Buddy Garcia, Chairman Larry R. Soward, Commissioner Bryan W. Shaw,Ph.D., Commissioner Mark R. Vickery, P.C., Executive Director 

## RtiEi'kE.L~ - l;i'F,~ 

## AIR PLAPY'IBIFiG SEC 

## O9PIRR30 

## PM 1: I-1


# TEXAS COMMISSION ON 

# ENVIRONMENTAL QUALITY
Protecting Texasby Reducing and Preventing Pollution 

### March 19,2009



### Docket No. 2007-1539-SIP Project No. 2007-016-SIP-NR

Docket No. 2006-0228-RUL Project No. 2006-022-116-EN

Lawrence E. Starfield Acting RegionalAdministrator U.S. Environmental ProtectionAgency 

## - Region 6 1445 Ross Avenue Dallas, Texas 75202-2733

Dear Mr. Starfield:

On February 25, 2009, the Texas Commission on Environmental Quality (Commission) adopted a revision to the State Implementation Plan (SIP) to address visibility impairment due to regional haze in Class 

### I federal
areas. 

### In addition, on January 10, 2007, the Commission adopted rules to add new sections to Chapter 116, Control of Air Pollution by Pennits for New Construction or Modification. These new rule sections add engineering and control requirements for Best Available Retrofit Technology (BART) on certain affected sources and are intended to fulfill a regional haze plan requirement under the Federal Clean Air Act and federal rules.

The Commission adopted these SIP revisions to meet the requirement of Federal Clean Air Act section 169A that Texas submit a plan to make reasonableprogress in reducing visibility impairment at Class 

### I federal areas, including Big Bend and GuadalupeNational Parks, resulting from anthropogenicairpollution.

Enclosed are the proposed revisions to the SIP, adopted rules, public hearing certifications, a completerecord of the public hearings, and the accompanying orders. 

### I look forward to your expeditious approval of these SIP revisions. Sincerely,

Buddy ~arcia' 

### I Chairman

Enclosures

cc: The Honorable Rick Perry, Governor of Texas Mr. Toby Baker, Office ofBudget, Planning and Policy, Office of the Governor Mr.Mark R. Vickery,P.G.,Executive Director, Texas Commissionon Environmental Quality

P.O. Bos 13087 

# . Austin, Texas 78711-3087 

# . 512-239-1000 Internet address: www.tceq.state.tx us

li llllill ll ill ll l ll 1 111- (1 8 1 1111

### THE STATE OF TEXAS 

## 6

COUNTY OFTRAVIS 

## 6

This is to certify that the attached are true and correct copies of documents for a revision to the Texas

StateImplementation Plan, adopted on February 25, 2009, pursuant to 40 Code ofFederal Regulations (C.F.R.) 

## 6 51.104. 

### I am the records administrator for the Air Quality Division of the Texas Commission on
EnvironmentalQuality (Commission).



# F Susana M. 

### Hildebrand,P.E. Director, Air QualityDivision Texas Commissionon EnvironmentalQualityTexas Commission on Environmental Quality Public Hearing February 19,2008 Concerning Revisions to the State Implementation Plan to Address Visibility Impairment Due to Regional Haze in Federal Class IAreas Rule Project No. 2007-016-SIP-NR
Volume 1 of 2

### INTRODUCTION

The Texas Commission on Environmental Quality (commission) held a public hearing inAustin, on February 19, 2008, to receive testimony regarding proposed revisions to the state implementation plan (SIP)to meetthe requirements of the Federal Clean Air Act (FCAA) 169A and 169Baddressing visibility impairment due to regional haze in Federal Class I areas.

These revisions implement Federal Clean Air Act requirements to make reasonable progress in reducing visibility impairment at Class I Federal areas, including Big Bend and Guadalupe Mountains National Parks, resulting from anthropogenic pollution.

The comment period closed on February 22, 2008. All testimony and comments have been reviewed and seriously considered. This hearing record, which istwovolumes, contains a complete

record of the public hearing and is divided into the following four sections:

Volume 1:

0 

### Public Notification and Proposal

0 

### Evaluation of Testimony

0 

### Staff Recommendations/Order

Volume 2:

o 

### Written and Oral Testimony

Additional copies ofthis hearing record are maintained inthe TCEQ central office at 121 00 Park 35 Circle, Austin, Texas 78753. Forfurther information, please contact Margaret Earnestat (512)239-

4581.

# EVALUATION OF

TESTIMONY

# Texas Cornmission 

# on EnvironmentalQuality

. INTEROFFICEMsMORANDUM



### To:

. 

### Commissioners Date:

. 

### November 16,2007 

### Thm: LaDonna C-uela, Chief Clerk Glenn Shankle,Executive Director

From: 

### David C. Schanbacher,

### P.E., ChiefEngineer ChiefEngineer's Office


### Docket No.: 

### 2007-1539;SIP Subject: 

### ~e~ional Haze StateImplementationPlan 

### (SIP) Revisions
' 

### Regional

### Haze SIP Submission ProjectNo. 2007-016-SIP-NR

Reasonsfor the

### SIP revision:' 

### TheFederalClean

### AirAct 

### (FW) and

### theUnited States~nv&nmenta~ ~rotection 

### Agency (EPA) regulations

### require statcs

### to submit SIPS

### tomake "reftsonablepropssn

### inreducing

### visibilrty impairment

### at Class 

### IFederal arkas

### resulting from auth~pogenic pollution. 

### FCAA,169A(a)(l), "declares 

### as anational goaltheprevention 

### of any

# m, andtheiemedyingof

### any existing impairment 

### ofvisibility

### in mandatory



### . Class 

### IFederal areas

### which inhpairmentresults 

### fromman-made 

### airpollution". Class

### Iareas

### aienational parks over 6,000 acres andwilderness areas 

### over 5,000 acres

### that Congress

### hasrecognized

### at significant sites. These SIPSmust "contain 

### ~h emission 

### limits,schedules of compliance and othermcesasures 

### asmay

### be necessary

### tomakereasonableprogress' 

### towardmeetingthenational goal" includingrequiringinstallation, operation, andmaintenanceofBest Available RetrofitTechnology 

### (BART), 

### "as determinedby the 

### Staten on certain existing stationary sources.



### . TheEPARegional

### HazeRule slmngly encourages @tes 

### to worktogetha 

### inregionalpar&ershiPsto reduce 

### b. There 

### are five regionalplanning o~011s 

### intheUnited States. Texas 

### is amember ofthe Central Regional

### AirPlanning&sociation 

### (CENRAP), whichincludesnine states, Texas, Louisiana, Oklahoma, Arkansas,

### Kansas,Missouri,Nebraska, Iowa, andMinnesota The deadlinefor 

### Texas and statesparticipating in aregional air'planning

### organization to submittheirRegid

### Haie SlPsisDecember 17,2007. ClWRAP provides analysis,modelingresults, andinfonnatio@ exchange among states,but each statewill

### submit

### its

, 

### . ' 

### ownregional haze 

### SIP.



# . Under

### whataothckityarewe 

### proposing

### these changes? 

### TexasHealth and Safety 

### Code (THSC), $3

### 82.002, Policy 

### andPurpose; 5382.0 11,

### GeneralPow& andDuties; 5382.012, State

### Air Control 

### Plan; FCAA, 

## 5110(a)(2)@)(i)CII),169Aand 169~ (42U.S.C., §§7410(a)(2)(D)(i)(Q; 7491 and 

### 7492);



### Is this 

### SIP revisionrequired by federal

### rule or 

### state statute? 

### Which ones? 

### Yes, two federal rules require this 

### STPrevision. TheEPA adoptedRegional 

### Hazeregulations 

### in40 Code ofFederal Regulations 

### (CFR) Part 51, Subpart

### P, on

### July 1,1999, and adopted amendmentsto SubpartP and a 

### newAppendix

### Y (BART guidelines) to Part 51 rn

### July 6,2005.

Are there 

### anylegal deadlinesby which this SIP

### revisionmustbe proposed, adopted, or effective? 

### Yes. The Regional

### Haze SIP deadlineis December 17,2007. Dueto federal suits regarding

### the

### BARTrule, the states 

### delayed implementationfor approximatelyfiveyears. However, theRegionalHaze SIP deadline remained unchanged. Many stateswill not meetthe 

### deadline. 

### The commission is scheduledto 

### considerthe 

### proposal ofthis SIP

### revision on December 5,2007, and adoptionin 

### July 2008.

### Commissioners 

### Page 2 

### 1

1/16/2007



### Re: Docket

### No. 2007-1539-SP

, , 

### . .



# . What issue@) 

### or problem(s) arewe trying 

### to solve? Makereasonablefurtherprogress

### inreturning visibility at Class 

### I areasto natural conditions and

### meeting federalrequirements. Since air

### emissions do notrecognize state

### boundaries, all 

### states

### must worktogetherto reduce emissions

### thatimpacteach stateand 

### surroundingstates.



# . Why is it important

### thatwe

### dothis 

### SIP revision? 

### Not submitting

### a SIP could lead to federal 

### .

'

### sanctions (emissionofhets and hig&way

### funding sanctions)or a

### Federal Implementation

### PI& 

## PIP)

orboth.

.



# . otherimportant bsckgomdor hirtohulinformation. 

### The~~~~;~ection 169A

### and

### Brequire ' 

### the

### EFA to adoptregulationstoreducevisibility impairmentresulting 

### '%om man-made 

### air poIlution" 

### in 156Class

### IFederal areas. 

### Theregulations require each state 

### SIPto containcontrol measures, includingBART, to

### makereasonable

### propstoward the national 

### goal ofnatural visibility conditions

### by 2064

### in dl Class

### Iareas. 

### Tbetwo 

### Class

### Iareas m 

### Texas 

### ireBig

### Bend and Guadalupe

### Mountains

### National Parks. 

### Each state

### borderingTexas

### has one ormore Class

### IFederal mas

### designated

### forvisibilityprotection. 

### Where

### Texas' emissions

### impactvisibility 

### in 

### ClassI Federal mas

### in other states,the

### Texas 

### SIPmustinclude

### p1ans.b reduce 

### Texas' visibilityimpacts

### in

, 

### thoseareastoo.


### TheEPA adopted

### Regional

## Hazeregulations 

### in40 Code

### ofFederalReguIations 

### (CFR) Part 51, 

### subpartP, onJuly 1,1999, and 

### adoptedamendmentsto Subpart

### P and a

### newAppendix

### Y 

### @ART guidelines)to

### Part 5

### 1onJuly 6,2005. 

### Scope 

### oftheSIP revision: The 1990

### FCAAAmendments

### togeth&

### with 

### EPAas Regional

### HazeRule set

### the 

### goalofreducing 'ban-made"

### impacts onvisibility 

### in Class 

### Iareas

### to zero (i.e., to 

### 'haturd" conditions) by 

### 2064for the 

### worst 20 percentvisibiLity days andpreventing any

### degradation

### for the

### best 20

### percentvisibility days.


### &NRAP and otherRegional

### Air ~larnlin~ Orgmkmtions

### haw cooperatedto calculate

## thebase period (2000-2004) worst

### 20 percent andbest 20perceht visibility for

### each Class

### Iarea 

### CENRAP is contractingprojectionsofvisibility impairment

### in 2018, the initialyear forwhich each

### state's 

### longterm strategy

### is tobe evaluated. The statemustreduce itsvisibm.impairmentimpact at 

### all Class 

### I
areas it impactsby 

### as

### much as is reasonable. The 

### format

### ofthis 

### SIP revision follows aprescribed templatedeveloped,bythe 

### CENRAP states.
The

### TCEQ uied a~hed estimate ofnaturalconditions for Class

### I areas in

### Texas and other 

### states as 

### permittedby 

### EPA guidance. These ~fin.4 

### esthwtes account

### fornatural dust 

### storms,which 

### explain

, '

a 

### sigd3cantnumber of impaired days 

### atthe Texas 

### ClassIareas.


### The Clean

### Air InterstateRule (CAB) program

### is expectedto

### reduceregional haze impact.



### . Followingthe 

### legislature's statutory direction, 

### fieTCEQ adopted 

### CAZRrequkemeuts applicable to electric generating

### units 

### in Texas. Intershietrading of CAJR

### emissionreduction credits

### makes t6e prediction ofCAIR's visibility improvementbenefitsuncertain for each Class

### I area 

### Additionally,the 

### commission addptedthe

### requirements ofthe

### BARTprogram, which requires certain

### older sourceswith 

### a

### visibility irnpakmentimpact 011 

### a Class

### Iarea

### to apply

### BARTtothe

### Commissioners 

### Page 

### 3 11/16/2007

' 

### Re: DocketNo. 2007-1539-SIP



### sourceto reduce its

### impact

### on a

### nearby Class 

### Iarea.

### The 

### SIP must contain a 

### list ofBART-eligible
sources and the 

### determination 

### ofBARTfor each sourcethat is I-easonably anticipatedto .contributeto visibilityimpairinent (BART-subject).

, f 

### Each state must evaluate and determineif additionalemissionsreductions arenecessary. The statuteand 

### EPA rules and pidance 

### set criteriafor determiningwhether additional reductions arereasonable. These criteria 

### ari based onthe cost ofcontsol and otherrelated 

### faotm. cbanges'required by federal rule: Theproposed 

### SIP +$ion is intendedto satis@federal 

### requirements. States 

### are requiredto submit.Regional Haze 

### SIPS under FCAA, 

### $1694

### Visibility ProtectionforFederal Class

### IAreas, and $

### 1 69B,

### Visiiility;and 

### 40

### CFRPart 51,Subpart

### P. Changes required by statestatute: 

### N/A '
Staff

### recomm;ndations that arenot =xpresslyrequired by 

### federalruleor&ate statuk None.
Impact on the regulated community:

. 

