBS came from  the  Na-
tional Surface Water Survey (NSWS), the DDRP,
and updated deposition information from EPA at-
mospheric   modeling    studies   discussed   in
Chapter 3 of this report.

Nitrogen uptake parameters  in the  model were
used to  provide simple  surrogates  for complex
processes within the nitrogen cycle. That is, these
parameters were adjusted to yield  "best case" (i.e.,
maximum nitrogen retention in the biota within a
watershed) and "worst case" (i.e.,  complete nitro-
gen saturation in the biota within a watershed) ap-
proximations to estimate the resulting combined
effects  by nitrogen and sulfur deposition  on lake
and stream acidity.  Thus, model  results provide
upper and lower bounds on the levels of acidifica-
tion that more realistic models (currently under
development) would likely project.

The NBS projected  surface water chemistry for two
target years (years  2015 and 2040) using the as-
sumption that emissions reductions of  10 million
tons SO2 and 2 million tons NOX mandated by the
1990 Clean Air Act Amendments of (CAAA) were
fully implemented.  As such, deposition  rates for
sulfur and  nitrogen were assumed to equal those
projected by atmospheric models to accompany
emissions    reductions    with     full   CAAA
implementation at  the year  2010  and that these
rates would be attained by the year 2020.

After the year 2010,  the NBS defined  different
deposition  scenario projections for years between
the years 2010 and 2020 using SO42' and NO3-
deposition  rates that decline linearly from  the
common year 2010 rates to a selection of  different
modeled year 2020 deposition rates for each sce-
nario modeled.  For example, some modeled sce-
narios   maintained the  2010 deposition  rates
through the  year  2020,  while some  alternative
                                               B-1

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 ACID DEPOSITION STANDARD FEASIBILITY STUDY
 modeled scenarios decreased the year 2010 rate to
 background  deposition  rates only  by  the  year
 2020.  Rates  for  still other modeled  scenarios
 decreased to  levels  between  these  extremes.
 (Background deposition  rates are those materials
 that originate from  only natural, agricultural fertil-
 izer, and  domestic  livestock sources.)  Each mod-
 eled deposition rate was then assumed to remain
 constant at the specific  modeled 2020 rate  until
 the year 2040,  the end of the model projection pe-
 riod. The selected plots from the NBS contained
 in this appendix include model projections for the
 years  2015  and  2040.  The  2040 plots  were
 primarily   depended  upon  for the  review  and
 conclusions from the NBS presented in Chapter 2
 of this report.

 In examining the NBS plots it is first important to
 recognize that the plotted response surfaces repre-
 sent only  projected proportions for the subpopula-
 tions of sensitive surface waters modeled by the
 NBS; they do not represent responses for either all
 surface waters  or for all NSWS  sampled surface
 waters in  the modeled regions.   Each page holds
 four NBS  plots displaying projected  response sur-
 faces over ranges of possible sulfur and nitrogen
 deposition rates at the year 2040.  Each of the four
 plots represent  one of the four possible durations
 used to bound  likely alterative times to watershed
 nitrogen saturation:  50 years,  100  years,  250
 years, and never (i.e., assumes  nitrogen uptake
 remains constant into  the future at  recently  esti-
 mated rates).

 Sets of pages are grouped within  the three mod-
 eled regions,  (1) Adirondacks Region, (2) mid-Ap-
 palachian  Region,  and (3)  Southern Blue Ridge
 Province.   Within the 10 pages for each region,
 one  each  is presented for  projections of relative
 proportions of  lakes with ANC<0 ueq/l, ANGS50
 ueq/l,  pH<5.0,  pH<5.5,  and  pH<6.0 over  the
 ranges of  sulfur and nitrogen depositions assessed
 for each region and for each of the four bounding
times to watershed nitrogen  saturation,  for  the
 years 2015 and 2040.

 INTERPRETING THE NBS PLOTS
To  illustrate interpretation  of the NBS plots,  the
first  page  of year  2040 plots  shows projected
 percentages of  NBS target population lakes in the
Adirondack Mountains having ANC of 0 ueq/l or
 less, under assumptions of four bounding times to
watershed  nitrogen  saturation equal 50, 100, and
250  years, and never  (i.e.,  constant).  Response
contours for each plot show how percentages of
target waters are projected to relate to possible
differences in total sulfur and nitrogen deposition
loading rates throughout the modeled ranges for
these depositions.   For these plots,  deposition
ranges  for  the  year 2040  begin  at  projected
background deposition rates for sulfur and nitrogen
(1 kg S/ha/yr and 4 kg N/ha/yr) and extend to their
maximum modeled concentrations (7.5 kg S/ha/yr
and 11.3 kg N/ha/yr), which are the rates pro-
jected  to accompany full implementation  of the
1990 CAM.

