Technical Support Document 

for the 

Louisiana Regional Haze State Implementation Plan 

Docket ID: EPA-R06-OAR-2008-0510 

February 2012 

Prepared by: 

Ellen Belk 

Sandra Rennie 

Joe Kordzi 

Dayana Medina 

Michael Feldman 

Erik Snyder 

Carrie Thomas 

Carrie Paige 

Bill Nally 

U.S. EPA Region 6, Dallas Texas 

 

1 
Table of Contents 

I. Executive Summary of Proposed Action 

II. What is the Background for Our Proposed Actions? 

A. The Regional Haze Problem 

B. Requirements of the CAA and EPA’s Regional Haze Rule (RHR) 

C. Roles of Agencies in Addressing Regional Haze 

III. What are the Requirements for Regional Haze SIPs? 

A. The CAA and the Regional Haze Rule 

B. Determination of Baseline, Natural, and Current Visibility Conditions 

C. Determination of Reasonable Progress Goals 

D. Best Available Retrofit Technology (BART) 

E. Long-Term Strategy (LTS) 

F. Coordinating Regional Haze and Reasonably Attributable Visibility Impairment (RAVI) 

G. Monitoring Strategy and Other SIP Requirements 

H. Coordination with Federal Land Managers 

I. Periodic SIP Revisions and Five-year Progress Reports 

J. Determination of the Adequacy of Existing Implementation Plan 

IV. Our Analysis of Louisiana’s Regional Haze SIP 

A. Identification of Affected Class I Areas 

B. Determination of Baseline, Natural and Current Visibility Conditions 

1. Estimating Natural Visibility Conditions 

2. Estimating Baseline Visibility Conditions 

3. Natural Visibility Impairment 

4. Uniform Rate of Progress 

C. Evaluation of Louisiana’s Reasonable Progress Goals 

D. Evaluation of Louisiana’s BART Analyses 

1. Identification of BART-Eligible Sources 

2. Identification of Sources Subject to BART 

3. BART Determinations 

 a. ConocoPhillips 

 b. Rhodia 

 c. Sid Richardson Carbon Company 

E. Long-Term Strategy 

1. Emissions Inventories 

 a. Louisiana’s 2002 Emission Inventory 

 b. Louisiana’s 2018 Emission Inventory 

2. Visibility Projection Modeling 

3. Sources of Visibility Impairment 

 a. Sources of Visibility Impairment in the Breton Class I Area 

 b. Louisiana’s Contribution to Visibility Impairment in Class I Areas Outside the 

State 

4. Consultation for Other State’s Class I Areas 

5. Mandatory Long-Term Strategy Factors 

 a. Reductions Due to Ongoing Air Pollution Programs 

 b. Measures to Mitigate the Impacts of Construction Activities 

2 
 c. Emissions Limitations and Schedules of Compliance 

 d. Source Retirement and Replacement Schedules 

 e. Agricultural and Forestry Smoke Management Techniques 

 f. Enforceability of Emissions Limitations and Control Measures 

 g. Anticipated Net Effect on Visibility Due to Projected Changes 

 F. Coordination of RAVI and Regional Haze Requirements 

G. Monitoring Strategy and Other SIP Requirements

H. Coordination with Federal Land Managers 

I. Periodic SIP Revisions and Five-year Progress Reports 

J. Determination of the Adequacy of Existing Implementation Plan 

V. Proposed Action 

3 
Tables

Table 1. Summary of Uniform Rate of Progress 

Table 2. Comparison of Reasonable Progress Goals to Uniform Rate of Progress on Most 

Impaired Days for Louisiana Class I areas 

Table 3. Comparison of Reasonable Progress Goals to Baseline Conditions on Least Impaired 

Days for Louisiana Class I areas 

Table 4. Alpine Geophysics Subregional Control Strategy for Breton Island 

Louisiana Plants 

Table 5. Alpine Geophysics Subregional Control Strategy for Breton Island 

Plants in Alabama, Mississippi, and Florida 

Table 6. Facilities with BART-eligible units in Louisiana 

Table 7. BART-eligible Facilities Identified by LDEQ as a) Requested to Screen or Perform 

Refined Modeling or b) as Not Subject to BART 

Table 8. BART-eligible Facilities Identified by LDEQ as Requested to Screen or Perform 

Refined Modeling: CALPUFF/CALPOST Screening Results 

Table 9. Non-EGU Sources in Louisiana Subject to BART 

Table 10. ConocoPhillips Alliance Refinery BART-Subject Units 

Table 11. Louisiana 2002 Emissions Inventory 

Table 12. Louisiana 2018 Emissions Inventory 

Table 13. Percent Contribution from Louisiana Emissions to Total Visibility Impairment at 

Class I areas on 20% Worst Days 

 

4 
Figures and Appendices 

Figures 

Figure 1. Map of Class I Areas 

Figure 2. Location of Louisiana’s Class I Area: Breton National Wilderness Area 

Figure 3. Map of Regional Planning Organization Boundaries 

 

Appendices 

Appendix A: Modeling and Emission Inventory Development; Review and Analysis for 

Louisiana’s Regional Haze State Implementation Plan Submittal 

Appendix B: ConocoPhillips Subject-to-BART Heaters Emissions (lb/hr) 

Appendix C: Rhodia Subject to BART Units Emissions (lb/hr) 

Appendix D: Percent Contribution from Louisiana Emissions to Total Visibility Impairment at 

Class I areas on 20% Worst Days 

Appendix E: Incidence of Biomass Burning in Louisiana 

 

5 
Supplementary Information 

Throughout this document wherever “we,” “us,” or “our” is used, we mean the 

Environmental Protection Agency (EPA). 

Italics: For convenience, for each section of the outline in this technical support 

document (TSD), we include information from the Notice of Proposed Rulemaking in italicized 

text, with the exception of tables. Some non-substantive changes have been made to this text to 

facilitate reading of this TSD, including the renumbering of tables, as appropriate. 

We note for the Appendices, each Appendix begins with page 1. 

 

6 
I. Executive Summary of Proposed Action 

The EPA is proposing a partial limited approval of Louisiana’s June 13, 2008, State 

Implementation Plan (SIP) revision addressing regional haze (RH) under the Clean Air Act 

(CAA) sections 301(a) and 110(k)(3) because certain provisions of the revision strengthen the 

Louisiana (LA) SIP. The EPA is also proposing a partial disapproval of the LA RH SIP submittal 

because the submittal includes several deficient provisions. The deficiencies identified in today’s 

action go beyond those identified in the limited disapproval proposed on December 30, 2011 (76 

FR 82219). Certain elements of the State’s Best Available Retrofit Technology (BART) 

evaluations and determinations are not fully adequate to meet the federal requirements. 

Additionally, as a result of the deficiencies related to BART, the Long-Term Strategy (LTS) and 

Reasonable Progress Goals (RPGs) are not fully adequate to meet federal requirements. Finally, 

because visibility impacts from smoke are significant in Louisiana, we propose that Louisiana 

should finalize its Smoke Management Plan (SMP). The portions of the revision proposed for 

limited approval nevertheless represent an improvement over the current SIP, and make 

considerable progress in fulfilling the applicable CAA RH program requirements. The proposed 

rulemaking and this TSD explain the basis for EPA's proposed partial limited approval and 

partial disapproval. 

Under CAA sections 301(a) and 110(k)(6) and EPA’s long-standing guidance,1

 a limited 

approval results in approval of portions of the SIP submittal, even though they are deficient and 

prevent EPA from granting a full approval of the SIP revision. In an earlier proposed action, 

EPA has proposed a limited disapproval of Louisiana’s RH SIP revision for not meeting all the 

applicable requirements of the CAA (76 FR 82219). In today’s proposed action, having 

concluded based on a careful review of the LA RH SIP revision that there are deficiencies in the 

SIP beyond those identified in the proposed limited disapproval of the LA RH SIP, we are 

proposing a partial disapproval of those additional deficiencies and a partial limited approval of 

the rest of the LA RH SIP. The partial limited approval proposes to give limited approval to 

those portions of the SIP that are not being disapproved in today’s action for their benefit in 

strengthening the SIP even though they do not fully meet regional haze requirements. 

Specifically, we are proposing to find that the following elements of the submittal fully 

satisfy federal requirements insofar as the elements do not rely on the sulfur dioxide (SO2) 

reductions from the Clean Air Interstate Rule (CAIR): the State’s identification of affected Class 

I areas; the establishment of baseline, natural and current visibility conditions, including the 

Uniform Rate of Progress (URP); coordination of reasonably attributable visibility impairment 

(RAVI) and RH requirements; the RH monitoring strategy and other SIP requirements under 

Title 40 of the Code of Federal Regulations (denoted 40 CFR), Part 51.308(d)(4); the State’s 

commitment to submit periodic RH SIP revisions and periodic progress reports describing 

progress towards the State’s RPGs; the State’s commitment to make a determination of the 

adequacy of the existing SIP at the time a progress report is submitted; and the State’s 

coordination with Federal Land Managers (FLMs). 

We are proposing to find that Louisiana’s RPGs meet some federal requirements, but 

also contain some deficiencies. We are proposing to find that the State’s RPGs are deficient 

given our proposed finding that certain of Louisiana’s BART determinations are not fully 

approvable. In general, the State followed the requirements of 40 CFR 51.308(d)(1), but these 

 

1

 Processing of State Implementation Plan (SIP) Revisions, EPA Memorandum from John Calcagni, Director, Air 

Quality Management Division, OAQPS, to Air Division Directors, EPA Regional Offices I-X (1992 Calcagni 

Memorandum) located at http://www.epa.gov/ttn/caaa/t1/memoranda/siproc.pdf. 

7 
goals do not reflect appropriate emissions reductions from BART. 

For LTS, we are proposing to find that the State’s LTS satisfies many of the requirements 

under 40 CFR 51.308(d)(3); however, we are proposing to find that the submitted LTS is 

deficient because a portion of it relies on BART determinations that we are proposing to 

disapprove. Also, because visibility impacts from smoke are significant in Louisiana, we propose 

to find that that Louisiana should finalize its SMP. 

For the BART analyses for sources other than electric generating units (EGUs), we are 

proposing to find that the State’s identification of subject-to-BART sources meets federal 

requirements in part, but that the state should have identified the Mosaic facility as being subject 

to BART and made a BART determination for the source. This is discussed in more detail below 

and in section IV.D.2 of the proposal. We are also proposing to find that the BART 

determinations made by the Louisiana Department of Environmental Quality’s (LDEQ) for 

Conoco Phillips, Rhodia, and Sid Richardson Carbon Black are not fully approvable. These 

BART determinations are discussed in more detail below and in section IV.D.3 of the proposal. 

As noted above, in an earlier proposed action, the EPA proposed a limited disapproval of 

the Louisiana regional haze SIP. The EPA’s proposed limited disapproval is based on 

deficiencies in the state’s regional haze SIP submittal arising from the state’s reliance on the 

CAIR to meet certain regional haze requirements. In the same December 30, 2011 notice, the 

EPA proposed to find that the Transport Rule,2

 a rule issued in 2011 to address the interstate 

transport of nitrogen oxides (NOX) and SO2 in the eastern United States would, like the CAIR, 

provide for greater reasonable progress towards the national goal than would BART. 76 FR 

82219. Based on this proposed finding, the EPA also proposed to revise the Regional Haze Rule 

(RHR) to allow states to substitute participation in the trading programs under the Transport 

Rule for source-specific BART. This proposed revision applies only to EGUs in the states in the 

Transport Rule region and only to the pollutants subject to the requirements of the Transport 

Rule. States such as Louisiana that are subject to the requirements of the Transport Rule trading 

program only for NOX must still address BART for EGUs for SO2 and other visibility impairing 

pollutants. See, 76 FR at 82224. Consequently, while we proposed on December 30, 2011 to 

issue a federal implementation plan (FIP) to address the deficiencies in Louisiana’s SIP 

associated with the BART requirements for NOX for EGUs, we did not propose a plan to address 

the deficiencies associated with the BART requirements for SO2. The docket for this earlier EPA 

proposed limited disapproval of Louisiana’s regional haze SIP may be found at Docket ID No. 

EPA-HQ-OAR-2011-0729. 

Louisiana also relied on the CAIR in assessing the need for emissions reductions from 

EGUs to ensure reasonable progress. Consequently, Louisiana will have to reconsider whether 

reductions of SO2 from EGUs, whether subject to BART or not, are appropriate for ensuring 

reasonable progress. 

Where a submittal addresses a mandatory requirement of the CAA, we must, within 24 

months following a final disapproval, either approve a SIP or promulgate a FIP. CAA section 

110(c)(1). At this time, we are not proposing a FIP for the portions of the Louisiana RH SIP we 

are proposing in this action to find deficient because the LDEQ has expressed its intent to revise 

the Louisiana RH SIP by correcting the deficiencies. We are electing to not propose a FIP at this 

time in order to provide Louisiana time to correct these deficiencies. However, a final partial 

disapproval of Louisiana’s RH SIP will start the two-year mandatory FIP clock. If the State 

submits an approvable rule revision during the FIP clock period, final approval of the rule 

 

2

 76 FR 48208 (August 8, 2011). 

8 
revision correcting the deficiencies will terminate the FIP clock. 

 

9 
II. What is the Background for Our Proposed Actions? 

Relationship of this TSD to our Proposal 

 This TSD is not meant to be a complete rationale for our decision. It merely provides 

additional information for some of the technical aspects of the basis for this action when needed. 

In some of the non-technical areas, our Federal Register (FR) notice provides more detail than 

does this TSD. Also, this TSD treats the requirements of 40 CFR 51.308 in the order in which 

they appear in the FR notice. The TSD also attempts to refer the reader to the specific portions of 

the Louisiana RH SIP submittal that we relied upon for our analysis of particular portions of 40 

CFR 51.308. 

Throughout this document, we often use language such as, “we find” or other similar 

phrases that on the surface would suggest a final determination has been made. However, all 

aspects of our TSD should be considered to be part of our proposal and are subject to change 

based on comments and other information we may receive during our public comment period. 

This TSD contains several appendices that support our proposal. TSD Appendix A 

provides “Modeling and Emission Inventory Development; Review and Analysis for Louisiana’s 

Regional Haze State Implementation Plan.” TSD Appendix B provides the emissions for several 

units at ConocoPhillips. TSD Appendix C contains the emissions for Rhodia. TSD Appendix D 

provides the information which was used to develop Table 13: Percent Contribution from 

Louisiana Emissions to Total Visibility Impairment at Class I areas on 20% Worst Days. TSD 

Appendix E shows “Incidence of Biomass Burning in Louisiana.” 

A. The Regional Haze Problem 

Regional haze is visibility impairment that is produced by a multitude of sources and 

activities which are located across a broad geographic area and emit fine particulate matter 

(PM2.5) (e.g., sulfates, nitrates, organic carbon, elemental carbon, and soil dust), and their 

precursors (e.g., SO2, NOX, and in some cases, ammonia (NH3) and volatile organic compounds 

(VOCs)). Fine particle precursors react in the atmosphere to form fine particulate matter that 

impairs visibility by scattering and absorbing light. Visibility impairment reduces the clarity, 

color, and visible distance that one can see. PM2.5 can also cause serious health effects and 

mortality in humans and contributes to environmental effects such as acid deposition and 

eutrophication. 

Data from the existing visibility monitoring network, the “Interagency Monitoring of 

Protected Visual Environments” (IMPROVE) monitoring network, show that visibility 

impairment caused by air pollution occurs virtually all the time at most national park and 

wilderness areas. The average visual range3

 in many Class I areas4 (i.e., national parks and 

memorial parks, wilderness areas, and international parks meeting certain size criteria) in the 

 

3

 Visual range is the greatest distance, in kilometers or miles, at which a dark object can be viewed against the sky. 4

 Areas designated as mandatory Class I Federal areas consist of national parks exceeding 6,000 acres, wilderness 

areas and national memorial parks exceeding 5,000 acres, and all international parks that were in existence on 

August 7, 1977. See, 42 U.S.C. 7472(a). In accordance with section 169A of the CAA, the EPA, in consultation 

with the Department of Interior, promulgated a list of 156 areas where visibility is identified as an important 

value. See, 44 FR 69122, November 30, 1979. The extent of a mandatory Class I area includes subsequent 

changes in boundaries, such as park expansions. See, 42 U.S.C. 7472(a). Although states and tribes may 

designate as Class I additional areas which they consider to have visibility as an important value, the 

requirements of the visibility program set forth in section 169A of the CAA apply only to “mandatory Class I 

Federal areas.” Each mandatory Class I Federal area is the responsibility of a “Federal Land Manager.” See, 42 

U.S.C. 7602(i). When the term “Class I area” is used in this action, it means a “mandatory Class I Federal area.” 

10 
western United States is 100-150 kilometers, or about one-half to two-thirds of the visual range 

that would exist without anthropogenic air pollution. In most of the eastern Class I areas of the 

United States, the average visual range is less than 30 kilometers, or about one-fifth of the visual 

range that would exist under estimated natural conditions. See, 64 FR 35715, July 1, 1999. 

The Regional Haze Rule (RHR) is codified at 40 CFR 51.308. 

Congress adopted the visibility provisions to protect visibility in 156 Federal Class I 

areas, which include certain national parks, memorial parks, and wilderness areas over a 

certain size, and all international parks. These areas are defined at 40 CFR 81.400, are listed 

by state at 40 CFR 81.401-81.437, and are depicted in Figure 1. The only Class I area within 

Louisiana, the Breton National Wilderness Area, is depicted in Figure 2. 

Figure 1. Map of Class I Areas 

11 
Figure 2. Location of the Class I Area, Breton National Wilderness Area in Louisiana 

B. Requirements of the CAA and EPA’s Regional Haze Rule (RHR) 

In section 169A of the 1977 Amendments to the CAA, Congress created a program for 

protecting visibility in the nation’s national parks and wilderness areas. This establishes as a 

national goal the “prevention of any future, and the remedying of any existing, impairment of 

visibility in mandatory Class I Federal areas which impairment results from manmade air 

pollution.” On December 2, 1980, the EPA promulgated regulations to address visibility 

impairment in Class I areas that is “reasonably attributable” to a single source or small group 

of sources, i.e., “reasonably attributable visibility impairment.” 45 FR 80084. These regulations 

represented the first phase in addressing visibility impairment. The EPA deferred action on 

regional haze that emanates from a variety of sources until monitoring, modeling, and scientific 

knowledge about the relationships between pollutants and visibility impairment were improved. 

Congress added section 169B to the CAA in 1990 to address regional haze issues. The 

EPA promulgated a rule to address regional haze on July 1, 1999 (64 FR 35713), the RHR. The 

RHR revised the existing visibility regulations to integrate into the regulation provisions 

addressing regional haze impairment and established a comprehensive visibility protection 

program for Class I areas. The requirements for regional haze, found at 40 CFR 51.308 and 

51.309, are included in the EPA’s visibility protection regulations at 40 CFR 51.300-309. Some 

of the main elements of the regional haze requirements are summarized below and in section III 

of the proposal. The requirement to submit a regional haze SIP applies to all 50 states, the 

District of Columbia, and the Virgin Islands.5

 40 CFR 51.308(b) requires states to submit the 

first implementation plan addressing regional haze visibility impairment no later than December 

17, 2007. 

In the 1990 Amendments to the CAA, Congress added Section 169B and called on us to 

issue RH rules. The RH rule that we promulgated on July 1, 1999 (64 FR 35714) revised the 

existing visibility regulations to integrate provisions addressing regional haze visibility 

impairment and establish a comprehensive visibility protection program for Federal Class I 

areas. These regulations represented the second phase in addressing visibility impairment. States 

were required to submit SIPs to us that set out each state’s plan for complying with the RH Rule, 

including consultation and coordination with other states and with FLMs. States were required to 

 

5

 Albuquerque/Bernalillo County in New Mexico must also submit a regional haze SIP to completely satisfy the 

requirements of section 110(a)(2)(D) of the CAA for the entire State of New Mexico under the New Mexico Air 

Quality Control Act (section 74-2-4). 

12 
submit a Regional Haze SIP to us within three years after the date of designation of areas under 

the National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM2.5). We 

promulgated PM2.5 designations on December 17, 2004, and thus, regional haze SIPs were to be 

submitted to us by December 17, 2007, which is also specified at 40 CFR 51.308(b). We 

received the Louisiana RH SIP on June 13, 2008. 

C. Roles of Agencies in Addressing Regional Haze 

Successful implementation of the RH program will require long-term regional 

coordination among states, tribal governments and various federal agencies. As noted above, 

pollution affecting the air quality in Class I areas can be transported over long distances, even 

hundreds of kilometers (km). Therefore, to address effectively the problem of visibility 

impairment in Class I areas, states need to develop strategies in coordination with one another, 

taking into account the effect of emissions from one jurisdiction on the air quality in another. 

Because the pollutants that lead to RH can originate from sources located across broad 

geographic areas, we have encouraged the states and tribes across the United States (U.S.) to 

address visibility impairment from a regional perspective. Five regional planning organizations 

(RPOs) were developed to address RH and related issues. The RPOs first evaluated technical 

information to better understand how their states and tribes impact Class I areas across the 

country, and then pursued the development of regional strategies to reduce emissions of 

particulate matter and other pollutants leading to RH. 

The Central Regional Air Planning Association (CENRAP) is an organization of states, 

tribes, federal agencies and other interested parties that identifies RH and visibility issues and 

develops strategies to address them. The CENRAP is one of the five RPOs across the U.S. and 

includes the states and tribal areas of Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, 

Missouri, Arkansas, and Louisiana. 

The RH rule addressed the combined visibility effects of various pollution sources over a 

wide geographic region. Consequently, all 50 states, including those without Class I areas, 

Washington, D.C., and the Virgin Islands, were required to submit Regional Haze SIPs (40 CFR 

51.300(b)(3)). We designated five RPOs to assist with the coordination and cooperation needed 

to address the visibility issue, as shown by Figure 3. 

13 
Figure 3. Map of Regional Planning Organization Boundaries 

 

The CENRAP also includes federally recognized Indian tribes located within the 

geographic boundaries of its member states. Louisiana and its air pollution control agency, the 

LDEQ, chose to participate in the CENRAP to develop the technical analyses needed to fulfill 

the requirements of the RH Rule. 

III. What are the Requirements for Regional Haze SIPs? 

The following is a summary and basic explanation of the regulations covered under the 

RHR. See, 40 CFR 51.308 for a complete listing of the regulations under which this SIP is being 

evaluated. 

A. The CAA and the Regional Haze Rule 

RH SIPs must assure reasonable progress towards the national goal of achieving natural 

visibility conditions in Class I areas. Section 169A of the CAA and our implementing regulations 

require states to establish long-term strategies for making reasonable progress toward meeting 

this goal. Implementation plans must also give specific attention to certain stationary sources 

that were in existence on August 7, 1977, but were not in operation before August 7, 1962, and 

require these sources, where appropriate, to install BART controls for the purpose of eliminating 

or reducing visibility impairment. The specific RH SIP requirements are discussed in further 

detail below. 

B. Determination of Baseline, Natural, and Current Visibility Conditions 

The RHR establishes the deciview (dv) as the principal metric for measuring visibility. 

14 
See, 70 FR 39104 at 39118. This visibility metric expresses uniform changes in the degree of 

haze in terms of common increments across the entire range of visibility conditions, from pristine 

to extremely hazy conditions. Visibility is sometimes expressed in terms of the visual range, 

which is the greatest distance, in kilometers or miles, at which a dark object can just be 

distinguished against the sky. The deciview is a useful measure for tracking progress in 

improving visibility, because each deciview change is an equal incremental change in visibility 

perceived by the human eye. Most people can detect a change in visibility of one deciview. 6

 

The deciview is used in expressing RPGs (which are interim visibility goals towards 

meeting the national visibility goal), defining baseline, current, and natural conditions, and 

tracking changes in visibility. The RH SIPs must contain measures that ensure “reasonable 

progress” toward the national goal of preventing and remedying visibility impairment in Class I 

areas caused by man-made air pollution by reducing anthropogenic emissions that cause RH. 

The national goal is a return to natural conditions, i.e., man-made sources of air pollution would 

no longer impair visibility in Class I areas. 

To track changes in visibility over time at each of the 156 Class I areas covered by the 

visibility program (40 CFR 81.401-437), and as part of the process for determining reasonable 

progress, states must calculate the degree of existing visibility impairment at each Class I area 

at the time of each RH SIP submittal and periodically review progress every five years, midway 

through each 10-year implementation period. To do this, the RHR requires states to determine 

the degree of impairment (in deciviews) for the average of the 20 percent least impaired (“best”) 

and 20 percent most impaired (“worst”) visibility days over a specified time period at each of 

their Class I areas. In addition, states must also develop an estimate of natural visibility 

conditions for the purpose of comparing progress toward the national goal. Natural visibility is 

determined by estimating the natural concentrations of pollutants that cause visibility 

impairment and then calculating total light extinction based on those estimates. We have 

provided guidance to states regarding how to calculate baseline, natural and current visibility 

conditions.7

For the first RH SIPs that were due by December 17, 2007, “baseline visibility 

conditions” were the starting points for assessing “current” visibility impairment. Baseline 

visibility conditions represent the degree of visibility impairment for the 20 percent least 

impaired days and 20 percent most impaired days for each calendar year from 2000 to 2004. 

Using monitoring data for 2000 through 2004, states are required to calculate the average 

degree of visibility impairment for each Class I area, based on the average of annual values over 

the five-year period. The comparison of initial baseline visibility conditions to natural visibility 

conditions indicates the amount of improvement necessary to attain natural visibility, while the 

future comparison of baseline conditions to the then current conditions will indicate the amount 

of progress made. In general, the 2000 - 2004 baseline period is considered the time from which 

improvement in visibility is measured. 

 

6

 The preamble to the RHR provides additional details about the deciview. 64 FR 35714, 35725 (July 1, 1999). 7

 Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, September 2003, EPA454/B-03-005, available at http://www.epa.gov/ttncaaa1/t1/memoranda/rh_envcurhr_gd.pdf, (hereinafter 

referred to as “our 2003 Natural Visibility Guidance”); and Guidance for Tracking Progress Under the Regional 

Haze Rule,(EPA-454/B-03-004, September 2003, available at 

http://www.epa.gov/ttncaaa1/t1/memoranda/rh_tpurhr_gd.pdf, (hereinafter referred to as our “2003 Tracking 

Progress Guidance”). 

15 
A deciview is a uniform measure of light extinction caused by regional haze. The 

deciview scale approaches zero for no visibility degradation and increases as visibility is 

degraded. The deciview scale was designed similar to the decibel scale for sound, so that equal 

changes in deciview are equally perceptible. Common current values in the west are 15 to 20 dv; 

common current values in the east are 25 to 30 dv. 

 In 2005, the IMPROVE Steering Committee made recommendations for a refined 

equation that modifies the terms of the original equation to account for the most recent data. The 

purpose of this refinement is to provide more accurate estimates of the various factors that affect 

the calculation of light extinction. The new IMPROVE equation estimates additive extinction 

coefficients for each of several chemical constituents of particulate matter: sulfurous, nitrate, 

organic carbonaceous, elemental “light-absorbing” carbonaceous, fine soil, chlorine or chloride, 

and coarse matter. The equation also accounts for Rayleigh scattering of light (due to 

atmospheric gases) and for deliquescence8

 on sulfurous, nitrate, and chlorine or chloride 

particulates with an estimate of particle-bound water as a function of relative humidity. It reflects 

the most recent review of the science9 and it accounts for the effect of particle size distribution 

on light extinction efficiency of sulfate, nitrate, and organic carbon. It also adjusts the mass 

multiplier for organic carbon (particulate organic matter) by increasing it from 1.4 to 1.8. New 

terms are added to the equation to account for light extinction by sea salt and light absorption by 

gaseous nitrogen dioxide. Site-specific values are used for Rayleigh scattering to account for the 

site-specific effects of elevation and temperature. Separate relative humidity enhancement 

factors are used for small and large size distributions of ammonium sulfate and ammonium 

nitrate and for sea salt. The terms for the remaining contributors, elemental carbon (lightabsorbing carbon), fine soil, and coarse mass terms, do not change between the original and new 

IMPROVE equations. 

For each mandatory Class I Federal area located within the State, the State must 

determine the natural visibility conditions for the most impaired and least impaired days. Natural 

visibility conditions must be calculated by estimating the degree of visibility impairment existing 

under natural conditions for the most impaired and least impaired days, based on available 

monitoring information and appropriate data analysis techniques. 

The period for establishing baseline visibility conditions is 2000 to 2004. Baseline 

visibility conditions must be calculated, using available monitoring data, by establishing the 

average degree of visibility impairment for the most and least impaired days for each calendar 

year from 2000 to 2004. The baseline visibility conditions are the average of these annual values. 

For mandatory Class I Federal areas without onsite monitoring data for 2000–2004, Louisiana 

must establish baseline values using the most representative available monitoring data for 2000–

 

8

 Deliquescence: tending to melt or dissolve. 

9

 An explanation of the revised IMPROVE equation is found in LA RH SIP, Appendix B, “Technical Support 

Document for the Central regional Air Planning Association (CENRAP),” and information regarding the science 

behind it can be found in numerous published papers. See for example: Hand, J.L., and Malm, W.C., 2006, Review 

of the IMPROVE Equation for Estimating Ambient Light Extinction Coefficients - Final Report. March 2006. 