### , Whowill be affected? SomeBART-eligible sourceswere 

### required to submitmodelingreports demonstrating

### impactsbelowthreshold

### on Class 

### Iareas. No additionalcontrols

### were added to

### this revision.

Doesitcreate a 

### group of affected persons,whowere not affected previously? How?

### NO.
Will there be a 

### fiscaiimpact? 

### Ifso, estimate. No impact is estimated

### underthe 

### inik Regional Haze SIP.
Impact on thepublic:

Whowabe

### affected? Texas

### willbenefit

### from increasedvisibility atBigBend

### NationalPark and GuadalupeMountainsNational 

### Park. 

### Visibility oould alsopotentiallyimproveatClass 

### IAreas 

### in surrounding states.

' 

### Does it 

### create a 

### of affected persons

### who

### w& not affected previously? How? 

### N/A

r 

### ~ill'there be a fiscal 

### impact? 

### If so, 

### estimate. 

### N/A
Impact 

### on agency programs:


### The continued cost

### ofparticipating 

### inCZNRAP.

. 

### No 

### new rules h~ve been added.

Informational meetings:

Have 

### any informational,me&ngs be& held? Yes,November 2007



# . With

### whom? 

### Persons or companiescurregtly interestedin STP 

### changes.

### Commissioners ' 

### Page 

### 4 11/16/2007

. . 

### Re: 

### Docket

### No. 2007-1'539-SIP



# . Whatwere the genedsentiments? 

### Some apprehensionand uncertaintyis expected

### withthe implementatioll ofa

### newfederal and concern aboutthe long schedule.

B 

### Were any changesmade

### in responseto stakeholder concerns? 

### None 

### are expected. TheTCEQ 

### is. followingfederal guidance. PoIicy issues:

. 

### What policy 

### issuesareaffected? 

### Pollution

### transport&omMexico and America

### is amajor factor

### invisibilityimpairmentatTexas' Class

### Iareas. 

### The goal 

### ofnatural 

### visibility

### willnot

### be

### met unless internationaltransport

### is addressedbythe.federaIgovernment



# . 'he~ry 

### policies

### that are

### not currently

### bas& on rule being madeinto a

### rde? 

### NO:.
Whet 

### arethe consequences

### if

### this'SlP revisionis notapproved t~:~o 

### forward? Not 

### submittinga

. 

### SIPcould leadto

### federal sanctions (emission offsets 

### and highway

### funding sanctions) or aFederal

. 

### Implementation

### Plan 

### (FP) orboth.

' 

### Are there 

### alternatives?. Fehdskctions.

. '

. . 

### Potentially controversialmatters:

. 

### ~atiial parks 

### in momding.states 

### ofOkIahoma,

### Arkansas, 

### Louisiana, and

### New Mexico.



### . may want moreinputon potentially 

### petted new sources 

### inproximity 

### totheir Class 

### I mess. 

### Presently, 

### therules dowthese states

### andfederal 

### landmsnagers (FLMs) 

### toreviewnew sources

, 

### within 100kilometers. Oklahomahas 

### requestedthe opportunityto 

### examine and comment onnew source app?ications greaterthan 100kilometers 

### fi~m Class

### I areas

### thatmay impact

### its

### p.arks. 

### FLMs

, , 

### for

### theForest Service, 

### Fish and 

### Wildlife Service, 

### andthe

### NationalPark Servicehave also

### requeskd

.. 

### the opportunityto examine

### new sourceapplicationsgreater

### than 100kilomete

### &om theirClass 

### I

, 

### areas.



# .

. 

### There

### willlikelybe some concern

### fromthe public

### thatthis 

# SIPdoes not

### make dcient progresstowaidnatural

### visibility. Thenational goal

### isto reach

### naturalvisibilityby 

### 2064. Atthe rate ofirr@royement proposed 

### inthis 

### SIP,natural visibility levelswould not be reached

### until 2080 

### at the Guadalupe~ountains'aud 2148 

### atBigBend
Key points 

### in proposed 

### SIP revisionschedule:

. 

### Anticipatedproposal date: 

### December 5,2007

Public hearing date.(ifany): 

### February 19,2008 Public comment period:

, 

### December21, 2007throughFebruary 22,2008 (includesmaudated 

### 60-day review by

### FLMs)



# . Anticipated adoptiondate: 

### July 9,2008
Agency contacts: keg 

### Nudd, P.E., Technical Specialisf 239-1247,

### Air Quality

### Planning Margaret Earnest, 

### SF RojectManager, 239-458

### 1,

### Air Quality 

### Planning John

### Minter, Staff

### Attorney, 23

### 9-0663 

### .' 

### .Commissioners Page 

### 5

. . 

### 11/16/2007



### Re: DocketNo. 2007-1539-SIP



### Attachments



### cc: 

### Chief Clerk, 5 copies 

### ExecutiveDirector's Office David C. Schanbacl~er, 

### P.E. Susana

### Hildebrand, 

### P.E. Ashley 

### K.

### Wadick Daniel Womack 

### Office ofGeneral 

### Counsel Greg

### Nudd,

### PE. Kelly Keel

. 

## . Margaret

### Earnest



### . . 

### Joyce Spencer



### .

# Texas Commission on Environmental Quality
INTEROFFICE MEMORANDUM

To: Commissioners Date: February 6, 2009
Thru: LaDonna Castaiiuela, Chief Clerk Mark R. Vickery, P.G., Executive Director

From: David C. Schanbacher,P.E., Chief Engineer Chief Engineer's Office
Docket No.: 2007-1539-SLP
Subject: Regional Haze State Implementation Plan (SIP) Revision Regional Haze SIP Submission Project No. 2007-016-SIP-NR
Scope of the SIP revision: The 1990Federal Clean Air Act (FCAA) Amendments together with the United States Environmental Protection Agency's (EPA) Regional Haze Rule set the goal of reducing "man-made" impacts on visibility in Class 

### I areas to zero (i.e., to "natural" conditions) by 2064 for the worst 20 percent visibility days and preventing any degradation for the best 20 percent visibility days.

The Central Regional Air Planning Association (CENRAP) and other Regional Air Planning Organizations have cooperated to calculate the base period (2000-2004) worst 20 percent and best 20 percent visibility for each Class I area. CENRAP has developed projections ofvisibility impairment in 201 8, the initial year for which each state's long-term strategy is to be evaluated. The statemust reduce its visibility impairment impact at all Class I areas it impacts by as much as is reasonable. The format of this SIP revision follows a prescribed template developed by the CENRAP states.

The TCEQ used a refined estimate of natural conditions for Class 

### I areas in Texas and other states as permitted by EPA guidance. These refined estimates account for natural dust storms, which explain a significant number of impaired days at the Texas Class I areas.
The Clean Air Interstate Rule (CAIR) program was designed to reduce interstate transport of emissions that affect fine particulate matter and ozone. Because these precursor emissions also affect visibility, the CAIR program is also an integral part of reducing regional haze. Following the legislature's statutory direction, the TCEQ adopted CAIR requirements applicable to electric generating units 

### in Texas. Upon several challenges to CAIR, the rule has been remanded back to EPA by a federal appeals court in order for EPA topromulgate
a new rule that is consistent with the court's decision, CAIR is still in effect until such time as the new rule is adopted. The TCEQ expects that a replacement program will be in place that.makescomparable reductions in pollutants causing regional haze prior to 2018.

The commission has also adopted the requirements of the BART program, which requires certain older
sources with a visibility impairment impact on any Class I area to apply BART to the source to reduce its impact on those Class 

### I areas. This SIP revision contains a list of BART-eligible sources and a summary of the results ofthe BART modeling analyses. The appendix contains reports documenting the modeling results for sources that were potentially BART eligible; the modeling results showed that the visibility impacts of those sources were below the threshold established by EPA and adopted by the TCEQ.

Each state must evaluate and determine if additional emissions reductions are necessary. The statute and EPA rules and guidance set criteria for determining whether additional reductions are reasonable. These criteria are based on the cost of control and otherrelated factors.Commissioners Page

### 2 February 6,2009

Re: Docket No. 2007-1539-SIP



### Reasons for the SIP revision: The FCAA and the EPA regulations require states to submit a SIP to make "reasonable progress" in reducing visibility impairment at Federal Class 

### I areas resulting fiom anthropogenic pollution. FCAA, 

### § 169A(a)(l), "declares as a national goal the prevention of any future, and the remedying of any existing impairment of visibility in mandatory Federal Class I areas which impairment results fiom man-made air pollution." Class I areas are national parks over 6,000 acres and wilderness areas over 5,000 acres that Congress has recognized
as significant sites. These SIPSmust "contain such emission limits, schedules of compliance and other measures as may be necessary to make reasonable progress toward meeting the national goal" including requiring installation, operation, and maintenance of Best Available Retrofit Technology (BART), "as determined by the State" on certain existing stationary sources.

The EPA Regional Haze Rule strongly encourages states to work together in regional partnerships to reduce haze. There are five regional planning organizations in the United States. Texas is a member of CENRAP, which includes nine states; Texas, Louisiana, Oklahoma, Arkansas, Kansas, Missouri, Nebraska, Iowa, and Minnesota. The deadline for Texas and states participating 

### in a regional air planning organization to submit their Regional Haze SIP was December 17,2007. CENRAPprovides analysis, modeling results, and informational exchange among states, but each state will submit its own regional haze SIP. 

### Statutory Authority: Texas Health and Safety Code (THSC), $382.002, Policy and Purpose; $382.011, General Powers and Duties; 8382.012, State Air Control Plan; FCAA, $1lO(a)(2)(D)(i)(lI), 169A and 169B(42U.S.C., $874

### IO(a)(2)(D)(i)(lI);7491 and 7492). 

### Potentially controversial matters: On July 11, 2008, the Clean Air Interstate Rule (CAIR) was vacated by the DC Circuit Court of Appeals (State of North Carolina v. U.S. 

### EPA). CAIR was a major federal rule to red~~ce emissions from electric generating units and is a significant element of Texas's planned reductions of both sulfur dioxide and nitrogen oxides from these sources. Upon a motion for rehearing, the appeals court issued a decision December 23, 2008, remanding CAIR to EPA to initiate rulemaking consistent with its opinion, but the court didnot vacate CAIR, allowing it to remain in effect until replaced by EPA rule. EPA has also been sued for failing to act on the December 17, 2007, due date for Regional Haze plans. In anticipation ofpublishing a notice of finding of failure to submit a required SIP, in mid-December 2008 EPA Region 6 staff recommended that Texas submit its SIPrevision incorporating CAIR or CAIR replacement. The notice was eventually published January 15,2009,in the FederalRegister, starting a 24-month Federal Implementation Plan (FIP) clock and possible subsequent sanctions. This FIP clock can only be stopped by submittal to and full approval by the EPA. IfEPA finalizes a new rule to meet the appeals court directive, Texas will need to consider new state rulemaking or implementation of the federal CAIR replacement.

