ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794J )276 €I (217) 782-21329

James R. Thompson Center, 100 West Randolph, Suite 11-300, Chicago, IL 60601 @ (312) 814··6026

PAT QUINN, GOVERNOR

217/782-5544

217/782-9143 (TDD)

June 24, 2011 CERTIFIED MAIL

7009 2820 0001 7492 1699

Ms. Cheryl A. Ne"Wlon, Director

Otnce ofthe Air and Radiation Division

U. S. Environmental Protection Agency Region V (R-18J)

77 West Jackson Boulevard

Chicago, IL 60604-3507

Re: Regional Haze Program Requirements

n 0 DearM~:

Pursuai1t to Section 169A ofthe Clean Air Act ("CAN') (42 U.S.C. § 7491) and Section 4 ofthe

Illinois Environmental Protection Act (4] 5 ILCS 5/4), the Illinois Environmental Protection

Agency submits the enclosed revision to the Illinois State Implementation Plan ("SIP"). This

revision has been prepared to satisfy Illinois' obligation under these sections to develop a

Regional Haze SIP with measures necessary to make reasonable progress towards remedying

visibility impairment in Class I areas. Under 40 CFR § 51.308, the core requirements for the

plan include reasonable progress goals, calculations of baseline and natural visibility conditions,

a long-term strategy for regional haze, a monitoring strategy, and Best Available Retrofit

Technology requirements for regional haze visibility impairment.

In order to assist with your review ofthis plan submittal, the following documents are enclosed (two

hard copies and one electronic copy on disc):

Attachment 1) Regional Haze State Implementation Plan for Illinois, AQPSTR 10-08,

May] 0,2011.

• Appendix A, Draft List ofClass I Areas Located Within (or

Impacted by) Midwest RPO States, June 26, 2007.

• Appendix B, Regional Air Quality Analysis for Ozone, PM25 , and

Regional Haze: Final Technical Support Doeument, April 25,

2008.

• Appendix C, 2012 Site Directory (Illinois Air Monitoring

Network).

Rockford .. 4)(1'.1 N. ,'Aain St., Rockford, Il611CJ3 e (815) 987-77(,()

f.lgin .. .'595 S, Stale, Elgin, It. 60123 .. (847) 608-3131

Bureau of land - Peoria /620 N. University SL, I'eoriil, IL 61614" (309) 693-5462

Collinsville ,2009 Mall Street, Collinsville, IL 62234 0 (618) 346-5120

--------_._--~_._-----

Des Plaines" 95 11 W. Harrisoll 51., Des Plaines, IL 60016 e (847) 294·if1JUO

Peoria .. 5415 N. University 51.. Peoria, Il 61614" (09) 69]-'i463

Champaign" 2125 5. Firq 51., Champaign, IL 611J20" (2'17) 278-5800

Marion .. 2309 W. M,lin St., Suite 11&, Marion, IL 62959 e (618) 993·7200
Attachment 2)

Attachment 3)

Attachment 4)

Attachment 5)

Attachment 6)

Attachment 7)

Attachment 8)

Attachment 9)

Attachment 10)

Attachment 11)

Technical Support Document for Best Available Retrofit Technology

Under the Regional Haze Rule, AQPSTR 09-06, April 29, 2011.

• Appendix A, Single Source Modeling to Support Regional Haze

BART Modeling Protocol, March 21, 2006, Lake Michigan Air

Directors Consortium.

• Appendix B, Regional Air Quality Analysis for Ozone, PM2s, and

Regional Haze: Final Technical Support Document, April 25,

2008. (See Attachment 1, above)

• Appendix C, llIinois Mercury RLlle, 35 Ill. Adm. Code 225.

• Appendix D, BART Analysis for the Kincaid Power Plant, ENSR

Corporation, January 2009, Document No. 02285-076-400.

• Appendix E, Consent Decree between the United States of

America, et a1. and ExxonMobil Corporation, et a1.

• Appendix F, Consent Decree between the United States of

America, et a1. and CITGO Petroleum Corporation, et a1.

Ameren Energy Resources, Notice of Intent, dated December 27,2007.

