REVISIONS TO THE STATE IMPLEMENTATION PLAN (SIP) 

CONCERNING REGIONAL HAZE 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

P.O. BOX 13087 

AUSTIN, TEXAS 78711-3087 

PROJECT NO. 2007-016-SIP-NR 

Proposed

December 5, 2007

Adopted 

February 25, 2009 
SECTION VI. CONTROL STRATEGY 

A. Introduction (No change.) 

B. Ozone (No change.) 

C. Particulate Matter (No change.) 

D. Carbon Monoxide (No change.) 

E. Lead (No change.) 

F. Oxides of Nitrogen (No change.) 

G. Sulfur Dioxide (No change.) 

H. Conformity with the National Ambient Air Quality Standards (No change.) 

I. Site Specific (No change.) 

J. Mobile Source Strategies (No change.) 

K. Clean Air Interstate Rule (No change.) 

L. Transport (Proposed.) 

M. Regional Haze (New.) 
ES-1 

EXECUTIVE SUMMARY 

The Federal Clean Air Act (FCAA) and United States Environmental Protection Agency (EPA)

regulations require states to submit State Implementation Plan (SIPs) to make “reasonable 

progress” in reducing visibility impairment at Federal Class I Federal areas resulting from 

anthropogenic pollution. FCAA, 169A(a)(1), “declares as a national goal the prevention of any 

future, and the remedying of any existing impairment of visibility in mandatory Federal Class I 

Federal areas which impairment results from man-made air pollution.” Class I areas are national 

parks over 6,000 acres and wilderness areas over 5,000 acres that Congress has recognized at 

significant sites. These SIPs must “contain such emission limits, schedules of compliance and 

other measures as may be necessary to make reasonable progress toward meeting the national 

goal” including requiring installation, operation, and maintenance of Best Available Retrofit 

Technology (BART), “as determined by the State” on certain existing stationary sources. 

The EPA Regional Haze Rule strongly encourages states to work together in regional 

partnerships to reduce haze. There are five regional planning organizations in the United States. 

Texas is a member of the Central Regional Air Planning Association (CENRAP), which includes 

nine states, Texas, Louisiana, Oklahoma, Arkansas, Kansas, Missouri, Nebraska, Iowa, and 

Minnesota. CENRAP provides analysis, modeling results, and informational exchange among 

states, but each state submits its own regional haze SIP. 

The FCAA, Section 169A and B require the EPA to adopt regulations to reduce visibility 

impairment resulting “from man-made air pollution” in 156 Federal Class I Federal areas. The 

regulations require each state SIP to contain control measures, including BART, to make 

reasonable progress toward the national goal of natural visibility conditions by 2064 in all Class I 

areas. The two Class I areas in Texas are Big Bend and Guadalupe Mountains National Parks. 

Each state bordering Texas has one or more Federal Class I Federal areas designated for visibility 

protection. Where Texas’ emissions impact visibility in Federal Class I Federal areas in other 

states, the Texas SIP must include plans to reduce Texas’ visibility impacts in those areas too. 

The EPA adopted Regional Haze regulations in 40 Code of Federal Regulations (CFR) Part 51, 

subpart P, on July 1, 1999, and adopted amendments to Subpart P and a new Appendix Y (BART 

guidelines) to Part 51 on July 6, 2005. 

The 1990 FCAA Amendments together with EPA’s Regional Haze Rule set the goal of reducing 

“man-made” impacts on visibility in Class I areas to zero (i.e., to “natural” conditions) by 2064 

for the worst 20 percent visibility days and preventing any degradation for the best 20 percent 

visibility days. CENRAP and other Regional Air Planning Organizations have cooperated to 

calculate the base period (2000-2004) worst 20 percent and best 20 percent visibility for each 

Class I area. CENRAP is contracting has developed projections of visibility impairment in 2018, 

the initial year for which each state’s long-term strategy is to be evaluated. The state must reduce 

its visibility impairment impact at all Class I areas it impacts by as much as is reasonable. The 

format of this SIP revision follows a prescribed template developed by the CENRAP states. 

The TCEQ used a refined estimate of natural conditions for Class I areas in Texas and other states 

as permitted by EPA guidance. These refined estimates account for natural dust storms, which 

explain a significant number of impaired days at the Texas Class I areas. 

The Clean Air Interstate Rule (CAIR) program is expectedwas designed to reduce interstate 

transport of emissions that affect fine particulate matter and ozone. Because these precursor 

emissions affect visibility, the CAIR program is also an integral part of reducing regional haze 

impact. Following the legislature’s statutory direction, the TCEQ adopted CAIR requirements 

applicable to electric generating units in Texas. Interstate trading of CAIR emission reduction 

credits makes the prediction of CAIR’s visibility improvement benefits uncertain for each Class I 

area.
ES-2 

AdditionallyOn July 11, 2008, the United States Court of Appeals for the District of Columbia 

Circuit vacated CAIR in its entirety. Upon a motion for rehearing, the appeals court issued a 

decision remanding CAIR to EPA to initiate rulemaking consistent with its opinion, but the court 

did not vacate CAIR, allowing it to remain in effect until replaced by EPA rule. The TCEQ 

expects that a replacement program will be in place that makes comparable reductions in 

pollutants causing regional haze prior to 2018. 

The commission has also adopted the requirements of the BART program, which requires certain 

older sources with a visibility impairment impact on a Class I area to apply BART to the source 

to reduce its impact on a nearby Class I area. This SIP revision contains a list of BART-eligible 

sources and the determinationanother list of BART for each source that ismodeling outcomes. 

The appendix contains modeling summaries of sources that were reasonably anticipated to 

contribute to visibility impairment (BART-subject).; however, after modeling, these sources were 

below the EPA threshold. 

Each state must evaluate and determine if additional emissions reductions are necessary. The 

statute and EPA rules and guidance set criteria for determining whether additional reductions are 

reasonable. These criteria are based on the cost of controls and other related factors. The TCEQ 

has determined that no additional controls will be implemented with this SIP revision. 

Reductions at Big Bend are dependent upon reducing emissions from Mexico and Central 

America. The TCEQ specifically asks the EPA for federal efforts to reduce the international 

transport impacts on regional haze coming into the United States across Texas’ southern border. 

CENRAP modeling estimates of the base period visibility impairment at the two Texas Class I 

areas from the United States and foreign contributions indicate 52 percent of the visibility 

impairment at Big Bend National Park and 20 percent of the visibility impairment at Guadalupe 

Mountains National Park on the worst 20 percent of regional haze days comes from international 

transport. The preamble to the July 1, 1999, issuance of the Regional Haze Rule clearly says that 

states are not required to carry out compensatory overcontrol to make up for the lack of progress 

in reducing the impacts of international transport. The TCEQ expects that the EPA will pursue 

international emission reductions to improve visibility at Texas’ Class 1 areas.

In conclusion, the TCEQ has implemented rules that limit and minimize emissions causing both 

local Texas and regional visibility impairment. The Texas SIP includes numerous rules that 

minimize emissions that cause or contribute to localTexas and regional visibility impairment. 

The TCEQ plans to continue to implement all these rules that protect visibility at Class I areas in 

Texas and other states. 
i 

SECTION V: LEGAL AUTHORITY 

A. General

The TCEQ has the legal authority to implement, maintain and enforce the National Ambient Air 

Quality Standards (NAAQS) and to control the quality of the state’s air, including maintaining 

adequate visibility. 

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more 

comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon’s 

Texas Civil Statutes. The Legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 

1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003 and 2005. In 1989, the TCAA was 

codified as Chapter 382 of the Texas Health & Safety Code. 

Originally, the TCAA stated that the Texas Air Control Board (TACB) is the state air pollution 

control agency and is the principal authority in the state on matters relating to the quality of air 

resources. In 1991, the Legislature abolished the TACB effective September 1, 1993, and its 

powers, duties, responsibilities and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the 

general provisions, organization and general powers and duties of the TNRCC, and the 

responsibilities and authority of the Executive Director. This Chapter also authorizes the TNRCC 

to implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives 

the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence 

of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the Texas 

Commission on Environmental Quality (TCEQ). 

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state’s air and to control the quality of the state’s air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; conduct research and 

investigations; enter property and examine records; prescribe monitoring requirements; institute 

enforcement proceedings; enter into contracts and execute instruments; formulate rules; issue 

orders taking into consideration factors bearing upon health, welfare, social and economic factors, 

and practicability and reasonableness; conduct hearings; establish air quality control regions; 

encourage cooperation with citizens’ groups and other agencies and political subdivisions of the 

state as well as with industries and the Federal Government; and establish and operate a system of 

permits for construction or modification of facilities. 

Local government authority is found in Subchapter E of the TCAA. Local governments have the 

same power as the TCEQ to enter property and make inspections. They also may make 

recommendations to the commission concerning any action of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town may enact and enforce 

ordinances for the control and abatement of air pollution not inconsistent with the provisions of 

the TCAA or the rules or orders of the commission. 

 

Subchapters F, G, and H of the TCAA authorize the TCEQ to establish low emission vehicle 

requirements for mass transit authorities, local government fleets, and private fleets; create a 

mobile emissions reduction credit program; establish vehicle inspection and maintenance 

programs in certain areas of the state, consistent with the requirements of the Federal Clean Air 

Act; establish gasoline volatility and low emission diesel standards; and fund and authorize 

participating counties to implement low-income vehicle repair assistance, retrofit and accelerated 

vehicle retirement programs. 
ii 

B. Applicable Law

The following statutes and rules provide necessary authority to adopt and implement the SIP. 

The rules listed below have previously been submitted as part of the SIP. 

 

Statutes

TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2005 

TEXAS WATER CODE September 1, 2005 

All sections of each subchapter are included, unless otherwise noted. 

Chapter 5: Texas Natural Resource Conservation Commission 

Subchapter A: General Provisions 

Subchapter B: Organization of the Texas Natural Resource Conservation Commission 

Subchapter C: Texas Natural Resource Conservation Commission 

Subchapter D: General Powers and Duties of the Commission 

Subchapter E: Administrative Provisions for Commission 

Subchapter F: Executive Director (except §§ 5.225, 5.226, 5.227, 5.2275, 5.232, and 5.236) 

Subchapter H: Delegation of Hearings 

Subchapter I: Judicial Review 

Subchapter J: Consolidated Permit Processing 

Subchapter L: Emergency and Temporary Orders (§§ 5.514, 5.5145 and 5.515 only) 

Chapter 7: Enforcement 

Subchapter A: General Provisions (§§ 7.001, 7.002, 7.0025, 7.004, 7.005 only) 

Subchapter B: Corrective Action and Injunctive Relief (§ 7.032 only) 

Subchapter C: Administrative Penalties 

Subchapter E Criminal Offenses and Penalties: §§ 7.177, 7.179-7.181 

Rules

All of the following rules are found in Title 30, Texas Administrative Code, as of the following 

effective dates: 

Chapter 7, Memoranda of Understanding, §§ 7.110 and 7.119 May 2, 2002 

Chapter 35, Subchapters A-C, K: Emergency and Temporary December 10, 1998 

Orders and Permits; Temporary Suspension or Amendment of 

Permit Conditions 

Chapter 39, Public Notice, §§ 39.201; 39.401; 39.403(a) and August 15, 2002 

(b)(8)-(10); 39.405(f)(1) and (g); 39.409; 39.411 (a), (b)(1)-(6) 

and (8)-(10) and (c)(1)-(6) and (d); 39.413(9), (11), (12) and (14); 

39.418(a) and (b)(3) and (4); 39.419(a), (b),(d) and (e); 

39.420(a), (b) and (c)(3) and (4); 39.423 (a) and (b); 39.601; 

39.602; 39.603; 39.604; and 39.605 

Chapter 55, Request for Contested Case Hearings; Public August 29, 2002 

Comment, §§ 55.1; 55.21(a) - (d), (e)(2), (3) and (12), (f) and (g); 

55.101(a), (b), (c)(6) - (8); 55.103; 55.150; 55.152(a)(1), (2) and 

(6) and (b); 55.154; 55.156; 55.200; 55.201(a) - (h); 55.203; 

55.205; 55.206; 55.209 and 55.211 

Chapter 101: General Air Quality Rules August 16, 2007 
iii 

Chapter 106: Permits by Rule, Subchapter A June 30, 2004 

Chapter 111: Control of Air Pollution from Visible Emissions July 19, 2006 

and Particulate Matter 

Chapter 112: Control of Air Pollution from Sulfur Compounds July 12, 2001 

 

Chapter 113: Standards of Performance for Hazardous Air Pollutants June 15, 2005 

and for Designated Facilities and Pollutants 

 

Chapter 114: Control of Air Pollution from Motor Vehicles July 19, 2007 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds July 19, 2007 

Chapter 116: Permits for New Construction or Modification March 15, 2007 

Chapter 117: Control of Air Pollution from Nitrogen Compounds June 14, 2007 

Chapter 118: Control of Air Pollution Episodes March 5, 2000 

Chapter 122, § 122.122: Potential to Emit December 11, 2002 

Chapter 122, § 122.215: Minor Permit Revisions June 3, 2001 

Chapter 122, § 122.216: Applications for Minor Permit Revisions June 3, 2001 

Chapter 122, § 122.217: Procedures for Minor Permit Revisions December 11, 2002 

Chapter 122, § 122.218: Minor Permit Revision Procedures for Permit Revisions June 3, 2001 

Involving the Use of Economic Incentives, Marketable Permits, and Emissions Trading 
iv 

TABLE OF CONTENTS

LIST OF TABLES................................................................................. vii 

LIST OF FIGURES................................................................................. ix 

LIST OF APPENDICES........................................................................... xi 

LIST OF ACRONYMS........................................................................... xii

CHAPTER 1. BACKGROUND AND OVERVIEW OF THE FEDERAL REGIONAL 

HAZE REGULATION.................................................................. 1-1 

1.1 GENERAL BACKGROUND............................................................... 1-1 

1.2 VISIBILITY-IMPAIRING EMISSIONS................................................... 1-1 

1.3 HISTORY OF FEDERAL REGIONAL HAZE RULE................................. 1-4 

1.4 CLASS I AREAS.............................................................................. 1-4

CHAPTER 2. GENERAL PLANNING PROVISIONS .................................... 2-1 

2.1 INTRODUCTION.............................................................................. 2-1 

2.2 PUBLIC HEARING AND COMMENT INFORMATION............................... 2-1

CHAPTER 3. REGIONAL PLANNING...................................................... 3-1 

3.1 OVERVIEW.................................................................................... 3-1 

3.2 HISTORY OF TEXAS PARTICIPATION................................................ 3-3

CHAPTER 4. STATE, TRIBE, AND FEDERAL LAND MANAGER 

 CONSULTATION........................................................................ 4-1 

4.1 INTRODUCTION............................................................................... 4-1 

4.2 CONSULTATION ON CLASS I AREAS IN TEXAS.................................... 4-1 

4.3 CONSULTATIONS ON CLASS I AREAS IN OTHER STATES..................... 4-2

CHAPTER 5. ASSESSMENT OF BASELINE AND CURRENT CONDITIONS AND 

ESTIMATE OF NATURAL CONDITIONS IN CLASS I AREAS............... 5-1 

5.1 VISIBILITY REQUIREMENTS............................................................ 5-1 

5.1.1 Default and Refined Values for Natural Visibility Conditions........................ 5-2 

5.1.2 Consultation Regarding the Visibility Metrics.......................................... 5-2 

5.2 BASELINE VISIBILITY CONDITIONS................................................ 5-3 

5.3 NATURAL VISIBILITY CONDITIONS................................................... 5-3

5.3 NATURAL VISIBILITY CONDITIONS ONGOING EFFORTS..................... 5-6 

CHAPTER 6. MONITORING STRATEGY..................................................... 6-1 

6.1 INTRODUCTION.............................................................................. 6-1 

6.2 MONITORING AT CLASS I AREAS IN TEXAS....................................... 6-1 

6.3 ASSESSMENT OF VISIBILITY IMPROVEMENT AT CLASS I AREAS............ 6-1 

6.4 REPORTING VISIBILITY MONITORING DATA TO THE ADMINISTRATOR... 6-3 

6.5 ASSESSING THE IMPACT OF EMISSIONS FROM TEXAS ON CLASS I 

 AREAS.................................................................................... 6-3

CHAPTER 7. EMISSIONS INVENTORY................................................... 7-1

CHAPTER 8. MODELING ASSESSMENT................................................... 8-1 

8.1 OVERVIEW.................................................................................... 8-1 

8.2 BACKGROUND.............................................................................. 8-1 

8.3 CENRAP MODELING TEAM............................................................... 8-2 

8.4 THE 2002 ANNUAL EMISSIONS AND AIR QUALITY MODELING............... 8-3 

8.4.1 Modeling Protocol........................................................................... 8-3 

8.4.2 Quality Assurance Project Plan (QAPP)................................................... 8-3 
v 

8.4.3 Model Selection.............................................................................. 8-3 

8.4.4 MM5 Meteorological Model Configuration................................................ 8-4 

8.4.5 SMOKE Emissions Model Configuration ................................................ 8-5 

8.4.6 CMAQ Air Quality Model Configuration ................................................ 8-5 

8.4.7 CAMx Air Quality Model Configuration ................................................ 8-5 

8.4.8 Modeling Domains........................................................................... 8-6 

8.4.9 Vertical Structure of Modeling Domain................................................... 8-7 

8.4.10 2002 Calendar Year Selection............................................................ 8-8 

8.4.11 Initial Concentrations and Boundary Conditions ....................................... 8-9 

8.4.12 Emission Input Preparation............................................................... 8-10 

8.4.13 Meteorological Data Input Preparation................................................... 8-11 

8.4.14 Photolysis Rate Model Input............................................................ 8-12 

8.4.15 Air Quality Data Input Preparation....................................................... 8-12 

8.4.16 2002 Base Case Modeling and Model Performance Evaluation .................. 8-13 

8.4.17 2018 Modeling and Visibility Projections ................................................ 8-15 

8.4.18 Additional Supporting Analysis .......................................................... 8-19

CHAPTER 9. BEST AVAILABLE RETROFIT TECHNOLOGY........................ 9-1 

9.1 BART-Eligible Sources in Texas.............................................................. 9-1 

9.2 Determination of Sources Subject to BART .............................................. 9-6 

9.2.1 Cumulative Modeling Using CAMx PSAT............................................. 9-6 

9.2.2 Individual Source Attribution Approach.................................................. 9-13 

9.3 SITES REMOVED FROM FURTHER BART CONSIDERATION.................... 9-15 

9.4 POST-BART EMISSIONS REDUCTIONS 9.4 DETERMINATION OF BART FOR 

SOURCES SUBJECT TO BART ....................................................... 9-17 

9.5 SITES REMOVED FROM FURTHER BART CONSIDERATION 9.5 POST-BART 

EMISSIONS REDUCTIONS ............................................................ 9-21

CHAPTER 10. REASONABLE PROGRESS GOALS......................................... 10-1 

10.1 INTRODUCTION ............................................................................ 10-1 

10.2 REASONABLE PROGRESS GOALS FOR TEXAS CLASS I AREAS.............. 10-1 

10.3 CONSIDERATION OF ADDITIONAL POLLUTION CONTROL .................. 10-4 

10.4 FOUR FACTOR ANALYSIS ................................................................ 10-6 

10.4.1 Applying the Statutory Factors ........................................................ 10-8 

10.4.2 Four Factor Analysis Process............................................................. 10-8 

10.5 UNCERTAINTY IN THE REASONABLE PROGRESS GOALS..................... 10-10 

10.6 INTERNATIONAL SOURCES OF VISIBILITY IMPAIRMENT.................... 10-11 

10.7 REDUCTIONS REQUIRED TO MEET THE UNIFORM RATE OF PROGRESS... 10-11 

10.8 CONSULTATION........................................................................ 10-12 

10.9 REPORTING................................................................................. 10-12

CHAPTER 11. LONG-TERM STRATEGY TO REACH REASONABLE 

PROGRESS GOALS....................................................................... 11-1 

11.1 INTRODUCTION............................................................................ 11-1 

11.1.1 Reasonably Attributable Visibility Impairment..................................... 11-6 

11.2 CONSULTATION............................................................................ 11-6 

11.2.1 Consultation on Class I Areas in Texas.............................................. 11-7 

11.2.2 Consultation on Class I Areas Impacted by Emissions from Texas ................ 11-7 

11.2.3 Texas’ Impacts and 2018 Impact Reduction for Class I Areas Outside Texas...... 11-7 

11.3 REQUEST FOR FEDERAL EFFORTS TO REDUCE INTERNATIONAL 

 TRANSPORT.............................................................................. 11-29 

11.4 MINIMIZING VISIBILITY IMPAIRMENT FROM TEXAS EMISSIONS......... 11-30 

11.4.1 Opacity Limitations........................................................................ 11-30 

11.4.2 Sulfur Emission Limitations............................................................. 11-30 

11.4.3 Best Available Control Technology (BACT) Requirements........................ 11-30 
vi 

11.4.4 Programs to Manage Smoke Impacts on Class I Areas.............................. 11-31 

11.4.5 Program to Lower the Impact of Construction Activity on Air and Water Quality...11-31 

11.5 FEDERAL PROGRAMS THAT REDUCE EMISSIONS.............................. 11-32 

11.5.1 Texas Vehicle Inspection and Maintenance Programs................................ 11-32 

11.5.2 Air Check Texas Repair and Replacement Assistance Program.................... 11-32 

11.6 EMISSION REDUCTIONS SINCE ISSUANCE OF THE REGIONAL 

HAZE RULE.............................................................................. 11-33 

11.6.1 NOX Emission Reduction Requirements in Texas Ozone SIP Revisions......... 11-33 

11.6.2 SO2 and NOX Reduction Requirements under Senate Bill 7......................... 11-33 

11.6.3 CAIR Reductions for NOX and SO2...................................................... 11-34 

11.6.4 Best Available Retrofit Technology (BART) Requirements......................... 11-36 

11.6.5 Comparison of the NOX Emission Limits for EGUs with CAIR Limits............. 11-37 

11.6.6 Sulfur Dioxide Reductions under the EPA Refinery Consent Decrees............. 11-38 

11.6.7 Texas Low Emissions Diesel (TxLED) Program ...................................... 11-38 

11.6.8 The Texas Emission Reduction Plan (TERP).......................................... 11-38

CHAPTER 12. COMPREHENSIVE PERIODIC IMPLEMENTATION PLAN REVISIONS 

AND ADEQUACY OF THE EXISTING PLAN..................................... 12-1 
vii 

LIST OF TABLES 

Table 1-1: Visibility-Impairing Pollutants....................................................... 1-2 

Table 1-2: Comparison of Ambient Fine Particles (Ultrafine plus Accumulation-Mode) 

and Coarse Particles............................................................... 1-3 

Table 4-1: Consultation Calls .................................................................. 4-1 

Table 5-1: Baseline Haze Indices............................................................... 5-3 

Table 5-2: Visibility Metrics for the Class I Areas in Texas................................. 5-4 

Table 7-1: CENRAP’s 2002 Base Year Emissions Inventory Summary for Texas...... 7-1 

Table 7-2: Statewide Biogenic Emissions...................................................... 7-2 

Table 7-3: CENRAP’s 2018 Emissions Inventory Summary for Texas.................. 7-3 

Table 8-1: Federal Mandated Class I Areas in the CENRAP States.......................... 8-2 

Table 8-2: MM5 34 Vertical Layer Definitions............................................... 8-8 

Table 8-3: Ground-level Ambient Data Monitoring Networks and Stations for 2002.... 8-13 

Table 9-1: BART-TableEmissions from Companies Surveyed as a Percentage 

of State Total Point Source Emissions .......................................... 9-2 

Table 9-2: BART-Eligible Sources Based on Results of TCEQ Survey................... 9-3 

Table 9-3: BART-Eligible Sources Screened Out Using Cumulative CAMx Modeling .. 9-7

Table 9-4: BART-Eligible Source Distance to Each Class I Area......................... 9-9

Table 9-5: BART-Eligible Sources Exempted Based on CALPUFF Modeling........ 9-14 

Table 9-6: BART-Eligible Sources Screened Out on Individual Basis Using 

CAMx................................................................................ 9-15 

Table 9-7: Sites Removed From BART Due to Exemption Requests ....................... 9-16 

Table 9-8: Summary of BART-Eligible Source Determinations ............................. 9-17 

Table 9-9: Post-BART Emissions Reductions at Texas Sources............................. 9-21 

Table 10-1: Uniform Rate of Progress for Class I Areas in Texas on Worst 20 

Percent Days......................................................................... 10-1 

Table 10-2: Reasonable Progress Goals for Class I Areas on Worst 20 Percent 

Days.................................................................................... 10-1 

Table 10-3: Reasonable Progress Goals for Class I Areas on Best 20 Percent Days....... 10-4 

Table 10-4: Cost of Controls for Class I Areas ................................................. 10-5 

Table 10-5: TCEQ Point Source Control Strategy Summary ................................. 10-5 

Table 10-6: Estimated Haze Index Improvements for Affected Class I Areas .............. 10-6 

Table 10-7: Comparison of Sulfur Dioxide Emissions ..................................... 10-10 

Table 10-8: Contributions to Visibility in the Texas Class I Areas on Worst 

20 Percent Days..................................................................... 10-11 

Table 10-9: Emissions Reductions Required to Meet Uniform Rate of Progress.......... 10-11 

Table 11-1: Pollutant Contributions to Extinction at Big Bend from Texas and 

from All Areas on Worst 20 Percent Days in 2002 and 2018................. 11-4 

Table 11-2: Pollutant Contributions to Extinction at Guadalupe Mountains from 

Texas and from All Areas on Worst 20 Percent Days in 2002 and 2018.... 11-6 

Table 11-3: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Carlsbad Caverns National Park on 

Worst 20 Percent Days ............................................................ 11-10 

Table 11-4: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Salt Creek Wilderness Area on Worst 

20 Percent Days ...................................................................... 11-12 

Table 11-5: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at White Mountain Wilderness Area on 

Worst 20 Percent Days............................................................. 11-13 

Table 11-6: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

 2018 Total Visibility Extinction at Wheeler Peak Wilderness Area on 

Worst 20 Percent Days.......................................................... 11-15 
viii 

Table 11-7: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Wichita Mountains Wilderness Area 

 on Worst 20 Percent Days................................................... 11-16 

Table 11-8: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Great Sand Dunes Wilderness Area 

on Worst 20 Percent Days......................................................... 11-19

Table 11-9: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Rocky Mountain National Park on 

Worst 20 Percent Days............................................................ 11-20 

Table 11-10: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Caney Creek Wilderness Area on Worst 

 20 Percent Days..................................................................... 11-23 

Table 11-11: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Upper Buffalo Wilderness Area on 

Worst 20 Percent Days............................................................ 11-24 

Table 11-12: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Hercules-Glades Wilderness Area on 

Worst 20 Percent Days............................................................ 11-26 

Table 11-13: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Mingo Wilderness Area on Worst 

20 Percent Days.................................................................... 11-27 

Table 11-14: Texas’ Apportioned Contribution to the Measured 2002 and Projected 

2018 Total Visibility Extinction at Breton Wilderness Area on Worst 

20 Percent Days...................................................................... 11-29 

Table 11-15: EGU Emission Allowances in Texas under the CAIR Program............ 11-34 

Table 11-16: Texas Electric Generating Utility NOX Control Strategies Compared 

to CAIR.............................................................................. 11-37 

Table 11-17: Annual SO2 Emissions at Consent Decree Impacted Sources............... 11-38 
ix 

LIST OF FIGURES 

Figure 1-1: Regional Class I Areas............................................................. 1-5 

Figure 3-1: Map of the Regional Planning Organizations ................................... 3-2 

Figure 5-1: Generic Glide Path to Achieve Natural Conditions in 60 Years................. 5-2 

Figure 5-2: Big Bend Uniform Rate of Progress (URP)...................................... 5-5 

Figure 5-3: Guadalupe Mountains Uniform Rate of Progress............................... 5-5 

Figure 7-1: Comparison of Base and Projected Annual Emissions by Source Category... 7-3 

Figure 8-1: National Inter-RPO Modeling Domain............................................. 8-7 

Figure 8-2: Observed and Base Case Modeled Concentrations at Big Bend.............. 8-14 

Figure 8-3: Observed and Base Case Modeled Concentrations at Guadalupe 

Mountains............................................................................. 8-15 

Figure 8-4: 2018 Visibility Projections Expressed as Percent of Meeting the 2018 

URP Point............................................................................ 8-18 

Figure 10-1: Glide Path for Big Bend Worst 20 Percent Days................................ 10-3 

Figure 10-2: Glide Path for Guadalupe Mountains Worst 20 Percent Days................ 10-3 

Figure 11-1: Comparison of Extinction, Deciviews and Visual Range....................... 11-2 

Figure 11-2: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE) 

Worst 20 Percent Days in 2002.................................................... 11-2 

Figure 11-3: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE) 

on Best 20 Percent Days in 2002.................................................. 11-3 

Figure 11-4: Areas and Pollutants Causing Regional Haze at Guadalupe 

Mountains (GUMO) on the Worst 20 Percent Days in 2002 ................ 11-5 

Figure 11-5: Areas and Pollutants Causing Regional Haze at Guadalupe 

Mountains (GUMO) on Best 20 Percent Days in 2002....................... 11-5 

Figure 11-6: Calculated Regional Haze Impacts of Emissions from Western Areas 

of Texas at Each Class I Area in New Mexico on Worst 20 Percent 

Days in 2002........................................................................ 11-8 

Figure 11-7: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns 

National Park on Worst 20 Percent Days in 2002............................... 11-9 

Figure 11-8: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns 

National Park on Best 20 Percent Days in 2002................................. 11-10 

Figure 11-9: Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) 

in New Mexico on Worst 20 Percent Days in 2002............................ 11-11 

Figure 11-10: Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) 

in New Mexico on Best 20 Percent Days in 2002.............................. 11-11 

Figure 11-11: Areas and Pollutants Causing Regional Haze at White Mountain 

(WHIT) in New Mexico on Worst 20 Percent Days in 2002 ............... 11-12 

Figure 11-12: Areas and Pollutants Causing Regional Haze at White Mountain 

(WHIT) in New Mexico on Best 20 Percent Days in 2002..................... 11-13 

Figure 11-13: Areas and Pollutants Causing Regional Haze at Wheeler Peak 

Wilderness Area on Worst 20 Percent Days in 2002 ........................... 11-14 

Figure 11-14: Areas and Pollutants Causing Regional Haze at Wheeler Peak 

Wilderness Area on Best 20 Percent Days in 2002............................... 11-14 

Figure 11-15: Areas and Pollutants Causing Regional Haze at Wichita Mountains 

(WIMO) in Oklahoma on Worst 20 Percent Days in 2002................... 11-15 

Figure 11-16: Areas and Pollutants Causing Regional Haze at Wichita Mountains 

(WIMO) in Oklahoma on Best 20 Percent Days in 2002..................... 11-16 

Figure 11-17: Calculated Regional Haze Impacts of West Texas Emissions at 

Each Class I Area in Colorado Included in CENRAP PSAT Modeling 

on Worst 20 Percent Days in 2002.............................................. 11-17 

Figure 11-18: Areas and Pollutants Causing Regional Haze at Great Sand Dunes 

(GRSA) in Colorado on Worst 20 Percent Days in 2002................... 11-18 

Figure 11-19: Areas and Pollutants Causing Regional Haze at Great Sand Dunes 

(GRSA) in Colorado on Best 20 Percent Days in 2002........................ 11-18 
x 

Figure 11-20: Areas and Pollutants Causing Regional Haze at Rocky Mountains 

 National Park (ROMO) in Colorado on Worst 20 Percent Days 

in 2002................................................................................. 11-19 

Figure 11-21: Areas and Pollutants Causing Regional Haze at Rocky Mountains 

National Park (ROMO) in Colorado on Best 20 Percent Days in 2002..... 11-20 

Figure 11-22: Areas and Pollutants Causing Regional Haze at Caney Creek 

(CACR) in Arkansas on Worst 20 Percent Days in 2002....................... 11-21 

Figure 11-23: Areas and Pollutants Causing Regional Haze at Caney Creek 

(CACR) in Arkansas on Best 20 Percent of Days in 2002..................... 11-22 

Figure 11-24: Areas and Pollutants Causing Regional Haze at Upper Buffalo 

(UPBU) in Arkansas on Worst 20 Percent Days in 2002....................... 11-23 

Figure 11-25: Areas and Pollutants Causing Regional Haze at Upper Buffalo 

(UPBU) in Arkansas on Best 20 Percent Days in 2002......................... 11-24 

Figure 11-26: Areas and Pollutants Causing Regional Haze at Hercules-Glades 

 (HEGL) in Missouri on Worst 20 Percent Days in 2002...................... 11-25 

Figure 11-27: Areas and Pollutants Causing Regional Haze at Hercules-Glades 

 (HEGL) in Missouri on the Best 20 Percent of Days 2002.................... 11-25 

Figure 11-28: Areas and Pollutants Causing Regional Haze at Mingo (MING) 

in Missouri on Worst 20 Percent Days in 2002................................... 11-26 

Figure 11-29: Areas and Pollutants Causing Regional Haze at Mingo (MING) 

in Missouri on Best 20 Percent Days in 2002..................................... 11-27 

Figure 11-30: Areas and Pollutants Causing Regional Haze at Breton Wilderness 

 Area (BRET) in Louisiana on Worst 20 Percent Days in 2002.............. 11-28 

Figure 11-31: Areas and Pollutants Causing Regional Haze at Breton Wilderness 

Area (BRET) in Louisiana on Best 20 Percent Days in 2002................. 11-28 

Figure 11-32: CAIR Emission Reduction States................................................ 11-34 
xi 

LIST OF APPENDICES 

Appendix 1-1 EPA Regional Haze Rule 1999 

Appendix 2-1 Public Participation Process (after proposal)

Appendix 2-2 Public Comments and Responses on SIP Draft (after proposal)

Appendix 4-1 Summary of Three Texas Consultation Calls 

Appendix 4-2 Contact List for Consultation Calls 

Appendix 4-3 Additional Consultation Letters to Adjacent States 

Appendix 5-1 Discussion of the Original and Revised IMPROVE Algorithms 

Appendix 5-2 Estimate of Natural Visibility Conditions 

Appendix 5-2a Natural Events: Dust Storms in West Texas 

Appendix 5-2b Estimating Natural Conditions Based on Revised IMPROVE 

 Algorithim 

Appendix 5-2c Texas Natural Conditions SAS Program File and Data 

Appendix 7-1 Texas Emissions Inventory Development: Base Year 2002 and 

 Projected Year 2018 

Appendix 7-2 Integrated Planning Model Projections of Electric Generating Unit 

 Emissions for the Regional Haze State Implementation Plan 

Appendix 8-1 Technical Support Document for CENRAP Emissions and Air 

 Quality Modeling to Support Regional Haze SIP 

Appendix 8-2 Big Bend Model Performance Analysis 

Appendix 8-3 Modeling Protocol for the CENRAP 2002 Annual Emissions and Air 

 Quality Modeling 

Appendix 8-4 Quality Assurance Project Plan for Central Regional Air Planning 

 Association Emissions and Air Quality Modeling 

Appendix 9-1 U.S. EPA BART Rule 

Appendix 9-2 Texas BART Rule 

Appendix 9-3 Texas Survey for BART-EligibilityCAMx Modeling Protocol, Screening 

Analysis of Potentially BART- Eligible Sources in Texas (online)

Appendix 9-4 CAMx Modeling Protocol, Screening Analysis of Potentially BART- 

 Eligible Sources in Texas

Appendix 9-5 CAMx Modeling Report, Final Report, Screening Analysis of 

 Potential BART-Eligible Sources in Texas (online)

Appendix 9-6 CAMx Screening Modeling Report and Addendums 1 and 2 (online)

Appendix 9-7 Certification of Screening Modeling Data 

Appendix 9-8 CALPUFF Modeling Guidelines and Modeling Summaries (online)

Appendix 9-8 CAMx Modeling Guidelines (online)

Appendix 9-9 CAMx Modeling Guidelines 

Appendix 9-10 BART Engineering Guidance Documents and Forms 

Appendix 9-11 Documentation of Emission Reductions 

Appendix 9-12 County Abbreviations 

Appendix 9-13 BART-Eligible List 

Appendix 10-1 Analysis of Control Strategies RPG 

Appendix 10-2 Estimating Visibility Impacts from Additional Point Source Controls 

Appendix 10-3 Uniform Rate of Progress Curves Using Default Natural Conditions 

 Estimates 

Appendix 10-4 Detailed Calculations for Estimating Visibility Impacts 

Appendix 11-1 Fire Management Plans

Appendix 11-2 Federal and Texas Programs Related to On-road and Non-road 

 Mobile Sources 

Appendix 11-3 Major Point Source NOX Rules and Reductions Promulgated in Texas 

 Since 2000

Appendix 11-4 ASARCO El Paso 

Deleted: 3

Deleted: 4

Deleted: 5

Deleted: 6

Deleted: 7

Deleted: 10

Deleted: 11

Deleted: 12
xii 

 LIST OF ACRONYMS 

 

AEO Annual Energy Outlook, forecasts by Department of Energy 

AOI Area of influence 

B20% Best 20 percent (days of visibility) 

BACT Best Available Control Technology 

BADL Badlands Wilderness Area 

BAND Bandelier Wilderness Area 

BART Best Available Retrofit Technology 

BC Boundary conditions 

BEIS3 Biogenic Emissions Inventory System Version 3 

Bext Light extinction 

BIBE Big Bend National Park 

bnatural Clean natural conditions 

BOAP Bosque del Apache Wilderness Area 

BOWA Boundary Waters Canoe Area Wilderness 

BRAVO Big Bend Regional Aerosol and Visibility Observational study 

BRET Breton Wilderness Area 

bsource Total light extinction due to a source 

CACR Caney Creek Wilderness Area 

CAIR Clean Air Interstate Rule 

CALPUFF California Puff Model 

CAMR Clean Air Mercury Rule

CAMx Comprehensive Air Quality Model with extensions 

CENRAP Central Regional Air Planning Association 

CFR Code of Federal Regulations 

CM Coarse mass 

CMAQ Community Multiscale Air Quality Modeling System 

DRI Desert Research Institute 

dv deciviews 

EC Elemental carbon 

EGAS Economic Growth Analysis System 

EGU Electric generating unit 

ENVIRON ENVIRON International Corporation 

EPA United States Environmental Protection Agency 

ERCOT Electric Reliability Council of Texas 

f(RH) Relative Humidity adjustment factor 

FCAA Federal Clean Air Act 

FIPS Federal Information Processing Standard 

FLAG Federal Land Managers’ Air Quality Related Values Work Group 

FLM Federal Land Manager 

FS United States Forest Service 

FWS United States Fish and Wildlife Service 

FR Federal Register 

GEOSCHEMChem

Goddard Earth Observing System - Chemistry model 

GICL Gila Wilderness Area 

GRSA Great Sand Dunes Wilderness Area 

GUMO Guadalupe Mountains National Park 

HEGL Hercules-Glades Wilderness Area 

Deleted: 
xiii 

HI Haze Index 

IC Initial conditions 

IDNR Iowa Department of Natural Resources 

IMPROVE Interagency Monitoring of Protected Visual Environments 

IPM Integrated Planning Model 

ISLE Isle Royale National Park 

JPROC Photolysis Rates Processor 

km kilometers 

LAER Lowest Achievable Emission Rate 

LOST Lostwood Wilderness Area 

LTS Long-term strategy 

MACA Mammoth Cave National Park 

MATS Modeled Attainment Test Software 

mb millibars 

MEVE Mesa Verde National Park 

MING Mingo Wilderness Area 

Mm-1 Inverse Megameters 

MM5 Mesoscale Meteorological Model, 5th Generation (developed by 

Pennsylvania State University / National Center for Atmospheric 

Research PSU/NCAR) 

MMS Minerals Management Service

MOBILE5 MOBILE Vehicle Emission Modeling Software Version 5 

MOZI Mount Zirkel Wilderness Area 

MPE Model performance evaluation 

MPI Message passing interface 

MRPO Midwest Regional Planning Organization 

NAAQS National ambient air quality standards 

NARSTO North American Research Strategy for Tropospheric Ozone 

NH4

 Ammonium 

NO3

 Nitrate 

NOx Nitrogen oxides 

non-EGU Non-electrical generating units 

NPS National Park Service, United States Department of the Interior 

NSPS New source performance standards 

NSR New Source Review 

OC Organic carbon 

OMC Organic mass carbon 

PGM Photochemical Grid Model 

PiG Plume-in-Grid 

PLUVUE Plume Visibility Model 

PM Particulate matter 

PM10 Particulate matter with aerodynamic diameters less than 10 

microns 

PM2.5 Particulate matter with aerodynamic diameters less than 2.5 

microns 

POA Primary organic aerosol 

PPM Piecewise-Parabolic Method 

PSAT Particulate Matter Source Apportionment Technology 

PSD Prevention of significant deterioration 

Deleted: MOBILE6

Deleted: MOBILE Vehicle 

Emission Modeling Software 

Version 6
xiv 

PTE Potential to emit 

Q/D Emissions over distance (to Class I area) 

QA/QC Quality Assurance/Quality Control 

QAPP Quality Assurance Program Plan 

RH Relative Humidity 

ROMO Rocky Mountain National Park 

RPG Reasonable progress goal 

RPO Regional Planning Organization 

RRF Relative response factor (s?)