National parks in surrounding states of Oklahoma, Arkansas, Louisiana, and New Mexico may want more input on permit applications for major new sources as covered in the Prevention of Significant DeteriorationCommissioners Page 

### 3 February 

### 6,2009

Re: Docket No. 2007-1539-SIP
(PSD) program if these proposed sites are in proximity to their Class I areas. Presently, the rules and EPA guidance allow these states and Federal Land Managers (FLMs) to review new sources within 100 kilometers. Oklahomahas requested the opportunity to examine and comment on some new source applications within 300 kilometers of Oklahoma's Wichita Mountains Class I area. FLMs for the Forest Service (FS), Fish and Wildlife Service (FWS), and the National Park Service (NPS) have also requested a change in our PSD procedures so that more permit applications undergo a visibility impact review. The agency plans to work directly with the FLMs and the states to try to resolve their concerns.
OnFebruary 13,2008,the TCEQ approved the renewal of Air Quality Permit Number 20345 for the American Smelting and Refining Company (ASARCO) El Paso copper smelter. On February 6,2009, the TCEQ received confirmation fromASARCO LLCthat it intends to close the smelter and requests that TCEQ void all air permits and pending applications for theplant. The TCEQ voided these permits and applications on February 9,2009 (See Appendix 11 -4: ASARCO ElPaso). The TCEQ will continue to consult with affected states and Federal Land Managers for the next Regional Haze SIPrevision.

Pollution transport from Mexico and Central America is a major factor in visibility impairment 'at Texas' Class I areas. The goal ofnatural visibility will not be met unless international transport is addressed by the federal government.

The public may express concern that this SIP does not make sufficient progress toward natural visibility. The national goal is to reach natural visibility by 2064. At the rate ofimprovement proposed in this SIP, natural visibility levels would not be reached until 2081 at the Guadalupe Mountains and 2155 at Big Bend.

Public comment: Comments were received from the USEPA, FS, FWS, NPS, Sierra Club, CitizensLeague for Environmental Action Now, and citizens. Additional information was provided in the SIP to address the comments. Significant changes from proposal: Two significant additions were made to the adopted SIP after public comments: Additional consultations along with area of influence maps and formal letters were sent to adjacent states to discuss the Texas impact on Class I areas outside of Texas (see Chapter 4 and Appendix 4-3). All Class I areas in adjacent states were added in tables, including worst and best 20 percent of visibility days, and the pollutant breakdown of Texas' apportioned contribution at each area (see Chapter 11 ).Commissioners Page 

### 4 February 

### 6,2009

Re: Docket No. 2007-1539-SIP
Key points in adoption SIP revision schedule:
Proposal date: December 5,2007 Public hearing date: February 19,2008 Public comment period: December 21,2007through February 22, 2008 (includes mandated 60-day review by FLMs) Anticipated adoption date: February 25,2009
Agency contacts: 

### Kim Herndon, SIP Team Lead, Air Quality Planning, 239-1421
Margaret Earnest, SIPProject Manager, Air Quality Planning, 239-4581, John Minter, Staff Attorney, 239-0663

Attachments
cc: Chief Clerk, 5 copies Executive Director's Office David 

### C. Schanbacher, P.E. Daniel Womack Kevin Patteson Betsy Bird Office of General Counsel Margaret Earnest

### EVALUATION OF TESTIMONY

### RESPONSETO COMMENTS Regional Haze SIP, proposed 12-5-07

To assist readers with all the federal agencies that commented, a short acronym list is provided. A more completelist is located atthe beginning ofthe Regional Haze SIP. EPA United StatesEnvironmental Protection Agency FLM Federal Land Managers (includes NPS, FWS, and FS for this document) FS United States Forest Service FWS United StatesFish and Wildlife Service NPS National Park Service, United States Department ofthe Interior Chapter 1: 

### Background and Overview of the Federal Regional Haze Regulation 

### The Forest Service (FS) and one individual requested rewording ofthe sentence in paragraph one defining Class I areas as those 

### ".

. .that Congress has recognized at significant sites" to "Class 1


### areas are national parks over 6:000 acres and wilderness areas over 5,000 acres that were in existence before August 7, 1977." One individual commented that the Texas Commission on EnvironmentalQuality (TCEQ) stated that GuadalupeMountains containsthe only congressionally designated wilderness in Texas; however, there are fivecongressionally designated wilderness areas in East Texas.

The commission made the changes the FS suggested; this change also corrected the comment of the individual.



### The FS commentedthat Big Bend and GuadalupeMountains are identified in Chapter 1: 

### Background and Overview ofthe Federal Regional Haze Regulation,but out-of-stateClass I areas are not. Including a summary ofthose otherimpacted Class I areas would provide balance to this chapter. The FS requested that the TCEQ include the out-of-state Class 1

### areasthat Texas impacts in Chapter 1. Additionally,the FS commented that Texas should quantitatively summarizeits reasonable progress goals and associated rationalefor each Class 1

### area addressed in the Texas Regional Haze State Implementation Plan (SIP) revision.

The commission added revisions in Chapter 1 

### that direct the reader to Chapter 11: 

### LongTermStrategy to ReachReasonable Progress Goals for analysis of Texas' impacts on all impacted Class 

### I areas. The commissiondisagrees with the suggestion that the Texas Regional Haze SIPrevision should list the reasonableprogress goals established by each statewith a Class 

### I area that Texas impacts. Instead, Chapter 11 

### details both the total and Texas1apportioned 2002 

### and projected 2018 

### extinction impacts on each Class 

### I area impacted by Texas' emissions.



### One individualcommented that Table 1-1 : 

### Visibility-Impairing Pollutants lists evergreen trees as emitting volatile organiccompounds (VOC),but other trees, like oak, also emit VOC.
Evergreen was removed from Table 1-1 

### in response to this comment.


### One individual commented that Table 1-1 

### does not documentthat many areas with bare soil or little vegetation are due to human impacts. Example: overgrazingoccurred in the areathat is now Big Bend before it became a park.

Table 1-1 

### lists only major sources and not all possible sources. After discussions, the FLMs suggested that the commission couldjudiciously use 80 

### percent as the natural source of
course and fine dust and 20 

### percent of course and fine dust due to human activity. The comparison plots in Chapter 

### 5: Assessment ofBaseline and Current Conditions andEstimate ofNatura1 Conditionsin 

### ClassIAreas show little difference in the final calculation whethernatural dust sources are 80 or 100percent. The commission made no changes in Chapter 1in response to this comment, but changes were made in Chapter5 and Appendix 5-2: 

### Estimate of Natural VisibilityConditions. (Also see responses on grazing under Chapter 8: 

### ModelingAssessment.)



### One individual would appreciate a definition of "maintaining adequate visibility." One individual wants TCEQ to strive for better than adequate air quality in Big Bend and Guadalupe Mountains.

The commission followsthe requirements of the Federal Clean Air Act and EPA in regard to visibility. Sincethereis no health based standardfor visibility, there is not an exact number to reach. Thecommission's goal is to reduce haze-impairing pollutants in Texas and surroundingstates to approximately natural conditions. Texas has calculated natural conditions to be about 

### 11deciviews atthe state's two Class 

### I areas.
Chavter 2: General Planning Provisions 

### The United StatesEnvironmental ProtectionAgency (EPA) commentedthat the TCEQ should
ensure it followed the requirements of Part 

### 51, Appendix V. The EPA also suggested that TCEQ edit the paragraph "Public ]'Jotice" in Chapter 2: 

### General Planning Provisions to include a reference to Part 

### 51, AppendixV. 

### The EPA suggested additional documentation that the state complied with Part 

### 5 1,Appendix V 

### be included in Appendix 2- 1: 

### Public Participation Process.

The commission has added the reference to Part 51, Appendix V. When the commission submits any SIPrevision to the EPA for approval, it follows the administrative requirements of AppendixV, Section 2.0. This revision will be no exception. The commission's order, referral letter, public hearing record book, and SIPnarrative will addressthose relevant criteria.
Chapter 4: State, Tribe, and Federal Land Manager Consultation 

### The EPA, National Park Service(NPS), Fish and Wildlife Service (FWS), Forest Service (FS), and one individual commentedthat the consultation process appeared incomplete. Circular questions about states that have not completed their BART or Regional Haze SIP process have arisen. All commenters requested: 1)more details on the teclmical information that was communicated and 2) signed documentation that adjacent states (Louisiana, Arkansas, Missouri, Oklahoma, Colorado, and New Mexico) were satisfiedwith Texas' existing regulations for the next revision.

The EPA specifically requested that TCEQ should addressthe requirements of Section 51.308(d)(l)(iv). a) Do these states agree with the TCEQ on the level of their apportionments? b) What, if any, reductions in these states' sources were negotiated through the consultation process aspart ofthe TCEQYs reasonable progress strategy? c) The TCEQ should demonstrate that it has included in its implementation plan all measures necessary to obtain its shareofthe emission reductionsneeded to meet the progress goal for those Class I areas for which it causes or contributes to visibility impairment. d) In Chapter4, 

### the TCEQ states that it attended Oklahoma's three consultation calls held in August and September 2007. The TCEQ should discussthe results ofthose calls, including

, 

### whether Oklahoma requested any additi

The commission acknowledges some Regional Haze SIP and Best Available Retrofit Technology (BART) timing issues regarding consultation with neighboring states. To address this issue, the commission sent a formal consultation letter with attached ParticulateMatter Source Apportionment Technology (PSAT) results, and where applicable, area of influence maps of Texas sources on Class 

### I areas, and documents containing source-specific data on nitrogen oxides (NOx) and sulfur dioxide (SOz)contributions to neighboring states. The consultation letter discussed expected emissions reductions by 2018 thatwill improve visibility in the affected Class 

### I areas. The commission also requested recipients of the letters to confirm they arenot expecting any additional emission reductions from Texas sources. The letters and replies arein Appendix 4-3: 

### Additional Consultation Letters to Adjacent States.
Oklahoma, Missouri, Arkansas and Colorado have replied with letters that those states
concur with Texas' current level of controls; full replies arein Appendix 4-3. Colorado agrees that Texas' impact at Great Sand Dunes Wilderness Area was less than 5 percent and was not significant per Colorado's criteria. Louisiana has agreed via e-mail that Texas' existing regulations will suffice for now, and Louisiana does not expect more controls at this time. In the consultation calls with Oklahoma Department of Environmental Quality (ODEQ), Oklahoma did not request any additional emissions reductions from Texas. The commission requested written responses in 30 days so the comments could be added to Appendix 4-3. The commission has madechanges to Chapter 

### 4: 

### State, Tribe,andFederal Land Manager Consultation and added a new appendix 4-3.
Chapter 

### 5: Estimate ofNatural Conditions in Class 

### I Areas 

### The EPA commented that the TCEQ should provide more detail than ispresent in Appendix 5-2: 

### Estimate of 

### Natural Visibilig) 

### Conditions on the calculation ofthe refined estimates of natural visibility for the two Texas Class I areas. Appendix 5-2b: 

### Estimating Natural Conditions Based on Revised IMPROVE Algorithim outlines the method used for the calculation of Texas' estimates of natural visibility at Big Bend and Guadalupe Mountains, including the scaling factors used, which arecontained in the second partof Table 5-1: 

### Regional Annual Mean -Natural Concentrations (RAM-NC)of TrijonisandtheEPA. However, so others may more easily reproducethe calculations and
see the details of both how the factors were calculated as well as the resultant calculations of natural visibility, the SAS Program code and input data files arebundled into a 

### ZIP file named TXNC.zip and provided as Appendix 5-2c: 

### TexasNatural ConditionsSAS 

### Program File andData. The appendixwas expanded to includemore details asthe EPA requested in their comments.



### The NPS and FWS find the basic approach used by Texas in adjusting natural conditions for Big Bend and Guadalupe Mountains reasonable. However, Texas should provide a rationale for what fraction of course mass and fine soil is natural and what fraction is from human activity. Since human activity adds uncertainty to the estimate of what fraction of the course mass and fine soil is natural, Texas should present an alternative with a different fraction.

