# Appendix 1.2

EPA Checklist for Regional Haze SIPs Submitted Unde r

40 CFR 51.308EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/04/06Purpose:This checklist has been prepared by EPA staff to use in reviewing regional haze SIPs to ensure that the SIPs have the necessary components. Thechecklist represents our best efforts to summarizethe requirements of the regional haze rule but it is not a regulation and does not change orsubstitute for any legal requirements in the CleanAir Act (CAA) or the regional haze rule. Any decisions regarding the completeness of a particularSIP will be made based on the CAA and the relevantregulations. Therefore, interested parties are free to raise questions and objections to thechecklist and its use in a particular situation.Acronyms and Terms:BART is Best Available Retrofit TechnologyCAA is the Clean Air ActCAIR is Clean Air Interstate RuleEI is Emissions InventoryFLM is Federal Land ManagerGlidepath is the linear rate of improvement sufficient to attain natural conditions by 2064LTS is Long Term StrategyRAVI is Reasonably Attributable Visibility ImpairmentRHR is the Regional Haze RuleRPO is Regional Planning OrganizationRPG is Reasonable Progress GoalNotes:1. This checklist is based on Appendix V to 40 CFRPart 51, and 40 CFR 51.308, as updated by the BARTRule (70 FR 39104, July 6,2005), and the trading rule, as proposed in 70 FR 44154, August 1, 2005. This checklist will be revised if necessary, should that benecessitated by the final version of the trading rule.2. All boxes should either be “Y” or “N/A” or the SIP may be deficient.3. This checklist assumes the State will not be participating in a trading program, or other alternative measure to BART. If this is not thecase, then additional/alternative regulations thatappear in 51.308(e)(2) and (3) apply.4. Only the requirements from 51.308 pertaining tothecurrentRH SIP submission, and not those pertaining to future revisions and/orreports required under 51.308(f), (g), and (h) (except for a SIP commitment to do them), were included.EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/0625. The “1999 RHR” is 64 FR 35714, July 1, 1999.6.The “2005 BART Rule” is 70 FR 39104, July 6, 2005.7.The “BART Guidelines” isAppendix Y to Part 51—Guidelines for BART Determinations Under the Regional Haze Rule, 70 FR39104, July 6, 2005.8.The “Tracking Guidance” is theGuidance for Tracking Progress Under the Regional Haze Rule, EPA-454/B-03-004, September,2003.9.The “Attainment Guidance” is theDraft Guidance for Demonstrating Attainment of AirQuality Goals for PM2.5 and Regional Haze,January 2, 2001.10.The “Natural Visibility Guidance” is theGuidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA454/B-03-005, September 2003.11.The “Baseline Memo” is a memo,2002 Base Year Emission Inventory SIP Planning: 8-Hour Ozone, PM2.5 and Regional HazePrograms, dated 11/18/2002, from Lydia Wegman to the Regional Air Directors.12.The “draft RPG Guidance” is theDraft Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, datedNovember 28, 2005.13.The “Visibility Monitoring Guidance” is VisibilityMonitoring Guidance, EPA-454/R-99-003, June 1999.14.The “EI Guidance” is theEmissions Inventory Guidance for Implementation ofOzone and Particulate Matter National Ambient AirQuality Standards (NAAQS) and Regional Haze Regulations, EPA-454/R-05-001, dated August, 2005.15.The “Interim Fire Policy” is theInterim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998.* Requirements that do not apply to States withoutClass I areas are denoted by an asterisk.EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/063SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferences

Y / N or N/AAdministrative Requirements from Appendix V to Part51Y2.1(a)Has a letter of submittal from the governor / designee,requesting EPA approval of the SIP been received?Pg 6Y2.1(b)Has the State provided evidence it has adopted thelegallyenforceable portions of the plan in the State codeor body ofregulations; or issued the necessary permits, orders, consentagreements in final form?Appendix 9.7Y2.1(c)Has the State provided evidence it has the necessary legalauthority under State law to adopt and implement the plan?Appendix 2.1Y2.1(d)Has the official State regulation /document beensigned/stamped/dated by the appropriate State officialindicating that it is fully enforceable by the State?PrefaceY2.1(e)Has