### Technical Comments on the Public Review Draft of the

Washington State Regional Haze State Implementation Plan

Reasonable Progress Goals

Although Ecology has improved its documentation of a four

- factor analysis, it has not yet taken
measures to reduce emissions of haze

- causing pollutants beyond BART. Because Ecology’s Reasonable Progress Goals are substantially slower than the uniform rate of progress, the Regional Haze Rule requires sta tes to further reduce its emissions or demonstrate why additional emission reductions are not reasonable at this time. Ecology has identified several source categories for which NOx and SO 2 emission reductions may be reasonable including process heaters, FCCU/CO Boiler units at petroleum refineries, dry process cement kilns, industrial boilers, and Kraft pulping mills. Ecology states that it is not reasonable to require additional
controls on these sources at this time because of there is not sufficient time to go through the rule making process, as would be required under Washington State Law. However, we note that Oregon was able to identify go through the rule making process to obtain controls under Reasonable Progress for the PGE Boardman Facility.

Additionally, it is unclear why Ecology is setting the Reasonable Progress Goals for the 20% Least Impaired Days as no degradation (i.e., the same deciview value as baseline) when the WRAP modeling shows lower values are projected for all Class I areas in Washington.
This is in contradiction to § 51.308 (d) (1) (vi)

“ (vi) 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. ”

In Ecology’s “ Federal Land Managers Comments and Ecology’s Response to Comments ” document (Appendix B, p. B12), Ecology addresses the Forest Service concern that visibility conditions at the NOCA1 IMPROVE site are projecte d to deteriorate by 2018. The Forest Service acknowledges that the roughly 9,500 tpy of SO2 reductions apparently not included in the WRAP modeling are significant and would most likely influence the projected visibility conditions favorably. Indeed wors t 20% day sulfate concentrations have been declining at most Washington Class I areas, including NOCA1, from 2000 to 2008. In the same time period, however, monitoring data shows that clearest 20% day sulfate values at NOCA1 are increasing. In discussing the FS comment on modeled increase in sulfate impacts at NOCA1, Ecology makes the following statement: “Ecology’s investigation of the projected increases in visibility impairment at NOCA1 concluded that the projected increase in visibility impairment is the result of the comparatively long residence time of air parcels near the monitor combined with the presence of large point sources of SO 2 .”2

In light of the worsening clear day sulfate concentrations, the confusion surrounding the WRAP modeling results , and Ecology’s own statement that increasing impairment at NOCA1 can be expected due to large nearby SO2 point sources, it would seem that these large point sources should be identified, and would be candidates for reasonable progress controls as soon as practicable.

TransAlta BART Determination

Flex Fuels plus Selective Catalytic Reduction

The BART rule (FR Vol. 70. No. 128/July 6, 2005), specifies the five

- step process used in determining BART. These steps are as follows:
1. Identifying all available retrofit technologies ; 2. Eliminate technically infeasible options ; 3. Evaluate control effectiveness of remaining control technologies ; 4. Evaluate impacts and document the results ; and
5. Evaluate visibility impacts

.

The process is very linear. Ecology appropr iately identified both selective catalytic reduction (SCR) and selective non

- catalytic reduction (SNCR) as available retrofit technologies for controlling NOx. However, it is unclear whether or not Ecology is stating that SCR is technically infeasible or not due to complications associated with the tight spacing at TransAlta’s Centralia facility. Ecology’s cites the following issues for not selecting SCR as BART (Appendix L of Public Review Draft of the WA RH SIP):

T he tight construction site

, P otential difficulty in finding a location for ammonia storage that is safe, does not impede access to other components, or interfere with underground or above ground utilities and ducting,
El evated construction location , and Difficulty in ducting exhaust gas from the boiler through the SCR units to the ESPs while achieving even flue gas distribution across the SCR catalyst beds and within the ESP.

