Appendix J 

Regional Haze Consultation 
1. Introduction 

The Southeast Regional Planning Organization, Visibility Improvement State and Tribal 

Association of the Southeast (VISTAS), is comprised of the ten Southeast States 

(Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, 

Tennessee, Virginia and West Virginia) and the local programs and tribal agencies 

located within these states. The VISTAS states have jointly developed the technical 

analyses to define the visibility improvement by 2018 under existing federal and state 

regulations compared to the uniform rate of progress, sulfur dioxide (SO2) Areas of 

Influence for each Class I area, and methods to prioritize contributions from individual 

sources within the Areas of Influence. The states collectively accepted the conclusions of 

these analyses. 

In December 2006, the VISTAS State Air Directors held their first formal consultation 

meeting to review the latest modeling results and the SO2 Areas of Influence analyses. 

The Air Directors agreed to look at reasonable control measures for sources on the lists 

for the SO2 Areas of Influence. Each state would consider sources within their state and 

would identify sources in neighboring states that they would like to have that neighboring 

state consider. States acknowledged that the review process would differ among states 

since some Class I areas are projected to see visibility improvements near the uniform 

rate of progress while most Class I areas are projected to have greater improvements than 

uniform rate of progress. 

In May 2007, the VISTAS State Air Directors met for their second formal interstate 

consultation. States shared their lists of sources in their state and neighboring states for 

each Class I area. They also shared their criteria for listing sources and their plans for 

further interstate consultation. ADEM has evaluated the impact of Alabama sources on 

Class I areas in neighboring states and determined that there are no additional reasonable 

control measures that should be implemented to mitigate impacts in Class I areas in 

neighboring states. Additionally, when evaluating source impacts at the Sipsey 

Wilderness, only two non-Alabama sources had impacts of greater than one percent to 

visibility impairment. Both of these sources were Georgia Power utility sources. For this 

progress goal, ADEM made the decision to not evaluate EGU sources under RFP if the 

Class I area was projected to meet the glidepath. Therefore, the only sources considered 

for RFP in Alabama were Alabama sources. This analysis of impacts from Alabama 

sources is discussed in greater detail in Appendix H. 

2.0 Consultation Letters 

Below is a list of the consultation letters: 

Letter: 8/2/2007, NCDNR Consultation letter to State of Alabama regarding 

Reasonable progress 

................................................................................................................................

Letter: 4/9/2007, GAEPD Consultation letter to State of Alabama regarding 

Reasonable progress 

................................................................................................................................
Letter: 5/4/2007, FL-DEP Consultation letter to State of Alabama regarding 

Reasonable progress 

................................................................................................................................ 

Updated Email 11/15/2007 FL-DEP Consultation email to State of Alabama regarding 

Reasonable progress 

................................................................................................... 

Letter: 10/10/2003, Charles D. Myers, U.S. Department of Agriculture letter outlining 

what they will be looking for in SIPs, providing a point of contact and requesting key 

points of contact on ADEM’s staff . 

 ................................................................................................................................. 

Letter: 8/1/2006, Sandra V. Silva and Christine L. Shaver, U.S. Fish and Wildlife Service 

and National Park Service letter to discuss their interests with respect to the Regional 

Haze SIP development 

.................................................................................................................................. 












From: Rogers, Tom [mailto:Tom.Rogers@dep.state.fl.us] 

Sent: Thursday, November 15, 2007 9:15 AM 

To: Jimmy Johnston; Bacon, Leigh 

Cc: James Boylan; George, Larry; Kahn, Joseph 

Subject: Florida Sources Subject to Reasonable Progress 

Jimmy and Leigh,

The Florida Department of Environmental Protection (DEP) has developed a state rule for 

the reasonable progress requirements of the federal regional haze rule. The details of the 

rule have evolved since first presented to you in June at the Asheville meeting, but the 

essence of the rule is the same, with Florida proposing a permit-based program that 

requires certain large sources of SO2 to make a determination of “Reasonable Progress 

Control Technology (RPCT)” for each subject unit based on the four factors in the rule. 

 DEP would make the final determination, issuing a permit with RPCT emission limits.

Attached is the list of sources (units) that meet the selection criteria in the rule. That is, 

units having SO2 emissions of at least 250 tons per year, an emissions (Q) to distance (d) 

ratio of greater than or equal to 50 (Q/d >= 50), and is within 300 km of the Class I area. 

 Both Q and d are based on the VISTAS data, with Q based on 2002 emissions and d the 

distance to the IMPROVE monitor at each Class I area. Sources in Georgia and Alabama 

that meet these criteria, and for which we would like each state to consider in developing 

their reasonable progress goals, would replace the sources we had previously communicated 

to you based on different draft criteria. However, our analysis did not identify any sources 

in either Georgia or Alabama that would meet these criteria for Florida Class I areas. 

The rule can be reviewed at http://www.dep.state.fl.us/air/rules/regulatory.htm , under the 

project for Regional Haze Reasonable Progress. We will be taking this rule before the 

state’s Environmental Regulation Commission on December 4. If you have any comments to 

make on the rule, please provide them before the end of November if you can. If you have 

any questions about the rule, please call or e-mail me at your convenience.

