# Exhibit 3

Consultation

A. Introduction B. VISTAS Analyses for Reasonable Progress

– FLM Meeting April 25, 2007 C. VISTAS Consultation Meeting - Atlanta, GA, May 14, 2007 D. Letter to GA EPD, May 4, 2007 E. Letter to AL DEM, May 4, 2007 F. Letter to GA EPD, August 1, 2008 G. Letter from GA EPD, May 26, 2009 H. Notes from Interstate Regional Haze Consultation Meeting, January 23, 2007 I. Letter from Federal Land Managers on Pre-hearing draft (60-day review requirement), October 26, 2009 J. Response to Federal Land Managers 60 -day revie w comments letter.Introduction

The Southeast Regional Planning Organization, Visibility Improvement State and Tribal Association of the Southeast (VISTAS), is comprised of the ten Southeast States (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia and West Virginia) and the local programs and tribal agencies located within these states. The VISTAS states have jointly developed the technical analyses to define the visibility improvement by 2018 under existing federal and state regulations compared to the uniform rate of progress, sulfur dioxide (SO2) Areas of Influence for each Class I area, and methods to prioritize contributions from individual sources within the Areas of Influence. The states collectively accepted the conclusions of these analyses. In December 2006, the VISTAS State Air Directors held their first formal consultation meeting to review the modeling results and the SO2 Areas of Influence analyses. The Air Directors agreed to look at reasonable control measures for sources on the lists for the SO2 Areas of I nfluence. Each state would consider sources within their state and would identify sources in neighboring states that they would like to have that neighboring state consider. States acknowledged that the review process would differ among states since some Class I areas are projected to see visibility improvements near the uniform rate of progress while most Class I areas are projected to have greater improvements than uniform rate of progress. In May 2007, the VISTAS State Air Directors met for their second formal interstate consultation. States shared their lists of sources in their state and neighboring states for each Class I area. They also shared their criteria for listing sources and their plans for further interstate consultation. A summary of this meeting is included in this Appendix. Three Class I areas outside of Florida are potentially impacted by sources in Florida. The Okefenokee National Wilderness Area and Wolf Island National Wilderness Area are located in Southeastern Georgia and the Breton National Wilderness Area is located off the coast of Louisiana. The Florida DEP has consulted with the responsible states regarding its evaluation of visibility impairment at these Class I areas. Copies of the consultation letters or reports may be found in this Appendix.

# VISTAS Analyses for Reasonable Progress
FLM Meeting

April 25, 2007

# Presentation Objectives

 

# VISTAS Overview

 

# Contributions

 

# VISTAS 2018 modeling results

 

# Reasonable Progress Analysis

## Cold Mountain, Shining Rock Wilderness Area 

# Regional Haze Rule requires states to protect visibility in 156 “Class I” natural parks and wilderness areas.

# Areas with Poorest Visibility are similar to PM2.5 Non

- attainment Areas

# New IMPROVE Equation

 

# Endorsed by IMPROVE Steering Committee as accounting for latest science

 

# Calculated and measured light extinction (nephelometer) show good correlation

 

# Generally higher extinction on 20% worst days, lower extinction on 20% best days than original equation

### All Days

y = 0.93x + 9.16 R 2

= 0.87

0 50 100 150 200 250 300

0 50 100 150 200 250 300 24-hr Nephelometer b sp (Mm -1 )24-hr Aerosol bsp(Mm-1) 

# Aerosol Scattering vs. Nephelometer Scattering Using New or Old IMPROVE Algorithm and Daily f(RH) Great Smoky Mtns, 2000

- 2004

All Days

y = 0.70x + 17.18 R 2 = 0.89

0 50 100 150 200 250 300

0 50 100 150 200 250 300 24-hr Nephelometer b sp (Mm -1 )24-hr Aerosol bsp(Mm-1) 

# New IMPROVE Old IMPROVE

### Natural Conditions

0 10 20 30 40 50 Great Smoky Mtns NP Shenandoah NP Cape Romain W Okefenokee W Everglades NP Breton W * Left = Default Natural Conditions; Center = New IMPROVE Algorithm; Right = W20 with New IMPROVE Algorithmbext (Mm-1) Sea Salt CM Soil EC POM Am Nitr Am Sulf Rayleigh

# Great Smoky Mtns
- Glide Path to Natural Conditions (2004
- 2064)

0 5 10 15 20 25 30 351986-19901988-19921990-19941992-19961994-19981996-20001998-20022000-2004200620082010201220142016201820202022202420262028203020322034203620382040204220442046204820502052205420562058206020622064Deciviews (dv) 

### Default Glide Path New Glide Path Default 5

- yr Rolling Avg New 5

- yr Rolling Avg Ave. 20% Worst

- Default Ave. 20% Worst

- New



### Base default Base new Natural default Natural new 28.8 30.3 11.51 dv 11.3 dv

## Glide Path to Natural Conditions (2004-2064) (5-yr Rolling Average for 20% Haziest Days - New IMPROVE equation and NB II )



### 0 5 10 15 20 25 30 351986-19901988-19921990-19941992-19961994-19981996-20001998-20022000-2004200620082010201220142016201820202022202420262028203020322034203620382040204220442046204820502052205420562058206020622064Deciviews (dv) New Glide Path ROMA Default Glide Path ROMA New 5-yr Rolling Avg ROMA Default 5-yr Rolling Avg ROMA Annual g90 - New Annual g90 - Old