Dynegy Midwest Generation, Inc., Notice of Intent, dated November 26,

2007.

Midwest Generation, LLC, Notice ofIntent, dated December 27, 2007.

Notice of Hearing

Presentations of Hearing held December 6, 2010

Transcript of Hearing held December 6, 2010

Responsiveness Summary

Kincaid Generation, LLC, Joint Construction and Operating Permit

City of Springfield (CWLP) Joint Construction and Operating Permit

In addition, the Regional Haze SIP Checklist is enclosed to assist in your review. If further

information is required, please contact Rob Kaleel, Manager, Air Quality Planning Section, Bmeau

of Air, at 217/785-4]40.

Sincerely,

d-~~ Lamel L. Kroack

Chief, Bureau of Air

Attachments

2
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

Purpose: 

This checklist has been prepared by EPA staff to use in reviewing regional haze SIPs to ensure that the SIPs have the necessary components. The 

checklist represents our best efforts to summarize the requirements of the regional haze rule but it is not a regulation and does not change or 

substitute for any legal requirements in the Clean Air Act (CAA) or the regional haze rule. Any decisions regarding the completeness of a particular 

SIP will be made based on the CAA and the relevant regulations. Therefore, interested parties are free to raise questions and objections to the 

checklist and its use in a particular situation.

Acronyms and Terms:

BART is Best Available Retrofit Technology

CAA is the Clean Air Act

CAIR is Clean Air Interstate Rule

EI is Emissions Inventory

FLM is Federal Land Manager

Glidepath is the linear rate of improvement sufficient to attain natural conditions by 2064

LTS is Long Term Strategy

RAVI is Reasonably Attributable Visibility Impairment

RHR is the Regional Haze Rule

RPO is Regional Planning Organization 

RPG is Reasonable Progress Goal

Notes:

1. This checklist is based on Appendix V to 40 CFR Part 51, and 40 CFR 51.308, as updated by the BART Rule (70 FR 39104, July 6,

2005), and the trading rule, as proposed in 70 FR 44154, August 1, 2005. This checklist will be revised if necessary, should that be 

necessitated by the final version of the trading rule. 

2. All boxes should either be “Y” or “N/A” or the SIP may be deficient.

3. This checklist assumes the State will not be participating in a trading program, or other alternative measure to BART. If this is not the 

case, then additional/alternative regulations that appear in 51.308(e)(2) and (3) apply.

4. Only the requirements from 51.308 pertaining to the current RH SIP submission, and not those pertaining to future revisions and/or 

reports required under 51.308(f), (g), and (h) (except for a SIP commitment to do them), were included.
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

2

5. The “1999 RHR” is 64 FR 35714, July 1, 1999.

6. The “2005 BART Rule” is 70 FR 39104, July 6, 2005.

7. The “BART Guidelines” is Appendix Y to Part 51—Guidelines for BART Determinations Under the Regional Haze Rule, 70 FR 

39104, July 6, 2005.

8. The “Tracking Guidance” is the Guidance for Tracking Progress Under the Regional Haze Rule, EPA-454/B-03-004, September, 

2003.

9. The “Attainment Guidance” is the Draft Guidance for Demonstrating Attainment of Air Quality Goals for PM2.5 and Regional Haze, 

January 2, 2001.

10. The “Natural Visibility Guidance” is the Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA454/B-03-005, September 2003.

11. The “Baseline Memo” is a memo, 2002 Base Year Emission Inventory SIP Planning: 8-Hour Ozone, PM2.5 and Regional Haze 

Programs, dated 11/18/2002, from Lydia Wegman to the Regional Air Directors.

12. The “draft RPG Guidance” is the Draft Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, dated 

November 28, 2005.

13. The “Visibility Monitoring Guidance” is Visibility Monitoring Guidance, EPA-454/R-99-003, June 1999.

14. The “EI Guidance” is the Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air 

Quality Standards (NAAQS) and Regional Haze Regulations, EPA-454/R-05-001, dated August, 2005.

