Appendix P 

FLM Comments 

on 

Alabama’s Draft RH SIP 
The following comments were received on Alabama’s Draft Regional Haze SIP from the 

Department of Agriculture’s National Forest Service and the Department of Interior’s Fish and 

Wildlife Service. These comments are part of the ongoing consultation with the Federal Land 

Managers as required by the Clean Air Act. 

Fish and Wildlife Service Comments email from Catherine Collins (FWS) dated 12/26/07 

National Forest Service Comments hard copy from Miera Crawford dated 12/10/07, Forest 

Supervisor, email from Cindy Huber, Air Resource Specialist dated 2/5/08 
File Code: 2580 

Date: December 10, 2007 

 

Mr. Ronald W. Gore 

Chief, Air Division 

Alabama Department of Environmental Management 

P. O. Box 301463 

Montgomery, AL 36130-1463 

Dear Mr. Gore: 

On November 16, the State of Alabama submitted a draft implementation plan describing your 

proposal to improve air quality regional haze impacts at mandatory Class I areas across your 

region. We appreciate the opportunity to work closely with the State through the initial 

evaluation, development, and, now, subsequent review of this plan. Cooperative efforts such as 

these ensure that, together, we will continue to make progress toward the Clean Air Act’s goal of 

natural visibility conditions at our Class I wilderness areas and parks. 

This letter acknowledges that the U. S. Department of Agriculture, Forest Service, has received 

and conducted a substantive review of your proposed Regional Haze Rule implementation plan. 

Please note, however, that only the U. S. Environmental Protection Agency (EPA) can make a 

final determination about the document’s completeness, and therefore, only the EPA has the 

ability to approve the document. The Forest Service’s participation in the State of Alabama’s 

administrative process does not waive any legal defenses or sovereignty rights it may have under 

the laws of the United States, including the Clean Air Act and its implementing regulations. 

As outlined in a letter to the State in October 2006, our review focused on eight (8) basic content 

areas. The content areas reflect priorities for the Federal Land Manager agencies, and we have 

attached comments associated with these priorities. Note that we have highlighted comments in 

bold face that we feel warrant additional consultation prior to public release. We look forward to 

your response as required by 40 CFR 51.308(i)(3). For further information, please contact Cindy 

Huber at (540) 265-5156 or Ann Mebane at (307) 578-8241. 

Again, we appreciate the opportunity to work closely with the State of Alabama. The Forest 

Service compliments you on your hard work and dedication to significant improvement in our 

nation’s air quality values and visibility. 

Sincerely, 

/s/ Miera Crawford Nagy 

MIERA CRAWFORD NAGY 

Forest Supervisor 
Enclosure 

cc: Michele Notarianni EPA Region 4 

Stacy Harder EPA Region 4 

Enclosure 

Forest Service Technical Comments on ADEM’s Draft Regional Haze State Implementation 

Plan 

Overall Comments

As stated in our letter, we feel that your agency has addressed each of the priority content areas 

with which the Federal Land Managers (FLMs) are concerned in the draft Regional Haze 

Regulations State Implementation Plan (SIP), and we appreciate the clarity of the document. 

However we do have several areas of concern which we look forward to discussing with you 

during out consultation. Our concerns are addressed in more detail in our section-specific 

comments, and include: 

 the lack of information within the main body of the SIP about the impacts of sources 

outside of Alabama on Sipsey Wilderness, 

 the lack of information within the main body of the SIP about the impacts of 

Alabama sources on Class I areas outside of Alabama, 

 lack of Reasonable Progress analyses for several sources, 

 exclusion of Oak Grove Resources from BART determination analysis, 

 ADEMs proposal to use the Uniform Rate of Progress instead of the modeled levels 

for the Reasonable Progress Goals for the hazy and clear days, and 

 incorporation of the Smoke Management Program into the SIP. 

All of these issues warrant further attention; but the Reasonable Progress Goals present our 

largest concerns. Setting a Reasonable Progress Goal for the worst days at the Uniform Rate of 

Progress and a Goal for the best days at current monitored values is inconsistent with the 

Regional Haze Rule. After working for many years with the southeastern states through 

VISTAS, it is our opinion that the CMAQ modeling provides the best estimates of visibility 

improvement from control strategies and therefore should be used for both worst day and best 

day Reasonable Progress Goals. 