The final BART rule states (page 39165 of the July 6, 2006 FR/Vol. 70. No. 128) “ where you
conclude that a control option identified in Step 1 is technically infeasible, you should demonstrate that ... specific circumstances preclude its application to a particular emission unit. A demonstration of technical infeasibility may involve irresolvable technical difficulties with applying the control to the source (e.g., size of the unit, location of the proposed site, operation3

problems related to specific circumstances of the source, space constraints, reliability, and adverse side effects on the rest of the facility). Wh ere the resolution of technical difficulties is merely a matter of increased cost, you should consider the technology to be technically feasible. The cost of a control alternative is considered later in the process. ”

However, in Ecology’s BART Determin ation Support Documentation for TransAlta Centralia Generation, LLC Power Plant (Revised April 2010) Ecology states that “The primary difficulties are lack of space for easy installation of the catalyst beds and ducts, leading to very high
construction cos ts that far surpass ranges of acceptable cost effectiveness ”

. This implies that Ecology believes SCR is technically feasible, but was not selected as BART due to excessive costs. This is further supported by the statement that “Ecology concurs with Trans Alta that the construction costs to overcome the technical difficulties of retrofitting an SCR system on its boilers, given its current configuration and installed emission controls, render this technology economically infeasible for implementation at this time. ”

TransAlta evaluated the cost of retrofitting SCR in a “hot, dirty” location, above the first ESPs, as a cost of $413/kW, based upon scaling the $200/kW using “engineering judgment”. Ecology compares this with the PGE Boardman’s SCR retrofit cos t of $382/kW, prepared by PGE’s consultant. However, we note that the PGE cost estimate revised by Oregon DEQ, after hiring an independent third party engineering firm to analyze the costs (Eastern Research Group). ERG
estimated the cost of an SCR retrof it at the PGE Boardman facility at approximately $250/kW, which is 35% less than the estimate prepared by PGE’s consultant.

Today, we note a similar situation exists for the TransAlta Centralia power plant in which TransAlta has prepared a cost estimate, which varies greatly from estimates provided by the National Park Service and estimates in the ERG report to Oregon DEQ. Referring to the National Park Service references of costs for recent SCR retrofits, we note that “ the overall range for these industry studies is $50/kW to $300/kW. The upper end of this range is for highly complex retrofits with severe space constraints, such as Belews Creek, reported to cost $265/kW, or Cinergy’s Gibson Units 2

- 4. Gibson, a highly complex, space

- constrained r etrofit in which the SCR was built 230 feet above the power station using the largest crane in the world only cost $251/kW in 2007 ” . Thus TransAlta’s cost estimate of $413/kW is suspect because it far surpasses not only the revised costs for installing SC R at the PGE Boardman facility, but at other highly complex sites as well. Ecology did not perform and document its own independent cost
estimate.

Using the $413/kW estimate, Ecology states that annualized costs for installing SCR on both
units would h ave a cost effectiveness of $9091/ton NOx removed. Other states have found that $7300/ton is cost effective for NOx removal as BART. If TransAlta’s cost estimates are over

inflated, by 35

- 65% greater than the upper range of costs for other complex SCR installations, it4

appears that SCR installation at TransAlta would be reasonable. Ecology does not provide its own cost analysis which supports its rationale for dismissing SCR as infeasible due to excessive

costs

Ecology’s BART determination is also la cking an evaluation of the visibility improvement which could be accomplished by Flex Fuels plus SCR. Thus the benefits associated with incurring the costs of adding SCR on both units is not quantified, thus the BART analysis is incomplete.

Flex Fuels Plus Selective Non

- Catalytic Reduction (SNCR)

The rationale Ecology provides for not selecting Flex Fuels plus SNCR as BART for NOx is unconvincing. Ecology cites the combination of the following factors, when considered together; provide sufficient ra tionale for Ecology to dismiss this option as BART. These factors

are:

Incremental cost effectiveness energy and non

- air quality environmental impacts existing air pollution controls, remaining useful life of the facility, and Compliance with State cl imate change rules.

Each of these reasons is examined below.

Ecology states that the incremental cost effectiveness of Flex Fuels plus SNCR is $2145/ton

. Yet, it does not provide any additional analysis, such as creating a least

- cost envelope of
dominan t alternatives which would help one determine whether Flex Fuels plus SNCR is unreasonable. Ecology recognizes that the combination of Flex Fuels and SNCR would increase the level of visibility improvement at the 12 affected Class I areas, in some cases u p to nearly 2.0 deciviews of improvement. Ecology merely states that “While this additional project does result in some visibility benefit, we must also weigh other factors of the BART analysis to determine feasibility.