Thomas G. Rogers, Administrator

Air Modeling and Data Assessment Section

Division of Air Resource Management

Florida Department of Environmental Protection

2600 Blair Stone Road, MS 5500

Tallahassee, Florida 32399-2400

Ph: (850) 921-9554

Fax: (850) 922-6979

e-mail: tom.rogers@dep.state.fl.us

 

Please note: Florida has a very broad public records law. Most written communications to or from state officials 

regarding state business are public records available to the public and media upon request. Your e-mail 

communication may therefore be subject to public disclosure.

 
Class I Proposed Sources Selected for RPCT Review 

Plant Name Unit Class I Area Impacted Q/d 

CITY OF GAINESVILLE, GRU DEERHAVEN 5 CHAS 61.37 

OKEF 62.12 

FLORIDA CRUSHED STONE CO. 18 CHAS 129.62 

FLORIDA POWER & LIGHT MANATEE 1 CHAS 108.16 

2 CHAS 117.05 

EVER 50.72 

FLORIDA POWER & LIGHT PORT EVERGLADES 3 EVER 67.27 

4 EVER 65.12 

FLORIDA POWER & LIGHT TURKEY POINT 1 EVER 122.1 

2 EVER 130.08 

GULF POWER COMPANY CRIST 7 BRET 86.13 

SAMA 72.07 

SMURFIT STONE CORPORATION (FERN. BEACH) 15 OKEF 50.2 

LAKELAND ELECTRIC C.D. MCINTOSH 6 CHAS 72.32 

JEA NORTHSIDE 27 OKEF 73.49 

3 OKEF 108.63 

PROGRESS ENERGY FLORIDA ANCLOTE 1 CHAS 216.98 

SAMA 55.35 

2 CHAS 206.75 

SAMA 52.74 

PROGRESS ENERGY FLORIDA BARTOW 1 CHAS 62.17 

2 CHAS 65.53 

3 CHAS 113.69 

PROGRESS ENERGY FLORIDACRYSTAL RIVER 1 CHAS 692.18 

OKEF 92.31 

SAMA 100.21 

2 CHAS 755.21 

OKEF 100.72 

SAMA 109.33 

3 CHAS 963.18 

OKEF 128.45 

SAMA 139.44 

4 CHAS 897.56 

OKEF 119.7 

SAMA 129.94 

JEA SAINT JOHNS RIVER 16 CHAS 52.55 

OKEF 170.09 

17 OKEF 156.41 

SEMINOLE ELECTRIC COOPERATIVE 1 CHAS 77.07 

OKEF 89.56 

2 CHAS 90.23 

OKEF 104.86 

SAMA 51.67 

TAMPA ELECTRIC COMPANY F.J. GANNON 1 CHAS 54.52 

2 CHAS 52.24 

3 CHAS 59.22 

4 CHAS 58.95 

5 CHAS 85.02 

6 CHAS 170.18 

SAMA 54.3 




3. Consultation Minutes 

Meeting Minutes: 1/23/2007, Summary of VISTAS States consultation meeting with 

Louisiana 

..................................................................................................... 

Meeting Minutes: 5/14/2007, Summary of VISTAS States consultation meeting at the Air 

Directors Meeting 

.................................................................................................................. 

Meeting Minutes: 6/12/2007, Summary of VISTAS States consultation meeting with 

Federal Land Managers and Environmental Protection Agency 

.................................................................................................................. 

Meeting Minutes: 10/30/2007, Summary of VISTAS and CENRAP States Consultation 

Call with Federal Land Managers 

.................................................................................................................. 
Interstate Regional Haze Meeting Summary 

January 23, 2007 

Point Clear, Alabama 

An interstate Regional Haze consultation meeting was held on January 23, 2007 in Point 

Clear, AL to discuss the various components of the Regional Haze SIP as it applies to the 

Breton Wilderness Area, which is designated as a Class I area by the Clean Air Act. 

There were representatives from the coastal states of Florida, Alabama, Mississippi and 

Louisiana, as well as a representative from VISTAS. CENRAP representatives were not 

in attendance at this meeting. A consultation meeting will be scheduled to include 

representatives of EPA and the FLM responsible for Breton. 

Modeling was the first item for discussion on the agenda. The latest modeling runs for 

year 2018 show greater consistency between the RPOs results. CENRAP model results 

using the new IMPROVE algorithm puts Breton just below the glide slope showing that it 

meets approximately 95% of our reductions. The VISTAS model results show that 

Breton meets a little more than 80% of the reductions necessary to meet the glide slope. 

The most recent version of the CENRAP inventory was not available when VISTAS 

performed its modeling which could also account for differences in the modeling results. 

However, model performance in estimating 2000-2004 modeling results as they relate to 

actual monitoring data is very poor, allowing more uncertainty in an already uncertain 

process. 

During the discussion of the modeling results Louisiana voiced its concern with the use 

of substitute data from the Gulfport Monitor. We believe that the data from this monitor 

skews the model performance as it pertains to Breton. There are distinct differences 

between the geography of the area as well as the urban versus non-urban siting of the 

monitors. Furthermore, the monitor at Gulfport is a SEARCH monitor, not an 

IMPROVE monitor. According to RH guidance, data is to be derived from IMPROVE 

monitors. Bottom line: Louisiana has a good case for using non-substituted data. 

