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 review comments 

letter. 

Appendix J 

Regional Haze SIP for Florida

Page 1 of 89
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 

Influence. 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. 

Appendix J 

Regional Haze SIP for Florida

Page 2 of 89
VISTAS

Analyses for

Reasonable 

Progress

FLM Meeting

April 25, 2007

Appendix J 

Regional Haze SIP for Florida

Page 3 of 89
Presentation Objectives

 VISTAS Overview

 Contributions

 VISTAS 2018 modeling results

 Reasonable Progress Analysis

Appendix J 

Regional Haze SIP for Florida

Page 4 of 89
Cold Mountain, Shining Rock Wilderness Area

Regional Haze Rule requires states to protect visibility 

in 156 “Class I” natural parks and wilderness areas.

Appendix J 

Regional Haze SIP for Florida

Page 5 of 89
Areas with Poorest Visibility are similar to PM2.5 Non-attainment Areas

Appendix J 

Regional Haze SIP for Florida

Page 6 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 7 of 89
All Days

y = 0.93x + 9.16

R2

 = 0.87

0

50

100

150

200

250

300

0 50 100 150 200 250 300

24-hr Nephelometer bsp (Mm-1)

24-hr Aerosol b sp (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

R2

 = 0.89

0

50

100

150

200

250

300

0 50 100 150 200 250 300

24-hr Nephelometer bsp (Mm-1)

24-hr Aerosol b sp (Mm-1)

New IMPROVE Old IMPROVE

Appendix J 

Regional Haze SIP for Florida

Page 8 of 89
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 Algorithm

bext (Mm-1)

Sea Salt

CM

Soil

EC

POM

Am Nitr

Am Sulf

Rayleigh

Appendix J 

Regional Haze SIP for Florida

Page 9 of 89
Great Smoky Mtns - Glide Path to Natural Conditions (2004-2064)

0

5

10

15

20

25

30

35

1986-19901988-19921990-19941992-19961994-19981996-20001998-20022000-2004

200620082010201220142016201820202022202420262028203020322034203620382040204220442046204820502052205420562058206020622064

Deciviews (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

Appendix J 

Regional Haze SIP for Florida

Page 10 of 89
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

35

1986-19901988-19921990-19941992-19961994-19981996-20001998-20022000-2004

200620082010201220142016201820202022202420262028203020322034203620382040204220442046204820502052205420562058206020622064

Deciviews (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

Appendix J 

Regional Haze SIP for Florida

Page 11 of 89
All Days

y = 1.18x + 0.77

R2

 = 0.86

0

50

100

150

200

250

300

0 50 100 150 200 250 300

24-hr Nephelometer bsp (Mm-1)

24-hr Aerosol b sp (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

R2

 = 0.91

0

50

100

150

200

250

300

0 50 100 150 200 250 300

24-hr Nephelometer bsp (Mm-1)

24-hr Aerosol b sp (Mm-1)

Appendix J 

Regional Haze SIP for Florida

Page 12 of 89
Average Extinction for 20% Haziest Days

New IMPROVE Algorithm 

2000-2004

0

50

100

150

200

250

300

SWAN

ROMA

OKEF

EVER

CHAS

SAMADOSO

SHEN

JARI

LIGO

SHRO

GRSM

COHU

SIPS

MACA

BRIG

BRET

MING

HEGLUPBU

CACR

VISTAS coastal VISTAS inland non-VISTAS

Extinction (Mm -1)