Base old Base new Default NB NB2 Cape Romain 25.3 26.5 11.48 dv 12.2 dv

### All Days

y = 1.18x + 0.77 R 2

= 0.86

0 50 100 150 200 250 300

0 50 100 150 200 250 300 24-hr Nephelometer b sp (Mm -1 )24-hr Aerosol bsp(Mm-1) 

# Aerosol Scattering vs. Nephelometer Scattering Using New or Old IMPROVE Algorithm and Daily f(RH) ROMA, 2004

All Days

y = 1.00x + 5.80 R 2

= 0.91

0 50 100 150 200 250 300

0 50 100 150 200 250 300 24-hr Nephelometer b sp (Mm -1 )24-hr Aerosol bsp(Mm-1)

# Average Extinction for 20% Haziest Days

New IMPROVE Algorithm 

# 2000
- 2004

0 50 100 150 200 250 300SWANROMAOKEFEVERCHASSAMADOSOSHENJARILIGOSHROGRSMCOHUSIPSMACABRIGBRETMINGHEGLUPBUCACR



### VISTAS coastal VISTAS inland non - VISTASExtinction (Mm-1) 

### Sea Salt Coarse Soil EC Organic C NH4NO3 (NH4)2SO4 Rayleigh

### GRSM1 2000-2004 Reconstructed Extinction 20% Worst Days

0 50 100 150 200 250 300 3503/85/176/36/106/287/17/87/228/58/168/198/238/2610/1510/1810/2110/2410/2711/212/115/15/76/96/126/216/277/37/127/187/217/247/308/28/58/88/118/148/178/238/269/79/139/1911/182/255/25/85/176/16/136/196/227/17/77/107/167/318/38/68/98/128/158/219/59/89/119/179/233/164/275/245/276/56/116/206/266/297/57/177/207/268/78/108/168/198/228/258/289/39/69/129/211/102/216/86/116/206/266/297/87/177/207/298/48/108/168/198/258/288/319/39/129/159/3010/310/30

2000 2001 2002 2003 2004Extinction (Mm-1) ECM ESoil ELAC EOMC EAmm_NO3 EAmm_SO4 Rayleigh

### SAMA1 2001-2004 Reconstructed Extinction New IMPROVE Algorithm 20% Worst Days

0 50 100 150 200 250 3001/221/282/122/213/115/75/135/165/256/216/247/97/127/157/308/268/299/199/2811/911/1211/1812/312/122/42/132/162/253/304/54/84/174/265/25/55/85/116/47/47/77/167/199/1710/1710/2010/2312/71/152/204/154/244/274/305/306/26/236/267/57/89/99/159/189/2410/310/610/2110/2411/81/101/131/161/221/282/183/103/134/65/65/95/126/207/268/78/199/99/249/3010/310/2110/2710/30

2001 2002 2003 2004Extinction (Mm-1) Sea Salt CM Soil LAC POM Amm NO3 Amm SO4 Rayleigh

# Average Extinction for 20% Best Days

New IMPROVE Algorithm 

# 2000
- 2004

0 10 20 30 40 50 60SWANROMAOKEFEVERCHASSAMADOSOSHENJARILIGOSHROGRSMCOHUSIPSMACABRIGBRETMINGHEGLUPBUCACR



## VISTAS coastal VISTAS inland non - VISTASExtinction (Mm-1) 

### Sea Salt CM Soil EC Organic C NH4NO3 (NH4)2SO4 Rayleigh

# Conclusions: Contributions

 

# On 20% Haziest Days

 

# SO4 dominates light extinction

 

# Organic carbon second most important

 

# mostly modern carbon, vegetative emissions

 

# fire indicated on few days

 

# NO3 contribution small

 

# SO4 also dominates 20% Best Days

 

# Conclude: Focus on reducing SO2 emissions

# VISTAS States SO2 Emissions
- 2002

Utilities Industrial On road Non road Other Utilities: 76% Industrial: 20%

96% of SO2 Emissions in the VISTAS States in 2002 from Utility and Industrial Sources 4.8 Million tons

### 250,000 125,000

25,000 Annual SO 2 

### emissions 

# SO2 Point Sources emitting > 5,000 tons per year 2002 Inventory

# Progress Energy facility in Asheville, NC

# VISTAS States SO2 Emissions

Utilities Industrial On road Non road Other 2002: 4.8 Million tons 2018: 2.2 Million tons

Utilities reduce 70% by 2018 45% 52%100 200 300 400 500 600 700 

### Miscellaneous Nonroad Onroad Industrial Other Fuel Combustion EGUAnnual SO2 (Thousand Tons) 

# 2002, 2009, 2018 Base G2 SO2 Emissions in VISTAS States

# VISTAS 2018 Base G2 Visibility Projections (Delivered Mar 2007)

 

# CMAQ Air Quality Model 2018 Run

 

# Accounts for Clean Air Interstate Rule (utility controls)

 

# Does not include controls for BART (Best Available Retrofit Technology)

 

# VISTAS states inventories as of Feb 2007

 