The states also discussed the impact of pollution on Breton and agreed that all modeling 

results show that sulfates seem to be the most pressing problem. Although CAIR is 

expected to provide reductions from the EGUs, it appears that non-EGUs may have to 

significantly reduce emissions in order for Breton to meet glide slope predictions for 

2018. Louisiana representatives stated that the state is looking at methods of achieving 

the necessary reductions from the non-EGU components. VISTAS states are looking at 

this speciated component as well, be it through some form of regulation or through the 

permitting process. 

All of the states are in the process of making BART determinations. No state has 

constructed a draft rule. BART and reasonable further progress (RFP) seems to be a 

political as well as economic dilemma in the VISTAS states that were in attendance. 

Like Louisiana, the hurricane seasons of the past 2-3 years have wreaked havoc on 

industry and its ability to make a comeback. The governments would rather suffer a little 

pollution instead of losing the economic backbone of a community. 

There was much discussion on how to show RFP. Because Breton has the predicament 

of incomplete monitor data, there was a consensus that by showing the steady decline of 
emissions coupled with the reductions that will take place through state and national 

initiatives and the additional monitoring data that will be available from the Breton 

IMPROVE monitor, the state has fulfilled the requirements as well as can be expected. 

Additionally, several of the 20% worst days in the 2002 modeling year are coming from 

the Gulf of Mexico. VISTAS data indicates that if international emissions were taken 

into account, reductions projected as a result of CAIR would be sufficient to meet the 

uniform rate of progress in 2018. This provides further evidence that the state has 

fulfilled the reasonable progress goals. Louisiana also intends to use the studies compiled 

by Dr. Hsu which indicate that Breton does not suffer from Regional Haze, but rather 

from fog. This study shows that there are other mitigating factors which cause visibility 

impairment in and around the island chain. 

All meeting attendees are aware of the eroded state of the islands, however, there was no 

interest expressed for pursuit of a reclassification of the area either from the Department 

of the Interior or Congress. 

The group concluded the meeting by agreeing to continue these discussions via 

telephone. The next meeting will include representatives of EPA and the FLM. 

List of Representatives: 

Florida Tom Rogers 

Alabama Leigh Bacon, Tim Martin, Scott Southwick and 

Chris Howard 

Mississippi Elliott Bickerstaff, Michelle Root, and Maya Rao 

Louisiana James Orgeron, Patrick Pakunpanya, Yvette 

McGhee and Vivian Aucoin 

VISTAS Pat Brewer 
VISTAS State Consultation Meeting- Air Directors Meeting 

Atlanta, GA 

May 14, 2007 

Objective: Under the Regional Haze Rule, Section 51.308(d)(1)(i), where a State’s 

emissions are reasonably anticipated to cause or contribute to visibility impairment in a 

Class I area located in another State or States, the States are required to consult to 

develop coordinated emissions management strategies. The objectives of this 

consultation meeting were to review the VISTAS technical analyses and for each 

VISTAS state to share its plans for analyzing reasonable control measures and setting 

reasonable progress goals. 

This meeting is the second formal consultation between the VISTAS states. The first 

consultation meeting was held in December 2006 in Nashville, TN. There states 

discussed their expectations for reasonable progress and the process that states would 

follow to define reasonable progress goals and to set long-term strategies to meet those 

goals. 

Introduction 

Sheila Holman reviewed the 2009 air quality modeling results for ozone and fine 

particulate matter (particles with diameters less than 2.5 microns, PM2.5). Ozone and 

PM2.5 levels will be significantly reduced between 2002 and 2009 and most urban areas 

will be attaining by 2009. ASIP is prepared to assist states with remaining nonattainment 

areas in control strategy development. Emissions control measures for ozone and PM2.5 

will improve also visibility. 

Pat Brewer summarized the VISTAS technical analyses that support State 

Implementation Plans (SIPs) including: 

• Baseline and natural visibility conditions and uniform rate of progress 

• Contribution assessment demonstrating that ammonium sulfate is the major 

contributor to haze in the southeastern US and indicating that SO2 emissions 

controls would be the most effective measures to improve visibility 

• VISTAS state emissions inventories for 2002, 2009, and 2018. SO2 emissions 

from electric utilities in the VISTAS state are projected to be reduced by 70% 

between 2002 and 2018. 

• VISTAS Base G2a emissions and air quality modeling results indicate visibility 

improvements greater than uniform rate of progress for all the VISTAS 

mountain Class I areas and many of the coastal Class I areas. 

• VISTAS Base G2a modeling results agree well with CENRAP and MRPO 

results for border Class I areas. MANE-VU Base A results do not show as large 

visibility improvements as VISTAS Base G2a results for the Mid-Atlantic Class 

I areas, but MANE-VU Base A inventories are out of date for VISTAS, 

CENRAP, and MRPO. MANE-VU has updated Base B inventories for all the 

eastern RPOs; results of CMAQ Base B runs are expected summer 2007. 