15. The “Interim Fire Policy” is the Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998.

* Requirements that do not apply to States without Class I areas are denoted by an asterisk.
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

3

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Administrative Requirements from Appendix V to Part 51

Y

2.1(a) Has a letter of submittal from the governor / designee, 

requesting EPA approval of the SIP been received?

Cover Letter 

from Laurel 

L. Kroack,

Chief, Bureau 

of Air

Y

2.1(b) Has the State provided evidence it has adopted the legally 

enforceable portions of the plan in the State code or body of 

regulations; or issued the necessary permits, orders, consent 

agreements in final form?

Attachments 

10 & 11 

Y

2.1(c) Has the State provided evidence it has the necessary legal 

authority under State law to adopt and implement the plan?

Cover Letter 

from Laurel 

L. Kroack, 

Chief, Bureau 

of Air

Y

2.1(d) Has the official State regulation /document been 

signed/stamped/dated by the appropriate State official 

indicating that it is fully enforceable by the State?

Attachments 

10 & 11

Y

2.1(e) Has the State provided evidence it followed all of the 

procedural requirements of the State’s laws and constitution 

in the adoption/issuance of the plan?

Attachments 

1, 2, 6, 8, 9, 10 

& 11
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

4

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

2.1(f) Has the State provided evidence that public notice was 

given of the proposed change consistent with procedures 

approved by EPA, including the date of publication of such 

notice?

Attachment 6

Y

2.1(g) Has the State provided a certification that public hearings(s) 

were held in accordance with the information provided in 

the public notice and the State’s laws and constitution, if 

applicable?

Attachment 8 

Y

2.1(h) Has the State provided a compilation of public comments 

and the State’s response thereto?

Attachment 9

Technical Requirements from 40 CFR 51.308

N (b) Was the SIP submitted no later than December 17, 2007?
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

5

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d) Did the State provide a table identifying each mandatory 

Class I Federal area located within the State and in each 

mandatory Class I Federal area located outside the State 

affected by emissions from within the State?

Attachment 1, 

Appendix B, 

Regional Air 

Quality 

Analyses for 

Ozone, PM2.5, 

and Regional 

Haze: Final 

Technical 

Support 

Document, 

April 25, 2008 

(hereinafter 

referred to as 

“MRPO

TSD”) pp. 93-

95

$ Visibility Monitoring Guidance

N/

A

* (d)(1) Did the State establish RPGs for each Class I area that 

provide for an improvement in visibility for the most 

impaired days over the period of the SIP, and ensure no 

degradation in visibility for the least impaired days over the 

same period?

N/A $ p. 35730 of the 1999 RHR

$ p. 1-6 of the Tracking Guidance

$ Attainment Guidance

$ draft RPG Guidance
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

6

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

N/

A

* (d)(1)(i)(A) In establishing RPGs for each Class I area, did the State 

consider the costs of compliance, the time necessary for 

compliance, the energy and non-air quality environmental 

impacts of compliance, and the remaining useful life of any 

potentially affected sources, and include a demonstration 

showing how these factors were taken into consideration in 

selecting the goal?

N/A $ p. 35731-33 of the 1999 RHR

$ draft RPG Guidance

N/

A

* (d)(1)(i)(B) Did the State submit the glidepath (i.e., rate of progress

needed to attain natural visibility conditions by 2064) for 

each Class I area?

N/A $ p. 35727-33, 35 of the 1999 RHR

$ Natural Visibility Guidance

$ p. 39124, 39143 of the 2005 BART rule

$The Baseline Memo

N/

A

* (d)(1)(i)(B) In establishing the RPG for each Class I area, did the State 

calculate the uniform rate of improvement in visibility and 

the emission reduction measures needed to achieve it for the 

period covered by the SIP?

N/A

$ p. 35732 of the 1999 RHR

$ draft RPG Guidance

N/

A

* (d)(1)(ii) If the State establishes a RPG < the glidepath, has it 

demonstrated, based on the factors in (d)(1)(i)(A), the rate 

of progress for the SIP to attain natural conditions by 2064 

is not reasonable, and its RPG is reasonable?