# Inventories for neighboring states effective Aug 2006

## New IMPROVE equation 

# Uniform Rate of Progress Glide Path (Base G2a projections) Great Smoky Mountains
- 20% Worst Days

30.28 29.01 25.85 22.69 19.53 16.37 13.20 11.31 22.87

0 5 10 15 20 25 30 35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064 

### YearHaziness Index (Deciviews)



### Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction


## Similar results for Shining Rock, Linville Gorge, Cohutta, VA, WV sites Uniform rate of progress = 4.4 dv by 2018

# 20% Haziest Days at Great Smoky Mtns

2000
- 2004 2018 Base F

# Natural Background Visibility Great Smoky Mtns

# Cape Romain
- 20% Worst Days

26.48 25.53 23.15 20.77 18.39 16.01 13.64 12.21 22.72

0 5 10 15 20 25 30 35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064 

### YearHaziness Index (Deciviews)



### Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction 

## New IMPROVE equation 

## Uniform rate of progress = 3.3 dv by 2018 

# Uniform Rate of Progress Glide Path (Base G2a projections)

### 0% 20% 40% 60% 80% 100% 120% 140% 160% 180% 200%COHUDOSOGRSMJARILIGOMACASHENSHROSIPSCHASEVEROKEFROMASAMASWANBRETBRIGCACRHEGLMINGUPBUPercent of target reduction achieved



### VISTAS non - VISTAS 

# 2018 Base G2a CMAQ Visibility Projection for 20% Worst Days

CMAQ New IMPROVE Algorithm CMAQ Old IMPROVE Algorithm

# VISTAS 2018 Base G2a (Apr 4 2007) Uniform Rate of Progress Using New IMPROVE equation



# .

. . . .

Hercules Glade, MO



# . .

Likely to meet (>110%) May meet (90

- 110%) Likely not meet (<90%)

# 2018 Base G2a CMAQ Visibility Projection for 20% Best Days

- 50%

- 40%

- 30%

- 20%

- 10%

0%
10%
20%
30%
40%
50%COHUDOSOGRSMJARILIGOMACASHENSHROSIPSCHASEVEROKEFROMASAMASWANBRETBRIGCACRHEGLMINGUPBUPercent of target reduction achieved



### VISTAS non -VISTAS CMAQ New IMPROVE Algorithm CMAQ Old IMPROVE Algorithm

# International Emissions Transport

 

# Objective: Account for contribution from international emissions in evaluating progress toward visibility improvement goals by 2018

 

# Approach: GEOS

- CHEM global model used to define boundary conditions for CMAQ 36 -km modeling for continental US

 

# Zero out Boundary Conditions, Mexican, and Canadian emissions from VISTAS 2018 CMAQ run

# Breton
- 20% Worst Days

26.00 25.08 22.80 20.52 18.23 15.95 13.67 12.30 23.36 21.62



## 0 5 10 15 20 25 30 35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064 YearHaziness Index (Deciviews)



### Glide Path Natural Condition Observation Base G Base G w/o Intl. Transport 

# Uniform Rate of Progress Glide Path (Base G2a projections)

# VISTAS Reasonable Progress Analyses

 

# Given projected 2018 emissions, what additional emissions reductions would be reasonable?

 

# Consider Source Sectors

 

# Consider Geographic Area of Influence

 

# Consider Individual Sources

# VISTAS States SO2 Emissions

Utilities Industrial On road Non road Other 2002: 4.8 Million tons 2018: 2.2 Million tons

Utilities reduce 70% by 2018 Industrial increases 10% 45% 52% 

# On Road Non Road

# VISTAS Source Sector Emissions Sensitivities (Delivered Jan 2006)

 

# Evaluated responses to emissions reductions for specific pollutants and source sectors

 

# Greatest visibility improvement from further reducing SO2 emissions from utilities and industries

# Great Smoky Mountains, TN (Worst)

- 12.00

- 10.00

- 8.00

- 6.00

- 4.00

- 2.00

0.00**∆**Bext(Mm-1) 

## Bio. Antro. BCs MRPO M- VU CEN VISTAS WV VA TN SC NC MS KY GA FL AL 

# Greatest benefits from SO2 reductions from Utilities and IndustriesVISTAS 2018 Base Case SO2 EGU Sources

51,000
25,500

5,100 

# 2018 SO2 Emissions Electric Utilities Assuming CAIR

2018 SO2

- EGU 51,000 25,550

5,100VISTAS 2018 Base Case SO2 Non-EGU Sources

51,000
25,500 5,100 

## 2018 SO2 - Industry 51,000 25,550

5,100 

# 2018 SO2 Emissions Industrial

# VISTAS SO2 Areas of Influence Analyses (2006)

 

# Use wind trajectories to define geographic areas most likely to influence Class I areas on 20% worst days in 2000

- 2004

 

# Consider SO2 emissions from EGU and non

- EGU point sources in geographic Areas of Influence

# Back Trajectories for 20% Haziest Days for 2002 Great Smoky Mtns.

# Residence Time 2000

- 2003

– 20% Worst Days: Great Smoky Mtns.

# SO2 Area of Influence for Great Smoky Mountains

Green circles indicate 100

- km and 200

- km radii from Class I area. Red line perimeter indicate Area of Influence with Residence Time > 10% Orange line perimeter indicate Area of Influence with Residence Time > 5%.