Additionally, Ecology identifies t he energy and non

- air quality environmental impacts as another factor in not selecting this option as BART. Ecology states that this alternative would result in a parasitic load of 1.4 MW. The EPA BART rule states “...because energy penalties or benefits can usually be quantified in terms of additional costs or income to the source, the energy impacts analysis can, in most cases, simply be factored into the cost impact analysis .”. It appears that Ecology is double counting energy penalties (i.e., parasit ic load) in making its BART
determination.5

Ecology also states that there is a potential for ammonia slip with SNCR, which would in turn contribute to visibility impacts. Ecology then states that this is a manageable impact. Ammonia slip may cause visib ility impacts in an ammonia limited environment. However Ecology has not demonstrated that the atmosphere between Centralia and the affected Class I areas is ammonia limited, nor has it quantified the potential impact through the modeling evaluation. In fact, this is an air quality impact, not a non

- air quality impact, under which it is claimed. Additionally,
SNCR has been selected as BART for a number of coal

- fired power plants, all of which face this same potential for ammonia slip (e.g., PGE Boardman, Oregon, Trigen Craig, CO, Golden Valley Electric Healy, AK, Basin Electric, Leland Olds Power Plant, ND, etc.). Apparently, other states believe this is a manageable issue.

Ecology also considered the existing controls at the facility in making its B ART determination. The BART rule allows for consideration of existing controls in the BART determination process. Existing controls are to be included as part of Step 1 (identify all available retrofit control techniques), and Step 2 (include control opt ions that involve improvements to existing controls in addition to add on or complete replacement of existing controls.) If the existing controls were put in place after the baseline period, they could be evaluated as any other control alternative. The p resence of existing controls by itself is not sufficient basis to dismiss other control technologies. Ecology already considers the comparative cost of existing controls and Flex Fuels plus SNCR in the incremental cost analysis. Ecology is double counting this factor as a rationale for not selecting Flex Fuels plus SNCR as BART.

Ecology also states that they believe the likely remaining useful life of the TransAlta Centralia facility is 15 years or less. Should this become an enforceable permit condition, then it can be
included in the determination of annualized cost effectiven ess, and not be considered as a separate factor. We refer Ecology to the most recent proposal by Oregon DEQ for early shutdown options for the PGE Boardman power plant as an example of the proper way to consider a shortened remaining useful life in determ ining BART.

Finally, Ecology identifies a proposed 3

- step process requiring TransAlta to comply with
Executive Order 09

- 05 pertaining to State climate change regulations. Ecology states that this factor affects the remaining life of the facility. As such, Ecology needs to account for this in the annualize costs of potential BART alternatives, and not cite it as an independent factor.

When only considering factors which are not double counted, Flex Fuels plus SNCR is not selected as BART solely becau se of the incremental cost effectiveness of $2145/ton. This value is within reasonable costs as identified by other states. Ecology should revise its BART
determination.6

BART Exemption Modeling for Alcoa Wenatchee Aluminum Works

The US Forest Service has reviewed Ecology’s response to our previous comments on the acceptability of the use of fine

- resolution CALMET wind fields in the Alcoa Wenatchee Works BART exemption modeling and information provided in Appendix I of the Public Review Draft
of the Re gional Haze SIP . Ecology’s response has not resolved our concerns about both procedural and technical issues with this analysis.

General Issues:

Ecology argued that no lower limit exists to the application of CALMET examined applications
of CALMET. E cology stated : “ After finding numerous references to analyses with CALPUFF using similar grid spacing in equally complex terrain between 1999 and 2007 and finding no mention of any lower limit to the acceptable meteorological grid spacing,” First, we would like to highlight the oversight in Ecology’s argument that, in each of the cases cited by Ecology, no corresponding performance evaluation was conducted that objectively documented that greater performance was achieved with the application of CALMET at a higher resolution. Rather, Ecology should have focused its review upon published cases that documented the improved performance of CALMET. Earth Tech (2001), RWDI (2002), and Scire et al. (2009) all documented evaluations of CALMET at high resolutions. In each case, poor performance was achieved when relying solely upon the ability of CALMET to induce specific features into the 3

- D windfield. Chandresekar (2003) provides the best summary of CALMET’s capabilities: “ ...regions of complex terr ain can introduce additional difficulties like inadequate density of observations, limitations of a diagnostic model to reproduce the observed features over complex terrain, and difficulties in fully resolving terrain features by using a coarse prognostic model over a complex terrain. The effectiveness of this approach may therefore be different for a region of complex terrain .”