In response to this comment, the commission added information to Chapter 5 and Appendix 5-2 to show the comparisons between 80 and 100percent of the coarsemass and fine soil dueto a natural dust source. After discussions on the FLMs comments, the FLMs suggested that the commission could judiciously use 80 percent as the natural source of
course and fine dust and 20 percent of course and fine dust due to human activity. The comparison plots in Chapter 5 and Appendix 5-2 show little differencein the final calculation whether natural dust sources are 80 or 100percent. Additional supporting research from the Chihuahuan Desert (summarized and referenced in Appendix 5-2 Gill, 

### T. et al. 

### 2005; Kavouras, 

### 1. G. etal. 

### 2006 and 

### 2007) suggests that, at least for the estimation of natural visibility values forTexas Class 

### I areas, major dust events are predominantly natural in origin.



### The EPA suggested that the TCEQ explain why the baseline average for Big Bend, shown in Table 5-1 : 

### Baseline 

### Haze Indices, does not include datafrom 2000.The fourth quarter data of 2000 for Big Bend was not sufficiently complete. The fourth quarter had only 10complete days. This information is reflected in the Regional Haze Rule data that can be obtained through the Visibility Information Exchange Web System (VIEWS), such asthe summary data through 2004 (at 

### vista.cira.colostate.edu/views/Web/IMPROVE/SummaryData.as~x~. Thecommission made additional explanations in the SIPrevision for clarification.


### The NPS, FWS, and FS acknowledged Texas' right to develop its own estimates of natural conditions, as established in 40 

### Code ofFederal Regulations (CFR) 51.308;

### however, the FLMs requested that the EPA default estimatesof natural conditions given equal weight in all tables, plots, and predictions that involveor depend upon an estimate ofnatural conditions.

Thecomparisons with the EPA default, ormore specifically, the Natural Conditions I1 (NC 

### IT) committee's estimates using the NewIRevised IMPROVE Algorithm, areavailable in Appendix 5-2. The commission made some changes in response to this comment, however theNC 

### I1 estimateswill remain in the appendix.



### The NPS and FWS suggested that it would help the reader to summarize how the refinement affects the revised natural condition ifthe state included a chart showing the breakdown of each basic pollutant component. NPS and FWS also suggest that this would give a non-technical reader a simple reference about which componentsin the haze calculation were changed and by how much.

In response to the comments, a paragraph has been added to Chapter 5, Section 5.3. In addition, a note tothis effect has been added to Table5-1 in Appendix 5-2 to illustrate that the fractions shown for all but course mass and fine soil areessentially the same as used by theNatural Conditions 11.



### The EPA asked that the TCEQ provide documentation that supports the estimate that, at least for the estimation of natural visibility values for Texas Class I areas, major dust events can be assumed to be completely natural in origin.

Thecommission has included additional supporting evidence in additional appendices (and references therein) to Chapter 5. Sincethere is uncertainty in this estimate, as there is in all the components of naturalvisibility conditions, the commission has provided plots showing theresults for the 20 percent worst natural conditions haze index (in deciviews) if one were to treat only 80 percent of the coarse mass and fine soil to be natural. However, this 80 percent calculation is displayed only as an indication of how little sensitivitythis natural visibility estimate has to approximating 100percent of the coarse mass and fine soil as natural.



### The EPA noted that wind blown dust is a more important factor for Guadalupe Mountains than at BigBend. The TCEQ acknowledges that the number of dust storms at Guadalupe Mountains and BigBend do not correlate with each other in the SIP and appendixes. Because ofthese differences,the natural conditions for these two sites should be evaluated individually. The EPA requested that the TCEQ show how tinis informationwas considered in the assumptions and show calculations of the natural visibility values for each of Texas' Class I areas.
The commission did calculate separate equations for Big Bend and GuadalupeMountains; therefore, two different numberswere recommended for natural conditions (see Chapter 5 and Appendix 5-2). Regarding the difference in dustat Big Bend and Guadalupe Mountains,even using 80 percent versus 100 percent of the coarse mass and fine soil as natural made little difference in the final calculation (see Figures 5-1 and 5-3 in Chapter 5

### and Figures 5-1 and 5-2 in Appendix 5-2). 

### In response to this comment, the commission added figures to Chapter 5 and Appendix 5-2 to show the comparisons.

The comment in the Stuart Dattner's paper in Appendix 5-2a: 

### Natural Events: Dust Storms in West Texas about how the natural conditions for these two sites should be evaluated individually stems from the commission's long-standing assertion that Big Bend and Guadalupe Mountains cannot simply be treated as being essentially the same (Dattner, 2007 at 

### ~.tcea.state.tx.us/assetsl~ubliclim~lementation/air/siv/bart/hazesipdust storms.pdf>). There is ample evidence,in addition to that cited in the dust storm paper, that these parks arein many ways quite different. However, this paper does support the assertion ofthe Appendix 5-2b: 

### EstimatingNatural ConditionsBased on theRevised IMPROWAlgorithm, (cwww.tcea.state.tx.us/assets/public/im~lementation/air/si~~a~/haze sip est.natura1 conditions.~df>), that the observed coarse mass and fine soil components of haze in the western United States, including Big Bend and Guadalupe Mountains, are consistent with Trijonis' estimates ofnatural conditions (see reference Trijonis 1990)'which
areused by the EPA and the Natural Conditions I1

### committee in obtaining default estimates of natural conditions. In addition, though the estimate that the 20 

### percent worst natural visibility conditions can be best approximated by using 100percent of the coarse mass and fine soil as stemming from natural sources is common to the calculation of natural conditions atboth Texas Class 

### I areas, the actual computations arecarried out using each area's own data. Chapter 6: Monitoring Stratem 

### The NPS, FWS, FS, and one individual commented that the TCEQ stated it will participate in the monitoring network as long as EPA or other states fund these programs. One individual considered theprevious statement showed a lack of commitment by the TCEQ to protect Class I
areas in and outside Texas. The NPS and FWS commented that the SIP stated the current funding forthe Interagency Monitoring of Protected Visual Environments (IMPROVE) network to be primarily EPA with some funding from hTS. However, all the FLM agencies with Class I area management responsibilities (including FWS and FS) contribute tothe establishment and operation ofthe IMPROVE monitoring network. The individual commented that the TCEQ has 

### permitted air emissions in Texas to degrade visibility both inside and outside Texas, but considered it unfair that Texas was not willing to fund a Web site, monitoring, and collaboration with others whose Class I areas are diminished by Texas' air emissions. The commenters suggest Texas have a contingency plan for monitoring and reporting of data in casethe IMPROVE program curtails operation of IMPROVE monitors or funding for Visibility Information Exchange Web System (VIEWS).

The commission agreesthat the proposed SIP revision did not mention that the financial contributions from the FWS and FS to fundingthe IMPROVE monitoring 

### at Class 

### I areas. The SIPis revised to acknowledge these contributions. The commission agrees that it plans to consult with the FLM agencies for all the Class 

### I areas that Texas impacts ifthe current federal funding of any of these IMPROVE monitoring network sites or the VIEWS services is threatened. Thecommission considers both continued IMPROVE monitoring at current Class

### I IMPROVE sites and continued VIEWS services to be centrally important to the effort to reduce anthropogenic haze impacts at these sites. The commission plans to work with the FLMs to attempt to find the funding to continue the current Class 

### I IMPROVE monitoring and VIEWS services for these sites. The commission has added these commitments to the SIPin Chapter 6 Section 6.2. Concerning the availability of alternative data sites for the two Class 

### I areas in Texas, the analysis by the IMPROVE Steering Committee has shown definitively that the two sites areeach unique in the current IMPROVE Class 

### I site network, so there is no acceptable, reasonably representative alternativethat could substitute for either site.In response to the question about the TCEQ's monitoring and monitoring plans atBig Bend and atGuadalupe Mountains, the commission notes that it currently operates a PM2.5 TEOM, which is a Tapered Element Oscillating Microbalance that measures particulate matter with aerodynamic diameters less than 2.5 microns, an every-sixth-day PM2.S chemical speciation monitoring site, and a set of meteorological instruments atthe Big Bend IMPROVE site. Additionally, the TCEQ hosts the NPS ozone data from Big Bend on the TCEQWeb site. In fact, the NPS ozone data appear on the TCEQ Web site.

Thecommission currently plans to continuethis monitoring but ,isunable to make a binding commitment about future operation of these instruments. Operation is dependent on future funding of TCEQ monitoring and on potentially competing priorities for resources. As long
asthe TCEQis ableto continue its monitoring atBig Bend, it will make all thedata availableto the FLMs, theEPA, and the public. Chapter 7: Emissions Inventorv 

### The EPA requested an explanationof how the TCEQ resolved any significant differences between the actual locationsof stationary sources in 2002 and the Integrated PlanningModel (1PM)-generated 20 18locations.

As part of the review of theIPMVersion 2.19 projections of emissions to the 2018 planning year for regional haze, the commission obtained from the EPA's Clean Air Markets Division an explanation of the procedure the IPM uses forpredicting locations of new electric generating units (EGUs). As would be expected based on economic and logistic considerations, the procedure places a high priority on locating new units atexisting plants. In consideration of current airquality, the model also projects locations of new units based
on a hierarchy of county attainment status, such that the units arelocated in pollutant attainment counties, particulate matter nonattainment counties, and eight-hour ozone nonattainment counties, in that order. Thecommission acknowledges the uncertainties that anyprojection tool would have in predicting the location of new electric generating units, but considers the procedure used by the IPM is reasonable. Appendix 7-2: 

### Integrated Planning Model Projections ofElectric Generating Unit Emissions for the Regional Haze State Implementation Plan has been revised to discuss the EPA's procedure used by the IPM to locate projected EGUs.



### The EPA asked how the TCEQ resolved any significantdifferences between the 2002 magnitudes of stationary sources and the IPM-generated 2018 magnitudes.

CentralRegional Air Planning Association (CENRAP) used the 

### IPM Version 2.19 to project emissions of EGUs from the base year of 2002 to the future planning year of 2018. CENRAPthen used the projected EGU emissions in its photochemical modeling of visibility impacts in Class 

### I areas. Inputs developed for IPM runs arebased on assumptions applicable atthe time themodel is constructed, including fuel prices, fuel availability, regulatory policies, and a multitude of related factors. Emissions projected by the IPM for Texas EGUs are summarized in Appendix 7-2.

Table 2: 

### Texas Emissions ofSOl andNOsfrom EGUs 

## -IPM 2.19 

### Versus IPM 3.0 in Appendix 7-2 shows that for the period 2002 to2018, the IPMVersion 2.19 predicted an approximately 35percent decrease in Texas EGU emissions of sulfur dioxide, the pollutant most important for regional haze formation in Class 

### I areas of interest downwind from Texas. Based on regulatory programs intended to result in overall decreases of sulfur dioxide in Texas, this result appears to be reasonable. The commission acknowledges the uncertainty in the emissions projections, as the 2018 planning horizon forregional haze is particularly long and model assumptions arethus quite uncertain. However, thecommission still regards the 

### TPM as a viable EGU emissionsplanning tool for Regional Haze SIPdevelopment and is not aware of a better tool. The commission has made no changes in this 

### SIPrevision.



### The EPA asked whether the IPM-predicted total electrical generating capacity for 20

### I 8 

### appears to be reasonable when compared with that in 2002.
Appendix 7-2 focuses on electric generating capacity in Texas mainly for coalllignite- and gas-fired electric generating capacity since emissionsfrom the combustion ofthese fuels are of most concern relative to visibility impacts. The appendix provides a comparison oftotal capacity for these fuels for 2005 based on data from the National Electric Energy Database System, and for 2018 as projected by the 

### IPM. As shown in Table 1: 

### Electric Generating CapacitJ) 

### in Tam 

# -IPM 2.19 VersusIPM 3.0 of Appendix 7-2, the 

### IPM Version 2.19 used 

### by CENRAP projected an approximately 28 percent increase in total generating capacity in Texas for these fuels (combined) duringthe planning period. The commission believes this projected increase is reasonable based in part on population projections from the Office of the Texas Comptroller,which show about a 20 percent increase in population from 2005 to 2018. Also, generating capacity projections from theElectric Reliability Council of Texas (ERCOT) show continued growth of coawlignite- and gas-fired capacity for the ERCOT region atleast through 2013, the furthest projection year availablefrom ERCOT. The commission acknowledges that the futuregrowth of generating capacity forthese fuel types will be related to more than population growth (e.g., fuel prices, fuel availability, environmental policies, growth in renewable energy resources, and other related factors), and that both the population projections and ERCOT-generating capacity projections are subject to uncertainties asarethe projections. Appendix 7-2 has been revised to clariw the discussion of the IPM-projected total generating capacity.