As part of its long-term strategy, we expect that the State will rely in great part on the new source 

review (NSR) and prevention of significant deterioration (PSD) programs to assure that new 

sources do not unduly impair the expected progress toward natural conditions. Section 7.2.1 of 

the November 2007 draft speaks to emissions reductions of ongoing programs but does not 

include a discussion of the interaction between the existing new source review program and 

progress on the regional haze plan. Given the uncertainty in the new source growth estimates 

used to develop the 2018 emissions inventory, and ultimately the 2018 visibility projections, we 

feel it would be appropriate for the state to discuss the relationship between the Regional Haze 

Plan and requirements of the NSR and PSD programs within the SIP. Specifically, how does the 
State anticipate addressing new sources of air pollution in the PSD process in regards to its 

reasonable progress goals and long term strategy; and, how will it analyze the affect of new 

emissions from these new sources on progress toward the interim visibility goals established 

under this SIP, as well as the ultimate goal of natural background visibility by 2064? 

Finally, we recognize that the Regional Planning Organizations have provided significant 

resources to the states throughout the Regional Haze planning process, and that it will be 

detrimental to the state agencies if these resources are no longer available for subsequent 

planning and periodic SIP reviews. We will strongly encourage the EPA to maintain support for 

the Regional Planning Organizations and the integrated technical analyses that will be necessary 

as we begin tracking reasonable progress for the Class I areas under the Regional Haze State 

Implementation Plans. 

 

Specific Comments

While overall we are satisfied with the extent of the information provided in the Alabama Draft 

SIP, we will expand on the three areas of concern previously expressed and provide several 

suggested changes that we feel may increase the clarity of the document. The following 

comments are organized by Section of the draft SIP. 

Executive Summary: 

No comment, this section has yet to be added. 

Section 1: Introduction 

Page 1, paragraph 2 – Change “In eastern parks,...” to “In eastern Class I areas,...” This better 

reflects that Class I areas can be parks or wildernesses. 

 

Page 5, Figure 1.4-2 – The acreages for some of the Class I areas are incorrect. The correct 

acreages can be found on the spreadsheet distributed by Pat Brewer on or around October 30, 

2007. The correct acreage for Sipsey Wilderness is 24,922 acres. 

Page 10, Section 2.3 - The value for baseline 20% worst days for Sipsey should be expressed as a 

discrete value which is 29.0 dv. Likewise, natural background should also be expressed as a 

discrete value which is 11.0 dv 

Page 11, Table 2.3-1 – According to the ARS support document and the values posted on the 

VIEWS website, the natural background on the average 20% worst days should be 11.0 dv and 

30.3 Mm-1. 

 

Page 11, second paragraph – Sulfate levels on the 20 % worst days account for 75% of visibility 

impairment at Sipsey. Also, consider changing sentence 4 to, “On the best days at Sipsey 

ammonium sulfate accounts for 50% of visibility impairment.” (See Section 3.4 of Appendix B 

for these values.) 
Page 13, second paragraph – Consider changing the second sentence to “Sources include 

agricultural and wildland (wildfire, wildland fire use and prescribed fire) burning, and 

incomplete combustion of fossil fuels.” This more accurately characterizes the types of 

wildland fire that occur. 

Page 15, second paragraph – I did not find the CART analyses in Appendix B. Please identify 

the correct Appendix for this information. 

Section 4.1: Baseline Emissions Inventory 

Page 19, 4th paragraph – The statement, “Thus, fire emissions remain the same for air quality 

modeling in both the base and any future years” is misleading and should be corrected. I believe 

the intent may have been to say that the fire locations remained the same. In fact fire emissions 

for 2009 and 2018 were increased in all states except Florida to reflect anticipated increases in 

the use of prescribed fire as a management tool on federal lands. This is discussed in section 

4.1.7 on page 21 of the draft SIP. 

Page 21, Table 4.1 – It would be helpful to show values for the EGU and non-EGU point sources 

instead of lumping them into a single category, because they are often referred to as EGU and 

non-EGU throughout the document. 