Thus,  the  plots  on  page   B-10  shows   NBS
projections  for proportions of Adirondack  lakes
having ANC<0 ueq/l.  The  upper right plot shows
projections for an assumed 100 years to watershed
nitrogen saturation.   Here,  in  the upper right
corner of this upper right plot, model projections
estimate that  approximately 26  percent of  the
target Adirondack lakes  may be acidic (ANC<0
ueq/l) in the year 2040 for  modeled  sulfur and
nitrogen deposition rates projected to accompany
implementation of the 1990 CAAA.   With only
"background" deposition of  sulfur and nitrogen, as
shown in the lower left corner of the upper right
plot, 3.4 percent of these target lakes are projected
to be acidic in 2040.

In reviewing these plots, it  is helpful  to recognize
that several  relationships  generally apply to all of
them:

   * The slopes of contour  lines in each  of the
     NBS response plots reflect the relative im-
     portance of sulfur and nitrogen  in causing
     the  projected   response   relationships.
     Nearly vertically plotted response contours
     indicate that the projected ANC response is
     attributable primarily to sulfur deposition.
     Nearly   horizontal   plotted   response
     contours indicate the plotted ANC response
     is   attributable   primarily   to   nitrogen
     deposition.   A forty-five degree diagonal
     contour indicates  equal  contributions  by
     both sulfur and nitrogen depositions.

   * Changes in the spacing between individual
     response contours within each plot appears
     to  be  attributable  to  patterns  in  sample
     weighting during model  projections, rather
     than due to some intrinsic character of the
     deposition-response relationships.

   * The density of response contours across the
     modeled deposition ranges for each plot di-
     rectly relates  to the potential average  re-
     sponsiveness by target waterbodies to po-
                                               B-2

-------
                                                                     APPENDIX 8: SELECTED NBS PLOTS
     tential changes in sulfur and nitrogen depo-
     sition rates on the specified water  quality
     classification variable modeled (e.g., ANC<
     0  ueq/l).   Therefore,  plots with a  high
     density of contour lines depict a high level
     of  responsiveness  to  future  possible
     changes in deposition rates.

   * In general, modeled ANC responses to re-
     ductions in sulfur deposition found during
     the NBS appear  to be linear  and propor-
     tionally equivalent  across the  ranges  of
     modeled sulfur reductions.  Additional in-
     vestigation may help to determine whether
     this relationship is due to  actual environ-
     mental  functions  or  to  some   artifact
     inherent in the model's application.

In considering possible individual extrapolation of
the results presented with these plots, beyond that
presented in the preceding chapters, care must be
taken to ensure that these results are  not over ex-
trapolated. That is, in  applying the NBS model re-
sults, as is the case when applying any simulation
modeling results, it is  important that  the assump-
tions underlying the modeling be understood and
carefully considered relative to additional  condi-
tions or systems to which they are  to be applied.
In doing this, the modeled processes should be de-
scribed and evaluated  to determine  how well they
correspond to  the system  (e.g.,  watershed)  for
which the application is intended.   In general,
models should only be applied to (i.e., constrained
to) systems, conditions, and assumptions that fall
within or very near the boundaries of those used to
develop the model. Whenever models are applied
outside these  boundaries,  the  consequences  of
knowingly violating the model's constraints should
be assessed as part  of the model analysis. Unfortu-
nately, violation of model assumptions cannot al-
ways be readily known or easily assessed.  Never-
theless, when model constraints are  not met by the
natural processes modeled or by the data collected
for model  input,  model projections typically will
deviate from  reality.   The magnitude of such
deviations  contribute markedly to what  is gener-
ally called model  uncertainty.  Reasons  why wa-
tershed models, including MAGIC, are particular
difficult to design and test include the  following.

   * Processes  controlling watershed functions
     are very difficult to observe either in nature
     or in any laboratory  experiment.  Thus,
     these processes may be either virtually un-
     known or inaccurately represented in the
     model, i.e., the model might not be a "true"
     model.

  * Actual  conditions within individual water-
     sheds that determine processing or transfer
     rates   may  be   unknown  or   poorly
     quantified.  Consequently, the model might
     be poorly parameterized, i.e., the modeled
     parameters may  be  poorly adjusted  or
     calibrated  to   approximate   parameters
     actually  occurring within  the  modeled
     system.

  « Inputs to the models can be poorly known
     or unable to be accurately predicted (e.g.,
     dry deposition loads to a watershed).

  * Models often are difficult to test.  That is,
     models  may  be  largely  "unverified,"
     "unconfirmed," or "unvalidated."   In fact, it
     is often argued that a model can never be
     confirmed to be true, it can only be falsi-
     fied by failing to accurately project some
     outcome.  Further, when a  model does ac-
     curately predict an outcome, its validity is
     not proven, because the "right" result may
     have been projected for the wrong reason.

Further, it is  useful to remember that environ-
mental monitoring and simulation modeling have
complementary  environmental  assessment  roles.
Effects monitoring (i.e.,  surface water chemistry) is
necessary to determine the actual effects of acidic
deposition rates on environmental resources and to
provide data needed to develop  and  test models.
In turn, simulation modeling is useful  to project
potential differences among  future deposition or
environmental scenarios. This is particularly  true
for projections of acidic deposition effects because
no  set of monitoring records of sufficient length
exist  that allow establishing  a clear statistical
relationship  linking changing historic ecological
responses to  changing  acidic  deposition  input
rates. Without this historic record it is not possible
statistically  to  project  future changes,  i.e., we
cannot  predict the future  directly from the  past
because we  do not know the past.