SACR Salt Creek Wilderness Area 

SAPE San Pedro Parks Wilderness Area 

SIP State Implementation Plan 

SIPS Sipsey Wilderness Area 

SMOKE Sparse Matrix Operator Kernel Emissions 

SO2

 Sulfur dioxide 

SO4

 Sulfate 

SOA Secondary organic aerosol 

SOAA Secondary organic aerosols anthropogenic (human-made) 

SOAB Secondary organic aerosols biogenic (from plants) 

TAC Texas Administrative Code 

TCAA Texas Clean Air Act 

TCEQ Texas Commission on Environmental Quality 

TEOM Tapered Element Oscillating Microbalance 

TERP Texas Emissions Reduction Program 

THRO Theodore Roosevelt National Park 

TIP Tribal Implementation Plan 

TOMS Total Ozone Mapping Spectrometer satellite data 

tpy tons per year 

TSD Technical Support Document 

TUV Tropospheric Ultraviolet and Visible (Radiation Model) 

UCR University of California at Riverside 

UPBU Upper Buffalo Wilderness Area 

URP Uniform rate of progress 

VIEWS Visibility Information Exchange Web System 

VISTAS Visibility Improvement State and Tribal Association of the 

Southeast 

VOC Volatile organic compounds 

VOYA Voyageurs National Park 

W20% Worst 20 percent (days of visibility) 

WEMI Weminuche Wilderness Area 

WHIT White Mountain Wilderness Area 

WHPE Wheeler Peak Wilderness Area 

WHRI White River National Forest 

WICA Wind Cave National Park 

WIMO Wichita Mountains Wilderness Area

WRAP Western Regional Air Partnership 

 
1-1 

CHAPTER 1. BACKGROUND AND OVERVIEW OF THE FEDERAL 

REGIONAL HAZE REGULATION 

1.1 GENERAL BACKGROUND 

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

These emission sources and activities are located across a broad geographical area. The 

emissions consist of fine particles and their precursors. Visibility impairment caused by air 

pollution occurs virtually all of the time at most Class I visibility protected national park and 

wilderness area monitoring stations (VIEWS 2007). A significant factor in visibility impairment 

is regional transport of fine particles that contribute to elevated particulate matter (PM) levels and 

regional haze impairment of visibility. . 

Haze-forming pollution comes from both human and natural sources. Windblown dust and soot 

from wildfires contribute to haze, as do motor vehicles, electric generating facilities, industrial 

fuel burning, and manufacturing operations. PM and PM precursor emissions are the major cause 

of reduced visibility (haze) in the United States and at many of our national parks and wilderness 

areas. Some haze-forming particles are directly emitted into the air. The usual term for directly 

emitted particles is primary particles. Secondary particles, created when emitted gases form 

particles downwind of the emission sources, usually dominate the causes of regional haze. 

Nitrates and sulfates, which result from NO2 and SO2 emissions, are examples of secondary 

particles that contribute to regional haze. 

In many scenic areas, haze substantially reduces visual range. In eastern Class I areas, haze from 

human activity reduces average visual range from the natural condition of approximately 90 miles 

to 15-to-25 miles. In the West, haze from human activity reduces visual range from the natural 

condition of approximately 140 miles to 35-to-90 miles. Haze Visibility impairment is 

measuredexpressed in deciviews (dv). A deciview is a unit of visibility impairment proportional 

to the logarithm of the atmospheric light extinction. One deciview is approximately the minimum 

amount of change in visibility impairment that a human observer can detect. 

1.2 VISIBILITY-IMPAIRING EMISSIONS 

The Central Regional Air Planning Association (CENRAP) and the Texas Commission on 

Environmental Quality (TCEQ) data analysis and modeling show that several types of emissions 

are involved in reducing visibility, including sulfur dioxide (SO2), nitrogen oxides (NOX), and 

particulate matter (PM). Table 1-1: Visibility-Impairing Pollutants and Table 1-2: Comparison of 

Ambient Fine Particles (Ultrafine plus Accumulation-Mode) and Coarse Particles discuss some 

of the emissions, different variations of the molecules in the atmosphere, and various sources of 

the emissions. Visibility improvement is not a Unlike pollutants like ozone, PM2.5, and carbon 

monoxide, visibility is not a measurable concentration for which a standard, like the national 

ambient air quality standard (NAAQS) that states must not exceed, like the ones for ozone, PM2.5, 

and carbon monoxidecould be set. Instead, the Regional Haze Rule sets out procedures states 

must follow to decide how much emission reduction isemissions reductions are reasonable to 

move toward the national goal that Congress has established under the Federal Clean Air Act 

(FCAA): returning Class I areas to natural visibility conditions. The United States 

Environmental Protection Agency (EPA) has set 2064 as the target date to reach the goal set by 

Congress to reach natural conditions at all Class I areas. To accomplish this goal, a state must 

first determine what “natural conditions” are and then plan how to reach those conditions.

Table 1-1 provides information about particulate matter components that contribute to regional 

haze. 
1-2 

Table 1-1: Visibility-Impairing Pollutants 

Major 

Components 

of Particles 

Symbol Directly 

Emitted? 

Formed 

in 

the Air?

Formed 

From 

In which 

Size Range? 

micrometers 

(μm) 

Major Sources 

Sulfates SO4 (Yes)* Yes SO2 PM2.5 

Coal-fired power 

plants, 

oil fields and 

refineries, 

paper mills 

Nitrates NO3 (No)* Yes NO2 PM2.5 All combustion 

Secondary 

Organic 

Carbon 

OC No Yes VOC** PM2.5

Gasoline, 

organic solvents, 

evergreen 

treesbiogenics

Primary 

Organic 

Carbon 

OC Yes No -- PM2.5

Incomplete 

combustion 

Elemental 

Carbon 

(i.e., black 

carbon) 

EC Yes No -- PM2.5

Incomplete 

combustion 

Fine Soil 

Dust FS Yes No -- PM2.5

Wind blowing over 

loose soil, 

motor vehicles 

running on paved 

and unpaved roads 

Coarse Mass, 

which is 

normally 

~ 100% 

Coarse Soil 

Dust 

CM Yes No -- PMCOARSE, i.e. 

PM10 – 2.5 

Wind blowing over 

loose soil, 

motor vehicles 

running on paved 

and unpaved roads 

*There are few significant, direct sulfate sources; direct nitrate sources are rare. 

**Volatile organic compounds 

Table 1-2 provides additional information about particles. The table breaks down the fine 

particles into ultrafine particles that are less than 0.1 μm in diameter and accumulation mode 

particles that are generally between 0.1 and 1.0 μm in diameter. Ultrafine particles agglomerate 

to form accumulation mode particles. Some of the accumulation mode particles, most notably 

sulfates, grow above 1.0 μm in diameter, as the humidity becomes high. A relatively small 

percentage of the coarsesoil and dust particles are smaller than 2.5 μm in aerodynamic diameter, 

so samplers collect them with the fine particles. Table 1-1 lists only typical, major sources of 

each component. Table 1-2 provides a more inclusive listing of sources. 

Deleted: 
1-3 

Table 1-2: Comparison of Ambient Fine Particles (Ultrafine plus Accumulation-Mode) and 

Coarse Particles 

 Ultrafine Accumulation Coarse 

Formation 

Processes: 

Combustion, high-temperature processes, and 

atmospheric reactions 

Break-up of large solids/droplets 

Formed by: • Nucleation 

• Condensation 

• Coagulation 

• Condensation 

• Coagulation 

• Reactions of gases in 

or on particles 

• Evaporation of fog 

and cloud droplets in 

which gases have 

dissolved and reacted 

• Mechanical disruption 

(crushing, grinding, abrasion of 

surfaces) 

• Evaporation of sprays 

• Suspension of dusts 

• Reactions of gases in or on 

particles 

Composed of: • Sulfate 

• Elemental carbon 

• Metal compounds 

• Organic compounds 

with very low 

saturation vapor 

pressure at ambient 

temperature 

• Sulfate, nitrate 

ammonium, and 

hydrogen ions 

• Elemental carbon 

• Large variety of 

organic compounds 

• Metals: compounds 

of Pb, Cd, V, Ni, Cu, 

Zn, Mn, Fe, etc. 

• Particle-bound water 

• Suspended soil or street dust 

• Fly ash from uncontrolled 

combustion of coal, oil, and 

wood 

• Nitrates/chlorides/sulfates from 

HNO3,/HCI/SO2 reactions with 

coarse particles 

• Oxides of crustal elements (Si, 

Al, Ti, Fe) 

• CaCO3, CaSO4, NaC1, sea salt 

• Pollen, mold, fungal spores 

• Plant and animal fragments 

• Tire, brake pad, and road wear 

debris 

Sources: • Combustion 

• Atmospheric 

transformation of 

SO2 and some 

organic compounds 

• High temperature 

processes 

• Combustion of coal, 

oil, gasoline, diesel 

fuel, wood 

• Atmospheric 

transformation 

products of NOx, SO2, 

and organic 

compounds, including 

biogenic organic 

species (e.g., terpenes) 

• High-temperature 

processes, smelters, 

steel mills, etc. 

• Resuspension of industrial dust 

and soil tracked onto roads and 

streets 

• Suspension from disturbed soil 

(e.g., farming, mining, unpaved 

roads) 

• Construction and demolition 

• Uncontrolled coal and oil 

combustion 

• Ocean spray 

• Biological sources 

Atmospheric 

half-life: Minutes to hours Days to weeks Minutes to hours 

Atmospheric 

Removal 

Processes: 

• Grows into 

accumulation mode 

• Diffuses to raindrops 

• Forms cloud droplets 

and rains out (Organic 

carbon and elemental 

carbon particles may 

not take up water until 

they have aged.) 

• Dry deposition 

• Dry deposition by fallout 

• Scavenging by falling rain 

drops 

Travel distance: <1 to 10s of km 100s to 1000s of km <1 to 10s of km (small size tail, 

100s to 1000s in dust storms) 

Source: Adapted from Wilson and Suh (1997), CD, p. 2-52. 
1-4 

1.3 HISTORY OF FEDERAL REGIONAL HAZE RULE 

In the FCAA amendments of 1977, Congress added §169 (42 United States Code (USC), 

§7491), setting forth a national visibility goal of restoring natural conditions in certain 

national parks and wilderness areas. The EPA designated national parks and wilderness 

areas meeting certain criteria and containing vistas as an important feature, as Class I 

areas for visibility protection under regional haze state implementation plan (SIP) 

provisions. 

In response to the 1977 FCAA amendments, the EPA required control measures to address plume 

blight and reasonably attributable visibility impairment. These plume blight and reasonably 

attributable visibility impairment control measures did little to address regional haze throughout 

the contiguous 48 states. 

When Congress amended the FCAA again in 1990, it added §169B (42 USC, §§7492) requiring 

further research and regular assessments of the progress made toward visibility goals. In 1993, 

the National Academy of Sciences concluded that “current scientific knowledge is adequate and 

control technologies are available for taking regulatory action to improve and protect visibility” 

(NRC 1993).

In addition to authorizing the creation of visibility transport commissions and setting forth their 

duties, §169B(f) of the FCAA specifically mandated the creation of the Grand Canyon Visibility 

Transport Commission (GCVTC) to make recommendations to the EPA for the region affecting 

visibility in Grand Canyon National Park. After four years of research and policy development, 

the GCVTC submitted its report to the EPA in June 1996 (GCVTC 1996). This report, as well as 

other research reports prepared by the GCVTC, contributed information to the EPA’s 

development of the federal Regional Haze Rule. 

The EPA promulgated the Regional Haze Rule on July 1, 1999 (Appendix 1-1: EPA Regional 

Haze Rule 1999). The federal rule’s objective is to achieve the national visibility goal of 

restoring natural visibility conditions to Class I areas by 2064. Generally, the EPA’s default 

estimates of natural conditions are 8 deciviews for the western states and 12 deciviews for the 

eastern states. States may calculate the natural conditions for each Class I area instead of using 

the default goal. Chapter 5: Assessment of Baseline and Current Conditions and Estimate of 

Natural Conditions in Class I Areas discusses natural conditions in more detail. The rulemaking 

addressed the combined visibility effects of sources over a broad geographic region, meaning that 

many states, including all those without Class I areas, must participate in haze reduction efforts. 

The EPA designated five Regional Planning Organizations (RPOs) to assist with the coordination 

and cooperation needed to address visibility and haze issues. Those states and tribes that make up 

the midsection of the contiguous United States, including Texas, were designated as the 

CENRAP. 

1.4 CLASS I AREAS 

Texas has two Class I areas within its borders, both located in West Texas (Figure 1-1: Regional 

Class I Areas). Big Bend National Park (Big Bend), in Brewster County, borders the Rio Grande 

and Mexico. Guadalupe Mountains National Park (Guadalupe Mountains), in Culberson County, 

borders New Mexico. Chapter 11: Long-Term Strategies addresses Texas’ impacts and longterm strategies for Class I areas outside of Texas.
1-5 

Figure 1-1: Regional Class I Areas 

Big Bend National Park 

Big Bend was authorized as a national park on June 20, 1935, and then established and signed 

into law on June 12, 1944, as the nation’s 27th national park. The park gets its name from the 

course of the Rio Grande, which makes a great bend from a southeasterly to a northerly direction 

in the western portion of Texas. Big Bend receives approximately 350,000 visitors annually. 

The park is slightly larger than Rhode Island and comprises more than 801,000 acres (1,252 

square miles). The boundary includes 118 miles of the Rio Grande, which is also the 

international border between the United States and Mexico. In 1978, Congress designated a 196-

mile portion of the Rio Grande, from the Chihuahua and Coahuila state line to the Terrell and Val 

Verde county line, as a Wild and Scenic River. The upper 69 miles are within the boundaries of 

Big Bend. 

The park exhibits dramatic contrasts; its climate is one of extremes. As a result of the range in 

altitude from 1,700 feet along the river to 7,800 feet in the Chisos Mountains, a wide variation in 

available moisture and in temperatures exists throughout the park. These variations contribute to 

the great diversity in plant and animal habitats. 

Big Bend has national significance as the largest protected area of Chihuahuan Desert in the 

continental United States. The park’s river, desert, and mountain environments support an 

extraordinary richness of biological diversity and provide unparallel recreation opportunities. 

Few areas exceed the park’s values for the protection and study of geologic and paleontologic 

resources. Archeologists have discovered artifacts estimated to be 9,000 years old, and historic 

buildings and landscapes offer graphic illustration of life along the international border at the turn 

of the century. Big Bend is rich in economic, cultural, and military history from its extensive use 

by the Comanches, miners, farmers, ranchers, United States cavalry units, and Poncho Villa’s 

revolutionaries. 
1-6 

Big Bend was designated a Biosphere Reserve in 1976, under the Man and the Biosphere 

Program. Big Bend is one of only 250 such areas in the world whose ecosystems are particularly 

well preserved (National Park Service (NPS) 2007). 

Guadalupe Mountains National Park 

Guadalupe Mountains was established on September 30, 1972, and contains Guadalupe Peak, the 

highest point in Texas at 8,749 feet (2,667 meters) in elevation, as well as the next three highest 

peaks in the state. The park covers 86,416 acres and is in the same mountain range as Carlsbad 

Caverns National Park, which is located about 40 miles to the northeast in New Mexico. The 

park also contains the only a congressionally designated wilderness in Texas,of 46,850 acres 

called the Guadalupe Mountains Wilderness at 46,850 acres. The terrain is rough and natural 

with mountain peaks steeply rising up to 3,000 feet above the canyon floors. 

The mountains are a “sky island” rising more than a mile above the floor of the Salt Basin on the 

west. The slopes extend through three major ecological zones from desert to remnants of a high 

altitude forest. Ponderosa pine, Douglas fir, white pine, and quaking aspen grow side by side 

with desert species such as agaves and cacti. The altitude encourages relatively high amounts of 

rainfall that quickly drain into the porous limestone bedrock and recharges the Capitan Aquifer. 

The Guadalupe Mountains preserve the 2,000-foot thick limestone layer of the Capitan Reef, one 

of the finest examples of an ancient marine fossil reef on earth. Outcrops in the park expose 

rocks from the entire range of associated depositional environments from shallow lagoon to reef, 

forereef debris slopes, and deep basin deposits. The park contains the world standard section that 

represents the middle part of the Permian Period of geologic time. Geologists from around the 

world study the 280 to 260 million year old rocks preserved there (NPS 2007). 
2-1 

CHAPTER 2. GENERAL PLANNING PROVISIONS 

2.1 INTRODUCTION 

In accordance with 40 CFR §51.308(a) and (b), the TCEQ submits this state implementation plan 

(SIP) revision to meet the requirements of the EPA’s Regional Haze Rule. This plan addresses 

the core requirements of 40 CFR §51.308(d) and the Best Available Retrofit Technology (BART) 

components of 40 CFR §50.308(e). In addition, this SIP revision addresses coordination with 

regional planning groups, states and tribes, and the Federal Land Managers (FLMs). Texas also 

commits to plan revisions and adequacy determinations as outlined in this SIP. 

2.2 PUBLIC HEARING AND COMMENT INFORMATION 

The TCEQ will provide provided notice to the public of the opportunity to comment on the 

proposed Regional Haze SIP after the commission approval for publication on December 5, 2007. 

The TCEQ will also announceannounced and hold held a public hearing. Notice of both the 

public hearing and the comment period will bewere published in newspapers around the state 

(Appendix 2-1: Public Participation Process). The public comment period will beginbegan

December 21, 2007, and endended February 22, 2008. The public hearing will bewas held in 

Austin on February 19, 2008. The length of the comment period will was longer to give 

sufficient time for the FLMs to provide recommendations on the proposed SIP revision that 

cancould be provided to the general public, as well as meet the requirement that FLMs are 

consulted at least 60 days prior to the public hearing on the SIP revision. The FLM comment 

period begins onwas November 16, 2007, through January 16, 2008. The TCEQ web site will 

provide a summary ofprovided the complete FLM comments at least 30 days prior to the hearing 

date. 

The TCEQ will acceptaccepted comments electronically through the eComments system or by,

fax or , and mail. All comments should referencereferenced the “Regional Haze SIP” and project 

number 2007-016-SIP-NR. Electronic comments may be submitted at 

<http://www5.tceq.state.tx.us/rules/ecomments/>. File size restrictions may apply to comments 

being submitted via the eComments system. All eComments are acknowledged with a 

confirmation e-mail. 

Fax or mail commentsComments went to: 

Margaret Earnest

MC 206

State Implementation Plan Team, Chief Engineer’s Office

Texas Commission on Environmental Quality

P. O. Box 13087

Austin TX 78711-3087 

Fax: (512)-239-5687

Public Hearing 

City Date Time Location 

Austin February 

19, 2008 

2:00 PM Texas Commission on Environmental Quality 

12100 Park 35 Circles, Austin TX 78753 

Building E, Room 201S 

Public comments, including those made by staff of federal agencies, will bewere summarized and 

addressed in Appendix 2-2: Public Comments and Responses on SIP Draft. The final SIP will 

incorporateincorporated public comments as appropriate and will be published on the TCEQ’s 

web site at <http://www.tceq.state.tx.us/implementation/air/sip/bart/haze.html>. 
3-1 

CHAPTER 3. REGIONAL PLANNING 

3.1 OVERVIEW 

In the preamble to the Regional Haze Rule, the EPA acknowledged the key role of regional 

pollutant transport in contributing to haze in federal Class I areas and recognized the value of 

multi-state coordination for planning and implementing regional haze programs (EPA 1999). The 

EPA established grant funding for five RPOs as follows: 

• Central Regional Air Planning Association 

• Western Regional Air Partnership 

• Midwest Regional Planning Organization 

• Visibility Improvement State and Tribal Association of the Southeast 

• Mid-Atlantic/Northeast Visibility Union. 

Figure 3-1: Map of the Regional Planning Organizations shows the geographic areas of the five 

RPOs. Texas is a member of CENRAP, as are Oklahoma, Louisiana, Arkansas, Missouri, 

Kansas, Nebraska, Iowa, and Minnesota. Some tribes, including the Alabama Coushatta of 

eastern Texas, also participate in CENRAP. 

The CENRAP’s planning process was initiated in late 1999 with the first in a series of workshops 

held to develop the organization’s charter and bylaws, to conduct initial long-range planning, and 

to prepare its first grant application. The organization’s charter can be found at CENRAP’s web 

site: <www.cenrap.org>. 

The CENRAP defines the purposes of the organization as follows. 

• Identify regional, common air management issues, and develop and identify strategies to 

address these issues. 

• Promote policies that ensure fair and equitable treatment of all participating members. 

• Coordinate science and technology to support air quality policy issues in the central 

states. 

• Promote the implementation of federal visibility rules. 

• Recommend strategies on regional haze and other air quality issues for use by member 

states and tribes in developing implementation programs, regulations, and laws. 

• Conduct research and undertake other activities as necessary to provide the membership 

with information to support the development of sound state and tribal air pollution 

policies. 

In concurrence with EPA policy, the CENRAP’s bylaws state that “the CENRAP has no 

regulatory authority and recognizes that its members, in accordance with existing law, retain all 

legal authority” (CENRAP 2000). While Texas participates in CENRAP and benefits from the 

technical work coordinated by the RPO, Texas has sole responsibility and authority for the 

development and content of its Regional Haze SIP. 
3-2 

Figure 3-1: Map of the Regional Planning Organizations 

The Policy Oversight Group (POG) is the governing body for CENRAP. The POG establishes 

internal policies, protocols, strategies, and budgets and provides guidance to the various 

CENRAP workgroups. Voting membership on the POG includes: 

• designee of governor or environmental commissioner from each member state; and 

• one tribal representative for each of the EPA Regions V, VI, and VII. 

Ex-officio membership on the POG includes the following: 

• United States Secretary of the Interior or designee; 

• United States Secretary of Agriculture or designee; 

• Administrator of the EPA or designee; 

• two representatives from local programs that are members of the Central States Air 

Resources Agencies (CenSARA); and 

• additional tribal representatives designated in accordance with the bylaws 

The POG established five CENRAP workgroups that work in particular disciplines and facilitate 

the development of the regional haze implementation plans. The workgroups are as follows. 

• Modeling 

• Emissions Inventory 

• Monitoring 

• Implementation and Control Strategies 

• Communications 

The Communications workgroup establishes internal communication protocols, assists with 

contract development, manages the CENRAP web site, and conducts public outreach. The other 

four workgroups conduct strategic planning for their subject matter areas and conduct and 

document the work of contractors or the in-kind services of CENRAP participants. 
3-3 

A Technical Steering Committee comprised of representatives from the states, tribes, and other 

stakeholder groups discusses complex technical issues and provides technical guidance to the 

workgroups. Also, representatives from CENRAP participate in discussions with other RPOs 

about issues that affect some or all of the RPOs and that require close communication among 

these organizations. 

The POG and workgroups meet quarterly or biannually, depending on the need. The technical 

steering committee meets biannually. The POG usually holds conference calls once per month. 

The frequency of workgroup and steering committee conference calls varies. 

The CENRAP may remain active following the initial submission of implementation plans by the 

states, since the Regional Haze Rule requires periodic progress reports and implementation plan 

revisions. The extent to which the CENRAP remains active will depend on the usefulness of the 

organization to its members and the availability of continuing, adequate funding to cover the 

organization’s expenses. 

3.2 HISTORY OF TEXAS PARTICIPATION 

The TCEQ has participated in the planning process for regional haze since December 1999, when 

a workshop was convened by CenSARA to begin developing the charter, bylaws, and initial longrange plan for the CENRAP. After workgroups were formed, the TCEQ participated in the 

Modeling, Emissions Inventory, Monitoring, and Implementation and Control Strategies 

workgroups. The TCEQ designated appropriate workgroup representatives based on their areas 

of expertise. For approximately three years, a TCEQ staff member dedicated time as co-chair of 

the Emissions Inventory workgroup. For more than two years, four TCEQ staff members have 

dedicated time to monthly CENRAP conference calls with four of the technical workgroups and 

dedicated additional time to activities that include analyzing modeling changes, participating in 

quality control checks, and more. In addition, the TCEQ has one SIP coordinator dedicated 

solely to regional haze issues. The TCEQ has represented the state on the POG and technical 

steering committee from their inceptions. 

Significant portions of this SIP were developed based on emissions inventories, modeling, and 

SIP protocols created by the CENRAP and its contractors. Through its participation, the TCEQ 

provided data to the CENRAP in order to produce emissions inventories and modeling that the 

states could use when drafting their Regional Haze SIPs. 

The Regional Haze Rule does not require states and tribes to participate in RPOs. However, 

Texas will continue participation in the CENRAP as necessary to fulfill the state’s legal 

obligations in meeting the requirements of the rule. Texas’ continued participation is contingent 

on CENRAP’s receiving continued, adequate funding from the EPA. 
4-1 

CHAPTER 4. STATE, TRIBE, AND FEDERAL LAND 

MANAGER CONSULTATION 

4.1 INTRODUCTION 

Title 40 CFR §51.308(i) requires each state to consult with identified FLMs prior to the proposal 

of the Regional Haze SIP. In development of this plan, the FLMs were consulted in accordance 

with the provisions of §51.308(i)(2). In developing its reasonable progress goals (RPGs), states 

are required to consult with other states reasonably anticipated to cause or contribute to visibility 

impairment in their Class I areas. If a state determines it has emissions that are reasonably 

anticipated to contribute to visibility impairment in any Class I area in another state, that state 

must consult with the other states when developing its long-term strategy. The TCEQ provided 

other states, tribes, FLMs, and other stakeholders an opportunity for consultation through 

teleconference calls and notified the FLMs of their opportunity to consult in person at least 60 

days prior to holding public hearings. 

During the consultation process, the states, FLMs, and stakeholders were given the opportunity to 

address the assessment of the visibility impairment of visibility in any Class I areas, materials 

presented to stakeholders prior to the consultation calls, recommendations on the development of 

RPGs, and recommendations on the development of strategies to address visibility impairment. 

Throughout the consultation calls, the TCEQ encouraged participants to continue coordination 

and consultation during the development of the SIP prior to adoption. The FLMs must be 

consulted in the following instances: development and review of implementation plan revisions; 

review of five-year progress reports; and development and implementation of other programs that 

may contribute to impairment of visibility in Class I areas. 

4.2 CONSULTATION ON CLASS I AREAS IN TEXAS 

The TCEQ held Regional Haze SIP consultation meetings by conference call with FLMs for the 

Class I visibility areas in Texas, Big Bend and Guadalupe Mountains, other states that impact the 

Texas Class I areas, the EPA, and stakeholders such as industry and environmental 

representatives. Table 4-1: Consultation Calls contains the dates and times of the consultation 

calls. 

Table 4-1: Consultation Calls 

Call Date Time 

1st Consultation call July 11, 2007 2:30-4:00 p.m. 

2nd Consultation call July 18, 2007 10:00-11:30 p.m. 

3rd Consultation call July 31, 2007 10:00-11:30 p.m. 

The first consultation call primarily addressed four technical papers. These papers discussed 

natural conditions, the impacts of dust storms in Big Bend and Guadalupe Mountains, Integrated 

Planning Model (IPM) emission projections, and glide path and RPGs. A summary paper of 

these technical papers was provided to consultation participants. 

The second and third consultation calls consisted of open dialogue between the states and FLMs 

to gather input on the content of the technical papers. Additionally, the FLMs suggested that the 

TCEQ revise the prevention of significant deterioration (PSD) permit process to include FLM 

notification provisions. Texas has committed to further consultations with the FLMs aimed at a 

mutually agreeable set of procedures to address their concerns about the Texas PSD program. 

Deleted: : 

Deleted: ;

Deleted: ;

Deleted: ;
4-2 

More detailed summaries from all three calls are provided in Appendix 4-1: Summary of Three 

Texas Consultation Calls.

A list of persons or entities contacted to participate in the consultation process is provided in 

Appendix 4-2: Contact List for Consultation Calls. Chapter 11 of this SIP also discusses the 

consultation process regarding development of the long-term strategy. 

The TCEQ has determined which states contribute to visibility impairment at the Texas Class I 

area by using the results from the CENRAP particulate matter source apportionment technology 

(PSAT) modeling. These states are New Mexico, Oklahoma, Kansas, and Louisiana. Appendix 

8-1: Technical Support Document for CENRAP Emissions and Air Quality Modeling to Support 

Regional Haze State Implementation Plans shows the pertinent modeling results. Texas is not 

requesting additional reductions from other states at this time. 

4.3 CONSULTATIONS ON CLASS I AREAS IN OTHER STATES 

The TCEQ has participated in the CENRAP since its inception in 1999. The TCEQ has 

cooperated with all CENRAP states, tribes, and FLMs that participated in: 

• developing information on base period 2002 visibility impairment; 

• developing projections of 2018 emissions and visibility impairment considering all 

adopted emissions reductions required in Texas and federal rules; and 

• developing estimates of 2064 natural conditions. 

Texas and federal rules that specifically reduce visibility-impairing pollutants include the Clean 

Air Interstate Rule (CAIR), BART requirements, the emissions reductions from the federal motor 

vehicle emission control program (FMVCP), the EPA refinery consent decrees, and the EPA 

requirements for cleaner non-road diesel and gasoline-powered engines. 

The TCEQ participated in the Modeling, Emissions Inventory, Monitoring, and Implementation 

and Control Strategies workgroups of CENRAP. The TCEQ designated appropriate workgroup 

representatives based on their areas of expertise. For more than two years, the TCEQ has 

dedicated time to monthly technical workgroups through CENRAP conference calls. Since 1999, 

Texas has actively participated in regional planning (Chapter 3). The TCEQ also participated in 

inter-regional planning organization calls that related to modeling. The FLMs, EPA, tribes, 

states, and industry were encouraged to participate in workgroup calls, workshops, and meetings. 

Arkansas and Missouri have begun consultation with Texas about the impact of Texas’ emissions 

on regional haze at the Class I areas in those states. They have accepted Texas’ planned 

emissions and regional haze impact reductions as adequate for their Class I areas. 

Oklahoma has invited Texas to consult about Oklahoma’s Class I area, the Wichita Mountains 

National Wildlife Refuge. The TCEQ attended Oklahoma’s three consultation calls held in 

August and September 2007. 

The TCEQ has reviewed CENRAP modeling to assess which Class I areas in other states might 

be impacted by Texas’ emissions. Modeling indicated that Texas impacts Breton Wilderness 

Area in Louisiana, the Great Sand Dunes in Colorado, and several Class I sites in New Mexico. 

At this time, these states have not invited TexasThe TCEQ also consulted the adjacent states in 

which the modeling data indicated no significant impact by Texas, including Arkansas, Missouri, 

and Oklahoma. 

Through conference calls, Arkansas and Missouri consulted with Texas about the impact of 

Texas’ emissions on regional haze at the Class I areas in those states. They accepted Texas’ 

planned emissions and regional haze impact reductions as adequate for their Class I areas for this 

initial SIP (Appendix 4-3). 
4-3 

Oklahoma invited Texas to consult about Oklahoma’s Class I area, the Wichita Mountains 

National Wildlife Refuge. The TCEQ attended Oklahoma’s three consultation calls held in 

August and September 2007. In August 2007, the TCEQ received a letter from Oklahoma 

regarding visibility improvements in the Wichita Mountains National Wildlife Refuge. The letter 

requested that Oklahoma be able to formal participation in their comment on best available 

control technology determinations for PSD sources that significantly impact Wichita Mountains 

and a request that Class I impact reviews by required for all proposed PSD sources within 300 

kilometers of a Class I area. In an October 2007, response letter the TCEQ has agreed to notify 

Oklahoma, along with the relevant FLM, whenever modeling indicates that a proposed source 

significantly impacts Wichita Mountains. In regards to the 300 kilometer request, the TCEQ is 

urging the EPA to adopt significant impact levels for Class I reviews so that there is a standard 

review process across the country. During the interim, the TCEQ is committed to working with 

the FLMs on mutually acceptable criteria for determining when a proposed PSD source should 

conduct a Class I review. Appendix 4-3: Additional Consultation with States contains a copy of 

these letters. 

In response to comments from the EPA and FLMs in March 2008, the TCEQ sent consultation 

letters to Oklahoma, Louisiana, Missouri, Arkansas, Colorado and New Mexico. Included with 

the letters were a discussion and data of the CENRAP Particulate Matter Source Apportionment 

Technology (PSAT) modeling determining the contribution from each Texas source area to 

visibility impairment at Class I areas in the given state. The TCEQ participated fully in the 

analysis of this data, base period visibility impairment, natural visibility condition estimates, and 

2018 projections based on current and anticipated future state and federal controls. The PSAT 

modeling indicates that the probable impact of Texas sources will be reduced by 2018 in all of the 

affected Class I Areas due to the expected emissions reductions from current and planned 

controls. Also included with the consultation processletter, where applicable, were area of 

influence maps for each Class I area in the CENRAP states. For reference purposes, the map 

showed the portions of Texas that are in the first and second order sulfate and nitrate areas of 

influence for the given Class I Area. The sulfur dioxide and nitrogen oxide sources shown on the 

map are Texas sources the TCEQ identified as high priority due to the fact that they have an 

emissions over distance equal to or greater than five (q/d ≥ 5) for one or more Class I areas. Also 

included was a table of sources of particular interest to the affected Class I Area(s) due to their 

emissions and their positions within the area of influence. The TCEQ also requested recipients of 

the letters to confirm they are not expecting any additional emission reductions. These letters and 

associated documents are included in Appendix 4-3. 

In an April 21, 2008, letter, Missouri’s Department of Natural Resources responded that no 

further emissions reductions were requested of Texas (Appendix 4-3). In a June 10, 2008, letter, 

Arkansas’ Department of Environmental Quality responded that no further emissions reductions 

were requested of Texas (Appendix 4-3). In a June 24, 2008 letter, Colorado’s Department of 

Public Health and Environment responded that no further emissions reductions were requested of 

Texas at this time (Appendix 4-3). Louisiana sent confirmation that “the Louisiana Department 

of Environmental Quality has determined that emissions form the State of Texas do not contribute 

to visibility impairment at Breton Wilderness Class I Area.” New Mexico has not responded to 

the letter as of December 2008. 

 
5-1 

CHAPTER 5. ASSESSMENT OF BASELINE AND CURRENT CONDITIONS AND 

ESTIMATE OF NATURAL CONDITIONS IN CLASS I AREAS 

5.1 VISIBILITY REQUIREMENTS 

The goal of the Regional Haze Rule is to restore natural visibility conditions to the 156 Class I 

areas identified in the 1977 FCAAFederal Clean Air Act Amendments. Title 40 Code of Federal 

Regulations (CFR) §51.301 defines natural conditions as including “naturally occurring 

phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, 

or coloration.” State regional haze plans must contain measures that make “reasonable progress” 

toward this goal by reducing anthropogenic emissions that cause haze. Three metrics of visibility 

are part of the determination of progress toward this goal: 

• baseline conditions, i.e., conditions observed during the baseline period, 2000 through 

2004; 

• natural conditions, i.e., those conditions existing in the absence of human-induced 

visibility impairment; and 

• current conditions, i.e., conditions observed during the current period, which is the same 

as the baseline, for this initial period. 

