# Appendix J

Consultation ProcessAppendix J – Consultation Process

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

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

• J.3 – Summary VISTAS cons ultation 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 letterInterstate Regional Haze Meeting Summary January 23, 2007 Point Clear, Alabama

An interstate Regional Haze consultation m eeting 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 st ates of Florida, Alab ama, Mississippi and Louisiana, as well as a representative from VISTAS. CENRAP repr esentatives were not in attendance at this meeting. A consultation meeting will be scheduled to include representatives of EPA and th e FLM responsible for Breton.

Modeling was the first item for discussion on th e agenda. The latest modeling runs for year 2018 show greater consistency between th e RPOs results. CENRAP model results using the new IMPROVE algorit hm puts Breton just below th e 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 i nventory was not available when VISTAS performed its modeling which could also accoun t 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 c oncern 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 guidan ce, 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 po llution on Breton and agr eed that all modeling results show that sulfates seem to be the most pressing problem. Although CAIR is expected to provide reducti ons from the EGUs, it appears that non-EGUs may have to significantly reduce emissions in order for Br eton to meet glide slope predictions for 2018. Louisiana representatives stated that th e state is looking at methods of achieving the necessary reductions from the non-EGU com ponents. VISTAS states are looking at this speciated component as well, be it th rough some form of re gulation or through the permitting process.

All of the states are in the process of making BART determinations. No state has constructed a draft rule. BART and reasonable further progress (RFP) seems to be a political as well as economic dilemma in the VISTAS states that were in attendance. Like Louisiana, the hurricane seasons of the past 2-3 years have wreaked havoc onindustry and its ability to make a comeback. The governments would rather suffer a little pollution instead of losing the economic backbone of a community.

There was much discussion on how to show RFP. Because Breton has the predicament of incomplete monitor data, there was a cons ensus that by showing the steady decline of emissions coupled with the reductions that will take place thr ough state and national initiatives and the additional monitoring data that will be available from the Breton IMPROVE monitor, the state has fulfilled the re quirements 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 pr ovides 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 ot her 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 agreei ng 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 BrewerVISIBILITY 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, Metr o 4, Eastern Band of Cherokee Indians VISTAS State Cons ultation 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 require d to consult to develop coordinated emissions management strategies. The object ives 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 betw een 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 w ould follow to define reasonable progress goals and to set long-term strategies to meet those goals.

Introduction Sheila Holman reviewed the 2009 ai r quality modeling results for oz one and fine particulate matter (particles with diameters less than 2.5 micr ons, PM2.5). Ozone and PM2.5 levels will be significantly reduced between 2002 and 2009 and most urban areas wi ll 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 VIST AS technical analyses that s upport state implementation plans (SIPs) including:

• Baseline and natural visibi lity conditions and un iform 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 projec ted to be reduced by 70% between 2002 and 2018.

• VISTAS Base G2a emissions and air quality modeling results i ndicate 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 i nventories 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 i ndicate that further SO2 reduc tions from electric generating units and industrial sources would have the greatest visibility be nefits in 2009 or 2018, compared to other fine particle components.• VISTAS emissions sensitivities also indicate that VISTAS stat es are major contributors to VISTAS Class I areas. MRPO, MANE-VU, an d CENRAP are important source regions for Class I areas bordering these re gions. VISTAS coastal sites are influenced by emissions from outside the VISTAS modeling domain (international emissions or continental emissions that have been transp orted outside the doma in and are recirculated back into the domain.)

• VISTAS SO2 Areas of Influence demonstrate th e geographic areas most likely to contribute emissions to Class I areas on 20% worst visibility days.

• Source attribution by CENRAP and MANE-VU co mpared to VISTAS results as VISTAS states begin consultation w ith states in these RPOs.

Renee Shealy reviewed expectations of the Federa l 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 Planni ng 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 estab lishing baseline and natural conditions, uniform rate of progress, emissions inventories, and ar eas of influence. VISTAS technical analyses should meet these expectations.

• FLM recognize state flexibility in setting reas onable progress goals and defining emissions strategies to meet those goals. FLM expect st ates 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 poi nt. If actual installa tions differ from those referenced in the SIP then a SI P revision would be appropriate.