Finally, it is important to note that EPA shifted its policy in 2009 regarding the resolution of
CALMET wind fields as a direct re sponse to the growing trend of applications of CALMET at higher resolutions with little or no scientific justification.

Procedural Issues:

Ecology acknowledges that the Washington

- Oregon

- Idaho BART Modeling Protocol was developed to provide consistency be tween the BART modeling performed in the three states. But Ecology also states that “ the authors of the protocol agreed that the document was to be a guideline, and that States have the ability to deviate from the guideline under certain
circumstances”

. There is no documented mechanism which allows for unilateral approval of deviations from the modeling protocol.

Further, section 6 of the EPA Guidelines on Air quality Modeling (GAQM) published in Appendix W of Part 51 includes recommendations regarding the application of CALPUFF for visibility assessments for long range transport in general. The GAQM indicates that such7

applications will require significant consultation with the appropriate reviewing authority and the affected FLM (Federal Land Manager ). As indicated in our previous comments, the reviewing authority (US EPA Region 10) and the US Forest Service have both indicated the unacceptable nature of Ecology’s deviation from the modeling protocol. As such, Ecology has not followed established pro tocol or EPA guidance on this issue.

Technical issues:

Ecology’s justification for use of the 0.5 km grid resolution is not consistent with EPA’s guidance on this issue. The May 15, 2009 EPA Regulatory Air Quality Modeling Clearinghouse
Memo states the following in addressing the use of fin er resolution CALMET wind field.

An argument for the use of finer resolution CALMET wind fields should address two
components.

1. The prognostic meteorological data sets from numerical weather prediction (NWP)
models la ck sufficient resolution to capture the meteorological features of interest which would be responsible for transport of airborne contaminants from the source to the Class I area(s) of interest.
2. Diagnostic wind model (DWM) such as CALMET can enhance the NWP data used as the first

- guess wind field (CALMET switch setting IPROG=14) sufficiently to adequately replicate the key meteorological features of interest.

In addressing the first issue, it is necessary to identify the meteorological features of interest
which are responsible for transport of airborne contaminants from Alcoa Wenatchee Aluminum Works to the Alpine Lakes Wilderness. In addressing this

, (1) the meteorological conditions associated with transport of air pollutants from Alcoa Wenatchee Aluminu m works to the Alpine
Lakes Wilderness need to be identified, and (2) the scale of motion needs to be identified for
these conditions.

A general rule of thumb is that a prognostic meteorological model cannot physically resolve a meteorological feature th at is less than five times the grid resolution (horizontally and vertically) (ref: NOAA COMET learning module on numerical weather prediction). Thus, if the horizontal grid resolution of the prognostic meteorological model is 4

- km, it is reasonable to ass ume that it cannot resolve a meteorological feature less than 20

- km in length or width.

For example, if a cold air mass descends along the east side of the Cascades causing easterly flows during the winter time, which transports pollutants from the Alcoa Wenatchee Aluminum Works to the Alpine Lakes Wilderness, then the scale of this synoptic system may be on the order of hundreds of kilometers, a phenomenon easily resolved by a 4

- km MM5 run. However, in the case of up

- valley flows driven by difference i n the local surface energy budgets, this phenomenon may be on the scale of the length of the valley of interest, something which may not be resolved by a 4

- km MM5 model8

Thus, if the locally

- forced flows (such as mountain

- valley winds) are the meteorological feature of interest and the only meteorological features which drive the transport winds from the Alcoa Wenatchee Aluminum Works towards the Alpine Lakes Wilderness, a nd these flows are less
than 20

- km, indeed, the 4 km NWP data cannot resolve this phenomenon. However, there may be other meteorological phenomenon of 20

- km or larger scale which can drive flows from the Alcoa Wenatchee Aluminum Works towards the Alpine La kes Wilderness. These should also be addressed and a discussion of which meteorological feature is associated with worst

- case haze impacts in the wilderness ought to be identified as well.

The second component of EPA’s recommendation is to demonstrate th at CALMET can enhance
NWP data used as the first

- guess wind field sufficiently to adequately replicate key meteorological features of interest.