### The 

### FS questioned why the 201

### 8 

### modeling over-predicts point source emissions, considering point source emissions have declined in every year since 2001.

From 2002 to 2018, CENRAP projected emission increases in the organic compounds, carbon monoxide, and particulate categories. For non-EGU sources CENRAP predicted increases in all contaminant categories (ranging from slight in nitrogen oxide and sulfur dioxide categories to significant increases in carbon monoxide and organic compounds). The increases predicted by CENRAP's modeling arein contrast to actual decreasesin these emissions in the actual annual inventory data collected between 2002 and 2005. Between 2002 and 2005, the historical data indicate actual industrial source emissions have decreased or held approximately constant for the point sources in all categories except carbon monoxide from electric generating units. Based on a historical decrease in emissions, CENRAl"s predicted increase is considered conservative.



### The EPA commented that Section 

### 51.308(d)(4)(v) requires the TCEQ to submit an emissions inventory that includes emissions for a baseline year, emissions for the most recent year that data
are available, and estimates of future projected emissions. The EPA 

### requested that the TCEQ contrast its 2005 

### emission inventory with that from its baseline year of2002, 

### and 201

### 8, 

### in order to check the accuracy ofthe EI projection methodology.

A summary ofthe 2005 emissions inventory data was included in Appendix 7-1: 

### Texas EmissionsInvetztoq:l, Development: Base Year2002

### andProjected Year2018, Section 7.5 of this 

### SIPrevision. Summary data from 2002,2005, and projected 2018 inventories areall included in the SIPrevision. The commission made no changes in response to this comment.

### The EPA,NPS, FWS, and FS commented that it was unclear which category the over reported tons per year (tpy) of sulhrdioxide were in and requested clarificationon why Texasbelieves the CENRAP-generated sulfur dioxide inventory is incorrect.

The 111,853 tpy of area source sulfur dioxide emissions modeled by the CENRAP are significantly higher than the 15,633 tpy of area source sulfur dioxide emissions reported by theTCEQ in 2002. The difference is attributed toindustrial and residential coal combustion, which was erroneously included in the CENRAP modeling. 

### In other areas of the country, coal burning is used as fuel for small industrial sources and also to warm residential homes. Because ofthe abundance of natural gas, coal is not a preferred fuel type for these sources in Texas,therefore the use assumptions in the CENRAP model are not valid. The Texas area source 

### 2002 annual inventory, developed with knowledge of fuel usage in Texas and submitted to EPA, is a more accurate reflection ofthe 

### SOz emissions from these types of sources.
The EPA, NPS, and FWS questioned that CENRAPYs modeled emissions estimate was not expected to significantly impactvisibility estimates for 2018because ofthe relatively small contribution from these Texas sources on Class I areas. The EPA, NPS and FWS commented that data presented in the SIP narrative suggestedthat Texas sources' emissions constitutethe majority ofvisibility impact at the Wichita MountainsSalt Creek, and Caney Creek; and indicated that Texas sources' emissionshave a great impact at White Mountain. The EPA, NPS and FWS asked that the TCEQ explain the specific differencebetween the reported TCEQ sulfur dioxide inventory and the CENRAPmodeled inventory as well as the rationale for why TCEQ considers Texas' contributionto visibility impairmentin neighboring states' Class I areas to not be significant.

The SIPstatement that "the SO2 emissions modeled by the CENRAP are significantly higher than the 15,633tpy reported by the TCEQwas intended to refer specifically to the
area sources of industrial and residential coal combustion that were over-represented in the CENRAPmodeling inventory, not all SO2 emissions. Thecommission did not intend to imply that emissions or emissions contributions to visibility from its sources were insignificant. The erroneously modeled industrial and residential coal combustion sources aretypically individually smaller and distant from Class 

### I areas. As a result, their representation in the model does not significantly detrimentally affect visibility estimates or model conclusions. In response to this comment, additions were made to Chapter 7: 

### Emissions Inventory and Appendix 7-1 of the SIPrevision for clarity.



### The NPS and FWS referenced the SIP Table 7-3: 

### CENRAP's 

### 2018Emissions Inventor)? Summary for Texas 

### showingthat emission estimates oforganics,primary particulatesand ammonia are predicted to increase during the planningperiod (years 2002 to 2018). The NPS and FWS suggested that the TCEQ include a summary within the SIPrevision of why estimates predict increases in organics,primary particulates, ammonia, and area source sulfur dioxide, together with a discussion of how much these increasesare expected to affectvisibility impairment at both Texas' and neighboring states' Class I areas rather than relying on the referenced CENRAP Technical Summary Document (TSD). This discussion should also consider the effects of emission decreases projected for sulfur and nitrogen products.
Appendix 7-1 discusses the use of EPA's Economic Growth Analysis System Version 5.0 (EGASS) methodology to predict 2018 emissions. The EGAS 5.0 factorswere based on the most recently available (at the time of inventory projection) set of economic and demographicprojections developed by Regional Economic Model, Incorporated (REMI) and the most current energy forecasts prepared by Department of Energy's Annual Energy Outlook (AEO). Data such as statistics from the Bureau of Labor, population growth, and projected energy use from the Department of Energy areinput into the model. These 

### 8anticipated increases in emissions are off-set in each category and region of the stateby the appropriateon-the-books controls. TheEGASS was used to predict future emissions for
area sources except for wind blown dust from non-agricultural land use categories, emissions from wildfires, and emissions from Mexico. These categories were held constant.

The specific levels of area source emissions for the 

### NOx, S02, VOC, carbon monoxide (CO), ammonia, PMZ.~, and particulate matter with aerodynamic diameters less than 10microns (I'Mlo) arelisted in both Table 7-1: 

### CENRAP's 2002

### Base YearEmissions Inventory Summaglfor Texasand Table 7-3. Theemissions inventory predictions made for the CENRAP modeling indicate, for the area sourcecategory, sulfur dioxide emissions increase by approximately 2 percent. Statewideemissionsof organics arepredicted to increase by 

### 6 percent, the PMloby 2 percent and the PM25 by approximately 7percent.

Ammonia is predicted to increase by 

### 33 percent Thelargest portion of ammonia emissions
areassociated with the area source agricultural-based sources. The Carnegie Mellon University model was used to estimate these emissions. Ammonia is not 

### a limitingpollutant for visibility for Texas' and neighboring Class 1areas. The area source sulfur dioxide emissions were from industrial.and residential fuel combustion categories,heavily influenced by population growth, which are erroneously included in the CENRAP inventory. These coal-burning industrial and residential sources arenot applicableto Texas and were not part of Texas' area source 2002 annual emissions inventory submission to EPA. Changeswere not made in response to comments because the chapter summarizes the modeled values.



### The NPS, FWS, and FS agreed that Mexico emissionscontained within the boundaries of the CENRAP modeling domain are important contributorsto visibility impairment at Big Bend and Guadalupe. The NPS, FWS, and FS requested that Texas acknowledgethe 

### work contained in the final Big Bend Regional Aerosol and Visibility Observational (BRAVO) study. The BRAVO study indicated sources in Mexico, Texas, and the eastern United States all play a role in sulfate conditions at Big Bend. TheNPS, FWS, and FS look forward to working with Texas to solicit EPA action with its sister agencies to address the Mexico portion of sulfate impairment at 

### Big Bend. The NPS, FWS, and FS also requested that the SIP speak to the Texas contribution to sulfate found in the BRAVO field study in the long-term strategy and reasonable progress sections. City League for Environmental Action Now (CLEAN) also agreed with the BRAVO study 2004,


### an interagency report, which CLEAN interpreted found sulfur emissions from coal-fired power plants contributed to 

### a larger proportion ofhaze in Big Bend than previously suspected.

Thecommission used the emissions inventory for the modeling from the BRAVO study as updated by Mexico. The commission used the latest available acceptable data for modeling for long term strategy and reasonable progress modeling. The BRAVO study collected data in 1999,then analyzed and produced the BRAVO Report in 2004, indicating that approximately one-third of the sulfate at Big Bend comes from outsidethe United States, one-third from Texas, and one-third from areas of the United States upwind of Texas. The commission revised Chapter 11 Section 11.3 to include reference to the BRAVO report.

Themodeling forthe SIPrevision uses the latest available emissions estimates, including BRAVO study emissions estimates. Thecommission agrees that sulfur emissions are the most significant contributorto haze in theBig Bend Class

### I area. Thecommission disagrees that the importance of sulfur dioxide emissions in contributing tovisibility impairment at Big Bend is a new finding. TheNPS monitoring atBig Bend was showing this fact in the 1990s. Coal fired power plants arethe major source of sulfur dioxide emissions. In the 2002 base period forthe Regional Haze SIPrevision, sulfatepollution contributed 

### 55percent ofthe visibility impairment from pollution. Texas' sulfur dioxide emissions contributed 21 percent of this 55 percent of thevisibility impairment from pollution atBig Bend on the 20 percent worst visibility days in 2002.



### One individual was concerned that commission does not know the extent of emissions from upstream oil and gas production. This information should have been gathered by 1999for the 

### Houston-Galveston-Brazoria (HGB) Ozone One-Hour Nonattainment Area SIPrevision. The individual commented that numerous small to medium size point sources should be controlled to reduce regional haze, hazardous airpollutants, and transported ozone and precursors. This individual suggested improving the emissions inventory and expanding its categories.

The commission acknowledges the need to improve the upstream oil and gas production emissions inventory. Currenteffort is underway by theTCEQ and CENRAPto improve this estimate and any improved estimateswill be included in the five year SIPreview. No changes were made to the SIP.



### The EPA asked whether the mix ofelectrical generating capacity (gas versus coal plus renewables) 

### asprojected in 20 18by the IPM appears reasonable when compared to that in 2002.

As shown in Table 1ofAppendix 7-2, the IPMVersion 2.19, used by CENRAP, projected an approximately 14percent increase in coalllignite-fired generating capacity in Texas from 2005 to 2018, and about a 32 percent increase in gas-fired capacity. TheERCOT projections, which areavailable to 2013, show a greater percentage growth in coaYlignitefired than natural gas-fired capacity based on utility planning that is publicly available. Both the IPM and ERCOT projections show a greater amount of gas-fired capacity in the latest available projection year than coaMignite-fired capacity. Although IPM projections of generating capacity from renewable resources such aswind power arenot summarized in Appendix 7-2 (since sources such aswind power do not create visibility impairing pollutants), other data obtained from the EPA indicate that JPM projections of generating capacity from such renewable sources aremuch lower than those from ERCOT. As is the
case for total projected generating capacities, the commission acknowledges that the projected mix of fuels for generating capacity is subject to uncertainties. Appendir 7-2 has been revised to clarify the discussion ofthe JPM-projected generating capacities for coalnignite and natural gas.


### The FS commented that the Midwest Regional Planning Organization used the IPM Version 3.0 rather than Version 2.19. The FS requested that the TCEQ justify the use of IPM Version 2.19 in light ofthe EPA's recent indication that IPM Version 3.0 provides a significantly more accurate prediction of future EGU operating scenarios and emissions.

The commission is not aware of a specific indication from the EPA that the IPMVersion 3.0 provides a significantly more accurate prediction of future EGU operating scenarios and emissions than IPMversion 2.19. The commission acknowledges that Version 3.0 was based
on more recent assumptions relating to fuel prices, fuel availability, regulatory policies, and
a multitude of other factors. Thus, the commission conducted an analysis comparing the potential visibility impacts on Class 

### I areas from Texas EGU emissions, based on projections of emissions from each version of the model. This analysis is documented in Appendir 7-2. The analysis provided evidence that visibility impacts of EGU emissions from each IPM version would be similar. Thus, the commission concluded that the IPM version 2.19 would be a viable planning tool for Texas to use for regional haze. Due to the particularly long planning horizon to 2018 for regional haze and the uncertainty in the assumptions upon which the IPM is based, the commission does not conclude that either version ofIPM is necessarily better than the other. The commission is also not aware of a

### better EGU emissions planning tool than the IPMfor regional haze SIPdevelopment. The commission made no changes in response tothis comment.