the State provided evidence it followed all oftheprocedural requirements of the State’s laws and constitutionin the adoption/issuance of the plan?Appendix 2.1Y2.1(f)Has the State provided evidence that public noticewasgiven of the proposed change consistent with proceduresapproved by EPA, including the date of publicationof suchnotice?Appendix 2.1Y2.1(g)Has the State provided a certification that publichearings(s)were held in accordance with the information provided inthe public notice and the State’s laws and constitution, ifapplicable?Appendix 2.1EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/064SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesY2.1(h)Has the State provided a compilation of public commentsand the State’s response thereto?Appendix 2.1Technical Requirements from 40 CFR 51.308N(b) Was the SIP submitted no later than December 17, 2007?Y(d)Did the State provide a table identifying each mandatoryClass I Federal area located within the State and in eachmandatory Class I Federal area located outside theStateaffected by emissions from within the State?1.2$Visibility Monitoring GuidanceNA*(d)(1)Did the State establish RPGs for each Class I areathatprovide for an improvement in visibility for the mostimpaired days over the period of the SIP, and ensure nodegradation in visibility for the least impaired days over thesame period?$p. 35730 of the 1999 RHR$p. 1-6 of the Tracking Guidance$Attainment Guidance$draft RPG GuidanceNA*(d)(1)(i)(A)In establishing RPGs for each Class I area, did theStateconsider the costs of compliance, the time necessary forcompliance, the energy and non-air quality environmentalimpacts of compliance, and the remaining useful life of anypotentially affected sources, and include a demonstrationshowing how these factors were taken into consideration inselecting the goal?$p. 35731-33 of the 1999 RHR$draft RPG GuidanceNA*(d)(1)(i)(B)Did the State submit the glidepath (i.e., rate of progressneeded to attain natural visibility conditions by 2064) foreach Class I area?$p. 35727-33, 35 of the 1999 RHR$Natural Visibility Guidance$p. 39124, 39143 of the 2005 BART rule$The Baseline MemoEPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/065SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesNA*(d)(1)(i)(B)In establishing the RPG for each Class I area, didthe Statecalculate the uniform rate of improvement in visibility andthe emission reduction measures needed to achieve it for theperiod covered by the SIP?$p. 35732 of the 1999 RHR$draft RPG GuidanceNA*(d)(1)(ii)If the State establishes a RPG < the glidepath, hasitdemonstrated, based on the factors in (d)(1)(i)(A),the rateof progress for the SIP to attain natural conditions by 2064is not reasonable, and its RPG is reasonable?$p. 35732 of the 1999 RHRNA*(d)(1)(ii)If the State establishes a RPG < the glidepath, didit provideto the public for review as part of its SIP, an assessment ofthe number of years it would take to attain naturalconditions using its RPG?$p. 35732 of the 1999 RHRY(d)(1)(iv)In developing its RPG, has the State consulted withthoseStates that may reasonably be anticipated to causeorcontribute to visibility impairment in the Class Iareas?Chapter 11$p. 35735 of the 1999 RHRNA(d)(1)(iv)If the State cannot agree with another State(s) that a goalprovides for reasonable progress, has the State described inits submittal the actions taken to resolve the disagreement?$p. 35732 of the 1999 RHRNA*(d)(1)(vi)Has the State adopted RPGs that represents at leastthevisibility improvement expected from implementationofother CAA programs during the applicable planning period?$p. 35733 of the 1999 RHRNA*(d)(2)(i)Has the State calculated baseline visibility conditions foreach Class I area for the most impaired and least impaireddays using 2000 to 2004 monitoring data?$p. 35728-30 of the 1999 RHR$Natural Visibility Guidance$Attainment Guidance$Tracking GuidanceEPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/066SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesNA*(d)(2)(i)In calculating the baseline visibility conditions,did the Stateestimate the average degree of visibility impairment for themost and least impaired days for each calendar yearfrom2000 to 2004, and then determine the average of theseannual values?NA*(d)(2)(i)If the State has Class I areas without onsite monitoring datafor 2000 - 2004, did the State use the most representativeavailable monitoring data for 2000 - 2004 to establishbaseline values, in consultation with the EPA RegionalOffice?