Prepared for Interagency Monitoring of Protected Visual Environments (IMPROVE), Colorado State University, 

Cooperative Institute for Research in the Atmosphere, Fort Collins, Colorado. 

http://vista.cira.colostate.edu/improve/publications/GrayLit/016_IMPROVEeqReview/IMPROVEeqReview.htm; and 

Pitchford, Marc., 2006, Natural Haze Levels II: Application of the New IMPROVE Algorithm to Natural Species 

Concentrations Estimates. Final Report of the Natural Haze Levels II Committee to the RPO Monitoring/Data 

Analysis Workgroup. September 2006 

http://vista.cira.colostate.edu/improve/Publications/GrayLit/029_NaturalCondII/naturalhazelevelsIIrenatu.ppt

16 
2004, in consultation with the Administrator or his or her designee. 

In establishing a reasonable progress goal for any mandatory Class I Federal area within 

the State, Louisiana must analyze and determine the rate of progress needed to attain natural 

visibility conditions by the year 2064. To calculate this rate of progress, Louisiana must compare 

baseline visibility conditions to natural visibility conditions in the mandatory Federal Class I area 

and determine the uniform rate of visibility improvement (measured in deciviews) that would 

need to be maintained during each implementation period10 in order to attain natural visibility 

conditions by 2064. 

C. Determination of Reasonable Progress Goals 

The vehicle for ensuring continuing progress towards achieving the natural visibility 

goal is the submission of a series of RH SIPs from the states that establish two RPGs (i.e., two 

distinct goals, one for the “best” and one for the “worst” days) for every Class I area for each 

(approximately) 10-year implementation period. See, 70 FR 3915; See also 64 FR 35714. The 

RHR does not mandate specific milestones or rates of progress, but instead calls for states to 

establish goals that provide for “reasonable progress” toward achieving natural (i.e., 

“background”) visibility conditions. In setting RPGs, states must provide for an improvement in 

visibility for the most impaired days over the (approximately) 10-year period of the SIP, and 

ensure no degradation in visibility for the least impaired days over the same period. Id. 

States have significant discretion in establishing RPGs, but are required to consider the 

following factors established in section 169A of the CAA and in our RHR at 40 CFR 

51.308(d)(1)(i)(A): (1) the costs of compliance; (2) the time necessary for compliance; (3) the 

energy and non-air quality environmental impacts of compliance; and (4) the remaining useful 

life of any potentially affected sources. States must demonstrate in their SIPs how these factors 

are considered when selecting the RPGs for the best and worst days for each applicable Class I 

area. States have considerable flexibility in how they take these factors into consideration, as 

noted in our Reasonable Progress Guidance.11 In setting the RPGs, states must also consider the 

rate of progress needed to reach natural visibility conditions by 2064 (the URP) and the 

emission reduction measures needed to achieve that rate of progress over the 10-year period of 

the SIP. Uniform progress towards achievement of natural conditions by the year 2064 

represents a rate of progress, which states are to use for analytical comparison to the amount of 

progress they expect to achieve. In setting RPGs, each state with one or more Class I areas 

(“Class I State”) must also consult with potentially “contributing states,” i.e., other nearby 

states with emission sources that may be affecting visibility impairment at the Class I State’s 

areas. 40 CFR 51.308(d)(1)(iv). 

For each mandatory Class I Federal area located within the state, Louisiana must 

establish goals (expressed in deciviews) that provide for reasonable progress towards achieving 

natural visibility conditions. The reasonable progress goals must 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. 

 

10 Each implementation period is 10 years, thus there are 6 implementation periods to attain natural visibility 

conditions by 2064. 11 Guidance for Setting Reasonable Progress Goals under the Regional Haze Program, June 1, 2007, memorandum 

from William L. Wehrum, Acting Assistant Administrator for Air and Radiation, to EPA Regional 

Administrators, EPA Regions 1-10 (pp.4-2, 5-1). 

17 
In addition to this explicit regulatory requirement, the RHR also establishes an analytical 

requirement to ensure that each State considers carefully the suite of emission reduction 

measures necessary to attain the URP. The RHR provides that EPA will consider both the State’s 

consideration of the four factors in 40 CFR 51.308(d)(1)(i)(A) and its analysis of the URP “[i]n 

determining whether the State’s goal for visibility improvement provides for reasonable 

progress.” 40 CFR 51.308(d)(1)(iii). As explained in the preamble to the RHR, the URP analysis 

was adopted to ensure that States use a common analytical framework and to ensure an informed 

and equitable decision making process to ensure a transparent process that would, among other 

things, ensure that the public would be provided with the information necessary to understand 

the emission reductions needed, the costs of such measures, and other factors associated with 

improvements in visibility. 64 FR 35714 at 35733. The preamble to the RHR also makes clear 

that the URP does not establish a “safe harbor” for the state in setting its progress goals, 

providing that after considering the four statutory factors under 40 CFR 51.308(d)(1)(iii), states 

may adopt RPGs that provide for greater, equal, or less visibility improvement than that 

represented by the URP 64 FR 35714 at 35732. 

D. Best Available Retrofit Technology (BART) 

Section 169A of the CAA directs states to evaluate the use of retrofit controls at certain 

larger, often uncontrolled, older stationary sources with the potential to emit greater than 250 

tons per year (tpy) or more of any visibility impairing pollutant in order to address visibility 

impacts from these sources. Specifically, section 169A(b)(2)(A) of the Act requires states to 

revise their SIPs to contain such measures as may be necessary to make reasonable progress 

towards the natural visibility goal, including a requirement that certain categories of existing 

major stationary sources12 built between 1962 and 1977 procure, install, and operate the “Best 

Available Retrofit Technology”, as determined by the state or us in the case of a plan 

promulgated under section 110(c) of the CAA. Under the RHR, states are directed to conduct 

BART determinations for such “BART-eligible” sources that may be anticipated to cause or 

contribute to any visibility impairment in a Class I area. Rather than requiring source-specific 

BART controls, states also have the flexibility to adopt an emissions trading program or other 

alternative program as long as the alternative provides greater reasonable progress towards 

improving visibility than BART. 

We promulgated regulations addressing RH in 1999, 64 FR 35714 (July 1, 1999), 

codified at 40 CFR part 51, subpart P.13 These regulations require all states to submit 

implementation plans that, among other measures, contain either emission limits representing 

BART for certain sources constructed between 1962 and 1977, or alternative measures that 

provide for greater reasonable progress than BART. 40 CFR 51.308(e). 

On July 6, 2005, we published the Guidelines for BART Determinations Under the 

Regional Haze Rule at Appendix Y to 40 CFR Part 51 (“BART Guidelines”) to assist states in 

determining which of their sources should be subject to the BART requirements and in 

determining appropriate emission limits for each applicable source. 70 FR 39104. In making a 

BART determination for a fossil fuel-fired electric generating plant with a total generating 

capacity in excess of 750 megawatts (MW), a state must use the approach set forth in the BART 

 

12 The set of “major stationary sources” potentially subject to BART are listed in CAA section 169A(g)(7). 13 In American Corn Growers Ass’n v. EPA, 291 F.3d 1 (D.C. Cir. 2002), the U.S Court of Appeals for the District 

of Columbia Circuit issued a ruling vacating and remanding the BART provisions of the regional haze rule. In 

2005, we issued BART guidelines to address the court’s ruling in that case. See 70 FR 39104 (July 6, 2005). 

18 
Guidelines. A state is encouraged, but not required, to follow the BART Guidelines in making 

BART determinations for other types of sources; however, all subject to BART sources are 

required to comply with the five BART factors (or steps) (40 CFR 51.308(e)(1)(ii)(A)). 

The process of establishing BART emission limitations can be logically broken down into 

three steps: first, states identify those sources that meet the definition of “BART-eligible source” 

set forth in 40 CFR 51.301;14 second, states determine whether each identified source “emits 

any air pollutant which may reasonably be anticipated to cause or contribute to any impairment 

of visibility in any such area” (a source that fits this description is “subject to BART,”) and; 

third, for each source subject to BART, states then identify the appropriate type and the level of 

control for reducing emissions. 

States must address all visibility-impairing pollutants emitted by a source in the BART 

determination process. The most significant visibility impairing pollutants are SO2, NOX, and 

PM. We have stated that states should use their best judgment in determining whether VOC or 

ammonia compounds impair visibility in Class I areas. 

Under the BART Guidelines, states may select an exemption threshold value for their 

BART modeling, below which a BART-eligible source would not be expected to cause or 

contribute to visibility impairment in any Class I area. The state must document this exemption 

threshold value in the SIP and must state the basis for its selection of that value. States have 

three options for exempting a BART-eligible source from the BART requirements, including 

dispersion modeling demonstrating that the source cannot reasonably be anticipated to cause or 

contribute to visibility impairment in a Class I area, use of model plants to exempt sources with 

common characteristics, and cumulative modeling to show that no sources in Louisiana are 

subject to BART. Any source with emissions that model above the threshold value would be 

subject to a BART determination review. The BART Guidelines acknowledge varying 

circumstances affecting different Class I areas. States should consider the number of emission 

sources affecting the Class I areas at issue and the magnitude of the individual sources’ impacts. 

Any exemption threshold set by the state should not be higher than 0.5 dv. See also, 40 CFR part 

51, Appendix Y, section III.A.1. 

In their SIPs, states must identify potential BART sources, described as “BART-eligible 

sources” in the RHR, and document their BART control determination analyses. The term 

“BART-eligible source” used in the BART Guidelines means the collection of individual 

emission units at a facility that together comprises the BART-eligible source. In making BART 

determinations, section 169A(g)(2) of the CAA requires that states consider the following 

factors: (1) the costs of compliance; (2) the energy and non-air quality environmental impacts of 

compliance; (3) any existing pollution control technology in use at the source; (4) the remaining 

useful life of the source; and (5) the degree of improvement in visibility which may reasonably be 

anticipated to result from the use of such technology. States are free to determine the weight and 

significance to be assigned to each factor. See, 40 CFR 51.308(e)(1)(ii). 

A RH SIP must include source-specific BART emission limits and compliance schedules 

for each source subject to BART (See, CAA section 169A(b)(2), 40 CFR 51.308(e), and 64 FR 

35714, 35741). Once a state has made its BART determination, the BART controls must be 

installed and in operation as expeditiously as practicable, but no later than five years after the 

date of our approval of the RH SIP. CAA section 169(g)(4) and 40 CFR 51.308(e)(1)(iv). In 

 

14 BART-eligible sources are those sources that have the potential to emit 250 tons or more of a visibility-impairing 

air pollutant, were put in place between August 7, 1962 and August 7, 1977, and whose operations fall within 

one or more of 26 specifically listed source categories. 

19 
addition to what is required by the RHR, general SIP requirements mandate that the SIP must 

also include all regulatory requirements related to monitoring, recordkeeping, and reporting for 

the BART controls on the source. See, CAA section 110(a). 

As noted above, the RHR allows states to implement an alternative program in lieu of 

BART so long as the alternative program can be demonstrated to achieve greater reasonable 

progress toward the national visibility goal than would BART. Under regulations issued in 2005 

revising the RH program, the EPA made just such a demonstration for the CAIR. See, 70 FR 

39104 (July 6, 2005). The EPA’s regulations provide that states participating in the CAIR capand-trade program under 40 CFR part 96 pursuant to an EPA-approved CAIR SIP or which 

remain subject to the CAIR FIP in 40 CFR part 97 need not require affected BART-eligible 

EGUs to install, operate, and maintain BART for emissions of SO2 and NOX. See, 40 CFR 

51.308(e)(4). Because the CAIR did not address direct emissions of PM, states were still 

required to conduct a BART analysis for PM emissions from EGUs subject to BART for that 

pollutant. The CAIR required controls of both SO2 and NOX in Louisiana. Challenges to the 

CAIR, however, resulted in the remand of the rule to the EPA. See, North Carolina v. EPA, 550 

F.3d 1176 (D.C. Cir. 2008). The EPA issued the Transport Rule in 2011 to address the interstate 

transport of NOX and SO2 in the eastern United States. See, 76 FR 48208 (August 8, 2011). On 

December 30, 2011, the EPA proposed to find that the trading programs in the Transport Rule

would achieve greater reasonable progress towards the national goal than would BART in the 

states in which the Transport Rule applies. 76 FR 82219. Based on this proposed finding, the 

EPA also proposed to revise the RHR to allow states to substitute participation in the trading 

programs under the Transport Rule for source-specific BART. The transport rule requires 

control of NOX during the ozone season in Louisiana. It does not, however, require control of 

SO2. The EPA has not taken final action on that rule. 

Modeling Methodology 

The BART Guidelines provide that states may choose to use the CALPUFF15 modeling 

system or another appropriate model to predict the visibility impacts from a single source on a 

Class I area and to therefore, determine whether an individual source is anticipated to cause or 

contribute to impairment of visibility in Class I areas, i.e., “is subject to BART.” The Guidelines 

state that we believe CALPUFF is the best regulatory modeling application currently available 

for predicting a single source’s contribution to visibility impairment (70 FR 39162). The LDEQ 

used the CALPUFF modeling system to determine whether individual sources in Louisiana were 

subject to or exempt from BART. 

The BART Guidelines also recommend that states develop a modeling protocol for 

making individual source attributions, and suggest that states may want to consult with us and 

their RPO to address any issues prior to modeling. The CENRAP states, including Louisiana, 

developed the “CENRAP BART Modeling Guidelines.”16 Stakeholders, including the EPA, 

 

15 Note that our reference to CALPUFF encompasses the entire CALPUFF modeling system, which includes the 

CALMET, CALPUFF, and CALPOST models and other pre and post processors. The different versions of 

CALPUFF have corresponding versions of CALMET, CALPOST, etc. which may not be compatible with 

previous versions (e.g., the output from a newer version of CALMET may not be compatible with an older 

version of CALPUFF). The different versions of the CALPUFF modeling system are available from the model 

developer at http://www.src.com/verio/download/download.htm. 16 CENRAP BART Modeling Guidelines, T. W. Tesche, D. E. McNally, and G. J. Schewe (Alpine Geophysics 

LLC), December 15, 2005, available at 

http://www.deq.state.ok.us/aqdnew/RulesAndPlanning/Regional_Haze/SIP/Appendices/index.htm. 

20 
FLMs, industrial sources, trade groups, and other interested parties, actively participated in the 

development and review of the CENRAP protocol. The CENRAP provided readily available 

modeling databases for use by states to conduct their analyses. We note that the original 

meteorological databases generated by the CENRAP did not include observations as the EPA 

guidance recommends, therefore sources were evaluated using the 1st High values instead of the 

8th High values. The use of the 1st High modeling values was agreed to by the EPA, 

representatives of the FLMs, and the CENRAP stakeholders. 

E. Long-Term Strategy (LTS) 

Consistent with the requirement in section 169A(b) of the CAA that states include in their 

RH SIP a 10 to 15-year strategy for making reasonable progress, 40 CFR 51.308(d)(3) of the 

RHR requires that states include a LTS in their RH SIPs. The LTS is the compilation of all 

control measures a state will use during the implementation period of the specific SIP submittal 

to meet any applicable RPGs. The LTS must include “enforceable emissions limitations, 

compliance schedules, and other measures as necessary to achieve the reasonable progress 

goals” for all Class I areas within, or affected by emissions from, the state. 40 CFR 

51.308(d)(3). 

When a state’s emissions are reasonably anticipated to cause or contribute to visibility 

impairment in a Class I area located in another state, the RHR requires the impacted state to 

coordinate with the contributing states in order to develop coordinated emissions management 

strategies. 40 CFR 51.308(d)(3)(i). Also, a state with a Class I area impacted by emissions from 

another state must consult with such contributing state, (id.) and must also demonstrate that it 

has included in its SIP all measures necessary to obtain its share of emission reductions needed 

to meet the reasonable progress goals for the Class I area. Id. at (d)(3)(ii). The RPOs have 

provided forums for significant interstate consultation, but additional consultations between 

states may be required to sufficiently address interstate visibility issues. This is especially true 

where two states belong to different RPOs. 

States should consider all types of anthropogenic sources of visibility impairment in 

developing their LTS, including stationary, minor, mobile, and area sources. At a minimum, 

states must describe how each of the following seven factors listed below are taken into account 

in developing their LTS: (1) emission reductions due to ongoing air pollution control programs, 

including measures to address RAVI; (2) measures to mitigate the impacts of construction 

activities; (3) emissions limitations and schedules for compliance to achieve the RPG; (4) source 

retirement and replacement schedules; (5) smoke management techniques for agricultural and 

forestry management purposes including plans as currently exist within the state for these 

purposes; (6) enforceability of emissions limitations and control measures; and (7) the 

anticipated net effect on visibility due to projected changes in point, area, and mobile source 

emissions over the period addressed by the LTS. 40 CFR 51.308(d)(3)(v). 

F. Coordinating Regional Haze and Reasonably Attributable Visibility Impairment 

(RAVI)

As part of the RHR, we revised 40 CFR 51.306(c) regarding the LTS for RAVI to require 

that the RAVI plan must provide for a periodic review and SIP revision not less frequently than 

every three years until the date of submission of the state’s first plan addressing RH visibility 

impairment, which was due December 17, 2007, in accordance with 40 CFR 51.308(b) and (c). 

 

21 
On or before this date, the state must revise its plan to provide for review and revision of a 

coordinated LTS for addressing RAVI and RH, and the state must submit the first such 

coordinated LTS with its first RH SIP. Future coordinated LTS and periodic progress reports 

evaluating progress towards RPGs, must be submitted consistent with the schedule for SIP 

submission and periodic progress reports set forth in 40 CFR 51.308(f) and (g), respectively. 

The periodic review of a state’s LTS must report on both RH and RAVI and must be submitted to 

us as a SIP revision. 

G. Monitoring Strategy and Other SIP Requirements 

40 CFR 51.308(d)(4) of the RHR includes the requirement for a monitoring strategy for 

measuring, characterizing, and reporting of RH visibility impairment that is representative of all 

mandatory Class I Federal areas within the state. The strategy must be coordinated with the 

monitoring strategy required in 40 CFR 51.305 for RAVI. Compliance with this requirement may 

be met through “participation” in the IMPROVE network, i.e., review and use of monitoring 

data from the network. The monitoring strategy is due with the first RH SIP, and it must be 

reviewed every five years. The monitoring strategy must also provide for additional monitoring 

sites if the IMPROVE network is not sufficient to determine whether RPGs will be met. 

The SIP must provide for the following, pursuant to 40 CFR 51.308(d)(4)(i)-(vi): 

(i) The establishment of any additional monitoring sites or equipment needed to assess 

whether reasonable progress goals to address regional haze for all mandatory Class I 

Federal areas within Louisiana are being achieved. 

(ii) Procedures by which monitoring data and other information are used in determining the 

contribution of emissions from within Louisiana to regional haze visibility impairment at 

mandatory Class I Federal areas both within and outside the State. 

(iii)For a State with no mandatory Class I Federal areas, 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 mandatory Class I Federal areas 

in other States. 

(iv)The SIP must provide for the reporting of all visibility monitoring data to the 

Administrator at least annually for each mandatory Class I Federal area in the State. To 

the extent possible, Louisiana should report visibility monitoring data electronically. 

(v) A statewide inventory of emissions of pollutants that are reasonably anticipated to cause 

or contribute to visibility impairment in any mandatory Class I Federal area. The 

inventory must include emissions for a baseline year, emissions for the most recent year 

for which data are available, and estimates of future projected emissions. The State must 

also include a commitment to update the inventory periodically. 

(vi)Other elements, including reporting, recordkeeping, and other measures, necessary to 

assess and report on visibility. 

22 
The RHR requires control strategies to cover an initial implementation period extending 

to the year 2018, with a comprehensive reassessment and revision of those strategies, as 

appropriate, every 10 years thereafter. Periodic SIP revisions must meet the core requirements 

of 40 CFR 51.308(d) with the exception of BART. The requirement to evaluate sources for BART 

applies only to RH SIPs that address the first implementation period. See, 40 CFR 51.308(f). 

Facilities subject to BART must continue to comply with the BART provisions of 40 CFR 

51.308(e), as noted above. Periodic SIP revisions will assure that the statutory requirement of 

reasonable progress will continue to be met. 

H. Coordination with Federal Land Managers 

The RHR requires that states consult with FLMs before adopting and submitting their 

SIPs. 40 CFR 51.308(i). States must provide FLMs an opportunity for consultation, in person 

and at least 60 days prior to holding any public hearing on the SIP. This consultation must 

include the opportunity for the FLMs to discuss their assessment of impairment of visibility in 

any Class I area and to offer recommendations on the development of the RPGs and on the 

development and implementation of strategies to address visibility impairment. Further, a state 

must include in its SIP a description of how it addressed any comments provided by the FLMs. 

Finally, a SIP must provide procedures for continuing consultation between the state and FLMs 

regarding the state’s visibility protection program, including development and review of SIP 

revisions, five-year progress reports, and the implementation of other programs having the 

potential to contribute to impairment of visibility in Class I areas. 

The SIP must provide for the following, pursuant to 40 CFR 51.308(i)(1)-(4): 

(1) By November 29, 1999, Louisiana must identify in writing to the FLMs the title of the 

official to which the FLM of any mandatory Class I Federal area can submit any 

recommendations on the implementation of this subpart including, but not limited to: 

(i) Identification of impairment of visibility in any mandatory Class I Federal 

area(s); and 

(ii) Identification of elements for inclusion in the visibility monitoring strategy 

required by 40 CFR 51.305 and this section. 

(2) Louisiana must provide the Federal Land Manager with an opportunity for consultation, 

in person and at least 60 days prior to holding any public hearing on a SIP (or plan 

revision) for regional haze required by this subpart. This consultation must include the 

opportunity for the affected FLMs to discuss their: 

(i) Assessment of impairment of visibility in any mandatory Class I Federal area; 

and 

(i) Recommendations on the development of the reasonable progress goal and on 

the development and implementation of strategies to address visibility 

impairment. 

23 
(3) In developing any SIP (or plan revision), Louisiana must include a description of how it 

addressed any comments provided by the FLMs. 

(4) The SIP (or SIP revision) must provide procedures for continuing consultation between 

Louisiana and Federal Land Manager(s) on the implementation of the visibility protection 

program required by this subpart, 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 mandatory Class I Federal areas. 

I. Periodic SIP Revisions and Five-year Progress Reports

The SIP must provide for the following, pursuant to 40 CFR 51.308(f) and (g): 

40 CFR 51.308(f): Each state identified in 40 CFR 51. 300(b)(3), which includes Louisiana, 

must revise and submit its regional haze SIP revision to the EPA by July 31, 2018 and every 

ten years thereafter. In each SIP revision, Louisiana must evaluate and reassess all of the 

elements required in paragraph (d) of this section, taking into account improvements in 

monitoring data collection and analysis techniques, control technologies, and other relevant 

factors. In evaluating and reassessing these elements, Louisiana must address the following: 

(1) Current visibility conditions for the most impaired and least impaired days, and actual 

progress made towards natural conditions during the previous implementation period. 

The period for calculating current visibility conditions is the most recent five year period 

preceding the required date of the SIP submittal for which data are available. Current 

visibility conditions must be calculated based on the annual average level of visibility 

impairment for the most and least impaired days for each of these five years. Current 

visibility conditions are the average of these annual values. 

(2) The effectiveness of the long-term strategy for achieving reasonable progress goals over 

the prior implementation period(s); and 

(3) Affirmation of, or revision to, the reasonable progress goal in accordance with the 

procedures set forth in paragraph (d)(1) of this section. If Louisiana established a 

reasonable progress goal for the prior period which provided a slower rate of progress 

than that needed to attain natural conditions by the year 2064, it must evaluate and 

determine the reasonableness, based on the factors in paragraph (d)(1)(i)(A) of this 

section, of additional measures that could be adopted to achieve the degree of visibility 

improvement projected by the analysis contained in the first SIP described in paragraph 

(d)(1)(i)(B) of this section. 

40 CFR 51.308(g): Each state identified in 40 CFR 51. 300(b)(3), which includes Louisiana, 

must submit a report to the Administrator every 5 years evaluating progress towards the 

reasonable progress goal for each mandatory Class I Federal area located within it and in each 

mandatory Class I Federal area located outside it which may be affected by emissions from 

within it. The first progress report is due 5 years from submittal of the initial SIP addressing 

paragraphs (d) and (e) of this section. The progress reports must be in the form of SIP 

24 
revisions that comply with the procedural requirements of 40 CFR 51.102 and 40 CFR 

51.103. Periodic progress reports must contain at a minimum the following elements: 

(1) A description of the status of implementation of all measures included in the SIP for 

achieving reasonable progress goals for mandatory Class I Federal areas both within and 

outside of Louisiana. 

(2) A summary of the emissions reductions achieved throughout Louisiana through 

implementation of the measures described in paragraph (g)(1) of this section. 

(3) For each mandatory Class I Federal area within Louisiana, it must assess the following 

visibility conditions and changes, with values for most impaired and least impaired days 

expressed in terms of 5-year averages of these annual values. 

(i) The current visibility conditions for the most impaired and least impaired days; 

(ii) The difference between current visibility conditions for the most impaired and 

least impaired days and baseline visibility conditions; 

(iii)The change in visibility impairment for the most impaired and least impaired days 

over the past 5 years; 

(4) An analysis tracking the change over the past 5 years in emissions of pollutants 

contributing to visibility impairment from all sources and activities within Louisiana. 

Emissions changes should be identified by type of source or activity. The analysis must 

be based on the most recent updated emissions inventory, with estimates projected 

forward as necessary and appropriate, to account for emissions changes during the 

applicable 5-year period. 

(5) An assessment of any significant changes in anthropogenic emissions within or outside of 

Louisiana that have occurred over the past 5 years that have limited or impeded progress 

in reducing pollutant emissions and improving visibility. 

 

(6) An assessment of whether the current SIP elements and strategies are sufficient to enable 

Louisiana, or other States with mandatory Federal Class I areas affected by emissions 

from it, to meet all established reasonable progress goals. 

(7) A review of the Louisiana visibility monitoring strategy and any modifications to the 

strategy as necessary. 

J. Determination of Adequacy of Existing Implementation Plan 

The SIP must provide for the following, pursuant to 40 CFR 51.308(h): 

25 
 At the same time Louisiana is required to submit any 5-year progress report to us in 

accordance with paragraph (g) of this section, it must also take one of the following actions 

based upon the information presented in the progress report: 

(1) If Louisiana determines that the existing SIP requires no further substantive revision at 

this time in order to achieve established goals for visibility improvement and emissions 

reductions, it must provide to the Administrator a declaration that further revision of the 

existing SIP is not needed at this time. 

(2) If Louisiana determines that the SIP is or may be inadequate to ensure reasonable 

progress due to emissions from sources in another state(s) which participated in a 

regional planning process, then Louisiana must provide notification to the Administrator 

and to the other state(s) which participated in the regional planning process. Louisiana 

must also collaborate with the other state(s) through the regional planning process for the 

purpose of developing additional strategies to address the plan’s deficiencies. 

(3) Where Louisiana determines that the SIP is or may be inadequate to ensure reasonable 

progress due to emissions from sources in another country, it shall provide notification, 

along with available information, to the Administrator. 

(4) Where Louisiana determines that the SIP is or may be inadequate to ensure reasonable 

progress due to emissions from sources within the State, then Louisiana shall revise its 

SIP to address the plan’s deficiencies within one year. 

IV. Our Analysis of Louisiana’s Regional Haze SIP 

In evaluating the Louisiana RH SIP, we reviewed all the parts of the submittal, 

including the body of the SIP itself, and all appendices. In addition, we drew upon the 

following additional documents that may not have been specifically discussed in our TSD 

and/or the FR publication(s) of our decision: 

1. 40 CFR Part 51: Requirements for Preparation, Adoption, and Submittal of Implementation 

Plans. 

2. 40 CFR Part 51, Appendix V: Criteria for Determining the Completeness of Plan 

Submissions. 

3. The “BART Guidelines” in 40 CFR Part 51, Appendix Y: Guidelines for BART 

Determinations. 

 Under the Regional Haze Rule, 70 FR 39104, July 6, 2005. 

4. Guidance for Tracking Progress Under the Regional Haze Rule, EPA-454/B-03-004, 

 September, 2003. 

5. Guidance for Demonstrating Attainment of Air Quality Goals for PM2.5 and Regional Haze, 

 January 2, 2001. 

6. Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA- 

 454/B-03-005, September 2003. 

7. The “Baseline Memo,” which is entitled, “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.” 

26 
8. Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, dated 

 June 1, 2007. 

9. Visibility Monitoring Guidance, EPA-454/R-99-003, June 1999. 

10. 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. 

11. Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998. 

12. “Processing of State Implementation Plan (SIP) Submittals,” EPA Memorandum from John 

Calcagni, Director, Air Quality Management Division, OAQPS, to the Regional Air 

Directors, undated; released July 21, 1992. 

A. Identification of Affected Class I Areas 

As required by 40 CFR 51.308(d) of the RHR, the State of Louisiana has identified one 

Class I area within its borders, Breton National Wilderness Area (Breton NWA, or Breton). Part 

of a long chain of barrier islands, the area comprises a small part of the Breton National 

Wildlife Refuge located in the Breton Sound off the southeast coast of Louisiana. Breton NWA 

was identified by the LDEQ in its SIP. The FLM for Breton NWA is the U.S. Fish and Wildlife 

Service (USFWS) a bureau within the U.S. Department of Interior. The Louisiana RH SIP 

establishes RPGs for Breton and a LTS to achieve these goals within the first RH implementation 

period ending in 2018. 