Simulation  models, such  as the MAGIC model,
generally do not require well quantified historical
relationships  to   provide   potentially   useful
projections  of future  conditions.  But  watershed
simulation modeling,  including  the  NBS,  often
continues to include significant  uncertainties, as
noted in the above paragraphs and in Chapter 2.
This is especially the case  regarding the modeling
of nitrogen cycling within watersheds and the po-
                                                B-3

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
tential acidifying effects of nitrogen deposition on
soils, watersheds, and  associated surface waters.
Additional uncertainties also remain regarding ex-
actly which processes to include in such models
and  about how such processes should be linked
within these models.   Further, there is almost a
complete  dearth  of  monitoring  and   survey
information on the regional distributions of water-
shed characteristics that would allow such models
to be calibrated  and  applied to project future
effects. Improving capabilities to model these rela-
tionships will lead to better projections of potential
future environmental effects from both  sulfur and
nitrogen  deposition.  Present knowledge of nitro-
gen cycling and early steps toward nitrogen mod-
eling provides a solid foundation for more impor-
tant and  productive advances in this field.  These
advances, particularly, would lead to significantly
reduced  uncertainty  in  potential future effects of
nitrogen.

-------
                                                               APPENDIX B:  SELECTED NBS PLOTS
Percent of target, population lakes with ANC<=0,
AdirondacRs Region at Year 201 5
where depositjon=median regional @ year 2015.
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rogen Deposition (kg h
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\ .
6.5%

i i i i i I
0 2 4 6 8 10
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 250 yr)
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen uptake constant)
                                      B-5

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population lakes with ANC<=50,
Adirondacks Region at Year 2015
where deposition=median regional @ year 201 5.
12 •
-5
j 10 -
Deposition (kg N
O) 00
i i
c
is
~S 2 -
S
0 -
12 -
J 10 -
rogen Deposition (kg N)
A O> 00
i i i
;=:
3 2 -
0 -


^^
55.4%

i i i i i i
0 2 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 50 yr)


ei
53.5 %

i i i i i i
0 2 4 6 8 10
12 -
^?
g 10 -
f -
1 ••
O
Total Nitrogen
0 10 *
i i i
12 -
1,0-
2
O
i 8"
8 e -
8- 6
Q
o A
8° 4
ss
Z
3 2 r-
0 -

t
)
V
53.4%

i i i ii i
0 2 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)

~T
.A
53.5%"

i i 1 i ! '
024 6 8 10
             Total Sulfur Deposition (kg S/ha/yr)
           (Assumes nitrogen saturation @ 250 yr)
Total Sutfur Deposition (kg S/ha/yr)
(Assumes nitrogen uptake constant)

-------
                                                               APPENDIX B:  SELECTED NBS PLOTS
Percent of target population lakes with pH<=5.0,
Adirondacks Region at Year 201 5
where deposfton=median regional @ year 2015.
pH estimated from empirical pH-ANC model.
12 -
J 10 -
rogen Deposition (kg K
•*»• O) 00
. i i i
Z
"a 2 -
£
0 -

x^
^^VQ
16%

till
0246



i i
8 10
12 -
1 10 -
rogen Deposition (kg Is
4* 
I
8%

6
j


8 10



   Total Sulfur Deposition (kg S/ha/yr)
 (Assumes nitrogen saturation @ 50 yr)
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)
1
O9
Deposlllon (t
c
1
Z

12 -
10 -

8 -
6 -

4 -
2 -
0 -

\ VI
( i
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3.3%




i i i i i i
0 24 6 3 10
                                           *
                                           .2
                                           Si
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12 -
10 -
8 -
6 -
4 -
2 -
0 -



i
3.
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5%.



i i i i i i
0 2 4 6 8 10
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 250 yr)
  Total Sulfur Deposition (kg S/ha/yr)
  (Assumes nitrogen uptake constant)
                                       B-7

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                         Percent of target population lakes with pH<=5.5,
                                Adirondacks Region at Year 201 5
                         where deposition=median regional @ year 2015.
                           pH estimated from empirical pH-ANC model.


ogen Deposi
To
     12  -
     10 -
                       25.4%
          i
          0
i
2
i
4
i
6
i
8
a/yr
kg
io
Total Nitrogen Dep
10
i
0
i
2
i
4
i
6
i
8
 i
10
            Total Sulfur Deposition (kg S/ha/yr)
          (Assumes nitrogen saturation @ 50 yr)
                                            Total Sulfur Deposition (kg S/ha/yr)
                                          (Assumes nitrogen saturation @ 100 yr)
12 -
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C3
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i i i i i i
0 2 4 6 8 10
a/yr
otal Nitrogen Deposition (kg
                                                      0 -
                                                                                *l4-
                                                                       9.6 %
                                                          r^
                                                          0
                                                       !
                                                       4
                                                       i
                                                       6
                                                       8
                                                      10
           Total Sulfur Deposition (kg S/ha/yr)
         (Assumes nitrogen saturation @ 250 yr)
                                           Total Suifur Deposition (kg S/ha/yr)
                                           (Assumes nitrogen uptake constant)
                                             B-8