One of the key contentions made by Ecology is that use of the 4

- km CALMET generated wind field creates “errors” in the surface wind field, which are resolved by use of the 0.5

- km wind field. This is demonstrated in Figure I

- 2 and I

- 3 in which both the 4

- km and 0.5

- km surface
winds are shown with the 0.5

- km resolved terrain as background. Ecology states “...the f iner resolution modeling provides a much more detailed spatial pattern in the winds which conforms more accurately to the terrain when compared with the wind fields from the lower resolution model runs. It is clear from these plots that the lower resolut ion runs will miss much of the terrain channeling within the modeling domain. More important, the failure of the 4

- km grid to accurately represent peaks w ill allow air to flow unimpeded through regions that would otherwise deflect it.” In examining the va lidity of this statement, we note the following.

Ecology’s approach is based upon the flawed assumption that increased structural detail of the higher resolution wind field is an indication of improved performance of the wind model. In the IWAQM guidance reassessment (EPA, 2009), EPA warned of the temptation to apply this form of reasoning. EPA stated: “... the higher resolution CALMET simulations may increase the structural detail of the final wind fields; however, the majority of CALMET evaluations to date have been subjective in nature and have relied upon the perceived increase in structural detail (i.e. “realism”). This evaluation relies upon the perceived increase in structural detail without any form of a statistical performance evaluation to verify the objective accuracy of high resolution wind fields. In short, a subjective assessment that a wind field is “realistic” is not sufficient to support the assumption that the wind field accurately reflects reality. ” Ecology uses the exact same reasoning a nd arbitrarily concludes that the increased structural detail must in fact be the correct wind field realization without any means to support such. In essence, the argument is condensed into “we will apply CALMET at a higher resolution to justify a higher resolution of
CALMET.”

Evaluation of the 4

- km and the 0.5

- km wind field is performed by comparing it with the 0.5

- km resolved terrain, not both the 4

- km and 0.5

- km terrain. Following this logic, it is reasonable to
conclude that the 0.5

- km winds should b e evaluated by comparing them with terrain resolved at a9

higher resolution, perhaps 10 meters. Under this evaluation scenario, if any locations occur
where the 0.5

- km winds appear to move towards the 10 meter resolved terrain, rather than tangential to th e terrain, then the 0.5

- km wind should be deemed inappropriate. Similarly, if 12

- km winds were plotted against a 4

- km resolved terrain, and locations were found in which the
12

- km winds were found to flow towards the terrain, then they should be found to be inappropriate. Following this logic, it appears that plotting the winds created with the same resolution as the terrain will always be selected, especially if the performance is evaluated based upon terrain following flows. Is there a point of diminis hing returns when the use of higher grid resolution no longer affects the results? If so, this has not been demonstrated.

Ecology inherently assumes that any deviation from tangential airflow is unexpected and therefore in error. In fact, numerous forc es operating at different scales of motion, determine the wind direction, making it one of the most difficult meteorological parameters to accurately predict because of small scale influences near the surface.

Air can flow up and over terrain if it has su fficient amount of kinetic energy to overcome resistant forces. The behavior of the air flow is determined by the ratio of the amount of kinetic energy of the air flow to the resisting forces of gravity, buoyancy, (i.e., static stability) and
terrain hei ght (referred to as the local Froude number). Thus if the sufficient kinetic energy exists, the wind would be expected to travel up and over terrain, rather than around it. Even if sufficient kinetic energy did not exist, the wind direction may not nece ssarily be channeled directly through the terrain, as frictional forces, and small scale differences in surface albedo, and Bowen ratios would act to induce turbulence, resulting in unexpected wind directions.

CALMET must rely on the limited surface and upper air observations in the computational domain to calculate the local Froude number. Recall, that CALMET must obtain the needed information from observation stations which may not be representative of the location of interest (in this case, the terrain between Wenatchee and Alpine Lakes Wilderness). Thus, the CALMET calculated wind behavior is not necessarily representative of reality.

Additionally, the terrain height used may not be representative of actual terrain features of interest as it’s is bas ed upon the terrain radius of influence (TERRAD) specified by the user. Additionally, the static stability used in the calculation of the local Froude Number is based upon the potential temperature lapse rate, determined from the domain representative uppe r

- air station specified by the user. If the upper air station is far away from the local terrain of interest, it will not be representative of the local temperature structure of the complex terrain between Wenatchee and Alpine Lakes Wilderness.

