Appendix J 

Consultation Process 
Appendix J – Consultation Process 

• J.1 - Breton January 23, 2007 meeting summary 

• J.2 - VISTAS state consultation meeting May 14, 2007 

• J.3 – Summary VISTAS consultation meeting June 12, 2007 

• J.4 – Breton consultation notes October 30, 2007 

• J.5 – Mississippi / Alabama interstate consultation letter 

• J.6 – Mississippi / Louisiana interstate consultation letter 
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 

we meet 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 

Appendix J.1
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 

Appendix J.1
 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 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 inventories for VISTAS, 

CENRAP, and MRPO in Base A are out of date. MANE-VU is running CMAQ with 

updated Base B inventories for all the eastern RPOs. 

• VISTAS emissions sensitivities indicate that further SO2 reductions from electric generating 

units and industrial sources would have the greatest visibility benefits in 2009 or 2018, 

compared to other fine particle components. 

Appendix J.2
• 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 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. 

• Source attribution by CENRAP and MANE-VU compared to VISTAS results as VISTAS 

states begin consultation with states in these RPOs. 

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 are identified and control measures 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. 

Appendix J.2
• 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 using simplified 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 and Clean Air Mercury Rule 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. 

 

• SC developed a list of sources in the Area of Influence for Cape Romain and is consulting 

with NC and GA about sources in those states impacting Cape Romain and impacts from SC 

sources on Class I areas in those states. SC considers controls under CAIR as reasonable 

progress for EGU and is considering 4 statutory factors for non-EGU sources if costs are less 

than $3000 per ton. 

• GA has sent letters to sources in GA asking for evaluation of the four statutory factors. GA 

also has sent letters to AL, FL, NC, SC, and TN listing the GA sources that are being 

considered for GA and neighboring Class I areas and asking FL, SC, and TN to consider 

specific sources in those states for GA Class I areas. GA used separate criteria for the two 

Class I areas in the state. For Cohutta, which is projected to see visibility improvements 

better than the uniform rate of progress, GA determined that planned utility controls by 2018 

are reasonable and is considering additional controls for non-EGU industrial sources. For 

Okefenokee, which is very close to the uniform rate of progress, GA is considering additional 

control measures for both EGU and non-EGU sources. To implement these controls GA is 

considering a multi-pollutant rule with specific controls added to the Title V permits. 

• NC determined that SO2 emission reductions under the NC Clean Smokestacks Act are 

reasonable controls for utilities for this first round of the SIP. NC then reviewed the capital 

and operational costs for the scrubbers installed under the NC Clean Smokestacks Act and 

determined that the maximum cost will be $2000 dollars per ton. NC chose to use this same 

threshold as maximum cost that would be reasonable to ask of a non-EGU industrial source. 

NC is now reviewing feasibility of control measures with costs below $2000. NC has 

developed a BART framework rule. Any controls for BART or reasonable progress would be 

included in Title V permits. 

Appendix J.2
• WV has identified sources in WV and in MD, TN, and VA that are impacting WV Class I 

areas. WV would cite IPM results in the regional haze SIP and would allow emissions 

trading under CAIR. 

• VA has identified sources in VA and in MD, NC, and WV that are impacting VA Class I 

areas. VA has adopting enabling rules for BART, will deal with specific BART controls in 

state operating permits. VA will cite IPM results as modified by VA in Base G in the regional 

haze SIP and will include specific controls in the Title V permits when those controls are 

installed. 

• KY is considering sources for Mammoth Cave and for Mingo and Caney Creek. KY and TN 

are consulting with AR and MO. KY is consulting with WV on one source. KY will likely 

conclude that EGU controls projected for CAIR are reasonable. Controls will be included in 

permits. 

• TN has identified sources impacting Class I areas, GA has asked TN to add one additional 

source to TN’s list. Most sources on TN’s list are installing controls or reducing emissions. 

TN is considering a draft regional haze rule, currently discussing with EPA. Controls will be 

added to the Title V permits. 

• AL expects controls on two BART sources. AL considers the emissions reductions under 

CAIR are reasonable for EGU and is considering a few non-EGU sources for Sipsey, AL, 

Breton, LA, and Saint Marks, FL. AL will provide revised emissions to FL and does not 

expect to need further consultation with FL. 

