# Appendix O.2
USFS Comments on Draft Prehearing SIPUnited States Forest Chattahoochee-Omnee 1755 Cleveiamd Highway 

## USDA Department of Service National Forests GainesvilIe, GA 30501 Agriculture Supervisor's Office (770) 29%3000

Mr. Jimmy Johnston Georgia Department ofNatural Resources Environmental Protection Division Air Protection Branch File Code: 2580 Date:

4244 International Parkway, Suite 120 Atlanta, GA 30354 

# I
Dear 

### Mr. Johnston: On December 22,2008, we received a draft implementation plan fiom the State of Georgiathat describes your proposal to improve 

### air quality regional 

### haze impacts at mandatory Class 

### I areas in your state. We appreciate

### the opportunity to work closely with your Agency through the initial evaluation, development, and now, subsequent review ofthis plan. Cooperative efforts such 

### as these ensure that, together, we will continue to make progress toward the Clean Air Act's goal of natural visibility conditions at our Class 

### I wilderness areas and parks. This letter acknowledges

### that the U.S. Department of Agriculture, U.S. Forest Service

### has received and conducted a substantive review of your proposed Regional 

### Haze Rule implementationplan. Please note, however, that only the U.S. Environmental Protection Agency 

### ('PA)can make a 

### final determination about the document's completeness, and therefore, only the EPA has the ability to approve the document. The Forest Service's participationin the Stateof Georgia's administrativeprocess does not waive any legal defenses or sovereigntyrights it may have under the laws ofthe United States, includiithe Clean Air Act and its implementing regulations. 

### Our review focused on eightbasic content areas which reflect priorities for the Forest Service. We have attached commentsto this letter. We look forward to your response required by 40 CFR 51.308(i)(3). For further information, please contact 

### Bill Jackson, Air Quality Specialist, at (828) 257-48 

### 15. Again, we appreciate the opportunity to work closely with the State of Georgia. The Forest Servicecompliments you onyour hard work and dedicationto significantimprovementin our nation's 

### air quality values and visibility. Sincerely,

Forest Supervisor
cc: Ann 

### Acheson, Ray

### M Ellis
Caring for the Land and Serving People Printedon Recycled Paper 

# 43Chattahoocheeand OconeeNational Forests Comments Georgia Regional Haze State Implementation Plan 

### (SIP)
page V 

### -For the 20 percent worst days the Reasonable Progress goal should be 7.45 and not 7.47; and the deciview (dv) improvement needed by 2064 should be 12.02 dv and not 12.00. page 4 -Joyce Kilmer, Tennessee shouldbe identified as Joyce Kilmer - Slickrock Wilderness Area, North Carolina and Tennessee. page 6 (2nd paragraph) 

### -Here and elsewhere in the document the following statement 

### can be removed: "Note that on July 11,2008 

## .

# .." page 1 1 

### -We concur with using the New IMPROVE equation. page 12 (1" paragraph) 

### -We would recommend the following phrase, "The 20 percent best visibility days at the Southern Appalachian sites 

## . 

# . ."be changed to "The 20 percent best visibility days 

### at Cohutta Wilderness 

## .. ." page 14 (1' paragraph) - Shouldread as 

## ".

. .wildfires or prescribed fires." page 15 (3" paragraph) -Please add to the end ofthe 1" sentence 

## ".

. .in comparisonto the former IMPROVE equation." page 17 -The values in Figure 3.1-1 should be listed to only two decimal places. page 24 

### -there is no image on Figure 42-1. (SO2 emissions in 2002 in the VISTAS States). 10. page 40 -We recognize 

### the.lack of IMPROVE 

### data contributed to assessing model performance at Cohutta Wilderness and we concur with the methods in Appendix 

### B to substitute data &omGreat Smoky Mountains National Park on the daysthe Cohutta monitoring site was missing data. 11. page 46 

### -We are recommending that the Smoke Management Plan (SMP) document should not be included in Appendix 

### H. 10, but ixlstead a reference shouldbe 

### made (as was done on page 103) that Georgia does operateunder a SMP. Our concern is that Georgia 

### may lose maximum flexibilityto modifj.the SMP on an as needed basis without having 

### to go through a SIP revision, or waiting for long periods of evaluation such as prescribed by the Regional 

### Haze review cycle. As stated in the pre-draft SIP, we concur with your findingthat wildland fire emissions are not a significantcontributor

### to visibility impairment at the Class 

### I 

### areas and further emission reduction techniques from prescribed fires are not needed before 201

### 8. Based upon this &ding, it 

### appearsthe current prescribed 

### fire smoke management techniques implemented in Georgia are adequateto protect visibility 

### in the Class I areas. If you concur, we suggestyour agency note this

Caring for the Land and Serving People Printed on Recycled Paper 

# afinding in the 

### final SIP. Also, you may want to note that your agency and the Georgia prescribed fire community are continuing to work together to refine the smoke managementtechniques to address ecological, human health and webe needs. 12. page 50 -Figure 7.2.4-1 please remove "ew IMPROVEAl-orith" hm the graphic. 13. page 70 (la paragraph) -Please delete the words 

## "..

.most current 

## ..." andjust say 

# ".

.. were developed using the Base G VISTAS 2002 base year 

## . . ." 14. We are recommending the VISTAS Area of Influence (AOI) electronic spreadsheetthat includes 

### all sources be included in the Appendices. Appendix H.5 only includes the BART eligible sources. 15. We agree that the Reasonable Progress approachused in tbis 

### firstRegional 

### Haze SIP is a good approach and we appreciate the State of Georgiautilizing a lower Qld (source emissions divided by distanceto the Class I area) value in comparison to other southeastern states. 16. The predrafi SIP does not discuss how emissions fiom all significant stationary sources in Georgia will affect visibility in Class 

### I 

### areas outside of Georgia; specifically Joyce Kilmer-Slickrock, LinviUe Gorge, Shining Rock and Sipsey Wildernesses. The information is contained in the VISTAS 

### Area of Influence (AOI) analyses and it would be appropriateto discuss how emission changes planned for all of Georgia sources (not only 

### BART sources) will affect visibility at Class 

### I areas in other states. There are three sections ofthe Regional 

### Haze Rule that we believe support our request:


### a 51.308 (d)(3) Lonn term stratem. "Each State... 

### must submit a long-term strategy that 

### addressesregional haze visibility impairment

# ... for each mandatory Class 

### I Federal area located outsidethe Statewhich may be affected by emissions from the State. The long-term strategy must include enforceable emissions litations, compliance schedules, and other measures as necessary to achieve the reasonable progress goals established by States having mandatory Class I Federal areas." b. 51.308 (d) (3) (i) "Where the State 

### has emissions that 

### are reasonably anticipated to contributeto visibility impairmentin any 

## ... Class 

### I area located in another State

# ..., the State must consult with the other State(s) in orderto develop coordinated emissionmanagement strategies."


### c. 5 1.308 (d) 

### (3) 

### (ii) "If

### the State has participated in a regional planning process, the State must ensure it 

### has included 

### all measures needed to achieveits apportionment of emission reduction obligationsagreed upon thu& that 

### process." Section 10, 'Interstate Consultation', should include a list of Georgia sources the A01 identified as having a potentid to impactthe Class I areas in Alabama and NorthCarolina. The 

### list also needs to include the pollution reductionsthat are anticipatedat each source before 2018. 17. page 114 -We are recommendingthat the year the fmt 5-year progress report willbe completed also be included in the first gatagraph.