CALMET al so lacks the necessary physics to balance the forces when air flows near terrain, as such it forces air to flow tangentially to the terrain. The tendency of CALMET to generate terrain following flows is a known limitation in the model. This has been docum ented by EPA in its discussion of the ability of diagnostic wind model (DWM) to enhance numeric weather10

prediction (NWP) data to adequately replicate meteorological fields of interest (Section 2.2 of the Reassessment of IWAQM Phase 2 Summary report, draft May 27, 2009). In that discussion, EPA states that CALMET only contains algorithms for certain aspects of the valley wind system (drainage flows). Other portions of the wind system (cross

- valley, up/down valley circulations) are neglected in the algorit hm (Scire et al. 2000a).

CALMET also does not adjust the velocity to represent the decrease in kinetic energy of an air parcel as it works to ascend the barrier. This creates another concern regarding the directionality of the wind determined by the F roude number adjustment. CALMET assumes that the resultant wind vector will flow tangentially to the terrain obstacle. This assumption is only
valid for isolated terrain features.

Given the limitations of diagnostic models to ensure dynamically consist ent wind fields (Seaman, 2000), there is legitimate concern that the increased structural detail in the horizontal wind fields resulting from application of CALMET at higher grid resolutions may lead to spurious effects on plume dispersion which may not be obvious, even from a detailed review of horizontal wind fields. As such, the decrease in model

- predicted results as a function of increasing horizontal grid resolution in CALMET may be cause d by inappropriate changes in the vertical velocity fields which in turn may enhance vertical turbulence and plume dispersion.

CALMET is a mass

- consistent diagnostic wind field model (DWM) and uses divergence to calculate vertical motions in the atmosphere (given in equation 2

- 2 of the CALMET User’s Guide (Scire et al . 2000)). In order to maintain the constraint of mass

- consistency, the vertical component of the wind must change in relation to changes in the horizontal resolution. Reviwing the CALMET source code shows that the change from 4

- km resolution to 0.5

- km wil l result in an order of magnitude change in the rate of change of the horizontal wind components (represented by du/dx and dv/dy in the divergence calculations). In order to maintain mass consistency, the vertical velocity must increase due to the increa se in the horizontal resolution of
the model.

Ecology assumes that the slight decrease in model

- predicted concentrations is a result of a longer plume trajectory resulting from the finer grid resolution. It does not consider the implications of
enhanced vertical turbulence and plume dispersion which may occur as a result of increasing grid resolution within CALMET. Without performing a more detailed analysis which evaluates these phenomenons, the justification is purely theoretical and does not justify the use of the higher resolution grid spacing in CALMET as compared to the grid spacing of the NWP.

Additionally, there are several other important meteorological variables which affect visibility. These parameters include vertical velocity and turbulenc e parameters which affect plume dilution, vertical temperature gradients, which affect which whether or not plumes will move over or follow terrain, and relative humidity which affects hygroscopic particle growth rates such
as ammonium sulfate and ammonium nitrate . The Forest Service is particularly interested in11

knowing whether or not the change in grid resolution from 4.0km to 0.5km resulted in a change in vertical wind velocity or turbulence which may have artificially altered the plume dilution.

Fina lly, in assessing any model performance, one must use an appropriate standard for evaluation. In most cases, this is the actual observation of the parameter of interest (e.g., wind direction and speed, or a tracer study for air quality modeling). Due to an absence of valid meteorological data in the area of interest, Ecology was not able to conduct a quantitative model performance evaluation. Only a subjective analysis was performed, on a very limited number of
hours out of the entire 3

- year period, thu s creating a low degree of confidence in the interpretation of the results.

An objective analysis is needed to assess model performance. EPA has identified several methods for assessing model performance, all of which include a comparison with observatio n data. Statistical measures should be identified and compared with statistical benchmarks. Additionally, graphical evaluation tools such as time series plots of predicted wind speed, wind speed bias, root mean square error and Index of Agreement (IOA) ar e some examples of these recommended model performance metrics. Given the lack of a complete statistical model performance analysis, the subjective evaluation provided by Ecology does not provide a high degree of confidence in their interpretation of resu lts.

In summary, Ecology has inappropriately exempted Alcoa Wenatchee Aluminum Works from BART based upon a technically flawed modeling analysis. As such, a BART analysis for this facility needs to be performed or the facility must take federally enforce able limits to reduce its contribution to haze in the Alpine Lakes Wilderness following the established BART modeling protocol.