Sea Salt

Coarse

Soil

EC

Organic C

NH4NO3

(NH4)2SO4

Rayleigh

Appendix J 

Regional Haze SIP for Florida

Page 13 of 89
GRSM1

2000-2004 Reconstructed Extinction

20% Worst Days

0

50

100

150

200

250

300

350

3/8 5/17 6/3 6/10 6/28 7/1 7/8 7/22 8/5 8/16 8/19 8/23 8/26 10/15 10/18 10/21 10/24 10/27 11/2 12/11 5/1 5/7 6/9 6/12 6/21 6/27 7/3 7/12 7/18 7/21 7/24 7/30 8/2 8/5 8/8 8/11 8/14 8/17 8/23 8/26 9/7 9/13 9/19 11/18 2/25 5/2 5/8 5/17 6/1 6/13 6/19 6/22 7/1 7/7 7/10 7/16 7/31 8/3 8/6 8/9 8/12 8/15 8/21 9/5 9/8 9/11 9/17 9/23 3/16 4/27 5/24 5/27 6/5 6/11 6/20 6/26 6/29 7/5 7/17 7/20 7/26 8/7 8/10 8/16 8/19 8/22 8/25 8/28 9/3 9/6 9/12 9/21 1/10 2/21 6/8 6/11 6/20 6/26 6/29 7/8 7/17 7/20 7/29 8/4 8/10 8/16 8/19 8/25 8/28 8/31 9/3 9/12 9/15 9/30 10/3 10/30

2000 2001 2002 2003 2004

Extinction (Mm -1)

ECM

ESoil

ELAC

EOMC

EAmm_NO3

EAmm_SO4

Rayleigh

Appendix J 

Regional Haze SIP for Florida

Page 14 of 89
SAMA1

2001-2004 Reconstructed Extinction

New IMPROVE Algorithm

20% Worst Days

0

50

100

150

200

250

300

1/221/282/122/213/11

5/7

5/135/165/256/216/24

7/9

7/127/157/308/268/299/199/2811/9

11/1211/18

12/3

12/12

2/4

2/132/162/253/30

4/54/8

4/174/26

5/25/55/8

5/11

6/47/47/7

7/167/199/17

10/1710/2010/23

12/71/152/204/154/244/274/305/30

6/2

6/236/26

7/57/89/9

9/159/189/2410/310/6

10/2110/24

11/81/101/131/161/221/282/183/103/13

4/65/65/9

5/126/207/26

8/7

8/19

9/9

9/249/3010/3

10/2110/2710/30

2001 2002 2003 2004

Extinction (Mm-1)

Sea Salt

CM

Soil

LAC

POM

Amm NO3

Amm SO4

Rayleigh

Appendix J 

Regional Haze SIP for Florida

Page 15 of 89
Average Extinction for 20% Best Days

New IMPROVE Algorithm

2000-2004

0

10

20

30

40

50

60

SWAN

ROMA

OKEF

EVER

CHAS

SAMADOSO

SHEN

JARI

LIGO

SHRO

GRSM

COHU

SIPS

MACA

BRIG

BRET

MING

HEGL

UPBU

CACR

VISTAS coastal VISTAS inland non-VISTAS

Extinction (Mm-1)

Sea Salt

CM

Soil

EC

Organic C

NH4NO3

(NH4)2SO4

Rayleigh

Appendix J 

Regional Haze SIP for Florida

Page 16 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 17 of 89
VISTAS States SO2 Emissions - 2002 

Utilities

Industrial

On road

Non road

Other

Industrial: 20% Utilities: 76%

96% of SO2 Emissions in the VISTAS States in 2002 

from Utility and Industrial Sources

4.8 Million tons

Appendix J 

Regional Haze SIP for Florida

Page 18 of 89
250,000

125,000

25,000

Annual SO2 emissions

SO2 Point Sources emitting > 5,000 tons per year

2002 Inventory

Appendix J 

Regional Haze SIP for Florida

Page 19 of 89
Appendix J 

Progress Energy facility in Asheville, NC

Regional Haze SIP for Florida

Page 20 of 89
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%

Appendix J 

Regional Haze SIP for Florida

Page 21 of 89
100

200

300

400

500

600

700

Miscellaneous

Nonroad

Onroad

Industrial

Other Fuel Combustion

EGU

Annual SO2 (Thousand Tons)

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

Appendix J 

Regional Haze SIP for Florida

Page 22 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 23 of 89
New IMPROVE equation

Uniform Rate of Progress Glide Path (Base G2a projections)

Great Smoky Mountains - 20% Worst Days

30.2829.01

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

Year

Haziness 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

Appendix J 

Regional Haze SIP for Florida

Page 24 of 89
20% Haziest Days at Great Smoky Mtns

2000-2004 2018 Base F

Appendix J 

Regional Haze SIP for Florida

Page 25 of 89
Natural Background Visibility Great Smoky Mtns

Appendix J 

Regional Haze SIP for Florida

Page 26 of 89
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

Year

Haziness 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)