N/A $ p. 35732 of the 1999 RHR

N/

A

* (d)(1)(ii) If the State establishes a RPG < the glidepath, did it provide 

to the public for review as part of its SIP, an assessment of 

the number of years it would take to attain natural 

conditions using its RPG?

N/A $ p. 35732 of the 1999 RHR
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

7

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(1)(iv) In developing its RPG, has the State consulted with those 

States that may reasonably be anticipated to cause or 

contribute to visibility impairment in the Class I areas?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, and 

MRPO 

Consultation

$ p. 35735 of the 1999 RHR

N/

A

(d)(1)(iv) If the State cannot agree with another State(s) that a goal 

provides for reasonable progress, has the State described in 

its submittal the actions taken to resolve the disagreement?

N/A $ p. 35732 of the 1999 RHR

N/

A

* (d)(1)(vi) Has the State adopted RPGs that represents at least the 

visibility improvement expected from implementation of 

other CAA programs during the applicable planning period?

N/A $ p. 35733 of the 1999 RHR

N/

A

* (d)(2)(i) Has the State calculated baseline visibility conditions for 

each Class I area for the most impaired and least impaired 

days using 2000 to 2004 monitoring data?

N/A $ p. 35728-30 of the 1999 RHR

$ Natural Visibility Guidance

$ Attainment Guidance

$Tracking Guidance

N/

A

* (d)(2)(i) In calculating the baseline visibility conditions, did the State 

estimate the average degree of visibility impairment for the 

most and least impaired days for each calendar year from 

2000 to 2004, and then determine the average of these 

annual values?

N/A
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

8

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

N/

A

* (d)(2)(i) If the State has Class I areas without onsite monitoring data

for 2000 - 2004, did the State use the most representative 

available monitoring data for 2000 - 2004 to establish 

baseline values, in consultation with the EPA Regional 

Office?

N/A $ p. 35728-29 of the 1999 RHR

$ Visibility Monitoring Guidance

N/

A

* (d)(2)(iii) Did the State calculate natural visibility conditions for the 

most impaired and least impaired days by estimating the 

degree of impairment based on available monitoring 

information and appropriate data analysis techniques?

N/A $ p. 35764, 35729-30 of the 1999 RHR

$ Natural Visibility Guidance

N/

A

* (d)(2)(iv)A Did the State calculate the number of deciviews by which 

baseline conditions exceed natural visibility conditions for 

the most impaired and least impaired days for the first 

planning period?

N/A $ p. 35732 of the 1999 RHR

Y

(d)(3) Did the State submit a LTS that addresses visibility 

impairment for each Class I area, inside and outside the 

State, which may be affected by the State’s emissions?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

8.0

$ p. 35734-35 of the 1999 RHR
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

9

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(3) Does the LTS include enforceable emissions limitations, 

compliance schedules, and other measures as necessary to 

achieve the RPGs established by States having Class I 

areas?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

8.0

$ p. 35734-35 of the 1999 RHR

Y

(d)(3)(i) In establishing its LTS, did the State consult with other 

State(s) to develop coordinated emission management 

strategies for cases in which it has emissions that are 

reasonably anticipated to contribute to visibility impairment 

in any Class I area located in those State(s)?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

9.0, and 

MRPO 

Consultation

$ p. 35735 of the 1999 RHR

N/

A

(d)(3)(i) In establishing its LTS, did the State consult with other 

State(s) to develop coordinated emission management 

strategies for cases in which those State(s) have emissions 

that are reasonably anticipated to contribute to visibility 

impairment in any Class I area located within the State?

N/A
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

10

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(3)(ii) In establishing its LTS, where multiple State(s) cause or 

contribute to impairment of the same Class I area, did the 

State include all measures necessary to obtain its share of 

the emission reductions needed to meet the RPG for the 

area?