$p. 35728-29 of the 1999 RHR$Visibility Monitoring GuidanceNA*(d)(2)(iii)Did the State calculate natural visibility conditions for themost impaired and least impaired days by estimatingthedegree of impairment based on available monitoringinformation and appropriate data analysis techniques?$p. 35764, 35729-30 of the 1999 RHR$Natural Visibility GuidanceNA*(d)(2)(iv)ADid the State calculate the number of deciviews bywhichbaseline conditions exceed natural visibility conditions forthe most impaired and least impaired days for the firstplanning period?$p. 35732 of the 1999 RHRY(d)(3)Did the State submit a LTS that addresses visibilityimpairment for each Class I area, inside and outside theState, which may be affected by the State’s emissions?Chapter 10$p. 35734-35 of the 1999 RHRY(d)(3)Does the LTS include enforceable emissions limitations,compliance schedules, and other measures as necessary toachieve the RPGs established by States having ClassIareas?10.4&Appendix 9.7$p. 35734-35 of the 1999 RHREPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/067SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesY(d)(3)(i)In establishing its LTS, did the State consult withotherState(s) to develop coordinated emission managementstrategies for cases in which it has emissions thatarereasonably anticipated to contribute to visibilityimpairmentin any Class I area located in those State(s)?Chapter 11$p. 35735 of the 1999 RHRNA(d)(3)(i)In establishing its LTS, did the State consult withotherState(s) to develop coordinated emission managementstrategies for cases in which those State(s) have emissionsthat are reasonably anticipated to contribute to visibilityimpairment in any Class I area located within the State?Y(d)(3)(ii)In establishing its LTS, where multiple State(s) cause orcontribute to impairment of the same Class I area,did theState include all measures necessary to obtain itsshare ofthe emission reductions needed to meet the RPG forthearea?Chapter 10$p. 35735 of the 1999 RHRY(d)(3)(ii)In addressing (d)(3)(ii), above, if the State participated in aRPO, did it ensure it included all measures neededtoachieve its apportionment of emission reduction obligationsagreed upon through that process?Chapter 10$p. 35735 of the 1999 RHRY(d)(3)(iii)In establishing its LTS, did the State document thetechnicalbasis, including modeling, monitoring and emissionsinformation, on which it is relying to determine itsapportionment of emission reduction obligations necessaryfor achieving reasonable progress in each Class I area itaffects?Chapter 10$p. 35735 of the 1999 RHR$EI GuidanceEPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/068SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesY(d)(3)(iii)In addressing (d)(3)(iii), above, did the State identify thebaseline emissions inventory on which its strategies arebased?10.4.1.1$p. 35728 of the 1999 RHR$Baseline Memo$EI GuidanceY(d)(3)(iv)Did the State identify all anthropogenic sources ofvisibilityimpairment considered by it in developing its LTS,including consideration of major and minor stationarysources, mobile sources, and area sources?10.4.2$p. 35735 of the 1999 RHR$EI GuidanceY(d)(3)(v)(A)In developing its LTS, did the State consider the emissionreductions due to ongoing air pollution control programs,including measures to address RAVI?10.4.3.1$p. 35737 of the 1999 RHRY(d)(3)(v)(B)In developing its LTS, did the State consider measures tomitigate the impacts of construction activities?10.4.3.2$p. 35737 of the 1999 RHRY(d)(3)(v)(C)In developing its LTS, did the State consider emissionslimitations and schedules for compliance to achievethereasonable progress goal?10.4.3.3$p. 35737 of the 1999 RHRY(d)(3)(v)(D)In developing its LTS, did the State consider sourceretirement and replacement schedules?10.4.3.4$p. 35737 of the 1999 RHRY(d)(3)(v)(E)In developing its LTS, did the State consider smokemanagement techniques for agricultural and forestrymanagement purposes, including plans as currently existwithin the State for these purposes?10.4.3.5$p. 35736 of the 1999 RHR$Interim Fire PolicyY(d)(3)(v)(F)In developing its LTS, did the State consider enforceabilityof emissions limitations and control measures?10.4.3.6$p. 35737 of the 1999 RHREPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/069SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesY(d)(3)(v)(G)In developing its LTS, did the State consider the anticipatednet effect on visibility due to projected changes in point,area, and mobile source emissions over the period addressedby the LTS?10.4.3.7$p. 35737 of the 1999 RHRNA*(d)(4)Did the State submit with the SIP a monitoring strategy formeasuring, characterizing, and reporting of regional hazevisibility impairment representative of all Class Iareaswithin the State?