In developing its SIP, the LDEQ also considered whether Louisiana emissions from 

Louisiana sources impact visibility at Class I areas outside of the state and determined that 

Louisiana emissions do not cause or contribute to visibility impairment at Class I areas outside 

the State. Class I areas outside of Louisiana that were considered by the LDEQ included the 

14,460 acre Caney Creek Wilderness Area in southwest Arkansas. In other parts of its SIP, the 

LDEQ does examine the impact of Louisiana’s emissions on the visibility at other Class I areas 

as well. 

We propose to find that the LDEQ correctly identified the Breton Class I area in 

Louisiana, and other Class I areas outside of its borders that may be impacted by emissions from 

Louisiana sources. 

The CENRAP regional modeling has shown that, at the present time, facilities in 

Louisiana have little impact on the worst visibility days in the Caney Creek Area.17 The FLM for 

the Caney Creek area in Arkansas is the U.S. Department of Agriculture (USDA) Forest Service. 

As discussed in section IV.C.3 of this TSD, the LDEQ consulted with state air quality agencies 

in surrounding states, including Arkansas, to determine what impact its emissions might have on 

the other states’ Class I areas. 

B. Determination of Baseline, Natural and Current Visibility Conditions 

As required by 40 CFR 51.308(d)(2)(i) of the RHR and in accordance with the EPA’s 

Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, 

 

17 LA RH SIP TSD, Appendix B Section 5.4.3.1: Technical Support Document for CENRAP Emissions, And Air 

Quality Modeling to Support Regional Haze, State Implementation Plans, Appendix E, CAMx PM Source 

Apportionment Technology (PSAT), Extinction (Mm-1) Contributions for the 2002 Worst and Best 20 Percent 

Days at CENRAP Class I Areas, Figure E-1: Caney Creek Wilderness Area (CACR), Arkansas. 

27 
(“Visibility Guidance”),18 the LDEQ calculated baseline/current19 and natural visibility 

conditions for Breton NWA on the most impaired and least impaired days, as summarized below. 

Note: 40 CFR 51.308(d)(2)(ii) is not applicable because this SIP was submitted after 2003, and 

40 CFR 51.308(d)(2)(iv)(B) is not applicable because this is the first SIP period. 

• Estimating Natural Visibility Conditions 

• Estimating Baseline Visibility Conditions 

• Natural Visibility Impairment 

• Uniform Rate of Progress 

1. Estimating Natural Visibility Conditions 40 CFR 51.308(d)(2)(iii) 

Natural background visibility, as defined in the Visibility Guidance, is estimated by 

calculating the expected light extinction using default estimates of natural concentrations of fine 

particle components adjusted by site-specific estimates of humidity. This calculation uses the 

IMPROVE equation, which is a formula for estimating light extinction from the estimated 

natural concentrations of fine particle components (or from components measured by the 

IMPROVE monitors). As documented in the Visibility Guidance, the EPA allows states to use 

“refined” or alternative approaches to the Visibility Guidance to estimate the values that 

characterize the natural visibility conditions of Class I areas. One alternative approach is to 

develop and justify the use of alternative estimates of natural concentrations of fine particle 

components. Another alternative is to use the “new IMPROVE equation” that was adopted for 

use by the IMPROVE Steering Committee in December 2005.20 The purpose of this refinement to 

the “old IMPROVE equation” is to provide more accurate estimates of the various factors that 

affect the calculation of light extinction. 

The LDEQ opted to use the new IMPROVE equation to calculate the “refined” natural 

visibility conditions. For Breton NWA, the LDEQ used the new IMPROVE equation to calculate 

the “refined” natural visibility value for the 20 percent worst days to be 11.93 deciviews and for 

the 20 percent best days to be 4.25 deciviews. We reviewed the LDEQ’s estimates of the natural 

visibility conditions for Breton NWA and are proposing to find them acceptable using the new 

IMPROVE equation. 

The new IMPROVE equation takes into account the most recent review of the science21

and it accounts for the effect of particle size distribution on light extinction efficiency of sulfate 

 

18 Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA-454/B-03-005, 

September 2003. 

19 As this is the first RH SIP submittal, the calculated baseline visibility condition and the current visibility 

condition will be the same. We expect that subsequent RH SIP submittals will reflect different calculated 

numbers for baseline and current visibility conditions due to the change in conditions. 20 The IMPROVE program is a cooperative measurement effort governed by a steering committee composed of 

representatives from Federal agencies (including the EPA and FLMs) and RPOs. The IMPROVE monitoring 

program was established in 1985 to aid the creation of Federal and State implementation plans for the protection 

of visibility in Class I areas. One of the objectives of IMPROVE is to identify chemical species and emission 

sources responsible for existing anthropogenic visibility impairment. The IMPROVE program has also been a 

key participant in visibility-related research, including the advancement of monitoring instrumentation, analysis 

techniques, visibility modeling, policy formulation and source attribution field studies. 21 The science behind the revised IMPROVE equation is discussed Chapter 5 and Appendix B of the LDEQ’s TSD 

for the Louisiana RH SIP and in numerous published papers. See for example: Hand, J.L., and Malm, W.C., 

2006, Review of the IMPROVE Equation for Estimating Ambient Light Extinction Coefficients - Final Report.

28 
(SO4), nitrate (NO3), and organic carbon. It also adjusts the mass multiplier for organic carbon 

(particulate organic matter) by increasing it from 1.4 to 1.8. New terms are added to the 

equation to account for light extinction by sea salt and light absorption by gaseous nitrogen 

dioxide. Site-specific values are used for Rayleigh scattering (scattering of light due to 

atmospheric gases) to account for the site-specific effects of elevation and temperature. Separate 

relative humidity enhancement factors are used for small and large size distributions of 

ammonium sulfate and ammonium nitrate and for sea salt. The terms for the remaining 

contributors, elemental carbon (light-absorbing carbon), fine soil, and coarse mass terms, do not 

change between the original and new IMPROVE equations. 

State Submittal: Chapter 5, and Appendices B and C 

 

Natural background visibility, as defined in the Visibility Guidance, is based on annual 

average concentrations of fine particle components. Natural background visibility for the 20% 

worst days is estimated by assuming that fine particle concentrations for natural background are 

normally distributed and the 90th percentile of the annual distribution represents natural 

background visibility on the 20% worst days (i.e., Method 1 prediction per the Visibility 

Guidance). 

 In the Visibility Guidance, we provided default estimates for the natural visibility 

conditions at almost all Class I areas. For Breton, the default natural visibility value for the 20% 

worst days is 11.53 dv and for the 20% best days is 3.85 dv (Visibility Guidance, page 60). 

 The Visibility Guidance also provided that states may use a “refined approach” to 

estimate the values that characterize the natural visibility conditions of the Class I areas. The 

purpose of such a refinement would be to provide more accurate estimates with changes to the 

extinction algorithm that may include the concentration values, factors to calculate extinction 

from a measured particular species and particle size, the extinction coefficients for certain 

compounds, geographical variation (by altitude) of a fixed value, and the addition of visibility 

pollutants. 

 As with the calculation of baseline conditions, the LDEQ’s choice of the new IMPROVE 

equation as the basis for its refined estimate is consistent with the EPA’s Guidance, which says 

“the same algorithm [old or new] should be used to calculate the glide path....”22 Because the 

LDEQ calculated the baseline conditions using the new IMPROVE algorithm, it is consistent 

that they also calculated the natural visibility conditions using the new IMPROVE algorithm. 

(“Guidance on the Use of Models and other Analyses for Demonstrating Attainment of Air 

Quality Goals for Ozone, PM2.5, and Regional Haze,” April, 2007). See Chapter 5 of the LA RH 

submittal, page 16. 

2. Estimating Baseline Visibility Conditions 40 CFR 51.308(d)(2)(i)

As required by 40 CFR 51.308(d)(2)(i) of the RHR and in accordance with the Visibility 

 

March 2006. Prepared for Interagency Monitoring of Protected Visual Environments (IMPROVE), Colorado 

State University, Cooperative Institute for Research in the Atmosphere, Fort Collins, Colorado, available at

http://vista.cira.colostate.edu/improve/publications/GrayLit/016_IMPROVEeqReview/IMPROVEeqReview.htm

and Pitchford, Marc., 2006, Natural Haze Levels II: Application of the New IMPROVE Algorithm to Natural 

Species Concentrations Estimates. Final Report of the Natural Haze Levels II Committee to the RPO 

Monitoring/Data Analysis Workgroup. September 2006, available at 

http://vista.cira.colostate.edu/improve/Publications/GrayLit/029_NaturalCondII/naturalhazelevelsIIreport.ppt. 22 The “glide path” is the uniform rate of progress needed to reach natural visibility conditions by 2064. 

29 
Guidance, the LDEQ calculated baseline visibility conditions for Breton NWA. The baseline 

condition calculation begins with the calculation of light extinction, using the IMPROVE 

equation. The IMPROVE equation sums the light extinction23 resulting from individual 

pollutants, such as sulfates and nitrates. As with the natural visibility conditions calculation, the 

LDEQ chose to use the new IMPROVE equation. 

The period for establishing baseline visibility conditions is 2000-2004, and baseline 

conditions must be calculated using available monitoring data. 40 CFR 51.308(d)(2). The Breton 

IMPROVE monitor did not meet the data capture requirements of the RHR for the 2000-2004 

monitoring period; however data from a nearby monitoring site, the Gulfport SEARCH site, was 

used to supplement the Breton monitoring data. We found the use of this data to be acceptable. 

The Breton monitor was subsequently destroyed in 2005 by Hurricane Katrina and since 

replaced and relocated. The LDEQ calculated the baseline conditions at the Breton Class I area 

as 25.73 deciviews on the 20 percent worst days, and 13.12 deciviews on the 20 percent best 

days. We have reviewed the LDEQ’s estimation of baseline visibility conditions at Breton and 

are proposing to find these estimates acceptable. 

State Submittal: Chapter 5, Appendices B and C 

Baseline conditions represent visibility for the best and worst days at the time the 

regional haze program is established. Baseline conditions are calculated using multiyear 

averaging of the 20 percent of monitored days with the highest (most impaired, or worst days) 

and the 20 percent of monitored days with the lowest (least impaired, or best days) light 

extinction values, expressed in deciviews, for the years 2000 through 2004. 

 The baseline is the starting point for this regional haze submittal, against which progress 

toward the national visibility goal is measured. As with the natural visibility conditions 

calculation, in calculating baseline conditions, the LDEQ chose to use the new IMPROVE 

equation. The choice between use of the previous or newer equation for calculating the visibility 

metrics for each Class I area is made by the state in which the Class I area is located. LDEQ has 

chosen to use the newer equation, referred to in the SIP as a “refined” approach, for calculating 

both the baseline and natural visibility conditions because it takes into account the most recent 

review of the science and because it is recommended by the IMPROVE Steering Committee. 

The primary source of monitoring information for this RH SIP was the Breton 

IMPROVE monitor. However the Breton data was incomplete and so data from the Gulfport 

SEARCH monitoring site was used as well. The method used by the LDEQ for data substitution 

for the Breton monitor is described below; additional information is also available in the LA RH 

SIP Appendix C, “Proposed Data Substitution Method for Breton.” 

The Breton monitor started operating in late 2000, and had one incomplete quarter in 

each of the years 2001, 2002, and 2003. (The Breton monitor was destroyed during Hurricane 

Katrina on August 28, 2005, and was ultimately replaced and relocated to a site near Lake 

Catherine in St. Bernard Parish, Louisiana). Because the data from the Breton IMPROVE 

monitor did not meet the EPA’s RHR data capture requirements for the five year averaging 

period 2000 – 2004, data from two relatively close monitoring sites, the Gulfport SEARCH site 

and the Sikes IMPROVE site, were considered as sources of additional monitoring data. A 

 

23 The amount of light lost as it travels over one million meters. The haze index, in units of deciviews (dv), is 

calculated directly from the total light extinction, bext expressed in inverse megameters (Mm-1), as follows: HI = 

10 ln(bext /10). 

30 
statistical analysis of the two proposed data sets was provided to the Visibility Improvement - 

States and Tribal Associations of the Southeast (VISTAS) RPO by Joe Adlhoch of Air Resource 

Specialists. The analysis demonstrated that the seasonal correlations of species mass 

comparisons were statistically more significant between Breton and Gulfport than Breton and 

Sikes. Gulfport was selected as the source for substitute data for the baseline period.24 As a 

consequence, the Louisiana RH SIP employs a combination of visibility data from both the 

Breton IMPROVE and Gulfport SEARCH sites for period 2001-2004. The resulting baseline 

conditions represent an average for 2001-2004. 

The LDEQ calculated the baseline by first summing the light extinction (where the 

extinction coefficient is expressed in Mm-1) for sulfate, nitrate, organic carbonaceous, elemental 

“light-absorbing” carbonaceous, fine soil, chlorine or chloride, and coarse matter, using the 

following equation: 

βext = βext S + βext NO3 + βext organic+ βext elemental+ βext Soil+ βext coarse+ βext Cl+ βext Rayleigh 

 The LDEQ then converted the total light extinction values to deciviews, using the Haze 

Index (HI) equation: 

HI (dv) = 10 ln[βext/(10 Mm -1)] 

 The LDEQ calculated the baseline conditions at Breton as 25.73 dv on the 20% worst 

days, and 13.12 dv on the 20% best days. 

3. Natural Visibility Impairment 40 CFR 51.308(d)(2)(iv)(A)

To address 40 CFR 51.308(d)(2)(iv)(A), the LDEQ also calculated the number of 

deciviews by which baseline conditions exceed natural visibility conditions for the best and worst 

days at Breton NWA. For the 20 percent worst days, the LDEQ calculated the number of 

deciviews by which baseline conditions exceed natural visibility conditions to be 13.80 dv 

(baseline of 25.73 dv, minus natural conditions of 11.93 dv). For the 20 percent best days at 

Breton, the baseline conditions exceed natural visibility conditions by 8.87 dv (baseline of 13.12 

dv, minus natural conditions of 4.25 dv). We have reviewed the LDEQ’s estimates of the natural 

visibility impairment at Breton NWA and are proposing to find these estimates acceptable. 

State Submittal: Chapter 8, including Figure 8.2 

Consistent with the graph displayed in Figure 8.2 of the LA RH SIP submittal, the 

number of deciviews by which baseline conditions exceed natural visibility conditions at Breton 

for the most impaired (20% worst) days is 13.80 dv (25.73 – 11.93). Similarly (but not shown in 

the figure), baseline conditions exceed natural visibility conditions for the least impaired (20% 

best) days by 8.87 dv (13.12– 4.25) at Breton. The amount of visibility impairment can be 

calculated by subtracting the natural visibility condition values from the baseline values. 

4. Uniform Rate of Progress 40 CFR 51.308(d)(1)(i)(B) 

In setting the RPGs, the LDEQ analyzed and determined the URP needed to reach 

 

24 The data substitution method for Breton, including results of the statistical analysis performed by VISTAS are 

included in Appendix C of the LA RH SIP submittal, June 13, 2008. 

31 
natural visibility conditions by the year 2064. In so doing, the LDEQ compared the baseline 

visibility conditions to the natural visibility conditions in Breton NWA and determined the URP 

needed in order to attain natural visibility conditions by 2064. The LDEQ constructed the URP 

consistent with the requirements of the RHR and our 2003 Tracking Progress Guidance by 

plotting a straight graphical line from the baseline level of visibility impairment for 2000-2004 

to the level of visibility conditions representing no anthropogenic impairment in 2064 for Breton 

NWA. 

Using a baseline visibility value of 25.73 dv and a “refined” natural visibility value of 

11.93 dv for the 20 percent worst days for Breton, the LDEQ calculated the URP to be 

approximately 0.23 dv per year. This results in a total reduction of 13.80 dv that are necessary to 

reach the natural visibility condition of 11.93 dv in 2064 for Breton NWA. The URP results in a 

visibility improvement of 3.22 dv for Breton for the period covered by this SIP revision submittal 

(up to and including 2018). 

Table 1. Summary of Uniform Rate of Progress 

Visibility Metric Breton NWA 

Baseline Conditions 25.73 dv 

Natural Visibility 11.93 dv 

Total Improvement by 2064 13.80 dv 

Improvement for this SIP by 2018 3.22 dv* 

Uniform Rate of Progress 0.23 dv/yr* 

 We are proposing to find that the LDEQ has appropriately calculated the URP and has 

satisfied the requirement in 40 CFR 51.308(d)(1)(i)(B). 

State Submittal: Chapter 10, including section 10-2 and Figure 10.1 

In Table I above, the values with an asterisk are consistent with the glide path shown in 

LA RH SIP Figure 10.1. 

See Sections III.B.1 – B.2 of this TSD for a discussion on the LDEQ’s calculations of 

baseline and natural visibility conditions. As discussed above, the LDEQ calculated the URP to 

be 3.22 dv improvement necessary by 2018, and an overall URP of 0.23 dv/year (13.80/60), as 

depicted in Table 1. The LA RH SIP Figure 10.1 shows a comparison of the URP, RPG, and the 

anticipated improvement in visibility for the Breton Class I area. The calculations made to 

achieve these results: 25.73 – 11.93 = 13.80. 2064 – 2004 = 60 years. 13.80/60 = 0.23 dv per 

year. 2018-2004 = 14 years. Thus, 14 x 0.23 = 3.22 dv = visibility improvement by 2018. 

 

32 
C. Evaluation of Louisiana’s Reasonable Progress Goals 40 CFR 51.308(d)(1)(ii)-(iii)

We are proposing to find that Louisiana’s RPGs meet some federal requirements, but 

also contain some deficiencies. This section discusses three RPG requirements as they relate to 

the LA RH SIP: 1) establishment of the RPG; 2) reasonable progress four factor analysis; and 3) 

reasonable progress consultation. See the TSD for a more detailed discussion of RPG 

requirements and the LA RH SIP for RPGs. The establishment of RPGs and the reasonable 

progress four factor analysis for Louisiana are linked to the EPA’s CAIR and the Transport 

Rule. As discussed in the Executive Summary above, in an earlier proposed action the EPA 

proposed a limited disapproval of the LA RH SIP (76 FR 82219). As discussed in that proposal, 

a number of states, including Louisiana, fully consistent with the EPA’s regulations at the time, 

relied on the trading programs of the CAIR to satisfy the BART requirement and the requirement 

for a long-term strategy sufficient to achieve the state-adopted reasonable progress goals. 

Louisiana also relied on the CAIR in assessing the need for emissions reductions from EGUs to 

ensure reasonable progress. As a result, Louisiana will have to consider whether EGUs 

previously covered by the CAIR, whether subject to BART or not, should be controlled to ensure 

reasonable progress.25 

 We are proposing to find that the State’s RPGs are deficient given our proposed 

finding, discussed in section IV.D. below, that certain of Louisiana’s BART determinations are 

not fully approvable. In general, the State followed the requirements of 40 CFR 51.308(d)(1), 

but these goals do not reflect appropriate emissions reductions from BART. 

Establishment of the Reasonable Progress Goals 

The LDEQ adopted the CENRAP modeled 2018 visibility conditions as the RPGs for 

Breton NWA Class I area. The LDEQ established a RPG of 22.51 dv for Breton for 2018 for the 

20% worst days. This represents a 3.22 dv improvement over a baseline of 25.73 dv. 

 The CENRAP’s projections for 2018 for the 20% worst and best days for Breton, which 

Louisiana used in developing its RPGs for Breton, are shown in the LA RH SIP Appendix B 

titled, “Technical Support Document for CENRAP Emissions and Air Quality Modeling to 

Support Regional Haze State Implementation Plans.”26 A comparison of the LDEQ’s predicted 

rate of progress to the glide path on the 20% worst days shows that, with projected control of 

Louisiana sources, Louisiana will be very close to the glide path throughout the first planning 

period.27 The CENRAP modeling shows that for the 20% best days, there would be a 0.90 dv 

improvement in visibility from the baseline for Breton. See, 40 CFR 51.308(d)(1). 

Table 2 shows a comparison of RPGs to URPs on most impaired days at Breton. 

 

 

25 Because the Transport Rule will result in greater emission reductions overall than the CAIR, the EPA did not 

include the RPGs set by affected states in its December 30, 2011 limited disapproval (Transport Better than 

BART proposal, December 30, 2011, 76 FR 82219). 26 The TSD for CENRAP Emissions and Air Quality Modeling to Support RH State Implementation is found in 

Appendix B of the Louisiana RH SIP. 27 See the LA RH SIP submittal, Chapter 8, Section 8.5, Figure 8.2. 

33 
Table 2. Comparison of Reasonable Progress Goals to Uniform Rate of Progress 

on Most Impaired Days for Louisiana Class I areas

Louisiana 

Class I 

Area 

Visibility Conditions on 20% Worst Days (dv) 

Average for 20% 

Worst Days 

(Baseline 2000-

2004)

2018 URP 

Goal RPG 

Deciview Improvement 

Projected by 2018 using 

RPG (dv) 

Breton 25.73 22.51 22.72 3.01 

The CENRAP’s projections for 2018 for the 20% best days for Breton, which represent 

the LDEQ’s RPGs for the 20% best days, are shown in Appendix D within LA RH SIP 

Appendix B: “CENRAP Emissions and Air Quality Modeling to Support RH State 

Implementation.” The LDEQ’s RPGs for the 20% best days (CENRAP projection) are shown in 

Table 3, which is adapted from Figure D-3b of Appendix D within LA RH SIP Appendix B. 

Table 3. Comparison of Reasonable Progress Goals to Baseline Conditions on Least 

Impaired Days for Louisiana Class I areas

Louisiana 

Class I Area 

Visibility Conditions on 20% Best Days (dv) 

Achieved “No 

Degradation” 

(Y/N) Average for 20% Best Days 

(Baseline 2000-2004) 

RPG 

(CENRAP Projection)

Breton 13.12 12.22 Yes 

LDEQ’s Reasonable Progress “Four Factor” Analysis 40 CFR 51.308(d)(1)(i)(A)

In establishing RPGs for a Class I area, the State is required by CAA §169A(g)(1) and 40 

CFR 51.308(d)(1)(i)(A) to “[c]onsider 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.” In addition to this explicit 

statutory requirement, the RHR also establishes an analytical requirement to ensure that each 

state considers carefully the suite of emission reduction measures necessary to attain the URP. 

The RHR provides that the EPA will consider both the state’s consideration of the four factors in 

40 CFR 51.308(d)(1)(i)(A) and its analysis of the URP “[i]n determining whether the State’s 

goal for visibility improvement provides for reasonable progress.” 40 CFR 51.308(d)(1)(iii). As 

explained in the preamble to the RHR, the URP analysis was adopted to ensure that states use a 

common analytical framework and to ensure an informed and equitable decision making process 

to ensure a transparent process that would, among other things, ensure that the public would be 

34 
provided with the information necessary to understand the emission reductions needed, the costs 

of such measures, and other factors associated with improvements in visibility. 64 FR at 35733. 

 In establishing its RPGs for 2018 for the 20% worst days, the LDEQ relied on the 

improvements in visibility that were anticipated to result from federal, State, and local control 

programs that were either currently in effect or with mandated future-year emission reduction 

schedules that predate 2018, including BART emission limitations projected by the LDEQ. Based 

on the emissions reductions from these measures, the CENRAP modeled the projected visibility 

conditions anticipated at each Class I area in the region in 2018, and the LDEQ used these 

results to establish RPGs. 

States do have discretion in setting RPGs, but are required to do more than establish 

RPGs that meet or exceed the URP. The LDEQ did provide an analysis that considered the four 

statutory factors under 40 CFR 51.308(d)(1)(i)(A) to evaluate the potential of controlling certain 

sources or source categories for addressing visibility impacts from man-made sources within its 

borders. 

 The LDEQ provides an analysis in Appendix H, CENRAP Regional Control Strategy 

Analysis Plan, showing that the URP goals are reasonable. In addition, the LDEQ provided a 

discussion of the four factors required for this analysis: costs of compliance, time for 

compliance, energy and non-air quality environmental impacts of compliance, and remaining 

useful life of any potentially affected sources in Chapter 10 of the RH SIP. 

In identifying and prioritizing potential regional haze control strategies, the LDEQ 

referenced the Alpine Geophysics report for the CENRAP. Table 7-4 of this report outlines 

potential facilities that could be considered when developing a subregional SO2 control strategy 

with the associated approximate costs (see the LA RH SIP Appendix H). TSD Table 4 shows the 

facilities in Louisiana identified in the Alpine Report that potentially significantly impact 

visibility at Breton for which controls may be available. The LDEQ found that significant 

reductions would be achieved from consent decrees and the CAIR, and further examined the 

sources in Louisiana identified in the Alpine report for potential reductions. More information 

about the state’s discussion is available in section IV.C of the TSD and in the LA RH SIP 

submittal. 

Table 4 below shows the facilities in Louisiana identified in the Alpine Report that 

potentially significantly impact visibility at Breton for which controls may be available. 

35 
Table 4. Alpine Geophysics Subregional Control Strategy for Breton Island 

Louisiana Plants

BART source category Facility name Parish 

Fossil fuel-fired steam 

electric plant 

Louisiana Generating 

LLC, Big Cajun 2 

Power Plant 

Pointe Coupee 

Petroleum Refinery 

Marathon Ashland 

Petroleum 

LLC-LA Refining 

St. John the Baptist 

ExxonMobil Refining 

& Supply Co., 

ExxonMobil Baton 

Rouge Refinery 

East Baton Rouge 

PCS Nitrogen, 

Geismar Plant – 

Ammonia Group 

Ascension 

Chemical Process Cytec Industries, Inc., 

Fortier Plant Jefferson 

Sulfuric Acid 

Rhodia, Inc., Baton 

Rouge Facility East Baton Rouge 

E.I. du Pont de 

Nemours & Co., Inc., 

Burnside Plant 

Ascension 

The LDEQ considered these sources in Chapter 10 of its RH SIP submittal. Additionally, the 

Alpine Report includes several facilities in the control strategy for Breton Island which are 

located in states other than Louisiana. These are listed in Table 5 below. 

36 
Table 5. Alpine Geophysics Subregional Control Strategy for Breton Island

Plants in Alabama, Mississippi, and Florida

BART source category Facility name County and State 

Fossil fuel-fired steam 

electric plant 

Gulf Power Company 

Crist Electric Generating

Escambia, 

Florida 

Alabama Power 

Company – Barry 

Mobile, 

Alabama 

Petroleum refinery 

Chevron Products 

Company, Pascagoula 

Ref 

Jackson, 

Mississippi 

ExxonMobil Production 

Co. 

Santa Rosa, 

Florida 

Chemical process Akzo Nobel Chemicals 

Inc. 

Mobile, 

Alabama 

Kraft pulp mills International Paper 

Company 

Dallas, 

Alabama 

As discussed above, Louisiana will have to consider whether EGUs previously covered by the 

CAIR, whether subject to BART or not, should be controlled to ensure reasonable progress. 

Also, LDEQ must ensure it has adequately satisfied the RPG requirements to conduct a four 

factor analysis for sources that cause or contribute to visibility impacts at Breton. 

Reasonable Progress Consultation 40 CFR 51.308(d)(1)(iv) 

The LDEQ worked with the VISTAS and the CENRAP states to jointly develop the 

consultation strategy. The LDEQ used the CENRAP as the main vehicle for facilitating 

collaboration with FLMs and other states in developing its RH SIP. The LDEQ was able to use 

the CENRAP generated products, such as regional photochemical modeling results and visibility 

projections, and source apportionment modeling to assist in identifying neighboring states’ 

contributions to the visibility impairment at Breton NWA. 

The LDEQ determined that in addition to Louisiana, the following states make a 

contribution to decreased visibility in Louisiana’s Class I area: Mississippi, Alabama, and 

Florida (see Table 5 above). The LDEQ conducted consultations in the form of face-to-face 

meetings and conference calls. Participants in the consultation process included states and 

tribes, the CENRAP and other RPOs, the EPA, and FLMs. The participating states determined 

that regional modeling and other findings based on existing and proposed controls arising from 

local, state, and federal requirements indicated that the Class I area in Louisiana is expected to 

meet the rate of progress goals for the first implementation period ending in 2018. The LDEQ 

determined that additional emissions reductions from other states were not necessary to address 

37 
visibility impairment at Breton for the first implementation period ending in 2018, and all states 

participating in its consultations agreed with this. 

State Submittal: Chapter 10 (pages 61-62) and Appendix I 

 The LDEQ participated in consultations with Alabama, Florida, and Mississippi, in faceto-face meetings on January 23, 2007 in Point Clear AL, and by conference call on October 30, 

2007. Louisiana also participated in discussions focused on Class I areas in Oklahoma including 

the Wichita Mountains Wilderness Area, and with Arkansas, Missouri, and Texas (p. 64 of the 

LA RH SIP). 

Reasonable Progress Goal To Be Considered by Administrator: 40 CFR 51.308(d)(1)(v) 

 Pursuant to 40 CFR 51.308(d)(1)(v), “The reasonable progress goals established by the 

State are not directly enforceable but will be considered by the Administrator in evaluating the 

adequacy of the measures in the SIP to achieve the progress goal adopted by the State,” refers to 

our review of RH SIPs. Because it does not require a response from the state, it is not separately 

evaluated here. We find that this requirement is not applicable to the LA RH SIP at this time. 

This provision will be reconsidered upon receipt of submittals from the LDEQ for subsequent 

implementation periods.