To calculate these metrics the concentrations of visibility-impairing pollutants are included as 

distinct terms in a light extinction algorithm with respective extinction coefficients and relative 

humidity factors. Total light extinction when converted to a haze index in deciviews is calculated 

for the average of the best 20 percent and worst 20 percent visibility days. Title 40 CFR §51.301 

defines a deciview as “a haze index derived from calculated light extinction, such that uniform 

changes in haziness correspond to uniform incremental changes in perception across the entire 

range of conditions, from pristine to highly impaired.” 

Texas and other CENRAP states have elected to perform their primary visibility projections using 

the new Interagency Monitoring of Protected Visual Environments (IMPROVE) algorithm to 

calculate visibility metrics for developing RPGs because this algorithm is based on more recent 

science and the updated algorithm better fits the observed light extinction values. Appendix 5-1: 

Discussion of the Original and Revised IMPROVE Algorithms provides a discussion on the 

choice of the IMPROVE algorithm comparing the old and new equations. For more detailed 

documentation on the original (old) and revised (new) algorithm changes, please visit the 

IMPROVE web site at http://vista.cira.colostate.edu/improve. 

Baseline visibility is, the starting point for the improvement of visibility conditions. It, is the 

average obtained fromby using monitoring data for 2000 through 2004 and represents current 

visibility conditions for this initial period. Comparison of initial baseline conditions to natural 

visibility conditions revealsshows the improvement necessary to attain natural visibility by 2064. 

Natural visibility is determined by estimating the natural concentrations of visibility-impairing 

pollutants and then calculating total light extinction with the chosen light extinction algorithm 

(Figure 5-1: Generic Glide Path to Achieve Natural Conditions in 60 Years). Each state must 

estimate natural visibility levels for Class I areas within its borders in consultation with FLMs 

and other states that impact the Class I areas (40 CFR §51.308(d)(2)). Current conditions are 

assessed every five years as part of the plan review where actual progress in reducing visibility 

impairment is compared to reduction commitments in the plan. 
5-2 

Figure 5-1: Generic Glide Path to Achieve Natural Conditions in 60 Years 

Source: EPA 

5.1.1 Default and Refined Values for Natural Visibility Conditions 

The EPA’s Guidance for Estimating Natural Visibility Conditions Under the Regional Haze 

Program (EPA 2003) provides states a “default” estimate of natural visibility. The default values 

of concentrations of visibility pollutants are based on a 1990 National Acid Precipitation 

Assessment Program report (Trijonis, 1990). In the EPA’s guidance, the United States is divided 

into East and West regions approximately along the western boundary of the states one tier west 

of the Mississippi River. This division divides the CENRAP states into its own East region 

(Arkansas, Iowa, Louisiana, Minnesota, and Missouri), containing seven Class I areas, and West 

region (Kansas, Nebraska, Oklahoma, and Texas), containing three Class I areas. In comparing 

the two regions, only sulfate (SO4) and organic carbon have different values, but the calculated 

deciview difference is significant. 

However, the ultimate responsibility for calculating natural conditions lies with theeach state 

(40 CFR §51.308(d)(2)). The TCEQ determined that the default estimates were insufficiently 

accurate and that data and methods were available to improve these estimates, and. Therefore, 

TCEQ chose to develop its own refined estimates. 

5.1.2 Consultation Regarding the Visibility Metrics 

Consultation among states is required by the Regional Haze Rule. As part of a long-term strategy 

for regional haze, a state whose emissions are “reasonably anticipated” to contribute to 

impairment in other states’ Class I areas must consult with those states (40 CFR §51.308(d)(3)). 

Likewise, states with Class I areas are to consult with any states whose emissions affect their 

Class I areas. Consultation among states is facilitated through RPOs, though some required 

consultations cross RPO boundaries. For example, Texas and New Mexico must collaborate on 

planning for the Guadalupe Mountains, though the two states participate in different RPOs. 

A chief purpose of the RPOs is to provide a means for states to confer on all aspects of the 

regional haze issue, including consultation on RPGs and long-term strategies, which are based on 

the baseline, current, and natural visibility determinations. This process is described in Chapter 

3: Regional Planning. The CENRAP provides a forum for member states and tribes to consult 

on determinations of baseline and natural visibility conditions in subject Class I areas. States in 

the CENRAP have also conferred with neighboring Class I area states outside CENRAP, both 

individually and by way of the appropriate RPO. 
5-3 

Title 40 CFR §51.308(i) requires Class I area states to coordinate with the FLMs, including 

consultation on implementation, assessment of visibility impairment, and recommendations 

regarding RPGs and strategies for improvement. This consultation requirement is discussed in 

Chapter 4: State, Tribe, And Federal Land Manager Consultation. Through participation in the 

CENRAP and individually, Texas has completed this regulatory requirement. 

5.2 BASELINE VISIBILITY CONDITIONS 

For the five-year baseline period, 2000 through 2004, sites are required to have three valid years 

of data from which baseline conditions can be constructed. The Visibility Information Exchange 

Web System (VIEWS) <http://vista.cira.colostate.edu/views/> has posted haze index values, 

based on the revised IMPROVE algorithm, for the 20 percent worst and best days for each 

complete year of the baseline period. From these values, the baseline haze index is calculated by 

averaging over the baseline period. Table 5-1: Baseline Haze Indices shows this calculation for 

both Big Bend and Guadalupe Mountains using the VIEWS summary data updated August 2007. 

Baseline visibility for the Big Bend Class I area is 5.78 deciviews for the best 20 percent of the 

sample days and 17.30 deciviews for the worst 20 percent of the sample days. This baseline 

visibility is based on sampling data collected at the Big Bend IMPROVE monitoring site. 

Baseline visibility for the Guadalupe Mountains Class I area is 5.95 deciviews for the best 20 

percent of the sample days and 17.19 deciviews for the worst 20 percent of the sample days. This 

baseline visibility is based on sampling data collected at the Guadalupe Mountains IMPROVE 

monitoring site. 

Table 5-1: Baseline Haze Indices 

Haze Index (deciviews) Class I Area Site ID Year 

Most Impaired Least Impaired 

2001 17.31 7.09 

2002 18.21 5.68 

2003 17.18 5.74 

2004 16.51 4.62 

Big Bend* BIBE1 

Average 17.30 5.78 

2000 17.14 6.26 

2001 16.61 6.34 

2002 18.12 6.38 

2003 18.50 5.91 

2004 15.57 4.83 

Guadalupe Mountains GUMO1

Average 17.19 5.95 

 * The fourth quarter of 2000 for Big Bend was not sufficiently complete for use in calculating a baseline 

average for regulatory purposes: The fourth quarter had only ten complete days. 

5.3 NATURAL VISIBILITY CONDITIONS 

Using the revised IMPROVE algorithm and the methodology detailed in Appendix 5-2: Estimate 

of Natural Visibility Conditions, the TCEQ has determined, subject to significant uncertainties in 

natural concentrations of organic carbon, that natural visibility conditions for the Big Bend Class 

I area are best represented by 10.09 deciviews for the worst 20 percent days. The Guadalupe 

Mountains Class I area is best represented by 12.26 deciviews for the worst 20 percent days. 

Appendix 5-2 provides calculations, methodologies, a discussion of the reasons for the selection 

of the methodology, and a demonstration of the appropriateness of these values for both Class I 

areas. Table 5-2: Visibility Metrics for the Class I Areas in Texas reports the visibility metrics 

computed for Big Bend and Guadalupe Mountains. 
5-4 

Table 5-2: Visibility Metrics for the Class I Areas in Texas 

Estimate of Natural Visibility Conditions 

Haze Index (deciviews) Class I Area 

Most Impaired Least Impaired 

Big Bend 10.09 2.19 

Guadalupe Mountains 12.26 2.10 

Baseline Visibility Conditions, 2000–2004 

Haze Index (deciviews) Class I Area

Most Impaired Least Impaired 

Big Bend 17.30 5.78 

Guadalupe Mountains 17.19 5.95 

Estimate of Extent Baseline Exceeds Natural Visibility 

Conditions 

Haze Index (deciviews) Class I Area

Most Impaired Least Impaired

Big Bend 7.21 3.59 

Guadalupe Mountains 4.93 3.85 

Analysis of the dust storms that dominate high dust events at Guadalupe Mountains and 

significantly impact Big Bend suggests that the dust originates from dry desert and dry lake bed 

areas with little or no human activity, almost all of which are situated in the Chihuahuan Desert. 

For instance, Gill, et al. conclude that “Field campaigns revealed that ... the vast majority of 

source points were natural desert landscapes” (Gill et al. 2005). 

The times when human-caused dust is likely to be more important at these sites are on days with 

less visibility impairment than on the worst dust impaired days, since the most dust impaired days 

are dominated by dust storms and other blowing dust from the surrounding desert landscape. As 

shown in the dust storm paper of Appendix 5-2a, there are enough dust storm days at Guadalupe 

Mountains to make a reasonable estimate of the worst 20 percent natural visibility conditions. In 

other words, there were enough dust storms documented at Guadalupe Mountains to account for 

all of the worst 20 percent days. This lends credence to the assumption that natural dust 

dominates on those days and that human-caused dust is of minimal importance for the low 

visibility days. 

The situation at Big Bend is a little more uncertain because the dust impact is less from major 

dust storms and more from “locally”1 windblown dust, as shown by the studies by Kavouras, et 

al. (2006 and 2007). However, the area of the park is approximately 801,000 acres, and broad 

restrictions on human use of the park are in place to minimize human impact on its desert 

environment. Additionally, the Big Bend IMPROVE monitoring site is surrounded by the park, 

with the closest park boundary approximately ten miles away, while land use and soil erodibility 

indicates the landscape surrounding Big Bend (and even Guadalupe Mountains) is 

overwhelmingly dominated by highly erodible soils in scrub/scrubland areas. 

As explained in Appendix 5-2: Estimate of Natural Visibility Conditions, the estimates for what 

portion of each visibility component is to be considered as natural, at least for the estimation of 

natural visibility values for Texas’ Class I areas, is taken to be essentially the same as used by the 

Natural Conditions II (NC II) committee (Pitchford, et al. 2006), with the exception of fine soil 

(FS) and course mass (CM). As justified within that appendix and within the other referenced 

 

1

 Note that “local” as used in the Kavouras work does not correspond with any distance measure, but with 

how well the dust dominated days in the 20 percent worst measured visibility days correlated with local 

wind speed and direction. 
5-5 

10.1

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Figure 5-2: Big Bend Uniform Rate of Progress (URP) 

TX NC is Texas’ estimate of natural conditions. 

80 % CM&FS is a comparison where 80 percent of fine soil and course mass is taken as natural. 

12.3

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Figure 5-3: Guadalupe Mountains Uniform Rate of Progress 
5-6 

work, the TCEQ estimate takes essentially all fine soil and course mass concentrations to be 

approximated as natural, at least for the estimation of the least and most impaired natural 

visibility values for Texas’ Class I areas. (The actual computations are carried out using each 

area’s own data.) 

Since the estimate has some degree of uncertainty, just as there is uncertainty in the estimates 

used by the NC II, the TCEQ provides in Figure 5-2: Big Bend Uniform Rate of Progress (URP)

and Figure 5-3: Guadalupe Mountains Uniform Rate of Progress graphs of the Uniform Rate of 

Progress (URP) for the worst 20 percent days both with the estimate approximating 100 percent 

fine soil and course mass as natural (TX NC) along with a calculation treating only 80 percent 

fine soil and course mass as natural (80% CM&FS), for both Texas Class I areas. This 80 percent 

calculation is displayed due to a request from some Federal Land Managers to illustrate how 

sensitive this natural visibility estimate is to approximating 100 percent of the fine soil and course 

mass as natural; there is no other significance to this 80 percent calculation for this SIP. 

5.4 NATURAL VISIBILITY CONDITIONS ONGOING EFFORTS

Because natural visibility estimates are calculated from complex environmental chemistry, 

require significant assumptions in the calculation and are ultimately calculated without a directly 

observable measurement, there remains considerable potential for improvement in estimation. 

Since the natural concentrations and statistics of all components important for Regional Haze 

have significant uncertainties, the TCEQ will be continuing to evaluate data, modeling, and any 

other sources of information, as well as potentially devising additional monitoring, sampling 

and/or analysis schemes, in order to further improve these estimates. Furthermore, the TCEQ 

plans to work with the EPA, FLMs, and other experts and researchers to refine natural conditions 

estimates for future five-year reports and major regional haze SIP revisions. 

At this point, the component that most likely needs improved estimation is organic carbon.2 

Improved sampling and/or analysis techniques are likely methods in the pursuit of an improved 

characterization of the natural contributions to this component. However, the application of such 

methods will depend upon available resources and estimates of potential benefits. 

 

2

 Additionally, there is significant regulatory uncertainty with regard to what prescribed fires should or 

should not be considered as “natural.” When the EPA revises the Interim Air Quality Policy on Wildland 

and Prescribed Fires, it is expected such issues will be clarified. 
6-1 

CHAPTER 6. MONITORING STRATEGY 

6.1 INTRODUCTION 

Title 40 CFR §51.308(d)(4) of the Regional Haze Rule requires a monitoring strategy for 

measuring, characterizing, and reporting regional haze visibility impairment that is representative 

of all mandatory Class I areas within Texas. The monitoring strategy relies upon data from the 

Interagency Monitoring of Protected Visual Environments (IMPROVE) program. A steering 

committee with representatives from federal, regional, and state organizations governs the 

program. These organizations include the United States Environmental Protection Agency 

(EPA), the National Park Service (NPS), the United States Fish and Wildlife Service (FWS), the 

United States Forest Service, the Bureau of Land Management (BLM), the National Association 

of Clean Air Agencies, and other entities. The IMPROVE Steering Committee allocates 

IMPROVE monitoring resources, which come from a number of agencies. Much of the funding 

comes from including the EPA from funds appropriated by Congress to support state air quality 

management programs. Some funding comes from the, NPS, FWS, and BLM. The IMPROVE 

program arranges for the operation of IMPROVE monitors, the analysis of samples from the 

monitors, and the validation and internet posting of the IMPROVE data as well as maintenance of 

the Visibility Information Exchange Web System (VIEWS) web site 

<http://vista.cira.colostate.edu/views>, which makes the data easily available to states, regional 

planning organizations, and the public. The state regional planning organizations (RPOs) 

contribute financial support to the VIEWS program and web site. 

6.2 MONITORING AT CLASS I AREAS IN TEXAS 

Currently, the IMPROVE program provides an IMPROVE monitor at each of the two Class I 

areas in Texas, Big Bend and Guadalupe Mountains. Because of their location, the monitors are 

appropriate for determining progress in reducing visibility impairment in the Texas Class I areas. 

The monitoring strategy relies on continuation of IMPROVE monitoring at these sites. The 

Texas Commission on Environmental Quality (TCEQ will continue) plans to continue to 

participate in the IMPROVE network through the financial support of the EPA. The TCEQ will 

also continue to participate in the IMPROVE program through its membership in plans to 

continue supporting the VIEWS work and the VIEWS web site by urging CENRAP as long as the 

EPA continues to fund the CENRAP adequatelyto continue its funding of VIEWS. No additional 

monitoring beyond the IMPROVE network is required or necessary for assessing visibility 

conditions at the two Class I areas in Texas or at the Class I areas that Texas’ emissions affect in 

other states. 

The IMPROVE program reviewed its aerosol monitoring sites in 2006 to set priorities for 

maintaining the sites, in the event of federal budget cuts affecting the IMPROVE program. This 

review determined that the IMPROVE aerosol samplers at Texas’ two Class I areas represent 

conditions different from the conditions at the nearest Class I area IMPROVE monitors. Texas’ 

two Class I IMPROVE monitors are not candidates for discontinuation since other IMPROVE 

monitors cannot represent conditions at Big Bend or Guadalupe Mountains. 

The TCEQ considers that continued IMPROVE monitoring at all current Class I IMPROVE sites 

that Texas’ emissions impact and continued VIEWS services are all centrally important to the 

effort to monitor reductions in anthropogenic haze impacts at these sites. If funding for these 

IMPROVE sites or the VIEWS program is threatened, the TCEQ plans to work closely with the 

EPA, the FLMs, and neighboring states to attempt to find the funding to continue the current 

Class I IMPROVE monitoring and VIEWS services for these sites. 

6.3 ASSESSMENT OF VISIBILITY IMPROVEMENT AT CLASS I AREAS 

Future assessments of visibility impairment and progress in reducing visibility impairment at 

Texas’ two Class I areas, and at Class I areas in other states that Texas’ emissions affect, will use 

the new IMPROVE equation and will use data as prescribed in the EPA’s Regional Haze Rule 

(40 CFR Part 51, Subpart P). The assessment will follow, as appropriate, the EPA’s official 
6-2 

guidance including Guidance on the Use of Models and Other Analyses for Demonstrating 

Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze (EPA 2007). 
6-3 

6.4 REPORTING VISIBILITY MONITORING DATA TO THE ADMINISTRATOR 

The TCEQ does not directly collect or handle IMPROVE data. The TCEQ will plans to continue 

to 

participate in the IMPROVE Visibility Information Exchange Web System (VIEWS) through 

CENRAP <http://vista.cira.colostate.edu/views>. The TCEQ considers VIEWS to be a core part 

of the overall IMPROVE program. The TCEQ will plans to continue to report IMPROVE data 

from the two Class I areas in Texas to the EPA by continuing to support its posting on the 

VIEWS web system. The TCEQ’s support will be through continuing membership in CENRAP 

and through requesting that both the EPA and this multi-state organization continue to support 

VIEWS. 

If Texas collects any visibility monitoring data through the state’s air quality monitoring 

networks, the TCEQ will report those data to the EPA as specified under the Performance 

Partnership Grant agreement negotiated with the EPA Region 6. All validated data and data 

analysis results from any TCEQ visibility-related special studies are public information. TCEQ 

willplans to continue its practice of sharing the data and information with the EPA, the Federal 

Land Managers, and the public. 

The TCEQ currently has a TEOM (tapered element oscillating microbalance) continuous monitor 

for PM2.5, an every-sixth-day chemical speciation monitor, and meteorological equipment 

operating at Big Bend. The data from these monitors is available from the TCEQ. Additionally, 

the TCEQ hosts the National Park Service’s Big Bend ozone data on the TCEQ web site. 

6.5 ASSESSING THE IMPACT OF EMISSIONS FROM TEXAS ON CLASS I AREAS 

Chapters 5, 8, 10, and 11 describe the procedures used in developing this SIP revision. These 

chapters include the procedures to assess the quantitative impact of emissions from Texas on 

Class I areas in Texas and on Class I areas that Texas’ emissions affect in other states. 

Chapter 7 describes the procedures used for this SIP revision to produce the statewide emissions 

inventory of pollutants reasonably anticipated to cause or contribute to visibility impairment in all 

the mandatory Class I areas that Texas’ emissions affect. Chapter 12 describes the plans for the 

five-year implementation plan review and for the 2018 regional haze SIP revision. 

The Performance Partnership Grant agreement negotiated with the EPA Region 6 and the quality 

assurance procedures for collecting and reporting periodic emissions inventories to the EPA 

describe the collection, quality assurance, record keeping, maintenance, availability, and 

reporting of emissions and monitoring data to the EPA. 

Deleted: 
7-1 

CHAPTER 7. EMISSIONS INVENTORY 

Title 40 CFR §51.308(d)(4)(v) requires a statewide emissions inventory of pollutants that are 

reasonably anticipated to cause or contribute to visibility impairment in any Class I area. As 

specified in this section, the pollutants to be inventoried include volatile organic compounds 

(VOC), nitrogen oxides (NOX), fine particulate matter (PM2.5), particulate matter less than ten 

microns in diameter (PM10), ammonia (NH3), and sulfur dioxide (SO2). In accordance with the 

EPA guidance, the TCEQ developed a baseline Texas inventory for the year 2002, and submitted 

the inventory to the Central Regional Air Planning Association (CENRAP) for use in 

photochemical modeling supporting the Regional Haze SIP. A summary of the CENRAP 

developed 2002 Texas inventory is provided in Table 7-1: CENRAP’s 2002 Base Year Emissions 

Inventory Summary for Texas. Details for the 2002 emissions inventory are provided in 

Appendix 7-1: Texas Emissions Inventory Development: Base Year 2002 and Projected Year 

2018.

Table 7-1: CENRAP’s 2002 Base Year Emissions Inventory Summary for Texas 

Category CO 

(tpy) 

NOX 

(tpy) 

SO2 

(tpy) 

TOG* 

(tpy) 

PM2.5 

(tpy) 

PM10 

(tpy) 

NH3 

(tpy) 

Area 

 

908,407 

 

280,811 111,853 1,163,549 347,490 1,552,824 380,057 

Point 

 

498,467 

 

600,725 821,961 207,695 46,789 80,947 

 

2,609 

NonRoad 

 

1,210,158 

 

242,551 21,828 148,952 15,089 15,556 56 

On-Road 

 

4,098,391 

 

664,163 18,814 309,707 11,275 15,476 

 

21,599 

Total 

 

6,715,423 1,788,250 974,457 1,829,902 420,642 1,664,803 404,321 

*TOG is total organic gas, which includes total hydrocarbons. 

The 2002 baseline inventory is composed of several different categories. The point sources are 

defined as industrial, commercial, or institutional sites that meet the reporting requirements of 30 

Texas Administrative Code (TAC) §101.10. Area sources include commercial, small-scale 

industrial, and residential categories of sources that use materials or operate processes that can 

generate emissions. These sources of emissions fall below the point source reporting levels and 

are too numerous or too small to identify individually. The area source fires inventory is also 

included in the area source category. This category includes agricultural burning, prescribed 

burning of forests, and prescribed burning of rangeland. The fugitive dust inventory includes dust 

from construction, mining, quarrying, bulk materials storage (such as coal and gravel), and 

feedlots. 

The area source SO2 emissions modeledused by the CENRAP in their modeling are significantly 

higher than the 15,633 tons per year (tpy) reported by the TCEQ. The difference is industrial and 

residential coal combustion which was erroneously included in the CENRAP inventory. The 

TCEQ has been working with CENRAP to correct this error for future modeling, but there was 

not sufficient time to remodel with the more accurate TCEQ-supplied inventory. CENRAP’s 

modeled emissions estimate is not expected to significantly impact visibility estimates for 2018 

because of the relatively small contribution from these Texas sources on Class I areas. 

Non-road mobile sources include aircraft operations, marine vessels, recreational boats, railroad 

locomotives, and a broad category of non-road equipment that include everything from 600-

horsepower engines mounted on construction equipment to one-horsepower string trimmers. 

On-road mobile sources of emissions consist of automobiles, trucks, motorcycles, and other 

motor vehicles traveling on public roadways. On-road mobile source emissions are usually 
7-2 

categorized as either combustion-related emissions or evaporative hydrocarbon emissions. 

Combustion-related emissions are estimated for vehicle engine exhaust. Evaporative 

hydrocarbon emissions are estimated for the fuel tank and other evaporative leak sources on the 

vehicle. 

Biogenic sources include hydrocarbon emissions from crops, lawn grass, and trees as well as a 

small amount of NOX emissions from soils. These emissions are listed in Table 7-2: Statewide 

Biogenic Emissions. 

Table 7-2: Statewide Biogenic Emissions 

Nitrogen Oxide 

 (tpy) 

Carbon Monoxide 

(tpy) 

Volatile Organic 

Biogenic Compounds (tpy) 

184,896 755,941 4,033,760 

Methodologies used in developing the 2002 emissions inventory are documented in Appendix 

7-1. Technical The technical support documents compiled by the CENRAP are available at 

<www.cenrap.org>in Appendix 8-1: Technical Support Document for CENRAP Emissions and 

Air Quality Modeling to Support Regional Haze SIP. 

The CENRAP projected the 2002 base year emissions for Texas and other central states to the 

2018 future planning year primarily using the Economic Growth Analysis System 

(EGAS6EGAS5) for non-electric generating unit point sources, area sources, and non-road 

mobile sources; MOBILE6 for on-road mobile sources; and the Integrated Planning Model 

Version (IPM) 2.19 for electric generating units (Appendix 7-2: Integrated Planning Model 

Projections of Electric Generating Unit Emissions for the Regional Haze State Implementation 

Plan). Emissions from recently permitted electric generating units were incorporated into the 

IPM file. Only the units that will be shut down under enforceable actions are removed from the 

future inventory. 

This approach is likely to significantly over predictFrom 2002 to 2018, the CENRAP projected 

point source emissions increases in the organic compounds, CO, and particulate matter (PM) 

categories. For non-EGU industrial sources, CENRAP predicted increases in all contaminant 

categories (ranging from slight increases in NOX and SO2 to significant increases in CO and 

organic compounds). The increases predicted by CENRAP’s inventory are contra-indicated by 

the actual decreases represented in the annual inventory data collected between 2002 and 2005. 

See Appendix 7-2 for a summary of the 2005 inventory. Between 2002 and 2005, the historical 

data indicate actual source emissions have decreased or held approximately constant for the point 

sources in all categories except CO from EGUs. Based on historical decreases in emissions, 

CENRAP’s predicted increase is considered conservative and likely over predicts Texas point 

source emissions for 2018 and therefore is a conservative approach to the inventory development. 

Statewide point source emissions have declined every year in Texas in an environment of 

significant economic growth. A summary of Texas emissions projected to 2018 is provided in 

Table 7-3: CENRAP’s 2018 Emissions Inventory Summary for Texas. 
7-3 

Table 7-3: CENRAP’s 2018 Emissions Inventory Summary for Texas 

Category CO 

(tpy) 

NOX 

(tpy) 

SO2 

(tpy) 

TOG 

(tpy) 

PM2.5 

(tpy) 

PM10 

(tpy) 

NH3 

(tpy) 

Area 

 

899,497 

 

274,663 114,138 1,420,681 354,712 1,557,089 562,379 

Point 

 

542,128 

 

525,174 625,068 283,290 80,577 121,733 

 

6,790 

NonRoad 

 

1,921,674 

 

167,451 6,988 119,855 10,588 11,498 239 

On-Road 

 

2,710,631 

 

148,387 2,925 125,234 5,337 5,337 

 

32,191 

 Total 

 

6,073,930 1,115,676 749,119 1,949,060 451,214 1,695,657 601,598 

*TOG is total organic gas, which includes total hydrocarbons 

Methodologies used by the CENRAP in developing the 2018 emissions inventory are 

documented in Appendix 7-1. Technical support documents detailing the inventory development 

are available but are not included in Appendix 8-1. These documents are available at 

<www.cenrap.org>.<www.tceq.state.tx.us/implementation/air/sip/bart/haze_appendices.html>. 

A comparison of the change in emissions by source category is shown in Figure 7-1: Comparison 

of Base and Projected Annual Emissions by Source Category. Even though PM2 5 is a 

subcategory of PM10, both are shown for purposes of comparison. 

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

Area 2002 Area 2018 Point 2002 Point 2018 Non-road

2002

Non-road

2018

On-road

2002

On-road

2018

Tons per year

NH3

PM10

PM2.5

TOG

SO2

NOX

CO

Figure 7-1: Comparison of Base and Projected Annual Emissions by Source Category 

Deleted: 7
8-1 

CHAPTER 8. MODELING ASSESSMENT 

8.1 OVERVIEW 

The Texas Commission on Environmental Quality (TCEQ) participated in the Central Regional 

Air Planning Association (CENRAP) regional planning process, as described in Chapter 3: 

Regional Planning and is using the technical work conducted by CENRAP in support of this state 

implementation plan (SIP) revision (Table 8-1: Federal Mandated Class I Areas in the CENRAP 

States). The CENRAP 2002 and projected 2018 annual emissions and air quality modeling was 

performed by the CENRAP modeling team. Where necessary, the TCEQ also conducted analyses 

specific to Texas. For instance, the TCEQ conducted best available retrofit technology (BART) 

screening modeling analyses independently from CENRAP, but used the databases developed by 

CENRAP as the basis for the analyses. The BART screening modeling analyses are described 

further in Chapter 9: Best Available Retrofit Technology. 

This chapter describes CENRAP regional emissions and air quality modeling that was conducted 

to support the central states’ regional haze SIPs. The information contained in this chapter draws 

from the Technical Support Document (TSD) developed by the CENRAP modeling team. The 

TSD, contained in Appendix 8-1: Technical Support Document for CENRAP Emissions and Air 

Quality Modeling to Support Regional Haze SIP, provides further detail on the modeling 

analyses. Chapter 1 of the TSD presents the background, an overview of the approach, and a 

summary of the results of the CENRAP meteorological, emissions, and air quality modeling. 

Appendix A of the TSD contains more details on the meteorological model evaluation. Details 

on the emissions modeling are provided in Chapter 2 and Appendix B of the TSD. The model 

performance evaluation is presented in Chapter 3 and Appendix C of the TSD. The 2018 

visibility projections and comparisons with the 2018 uniform rate of progress (URP) point are 

provided in Chapter 4 of the TSD, with more details given in Appendix D. Chapter 5 of the TSD 

contains additional supporting analysis with details on the particulate matter (PM) source 

apportionment modeling and alternative projections provided in Appendices E and F of the TSD, 

respectively. Chapter 6 lists the references cited in TSD. 

8.2 BACKGROUND 

The 1977 Federal Clean Air Act (FCAA) amendments added the protection of visibility in 

Federal Class I areas and established the national goal for visibility protection. The FCAA 

requires states to submit SIPs containing emission limits and schedules of compliance. In 

response to these mandates, the United States Environmental Protection Agency (EPA) 

promulgated the Regional Haze Rule requiring states to establish goals that provide for 

reasonable progress towards achieving natural visibility conditions at Class I areas. CENRAP has 

used regional air quality models to determine the level of visibility improvement expected by 

2018. 

The CENRAP Emissions and Air Quality Modeling Team consists of staff from ENVIRON and 

University of California at Riverside (UCR), with assistance and coordination from the CENRAP 

states, tribes, federal agencies, and stakeholders. The team performed the emissions and air 

quality modeling simulations for states and tribes within the CENRAP region, which provided 

analytical results used in developing implementation plans under the Regional Haze Rule. The 

CENRAP team performed emissions and air quality modeling used by the TCEQ to determine the 

2018 reasonable progress goals (RPGs). 
8-2 

Table 8-1: Federal Mandated Class I Areas in the CENRAP States 

Class I Area Acreage Federal Land 

Manager Public Law 

Arkansas

Caney Creek Wilderness Area 14,460 USDA-FS 93-622 

Upper Buffalo Wilderness Area 12,018 USDA-FS 93-622 

Louisiana

Breton Wilderness Area 5,000+ USDI-FWS 93-632 

Minnesota

Boundary Waters Canoe Area Wilderness 810,088 USDA-FS 99-577 

Voyageurs National Park 114,964 USDI-NPS 99-261 

Missouri

Hercules-Glades Wilderness Area 12,314 USDA-FS 94-557 

Mingo Wilderness Area 8,000 USDI-FWS 95-557 

Oklahoma

Wichita Mountains Wilderness Area 8,900 USDI-FWS 91-504 

Texas

Big Bend National Park 708,118 USDI-NPS 74-157 

Guadalupe Mountains National Park 76,292 USDI-NPS 89-667 

8.3 CENRAP MODELING TEAM 

The CENRAP goals included support to states and tribes to meet the requirements of the 

Regional Haze Rule and development of scientifically supportable, cost-effective control 

strategies that the states and tribes may adopt to reduce anthropogenic effects on visibility 

impairment at Class I areas. One component of CENRAP’s support to states and tribes as part of 

compliance with the Regional Haze Rule is performing emissions and air quality modeling. The 

CENRAP implemented modeling projects to: 

• obtain a better understanding of the causes of visibility impairment; 

• identify potential mitigation measures for visibility impairment at Class I areas; 

• evaluate the effects of alternative control strategies for improving visibility; and 

• project future-year air quality and visibility conditions. 

The CENRAP Emissions and Air Quality Modeling Team performed the following activities: 

• emissions processing and modeling; 

• air quality and visibility modeling simulations; 

• analysis, display, and reporting of modeling results; and 

• storage and quality assurance of the modeling input and output files. 

The team performed work for the CENRAP Modeling Workgroup under the supervision from the 

CENRAP technical director, the CENRAP executive director, and the chair of the Modeling 

Workgroup. 
8-3 

8.4 THE 2002 ANNUAL EMISSIONS AND AIR QUALITY MODELING 

The CENRAP 2002 annual emissions and air quality modeling started on October 16, 2004. The 

effort involved the preparation of numerous databases, model simulations, presentations, and 

reports. Many of the modeling analyses are posted on the CENRAP modeling website at: 

http://pah.cert.ucr.edu/aqm/cenrap/index.shtml. The TCEQ also has many of these modeling 

analyses available on request only, as these are very large files 

http://www.tceq.state.tx.us/implementation/air/sip/sipcontact.html.

8.4.1 Modeling Protocol 

A modeling protocol following EPA guidance was prepared at the outset of the study to serve as 

an outline for performing the CENRAP emissions and air quality modeling and to communicate 

the modeling plans to the CENRAP participants. The modeling protocol took into account 

CENRAP’s long-term plan (CENRAP 2003) and the modeling needs of the regional haze SIPs. 

This modeling protocol is included in this SIP revision as Appendix 8-2: Modeling Protocol for 

the CENRAP 2002 Annual Emissions and Air Quality Modeling.

8.4.2 Quality Assurance Project Plan (QAPP) 

A QAPP was prepared for the CENRAP emissions and air quality modeling study (Appendix 8-3: 

Quality Assurance Project Plan for Central Regional Air Planning Association Emissions and 

Air Quality Modeling) and describes the quality management functions performed by the 

modeling team. The QAPP is based on the national consensus standards for quality assurance 

(ANSI/ASQC 1994). It follows EPA’s guidelines for quality assurance project plans for 

modeling (EPA 2002) and for QAPPs (EPA 2001), and takes into account the recommendations 

from the North American Research Strategy for Tropospheric Ozone (NARSTO) Quality 

Handbook for modeling projects (NARSTO 1998). The EPA and NARSTO guidance documents 

were developed specifically for modeling projects, which have different quality assurance 

concerns than environmental monitoring data collection projects. The work performed in this 

project involved modeling at the basic research level and for regulatory and planning 

applications. In order to use model outputs for these purposes, the modeling team must establish 

that each model is scientifically sound, robust, and defensible by following a project planning 

process that incorporates the following elements as described in the EPA modeling guidance 

document. 

• A systematic planning process including identification of assessments and related 

performance criteria. 

• Peer-reviewed theory and equations. 

• A carefully designed life-cycle development process that minimizes errors. 

• Documentation of any changes from original plans. 

• Clear documentation of assumptions, theory, and parameterization. 

• Input data and parameters that are accurate and appropriate for the analysis. 

• Output data. 

 

A key component of the CENRAP emissions and air quality modeling QAPP is the graphical 

display of model inputs and outputs and multiple peer review of each step of the modeling 

process. Work products (e.g., emissions plots, model outputs, etc.) have been displayed on the 

CENRAP modeling website for review by the CENRAP modeling team, modeling workgroup, 

and others. This website is at: http://pah.cert.ucr.edu/aqm/cenrap/index.shtml. 

8.4.3 Model Selection 

The selection of the meteorological, emissions, and air quality models for the CENRAP regional 

haze modeling was based on a review of previous regional haze modeling studies performed in 

the CENRAP region (e.g., Pitchford et al. 2004; Pun, Chen, and Seigneur 2004; Tonnesen and 

Morris 2004) as well as elsewhere in the United States (e.g., Morris et al 2004a; Tonnesen et al. 

2003; Baker 2004). The CENRAP emissions and air quality modeling protocol (Morris et al. 
8-4 

2004a) provides details on the justification for model selection and the formulation of the 

different models. 

Based on previous work by other Regional Planning Organizations (RPOs) and EPA, CENRAP 

selected the following models for use in modeling PM and regional haze in the central states: 

• MM5: The Pennsylvania State University/National Center for Atmospheric Research 

(PSU/NCAR) Mesoscale Meteorological Model (MM5 Version 3.6 Massively Parallel 

Processing (MPP)) is a non-hydrostatic, prognostic meteorological model routinely used for 

urban- and regional-scale photochemical, fine particulate, and regional haze regulatory 

modeling studies (Anthes and Warner 1978; Chen and Dudhia 2001; Stauffer and Seaman 

1990, 1991; Xiu and Pleim 2000). 

• SMOKE: 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, area, point, fire, and biogenic emission sources for photochemical grid 

models (Coats 1995; Houyoux and Vukovich 1999). As with most "emissions models," 

SMOKE is principally an emission processing system and not a true emissions modeling 

system. With the exception of mobile and biogenic sources, the purpose of SMOKE is to 

provide an efficient tool for converting existing base emissions inventory data into the hourly, 

gridded, speciated, and formatted emission files required by an air quality model. 

• CMAQ: EPA’s Models-3/Community Multiscale Air Quality (CMAQ) modeling system is a 

"One-Atmosphere" photochemical grid model capable of simulating ozone, PM, visibility, 

and acid deposition at a regional scale for extended periods of time (Dennis, et al. 1996; Byun 

et al. 1998a; Byun and Ching 1999; Pleim et al. 2003). 

• CAMx: ENVIRON’s Comprehensive Air Quality Model with Extensions (CAMx) modeling 

system is also a state-of-science "One-Atmosphere" photochemical grid model capable of 

simulating ozone, PM, visibility, and acid deposition at a regional scale for extended periods 

of time. (ENVIRON 2006). 