Attachment 1,

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Sections 

8.0 and 9.0,

and MRPO 

Consultation

$ p. 35735 of the 1999 RHR

Y

(d)(3)(ii) In addressing (d)(3)(ii), above, if the State participated in a 

RPO, did it ensure it included all measures needed to 

achieve its apportionment of emission reduction obligations 

agreed upon through that process?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Sections 

8.0 and 9.0,

and MRPO 

Consultation

$ p. 35735 of the 1999 RHR
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

11

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(3)(iii) In establishing its LTS, did the State document the technical 

basis, including modeling, monitoring and emissions 

information, on which it is relying to determine its 

apportionment of emission reduction obligations necessary 

for achieving reasonable progress in each Class I area it 

affects?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Sections 

8.0 and 9.0,

and MRPO 

Consultation

$ p. 35735 of the 1999 RHR

$ EI Guidance

Y

(d)(3)(iii) In addressing (d)(3)(iii), above, did the State identify the 

baseline emissions inventory on which its strategies are 

based?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

5.0, and 

MRPO 

Consultation

$ p. 35728 of the 1999 RHR

$ Baseline Memo

$EI Guidance
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

12

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(3)(iv) Did the State identify all anthropogenic sources of visibility 

impairment considered by it in developing its LTS, 

including consideration of major and minor stationary 

sources, mobile sources, and area sources?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

5.0, and 

MRPO 

Consultation

$ p. 35735 of the 1999 RHR

$ EI Guidance

Y

(d)(3)(v)(A) In developing its LTS, did the State consider the emission 

reductions due to ongoing air pollution control programs, 

including measures to address RAVI?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

8.0, and 

MRPO 

Consultation

$ p. 35737 of the 1999 RHR
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

13

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(3)(v)(B) In developing its LTS, did the State consider measures to 

mitigate the impacts of construction activities?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

8.0 and 

MRPO 

Consultation

$ p. 35737 of the 1999 RHR

Y

(d)(3)(v)(C) In developing its LTS, did the State consider emissions 

limitations and schedules for compliance to achieve the 

reasonable progress goal?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Sections

6.0 and 8.0, 

and MRPO 

Consultation

$ p. 35737 of the 1999 RHR
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

14

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(3)(v)(D) In developing its LTS, did the State consider source 

retirement and replacement schedules?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Sections

6.0 and 8.0, 

and MRPO 

Consultation

$ p. 35737 of the 1999 RHR

Y

(d)(3)(v)(E) In developing its LTS, did the State consider smoke 

management techniques for agricultural and forestry 

management purposes, including plans as currently exist 

within the State for these purposes?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

8.0 et seq., and 

MRPO 

Consultation

$ p. 35736 of the 1999 RHR

$ Interim Fire Policy
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

15

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(3)(v)(F) In developing its LTS, did the State consider enforceability

of emissions limitations and control measures?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Sections 

6.0 and 8.0,

and MRPO 

Consultation

$ p. 35737 of the 1999 RHR

Y

(d)(3)(v)(G) In developing its LTS, did the State consider the anticipated 

net effect on visibility due to projected changes in point, 

area, and mobile source emissions over the period addressed 

by the LTS?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Sections

8.0 and 9.0,

and MRPO 

TSD

$ p. 35737 of the 1999 RHR

N/

A

* (d)(4) Did the State submit with the SIP a monitoring strategy for 

measuring, characterizing, and reporting of regional haze 

visibility impairment representative of all Class I areas 

within the State?

N/A $ p. 35744 of the 1999 RHR

$ Attainment Guidance

$ Tracking Guidance

$Visibility Monitoring Guidance

N/

A

* (d)(4) Did the State coordinate the above monitoring strategy with 

the RAVI monitoring strategy in § 51.305?

N/A $ p. 35717, 37, of the 1999 RHR
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

16

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

N/

A

* (d)(4)(i) Did the SIP provide for the establishment of any additional 

monitoring sites or equipment needed to assess whether 

RPGs to address regional haze for all Class I areas within 

the State are being achieved?

N/A $ p. 35744 of the 1999 RHR

$ Attainment Guidance

$ Tracking Guidance

$Visibility Monitoring Guidance

N/

A

* (d)(4)(ii) Did the SIP establish procedures by which monitoring data 

and other information are used in determining the 

contribution of emissions from within the State to regional 

haze visibility impairment at Class I areas both within and 

outside the State?