• MS has identified no sources that impact Sipsey, AL and AL agrees. MS has identified 6 

sources that potentially impact Breton and is considering controls for these sources. MS will 

continue to consult with LA and does not see need for further consultation with VISTAS or 

MANE-VU states. 

• FL has identified sources in the AoI for 3 FL Class I areas (CHAS, EVER, SAMA) and 3 

neighboring states (Breton, LA, Okefenokee, GA and Wolf Island, GA). Fl has sent letters to 

AL and GA listing FL sources being considered and asking those states to consider sources 

for FL Class I areas. FL intends to develop a rule for requiring analyses of four statutory 

factors for identified FL sources. FL expects to use the VISTAS Base G2a 2018 emissions in 

the SIP and to allow trading. FL will not set a reasonable progress goal in the SIP but will set 

the process for the four-factor analysis and the goal will be the outcome of that process. FL 

and GA will continue consultation. FL expects the SIP will be submitted to EPA after 

December 2007. 

VISTAS states recognize that VISTAS Base G utility SO2 emissions are lower than projections from 

IPM (VISTAS version 2.1.9) and that emissions in another region of the country may be higher than 

IPM projections if additional credits are generated by additional controls on VISTAS sources. 

Appendix J.2
VISTAS States trust the reductions in the VISTAS Base G inventory because they reviewed and 

updated the 2009 and 2018 emissions with their utilities in summer 2006. 

VISTAS states agree that the state with the Class I area will set the reasonable progress goal for the 

Class I area and will consult with neighboring States. The long-term strategy will need to 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. 

VISTAS plans to initiate the emissions and air quality modeling for the Long-Term Strategy in July. 

Appendix J.2
VISTAS State Consultation Meeting 

Federal Land Managers and Environmental Protection Agency 

Asheville, North Carolina 

June 12, 2007 

Attendees/Affiliation

Tim Allen, FWS Cindy Huber, FS 

Diana Andrews, KY Bill Jackson, FS 

Julie Aslinger, TN Brenda Johnson, EPA Region 4 

Vivian Aucoin, LA Jimmy Johnston, GA 

Leigh Bacon, AL Rhea Jones, EPA OAQPS 

Tom Ballou, VA Kathy Kaufman, NC 

Elliott Bickerstaff, MS Martin Luther, KY 

Laura Boothe, NC Tim Martin, AL 

Jim Boylan, GA Doris McLeod, VA 

Lona Brewer, KY Ann Mebane, FS 

Pat Brewer, VISTAS Brock Nicholson, NC 

Joelle Burleson, NC Michele Notarianni, EPA OAQPS 

Bob Carson, NPS Bruce Polkowsky, NPS 

Catherine Collins, FWS Jim Renfro, NPS 

Fred Durham, WV Tom Rogers, FL 

Stacey Gardner, SC Renee Shealy, SC 

Rick Gillam, EPA Region 4 Don Shepherd, NPS 

John Glass, SC Andrea Stacy, FS 

Janice Godfrey, NC Barry Stephens, TN 

Todd Hawes, EPA OAQPS Bob Stroik, NPS 

Sheila Holman, NC Ming Xie, NC 

John Hornback, Metro4/SESARM 

Chris Howard, AL 

Objectives

The purpose of this consultation meeting was to overview the VISTAS and state 

technical analyses that will be the basis of the state implementation plans for regional 

haze and to receive feedback from the Federal Land Managers (FLM) and the 

Environmental Protection Agency (EPA) on the presented materials. 

Expectations

The meeting opened with participants stating their expectations for consultation. 

FLM interests included: 

• understanding VISTAS technical analyses and how states will use these analyses 

in SIPs 

Appendix J.3
• understanding states’ reasonable progress goals and having opportunity to consult 

on these goals 

• states’ plans for consultation with neighboring states 

• states’ plans for mid-course review 

• states’ plans for continued consultation with FLM 

EPA interests included: 

• learn how states are using technical analyses 

• understand FLMs positions 

• provide clarification of revised reasonable progress guidance 

• observe and report outstanding issues to management 

States interests included: 

• feedback from the FLM and EPA if technical analyses, when completed, would 

meet FLM and EPA expectations for SIP documentation. 