$p. 35744 of the 1999 RHR$Attainment Guidance$Tracking Guidance$Visibility Monitoring GuidanceNA*(d)(4)Did the State coordinate the above monitoring strategy withthe RAVI monitoring strategy in § 51.305?$p. 35717, 37, of the 1999 RHRNA*(d)(4)(i)Did the SIP provide for the establishment of any additionalmonitoring sites or equipment needed to assess whetherRPGs to address regional haze for all Class I areaswithinthe State are being achieved?$p. 35744 of the 1999 RHR$Attainment Guidance$Tracking Guidance$Visibility Monitoring GuidanceNA*(d)(4)(ii)Did the SIP establish procedures by which monitoring dataand other information are used in determining thecontribution of emissions from within the State toregionalhaze visibility impairment at Class I areas both within andoutside the State?$p. 35744 of the 1999 RHR$Attainment Guidance$Tracking Guidance$Visibility Monitoring GuidanceY(d)(4)(iii)For a State with no Class I areas, did the SIP establishprocedures by which monitoring data and other informationare used in determining the contribution of emissions fromwithin the State to regional haze visibility impairment atClass I areas in other States?Chapter 10$p. 35744 of the 1999 RHR$Attainment Guidance$Tracking Guidance$Visibility Monitoring GuidanceEPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/0610SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesNA*(d)(4)(iv)Did the SIP provide for the reporting of all visibilitymonitoring data to EPA at least annually for each Class Iarea in the State?$p. 35744-45 of the 1999 RHR$Visibility Monitoring GuidanceY(d)(4)(v)Did the SIP include a statewide EI of pollutants that arereasonably anticipated to cause or contribute to visibilityimpairment in any Class I area?Appendix 7.1$Attainment GuidanceY(d)(4)(v)Did the EI include emissions for a baseline year, emissionsfor the most recent year for which data are available, andestimates of future projected emissions?Appendix 7.1&Appendix 7.2$p. 35728-29 of the 1999 RHR$Visibility Monitoring Guidance$Attainment GuidanceY(d)(4)(v)Did the SIP include a commitment to update the EIperiodically?7.7$EI GuidanceY(d)(4)(vi)Did the SIP include other elements necessary to assess andreport on visibility (e.g., reporting, recordkeeping, etc.)?7.7Y(e)Did the State submit a SIP containing emission limitationsrepresenting BART, and schedules for compliance withBART, for each BART eligible source that may reasonablybe anticipated to cause or contribute to any impairment ofvisibility in any Class I area?Appendix 9.7$BART GuidelinesY(e)(1)(i)Did the SIP include a list of all BART-eligible sourceswithin the State with supporting documentation?9.1$BART GuidelinesEPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/0611SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesY(e)(1)(ii)Did the SIP include a determination of BART for eachBART-eligible source in the State that emits any airpollutant which may reasonably be anticipated to cause orcontribute to any impairment of visibility in any Class Iarea?9.3$BART GuidelinesY(e)(1)(ii)(A)Did the SIP include a determination of BART based on ananalysis of the best system of continuous emissioncontroltechnology available, and associated emission reductionsachievable for each source subject to BART within theState?9.3$BART GuidelinesY(e)(1)(ii)(A)In the BART analysis, did the State take into considerationthe technology available, the costs of compliance,theenergy and nonair quality environmental impacts ofcompliance, any pollution control equipment in useat thesource, the remaining useful life of the source, and thedegree of improvement in visibility which may reasonablybe anticipated to result from the use of such technology?Appendix 9.5-9.8$BART Guidelines$p 39107, 127 of the 2005 BART RuleY(e)(1)(ii)(B)Did the State determine BART for fossil-fuel firedpowerplants > 750 megawatts pursuant to the BART guidelines?9.3$BART Guidelines$p 39108 of the 2005 BART RuleEPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/0612SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesNA(e)(1)(iii)If the State has determined that technological or economiclimitations on the applicability of measurementmethodology to a particular source would make theimposition of an emission standard infeasible, hasthe Stateprescribed a design, equipment, work practice, or otheroperational standard, to require the application ofBART, asan alternative to a BART emission standard?