8.4.4 MM5 Meteorological Model Configuration 

The Iowa Department of Natural Resources (IDNR) performed the 2002 annual MM5 modeling 

on a 36 kilometer (km) grid for the continental United States (Johnson 2007). The TCEQ and 

EPA Region VII carried out MM5 modeling on a 12 km grid covering the central states for 

portions of 2002. 

The MM5 Version 3.63 configuration used in the generation of the meteorological modeling 

datasets consists of the following (see Table 8-2: MM5 34 Vertical Layer Definitions for more 

details): 

• 36 km grid with 34 vertical layers; 

• 12 km nested grid for episodic modeling; 

• Two-way nesting (without feedback) within the 36 km grid for 12 km runs; 

• Initialization and boundary conditions were established using analysis fields generated by 

the Eta model. The Eta model is a hydrostatic mesoscale model that uses a pressurebased coordinate system, allowing for easier solutions to the equations of motion. The 

Eta model excels in capturing small-scale meteorological phenomena, especially those 

induced by terrain, thus improving precipitation forecasts compared to previous 

mesoscale models (Black 1994); 

o Eta 3D and surface analysis data (ds609.2); 

o NCEP global tropospheric SST data (ds083.0) not used; 

o Observational enhancement (LITTLE_R); 

 NCEP ADP surface obs (ds464.0); 

 NCEP ADP upper-air obs (ds353.4); 

• Pleim-Xiu (P-X) land-surface model (LSM); 
8-5 

• Pleim-Chang Asymmetric Convective Mixing (ACM) PBL model; 

• Kain-Fritsch 2 cumulus parameterization; 

• Mixed phase (Reisner 1) cloud microphysics; 

• Rapid Radiative Transfer Model (RRTM) radiation; 

• No shallow convection (ISHALLO=0); 

• standardStandard 3D FDDA analysis nudging outside of PBL; and 

• surfaceSurface nudging of the winds only. 

8.4.5 SMOKE Emissions Model Configuration 

SMOKE supports area, mobile, fire, and point source emission processing and includes biogenic 

emissions modeling through a rewrite of the Biogenic Emission Inventory System, Version 3 

(BEIS3) (see http://www.epa.gov/ttn/chief/software.html#pcbeis). SMOKE has been available 

since 1996, and has been used for emissions processing in a number of regional air quality 

modeling applications. In 1998 and 1999, SMOKE was redesigned and improved with the 

support of the EPA, for use with EPA's Models-3/CMAQ 

(http://www.epa.gov/asmdnerl/models3). The primary purposes of the SMOKE redesign were 

support of: (a) emissions processing with user-selected chemical mechanisms; and (b) emissions 

processing for reactivity assessments. 

As an emissions processing system, SMOKE has far fewer "science configuration" options 

compared with the MM5 and CMAQ models. Appendix 8-1 summarizes the version of the 

SMOKE system used and the sources of data used in constructing the required modeling 

inventories. 

8.4.6 CMAQ Air Quality Model Configuration 

CENRAP used CMAQ Version 4.5 with the “SOAmods enhancement,” or modifications to the 

secondary organic aerosol (SOA) chemical mechanism as described below, and used the model 

configuration as shown in Table 8-4. The model was set up and exercised on the same 36 km 

RPO national grid that Western Regional Air Partnership (WRAP) and Visibility Improvements 

State and Tribal Association of the Southeast (VISTAS) used. CENRAP performed 12 km 

CMAQ sensitivity tests and found little change in model performance with a large penalty in 

computation time. Consequently, on February 7, 2006, the CENRAP Modeling Workgroup 

decided to proceed with the CENRAP emissions and air quality modeling using just the 36 km 

national RPO grid (Morris et al. 2006a). 

Initial CMAQ 2002 simulations that VISTAS ran found that the model greatly underestimates 

organic mass carbon (OMC) concentrations, especially in the summer. A review of the CMAQ 

formulation found that it failed to treat SOA formation from sesquiterpenes and isoprene and also 

failed to account for the fact that SOA can become polymerized so that it is no longer volatile and 

stays in the particle form. Thus, VISTAS updated the CMAQ SOA module to include these 

missing processes and found much improved OMC model performance (Morris et al. 2006c). 

CENRAP tested the CMAQ Version 4.5 with SOA modification enhancement and found it 

performed much better for OMC than the standard versions of CMAQ Version 4.5. Therefore, 

CENRAP adopted CMAQ Version 4.5, with the enhanced SOA modifications (Morris et al. 

2006c). CMAQ Version 4.5 is available from the CMAS center (www.cmascenter.org).

8.4.7 CAMx Air Quality Model Configuration 

The CENRAP used CAMx Version 4.40 options similar to those used for CMAQ. The CENRAP 

initially ran CAMx in side-by-side comparisons with CMAQ. The CENRAP reviewed 

comparative model performance results and other factors for CAMx Version 4 and CMAQ 

Version 4.4 with SOA modifications presented at the February 7, 2006, CENRAP Modeling 

Workgroup meeting. The results indicated that: 
8-6 

• No one model consistently performed better than the other over all species and averaging 

times; 

• Both models performed well for sulfate; 

• CMAQ’s winter nitrate over-prediction tendency was not as large as CAMx’s; 

• CAMx performed slightly better than CMAQ for elemental carbon (EC); 

• CMAQ performed much better than CAMx for OMC; 

• Both models over-predicted fine soil and under-predicted coarse mass (CM); 

• CMAQ ran faster than CAMx due to message passing interface (MPI) multi-processing 

capability; 

• CAMx required much less disk space than CMAQ (Morris et al. 2006b). 

Based on these factors, the CENRAP selected CMAQ as the lead air quality model for the 

CENRAP regional haze modeling with CAMx as the secondary corroborative model. However, 

CAMx also contained a PM Source Apportionment Technology (PSAT) capability that was used 

widely in the CENRAP modeling. CMAQ does not have this capability. Appendix 8-1 lists the 

main CAMx configuration for the annual modeling. The CENRAP selected it, in part, to be 

consistent with the CMAQ model configuration. One exception was that the CAMx PSAT 

simulations used the Bott advection solver rather than the Piecewise-Parabolic Method (PPM) 

advection solver. The PPM advection solver is typically used in the standard CAMx and CMAQ 

runs. However, the Bott advection solver is more computationally efficient and the high 

computational requirements of the CAMx PSAT runs dictated this choice. 

8.4.8 Modeling Domains 

The CENRAP conducted emissions and air quality modeling on the 36 km national RPO domain 

as depicted in Figure 8-1: National Inter-RPO Modeling Domain. This domain consists of a 148 

by 112 array of 36 km by 36 km grid cells covering the continental United States. Sensitivity 

simulations were also performed for episodes on a 12 km modeling domain covering the central 

states; however, the results were very similar to the 36 km results so CENRAP elected to proceed 

with the 2002 annual modeling using the 36 km domain for computational efficiency (Morris et 

al. 2006a). 

Deleted: 2
8-7 

Figure 8-1: National Inter-RPO Modeling Domain 

Note: 36 km grid used for the CENRAP 2002 annual SMOKE, CMAQ, and CAMx modeling 

8.4.9 Vertical Structure of Modeling Domain 

The MM5 meteorological model ran using 34 vertical layers from the surface to a pressure level 

of 100 millibars (mb) (approximately 15 km above ground level). Both the CMAQ and CAMx 

air quality models can employ layer collapsing in which vertical layers in the MM5 are combined 

in the air quality model, which improves computational efficiency. WRAP and VISTAS 

evaluated the sensitivity of the CMAQ model estimates to the number of vertical layers 

(Tonnesen et al. 2005, 2006; Morris et al. 2004a). CMAQ model simulations were performed 

with no layer collapsing (i.e., the same 34 layers as used by MM5) and with various levels of 

layer collapsing. These studies found that using 19 vertical layers up to 100 mb (i.e., same model 

top as MM5) and matching the eight lowest MM5 vertical layers near the surface produced nearly 

identical results as with no layer collapsing. They also found that very aggressive layer 

collapsing (e.g., 34 to 12 layers) produced results with substantial differences compared to no 

layer collapsing. Therefore, based on the WRAP and VISTAS sensitivity analysis, CENRAP 

adopted the 19 vertical layer configuration up to the 100 mb model top. Figure 8-2 displays the 

definition of the 34 MM5 vertical layers and how they collapsed to 19 vertical layers in the 

CENRAP air quality modeling. 

Deleted: 2

Deleted: 3
8-8 

Table 8-2: MM5 34 Vertical Layer Definitions 

Note: Scheme for collapsing the 34 layers down to 19 layers for the CENRAP CMAQ, and CAMx 2002 annual 

modeling. 

8.4.10 2002 Calendar Year Selection 

The CENRAP selected the calendar year 2002 for regional haze annual modeling as described in 

the modeling protocol (Morris et al. 2004a). The EPA’s applicable guidance on PM2.5 and 

regional haze modeling at that time (EPA 2001) identified specific goals to consider when 

selecting modeling periods for use in demonstrating reasonable progress in attaining the regional 

haze goals. Since there is much in common with the goals for selecting episodes for annual and 

episodic PM2.5 attainment demonstrations as well as regional haze, EPA’s current guidance 

addresses all three in a common document (EPA 2007). At the time of the modeling period 

selection, EPA had also published an updated summary of PM2.5 and Regional Haze Modeling 

Guidance (Timin 2002) that served, in some respects, as an interim placeholder until issuance of 

the final guidance as part of the PM2.5 and regional haze National Ambient Air Quality Standards 

MM5 CMAQ 19L

Layer Sigma Pres(mb) Height(m Depth(m) Layer Sigma Pres(mb) Height(m) Depth(m)

34 0.000 100 14662 1841 19 0.000 100 14662 6536

33 0.050 145 12822 1466 0.050 145

32 0.100 190 11356 1228 0.100 190

31 0.150 235 10127 1062 0.150 235

30 0.200 280 9066 939 0.200 280

29 0.250 325 8127 843 18 0.250 325 8127 2966

28 0.300 370 7284 767 0.300 370

27 0.350 415 6517 704 0.350 415

26 0.400 460 5812 652 0.400 460

25 0.450 505 5160 607 17 0.450 505 5160 1712

24 0.500 550 4553 569 0.500 550

23 0.550 595 3984 536 0.550 595

22 0.600 640 3448 506 16 0.600 640 3448 986

21 0.650 685 2942 480 0.650 685

20 0.700 730 2462 367 15 0.700 730 2462 633

19 0.740 766 2095 266 0.740 766

18 0.770 793 1828 259 14 0.770 793 1828 428

17 0.800 820 1569 169 0.800 820

16 0.820 838 1400 166 13 0.820 838 1400 329

15 0.840 856 1235 163 0.840 856

14 0.860 874 1071 160 12 0.860 874 1071 160

13 0.880 892 911 158 11 0.880 892 911 158

12 0.900 910 753 78 10 0.900 910 753 155

11 0.910 919 675 77 0.910 919

10 0.920 928 598 77 9 0.920 928 598 153

9 0.930 937 521 76 0.930 937

8 0.940 946 445 76 8 0.940 946 445 76

7 0.950 955 369 75 7 0.950 955 369 75

6 0.960 964 294 74 6 0.960 964 294 74

5 0.970 973 220 74 5 0.970 973 220 74

4 0.980 982 146 37 4 0.980 982 146 37

3 0.985 986.5 109 37 3 0.985 986.5 109 37

2 0.990 991 73 36 2 0.990 991 73 36

1 0.995 995.5 36 36 1 0.995 995.5 36 36

0 1.000 1000 0 0 0 1.000 1000 0 0
8-9 

implementation process published in April 2007 (EPA 2007). The interim EPA modeling 

guidance for episode selection (EPA 2001; Timin 2002) was consistent with the final EPA 

regional haze modeling guidance (EPA 2007). 

EPA recommends that the selection of a modeling period derive from three principal criteria: 

• a variety of meteorological conditions should be covered that include the types of 

meteorological conditions that produce the worst 20 percent and best 20 percent visibility 

days at Class I areas in the CENRAP states during the 2000 through 2004 baseline 

period; 

• to the extent possible, the modeling data base should include days for which enhanced 

databases (i.e., beyond routine aerometric and emissions monitoring) are available; and 

• sufficient days should be available such that relative response factors (RRFs) can be 

based on several (i.e., >15) days. 

For regional haze modeling, the guidance goes further by suggesting that the preferred approach 

is to model a full, representative year (EPA 2001, pg. 188). Moreover, calculations of the 

required RRF values should be based on model results averaged over the 20 percent worst and 20 

percent best visibility days determined for each Class I area based on monitoring data from the 

2000 through 2004 baseline period. More recent EPA guidance (Timin 2002) suggests that states 

should model at least the 10 worst and 10 best visibility days at each Class 1 area. EPA also lists 

several "other considerations" to bear in mind when choosing potential PM and regional haze 

episodes including: 

• choose periods that have already been modeled; 

• choose periods that are drawn from the years upon which the current design values are 

based; 

• include weekend days among those chosen; and 

• choose modeling periods that meet as many episode selection criteria as possible in the 

maximum number of nonattainment or Class I areas as possible. 

Due to limited available resources, CENRAP modeled a single calendar year. The Regional Haze 

Rule uses the five-year baseline period of 2000 through 2004 as the starting point for projecting 

future-year visibility. Thus, the modeling year should be selected from this five-year baseline 

period. The CENRAP selected the 2002 calendar year, which lies in the middle of the 2000 

through 2004 baseline, for the following reasons. 

• Based on available information, 2002 appears to be a fairly typical year in terms of 

meteorology for the five-year baseline period of 2000 through 2004. 

• 2003 and 2004 appeared to be colder and wetter than typical in the eastern United States. 

• The enhanced Interagency Monitoring of Protected Visual Environments (IMPROVE) 

and IMPROVE protocol sites and supersites PM monitoring data were fully operational 

by 2002. Much less IMPROVE monitoring data was available during 2000 through 

2001, especially in the CENRAP region. 

• IMPROVE data for 2003 and 2004 were not yet available at the time that the CENRAP 

modeling was initiated. 

• The other RPOs were using 2002. 

8.4.11 Initial Concentrations and Boundary Conditions 

The CMAQ and CAMx models were operated separately for each of four quarters of the 2002 

year using an approximate 15-day spin-up period (i.e., the models started approximately 15 days 

before the first day of interest in each quarter to limit the influence of the assumed initial 

concentrations, e.g., start June 15 for the third quarter, whose first day of interest is July 1). 

Sensitivity simulations demonstrated that with fifteen initialization days, the influence of initial 
8-10 

concentrations was minimal using the 36 km Inter-RPO continental United States modeling 

domain. Consequently, clean initial concentrations were specified in the CMAQ and CAMx 

modeling using a 15-day spin-up period. 

Boundary conditions (i.e., the assumed concentrations along the later edges of the 36 km 

modeling domain, see Figure 8-1) used the results from a 2002 simulation by the GEOSCHEMChem global circulation/chemistry model. GEOS-CHEMChem is a three-dimensional 

global chemistry model driven by assimilated meteorological observations from the Goddard 

Earth Observing System (GEOS) of the NASA Global Modeling and Assimilation Office. 

Research groups around the world apply it to a wide range of atmospheric composition problems, 

including future climates and planetary atmospheres using general circulation model meteorology 

to drive the model. The Atmospheric Chemistry Modeling Group at Harvard University provides 

central management and support of the model. 

VISTAS coordinated a joint RPO study in which Harvard University applied the GEOSCHEMChem global model for the 2002 calendar year (Jacob, Park, and Logan 2005). The 

University of Houston was retained to process the 2002 GEOS-CHEMChem output into 

boundary conditions for the CMAQ model (Byun 2004). 

There were several quality assurance (QA) checks of the boundary conditions generated from the 

2002 GEOS-CHEMChem output. The first QA check was a range check to assure reasonable 

values. The boundary conditions were compared against the GEOS-CHEMChem outputs to 

assure the mapping and interpolation were performed correctly. The University of Houston 

supplied the code to map the GEOS-CHEMChem output to the CMAQ boundary conditions 

format. Environ reviewed the code and duplicated generation of the boundary conditions for 

several time periods during 2002. 

8.4.12 Emission Input Preparation 

The CENRAP SMOKE emissions modeling used updated 2002 emissions data for the United 

States (Pechan 2005c,e; Reid et al. 2004a,b), 1999 emissions data for Mexico (ERG 2006), and 

2000 emissions data for Canada. These data were used to generate a final 2002 Base G Typical 

(Typ02G) annual emissions database. Numerous iterations of the emissions modeling were 

conducted using interim databases before arriving at the final Base G emission inventories (e.g., 

Morris et al. 2005). The 2018 Base G base case emissions (Base18G) for most source categories 

in the United States were based on projections of the 2002 inventory assuming growth and 

control (Pechan 2005d). 2018 EGU emissions were based on the run 2.1.9 of the Integrated 

Planning Model (IPM) updated by the CENRAP states. Canadian emissions for the Base18G 

scenario were based on a 2020 inventory. The Mexican 1999 inventory was held constant for 

2018. 

The Typ02G and Base18G emission inventories represent significant improvements to the 

preliminary emissions modeling CENRAP performed (Morris et al. 2005). While the preliminary 

2002 modeling served to develop the infrastructure for modeling large emissions data sets and 

producing annual emissions simulations, much of the input data (both as inventories and ancillary 

data) were placeholders for actual 2002 data being prepared through calendar year 2005. As 

actual 2002 data sets became available, they were integrated into the SMOKE modeling and QA 

system that was developed during the preliminary modeling, to produce a high-quality emissions 

data set for use in the final CMAQ and CAMx modeling. The addition of entirely new inventory 

categories, like marine shipping, added complexity to the modeling. By the end of the emissions 

data collection phase, there were 23 separate emissions processing streams covering a variety of 

source categories necessary to generate model-ready emission inputs for the 2002 calendar year. 

Details on the emissions modeling are in Chapter 2 and Appendix B of the TSD (Appendix 8-1). 

Deleted: 2
8-11 

8.4.13 Meteorological Data Input Preparation 

The IDNR conducted the 2002 36 km MM5 meteorological modeling and also performed a 

preliminary model performance evaluation (Johnson, 2007). CENRAP performed an additional 

MM5 evaluation of the CENRAP 2002 36 km MM5 simulation that included a comparative 

evaluation against the final VISTAS 2002 36 km MM5 and an interim WRAP 2002 36 km 

simulation (Kemball-Cook et al. 2004). Kemball-Cook and co-workers (2004) found the 

following in the comparative evaluation of the CENRAP, WRAP, and VISTAS 2002 36 km 

MM5 simulations (details in Appendix A of the TSD): 

Surface Meteorological Performance within the CENRAP Region

• The three MM5 simulations (CENRAP, VISTAS, and WRAP) obtained comparable 

model performance for winds and humidity that were within model performance 

benchmarks. 

• The WRAP MM5 simulation obtained better temperature model performance than the 

other two simulations due to the use of surface temperature data assimilation. 

o In the final WRAP MM5 simulation the use of surface temperature assimilation 

was dropped because it introduced instability in the vertical structure of the 

atmosphere. 

• For all three runs, the northern portion of CENRAP domain (e.g. Minnesota) had a cold 

bias in winter and a warm bias in summer. 

Surface Meteorological Performance outside the CENRAP Region

• All three runs had similar surface wind model performance in the western United States 

that was outside the model performance benchmarks. 

• For temperature, the WRAP MM5 simulation had the best performance overall due to the 

surface temperature data assimilation that was dropped in the final WRAP run. 

• The three runs had comparable humidity performance, although WRAP exhibited a larger 

wet bias in the summer and in the southwestern United States. 

Upper-Air Meteorological Performance

• The VISTAS and CENRAP MM5 simulations were better able to reproduce the deep 

convective summer boundary layers compared to the WRAP MM5 simulations, which 

exhibited a smoother decrease in temperature with increase in altitude. 

• CENRAP and VISTAS MM5 simulations better simulated the surface temperature 

inversions than WRAP. 

• WRAP was better able to simulate the surface temperature. 

• All three models exhibited similar vertical wind profiles. 

Precipitation Performance

• In winter, all three MM5 simulations exhibited similar, fairly good performance in 

reproducing the spatial distribution and magnitudes of the monthly average observed 

precipitation. 

• In summer, all runs had a wet bias, particularly in the desert southwest where the interim 

WRAP run had the largest wet bias. 

In conclusion, the VISTAS simulation appeared to perform best, and the CENRAP MM5 model 

performance was generally between the VISTAS and WRAP performance, with performance 

more similar to VISTAS than WRAP. Although the interim WRAP MM5 simulation performed 

best for surface temperature due to the surface temperature data assimilation, the surface 

temperature assimilation degraded the MM5 upper-air performance including the ability to 

assimilate surface inversions and was ultimately dropped from the final WRAP MM5 simulations 

(Kemball-Cook et al. 2005). 
8-12 

The IDNR 12 km MM5 simulations were also evaluated and compared with the performance of 

the 36 km MM5 simulation (Johnson et al. 2007). The IDNR 36 km and 12 km MM5 model 

performance was similar (Johnson 2007), which supported the findings of the CMAQ and CAMx 

36 and 12 km sensitivity simulations that there was little benefit of using a 12 km grid for 

simulating regional haze at rural Class I areas (Morris et al. 2006a). However, as noted by 

Tonnesen and co-workers (2005; 2006) and EPA modeling guidance (1991; 1999; 2001; 2007) 

this finding does not necessarily hold for eight-hour ozone and PM2.5 modeling that is 

characterized by sharper concentration gradients and frequently occurs in the urban environment 

as compared to the more rural nature of regional haze. 

8.4.14 Photolysis Rate Model Input 

Several chemical reactions in the atmosphere are initiated by the photodissociation of various 

trace gases. To accurately represent the complex chemical transformations in the atmosphere, 

accurate estimates of these photodissociation rates must be made. The Models-3/CMAQ system 

includes the JPROC processor, which calculates a table of clear-sky photolysis rates (or J-values) 

for a specific date. JPROC uses default values for total aerosol loading and provides the option to 

use default ozone column data or to use measured total ozone column data. These data come 

from the Total Ozone Mapping Spectrometer (TOMS) satellite data. TOMS data that is available 

at 24-hour averages was obtained from http://toms.gsfc.nasa.gov/eptoms/ep.html. Day-specific 

TOMS data was used in the CMAQ radiation model (JPROC) to calculate photolysis rates. The 

TOMS data were missing or erroneous for several periods in 2002: August 2-12, June 10, and 

November 18-19. Thus, the TOMS data for August 1, 2002, was used for August 2-7 and TOMS 

data for August 13 was used for August 8-12. Similarly, TOMS data for June 9 was used for 

June 10 and data for August 17 was used for August 18-19. Note that the total column of ozone 

in the atmosphere is dominated by stratospheric ozone, which has very little day-to-day 

variability, so the use of TOMS data within a week or two of an actual day introduces minimal 

uncertainties in the modeling analysis. 

JPROC produces a "look-up" table that provides photolysis rates as a function of latitude, 

altitude, and time (in terms of the number of hours of deviation from local noon, or hour angle). 

In the current CMAQ implementation, the J-values are calculated for six latitudinal bands (10o, 

20o, 30o, 40o, 50o, and 60o N), seven altitudes (0 km, 1 km, 2 km, 3 km, 4 km, 5 km, and 10 km), 

and hourly values up to plus or minus 8 hours of deviation from local noon. During model 

calculations, photolysis rates for each model grid cell are estimated by first interpolating the 

clear-sky photolysis rates from the look-up table using the grid cell latitude, altitude, and hour 

angle, followed by applying a cloud correction (attenuation) factor based on the cloud inputs from 

MM5. 

The photolysis rates input file was prepared as separate look-up tables for each simulation day. 

Photolysis files are ASCII files that were visually checked for selected days to verify that 

photolysis rates are within the expected ranges. 

The Tropospheric Ultraviolet and Visible (TUV) Radiation Model 

(http://cprm.acd.ucar.edu/Models/TUV/) is used to generate the photolysis rates input file for 

CAMx. TOMS ozone data and land use data were used to develop the CAMx 

Albedo/Haze/Ozone input file for 2002. As for CMAQ, the missing TOMS data period in the fall 

of 2002 was filled in using observed TOMS data on either side of the missing period using the 

same procedures as described above for CMAQ. Default land use specific albedo values were 

used and a constant haze value used, corresponding to rural conditions over North America.

8.4.15 Air Quality Data Input Preparation 

Air quality data used with the CMAQ and CAMx modeling systems include: (1) initial 

concentrations that are the assumed initial three-dimensional concentrations throughout the 

modeling domain; (2) the boundary conditions that are the concentrations assumed along the 
8-13 

lateral edges of the RPO national 36 km modeling domain; and (3) air quality observations that 

are used in the model performance evaluation (MPE). The MPE is discussed in Chapter 3 and 

Appendix C of the TSD. 

As previously noted, CMAQ default clean initial concentrations were used along with an 

approximately 15-day spin up (initialization) period to eliminate any significant influence of the 

initial concentrations on the modeled concentrations for the days of interest. The same initial 

concentrations were used with CAMx. Both CMAQ and CAMx were run for each quarter of the 

year. Each quarter’s model run was initialized 15 days prior to the first day of interest (e.g., for 

the third quarter, July-August-September, the model was initialized on June 15, 2002, with the 

first modeling day of interest July 1, 2002). The CMAQ boundary conditions for the inter-RPO 

36 km continental United States grid (Figure 8-1) were based on day-specific three-hour averages 

from the output of the GEOS-CHEMChem global simulation model of 2002 (Jacob, Park, and 

Logan 2005). The 2002 GEOS-CHEMChem output was mapped to the species and vertical layer 

structure of CMAQ and interpolated to the lateral boundaries of the 36 km grid shown in Figure 

8-1 (Byun 2004). 

Table 8-3 summarizes the surface air quality monitoring networks and the number of sites 

available in the CENRAP region that were used in the model performance evaluation. Data from 

these monitoring networks were also used to evaluate the CMAQ and CAMx models outside of 

the CENRAP region. 

Table 8-3: Ground-level Ambient Data Monitoring Networks and Stations for 2002 

Monitoring 

Network Chemical Species Measured 

Sampling 

Frequency; 

Duration 

Approximate 

Number of 

Monitors 

IMPROVE Speciated PM2.5 and PM10 1 in 3 days; 24 hr 11 

CASTNET Speciated PM2.5 and Ozone 

Hourly, Weekly; 1 

hr, 1 Week 3 

NADP Wet SO4, Wet NO3, and Wet NH4 Weekly 23 

EPA-STN Speciated PM2.5 Varies; Varies 12 

AIRS/AQS CO, NO, NO2, NOX, and Ozone Hourly; Hourly 25 

Note: Available in the CENRAP states for calendar year 2002 and used in the model performance 

evaluation. 

8.4.16 2002 Base Case Modeling and Model Performance Evaluation 

CENRAP’s modeling contractors evaluated the CMAQ and CAMx modeling results against 

ambient measurements of PM species, gas-phase species, and wet deposition. Table 8-6 

summarizes the networks used in the model evaluation, the species measured, and the averaging 

times and frequency of the measurements. CENRAP carried out numerous iterations of CMAQ 

and CAMx 2002 base case simulations and model performance evaluations during the course of 

the CENRAP modeling study. Most of them are posted on the CENRAP modeling website 

(http://pah.cert.ucr.edu/aqm/cenrap/cmaq.shtml), and summaries of the work are in previous 

reports and presentations for CENRAP (e.g., Morris et al. 2005; 2006a, b). Chapter 3 and 

Appendix C of the TSD provide details on the final 2002 Base F 36 km CMAQ base case 

modeling performance evaluation. Because of the similarity between 2002 Base F and 2002 Base 

G and resource constraints, CENRAP did not repeat the model evaluation for Base G. In general, 

the model performance of the CMAQ and CAMx models for sulfate (SO4) and elemental carbon 

(EC) was good. Model performance for nitrate (NO3) was variable, with a summer 

underestimation and winter overestimation bias. Performance for organic carbon mass (OMC) 

was also variable, with the inclusion of the SOA modification enhancement in CMAQ Version 

4.5 greatly improving the CMAQ summer OMC model performance (Morris et al., 2006c). 

Model performance for soil and CM was generally poor. Part of the poor performance for fine 

soil and coarse mass appear to be due to measurement-model incommensurability. The 

Deleted: 2

Deleted: 2

Deleted: 6
8-14 

IMPROVE measured values are due, in part, to local blowing dust sources that are not captured in 

the model’s emission inputs and the 36 km grid resolution is not conducive to modeling localized 

events. Also, the model usually fails to simulate locally high winds creating dust clouds in one 

part of the Chihuahuan Desert that later move with lower speed winds to affect Guadalupe 

Mountains National Park or other Class I areas. Figures 8-2 and 8-3 show the observed light 

extinction compared to the modeled light extinction at Big Bend National Park and Guadalupe 

Mountains National Park. 

Worst 20% Obs (left) vs Typ02g (right) at BIBE1

0

20

40

60

80

100

120

140

29 71 89 92 95 101 110 113 116 119 125 128 131 143 167 191 218 221 230 242 245 254 275 329 _ Avg

Julian Day in Worst 20% group

bEXT (1/Mm)

bCM

bSOIL

bEC

bOC

bNO3

bSO4

Figure 8-2: Observed and Base Case Modeled Concentrations at Big Bend 

Note: Extinction calculated using the new IMPROVE equation using observed concentrations 

and base case modeled concentrations at Big Bend National Park. The new IMPROVE equation 

calculations relied on 2002 IMPROVE data for the worst 20 percent of monitored days and the 

modeling used the 2002 baseBase F emission inventory. 

Deleted: 4

Deleted: 5

Deleted: 4
8-15 

Worst 20% Obs (left) vs Typ02g (right) at GUMO1

0

10

20

30

40

50

60

70

80

90

100

74 83 92 95 122 131 137 146 161 164 167 170 173 176 191 218 221 245 251 254 260 266 272 329 _ Avg

Julian Day in Worst 20% group

bEXT (1/Mm)

bCM

bSOIL

bEC

bOC

bNO3

bSO4

Figure 8-3: Observed and Base Case Modeled Concentrations at Guadalupe Mountains 

Note: Extinction calculated using the new IMPROVE equation using observed concentrations 

and base case modeled concentrations at Guadalupe Mountains National Park. The new 

IMPROVE equation calculations relied on 2002 IMPROVE data for the worst 20 percent of 

monitored days and the modeling used the 2002 baseBase F emission inventory. 

8.4.17 2018 Modeling and Visibility Projections 

Emissions for the 2018 base case were generated following the procedures discussed in Chapter 2 

of the TSD. Emissions in 2018 for electrical generating units (EGUs) were based on simulations 

of the Integrated Planning Model (IPM) that took into account the effects of the Clean Air 

Interstate Rule (CAIR) on emissions from EGUs in CAIR states using an IPM realization of a 

CAIR cap and trade program. For the purposes of this SIP revision, the TCEQ is assuming that 

the federal appellate court remand of CAIR to EPA will result in a replacement program 

providing comparable emissions reductions at EGUs before 2018. Emissions for on-road and 

non-road mobile sources were based on activity growth and emissions factors from the EPA 

MOBILE Vehicle Emission Modeling Software Version 6 (MOBILE6) and NONROAD models, 

respectively. Area sources and non-EGU point sources were grown to 2018 levels using 

Economic Growth Analysis System (EGAS) (Pechan 2005d). The Canadian year 2000 emissions 

inventory was replaced by a Canadian 2020 emissions inventory for the 2018 CMAQ/CAMx 

simulations. 

The following sources were assumed to remain constant between the 2002 and 2018 base case 

simulations: 

• biogenic VOC and NOX emissions from the Biogenic Emissions Inventory System 

Version 3 (BEIS3) model; 

• wind-blown dust associated with non-agricultural sources (i.e., natural wind-blown 

fugitive dust); 

Deleted: 5
8-16 

• off-shore emissions associated with off-shore marine and oil and gas production 

activities; 

• emissions from wildfires; 

• emissions from Mexico; and 

• global transport (i.e., emissions due to boundary conditions from the 2002 GEOSCHEMChem global chemistry model). 

The results from the 2002 and 2018 CMAQ and CAMx simulations were used to project 2018 

PM levels from which 2018 visibility estimates were obtained. The 2002 and 2018 modeling 

results were used in a relative sense to scale the observed PM concentrations from the 2000 

through 2004 baseline and the IMPROVE monitoring network to obtain the 2018 PM projections. 

The modeled scaling factors are called relative response factors (RRFs) and are constructed as the 

ratio of modeling results for the 2018 model simulation to the 2002 model simulation. Two 

important regional haze metrics are the average visibility for the worst 20 percent and best 20 

percent days from the 2000 through 2004 five-year baseline. For the 2018 visibility projections, 

EPA guidance recommends developing Class I area and PM species specific RRFs using the 

average modeling results for the worst 20 percent days during the 2002 modeling period and the 

2002 and 2018 emission scenarios. The results of the CENRAP 2018 visibility projections 

following EPA guidance procedures (EPA 2007a) are provided in Chapter 4 and Appendix D of 

the TSD in Appendix 8-1 of this SIP revision. CENRAP has also developed alternative 

procedures for visibility projections that are discussed in Chapter 5 and Appendix D of the TSD. 

For example, much of the CM impact at Class I area IMPROVE monitors are believed to be 

natural and primarily from local sources that are subgrid-scale to the modeled 36 km grid so are 

not represented in the modeling. Thus, one alternative visibility projection approach is to set the 

RRF for CM to 1.0. That is, the CM impacts in 2018 are assumed to be the same as in the 

observed 2000-2004 baseline. Similarly, the soil impacts at IMPROVE monitors are likely 

mainly due to local dust sources so another alternative approach is to set the RRFs for both CM 

and soil to 1.0. 

The 2018 visibility projections for the worst 20 percent days are compared against a 2018 point 

on the uniform rate of progress (URP) glide path or the “2018 URP point.” The 2018 URP point 

is obtained by constructing a linear visibility glide path in deciviews from the observed 2000 

through 2004 baseline (EPA 2003a) for the worst 20 percent days to the 2064 natural conditions 

(EPA 2003b). Where the linear glide path crosses the year 2018 is the 2018 URP point. States 

may use the modeled 2018 visibility to help define their 2018 RPG in their Regional Haze SIPs. 

The 2018 URP point is used as a benchmark to help judge the 2018 modeled visibility projections 

and the state’s RPG. However, as noted in EPA’s RPG guidance, “The glide path is not a 

presumptive target, and states may establish a RPG that provides for greater, lesser, or equivalent 

visibility improvement as that described by the glide path” (EPA 2007b). Chapter 4 and 

Appendix D of the TSD present the 2018 visibility projections for the CENRAP Class I areas and 

their comparisons with the 2018 URP point using EPA default visibility projection procedures 

(EPA 2007a) and EPA default URP glide paths (EPA 2003a,b; 2007b). 

Various techniques have been developed to display the 2018 visibility modeling results including 

“DotPlots” that display the 2018 visibility projections as a percentage of meeting the 2018 point 

on the URP glide path. A value of 100 percent on the DotPlot indicates that the Class I area is 

predicted to meet the 2018 point on the URP glide path. Over 100 percent means the 2018 

visibility projection obtains more visibility improvements (reductions) than required to meet the 

2018 point on the URP glide path (i.e., projected value is below the glide path). Less than 100 

percent indicates that fewer visibility improvements are projected than are needed to meet the 

2018 point URP on the glide path (i.e., above the glide path). Figure 8-4 displays a DotPlot that 

compares the 2018 visibility projections from the CENRAP 2018 Base G CMAQ simulation with 

the 2018 URP point using the EPA default RRFs and alternative RRFs that set the CM and soil 

RRFs to unity (i.e., assume CM and soil are natural so remain unchanged from the 2000-2004 
8-17 

baseline). For these results, the 2018 visibility projections at the Hercules Glades (HEGL1) Class 

I area meets the 2018 point on the URP glide path (100 percent), whereas the 2018 visibility 

projections at Caney Creek (CACR), Mingo (MING), and Upper Buffalo (UPBU) achieve more 

visibility improvements than needed to meet the 2018 URP point so are below the 2018 URP 

glide path. However, the 2018 visibility projections at Breton come up slightly short 

(approximately 5 percent) of meeting the 2018 point on the URP glide path and Wichita 

Mountains (WIMO) comes up approximately 40 percent short of meeting the 2018 point on the 

URP glide path. Class I areas at the northern (e.g., VOYA, BOWA, and ISLE) and southern 

(e.g., BIBE and GUMO) boundaries of the United States also fall short of achieving the 2018 

URP point. 

High contributions of international transport and/or natural sources (e.g., windblown dust) affect 

the ability of these Class I areas to be on the URP glide path calculated using the default estimates 

produced by the Natural Conditions II Committee (NC-II). Chapters 4 and 5 of the TSD in 

Appendix 8-1 discuss these issues in more detail. 
8-18 

CMAQ BaseGa Method 1 predictions for CENRAP+ sites

0%

20%

40%

60%

80%

100%

120%

140%

160%

180%

200%

BIBE1

GUMO1

WIMO1

CACR1

UPBU1

HEGL1

MING1

BRET1

VOYA2

BOWA1

MACA1

SIPS1

ISLE1

SACR1

WHIT1

WHPE1

GRSA1

ROMO1

WICA1

BADL1

THRO1

LOST1

Percent of target reduction achieved

Regular RRF

CM RRF=1

CM&SOIL RRFs=1

CENRAP non-CENRAP

Figure 8-4: 2018 Visibility Projections Expressed as Percent of Meeting the 2018 URP Point 

Note: Using the default NC-II estimates of natural conditions. 