• Some states would like to consider this meeting to meet the requirement for a face 

to face meeting with FLM, with further follow up and discussions by conference 

call. 

• Common understanding between states, FLM, and EPA of revised reasonable 

progress guidance 

• This first SIP for regional haze will be a learning experience. States can use midcourse review to evaluate what is working and where revisions are needed. 

Technical Analysis Summary

Pat Brewer summarized the VISTAS Technical Analyses (see presentation on 

VISTAS website, http://www.vistas-sesarm.org/documents/FinalDocs.asp). 

Ammonium sulfate is the primary contributor to haze at the VISTAS Class I areas. 

Emissions sensitivity analyses showed greatest visibility benefit from reducing SO2 

from electric utilities or industrial point sources and little benefit from reducing NOx, 

anthropogenic VOC, or primary sources of carbon. Ninety-six percent of the SO2 

emissions in the VISTAS states are from electric utility or industrial point sources. 

SO2 Areas of Influence were defined for each Class I area. In 2018 coal fired electric 

utility boilers and coal fired industrial boilers are the largest SO2 emission categories 

in every SO2 Area of Influence. Several other industrial categories were minor 

contributors to SO2 emissions in the Areas of Influence. Control options and costs of 

controls were provided to the states. 

Concurrent Consultative Sessions

The meeting then broke into two concurrent sessions addressing the mountain or 

coastal Class I areas. Each state then summarized: 

• criteria used to rank sources in SO2 Areas of Influence for Class I areas in that state 

• list of sources for which reasonable control measures and 4 statutory factors are 

being considered 

Appendix J.3
• expected controls from exiting regulations for listed sources 

• status of BART determination 

• plans for consultation with neighboring states 

• next steps 

Groupings for of Class I Areas for VISTAS and Surrounding Regions

Status of BART Determinations in Each State

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

Mountains Groupings

1. Great Smoky Mtns (5 sites)

2. Mammoth Cave

3. Sipsey

4. Shenandoah (4 sites)

Coastal Groupings

5. Swanquarter

6. Cape Romain 

7. Okefenofee (4 sites)

8. Everglades

Neighboring Sites

9. Breton

10.Mingo (4 sites)

11.Brigantine

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

.

.

.

.

Hercules 

Glade, 

MO .

.

VISTAS Class I Areas

Mountains Groupings

1. Great Smoky Mtns (5 sites)

2. Mammoth Cave

3. Sipsey

4. Shenandoah (4 sites)

Coastal Groupings

5. Swanquarter

6. Cape Romain 

7. Okefenofee (4 sites)

8. Everglades

Neighboring Sites

9. Breton

10.Mingo (4 sites)

11.Brigantine

BART control for some sources subject to BART may be fuel switching

Some BART subject facilities took limits to exempt out, these are not included as a control

Alabama NO 31 2 2

*listed individual units, may or may not be the same facility

W.Virginia NO 22 3 0

Florida NO 47 9 don't know

Kentucky NO 31 1 1 maybe

Mississippi NO 15 2 1

N. Carolina NO 17 2 0

S. Carolina NO 21 14 0

Virginia NO 13 3 3*

Georgia NO 25 3 1 or 2

Tennessee NO 13 4 1 or 2

STATE Complete Eligible Subject Controlled

BART control for some sources subject to BART may be fuel switching

Some BART subject facilities took limits to exempt out, these are not included as a control

Alabama NO 31 2 2

*listed individual units, may or may not be the same facility

W.Virginia NO 22 3 0

Florida NO 47 9 don't know

Kentucky NO 31 1 1 maybe

Mississippi NO 15 2 1

N. Carolina NO 17 2 0

S. Carolina NO 21 14 0

Virginia NO 13 3 3*

Georgia NO 25 3 1 or 2

Tennessee NO 13 4 1 or 2

STATE Complete Eligible Subject Controlled

Appendix J.3
Issues Discussed and Resolved

 

• Reasonable progress goal should be reported using deciview with one significant 

digit beyond the decimal point (e.g. 25.4 dv, not 25.44 dv). 

• Final long-term strategy (LTS) run will not be completed in time for FLM 

consultation prior to public review. States can report that reasonable progress goal 

for 20% worst days will be at least as stringent as BaseG2a modeling results and 

that additional BART and reasonable measures within the state and neighboring 

states could accomplish greater progress than the Base G2. The final RPG would 

be reflected in the RH SIP submittal. 