-------
                                                                APPENDIX B: SELECTED NBS PLOTS
Percent of target population lakes with pH<=6.0,
Adirondacks Region at Year 2015
where deposition=median regional @ year 2015.
pH estimated from empirical pH-ANC model.
12 -
>.
^ 10 -
2 „
Total Nitrogen Deposition (kg N/ha/yr) Total Nitrogen Deposition
0 IU * 0> CO 0 • M OMATOO
r-J 	 1 	 1 	 1 	 1 	 	 II 1 I , 1 I

J ^ ?
38.1 %
i i i i i i
0 2 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 50 yr)

Hi
30.2%
i i i i i i
0 2 4 6 8 10
Total Nitrogen Deposition (kg N/ha/yr)
O M A O) 00 O N>
II 1 1 1 1 1

Jl
A. W«- 
-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                               Percent of target population lakes with ANC<=0,
                                      Adirondacks Region at Year 2040
                              where deposition=median regional @ year 2020.
            o
            f
           a
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      12 -

      10 -

       a -

       s -

       4 -

       2 -
                0 -
                                      6
                                  8
 10
                      Total Sulfur Deposition (kg S/ha/yr)
                    (Assumes nitrogen saturation @ 50 yr)
                                                             12 -
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10
                                                         Total Sulfur Deposition (kg S/ha/yr)
                                                       (Assumes nitrogen saturation @ 100 yr)
               12 -
               10  -
          *   8  -
           
-------
                                                               APPENDIX B: SELECTED NBS PLOTS
                   Percent of target population lakes with ANC<=50,
                            Adirondacks Region at Year 2040
                   where deposition=median regional @ year 2020.
     12 -
     10 -
 I
 o
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6 -

4 -

2 -

0 -
            53.2%
          i
          0
                           B
i
8
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                                 10
           Total Sulfur Deposition (kg S/ha/yr)
          (Assumes nitrogen saturation @ 50 yr)
                                              t
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                                                         50.9%
i
0
i^
4
i
8
10
                                                         Total Sulfur Deposition (kg S/ha/yr)
                                                       (Assumes nitrogen saturation @ 100 yr)
    12 -

j  10 -


f   8-
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Q
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o
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     0 -
           44.1 %
                                 8
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                                      10
           Total Sulfur Deposition (kg S/ha/yr)
         (Assumes nitrogen saturation @ 250 yr)
             •^
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                                              2
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                                              6 -

                                              4."

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                                              0 -
                                                          44%
                            i
                            2
                                                                          8    10
                                                         Total Sulfur Deposition (kg S/ha/yr)
                                                         (Assumes nitrogen uptake constant)
                                          B-11

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
     12 -

1   10 -
OJ
t    8-
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3    2 -

      0 -
             4.1 %
                          Percent of target population lakes with pH<=5.0,
                                Adirondacks Region at Year 2040
                         where deposition=median r  „
                           pH estimated from empirical pH
                    8
                                         10
            Total Sulfur Deposition (kg S/ha/yr)
           (Assumes nitrogen saturation @ 50 yr)
                                                      12 -
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                                                model.
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8
10
                                             Total Sulfur Deposition (kg S/ha/yr)
                                           (Assumes nitrogen saturation @ 100 yr)

Q.
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    10 -

     8 -

     6 -

     4 -

     2 -

     0 -
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10
           Total Sulfur Deposition (kg S/ha/yr)
         (Assumes nitrogen saturation @ 250 yr)
                                 3
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                   i
                   8
                  10
                                            Total Sulfur Deposition (kg S/ha/yr)
                                            (Assumes nitrogen uptake constant)
                                             B-12

-------
                                                                   APPENDIX B: SELECTED NBS PLOTS
                                                          Will i yH<=5.5,
                         percent or target
      it or target popuiauon lanes wiui pn
       AdirondacKS Region at Year 2040
wheredeposition=median regional ©year 2020.
  pH estimated from empirical pH-ANC model.
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     10 -

      8 -

      6 -

      4 -

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                                    6.1 %
                                   8
                                        10
                                 i
                                 0
i
8
                                i
                               10
            Total Sulfur Deposition (kg S/ha/yr)
           (Assumes nitrogen saturation @ 50 yr)
                                                            Total Sulfur Deposition (kg S/ha/yr)
                                                          (Assumes nitrogen saturation @ 100 yr)
     12 -
8
Q.
O
Q