# 2018 SO2 Emissions weighted by Residence Time Great Smoky Mtn., TN

Green circles indicate 100

- km and 200

- km radii from Class I area. Red line perimeter indicate Area of Influence with Residence Time > 10%. Orange line perimeter indicate Area of Influence with Residence Time > 5%.

# .

. . .

.

. Hercules Glade, MO 

# Mountain Class I Areas

Area of Influence Groupings

• GRSM (5) 2. MACA 3. SHEN (4) 4. SIPS 5. SWAN 6. BRIG 7. MING (4)

# Back Trajectories for 20% Worst Days for 2002 Cape Romain, SC

# Residence Time for 20% Worst Days in 2000

- 2003

– Cape Romain, SC

# SO2 Area of Influence for Cape Romain, SC

Green circles indicate 100

- km and 200

- km radii from Class I area. Red line perimeter indicate Area of Influence with Residence Time > 10% Orange line perimeter indicate Area of Influence with Residence Time > 5%.

# 2018 SO2 Emissions weighted by Residence Time Cape Romain, SC

Green circles indicate 100

- km and 200

- km radii from Class I area. Red line perimeter indicate Area of Influence with Residence Time > 10%. Orange line perimeter indicate Area of Influence with Residence Time > 5%.

# .

. . .

.

. Hercules Glade, MO 

# Coastal Class I Areas

Area of Influence Groupings

• OKEF (4) 2. EVER 3. ROMA 4. SWAN 5. BRET 6. BRIG

# Reasonable Progress Analysis

 

# States consider 4 Statutory Factors to determine what controls are reasonable

 

# Costs of Compliance

 

# Time to Comply

 

# Remaining Useful Life

 

# Energy and Other Environmental and Impacts

### Tier VOC NOX CO 

## SO2 PM- 10 PM- 2.5 NH3 

## Fuel Comb. Elec. Util. 0% 22% 1% 

## 54% 11% 21% 1% 

## Fuel Comb. Industrial 1% 18% 2% 

## 30% 3% 5% 0% 

## Fuel Comb. Other 5% 6% 3% 

## 6% 5% 12% 1% 

## Chem & Allied Product 2% 0% 0% 

## 2% 1% 1% 0% 

## Metals Processing 1% 1% 2% 

## 3% 2% 5% 0% 

### Petroleum & Related Industries 0% 0% 0% 1% 0% 0% 0% 

## Other Industrial Processes 6% 5% 1% 

## 3% 8% 11% 0% 

### Solvent Utilization 44% 1% 0% 0% 0% 1% 0% 

### Storage & Transport 6% 0% 0% 0% 0% 1% 0% 

### Waste Disposal & Recycling 4% 2% 3% 0% 5% 11% 0% 

### Highway Vehicles 18% 25% 48% 0% 2% 2% 11% 

### Off

- highway 11% 18% 35% 1% 2% 4% 0% 

## Miscellaneous (e.g. Agriculture, Forest Fires) 1% 1% 5% 0% 

## 59% 26% 86% 

# Annual 2018 BaseG2 Emissions (%) Within Area of Influence Great Smoky Mountains, TN

## Tier SO2 

# Fuel Comb. Elec. Util. -Coal 54% Fuel Comb. Elec. Util.

- Oil 0% Fuel 

## Comb . Elec. Util.

- Gas 0% Fuel Comb. Elec. Util. -Other 0% Fuel Comb. Elec. Util.

- Internal Combustion 0% 

# Fuel Comb. Industrial -Coal 22% Fuel Comb. Industrial
- Oil 5% Fuel Comb. Industrial
- Gas 2% Fuel Comb. Industrial
- Other 1% Fuel Comb. Industrial

- Internal Combustion 0% 

## Fuel Comb. Other
- Commercial/Institutional Coal 2% Fuel Comb. Other
- Commercial/Institutional Oil 3% Fuel Comb. Other

- Commercial/Institutional Gas 0% Fuel Comb. Other

- Residential Wood 0% 

## Fuel Comb. Other
- Residential Other 1% 

# Annual 2018 BaseG2 Emissions (%) Within Area of Influence Great Smoky Mountains, TN

### Tier VOC NOX CO 

## SO2 PM- 10 PM- 2.5 NH3 

## Fuel Comb. Elec. Util. 0% 20% 1% 

## 46% 8% 16% 1% 

## Fuel Comb. Industrial 1% 17% 2% 

## 34% 3% 5% 0% 

## Fuel Comb. Other 4% 5% 2% 

## 6% 4% 7% 1% 

## Chemical & Allied Product Mfg 1% 1% 0% 

## 4% 1% 1% 1% 

### Metals Processing 0% 0% 0% 1% 0% 0% 0% 

### Petroleum & Related Industries 0% 0% 0% 0% 0% 0% 0% 

## Other Industrial Processes 6% 6% 1% 

## 6% 8% 9% 2% 

### Solvent Utilization 40% 0% 0% 0% 0% 0% 0% 

### Storage & Transport 7% 0% 0% 0% 0% 1% 0% 

### Waste Disposal & Recycling 4% 3% 7% 1% 7% 15% 0% 

### Highway Vehicles 19% 25% 41% 1% 1% 1% 11% 

### Off

- highway 14% 19% 32% 1% 2% 4% 0% 

### Miscellaneous 4% 3% 14% 1% 

### 65% 40% 84% 

# Annual 2018 BaseG2 Emissions (%) Within Area of Influence Cape Romain, SC

## Tier SO2 Fuel Comb. Elec. Util.
- Coal 44%
Fuel Comb. Elec. Util. -Oil 0% Fuel Comb. Elec. Util.

- Gas 0% Fuel Comb. Elec. Util.