• VISTAS emissions sensitivities indicate that further SO2 reductions from 

electric generating units and industrial sources would have the greatest visibility 

benefits, compared to other fine particle components. 

• VISTAS emissions sensitivities also indicate that VISTAS states are major 

contributors to VISTAS Class I areas. MRPO, MANE-VU, and CENRAP are 
important source regions for Class I areas bordering these regions. VISTAS 

coastal sites are influenced by emissions from outside the VISTAS modeling 

domain (international emissions or continental emissions that have been 

transported over water outside the domain and are recirculated back into the 

domain.) 

• VISTAS SO2 Areas of Influence demonstrate the geographic areas most likely 

to contribute emissions to Class I areas on 20% worst visibility days. 

• CENRAP source attribution analyses using the CAMx regioinal air quality 

model with the PSAT source apportionment tool indicate that sources in KY and 

TN impact Class I areas in AR and MO. KY and TN are participating in 

consultation discussions with AR and MO. 

• MANE-VU source attribution analyses using several metrics (emissions divided 

by distance, Q/d, and CALPUFF and REMSAD air quality models) suggest that 

several VISTAS states have contributions greater than 1% of the total sulfate 

loading at Class I areas in MANE-VU states. MANE-VU states have sent letters 

to VISTAS states indicating their conclusion of impact and interest in a 

consultation meeting. 

Renee Shealy reviewed expectations of the Federal Land Managers for documentation in 

the State Implementation Plans (SIPs) and for consultation. These expectations were 

discussed in the meeting April 25-26 in Denver, CO with Regional Planning 

Organizations (RPO), Federal Land Managers (FLM) and the Environmental Protection 

Agency (EPA). FLM expectations have previously been presented in letters sent to all 

states in August 2006. 

• The FLM letter lists expectations for establishing baseline and natural conditions, 

uniform rate of progress, emissions inventories, and areas of influence. VISTAS 

technical analyses should meet these expectations. 

• FLM recognize state flexibility in setting reasonable progress goals and defining 

emissions strategies to meet those goals. FLM expect states to compare the rate 

of reasonable progress to the uniform rate of progress. FLM will be looking at 

how well the long-term strategy is supported by the technical analyses. 

• FLM interpret that the 60-day review period does not start until FLM receive the 

SIP documents for review. The VISTAS meeting with FLM and EPA in June 

will meet the requirement for a face-to-face meeting. 

• FLM emphasized the importance of describing the state’s plans for mid-course 

review in 2012 in the SIP submitted in December 2007. The mid-course review 

should consider most recent visibility trends from monitoring data, emissions 

trends, and compare controls anticipated in the SIP with controls implementation 

to that point. If actual installations differ from those referenced in the SIP then a 

SIP revision would be appropriate. 

• FLM will be looking for regional consistency among states, especially how 

reasonable progress goals are identified and control measures to address goals. 

The FLM will be looking for consistency in SIPs between neighboring states 

(RPOs). 

State Consultation 

Each VISTAS state shared a description of the process used to rank SO2 sources in the 

Area of Influence for each Class I area. VISTAS states are evaluating identified sources 

using the four statutory factors to determine what additional control measures are 
reasonable for this first period of the regional haze rule. States are considering Areas of 

Influence for Class I areas within in the state and in neighboring states. 

All states started with the list of sources, 2002 and 2018 emissions, potential control 

measures, and costs of controls in 2005 dollars as provided by Greg Stella in November 

2006. Most states ranked sources using residence time (RT) and emissions divided by 

distance (Q/d) from the Class I areas. 

• GA used a residence time for EGU greater than 5% and for non-EGU greater than 

10% and looked at sources with contributions calculated by RT *Q/d greater than 

0.5%. 

• Other states considered sources with RT greater than 10%, Q/d greater than 5, and 

contributions calculated by RT*Q/d greater than 1%. 

• Florida is considering additional criteria that will be easier to explain during 

public review: sources with SO2 emissions greater than 250 tons and within 300 

km of a Class I area. 

Each state shared its list of top ranking SO2 sources in that state and neighboring states or 

described the sources on its list. Each state also described its regulatory process to 

develop the regional haze SIP. All states have adopted the Clean Air Interstate Rule 

(CAIR) and Clean Air Mercury Rule (CAMR) and plan to reference these rules in the 

regional haze SIP. SIPs will cite specific consent decrees, enforceable requirements, and 

the VISTAS Base G2 EGU inventory (based on IPM results and modified by states based 

on utility plans.) SIPs will allow trading under CAIR. Most states will include installed 

controls in Title V permits but will not list specific controls in the SIP. 

Some states stated that EGU controls under CAIR will be considered reasonable 

progress. States are considering if there is a threshold cost per ton for SO2 emissions 

reductions for non-EGU sources. States are consulting with their neighbors about 

sources in neighboring states that impact Class I areas in the host state and sources in the 

host state that might be impacting Class I areas in neighboring states. Specific plans are 

under development; status of planning in each state is summarized below. 

 

• SC developed a list of sources in the Area of Influence for Cape Romain and is 

consulting with NC and GA about sources in those states impacting Cape Romain 

and impacts from SC sources on Class I areas in those states. SC considers 

controls under CAIR as reasonable progress for EGU and is considering 4 

statutory factors for non-EGU sources if costs are less than $3000 per ton. 