Reasonable Progress Goal Minimum: 40 CFR 51.308(d)(1)(vi) 

 Louisiana may not adopt a reasonable progress goal that represents less visibility 

improvement than is expected to result from implementation of other requirements of the CAA 

during the applicable planning period. We find that Louisiana meets this requirement. The RPGs 

established by Louisiana are based on the CENRAP 2018 modeling projections. The modeling 

projections conducted by the CENRAP contain projections of the visibility conditions that are 

anticipated to be realized at each Class I area between the 2002 base year and the 2018 future 

year. These projections are based on an assessment of the visibility improvements associated 

with local, State, and federal control programs that are either currently in effect or with mandated 

future-year. However, as we discuss elsewhere, these modeling projections assume SO2 BART 

reductions under the CAIR. Therefore, we propose to find that Louisiana has not satisfied 40 

CFR 51.308(d)(1)(vi). 

 

State Submittal: Chapter 10 and Appendix I 

 The RPGs established by Louisiana are based on the CENRAP 2018 modeling 

projections. The modeling projections conducted by the CENRAP contain projections of the 

visibility conditions that are anticipated to be realized at each Class I area between the 2004 base 

year and the 2018 future year. These projections are based on an assessment of the visibility 

improvements associated with local, State, and federal control programs that are either currently 

in effect or with mandated future-year emission reduction schedules, as well as on the BART 

emission limitations established to date. 

Reasonable Progress Goals with Rate of Improvement Slower than Needed to Attain 

Natural Visibility Conditions by 2064. 

38 
For the period of the SIP, if Louisiana establishes a reasonable progress goal that 

provides for a slower rate of improvement in visibility than the rate that would be needed to 

attain natural conditions by 2064, it must demonstrate, based on the factors in 40 CFR 

51.308(d)(1)(i)(A), that the rate of progress for the SIP to attain natural conditions by 2064 is not 

reasonable; and that the progress goal adopted by it is reasonable, as indicated in 40 CFR 

51.308(d)(1)(ii). We note that Louisiana’s RPG is slightly slower than the URP. As we discuss 

above, Louisiana’s RPG relies on the CAIR, and as a result, Louisiana will have to reconsider 

whether reductions of SO2 from EGUs, whether subject to BART or not, are appropriate for 

ensuring reasonable progress and evaluate whether the reconsidered RPGs meet the rate of 

improvement needed to attain natural visibility conditions by 2064. Therefore we find that the 

LA RH SIP has not satisfied 40 CFR 51.308(d)(1)(ii). 

D. Evaluation of Louisiana’s BART Analyses 40 CFR 51.308(e) 

BART is an element of Louisiana’s LTS for the first implementation period. As discussed 

in more detail below and in section III.D of the proposal, the BART evaluation process consists 

of three components: (1) an identification of all the BART-eligible sources; (2) an assessment of 

whether those BART-eligible sources are subject to BART; and (3) a determination of any BART 

controls. The LDEQ addressed these steps as follows: 

Louisiana must 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 mandatory Class I 

Federal area, unless it demonstrates that an emissions trading program or other alternative will 

achieve greater reasonable progress toward natural visibility conditions. 

Note: The evaluation of whether the RH SIP contains “adequate 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 mandatory Class I Federal area” is conducted within each BART 

 evaluation. 

40 CFR 51.308(e)(2) – (3) addresses the use of a trading program or other alternative to BART 

and is applicable to this SIP, because Louisiana relies on the CAIR, to satisfy its BART 

requirements for NOX and SO2 for EGUs. 

1. Identification of BART-Eligible Sources 40 CFR 51.308(e)(1)(i)

An initial step of a BART evaluation is to identify all the BART-eligible sources within the 

state’s boundaries. The LDEQ identified the BART-eligible sources in Louisiana by utilizing the 

three eligibility criteria in the BART Guidelines (70 FR 39158) and our regulations (40 CFR 

51.301): (1) one or more emission units at the facility fit within one of the 26 categories listed in 

the BART Guidelines; (2) the emission unit(s) began operation on or after August 6, 1962, and 

was in existence on August 6, 1977; and (3) potential emissions of any visibility-impairing 

pollutant from subject units are 250 tpy or more. 

The LDEQ determined that the visibility-impairing pollutants in Louisiana include SO2, 

NOX, and PM, using PM less than 10 microns in diameter (PM10) as an indicator for PM (LA RH 

SIP, Chapter 9, p. 36). This is consistent with the RHR (40 CFR 51 Appendix Y, III.A.2). 

39 
The LDEQ sent a letter and survey form, together with guidance materials, requesting 

information about BART eligibility to every reporter (1167 facilities) to the emissions inventory 

for the state requesting information about BART eligibility. Of the 1167 facilities contacted, 

1165 facilities responded, and reported 76 BART-eligible facilities. Of the two non-responders, 

one was found to be out of business, and the other was determined to have minor emissions. See 

the TSD for more information. Each of the 76 BART-eligible facilities is identified in Table 6 

below. We agree with the LDEQ’s identification of BART-eligible sources. 

State Submittal: Chapter 9: Best Available Retrofit Technology (BART), and Appendix F 

 LDEQ identified sources as BART-eligible if they: 

1. Belonged to one of the twenty-six BART categories listed below; 

2. Did not operate before August 7, 1962, but were in existence on August 7, 1977; and 

3. Had the potential to emit 250 tpy or more of any visibility-impairing pollutant. 

The LDEQ determined that ammonia and VOCs are not significant contributors to 

visibility impairment for the following reasons: Ammonia emissions in Louisiana are primarily 

due to area sources, which are not subject to BART. Ammonia emissions are addressed through 

the Louisiana Toxic Air Pollutant Emission Control Program LAC 33:III.Chapter 51 and 

controls have been implemented to lower ammonia emissions statewide. Ammonia emissions 

identified from BART-eligible sources are 0.21 % of the total ammonia emissions in the state. 

The emissions inventory prepared for the CENRAP modeling demonstrates that ammonia from 

point sources is not a significant visibility-impairing pollutant in Louisiana. The CENRAP 

modeling also demonstrated that VOCs from anthropogenic sources are not significant visibilityimpairing pollutants at Breton NWA. VOC emissions are currently being addressed by the state 

in LAC 33:III.Chapter 21, Control of Emission of Organic Compounds. These rules were 

promulgated as a control measure for an ozone nonattainment area and are applicable state-wide 

at various levels and are considered by the state to be Reasonable Available Control Technology 

(cite where this was approved into the LA SIP). BART emissions of VOC are 0.04% of the total 

visibility impairment at Breton. 

 Louisiana decided to eliminate VOCs and ammonia from among the visibility-impairing 

pollutants for several reasons, including that “an overwhelming majority of light extinction due 

to SO4 is caused by SO2 emissions (see the LA RH SIP, Chapter 9, p. 36 for additional 

information). The RHR directs states to exercise judgment in deciding whether VOCs and NH3

impair visibility in their 22 Class I area(s). 70 FR 39104, at 39160. As discussed above in section 

V.C.3, the CENRAP performed modeling sensitivity analyses and/or other analyses, which 

demonstrated that anthropogenic emissions of VOC and NH3 do not significantly impair 

visibility in the CENRAP region. Therefore, Louisiana did not consider ammonia or VOCs 

among visibility-impairing pollutants and did not further evaluate NH3 and VOC emissions 

sources for potential controls under BART or reasonable progress. 

 On November 4, 2002, LDEQ sent a letter and survey form, together with guidance 

materials, to every reporter (1167 facilities) to the emissions inventory for the state requesting 

information about BART eligibility by December 6, 2002. This survey is included in Appendix F 

of the LA RH SIP. Appendix E of the Louisiana RH submittal provides the survey results, as 

well as a detailed description of each BART-eligible emission unit. 

40 
Each of the 76 identified facilities fell in one or more of the 26 BART categories: 

1. Fossil-fuel fired steam electric plants of more than 250 million British thermal units 

(BTU) per hour heat input, 

2. Coal cleaning plants (thermal dryers), 

3. Kraft pulp mills, 

4. Portland cement plants, 

5. Primary zinc smelters, 

6. Iron and steel mill plants, 

7. Primary aluminum ore reduction plants, 

8. Primary copper smelters, 

9. Municipal incinerators capable of charging more than 250 tons of refuse per day, 

10. Hydrofluoric, sulfuric, and nitric acid plants, 

11. Petroleum refineries, 

12. Lime plants, 

13. Phosphate rock processing plants, 

14. Coke oven batteries, 

15. Sulfur recovery plants, 

16. Carbon black plants (furnace process), 

17. Primary lead smelters, 

18. Fuel conversion plants, 

19. Sintering plants, 

20. Secondary metal production facilities, 

21. Chemical process plants, 

22. Fossil-fuel boilers of more than 250 million BTUs per hour heat input, 

23. Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, 

24. Taconite ore processing facilities, 

25. Glass fiber processing plants, and 

26. Charcoal production facilities. 

Also, these identified units had potential emissions of 250 tpy or more for one or more 

visibility-impairing pollutant, were in existence on August 7, 1977 and began operation after 

August 7, 1962. These emissions units comprise the “BART-eligible sources” listed in Table 6, 

as adapted from Appendix E of the Louisiana RH SIP: 

Table 6. Facilities with BART-eligible units in Louisiana (76)28

BART 

source 

category

Facility name Parish

Unit Description 

Fossil fuelfired steam 

electric plants 

Cleco Power LLC., 

Rodemacher Power Station Rapides Unit 1 boiler 

 

28 The LDEQ RH SIP submittal has “77” in its Table title; however, only 76 sources are listed. 

41 
of more than 

250 

MMBTU/hr 

heat input

Entergy Louisiana, 

Sterlington Ouachita Unit 7 boiler 

City of Ruston, Ruston 

Electrical Generation Station Lincoln Boilers 1, 2, and 3 

City of Natchitoches Utility 

Dept. Natchitoches 3 boilers 

Louisiana Generating 

LLC, Big Cajun 2 Power Plant Pointe Coupee Units 1, 2, and 3 

Entergy New Orleans, 

Michoud Orleans Units 2 and 3 

Entergy Louisiana, 

Waterford St. Charles Units 1 and 2 

Entergy Gulf States, 

Willow Glen Iberville Units 2, 3, 4, and 5 boilers 

Louisiana Energy & 

Power Authority, 

Morgan City Steam Plant 

St. Mary, 

St. Martin Units 1, 2, 3, and 4 boilers 

Entergy Louisiana, 

Ninemile Point Jefferson Units 4 and 5 boilers 

Entergy Gulf States, 

Nelson Calcasieu # 4 boiler 

Fossil fuelfired steam 

electric plants 

of more than 

250 

MMBTU/hr 

heat input 

(continued) 

Cleco Power LLC., 

Teche Power Station St. Mary Unit 3 boiler 

Louisiana Energy and 

Power Authority, Plaquemine 

Steam 

Plant 

Iberville Boilers 1 and 2 

Entergy Louisiana, Little 

Gypsy St. Charles Units 2 and 3 

Louisiana Generating 

LLC, Big Cajun 1 

Power Plant 

Pointe Coupee Units 1 and 2 

42 
Lafayette Utilities 

System, Louis "Doc" 

Bonin Electric 

Generation Station 

Lafayette Units 1, 2 and 3 

Terrebonne Parish 

Consolidated 

Government, Houma 

Generating Station 

Terrebonne Units 15 and 16 boilers 

Monochem, Inc., 

Geismar Facility Ascension #1, 2, and 3 boiler stacks 

Secondary 

metal 

production

Exide Technologies, 

Baton Rouge Smelter 

East Baton 

Rouge 

Various emission points in 

facility 

Kraft pulp 

mills 

Graphics Packaging 

International, 

West Monroe Mill 

Ouachita Various emission points in 

facility 

Smurfit-Stone 

Container Enterprise, Inc. Jackson Various emission points in facility 

International Paper 

Company, Bastrop - 

Louisiana Mill 

Morehouse Various emission points in 

facility 

International Paper, 

Pineville Mill Rapides Various emission points in facility 

Kraft pulp 

mills 

(continued)

Boise Cascade, 

DeRidder Paper Mill Beauregard Recovery furnace, bark boiler #1, and lime kiln 

Weyerhaeuser 

Company, Red River 

Mill 

Natchitoches Various emission points in 

facility 

Temple Inland, 

Bogalusa Mill Washington Lime kiln, #12 hogged fuel boiler 

Georgia Pacific, Port 

Hudson Operations 

East Baton 

Rouge 

Various emission points in 

facility 

43 
Tembec USA LLC, St. 

Francisville Mill West Feliciana Various emission points in facility 

Petroleum 

Refinery 

ConocoPhillips Co., 

Alliance Refinery Plaquemines Various emission points in facility 

Marathon Petroleum 

Company, LLC-LA 

Refining Division, 

Garyville Refinery 

St. John the 

Baptist 

Various emission points and 

storage vessels in facility 

Murphy Oil USA, Inc., 

Meraux Refinery St. Bernard Various emission points in facility 

Valero Refining-New 

Orleans, LLC, St. 

Charles Refinery 

St. Charles 

Hydrotreater heater, FCC 

unit, flare #1, and sulfur 

recovery unit 

ExxonMobil Refining 

& Supply Co., 

ExxonMobil Baton 

Rouge Refinery 

East Baton 

Rouge 

Various emission points in 

facility 

Chalmette Refining, 

L.L.C., Chalmette Refinery Orleans Various emission points and storage vessels in facility 

Petroleum 

Refinery 

(continued) 

Placid Refining 

Company, L.L.C., 

Port Allen Refinery 

West Baton 

Rouge 

Various emission points and 

storage vessels in facility 

Motiva Enterprises 

LLC, Norco Refinery St. Charles Various emission points in facility 

CITGO Petroleum, 

Lake Charles 

Manufacturing Complex 

Calcasieu Various emission points in 

facility 

Motiva Enterprises, 

LLC, Convent 

Refinery 

St. James Various emission points in 

facility 

CITGO Petroleum 

Corporation, Clifton 

Ridge Terminal 

Calcasieu Various storage vessels 

44 
CITGO Petroleum 

Corporation, Pecan 

Grove Tank 

Calcasieu Various storage vessels and 

fugitives 

Petroleum 

Storage 

Koch Pipeline 

Company, L.P., St. 

James Terminal 

St. James Various emission points and 

storage vessels in facility 

Sulfur 

recovery 

plants 

Chemtrade Refinery 

Services Inc., Sulfuric 

Acid Plant 

Caddo SO2 Scrubber Tail Gas Vent 

Carbon 

black 

Degussa Engineered 

Carbons, LP, Ivanhoe 

Carbon Black Plant 

St. Mary Various emission points in 

facility 

Sid Richardson Carbon 

Company, Addis Plant Iberville Units 1,2, and 3 flares and dryers 2,3, and 4 

Cabot Corporation, 

Cabot Ville Platte 

Plant 

Evangeline Various emission points in 

facility 

Carbon 

black 

(continued) 

Cabot Corporation, 

Canal Plant St. Mary Various emission points in Facility 

Columbian Chemicals 

Company, North Bend St. Mary Various emission points in facility 

Chemical 

process 

plants 

Koch Nitrogen 

Company, Sterlington 

Ammonia Plant 

Ouachita Various emission points in 

Facility 

Procter & Gamble 

Manufacturing 

Company, Alexandria 

Plant 

Rapides #2 process heater 

PCS Nitrogen, 

Geismar Plant – 

Ammonia Group 

Iberville 

Various emission points in 

sulfuric acid, phosphoric 

acid, ammonia, nitric acid, 

and ammonium nitrate 

plants and other emission 

points in facility 

45 
Mosaic Fertilizer LLC, 

Uncle Sam Plant St. James Various emission points in Facility 

DuPont, Pontchartrain 

Diamines Unit 

St. John the 

Baptist 

Various emission points in 

Facility 

ExxonMobil, Baton Rouge 

Chemical Plant 

East Baton 

Rouge 

Various emission points in 

Facility 

CF Industries, 

Donaldsonville Ascension 

Various emission points in 

the # 1, 2, 3, 4 ammonia 

plants, # 1 and 2 urea plants, 

#1 nitric acid plant and other 

emission points in facility 

Shell Chemical LP, 

Norco Chemical Plant 

- East Site 

St. Charles Various emission points in 

Facility 

Chemical 

Process 

(continued) 

Gramercy Alumina St. John the 

Baptist 

Various emission points in 

Facility 

Union Carbide Corp., 

Taft/Star 

Manufacturing 

Complex 

St. Charles Various emission points and 

storage vessels in facility 

Mosaic Fertilizer LLC, 

Faustina Plant Ascension Various emission points in Facility 

Chevron Oronite 

Company LLC, Oak 

Point Plant 

Plaquemines Incinerator 

BASF Corporation, 

Geismar Site Ascension Boiler #6 

Shell Chemical LP, 

Geismar Plant Ascension Various emission points in Facility 

TOTAL 

Petrochemicals USA, 

Inc., Cos-Mar Styrene 

Monomer Plant 

Iberville Various emission points and 

storage vessels in facility 

46 
Lyondell Chemical 

Company, Lake 

Charles Plant 

Calcasieu 

Various emission points in 

nitric acid plant and in 

facility 

Williams Olefins LLC, 

Geismar Ethylene 

Plant 

Iberville Olefin cracking heaters 

Chemtura USA 

Corporation, Geismar 

Plant 

Ascension Various emission points in 

Facility 

Sasol North America 

Inc., Lake Charles 

Chemical Plant 

Calcasieu Various emission points in 

Facility 

DuPont Performance 

Elastomers, 

Pontchartrain 

Chloroprene Unit 

St. John the 

Baptist 

Various emission points and 

storage vessels in facility 

Chemical 

Process 

(continued) 

The Dow Chemical 

Company, Louisiana 

Operations 

Iberville Various emission points in 

Facility 

PPG Industries, Inc., 

Derivatives Calcasieu Various emission points in Facility 

Equistar Chemicals, 

Lake Charles Plant Calcasieu Various emission points in facility 

Syngenta Crop 

Protection, St. Gabriel 

Plant - HCN Unit 

Iberville Various emission points in 

facility 

Firestone Polymers 

LLC, Lake Charles 

Facility 

Calcasieu Various emission points in 

facility 

Chevron Phillips 

Chemical Company, 

LP, St. James Styrene 

Facility 

Ascension ABC Boilers 

Lion Copolymer, LLC, 

Baton Rouge Plant 

East Baton 

Rouge 

Various emission points in 

facility 

47 
Sulfuric 

Acid 

Rhodia, Inc., Baton 

Rouge Facility 

East Baton 

Rouge Sulfuric acid Units 1 and 2 

E.I. du Pont de 

Nemours & Co., Inc., 

Burnside Plant 

Ascension Sulfuric acid plant and other 

emission points in facility 

2. Identification of Sources Subject to BART 

The next step of the BART evaluation is to identify those BART-eligible sources that may 

reasonably be anticipated to cause or contribute to any visibility impairment at any Class I area, 

i.e. those sources that are subject to BART. The BART Guidelines allow states to consider 

exempting some BART-eligible sources from further BART review because they may not 

reasonably be anticipated to cause or contribute to any visibility impairment in a Class I area. 

Following the identification of those sources that were determined to be BART eligible, the 

LDEQ performed a combination approach to determine whether BART-eligible sources would 

cause or contribute to visibility impairment at Breton. The LDEQ used a combination of an 

individual source attribution approach (dispersion modeling), and, for sources with common 

characteristics, a model plant approach.29 Please see the TSD and Appendix A of the TSD for 

more details regarding how sources were exempted from BART by the LDEQ and our analysis of 

this modeling. 

Louisiana considered each of the 76 BART-eligible facilities described earlier using the 

modeling methodologies described below. 

State Submittal: Chapter 9 BART and Appendix E 

LDEQ provided screening modeling results in Chapter 9 and Appendix E of the LA RH 

SIP for all sources identified in the LA RH SIP as BART-eligible sources. Louisiana considered 

each of the 76 BART-eligible facilities described earlier. Modeling using the methodologies 

described in the sections below, titled “Modeling Methodology” and “Contribution Threshold” 

was considered. 

Modeling Methodology 

The BART Guidelines direct states to address SO2, NOX and PM emissions as visibilityimpairing pollutants, and states must exercise their “best judgment to determine whether 

ammonia or VOC emissions from a source are likely to have an impact on visibility in an area.” 

See, 70 FR 39162. As noted above, the LDEQ determined that the visibility-impairing pollutants 

in Louisiana are SO2, NOX, and particulate matter. Louisiana decided to not consider VOCs and 

ammonia among visibility-impairing pollutants for several reasons, as discussed below. We 

propose to accept the State’s decision to address only SO2, NOX, and PM as the visibility 

impairing pollutants. 

Consistent with BART Guidelines, the LDEQ used the CALPUFF modeling system to 

 

29 The “model plant” approach can be used to determine whether a category of sources that share specific 

characteristics should be exempted from BART because these sources are not anticipated to cause or contribute 

to visibility impairment at a Class I area. See 40 CFR 51 Appendix Y.III. 

48 
determine whether individual sources identified as BART-eligible were subject to or exempt from 

BART. For this modeling, Louisiana considered 76 BART-eligible facilities, as discussed in 

section IV.D.1. Based on this analysis, Louisiana identified 27 facilities for further consideration 

due to visibility impact above a 0.5 dv contribution threshold. These facilities are discussed in 

the next section of this action and are identified in Table 7 below. We are proposing to find the 

LDEQ’s chosen modeling methodology and screening approach are acceptable. 

 For states using modeling to determine the applicability of BART to single sources, the 

BART Guidelines note that an important step is to set a contribution threshold to assess whether 

the impact of a single source is sufficient to cause or contribute to visibility impairment at a 

Class I area. The BART Guidelines state that, “[a] single source that is responsible for a 1.0 

deciview change or more should be considered to ‘cause’ visibility impairment.” 70 FR 39104, 

39161. The BART Guidelines also state that “the appropriate threshold for determining whether 

a source contributes to visibility impairment “may reasonably differ across states,” but “[a]s a 

general matter, any threshold that you use for determining whether a source ‘contributes’ to 

visibility impairment should not be higher than 0.5 deciviews.” Id. Further, in setting a 

contribution threshold, states should “consider the number of emissions sources affecting the 

Class I areas at issue and the magnitude of the individual sources’ impacts.” The Guidelines 

affirm that states are free to use a lower threshold if they conclude that the location of a large 

number of BART-eligible sources in proximity of a Class I area justifies this approach. 

Considering the number of sources affecting Louisiana’s Class I area and the magnitude of each 

source’s impact, the LDEQ used a contribution threshold of 0.5 dv for determining which 

sources are subject to BART. We propose to accept the State’s selection of 0.5 dv as the 

threshold value. 

For the 27 facilities referenced above, Louisiana requested that the facilities provide 

additional modeling: Screening Modeling and, for sources that failed the Screening Modeling, 

Refined Modeling. Those facilities that the LDEQ requested to conduct this additional modeling 

and the results of the individual Screening and Refined Modeling analyses for each of these 

sources are shown in Table 7 below.30 Our evaluation of these modeling results showed that 

there was one facility, Mosaic Fertilizer Uncle Sam Plant (Mosaic), which had modeled visibility 

impacts that exceeded the 0.5 dv contribution threshold, but which the LDEQ determined was 

not subject to BART. At the time of the submittal, the LDEQ’s modeling showed that, using thencurrent permit maximum hourly emission rates, Mosaic had an operating emissions rate of 2,250 

lbs/hr (maximum) and a significant modeled visibility impact at Breton of over 0.5 dv. At that 

time, Mosaic was reviewing possibilities for future control strategies on the A-Train Sulfuric 

Acid Stack that could be expected to reduce SO2 emissions for the facility. For purposes of 

performing a refined modeling analysis and exempting the source from BART requirements, 

Mosaic considered potential future emission rates based on future controls, and used a modeling 

data input of 258.3 lbs/hr (maximum). Although future controls were being considered, they were 

not yet in place. The RHR states that a source can be exempted if its visibility impacts at the time 

the SIP is developed are less than the screening value. See, 70 FR 39118. Because Mosaic’s 

impacts were greater than the screening value, at that time, the LDEQ should have completed a 

full five factor analysis to assure the appropriate BART level of control was implemented (as 

discussed in section IV.D.3). Therefore, we propose to find that the LDEQ erred in exempting the 

Mosaic facility from BART. For those facilities for which Screening and Refined Modeling was 

 

30 The LDEQ provided screening modeling results for all sources identified as BART-eligible; see Appendix E of 

the LA RH SIP submission.

49 
provided, with the exception of Mosaic, we propose to approve the modeling in the LA RH SIP 

submittal that identifies which sources are exempt from BART. 

The LDEQ’s BART Modeling Protocol is found in Chapter 9 and Appendix E of the LA 

RH submittal. The LDEQ utilized BART modeling to determine what sources contribute to 

visibility impairment in Louisiana’s Class I area-- Breton, as well as nearby Class I areas in other 

states, with sources having a visibility impact below 0.5 deciviews being exempt from BART. In 

accordance with the BART Guidelines, Louisiana employed both a model plant approach and 

dispersion modeling to further exempt sources from being subject to BART. 

 The BART Guidelines31 explain that “analyses of model plants could be used to exempt 

certain BART-eligible sources that share specific characteristics.” The BART Guidelines further 

explain how these types of analyses should be conducted: 

In carrying out this approach, you could use modeling analyses of representative 

plants to reflect groupings of specific sources with important common 

characteristics. Based on these analyses, you may find that certain types of 

sources are clearly anticipated to cause or contribute to visibility impairment. You 

could then choose to categorically require those types of sources to undergo a 

BART determination. Conversely, you may find based on representative plant 

analyses that certain types of sources are not reasonably anticipated to cause or 

contribute to visibility impairment. To do this, you may conduct your own 

modeling to establish emission levels and distances from Class I areas on which 

you can rely to exempt sources with those characteristics. For example, based on 

your modeling you might choose to exempt all NOX-only sources that emit less 

than a certain amount per year and are located a certain distance from a Class I 

area. You could then choose to categorically exempt such sources from the BART 

determination process. 

Louisiana adopted this approach and proceeded in its model plant analysis by selecting specific 

facilities as “models,” exempting those facilities from being subject to BART though dispersion 

modeling, and then using the results of those analyses, to exclude additional sources. Louisiana 

created an artificial model source to examine impacts to Class I areas to the north and west—

Upper Buffalo, Hercules Glades, or Wichita Mountains Class I areas. This source resulted in 

visibility impacts to these Class I areas of less than Louisiana’s threshold of 0.5 dv. Louisiana 

reasoned that due to the model plant’s location, in northwest Louisiana, all Louisiana BART 

facilities to the south and the east of the model plant with fewer NOX, SO2, and PM emissions 

(and certain other modeling parameters) would also not have an impact of 0.5 deciviews or more 

to Upper Buffalo, Hercules Glades, or Wichita Mountains. Louisiana then examined the Class I 

areas to the east and noted that the Sipsey and Mammoth Cave Class I areas are more than 300 

kms from any Louisiana BART source. Louisiana used residence time and area of influence plots 

for Sipsey and Mammoth Cave for 2002-2004 supplied by the VISTAS RPO. Louisiana 

concluded these plots shown indicate that visibility impacts from its sources on these Class I 

areas were minimal and both should be removed from consideration. Louisiana concluded the 

Class I areas of concern for Louisiana BART-eligible facilities were Caney Creek in Arkansas 

and Breton Island in Louisiana. 

 

31 70 FR 39162 

50 
Louisiana noted the two facilities with the highest emission divided by distance ratios 

with respect to the Caney Creek Class I area were Smurfit Stone in Jackson Parish, Louisiana 

and Chemtrade Refining in Caddo Parish, Louisiana. Louisiana conducted CALPUFF screening 

and concluded that either facility had impacts less than 0.5 dv. Another facility, Graphics 

Packaging, was requested to conduct its own BART screening analysis and was similarly 

exempted. Based on the results of its model plant analysis and the Graphics Packaging analyses, 

Louisiana concluded none of its sources resulted in visibility impacts at Caney Creek above the 

selected BART threshold of 0.5 dv. 

Louisiana took a different approach for assessing the BART visibility impacts at Breton 

Island. Louisiana modeled two facilities, the ConocoPhillips Alliance Refiner in St. Bernard 

Parish, Louisiana and the Big Cajun 2 power plant in Pointe Coupee Parish, Louisiana. 32 

Louisiana noted that both the ConocoPhillips and Big Cajun sources each resulted in visibility 

impacts greater than the selected BART threshold of 0.5 dv. Louisiana requested that any facility 

with an emissions-to-distance ratio greater than that from Big Cajun 2 should conduct its own 

BART screening modeling. Louisiana then preformed BART screening modeling on a number of 

other sources for visibility impacts on Breton Island and removed all other sources with lower 

emissions-to-distance ratios. 

Based on this analysis, Louisiana identified 27 facilities for further consideration of 

visibility impact above a contribution threshold, and requested that these facilities either screen 

or perform refined modeling. These facilities are identified with bolded text in Table 7 below, 

and are also discussed further in the next section of this TSD. The facilities in Table 7 which are 

not highlighted were determined by LDEQ’s analysis to be not subject to BART. 