- Other 2% Fuel Comb. Elec. Util.

- Internal Combustion 1% 

## Fuel Comb. Industrial
- Coal 21% Fuel Comb. Industrial
- Oil 9% Fuel Comb. Industrial
- Gas 2% Fuel Comb. Industrial
- Other 2% Fuel Comb. Industrial

- Internal Combustion 0% Other Industrial Processes

- Agriculture, Food, & Kindred Products 0% Other Industrial Processes

- Textiles, Leather, & Apparel Products 0% 

## Other Industrial
- Wood, Pulp & Paper, & Publishing Products 3% Other Industrial Processes

- Rubber & Miscellaneous Plastic Products 0% 

## Other Industrial Processes
- Mineral Products 3% Chemical and Allied Product Manufacturing 4% 

# Annual 2018 SO2 Emissions (%) Within Area of Influence Cape Romain, SC

# 4 Statutory Factors

 

# For Utilities and Industrial Boilers

 

# Switch to fuel with lower sulfur content

 

# Coal or Oil

 

# Post

- combustion controls

 

# Flue Gas Desulfurization

# 4 Statutory Factors (continued)

 

# Costs of Compliance

 

# Fuel switch for coal or oil

 

# May have to blend low S fuel to maintain boiler performance

 

# Price difference for lower S fuel

 

# Cost of boiler modifications for lower S fuel

 

# <$1000/ton

# 4 Statutory Factors (continued)

 

# Costs of Compliance

 

# Flue Gas Desulfurization

 

# Construction costs: absorber tower, sorbent, waste handling facility

 

# Operational and maintenance costs

 

# Costs per ton vary with boiler size, type, facility

 

# Utility costs range $1,000

- $5,000/ton

 

# Industrial costs range $3,000

- $20,000+/ton

# 4 Statutory Factors (continued)

 

# Time for Compliance

 

# 2+ years for fuel switching

 

# 3+ years for post

- combustion control (dependent on market and availability of labor and materials)

 

# Remaining Useful Life

 

# Facility specific

# 4 Statutory Factors (continued)

 

# Energy and Non

- Air Environmental Impacts

 

# Lower sulfur fuel may affect boiler operations

 

# FGD slightly reduces energy production

 

# Burn more coal per unit energy produced

 

# Increase disposal of sludge, wastewater

 

# Increase carbon emissions

 

# CO2 is released as byproduct from CaSO4 formation

#  States define sources for which 4 statutory factors will be analyzed.  VISTAS 2018 Long Term Strategy run in summer 2007  CAIR, BART, and controls for reasonable further progress 

#  States are consulting with Federal Land Managers, EPA, neighboring RPOs, public  States submit SIP December 2007 

# VISTAS 2007 Schedule

# VISTAS States SIP Development

FLM Consultation Period Jun

– Oct 2007 

## VISTAS Contractor Reports 2006

– 2007 

## Presentations to EPA, FLM, stakeholders, other states/RPOs Dec 2006

– Jun 2007



## State Defines Reasonable Progress Goal

Revised State Recommendations Consultation and Review Feb

– May 2007



## State Implementation Plans Submitted Dec 2007 Public Hearings Sept

– Nov 2007 

## VISTAS Technical Support Document May

- July 2007 

## NC Draft Technical Support Document Apr 2007



## State Documentation

For Public Hearings Sep 2007 

## VISTAS Reasonable Progress Plan Sep 2006 

## 2018 Base G2 Model Results Mar 2007 

## SO2 Areas of Influence Nov 2006



## States Define Sources to Evaluate 4 Statutory Factors Spring 2007



## States Define BART controls Spring 2007 

## Emissions Sensitivity Runs Jan

– Mar 2007



## Long Term Strategy Run Aug 2007 

## Final State RecommendationsVISIBILITY IMPROVEMENT

– STATE AND TRIBAL ASSOCIATION OF THE SOUTHEAST 526 FOREST PKWY STE F FOREST PARK GA 30297- 6140 (voice) 404- 361 -4000 (fax) 404- 361
- 2411 www .vistas-sesarm.org

AL, FL, GA, KY, MS, NC, SC, TN, VA, WV, Metro 4, Eastern Band of Cherokee Indians

VISTAS State Consultation Meeting

Atlanta, GA May 14, 2007

Objective: Under the Regional Haze Rule, Section 51.308(d)(1)(i), where a State’s emissions are reasonably anticipated to cause or contribute to visibility impairment in a Class I area located in
a nother State or States, the States are required to consult to develop coordinated emissions management strategies. The objectives of this consultation meeting were to review the VISTAS technical analyses and for each VISTAS state to share its plans for analyzing reasonable control measures and setting reasonable progress goals. This meeting is the second formal consultation between the VISTAS states. The first consultation meeting was held in December 2006 in Nashville, TN. There states discussed their expectations for
re asonable progress and the process that states would follow to define reasonable progress goals and to set long-term strategies to meet those goals.