• GA has sent letters to sources in GA asking for evaluation of the four statutory 

factors. GA also has sent letters to AL, FL, NC, SC, and TN listing the GA 

sources that are being considered for GA and neighboring Class I areas and 

asking FL, SC, and TN to consider specific sources in those states for GA Class I 

areas. GA used separate criteria for the two Class I areas in the state. For 

Cohutta, which is projected to see visibility improvements better than the uniform 

rate of progress, GA determined that planned utility controls by 2018 are 

reasonable and is considering additional controls for non-EGU industrial sources. 

For Okefenokee, which is very close to the uniform rate of progress, GA is 

considering additional control measures for both EGU and non-EGU sources. To 

implement these controls GA is considering a multi-pollutant rule with specific 

controls added to the Title V permits. 
• NC determined that SO2 emission reductions under the NC Clean Smokestacks 

Act are reasonable controls for utilities for this first round of the SIP. NC then 

reviewed the capital and operational costs for the scrubbers installed under the NC 

Clean Smokestacks Act and determined that the maximum cost will be $2000 

dollars per ton. NC chose to use this same threshold as maximum cost that would 

be reasonable to ask of a non-EGU industrial source. NC is now reviewing 

feasibility of control measures with costs below $2000. NC has developed a 

BART framework rule. Any controls for BART or reasonable progress would be 

included in Title V permits. 

• WV has identified sources in WV and in MD, TN, and VA that are impacting WV 

Class I areas. WV would cite IPM results in the regional haze SIP and would 

allow emissions trading under CAIR. 

• VA has identified sources in VA and in MD, NC, and WV that are impacting VA 

Class I areas. VA has adopting enabling rules for BART, will deal with specific 

BART controls in state operating permits. VA will cite IPM results as modified 

by VA in Base G in the regional haze SIP and will include specific controls in the 

Title V permits when those controls are installed. 

• KY is considering sources for Mammoth Cave and for Mingo and Caney Creek. 

KY and TN are consulting with AR and MO. KY is consulting with WV on one 

source. KY will likely conclude that EGU controls projected for CAIR are 

reasonable. Controls will be included in permits. 

• TN has identified sources impacting Class I areas, GA has asked TN to add one 

additional source to TN’s list. Most sources on TN’s list are installing controls or 

reducing emissions. TN is considering a draft regional haze rule, currently 

discussing with EPA. Controls will be added to the Title V permits. 

• AL expects controls on two BART sources. AL considers the emissions 

reductions under CAIR are reasonable for EGU and is considering a few nonEGU sources for Sipsey, AL, Breton, LA, and Saint Marks, FL. AL will provide 

revised emissions to FL and does not expect to need further consultation with FL. 

• MS has identified no sources that impact Sipsey, AL and AL agrees. MS has 

identified 6 sources that potentially impact Breton and is considering controls for 

these sources. MS will continue to consult with LA and does not see need for 

further consultation with VISTAS or MANE-VU states. 

• FL has identified sources in the AoI for 3 FL Class I areas (CHAS, EVER, 

SAMA) and 3 neighboring states (Breton, LA, Okefenokee, GA and Wolf Island, 

GA). Fl has sent letters to AL and GA listing FL sources being considered and 

asking those states to consider sources for FL Class I areas. FL intends to develop 

a rule for requiring analyses of four statutory factors for identified FL sources. 

FL expects to use the VISTAS Base G2a 2018 emissions in the SIP and to allow 

trading. FL will not set a reasonable progress goal in the SIP but will set the 

process for the four-factor analysis and the goal will be the outcome of that 
process. FL and GA will continue consultation. FL expects the SIP will be 

submitted to EPA after December 2007. 

VISTAS states recognize that VISTAS Base G utility SO2 emissions are lower than 

projections from IPM (VISTAS version 2.1.9) and that emissions in another region of the 

country may be higher than IPM projections if additional credits are generated by 

additional controls on VISTAS sources. 

VISTAS States trust the reductions in the VISTAS Base G inventory because they 

reviewed and updated the 2009 and 2018 emissions with their utilities in summer 2006. 

VISTAS states agree that the state with the Class I area will set the reasonable progress 

goal for the Class I area and will consult with neighboring States. The long-term strategy 

will need to include the Base G2a controls plus BART controls and any additional control 

measures in the State or neighboring States. The states will continue to use the VISTAS 

state calls to discuss setting goals and long-term strategies. 