• Consultation with non-VISTAS states: AR and MO are consulting with KY and 

TN. LA is participating in VISTAS meetings as consultation for BRET. MANEVU states have asked VISTAS states to consult this summer (call in July, meeting 

in Aug). 

• All four statutory factors need to be considered, but if there are no cost effective 

controls for a source, then the other three factors do not need to be addressed in 

depth. 

• GA found that 2018 emissions for non-EGU sources were sometimes 

overestimated, likely due to overestimating growth factors. 

• SIP wording should note that sources that take emissions limits to exempt from 

BART cannot go above that limit in the future. 

Issues Requiring Follow-up

• FLM asked KY about their plans to consult with MRPO states re impacts on 

Mammoth Cave 

• FLM and EPA asked for justification of the Class I area groupings. The 

groupings were intended to organize presentation of data for similar sites. The 

groupings are based on similar Areas of Influence and similar responses to 

geographic sensitivity analyses. 

• Most states used emissions divided by distance (Q/d) and maximum residence 

time (RTmax) to rank sources in the SO2 Areas of Influence. Most states used a 

1% contribution as cutoff to consider a source for 4 factor analysis of reasonable 

further controls. GA used 0.5% contribution as cut off. FLM and EPA asked for 

justification of cutoff value that states selected. FLM also suggested that states 

consider if a source affects more than one Class I area. 

• FLM need follow up from states on BART controls under review. 

• FLM would like to help define what midcourse review will look like. Focus 

expected to be on emissions changes from baseline to 2012 (CAIR, CSA, BART, 

projected mobile reductions). Trends in monitoring data may also be considered 

but may be difficult to interpret due to inter-annual variability in meteorology. 

What commitments will states make if emissions reductions are less than 

projected in the SIP? Need to describe in SIP how States will check progress and 

make corrections if/as needed. 

Appendix J.3
• SIP narratives need wording about new source growth and how PSD permitting 

will be affected, as well as about uncertainty in the 2018 projections. Each SIP 

must commit to what will be specifically reviewed at the 5-year check. Would 

like to see specific procedures on consulting with FLM. 

• FLM also suggested that States should interrelate PSD and haze by having the 

haze SIP set a zone around each Class I area to point out to state PSD permitters 

the area where they need to look more critically at controlling growth to protect 

the Air Quality Related Values (AQRVs) 

• Don’t forget deposition data, what improvements in deposition projected? Bill 

Jackson will make available upon request deposition results for 12 km grid using 

2018 Base G emissions (provided by Bill by Alpine Geophysics). 

• Consider benefits from ozone and PM2.5 attainment. How will new ozone 

standard affect visibility? 

• Florida needs to discuss with EPA Region 4 its plans for setting reasonable 

progress process. 

• FLM would prefer that they get a copy of the SIPs 60 days prior to the public 

hearing. 

• If states are not going to meet the December 17, 2007 deadline, they need to let 

EPA know and work with them. 

• Since Breton is not meeting the uniform rate of progress glidepath, FLM 

suggested that emissions sources permitted by Mineral Management Services 

should be separated from domestic sources (this has not been done to date). FLM 

also suggested that LA alert EPA that there is a marine treaty issue with MMS 

permits. 

• For Class I areas impacted by sources in different RPOs, it would be helpful if 

states used consistent methods for weight of evidence and reasonable progress 

goals. For BRET, LA could do similar AoI analysis for sources as VISTAS 

states. 

• Setting RPG for 20% best days: do states set as no degradation from 2000-2004 

baseline or as modeled results for 20% best days in 2018? In follow up with EPA 

and FLM: rule states no degradation on the 20% best days but also says that can’t 

set goal worse than progress expected under implementation of controls under 

other CAA programs. If Base G2 model results project that 20% best days will be 

better in 2018 than in 2000-2004, then states should discuss this is setting goal for 

20% best days. FLM pointed out if states use model results for 20% worst days, 

they should also use model results for 20% best days. States’ concern is whether 

model performance for 20% best days is reliable since most of VISTAS model 

performance evaluation to date has focused on 20% worst days, not 20% best 

days. For instance, there are issues with poor nitrate performance issues on 

winter days that could affect model projections for nitrate in 2018 for 20% best 

days that occur in the winter. 