Introduction Sheila Holman reviewed the 2009 air quality modeling results for ozone and fine particulate matter (particles with diameters less than 2.5 microns, PM2.5). Ozone and PM2.5 levels will be significantly reduced between 2002 and 2009 and most urban areas will be attaining by 2009. ASIP is prepared to assist states with remaining nonattainment areas in control strategy development. Emissions control measures for ozone and PM2.5 will improve also visibility. Pat Brewer summarized the VISTAS technical analyses that support state implementation plans (SIPs) including: Baseline and natural visibility conditions and uniform rate of progress Contribution assessment demonstrating that ammonium sulfate is the major contributor to haze in the southeastern US and indicating that SO2 emissions controls would be the most effective measures to improve visibility VISTAS state emissions inventories for 2002, 2009, and 2018. SO2 emissions from electric utilities in the VISTAS state are projected to be reduced by 70% between 2002 and 2018. VISTAS Base G2a emissions and air quality modeling results indicate visibility improvements greater than uniform rate of progress for all the VISTAS mountain Class I areas and many of the coastal Class I areas. VISTAS Base G2a modeling results agree well with CENRAP and MRPO results for border Class I areas. MANE-VU Base A results do not show as large visibility improvements as VISTAS Base G2a results for the Mid-Atlantic Class I areas, but MANE-VU Base A inventories are out of date for VISTAS, CENRAP, and MRPO. MANE-VU has updated Base B inventories for all the eastern RPOs; results of CMAQ Base B runs are expected
summ er 2007.VISTAS emissions sensitivities indicate that further SO2 reductions from electric generating

units and industrial sources would have the greatest visibility benefits, compared to other fine particle components. VISTAS emissions sensitivities also indicate that VISTAS states are major contributors to VISTAS Class I areas. MRPO, MANE-VU, and CENRAP are important source regions for Class I areas bordering these regions. VISTAS coastal sites are influenced by emissions from outside the VISTAS modeling domain (international emissions or continental emissions that have been transported over water outside the domain and are recirculated back into the domain.) VISTAS SO2 Areas of Influence demonstrate the geographic areas most likely to contribute emissions to Class I areas on 20% worst visibility days. CENRAP source attribution analyses using the CAMx regional air quality model with the PSAT source apportionment tool indicate that sources in KY and TN impact Class I areas in AR and MO. KY and TN are participating in consultation discussions with AR and MO. MANE-VU source attribution analyses using several metrics (emissions divided by distance, Q/d, and CALPUFF and REMSAD air quality models) suggest that several VISTAS states ha ve contributions greater than 1% of the total sulfate loading at Class I areas in MANE- VU states. MANE-VU states have sent letters to VISTAS states indicating their conclusion of impact and interest in a consultation meeting. Renee Shealy reviewed expectations of the Federal Land Managers for documentation in the State Implementation Plans (SIPs) and for consultation. These expectations were discussed in the meeting April 25-26 in Denver, CO with Regional Planning Organizations (RPO), Federal Land Managers (FLM) and the Environmental Protection Agency (EPA). FLM expectations have previously been presented in letters sent to all states in August 2006. The FLM letter lists expectations for establishing baseline and natural conditions, uniform rate of progress, emissions inventories, and areas of influence. VISTAS technical analyses should meet these expectations. FLM recognize state flexibility in setting reasonable progress goals and defining emissions strategies to meet those goals. FLM expect states to compare the rate of reasonable progress to the uniform rate of progress. FLM will be looking at how well the long-term strategy is supported by the technical analyses. FLM interpret that the 60-day review period does not start until FLM receive the SIP documents for review. The VISTAS meeting with FLM and EPA in June will meet the requirement for a face- to -face meeting. FLM emphasized the importance of describing the state’s plans for mid -course review in 2012 in t he SIP submitted in December 2007. The mid-course review should consider most recent visibility trends from monitoring data, emissions trends, and compare controls anticipated in the SIP with controls implementation to that point. If actual installations differ from those referenced in the SIP then a SIP revision would be appropriate. FLM will be looking for regional consistency among states, especially how reasonable progress goals and control measures are identified to address goals. The FLM will be looking for consistency in SIPs between neighboring states (RPOs).State Consultation

Each VISTAS state shared a description of the process used to rank SO2 sources in the Area of Influence for each Class I area. VISTAS states are evaluating identified sources using the four statutory factors to determine what additional control measures are reasonable for this first period of the regional haze rule. States are considering Areas of Influence for Class I areas within in the state and in neighboring states. All states started with the list of sources, 2002 and 2018 emissions, potential control measures, and costs of controls in 2005 dollars as provided by Greg Stella in November 2006. Most states ranked sources using residence time (RT) and emissions divided by distance (Q/d) from the Class I areas.
GA used a residence time for EGU greater than 5% and for non-EGU greater than 10% and looked at sources with contributions calculated by RT *Q/d greater than 0.5%. Other states considered sources with RT greater than 10%, Q/d greater than 5, and contributions calculated by RT*Q/d greater than 1%. Florida is considering additional criteria that will be easier to explain during public review: sources with SO2 emissions greater than 250 tons and within 300 km of a Class I area. Each state shared its list of top ranking SO2 sources in that state and neighboring states or described the sources on its list. Each state also described its regulatory process to develop the regional haze SIP. All states have adopted the Clean Air Interstate Rule (CAIR) and Clean Air Mercury Rule (CAMR) and plan to reference these rules in the regional haze SIP. SIPs will cite specific consent decrees, enforceable requirements, and the VISTAS Base G2 EGU inventory (based on IPM results and modified by states based on utility plans.) SIPs will allow trading under CAIR. Most states will include installed controls in Title V permits but will not list specific controls in the SIP. Some states stated that EGU controls under CAIR will be considered reasonable progress. States are considering if there is a threshold cost per ton for SO2 emissions reductions for non-EGU sources. States are consulting with their neighbors about sources in neighboring states that impact Class I areas in the host state and sources in the host state that might be impacting Class I areas in neighboring states. Each VISTAS state with a Class I area will set the reasonable progress goal for that Class I area in consultation with neighboring States. The long-term strategy will include the Base G2a controls plus BART controls and any additional control measures in the State or neighboring States. The states will continue to use the VISTAS state calls to discuss setting goals and long-term strategies.Interstate Regional Haze Meeting Summary