BADL Badlands Wilderness Area 

BOWA Boundary Waters Canoe Area Wilderness 

CACR Caney Creek Wilderness Area 

HEGL Hercules-Glades Wilderness Area 

ISLE Isle Royale National Park 

LOST Lostwood Wilderness Area 

MACA Mammoth Cave National Park 

SIPS Sipsey Wilderness Area 

THRO Theodore Roosevelt National Park 

UPBU Upper Buffalo Wilderness Area 

VOYA Voyageurs National Park 

WICA Wind Cave National Park

Deleted: 6
8-19 

8.4.18 Additional Supporting Analysis 

CENRAP performed numerous supporting analyses of its modeling results including analyzing 

alternative glide paths and 2018 projection approaches and performing confirmatory analysis of 

the 2018 visibility projections. Details on the additional supporting analysis are contained in 

Chapter 5 of the TSD, which include: 

• The CENRAP 2018 visibility projections were compared with those generated by 

VISTAS and MRPO. There was close agreement between the CENRAP and VISTAS 

2018 visibility projections at almost all common Class I areas, with the exception of 

Breton Island where the CENRAP’s projections were slightly more optimistic than 

VISTAS’. The MRPO 2018 visibility projections were less optimistic than CENRAP’s 

at the four Arkansas-Missouri Class I areas. This difference may have been due to 

CENRAP’s BART emission controls in CENRAP states that were not included in the 

2018 MRPO inventory. 

• Extinction based glide paths were developed and the CENRAP 2018 visibility projections 

were shown to produce nearly identical estimates of achieving the 2018 URP point when 

using total extinction glide paths as when the linear deciview glide paths were used. 

With the extinction based glide paths the analysis of 2018 URP could be made on a PM 

species-by-species basis where it was shown that 2018 extinctions due to SO4 and, to a 

lesser extent, NO3 and EC, achieve the URP, but the other species do not and, in fact, 

extinction due to soil and CM is projected to get worse. 

• 2018 visibility projections were made using EPA’s Modeled Attainment Test Software 

(MATS) and the CENRAP Typ02G and Base18G modeling results. The CENRAP 2018 

visibility projections agreed with those generated by MATS with three exceptions: 

Breton, Boundary Waters, and Mingo Class I areas. At these three Class I areas MATS 

did not produce any 2018 visibility projections due to insufficient observed 2000-2004 

data in the raw IMPROVE database to produce a valid baseline. CENRAP used filled 

data for these three Class I areas. 

• PM PSAT modeling was conducted to estimate the contributions to visibility impairment 

at Class I areas by source region (e.g., states) and major source category. Source 

contributions were obtained for a 2002 and 2018 base case and the PSAT modeling 

results were implemented in a PSAT Visualization Tool that was provided to CENRAP 

states and others. Major findings from the PSAT source apportionment modeling include 

the following: 

o Sulfate from elevated point sources was the highest source category contribution 

to visibility impairment at CENRAP Class I areas for the worst 20 percent days. 

o International transport contributed significantly to visibility impairment at 

CENRAP Class I areas on the southern (BIBE and GUMO) and northern 

(BOWA and VOYA) borders of the United States and to a lesser extent at 

WIMO. 

• Alternative visibility projections were made, assuming that CM alone, and CM and soil 

were natural in origin. 

• Visibility projections were made using an alternative model (CAMx) that verified the 

projections made by CMAQ. 

• The effects of international transport were examined several ways indicating that the 

inability of the 2018 visibility projections to achieve the 2018 URP point at the northern 

and southern border Class I areas was due to high contributions due to International 

Transport. 

Visibility trends for the worst 20 percent days, best 20 percent days, and all monitored days were 

analyzed at CENRAP Class I areas using the period of record IMPROVE observations. At most 

Class I areas there were insufficient years of data to produce a discernable trend. In addition, 

there was significant year-to-year variability in visibility impairment with episodic events (e.g., 

wildfires and windblown dust) confounding the analysis. 
9-1 

CHAPTER 9. BEST AVAILABLE RETROFIT TECHNOLOGY 

On July 6, 2005, the EPA published final amendments to its 1999 Regional Haze Rule including 

Appendix Y, the final guidance for Best Available Retrofit Technology (BART) determinations 

in the Federal Register (70 FR 39104-39172). The BART rule requires the installation of BART 

on emission sources that fit specific criteria and “may reasonably be anticipated to cause or 

contribute” to visibility impairment in any Class I area (Appendix 9-1: U.S. EPA BART Rule). 

9.1 BART-ELIGIBLE SOURCES IN TEXAS 

The TCEQ’sTexas Commission on Environmental Quality’s (TCEQ) BART rule adopted on 

January 10, 2007, identifies potentially affected sources as those: 

• belonging to one of 26 industry source categories; 

• having the potential to emit (PTE) 250 tons per year (tpy) or more of any visibilityimpairing pollutant; and 

• not operating prior to August 7, 1962, and in existence on August 7, 1977 

(Appendix 9-2: Texas BART Rule). 

The state is not required to make a determination of BART for SO2 or NOX if a BART-eligible 

source has the PTE less than 40 tons per year of such pollutant(s) or less than 15 tons per year for 

PM10. 

A state that opts to participate in the CAIR program need not require affected BART-eligible 

EGUs to install, operate, and maintain BART for SO2 or NOX. Texas has made the determination 

that participation in CAIR is participating in equivalent to BART. This exempts EGUs impacted 

by CAIR from a BART analysis for SO2 and NOx. As of the date of this SIP revision, CAIR 

remains in effect until replaced by EPA rule consistent with the D.C. Circuit Court of Appeals’ 

remand of CAIR back to EPA. As a result, EGUs subject to the cap and trade system established 

by CAIR have not been evaluated for BART for SO2 and NOx. The TCEQ will take appropriate 

action if CAIR is not replaced with a system that the US EPA considers to be equivalent to 

BART. 

The TCEQ has also adopted the model plants, or option 2, developed by the EPA; this is an 

approach for using model plants to exempt individual sources with common characteristics 

(70 FR 39162-3). Any BART-eligible source that has the PTE less than 500 tons per year of 

combined SO2 and NOX and that is located more than 50 kilometers from any Class I area is not 

subject to BART for SO2 and NOX. Any BART-eligible source that has the PTE less than 1,000 

tons per year of combined SO2 and NOX and that is located more than 100 kilometers from any 

Class I area is not subject to BART for SO2 and NOX.

Sources which meet this model plant exemption are considered not to be negatively impacting 

visibility at Class I areas and are therefore not required to complete a BART analysis. 

The TCEQ reviewed its emission inventory

The TCEQ manages emissions and emissions-related data and in the State of Texas Air Reporting 

System (STARS). The STARS was used the EPA’s model plants as an initial screening tool for 

identifying to determine which sources were potentially BART-eligible sources. Surveys were 

sent to . This database does not store any permit related information such as build dates or 

permitted allowable emission levels. As a result of these database limitations the TCEQ surveyed 

companies regarding their potential to emit and construction dates in order to complete the initial 

BART determination (Appendix 9-3: Texas Survey for BART-Eligibility). 

Texas Source Survey 

Each of the 26 BART source categories were addressed for Texas. The Standard Industrial Codes 

(SIC) as well as the applicable Source Classifications Codes (SCC) were identified by TCEQ 

Deleted: 
9-2 

staff using the 26 applicable source categories listed in Section III(H) of the 40CFR Part 51, 

Regional Haze Regulations. This list was compared with other states and regional planning 

organization lists for completeness. The initial survey population was based on this SIC/SCC list 

only. 

As provided for in the EPA guidance document for BART, the TCEQ chose to adopt a model 

plant analysis to reasonably eliminate smaller sources of NOX and SO2 emissions which were 

distant from a Class I area. The EPA guidance provides exemption of sources from consideration 

if their actual emission of NOX or SO2 (or combination of NOX and SO2) were less than 500 tpy 

as long as they were located more than 50 kilometers (km) from any Class I area; sources were 

also exempted if their 2002 emissions of NOX or SO2 (or combination of NOX and SO2) were less 

than 1,000 tpy as long as they were located more than 100 km from any Class I area. The TCEQ 

reduced the emission threshold to 750 tpy for sources greater than 100 km and 375 tpy for 

sources greater than 50 km to capture sources that might not have met EPA’s threshold based 

only on their 2002 emissions levels. Given their distance from Class I areas, the relatively low 

emissions from the screened out sources are unlikely to significantly impact visibility at those 

areas. 

Based on an estimate by TCEQ staff, the actual emissions are typically 80 percent of the 

permitted amount. Using this estimate, staff assumed that companies with actual volatile organic 

compounds (VOC) emissions of 200 tpy would reasonably have a permitted potential to emit of 

250 tpy. Companies with the applicable source categories and actual emissions at their sites of 

200 tpy or more of VOC or PM10 were also asked to complete the survey. In 2002, PM2.5 data 

were collected but a review of the database indicated that some companies did not fully report 

fine particulate matter until later inventories. As allowed by the BART guidelines, PM10 was 

used as a surrogate in order to fully capture sources of particulate matter. 

A county level distance screen was employed to avoid removing sources that barely exceeded 

distance calculations. If any portion of the county was within the applicable distance to the 

nearest Class I area, then all the sites within that county were considered within the applicable 

distance. Additionally, all BART category sites within counties within 50 km of a Class I area 

were surveyed. The Class I areas considered for the Texas screening included the Guadalupe 

Mountains, Big Bend, Carlsbad Caverns, Wichita Mountains, Caney Creek, Breton Island, and 

Salt Creek. 

As a result of the screening analysis, 254 sites (approximately 250 12 percent of the 2,165 sources 

in the 2002 emissions inventory) were identified as potentially BART-eligible sources. based on 

distance and actual emissions. A survey was sent to these sites to ask for site representatives to 

help in identifying construction or reconstruction dates and whether the PTE of the BARTeligible equipment exceeded 250 tpy. 

The emissions represented by the surveyed sites are summarized in Table 9-1: Emissions from 

Companies Surveyed as a Percentage of State Total Point Source Emissions. Sources emitting a 

large percentage of the actual emissions in the state were in the survey population. Emissions 

covered in the survey ranged from 61.7 percent of the 2002 VOC inventory to 97.7 percent of the 

SO2 inventory. 

Table 9-1: Emissions from Companies Surveyed as a Percentage of State Total Point 

Source Emissions 

Source Emissions (tpy) 

PM10 SO2 NOX VOC 

BART Survey 49,638 786,274 467,534 95,442

2002 State Total 66,064 805,133 601,447 154,665
9-3 

Surveys were sent to 254 companies. The survey was a two step process. Companies were first 

asked to identify if they have any equipment built or reconstructed during the applicable time 

period or if the PTE of their site were less than 250 tpy. Companies that did not have BART 

applicable equipment based on low emissions or construction dates were not asked to supply any 

further information and were considered not BART-eligible. 

If the site did possibly have BART applicable equipment, they were asked to complete a detailed 

survey of all operating and idle equipment at each site. The detailed survey asked whether each 

piece of equipment at the site was built or reconstructed between the applicable dates. The 

companies were asked if the PTE of their BART-eligible equipment exceeded the 250 tpy 

threshold for the applicable emissions. Any source with a PTE from equipment built during the 

applicable period was considered BART-eligible. 

Based on results from the surveys completed by potentially BART-eligible sources and submitted 

to the TCEQ in 2005, over 100 sources were identified as BART-eligible. Table 9-2: BARTEligible Sources Based on Results of TCEQ Survey presents the sources that were determined to 

be BART-eligible. 

Table 9-2: BART-Eligible Sources Based on Results of TCEQ Survey 

No. Account Source Regulated 

Entity SIC 

1 AC0017B ABITIBI CONSOLIDATED CORP RN100220110 2621 

2 TG0044C AEP TEXAS RN101531226 4911 

3 CD0013K AEP TEXAS CENTRAL COMPANY RN102560687 4911 

4 NE0024E AEP TEXAS CENTRAL COMPANY RN100642040 4911 

5 NE0026A AEP TEXAS CENTRAL COMPANY RN100552181 4911 

6 JI0030K AEP TEXAS NORTH COMPANY RN100215557 4911 

7 CB0003M ALCOA ALUMINA & CHEMICALS RN100242577 2819 

8 MM0001T ALCOA INC RN100221472 3334 

9 HT0011Q ALON USA LP RN100250869 2911 

10 ED0034O ASH GROVE (formerly NORTH TEXAS CEMENT) RN100225978 3241 

11 HG0558G ATOFINA CHEMICALS INC RN100209444 2869 

12 BL0021O BASF CORPORATION RN100218049 2869 

13 GB0001R BP AMOCO CHEMICAL COMPANY RN102536307 2869 

14 GB0004L BP PRODUCTS NORTH AMERICA IN TEXAS RN102535077 2911 

15 GH0003Q CABOT CORPORATION RN100221761 2895 

16 BG0045E CAPITOL CEMENT DIV CAPITOL RN100211507 3241 

17 GH0004O CELANESE CHEMICAL RN101996395 2869 

18 MH0009H CELANESE LIMITED RN100258060 2869 

19 ED0011D CHAPARRAL STEEL MIDLOTHIAN RN100216472 3312 

20 BJ0001T CHEMICAL LIME LTD RN100219856 3274 

21 HG0310V CHEVRON PHILLIPS CHEMICAL RN103919817 2869 

22 BL0758C CHEVRON PHILLIPS CHEMICAL RN100825249 2869 

23 HW0013C CHEVRON PHILLIPS CHEMICAL CO RN102320850 2869 

24 NE0027V CITGO REFINING & CHEMICALS RN102555166 2911 

25 BG0057U CITY PUBLIC SERVICE RN100217975 4911 

26 BG0186I CITY PUBLIC SERVICE RN100217835 4911 

27 HW0018P CONOCO PHILLIPS (formerly PHILLIPS 66) RN102495884 2911 

28 CR0020C COPANO PROCESSING LP RN101271419 1321 

29 AB0012W DCP (formerly DUKE ENERGY FIELD SERVICES) RN100218684 1321 

30 HW0008S DEGUSSA ENGINEERED CARBONS RN100209659 2895 

31 HGA005E DOW RN104150123 2869 

32 HG0126Q DOW RN100227016 2869 

Deleted: 

Deleted: 1

Deleted: 

Deleted: 

Deleted: Page Break

Deleted: 1
9-4 

33 CI0022A DYNEGY MIDSTREAM SERVICES RN100222900 1321 

34 HH0042M EASTMAN CHEMICAL COMPANY RN100219815 2869 

35 HG0218K EI DUPONT RN100225085 2869 

36 OC0007J EI DUPONT DENEMOURS & CO RN100542711 2869 

37 EE0029T EL PASO ELECTRIC CO RN100211309 4911 

38 TH0004D ELECTRIC UTILITY DEPT RN100219872 4911 

39 CG0012C ENBRIDGE PIPELINES RN102166964 1321 

40 MQ0009F ENTERGY GULF STATES INC RN100226877 4911 

41 OC0013O ENTERGY GULF STATES INC RN102513041 4911 

42 BL0113I EQUISTAR RN100218601 2869 

43 BL0268B EQUISTAR CHEMICALS LP RN100237668 2821 

44 HG0033B EQUISTAR CHEMICALS LP RN100542281 2869 

45 HG0228H EXXON CHEMICAL CO RN102212925 2869 

46 JE0065M EXXON MOBIL CHEMICAL CO RN100211903 2821 

47 HG0229F EXXONMOBIL CHEMICAL CO RN102574803 2869 

48 HG0232Q EXXONMOBIL CORP RN102579307 2911 

49 JE0067I EXXONMOBIL OIL CORP RN102450756 2911 

50 NE0120H FLINT HILLS RESOURCES RN102534138 2911 

51 NE0122D FLINT HILLS RESOURCES LP RN100235266 2911 

52 JE0052V HUNTSMAN CORPORATION RN100219252 2869 

53 JE0135Q HUNTSMAN PETROCHEMICAL CORP RN100217389 2869 

54 EB0057B HUNTSMAN POLYMERS RN101867554 2869 

55 BL0002S INEOS OLEFINS & POLYMERS RN100238708 2869 

56 CG0010G INTERNATIONAL PAPER CO RN100543115 2621 

57 OCA002B INVISTA RN104392626 2869 

58 VC0008Q INVISTA (formerly DU PONT DE NEMOURS) RN102663671 2869 

59 WE0005G LAREDO POWER RN100213909 4911 

60 MB0123F LEHIGH CEMENT COMPANY RN100218254 3241 

61 NE0025C LON C HILL POWER RN100215979 4911 

62 BC0015L LOWER COLORADO RIVER AUTHORITY RN102038486 4911 

63 FC0018G LOWER COLORADO RIVER AUTHORITY RN100226844 4911 

64 HG1575W LYONDELL CHEMICAL RN100633650 2869 

65 HG0048L LYONDELL CITGO REFINING RN100218130 2911 

66 GB0055R MARATHON ASHLAND PETROLEUM RN100210608 2911 

67 HH0019H NORIT AMERICAS INC RN102609724 2819 

68 GB0037T NRG TEXAS (formerly TEXAS GENCO LP) RN101062826 4911 

69 ED0051O OWENS CORNING RN100223585 3296 

70 HG1451S OXYVINYLSLP RN102518065 2821 

71 HG0175D PASADENA REFINING RN100716661 2911 

72 JE0042B PREMCOR REFINING GROUP RN102584026 2911 

73 MC0002H REGENCY TILDEN GAS (formerly ENBRIDGE) RN100216621 2819 

74 HG0697O RHODIA INC RN100220581 2819 

75 HG0632T ROHM & HAAS TEXAS RN100223205 2869 

76 HG0659W SHELL OIL CO RN100211879 2911 

77 HW0017R SID RICHARDSON CARBON RN100222413 2895 

78 HT0027B SID RICHARDSON CARBON CO RN100226026 2895 

79 BL0038U SOLUTIA INC RN100238682 2869 

80 TF0012D SOUTHWESTERN ELECTRIC POWER RN100213370 4911 

81 GJ0043K SOUTHWESTERN ELECTRIC POWER RN102156916 4911 

82 ME0006A SOUTHWESTERN ELECTRIC POWER RN100542596 4911 

83 PG0040T SOUTHWESTERN PUBLIC SERVICE RN100224641 4911 

84 PG0041R SOUTHWESTERN PUBLIC SERVICE RN100224849 4911 

Deleted: Page Break

Table 9-1: BART-Eligible 

Sources Based on Results of 

TCEQ Survey (cont’d)¶

No. ... [1]
9-5 

85 LN0081B SOUTHWESTERN PUBLIC SERVICE RN100224765 4911 

86 JE0091L SUN MARINE TERMINAL RN100214626 4226 

87 WN0042V TARGA RN102552387 1311 

88 CY0019H TARGA (formerly DYNEGY MIDSTREAM) RN102551785 1311 

89 OC0019C TEMPLE-INLAND RN100214428 2621 

90 CI0012D TEXAS GENCO LP RN100825371 4911 

91 FG0020V TEXAS GENCO LP RN100888312 4911 

92 HK0014M TEXAS LEHIGH CEMENT CO RN102597846 3241 

93 HG0562P TEXAS PETROCHEMICALS LP RN100219526 2869 

94 BL0082R THE DOW CHEMICAL CO RN100225945 2869 

95 JE0039N THE GOODYEAR TIRE AND RUBBER CO RN102561925 2822 

96 NE0022I TICONA POLYMERS INC RN101625721 2869 

97 JE0005H TOTAL PETROCHEMICALS RN102457520 2911 

98 ED0066B TXI OPERATIONS LP RN100217199 3241 

99 FI0020W TXU BIG BROWN COMPANY LP RN101198059 4911 

100 DB0251U TXU ELECTRIC COMPANY RN101559854 4911 

101 FB0025U TXU GENERATION COMPANY LP RN102285855 4911 

102 HQ0012T TXU GENERATION COMPANY LP RN100664812 4911 

103 MB0116C TXU GENERATION COMPANY LP RN102566494 4911 

104 MM0023J TXU GENERATION COMPANY LP RN102147881 4911 

105 MO0014L TXU GENERATION COMPANY LP RN102285848 4911 

106 RL0020K TXU GENERATION COMPANY LP RN102583093 4911 

107 TA0352I TXU GENERATION COMPANY LP RN100693308 4911 

108 WC0028Q TXU GENERATION COMPANY LP RN102183969 4911 

109 YB0017V TXU GENERATION COMPANY LP RN102563426 4911 

110 TF0013B TXU GENERATION COMPANY LP RN102285921 4911 

111 GB0076J UNION CARBIDE CORP RN100219351 2869 

112 CB0028T UNION CARBIDE CORPORATION RN102181526 2869 

113 HR0018T VALENCE MIDSTREAM LTD RN100213685 1321 

114 GB0073P VALERO REFINING CO TEXAS RN100238385 2911 

115 NE0043A VALERO REFINING COMPANY RN100211663 2911 

116 MR0008T VALERO MCKEE RN100210517 2911 

117 WH0014S VETROTEX WICHITA FALLS PLANT RN100218601 3229 

118 VC0003D VICTORIA POWER RN100214980 4911 

119 JB0016M VINTAGE PETROLEUM INC RN100214592 1311 

120 JC0003K WESTVACO RN102157609 2631 

Deleted: (formerly XCEL)

Deleted: ¶

Page Break

Table 9-1: BART-Eligible 

Sources Based on Results of 

TCEQ Survey (cont’d)¶

No.

Deleted: (formerly

ATOFINA)

Deleted: (formerly

DIAMOND)

... [2]
9-6 

9.2 DETERMINATION OF SOURCES SUBJECT TO BART 

Under the EPA’s BART guidelines, the state has two options regarding its BART-eligible 

sources: 

• make BART determinations for all sources; or 

• consider exempting some sources from BART because they do not cause or 

contribute to visibility impairment in a Class I area. 

The TCEQ has chosenchose the second option that considers exempting some sources. 

When exempting sources from BART because they do not cause or contribute to visibility 

impairment in a Class I area, the guidelines suggest three sub-options for determining that certain 

sources are not subject to BART: 

• individual source attribution approach; 

• the use of model plants to exempt sources with common characteristics 

(70 FR 39162-3); and

• a cumulative modeling analysis to show that groups of sources in a state are not subject to 

BART; 

• and finally; an individual source attribution approach. 

The TCEQ exercised all three sub-options above to determine which sources were subject to 

BART. These options are explained further below, in the order in which the TCEQ and the 

sources performed the analyses. 

Section 9.2.1 describes the cumulative modeling analyses that the TCEQ performed for the 

sources identified as BART-eligible. Since there were was such a large number of BARTeligible sources in Texas, the TCEQ performed cumulative modeling analyses using CAMx 

PSAT technology. Once the TCEQ had completed the CAMx screeningmodeling analysis, 

several BART-eligible sources were determined to be insignificant (screened out) and several 

remained potentially BART-eligible (did not screen out). Screening out is a process that further 

examines and evaluates sources for inclusion or exclusion in the BART program. Sources that 

did not screen out through the cumulative modeling analysis were required to perform sourcespecific screening modeling analyses using either the CALPUFF or the CAMx model setup 

developed by the TCEQ. These source-specific modeling analyses are described in Section 9.2.2. 

BART-eligible sources that did not screen out in any of the modeling analyses had the option of 

reducing the emissions from their BART-eligible units using an enforceable mechanism, such as 

a permit, or performing an engineering analysis. The BART-eligible sources that chose to reduce 

potential emissions are discussed in Section 9.3. The emission reductions resulting from the 

engineering analyses and resulting emission controls are presented in Section 9.5. 

9.2.1 Cumulative Modeling Using CAMx PSAT 

The TCEQ conducted screening modeling analyses as described in the CAMx modeling protocol, 

Screening Analysis of Potentially BART-Eligible Sources in Texas, and the final CAMx modeling 

report, Final Report, Screening Analysis of Potential BART-Eligible Sources in Texas, presented 

in Appendices 9-4 and 9-5, respectively. In addition to the CAMx modeling, the TCEQ 

developed Texas model plants based on the CAMx modeling results. The model plants are 

discussed in the addendums to the CAMx modeling report, Addendum I, BART Exemption 

Screening Analysis, and Addendum II, BART Exemption Screening Analysis. Both addendums 

are contained in Appendix 9-6. Sources that successfully screened out in the CAMx screening 

modeling analyses or by using the Texas model plants were required to review the modeling 

analysis and data used and to certify that they agree with the screening modeling analyses and 

inputs. Copies of these certifications are contained in Appendix 9-7. Table 9-3 shows the 

BART-eligible sources that successfully screened out in the cumulative modeling analyses. 

Deleted: . 

Deleted: 

Deleted: 4

Deleted: 3 

Deleted: 4

Deleted: 5

Deleted: 6

Deleted: 2
9-7 

BART-eligible sources that did not screen out of the cumulative modeling were required to 

conduct their own screening modeling analysis using either the CALPUFF or the CAMx 

modeling setup developed by the TCEQ. The single source modeling analyses are outlined in 

Section 9.2.2. 

Table 9-3: BART-Eligible Sources Screened Out Using Cumulative CAMx Modeling 

No. Account Source Regulated Entity SIC 

1 TG0044C AEP TEXAS RN101531226 4911 

2 CD0013K AEP TEXAS CENTRAL COMPANY RN102560687 4911 

3 NE0024E AEP TEXAS CENTRAL COMPANY RN100642040 4911 

4 NE0026A AEP TEXAS CENTRAL COMPANY RN100552181 4911 

5 JI0030K AEP TEXAS NORTH COMPANY RN100215557 4911 

6 CB0003M ALCOA ALUMINA & CHEMICALS RN100242577 2819 

7 HG0558G ATOFINA CHEMICALS INC RN100209444 2869 

8 BL0021O BASF CORPORATION RN100218049 2869 

9 GB0001R BP AMOCO CHEMICAL COMPANY RN102536307 2869 

10 MH0009H CELANESE LIMITED RN100258060 2869 

11 ED0011D CHAPARRAL STEEL MIDLOTHIAN RN100216472 3312 

12 BJ0001T CHEMICAL LIME LTD RN100219856 3274 

13 BL0758C CHEVRON PHILLIPS CHEMICAL RN100825249 2869 

14 HG0310V CHEVRON PHILLIPS CHEMICAL RN103919817 2869 

15 HW0013C CHEVRON PHILLIPS CHEMICAL RN102320850 2869 

16 BG0057U CITY PUBLIC SERVICE RN100217975 4911 

17 BG0186I CITY PUBLIC SERVICE RN100217835 4911 

18 CR0020C COPANO PROCESSING LP RN101271419 1321 

19 CI0022A DYNEGY MIDSTREAM SERVICES RN100222900 1321 

20 HG0218K EI DUPONT RN100225085 2869 

21 EE0029T EL PASO ELECTRIC CO RN100211309 4911 

22 TH0004D ELECTRIC UTILITY DEPT RN100219872 4911 

23 MQ0009F ENTERGY GULF STATES INC RN100226877 4911 

24 OC0013O ENTERGY GULF STATES INC RN102513041 4911 

25 BL0113I EQUISTAR RN100218601 2869 

26 BL0268B EQUISTAR CHEMICALS LP RN100237668 2821 

27 HG0228H EXXON CHEMICAL CO RN102212925 2869 

28 JE0065M EXXON MOBIL CHEMICAL CO RN100211903 2821 

29 HG0229F EXXONMOBIL CHEMICAL CO RN102574803 2869 

30 NE0120H Flint Hills Resources RN102534138 2911 

31 NE0122D FLINT HILLS RESOURCES LP RN100235266 2911 

32 JE0052V HUNTSMAN CORPORATION RN100219252 2869 

33 JE0135Q HUNTSMAN PETROCHEMICAL RN100217389 2869 

34 BL0002S Ineos Olefins & Polymers RN100238708 2869 

35 WE0005G LAREDO POWER RN100213909 4911 

36 MB0123F LEHIGH CEMENT COMPANY RN100218254 3241 

37 NE0025C LON C HILL POWER RN100215979 4911 

38 BC0015L Lower Colorado River Authority RN102038486 4911 

Deleted: Page Break

Deleted: 2
9-8 

No. Account Source Regulated Entity SIC 

39 FC0018G Lower Colorado River Authority RN100226844 4911 

40 HG1575W Lyondell Chemical RN100633650 2869 

41 HG1451S OXYVINYLSLP RN102518065 2821 

42 JE0042B PREMCOR REFINING GROUP RN102584026 2911 

43 HG0632T ROHM & HAAS TEXAS RN100223205 2869 

44 BL0038U SOLUTIA INC RN100238682 2869 

45 GJ0043K SOUTHWESTERN ELECTRIC POWER RN102156916 4911 

46 LN0081B 

SOUTHWESTERN PUBLIC SERVICE 

(FORMERLY XCEL) RN100224765 4911 

47 ME0006A SOUTHWESTERN ELECTRIC POWER RN100542596 4911 

48 PG0040T SOUTHWESTERN PUBLIC SERVICE RN100224641 4911 

49 PG0041R SOUTHWESTERN PUBLIC SERVICE RN100224849 4911 

50 JE0091L SUN MARINE TERMINAL RN100214626 4226 

51 WN0042V TARGA RN102552387 1311 

52 CI0012D TEXAS GENCO LP RN100825371 4911 

53 FG0020V TEXAS GENCO LP RN100888312 4911 

54 HG0562P TEXAS PETROCHEMICALS LP RN100219526 2869 

55 BL0082R THE DOW CHEMICAL CO RN100225945 2869 

56 NE0022I TICONA POLYMERS INC RN101625721 2869 

57 FI0020W TXU BIG BROWN COMPANY LP RN101198059 4911 

58 DB0251U TXU ELECTRIC COMPANY RN101559854 4911 

59 FB0025U TXU GENERATION COMPANY LP RN102285855 4911 

60 HQ0012T TXU GENERATION COMPANY LP RN100664812 4911 

61 MB0116C TXU GENERATION COMPANY LP RN102566494 4911 

62 MM0023J TXU GENERATION COMPANY LP RN102147881 4911 

63 MO0014L TXU GENERATION COMPANY LP RN102285848 4911 

64 RL0020K TXU GENERATION COMPANY LP RN102583093 4911 

65 TA0352I TXU GENERATION COMPANY LP RN100693308 4911 

66 WC0028Q TXU GENERATION COMPANY LP RN102183969 4911 

67 YB0017V TXU GENERATION COMPANY LP RN102563426 4911 

68 GB0076J UNION CARBIDE CORP RN100219351 2869 

69 CB0028T UNION CARBIDE CORPORATION RN102181526 2869 

70 GB0073P VALERO REFINING CO TEXAS RN100238385 2911 

71 VC0003D VICTORIA POWER RN100214980 4911 

72 JB0016M VINTAGE PETROLEUM INC RN100214592 1311 

Distances from the BART-eligible sources to Class I areas were determined and are shown in 

Table 9-4 that follows. 

Deleted: ¶

Page Break

¶

Table 9-2: BART-Eligible 

Sources Screened Out Using 

Cumulative CAMx (cont’d)¶

No.

Deleted: Page Break

... [3]
9-9 

Table 9-4: BART-Eligible Source Distance to Each Class I 

Distance to Class I (km) 

Regulated 

Entity Company 

Big Bend 

Breton Isle 

Caney Creek 

Carlsbad Caverns 

Guada-lupe Mtns 

Salt Creek 

Upper Buffalo 

Wheeler Peak 

WM

RN100220110 ABITIBI CONSOLIDATED CORP 851 580 343 937 968 946 514 1148 RN102560687 AEP TEXAS CENTRAL CO 652 957 979 945 953 1054 1152 1374 RN100642040 AEP TEXAS CENTRAL CO 608 862 815 860 874 951 988 1255 RN100552181 AEP TEXAS CENTRAL CO 590 865 797 838 852 926 970 1229 RN100215557 AEP TEXAS NORTH CO 497 1071 556 460 495 455 681 688 RN101531226 AEP TEXAS NORTH CO 351 1125 684 393 420 442 821 733 RN100221472 ALCOA INC 609 792 510 731 758 769 679 1022 RN100242577 ALCOA WORLD ALUMINA LLC 652 759 680 859 878 927 854 1209 RN100250869 ALON USA LP 373 1223 720 295 329 316 837 604 RN100225978 ASH GROVE TEXASLP 693 827 342 710 744 700 496 893 RN100209444 ATTOFINA CHEMICALS INC 780 609 526 932 957 972 698 1217 RN100219872 AUSTIN ENERGY 553 843 563 690 715 738 731 1005 RN100218049 BASF CORPORATION 760 641 613 942 965 996 785 1258 RN102536307 BP AMOCO CHEMICAL CO 804 590 566 969 993 1014 736 1264 RN102535077 BP PRODUCTS NORTH AMERICA 805 562 564 970 994 1014 735 1264 RN100221761 CABOT CORPORATION 721 1296 642 497 535 377 686 414 RN100211507 CAPITOL CEMENT DIV 466 924 677 652 672 724 843 1017 RN101996395 CELANESE CHEMICAL 717 1297 645 492 531 373 689 413 RN100258060 CELANESE LTD 702 703 642 894 915 955 816 1227 RN100216472 CHAPARRAL STEEL 687 828 348 707 741 699 503 894 RN100219856 CHEMICAL LIME LTD 603 858 443 658 689 672 601 901 RN103919817 CHEVRON PHILLIPS CHEMICAL 805 584 515 953 979 990 686 1231 RN102320850 CHEVRON PHILLIPS CHEMICAL 733 1332 676 494 531 365 715 379 RN100825249 CHEVRON PHILLIPS CHEMICAL 726 673 612 908 930 964 785 1229 RN102555166 CITGO REFINING & CHEMICALS 557 866 798 837 852 926 971 1229 RN100217975 CITY PUBLIC SERVICE 475 917 693 673 692 748 861 1044 RN100217835 CITY PUBLIC SERVICE 470 923 701 671 689 748 868 1045 RN102495884 CONOCO PHILLIPS 732 1333 677 492 530 363 716 378 RN101271419 COPANO PROCESSING LP 640 751 598 813 835 868 771 1138 RN100218684 DCP MIDSTREAM LP 350 1355 837 167 204 198 943 519 
9-10 

Distance to Class I (km) 

Regulated 

Entity Company 

Big Bend 

Breton Isle 

Caney Creek 

Carlsbad Caverns 

Guada-lupe Mtns 

Salt Creek 

Upper Buffalo 

Wheeler Peak 

WM

RN100209659 DEGUSSA ENG CARBONS 728 1337 683 486 524 357 722 373 RN100227016 DOW CHEMICAL CO 791 600 539 947 972 988 710 1235 RN104150123 DOW CHEMICAL CO 796 598 536 951 975 987 717 1238 RN100222900 DYNEGY MIDSTREAM SERVICES 807 583 513 954 980 991 684 1231 RN100219815 EASTMAN CHEMICAL COMPANY 886 623 224 927 960 915 397 1084 RN100225085 EI DUPONT DE NEMOURS & CO 794 596 530 947 972 987 701 1232 RN100542711 EI DUPONT DE NEMOURS & CO 918 472 484 1053 1080 1080 646 1303 RN100211309 EL PASO ELECTRIC CO 428 1689 1178 178 146 260 1273 518 RN102166964 ENBRIDGE PIPELINES LP 940 647 135 952 987 924 308 1067 RN100226877 ENTERGY GULF STATES INC 753 643 461 878 906 908 634 1143 RN102513041 ENTERGY GULF STATES INC 907 484 487 1043 1070 1071 650 1295 RN100210574 EQUISTAR 777 619 582 948 971 996 753 1252 RN100237668 EQUISTAR CHEMICALS LP 777 618 582 948 972 997 754 1252 RN100542281 EQUISTAR CHEMICALS LP 787 603 517 935 961 973 688 1216 RN100211903 EXXON MOBIL CHEMICALS 889 501 482 1024 1051 1053 647 1279 RN102212925 EXXONMOBIL CHEMICAL CO 796 594 524 947 972 986 695 1229 RN102574803 EXXONMOBIL CHEMICAL CO 795 594 525 947 972 986 696 1229 RN102579307 EXXONMOBIL CORP 796 598 526 944 970 982 697 1236 RN102450756 EXXONMOBIL OIL CORP 888 502 482 1023 1050 1052 647 1278 RN102534138 FLINT HILLS RESOURCES LP 590 865 798 838 852 927 971 1230 RN100235266 FLINT HILLS RESOURCES LP 580 874 800 829 843 918 972 1222 RN100219252 HUNTSMAN CORP 899 491 492 1037 1064 1067 656 1293 RN100217389 HUNTSMAN CORP 897 493 501 1038 1065 1069 666 1297 RN101867554 HUNTSMAN POLYMERS CORP 293 1303 819 212 241 277 936 600 RN100238708 INEOS USA LLC 779 617 584 951 974 1000 756 1255 RN100543115 INTERNATIONAL PAPER CO 974 619 128 988 1023 960 296 1099 RN104392626 INVISTA 918 472 484 1053 1080 1080 646 1303 RN102663671 INVISTA S.A.R.L. 614 797 693 824 842 896 866 1182 RN100213909 LAREDO WLE LP 411 1069 918 703 710 818 1086 1145 RN100218254 LEHIGH CEMENT COMPANY 623 820 438 694 725 712 601 942 RN100215979 LON C HILL LP 571 882 802 820 834 911 974 1216 
9-11 

Distance to Class I (km) 

Regulated 

Entity Company 

Big Bend 

Breton Isle 

Caney Creek 

Carlsbad Caverns 

Guada-lupe Mtns 

Salt Creek 

Upper Buffalo 

Wheeler Peak 

WM

RN102038486 LCRA 583 810 559 727 752 775 729 1040 RN100226844 LCRA 630 760 558 783 807 831 730 1094 RN100633650 LYONDELL CHEMICAL CO 787 603 518 936 962 975 690 1218 RN100218130 LYONDELL CITGO REFINING 775 615 529 928 953 969 703 1216 RN100210608 MARATHON PETROLEUM 806 587 564 971 995 1015 734 1265 RN102609724 NORIT AMERICAS INC 915 603 209 954 988 940 381 1104 RN101062826 NRG TEXAS LP 799 593 552 960 984 1003 723 1251 RN100223585 OWENS-CORNING 701 811 336 724 758 717 494 910 RN102518065 OXY VINYLS LP 789 601 528 941 966 981 699 1226 RN100716661 PASADENA REFINING SYSTEM 777 613 528 930 955 971 703 1217 RN102584026 PREMCOR REFINING GROUP 897 493 505 1039 1066 1070 669 1299 RN100216621 REGENCY FS (FIELD SERVICES) 468 953 788 711 725 804 957 1113 RN100223205 RHODIA, INC. 797 593 524 948 973 987 695 1230 RN100223205 ROHM & HAAS TEXAS 788 602 528 940 965 980 699 1225 RN100211879 SHELL OIL CO 785 604 530 938 964 979 701 1224 RN100222413 SID RICHARDSON CARBON 727 1337 683 486 524 357 722 373 RN100226026 SID RICHARDSON CARBON 218 1407 945 142 153 275 1063 618 RN100238682 SOLUTIA INC 777 618 582 948 972 997 754 1252 RN102156916 SOUTHWESTERN ELEC POWER 888 616 231 932 965 921 403 1092 RN100542596 SOUTHWESTERN ELEC POWER 915 632 178 941 975 921 351 1077 RN100213370 SOUTHWESTERN ELEC POWER 900 668 165 914 949 890 338 1041 RN100224641 SOUTHWESTERN PUBLIC SERV 679 1346 705 435 473 308 754 362 RN100224849 SOUTHWESTERN PUBLIC SERV 681 1347 705 436 474 309 754 361 RN100224765 SOUTHWESTERN PUBLIC SERV 490 1282 712 304 344 248 803 477 RN100214626 SUN MARINE TERMINAL 896 494 505 1038 1065 1070 670 1299 RN102551785 TARGA MIDSTREAM SERVICES 251 1327 859 196 219 288 979 621 RN102552387 TARGA MIDSTREAM SERVICES 684 925 361 647 684 617 488 786 RN100214428 TEMPLE-INLAND 921 471 466 1050 1077 1074 628 1293 RN100888312 TEXAS GENCO 736 656 565 901 925 949 738 1205 RN100825371 TEXAS GENCO 804 585 523 955 980 993 694 1236 RN102597846 TEXAS LEHIGH CEMENT CO 525 867 599 678 701 734 767 1009 
9-12 

Distance to Class I (km) 

Regulated 

Entity Company 

Big Bend 

Breton Isle 

Caney Creek 

Carlsbad Caverns 

Guada-lupe Mtns 

Salt Creek 

Upper Buffalo 

Wheeler Peak 

WM

RN100g219526 TEXAS PETROCHEMICALS LP 772 617 534 927 952 968 706 1216 RN102561925 THE GOODYEAR TIRE & RUBBER 874 516 492 1013 1040 1044 659 1273 RN101625721 TICONA POLYMERS INC 562 911 839 824 836 920 1011 1230 RN102457520 TOTAL PETROCHEMICALS USA 904 485 493 1043 1070 1072 657 1298 RN100217199 TXI OPERATIONS LP 688 827 347 708 742 700 503 895 RN101198059 TXU BIG BROWN CO LP 741 719 340 802 833 806 511 1010 RN101559854 TXU GENERATION COMPANY 720 841 312 716 751 695 459 871 RN102285855 TXU GENERATION COMPANY 809 822 227 781 818 745 366 887 RN100664812 TXU GENERATION COMPANY 630 886 402 645 678 640 550 846 RN102566494 TXU GENERATION COMPANY 651 797 413 719 750 733 578 957 RN102147881 TXU GENERATION COMPANY 610 791 509 732 758 770 679 1022 RN102285848 TXU GENERATION COMPANY 403 1178 674 343 376 355 793 627 RN102583093 TXU GENERATION COMPANY 889 604 242 939 972 930 414 1104 RN100693308 TXU GENERATION COMPANY 680 865 352 680 715 665 498 852 RN102285921 TXU GENERATION COMPANY 885 685 170 897 932 872 342 1024 RN102183969 TXU GENERATION COMPANY 255 1360 884 162 186 261 1001 599 RN102563426 TXU GENERATION COMPANY 612 991 441 567 603 541 563 730 RN102181526 UNION CARBIDE CORP 634 783 702 848 867 921 876 1208 RN100219351 UNION CARBIDE CORP 802 591 565 967 991 1012 735 1262 RN100213685 VALENCE MIDSTREAM 842 717 204 853 888 831 372 990 RN100210517 VALERO MCKEE 751 1387 728 490 527 350 760 326 RN100238385 VALERO REFINING CO TEXAS 806 588 565 971 995 1015 735 1265 RN100211663 VALERO REFINING CO TEXAS 559 867 798 836 851 925 971 1229 RN100218601 VETROTEX AMERICA 671 1019 419 587 625 539 521 690 RN100214980 VICTORIA WLE LP 607 799 682 813 832 883 855 1169 RN100214592 VINTAGE PETROLEUM LLC 646 761 669 847 867 914 842 1195 RN102157609 WESTVACO 891 503 451 1016 1044 1040 617 1260 
9-13 

9.2.2 Individual Source Attribution Approach 

One of the air quality modeling approaches suggested by the EPA in the BART guidance is an 

individual source attribution approach. Specifically, this entails modeling source-specific BARTeligible units and comparing modeled impacts to a particular deciview threshold. 