Table 7. BART-eligible Facilities Identified by LDEQ as 

a) Requested to Screen or Perform Refined Modeling, or 

b) Not Subject to BART 

BART 

source 

category

Facility name Parish 

Unit Description 

Fossil fuelfired steam 

electric plants 

of more than 

250 

MMBTU/hr 

heat input

Cleco Power LLC., 

Rodemacher Power 

Station 

Rapides Unit 1 boiler 

Entergy Louisiana, 

Sterlington Ouachita Unit 7 boiler 

City of Ruston, Ruston 

Electrical Generation 

Station 

Lincoln Boilers 1, 2, and 3 

City of Natchitoches Utility 

Dept. Natchitoches 3 boilers 

 

32 We note that Louisiana only included PM impacts from Big Cajun 2, relying on SO2 and NOX exemptions due to 

the CAIR. As we note elsewhere, because the CAIR has been remanded, we cannot approve Louisiana’s reliance 

on the CAIR to satisfy BART. 

51 
Louisiana Generating 

LLC, Big Cajun 2 

Power Plant

Pointe Coupee Units 1, 2, and 3 

Entergy New Orleans, 

Michoud Orleans Units 2 and 3 

Entergy Louisiana, 

Waterford St. Charles Units 1 and 2 

Entergy Gulf States, 

Willow Glen

Iberville Units 2, 3, 4, and 5 boilers 

Louisiana Energy & 

Power Authority, 

Morgan City Steam Plant 

St. Mary, 

St. Martin Units 1, 2, 3, and 4 boilers 

Entergy Louisiana, 

Ninemile Point Jefferson Units 4 and 5 boilers 

Entergy Gulf States, 

Nelson Calcasieu # 4 boiler 

Fossil fuelfired steam 

electric 

plants of 

more than 

250 

MMBTU/hr 

heat input 

(continued) 

Cleco Power LLC., 

Teche Power Station St. Mary Unit 3 boiler 

Louisiana Energy and 

Power Authority, Plaquemine 

Steam Plant 

Iberville Boilers 1 and 2 

Entergy Louisiana, Little 

Gypsy St. Charles Units 2 and 3 

Louisiana Generating 

LLC, Big Cajun 1 

Power Plant 

Pointe Coupee Units 1 and 2 

Lafayette Utilities 

System, Louis "Doc" 

Bonin Electric 

Generation Station 

Lafayette Units 1, 2 and 3 

Terrebonne Parish 

Consolidated 

Government, Houma 

Generating Station 

Terrebonne Units 15 and 16 boilers 

52 
Monochem, Inc., 

Geismar Facility Ascension #1, 2, and 3 boiler stacks 

Secondary 

metal 

production

Exide Technologies, 

Baton Rouge Smelter 

East Baton 

Rouge 

Various emission points in 

facility 

Kraft pulp 

mills 

Graphics Packaging 

International, 

West Monroe Mill 

Ouachita Various emission points in 

facility 

Smurfit-Stone 

Container Enterprise, Inc. Jackson Various emission points in facility 

International Paper 

Company, Bastrop - 

Louisiana Mill 

Morehouse Various emission points in 

facility 

International Paper, 

Pineville Mill Rapides Various emission points in facility 

Kraft pulp 

mills 

(continued)

Boise Cascade, 

DeRidder Paper Mill Beauregard Recovery furnace, bark boiler #1, and lime kiln 

Weyerhaeuser 

Company, Red River Mill Natchitoches Various emission points in facility 

Temple Inland, 

Bogalusa Mill 

Washington Lime kiln, #12 hogged fuel 

boiler 

Georgia Pacific, Port 

Hudson Operations 

East Baton 

Rouge 

Various emission points in 

facility 

Tembec USA LLC, St. 

Francisville Mill West Feliciana Various emission points in facility 

Petroleum 

Refinery 

ConocoPhillips Co., 

Alliance Refinery Plaquemines Various emission points in facility 

53 
Marathon Petroleum 

Company, LLC-LA 

Refining Division, 

Garyville Refinery 

St. John the 

Baptist 

Various emission points 

and 

storage vessels in facility 

Murphy Oil USA, Inc., 

Meraux Refinery St. Bernard Various emission points in facility 

Valero Refining-New 

Orleans, LLC, St. 

Charles Refinery 

St. Charles 

Hydrotreater heater, FCC 

unit, flare #1, and sulfur 

recovery unit 

ExxonMobil Refining 

& Supply Co., 

ExxonMobil Baton 

Rouge Refinery 

East Baton 

Rouge 

Various emission points in 

facility 

Chalmette Refining, 

L.L.C., Chalmette 

Refinery 

Orleans 

Various emission points 

and 

storage vessels in facility 

Petroleum 

Refinery 

(continued) 

Placid Refining 

Company, L.L.C., 

Port Allen Refinery 

West Baton 

Rouge 

Various emission points 

and 

storage vessels in facility 

Motiva Enterprises 

LLC, Norco Refinery St. Charles Various emission points in facility 

CITGO Petroleum, 

Lake Charles 

Manufacturing Complex 

Calcasieu Various emission points in 

facility 

Motiva Enterprises, 

LLC, Convent Refinery St. James Various emission points in facility 

CITGO Petroleum 

Corporation, Clifton 

Ridge Terminal 

Calcasieu Various storage vessels 

CITGO Petroleum 

Corporation, Pecan 

Grove Tank 

Calcasieu Various storage vessels and 

fugitives 

54 
Petroleum 

Storage 

Koch Pipeline 

Company, L.P., St. 

James Terminal 

St. James Various emission points and 

storage vessels in facility 

Sulfur 

recovery 

plants 

Chemtrade Refinery 

Services Inc., Sulfuric 

Acid Plant 

Caddo SO2 Scrubber Tail Gas Vent 

Carbon 

black 

Degussa Engineered 

Carbons, LP, Ivanhoe 

Carbon Black Plant 

St. Mary Various emission points in 

facility 

Sid Richardson Carbon 

Company, Addis Plant Iberville Units 1,2, and 3 flares and dryers 2,3, and 4 

Cabot Corporation, 

Cabot Ville Platte Plant Evangeline Various emission points in facility 

Carbon 

black 

(continued) 

Cabot Corporation, 

Canal Plant St. Mary Various emission points in Facility 

Columbian Chemicals 

Company, North Bend St. Mary Various emission points in facility 

Chemical 

process 

plants 

Koch Nitrogen 

Company, Sterlington 

Ammonia Plant 

Ouachita Various emission points in 

Facility 

Procter & Gamble 

Manufacturing 

Company, Alexandria Plant 

Rapides #2 process heater 

PCS Nitrogen, 

Geismar Plant – 

Ammonia Group 

Iberville 

Various emission points in 

sulfuric acid, phosphoric 

acid, ammonia, nitric acid, 

and ammonium nitrate 

plants and other emission 

points in facility 

Mosaic Fertilizer LLC, 

Uncle Sam Plant St. James Various emission points in Facility 

55 
DuPont, Pontchartrain 

Diamines Unit 

St. John the 

Baptist 

Various emission points in 

Facility 

ExxonMobil, Baton Rouge 

Chemical Plant 

East Baton 

Rouge 

Various emission points in 

Facility 

CF Industries, 

Donaldsonville Ascension 

Various emission points in 

the # 1, 2, 3, 4 ammonia 

plants, # 1 and 2 urea 

plants, 

#1 nitric acid plant and 

other 

emission points in facility 

Shell Chemical LP, 

Norco Chemical Plant 

- East Site 

St. Charles Various emission points in 

Facility 

Chemical 

Process 

(continued) 

Gramercy Alumina St. John the 

Baptist 

Various emission points in 

Facility 

Union Carbide Corp., 

Taft/Star 

Manufacturing 

Complex 

St. Charles 

Various emission points 

and 

storage vessels in facility 

Mosaic Fertilizer LLC, 

Faustina Plant Ascension Various emission points in Facility 

Chevron Oronite 

Company LLC, Oak 

Point Plant 

Plaquemines Incinerator 

BASF Corporation, 

Geismar Site Ascension Boiler #6 

Shell Chemical LP, 

Geismar Plant Ascension Various emission points in Facility 

TOTAL 

Petrochemicals USA, 

Inc., Cos-Mar Styrene 

Monomer Plant 

Iberville Various emission points and 

storage vessels in facility 

56 
Lyondell Chemical 

Company, Lake 

Charles Plant 

Calcasieu 

Various emission points in 

nitric acid plant and in 

facility 

Williams Olefins LLC, 

Geismar Ethylene Plant Iberville Olefin cracking heaters 

Chemtura USA 

Corporation, Geismar Plant Ascension Various emission points in Facility 

Sasol North America 

Inc., Lake Charles 

Chemical Plant 

Calcasieu Various emission points in 

Facility 

DuPont Performance 

Elastomers, 

Pontchartrain 

Chloroprene Unit 

St. John the 

Baptist 

Various emission points and 

storage vessels in facility 

Chemical 

Process 

(continued) 

The Dow Chemical 

Company, Louisiana 

Operations 

Iberville Various emission points in 

Facility 

PPG Industries, Inc., 

Derivatives Calcasieu Various emission points in Facility 

Equistar Chemicals, 

Lake Charles Plant Calcasieu Various emission points in facility 

Syngenta Crop 

Protection, St. Gabriel 

Plant - HCN Unit 

Iberville Various emission points in 

facility 

Firestone Polymers 

LLC, Lake Charles Facility Calcasieu Various emission points in facility 

Chevron Phillips 

Chemical Company, 

LP, St. James Styrene Facility 

Ascension ABC Boilers 

Lion Copolymer, LLC, 

Baton Rouge Plant 

East Baton 

Rouge 

Various emission points in 

facility 

57 
Sulfuric 

Acid 

Rhodia, Inc., Baton 

Rouge Facility 

East Baton 

Rouge Sulfuric acid Units 1 and 2 

E.I. du Pont de 

Nemours & Co., Inc., 

Burnside Plant 

Ascension 

Sulfuric acid plant and 

other 

emission points in facility 

As discussed in section III.F.1 of this TSD, the original meteorological databases 

generated by the CENRAP did not include observations as the EPA guidance recommends. 

Therefore, in their evaluation to determine if a source exceeds the 0.5 dv contribution threshold 

at nearby Class I areas, states used the 1st high values (i.e., maximum value) of modeled 

visibility impacts instead of the 8th high values (i.e., 98th percentile value). The use of the 1st 

high modeled values was agreed to by EPA, representatives of the FLMs, and the CENRAP 

stakeholders. 

For the 27 facilities referenced in Table 7 above, Louisiana requested that the facilities 

either use screening modeling or perform refined modeling. The results of the individual 

screening and refined modeling analyses for each of these sources are shown in Table 8 below.33

Table 8. BART-eligible Facilities Identified by LDEQ as 

Requested to Screen or Perform Refined Modeling: 

CALPUFF/CALPOST Screening Results

BART source 

category Facility name Modeling 

Results 

Unit Description 

Louisiana Generating 

LLC, Big Cajun 2 

Power Plant 

Passed Refined 

Model Units 1, 2, and 3 

Entergy New Orleans, 

Michoud 

Passed Refined 

Model Units 2 and 3 

Entergy Gulf States, 

Willow Glen 

Passed Refined 

Model Units 2, 3, 4, and 5 boilers 

Secondary 

metal 

production

Exide Technologies, 

Baton Rouge Smelter 

Passed 

Screening 

Model 

Various emission points in 

facility 

Kraft pulp 

mills 

Graphics Packaging 

International, 

West Monroe Mill 

Passed 

Screening 

Model 

Various emission points in 

facility 

 

33 The LDEQ provided screening modeling results for all sources identified as BART-eligible; see Appendix E of 

the LA RH SIP submission. 

58 
Temple Inland, 

Bogalusa Mill 

Passed 

Screening 

Model 

Lime kiln, #12 hogged fuel 

boiler 

Georgia Pacific, Port 

Hudson Operations 

Passed 

Screening 

Model 

Various emission points in 

facility 

Petroleum 

Refinery 

ConocoPhillips Co., 

Alliance Refinery 

Failed Refined 

Model 

Various emission points in 

facility 

Marathon Petroleum 

Company, LLC-LA 

Refining Division, 

Garyville Refinery 

Passed 

Screening 

Model 

Various emission points and 

storage vessels in facility 

Murphy Oil USA, Inc., 

Meraux Refinery 

Passed Refined 

Model 

Various emission points in 

facility 

Valero Refining-New 

Orleans, LLC, St. 

Charles Refinery 

Passed 

Screening 

Model 

Hydrotreater heater, FCC 

unit, flare #1, and sulfur 

recovery unit 

ExxonMobil Refining 

& Supply Co., 

ExxonMobil Baton 

Rouge Refinery 

Passed 

Screening 

Model 

Various emission points in 

facility 

Chalmette Refining, 

L.L.C., Chalmette 

Refinery 

Passed 

Screening 

Model 

Various emission points and 

storage vessels in facility 

Petroleum 

Refinery 

(continued) 

Placid Refining 

Company, L.L.C., 

Port Allen Refinery 

Passed 

Screening 

Model 

Various emission points and 

storage vessels in facility 

Motiva Enterprises 

LLC, Norco Refinery 

Passed Refined 

Model 

Various emission points in 

facility 

Carbon black 

Degussa Engineered 

Carbons, LP, Ivanhoe 

Carbon Black Plant 

Passed Refined 

Model 

Various emission points in 

facility 

Sid Richardson Carbon 

Company, Addis Plant 

Failed Refined 

Model 

Units 1,2, and 3 flares and 

dryers 2,3, and 4 

59 
PCS Nitrogen, 

Geismar Plant – 

Ammonia Group 

Passed Refined 

Model 

Various emission points in 

sulfuric acid, phosphoric 

acid, ammonia, nitric acid, 

and ammonium nitrate plants 

and other emission points in 

facility 

Mosaic Fertilizer LLC, 

Uncle Sam Plant 

Passed Refined 

Model 

Various emission points in 

Facility 

ExxonMobil, Baton Rouge 

Chemical Plant 

Passed 

Screening 

Model 

Various emission points in 

Facility 

CF Industries, 

Donaldsonville 

Passed 

Screening 

Model 

Various emission points in 

the # 1, 2, 3, 4 ammonia 

plants, # 1 and 2 urea plants, 

#1 nitric acid plant and other 

emission points in facility 

Shell Chemical LP, 

Norco Chemical Plant 

- East Site 

Passed Refined 

Model 

Various emission points in 

Facility 

Chemical 

Process 

(continued) 

Gramercy Alumina 

Passed 

Screening 

Model 

Various emission points in 

Facility 

Union Carbide Corp., 

Taft/Star 

Manufacturing Complex 

Passed 

Screening 

Model 

Various emission points and 

storage vessels in facility 

Mosaic Fertilizer LLC, 

Faustina Plant 

Passed 

Screening 

Model 

Various emission points in 

Facility 

Sulfuric Acid 

Rhodia, Inc., Baton 

Rouge Facility 

Failed Refined 

Model Sulfuric acid Units 1 and 2 

E.I. du Pont de 

Nemours & Co., Inc., 

Burnside Plant 

Passed 

Screening 

Model 

Sulfuric acid plant and other 

emission points in facility 

Sources Subject to BART 

The sources that were not exempt from the BART requirements via dispersion modeling 

60 
analyses and/or the use of model plants are subject to BART. For sources subject to BART in 

Louisiana, the LDEQ must make a determination of BART. The LDEQ identified three sources as 

subject to BART and we identified one more, Mosaic, as discussed previously. All four of these 

sources are shown in Table 9. 

Table 9. Non-EGU Sources in Louisiana Subject to BART 

Facility Name BART

Emission Units

Source 

Category

Pollutants 

Evaluated

Visibility 

Contribution at 

Breton (dv) 

ConocoPhillips Co. 

Alliance Refinery 

Various emission 

points in facility 

Petroleum 

Refinery 

SO2 2. 69 

NOX

PM10

Rhodia, Inc. Sulfuric Acid 

Units 1 and 2 

Sulfuric Acid SO2 1.04 / 0.16* 

Sid Richardson 

Carbon Company 

Units 1,2, and 3 

flares and dryers 

2,3 and 4 

Carbon Black SO2 0.57 

Mosaic Fertilizer 

Uncle Sam Plant** 

Various emission 

points in facility* 

Chemical 

Process 

Facility* 

None* ** 

* Visibility contribution prior to CD controls / following implementation of CD controls. 

**This facility was identified by EPA as subject to BART. 

Louisiana did not submit source-specific BART evaluations for EGUs in its analysis 

because the state chose to meet BART requirements for EGUs for SO2 and NOX by participation 

in the CAIR, and because modeling results showed that the PM emissions from EGUs did not 

warrant further control. This is discussed further in the next section.

As discussed in section I of this TSD, CAIR has been remanded, and therefore, LDEQ 

must re-evaluate the visibility impacts from BART-eligible EGUs based on comprehensive 

modeling data. 

3. BART Determinations 40 CFR 51.308(e)(1)(ii)(A)

The next component of a BART evaluation is to perform the BART analysis. BART is a 

source-specific control determination, based on consideration of several factors set out in 

section 169A(g)(2) of the CAA. These factors include the costs of compliance and the degree of 

improvement in visibility associated with the use of possible control technologies. The EPA 

issued BART Guidelines (Appendix Y to Part 51) in 2005 to clarify the BART provisions based 

on the statutory and regulatory BART requirements (70 FR 39164). The BART Guidelines 

describe the BART analysis as consisting of the following five basic steps: 

• Step 1: Identify All Available Retrofit Control Technologies, 

• Step 2: Eliminate Technically Infeasible Options, 

• Step 3: Evaluate Control Effectiveness of Remaining Control Technologies, 

• Step 4: Evaluate Impacts and Document the Results, and 

61 
• Step 5: Evaluate Visibility Impacts 

We note the BART Guidelines provide that states must follow the guidelines in making 

BART determinations on a source-by-source basis for 750 MW power plants but are not required 

to use the process in the guidelines when making BART determinations for other types of 

sources. States with subject-to-BART units with a generating capacity less than 750 MW are 

strongly encouraged to follow the BART Guidelines in making BART determinations, but they 

are not required to do so. However, the requirement to perform a BART analysis that considers 

“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,” is found in 40 CFR 51.308(e)(1)(ii)(A) 

and the RHR, and applies to all subject-to-BART sources. 

For three facilities, ConocoPhillips Co., Rhodia Inc., and Sid Richardson Carbon 

Company, the LDEQ submitted a BART analysis under 40 CFR 51.308(e)(1)(ii)(A). For each of 

these facilities, we propose to find that the BART analysis satisfies part of the requirements, but 

does not satisfy all of the requirements. A summary of our proposed findings for these facilities is 

provided below. 

As previously discussed, we are proposing to find that the state should have identified 

Mosaic as being subject to BART and made a BART determination for the source. This is 

discussed in more detail in section IV.D.2 of this action. 

Also, as discussed in the Executive Summary above, in an earlier proposed action EPA 

proposed a limited disapproval of the LA RH SIP (76 FR 82219). EPA’s proposed limited 

disapproval is based on deficiencies in the LA RH SIP submittal arising from the state’s reliance 

on the CAIR to meet certain regional haze requirements. States such as Louisiana that are 

subject to the requirements of the Transport Rule trading program only for NOX must still 

address BART for EGUs for SO2 and other visibility impairing pollutants. See, 76 FR at 82224. 

While we proposed on December 30, 2011 to issue a FIP to address the deficiencies in 

Louisiana’s SIP associated with the BART requirements for NOX for EGUs, we did not propose a 

FIP to address the deficiencies associated with the BART requirements for SO2. Louisiana also 

relied on the CAIR in assessing the need for emissions reductions for SO2 from EGUs to satisfy 

BART requirements. Consequently, Louisiana will have to re-evaluate EGUs with respect to SO2

BART requirements. 

State Submittal: Louisiana’s Regional Haze SIP Appendix G contains the BART analysis 

provided by each of the three facilities subject to BART 

For the sources that the LDEQ identified as BART-eligible, and were not exempt from 

the BART requirements via dispersion modeling analyses and/or the use of model plants, the 

LDEQ must make a determination of BART for each BART-eligible source in Louisiana that 

emits any air pollutant which may reasonably be anticipated to cause or contribute to any 

impairment of visibility in any mandatory Class I Federal area. All such sources are subject to 

BART. The determination of BART must be based on an analysis of the best system of 

continuous emission control technology available and associated emission reductions achievable 

for each BART-eligible source that is subject to BART within the State. 

62 
a. ConocoPhillips

The ConocoPhillips Alliance Refinery is a petroleum refinery near Belle Chasse 

Louisiana and is a subject-to-BART source. On December 5, 2005, ConocoPhillips and the EPA 

entered into a Consent Decree (CD).34 The BART engineering analysis, provided by 

ConocoPhillips utilized emission reductions that are mandated per the CD for the fluidized 

catalytic cracker, the process refinery flares and the crude unit heater. Implementing these 

control projects per the CD emissions reductions will result in reducing the overall site visibility 

impacts. The visibility improvements resulting from this CD are discussed below. However, the 

LDEQ did not provide a complete BART evaluation for these units. The submittal does not 

analyze controls for these units using the five steps as required by 40 CFR 51.308(e). Also, no 

emissions limits for BART for these units were included in the LA RH SIP. Therefore, for the 

units covered by the CD, the LDEQ must provide BART analyses for the units to meet BART 

requirements (40 CFR 51.308(e)(1)(ii)(A)).35 Also, a unit’s BART emissions limits must be a part 

of the RH SIP, and therefore the LDEQ must include the BART emissions limits in the RH SIP 

through a SIP revision.36 We propose to find that the BART determination for ConocoPhillips 

Alliance Refinery is deficient at this time. 

There are several other units subject to BART at the ConocoPhillips Alliance facility. 

These include the cooling water tower and gas-fired heaters. Louisiana provided a BART 

analysis for these as follows: cooling water tower for PM and PM10, and process heaters for 

NOX. For these units, ConocoPhillips determined, and the LDEQ agreed that there was not a 

cost effective control. We are proposing to accept the LDEQ’s BART analysis that no additional 

controls are required to meet BART for these units. 

For three other units, the emissions of PM, SO2, and NOX are minimal; so, the potential 

visibility improvement from controls on these units is also minimal. These units are the Product 

Dock No. 1 MVR Loading, the Product Dock No. 2 MVR Loading, and Coke Transfer and 

Storage. For detailed information, see the TSD section IV.D.3.a.iii and TSD Appendix A. The 

installation of any additional controls would likely achieve negligible emissions reductions, have 

almost no visibility impact on Breton, and would not be cost-effective.37 We propose to find that 

the LDEQ’s analysis for these units is adequate to meet BART requirements. 

 

34 Civil Action No. H-05-0285. A copy of this CD is available in the docket for this rulemaking. 

35 The EPA recently finalized action approving New Jersey’s BART determinations for the ConocoPhillips 

Bayway Refinery, which is subject to the same CD as the ConocoPhillips Alliance Refinery. See

http://www.epa.gov/compliance/resources/cases/civil/caa/conocophillips.html. The proposal for that action 

explains that the EPA’s approval is based on New Jersey’s submittal of a complete BART evaluation for the 

subject-to BART units at the facility, and the fact that these units will be controlled “based on maximum feasible 

controls or a multi-factor analysis.” 76 FR 49711, at 49721; see also, 77 FR 19-01. The TSD for that action 

describes how New Jersey’s submittal included the BART analysis for NOX, SO2, and PM for the subject-toBART units at this source in compliance with 40 CFR 51.308(e)(1)(ii)(A). TSD, pages 27-29, available at

http://www.regulations.gov, Docket number EPA-R02-OAR-2011-0607. 36 The CAA requires RH SIPs to “to contain such emission limits. . . necessary to make reasonable progress toward 

meeting the national goal. . . .” CAA 169A(b)(2). The federal regulations further explain that the state must 

“submit an implementation plan containing emission limits 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 mandatory Class I Federal area.” 40 CFR 51.308(e). Finally, the preamble to the 

RHR states that “[t]he SIP revision must include the emission limitations determined to be BART for sources 

subject to BART . . . .” 64 FR 35714, at 35741. 37 “Consistent with the CAA and the implementing regulations, States can adopt a more streamlined approach to 

making BART determinations where appropriate. Although BART determinations are based on the totality of 

circumstances in a given situation, such as the distance of the source from a Class I area, the type and amount of 

63 
State Submittal Regarding BART for this source: Chapter 9 and Appendix G, pp. 154 – 348 

The ConocoPhillips Alliance refinery is located near Belle Chasse, which is 

approximately 94 kilometers from the Breton Class I area. The Alliance Refinery produces a 

wide range of petroleum products from crude oil, such as liquified petroleum gas, motor 

gasoline, jet fuel, diesel, carbon black feedstock, propane, and coke. The Alliance Refinery also 

produces petrochemicals such as benzene, toluene, xylenes, and by-product elemental sulfur. 

Emission sources at the Alliance Refinery include process heaters, boilers, storage vessels, 

loading facilities, fugitive emissions from equipment, process vents, and flares. 

The LDEQ provided a BART Engineering Analysis and Modeling Report for the 

ConocoPhillips Alliance Refinery in an attachment dated July 5, 2007 as part of Appendix G of 

its submittal. The report was prepared under direction of ConocoPhillips and includes analysis by 

Sage Environmental Consulting. (LA RH SIP Appendix G, pp. 154 – 348). 

For the units which are controlled by Consent Decree (see Table 10 below), the 

documentation provided does not analyze controls for each of the subject-to-BART units using 

the five steps as required by 40 CFR 51.308(e). 

For two flares, we note that the CD and the LA RH SIP Appendix G may be referring to 

the same units, but the CD does not include the EPN numbers. Appendix A of the First 

Amendment to the CD refers to the “Low Pressure Flare (coker)” and “High Pressure Flare” for 

the Alliance Refinery; these may be the same units as the subject-to-BART units labeled “Low 

Pressure Flare” (EPN 308F-D-l) and “High Pressure Flare” (EPN 308F-D-2). 

In order to satisfy BART requirements, Louisiana must either provide a BART analysis, 

or find that the controls required under the CD are among the most stringent. As discussed in 40 

CFR Part 51 Appendix Y(IV)(D)(1)(9) and 70 FR 39165, if the State finds that the controls 

required under the CD are among the most stringent, then it will need to be consistent with the 

following (40 CFR Part 51 Appendix Y(IV)(D)(1)(9)): 

 If you find that a BART source has controls already in place which are the most 

stringent controls available (note that this means that all possible improvements to 

any control devices have been made), then it is not necessary to comprehensively 

complete each following step of the BART analysis in this section. As long as 

these most stringent controls available are made federally enforceable for the 

purpose of implementing BART for that source, you may skip the remaining 

analyses in this section, including the visibility analysis in Step 5. Likewise, if a 

source commits to a BART determination that consists of the most stringent 

controls available, then there is no need to complete the remaining analyses in this 

section. 

 

pollutant at issue, and the availability and cost of controls, it is clear that in some situations, one or more factors 

will clearly suggest an outcome. Thus, for example, a State need not undertake an exhaustive analysis of a 

source’s impact on visibility resulting from relatively minor emissions of a pollutant where it is clear that 

controls would be costly and any improvements in visibility resulting from reductions in emissions of that 

pollutant would be negligible. In a scenario, for example, where a source emits thousands of tons of SO2 but less 

than one hundred tons of NOX, the State could easily conclude that requiring expensive controls to reduce NOX

would not be appropriate. In another situation, however, inexpensive NOX controls might be available and a 

State might reasonably conclude that NOX controls were justified as a means to improve visibility despite the 

fact that the source emits less than one hundred tons of the pollutant.” 70 FR 39116. 

64 
Also, a unit’s BART emissions limits must be a part of the RH SIP, and therefore the LDEQ 

must include the BART emissions limits for all subject-to-BART units in the RH SIP through a 

SIP revision. 

 

The emission units subject-to-BART are shown in Table 10,38 with columns providing 

information for the units as follows: 

• 5-factor analysis included? (Does the LA RH SIP Appendix G: ConocoPhillips Report 

included a 5-factor analysis for this unit?); 

• De minimis emissions? (Are emissions from this unit De minimis?) More information 

about this column is provided in Appendix B to this TSD. 

• Included in CD? (Is this unit included in the amended Consent Decree including the 

Alliance Refinery (Civil Action No. H-05-028)? 

• Proposed Action? (What is EPA’s proposed action for this unit with respect to the BART 

requirements?) 

 

 

38 Modified from a table in Appendix A within Appendix G of the Louisiana RH SIP. 

65 
Table 10. ConocoPhillips Alliance Refinery BART-Subject Units 

EPN Description 

5-factor analysis included?aDe minimis emissions?a,

b

Included in CD?c

Proposed Action? 

NOX SO2 PM 

308F-D-l Low Pressure Flare* Y D D D 

308F-D-2 High Pressure Flare* Y D D D 

301-B-2A CO Boiler Y D D D 

301-B-2B CO Boiler Y D D D 

191-H-1 Crude Charge Heater Y D D D 

292-H-1 Light Distillate Gulfiner Reactor 

Heater 

Y A D D 

292-H-2 Light Distillate Gulfiner Stabilizer 

Heater 

Y Y A D D 

1291-H-2/3 FCCU Light/Heavy Feed Heater Y Y A D D 

191-H-2 Vacuum Charge Heater Y Y A D D 

891-H-1 Delayed Coker Charge Heater Y Y A D D 

491-H-l Alkylation Isostripper Reboiler Y Y A D D 

491-H-2 Alkylation Depropanizer Reboiler Y Y A D D 

100-H-1 Coker Charge Storage Heater Y A D D 

293-H-I Heavy Distillate Gulfiner Reactor 

Feed Heater 

Y Y A D D 

293-H-2 Heavy Distillate Gulfiner Stabilizer 

Reboiler 

Y Y A D D 

1391-H-1 Catalytic Reformer Feed Heater No. 