January 23, 2007 Point Clear, Alabama An interstate Regional Haze consultation meeting was held on January 23, 2007 in Point Clear, AL to discuss the various components of the Regional Haze SIP as it applies to th e Breton Wilderness Area, which is designated as a Class I area by the Clean Air Act. There were representatives from the coastal states of Florida, Alabama, Mississippi and Louisiana, as well as a representative from VISTAS. CENRAP representatives were not in attenda nce at this meeting. A consultation meeting will be scheduled to include representatives of EPA and the FLM responsible for Breton. Modeling was the first item for discussion on the agenda. The latest modeling runs for year 2018 show greater consistency between the RPOs results. CENRAP model results using the new IMPROVE algorithm puts Breton just below the glide slope showing that it meets approximately 95% of our reductions. The VISTAS model results show that B reton meets a little more than 80% of the reductions necessary to meet the glide slope. The most recent version of the CENRAP inventory was not available when VISTAS performed its modeling which could also account for differences in the modeling results. However, model performance in estimating 2000-2004 modeling results as they relate to actual monitoring data is very poor, allowing more uncertainty in an already uncertain process. During the discussion of the modeling results Louisiana voiced its concern with the use of substitute data from the Gulfport Monitor. We believe that the data from this monitor skews the model performance as it pertains to Breton. There are distinct differences between the geography of the area as well as the urban versus non-urban siting of the monitors. Furthermore, the monitor at Gulfport is a SEARCH monitor, not an IMPROVE monitor. According to RH guidance, data is to be derived from IMPROVE monitors. Bottom line: Louisiana has a good case for using non-substituted data. The states also discussed the impact of pollution on Breton and agreed that all modeling results show that sulfates seem to be the most pressing problem. Although CAIR is expected to provide reductions from the EGUs, it appears that non-EGUs may have to significantly reduce emissions in order for Breton to meet glide slope predictions for 2018. Louisiana representatives stated that the state is looking at methods of achieving the necessary reductions from the non-EGU components. VISTAS states are looking at this speciated component as well, be it through some form of regulation or through the permitting process. All of the states are in the process of making BART determinations. No state has constructed a draft rule. BART and reasonable further progress (RFP) seems to be a political as well as economic dilemma in the VISTAS states that were in attendance. Like Louisiana, the hurricane seasons of the past 2-3 years have wreaked havoc onindustry and its ability to make a comeback. The governments would rather suffer a little

pollution instead of losing the economic backbone of a community. There was much discussion on how to show RFP. Because Breton has the predicament of incomplete monitor data, there was a consensus that by showing the steady decline of emissions coupled with the reductions that will take place through state and national initiatives and the additional monitoring data that will be available from the Breton IMPROVE monitor, the state has fulfilled the requirements as well as can be expected. Additionally, several of the 20% worst days in the 2002 modeling year are coming from the Gulf of Mexico. VISTAS data indicates that if international emissions were taken into account, reductions projected as a result of CAIR would be sufficient to meet the uniform rate of progress in 2018. This provides further evidence that the state has fulfilled the reasonable progress goals. Louisiana also intends to use the studies compiled by Dr. Hsu which indicate that Breton does not suffer from Regional Haze, but rather from fog. This study shows that there are other mitigating factors which cause visibility impairment in and around the island chain. All meeting attendees are aware of the eroded state of the islands, however, there was no interest expressed for pursuit of a reclassification of the area either from the Department of the Interior or Congress. The group concluded the meeting by agreeing to continue these discussions via telephone. The next meeting will include representatives of EPA and the FLM.

Li st of Representatives:

Florida Tom Rogers Alabama Leigh Bacon, Tim Martin, Scott Southwick and Chris Howard Mississippi Elliott Bickerstaff, Michelle Root, and Maya Rao Louisiana James Orgeron, Patrick Pakunpanya, Yvette McGhee and Vivian Aucoin VISTAS Pat BrewerDEP Response to the Federal Land Managers:

The DEP provided a preliminary draft of the Regional Haze Plan to the Federal Land Managers (FLM) on August 27, 2009. This met the requirement for the FLMs to have at least 60 days to comment prior to final submission to the U.S. EPA. The FLM response was received by the DEP on October 26, 2009. In general, the FLMs found the draft report to be of high quality and comprehensive. However, they had a number of questions and comments to which the DEP has tried to either address in the pre-hearing draft of the Regional Haze Plan or answer here. We respond to these questions and comments in the form provided in their letter for easy reference.