VISTAS plans to initiate the emissions and air quality modeling for the Long-Term 

Strategy in July. 
VISTAS State, EPA and FLM Consultation Meeting 

Asheville, NC 

June 12, 2007 

Attendees/Affiliation 

Tim Allen, FWS Cindy Huber, FS 

Diana Andrews, KY Bill Jackson, FS 

Julie Aslinger, TN Brenda Johnson, EPA Region 4 

Vivian Aucoin, LA Jimmy Johnston, GA 

Leigh Bacon, AL Rhea Jones, EPA OAQPS 

Tom Ballou, VA Kathy Kaufman, NC 

Elliott Bickerstaff, MS Martin Luther, KY 

Laura Boothe, NC Tim Martin, AL 

Jim Boylan, GA Doris McLeod, VA 

Lona Brewer, KY Ann Mebane, FS 

Pat Brewer, VISTAS Brock Nicholson, NC 

Joelle Burleson, NC Michele Notarianni, EPA OAQPS 

Bob Carson, NPS Bruce Polkowsky, NPS 

Catherine Collins, FWS Jim Renfro, NPS 

Fred Durham, WV Tom Rogers, FL 

Stacey Gardner, SC Renee Shealy, SC 

Rick Gillam, EPA Region 4 Don Shepherd, NPS 

John Glass, SC Andrea Stacy, FS 

Janice Godfrey, NC Barry Stephens, TN 

Todd Hawes, EPA OAQPS Bob Stroik, NPS 

Sheila Holman, NC Ming Xie, NC 

Chris Howard, AL John Hornback, Metro4/SESARM 

Objectives

The purpose of this consultation meeting was to overview the VISTAS and state 

technical analyses that will be the basis of the state implementation plans for regional 

haze and to receive feedback from the Federal Land Managers (FLM) and the 

Environmental Protection Agency (EPA) on the presented materials. 

Expectations

The meeting opened with participants stating their expectations for consultation. 

FLM interests included: 

• understanding VISTAS technical analyses and how states will use these analyses 

in SIPs 

• understanding states’ reasonable progress goals and having opportunity to consult 

on these goals 

• states’ plans for consultation with neighboring states 

• states’ plans for mid-course review 

• states’ plans for continued consultation with FLM 
EPA interests included: 

• learn how states are using technical analyses 

• understand FLMs positions 

• provide clarification of revised reasonable progress guidance 

• observe and report outstanding issues to management 

States interests included: 

• feedback from the FLM and EPA if technical analyses, when completed, would 

meet FLM and EPA expectations for SIP documentation. 

• Some states would like to consider this meeting to meet the requirement for a face 

to face meeting with FLM, with further follow up and discussions by conference 

call. 

• Common understanding between states, FLM, and EPA of revised reasonable 

progress guidance 

• This first SIP for regional haze will be a learning experience. States can use midcourse review to evaluate what is working and where revisions are needed. 

Technical Analysis Summary

Pat Brewer summarized the VISTAS Technical Analyses (see presentation on 

VISTAS website, http://www.vistas-sesarm.org/documents/FinalDocs.asp). 

Ammonium sulfate is the primary contributor to haze at the VISTAS Class I areas. 

Emissions sensitivity analyses showed greatest visibility benefit from reducing SO2 

from electric utilities or industrial point sources and little benefit from reducing NOx, 

anthropogenic VOC, or primary sources of carbon. Ninety-six percent of the SO2 

emissions in the VISTAS states are from electric utility or industrial point sources. 

SO2 Areas of Influence were defined for each Class I area. In 2018 coal fired electric 

utility boilers and coal fired industrial boilers are the largest SO2 emission categories 

in every SO2 Area of Influence. Several other industrial categories were minor 

contributors to SO2 emissions in the Areas of Influence. Control options and costs of 

controls were provided to the states. 

Concurrent Consultative Sessions

The meeting then broke into two concurrent sessions addressing the mountain or 

coastal Class I areas. Each state then summarized: 

• criteria used to rank sources in SO2 Areas of Influence for Class I areas in that state 

• list of sources for which reasonable control measures and 4 statutory factors are 

being considered 

• expected controls from exiting regulations for listed sources 

• status of BART determination 

• plans for consultation with neighboring states 

• next steps 
Groupings for of Class I Areas for VISTAS and Surrounding Regions

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

Mountains Groupings

1. Great Smoky Mtns (5 sites)

2. Mammoth Cave

3. Sipsey

4. Shenandoah (4 sites)

Coastal Groupings

5. Swanquarter

6. Cape Romain 

7. Okefenofee (4 sites)

8. Everglades

Neighboring Sites

9. Breton

10.Mingo (4 sites)

11.Brigantine

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

Mountains Groupings

1. Great Smoky Mtns (5 sites)

2. Mammoth Cave

3. Sipsey

4. Shenandoah (4 sites)

Coastal Groupings

5. Swanquarter

6. Cape Romain 

7. Okefenofee (4 sites)

8. Everglades

Neighboring Sites

9. Breton

10.Mingo (4 sites)

11.Brigantine

Status of BART Determinations in Each State

BART control for some sources subject to BART may be fuel switching

Some BART subject facilities took limits to exempt out, these are not included as a control

Alabama NO 31 2 2

*listed individual units, may or may not be the same facility

W.Virginia NO 22 3 0

Florida NO 47 9 don't know

Kentucky NO 31 1 1 maybe

Mississippi NO 15 2 1

N. Carolina NO 17 2 0

S. Carolina NO 21 14 0

Virginia NO 13 3 3*

Georgia NO 25 3 1 or 2

Tennessee NO 13 4 1 or 2

STATE Complete Eligible Subject Controlled

BART control for some sources subject to BART may be fuel switching

Some BART subject facilities took limits to exempt out, these are not included as a control

Alabama NO 31 2 2

*listed individual units, may or may not be the same facility

W.Virginia NO 22 3 0

Florida NO 47 9 don't know

Kentucky NO 31 1 1 maybe

Mississippi NO 15 2 1

N. Carolina NO 17 2 0

S. Carolina NO 21 14 0

Virginia NO 13 3 3*

Georgia NO 25 3 1 or 2

Tennessee NO 13 4 1 or 2

STATE Complete Eligible Subject Controlled

Issues Discussed and Resolved

• Reasonable progress goal should be reported using deciview with one significant 

digit beyond the decimal point (e.g. 25.4 dv, not 25.44 dv). 