 

CALPUFF 

The CALPUFF modeling protocol, Best Available Retrofit Technology (BART) Modeling 

Protocol to Determine Sources Subject to BART in the State of Texas, developed by the TCEQ for 

determining which sources are subject to BART is included in Appendix 9-8: CALPUFF 

Modeling Guidelines (online). Appendix 9-8 also contains a summary report for each modeling 

demonstration. Table 9-5: BART-Eligible Sources Exempt Based on CALPUFF Modeling 

Results lists the BART-eligible sources that are exempt from BART based on CALPUFF 

modeling results. 

Deleted: 7

Deleted: 7 

Deleted: 3:

Deleted: ¶

Page Break
9-14 

Table 9-5: BART-Eligible Sources Exempt Based on CALPUFF Modeling Results 

Regulated 

Entity Account Source SIC 

RN100221472 MM0001T ALCOA INC 3334 

RN100250869 HT0011Q ALON USA LP 2911 

RN100225978 ED0034O 

ASH GROVE (formerly NORTH TEXAS 

CEMENT) 3241 

RN100221761 GH0003Q CABOT CORPORATION 2895 

RN101996395 GH0004O CELANESE CHEMICAL 2869 

RN102495884 HW0018P CONOCO PHILLIPS (formerly PHILLIPS 66 CO) 2911 

RN100218684 AB0012W 

DCP (formerly DUKE ENERGY FIELD 

SERVICES) 1321 

RN100209659 HW0008S DEGUSSA ENGINEERED CARBONS 2869 

RN100219815 HH0042M EASTMAN CHEMICAL COMPANY 2869 

RN100542281 HG0033B EQUISTAR CHEMICALS LP 2869 

RN102579307 HG0232Q EXXONMOBIL CORP 2911 

RN102450756 JE0067I EXXONMOBIL OIL CORP 2911 

RN101867554 EB0057B HUNTSMAN POLYMERS 2869 

RN100543115 CG0010G INTERNATIONAL PAPER CO 2621 

RN104392626 OCA002B INVISTA 2869 

RN102663671 VC0008Q INVISTA (formerly DU PONT DE NEMOURS) 2869 

RN101062826 GB0037T NRG TEXAS (formerly TEXAS GENCO LP) 4911 

RN100223585 ED0051O OWENS CORNING 3296 

RN100220581 HG0697O RHODIA INC 2819 

RN100211879 HG0659W SHELL OIL CO 2911 

RN100222413 HW0017R SID RICHARDSON CARBON 2895 

RN100226026 HT0027B SID RICHARDSON CARBON CO 2895 

RN100213370 TF0012D SOUTHWESTERN ELECTRIC POWER 4911 

RN100214428 OC0019C TEMPLE-INLAND 2621 

RN102597846 HK0014M TEXAS LEHIGH CEMENT CO 3241 

RN102457520 JE0005H 

TOTAL PETROCHEMICALS INC (formerly 

ATOFINA PETROCHEMICALS INC) 2911 

RN100217199 ED0066B TXI OPERATIONS LP 3241 

RN102285921 TF0013B TXU GENERATION COMPANY LP 4911 

RN102157609 JC0003K WESTVACO 2631 

Deleted: 3

Deleted: No. ... [4]
9-15 

CAMx 

The CAMx modeling guideline, Guidance for the Application of the CAMx Hybrid 

Photochemical Grid Model to Assess Visibility Impacts of Texas BART Sources at Class I Areas, 

developed by the TCEQ is in Appendix 9-9. This appendix also contains the modeling summary 

reports for each modeling demonstration. Table 9-6 presents the BART-eligible sources that 

screened out on an individual basis using CAMx. 

Table 9-6: BART-Eligible Sources ExemptedScreened Out on Individual Basis Using Single 

Source CAMx Modeling 

No. Account Source Regulated Entity SIC 

1 GB0004L BP PRODUCTS NORTH AMERICA RN102535077 2911

2 NE0027V CITGO REFINING & CHEMICALS RN102555166 2911

3 HGA005E DOW RN104150123 2869

4 HG0048L LYONDELL CITGO REFINING RN100218130 2911

5 HG0175D PASADENA REFINING RN100716661 2911

6 NE0043A VALERO REFINING COMPANY RN100211663 2911 

Reference 

Number Reference Number 

Nearest 

Class I 

Area 

Distance 

to Nearest 

Class I 

area (km) 

Emission Rate 

Data Source 

Highest 

Impact 

(dv) 

Class I 

Area 

with 

Highest 

Impact 

RN102535077 

BP Products North 

American BRET 562 Permit Allowables 0.28 CACR 

RN102555166 

CITGO Corpus Christi 

Refinery BIBE 557 Permit Allowables 0.16 BIBE 

RN104150123 

Dow Chemical 

Company CACR 536 Permit Allowables 0.21 BRET 

RN100218130 Houston Refining LP CACR 529 

PTE, Permit 

Allowables 0.10 

UPBU/ 

CACR 

RN100716661 

Pasadena Refining 

System Inc. CACR 528 Permit Allowables 0.42 CACR 

RN100211663 

Valero Corpus Christi 

East Plant BIBE 554 

Facility Wide 

Emission Cap 0.11 

BIBE/ 

CACR 

9.3 SITES REMOVED FROM FURTHER BART CONSIDERATION 

The TCEQ BART rule was published January 10, 2007. Companies requested removal from 

further BART consideration per the exemptions in the rule or based on updated information on 

the site. To be removed from the list, a site had to be exempted for all potential haze causing 

pollutants, NOX, SO2, and fine particulate matter. A site may be exempted if the combined NOX

and SO2 potential to emit are less than 1,000 tpy, and the site is greater than 100 km from a Class 

I area. Some sites may be exempted if the combined NOX and SO2 potential to emit are less than 

500 tpy, and the site is greater than 50 km from a Class I area. Several sites requested exemption 

for combined SOX and NOX limits and certified that the TCEQ-sponsored modeling adequately 

represented particulate emissions. One site requested PM2.5 exemption due to de minimis levels 

of emissions. 

Updated site information included construction dates and potential emission rates of equipment. 

Two sites requested removal because the operating equipment did not meet a BART category. 

The results of granted exclusions are also shown in Table 9.7: Summary of BART-Eligible Source 

Determinations. 

Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough

Deleted: 8

Deleted: 4

Deleted: 4

Deleted: 9.3 ¶
9-16 

Table 9-7: Sites Removed From BART Due to Exemption Requests 

No. Regulated 

Entity Company Reason Account SIC 

1 RN100220110 

ABITIBI CONSOLIDATED 

CORP 

PTE*<1,000, 

de minimis PM AC0017B 2621 

2 RN102559291 BMC HOLDINGS INC 

PTE<1,000, 

PM certification JE0343H 2869 

3 RN100211507 CAPITOL CEMENT Shut down kiln BG0045E 3241 

4 RN100227016 CELANESE PTE<250 HG0126Q 2869 

5 RN100825249 

CHEVRON PHILLIPS 

CHEMICAL 

met TCEQ model 

plant BL0758C 2869 

6 RN100542711 

EI DUPONT DENEMOURS & 

CO 

PTE<1,000, 

 PM certification OC0007J 2869 

7 RN102166964 ENBRIDGE PIPELINES PTE<250 CG0012C 1321 

8 RN104579487 INEOS USA PTE<250 GBA007G 2869 

9 RN100212018 J.L. DAVIS GAS PROCESSING No BART sources CA0011B 1321 

10 RN100213719 

JOHNS MANVILLE 

INTERNATIONAL PTE<250 JH0025O 3296 

11 RN100633650 LYONDELL PETROCHEMICAL 

PTE<1,000, 

PM certification HG1575W 2869 

12 RN100210608 

MARATHON ASHLAND 

PETROLEUM PTE<250 GB0055R 2911 

13 RN102609724 NORIT AMERICAS INC 

PTE<1,000, 

PM certification HH0019H 2819 

14 RN102643327 

PUEBLO MIDSTREAM GAS 

CORP 

recheck dates, 

not BART AG0024G 1321 

15 RN100211408 REGENCY GAS SERVICES No BART equip PE0024Q 1321 

16 RN100216621 REGENCY TILDEN GAS 

PTE<1,000, 

PM certification MC0002H 2819 

17 RN102551785 TARGA Shut down CY0019H 1311 

18 RN102561925 

THE GOODYEAR TIRE AND 

RUBBER CO PTE<250 JE0039N 2822 

19 RN100213685 VALENCE MIDSTREAM LTD plant shut down HR0018T 1321 

20 RN100210517 VALERO MCKEE REFINERY 

PTE<1,000, 

PM certification MR0008T 2911 

21 RN100219310 VALERO REFINING TEXAS LP 

PTE<1,000, 

PM certification HG0130C 2911 

22 RN100218601 

VETROTEX AMERICA ST. 

GOBAIN 

PTE<500, 

 PM certification WH0014S 3229 

Note: *PTE is potential to emit 
9-17 

9.4 DETERMINATION OF BART FOR SOURCES SUBJECT TO BART 

Upon conclusion of all BART screening analyses and review of exclusion requests, no Texas 

sources remained subject to BART. The Some EGUs may become subject to BART pending 

resolution of CAIR at the federal level. Table 9-8: Summary of BART-Eligible Source 

Determination summarizes where a determination was made for all sources in the BART 

determination process. Several sources were added to the process after the BART survey, either 

at the site’s request or as a result of recent activity at the site. Their status is reflected in this 

table. Site activity included transfer of equipment or corporate reorganization resulting in site 

splits. Although not used thus far for any sources, the TCEQ’s Engineering Analysis Guidance 

and forms are in Appendix 9-10. 

Table 9-8: Summary of BART-Eligible Source Determinations 

Reason for Removal 

Account Company BARTeligible1 Cum. 

Model 

CAMx 

CALPUFF 

Single 

Source 

CAMx 

Exemption 

Request 

TG0044C AEP TEXAS y y 

CD0013K AEP TEXAS CENTRAL COMPANY y y 

NE0024E AEP TEXAS CENTRAL COMPANY y y 

NE0026A AEP TEXAS CENTRAL COMPANY y y 

JI0030K AEP TEXAS NORTH COMPANY y y 

CB0003M ALCOA ALUMINA & CHEMICALS y y 

BL0002S INEOS OLEFINS & POLYMERS y y 

HG0558G ATOFINA CHEMICALS INC y y 

BL0021O BASF CORPORATION y y 

GB0001R BP AMOCO CHEMICAL COMPANY y y 

MH0009H CELANESE LIMITED y y 

ED0011D CHAPARRAL STEEL MIDLOTHIAN y y 

BJ0001T CHEMICAL LIME LTD y y 

HG0310V CHEVRON PHILLIPS CHEMICAL y y 

HW0013C CHEVRON PHILLIPS CHEMICAL CO y y 

BG0057U CITY PUBLIC SERVICE y y 

BG0186I CITY PUBLIC SERVICE y y 

CR0020C COPANO PROCESSING LP y y 

CI0022A DYNEGY MIDSTREAM SERVICES y y 

WN0042V TARGA y y 

HG0218K EI DUPONT y y 

EE0029T EL PASO ELECTRIC CO y y 

TH0004D ELECTRIC UTILITY DEPT y y 

MQ0009F ENTERGY GULF STATES INC y y 

OC0013O ENTERGY GULF STATES INC y y 

BL0113I EQUISTAR y y 

BL0268B EQUISTAR CHEMICALS LP y y 

HG0033B EQUISTAR CHEMICALS LP y y 

HG0228H EXXON CHEMICAL CO y y 

JE0065M EXXON MOBIL CHEMICAL CO y y 

HG0229F EXXONMOBIL CHEMICAL CO y y 

NE0122D FLINT HILLS RESOURCES LP y y 

JE0052V HUNTSMAN CORPORATION y y 

JE0135Q HUNTSMAN PETROCHEMICAL y y 

Deleted: 9
9-18 

Reason for Removal 

Account Company BARTeligible1 Cum. 

Model 

CAMx 

CALPUFF 

Single 

Source 

CAMx 

Exemption 

Request 

CORP 

EB0057B HUNTSMAN POLYMERS y y 

GBA007G INEOS y 

NE0120H FLINT HILLS RESOURCES LP y y 

WE0005G LAREDO POWER y y 

MB0123F LEHIGH CEMENT COMPANY y y 

NE0025C LON C HILL POWER y y 

BC0015L 

LOWER COLORADO RIVER 

AUTHORITY y y 

FC0018G 

LOWER COLORADO RIVER 

AUTHORITY y y 

HG1575W LYONDELL CITGO REFINING y y y 

HG1451S OXYVINYLSLP y y 

JE0042B PREMCOR REFINING GROUP y y 

HG0632T ROHM & HAAS TEXAS y y 

BL0038U SOLUTIA INC y y 

GJ0043K SOUTHWESTERN ELECTRIC POWER y y 

ME0006A SOUTHWESTERN ELECTRIC POWER y y 

PG0040T SOUTHWESTERN PUBLIC SERVICE y y 

PG0041R SOUTHWESTERN PUBLIC SERVICE y y 

JE0091L SUN MARINE TERMINAL y y 

CI0012D TEXAS GENCO LP y y 

FG0020V TEXAS GENCO LP y y 

GB0037T NRG Texas y y 

HG0562P TEXAS PETROCHEMICALS LP y y 

BL0082R THE DOW CHEMICAL CO y y 

NE0022I TICONA POLYMERS INC y y 

ED0066B TXI OPERATIONS, L.P. y y 

FI0020W TXU BIG BROWN COMPANY LP y y 

DB0251U TXU ELECTRIC COMPANY y y 

FB0025U TXU GENERATION COMPANY LP y y 

HQ0012T TXU GENERATION COMPANY LP y y 

MB0116C TXU GENERATION COMPANY LP y y 

MM0023J TXU GENERATION COMPANY LP y y 

MO0014L TXU GENERATION COMPANY LP y y 

RL0020K TXU GENERATION COMPANY LP y y 

TA0352I TXU GENERATION COMPANY LP y y 

WC0028Q TXU GENERATION COMPANY LP y y 

YB0017V TXU GENERATION COMPANY LP y y 

GB0076J UNION CARBIDE CORP y y 

CB0028T UNION CARBIDE CORPORATION y y 

GB0073P VALERO REFINING CO TEXAS y y 

VC0003D VICTORIA POWER y y 

JB0016M VINTAGE PETROLEUM, INC. y y 

LN0081B SOUTHWESTERN PUBLIC SERVICE y y 

AC0017B ABITIBI CONSOLIDATED CORP y y 
9-19 

Reason for Removal 

Account Company BARTeligible1 Cum. 

Model 

CAMx 

CALPUFF 

Single 

Source 

CAMx 

Exemption 

Request 

TF0012D SOUTHWESTERN ELECTRIC POWER y y 

MM0001T ALCOA INC y y 

HT0011Q ALON USA LP y y 

ED0034O ASH GROVE y y 

JE0343H BMC HOLDINGS INC y 

GB0004L 

BP PRODUCTS NORTH AMERICA IN 

TEXAS y y 

GH0003Q CABOT CORPORATION y y 

BG0045E CAPITOL CEMENT DIV CAPITOL y y 

GH0004O CELANESE CHEMICAL y y 

BL0758C CHEVRON PHILLIPS CHEMICAL y y 

NE0027V CITGO REFINING & CHEMICALS y y 

HW0018P CONOCOPHILLIPS y y 

AB0012W DCP y y 

HW0008S DEGUSSA ENGINEERED CARBONS y y 

MR0008T DIAMOND SHAMROCK REFINING y y 

HGA005E DOW y y 

HG0126Q DOW y y 

HH0042M EASTMAN CHEMICAL COMPANY y y 

OC0007J EI DUPONT DENEMOURS & CO y y 

MC0002H ENBRIDGE PIPELINE y 

CG0012C ENBRIDGE PIPELINES y y 

HG0033B EQUISTAR CHEMICALS LP y 

HG0232Q EXXONMOBIL CORP - Baytown y y 

JE0067I EXXONMOBIL OIL CORP - Beaumont y y 

EB0057B HUNTSMAN POLYMERS y 

CG0010G INTERNATIONAL PAPER CO y y 

OCA002B INVISTA y y 

VC0008Q INVISTA y y 

JH0025O JOHNS MANVILLE INTERNATIONAL y 

HG0048L LYONDELL CITGO REFINING y y 

GB0055R 

MARATHON ASHLAND 

PETROLEUM y y 

HH0019H NORIT AMERICAS INC y y 

GB0037T NRG Texas y 

ED0051O OWENS CORNING y y 

HG0175D PASADENA REFINING y y 

AG0024G PUEBLO MIDSTREAM GAS CORP y 

PE0024Q REGENCY GAS SERVICES y 

HG0697O RHODIA, INC. y y 

HG0659W SHELL OIL CO y y 

HW0017R SID RICHARDSON CARBON y y 

HT0027B SID RICHARDSON CARBON y y 

CY0019H TARGA y y 

OC0019C TEMPLE-INLAND y y 

HK0014M TEXAS LEHIGH CEMENT CO y y 
9-20 

Reason for Removal 

Account Company BARTeligible1 Cum. 

Model 

CAMx 

CALPUFF 

Single 

Source 

CAMx 

Exemption 

Request 

JE0039N 

THE GOODYEAR TIRE AND RUBBER 

CO y y 

JE0005H TOTAL PETROCHEMICALS y y 

ED0066B TXI OPERATIONS, L.P. y 

TF0013B TXU GENERATION COMPANY LP y y 

HR0018T VALENCE MIDSTREAM LTD y y 

NE0043A VALERO REFINING COMPANY y y 

HG0130C VALERO REFINING TEXAS LP y 

WH0014S VETROTEX WICHITA FALLS PLANT y y 

JC0003K WESTVACO y y 

Note: 

1. Some sources were added to the determination process after the BART survey, either by their request or as a result of 

equipment transfers. These are indicated with a blank. 
9-21 

9.5 POST-BART EMISSIONS REDUCTIONS 

Subsequent to the 2002 base year inventory, some BART-eligible sources reduced their permitted 

emissions. Documentation of the emission reductions is in Appendix 9-11: Documentation of 

Emission Reductions. The sources and the estimated reductions are presented in Table 9-9. 

Reduction estimates are conservative because they are from the 2002 actual emissions level to a 

potential to emit level. Capitol Cement shut down their BART units. The final list of all BARTeligible sources is in Appendix 9-13: BART-Eligible List. 

Table 9-9: Post-BART Emissions Reductions at Texas Sources 

No. Regulated 

Entity Source Account* 

NOX

Reduced 

from 

Baseline 

2002 

(tpy) 

SO2 

Reduced 

from 

Baseline 

2002 

(tpy) 

PM 

Reduced 

from 

Baseline 

2002 

(tpy) 

1 RN100211507 CAPITOL CEMENT DIV BG0045E 1,328 1,193 100

2 RN100227016 DOW HG0126Q 694 0 0

3 RN102450756 EXXONMOBIL OIL*** JE0067I 2.7 290 0

4 RN102609724 NORIT AMERICAS INC HH0019H** 16.6 +5.4 0

5 RN100216621 

REGENCY TILDEN GAS 

(FORMERLY ENBRIDGE 

PIPELINE) MC0002H 2 2,276 0.2

6 RN102551785 

TARGA (FORMERLY 

DYNEGY MIDSTREAM 

SERVICES) CY0019H 336 0.3 0.5

7 RN102561925 

THE GOODYEAR TIRE 

AND RUBBER CO JE0039N 89.1 +11.3 2.9

8 RN100213685 

VALENCE MIDSTREAM 

LTD HR0018T 247.1 2,743.5 5.6

9 RN100218601 

VETROTEX AMERICA 

ST. GOBAIN WH0014S 62.6 16.4 59.0

Total estimated reductions in haze emissions 

= 9,485.2 tpy 2,778.1 6,535.9 168.2

*The first two letters in account number are the abbreviation for the source’s county location. See 

Appendix 9-12 for the list of county abbreviations. 

**Company has permit limiting combined SO2 and NOx to 841 tpy on previously grandfathered BART 

sources but 2002 . This limit is lower than actual emissions from these units were 8 tpy less than thisin 

previous years. For example, the facility emitted 1,266 tpy of NOX and SO2 in 1990. 

***ExxonMobil numbers are preliminary and subject to change. These estimates are based on reductions 

from the 2002 EI and proposed alterations to permit 19136pre- and an EPA consent decree. 

Deleted: 4

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Deleted: 12

Deleted: 6

Deleted: No.

Deleted: 11 

... [5]
9-22 

9.5 SITES REMOVED FROM FURTHER POST-BART CONSIDERATION

The TCEQ BART rule was published January 10, 2007. Companies requested removal from 

further BART consideration per the exemptions in the rule or based on updated information on 

the site. To be removed from the list, a site had to be exempted for all potential haze causing 

pollutants, NOX, SO2, and fine particulate matter. A site may be exempted if the combined NOX

and SO2 potential to emit are less than 1,000 tpy, and the site is greater than 100 km from a Class 

I area. Some sites may be exempted if the combined NOX and SO2 potential to emit are less than 

500 tpy, and the site is greater than 50 km from a Class I area. Several sites requested exemption 

for combined SOX and NOX limits and certified that the TCEQ-sponsored modeling adequately 

represented particulatehourly emissions One site requested PM 2.5 exemption due to de minimis

levels of emissions. 

Updated site information included construction dates and potential emission rates submitted. 

(Emission reductions as a result of equipment. Two sites requested removal because the 

operating equipment did not meet a BART category. Table 9-7 lists the sites removed from 

further BART consideration. Table 9-7: Sites Removed From BART Due to Exemption 

Requests per TCEQ BART Rule and Updated Site Informationthe completion of permit 49138 

(FCCU) will be updated when they become available.)

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10-1 

CHAPTER 10. REASONABLE PROGRESS GOALS 

10.1 INTRODUCTION 

The national goal for regional haze is to achieve natural visibility levels at Class I areas by 2064. 

The Texas Commission on Environmental Quality (TCEQ) must show reasonable progress 

toward the national goal by 2018. The uniform rate of progress (URP) named in the United 

States Environmental Protection Agency (EPA) guidance (described as uniform rate of 

improvement in 40 Code of Federal Regulations (CFR) §51.308(d)(1)(i)(B)) is a straight line 

between base period conditions on the worst 20 percent days and estimated natural visibility in 

2064conditions. Chapter 5: Assessment of Baseline and Current Conditions and Estimate of 

Natural Conditions in Class I Areas details the calculation of base period conditions and 

estimations of 2064 natural conditions. The URP is a tool for comparing the reasonable progress 

goals (RPGs) set by the state with the visibility improvement that would be needed to reach 

natural conditions by 2064. Table 10-1: Uniform Rate of Progress for Class I Areas in Texas 

(Worst 20 Percent Days) shows the URP goals for Texas’ 2018 deciview values for the two 

Texas Class I areas. 

Table 10-1 shows Texas’ calculation of natural conditions using the approximation that 100 

percent of the dust (coarse mass and fine soil) at both Big Bend and Guadalupe Mountains 

National Parks is natural. As Chapter 5 discusses in more detail, analysis indicated that the 

approximation that all the dust is natural is a better approximation than an estimate using any 

substantively lower percentage. 

The TCEQ plans to work with the EPA, Federal Land Managers (FLMs), and other experts and 

researchers as Texas continues to refine natural condition estimates for future five-year reports 

and ten-year Regional Haze SIP revisions.

Table 10-1: Uniform Rate of Progress for Class I Areas in Texas (Worst 20 Percent Days) 

Class I Area 

Improvement 

Needed by 2018 

assumingAssumi

ng URP (dv) 

Annual Progress 

AnnuallyNeeded

to 2018 

assumingMeet

URP (dv) 

Improvement 

Needed by 2064 

(dv) 

Big Bend 1.7 0.12 7.2

Guadalupe Mountains 1.2 0.08 4.9

10.2 REASONABLE PROGRESS GOALS FOR TEXAS CLASS I AREAS 

The TCEQ has determined that the rate of visibility improvement by 2018, shown in Table 10-2: 

Reasonable Progress Goals for Class I Areas (Worst 20 Percent Days), is reasonable and will be 

implemented as the RPGs for the listed Class I areas. 

Table 10-2: Reasonable Progress Goals for Class I Areas (Worst 20 Percent Days) 

Class I Area 

Improvement 

Projected by 

2018 using 

RPG (dv) 

Improvement 

by 2018 at 

URP

(dv) 

Projected 

Improvement 

by 2064

(dv) 

Date Natural 

Visibility 

Attained at RPG 

Rate 

Big Bend 0.7 1.7 2.9 2155 

Guadalupe Mountains 0.9 1.2 3.8 2081 

Deleted: ,

Deleted: 

Deleted: 
10-2 

These RPGs are derived from the CENRAP modeling and reflect emissions reduction reductions 

programs already in place, including CAIR and additional refinery SO2 reductions from refineries 

as a result of the EPA refinery consent decrees. These RPGs assume that either CAIR will 

remain in place or will be replaced by a comparable program to reduce visibility impairing 

pollution from EGUs in Texas and in the eastern United States. As Chapter 11: Long-Term 

Strategy to Reach Reasonable Progress Goals details, the TCEQ’s emissions reduction 

requirements have often gone beyond the Federal Clean Air Act (FCAA) requirements for the 

past 35 years and continue to go beyond many federal requirements today. Texas programs that 

often go beyond federal requirements include: 

• opacity limits on grandfathered facilities; 

• Best Available Control Technology (BACT) requirements that typically go beyond 

EPA’s New Source Performance Standards (NSPS) for new and modified sources; 

• extensive NOX emission limits on existing and new sources including major, minor, and 

area sources including some on a statewide basis; 

• the Texas Emissions Reduction Program (TERP), which provides financial incentives to 

accelerate the implementation of new, cleaner diesel engine technologies in on-road and 

non-road applications; and 

• the Air Check Texas Repair and Replacement Assistance Program, which provides 

financial incentives for scrappage of older gasoline-powered on-road vehicles. 

The reasonable progress goals were developed after considering the statutory factors: cost and 

time of compliance, the energy and non-air quality impacts of compliance, and the remaining 

useful life of existing sources. Appendix 10-1: Analysis of Control Strategies and Determination 

of Reasonable Progress Goals provides an analysis showing that these goals are reasonable. 

The TCEQ focused its control strategy analysis on point source emissions of SO2 and NOX. 

Chapter 11: Long-Term Strategy to Reach Reasonable Progress Goals demonstrates that these 

are the main anthropogenic pollutants that affect visibility at Class I areas in Texas and in 

neighboring states. For SO2, point sources make up over 9590 percent of the projected 2018 

statewide emissions. Point sources are clearly the issue for this pollutant. For NOX, point sources 

comprise over 45 percent of the projected statewide emissions. This is the largest single 

component. The next largest is area sources. Of that, the greatest component also has the 

greatest uncertainty: emissions from upstream oil and gas production. The Working with 

CENRAP, the TCEQ will continueplans to refine its understanding of those emissions and 

options for controls over the next few years. Nevertheless, Texas is moving aggressively to 

reduce those emissions through the $4 million grant program to pay for retrofits on rich burn 

compressor engines. Texas is going beyond federal requirements in an effort to reduce NOX

emissions of NOX from on-road and non-road mobile sources through the Texas Emissions 

Reduction Program (TERP). As a result, the TCEQ elected to focus the control strategy analysis 

on point sources. 

Figures 10-1: Glide Path for Big Bend Worst 20 Percent Days and 10-2: Glide Path for 

Guadalupe Mountains Worst 20 Percent Days graphically illustrate how these RPGs compare to 

the URP or the glide path for the Texas Class I areas. 

Deleted: ,

Deleted: ’

Deleted: , 

Deleted: )

Deleted: ,
10-3 

17.3 16.8

15.6

14.4

13.2

12.0

10.8 10.1

16.6

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews)

Uniform Rate of Progress (TX) Observation 2018 Projection

 Figure 10-1: Glide Path for Big Bend Worst 20 Percent Days 

17.2 16.9 16.0 15.2 14.4 13.6 12.8 12.3

16.3

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews)

Uniform Rate of Progress (TX) Observation 2018 Projection

 Figure 10-2: Glide Path for Guadalupe Mountains Worst 20 Percent Days 

The figures and tables above address the TCEQ’s RPGs for the worst 20 percent days at Big 

Bend and Guadalupe Mountains. These figures use the TCEQ’s refined estimate for natural 

conditions, rather than the EPA default values. Appendix 10-3: Uniform Rate of Progress 

Curves Using Default Natural Conditions Estimates shows the glide paths using the EPA default 

values. The natural condition estimate was not a factor in setting the RPG. Table 10-3: 
10-4 

Reasonable Progress Goals for Class I Areas (Best 20 Percent Days) provides the state’s RPGs 

for the 20 percent days with the best visibility at the Texas Class I areas. 

Table 10-3: Reasonable Progress Goals for Class I Areas (Best 20 Percent Days) 

Class I Area 

Baseline 

Visibility 

(dv) 

Projected 2018 

Visibility 

(RPG) (dv) 

Improvement 

by 2018 at RPG 

(dv) 

Big Bend 5.8 5.6 0.2 

Guadalupe Mountains 5.9 5.7 0.2 

These RPGs reflect visibility improvements from emissions reductions associated with the 

FCAA, the Texas Clean Air Act, Texas’ ozone SIP revisions and rules, and agreements between 

EPA and oil refineries for SO2 emissions reductions. These RPGs do not include additional 

emissions reductions from implementing the Texas BART rule and new rules adopted in the 

recent May 23, 2007, Dallas-Fort Worth eight-hour ozone attainment demonstration SIP revision. 

The TCEQ considered additional controls beyond those already adopted. Given the cost and 

insignificantimperceptible effect of additional controls, uncertainty of Clean Air Interstate Rule 

(CAIR) impacts, and significant international sources of visibility impairment (all discussed in 

the following section), it is not reasonable to require additional controls at this time to reduce the 

impact of Texas’ emissions on the two Class I areas in Texas. 

10.3 CONSIDERATION OF ADDITIONAL POLLUTION CONTROL 

Development of Area of Influence (AOI) Based Cost Data 

The TCEQ participated in its regional air planning organization, CENRAP, to develop emission 

inventories for 2002 and 2018, model the results of the emission reductions for each state, and 

draw areas of influence for each Class I area in the CENRAP domain. To draw the areas of 

influence CENRAP combined results from three techniques: 1) residence time difference plots 

for each pollutant that has a substantial effect on visibility impairment at each Class I area, 

2) a combination of backward trajectory analysis, emissions information, and monitored 

concentrations, and 3) tagged species source apportionment within reactive photochemical grid 

modeling. Appendix 10-1: Analysis of Control Strategies RPG provides more detailed 

information about CENRAP’s work to define areas of influence. 

For the Class I areas that emissions from Texas affect, the main visibility impairing pollutants 

resulting from human activity are sulfate and nitrate. The emissions that react to form these 

pollutants are, respectively, sulfur dioxide and nitrogen oxides. Because of the differences 

between conditions that lead to high sulfate and high nitrate conditions, the areas of influence for 

sulfur dioxide and nitrogen oxides are substantially different for several Class I areas that Texas 

emissions affect. 

The TCEQ used the control strategy analysis completed by the CENRAP as the starting point for 

the analysis of additional controls. The CENRAP’s CENRAP analysis used the EPA’s Air 

Control NetEPA AirControlNET tool to develop cost per ton estimates for the relevant pollutants. 

The TCEQ reviewed this information and made changes based on knowledge of the particular 

facilities and agency experience with implementing ozone control strategies. The analysis 

focused on moderate cost controls for sources that were likely to contribute to visibility 

impairment at Class I areas. This work resulted in an estimate of the 
10-5 

Texas assessed the costs and possible benefits of additional of potential controls, as shown in the 

following Tables 10-4 and 10-5. and reductions for Texas sources at ten Class I areas. These are 

Big Bend, Breton Island, Caney Creek, Carlsbad Caverns, Guadalupe Mountains, Salt Creek, 

Upper Buffalo, Wheeler Peak, White Mountain, and Wichita Mountains. Texas used the second 

level area of influence for each Class I area to determine sources that met the emissions over 

distance threshold and were within that Class I area’s AOI. The cost associated with potential 

controls for each Class I area are listed in Table 10-4: Cost of Controls for Class I Areas. The 

TCEQ’ssignificant point sources within each AOI are in Appendix 4-3: Additional Consultation 

Letters to Adjacent States. A master list of potential additional control costs associated with these 

units for each Class I area were determined and are in Appendix 10-1. 

Table 10-4: Cost of Controls for Class I Areas 

Class 1 Big Bend Breton Isle Caney Creek Carlsbad 

Caverns 

Guadalupe 

Mountains 

NOx $ 24,100,000 $ 27,000,000 $ 28,600,000 $ 24,100,000 $ 33,800,000 

SO2 $215,900,000 $231,000,000 $245,900,000 $255,500,000 $254,900,000 

Class 1 Salt Creek Upper Buffalo Wheeler Peak White 

Mountain 

Wichita 

Mountains 

NOx $ 27,000,000 $ 24,100,000 $ 22,700,000 $ 23,000,000 $ 28,100,000 

SO2 $251,900,000 $233,800,000 $229,500,000 $244,500,000 $269,500,000 

Many of these controls are in more than one area of influence. The total cost of all state-wide 

point source controls are summarized in Table 5: TCEQ Point Source Control Strategy 

Summary. 