N/A $ p. 35744 of the 1999 RHR

$ Attainment Guidance

$ Tracking Guidance

$ Visibility Monitoring Guidance

Y

(d)(4)(iii) For a State with no Class I areas, did the SIP establish 

procedures by which monitoring data and other information 

are used in determining the contribution of emissions from 

within the State to regional haze visibility impairment at 

Class I areas in other States?

MRPO TSD $ p. 35744 of the 1999 RHR

$ Attainment Guidance

$ Tracking Guidance

$ Visibility Monitoring Guidance

N/

A

* (d)(4)(iv) Did the SIP provide for the reporting of all visibility 

monitoring data to EPA at least annually for each Class I 

area in the State?

N/A $ p. 35744-45 of the 1999 RHR

$ Visibility Monitoring Guidance
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

17

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(4)(v) Did the SIP include a statewide EI of pollutants that are 

reasonably anticipated to cause or contribute to visibility 

impairment in any Class I area?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

5.0, and 

Section 3.6 in 

MRPO TSD

$ Attainment Guidance

Y

(d)(4)(v) Did the EI include emissions for a baseline year, emissions 

for the most recent year for which data are available, and 

estimates of future projected emissions?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

5.0, and 

Section 3.6 in 

MRPO TSD

$ p. 35728-29 of the 1999 RHR

$ Visibility Monitoring Guidance

$Attainment Guidance
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

18

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(d)(4)(v) Did the SIP include a commitment to update the EI 

periodically?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

5.0

$ EI Guidance

Y

(d)(4)(vi) Did the SIP include other elements necessary to assess and 

report on visibility (e.g., reporting, recordkeeping, etc.)?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

19

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(e) Did the State submit a SIP containing emission limitations 

representing BART, and schedules for compliance with 

BART, for each BART eligible source that may reasonably 

be anticipated to cause or contribute to any impairment of 

visibility in any Class I area?

Attachment 2, 

Technical 

Support 

Document for 

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ BART Guidelines

Y

(e)(1)(i) Did the SIP include a list of all BART-eligible sources 

within the State with supporting documentation?

Attachment 2, 

Technical 

Support 

Document for

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ BART Guidelines
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

20

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(e)(1)(ii) Did the SIP include a determination of BART for each 

BART-eligible source in the State that emits any air 

pollutant which may reasonably be anticipated to cause or 

contribute to any impairment of visibility in any Class I 

area?

Attachment 2, 

Technical 

Support 

Document for 

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ BART Guidelines

Y

(e)(1)(ii)(A) Did the SIP include a determination of BART based on an 

analysis of the best system of continuous emission control 

technology available, and associated emission reductions 

achievable for each source subject to BART within the 

State?

Attachment 2, 

Technical 

Support 

Document for 

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ BART Guidelines
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

21

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(e)(1)(ii)(A) In the BART analysis, did the State take into consideration 

the technology available, the costs of compliance, the 

energy and nonair quality environmental impacts of 

compliance, any pollution control equipment in use at the 

source, the remaining useful life of the source, and the 

degree of improvement in visibility which may reasonably 

be anticipated to result from the use of such technology?

Attachment 2, 

Technical 

Support 

Document for 

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ BART Guidelines 

$ p 39107, 127 of the 2005 BART Rule

Y

(e)(1)(ii)(B) Did the State determine BART for fossil-fuel fired power 

plants > 750 megawatts pursuant to the BART guidelines?

YES $ BART Guidelines

$ p 39108 of the 2005 BART Rule
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

22

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(e)(1)(iii) If the State has determined that technological or economic 

limitations on the applicability of measurement 

methodology to a particular source would make the 

imposition of an emission standard infeasible, has the State 

prescribed a design, equipment, work practice, or other 

operational standard, to require the application of BART, as 

an alternative to a BART emission standard?

Attachment 2, 

Technical 

Support 

Document for 

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ BART Guidelines

N/

A

(e)(1)(iii) If the State adopted a design, equipment, work practice, or 

other operational standard alternative to BART, did the 

State, to the degree possible, set forth the emission 

reduction to be achieved, and provide for compliance by 

means which achieve equivalent results?

