# Appendix P

FLM Comments

on Alabama’s Draft RH SIPThe following comments were received on Al abama’s Draft Regional Haze SIP from the Department of Agriculture’s National Forest Serv ice 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, Ai r Resource Specialist dated 2/5/08File 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 submitte d 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, s ubsequent 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. Departme nt of Agriculture, Forest Service, has received and conducted a substantive review of your propos ed Regional Haze Rule implementation plan. Please note, however, that only th e U. S. Environmental Protection Agency (EPA) can make a final determination about the document’s comple teness, and therefore, only the EPA has the ability to approve the document. The Forest Se rvice’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 Cl ean Air Act and its implementing regulations.

As outlined in a letter to the St ate 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 consultati on 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 clos ely 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 SupervisorEnclosure 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 e ach of the priority content areas with which the Federal Land Managers (FLMs) are concerned in th e draft Regional Haze Regulations State Implementation Plan (SIP), an d 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 con cerns are addressed in more detail in our section-specific comments, and include:

 the lack of information within the main bo dy 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 fr om 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 Man agement Program into the SIP

.

All of these issues warrant further attention; but the Reasonable Progress Goals present our largest concerns. Setting a Reas onable Progress Goal for the worst days at the Uniform Rate of Progress and a Goal for the best days at curren t monitored values is inconsistent with the Regional Haze Rule. After working for many y ears with the southeas tern states through VISTAS, it is our opinion that the CMAQ modeli ng provides the best estimates of visibility improvement from control strategies and theref ore 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 progre ss toward natural condi tions. Section 7.2.1 of the November 2007 draft speaks to emissions reductions of ongoing programs but does not

include a discussion of the in teraction between the existing new source review program and progress on the regional haze plan. Given the un certainty in the new source growth estimates used to develop the 2018 emissions inventory, an d ultimately the 2018 visibility projections, we feel it would be appropriate for the state to di scuss the relationship between the Regional Haze Plan and requirements of the NSR and PSD progr ams within the SIP. Specifically, how does theState anticipate addressing new sources of air po llution 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 to ward the interim visibility goals established under this SIP, as well as the ultimate goal of natural backgrou nd 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 re sources 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 an alyses that will be necessary as we begin tracking reasonable progress for th e 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 con cern previously expresse d and provide several suggested changes that we feel may increase the clarity of the document. The following comments are organized by S ection of the draft SIP.

Executive Summary : No comment, this sectio n 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 sp readsheet 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% wo rst days for Sipsey should be expressed as a

discrete value which is 29.0 dv. Likewise, natural background s hould 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, c onsider 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 changi ng the second sentence to “Sources include agricultural and wildland (wildfire, wildl and 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, 4 th paragraph – The statement, “Thus, fire em issions remain the same for air quality modeling in both the base and any fu ture years” is misleading and s hould be corrected. I believe the intent may have been to say th at the fire locations remained th e 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 Sweetener s 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 addi tional control strategies cons idered, 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 Co mmission (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 fi rst two sentences of this section. The first sentence could be replaced with a statement that is supported by VIST AS 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 cons ider, at a minimum, the followi ng 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 a ddition 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 fi rst 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 Si psey 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 mo re consistent with one another.

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

Page 49, Last sentence – Consider cha nging 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 partic ular importance to the Forest Service FLMs for several reasons. First, the information provi ded 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 a ssessments 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 vi sibility 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-sta te consultation both within the VISTAS region,

and with states outside of the VISTAS RPO. Fi nally, the AOI information can assist states in highlighting which sources they may need to fo llow up with in subsequent planning and review periods as they track progress towards the nationa l visibility goal. Because the AOI information can serve so many purposes we would like to s ee 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 a nd 7.5.4-2 could be modified to show only the