Table 10-5: TCEQ Point Source Control Strategy Summary 

The TCEQ used the CENRAP modeling to estimate the impact that the control strategy would 

have on the Class I areas impacted by Texas’ emissions. The CENRAP conducted a modeling 

analysis presuming an aggressive set of additional controls above and beyond CAIR and BART 

Texas used the results of this modeling analysis to determine an effectiveness ratio for NOx and 

SO2 reductions. The effectiveness ratio provides an estimate of improvement in visibility for 

every ton of NOX and SO2 reduced. Using these ratios, the TCEQ was able to develop an orderof-magnitude estimate of the likely visibility improvements resulting from the point source 

control strategy (see Table 10-6: Estimated Haze Index Improvements for Affected Class I 

Areas). This full analysis can be found in Appendix 10-2: Estimating Visibility Impacts from 

Additional Point Source Controls and in Appendix 10-4: Detailed Calculations for Estimating 

Visibility Impacts. Table 10-5 shows the results. 

Pollutant Tons Per Year 

(tpy) Reduced Estimated Cost 

Sulfur Dioxide (SO2) 155,873 $270,800,000

Nitrogen Oxides (NOX) 27,132 $53,500,000

Total Costs $324,300,000

Deleted: . 
10-6 

Table 10-5: Estimated Visibility Improvement

Table 10-6: Estimated Haze Index Improvements for Affected Class I Areas 

Class 1 Big Bend Breton Isle Caney Creek Carlsbad 

Caverns 

Guadalupe 

Mountains 

Haze Index 

Improvement 

(dv) 0.16 0.05 0.33 0.22 0.22 

Class 1 Salt Creek Upper 

Buffalo Wheeler Peak White Mountain 

Wichita 

Mountains 

Haze Index 

Improvement 

(dv) 0.18 0.16 0.04 0.24 0.36 

As Tables 10-5 and 10-6: Estimated Haze Index Improvements for Affected Class I Areas show, 

the analysis identified controls costing well over $300 million, yet the projected benefit of those 

controls on each Class I is negligiblenot perceptible. A single (1.0) deciview is the smallest 

perceptible improvement in visibility. In the TCEQ’s Best Available Retrofit Technology 

(BART) rule, the state considered 0.5 deciviewdeciviews as the threshold under which a facility 

was not considered to meaningfully contribute to visibility impairment. An A difference 

improvement of 0.05 deciviewdeciviews is well within the uncertainty of the modeling 

techniques and is much lower than perceptible. This improvement did not justify the substantial 

expense.

10.4 FOUR FACTOR ANALYSIS 

The Federal Regional Haze Rule requires states to set reasonable progress goals (RPGs) toward 

meeting a national goal of natural visibility conditions in Class I areas by the year 2064. The first 

RPG is to be established for the planning period 2008 to 2018. The State of Texas worked with 

CENRAP to develop RPGs for Texas Class I areas. 

The Federal Regional Haze Rule (§51.308(d)(1)(i)(A)) requires states to consider the factors 

listed in section 169A(g)(1) of the FCAA when setting reasonable progress goals. These factors 

are the cost of compliance, the time for compliance, the energy and non-air quality impacts of 

compliance, and the remaining useful life of any potentially affected sources (EPA 1999). 

• Cost of Compliance 

The cost of compliance is a factor used to determine whether compliance costs for 

sources are reasonable compared to the emission reduction and visibility improvement 

they will achieve. 

• Time Necessary for Compliance 

The time necessary for compliance factor may be used to adjust the reasonable progress 

goals to reflect the degree of improvement achievable within the first planning period, as 

opposed to the improvement expected at full implementation of a control measure. 

• Energy and Non-Air Quality Environmental Impacts of Compliance 

The energy and non-air quality environmental impacts of compliance factor is meant to 

consider whether the energy requirements of the control technology result in energy 

Class I Area Improvement

(dv)

Big Bend 0.05

Guadalupe Mountains 0.05

Deleted: 4 

Deleted: 5 

Deleted: Page Break

Deleted: 3
10-7 

penalties or benefits, or whether there are non-air quality impacts such as water quality 

and solid waste impacts resulting from the technology. 

• Remaining Useful Life of the Source 

The remaining useful life of the source factor is applicable only to those measures which 

would require retrofitting of control devices (or possibly production changes) at existing 

sources. Shutdowns of sources were only counted if the shutdowns were enforceable. 
10-8 

10.4.1 Applying the Statutory Factors 

Because the pollutants of primary concern were determined to be SO2 and NOX from point 

sources, the 2018 emissions inventory was assessed to determine the sources that would have the 

most impact on Class I areas from these pollutants. All units in the inventory were assessed. An 

emissions over distance to any Class I area analysis ratio with a threshold of five or greater 

(Q/d≥5 in tpy/kilometers) was applied to the projected 2018 emissions for both SO2 and NOX to 

eliminate sources so far away from a Class I area that any reduction in emissions would be 

unlikely to have a perceptible impact on visibility. Also, any source with predicted 2018 

emissions less than 100 tpy was excluded, since the regulatory and logistical overhead associated 

with controlling these small sources would not be justified by the likely benefit. 

The TCEQ also excluded additional NOX controls on cement kilns from consideration since 

Texas has already required all the measures determined to be reasonable to control NOX emission 

from these sources in the latest Dallas-Fort Worth ozone SIP revision. See Appendix 10-1: 

Analysis of Control Strategies and Determination of Reasonable Progress Goals for further 

discussion of Texas cement kilns. 

Determination of Proposed Controls 

The 2018 inventory included the on-the-books controls for each of the states in the CENRAP 

region. The list of proposed controls is for controls beyond those already included in the baseline 

level used in the modeling. This is necessary to provide a frame of reference to estimate the 

amount of emissions available for additional control and estimate the effect of control measures. 

Additionally, the progress toward the RPG with only on-the-books controls can also be assessed. 

CENRAP used the latest revised version of the EPA AirControlNET model (Alpine 2007) to 

analyze potential add-on control device strategies. AirControlNET is a control technology 

analysis tool developed to support the EPA in analyses of air pollution policies and regulations. 

The tool provides data on emission sources, potential pollution control measures and emission 

reductions, and the costs of implementing those controls. Every available SO2 and NOX control 

strategy in AirControlNET was run against the electric generating units (EGUs) and non-EGU 

point source inventories to develop a master list of available incremental control strategies for the 

entire CENRAP 36 kilometer domain. 

Texas reviewed the resulting data curves and some additional individual sources were selected 

from source-types that were not part of the CENRAP AirControlNET dataset. The analyses of 

these facilities were designed to ensure that opportunities for cost-effective visibility 

improvements were not overlooked. The first step in the technical evaluation of control measures 

for a source category was to establish the future emissions baseline with on-the-books 

regulations. This baseline was used to assess the potential emissions reductions with the 

proposed control. The TCEQ added flue gas desulfurization at nine carbon black units based on 

this analysis. 

10.4.2 Four Factor Analysis Process 

Cost of Compliance 

At a total estimated cost exceeding $300 million and no perceptible visibility benefit, Texas has 

determined that it is not reasonable to implement additional controls at this time. All units in 

Texas that met the emissions over distance threshold were assessed. The cost per ton of controls 

from EPA CAIR and existing TCEQ control programs were used as a threshold value for 

determining a proposed set of controls. The EPA estimated the cost of implementing CAIR was 

up to $2,700 per ton. This limiting threshold was used to limit the proposed controls group to 

cost effective measures. The annualized cost values, additional emissions reductions based on 

proposed efficiency, as listed in the AirControlNET files, were used. Modifications for Texas 

included the consideration of flue gas desulfurization for carbon black units. 
10-9 

Time Necessary for Compliance 

The time necessary for compliance was not a critical factor for the determination of applicable 

additional controls for Texas sources. The focus of the time necessary for compliance analysis 

for on-the-books controls will be to quantify the magnitude of emissions reductions that will 

occur prior to 2018. The EPA in its CAIR regulatory impact statement estimated that 

approximately 30 months is required to design, build, and install SO2 scrubbing technology for a 

single EGU boiler. The total time for a single facility to comply with one of the NOX caps would 

be about five years. Shortage of skilled labor as a result of increased design and construction of 

pollution control units required to meet deadlines in CAIR or its eventual replacement could 

increase times for some construction but completion by 2018 would still be anticipated. 

For mobile sources, MOBILE and NONROAD model runs were completed for the 2018 

emissions inventory. These model runs incorporate the degree of fleet and expected engine 

replacement prior to 2018. The completion of other proposed controls are anticipated by 2018. 

Energy and Non-Air Quality Environmental Impacts of Compliance 

To the extent energy impacts are quantifiable for a particular control, they have been included in 

the cost estimates. Including impacts on a source-by-source basis would have added further 

weight against finding that the potential additional controls were reasonable to apply.

Scrubbers, Selective Catalytic Reduction (SCR) systems, and Selective Non-Catalytic Reduction 

(SNCR) systems installed under the EGU control strategies would require electricity to operate 

fans and other ancillary equipment. In addition, steam would be required for some scrubbers and 

SCR systems. Additional fuel will be consumed at the utilities to produce this electricity and 

steam, resulting in the lowering of the energy efficiency of the plant. Estimates have given the 

electricity and steam required by controls installed to meet SO2 and NOX emission caps would be 

less than 1 percent of the total electricity and steam production of EGUs (EPA 1999). 

Source-by-source review of the non-air quality impacts of the potential controls would possibly 

have lead to a different determination about the unreasonableness of the set of potential additional 

controls. Scrubbers, coal washing, and spray dryers will require additional safeguards for fuel 

handling and waste handling systems to avoid additional non-air environmental impacts such as 

increased effluents in waste water discharges and storm water runoff. Solid waste disposal and 

wastewater treatment costs are expected to be less than five percent of the total operating costs of 

pollution control equipment. These factors will need to be considered specific to individual 

sources. 

Pilot testing of SNCR on wet and dry kilns in 2006 demonstrated that 30 to 40 percent reductions 

were achievable without hazardous by-product formation. In July 2006, ERG submitted a report 

to TCEQ entitled Assessment of NOX Emissions Reduction Strategies for Cement Kilns - Ellis 

County: Final Report (ERG 2006). 

Some low-NOX combustion technologies require electricity for turbo charging, or steam for steam 

injection. Systems that require only modifications to alter fuel-air mixing and combustion 

temperatures are not expected to produce any additional electricity or steam demands, or generate 

wastewater or solid waste. 

Remaining Useful life 

CENRAP considered remaining useful life in modeling for mobile sources that assumes reduced 

emissions per vehicle mile traveled due to the turnover of the on-road mobile source fleet. For 

sources with a relatively short remaining useful life, this consideration would have weighed more 

heavily against a determination that controlling those sources would have been reasonable. In 

general, this factor is not critical for sector analyses for the 2018 timeline. For the purposes of 
10-10 

initial analyses, no limited useful equipment life was assumed. A site-specific analysis would be 

needed to determine any units with limited useful life. Only units that were scheduled for 

shutdown under enforceable decrees were eliminated from the 2018 inventory and further 

analysis. 

10.5 UNCERTAINTY IN THE REASONABLE PROGRESS GOALS 

The majority of the emissions reductions underlying the predicted visibility improvements are 

from the CAIR program or its eventual replacement. The TCEQ presumes that any eventual 

replacement for CAIR will include interstate trading of emissions allowances. Although CAIR or 

its replacement program requires should result in substantial reductions in SO2 and NOX

emissions from electric generating units (EGUs). There, there is uncertainty regarding how 

CAIR will improve visibility will be improved at individual Class I areas because the CAIR 

program allows of trading of emissions allowances. The program will reduce visibility-impairing 

emissions across the entire eastern half of the United States, including Texas and Minnesota. 

Because emission allowances can be purchased by EGUs relatively close to the Texas Class I 

areas from EGUs far from the Texas Class I areas, the visibility improvement may not be as great 

as predicted by the CENRAP’s modeling. Conversely, nearby EGUs may elect to control beyond 

their emission caps and sell emission allowances out of state, resulting in reduced emissions 

closer to the Texas Class I areas. 

The CENRAP used the Integrated Planning Model (IPM) that the EPA employed to predict the 

emissions reductions expected from CAIR in 2018. This SIP revision presumes that those results 

would be comparable under any program to replace CAIR. The IPM model predicts the effect of 

emission trading programs considering economics, logistics, and the specific regulatory 

environment for each EGU. Table 10-7: Comparison of Sulfur Dioxide Emissions compares 

current emissions of SO2 to the CAIR caps and the IPM results for the 2018 planning year. 

Table 10-7: Comparison of Sulfur Dioxide Emissions 

Sources: EPA, CENRAP 

*Rounded to the nearest thousand 

The CAIR cap is the total allowable emissions of SO2 from EGUs in Texas under CAIR. The 

IPM model analysis used by CENRAP predicts that by 2018 EGUs in Texas will purchase 

approximately 125,000 tons per yeartpy of emissions allowances from out of state. The TCEQ 

requested that key EGUs in Texas review and comment on the predictions of the IPM model. 

However, no EGU was able to makemade an enforceable commitment to any particular pollution 

control strategy and preferred to retain the flexibility offered by the CAIR program. 

The potential overprediction of EGU emissions on Class I areas by the IPM model analysis. This 

uncertainty in the impact of the CAIR program is one reason why the agency has elected not to 

pursue additional controls at this time. In the five-year periodic progress report required by 40 

CFR §51.308(g), the TCEQ will plans to review emissions inventory and permit information to 

evaluate the accuracy of the predicted emissions used in the CENRAP modeling. 

SO2 Emissions Texas SO2

Emissions (tpy)* 

Current (2002 base case) 550,000 

EPA’s CAIR budget for Texas EGUs for 2015 225,000 

IPM projection CENRAP modeled for 2018 350,000 

Deleted: 6

Deleted: 6

Deleted: .
10-11 

10.6 INTERNATIONAL SOURCES OF VISIBILITY IMPAIRMENT 

The Texas Class I areas are close to Mexico, and international transport of emissions from 

Mexico and Central America significantly influence regional haze at these areas. The CENRAP 

conducted a particulate source apportionmentParticulate Matter Source Apportionment 

Technology (PSAT) analysis on the modeling conducted for the 2018 projections. The PSAT 

modeling apportioned all the particulate pollutant contributions to extinction except for secondary 

organic aerosol. The pollutants apportioned by geographic areas are sulfate, nitrate, primary 

organic carbon, elemental carbon, fine soil, and coarse mass. Table 10-8: Contributions to 

Visibility in the Texas Class I Areas on Worst 20 Percent Day summarizes the contribution from 

these areas to visibility impairment at the Texas Class I areas. 

Table 10-8: Contributions to Visibility in the Texas Class I Areas on Worst 20 Percent 

Days 

Boundary conditions are the conditions at the model’s geographic boundaries. These are 

visibility-impairing emissions from Central Mexico and further south into Central America. The 

analysis indicates that 52 percent of the impairment at Big Bend and 25 percent of the impairment 

at Guadalupe Mountains is from Mexico and further south. The national goal of natural visibility 

at these Class I areas cannot be met without substantial reductions in emissions from outside of 

the United States. 

10.7 REDUCTIONS REQUIRED TO MEET THE UNIFORM RATE OF PROGRESS 

The TCEQ’s analysis of point source reductions can be extrapolated to estimate the amount of 

reductions that would be required for the RPG to meet the URP for the Texas Class I areas. 

Table 10-9: Emissions Reductions Required to Meet Uniform Rate of Progress 

Class I Area 

Additional 

Improvement 

Needed to Meet URP

(dv) 

Approximate 

Additional Pollutant 

Reductions 

SO2 and NOX (tpy) 

Estimated Cost of 

Additional 

Reductions 

Big Bend 1.0 3,700,000 $6,500,000,000 

Guadalupe Mountains 0.3 1,100,000 $1,900,000,000 

Contribution by Area Big Bend 

(%) 

Guadalupe 

Mountains 

(%) 

Texas 24.8 34.8

Mexico 26.7 16.5

Boundary Conditions 25.7 8.7

Other US 11.9 18.9

Miscellaneous 5.8 9.6

Neighboring States 5.1 11.5

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Deleted: 7

Deleted: Page Break

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Deleted: )

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Deleted: 8

Deleted: 
10-12 

Table 10-9: Emissions Reductions Required to Meet Uniform Rate of Progress assumes that all 

of the reductions needed to meet the URP would come from Texas. These additional reductions 

would require significant over-control in order to compensate for the impacts of international 

pollution. The preamble to the July 1, 1999, issuance of the Regional Haze Rule clearly says that 

states are not required to carry out compensatory over-control to make up for the lack of progress 

in reducing the impacts of international transport. 

Table 10-9 illustrates that to meet the goal of natural visibility at Big Bend a better understanding 

of how pollutants are brought into the area is needed so that the correct sources can be addressed. 

This also reinforces the point that progress at the Texas Class I areas, especially at Big Bend, is 

dependent upon reducing emissions from Mexico and Central America. In Chapter 11: LongTerm Strategy to Reach Reasonable Progress Goals, the TCEQ specifically asks the EPA for 

federal efforts to reduce the international transport impacts on regional haze coming into the 

United States across Texas’ southern border. 

Given the significant impact from international emissions, the uncertainty in the impact of CAIR 

and the poor cost-effectiveness of additional, reasonable point source controls, the TCEQ has 

determined that additional controls for Regional Hazeregional haze are not appropriate at this 

time. 

10.8 CONSULTATION 

In determining a reasonable progress rate for each Class I area discussed previously, the TCEQ 

has consulted with the other states and tribes that are reasonably anticipated to cause or contribute 

to visibility impairment in each of the Texas Class I areas. Similarly, the TCEQ has consulted 

with other states whose Class I areas are impacted by pollution sources in Texas. The TCEQ 

invited tribes in the CENRAP states to the consultation calls, but no tribes participated in the 

consultation on Big Bend and Guadalupe Mountains. A full description of the consultation 

process is in Chapter 4: State, Tribe, and Federal Land Manager Consultation. 

10.9 REPORTING 

The TCEQ will report progress to the EPA Administrator every five years in accordance with 40 

CFR §51.308(g). Chapter 12: Comprehensive Periodic Implementation Plan Revisions and 

Adequacy of the Existing Plan, provides more detail on five-year reporting and ten-year SIP 

submittal requirements. 

Deleted: 8 

Deleted: 8

Deleted: ,

Deleted: 6 

Deleted: 7

Deleted: ¶
11-1 

CHAPTER 11. LONG-TERM STRATEGY TO REACH 

REASONABLE PROGRESS GOALS 

11.1 INTRODUCTION 

The long-term strategy for the Regional Haze SIP revision incorporates planning for the next ten 

years, from 2008 through 2018. Title 40 CFR §51.308.308(d)(3) specifies the requirements for 

the long-term strategy for regional haze (Appendix 1-1). 

The main anthropogenic emissions that affect visibility in Class I areas in Texas and neighboring 

states are SO2 and NOX. There is a much smaller anthropogenic PM impact in Texas from stack, 

engine exhaust, and fine soil emissions compared to SO2 and NOX. Although the contribution of 

anthropogenic VOC to the formation of secondary organic carbon PM is small, there is a 

contribution. The impact of coarse mass and fine soil at the two Texas Class I areas comes 

primarily from natural dust storms and dust blowing from the Chihuahuan Desert, which the 

modeling does not represent well. Chapter 5: Assessment of Baseline and Current Conditions 

and Estimate of Natural Conditions in Class I Areas discusses and documents the predominance 

of these natural impacts. The modeled impact of wild fire and prescribed burning emissions on 

primary organic carbon is uncertain because of questions about the accuracy of fire emission 

inventories. However, the modeled projections show that fires are the main source of the 

impacts. 

The bar Bar charts in Chapter 11this chapter show the modeledapportioned impact of different 

areas and pollutants to visibility impairment at Big Bend and other Guadalupe Mountains 

National Parks and at the Class I areas Texas emissions impact in other states (Figures 11-2

through 11-31). There are separate graphs to show the impacts of different source areas on the 

worst 20 percent of monitored days and on the best 20 percent of monitored days in 2002. The 

projected impact apportioned impacts shown in the figures use the modeling results scaled to 

measured pollutant concentrations according to the EPA’s modeling guidelines as detailed in 

Chapter 8: Modeling Assessment. As Chapter 5 explains, the projections for 2018 set the relative 

response factors (RRFs) for coarse mass (dust) and fine soil equal to one based on analysis 

showing that dust storms and wind blown desert dust are the dominant cause of the coarse mass 

and fine soil pollution at Big Bend and Guadalupe Mountains National Parks. Since the dominant 

source of these pollutants is natural, the TCEQ does not expect that to change between the base 

period and 2018. 

The primary organic carbon and elemental carbon (i.e., black carbon) captured in the modeling is 

are largely from fire. The term “primary” refers to a pollutant emitted directly to the atmosphere. 

The term “secondary” refers to a pollutant formed in the atmosphere by reaction, condensation, or 

both. The modeling indicates that primary organic carbon and black carbon at Big Bend comes 

on the worst 20 percent days come overwhelmingly from boundary conditions, which include the 

areas of southern Mexico, the Yucatan, and Central America with extensive agricultural burning 

and sometimes wildfire emissions each April and May. 

The haze pollutants listedshown in the figuresbar graphs and tables include: sulfate (SO4), nitrate 

(NO3), primary organic aerosols (POA), elemental carbon (EC), other inorganic fine particulate 

(Soilsoil), coarse mass (CM), anthropogenic secondary organic aerosols anthropogenic (SOAA) 

that are , which result from human-made activity, and biogenic secondary organic aerosols 

biogenic (SOAB) that come from plants), which form from hydrocarbon emissions from 

vegetation. Initial conditions (IC) and boundary conditions (BC) are areas related to the domain 

map; initial conditions are the assumed initial three-dimensional concentrations throughout the 

modeling domain, and boundary. Except on the first few days of the model runs, the contribution 

of initial conditions is vanishingly small. Boundary conditions (BC) are the concentrations 

assumedimported into the modeling domain along the lateral edges and the top of the CENRAP 

Deleted: s

Deleted: ’s
11-2 

modeling domain. These boundary conditions come from a year-long run of the global model 

GEOS-Chem. 

Figures 11-2 through 11-31 also make referencerefer to extinction (abbreviated as Bext) and 

Rayleigh. In the case of visibility, extinction or Bext refers to the loss of image-forming light as it 

passes from an object to the observer. Rayleigh scattering is the scattering of light by air 

molecules (Malm 1999). Figure 11-1 compares extinction to deciviews (dv) and visual range (in 

kilometers). 

Source: William Malm, Introduction to Visibility, 1999, National Park Service 

Figure 11-1: Comparison of Extinction, Deciviews and Visual Range 

Figure 11-2: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE) 

Note: On the worst on Worst 20 percent of daysPercent Days in 2002 

Deleted: 10
11-3 

Figure 11-3: Areas and Pollutants Causing Regional Haze at Big Bend (BIBE) on Best 20 

Percent Days in 2002 

Note the change in scale on the y-axis. 
11-4 

Table 11-1: Pollutant Contributions to Extinction at Big Bend from Texas and from All Areas on 

Worst 20 Percent Days in 2002 and 2018 

Texas Total Total, All 

Source Areas Texas Total Total, All Source Areas

Sulfate 5.50 26.10 3.95 23.00

Nitrate 0.59 2.05 0.56 1.99

Primary Organic Aerosol 0.55 5.81 0.41 5.61

Elemental Carbon 0.42 2.12 0.20 1.81

Fine Soil 0.99 2.54 0.98 2.54

Coarse Mass 3.82 7.03 3.87 7.03

Secondary Organic 

Aerosol, Anthropogenic not available1 0.64 not available1 0.59

Secondary Organic 

Aerosol, Biogenic not available1 1.52 not available1 1.49

Total 11.87 47.79 9.97 44.06

2002 Impacts at Big Bend

(inverse megameters)

2018 Impacts at Big Bend

 Particulate Matter (inverse megameters)

Constituent

1

 The CENRAP PSAT modeling did not apportion either the anthropogenic or the biogenic secondary 

organic aerosol (SOA). The reasons are (1) that sulfate and nitrate are generally the main causes of 

visibility impairment resulting from human activity and (2) that tracking the multiple volatile organic 

compound constituents and reaction products necessary to apportion SOA would have extended the 

modeling run times far beyond the time that was available for the modeling. 
11-5 

Figure 11-4: Areas and Pollutants Causing Regional Haze at Guadalupe Mountains 

(GUMO) on the Worst 20 Percent Days in 2002

Figure 11-5: Areas and Pollutants Causing Regional Haze at Guadalupe Mountains 

(GUMO) on Best 20 Percent Days in 2002 

Note: On the worst 20 percent of days 2002 the change on the y-axis.
11-6 

Table 11-2: Pollutant Contributions to Extinction at Guadalupe Mountains from Texas and 

from All Areas on Worst 20 Percent Days in 2002 and 2018 

Texas Total Total, All 

Source Areas Texas Total Total, All Source Areas

Sulfate 4.28 15.94 3.65 13.65

Nitrate 0.78 3.67 0.68 3.32

Primary Organic Aerosol 1.16 2.75 0.87 2.38

Elemental Carbon 0.53 1.19 0.28 0.86

Fine Soil 1.71 4.37 1.66 4.37

Coarse Mass 8.16 16.04 8.19 16.02

Secondary Organic 

Aerosol, Anthropogenic not available1 1.23 not available1 1.16

Secondary Organic 

Aerosol, Biogenic not available1 2.61 not available1 2.56

Total 16.62 47.80 15.33 44.32

2002 Impacts at

Guadalupe Mountains

(inverse megameters)

2018 Impacts at

Guadalupe Mountains

(inverse megameters) Particulate Matter 

Constituent

11.1.1 Reasonably Attributable Visibility Impairment 

Reasonably attributable visibility impairment (RAVI) is a specifically defined term from EPA’s 

early efforts to protect visibility at Class I areas. Limitations in RAVI requirements for 

improving visibility at many Class I areas led to provisions in the 1990 Clean Air Act 

Amendments that added the broader requirements for to reduce regional haze impacts at Class I 

areas. The EPA implemented these provisions in the Regional Haze Regulations first issued July 

1, 1999. 

The FLMs for Big Bend and Guadalupe Mountains National Parks have not identified any 

reasonably attributable visibility impairment from Texas or other United States sources. The 

FLMs for the Class I areas that Texas’ emissions impact in other states have not identified any 

reasonably attributable visibility impairment caused by Texas sources. For these reasons, the 

TCEQ does not have any measures in place or plansa requirement to address reasonably 

attributable visibility impairment. 

11.2 CONSULTATION 

The TCEQ has participated in the CENRAP since its inception in 1999 and has provided 

emission inventory information for all source categories. The TCEQ has cooperated with all 

CENRAP states and tribes through participation in the process of developing information on base 

period emission inventories and visibility impairment, estimates of 2064 natural conditions, and 

projections of 2018 emissions and visibility impairment considering all emission reduction 

requirements in Texas, including state and federal rules. These rules include the Clean Air 

Interstate Rule (CAIR), BART requirements, emission reductions from the Federal Motor 

Vehicle Emission Control Program (FMVCP), EPA refinery consent decrees, and EPA 

requirements for cleaner non-road diesel and gasoline-powered engines. Detailed information on 

consultation is in Chapter 3: Regional Planning and Chapter 4: State, Tribe, and Federal Land 
11-7 

Manager Consultation. Information on base period emissions inventory development is in 

Chapter 7: Emissions Inventory, and information on modeling is in Chapter 8: Modeling 

Assessment. 

11.2.1 Consultation on Class I Areas in Texas 

The TCEQ used CENRAP Particulate Matter Source Apportionment Technology (PSAT) 

modeling to determine that Kansas, Louisiana, New Mexico, and Oklahoma contribute to the 

states contributing to visibility impairment at Texas’ Class I areas. Since each state is considering 

which additional are Kansas, Louisiana, New Mexico, and Oklahoma. Each of these states has 

adopted or is in the process of adopting emissions reductions are it has determined to be 

reasonable under the factors listed in 40 CFR §51.308(d)(1), Reasonable Progress Goals. Based 

on their plans and commitments elicited through the consultation process, the commission has 

made a preliminary determination determined that the emissions reductions that these states are 

projecting are reasonable for contributing to reasonable progress in reducing their contributions to 

visibility impairment at Texas’ the two Class I areas. Arkansas and Missouri have completed 

their consultation with Texas regarding the impact of Texas’ emission and regional haze impact 

reductions on Arkansas’ and Missouri’s Class I areas. They have accepted the TCEQ’s planned 

emission reductions as adequate for their Class I areas. in Texas has consulted with Oklahoma 

regarding Oklahoma’s Class I area, the Wichita Mountains National Wildlife Refuge. Oklahoma 

consultation conference calls were held August 16, 30, and September 25, 2007. The TCEQ has 

communicated with New Mexico, Louisiana, and Colorado about consultation on the impact of 

Texas’ emissions on each states Class I areas. However, at this time, these three states have not 

invited Texas to a formal consultation regarding any of their respective Class I areas. Chapter 4 

discusses consultations with these states in detail. 

11.2.2 Consultation on Class I Areas Impacted by Emissions from Texas 

Arkansas, Missouri, and Oklahoma have each included Texas in consultations concerning 

regional haze impacts on the Class I areas in these states. The TCEQ reviewed CENRAP PSAT 

modeling to assess how Texas’ emissions might affect other statesstates’ Class I areas. Pursuant 

to this review, Texas has written to Arkansas, Missouri, and Oklahoma have included Texas in 

consultations concerning emissions. In the future, New Mexico, Oklahoma, New Mexico, 

Louisiana, and Colorado to ask whether emission reductions projected in Texas by 2018 are 

sufficient to meet Texas’ apportionment of the impact reduction needed to meet the reasonable 

progress goal for each Class I area in each state. Texas has completed its consultation with 

Louisiana, Arkansas, Missouri, Oklahoma, and Colorado are expected to consult with TCEQ on , 

and none of these states has asked Texas for further emission reductions to help the state meet its 

reasonable progress goals for its Class I area(s). Chapter 4 discusses these consultations in more 

detail. Appendix 4-3 contains the official communications from these states to Texas. 

11.2.3 Texas’ Impacts and 2018 Impact Reduction for Class I Areas Outside Texas 

The TCEQ’s review of the CENRAP PSAT modeling results to assess how Texas’ emissions 

might affect other states’ Class I areas in 2002 indicated that Texas’ emissions affect one or more 

Class I areas in New Mexico, Oklahoma, Colorado, Arkansas, Missouri, and Louisiana. This 

subsection presents the results of this review.

11.2.3.1 New Mexico 

Emissions from the western portion of Texas account for most of Texas’ impact on the Class I 

areas in New Mexico. The following graph shows the impacts of the western portion of Texas on 

their Class I areas in New Mexico that are included in the CENRAP PSAT modeling. The graph 

provides the basis for choosing the New Mexico Class I areas for more detailed examination of 

Texas’ impacts. Carlsbad Caverns National Park is not included in this graph since it has no 

regional haze monitor; instead, it uses data measured at Guadalupe Mountains National Park to 

assess the impact of regional haze on the park. 

Deleted: . 

Deleted: . ¶

Deleted: ¶

Figure 11-4: Calculated
11-8 

On February 13, 2008, the TCEQ approved the renewal of Air Quality Permit Number 20345 for

the American Smelting and Refining Company (ASARCO) El Paso copper smelter. On February 

6, 2009, the TCEQ received confirmation from ASARCO LLC that it intends to close the smelter

and requests that TCEQ void all air permits and pending applications for the plant. The TCEQ 

voided these permits and applications on February 9, 2009 (See Appendix 11-4: ASARCO El 

Paso). The TCEQ will continue to consult with affected states and Federal Land Managers on 

surrounding Class I areas of concern.

On February 13, 2008, the TCEQ approved the renewal of Air Quality Permit Number 20345 for 

the American Smelting and Refining Company (ASARCO) El Paso smelter. As of the date this 

SIP revision was finalized, the TCEQ has not yet made a final determination regarding the BART 

status of ASARCO’s facilities. Due to this and other permitting and operational readiness issues 

raised by ASARCO in their status report required by TCEQ order, there is uncertainty about the 

amount of allowable emissions the ASARCO El Paso facility would have should it begin 

operation. Because of this uncertainty in addition to time limitations, it is not possible for the 

TCEQ to account for possible future ASARCO El Paso emissions in this Regional Haze SIP 

revision. When the TCEQ has determined the allowable emissions from the ASARCO El Paso 

facility, the TCEQ will model the visibility impacts of these emissions at affected Class I areas. 

The TCEQ plans to consult with affected states and Federal Land Managers and include 

ASARCO’s emissions and impacts in its next Regional Haze SIP revision.

Figure 11-6: Calculated Regional Haze Impacts of West Texas Emissions from Western 

Areas of Texas at Each Class I Area in New Mexico 

Note: On the worston Worst 20 percent of days 2002Percent Days in 2002 

BANDBAND1 - Bandelier Wilderness AreaNational Monument

BOAPBOAP1 - Bosque del Apache Wilderness Area 

GICLGICL1 - Gila Wilderness Area 

SACRSACR1 - Salt Creek Wilderness Area 

SAPESAPE1 - San Pedro Parks Wilderness Area 

WHITWHIT1 - White Mountain Wilderness Area 

WHPEWHPE1 - Wheeler Peak Wilderness Area
11-9 

Figure 11-7: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns National 

Park on Worst 20 Percent Days in 2002 

Note: The impacts at Carlsbad Caverns National Park are calculated using the CENRAP PSAT tool for 

Guadalupe Mountains but using the EPA guidance for applying relative response factors (RRFs) since New 

Mexico is using modeled apportionment of coarse mass (CM) and fine soil (FS). These calculations do not 

use the Texas assumptions for Guadalupe Mountains and Big Bend National Parks that the RRFs for CM 

and FS both equal one. 

Deleted: 5
11-10 

Figure 11-8: Areas and Pollutants Causing Regional Haze at Carlsbad Caverns National 

Park on Best 20 Percent Days in 2002 

Note the change on the y-axis. 

Table 11-3: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Carlsbad Caverns National Park on Worst 20 Percent Days 

Texas Total Total, All Source 

Areas Texas Total Total, All Source 

Areas

Sulfate 4.28 15.94 3.65 13.65

Nitrate 0.78 3.67 0.68 3.32

Primary Organic Aerosol 1.16 2.75 0.87 2.38

Elemental Carbon 0.53 1.19 0.28 0.86

Fine Soil 1.71 4.37 1.66 4.37

Coarse Mass 8.16 16.04 8.24 16.13

Secondary Organic Aerosol, 

Anthropogenic not available1 1.23 not available1 1.16

Secondary Organic Aerosol, 

Biogenic not available1 2.61 not available1 2.56

Total 16.62 47.80 15.39 44.43

 Particulate Matter 

Constituent

2002 Impacts at Carlsbad Caverns2

(inverse megameters)

2018 Impacts at Carlsbad Caverns2

(inverse megameters)

1

 The CENRAP PSAT modeling did not apportion either the anthropogenic or the biogenic secondary 

organic aerosol (SOA). The reasons are (1) that sulfate and nitrate are generally the main causes of 

visibility impairment resulting from human activity and (2) that tracking the multiple volatile organic 

compound constituents and reaction products necessary to apportion SOA would have extended the 

modeling run times far beyond the time that was available for the modeling. 
11-11 

Figure 11-9: Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) in New 

Mexico on Worst 20 Percent Days in 2002 

Figure 11-10: Areas and Pollutants Causing Regional Haze at Salt Creek (SACR) in New 

Mexico on Best 20 Percent Days in 2002 

Note: On the worst 20 percent of dayschange in scale on the y-axis.
11-12 

Table 11-4: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Salt Creek Wilderness Area on Worst 20 Percent Days

Texas Total Total, All 

Source Areas Texas Total Total, All 

Source Areas

Sulfate 4.79 16.75 3.50 13.75

Nitrate 3.05 11.15 2.43 9.81

Primary Organic Aerosol 1.17 4.31 0.69 2.99

Elemental Carbon 0.76 2.31 0.30 1.23

Fine Soil 1.06 3.34 0.96 3.41

Coarse Mass 2.58 11.47 2.36 12.52

Secondary Organic 

Aerosol, Anthropogenic not available1 1.12 not available1 1.00

Secondary Organic 

Aerosol, Biogenic not available1 2.06 not available1 1.95

Total 13.41 52.50 10.24 46.67

 Particulate Matter 

Constituent

2002 Impacts at Salt Creek

(inverse megameters)

2018 Impacts at Salt Creek

(inverse megameters)

Figure 11-11: Areas and Pollutants Causing Regional Haze at White Mountain (WHIT) in 

New Mexico on Worst 20 Percent Days in 2002 

Deleted: 
11-13 

Figure 11-12: Areas and Pollutants Causing Regional Haze at White Mountain (WHIT) in 

New Mexico on Best 20 Percent Days in 2002 

Note the change in scale on the y-axis. 