• Final long-term strategy (LTS) run will not be completed in time for FLM 

consultation prior to public review. States can report that reasonable progress goal 

for 20% worst days will be at least as stringent as BaseG2a modeling results and 

that additional BART and reasonable measures within the state and neighboring 
states could accomplish greater progress than the Base G2. The final RPG would 

be reflected in the RH SIP submittal. 

• Consultation with non-VISTAS states: AR and MO are consulting with KY and 

TN. LA is participating in VISTAS meetings as consultation for BRET. MANEVU states have asked VISTAS states to consult this summer (call in July, meeting 

in Aug). 

• All four statutory factors need to be considered, but if there are no cost effective 

controls for a source, then the other three factors do not need to be addressed in 

depth. 

• GA found that 2018 emissions for non-EGU sources were sometimes 

overestimated, likely due to overestimating growth factors. 

• SIP wording should note that sources that take emissions limits to exempt from 

BART cannot go above that limit in the future. 

Issues Requiring Follow-up

• FLM asked KY about their plans to consult with MRPO states re impacts on 

Mammoth Cave 

• FLM and EPA asked for justification of the Class I area groupings. The 

groupings were intended to organize presentation of data for similar sites. The 

groupings are based on similar Areas of Influence and similar responses to 

geographic sensitivity analyses. 

• Most states used emissions divided by distance (Q/d) and maximum residence 

time (RTmax) to rank sources in the SO2 Areas of Influence. Most states used a 

1% contribution as cutoff to consider a source for 4 factor analysis of reasonable 

further controls. GA used 0.5% contribution as cut off. FLM and EPA asked for 

justification of cutoff value that states selected. FLM also suggested that states 

consider if a source affects more than one Class I area. 

• FLM need follow up from states on BART controls under review. 

• FLM would like to help define what midcourse review will look like. Focus 

expected to be on emissions changes from baseline to 2012 (CAIR, CSA, BART, 

projected mobile reductions). Trends in monitoring data may also be considered 

but may be difficult to interpret due to inter-annual variability in meteorology. 

What commitments will states make if emissions reductions are less than 

projected in the SIP? Need to describe in SIP how States will check progress and 

make corrections if/as needed. 

• SIP narratives need wording about new source growth and how PSD permitting 

will be affected, as well as about uncertainty in the 2018 projections. Each SIP 

must commit to what will be specifically reviewed at the 5-year check. Would 

like to see specific procedures on consulting with FLM. 

• FLM also suggested that States should interrelate PSD and haze by having the 

haze SIP set a zone around each Class I area to point out to state PSD permitters 

the area where they need to look more critically at controlling growth to protect 

the Air Quality Related Values (AQRVs) 

• Don’t forget deposition data, what improvements in deposition projected? Bill 

Jackson will make available upon request deposition results for 12 km grid using 

2018 Base G emissions (provided by Bill by Alpine Geophysics). 

• Consider benefits from ozone and PM2.5 attainment. How will new ozone 

standard affect visibility? 
• Florida needs to discuss with EPA Region 4 its plans for setting reasonable 

progress process. 

• FLM would prefer that they get a copy of the SIPs 60 days prior to the public 

hearing. 

• If states are not going to meet the December 17, 2007 deadline, they need to let 

EPA know and work with them. 

• Since Breton is not meeting the uniform rate of progress glidepath, FLM 

suggested that emissions sources permitted by Mineral Management Services 

should be separated from domestic sources (this has not been done to date). FLM 

also suggested that LA alert EPA that there is a marine treaty issue with MMS 

permits. 

• For Class I areas impacted by sources in different RPOs, it would be helpful if 

states used consistent methods for weight of evidence and reasonable progress 

goals. For BRET, LA could do similar AoI analysis for sources as VISTAS 

states. 

• Setting RPG for 20% best days: do states set as no degradation from 2000-2004 

baseline or as modeled results for 20% best days in 2018? In follow up with EPA 

and FLM: rule states no degradation on the 20% best days but also says that can’t 

set goal worse than progress expected under implementation of controls under 

other CAA programs. If Base G2 model results project that 20% best days will be 

better in 2018 than in 2000-2004, then states should discuss this is setting goal for 

20% best days. FLM pointed out if states use model results for 20% worst days, 

they should also use model results for 20% best days. States’ concern is whether 

model performance for 20% best days is reliable since most of VISTAS model 

performance evaluation to date has focused on 20% worst days, not 20% best 

days. For instance, there are issues with poor nitrate performance issues on 

winter days that could affect model projections for nitrate in 2018 for 20% best 

days that occur in the winter. 
Discussion of Revised Regional Haze Guidance

• EPA cautioned that states need to be careful to interpret the guidance as a whole 

and not isolate any single sentence in the guidance out of context of the whole 

document. The guidance does not trump the Regional Haze Rule or the Clean Air 

Act. 