1 

Y Y A D D 

l391-H-2/3 Catalytic Reformer Feed Heater Nos. 

2&3 

Y Y A D D 

1391-H-4 Depentanizer Reboiler Y Y A D D 

1391-H-5 Dry Reactivation Heater Y A D D 

1791-H-1 Reformate Splitter Reboiler Y Y A D D 

I792-H-l Hydrodealkylation Charge Heater Y Y A D D 

291-H-l Naphiner Reactor Feed Heater Y Y A D D 

291-H-2 Naphiner Deisohexanizer Reboiler Y Y A D D 

303-R-1 Cooling Water Tower No. 1 Y D D A 

406-D-15 Product Dock No.1 MVR Loading** Y A A A

406-D-16 Product Dock No.2 MVR Loading** Y A A A

891-CP Coke Transfer and Storage Y A A A

a Source: The LA RH SIP submittal, Appendix G; ConocoPhillips Report. 

b Source: See Appendix B to this TSD. 

c Source: Consent Decree and First and Second Amendments to the Consent Decree, Civil Action No. H-05-0285, 

which are in the docket for this action. 

d “A” represents a proposed approval; “D” represents a proposed disapproval. 

*Appendix A of the First Amendment to the Consent Decree includes for Alliance “Low Pressure Flare (coker)” and 

“High Pressure Flare,” which may be the same as these units. 

**Appendix A of the First Amendment to the Consent Decree includes for Alliance “Marine Vapor Recovery Flare 

– 406 D-15” and “Marine Vapor Recovery Flare – 406 D-16.” However, the title for the units is shown as Product 

Dock No. 1 MVR Loading and Production Dock No. 2 MVR Loading in LA RH SIP Appendix G ConocoPhillips’ 

Appendix A table “List of BART-Eligible Units Included in BART Modeling.” It is unclear whether the CD 

addresses the subject to BART units identified by the same numbers. 

66 
BART Analysis Provided for ConocoPhillips Units

As mentioned above, the LDEQ provided a BART Engineering Analysis and Modeling 

Report for the ConocoPhillips Alliance Refinery in an attachment dated July 5, 2007 as part of 

Appendix G of its submittal (pp. 154 – 348). The report was provided by ConocoPhillips and 

includes analysis by Sage Environmental Consulting. 

Cooling Water Towers. The LDEQ provided analysis for PM for Cooling Water Tower (303-R1) as summarized below. The LDEQ did not provide BART analyses for NOX or SO2 for these 

sources, as emissions from these pollutants are minimal. As provided in Appendix A of 

ConocoPhillips’ report which is within the LA RH SIP Appendix G, the Cooling Water Tower 

No. 1 emissions for SO2 and NOX are as follows: 

EPN Description SO2

(lb/hr) 

NOX

(lb/hr) 

303-R-1 Cooling Water Tower No. 1 0.0000 0.0000 

Step 1- Identify All Available Retrofit Control Technologies: The LA RH SIP Appendix G 

identified the use of High Efficiency Drift Eliminator (HEDE) (high end), Drift Eliminator, and 

Good Operating Practices, as the only control options available for PM for the cooling water 

towers.

Step 2- Eliminate Technically Infeasible Options: None of the three control options is considered 

technically infeasible for the units in question. 

Step 3- Evaluate Control Effectiveness of Remaining Control Technologies: The LA RH SIP 

Appendix G determined that a HEDE (high end) would have a control effectiveness of 99.51%, 

followed by a HEDE with a control effectiveness of 95.09%, a Drift Eliminator (industry 

standard) with a control effectiveness of 75.47%, and finally Good Operating Practices. 

Step 4- Evaluate Impacts and Document the Results: The LA RH SIP Appendix G included an 

economic analysis for high end HEDEs and HEDEs using the EPA Air Pollution Control Cost 

Manual, Sixth Edition, 2002 (EPA/452/B-02-001), Chapter 3, Electrostatic Precipitators (ESP). 

Based on the analysis in Steps 1-4, the LA RH SIP Appendix G found that using drift 

eliminators, and HEDEs to control PM from the cooling towers ranged in cost effectiveness from 

$231,436 to $441,462/ton of PM removed. 

Step 5- Evaluate Visibility Impacts: The LA RH SIP Appendix G found that using drift 

eliminators and HEDEs to control PM from the cooling towers resulted in a visibility benefit 

that ranged from 0.165 to 0.173 dv. The LA RH SIP Appendix G concludes that, considering the 

cost and projected visibility benefits, neither control was cost effective. 

67 
Process Heaters. The LA RH SIP Appendix G provided analysis for NOX for these units as 

summarized below. The LDEQ did not provide BART analyses for SO2 and PM as emissions of 

this pollutant from these units are minimal. As provided in Appendix A of ConocoPhillips’ 

report which is within the LA RH SIP Appendix G, emissions of NOX for these units are as 

follows: 

Step 1- Identify All Available Retrofit Control Technologies: The LA RH SIP Appendix G 

identified use of Selective catalytic reduction (SCR), Ultra-low NOX burners (ULNB), Low NOX

burners (LNB), Flue gas recirculation (FGR), Selective non-catalytic reduction (SNCR), and 

Water injection as six control options available for NOX for the heaters.

Step 2- Eliminate Technically Infeasible Options: Both Flue gas recirculation and Water 

injection were found to have significant drawbacks and thus were determined to be technically 

infeasible. 

Drawbacks of LNB and SNCR were discussed, and a decision was made not to include either 

technology in the cost effectiveness evaluation for process heaters. 

The two technologies considered to be potentially applicable options for the process heaters 

subject to BART were ULNB and SCR. Neither of these two control options was considered 

technically infeasible for the units in question. 

Step 3- Evaluate Control Effectiveness of Remaining Control Technologies: The LA RH SIP 

Appendix G determined that the NOX control effectiveness for the technologies considered was 

as follows: ULNB and SCR together are the most effective, followed by ULNB alone, SCR 

alone, and then Good Operating Practices. 

Step 4- Evaluate Impacts and Document the Results: The LA RH SIP Appendix G provides an 

economic analysis for each of the technologies in Step 3 above (LA RH SIP Appendix G section 

3.2.3 and Table 3-5 of the ConocoPhillips BART Engineering Analysis). 

Step 5- Evaluate Visibility Impacts: The LA RH SIP Appendix G determined, and LDEQ agreed 

that, considering the estimated costs per delta deciview visibility improvement, using ULNB or 

SCR to control NOX from the process heaters is not cost effective for improving visibility (LA 

RH SIP Appendix G section 3.2.3 and Table 3-5 of the ConocoPhillips BART Engineering 

Analysis). 

Other Subject to BART Units 

As shown in the LA RH SIP Appendix G, the following units have low emissions: Product Dock 

No. 1 MVR Loading, Product Dock No. 2 MVR Loading, and Coke Transfer and Storage. See 

the LA RH SIP Appendix G for more information. Appendix A of the First Amendment to the 

Consent Decree includes for Alliance “Marine Vapor Recovery Flare – 406 D-15” and “Marine 

Vapor Recovery Flare – 406 D-16.” However, the title for the units is shown as Product Dock 

No. 1 MVR Loading and Production Dock No. 2 MVR Loading in LA RH SIP Appendix G 

ConocoPhillips’ Appendix A table “List of BART-Eligible Units Included in BART Modeling.” 

68 
It is unclear whether the CD addresses the subject to BART units identified by the same 

numbers. Please see TSD Appendix B for information about emissions from these units. 

b. Rhodia

The Rhodia Sulfuric Acid plant is located in Baton Rouge. The Rhodia Sulfuric Acid plant 

produces sulfuric acid by using two sulfuric acid production trains, Unit 1 and Unit 2. Unit 1 

was constructed in 1953, and at the time of the SIP submittal, had a production rate of 700 tons 

of sulfuric acid per day (700 tons sulfuric acid/day). Although Rhodia Unit 1 was constructed 

outside the dates for BART-eligibility, the LDEQ identified it as BART-eligible. Therefore, we 

treat it as BART-eligible and have included this unit in the subject-to-BART discussion in this 

section.39 We request comments on whether this unit should be treated as BART-eligible. Unit 2 

was constructed in 1968, and has a production rate of 1500 tons sulfuric acid/day. Therefore, 

Unit 2 is an “existing stationary facility” for purposes of BART eligibility, as defined in 40 CFR 

51.301. 

Effective July 23, 2007, the EPA, LDEQ and other parties entered into a CD with Rhodia 

requiring a scrubber to be installed on each of the units to control SO2 emissions.40 The BART 

engineering analysis assumed emission reductions that have since been mandated per the CD for 

Units 1 and 2. As stated above, without controls, the BART screening modeling for Rhodia 

showed a visibility impact at Breton of greater than 0.5 dv. Implementing control projects per 

the CD emissions reductions will result in reducing the overall site visibility impacts, and based 

on modeling with controls the LDEQ expects the visibility impairment from Rhodia to be below 

0.5 dv at Breton. The visibility improvements resulting from this CD are discussed below. 

However, the LDEQ did not submit a complete BART evaluation for these units. The submittal 

does not analyze controls for the units using the five steps as required by 40 CFR 51.308(e). In 

order to satisfy BART requirements for SO2, Louisiana must provide a BART analysis. The 

LDEQ may be able to find that the controls required under the CD are among the most stringent, 

and therefore, no additional controls would be required for these units to meet BART. 40 CFR 51 

Appendix Y.IV.D.1.9. Also, the emissions limits for Rhodia’s subject-to-BART units were not 

included in the RH SIP revision, so the LDEQ must include the BART emission limits in the RH 

SIP through a SIP revision.41 We propose to find that the BART determination for Rhodia is 

deficient at this time. 

The visibility impact due to NOX and PM emissions from Rhodia’s two subject-to-BART 

units is minimal; so, the potential visibility improvement from controls on these units is also 

minimal. For detailed information, see section IV.D.3.b of this TSD and TSD Appendix C. The 

installation of any additional controls would likely achieve negligible emissions reductions, have 

almost no visibility impact on Breton, and would not be cost-effective.37 We propose to find the 

LDEQ’s analysis for these pollutants is adequate to meet BART requirements.

 

39 We note it is possible for a source to have been constructed prior to the BART eligibility timeframe of August 7, 

1962 to August 7, 1977, but to have been reconstructed during that timeframe and thus still BART-eligible. 70 

FR 39159-60. 40 Civil Action No. 2:07CV134 WL. A copy of this CD is available in the docket for this rulemaking. 

41 CAA 169A(b)(2); 40 CFR 51.308(e); and 64 FR 35714, at 35741. 

69 
State Submittal Regarding Rhodia: Chapter 9 and Appendix G, pp. 138 – 153, including 

information for SO2 NOX and PM BART for Units 1 and 2 (Rhodia BART Engineering Analysis, 

letter dated June 11, 2007, Table 1) 

The LDEQ provided documentation about the Rhodia facility dated June 14, 2007 as part 

of Appendix G of its submittal: “Summary of CALPUFF BART screening Modeling Analysis 

for Rhodia Sulfuric Acid Plant.” The document was provided by Rhodia and includes analysis by 

Providence Engineering and Environmental Group, LLC (Providence). (LA RH SIP Chapter 9 

and Appendix G pp. 138 – 153). 

Unit 2 was constructed in 1968, and has a production rate of 1500 tons sulfuric acid/day. 

For Unit 2, the CD required a scrubber by January 1, 2011 and required a scrubber on 

Unit 1 by May 1, 2012. The scrubber on Unit 2 began operating in November 2010. The two 

scrubbers are projected to reduce emissions from these plants by approximately 94%, and 

generate several thousand tons per year of SO2 reductions. According to Rhodia, the 94% control 

efficiency modeled in the abated scenario corresponds to long-term (annual average) emission 

limits required by the CD: 1.9 pounds of SO2 emitted per ton of sulfuric acid produced (1.9 lb 

SO2 emitted/ton sulfuric acid produced) for Unit 1, and 2.2 lb SO2 emitted/ton of sulfuric acid 

produced for Unit 2. 

For SO2, the documentation provided focused on Screening Modeling and does not 

analyze controls for the units using the five steps as required by 40 CFR 51.308(e). 

In order to satisfy BART requirements for SO2, Louisiana must either provide a BART 

analysis, or find that the controls required under the CD are among the most stringent (40 CFR 

Part 51 Appendix Y(IV)(D)(1)(9) and 70 FR 39165). If the State were to address these 

requirements with a BART analysis, it is possible that some of the information in the existing 

documentation would be useful. Alternatively, if the State addresses these requirements by 

finding that the controls required under the CD are among the most stringent, then it will need to 

be consistent with the following (40 CFR Part 51 Appendix Y(IV)(D)(1)(9): 

 If you find that a BART source has controls already in place which are the most 

stringent controls available (note that this means that all possible improvements to 

any control devices have been made), then it is not necessary to comprehensively 

complete each following step of the BART analysis in this section. As long as 

these most stringent controls available are made federally enforceable for the 

purpose of implementing BART for that source, you may skip the remaining 

analyses in this section, including the visibility analysis in Step 5. Likewise, if a 

source commits to a BART determination that consists of the most stringent 

controls available, then there is no need to complete the remaining analyses in this 

section. 

Also, a unit’s BART emissions limits must be a part of the RH SIP, and therefore the 

LDEQ must include the BART emissions limits in the RH SIP through a SIP revision. 

c. Sid Richardson Carbon Company 

70 
The Sid Richardson Carbon Company is a subject-to-BART source located in West Baton 

Rouge Parish. For the subject-to-BART units at the Sid Richardson facility, Sid 

Richardson/LDEQ submitted a BART engineering analysis. For PM, the LDEQ determined that 

the high efficiency fabric filters already in use at the facility are BART. We propose to find that 

the state acted within its discretion in making this determination, and that the PM analyses 

provided by the LDEQ and Sid Richardson meet BART requirements. 

For NOX, the LA RH SIP Chapter 9 states that the Sid Richardson engineering analyses 

included the potential installation of NOX add-on controls, but it determined that all were 

infeasible (there were no demonstrated NOX scrubbing technologies at any carbon black plants). 

However, there is not sufficient information in the LA RH SIP submittal to support the BART 

analysis conclusion that no controls are feasible. We propose to find that the NOX BART 

determination for Sid Richardson is deficient at this time. 

For SO2, the LA RH SIP Chapter 9 states that the Sid Richardson engineering analyses 

included the potential installation of SO2 add-on controls, but it determined that all were 

infeasible (there were no demonstrated SO2 scrubbing technologies at any carbon black plants). 

However, Appendix G of the LA RH SIP submittal reflects that the SO2 evaluation for Sid 

Richardson considered four potential approaches and evaluated them for cost effectiveness: 

three add-on controls – caustic scrubbing, wet limestone scrubbing, and Haldor Topsoe’s SNOX 

process, which is a process that removes SO2, NOX and PM from flue gas; the fourth approach 

would be to limit the sulfur content of the feedstock oil.42 The SIP documentation does not 

reconcile the cost analyses provided with the corresponding conclusion of the technical 

infeasibility for these same control options. Based on the cost analysis provided, the installation 

and use of scrubbers to control emissions may be well within a range that is cost effective. Also, 

the LDEQ indicated that no controls were technically feasible, but the record does not provide a 

sufficient basis for this conclusion. There is not sufficient information in the LA RH SIP submittal 

to support the BART analysis conclusion that a scrubber, or other technology, is not feasible. 

For these reasons, we propose to find that the SO2 BART determination for Sid Richardson is 

deficient at this time. 

State Submittal Regarding SO2 and PM BART Determinations (natural gas): Chapter 9 and 

Appendix G, pp. 1 – 137 

The Sid Richardson Plant is located in Addis, West Baton Rouge Parish, approximately 

234 km from Breton. The LDEQ provided a BART Engineering Analysis for the Sid Richardson 

Carbon Company, (the Addis Plant) in a report dated June 13, 2007, which is included in the LA 

RH SIP as part of Appendix G (pp. 1 – 137). This report, which will be referred to hereafter as 

the “LA’s Sid Richardson BART Analysis”, was prepared for the Sid Richardson Carbon 

Company, Ltd., Fort Worth, Texas, by Environ International Corporation and includes analysis 

by Environ. The Sid Richardson plant operates three carbon black production process trains, 

designated Units 1, 2, and 3. The plant produces carbon black by the oil furnace process in the 

following steps: reaction, primary filtering, flaring, pelletizing, and drying. Each unit operates 

with four reactors per reactor train, as shown in Figure 2-3 of the Environ BART Analysis for 

Sid Richardson, Appendix G of the LA RH SIP. 

 

42 LA RH SIP submittal TSD Appendix G, Environ Report, pg 14. 

71 
As presented in section 3.2 of this same report (Environ BART Analysis for Sid 

Richardson, Appendix G of the LA RH SIP), the following units at Sid Richardson are subject to 

BART: 

• Reactors 1, 2, 3, 4, 5, 6, 7, 8, 9 10 and associated flares 

• Primary and secondary carbon black conveyance for Units 1, 2 and 3 

 (primary and secondary bag filters) 

• Dryers 2, 3, and 4 (Dryers 1, 5, and 6 are not BART eligible) 

• Dried carbon black conveyance for Dryers 2, 3, and 4. 

As shown in Table 3-1 of LA’s Sid Richardson BART Analysis, the primary pollutant 

from the Addis Plant is SO2, constituting more than 90% of emissions. For example, during the 

year 2002, which had the highest production of the period 2001-2003, the maximum 24-hour 

actual emissions rate were as follows: NOX, = 1,039 lb/day, PM10 = 1,752 lb/day, and SO2 = 

38,968 lb/day (NOX, = 190 ton/yr, PM10 = 320 ton/yr, and SO2 = 7,112 ton/yr). For the subjectto-BART units at the Sid Richardson facility, LDEQ submitted a BART engineering analysis, as 

provided in the LA RH SIP Chapter 9 and Appendix G.43 

For PM, the LA RH SIP Appendix G Sid Richardson BART analysis states that Sid 

Richardson currently employs fabric filters capable of a vendor guaranteed efficiency of 

99.923%. It reviewed other PM control technologies such as HEPA/ULPA filters, and wet 

scrubbing technologies and concluded those controls are infeasible due to their not having been 

proven at carbon black facilities. The LA RH SIP Appendix G concluded that PM BART is the 

current level of control provided by the existing fabric filters. The EPA does not take a position 

on the feasibility of these additional PM control technologies. However, we note the already high 

capture efficiency of the current fabric filters, and that most of the emissions at the Sid 

Richardson facility are SO2.

In the NOX and SO2evaluations provided in the LA RH SIP Appendix G, although not 

specifically stated, the LA RH SIP Appendix G appears to conclude that for the purpose of a 

BART determination, an undemonstrated technology is equivalent to a demonstration of 

technical infeasibility. We disagree with this conclusion and note that the BART Guidelines 

provide clarification: 

In general, a commercially available control option will be presumed applicable if 

it has been used on the same or a similar source type. Absent a showing of this 

type, you evaluate technical feasibility by examining the physical and chemical 

characteristics of the pollutant-bearing gas stream, and comparing them to the gas 

stream characteristics of the source types to which the technology had been 

applied previously. Deployment of the control technology on a new or existing 

source with similar gas stream characteristics is generally a sufficient basis for 

concluding the technology is technically feasible barring a demonstration to the 

contrary .... 

 

43 Best Available Retrofit Technology Analysis, Sid Richardson Carbon Company, Ltd., Addis, Louisiana, Plant, 

AI Number 4174, Prepared for: Sid Richardson Carbon Company, Ltd., Fort Worth, Texas. Prepared by: Steven 

H. Ramsey, Christopher J. Colville, ENVIRON International Corporation, May, 2007, Project No. 26-18167A. 

72 
The BART Guidelines further provide clarification concerning what could determine technical 

infeasibility. These include an evaluation of the characteristics of the pollutant-bearing gas 

stream and the capabilities of the technology, or a showing that there are unresolvable technical 

difficulties with applying the control to the source. No such showing was made. 

Sid Richardson operates three carbon black production process trains designated as Unit 

1, Unit 2, and Unit 3. These units produce carbon black by the oil furnace process in four steps: 

reaction, primary filtering and flaring, pelletizing, and drying. Each Unit operates with four 

reactors per reactor train, as shown in Figure 2-3 of the Environ BART Analysis for Sid 

Richardson, Appendix G of the LA RH SIP). 

A summary of the LA RH SIP Appendix G Sid Richardson BART analysis for PM, NOx 

and SO2 is presented below. Unless otherwise identified, LA RH SIP Appendix G is the source 

of quoted material. 

PM

Step 1- Identify All Available Retrofit Control Technologies: 

The LA RH SIP Appendix G considered the following control approaches for stationary sources 

of PM: mechanical separators, electrostatic precipitation, fabric filtration, wet scrubbing, high 

efficiency particle air (HEPA) filters and Ultra-Low Penetration Air (ULPA) filters. 

Step 2- Eliminate Technically Infeasible Options: 

“. . . Based on review of EPA’s [RACT BACT LAER] Clearinghouse and knowledge of current 

emission control practices in the carbon black manufacturing industry, it is our opinion that the 

Sid Richardson Addis Plant meets current BACT for the control of PM.” LA RH SIP Appendix 

G. 

NOX

Step 1- Identify All Available Retrofit Control Technologies: 

The LA RH SIP Appendix G considered various controls for two approaches for control of NOX

emissions: modifications to the combustion process (e.g., ULNB, over fire air) that prevent the 

formation of NOX, and post-combustion controls that remove NOX from the flue gas (SNCR and 

SCR), as well as Non-selective Catalytic Reduction (NSCR), and wet chemical scrubbers. 

Step 2- Eliminate Technically Infeasible Options: 

Reactors: The LA RH SIP Appendix G found that none of the options identified in Step 1 of the 

analysis are technically feasible. From pdf p. 16 of Appendix G: “. . . To the best of our 

knowledge, none of the identified potentially available combustion modification options have 

ever been employed in a carbon black reactor. For these reasons, implementing combustion 

modifications for the purpose of preventing the formation of NOX in the reactors is not 

considered to be technically feasible.” Also for SNCR, SCR, and NSCR, to the best of their 

knowledge, neither SNCR, SCR, nor NSCR has ever been used to control emissions from a 

carbon black reactor and therefore is not considered to be technically feasible. For the various 

adsorption and absorption processes identified by EPA to control NOX emissions, “Since the 

combustion gases are already in direct contact with the carbon black produced in the reactors, 

Sid Richardson is, in practice, already employing carbon adsorption to reduce NOX emissions” 

For the use of wet chemical scrubbers, . . . “It is our understanding that there are a limited 

number of industrial applications in actual operation and that there are no wet chemical scrubbers 

73 
in use at carbon black manufacturing facilities. Therefore, we are of the opinion that this is not a 

demonstrated technology for the control of NOX emissions from the reactors.” (p. 16 – 17, 

Appendix G). “We are of the opinion that the Sid Richardson Addis Plant reactors meet current 

Best Available Control Technology (BACT) for NOX. 

Flares. “There are no options currently available for the direct control or elimination of NOX

emissions resulting from the combustions of flare pilot gas . . . Sid Richardson’s flares meet 

current BACT.” 

Dryers: “To the best of our knowledge, none of the identified potentially available combustion 

modification options have ever been employed in a carbon black reactor. For these reasons, 

combustion modifications are not considered to be technically feasible for the control of NOX

emissions from the dryers.” Also for SNCR, SCR, and NSCR, to the best of their knowledge, 

none of these as ever been used to control emissions from a carbon black reactor and therefore 

are not considered to be technically feasible for the control of NOX emissions from the dryers. 

For the various adsorption and absorption processes identified by the EPA to control NOX

emissions, “We are not aware that adsorption and/or absorption processes have ever been used to 

control NOX emissions from rotary dryers are carbon black plants.” For the use of wet chemical 

scrubbers, . . . “there are a limited number of industrial applications in actual operation and that 

there are no wet chemical scrubbers in use at carbon black manufacturing facilities. Therefore, 

we are of the opinion that this is not a demonstrated technology for the control of NOX emissions 

from the reactors.” (p. 18, Appendix G). “We are of the opinion that the Sid Richardson Addis 

Plant dryers meet current BACT for NOX.” 

SO2: 

Step 1- Identify All Available Retrofit Control Technologies: 

The LA RH SIP Appendix G included an analysis for Best Available Control Technology 

(BACT) for SO2 in a permit application to LDEQ in January 2006, which it provided as 

Attachment C of its report. These SO2 controls included SCOSOx, Adsorption, Turbosonic 

adsorption, FLEXSORB, Regenerative gas desulfurization, H2S removal, limestone or caustic 

scrubbing, wet gas scrubbers, E-LIDS, Claus, SNOX, Sulferox, and flue gas deacidification. 

Step 2- Eliminate Technically Infeasible Options: 

Sulfur removal technologies and a summary of their technical feasibility were provided in Table 

3.3-3 of the LA RH SIP Appendix G (p. 130 of 348). 

The above referenced BACT analysis makes the following statement regarding the 

technical feasibility of SO2 controls:44

The only control techniques determined to be technically feasible were the 

limiting of feedstock sulfur content or the installation of the following add-on 

control devices: 

• an adsorption process by Selective Adsorption Associates, Inc., 

 

44 Ibid., pdf page 137. 

74 
• the DynaWave System using limestone or caustic scrubbing material by 

Monsanto-Envirochem, and 

• the SNOX sulfur recovery/conversion process by Haldor Topsoe. 

For SO2, the LA RH SIP Appendix G determined that, “[t]he Sid Richardson Company’s 

... engineering analysis included the potential installation of ... SO2 add-on controls but deemed 

that all were infeasible (there were no demonstrated ... SO2 technologies at any carbon black 

plants). No work standard or practice was proposed nor does the department believe a work 

standard or practice is available.”45 However, in our review we found that Sid Richardson’s 

BART analysis included a January 2006 PSD BACT evaluation to support its discussion of 

potential retrofit controls for its subject to BART emissions units.46 As presented within that 

2006 BACT evaluation by Sid Richardson, four potential approaches were considered and 

evaluated for cost effectiveness: three add-on controls – caustic scrubbing, wet limestone 

scrubbing, and Haldor Topsoe’s SNOX process, which is a process that removes SO2, NOX and 

PM from flue gas. The Sid Richardson’ 2006 BACT evaluation determined that add-on SO2

controls have not been considered BACT for carbon black plants and no carbon black plant in 

the U.S. has installed add-on SO2 controls; therefore they are considered undemonstrated. The 

fourth approach would be to limit the sulfur content of the feedstock oil. As explained in the LA 

RH SIP submittal, “[t]he conclusion of the BACT analysis is that limiting the sulfur content of 

the feedstock oil is the only technically and economically feasible option. That limitation is 

already reflected in the Addis Plant emission limits.”47 

Step 3- Evaluate Control Effectiveness of Remaining Control Technologies: 

The techniques determined to be technically feasible were 

a) The limiting of feedstock sulfur content, or 

The installation of add-on control devices: 

b) An adsorption process (Selective Adsorption) 

c) Limestone or caustic scrubbing (DynaWave) 

d) SNOX sulfur recovery/conversion process (Haldor Topsoe) 

All three add-on control technologies could achieve at least 95% reduction in SO2 (postcombustion.) We note that the control effectiveness of limiting the feedstock sulfur content is 

provided in Appendix G, Sid Richardson, Table 3.3-4. 

Step 4- Evaluate Impacts and Document the Results: 

The BACT analysis referenced above presented cost data for caustic scrubbing, limestone 

scrubbing, and SNOX controls ranging from $479 to $1,560 per ton of SO2 removed. The LA 

RH SIP Appendix G found that the capital cost of installing scrubbers was $4.3 – 4.6 million. 

This corresponded to an annual cost-effectiveness for caustic scrubbing of $1,020/ SO2 ton 

removed for and to a cost-effectiveness for limestone scrubbing of $479/ SO2 ton removed. 

More specifically, the LA RH SIP Appendix G provided cost information for the 

following control techniques: 

 

45 Page 53 of the Louisiana Regional Haze SIP. 46 Attachment C to the Sid Richardson BART analysis. 47 LA RH SIP submittal TSD Appendix G, Environ Report, pg 14. 

75 
a) The limiting of feedstock sulfur content ($2,418 per ton SO2 produced); 

The installation of add-on control devices: 

b) Adsorption process ($3 million per day) 

c) Limestone or caustic scrubbing 

(capital cost of installation 4.3 – 4.6 million, and also disposal costs); 

Caustic: $1,020 per ton (annual cost); Limestone: $479 per ton 

d) SNOX sulfur recovery/conversion process (Haldor Topsoe) $1,560 per ton. 

Step 5- Evaluate Visibility Impacts: 

The LA RH SIP Appendix G did not evaluate the visibility impacts of those control 

options considered in Step four of the BART analysis, and did not compare the visibility 

improvements resulting from use of the control systems. 

D.5. De Minimis BART: 40 CFR 51.308(e)(1)(ii)(C) 

A determination of BART is required for each BART-eligible source in Louisiana that 

emits any air pollutant which may reasonably be anticipated to cause or contribute to any 

impairment of visibility in any mandatory Class I Federal area. All such sources are subject to 

BART. Louisiana is not required to make a determination of BART for SO2 or for NOX if a 

BART-eligible source has the potential to emit less than 40 tpy of such pollutant(s), or for PM10

if a BART-eligible source has the potential to emit less than 15 tpy of such pollutant. We find 

that this requirement is not applicable to the LA RH SIP at this time. This provision may be reconsidered upon receipt of all BART analyses from LDEQ. 