 

Section 7: Long Term Strategy 

Page 42, Section 7.2.1 - Appendix H states that Cargill Sweeteners will be reducing emissions 

by 50% under a Consent Decree with EPA. This should be added to the list of Control 

Requirements that begins on Page 42. 

Page 44, Smoke Management Plan section – This entire section would be better placed in 

Section 7.9 that addresses additional control strategies considered, because there are no 

calculated emissions reduction strategies for smoke as there are with the other programs listed. 

Wherever this section resides, there are changes that need to be made. The first statement is 

from the Grand Canyon Visibility Transport Commission (GCVTC) Report and applies only to 

the states in that area. The second sentence references Section 51.309(d) of the Regional Haze 

Rule which is an alternative to Section 51.308 for only those states in the GCVTC area, not 

Alabama. We recommend that ADEM delete the first two sentences of this section. The first 

sentence could be replaced with a statement that is supported by VISTAS findings or with 

statements regarding fire emissions that are found elsewhere in the draft SIP. The second 

sentence should be corrected to read “Section 51.308(d) (3) (v) of the Regional Haze Rule 

requires that the State must consider, at a minimum, the following factors in developing the longterm strategy: ...(E) Smoke management techniques for agricultural and forestry management 

purposes including plans as currently exist within the State for these purposes.” You could then 

continue with the remainder of the section as it is. 

Page 45, Section 7.2.2 – In conjunction with the comments above, we suggest making reference 

to the more complete discussion in Section 7.9, page 74. 
Page 45, Section 7.2.3, last sentence on the page – Consider changing the end of this sentence to 

read “...comprising more than half of remaining SO2 emissions in most states...” because the 

referenced figures show 2018 EGU emissions to be less than half of remaining emissions for 

Georgia, Mississippi and Virginia. 

Page 47, Tables 7.2.3-1 and 7.2.3-2 – Consider addition of EGU and non-EGU as subcategories 

of point sources, similar to what has been recommended for Table 4.1. 

Page 47, Section 7.2.4, paragraph 2 – Change the first sentence to “... visibility improvement on 

the worst days by 2018 resulting from the...” for clarity. 

Page 48, Figure 7.2.4-1 - Consider changing the title associated with the graphic to Reasonable 

Progress Assessment for Sipsey on the Worst 20% Days, because that is what is shown and this 

title makes Figures 7.2.4-1 and 7.2.4-4 more consistent with one another. 

Page 48, First paragraph – Again, include the phase “on the worst days” for clarity. 

Page 49, Last sentence – Consider changing it to “Specifically, Figure 7.2.4-4 demonstrates that

no degradation should occur for the Sipsey Wilderness Area, and, in fact, visibility should 

improve beyond that level. 

Section 7.5: Area of Influence 

Section 7.5 of the SIP identifies the geographic area of influence for Sipsey Wilderness. The 

Area of Influence (AOI) discussion is of particular importance to the Forest Service FLMs for 

several reasons. First, the information provided by the VISTAS Regional Planning Organization 

(RPO) allowed the states and FLMs to come to consensus on the realm of sources to be 

considered under further reasonable progress assessments for the VISTAS states, including 

Alabama (consultation meeting the week of June 12, 2007). Second, the AOI analysis can assist 

the VISTAS states in identifying sources anticipated to affect visibility in 2018 whether for Class 

I areas within their state, or for Class I areas in neighboring states. This source-specific 

information has provided a basis for state-to-state consultation both within the VISTAS region, 

and with states outside of the VISTAS RPO. Finally, the AOI information can assist states in 

highlighting which sources they may need to follow up with in subsequent planning and review 

periods as they track progress towards the national visibility goal. Because the AOI information 

can serve so many purposes we would like to see a table in the body of the SIP that provides 

information on sources affecting Sipsey (whether inside or outside of Alabama), as well as 

information on Alabama sources that affect Class I areas outside of Alabama. This is discussed 

further under Section 7.7. 

Pages 62 & 63 - The graphics in Figures 7.5.4-1 and 7.5.4-2 could be modified to show only the 

AOI metrics ADEM decided to utilize (in consultation with other VISTAS states and the FLMs) 

to consecutively narrow the potential list of sources for inclusion in the final AOI (i.e. Only show 

the lines for Residence Times greater than 5% and 10%, and not the 100 and 200 km radii). 