$BART GuidelinesNA(e)(1)(iii)If the State adopted a design, equipment, work practice, orother operational standard alternative to BART, didtheState, to the degree possible, set forth the emissionreduction to be achieved, and provide for compliance bymeans which achieve equivalent results?$BART Guidelines$p 39172 of the 2005 BART RuleY(e)(1)(iv)Has the State required each source subject to BARTtoinstall and operate BART as expeditiously as practicable,but no later than 5 years after approval of the SIP?9.3&Appendix 9.7$p 39158, 70, 72 of the 2005 BART RuleY(e)(1)(v)Has the State required each BART source to maintaintherequired control equipment and establish procedurestoensure such equipment is properly operated and maintained?9.3&Appendix 9.7$p 39172 of the 2005 BART RuleNA(e)(4)If the State is using its participation in CAIR toexemptBART-eligible EGU’s from BART, has it includedsupporting documentation?$p 39136-42 of the 2005 BART RuleEPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/0613SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesNA(e)(4)If the State is using its participation in CAIR toexemptBART-eligible EGU’s from BART, did it includeprovisions for a geographic enhancement to the program toaddress RAVI BART under § 51.302(c)?$p 39143, 57 of the 2005 BART RuleNA(e)(6)If a facility is seeking an exemption under §51.303(a)(2)–(h) for any of its BART-eligible emission units, has theappropriate documentation been included in the SIP?$§51.303(a)(2)–(h)Y(f)Has the State included a commitment it will submitits SIPrevision, as specified in 51.308(f),by July 31, 2018,andevery ten years thereafter?Chapter 12$p 35745 of the 1999 RHR$Section 110(a)(2)(H) of the CAAY(g)Has the State included a commitment it will submitits SIPreport, as specified in 51.308(g),by an exact date named,that is within 5 years from submittal of the initial SIP?Chapter 12$p 35745 of the 1999 RHR$Section 110(a)(2)(F) of the CAAY(h)Has the State included a commitment it will, at thetime ofthe submission of the SIP report, also submit adetermination of the adequacy of its existing Regional HazeSIP revision, as specified in 51.308(h)?Chapter 13$p 35745 of the 1999 RHR$Section 110(a)(2)(F) of the CAAY(i)(1)(i)-(ii)Did the State, by November 29, 1999, identify in writing tothe FLMs the title of the official to which any FLMcansubmit recommendations on the implementation 51.308including, (i) identification of impairment of visibility inany Class I area(s); and (ii) identification of elements forinclusion in the visibility monitoring strategy required by§51.305 and 51.308?Chapter 4$p. 35747-48 of the 1999 RHREPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.3088/4/0614SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR 51.308RegulationCitationRegulation Summary (not verbatim)Locationin SIPReferencesY(i)(2)Did the State provide the FLM an opportunity forconsultation, in person and at least 60 days priorto holdingany public hearing on the SIP (or its revision)?Chapter 4$p. 35747-48 of the 1999 RHRY(i)(2)(i)-(ii)Did the above consultation include the opportunityfor theFLMs to discuss their: (i) assessment of impairmentofvisibility in any Class I area; and, (ii) recommendations onthe development of the RPG and on the development andimplementation of strategies to address visibilityimpairment?Chapter 4$p. 35747-48 of the 1999 RHRY(i)(3)Did the State include in the SIP a description of how itaddressed any comments provided by the FLMs?Chapter 4$p. 35747-48 of the 1999 RHRY(i)(4)Does the SIP provide procedures for continuing consultationbetween the State and FLMs on the implementation of51.308, including development and review of SIP revisionsand 5-year progress reports, and on the implementation ofother programs having the potential to contribute toimpairment of visibility in Class I areas?Chapter 4$p. 35747-48 of the 1999 RHR