D.6. Design, Equipment, or Work Practice BART: 40 CFR 51.308(e)(1)(iii) 

 If Louisiana determines in establishing BART that technological or economic limitations 

on the applicability of measurement methodology to a particular source would make the 

imposition of an emission standard infeasible, it may instead prescribe a design, equipment, work 

practice, or other operational standard, or combination thereof, to require the application of 

BART. Such standard, to the degree possible, is to set forth the emission reduction to be 

achieved by implementation of such design, equipment, work practice or operation, and must 

provide for compliance by means which achieve equivalent results. Because LDEQ did not 

specifically require any design, equipment, or work practice BART at any BART-eligible 

facilities at the time of its June 13, 2007 submittal, we find that this requirement is not applicable 

to the LA RH SIP at this time. This provision may be re-considered upon receipt of all BART 

analyses from LDEQ. 

D.7. Installation of BART: 40 CFR 51.308(e)(1)(iv) – (v) 

 Each source subject to BART must (1) install and operate BART as expeditiously as 

practicable, but in no event later than 5 years after approval of the SIP revision, and (2) maintain 

the control equipment required by this subpart and establish procedures to ensure such 

equipment is properly operated and maintained. We will re-evaluate this requirement upon 

receipt of all BART analyses from LDEQ. 

D.8. CAIR for BART: 40 CFR 51.308(e)(2)-(4) 

This is discussed primarily in section I above. 

76 
D.9. Reasonable Progress and BART: 40 CFR 51.308(e)(5) 

 After a state has met the requirements for BART or implemented emissions trading 

program or other alternative measure that achieves more reasonable progress than the installation 

and operation of BART, BART-eligible sources will be subject to the requirements of paragraph 

(d) of this section in the same manner as other sources. We will re-evaluate this requirement 

upon receipt of all BART analyses from LDEQ. 

D.10. BART Exemptions: 40 CFR 51.308(e)(6) 

 Any BART-eligible facility subject to the requirement under paragraph (e) of this section 

to install, operate, and maintain BART, may apply to the Administrator for an exemption from 

that requirement. An application for an exemption will be subject to the requirements of 40 CFR 

51.303(a)(2)–(h). We will re-evaluate this requirement upon receipt of all BART analyses from 

LDEQ. 

E. Long-Term Strategy 

As described in section III.E of this action, the LTS is a compilation of state-specific 

control measures relied on by the state for achieving its RPGs. Louisiana’s LTS for the first 

implementation period addresses the emissions reductions from federal, state, and local controls 

that take effect in the state from the end of the baseline period starting in 2004 until 2018. The 

Louisiana LTS was developed by the LDEQ, in coordination with the CENRAP RPO, through an 

evaluation of the following components: (1) construction of a CENRAP 2002 baseline emission 

inventory (EI); (2) construction of a CENRAP 2018 EI, including reductions from the CENRAP 

member state controls required or expected under federal and state regulations, (including 

BART); (3) modeling to determine visibility improvement and apportion individual state 

contributions; (4) state consultation; and (5) application of the LTS factors. 

Louisiana, as with each State listed in 40 CFR 51.300(b)(3), must submit a LTS that 

addresses regional haze visibility impairment for each mandatory Class I Federal area within the 

state and for each mandatory Class I Federal area located outside the state which may be affected 

by emissions from within the state. The long-term strategy must include enforceable emissions 

limitations, compliance schedules, and other measures as necessary to achieve the reasonable 

progress goals established by States having mandatory Federal Class I areas. 

1. Emissions Inventories 40 CFR 51.308(d)(3)(iii) – (iv) 

40 CFR 51.308(d)(3)(iii) requires that Louisiana document the technical basis, including 

modeling, monitoring and emissions information, on which it relied upon to determine its 

apportionment of emission reduction obligations necessary for achieving reasonable progress in 

each mandatory Class I Federal area it affects. Louisiana must identify the baseline emissions 

inventory on which its strategies are based. 40 CFR 51.308(d)(3)(iv) requires that Louisiana 

identify all anthropogenic sources of visibility impairment considered by the state in developing 

its long-term strategy. This includes major and minor stationary sources, mobile sources, and 

area sources. Louisiana met these requirements by relying on technical analyses developed by its 

RPO, CENRAP, and approved by all state participants, as described below. 

The EI used in the RH technical analyses was developed by the CENRAP with assistance 

from Louisiana. The LDEQ provided a statewide EI for 2002, representing the mid-point of the 

77 
2000-2004 baseline period, and a projected EI for 2018, the end of the first 10-year planning 

period. The 2018 EI is based on visibility modeling conducted by the CENRAP. The 2018 EI was 

developed by projecting 2002 emissions and applying reductions expected from federal and state 

regulations affecting the emissions of the visibility-impairing pollutants NOX, PM, SO2, and 

VOCs. 

State Submittal: Chapter 7 Emission Inventory, Chapter 8 Modeling Assessment, and Chapter 6 

Monitoring 

40 CFR 51.308(d)(3)(iii) requires that Louisiana document the technical basis, including 

modeling, monitoring and emissions information, on which it relied to determine its 

apportionment of emission reduction obligations necessary for achieving reasonable progress in 

each mandatory Class I Federal area it affects. It may meet this requirement by relying on 

technical analyses developed by the regional planning organization and approved by all State 

participants. Louisiana must identify the baseline EI on which its strategies are based. The 

baseline EI year is presumed to be the most recent year of the consolidated periodic EI. 40 CFR 

51.308(d)(3)(iv) requires that Louisiana identify all anthropogenic sources of visibility 

impairment considered by the state in developing its long-term strategy. This includes major and 

minor stationary sources, mobile sources, and area sources. Louisiana met these requirements by 

relying on technical analyses developed by its RPO, CENRAP, and approved by all state 

participants, as described below. 

We find that Louisiana has adequately documented the technical basis, including 

modeling, monitoring, and emissions information, on which it relied upon to determine its 

apportionment of emission reduction obligations necessary for achieving reasonable progress in 

each mandatory Class I federal area it affects.48 We also find that Louisiana has adequately 

identified all anthropogenic sources of visibility impairment it considered in developing its LTS. 

We therefore propose to find that Louisiana has satisfied the requirements under 40 CFR 

51.308(d)(3)(iii) – (iv). 

The following discussion of EIs for the 2002 base and 2018 future year, 2002 and 2018 

photochemical modeling results, and our review of the results is a brief summary of the work 

that was done and our conclusions. For a more detailed discussion of the technical analyses 

including the photochemical modeling and our review and conclusions concerning what 

pollutants are causing regional haze in Breton, see TSD Appendix A. 

Emissions Inventory, Chapter 7

 The LDEQ developed the 2002 EI used for the regional haze technical analyses using 

estimates for four general categories of emissions sources: point, non-point, on-road mobile, and 

non-road mobile. For point sources, the LDEQ used the EPA’s 2002 biogenic source EI and 

completed the 2002 point source inventory with emission inventory reports which were provided 

by facilities following state and federal guidelines (utilizing AP-42 or other approved methods). 

For nonpoint sources, the LDEQ used in the regional haze technical analyses was developed by 

E.H. Pechan & Associates, Inc. through the CENRAP (see LA RH SIP, Appendix D). On-road 

mobile sources were estimated using the EPA’s MOBILE6.2 motor vehicle emissions factor 

model. Non-road mobile emissions data was derived from the “Emission Inventory Development 

 

48 A detailed evaluation of the 2002 and 2018 EIs and the CENRAP visibility projection modeling, as well as a 

discussion of what pollutants are driving regional haze in Breton are found in TSD Appendix A. 

78 
for Mobile Sources and Agricultural Dust Sources for the Central States” produced by Sonoma 

Technology, Inc. for the CENRAP in October 2004 using the EPA’s non-road emissions factor 

model, NONROAD 2004. Additional information about the LDEQ’s EI development for 2002 is 

provided in the section “Louisiana 2002 Emission Inventory” below. 

The 2018 EI was developed by projecting 2002 emissions using growth and control 

factors derived from the EGAS6, MOBILE6, and NONROAD models and applying reductions 

expected from federal and state regulations affecting the emissions of the visibility-impairing 

pollutants NOX, PM, SO2, and VOCs. The Integrated Planning Model (IPM) was used to forecast 

2018 electric generating unit (EGU) emissions. The RHR directs states to exercise judgment in 

deciding whether VOCs and NH3 impair visibility in their 22 Class I area(s). 70 FR 39104, at 

39160. As discussed in section III.F.1 below, Louisiana decided to not consider VOCs and 

ammonia among visibility-impairing pollutants for several reasons: 1) “an overwhelming 

majority of light extinction due to SO4 caused by SO2 emissions; 2) VOC emissions are currently 

addressed by the state in LAC 33:III.Chapter 21 Control of Emission of Organic Compounds; 

and 3) Ammonia emissions are addressed through the Louisiana Toxic Air Pollutant Emission 

Control Program LAC 33:III.Chapter 51 (see the LA RH SIP, Chapter 9, p. 36 for additional 

information). 

a. Louisiana’s 2002 Emission Inventory 

The LDEQ and the CENRAP developed an EI for four inventory source classifications: 

point, area, non-road and on-road mobile sources for the baseline year of 2002. Louisiana’s 

2002 EI provides estimates of annual emissions for haze producing pollutants by source 

category as summarized in Table 11, based on information in Chapter 7 of Louisiana’s RH SIP. 

Table 11. Louisiana 2002 Emissions Inventory (tons/year) 

SO2 NH3 NOX VOCs PM10 PM2.5

Point 286,050 9,237 312,634 89,025 73,333 60,899

Area 81,153 75,381 99,060 124,311 245,162 84,068

Non-road 

mobile

14,324 563 117,250 109,598 10,663 9,791

On-road 

mobile

4,653 3,748 15,137 64,643 3,563 2,689

Total 386,180 88,929 544,081 387,577 332,721 157,447

See below for details on how the 2002 EI was constructed. The EPA approved the 2002 

EI on September 3, 2009 (74 FR 45561). We are proposing to find that Louisiana’s 2002 EI is 

acceptable for the purpose of developing the LTS. 

 The source of data in Table 11 is the 2002 Base Year Inventory / Pechan (LA RH SIP 

Table 7.1) 

Louisiana relied on several sources of information in developing the 2002 EI. For the 

baseline year 2002, the LDEQ developed the 2002 point source EI using emissions data provided 

by facilities, as well as the biogenic source inventory developed by the EPA. EI data for two 

inventory source categories, non-point sources and non-road mobile sources were provided by 

79 
contractors to the CENRAP. On-road mobile source emissions were estimated using the EPA’s 

MOBILE 6.2 motor vehicle emissions factor model. 

Non-point Sources. The nonpoint, or area source, inventory includes emitters of ozone 

pollutants (i.e., NOX and VOCs), including sources that combust fuel (e.g., dry cleaners, 

degreasing, and industrial surface coating), as well as others such as gasoline distribution, asphalt 

paving, and fires and open burning (e.g., agricultural burning, structural fires, wildfires, 

prescribed burning). In addition, area source categories contributing to visibility pollutants (i.e., 

PM10, PM2.5, and NH3) are also included in the area source EI (e.g., fugitive dust, agricultural 

operations, livestock ammonia, etc.). The contractor reviewed all emission factors used in the 

inventory to ensure they were the most appropriate and up-to-date emission factors available and 

checked all calculations for accuracy. 

On-road Mobile Sources. The 2002 on-road mobile source emissions included emissions 

from vehicles certified for highway use. Emissions from these sources were estimated by 

combining EPA emission factors from the MOBILE6.2 model, expressed in grams per mile 

(g/mile), with vehicle miles traveled (VMT) activity data. County-level Highway Performance 

Monitoring System (HPMS) VMT data from the annual U.S. Highways Statistics Report 

(Section V) were used for all Louisiana counties. MOBILE6.2 emission factors were used in 

combination with the VMT data to estimate emissions by roadway type and vehicle type and 

vehicle class. 

Non-road Mobile Sources. The 2002 nonroad mobile source emissions encompassed a 

wide variety of equipment types that moved or were moved within a 12-month period and are 

covered under the EPA’s emissions regulations as nonroad mobile sources. The EPA’s 

NONROAD2004 model version was used to estimate emissions for most nonroad sources. The 

NONROAD2004 model estimated emissions from non-road equipment in the following 

categories: agricultural equipment, airport ground support, construction equipment, industrial 

and commercial equipment, residential and commercial lawn and garden equipment, logging 

equipment, recreational equipment, and recreational marine vessels. Aircraft, commercial 

marine, and locomotive emissions were estimated separately and were also included in the nonroad inventory. 

Biogenic Emission Sources. Biogenic emissions were prepared with the SMOKE-BEIS3 

(Sparse Matrix Operator Kernel Emission – Biogenic Emission Inventory System 3 version 0.9) 

preprocessor, which is a modified version of the Urban Air shed Model. The emission factors 

that are used in SMOKE-BEIS3 are the same as the emission factors as in the Biogenic 

Emissions Landcover Database version 3 (BELD3) provided by the EPA. A separate land 

classification scheme, based upon satellite (AVHRR, 1 km spatial resolution) and census 

information, aided in fining the forest, agriculture and urban portions of each county. For a full 

discussion of the EIs, see Chapter 2 of the LA TSD Appendix B. 

Point Sources. For purposes of the EI, point sources are defined as stationary commercial 

or industrial operations that emit 100 tpy or more of VOC or NOX, or lower thresholds in a 

nonattainment area. The LDEQ compiles a statewide EI for point sources on an annual basis. 

The reporting requirements for the nonattainment area are in accordance with those of the CAA 

80 
Amendments of 1990. Emissions data provided by the facilities are estimates of actual emissions 

for the facility during the previous calendar year. Estimation methodologies are required to 

follow state and federal guidelines utilizing AP-42 or other approved methods. Actual testing or 

measurement data must be substituted if available. Each facility meeting the emissions criteria 

submitted complete EI reports which contain site-specific data in conformance with EPA 

guidance for ozone maintenance areas. 

b. Louisiana’s 2018 Emission Inventory 

In constructing Louisiana’s 2018 EI, the LDEQ used a combination of our Economic 

Growth Analysis System (EGAS 6), our mobile emissions factor model (MOBILE 6), our off-road 

emissions factor model (NONROAD), and the Integrated Planning Model (IPM) for electric 

generating units. The CENRAP developed emissions for five inventory source classifications: 

point, area, non-road and on-road mobile sources, and biogenic sources. The CENRAP used the 

2002 EI, described above, to estimate emissions in 2018. All control strategies expected to take 

effect prior to 2018 are included in the projected EI. Louisiana’s 2018 EI provides estimates of 

annual emissions for haze producing pollutants by source category as summarized in Table 12, 

based on information in Chapter 7 of the Louisiana RH SIP. 

Table 12. Louisiana’s 2018 Emissions Inventory 

SO2 NH3 NOX VOCs PM10 PM2.5

Point 354,087 14,435 269,215 187,741 73,136 60,899

Area 87,538 36,896 114,374 117,600 16,936 14,536

Non-road 

mobile 11,584 72 106,685 64,294 8,670 7,955

On-road 

mobile 561 5,436 44,806 30,340 1,191 1,191

Total 453,770 56,839 535,080 399,975 99,933 84,581

The CENRAP and LDEQ used this and other states’ 2018 EIs to construct visibility 

projection modeling for 2018. We are proposing to find that Louisiana’s 2018 EI is acceptable. 

The source of data in Table 12 is the 2018 Base Year Inventory / Pechan (LA RH SIP 

Table 7.2) 

As mentioned above, in developing emissions for five inventory source classifications, 

the CENRAP used the 2002 EI to estimate emissions in 2018. The CENRAP contractors 

compiled the growth and control assumptions and factors used to estimate point-source 

emissions in 2018 from the EI for 2002. This included EGUs, internal combustion engines and 

other non-EGU point sources. The CENRAP states provided data for the area source and nonroad mobile EI for 2018, to which a CENRAP contractor applied area source growth and control 

factors. These control factors accounted for federal standards for commercial marine vessels and 

locomotives. For the remaining non-road mobile categories, the contractor ran our 

NONROAD2004 model for 2018. This accounted for estimated growth in equipment populations 

and incorporated anticipated effects of most final federal standards, including the Tier 4 

compression-ignition engine standards and the exhaust emissions standards for large spark81 
ignition engines, compression-ignition marine engines, and land-based recreational engines. The 

LDEQ and the CENRAP also developed the on-road mobile source EI for 2018 with contractor 

support. Biogenic emissions were held constant from the 2002 EI. Louisiana’s 2018 EI is 

summarized in Table 12. 

2. Visibility Projection Modeling 

The CENRAP performed modeling for the RH LTS for its member states, including 

Louisiana. The modeling analysis is a complex technical evaluation that began with selection of 

the modeling system. The CENRAP used (1) the Mesoscale Meteorological Model (MM5) 

meteorological model, (2) the Sparse Matrix Operator Kernel Emissions (SMOKE) modeling 

system to generate hourly gridded speciated emission inputs, (3) the Community Multiscale Air 

Quality (CMAQ) photochemical grid model and (4) the Comprehensive Air Quality model with 

extensions (CAMx), as a secondary corroborative model. The CAMx was also utilized with its 

Particulate Source Apportionment Technology (PSAT) tool to provide source apportionment for 

both the baseline and future case visibility modeling. 

The photochemical modeling of RH for the CENRAP states for 2002 and 2018 was 

conducted on the 36-km resolution national regional planning organization domain that covered 

the continental U.S., portions of Canada and Mexico, and portions of the Atlantic and Pacific 

Oceans along the east and west coasts. The CENRAP states’ modeling was developed consistent 

with our guidance.49

 The CENRAP examined the model performance of the regional modeling for the areas of 

interest before determining whether the CMAQ model results were suitable for use in the RH 

assessment of the LTS and for use in the modeling assessment. The 2002 modeling efforts were 

used to evaluate air quality/visibility modeling for a historical episode—in this case, for 

calendar year 2002—to demonstrate the suitability of the modeling systems for subsequent 

planning, sensitivity, and emissions control strategy modeling. Model performance evaluation is 

performed by comparing output from model simulations with ambient air quality data for the 

same time period to determine whether the model’s performance is sufficiently accurate to justify 

using the model for simulating future conditions. Once the CENRAP determined the model 

performance to be acceptable, it used the model to determine the 2018 RPGs using the current 

and future year air quality modeling predictions, and compared the RPGs to the URP. The 

results of the CENRAP’s visibility projection modeling are discussed in the section that follows. 

We are proposing to find that Louisiana’s visibility projection modeling is acceptable.

Chapter 8 of the Louisiana Regional Haze SIP discusses modeling for PM and visibility, 

including the modeling methods and protocol used by the CENRAP and the LDEQ in developing 

the PM and visibility modeling assessment. Sections 8.1 and 8.2 describe the baseline EI used by 

the CENRAP in the Louisiana analysis. A detailed description and discussion of the model 

selection, modeling protocol, quality assurance, performance evaluation, EI development and 

data used in the regional haze analysis can be found in Appendix B of the LA RH SIP and 

references therein. A short summary is provided below: 

 

49 Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for 

Ozone, PM2.5, and Regional Haze, (EPA-454/B-07-002), April 2007, located at 

http://www.epa.gov/scram001/guidance/guide/final-03-pm-rh-guidance.pdf. Emissions Inventory Guidance for 

Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and 

Regional Haze Regulations, August 2005, updated November 2005 (“our Modeling Guidance”), located at 

http://www.epa.gov/ttnchie1/eidocs/eiguid/index.html, EPA-454/R-05-001. 

82 
 The CENRAP performed modeling for the regional haze LTS for its member states, 

including Louisiana. The modeling analysis is a complex technical evaluation that began with 

selection of the modeling system. The CENRAP used the following modeling system: 

• Meteorological Model: The Pennsylvania State University/National Center for 

Atmospheric Research (PSU/NCAR) Mesoscale Meteorological Model (MM5) is a 

nonhydrostatic, prognostic meteorological model routinely used for urban- and regionalscale photochemical, PM2.5, and regional haze regulatory modeling studies. 

• Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) modeling 

system is an emissions modeling system that generates hourly gridded speciated emission 

inputs of mobile, non-road mobile, area, point, fire and biogenic emission sources for 

photochemical grid models. 

• Air Quality Model: The EPA’s Models-3/ CMAQ modeling system is a photochemical 

grid model capable of addressing ozone, PM, visibility and acid deposition at a regional 

scale. The photochemical model selected for this study was CMAQ version 4.5. It was 

modified by the CENRAP with a module for Secondary Organics Aerosols (SOA) in an 

open and transparent manner that was also subjected to outside peer review. The CAMx 

Version 4.40 model, applied using similar options as used by CMAQ, was used as a 

secondary corroborative model. CAMx was also utilized with its PSAT tool to provide 

source apportionment of predicted nitrate and sulfate aerosol concentrations. 

 The CMAQ and CAMx modeling of regional haze in the CENRAP region for 2002 and 

2018 was carried out on a grid of 36x36 kilometer (km) cells that covers the continental United 

States, portions of Canada and Mexico, and portions of the Atlantic and Pacific Oceans along the 

east and west coasts. Selection of a representative period of meteorology is crucial for evaluating 

baseline air quality conditions and projecting future changes in air quality due to changes in 

emissions of visibility-impairing pollutants. The CENRAP conducted an in-depth analysis which 

resulted in the selection of the entire year of 2002 (January 1-December 31) as the best period of 

meteorology available for conducting the modeling. The CENRAP modeling was developed 

consistent with our guidance.50

 The CENRAP examined the model performance of the regional modeling for the areas of 

interest before determining whether the CMAQ model results were suitable for use in the 

regional haze assessment of the LTS and for use in the modeling assessment. The modeling 

assessment predicts future levels of emissions and visibility impairment used to support the LTS 

and to compare predicted, modeled visibility levels with those on the URP. In keeping with the 

objective of the CMAQ modeling platform, the air quality model performance was evaluated 

using graphical and statistical assessments based on ambient measurements of PM species, 

 

50 “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for 

Ozone, PM2.5, and Regional Haze,”(EPA-454/B-07-002), April 2007, located at 

http://www.epa.gov/scram001/guidance/guide/final-03-pm-rh-guidance.pdf 

83 

See also “Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air 

Quality Standards (NAAQS) and Regional Haze Regulations,” August 2005, updated November 2005 (“our 

Modeling Guidance”), located at http://www.epa.gov/ttnchie1/eidocs/eiguid/index.html, EPA-454/R-05-001 
gas-phase species and wet deposition from various monitoring networks and databases for the 

2002 base year. The CENRAP used a diverse set of statistical parameters from our Modeling 

Guidance to stress and examine the model and modeling inputs. Once the CENRAP determined 

the model performance to be acceptable, the CENRAP used the model to assess the 2018 RPGs 

using the current and future year air quality modeling predictions, and compared the RPGs to the 

URP. 

 The CENRAP modeling shows that Louisiana sources are projected to have contributions 

to the Class I areas in Louisiana, Oklahoma (Wichita Mountains), Arkansas (Caney Creek), and 

Texas. The contribution from Louisiana sources to Breton Class I area accounted for 15.75% of 

the visibility impairment in 2002, and is projected to account for 24.67% in 2018. Also, the 

contribution from Louisiana sources to the Wichita Mountains Class I area in Oklahoma, 

accounted for 3.47 % of the visibility impairment at Wichita Mountains in 2002 and is projected 

to account for 4.83% in 2018. Similarly, the contribution from Louisiana sources to the Caney 

Creek Class I area in Arkansas, accounted for 2.86 % of the visibility impairment at Caney Creek 

in 2002 and is projected to account for 4.83% in 2018. Louisiana is also projected to contribute a 

small amount of visibility degradation at Class I areas in other states listed in Table 13. Table 13 

summarizes the projected contribution from Louisiana emissions on visibility degradation at 9 

Class I areas for the 20 percent worst days in 2002 and 2018, as modeled by the CENRAP.51 The 

CENRAP PSAT tool, which is included in the docket, allows for browsing through the model 

results in a number of different ways. 

3. Sources of Visibility Impairment 

Where Louisiana causes or contributes to impairment in a mandatory Class I Federal 

area, it must demonstrate that it has included in its SIP all measures necessary to obtain its 

share of the emission reductions needed to meet the progress goal for the area. If Louisiana has 

participated in a regional planning process, it must ensure it has included all measures needed 

to achieve its apportionment of emission reduction obligations agreed upon through that 

process. 

40 CFR 51.308(d)(3)(ii) requires that, “Where other states cause or contribute to 

impairment in a . . . Class I area, the state must demonstrate that it has included . . . all measures 

necessary to obtain its share of the emissions reductions needed to meet the progress goal for the 

area. 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 through that process.” 

 The CENRAP used CAMx with its PSAT tool to provide source apportionment by 

geographic region and major source category. The pollutants causing the highest levels of light 

extinction are associated with the sources causing the most visibility impairment. 

a. Sources of Visibility Impairment in the Breton Class I Area 

Visibility impairment at Breton in 2002 on the worst 20% days is primarily (69%) due to 

point source emissions that contribute 77.7 inverse megameters52 (Mm-1) of the total extinction 

 

51 See the LA RH SIP, Appendix B, and within that Appendix E of the TSD for CENRAP Emissions and Air 

Quality Modeling to Support Regional Haze State Implementation. 52 An inverse megameter is the direct measurement unit for visibility impairment data. It is the amount of light 

scattered and absorbed as it travels over a distance of one million meters. Deciviews (dv) can be calculated from 

extinction data as follows: dv = 10 x ln (bext(Mm-1)/10). 

84 
of 122.1 Mm-1. The largest contributions come from inside the state. In 2018, point sources 

continue to contribute the most to visibility impairment at Breton, even though this contribution 

has decreased substantially. “The top five contributing source groups to 2018 visibility 

impairment at [Breton] for the worst 20 percent days are: Louisiana Elevated Point Sources; 

Boundary Conditions;53 East Elevated Point Sources; Gulf of Mexico Area Sources; and 

Louisiana Area Sources. Gulf of Mexico Area sources include off shore shipping and oil and gas 

development emissions.”54 We are proposing to find that Louisiana’s identification of sources of 

visibility impairment for the Breton Class I area is acceptable. 

b. Louisiana’s Contribution to Visibility Impairment in Class I Areas Outside the State 

Table 13 shows the CENRAP CAMx and PSAT modeled contributions (in percentage of 

visibility impacts) to total extinction at all Class I areas from Louisiana sources for 2002 and 

2018, respectively. The CAMx PSAT results were utilized to evaluate the impact of Louisiana 

emission sources in 2002 and 2018 on visibility impairment at Class I areas outside of the state. 

Table 13. Percent Contribution from Louisiana Emissions to Total Visibility Impairment 

at Class I areas on 20% Worst Days 

Class I area State 2002 2018

Breton 

 (BRET1) Louisiana 15.75 24.67 

Wichita Mountains 

 (WIMO1) Oklahoma 3.47 4.83 

Caney Creek 

(CACR1) Arkansas 2.86 4.23 

Big Bend NP 

(BIBE1) Texas 2.79 3.32 

Upper Buffalo Wilderness 

(UPBU1) Arkansas 1.80 2.71 

Hercules Glades Wilderness 

(HEGL1) Missouri 1.71 2.43 

Guadalupe Mountains NP 

(GUMO1) Texas 1.32 1.57 

 

53 “Boundary Conditions” means “the assumed concentrations along the later edges of the 36 km modeling domain.” 

LA RH SIP submittal Appendix B, Environ Report, p. 1-16. 54 LA RH SIP submittal Appendix B, Environ Report, p. 5-18. 

85 
White Mountain Wilderness 

(WHIT1) 

New 

Mexico 1.28 1.44 

Sipsey Wilderness 

(SIPS1) Alabama 0.96 1.78 

Salt Creek 

(SACR1) 

New 

Mexico 0.93 1.07 

Mammoth Cave NP 

(MACA1) Kentucky 0.67 1.19 

Seney 

(SENE1) Michigan 0.54 0.77 

Bosque del Apache 

(BOAP1) 

New 

Mexico 0.42 0.48 

Great Smoky Mountains NP 

(GRSM1) Tennessee 0.40 0.83 

Isle Royale NP 

(ISLE1) Michigan 0.39 0.49 

Badlands NP 

(BADL1) 

South 

Dakota 0.36 0.41 

Cadiz 

(CADI1) Kentucky 0.34 0.59 

Gila Wilderness 

(GICL1) 

New 

Mexico 0.30 0.37 

Bondville 

(BOND1) Illinois 0.27 0.41 

Mingo 

(MING1) Missouri 0.22 0.33 

Bandelier 

(BAND1) 

New 

Mexico 0.21 0.24 

San Pedro Parks 

(SAPE1) 

New 

Mexico 0.20 0.22 

Wind Cave NP 

(WICA1) 

South 

Dakota 0.14 0.16 

86 
Wheeler Peak Wilderness 

(WHPE1) 

New 

Mexico 0.14 0.16 

As shown in the Table above, the largest contribution from Louisiana sources is at the Wichita 

Mountains Class I area in Oklahoma in both 2002 and 2018. Louisiana is also projected to 

contribute a small amount of visibility degradation at Class I areas in other states as listed in 

Table 13. This table summarizes the projected contribution from Louisiana’s emissions on 

visibility degradation to Class I areas for the 20 percent worst days in 2002 and 2018, as 

modeled by the CENRAP.55, 56 We are proposing to find that Louisiana’s identification of 

sources of visibility impairment for Class I areas outside the state is acceptable. 