Section 7.7: Reasonable Progress 
Page 69, Step 4 - We recommend the addition of a Table that shows all sources within the AOI 

(including those outside of Alabama) affecting Sipsey. Something similar to Table 5-2 on page 

H-43 of Appendix H; except that we would add county, plant name, unit descriptions, the 

fractional contribution to Q/d*RTMax, the 2002 and 2018 tons of sulfur dioxide emissions, and 

any reduction of emissions due to Reasonable Progress and BART. It is easier for a reader to 

have this information in the body of the SIP and not have to go to Appendices. The same or a 

similar table should also include Alabama sources affecting Class I areas outside of Alabama. 

(We suggest that ADEM contact Doris McLeod with Virginia Department of Environmental 

Quality to see how they are addressing this in Table 7.7.4-2 of their draft SIP.) 

Page 69, Step 5 – Appendix H, Table 5.2 shows three non-EGU facilities in the AOI for Sipsey 

but only one, Cargill Sweeteners North America, was evaluated under “Reasonable Progress”. 

We feel that Solution Inc. and International Paper should also go through the four factor 

“Reasonable Progress” analysis if there are any units that were not addressed under BART. In 

addition, the four-factor analysis for Reasonable Progress should also be conducted for Alabama 

sources that affect Class I areas outside of Alabama. From the AOI tables in Appendix H (pages 

H-43-49) it appears that the following facilities should be added to Alabama’s Reasonable 

Progress analyses: Escambia Operating Company (Breton and St. Marks), and Sanders Lead 

Company (St. Marks). 

Page 69, Step 5 – It would be helpful to have a least a short summary of all Reasonable Progress 

evaluations in the body of the SIP. 

Page 69 – One use of AOI information is to identify sources that will most likely be evaluated 

for additional emission reductions at the mid-course review or in the next planning period. For 

example, while the cost of applying controls to a source may be considered prohibitive now, the 

same cost may be reasonable in the next planning period. It would be beneficial to add the cost 

information to the table of information on the sources within the AOI that are analyzed for 

Reasonable Progress as well as BART controls. 

Section 7.8: BART 

Page 73, Table 7.8.4-1 – Why was Oak Grove Resources JCDH exempted from BART when the 

modeled impact at Sipsey was above the threshold of 0.5? 

Page 74, first paragraph, last sentence – We recommend the following change to the last 

sentence. “All eight EGUs demonstrated visibility impacts below the exemption threshold for all 

Class I areas.” 

Page 74, Section 7.8.5 – As we stated for Reasonable Progress, it would be beneficial to have 

short summaries of the BART determinations in the body of the SIP. Since there are only two 

sources this seems reasonable. We also would like to see the information from the summaries in 

a table, similar to comments under Reasonable Progress. We are interested in seeing emissions 

from 2002, 2018 (pre-BART) and 2018 (with BART) for the two sources that went through 

BART determinations. 
Section 7.9: Additional Emissions Controls Considered 

Page 75 – The first paragraph addresses emissions from agricultural and wildland burning and 

we concur that emissions of elemental carbon from this source category are a minor contributor 

to visibility impairment at Sipsey. We recommend that ADEM includes a statement that the 

prescribed fire smoke management techniques practiced currently, appear to be adequate for the 

purpose of visibility protection in this planning period. (ADEM could also mention that current 

smoke management guidelines specifically identify Class I areas as Smoke Sensitive Areas to be 

considered during smoke management planning.) Further we recommend that ADEM discusses 

the Alabama Smoke Management Program and the connection to the 1998 Interim Air Quality 

Policy on Wildland and Prescribed Fires, but does not include the Smoke Management Program 

as part of the Alabama SIP. If the Program is discussed but not included in the SIP, maximum 

flexibility is maintained to modify the Program on an as-needed basis without having to go 

through a SIP revision. This is especially important should we find that changes are needed to 

address human health concerns. 

Page 75, last paragraph – This paragraph seems out of place, as it discusses Reasonable Progress 

Goals, however we agree with the strategy of revising the Goals based on the best and final 

modeling results which reflect the cumulative benefits of the Base G2a emissions controls, 

BART controls and any additional measures to achieve reasonable progress by 2018. We hope 

that ADEM will adopt this position and use, at a minimum, the results of the modeling for the 

best and worst days as their minimum reasonable progress goals, in spite of the contradiction we 

see in Section 8. 