• FLM will be looking for regional consistenc y 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 neighbor ing 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 ar e 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 provi ded by Greg Stella in November 2006.• Most states ranked sources usi ng 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 contri butions 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 neighbor ing states or described the sources on its list. Each stat e also described its regulatory pr ocess to develop the regional haze SIP. All states have adopted the Clean Air Inters tate 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 invent ory (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 Ca pe 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 th e four statutory factors. GA also has sent letters to AL, FL, NC, SC, and TN listing the GA s ources 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, whic h is projected to see visibility improvements better than the uniform rate of progress, GA de termined 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 sour ces. To implement these controls GA is considering a multi-pollutant rule with specif ic 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 do llars per ton. NC chose to use this same threshold as maximum cost that would be reas onable 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.• 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 lis t 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 consid ering 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 furthe r consultation with FL.

• MS has identified no sources that impact Sipsey, AL and AL agrees. MS has identified 6 sources that potentially impact Br eton 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 (Breto n, LA, Okefenokee, GA and Wolf Isla nd, 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 analys es 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 se t a reasonable progress goal in the SIP but will set the process for the four-factor analysis and the go al will be the outcome of that process. FL and GA will continue consultation. FL exp ects the SIP will be submitted to EPA after December 2007.

VISTAS states recognize that VIST AS 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 cr edits are generated by additional controls on VISTAS sources.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 ne ighboring States. The long-term st rategy will need to include the Base G2a controls plus BART controls and any additional control measures in the State or neighboring States. The stat es will continue to use the VISTAS state calls to disc uss setting goals and long-term strategies.

VISTAS plans to initiate the emissions and air qual ity modeling for the Long-Term Strategy in July.VISTAS State Consultation Meeting Federal Land Managers and E nvironmental 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 Mi chele 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 consu ltation 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 stati ng their expectations for consultation.

FLM interests included:

• understanding VISTAS technical analyses and how states will use these analyses in SIPs• understanding states’ reasonable progress go als and having opport unity 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 revise d reasonable progress guidance

• observe and report outstandi ng 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 m eeting 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 experi ence. 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 great est visibility benef it from reducing SO2 from electric utilities or i ndustrial 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 el ectric 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 fire d industrial boilers are the largest SO2 emission categories in every SO2 Area of Influence. Several other industrial cat egories 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 contro l measures and 4 statutory factors are being considered• expected controls from exiti ng regulations for listed sources

• status of BART determination

• plans for consultation with neighboring states

• next steps

Groupings for of Class I Areas fo r 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 0 3 22 NO W.Virginia don't know 9 47 NO Florida 1 maybe 1 31 NO Kentucky 1 2 15 NO Mississippi 0 2 17 NO N. Carolina 0 14 21 NO S. Carolina 3* 3 13 NO Virginia 1 or 2 3 25 NO Georgia 1 or 2 4 13 NO Tennessee Controlled Subject Eligible Complete STATE

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 0 3 22 NO W.Virginia don't know 9 47 NO Florida 1 maybe 1 31 NO Kentucky 1 2 15 NO Mississippi 0 2 17 NO N. Carolina 0 14 21 NO S. Carolina 3* 3 13 NO Virginia 1 or 2 3 25 NO Georgia 1 or 2 4 13 NO T ennessee Controlled Subject Eligible Complete STATEIssues Discussed and Resolved

• Reasonable progress goal should be reporte d using deciview w ith one significant digit beyond the decimal point (e.g. 25.4 dv, not 25.44 dv).

• Final long-term strategy (LTS) run w ill 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 meas ures within the state and neighboring states could accomplish greater progress th an 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 m eetings as consultation for BRET. MANEVU states have asked VISTAS states to c onsult this summer (call in July, meeting in Aug).

• All four statutory factors n eed to be considered, but if there are no cost effective controls for a source, then the other thr ee factors do not need to be addressed in depth.

• GA found that 2018 emissions for non-EGU sources were sometimes overestimated, likely due to overest imating 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 consu lt 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 presenta tion of data for similar sites. The groupings are based on similar Areas of Influence and similar responses to geographic sensitivity analyses.