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                         Percent of target population lakes with pH<=6.0,
                                AdirondacKS Region at Year 2040
                         wheredeposition=median regional ©year2020.
                           pH estimated from empirical pH-ANC model.
     12  -
     10  -
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                                            *    8-
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2
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4
I
6
i
8
                                                                                         10
                                                       Total Sulfur Deposition (kg S/ha/yr)
                                                     (Assumes nitrogen saturation @ 100yr)
 
-------
                                                                APPENDIX B: SELECTED NBS PLOTS
                  Percent of target population streams witn ANu<=u,
                         Mid-Appalachian Region at Year 2015
                   where deposition=median regional @ year 201 5.
a/yr)
n (kg
en Depos
 ?    4-.
otal Nhr
a/yr)
on (kg
ogen De
                               8
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8
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           Total Sulfur Deposition (kg S/ha/yr)
          (Assumes nitrogen saturation @ SO yr)
                                          Total Sulfur Deposition (kg S/na/yr)
                                        (Assumes nitrogen saturation @ 100 yr)
ion (kg N/h
 «
Q

 
-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population streams witn ANo<=50,
Mid-Appalachian Region at Year 201 5
where deposffion=median regional @ year 201 5.
14 -
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Total Sulfur Deposition (kg S/ha/yr)








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Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 250 yr) (Assumes nitrogen uptake constant)
                                                B-16 :

-------
                                                               APPENDIX B:  SELECTED NBS PLOTS
Percent of target population streams with pH<=5.0,
Mid-Appalachian Region at Year 2015
where deposition=median regional @ year 2015.
pH estimated from empirical pH-ANC model.
14 -
1 12-
z
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*«
§.
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e

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population streams with pH<=5.5,
Mid-Appalachian Region at Year 2015
where deposition=median regional ©year 2015.
pH estimated from empirical pH-ANC model.
14 -
I 12-
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Deposition (kg
at oo o
§
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3.8%





i i i i i i
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Total Sulfur Deposition (kg S/ha/yr) Total Sulfur Deposition (kg S/ha/yr)
14 -
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2 10 -
1 '-
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1_ *T
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0 -
(Assumes nitrogen saturation @ 50 yr)

\
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0 2 4 6 8 10
14 -
1? 12 -
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1 ,.
1
& e-

-------
                                                               APPENDIX B: SELECTED NBS PLOTS
Percent of target population streams with pH<=6.0,
Mid-Appalachian Region at Year 201 5
where deposition=median regional ©year 2015.
pH estimated from empirical pH-ANC model.
14 -
f 12-
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o

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0 -
14 -
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Nitrogen DeposHion (kg N
* O) CO O
i i i i
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i i i i i i
0 2 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 50 yr)

N!i^tli'
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4.3%


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14 -
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Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)

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0 2 4 6 8 10
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 250 yr)
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen uptake constant)
                                      B-19

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population streams with ANC<=0,
Mid-Appalachian Region at Year 2040
where deposition=median. regional @ year 2020.
14 -
i .2-
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i-
& 6-
1 4"
l ^
0 -
14 -
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itrogen Deposition (kg N
A en oo o
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02 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 50 yr)

J
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%
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0 2 4 6 8 10
14 -
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Total Nitrogen Deposition
O CO 4k O) CO
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A 0> CO O
i i i i
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0246 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)

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1 1 1 1 1 i
0 2 4 6 8 10
              Total Sulfur Deposition (kg S/ha/yr)
           (Assumes nitrogen saturation @ 250 yr)
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen uptake constant)
                                                B-20

-------
                                                               APPENDIX B:  SELECTED NBS PLOTS
                  Percent of target population streams with ANC<=50,
                         Mid-Appalacnian Region at Year 2040
                    where deposition=median regional @ year 2020.
     u -


 I  12-

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 41
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            5.3%
          0    2    4     6    3   10


            Total Sulfur Deposition (kg S/ha/yr)

          (Assumes nitrogen saturation @ SO yr)
                                              14  -



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                                        4 -



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                                                  (Assumes nitrogen saturation @ 100 yr)
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4.6%
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         (Assumes nitrogen saturation @ 250 yr)
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                                                   Total Sulfur Deposition (kg S/ha/yr)

                                                   (Assumes nitrogen uptake constant)
                                        B-21

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population streams with pH<=5.0,
Mid-Appalachian Region at Year 2040
where deposition=median regional ©year 2020.
pH estimated from empirical pH-ANC model.
14 -
| 12-
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§
1 8 "
Total Nitrogen Depc
ro 4k o>
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Total Sulfur Deposition (kg S/ha/yr)
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1 1 1 I 1 1
0 2 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)



0



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                       4
8
10
            Total Sulfur Deposition (kg S/ha/yr)
          (Assumes nitrogen saturation @ 250 yr)
                               Total Sulfur Deposition (kg S/ha/yr)
                              (Assumes nitrogen uptake constant)
                                                 B-22

-------
                                                                  APPENDIX B: SELECTED NBS PLOTS
                        Percent of target population streams with pH<=5.5,
                              Mid-Appalachian Region at Year 2040
                         where deposition=median regional @ year 2020.
                           pH estimated from empirical pH-ANC model.
 s
.2
i