N/A $ BART Guidelines

$ p 39172 of the 2005 BART Rule
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

23

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(e)(1)(iv) Has the State required each source subject to BART to 

install and operate BART as expeditiously as practicable, 

but no later than 5 years after approval of the SIP?

Attachment 2, 

Technical 

Support 

Document for 

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ p 39158, 70, 72 of the 2005 BART Rule

Y

(e)(1)(v) Has the State required each BART source to maintain the 

required control equipment and establish procedures to 

ensure such equipment is properly operated and maintained?

Attachment 2, 

Technical 

Support 

Document for 

Best Available 

Retrofit 

Technology 

Under the 

Regional Haze 

Rule, 

AQPSTR 09-

06, April 29, 

2011

$ p 39172 of the 2005 BART Rule
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

24

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

N/

A

(e)(4) If the State is using its participation in CAIR to exempt 

BART-eligible EGU’s from BART, has it included 

supporting documentation?

N/A $ p 39136-42 of the 2005 BART Rule

N/

A

(e)(4) If the State is using its participation in CAIR to exempt 

BART-eligible EGU’s from BART, did it include 

provisions for a geographic enhancement to the program to 

address RAVI BART under § 51.302(c)?

N/A $ p 39143, 57 of the 2005 BART Rule

N/

A

(e)(6) If a facility is seeking an exemption under §51.303(a)(2)–

(h) for any of its BART-eligible emission units, has the 

appropriate documentation been included in the SIP?

N/A $ §51.303(a)(2)–(h)

Y

(f) Has the State included a commitment it will submit its SIP

revision, as specified in 51.308(f), by July 31, 2018, and 

every ten years thereafter?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

1.0

$p 35745 of the 1999 RHR

$ Section 110(a)(2)(H) of the CAA
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

25

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(g) Has the State included a commitment it will submit its SIP

report, as specified in 51.308(g), by an exact date named, 

that is within 5 years from submittal of the initial SIP?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

1.0

$p 35745 of the 1999 RHR

$ Section 110(a)(2)(F) of the CAA

Y

(h) Has the State included a commitment it will, at the time of 

the submission of the SIP report, also submit a 

determination of the adequacy of its existing Regional Haze 

SIP revision, as specified in 51.308(h)?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

1.0

$p 35745 of the 1999 RHR

$ Section 110(a)(2)(F) of the CAA

Y

(i)(1)(i)-(ii) Did the State, by November 29, 1999, identify in writing to 

the FLMs the title of the official to which any FLM can 

submit recommendations on the implementation 51.308 

including, (i) identification of impairment of visibility in 

any Class I area(s); and (ii) identification of elements for 

inclusion in the visibility monitoring strategy required by 

§51.305 and 51.308?

MRPO 

Consultation

$ p. 35747-48 of the 1999 RHR

Y

(i)(2) Did the State provide the FLM an opportunity for 

consultation, in person and at least 60 days prior to holding 

any public hearing on the SIP (or its revision)?

$ p. 35747-48 of the 1999 RHR
EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

05/31/11

26

Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308

Regulation 

Citation

Regulation Summary (not verbatim) Location

in SIP

References

Y

(i)(2)(i)-(ii) Did the above consultation include the opportunity for the 

FLMs to discuss their: (i) assessment of impairment of 

visibility in any Class I area; and, (ii) recommendations on 

the development of the RPG and on the development and 

implementation of strategies to address visibility 

impairment?

Attachment 9 $ p. 35747-48 of the 1999 RHR

Y

(i)(3) Did the State include in the SIP a description of how it 

addressed any comments provided by the FLMs?

Attachment 9 $ p. 35747-48 of the 1999 RHR

Y

(i)(4) Does the SIP provide procedures for continuing consultation

between the State and FLMs on the implementation of 

51.308, including development and review of SIP revisions 

and 5-year progress reports, and on the implementation of 

other programs having the potential to contribute to 

impairment of visibility in Class I areas?

Attachment 1, 

Regional Haze 

SIP for 

Illinois, 

AQPSTR 10-

08, May 10, 

2011, Section 

1.0

$ p. 35747-48 of the 1999 RHR