Appendix J.3
Discussion of Revised Regional Haze Guidance

• EPA cautioned that states need to be careful to interpret the guidance as a whole 

and not isolate any single sentence in the guidance out of context of the whole 

document. The guidance does not trump the Regional Haze Rule or the Clean Air 

Act. 

• States need to look at the four statutory factors to determine what measures are 

reasonable. 

• States have flexibility. The new guidance states that in deciding the minimum 

RPG it is reasonable to defer reductions to later planning periods in order to 

maintain a consistent glidepath toward the long-term goal. 

• One possible approach is to use uniform reasonable progress to back out what 

additional controls are necessary. 

• $/dv approach is included in the new guidance as an additional measure of cost 

effectiveness. It is not intended to be used instead of $/ton. VISTAS does not 

have plans to generate $/dv in response to new guidance. If used, the correct 

metric for this objective would be $/Mm-1 rather than $/dv because dv is 

logarithmic. 

Conclusions and Plan of Action

VISTAS states committed to share summary of the meeting with the VISTAS 

workgroups. FLM, EPA, and VISTAS workgroups are asked to review the Technical 

Summary that is posted on the VISTAS website and provide feedback if the format, 

when completed, would meet expectations for a SIP Narrative. Comments are 

requested by the July 23 workgroup call. 

VISTAS contractors are working on final project reports. Reports will be posted to 

the VISTAS website. States are working on documentation for SIPs and intend to 

provide documentation to FLM for formal review prior to the public hearings. NC 

and SC are looking to provide documentation in July; other states expect 

documentation to be ready in the Aug-Nov timeframe. Each state will independently 

set their FLM consultation, public review, and SIP submittal process. 

VISTAS states are consulting with neighboring states as appropriate to meet the 

regional haze rule requirements. Each state is defining its own consultation process. 

VISTAS states are not clear if a final meeting with the VISTAS workgroups is 

needed prior to the public review. States have been working directly with their 

sources as necessary to evaluate BART controls and reasonable further control 

measures. VISTAS is providing technical support to the States, but the States are not 

developing collective policy recommendations through VISTAS. 

Questions should be directed to John Hornback, Pat Brewer, or state contacts. 

Appendix J.3
Breton Wilderness Class I Area 

Regional Haze Consultation Meeting 

October 30, 2007 

 

Participants: 

Alabama: Leigh Barb Bacon and Tim Martin 

Florida: Tom Rogers 

Louisiana: James Orgeron, Vivian Aucoin, Michelle Morgan and Gilberto Cuadra 

Mississippi: Elliott Bickerstaff and Mary Evelyn Barnes 

FLM: Bruce Polkowski, Tim Allen, Jill Webster, Anne Mebane, and Meredith Bonds 

EPA Reg 6: Joe Kordzi 

Discussion Topics: 

Best Available Retrofit Technology (BART): 

Alabama: No formal rule making has been undertaken in regards to BART. Alabama felt as 

though all necessary authority to enforce the BART control measures were afforded by the 

Regional Haze Rule. 

According to department representatives, the only facility meeting BART requirements that is 

in the proximity to Breton is Big Escambia Creek, Escambia Operating Company LLC. The Big 

Escambia Creek gas production, treating and processing facility is a gas and condensate production, 

treating and processing facility. The facility has agreed to accept limits, which will mean a 40-50% 

reduction in SO2. The facility is approximately 220 km from Breton. 

Mississippi: No formal rule making has been undertaken in regards to BART. There are two 

facilities that are BART subject: Mississippi Phosphates and the Chevron Refinery, both of which are 

On the Mississippi Gulf Coast, about 50 km form Breton. Mississippi Phosphates total SO2 

emissions are less than 2000 tpy and they already have dual absorption scrubbers with acid demisters. 

The engineering analysis finds that there are no further controls that are technically feasible. 

The Chevron Refinery, Pascagoula, is currently under a Consent Decree Order which reduces 

SO2 by more than 4000 tpy. NOx and PM10 reductions are included in the CD as well, but they are 

not as significant. With these reductions, the visibility impact dropped from 3.89 dv impairment to 

0.79 dv impairment. 