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                         Percent of target population streams with pH<=6.0,
                               Mid-Appalachian Region at Year 2040
                         where deposition=medan regional @ year 2020.
                            pH estimated from empirical pHrANC model.
 O
 0s
 a
 .o
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      10 H
       8H
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             2.3%
                                                 14 -


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                                 8
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      10
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           (Assumes nitrogen saturation @ SO yr)
                                                        Total Sulfur Deposition (kg S/ha/yr)
                                                      (Assumes nitrogen saturation @ 100 yr)
I
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i

4
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8
10
            Total Sulfur Deposition (kg S/ha/yr)

          (Assumes nitrogen saturation @ 250 yr)
                                                       Total Sulfur Deposition (kg S/ha/yr)

                                                       (Assumes nitrogen uptake constant)
                                            8-24

-------
                                                             APPENDIX B:  SELECTED NBS PLOTS
Percent of target population streams with ANC<=0,
SouthemBlue Ridge Region at Year 201 5
where deposition=meaian regional @ year 2015.
12 -
Total NHrogen DeposHlon (kg N/ha/yr)
ro i A o> oo o
•
i i i i i
0 -
12 -
Ion (kg N/ha/yr)
•A
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1 1
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0%

1 . 1 1 1 1 1
0. 2 4 6 8 10
Total Sutfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 50 yr)




\
0%


i i i i i i
0 2 4 6 8 10
12 -
Total Nitrogen DeposHlon (kg N/ha/yr)
IO A O> 00 O
1 1 1 1 1
0 -
12 -
f 1Q-
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0
Q
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0%

i i i 1.1 i
0 2 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)


- -

V
0%


i i i i i i
0 2 4 6 8 10
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 250 yr)
Total Sutfur Deposition (kg S/ha/yr)
(Assumes nitrogen uptake constant)
                                     B-25

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population streams with ANC<=50,
Southern Blue Ridge Region at Year 2015
where deposition=meaian regional @ year 2015.
osltlon (kg N/ha/yr)
» oo o ro
O
Q
o A
I ."
3 2 -
0 -


14.6%"
i i i i i
02468

i
10
Total Nitrogen Deposition (kg N/ha/yr)
o ro 4k o> a o ro
i i i i i i i

KJ. \v
>v T*
i: -a rO
6.7%
i i i i i i
0 2 4 6 8 10
              Total Sulfur Deposition (kg S/ha/yr)
             (Assumes nitrogen saturation @ 50 yr)
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)

 o
 Z
 "3
12 -
10 -
8 -
4 -
2 -
0 -
-


A
5.9%

•
i i i i i i
0 24 6 8 10

>n (kg N/ha/yr)
1
a.
Q
c
Z

12 -
10 -
8 -
6 -
4 -
2 -
0 -


N\Sr
N ^
T
3.7%


i i i i i i
0 2 4 6 8 10
             Total Sulfur Deposition (kg S/ha/yr)
           (Assumes nitrogen saturation @ 250 yr)
 Total Sulfur Deposition (kg S/ha/yr)
 (Assumes nitrogen uptake constant)
                                                 B-26

-------
                                                               APPENDIX B: SELECTED NBS PLOTS
Percent of target population streams with pH<=5.0,
Southern Blue Ridge Region at Year 201 5
where deposttion=median regional @ year 2015.
pH estimated from empirical pH-ANC model.
12 -
1 10 -
OJ
t 8 "
O
I 6-
01
a
e
« 4 _
Z
3 2 -
0 -




A






i i i
024





t»

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1 1
6 8











12 -
j 10 -
51
* 8 -
§
! 6-
0
O
e
o A
.?
si
Z
5 2 -
0 -





^ h>

\
0%



1 i i i i i i
10 0 2 4 6 8 10
Total Sulfur Deposition (kg S/ha/yr) Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 50 yr) (Assumes nitrogen saturation @ 100 yr)
12 -
J 10 -
o
^ 8 -
c
1 6
Q. °
O
Q
c
1 4 "
Z
•5 2 -
o
1-
0 -




A







b
i
i







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i i i
024





• '
6 8





12 -
^| 10 -
a
* 8 -
c
8 s _
a. o
a
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o ..
I
Z
5 2 -
'o

0 -



-

T -
\
\
0%





i i i i i i i
10 0 2 4 6 8 10
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 250 yr)
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen uptake constant)
                                      B-27

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population streams with pH<=5.5,
Southern blue Ridge Region at Year 201 5
where deposjtjon=meaian regional @ year 2015.
pH estimated from empirical pH-ANC model.
12 -
^ 10 -
2
I
1 6-
4)
O
5? ^ ~
z
•S 2 -
0 -



\ -
0% '

i i i i i
02468



t
10
12 -
fotal Nitrogen Deposition (kg N/ha/yr)
to *. m oo o
i i i i i
0 -
Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 50 yr)
12 -
g 10 -
i 8.
o
1 • -