Appendix J 

Regional Haze SIP for Florida

Page 27 of 89
0%

20%

40%

60%

80%

100%

120%

140%

160%

180%

200%

COHU

DOSO

GRSM

JARI

LIGO

MACA

SHEN

SHRO

SIPS

CHAS

EVER

OKEF

ROMA

SAMA

SWAN

BRET

BRIG

CACR

HEGL

MING

UPBU

Percent 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

Appendix J 

Regional Haze SIP for Florida

Page 28 of 89
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%)

Appendix J 

Regional Haze SIP for Florida

Page 29 of 89
2018 Base G2a CMAQ Visibility Projection for 20% Best Days

-50%

-40%

-30%

-20%

-10%

0%

10%

20%

30%

40%

50%

COHU

DOSO

GRSM

JARI

LIGO

MACASHEN

SHRO

SIPS

CHAS

EVER

OKEF

ROMA

SAMA

SWAN

BRET

BRIG

CACR

HEGL

MING

UPBU

Percent of target reduction achieved

VISTAS non-VISTAS

CMAQ New IMPROVE Algorithm

CMAQ Old IMPROVE Algorithm

Appendix J 

Regional Haze SIP for Florida

Page 30 of 89
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 

Appendix J 

Regional Haze SIP for Florida

Page 31 of 89
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

Year

Haziness Index (Deciviews)

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

Uniform Rate of Progress Glide Path (Base G2a projections)

Appendix J 

Regional Haze SIP for Florida

Page 32 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 33 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 34 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 35 of 89
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 Industries

Appendix J 

Regional Haze SIP for Florida

Page 36 of 89
VISTAS 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

5,100

Appendix J 

Regional Haze SIP for Florida

Page 37 of 89
VISTAS 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

Appendix J 

Regional Haze SIP for Florida

Page 38 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 39 of 89
Back Trajectories for 20% Haziest Days for 2002

Great Smoky Mtns.

Appendix J 

Regional Haze SIP for Florida

Page 40 of 89
Residence Time 2000-2003 – 20% Worst Days: Great Smoky Mtns.

Appendix J 

Regional Haze SIP for Florida

Page 41 of 89
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%.

Appendix J 

Regional Haze SIP for Florida

Page 42 of 89
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 

Appendix J 

> 5%.

Regional Haze SIP for Florida

Page 43 of 89
.

.

.

.

.

.

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)

Appendix J 

Regional Haze SIP for Florida

Page 44 of 89
Back Trajectories for 20% Worst Days for 2002

Cape Romain, SC

Appendix J 

Regional Haze SIP for Florida

Page 45 of 89
Residence Time for 20% Worst Days in 2000-2003 – Cape Romain, SC

Appendix J 

Regional Haze SIP for Florida

Page 46 of 89
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%.

Appendix J 

Regional Haze SIP for Florida

Page 47 of 89
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%.

Appendix J 

Regional Haze SIP for Florida

Page 48 of 89
.

.

.

.

.

.

Hercules 

Glade, MO

Coastal Class I Areas

Area of Influence

Groupings 

• OKEF (4)

2. EVER 

3. ROMA

4. SWAN

5. BRET

6. BRIG

Appendix J 

Regional Haze SIP for Florida

Page 49 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 50 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 51 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 52 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 53 of 89
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

Appendix J 

Regional Haze SIP for Florida

Page 54 of 89
4 Statutory Factors

 For Utilities and Industrial Boilers

 Switch to fuel with lower sulfur content

 Coal or Oil

 Post-combustion controls

 Flue Gas Desulfurization

Appendix J 

Regional Haze SIP for Florida

Page 55 of 89
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

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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

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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

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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 

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 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

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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 Recommendations

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 VISIBILITY 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 

another 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 

reasonable 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 

summer 2007. 

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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 

have 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 the 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). 

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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. 

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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 the 

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 attendance 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 

Breton 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 on 

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industry 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. 

List 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 Brewer 

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DEP 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 satisfy 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-Stone). 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, we 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. 

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Construction Activity: As requested, we have added some examples. 

Best Available Retrofit Technology (BART): As recommended, the 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 the 

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: The 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 Point 

facility 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. 

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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. 

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