Page 76 - Figure 7.10-1 is very confusing and we suggest ADEM consider a different graphic or 

better explain what is being shown by the existing graphic. 

Page 78 and 79 – We like the inclusion of WINHAZE images to demonstrate pictorially the 

visibility change expected from emission reductions included in the SIP. 

Section 8: Reasonable Progress Goals 

ADEM proposes a Reasonable Progress Goal (RPG) equal to the 2018 value for Uniform Rate of 

Progress (URP) for the 20% worst visibility days, and a RPG equal to the current value for the 

20% best visibility days. This is inconsistent with the Regional Haze Rule, which says: “The 

State may not adopt a reasonable progress goal that represents less visibility improvement than is 

expected to result from implementation of other requirements of the CAA during the applicable 

planning period.” (See 40 CFR 51.308(d)(1)(B)(vi).) It’s our understanding that the 2018 

visibility projections presented in Section 7.10 were based upon “emission growth” and “on the 

books” controls, which are State and Federal controls that will be implemented between the 2002 

base year and the 2018 future year. (The final modeling results will also include emission 

reductions due to BART.) Since these projections show more improvement than the Uniform 

Rate of Progress, the citation listed above should lead ADEM to adopt the results of the final 

VISTAS modeling exercise as the minimum Reasonable Progress Goals for 2018. This includes 

goals for both the worst and best days.

ADEM states that the reason for adopting the URP is based on uncertainties in the modeling. As 

members of VISTAS, the FLMs have worked with the states to develop mutually agreeable 

analyses for use in preparing the Regional Haze SIPs, and as such felt there was agreement that 
the VISTAS analyses provide the best estimates for use in RH SIPs. It is our feeling that 

uncertainty is best dealt with at the mid-point review in 2013. At this time the State will access 

whether emission reductions and visibility changes are consistent with expectations. If they are 

not, then the State has several options available, including revising the SIP and the Long-Term 

Strategy to better reflect emissions changes and reassessing the impact on visibility 

improvement, including setting new reasonable progress goals if necessary. 

Section 11: Comprehensive Periodic Implementation Plan Revisions 

While large sulfur dioxide emissions reductions are anticipated under CAIR, EGU emissions are 

expected to remain a significant contributor to regional haze in 2018 even after implementation 

of this Federal Rule. Given that additional EGU reductions will still be necessary after 2018, and 

that there is a fair amount of uncertainty surrounding the modeling analyses conducted for future 

year projections as well as what is actually going to occur under CAIR, the tracking and review 

periods under the Regional Haze Regulations become increasingly important from the FLMs 

perspective. We are pleased to see ADEM’s commitment to completing the reasonable progress 

reports every five years, as well as comprehensive SIP revisions in subsequent planning periods, 

in accordance with the Regional Haze Regulations. 

We are also pleased to see that ADEM has included measures for ongoing consultation with the 

FLMs on page 85 and included annual discussions of the implementation process and the most 

recent IMPROVE monitoring data. We recommend adding the following sentence to clearly 

define “ongoing consultation” for future planning periods. “Consultation between ADEM and 

the FLMs will include early involvement of FLMs in the periodic review process and FLMs will 

receive copies of revised regional haze SIPs for comment prior to finalization.” We feel that 

clearly establishing the process for FLM consultation in the SIP document may eliminate any 

confusion as to what “ongoing consultation” requires in future years. 
Fish and Wildlife Service Comments regarding the Alabama Regional Haze State 

Implementation Plan 

Overall the Alabama draft Regional Haze State Implementation Plan is comprehensive and well 

written. With a few modifications, this SIP would be a good example for other states. 

Comments indicated in bold are of special importance and unless adequately addressed would be 

comments that would be significant comments that would be elevated to the Assistant Secretary 

of the Department of Interior. 

International Impairment

On pages 16, 48, 53, and 54 -- This is the first of many examples when the State subtracts 

estimates of 2018 visibility impact due to international emissions. Later in the document, the 

State refers to all international impairment predicted for 2018 as non-natural. This has been 

debated. On page 10, Section 2.3, it states: “note that Alabama is not considering international 

emissions to be a component of natural background.” 