The FS referred to a discussion in Appendix 

### 7-1 regarding 

### IPM 2.19 versus IPM 3.0. The FS commented that "since they state that IPM 

### 2.1.9 was constructed when natural gas was prevalent, it is likely that projections for Texas under 

### IPM 3.0 would have higher emissions due to more use of coal." The FS also commented that Texas said that statewide the emissions projected in both versions were very similar.



### The discussion in the proposed SIPreferred to by the FS is actually found in Section 7.3.2 of Appendix 7-1 instead of Section 7.2.2.4. As noted in Table 

### 1ofAppendix 7-2, total sulfur dioxide emissions projected to 2018 forTexas EGUs by the IPM Version 3.0 were approximately the same asthose projected by Version 2.19, even though theIPM Version 3.0 projected about a 14 percent greater coal-fired capacity in 2018 than did Version 2.19. The commission does not conclude that emissions of sulfur dioxide projected by the 

### IPM Version 3.0 would necessarily be greater than those projected by Version 2.19. The projected emissions area function not only of capacities for the fuel types but also of the assumptions upon which each IPMversion 

### is based, including the extent to which sources implement emission controls for projected units orpurchase credits in response tothe Clean Air Lnterstate Rule (CAIR) or successor cap and trade program. The

### ZPM Version 3.0 projected about a 10 percent decrease in nitrogen oxides from Version 2.19. The commission believes that theprojected decrease was primarily due to the fact that Version 3.0 retired a large number of nitrogen oxide-emittinggas-fired generating units. In response to this comment, the commission made revisions to Appendix 7-2 to clarify the discussion ofWM-projected emissions.

The FS commented that it would be helpful for a more detailed discussion ofthe IPM results and the analysis ofEGU impacts on visibility in the listed Class I areas. The FS said that a map showing the groupings ofEGUs would add to the discussion.



### Thecommission notes that Section 7.3.2 of SIPAppendix 7-1, to which the commenter referred, contains only a brief summary of the IPManalysis. A detailed discussion comparing results from theanalysis of the two IPMversions is provided in SIPAppendix 7-2. This appendix presents a map of TexasEGUs emitting sulfur dioxide, the pollutant of primary concern for downwind visibility impacts, and presents tables showingthe upwind Texas EGU groupings upon which the analysis is based. The commission considers that the map and the tables of EGU groupingsprovide sufficient information forthe discussion provided in the appendix. No changewas made to the SIP.

One individual questioned why the TCEQ did not state how accurately the emissions inventory was for regional haze and questioned ifthis emissions inventory was any better than past inventories. The individual referenced several reports discussing the inaccuracy ofthe emissions inventory in past ozone SIPSand other reports. 

### One individual believed TCEQ was doing nothing in this SIP, other than to reflect emission reduction programs already in place and additional sulfur dioxide reductions from refineries 

### as a result ofEPA refinery consent decrees. The commenter considered these reductions inadequate and insufficient for ozone attainment sincethe emissions inventories were deficient.



### The commission acknowledges the uncertainties of emissions inventory estimation techniques. Significant effort was made to provide the CENRAPmodeling with the best available emissions estimates. Additional effort was made in categories considered more critical to accurate modeling, such as mobile sources. The commission continues to be committed to improving the quality of emissions inventories. The reports referenced 

### by the individual mostly addressed industrial source VOC emissions. The nitrogen oxide andsulfur dioxide emissions were determined by the TCEQto have the most significant impact on visibility impairment. For example, atBig Bend National Park annualaverage sulfate and nitrate observed concentrations account for greater than 50 percent of the visibility impairment in 2002 as shown in Figure 8-2 of the Regional Haze SIPrevision. The sulfur dioxide and nitrogen oxide inventories arenot predisposed to the same level of uncertainty associated with parts of thevolatile organic compounds inventory because emissions of these pollutants generally result from combustion sources that can be measured directly and often have continuous measuring ormonitoring devices that record those emissions. In addition, ozone model understanding is more than a decade of ahead of regional haze modeling, while this Regional Haze SIPis the first for most states. Predicting regional haze
can be more complex than ozone photochemical modeling because while the same complex atmospheric chemistry is involved, there arealso more pollutants to model. Haze does not haveto meet a health based standard, but is measured in deciviews (dv) and meant to improvevisibility. TheRegion Haze Rule requires using all existing rules and regulations, state and federal, to determine a uniform rate of progress to improvevisibility. All nitrogen oxide reductions made in support of achieving the ozone standard throughout the state are beneficial also to reducing regional haze. The commission made no changes in response to these comments. Chapter 8: Modeling Assessment 

### TheNPS and FWS commented that both Figure 8-4: ObservedandBase CaseModeled Concentrationsat

### BigBend 

### and Figure 8-5: Observed and Base CaseModeled Concentrationsat GuadalupeMountains 

### are intended to support the discussionof the model performance evaluation. The commenters asked that the commissionexplain why the figures are referencing the Typical 2002G base year inventory instead of the actual 2002 performance inventory.

The

### CENRAP modeling team evaluated the differences in model performance evaluation 

### (MPE) results between a version ofthe 2002F base case and 2002Ftypical case and found the differences in the statistics to be negligible. A minor correctionwas made in the 2002F typical case inventory, and at that point, in an effort to conserve resources, the modeling team decided not to rerun the base case, but to rerun the typical case and perform an MPE
on the 2002 typical case. The MPE results for the 2002F typical case arethe most recent available. The commission made no change in response to this comment.



### The FS commented that in Chapter 

### 8 while high contributions from international transport and natural sources certainly affect progress for Class I 

### areas such as BigBend?these sources do not apply to the northern Class I 

### areas. The FS stated that transport from Canada is often associated with the cleanest days at these northern Class I 

### areas.
Thesentence referred to above was meant to apply to the Texas Class 

### I areas. The commission made minor changes to clarify the text.



### One individual commented that the commission did not acknowledge Harris County source impacts in other states. The commenter questioned ifthe commission investigated the cumulative affect of sourcesalong the Houston Ship Channel that can affect regional haze.

Thecommission disagrees with the commenter. The commission specifically requested that the Particulate Matter Source Apportionment Technology (PSAT) modeling analyses examine the impact of three Texas source regions. The results of the PSAT analyses conducted by CENRAPand the commission arepresented in Appendix 8-1: 

### Technical Support Document for CENRAPEmissions andAir QualiqtModeling to Support Regional Haze SIP, see Chapter 5: 

### Additional SupportingAnaJysis. As shown in Figure 5-8: 

### 30 Source Regions used in the CENRAP 2002 and 2018 CAMxPSAT PM Source Apportionment Modeling, Texas is broken up into three regions, one of these being the Gulf Coast whicb

### includes Harris County and the Houston Ship Channel. The source impacts from this area can be found in thePSAT results. An 

### example of the results for Caney Creek can be found in Figure 5-10: 

### PSAT SourceRegion by Source Category Contributions lo the Average 2000- 2004 Baseline and 2018 Projected Extinction for the Worst20 Percent VisibiZio~ Days at Canqy Creek, Arkansas of the TSD. The commission made no changes in response to this comment.



### One individual was concerned about the modeling results. 

### The individual stated that the commission admitted that visibility falls 5 

### percent short at Breton 

### and 40 

### percent short at Wichita Mountains. 

### In addition,the cornmenter asserted that the high contributionsof..



## .natural sources (e.g., windblown dust) are likely human caused because grazing and farming and can cause longterm changes to surface area exposure which creates more potential dust generating surfaces. The individual asked what the commission will do toreduce Texas's agricultural emissions sothat Class 

### I areas outside of Texas will reach acceptable visibility levels as soon aspossible. The individual advocated for quantification of agricultural impacts and destruction ofnatural plant coverage. This individual recommended rules to require best management practices for grazing, farming, and agricultural practices that expose soil and 

### an implementation plan with enforcement to ensure that the plan and goals are achieved.

The federal Regional Haze Rule suggests states should not try to attribute ancient human land disturbances as anthropogenic. Specifically,the 

### Guidarzce for Estimating Natural Visibility Conditions UndertheRegionalHaze Program (EPA

### 2003) states that "estimates of natural visibility conditions should reflect contemporary conditions and land use patterns," rather than "historic conditions."

While some dust (coarse mass and fine soil) atboth of Texas' Class 

### I areasmust be from
some human activity, analysis of the dust storms that dominate high dust events at Guadalupe Mountains, and significantly impact Big Bend suggests that the dust originates from drydesert and drylake bed areas with little or no human activity, almost all ofwhich
aresituated in the Chihuahuan Desert. For instance, in the2005 report

### Investigation of DustEmissionHotspots in Chihuahuan Desert Playa Basins, Gill et al. statetheconclusion that "Field campaigns revealed that



# . ..thevast majority of source points were natural desert landscapes" (Gill et al. 2005). In addition,the Gill et al. work found that:

Particle size analysis of surface sediment samples revealed that many of the dust source points have surface granulometries which create a "perfect storm" for aerosol emission. They include two orthree distinct grain size populations: very fine clays in the PM2.s range (including particles as small as0.2 micron in clay playa sites) and fine sands (50- 200 pm), and in some sites silts (10- 50pm particle size). This is consistent with current state-of-the-science knowledge of the desert wind erosion process. Sand grains saltate(bounce) across theland surface in wind storms, breaking apart and "sandblasting" silt and clay aggregates and releasing their individual constituent grains into the atmosphere as dust.

The commission has included additional supporting evidence in Appendix 5for the estimate that, at least for the estimation of natural visibility values for Texas Class 

### I areas, that major dust events can be approximated to be completely natural in origin. Additionally, since there is uncertainty in this estimate, as there is in all the components of natural visibility conditions, the commission has provided plots showing the results for the 20 percent worst natural conditions Haze Index (in deciviews)if one were to treat only 80 percent of the coarse mass and fine soil to be natural. However, this 80 percent calculation is displayed only as an indication of how little sensitivity this natural visibility estimate has to approximating 100percent ofthe coarse mass and fine soil as natural.At this time the commission has no plans to add additional control measures for grazing and farming dust emissions. This issue may be reviewed in future Regional Haze SIP revisions.

One individual commented that the modelingmay be inaccurate for the following reasons: the modeling area is larger than used for other nonattainrnentdemonstrations; the poor quality of emissions inventory in Texas and other states; and the lack of credibility ofthe CAMx model being used since it has failed to model Houston and Dallas successfully towards ozone attainment using real monitoring data.

Due to these issues, the commenter suggested severe credibility problems for the Texas regional haze modeling. In Chapter 

### 8, the commission did not provide any information about the accuracy of the modeling doneby the TCEQ, CENRAP, or EPA. For previous ozone attainment SIP revisions, the commission statedthat the modeling conducted was sufficient, adequate, and documented attainment; yet, the goals were not met. This modeling analysis is currently the most credible analysis available for regional haze. Texas and other states arecontinuing to improve their emission inventories and their modeling platforms. The regional haze modeling domain encompasses such 

### a large area because pollutants that contribute to haze can travel great distances. The commission made no changes in response to this comment.

The NPS and FWS commented that there is a considerable amount of discussionin the SIP revision that emissions used by CENRAP and others for modeling were greater than the inventory reported by the commission. However, Figures 8-4 and 8-5 use the CENRAPtypical base year inventory of 2002 and consistently show significant under prediction of all visibility impact parameters when compared to observed values. Although the model is later used in a relative sense (employing relative reduction factors (RRFs)), Texas should address this apparent discontinuity between text describinga significant over estimate of SOzemissions and model performance metrics that indicatea significantunder estimate. One individual advocated for more control measures since the modeling under estimates many haze-forming pollutants.

Thecommission has analyzed the model performance and learned that the modeling under predicts the sulfate impacts from outside the United States, Texas, and states upwind of Texas. The commission has requested further analysis of the model performance. The initial results suggest that the model may be producing the correct sulfate concentrations but not transportingthem allthe way to these West Texas Class 

### I areas. The first report of this work has been added asAppendix 

### 8-2: Big BendModel PerformanceAna!vsis. The commission has further model performance analysis work under way to support improved model performance in future Regional Haze SIPrevisions. The commission is also working with its modeling contractor to correct the over estimation in the area source emissions inventories. No changes have been made in response to this comment. (For more details on controls, see the response under general comments with the current list of control measures, pages 44-45.)