Under Clarrifications

Enforceable Emission Limits in the SIP: With regard to the BART determinations and permit changes taken to meet exemption from BART, the permits and their technical determinations have been included in Exhibit 2, to be incorporated into the SIP. With regard to reasonable progress, the state has admittedly taken an administratively different path than what others have taken. While we agree that Section 308(d)(3) requires that the long-range plan include enforceable emission limitations and compliance schedules, we believe this requirement may be attained by incorporating into the SIP a process that leads to the appropriate emission limitations and compliance schedule. Florida took this alternative for state-specific reasons as explained in the draft SIP, and after consultation with the U.S. EPA regional office. Further, we believe our approach leads to at least the same, and possibly a better, affect on visibility in 2018 as would occur had we established the emission limitations prior to SIP submission. While we continue to encourage EPA to accept the state’s approach, we are open to consideration of EPA’s proposed alternative and will be working with them to satisf y their concerns.
To elaborate, EPA Region 4 has suggested that Florida could take the approach that existing programs, including CAIR , would suffice to meet the reasonable progress requirements with the addition of completing a four-factor analysis on the Smurfit-Stone facility in Fernandina Beach (the only facility on our list of sources to be addressed for the four-factor review that is not subject to CAIR). With a CAIR replacement rule on the way, this option is more attractive to the state now than it was in the past.
Finally, it should be noted that the reasonable progress goals established in the SIP (as determined through modeling) is only different from the EPA Region 4 approach by the potential additional reductions of a single source (Smurfit- St one). This single source has the least SO2 emissions of all the facilities on the RPCT list (the list defining the sources to undergo a four-factor analysis). Prevention of Significant Deterioration (PSD) Permitting Program : As suggested, w e have included a brief description in the plan of how the PSD program relates to the regional haze SIP. In short, all PSD applicants must address visibility as part of the air quality analysis. Such analysis then plays a role in making the best available control technology (BACT) determination.
Smoke Management Plan : Additional language summarizing the Florida Smoke Management Plan (SMP) has been added to section 7.2.2 Also, the SMP has been added as Appendix N.Construction Activity : As requested, w e have added some examples.

Best Available Retrofit Technology (BART) : As recommended, t he BART determination permits and their respective technical determinations have been added to the SIP as Exhibit 2, to be incorporated into the SIP.
Under the section, Specific Best Available Retrofit Technology (BART) for Florida Class I Areas
The FLM raises the question about the whether the maintenance operations at the Smurfit-Stone Panama City and Fernandina Beach plants should be used in determining their maximum impacts for exemption purposes. The DEP asked that the company quantify the impacts during maintenance operations, however we concluded that these emissions should not be used for the purpose of determining the exemption. The reason is that the BART rule (Appendix Y to 40 CFR 60 Part 51) clearly states that the emission estimates used in the models are intended to reflect steady-state operating conditions during periods of high capacity utilization. During these maintenance operations, the company is neither operating in steady-state, nor in a state of high capacity utilization.
With regard to the comment about compliance dates for facilities that received permit modifications to meet the exemption, we will need to work with the U.S. EPA regional office to work through th e flexibility they have in accepting these compliance dates.
Specific Comments on the BART Determinations
PCS White Springs Agricultural Chemicals, Inc. : In setting the BART emissions levels the DEP considered recent Best Available Control Technology (BACT) reviews. BACT determinations are the top-level control for new and modified sources, and DEP considers BACT to be a more rigorous determination than BART. As such, DEP was hesitant to require additional controls beyond what has recently been determined as BACT. A BART source meeting current BACT emission limits is considered to be meeting BART. The use of cesium catalyst and installation of additional beds will be considered in future BACT determinations.
Florida Power and Light (FPL) Turkey Point : T he final determination to accept the 0.7% sulfur oil use, to provide a better visibility benefit than what could have been achieved considering particulate control only, was considered by DEP to be a better than BART outcome. Since this source is covered by CAIR, only particulate emissions were necessary to be evaluated. Pushing the company to even lower sulfur fuel oil was not acceptable to the company and would have potentially led to less visibility improvement had the company not agreed to the cleaner fuel oil. Also, the DEP is cognizant of the fact that fuel oil is becoming a less desirable fuel option (costly and dirty), and while not explained in the BART determination, FPL is currently constructing new natural gas combined cycle units at the Turkey Pointfacility and at other sites. These newer, more efficient units will likely displace some or all of the oilfired boiler energy production.
The reference to additional documents referred to in the write-up was an error (resulting from some copy and pasting from other documents) and has been removed.City of Tallahassee Purdom : The federally enforceable construction permit that requires the shut-down

of this unit has been included in Exhibit 2, to be incorporated into the SIP.
Progress Energy Crystal River : The shut-down (or repowering) of the units 1 and 2 by December 31, 2020 is only federally enforceable if the proposed new nuclear facility (Levy County units 1 and 2) is operational. The Levy County nuclear units have been certified for construction by the state but still have to receive federal approval. In any case, the proposed regional haze SIP does not rely on units 1 and 2 being shut-down. Both units are included in the 2018 best and final modeling run and considered in the reasonable progress goal.