-------
                                                         APPENDIX B: SELECTED NBS PLOTS
              Percent of target population streams with pH<=6.0,
                  Southern Blue Ridge Region at Year 201 5
               where deposition=median regional @ year 2015.
                 pH estimated from empirical pH-ANC model.
12 -
1 10 -
Z
O9
* a -
§
3S
1 6-
%
1 10 -

2
t 8 -
o
xs
I 6-
O
Q
c
1 '-
w
z
5 2 -
Q
*~
0 -







t








I
0%






i i i i i
0 24 6 8

















12 -
5l
^ 10 -

O3
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§
1 6-
a
a
c
1 «-
w
Z
•5 2 -
"o
l-
0 -





-

-


A
0%






i 1 1 1 1 I 1
10 0 2 4 6 8 10
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 250 yr)
 Total Sulfur Deposition (kg S/ha/yr)
 (Assumes nitrogen uptake constant)
                                   B-29

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
Percent of target population streams witn ANtx=u,
Southern Blue Ridge Region at Year 2040
where deposition=meaian regionai @ year 2020.
12 -
J 10 -
1 •-
2.
Total Nitrogen DepoaK
.6 10 4k 0)
i , ' . •
12 -
Itlon (kg N/ha/yr)
CO O
1 6-

-------
                                                              APPENDIX B: SELECTED NBS PLOTS
                  Percent of target population streams with ANC<=50,
                       Southern Blue Ridge Region at Year 2040
                    where deposffion=meaian regional @ year 2020.
 §•
 Q
 8"
12 -



10 -



 8 -



 6 -



 4 -
 3    2 H
 o
      o H
                                 8
                                 10
            Total Sulfur Deposition (kg S/ha/yr)

          (Assumes nitrogen saturation @ 50 yr)
                                               ea
0.
o
a

a
                                         I
                                                  12 -
                                                  10 -
                                                   s H
                                                   4 H
                                              o H
                                                         3.8%
                          6
8
            10
                                                   Total Sulfur Deposition (kg S/ha/yr)

                                                  (Assumes nitrogen saturation @ 100 yr)
o
     12  -
     10  -
     6 -
     4 -
z
3    2 H
     o H
         i       i     ii     r
                           a
                                      10
           Total Sulfur Deposition (kg S/ha/yr)

         (Assumes nitrogen saturation @ 250 yr)
                                              OJ
                                              x.
                                              o
                                              Q

                                              o
                                             12 -



                                             10 -



                                              8 -



                                              6 -



                                              4 -
              2
                                                                  4
~T^

 6
                                                                                   10
                                                   Total Sulfur Deposition (kg S/ha/yr)

                                                   (Assumes nitrogen uptake constant)
                                       B-31

-------
 ACID DEPOSITION STANDARD FEASIBILITY STUDY
                        Percent of target population streams with pH<=5.0,
                             Southern Blue Ridge Region at Year 2040
                         where deposltion=median regional @ year 2020.
                            pH estimated from empirical pH-ANC model.
 *
  3
  8-
 Q
  4)

 f
  ffl
 .0
12 -
10 -
8 -
6 -
4 -
2 -

0 -





t







0%


I
I
c
jo
I
o
Q
e

-------
                                                                   APPENDIX B: SELECTED NBS PLOTS
                        Percent of target population streams with pH<=5.5,
                            Southern Blue Ridge Region at Year 2040
                         where deposition=median regional ©year 2020.
                           pH estimated from empirical pH-ANC model.

     12 -
     10  -
8    e  -I
g-   6  "I
Q
 0>
      4  -
      2 -
      0 -
\
0%
I
6
i
8
                                                     12 -
                                                     10 -
I

I   8-
JO
1
Q.
0>
Q

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                        Percent of target population streams with pH<=6.0,
                            Southern Blue Ridge Region at Year 2040
                         where deposition=meaian regional @ year 2020.
                           pH estimated from empirical pH-ANC model.
a/yr)
     12 -
     10 -
 f   8H
 _   6 -
 «
 O
 g    .  ,
 £   4 H
 Z
 «    2

      0
a/yr
Total Nitrogen De
O
1
(kg

09
1
o>
1
O
1
                             6
8     10
i
0
i
2
6
i
8
 i
10
            Total Sulfur Deposition (kg S/ha/yr)
           (Assumes nitrogen saturation @ 50 yr)
  Total Sulfur Deposition (kg S/ha/yr)
(Assumes nitrogen saturation @ 100 yr)
12 -
j 10 -
1 "
l •-
Q
O *
? "
Z
CB 2 ™
0 -




^
c





)%





0 2 4 6 8 10
12 -
j 10 -
0)
* 8-
i
8 s -
o. o -
o
0
I 4"
Z
•« 2 -
s
0 -




i
C



"

)%





1 1 1 1 1 I
0 2 4 6 8 10
           Total Sulfur Deposition (kg S/ha/yr)
         (Assumes nitrogen saturation @ 250 yr)
 Total Sulfur Deposition (kg S/ha/yr)
 (Assumes nitrogen uptake constant)
                                             B-34