AOI metrics ADEM decided to utili ze (in consultation with other VISTAS states and the FLMs) to consecutively narrow the potentia l 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 ProgressPage 69, Step 4 - We recommend the addition of a Table that shows all sources within the AOI (including those outside of Alabama) affecting Si psey. Something similar to Table 5-2 on page H-43 of Appendix H; except th at 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 Progr ess 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 w ith 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. a nd International Paper should al so 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 fo llowing facilities should be ad ded to Alabama’s Reasonable Progress analyses: Escambia Operating Compa ny (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 iden tify sources that will mo st likely be evaluated

for additional emission reductions at the mid-course review or in the next planning period. For example, while the cost of appl ying controls to a source may be considered prohibitive now, the same cost may be reasonable in the next planning period. It would be bene ficial 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 Resour ces 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 fo llowing 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 Reasonabl e 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 lik e to see the information from the summaries in a table, similar to comments under Reasonable Progr ess. 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 Emi ssions Controls Considered Page 75 – The first paragraph addresses emissi ons from agricultural a nd wildland burning and we concur that emissions of elemental carbon from this source category are a minor contributor to visibility impairment at Sipsey. We reco mmend that ADEM includes a statement that the prescribed fire smoke management techniques prac ticed 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 identif y 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 doe s 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 Progr am on an as-needed basis without having to go through a SIP revision. This is especially importa nt 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 be nefits 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 pr ogress 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 in clusion of WINHAZE images to demonstrate pictorially the visibility change expected from emi ssion 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 inconsiste nt 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 implem entation of other requirements of the CAA during the applicable planning period.” (See 40 CFR 51.308(d)(1)(B)(vi ).) It’s our understa nding that the 2018 visibility projections presen ted 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 fina l modeling results will also include emission reductions due to BART.) Sin ce these projections show more improvement than the Uniform Rate of Progress, the citation li sted 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 thatthe 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 re view in 2013. At this time the State will access whether emission reductions and visibility changes are consistent with exp ectations. If they are not, then the State has several options available, including revi sing the SIP and the Long-Term Strategy to better reflect emissions changes and reassessing the impact on visibility improvement, including setting new reasona ble progress goals if necessary.

Section 11: Comprehensive Periodi c Implementation Plan Revisions

While large sulfur dioxide emissions reductions are anticipated under CA IR, EGU emissions are expected to remain a significant contributor to regional haze in 2018 even after implementation

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

that there is a fair amount of uncertainty surrounding the modeli ng 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 co mmitment to completing the reasonable progress reports every five years, as we ll as comprehensive SIP revisions in subsequent planning periods, in accordance with the Regional Haze Regulations.

We are also pleased to see that ADEM has incl uded 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 recomme nd adding the following sentence to clearly define “ongoing consultation” fo r 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 consul tation in the SIP document may eliminate any confusion as to what “ongoing consulta tion” requires in future years.Fish and Wildlife Service Comments regarding the Alabama Regional Haze State Implementation Plan

Overall the Alabama draft Regional Haze State Im plementation 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 firs t 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 fo r 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 natura l 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 c ontribution without representing the matching difference in 2064 natural conditio ns is misleading and should be added. At minimum, it should be added in th e 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 discussi ng the benefit of th e 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 whethe r 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 (S olutia and Inte rnational Paper-Courtland) in the this section of the SIP. A discussion of the emissions from the 2002, 2018 (pre-BART) and2018 (with BART) should be included for th e 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 wors t days at the Uniform Rate of Progress and a Goal for the best days at current monitored val ues 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 rea sonable 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 th e books” controls, which are State and Federal controls that will be implemente d between 2002 based year and the 2018 future year. The final modeling results will also incl ude 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 re sults 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 de alt 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 em ission changes and reassess th e impact on visibility improvement, including setting new reasonable progress goals.In addition, the State should discuss the Regi onal Progress Goal and how it will affect the

Breton and St. Marks Class I areas.

On page 81, the State relies on the IMPROVE mon itoring 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 sect ion), 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 modifi ed 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 St ate will rely in great part on the New Source Review (NSR) and Prevention of Significant Deterioration (PSD) pe rmitting 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 visibi lity 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 proce ss 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 visibili ty 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 informa tion to neighboring states and the Gulf permitting authorities and provide information regard ing consultation with these entities. Clearly identifying these attributions also will assist in future requirements to assess the progress towards natural visibility conditions Bret on 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 Proces sing 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 th e 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 – Cour tland Mill. The actual company BART Determination documents on the Clearinghous e cannot be located. The State summaries lack a significant amount of information making it impossible to perform a meaningful thirdparty review. We would appreciate recei ving 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 porte nds a closer look at po ssible controls that might be considered by Solutia, Inc. in its BART determination.

There is a contradiction regard ing 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 Table7.8.4-1 of the RHSIP shows an impact of 0.535 dv. This difference should be explained or

rectified.