Emission Categories Held Constant The NPS, FWS, and one individual commented that the Gulf of Mexico has significant contributions in 2018 for the worst 20 percent of visibility days. Offshore emissions should not be held constant through the planning period. The commenters suggested that a better estimate of the future case emissions shouldbe made.

### The commission spoke with Minerals Management Senrice (MMS) personnel in spring 2008 

### who stated that MMS has no issues holding offshore emissions constant forthe following reasons:

MMS currently has no data tojustify growth in emissions and agrees that a projection to the futurewith no change is a reasonable one. Current closer-in leases are being exhausted and shutdown; new leases arefor deeper water offshore and further out into the gulf. Application of newer technology will reduce emissions per unit of production. MMS personnel indicate that these further out sources arelikely to have less impact onshore.

MMS is currently preparing a 2008 

### emission inventory, which will be completed in 2010. 

### Emission trends will be reviewed by the commission when that data is publicly available. No changes have been made based on these comments.



### One individual questioned why so many inventory categories between 2002 and 2018 were heid constant.

Global transport of air pollution from Chinawould vary. Mexico and Central America emissions vary dueto changesin economic activity. The Sam Houston National Forest and three other national forests in Texas are conducting more prescribed burning

### than in the past to provide better habitat for the federallyendangered Red-cockaded Woodpecker. So within Texas, there may be more burning of vegetation. Emissionsfrom wildfires between 2002 and 

### 2018 can vary greatly depending on droughts, winds, and other factors.

GEOS-Chem was used to model boundary conditions forthe CENRAP modeling domain, including those forChina. The commission cannot reasonably predict future emissions from China. Holding the these inventories constant while growing Texas and the United States emissions puts more emphasis on the potential future impact from Texas and United States sources on Class 

### Ivisibility impairment. Depending upon resources and quality of future global emission inventory data, the commission may consider future case model runs of GEOS-Chem orother global models to use for future case boundary conditions. In addition, regional haze from China appears not to be a significant factor in theworst 20 

### percent of days atClass 

### I areas that Texas impacts, so theassumptions about this source of regional haze arelikely to be insignificant in affectingfutureprojections for these Class I
areas.

For the Mexican and Central American emissions, the direction of emission changes is uncertain. Improving economic status often results in more investment in pollution controls. The improvement in pollution reduction may ormay not offset the increasing economic activity and energy usage in these countries. The commission understands that Mexico is currently working on the development of a 2005 

### emissions inventory and future emissions projections and will review1 this information when it becomes publicly available. In regards to prescribed burning and wildfires, the commission acknowledges that there
can be great variability from year to year. However, in current analyses, smoke emissions from fires are not an important contributorto regional haze at Class 

### I areas in Texas. No changes were made in response to these comments.

### One individual considered it a faulty assumption to use the same biogenic emission inventory between the base case and the future case for modeling. The commenter assertedthat biogenic VOC was not constant due to urban deforestation caused by sprawl. Predicting futurebiogenic inventories is projected to cost approximately $5 million and not necessarily more accuratethan thebase case inventory. Urban sprawl along with its vegetative changes is difficult to quantitatively estimate, so any predictions arealso likely to be uncertain. 

### If suff~cient resources were available to project a future inventory, the commission could use the results for modeling; however, the new inventory would likely be consistent with the currentbiogenics assumption. No changes were made in response to this comment. Chapter 9: Best Available Retrofit Technolow (BART) 

### The EPA and one individual noted concern that Texas had no BART sources that had to install control equipment ofthe approximately250 potentiallyBART-eligible sources in the state. Tlle EPA commentedthat Texas sources significantly contribute to visibility degradation to a number of Class I areasin other states, in some cases more than the host state. The EPA commented that it is unclear how this decision is "reasonable" under Section 51.308(e), which requires that, "The state must submitan implementationplan containing emission limitations representing BART and schedules for compliancewith BART for each BART-eligible source that may reasonably be anticipated to cause or contributeto any impairment ofvisibility in any mandatory Class I Federal area." The individual considered that Texas having no sources subjecttoBART showed that the commissionhas no desire to attain regional haze standards by the 2064 compliance date.
BART applies to sources completed between August 7,1962, and August 7,1977. Many of these sources have already been subject to controls, which lowered theemissions to levels that screened potentially BART-eligible sources from visibility impairment in Class 

### I areas. Some of these sources were constructed under Texas new source review (NSR) permitting requirements, which included best available controltechnology (BACT)requirements. These requirements were initially implemented between 1971 and 1972. Sources constructed under these rules were required to use effective engineering controls to minimize oreliminate emissions of all airpollutants. Additionally, Senate Bill 7, passed in the 76th session of the Texas Legislature in 1999, required all electric generating units (EGUs) to reduce sulfur dioxide and nitrogen oxide emissions under permits by no later than May 2005. Moreover, House Bill 2912, passed in the 77th session of theTexas Legislature in 2001, required all previously grandfathered sources (i.e. constructed prior to August 30,1971) to obtain standardpermits, permits by rule, oran individual permit. House Bill 2912 specified the performance required for upstream natural gas field compressors powered by internalcombustion engines. For all other individual permits, the engineering standard required the sources to apply ten-year old BACT to obtain a permit. The compliance date required by these permits for sources in eastern Texas (except for small business owners) was March 1,2007. Thecompliance date required by these permits for sources in western Texas and for small business owners was March 1,2008.

BART was designed to bring major sources that had been grandfathered under federal new source review rules under effective control, but all Texas sources have alreadybeen brought under effective emission control requirements by Texas permitting requirements, and to some extent, recent EPA refinery consent decrees. Thus, since Texas has already addressed the control technology of its sources by requiring permits even when federal new source review was not in place orthrough its subsequent permit requirements under state law, it is not surprising that BART, designed to add controls to unregulated industry, did not require additional reductions.

### Title 40 CFR 51.308(e)(4) says, "A state that chooses to meet the emission reduction requirements ofthe CAIR by participating in one or more of the EPA-administered CAIR trading programs for sulfur dioxideand nitrogen oxideneed not require BART-eligible EGUs subject to such trading programs in the state to install, operate, and maintain BART for the pollutants covered by such trading programs in the state." Texas has adopted the CAIR rule as well as other SIPrevisions that reduce emissions. These actions removed the large majority ofthe Texas sources from furtherBART consideration for sulfur dioxide and nitrogen oxide controls. The decision to treat CAIR as equivalent to BART will be revisited if CAIR is replaced with a trading program or rule that the EPA considers to be equivalent to BART, and that addresses the federal appellate court's ruling. The TCEQ will provide a SIPrevision to address this issue, once the federal government has finalized its decision with respect to CAIR or a replacement trading program for sulfur dioxide and nitrogen oxide. A large percentage of major non-EGU sulfur dioxide and nitrogen oxide sources in Texas
arehundreds of kilometers from the nearest Class 

### I area, so their contributions to visibility impairment at Class I areas aresmall. The emission reduction requirements under EPA's refinery consent decrees resulted in dramaticreductions in sulfur dioxide emissions from refinery and sulfuric acid plant emissions of sulfur dioxide. Without these consent decree reductions, BART requirements may have applied in somecases. Because emissionsfrom these facilities have already been controlled by Texas' permitting requirements, these
sources were not subjectto additional controls as a result of the BART requirements, which have been incorporated into the TCEQ's BART rule adopted on January 10,2007.



### In accordancewith the EPA guidance, the commissionimplemented the BART rule and followed procedures laid out in the rule. The commission modeled sources in a conservative
manner to screen out sources that had less that a 0.5 deciviewimpact on Class 

### I areas as provided in the EPA's BART rule. Some sources that did not screen out of the initial modeling choseto shut down facilities orto apply controls which reduced their impact on Class 

### I areas. Other sources already had extensivecontrols in place due to other emission control programs for ozone SIPrevisions, and the refinery consent decrees. TheBART process is fully explained in Chapter 

### 9: 

### BestAvailableRetroBt Technologyof the SIP revision. All BART-eligible sources arelisted. In addition, there is a list of sources that reduced their potential to emit through permit amendments, and/or by shutting down units in orderto avoid being subject to BART controls. At this time, all BART-eligible sources have modeled emission impacts below the BART determination threshold dueto emission reductions required by existing regulations or consent decrees. No changes were made in response to these comments.



### The EPA, NPS, FWS. and 

### FS commented that the federal Regional Haze Rule established BART criteria for exempting sources that are determined to be non-significant, and that the EPA offered
an upper bound of that single source significance level at 0.5 

### deciview. The EPA and FS asked that Texas provide a 

### discussion ofhow it arrived at its selected 0.5 

### deciview threshold value.

The 0.5 deciview threshold was adopted by the commission on January 10,2007, as part of the Texas BART rule. The response to comments in thatrule adoption stated: "The commission will not lower the 0.5 decivieajthreshold. Thecommission has received no evidencethat a lower threshold is appropriate in Texas. By using only a singlethreshold, the TCEQ does not intend to imply that the threshold for causing visibility impairment is the same as for contributing to. SinceTCEQ expects all Class 

### I areas have more than one source impacting visibility, any sourcethat causes visibility-impairment (such as, using for example, based on the EPA's threshold of a humanly perceptible visibility impact of 1.0 deciview or greater) also contributes to the same. So 'the contributes to' threshold is the
one relevant to this rule.


# ... Thecommission is following EPA guidance, Part 51, Appendix

### Y, Section III.A.l, and has made no changes in $116.1520 and $116.1530 in response to the comments." Additionally, as discussed previously, almost all Texas sources that might have been subject to BART technical analysis requirements under the BART rule arehundreds of kilometers from the nearest Class 

### I area and their emissions are already controlled under appropriate permitted emission limits. Since Texas has neither grandfathered sources nor a large number of sources near Class 

### I areas and potentially subject to BART technical analysis and control requirements under BART, the commission does not consider it appropriateto
use a threshold other than the 0.5 deciviewthreshold that EPA set. No changes were made in response to this comment.



### TheEPA, NPS, and FWS commented that several tables in Chapter 9 were difficult to understand. The EPA asks for further documentation and building of a cross-walk to help demonstrate what modeling was used to screen-out each source. The 

### NPS, FWS, and one individual questioned why Table 9-6: Post-BARTEmissions Reductions atTexas Sources in Chapter 9 and Appendix 9-12: BART-Eligible List are not the same. The NPS, FWS, and one individual asked the commissionto clarify the differences between the two tables and provide
more definite information regarding the ExxonMobil facility.

Thecommission acknowledges that the BART-eligible tables may be difficult to understand dueto the complexity of the BART process.

Thetable in Appendix 9-12 is the BART-eligible list that has been on the Web site since April 2006 when the BART survey results were posted; this same source list has been updated with details of each exemption, modeling completion, usage of the model plant, and whether the source passed or failed the modeling threshold. To simplify this potentially six page BART-eligible list, this larger list was broken into smaller and simpler tables with an explanation of the differences. Therefore, combining all the tables in Chapter 9 are approximately equivalent to the larger, more detailed table in Appendix 9-12. The exception is the greater detail in Table 9-6 of Chapter 9, which documents the estimated post-BART reductions of approximately 9,000 tpy and that is found only in Chapter 9.

Not all of the sources shown in the table in Appendix 9-12 referred to in the comment will reduce NOx, SO2,orparticulate matter emissions. Table 9-6 in Chapter 9 has been updated to clarify this, and to show the most current information available.. The detailed documentation of the emission reductions shown in Appendix 9-10 has also been updated with the most current information available. Reduction estimates are conservativebecause they are from the 2002 actual emissions level to a potential to emit level. Should any of the reductions noted in the tables need to be further updated, they will be incorporated into the SIPrevision atthe next review in 2013. In response to these comments,the commission simplified the tables in Chapter 9 and updated the information on ExxonMobil.