Louisiana: No formal BART rule making was undertaken. Those facilities that were subject to 

BART were either covered by CAIR reductions or by Consent Decree Orders. All model protocols 

except two have been submitted for approval by the FLMs and EPA. Emission reductions are 

expected to be significant. Louisiana plans to go to public notice on November 20, 2007 and the 

public hearing is scheduled for January 24, 2008 with the public comment period ending January 31, 

2008. 

Florida: Formal rule making was undertaken by Florida. There are three facilities in the Breton 

vicinity, but all have met exemption criteria. The largest utility in the area, Gulf Powers, Pensacola, is 

installing scrubbers on all units. SO2 reductions are expected to be rather significant; NOx and PM 

reductions will also occur. 

Florida is also promulgating a Reasonable Progress Rule. This rule is in the final stages and is 

expected to go final in December 2007, with an effective date of January 2008. This rule will require 

that 15 facilities (32 units) will undergo the 4 factor analysis as outlined in the Regional Haze rule. A 

compliance date of December 1, 2017 has been set. 

Appendix J.4
All parties on the call also gave updates on Regional Haze SIP submittals and answered questions 

posed by EPA Reg 6 and the FLMs to satisfaction. 

Appendix J.4
~

MISSISSIPPI

Ronald W. Gore, Chief, Air Division

Alabama Department of Environmental Management

P.O. Box 301463

Montgomery, Alabama 36130-1463

Dear Mr. Gore:

Thank you for providing a copy of the pre-hearing draft of the Alabama Regional Haze SIP for

Mississippi Department of Environmental Quality (MDEQ) to review. We appreciate ADEM

consulting with MDEQ on the Reasonable Progress Goals for the Regional Haze SIP.

MDEQ has reviewed the Alabama Regional Haze SIP and we agree with the Reasonable

Progress Goals for Sipsey Wilderness Area.

We will continue the collaboration with ADEM in the VISTAS studies and analyses and will -

look forward to future consultation with ADEM while addressing Regional Haze issues in future

planning periods.

If you have any questions or comments, please advise.

Sincerely, c;? J .I?Jt u a /l.6?w .

~';y~70, P.E., DEE

Chief, Air Division

~

OFFICE OF POLLUTION CONTROL

POST OFFICE Box 10385 . JACKSON, MISSISSIPPI 39289-0385 . TEL: (601) 961-5171. FAX: (601) 35+6612. www.deq.state.ms.us

AN EQUAL OPPORTUNITY EMpLOYER

~

STATE OF MISSISSIPPI

HALEy BARBOUR

GOVERNOR

DEPARTMENT OF ENVIRONMENTAL QUALITY

TRUDY D. FISHER, ExECUTIVE DIRECrOR

January 29, 2008

Re: Regional Haze State Implementation

Plan (SIP) Interstate Consultation

Appendix J.5
STATE OF MISSISSIPPI

HALEY BARBOUR

GoVERNOR

MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALIlY

TRUDY D. FISHER, ExEClJI1VE DIRECTOR

.

~

Ms. Vivian Aucoin

Louisiana Department of Environmental Quality

Office of Environmental Assessment

Box 4314

Baton Rouge, Louisiana 70821-4314

Dear Ms. Aucoin:

Thank you for providing a copy of the pre-hearing draft of the Louisiana Regional Haze SIP for

Mississippi Department of Environmental Quality (MDEQ) to review. We appreciate LDEQ

consulting with MDEQ on the Reasonable Progress Goals for the Regional Haze SIP.

MDEQ has reviewed the Louisiana Regional Haze SIP and we agree with the Reasonable

Progress Goals for Breton Wildlife Refuge.

We will continue the collaboration with LDEQ and will look forward to future consultation with

LDEQ while addressing Regional Haze issues in future planning periods.

If you have any questions or comments, please advise.

Sincerely,

OFFICE OF POlLUTION CONTROL

POST OFFICE Box 10385 . JACKSON, MISSISSIPPI 39289-0385 . TEL: (601) 961-5171 . FAX: (601)

AN EQUAL OpPORTUNm EMpLOYER

January 29, 2008

Re: Regional Haze State Implementation

Plan (SIP) Interstate Consultation

'1.~: p,!::

Chief, Air Division

354-6612. www.dcq.state.ms.us

Appendix J.6