Appendix O.2 

USFS Comments on Draft Prehearing 

SIP 
United 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 of Natural 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 Georgia that 

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 of this 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 

implementation plan. 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 participation in the 

State of Georgia's administrative process does not waive any legal defenses or sovereignty rights 

it may have under the laws of the United States, includii the Clean Air Act and its 

implementing regulations. 

Our review focused on eight basic content areas which reflect priorities for the Forest Service. 

We have attached comments to 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 

Service compliments you on your hard work and dedication to significant improvement in our 

nation's air quality values and visibility. 

Sincerely, 

Forest Supervisor 

cc: Ann Acheson, Ray M Ellis 

Caring for the Land and Serving People Printed on Recycled Paper 43 
Chattahoochee and Oconee National 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 should be 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 1 1,2008 . . ." 

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) - Should read as ". . . wildfires or prescribed fires." 

page 15 (3" paragraph) - Please add to the end of the 1" sentence ". . . in comparison to 

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 &om Great Smoky Mountains National Park on the days the 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 should be made (as was 

done on page 103) that Georgia does operate under a SMP. Our concern is that Georgia 

may lose maximum flexibility to 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 

finding that wildland fire emissions are not a significant contributor 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 appears the current 

prescribed fire smoke management techniques implemented in Georgia are adequate to 

protect visibility in the Class I areas. If you concur, we suggest your agency note this 

Caring for the Land and Serving People Printed on Recycled Paper a 
finding 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 

management techniques to address ecological, human health and webe needs. 

12. page 50 - Figure 7.2.4-1 please remove "ew IMPROVE Al-orith" hm the graphic. 

13. page 70 (la paragraph) - Please delete the words ".. . most current ..." and just say ". . . were developed using the Base G VISTAS 2002 base year . . ." 

14. We are recommending the VISTAS Area of Influence (AOI) electronic spreadsheet that 

includes all sources be included in the Appendices. Appendix H.5 only includes the 

BART eligible sources. 

15. We agree that the Reasonable Progress approach used in tbis first Regional Haze SIP is a 

good approach and we appreciate the State of Georgia utilizing a lower Qld (source 

emissions divided by distance to 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 appropriate to 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 of the 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 addresses regional haze visibility impairment ... for each mandatory Class I 

Federal area located outside the State which 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 contribute to visibility impairment in any ... Class I area located in another 

State ..., the State must consult with the other State(s) in order to develop 

coordinated emission management 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 achieve its 

apportionment of emission reduction obligations agreed upon thu& that 

process." 

Section 10, 'Interstate Consultation', should include a list of Georgia sources the A01 

identified as having a potentid to impact the Class I areas in Alabama and North 
Carolina. The list also needs to include the pollution reductions that are anticipated at 

each source before 20 1 8. 

17. page 114 - We are recommending that the year the fmt 5-year progress report will be 

completed also be included in the first gatagraph.