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        APPENDIX C

RANGE OF INFLUENCE OF EMISSIONS
FROM RADM TAGGED SUBREGIONS

-------

-------
                                       APPENDIX C

                         RANGE OF INFLUENCE OF EMISSIONS
                         FROM RADM TAGGED SUBREGIONS
This report  includes the first extensive use  of  a
Eulerian  model to study source-receptor relation-
ships.  Source-receptor relationships  are used  in
this report to analyze changes in sources of deposi-
tion from implementation of Title IV  of the Clean
Air Act Amendments of 1990 and to  investigate
the effectiveness of several geographically targeted
emissions reductions strategies to achieving target
loads  in sensitive receptor  regions.  The Tagged
Species Engineering Model1 was developed under
NAPAP to study such relationships.  The Tagged
Species Model gives the Eulerian RADM modeling
system the  capability to identify, for  assessment
purposes, the concentration  and deposition fields
attributable  to specified SO2 emissions sources in
the presence of the full concentration  fields. The
Tagged Model  preserves the oxidant competition
across space and time.  A tagging concept is ap-
plied in which additional, identical mass conserva-
tion equations are solved for a portion of the sulfur
concentration  field that originates from  specific
geographical locations  within the full modeling
domain.  This allows  tagged concentration fields
and tagged wet and dry deposition to  be identified
and tracked  in the model separate from, yet as por-
tions of, the  total sulfur chemical environment that
is nonlinear and that produces the complete  con-
centration and deposition fields.

Calculations from the Tagged Species Model illus-
trate the distances over which  an SO2 emissions
source can have an influence. The results from this
model permit the visualization  of source attribu-
tion. Emissions from a subregion (see Exhibit 19 for
the 53 tagged RADM subregions)  have a range of
influence is more than 1,000 kilometers. Typically,
the range  of influence of a subregion extends out
to between 500 and 1,200 kilometers.  The  dif-
ference  in scale of influence is primarily  due to
meteorology. A number of meteorological  factors
influence the existence of dominant transport di-
rections and determine how sources of SO2 emis-
sions influence nearby regions. Key factors  are the
position of the jet stream, which moves  storms
across the upper  Mid-West; the influence of the
Appalachian Mountains on winds  and rainfall  pat-
terns; the  Bermuda highs (stagnation) that move
Ohio River Valley emissions  in a counter-clock-
wise  direction; and the  ocean  and  Gulf Coast
weather that produces  lighter  winds and more
convective conditions, including a typically large
proportion of convective  clouds across the south-
ern states. Thus, the patterns and ranges of source
influence can vary. Models, such as those in the
RADM system,  help to interpret and explain the
deposition at receptors of  interest.

This appendix contains maps of which show the
proportion of total annual  sulfur  deposition  con-
tributed  by each of the 53 tagged RADM subre-
gions in 1985 and projected for 2010 with imple-
mentation of Title IV.
1 McHenry,  J.N.,  F.S.  Binkowski,  R.L. Dennis,  J.S.
  Chang, and D. Hopkins. 1992.  The tagged species
  engineering model (TSEM). Atmospheric Environment
  26A(8):1427-1443.
                                               C-1

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                  C-2

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          APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS
C-3

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
IvJL
                                               C-4

-------
          APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS
C-5

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                 C-6

-------
         APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-7

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                 C-8

-------
          APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS
C-9

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                C-10

-------
           APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-11

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                C-12

-------
                     RANGE OF INFLUENCE OF EMISSIONS
C-13

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-14

-------
                     RANGE OF INFLUENCE OF EMISSIONS
C-15

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-16

-------
          APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS
C-17

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                               C-18

-------
           APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-19

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                               C-20

-------
           APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-21

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                C-22

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  „.    ~vAppENDixC:  RANGE OF INFLUENCE OF EMISSIONS
C-23

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-24

-------
          APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-25

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                               C-26

-------
          APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS
C-27

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-28

-------
           APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS
C-29

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                 C-30

-------
          APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-31

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                               C-32

-------
           APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-33

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-34

-------
          APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-35

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                 C-36

-------
APPENDIX C: RANGE oNr*
	:	    J  •/'(
                                      OF EMISSIONS
C-37

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-38

-------
           APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-39

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-40

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APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY

-------
           APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
                           *. a-    ~R?::-.. ^safr.. '-s*
C-43

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                               C-44

-------
                   :  RANGE OF INFLUENCE OF EMISSIONS
C-45

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-46

-------
          APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-47

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-48

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EMISSIONS
APPENDIX C: RANGE OF

-------
ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                              C-50

-------
           APPENDIX C:  RANGE OF INFLUENCE OF EMISSIONS
C-51

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ACID DEPOSITION STANDARD FEASIBILITY STUDY
                                                C-52

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          APPENDIX C: RANGE OF INFLUENCE OF EMISSIONS
C-53

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ACID DEPOSITION STANDARD FEASIBILITY STUDY


-------