4. Consultation for Other State’s Class I Areas

The LDEQ used the CENRAP as its main vehicle for facilitating collaboration with FLMs 

and other states in the CENRAP, and the VISTAS for other states outside the CENRAP to satisfy 

its LTS consultation requirement. This helped the LDEQ and other state agencies analyze 

emission apportionments at Class I areas and develop coordinated RH SIP strategies. 

40 CFR 51.308(d)(3)(i) requires that Louisiana consult with other states if its emissions 

are reasonably anticipated to contribute to visibility impairment at that state’s Class I area(s), 

and that Louisiana consult with other states if those states’ emissions are reasonably anticipated 

to contribute to visibility impairment at Breton NWA. The LDEQ’s consultations with other 

states are described in section IV.C.3 of this action. The CENRAP visibility modeling 

demonstrates Louisiana sources are responsible for a visibility extinction of approximately 3.5 

Mm-1 at Caney Creek on the worst 20% days for 2002.26 The LDEQ consulted with Arkansas as 

well as Oklahoma, Texas, Mississippi, Alabama, and Florida whose emissions have a potential 

visibility impact at Breton. We are proposing to find that the LDEQ’s consultations satisfy the 

requirements under 40 CFR 51.308(d)(3)(i). 

State Submittal: Chapters 10 and 11 

 The LDEQ consulted with other States/Tribes in the CENRAP and VISTAS RPOs as a 

primary vehicle for facilitating collaboration with FLMs and other states in satisfying its LTS 

consultation requirement. Louisiana’s consultations with other states are discussed in section 

III.B.5 of this TSD. In addition to Louisiana, the LDEQ determined that Arkansas, Missouri, 

Oklahoma, and Texas contribute to visibility impairment at Breton and consulted with those 

states. The LDEQ also determined that in addition to impacting visibility at its own Class I area, 

sources in Louisiana also have a visibility impact at other Class I areas. Consistent with this, the 

LDEQ participated in consultations for Class I areas in Oklahoma including the Wichita 

Mountains Wilderness Area, Arkansas, Missouri, and Texas. The CENRAP visibility modeling 

demonstrates Louisiana sources are responsible for a relatively small visibility extinction at Class 

I areas other Breton. For more information about the contribution of facilities in Louisiana to 

visibility impairment in other states, see Table 13. Percent Contribution from Louisiana 

Emissions to Total Visibility Impairment at Class I areas on 20% Worst Days in section 

 

55 See TSD Appendix A for the CENRAP Emissions and Air Quality Modeling to Support Regional Haze State 

Implementation, as well as Appendix B of the LA RH SIP. 56 See TSD Appendix A for the CENRAP Emissions and Air Quality Modeling to Support Regional Haze State 

Implementation, as well as Appendix B of the LA RH SIP. 

87 
IV.E.3.a.above. Also, in consulting with VISTAS, the LDEQ consulted with Mississippi, 

Alabama, and Florida, all areas included in the Area of Influence for Breton identified by the 

CENRAP for Breton (see Appendix I). 

5. Mandatory Long Term Strategy Factors 

40 CFR 51.308(d)(3)(v) requires that Louisiana consider certain factors in developing its 

long-term strategy (the LTS factors). These include: (a) emission reductions due to ongoing air 

pollution control programs, including measures to address RAVI; (b) measures to mitigate the 

impacts of construction activities; (c) emissions limitations and schedules for compliance to 

achieve the reasonable progress goal; (d) source retirement and replacement schedules; (e) 

smoke management techniques for agricultural and forestry management purposes including 

plans as currently exist within the state for these purposes; (f) enforceability of emissions 

limitations and control measures; and (g) the anticipated net effect on visibility due to projected 

changes in point, area, and mobile source emissions over the period addressed by the long-term 

strategy. For the reasons outlined below, we are proposing to find that Louisiana has satisfied 

some, but not all of the requirements of 40 CFR 51.308(d)(3)(v). Also, Louisiana will have to 

consider whether EGUs previously covered by the CAIR, whether subject to BART or not, should 

be controlled to ensure reasonable progress. 

a. Reductions Due to Ongoing Air Pollution Programs 

In addition to its BART determinations, Louisiana’s LTS incorporates emission 

reductions due to a number of ongoing air pollution control programs. 

The LDEQ considered the Tier 2 Vehicle Emission Standards in developing its LTS. 

Federal Tier 2 Vehicle Emission Standards for passenger cars and light trucks were fully 

implemented in 2009 and similar rules for heavy trucks were also implemented by 2009. These 

federal standards will result in reductions of emissions of PM, ozone precursors, and nonmethane organic compounds. In developing its LTS, the LDEQ also considered the Highway 

Diesel and Nonroad Diesel Rules, which mandated the use of lower sulfur fuels in diesel engines 

beginning in 2006 for highway diesel fuel, and 2007 for non-road diesel fuel. These federal rules 

have resulted in more effective control of PM emissions from diesel engines by allowing the 

installation of control devices that were technically infeasible for fuels with higher sulfur 

content. In addition, the state will rely on federal consent decrees and implementation of the 

2008 ozone standard. 

As noted in the EPA’s separate notice proposing revisions to the RHR (76 FR 82219) a 

number of states, including Louisiana, fully consistent with the EPA’s regulations at the time, 

relied on the trading programs of the CAIR to satisfy the BART requirement and the requirement 

for a long-term strategy sufficient to achieve the state-adopted reasonable progress goals. In that 

notice, we proposed a limited disapproval of Louisiana’s long-term strategy and, for that reason, 

we are not taking action on the long-term strategy in our proposal insofar as Louisiana’s RH 

SIP relied on the CAIR. The docket for that rulemaking is available at Docket ID No. EPA-HQOAR-2011-0729. Louisiana’s LTS is also deficient because it relied on deficient non-EGU BART 

determinations as discussed in section IV.D of this action. 

In developing its LTS, Louisiana considered a number of pollution control programs 

required under federal regulations. These include the EPA’s CAIR, which was expected to 

reduce Louisiana’s emissions of NOX by 39,000 tons and to reduce Louisiana’s SO2 emissions 

88 
by 43,000 tons by 2015 (from 2003 levels); the federal Tier 2 Vehicle Emission Standards for 

passenger cars and light trucks, which were fully implemented in 2007, and similar rules for 

heavy trucks that were scheduled to be implemented by 2009; and the Highway Diesel and 

Nonroad Diesel Rules, which mandate the use of lower sulfur fuels in diesel engines beginning 

in 2006 for highway diesel fuel, and 2007 for nonroad diesel fuel. These federal rules have 

resulted in more effective control of PM emissions from diesel engines by allowing the 

installation of control devices that were technically infeasible for fuels with higher sulfur 

content. Also, Louisiana considered National VOC Emission Standards for the following 

categories: Automobile Refinish Coatings (63 FR 48806), Consumer Products (63 FR 48819), 

Architectural Coatings (63 FR 48848), as well as several federal consent decrees, and the 2008 

Ozone Standard. 

Section 51.308(d)(3)(v)(A) also requires that Louisiana consider measures to address 

reasonably attributable visibility impairment (RAVI) in developing its LTS. Louisiana submitted 

a Part I Visibility Plan on October 9, 1985 that we approved on June 10, 1986 (51 FR 20967). 

The Louisiana SIP revision, “Protection of Visibility, Proposed Part II – Long Term Strategy,” 

was approved by us on December 19, 1988 (53 FR 50958). The approved SIP met the 

requirements of 40 CFR 51.302 and 51.306. The FLMs did not identify any integral vistas in 

Louisiana. In addition, the Breton Class I area is not affected by RAVI, nor are any Louisiana 

sources affected by the RAVI provisions. Therefore, the Louisiana RH SIP does not incorporate 

any measures to specifically address RAVI. 

b. Measures to Mitigate the Impacts of Construction Activities 

40 CFR 51.308(d)(3)(v)(B) requires that Louisiana consider measures to mitigate the 

impacts of construction activities in developing its LTS. Construction-related activities are 

believed to be a small contributor to fine and coarse particulates in Louisiana. The LDEQ notes 

that Louisiana may require visibility monitoring in any Class I area where preconstruction and 

post-construction of any new source or major modification may have an adverse impact on 

visibility in any Class I area (LAC 33:III.504.E.3.b). In spite of a great deal of construction 

activity from the recovery from Hurricanes Katrina and Rita, no measurable impacts on visibility 

have been monitored from this activity. We are proposing to find that Louisiana satisfies this 

component of LTS. 

Emergency Orders were issued that allowed for repair of facilities from the hurricanes; 

however these orders stopped short of allowing complete replacement of emissions units. If new 

equipment was necessary, owners/operators were required to go through the normal permitting 

process. 

c. Emissions Limitations and Schedules of Compliance 

40 CFR 51.308(d)(3)(v)(C) requires that in developing its LTS, Louisiana consider 

emissions limitations and schedules of compliance to achieve the RPGs. As discussed in section 

IV.D.3 of this proposal, the SIP does not yet contain emission limits and schedules of compliance 

for those sources subject to BART. The BART emission limits established by the LDEQ are an 

element of the LTS, and because we are proposing to find that the relevant portion of the 

LDEQ’s BART determinations are deficient, we propose to find that this element of the LTS does 

not satisfy the federal requirements. 

89 
This includes enforceable emissions limitations and compliance schedules for recently 

adopted rulemakings, administrative orders, the issuance and enforcement of permits limiting 

emissions from major sources in Louisiana, state rules which specifically limit targeted 

emissions sources and categories, and several other ongoing air pollution control programs. The 

LDEQ has promulgated rules in order to administer these programs, as discussed in Chapter 11 

of the LA RH SIP, especially in section 11.4. 

We note that the LDEQ implements an air permitting program that includes the issuance 

of permits to all known major point sources in Louisiana. Each permit contains enforceable 

limitations on emissions of various pollutants, some of which may cause or contribute to regional 

haze at Breton. 

d. Source Retirement and Replacement Schedules 

40 CFR 51.308(d)(3)(v)(D) requires that Louisiana consider source retirement and 

replacement schedules in developing its LTS. The LDEQ adequately addressed how it considered 

source retirement and replacement schedules in the development of its LTS. Louisiana’s LTS 

includes the promulgation of new rules for retrofit technology for existing equipment to meet 

requirements for new NAAQS, which will also provide visibility benefits. We are proposing to 

find that the LDEQ properly addressed the requirements of 40 CFR 51.308(d)(3)(v)(D) in the 

development of its LTS. 

 

State Submittal: Chapter 11 

The LDEQ stated the statutory factor of the remaining useful life of the sources is 

applicable only to those measures which would require retrofitting of control devices at existing 

sources. Louisiana’s long-term strategy does not include the promulgation of new rules for 

visibility alone that would cause the retrofitting of control devices at this time. (Chapter 11, p. 

67). 

 

90 
e. Agricultural and Forestry Smoke Management Techniques 

40 CFR 51.308(d)(3)(v)(E) requires that Louisiana consider smoke management 

techniques for agricultural and forestry management purposes in developing its LTS. Where 

smoke impacts from fire are identified as an important contributor to regional haze, smoke 

management programs should be a key component of regional and State regional haze planning 

efforts and long-term strategies (64 FR 35736). 

The EPA encourages the development of smoke management programs between air 

regulators and land managers as a means to manage the impacts of wildland and prescribed 

burning. The sources of information described above, as well as other developmental efforts 

currently underway, provide effective, flexible approaches to smoke management. The LDEQ 

considered smoke management techniques for the purposes of agricultural and forestry 

management in its LTS. Chapter 13 of Title 33 of the LAC contains a general prohibition on 

“open burning of refuse, garbage, trade waste, or other waste material.” Although the LDEQ 

does not have the jurisdiction or authority to make any rule, regulation, recommendations, or 

determination with respect to agricultural burning or controlled burns of pastureland, 

marshland, or timberland, the Louisiana Department of Agriculture and Forestry (LDAF) does 

have the authority. The LDAF, in consultation with the LDEQ, is working to develop a SMP that 

includes measures that can be taken to reduce residual smoke from burning activities as well as 

a process to evaluate potential smoke impacts at sensitive receptors and guidelines for 

scheduling fires such that exposure of sensitive populations is minimized and visibility impacts in 

Class I areas are reduced. Because visibility impacts from smoke are significant in Louisiana, 

we propose to find that Louisiana should finalize its SMP. 

State Submittal: Chapter 11 

LDEQ states in section 11-4: 

According to the Louisiana Environmental Quality Act (La. R.S. 30:2054(B)(2)), the 

Louisiana Department of Environmental Quality does not have the jurisdiction or 

authority to make any rule, regulation, recommendations, or determination with 

respect to the following: 

Burning of agricultural by-products in the field in connection with the planting, 

harvesting, or processing of agricultural products. 

Controlled burning of cotton gin agricultural wastes in connection with cotton gin 

operations. 

Controlled burning in connection with timber stand management. 

Controlled burning of pastureland or marshland in connection with trapping or 

livestock production. 

Both the Louisiana Department of Agriculture and Forestry and the Louisiana State 

University Ag Center have Smoke Management Guidelines. 

91 
It appears from an examination of Figure 2-6 on page 2-41 of Appendix B57 of the 

Louisiana SIP that area fire contributes to approximately 35% of the total annual PM2.5 emissions 

for Louisiana. We consider this to be a significant contribution to the State’s PM2.5 EI. As we 

noted in comments we sent to the LDEQ on its draft RH SIP,58 there does not appear to be data 

presented in the SIP that directly relates the influence of area sources of fire to the visibility 

impacts at Breton. In order to investigate the incidence of fire from biomass burning in 

Louisiana, we drew upon the NASA Fire Information for Resource Management System 

(FIRMS) database, which is constructed using satellite remote sensing data.59 We overlaid this 

data with cropland data obtained from the U.S. Department of Agriculture’s National 

Agricultural Statistics Service (NASS) for 2009,60 which incorporates the National Land Cover 

Database, and plotted the result on a background image of the State of Louisiana that we 

obtained from the Louisiana State University.61 All work was accomplished using ArcGIS 9.3.1 

software. 

The results of those maps appear in TSD Appendix E. These maps provide insight as to 

the incidence of biomass burning. As can be seen, biomass burning is prevalent in Louisiana. 

This includes burning associated with cropland (especially sugarcane), pasture and grassland; 

forest and shrubland; and marsh areas. 

We note that both the LDAF and the Louisiana State University Agricultural Center have 

Smoke Management Guidelines. The LDEQ is working with the LDAF to develop a SMP for 

Louisiana. We appreciate the progress that has been made, and we will continue to work with 

Louisiana as they develop their SMP. 

f. Enforceability of Emissions Limitations and Control Measures 

40 CFR 51.308(d)(3)(v)(F) requires that Louisiana ensure the enforceability of emission 

limitations and control measures used to meet reasonable progress goals. The SIP does not yet 

contain emission limits and schedules of compliance for those EGU sources, if any, subject to 

SO2 BART. Also, Louisiana’s LTS is deficient because it relied on deficient non-EGU BART 

determinations as discussed in section IV.D of the proposed action. The emissions limits for 

these subject-to-BART sources were not included in the LA RH SIP.62 Therefore, we are 

proposing to find that the LDEQ has not fully satisfied the requirements of 40 CFR 

51.308(d)(3)(v)(F) in the development of its LTS. 

State Submittal: Chapter 11 

We note that in Chapter 11 of the LA RH SIP, LDEQ acknowledges that Louisiana is 

required to ensure that all emission limitations and control measures used to meet RPGs are 

enforceable (51.308(d)(3)(v)(F) 

 

57 TSD for the CENRAP Emissions and Air Quality Modeling to Support Regional Haze State Implementation 

Plans. 58 Letter from Mr. Guy Donaldson to Mr. James Orgeron, dated 1/31/08. 

59 FIRMS was developed by the University of Maryland with funding from NASA. 

http://firefly.geog.umd.edu/firms 60 Website: http://www.nass.usda.gov/research/Cropland/SARS1a.htm 61 LandSat Image (2005). Published by the USGS EROS Data Center and obtained from Louisiana State 

University. 62 CAA 169A(b)(2); 40 CFR 51.308(e); and 64 FR 35714, at 35741. 

92 
g. Anticipated Net Effect on Visibility Due to Projected Changes 

40 CFR 51.308(d)(3)(v)(G) requires that in developing its LTS, Louisiana consider the 

anticipated net effect on visibility due to projected changes in point, area, and mobile source 

emissions over the period addressed by the long-term strategy. In developing its RH SIP, the 

LDEQ relied on the CENRAP’s 2018 modeling projections, which show that net visibility is 

expected to improve by 3.22 dv at Breton NWA. The CENRAP’s 2018 modeling projections 

account for changes in point, area, and on-road and non-road mobile emissions. The results of 

the CENRAP’s 2018 modeling projections are discussed in sections IV.E.2 and IV.E.3 of this 

proposed rulemaking. We are proposing to find that Louisiana satisfies this component of LTS. 

The results of the CENRAP’s 2018 modeling projections are discussed in TSD Appendix 

A. 

F. Coordination of RAVI and Regional Haze Requirements

Our visibility regulations direct states to coordinate their RAVI LTS and monitoring 

provisions with those for RH, as explained in section III of the proposal. Under our RAVI 

regulations, the RAVI portion of a state SIP must address any integral vistas identified by the 

FLMs pursuant to 40 CFR 51.304. See, 40 CFR 51.302. An integral vista is defined in 40 CFR 

51.301 as a “view perceived from within the mandatory Class I Federal area of a specific 

landmark or panorama located outside the boundary of the mandatory Class I Federal area.” 

Visibility in any mandatory Class I Federal area includes any integral vista associated with that 

area. The FLMs for Breton have not identified any reasonably attributable visibility impairment 

(i.e., RAVI) from Louisiana or other U.S. sources. The FLMs for the Class I areas that 

Louisiana’s emissions impact in other states have not identified any reasonably attributable 

visibility impairment caused by Louisiana sources. For these reasons, the Louisiana RH SIP 

does not have any measures in place or a requirement to address RAVI. We propose to find that 

this requirement is not applicable to the LA RH SIP at this time. This provision may be reconsidered upon receipt of submittals from the LDEQ for subsequent implementation periods. 

G. Monitoring Strategy and Other SIP Requirements 

40 CFR 51.308(d)(4) requires the SIP contain a monitoring strategy for measuring, 

characterizing, and reporting of RH visibility impairment that is representative of all mandatory 

Class I Federal areas within the state. This monitoring strategy must be coordinated with the 

monitoring strategy required in 40 CFR 51.305 for reasonably attributable visibility impairment. 

As 40 CFR 51.308(d)(4) notes, compliance with this requirement may be met through 

participation in the IMPROVE network. This TSD discusses the IMPROVE network. We are 

proposing to find that the LDEQ has satisfied this requirement. 

40 CFR 51.308(d)(4)(i) requires the establishment of any additional monitoring sites or 

equipment needed to assess whether reasonable progress goals to address RH for all mandatory 

Class I Federal areas within the state are being achieved. The CENRAP monitoring workgroup 

noted there was a visibility void in Southern Arkansas. An IMPROVE protocol monitor was 

located in north central Louisiana. PM2.5 measurements from the Louisiana monitoring network 

help the LDEQ to characterize air pollution levels in areas across the state and therefore aid in 

the analysis of visibility improvement in and near the Class I areas. The LDEQ also commits in 

the Louisiana RH SIP to consider alternative approaches to evaluating visibility monitoring 

93 
obligations if that becomes necessary. We are proposing to find that the LDEQ has satisfied this 

requirement. 

40 CFR 51.308(d)(4)(ii) requires that the LDEQ establish procedures by which 

monitoring data and other information are used in determining the contribution of emissions 

from within Louisiana to RH visibility impairment at mandatory Class I Federal areas both 

within and outside the state. The monitor at Breton was owned and operated by the USFWS. 

After this monitor was destroyed by Hurricane Katrina in 2005, the monitor was replaced and 

relocated nearby, by the USFWS, at Lake Catherine in St. Bernard Parish. The IMPROVE 

monitoring program is national in scope, and other states have similar monitoring and data 

reporting procedures, ensuring a consistent and robust monitoring data collection system. As 40 

CFR 51.308(d)(4) indicates, participation in the IMPROVE program constitutes compliance with 

this requirement. We are therefore proposing that the LDEQ has satisfied this requirement. 

40 CFR 51.308(d)(4)(iv) requires that the SIP must provide for the reporting of all 

visibility monitoring data to the Administrator at least annually for each mandatory Class I 

Federal area in the state. To the extent possible, Louisiana should report visibility monitoring 

data electronically. 40 CFR 51.308(d)(4)(vi) also requires that the LDEQ provide for other 

elements, including reporting, recordkeeping, and other measures, necessary to assess and 

report on visibility. We are proposing that Louisiana’s participation in the IMPROVE network 

ensures the monitoring data is reported at least annually, is easily accessible, and therefore 

complies with this requirement. 

40 CFR 51.308(d)(4)(v) requires that the LDEQ maintain a statewide EI of pollutants 

that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory 

Class I Federal area. The inventory must include emissions for a baseline year, emissions for the 

most recent year for which data are available, and estimates of future projected emissions. The 

State must also include a commitment to update the EIs periodically. Please refer to section IV.E 

of the proposal, where we discuss the LDEQ’s EI. The LDEQ has stated that it intends to update 

the Louisiana statewide EIs periodically. We are proposing to find that this satisfies the 

requirement in 40 CFR 51.308(d)(4)(v). 

State Submittal: Chapter 6: Monitoring Strategy and Chapter 7 Emission Inventory 

The primary monitoring network for regional haze, both nationwide and in Louisiana is 

the IMPROVE network. Louisiana intends to satisfy the monitoring requirements of Section 

51.308(d)(4) through its participation in the IMPROVE monitoring network. This network is 

maintained through a cooperative measurement effort governed by a steering committee 

composed of representatives from Federal and regional-state organizations. As was true of the 

Breton monitor, the Lake Catherine monitor is owned and operated by the USFWS . Data 

produced by the IMPROVE monitoring network will be used by the LDEQ for preparing the 5-

year progress reports and the 10-year SIP revisions. 

 40 CFR 51.308(d)(4): As 40 CFR 51.308(d)(4) notes, compliance with this requirement 

may be met through participation in the IMPROVE network, which applies to the Breton 

monitor, as well as the new monitor at Lake Catherine. (As discussed in Section III.C.1 

Calculation of Baseline Conditions, data from the Gulfport SEARCH monitoring site was used 

as well.) The LDEQ stated its intention to rely on the IMPROVE network for complying with the 

regional haze monitoring requirement in our RHR for the current and future regional haze 

implementation periods. The primary monitoring network for regional haze in the CENRAP is 

94 
the IMPROVE network. FLMs responsible for Class I areas joined us in 1985 in response to the 

1977 CAA Amendments to form the IMPROVE Program. The IMPROVE Steering Committee 

consists of representatives from the FLMs, the EPA, and regional-state agencies. At the direction 

of the National Park Service, the Cooperative Institute for Research in the Atmosphere, at 

Colorado State University’s Foothills Campus in Fort Collins, Colorado, maintains the network 

plan on the IMPROVE Internet Web site.63 The primary objectives of the IMPROVE Web site 

are to provide federal, state, and air quality regulatory agencies as well as the general public 

access to IMPROVE data, data products, and metadata fully describing the IMPROVE database, 

including characteristics and history of all network sites. The Web site allows users to query 

data, review reports, and communicate with different members of the IMPROVE Program. 

 40 CFR 51.308(d)(4)(i): Toward the end of the year 2000, the Breton area IMPROVE 

monitor was added to the monitoring network. After being destroyed during Hurricane Katrina in 

2005, the Breton monitor was replaced and relocated to a site near Lake Catherine in St. Bernard 

Parish, Louisiana. Should the new monitor at Lake Catherine become inoperable or be shut 

down, Louisiana, in consultation with the EPA and the USFWS, will develop an alternative 

approach for meeting its visibility monitoring obligation, which may include seeking 

contingency funding for alternative monitoring and the reporting of that data. 

 40 CFR 51.308(d)(4)(ii): The IMPROVE program makes data available on the Internet 

via the site noted above and submits it to our air quality system. This information is used to 

characterize the visibility at Breton and assess Louisiana’s progress toward its RPGs. The 

IMPROVE monitoring program is national in scope, and other states have similar monitoring 

and data reporting procedures, ensuring a consistent and robust monitoring data collection 

system. 

40 CFR 51.308(d)(4)(iii): For a State with no mandatory Class I Federal areas, 

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 

mandatory Class I Federal areas in other States. This requirement is not applicable to Louisiana 

because Louisiana has a Class I area. 

 40 CFR 51.308(d)(4)(iv): To the extent possible, Louisiana should report visibility 

monitoring data electronically. 40 CFR 51.308(d)(4)(vi) also requires that the LDEQ provide for 

other elements, including reporting, recordkeeping, and other measures, necessary to assess and 

report on visibility. Again, Louisiana’s participation in the IMPROVE network ensures the 

monitoring data is reported at least annually and is available for download from the site 

referenced above. 

 40 CFR 51.308(d)(4)(v): The EI must include emissions for a baseline year, emissions for 

the most recent year for which data are available, and estimates of future projected emissions. 

The State must also include a commitment to update the EI periodically. Please refer to section 

III.D.3, above, where we discuss how the LDEQ has constructed its EI. The LDEQ has stated in 

Chapter 7, section 7.7, p. 26, of its RH SIP submittal that it intends to update the Louisiana 

statewide EIs periodically. 

H. Coordination with Federal Land Managers 

Breton NWA is a federally protected wilderness area for which the USFWS is the FLM. 

Although the FLMs are very active in participating in the RPOs, the RHR grants the FLMs a 

special role in the review of the RH SIPs, summarized in section III.H of the proposal. We view 

 

63 Please see http://vista.cira.colostate.edu/improve/. 

95 
both the FLMs and the state agencies as our partners in the RH process. 

40 CFR 51.308(i)(1) requires that by November 29, 1999, Louisiana must have identified 

in writing to the FLMs the title of the official to which the FLM of Breton can submit any 

recommendations on the implementation of 40 CFR 51.308. We acknowledge this section has 

been satisfied by all states via communication prior to this SIP. 

Under 40 CFR 51.308(i)(2), Louisiana was obligated to provide the USFWS with an 

opportunity for consultation, in person and at least 60 days prior to holding a public hearing on 

its RH SIP. In practice, state agencies have usually provided all FLMs – the Forest Service, the 

Park Service, and the USFWS, copies of their proposed RH SIP, as the FLMs collectively have 

reviewed these RH SIPs. The LDEQ followed this practice and proposed this implementation 

plan revision for public comment on November 20, 2007 and notified the federal land manager 

staff of the public hearing held on January 24 2008. 

40 CFR 51.308(i)(3) requires that the LDEQ provide in its RH SIP a description of how 

it addressed any comments provided by the FLMs. The LDEQ has provided that information in 

Appendix A of its RH SIP. 

Lastly, 40 CFR 51.308(i)(4) specifies the RH SIP must provide procedures for continuing 

consultation between the state and FLM on the implementation of the visibility protection 

program required by 40 CFR 51.308, including development and review of implementation plan 

revisions and 5-year progress reports, and on the implementation of other programs having the 

potential to contribute to impairment of visibility in the mandatory Class I Federal areas. The 

LDEQ has stipulated in its RH SIP it will continue to coordinate and consult with the FLMs as 

required by 40 CFR 51.308(i)(4). The LDEQ states it intends to consult the FLMs in the 

development of future progress reports and plan revisions, as well as during the implementation 

of programs having the potential to contribute to visibility impairment at Breton NWA. We are 

proposing to find that the LDEQ has satisfied 40 CFR 51.308(i). 

State Submittal: Chapter 4, and Chapter 10, Section 10.3 

I. Periodic SIP Revisions and Five-year Progress Reports 

The LDEQ affirmed its commitment to complete items required in the future under our 

RHR. The LDEQ acknowledged its requirement under 40 CFR 51.308(f), to submit periodic 

progress reports and RH SIP revisions, with the first report due by July 31, 2018 and every ten 

years thereafter. 

The LDEQ also acknowledged its requirement under 40 CFR 51.308(g), to submit a 

progress report in the form of a SIP revision to us every five years following this initial submittal 

of the Louisiana RH SIP. The report will evaluate the progress made towards the RPGs for each 

mandatory Class I area located within Louisiana and in each mandatory Class I area located 

outside Louisiana which may be affected by emissions from within Louisiana. We are proposing 

to find that the LDEQ has satisfied 40 CFR 51.308(f) and (g). 

State Submittal: The LDEQ acknowledged this requirement in Chapter 12, page 69 of its RH 

SIP 

J. Determination of the Adequacy of Existing Implementation Plan 

40 CFR 51.308(h) requires that Louisiana take one of the listed actions, as appropriate, 

at the same time the State is required to submit any 5-year progress report to the EPA in 

96 
97 

accordance with 40 CFR 51.308(g). The LDEQ has committed in its SIP to take one of the 

actions listed under 40 CFR 51.308(h), depending on the findings of the five-year progress 

report. We are proposing to find that the LDEQ has satisfied 40 CFR 51.308(h). 

State Submittal: The LDEQ acknowledged this requirement in Chapter 12, page 69 of its RH 

SIP submittal. The LDEQ stated it intends to use the findings of the five-year progress report 

required under 40 CFR 51.308(g) to make a determination regarding the adequacy of this RH 

SIP and take an appropriate action based upon the requirements of Section 51.308(h).