 

It is assumed that a fraction of the 2064 natural visibility condition is also attributable by 

international emission. Estimates vary but have been discussed by the RPOs. 

Providing graphics with 2018 reductions due to international contribution without representing 

the matching difference in 2064 natural conditions is misleading and should be added. At 

minimum, it should be added in the narrative as a modifying effect. 

Smoke Management Plan

On pages 44 and 75, the strong reference and possible inclusion of the State's smoke 

management plan in appendix may require a RH SIP revision each time the SMP is revised. 

Because the State establishes that contribution from smoke is a lower priority contribution, the 

State should consider discussing the benefit of the SMP without the strong reference or 

inclusion. It should be included whether the SMP is a voluntary or mandatory program. 

The State should also make a statement on whether the SMP includes Class I areas as a sensitive 

receptor. This is the most important factor to specify in determining whether a SMP has a direct 

effect on Class I visibility. 

BART

On page 74, Section 7.8.5, Alabama’s Evaluation of Subject-to BART Sources -- The State 

should summarize the two BART determinations (Solutia and International Paper-Courtland) in 

the this section of the SIP. A discussion of the emissions from the 2002, 2018 (pre-BART) and 
2018 (with BART) should be included for the sources that went through the BART 

determination. 

In this section it states that the permit will be issued prior to the public notices of the Regional 

Haze SIP. The state should describe the public notice for the permits being issued to address 

regional haze. 

Reasonable Progress Goal

On page 80, The State may not adopt a RP goal at a level less than what would be expected 

from implementing CAA program emission reductions. By adopting the URP for both the 

20% best and 20% worst day, the State has underestimated the benefit that is predicted to 

occur. 

 

Setting a Reasonable Progress Goal for the worst days at the Uniform Rate of Progress and 

a Goal for the best days at current monitored values is inconsistent with the Regional Haze 

Rule. The VISTAS CMAQ modeling should be used for both the worst day and best day 

Reasonable Progress Goals. 

ADEM proposes a Reasonable Progress Goal (RPG) equal to the 2018 value for Uniform 

Rate of Progress (URP) for the 20% worst visibility days, and a RPG equal to the current 

value for the 20% best visibility days. This is inconsistent with the Regional Haze Rule, 

which stays: “The State may not adopt a reasonable progress goal that represents less 

visibility improvement than is expected to result from implementation of the other 

requirements of the Clean Air Act (CAA) during the applicable planning period.” (See 40 

CFR 51.308(d)(1)(B)(vi).) 

It is our understanding that the 2018 visibility projections presented in Section 7.10 were 

based upon the “emissions growth” and “on the books” controls, which are State and 

Federal controls that will be implemented between 2002 based year and the 2018 future 

year. The final modeling results will also include emission reductions due to BART.) Since 

these projections show more improvement than the Uniform Rate of Progress, the citation 

listed above should lead ADEM to adopt the results of the final VISTAS modeling exercise 

as the minimum Reasonable Progress Goals for 2018. This includes goals for both the 

worst and best days. 

ADEM states that the reason for adopting the URP is based on uncertainties in the 

modeling. As members of VISTAS, the FLMs have worked with the states to develop 

mutually agreeable analyses for use in preparing the Regional Haze SIPs, and as such felt 

there was agreement that the VISTAS analyses provided the best estimates for use in the 

Regional Haze SIPs. Any uncertainty is best dealt with at the mid-point review in 2013. At 

this time the State should access whether the emission reductions and visibility changes are 

consistent with expectations. If not, then the State could revise the SIP and the Long-Term 

Strategy to better reflect emission changes and reassess the impact on visibility 

improvement, including setting new reasonable progress goals. 
In addition, the State should discuss the Regional Progress Goal and how it will affect the 

Breton and St. Marks Class I areas. 

On page 81, the State relies on the IMPROVE monitoring network to track visibility impairment 

into the future. The State should identify/discuss a backup plan to maintain tracking in the event 

of a loss of IMPROVE data. 

Affects of NSR/PSD permitting programs on the Long Term Strategy

Page XX (add to Section 7 – similar to fire section), the State should include a discussion about 

the relationship between PSD/NSR programs as part of the other programs that will benefit 

visibility in the LTS section. A new or modified major industrial source can have a serious 

impact on the State's ability to obtain RH goals. 