Table 11-5: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at White Mountain Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All 

Source Areas Texas Total Total, All 

Source Areas

Sulfate 2.78 10.51 2.37 8.92

Nitrate 0.53 3.05 0.47 2.68

Primary Organic Aerosol 1.14 3.87 0.78 3.13

Elemental Carbon 0.59 1.82 0.27 1.08

Fine Soil 0.55 1.89 0.53 1.95

Coarse Mass 1.81 6.68 1.80 7.29

Secondary Organic 

Aerosol, Anthropogenic not available1 1.83 not available1 1.64

Secondary Organic 

Aerosol, Biogenic not available1 3.27 not available1 3.11

Total 7.40 32.91 6.22 29.80

 Particulate Matter 

Constituent

2002 Impacts at White Mountain

(inverse megameters)

2018 Impacts at White Mountain

(inverse megameters)
11-14 

Figure 11-13: Areas and Pollutants Causing Regional Haze at Wheeler Peak Wilderness 

Area on Worst 20 Percent Days in 2002 

Figure 11-14: Areas and Pollutants Causing Regional Haze at Wheeler Peak Wilderness 

Area on Best 20 Percent Days in 2002 

Note the change in scale on the y-axis. 
11-15 

Table 11-6: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Wheeler Peak Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All 

Source Areas Texas Total Total, All Source Areas

Sulfate 0.76 5.27 0.79 5.00

Nitrate 0.22 1.64 0.19 1.48

Primary Organic Aerosol 0.28 3.93 0.18 3.64

Elemental Carbon 0.21 2.18 0.08 1.48

Fine Soil 0.25 1.75 0.23 1.88

Coarse Mass 0.12 2.77 0.12 3.09

Secondary Organic 

Aerosol, Anthropogenic not available1 1.41 not available1 1.28

Secondary Organic 

Aerosol, Biogenic not available1 3.03 not available1 2.96

Total 1.85 21.96 1.59 20.80

 Particulate Matter 

Constituent

2002 Impacts at Wheeler Peak

(inverse megameters)

2018 Impacts at Wheeler Peak

(inverse megameters)

11.2.3.2 Oklahoma 

Figure 11-15: Areas and Pollutants Causing Regional Haze at Wichita Mountains (WIMO) 

in Oklahoma on Worst 20 Percent Days in 2002 
11-16 

Figure 11-16: Areas and Pollutants Causing Regional Haze at Wichita Mountains (WIMO) 

in Oklahoma on Best 20 Percent Days in 2002 

Note: On the worst 20 percent of dayschange in scale on the y-axis. 

Table 11-7: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Wichita Mountains Wilderness Area on Worst 20 Percent 

Days

Texas Total Total, All Source 

Areas Texas Total Total, All Source 

Areas

Sulfate 13.98 49.12 9.68 33.33

Nitrate 7.89 23.72 6.08 18.10

Primary Organic Aerosol 3.05 11.81 2.57 10.92

Elemental Carbon 1.42 4.47 0.68 3.00

Fine Soil 0.29 0.79 0.30 0.79

Coarse Mass 1.51 4.64 1.49 4.35

Secondary Organic 

Aerosol, Anthropogenic not available1 2.57 not available1 2.22

Secondary Organic 

Aerosol, Biogenic not available1 2.91 not available1 2.84

Total 28.15 100.03 20.79 75.56

 Particulate Matter 

Constituent

2002 Impacts at Wichita Mountains

(inverse megameters)

2018 Impacts at Wichita Mountains

(inverse megameters)
11-17 

11.2.3.3 Colorado 

Emissions from the western portion of Texas account for most of Texas’ impact on the Class I 

areas in Colorado. The following graph shows the impacts of the western portion of Texas on the 

Class I areas in Colorado that are included in the CENRAP PSAT modeling. The graph is to 

show the basis for choosing Great Sand Dunes as the Colorado Class I area for more detailed 

examination of Texas’ impacts. 

Figure 11-17: Calculated Regional Haze Impacts of West Texas Emissions at Each Class I 

Area in Colorado Note: On the worst 20 percent of daysIncluded in CENRAP PSAT 

Modeling on Worst 20 Percent Days in 2002 

GRSA - Great Sand Dunes Wilderness AreaNational Park

MEVE - Mesa Verde National Park 

MOZI - Mount Zirkel Wilderness Area 

ROMO - Rocky Mountain National Park 

WEMI - Weminuche Wilderness Area 

WHRI - White River National Forest 
11-18 

Figure 11-18: Areas and Pollutants Causing Regional Haze at Great Sand Dunes (GRSA) 

in Colorado Note: On the worst on Worst 20 percent of days Percent Days in 2002 

Figure 11-19: Areas and Pollutants Causing Regional Haze at Great Sand Dunes (GRSA) 

in Colorado on Best 20 Percent Days in 2002 

Note the change in scale on the y-axis. 

Deleted: Page Break
11-19 

Table 11-8: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Great Sand Dunes Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All Source 

Areas Texas Total Total, All Source 

Areas

Sulfate 0.66 5.84 0.65 5.32

Nitrate 0.02 1.94 0.02 1.83

Primary Organic Aerosol 0.18 3.34 0.12 3.07

Elemental Carbon 0.10 1.57 0.04 1.08

Fine Soil 0.23 2.84 0.21 2.95

Coarse Mass 0.07 7.36 0.07 7.69

Secondary Organic 

Aerosol, Anthropogenic not available1 1.38 not available1 1.28

Secondary Organic 

Aerosol, Biogenic not available1 3.61 not available1 3.56

Total 1.25 27.88 1.11 26.77

 Particulate Matter 

Constituent

2002 Impacts at Great Sand Dunes

(inverse megameters)

2018 Impacts at Great Sand Dunes

(inverse megameters)

Figure 11-20: Areas and Pollutants Causing Regional Haze at Rocky Mountains National 

Park (ROMO) in Colorado on Worst 20 Percent Days in 2002 
11-20 

Figure 11-21: Areas and Pollutants Causing Regional Haze at Rocky Mountains National 

Park (ROMO) in Colorado on Best 20 Percent Days in 2002 

Note the change in scale on the y-axis. 

Table 11-9: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Rocky Mountain National Park on Worst 20 Percent Days 

Texas Total Total, All 

Source Areas Texas Total Total, All 

Source Areas

Sulfate 0.30 7.69 0.30 6.52

Nitrate 0.08 5.17 0.06 4.28

Primary Organic Aerosol 0.07 5.65 0.05 5.37

Elemental Carbon 0.03 2.33 0.02 1.54

Fine Soil 0.06 1.39 0.05 1.52

Coarse Mass 0.03 5.17 0.03 5.66

Secondary Organic 

Aerosol, Anthropogenic not available1 1.73 not available1 1.60

Secondary Organic 

Aerosol, Biogenic not available1 3.00 not available1 2.91

Total 0.58 32.13 0.51 29.41

 Particulate Matter 

Constituent

2002 Impacts at

Rocky Mountain National Park

(inverse megameters)

2018 Impacts at

Rocky Mountain National Park

(inverse megameters)
11-21 

11.2.3.4 Arkansas 

Figure 11-22: Areas and Pollutants Causing Regional Haze at Caney Creek (CACR) in 

Arkansas on Worst 20 Percent Days in 2002

Note: On the worst 20 percent of days 

2002

Deleted: 

Figure 11-
11-22 

Figure 11-23: Areas and Pollutants Causing Regional Haze at Caney Creek (CACR) in 

Arkansas on Best 20 Percent of Days in 2002 

Note the change in scale on the y-axis. 
11-23 

Table 11-10: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Caney Creek Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All Source 

Areas Texas Total Total, All Source Areas

Sulfate 11.55 87.05 7.24 48.95

Nitrate 1.49 13.78 0.83 7.57

Primary Organic Aerosol 0.83 10.50 0.83 9.93

Elemental Carbon 0.36 4.80 0.20 3.17

Fine Soil 0.15 1.12 0.17 1.29

Coarse Mass 0.50 3.73 0.47 3.58

Secondary Organic 

Aerosol, Anthropogenic not available1 3.94 not available1 3.21

Secondary Organic 

Aerosol, Biogenic not available1 9.00 not available1 8.14

Total 14.89 133.93 9.74 85.84

2002 Impacts at Caney Creek

(inverse megameters)

2018 Impacts at Caney Creek

 Particulate Matter (inverse megameters)

Constituent

Figure 11-24: Areas and Pollutants Causing Regional Haze at Upper Buffalo (UPBU) in 

Arkansas on Worst 20 Percent Days in 2002 
11-24 

Figure 11-25: Areas and Pollutants Causing Regional Haze at Upper Buffalo (UPBU) in 

Arkansas on Best 20 Percent Days in 2002 

Note the change in scale on the y-axis. 

Table 11-11: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Upper Buffalo Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All Source 

Areas Texas Total Total, All Source Areas

Sulfate 4.41 83.18 2.74 45.38

Nitrate 0.27 13.30 0.18 9.22

Primary Organic Aerosol 0.24 10.85 0.24 10.17

Elemental Carbon 0.10 4.72 0.05 3.07

Fine Soil 0.04 1.21 0.05 1.40

Coarse Mass 0.12 6.85 0.11 6.53

Secondary Organic 

Aerosol, Anthropogenic not available1 4.14 not available1 3.36

Secondary Organic 

Aerosol, Biogenic not available1 7.55 not available1 7.02

Total 5.19 131.79 3.38 86.16

 Particulate Matter 

Constituent

2002 Impacts at Upper Buffalo

(inverse megameters)

2018 Impacts at Upper Buffalo

(inverse megameters)
11-25 

11.2.3.5 Missouri 

Figure 11-26: Areas and Pollutants Causing Regional Haze at Hercules-Glades (HEGL) in 

Missouri on Worst 20 Percent Days in 2002 

Figure 11-27: Areas and Pollutants Causing Regional Haze at Hercules-Glades (HEGL) in 

Missouri on the Best 20 Percent of Days 2002 

Note the change in scale on the y-axis. 
11-26 

Table 11-12: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Hercules-Glades Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All Source 

Areas Texas Total Total, All Source Areas

Sulfate 3.48 87.94 2.51 50.63

Nitrate 2.56 17.91 1.51 12.35

Primary Organic Aerosol 0.33 14.55 0.28 12.95

Elemental Carbon 0.12 5.22 0.06 3.51

Fine Soil 0.03 0.92 0.03 1.00

Coarse Mass 0.06 2.78 0.06 2.48

Secondary Organic Aerosol, 

Anthropogenic not available1 4.50 not available1 3.76

Secondary Organic Aerosol, 

Biogenic not available1 6.22 not available1 5.83

Total 6.59 140.05 4.45 92.49

 Particulate Matter 

Constituent

2002 Impacts at Hercules-Glades

(inverse megameters)

2018 Impacts at Hercules-Glades

(inverse megameters)

Figure 11-28: Areas and Pollutants Causing Regional Haze at Mingo (MING) in Missouri 

on Worst 20 Percent Days in 2002 
11-27 

Figure 11-29: Areas and Pollutants Causing Regional Haze at Mingo (MING) in Missouri 

on Best 20 Percent Days in 2002 

Note the change in scale on the y-axis. 

Table 11-13: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Mingo Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All Source 

Areas Texas Total Total, All Source Areas

Sulfate 0.69 102.52 0.53 54.45

Nitrate 1.18 27.24 0.64 19.14

Primary Organic Aerosol 0.07 10.21 0.06 9.09

Elemental Carbon 0.03 5.49 0.02 3.53

Fine Soil 0.01 1.26 0.01 1.44

Coarse Mass 0.02 5.95 0.02 5.31

Secondary Organic Aerosol, 

Anthropogenic not available1 3.66 not available1 3.04

Secondary Organic Aerosol, 

Biogenic not available1 3.50 not available1 3.25

Total 2.01 159.83 1.28 99.24

 Particulate Matter 

Constituent

2002 Impacts at Mingo

(inverse megameters)

2018 Impacts at Mingo

(inverse megameters)
11-28 

11.2.3.6 Louisiana 

Figure 11-30: Areas and Pollutants Causing Regional Haze at Breton Wilderness Area 

(BRET) in Louisiana on Worst 20 Percent Days in 2002

Note: On the worst 20 percent of days 2002

Figure 11-31: Areas and Pollutants Causing Regional Haze at Breton Wilderness Area 

(BRET) in Louisiana on Best 20 Percent Days in 2002 
11-29 

Note the change in scale on the y-axis. 

Table 11-14: Texas’ Apportioned Contribution to the Measured 2002 and Projected 2018 

Total Visibility Extinction at Breton Wilderness Area on Worst 20 Percent Days 

Texas Total Total, All 

Source Areas Texas Total Total, All Source Areas

Sulfate 3.55 96.83 2.66 68.63

Nitrate 0.15 8.29 0.16 8.20

Primary Organic Aerosol 0.12 4.71 0.11 4.37

Elemental Carbon 0.14 5.40 0.06 3.92

Fine Soil 0.05 0.95 0.05 1.16

Coarse Mass 0.19 3.70 0.18 3.95

Secondary Organic 

Aerosol, Anthropogenic not available1 1.63 not available1 1.38

Secondary Organic 

Aerosol, Biogenic not available1 2.48 not available1 2.46

Total 4.20 123.99 3.23 94.06

 Particulate Matter 

Constituent

2002 Impacts at Breton

Wilderness Area

(inverse megameters)

2018 Impacts at Breton

Wilderness Area

(inverse megameters)

11.3 REQUEST FOR FEDERAL EFFORTS TO REDUCE INTERNATIONAL 

TRANSPORT 

Figures 11-2 and 11-4 show the CENRAP PSAT results apportioning the causes of 2000-2004 

regional haze on the worst 20 percent visibility days at Big Bend and Guadalupe Mountains, 

based on the 2002 base period modeling. The figures show large contributions from 

anthropogenic sources categorized as from Mexico and from the boundary conditions outside the 

CENRAP modeling domain. The boundary conditions domain includes some of central Mexico, 

all of southern Mexico, most of the Mexican Yucatan, and all of Central America. Chapter 8: 

Modeling Assessment describes the modeling in more detail. These results are directionally 

consistent with federal studies that have previously found substantial international pollutant 

transport impacts on regional haze at Big Bend. These studies include the Big Bend Regional 

Aerosol and Visibility Observational (BRAVO) study of regional haze impacts at Big Bend and a 

number of National Park Service (NPS) studies in the 1990s that relied on back trajectory 

analysis to determine where air accumulated regional haze on its way to Big Bend (NPS et al. 

2004). Figure 11-4 shows that the CENRAP PSAT modeling calculates that international 

transport contributes over 25 percent of the regional haze on the worst 20 percent of days during 

the base period at Guadalupe Mountains. Figures 11-9 and 11-15 show that international 

transport contributes over ten percent of the regional haze on the worst 20 percent of days at Salt 

Creek and Wichita Mountains. At Caney Creek, the international transport contribution to 

regional haze on the worst 20 percent of days is over five percent of the total (after discounting 

coarse mass, which the model does not represent reliably) (ENVIRON 2007). 

CENRAP modeling estimates of the base period visibility impairment at Big Bend from the 

United States and foreign contributions indicate 52 percent of the light extinction at Big Bend on 

the worst 20 percent of regional haze days comes from international transport. The 

concentrations are adjusted to match the visibility extinction measured for the 2000 through 2005 

base period. 

Deleted: 3

Deleted: 3

Deleted: 5

Deleted: 6

Deleted: ,
11-30 

Due to the large impact of international transport on anthropogenic regional haze in Texas, it will 

be impossible to reach natural conditions at the two Class I areas in Texas without reductions in 

international this transport impacts to parallel the reductions in United States anthropogenic 

regional haze impacts on Texas’ two Class I areas. Although the impact of international transport 

on Class I areas in the states bordering Texas is approximately ten percent or less of the total 

impairment, reductions in international transport of anthropogenic regional haze are necessarywill

also be needed for the Class I areas in these states to approach reach the natural conditions goal. 

The TCEQ requests that the EPA initiate and pursue federal efforts to reduce international 

transport of visibility impairing pollutants into Texas. 

11.4 MINIMIZING VISIBILITY IMPAIRMENT FROM TEXAS EMISSIONS 

The TCEQ has implemented rules that limit and minimize emissions causing both local and 

regional visibility impairment. The Texas SIP includes numerous rules that minimize emissions 

that cause or contribute to local and regional visibility impairment. The TCEQ plans to continue 

to implement all these rules that protect visibility at Class I areas in Texas and other states 

(Appendices 11-2 and 11-3). 

11.4.1 Opacity Limitations 

Title 30 TAC Chapter 111, Control of Air Pollution from Visible Emissions and Particulate 

Matter, limits visible emissions and mass emissions from industrial and power plant stacks, motor 

vehicles, and incinerators. Together with opacity limits in many preconstruction permits, these 

rules limit the emissions of PM from a wide variety of sources. The TCEQ continues to enforce 

both the rule and permit limits on opacity and PM emissions from electric generating units 

(EGUs) and other sources. 

11.4.2 Sulfur Emission Limitations 

Title 30 TAC Chapter 112 Control of Air Pollution from Sulfur Compounds limits sulfur dioxide, 

hydrogen sulfide, total reduced sulfur compounds, and sulfuric acid from a variety of sources 

including EGUs, sulfuric acid plants, smelters, and sulfur recovery units. These rules, together 

with many lower limitations in permits for new and modified sources, limit the impacts of 

ammonium sulfate from Texas on the Class I areas in Texas and at the Class I areas in other states 

that Texas impactsTexas’ emissions impact. 

11.4.3 Best Available Control Technology (BACT) Requirements 

BACT requirements have been in effect since 1972 for new and modified sources of air pollution 

for SO2, NOX, PM, and VOC. While federal new source review (NSR) rules requiring BACT 

apply only to major new sources or modifications, Texas law requires BACT for all emissions 

increases at new or modified units. The basic requirement is that each new and modified source 

of air pollution built in Texas use BACT to minimize or eliminate emissions of all pollutants 

subject to the national ambient air quality standards (NAAQS). This includes all the emissions 

from human activity that contribute to regional haze, such asincluding NOX, SO2, PM, and VOC. 

Title 30 TAC Chapter 116: Control of Air Pollution by Permits for New Construction or 

Modification contains these requirements. 

Each applicable source must obtain a construction permit before beginning construction. 

Issuance of a construction permit can occur only after an engineering determination that the 

facility will use BACT. In some cases, the BACT requirements apply through permits by rule or 

standard permits rather than through case-by-case review of each new or modified source of air 

pollution. 
11-31 

11.4.4 Programs to Manage Smoke Impacts on Class I Areas 

The Texas Forest Service (TFS) coordinates fire and smoke management issues in Texas. The 

34th Texas Legislature created the TFS in 1915. The legal mandate of the TFS includes the 

responsibility to "assume direction of all forest interests and all matters pertaining to forestry 

within the jurisdiction of the state." The TFS has developed a voluntary approach called the 

Texas Forest Service Smoke Management System, under which all land managers in Texas, 

including the NPS, inform the TFS before performing prescribed burns. The TFS dispatch office 

maintains communications with the TCEQ. 

Examination of the data for the worst 20 percent visibility days at both Big Bend and Guadalupe 

Mountains indicates that smoke from agricultural burning and wildfires in Texas are is not a large 

contributor to visibility impairment in Texas. There is no indication that agricultural burning and 

wildfires in Texas are significant contributors to regional haze on the worst 20 percent days at 

Class I areas that Texas impacts outside the state. For these reasons, the current rules, policies 

and plans listed below, along with the NPS smoke management plans, and the smoke 

management plans of other federal agencies responsible for Class I areas that Texas impacts, are 

adequate to meet the long-term strategy requirements. Appendix 11-1 contains documents in the 

following list. The TCEQ provides the documents as examples of the fire management plans that 

the responsible agencies maintain. This SIP revision does not incorporate the non-TCEQ 

documents. The outdoor burning rules are currently approved in to the Texas SIP.

• Texas Wildfire Protection Plan (TFS 2007) 

• Texas Forest Service Smoke Management System (TFS 1995) 

• 30 TAC Chapter 111, Subchapter B: Outdoor Burning (TCEQ 2006) 

• Big Bend National Park Fire Management Plan (NPS 2005a) 

• Guadalupe Mountains National Park Fire Management Plan (NPS 2005b) 

• Big Thicket National Preserve Fire Management Plan (NPS 2004a) 

• Lyndon B. Johnson National Historical Park Fire Management Plan (NPS 2005c) 

• Padre Island National Seashore Fire Management Plan (NPS 2004b) 

• San Antonio Missions National Historical Park Fire Management Plan (NPS 2004c). 

A significant component of preventing wildfires is the authority that Texas counties have to 

prohibit open burning in times of drought. The counties get their authority from §352.081 and 

§352.082 of the Texas Local Government Code, relating to outdoor burning. Another component 

in reducing wildfire hazards is the red flag warnings that the National Weather Service issues in 

times of drought, low humidity, and windy conditions. The broadcast media routinely publicize 

these warnings, especially during times of drought and outdoor burning bans. 

Because of the relatively low contribution of smoke from Texas to worst 20 percent day visibility 

impairment at Texas’ Class I areas and the Class I areas Texas’ emissions affect in other states, 

the TCEQ is not certifying a smoke management plan as part of this SIP revision. 

11.4.5 Program to Lower the Impact of Construction Activity on Air and Water Quality 

The main regulatory requirements that the TCEQ uses to minimize the air and water quality 

impacts of dust and soil from construction activity in Texas are under water pollution control 

requirements to prevent pollution from storm water runoff and mud and dirt tracked from 

construction sites. The reduction in silt-bearing runoff on paved roads and in mud and dirt 

tracked onto paved roads around construction sites reduces the amount of fine soil material 

suspended in the air from traffic in these areas. 

The TCEQ’s Texas Pollutant Discharge Emission System (TPDES) General Permit TXR150000 

regulates activities at construction sites one acre or larger. The size threshold applies to single 

Deleted: ¶

Page Break

Deleted: s

Deleted: :
11-32 

projects or multiple projects as part of a larger development plan. The TCEQ issued this permit 

March 5, 2003, pursuant to §26.040 of the Texas Water Code and §402 of the Clean Water Act. 

State rule 30 TAC §111.145, Construction and Demolition, provides additional authority and 

states:

 “For the purpose of this section, the following restrictions apply if the area of land 

affected by the listed activities is more than one acre in size, except for the City of El Paso, where 

restrictions shall apply regardless of the size of the area of land affected. No person may cause, 

suffer, allow, or permit a structure, road, street, alley, or parking area to be constructed, altered, 

repaired, or demolished, or land to be cleared without taking at least the following precautions to 

achieve control of dust emissions: 

 (1) Use of water or of suitable oil or chemicals for control of dust in the 

demolition of structures, in construction operations, in work performed on a road, street, alley, or 

parking area, or in the clearing of land.” 

11.5 FEDERAL PROGRAMS THAT REDUCE EMISSIONS 

The Federal Motor Vehicle Control Program (FMVCP) has produced and is continuing to 

produce large reductions in motor vehicle emissions of NOX, PM, and VOCs. The increasingly 

lower federal limits on sulfur content for gasoline and diesel fuel are continuing to reduce the 

sulfur input to total sulfur emissions from internal combustion engines. They are enabling lower 

NOX, PM, and VOC emission limits for on-road motor vehicles, both diesel and gasoline, as well 

as for non-road engines. The lower sulfur fuel content is also enabling implementation of lower 

emission limits on new on-road and non-road engines. 

The following lists several significant programs: 

Federal On-Road Measures 

• Federal Phase II reformulated gasoline (RFG) Dallas-Fort Worth (DFW) and HoustonGalveston-Brazoria (HGB) 

• Tier 2 vehicle emission standards and federal low-sulfur gasoline 

• National low emissions vehicle standards (NLEV) 

• Heavy-duty diesel standards 

Federal Non-Road Measures 

• Lawn and garden equipment 

• Tier 2 heavy-duty diesel equipment 

• Locomotive engine standards 

• Compression ignition standards for vehicles and equipment 

• Recreational marine engine standards 

Appendix 11-2: Federal and Texas Programs Related to On-Road and Non-Road Mobile 

Sources lists the federal and state rules and programs in considerable detail. 

11.5.1 Texas Vehicle Inspection and Maintenance Programs 

Motor vehicle inspection and maintenance programs are in place to maintain the effectiveness of 

the FMVCP in the HGB, DFW, Austin, and El Paso areas. The Department of Public Safety 

administers the programs and TCEQ maintains oversight of the programs including collecting and 

analyzing data directly from the equipment at the inspection stations. 

11.5.2 Air Check Texas Repair and Replacement Assistance Program 

In 2002, the TCEQ established a financial assistance program for qualified owners of vehicles 

that fail the emissions test. The Low Income Vehicle Repair Assistance, Retrofit, and 
11-33 

Accelerated Vehicle Retirement Program (LIRAP) provisions of House Bill 2134, 77th Texas 

Legislature 2001, created the program. House Bill 1611 passed in the 79th Legislature 2005, 

modified the program. The LIRAP applies only to counties that implement a vehicle inspection 

and maintenance program and have elected to implement LIRAP provisions. 

By enacting Senate Bill 12, the 80th Texas Legislature expanded the LIRAP program and 

appropriated $45 million for LIRAP for fiscal year 2008 and an additional $45 million for fiscal 

year 2009. The purpose of this voluntary program is to remove older, more polluting vehicles 

from Texas roadways in certain counties with high ozone. Under Senate Bill 12, residents of 

certain Texas counties who meet income criteria and whose vehicles meet certain registration 

criteria may be eligible to receive vouchers for up to $3,500 toward the purchase of a new or no 

more than three-year-old qualifying vehicle from participating auto dealers. A motor vehicle 

scrappage facility must certify that the engine from a retired vehicle has been destroyed for the 

vehicle owner to be eligible for the voucher. Accelerated retirement of older, higher polluting 

vehicles will reduce NOX, fine PM, and VOC emissions. 

11.6 EMISSION REDUCTIONS SINCE ISSUANCE OF THE REGIONAL HAZE RULE 

Since July 1, 1999, the TCEQ has implemented substantial programs that reduce Texas’ regional 

haze impact at Class I areas in Texas and in surrounding states. Appendix 11-3: Major Point 

Source NOX Rules and Reductions Promulgated in Texas Since 2000 provides a detailed list of 

the TCEQ rule provisions that regulate NOX and PM emissions.

11.6.1 NOX Emission Reduction Requirements in Texas Ozone SIP Revisions 

Texas’ SIP revisions from 2000 forward include required NOX emission reductions for the 

following regions: HGB, DFW, Beaumont-Port Arthur, Austin, and Northeast Texas as well as 

one for East Texas. In addition, the SIP includes the Texas low emission diesel requirements for 

East and Central Texas in 30 TAC Chapter 114. The rules for control of NOX emissions from 

stationary sources for the Texas ozone SIP are included in Chapter 117. Recent NOX control 

measures adopted in Chapter 117 address a wide range of point and area sources at major and 

minor sources of NOX. Some of these rules implemented the NOX reduction requirements of 

Senate Bill 7, for grandfathered EGUs, as discussed in more detail in Section 11.6.2 The TCEQ 

has submitted all of the Chapter 117 NOX limitations and requirements as well as the Chapter 114 

low emission diesel fuel requirements to EPA as revisions to the Texas SIP. 

11.6.2 SO2 and NOX Reduction Requirements under Senate Bill 7 

Senate Bill 7 required the following emission reductions from grandfathered EGUs: for NOX, a 

50 percent reduction of the 1997 emission level by May 1, 2003, and for SO2, a 25 percent 

reduction of the 1997 emission level by May 1, 2003, accompanied by an in-state emissions cap 

and trade program. Grandfathered EGUs are the EGUs built before Texas’ BACT emission 

control requirements for new and modified sources of air pollution went into effect in 1972. 

These requirements produced reductions approximately a decade before the BART emissions 

reductions will be effective in states without CAIR requirements. They were effective 

approximately six and seven years before the Phase I CAIR requirements will be effective in 

states that implement CAIR NOX and SO2 emission reductions. Phase I of CAIR becomes 

effective in 2009 for NOX and in 2010 for SO2. Phase II of CAIR will become effective in 2015, 

at which time it will become the limiting requirement for SO2 and NOX for most EGUs in Texas. 

This SIP revision presumes that either CAIR will be finally upheld by the courts or will be 

replaced with a federal program that achieves comparable reductions in emissions. On 

December 23, 2008, the U.S. Circuit Court of Appeals for the District of Columbia Circuit issued 

a decision remanding CAIR to EPA to initiate rulemaking consistent with its opinion, but the 

court did not vacate CAIR.
11-34 

11.6.3 CAIR Reductions for NOX and SO2

On March 10, 2005, the EPA issued the CAIR, requiring reductions in SO2 and NOX emissions 

from EGUs in 28 states and the District of Columbia (70 FR 25162-25405). These include states 

in the Northeast, the South, and along the Mississippi River plus Texas, the only largely western 

state subject to the CAIR emissions reductions requirements. Figure 11-32 shows that the CAIR 

emissions reductions requirements in Texas apply more than 480 miles west of the areas where 

CAIR requirements apply in other states. The map also shows that Texas is the only state where 

CAIR applies in the next tier of states west of the states that border the Mississippi River. 

Figure 11-32: CAIR Emission Reduction States 

Note: States shown in green have CAIR emission reductions requirements 

Source: TCEQ 2007 

Figure 11-11: CAIR Emission Reduction States

CAIR applies to SO2 in all CAIR areas except in Arkansas, Delaware, New Jersey, and New 

England. In states where CAIR applies to SO2, CAIR will reduce SO2 emission allowances by 

over 60 percent from 2003 federal acid rain cap levels. In all CAIR states, the program will 

reduce NOX emission allowances by over 60 percent from 2003 federal acid rain cap levels. 

CAIR establishes an EPA-administered cap-and-trade program for EGUs in which states may 

participate as a means of meeting these requirements. The Texas Legislature directed the TCEQ 

to participate in this interstate cap-and-trade system. SO2 and NOX reductions will occur in two 

phases under a cap-and-trade system established by the EPA. SO2 emission caps will be lowered 

in 2010 and again in 2015. NOX emission allowables will decrease in 2009 and again in 2015. 

Table 11-15 shows the emission allowances for EGUs in Texas under the CAIR program. 

Table 11-15: EGU Emission Allowances in Texas under the CAIR Program 

Annual NOX Cap (tons) 

State 2003 Acid Rain 

Emissions Inventory 

2009 CAIR 

Phase I Budget 

2015 CAIR 

Phase II Budget 

Texas 211,000 181,014 150,845 

Annual SO2 Cap (tons) 

Deleted: 

Deleted: 11

Deleted: 1
11-35 

State 2003 Acid Rain 

Emissions Inventory 

2010 CAIR 

Phase I Budget 

2015 CAIR 

Phase II Budget 

Texas 578,000 320,946 224,662 

Source: EPA 
11-36 

The TCEQ has submitted to the EPA as a revision to the Texas SIP its rules that implement the 

CAIR requirements. The following links provide further information on the CAIR SIP revisions 

and CAIR requirements for Texas. 

The Texas CAIR SIP - 

<http://www.tceq.state.tx.us/assets/public/implementation/air/sip/caircamr/05048CAIRSIP_adoption_final.pdf>

The Texas CAIR Rule - 

<http://www.tceq.state.tx.us/assets/public/implementation/air/sip/caircamr/05046101_ado_clean.pdf>

The Texas CAIR/CAMR Web Page - 

<http://www.tceq.state.tx.us/implementation/air/sip/caircamr.html>

11.6.4 Best Available Retrofit Technology (BART) Requirements 

The commission adopted the final BART Rule (30 TAC Chapter 116, Subchapter M) January 10, 

2007. It is available at: 

<http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=116&sc

h=M&rl=Y>. Because most sources reviewed under the BART rule are a long distance from the 

nearest Class I federal area, a large percentage fell below the de minimis level for impacting all 

Class I areas, so they did not have to proceed to a BART engineering analysis. Chapter 9: Best 

Available Retrofit Technology details the implementation of the BART program in Texas in 

Table 9-7. 
11-37 

11.6.5 Comparison of the NOX Emission Limits for EGUs with CAIR Limits 

The following table shows the relationship among the requirements. 

Table 11-16: Texas Electric Generating Utility NOX Control Strategies Compared to 

CAIR 

Facility Type State Emission Rate 

Requirements 

CAIR 2009 CAIR 2015 

Utility Electric Generation in Ozone Nonattainment Areas Emission Specifications for 

Attainment Demonstrations 

Houston-GalvestonBrazoria 

Pounds of 

NOX/MMBtu 

Pounds of 

NOX/MMBtu 

Pounds of 

NOX/MMBtu 

Gas-Fired Utility 

Boilers 

0.030 lb 0.15 lb 0.125 lb 

Coal-Fired Utility 

Boilers 

0.050 lb (wall-fired)

0.045 lb 

(tangential-fired)

0.15 lb 0.125 lb 

Oil-Fired Utility 

Boilers 

0.050 lb (wall-fired)

0.045 lb 

(tangential-fired)

0.15 lb 0.125 lb 

Auxiliary Steam 

Utility Boilers 

0.030 lb 0.15 lb 0.125 lb 

Stationary Gas 

Turbines 

0.032 lb 0.15 lb 0.125 lb 

Dallas-Fort Worth

Large Utility Boilers 0.033 lb 0.15 lb 0.125 lb 

Small Utility Boilers 0.06 lb 0.15 lb 0.125 lb 

Beaumont-Port Arthur 

All Utility Boilers 0.10 lb 0.15 lb 0.125 lb 

Utility Electric Generation in East and Central Texas 

Gas-Fired Utility 

Boilers 

0.14 lb 0.15 lb 0.125 lb 

Coal-Fired Utility 

Boilers 

0.165 lb 0.15 lb 0.125 lb 

Senate Bill 7 

East Texas Region 

Grandfathered 

Facilities 

0.14 lb 0.15 lb 0.125 lb 

West Texas and El 

Paso Region 

Grandfathered 

Facilities 

0.195 lb 0.15 lb 0.125 lb 

Source: TCEQ, current as of February 23, 2007 

Deleted: 2
11-38 

11.6.6 Sulfur Dioxide Reductions under the EPA Refinery Consent Decrees 

The EPA refinery consent decrees cover both SO2 and NOX. The NOX reductions are generally 

company-wide reduction requirements, butand the details of which emission points will have 

reductions and the amount of the reductions are not yet available. 

The EPA has provided specifics of the SO2 reductions by emission point for refineries. In 

addition, information is available regarding SO2 emission reductions at a large sulfuric acid plant 

at the western end of the Houston Ship Channel. The following table combines these SO2

emission reduction data. The growth projected growth from 2002 to 2018 are estimates from 

CENRAP’s emission inventory contractor (Pechan 2005). Since the TCEQ’s new and modified 

source permitting requirements prohibit an increase in allowable emissions without a construction 

permit, which requires use of BACT, the projected emission increases between 2002 and 2018 

may be substantially over estimated. 

Table 11-17: Annual SO2 Emissions at Consent Decree Impacted Sources 

SO2 Emissions 2002 (tpy) 2018 (tpy) 

Pre-decree levels 48,868 62,229

Reduction estimate* 45,453 56,433

Difference (remaining emissions) 3,415 5,796

*Reductions estimate applied to 2002 actual emissions to show theoretical impact. 

Controls will be in place before 2018. 

Source: EPA 1999 

11.6.7 Texas Low Emissions Diesel (TxLED) Program 

The goal of the TxLED program is to lower emissions of NOX and other pollutants from dieselpowered motor vehicles and non-road equipment. It applies to diesel fuel producers, importers, 

common carriers, distributors, transporters, bulk terminal operators, and retailers. The rules cover 

110 counties in eastern Texas, including the ozone nonattainment areas of Beaumont-Port Arthur, 

DFW, and HGB. The rules require that diesel fuel as defined under 30 TAC §114.6 produced for 

delivery and ultimate sale to the consumer for both on- and non-road use must contain less than 

10 percent by volume of aromatic hydrocarbons and have a cetane number of 48 or greater. The 

rules, which took effect October 1, 2005, allow some compliance options (30 TAC 114, 

Subchapter A, §114.6 and Subchapter H, Division 2, §§114.312 - 114.319). 

11.6.8 The Texas Emission Reduction Plan (TERP) 

TERP is a comprehensive set of incentive programs aimed at improving air quality in Texas. The 

TCEQ administers TERP grants and other TERP financial incentives. The Texas Legislature 

established the TERP in 2001 through enactment of Senate Bill 5. The TERP includes a number 

of voluntary financial incentive programs, as well as other assistance programs, to help improve 

the air quality in Texas. The goals of the TERP are to: 

• assure that the air in this state is safe to breathe and meets minimum federal standards 

established under the FCAA (42 USC §7407); 

• develop multi-pollutant approaches to solving the state’s environmental problems; and 

• adequately fund research and development that will make the state a leader in new 

technologies that can solve its environmental problems while creating new business and 

industry in the state. 

The primary objective of the TERP has been to reduce NOX emissions to aid in attaining the 

NAAQS for ozone. By encouraging replacement of older on-road and non-road engines with 

newer engines, the TERP has also decreased fine PM emissions from the motor vehicles and 

equipment using these engines. As of January 2007, the TCEQ had approved over $406 million 

in grants under the TERP since the program started in 2001. 

Deleted: 3
11-39 

The Texas Legislature approved over $143 million for fiscal year 2008 and $146 million for 

fiscal year 2009 to increase TERP grants aimed at NOX emission reductions in Texas. The 

program also reduces fine PM emissions by accelerating the replacement of older diesel engines 

with newer engines that have much lower PM emission rates. 
11-1 
12-1 

CHAPTER 12. COMPREHENSIVE PERIODIC IMPLEMENTATION PLAN 

REVISIONS AND ADEQUACY OF THE EXISTING PLAN 

Title 40 CFR §51.308(f) requires states to revise and submit to the EPA a comprehensive regional 

haze implementation plan revision every 10 years until 2064. In addition, 40 CFR §51.308(g) 

requires periodic reports in the form of a SIP revision that evaluates progress towards the 

reasonable progress goals established for each Class I area. In accordance with the requirements, 

the TCEQ plans to submit a report to the EPA on reasonable progress every five years following 

the initial submittal of the Regional Haze SIP. The report will be in the form of a SIP revision 

and will evaluate the progress made towards the reasonable progress goal for each Class I area 

located within Texas, and in each Class I area located outside of Texas that may be affected by 

emissions from within Texas. The TCEQ will consult with the Federal Land Managers during the 

SIP revision development process. All requirements listed in 40 CFR §51.308(g) will be 

addressed in the SIP revision for demonstrating reasonable progress. 

Depending on the findings of its five-year progress report, the TCEQ will examine the actions 

listed in 40 CFR §51.308(h). The findings of the five-year progress report may determine which 

action the state may choose as appropriate. 
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All appendices are available upon request. Pleaseon the web site.

(http://www.tceq.state.tx.us/implementation/air/sip/bart/haze_appendices.html ). 

If you have problems accessing, please contact: 

Margaret Earnest 

Texas Commission on Environmental Quality 

12100 Park 35 Circle 

Austin, TX 78752 

512-239-4581 

mearnest@tceq.state.tx.us