• Most states used emissi ons divided by distance (Q /d) and maximum residence time (RTmax) to rank sources in the SO2 Area s of Influence. Most states used a 1% contribution as cutoff to consider a s ource for 4 factor anal ysis of reasonable further controls. GA used 0.5% contribut ion as cut off. FLM and EPA asked for justification of cutoff value that states se lected. FLM also s uggested that states consider if a source affects mo re than one Class I area.

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

• FLM would like to help define what mi dcourse review will look like. Focus expected to be on emissions changes fr om 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 reducti ons are less than projected in the SIP? Need to describe in SIP how States will check progress and make corrections if/as needed.• SIP narratives need wording about ne w source growth and how PSD permitting will be affected, as well as about uncer tainty 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 shoul d interrelate PSD and haze by having the haze SIP set a zone around each Class I ar ea to point out to state PSD permitters the area where they need to look more crit ically at controlli ng growth to protect the Air Quality Related Values (AQRVs)

• Don’t forget deposition data, what impr ovements 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 Re gion 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 D ecember 17, 2007 deadline, they need to let EPA know and work with them.

• Since Breton is not meeting the unifo rm rate of progress glidepath, FLM suggested that emissions sources perm itted 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 th ere 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 wei ght of evidence an d reasonable progress goals. For BRET, LA could do similar AoI analysis for sources as VISTAS
states.

• Setting RPG for 20% best days: do stat es set as no degradation from 2000-2004 baseline or as modeled results for 20% be st 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 re sults 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 pointe d 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 mostof VISTAS model performance evaluation to date has fo cused on 20% worst days, not 20% best days. For instance, there are issues with poor nitr ate performance issues on winter days that could a ffect model projections for nitrate in 2018 for 20% best days that occur in the winter.Discussion of Revised Regional Haze Guidance

• EPA cautioned that states need to be caref ul 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 th e Regional Haze Rule or the Clean Air Act.

• States need to look at the four statutor y 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 pe riods in order to maintain a consistent glidepath toward the long-term goal.

• One possible approach is to use uniform reasonable pr ogress to back out what additional controls are necessary.

• $/dv approach is included in the new gui dance 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 summa ry 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 webs ite and provide feedback if the format, when completed, would meet expectati ons for a SIP Narrative. Comments are requested by the July 23 workgroup call.

VISTAS contractors are worki ng 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 re view prior to the public hearings. NC and SC are looking to provide documen tation in July; other states expect documentation to be ready in the Aug-Nov timeframe. Each state will independently set their FLM consultation, public revi ew, and SIP submittal process.

VISTAS states are consulting with neighbor ing 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 supp ort to the States, but the States are not developing collective policy r ecommendations through VISTAS.

Questions should be directed to John Ho rnback, Pat Brewer, or state contacts.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 We bster, 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 BA RT 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 proce ssing facility is a gas and condensate production, treating and processing facility. The facility ha s agreed to accept limits, which will mean a 40-50% reduction in SO 2 . The facility is approximately 220 km from Breton.

Mississippi: No formal rule making has been undertak en in regards to BART. There are two facilities that are BART subject: Mississippi Phosphat es and the Chevron Refinery, both of which are On the Mississippi Gulf Coast, about 50 km fo rm 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, Pa scagoula, is currently under a Consent Decree Order which reduces SO 2 by more than 4000 tpy. NOx and PM 10 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 undertak en. 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 peri od ending January 31, 2008.

Florida: Formal rule making was undertaken by Flor ida. There are three fa cilities in the Breton vicinity, but all have met exemption criteria. The la rgest utility in the area, Gulf Powers, Pensacola, is installing scrubbers on all units. SO 2 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 Ja nuary 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 Decemb er 1, 2017 has been set.All parties on the call also gave updates on Regi onal Haze SIP submittals and answered questions posed by EPA Reg 6 and the FLMs to satisfaction.~ 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, 

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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 ConsultationSTATE 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



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Chief, Air Division

12. www.dcq.state.ms.us 354-66