• States need to look at the four statutory factors to determine what measures are 

reasonable. 

• States have flexibility. The new guidance states that in deciding the minimum 

RPG it is reasonable to defer reductions to later planning periods in order to 

maintain a consistent glidepath toward the long-term goal. 

• One possible approach is to use uniform reasonable progress to back out what 

additional controls are necessary. 

• $/dv approach is included in the new guidance as an additional measure of cost 

effectiveness. It is not intended to be used instead of $/ton. VISTAS does not 

have plans to generate $/dv in response to new guidance. If used, the correct 

metric for this objective would be $/Mm-1 rather than $/dv because dv is 

logarithmic. 

Conclusions and Plan of Action

VISTAS states committed to share summary of the meeting with the VISTAS 

workgroups. FLM, EPA, and VISTAS workgroups are asked to review the Technical 

Summary that is posted on the VISTAS website and provide feedback if the format, 

when completed, would meet expectations for a SIP Narrative. Comments are 

requested by the July 23 workgroup call. 

VISTAS contractors are working on final project reports. Reports will be posted to 

the VISTAS website. States are working on documentation for SIPs and intend to 

provide documentation to FLM for formal review prior to the public hearings. NC 

and SC are looking to provide documentation in July; other states expect 

documentation to be ready in the Aug-Nov timeframe. Each state will independently 

set their FLM consultation, public review, and SIP submittal process. 

VISTAS states are consulting with neighboring states as appropriate to meet the 

regional haze rule requirements. Each state is defining its own consultation process. 

VISTAS states are not clear if a final meeting with the VISTAS workgroups is 

needed prior to the public review. States have been working directly with their 

sources as necessary to evaluate BART controls and reasonable further control 

measures. VISTAS is providing technical support to the States, but the States are not 

developing collective policy recommendations through VISTAS. 

Questions should be directed to John Hornback, Pat Brewer, or state contacts. 
Breton Wilderness Class I Area 

Regional Haze Consultation Meeting 

October 30, 2007 

Participants: 

Alabama: Leigh Barb Bacon and Tim Martin 

Florida: Tom Rogers 

Louisiana: James Orgeron, Vivian Aucoin, Michelle Morgan and Gilberto Cuadra 

Mississippi: Elliot Bickerstaff and Mary Ellen Barnes 

FLM: Bruce Polkowski, Tim Allen, Jill Webster, Anne Mebane, and Meredith 

Bonds 

EPA Reg 6: Joe Kordzi 

Discussion Topics: 

Best Available Retrofit Technology (BART): 

Alabama: No formal rule making has been undertaken in regards to BART. 

Alabama felt as though all necessary authority to enforce the BART control measures 

were afforded by the Regional Haze Rule. 

According to department representatives, the only facility meeting potential BART 

subject requirements that is in the proximity to Breton is Big Escambia Creek, Escambia 

Operating Company LLC. The Big Escambia Creek gas production, treating and 

processing facility is a gas and condensate production, treating and processing facility. 

The facility has agreed to accept limits, which will mean a 40-50% reduction in SO2. The 

facility is approximately 280 km from Breton. 

Mississippi: No formal rule making has been undertaken in regards to BART. There 

are two facilities that are BART eligible: Mississippi Phosphates and the Chevron 

Refinery. Mississippi Phosphates has added dual absorption scrubbers which will reduce 

SO2 emissions by 2000 tpy. Modeling shows that no further reductions will be necessary. 

The Chevron Refinery, Pascagoula, is currently under a Consent Decree Order which 

reduces SO2 by 4000 tpy. NOx and PM10 reductions are included in the CD as well. 

With these reductions, the visibility impact dropped almost 98%, from 3.89 dv 

impairment to 0.79 dv impairment. 

Louisiana: No formal BART rule making was undertaken. Those facilities that were 

subject to BART were either covered by CAIR reductions or by Consent Decree Orders. 

All model protocols except two have been submitted for approval by the FLMs and EPA. 

Emission reductions are expected to be significant. 

Florida: Formal rule making was undertaken by Florida. There are three facilities in 

the Breton vicinity, but all have met exemption criteria. The largest utility in the area, 

Gulf Powers, Pensacola, is installing scrubbers on all units. SO2 reductions are expected 

to be rather significant; NOx and PM reductions will also occur. 

Florida is also promulgating a Reasonable Progress Rule. This rule is in the final 

stages and is expected to go final in December 2007, with an effective date of January 

2008. This rule will require that 15 facilities (32 units) will undergo the 4 factor analysis 

as outlined in the Regional Haze rule. A compliance date of December 1, 2017 has been 

set. 
All parties on the call also gave updates on Regional Haze SIP submittals and answered 

questions posed by EPA Reg 6 and the FLMs to satisfaction.