As part of the Long- Term Strategy (LTS), the State will rely in great part on the New Source 

Review (NSR) and Prevention of Significant Deterioration (PSD) permitting programs to assure 

that new sources do not unduly impair the expected progress toward natural conditions. Section 

7.2.1. of the November 2007 draft SIP speaks to emissions reductions of ongoing programs but 

does not include a discussion of the interaction between the existing NSR program and progress 

on the regional haze plan. Given the uncertainty in the new source growth estimates used to 

develop the 2018 emission inventory, and ultimately the 2018 visibility projections, it would be 

appropriate for the state to discuss the relationship between the Regional Haze Plan and 

requirements of the NSR and PSD programs within the SIP. Specifically, how does the State 

anticipate addressing new sources of air pollution in the PSD process in regards to its reasonable 

progress goals and long term strategy; and, how will it analyze the affect of new emissions from 

these new sources on progress toward the interim visibility goals established under this SIP, as 

well as the ultimate goal of natural background visibility by 2064. 

Inter-State Consultation and Coordination

Page XX (add a new section), The State should make a statement about their impact (or 

lack of) on Class I areas outside the State. This discussion should include inter-State 

consultation documentation and a discussion on the affects on Breton Wilderness Area. 

The State should discuss and identify contribution of visibility impairing emissions from areas 

outside of Alabama (i.e. Breton and St. Marks). This should include apportionment information 

developed by the RPOs regarding Mississippi, Florida, and off shore Gulf emissions. 

The State should present apportionment information to neighboring states and the Gulf 

permitting authorities and provide information regarding consultation with these entities. Clearly 

identifying these attributions also will assist in future requirements to assess the progress towards 

natural visibility conditions Breton and St. Marks during the State’s mid-term review process in 

5 years. 
Items Relating to Alabama BART 

BART-Eligible Issues 

Sanders Lead and Escambia (Natural Gas Processing Plan, Flomation) do not appear on the 

“BART Eligible Unit List” (Attachment H.3) of the RHSIP, but the FWS received hardcopies of 

their exemption modeling. Both were below the 0.5 dv impact cutoff. It seems that they should 

appear on the BART Eligible Unit List. 

The Alabama Modeling Summary (Attachment H8) of the RH SIP lacks the modeling results for 

the following facilities that appear on the BART Eligible Unit List: 

- Escambia Operating Company – Big Escambia Creek (We can’t tell if this is the 

 same facility or a different one than the Escambia Natural Gas Processing Plant at 

 Flomation) 

- Alabama Power Co., Plant Barry 

- Chemical Lime Corp., Montevallo Plant 

- Chemical Lime Corp., Alabaster Plant 

- Alabama Power Co., Plant EC Gaston 

- Alabama Power Co., Plant Greene Co 

- Alabama Power Co., Plant Gorgas 

- American Cast Iron Pipe Company 

- TVA, Widows Creek 

- TVA, Colbert 

- Alabama Power Co., Plant Miller 

- Sanders Lead Company, Inc. 

- Hunt Refining Company 

- BP Amoco Chemical Company, Decatur Works 

BART Determination Issues 

Attachment H8 of the RHSIP contains State-developed summaries of the two BART 

Determinations of Solutia, Inc. and International Paper – Courtland Mill. The actual company 

BART Determination documents on the Clearinghouse cannot be located. The State summaries 

lack a significant amount of information making it impossible to perform a meaningful thirdparty review. We would appreciate receiving the Company BART Determinations. 

A potential issue relates to the significant 7.21 deciview impact of Solutia, Inc. on Sipsey as 

shown in Table 7.8.4-1. This impact should be reexamined and evaluated using the New 

IMPROVE equation. Such significant impact portends a closer look at possible controls that 

might be considered by Solutia, Inc. in its BART determination. 

There is a contradiction regarding Oak Grove Resources - JCDH in that the Alabama Modeling 

Summary (Attachment H8 – Table 4-6) shows this facility to have a 0.021 dv impact when Table 
7.8.4-1 of the RHSIP shows an impact of 0.535 dv. This difference should be explained or 

rectified.