### The EPA commented that in Chapter 9 ofthe SIP revision the TCEQ should address the following: a) The TCEQ should present additional detail on the methodology used to identie the initial list ofpotentially BART-eligible sources that received surveys. For instance, was a permit review part of this strategy? How did the TCEQ determine ifparticular sources were in one ofthe 26 BART categories; had a potential to emit of 250 tpy or more of any visibility-impairing pollutant; and were not operating prior to August 7, 1962, and were in existence on August 7, 1977? This should include a discussion ofthe sources discussed in Section 9.5, which were exempted from BART-eligibility through the TCEQ BART Rule. b) The TCEQ should present additional information that demonstrates this strategy effectively captured all potentially BART-eligible sources within the state.

### This Regional Haze SIPrevision provides additional information on the suwey methodology used by Texas. A copy of the suwey is included asAppendix 

### 9-3: Texas Survejj for BART Eligibility. 

### The updated information summarizes Texas' method to capture sources meeting the BART-eligibility requirements outlined in the EPA's Regional Haze Rule. Standard Industrial Codes and Source Classifications Codes were associated with the 26 

### source categories identified in the EPA BART Rule. The TCEQ suweyed all Texas sources with applicablecodes and emissions thresholds, includingfossil-fuel steam generating plants with potentially BART-eligible quantities of particulate, for additional information regarding build and reconstruct dates and potential to emitlevel for emissions. Theinformation obtained in this suwey helped identify the sources thatwere BARTeligible. Sources requested exemptions based on the 2007 

### Texas BART Rule, modeling for visibility impacts, orother updated information atthe site. Theexemption process is also discussed in Chapter 

### 9 Section 

### 9.2 through 9.5 

### of the Regional Haze SIPrevision. The BART-eligible sourceswere adequately captured in this process. Thecompanies suweyed represented over 97 

### percent ofthe sulfur dioxide and 77 

### percent of the nitrogen oxide emissions from 2002.



### The

### NPS and FWS commented that the two tables in Chapter 9 identify BART-eligible sources that were exempted afterperforming source-specific BART engineering determinations through either CALPUFF modeling (Table 9-3: BART-EligibleSources ExemptedBased on CALPUFF ModelingResults) or CAMxmodeling (Table 9-4: BART-Eligib le Sources Exempted Using Single Source CAfiModeling). The commenters suggested that it would be helpful to list the modeled visibility impactresults for each ofthese facilities in these tables (i.e., Class 

### I area, deciview impact, and distanceldirection information for each Class I area evaiuated in the individual source modeling analyses). The commenters suggest that this information would provide the reader with a quick reference ofthe relative importanceof each listed facility that 

### was exempted through individual source attribution modeling.

The commission provided the information requested in Chapter 

### 9. Table 

### 9-3 now presents the source, the Class 

### I area modeled with the greatest impact, distance to the Class 

### I areas, and the modeled visibility impact ateach Class I 

### area.


### One individual commented that the distancesused for BART-eligible sources are too short (50 kilometers or 3 1 miles and 100kilometers or 62 miles) since TCEQ and other agencies have shown that emissions can travel hundreds of miles away and affect Big Bend and Guadalupe Mountains. This individual suggests expanding distancesup to 400 kilometers or 250 miles, since it has been documented by studiesthat ozonecan be transportedinto the Dallas area from the Houston area. In the case referenced by the individual, ozone air pollution traveled over 400 kilometers or 250 miles.

The commission did not limit the distance from a Class 

### I area forpotential BART-eligibility to 50 

### or 100 

### kilometers. All sources regardless of distance, with the appropriatecategory of
sources as defined by the BART rule, within the statewere considered. Based on analysis of visibility impacts, the EPA allowed the use of the model plant analysis by which a state could choose toexempt sourcesthat emit smaller amounts of nitrogen oxide and or sulfur dioxide, as long as they were more distant from a Class I 

### area,per Option 2: Use ofModel Plants toExempt Individual Sources with Common Characteristics

### underAppendix 

### Y to Part 51-Guidelines for BART Determinations Under theRegional Haze Rule 

### (page

### 39162). Texas concurred with this use for the lesser significant emitting sourcesfor the purposes of BART analysis. All applicable sources within the 50 

### kilometer range were considered for BART. Additionally, all sources, regardless of their distance from the Class 1

### areas orquantity of emissions, were included in regional haze modeling and consideration foradditional potential controls, even if initially removed from BART consideration. Thecommissionlooked ata range of distances from approximately 90 to 600 km (see Appendix 9-6, Table B-1). No changes were made in response to this comment.



### One individual suggested the TCEQ establish areas of influence (AOI) to capture sources farther away than 50to 100kilometers away from Class 

### I areas. This individual suggest the TCEQ use these areas of influence subdivided geographicareas and emphasize sourcesthat have the highest possibility ofprovidingreductions that will benefit visibility and thus reduce regional haze impairment.

As part of the area of influence analysis, the TCEQ identified any sourcewithin an area of influence with potential a$d-on controls and its costs were included. The analysis included
sources greater than 50 to 100kilometers from any of the ten Class 

### I areas. Sources with potential controls were identified from the CENRAP list which was developed using EPA's AirControlNET. The visibility impact from these potential controls was evaluated and this SIPrevision is updated to reflect this analysis in Chapter 9. Control strategieswere limited to costs similar to those of otherair control programs such asEPA's estimate of the Clean Air Interstate Rule's cost of $2,700 per ton. Changes were made to Chapter 10 to more thoroughly explain the AOI-based analysis. Chapter 10: Reasonable Progress Goals (RPGs) 

### The FS commented that Texas correctly used the modeled value for the 20 percent best days as its reasonable progress goals (RPGs). As part of the consultation process, the FS has indicated to several other states their incorrect interpretation. The FS commends Texas for setting this reasonable progress goal correctly.

Thecommission appreciates the comment and looks forward to a continued and collaborative relationship with the FS and other FLMs.



### The EPA requested that the TCEQ discuss the emissions reductions resulting from its BART rule. In Chapter 10,the TCEQ stated its reasonableprogress goals, "These RPGs do not include additional emissions reductions from implementing the Texas BART rule



## . ..."

The reductions associated with the BART rule are discussed in the Chapter 9 and summarized in Table 9-5: Post-BARTEmissions Reductions af Texas Sources. Although Chapter 9 estimates potential reductions, the commission chose not to include these reductions in the long term strategy in Chapter 10atthis time. Texas may examine these reductions again atthe next revision, if needed. The commission made no changesin response to this comment.



### The EPA commented that there is no provision in the federal Regional Haze Rule for delaying potentially cost effective controls due to modeling uncertainty. The EPA noted that the TCEQ's proposed SIP stated a potential overprediction of electric generating units emissions on Class I
areas by the IPM model analysis. Also, the EPA commented that the uncertainty in the impact of the CAIRprogram is one reason why the TCEQ has elected not to pursue additional controls at this time.

Due to the uncertainty in the impact of CAIR orits eventual replacement (whether over predicting or under predicting emissions), the commission's approach atthis time is to track CAIR or replacement program over the five-year and ten-year intervals, and determine if additional controls are needed in Texas.



### The EPA commented that under Section 51.308(d)(3)(ii), the TCEQ must demonstrate it has included all measures necessary to obtain its share ofthe emission reductions needed to meet the progress goal of Class 

### I areas in other states as well. The EPA requested that the TCEQ

### investigate reductions at Wichita Mountains in Oklahoma, Caney Creek in Arkansas, and 

### Salt Creek in New Mexico, as well as other Class I areas Texas has shown to impact.

The commission has updated Chapter 

### 10of the 

### SIP revision and Appendix 10-1: Analysis 

### of ControlStrategies

### RPG with a summary ofTexas' proposed control strategies for ten Class 

### I areas. This includes the Big Bend and Guadalupe Mountains National Parks and eight others outside the state. The summary includes impacts of visibility impairment from proposed controls for those Class 

### I areas.


### The EPA, FS, and one individual noted that the TCEQ took the position that even if over $300 

### million dollars was spent on sulfur dioxide and nitrogen oxide controls atthe 24 sources (Table 10-4: The TCEQ's Point Source Control StrategySurnmaly),only 0.05 deciview improvement would be seen at Big Bend and Guadalupe Mountains (Table 10-5: Estimated Visibility 

### Inzprovement). The EPA and FS noted this assessmentdid not consider that the average cost of sulfur dioxide control was approximately $1,850 per ton. Consideringthat sulfate (SO4)was the dominant controllable pollutant the TCEQ indicated causes or contributes to visibility impairment (Figures 8-4 and 8-5), the TCEQ should reconsider this assessment. One individual considered the value ofpeople's lives and the pristine wilderness worth the cost of controls.

The commission did consider source controls that were not already on the books. The onthe-books controls, including CAIR, were included in the CENRAP Base G modeling run. A CENRAP-directed effort used EPA's AirControlNet program to determine additional controls forvarious sourcecategories beyond theBase 

### G. These potential controls, associated costs, and benefits were considered in the four factor analysiswhich is revised in the 

### SIP. The incremental cost was not reduced in this study. The commission's proposed control strategy for additional controls results in a negligible projected improvement in visibility. The commission's analysis concludes that additional controls forregional haze
arenot reasonable at this time. However, this will be reviewed in future 

### SIP revisions.



### The FS referred to paragraph in Chapter 10 indicating that no electric generating unit was able to make an enforceable commitment to any particular pollution control strategy. The FS commented that Texas has no basis to state that the 

### IPM projections were an over prediction. The FScommented that the 

### IPM projections could also be an under prediction, which would not add to thejustification for not pursuing any additional controls.

The commission's wording in the proposed Regional Haze 

### SIP referred to a potential over prediction of emissions by the 

### IPM. However, the commission agrees with the commenter that the 

### IPMcould also be under predicting. The paragraph has been revised.



### The EPA commented that an evaluationon emissions over distance analysis (Q/5d) can be conducted but emissions over distance analysis are sensitiveto the meteorology that impacts the transport and may not yield a conservative analysis. For example, ifthe source modeled is not upwind (and the source does not transport direct'lyto the Class I 

### area frequently), the analysis would not be conservativeto evaluate another source that is upwind of the Class 1

### area more frequently. The EPA requested an expanded discussion ofthis issue sothe analysis for all
sources is a 

### conservative assessment.

The commission agrees emissions over distance analyses can be sensitive to weather and transport and may not yield a conservative analysis so it used areas of influence for the top priority anthropogenic pollutant emissions from Texas for each Class 

### I area affected by emissions from Texas. Development of these areas of influence integrated considerations of wind flow, frequency of pollutant impacts, residence time, and concentration of sources as well as distance from the individual sources to the Class 

### I receptor and the emission rate of each source. Chapter 10and its appendices provide furtherinformation on the use of areasof influence and the four factor analysis in determining whether all reasonable controls have been applied in this round of emission reductions to proceed toward the national goal of natural conditions at all Class 

### I areas. Changes were made in response to this comment. 

### The NPS, FWS, and one individual commented that the text associated with Table 10-7: Contributionsto Visibilig) in the Texas Class

### IAreas 

### implies thatthe boundary conditions contribution to impairment is primarily from Central America. The CENRAPmodeling assessment did not differentiate among five large-scalemodel boundaries when compiling data for sulfates and nitrates. The commenters requested Texas clarify whether Table 10-7 is referring to total contribution to extinction or contributions to sulfate and nitrate impairmentbased on the CENRAP tracking model. The TCEQ needs to acknowledge that a portion of boundary conditions may be a result ofrecirculation of Texas and other United States-generated emissions. The SIPrevision should note that boundary conditions are highly uncertain and that contributions from within the model boundaries may be significantly higher.

Because the CENRAP modeling does not identify the source area of pollutants transported into the CENRAPmodeling domain from theboundary, the information about source areas beyond the CENRAP modeling domain comes in part from available information about the location, density, and nature of anthropogenic and natural sources. The information also
comes from back trajectory analysis conducted by the NPS 

### in the 1990sand back trajectory analysis for the 20 percent worst of days in 2002 atBig Bend.

The commission interprets these data to be generally consistent with the CENRAP particulate matter source apportionment (PSAT) modeling, which shows in Figure 11-2: 

### Areas andPollutants Causing Regional Haze atBig Bend that the extinction contribution from Mexico and from the boundary conditions areroughly equal, but that nearly all the international transport of organic carbon and black carbon comes from the boundary condition area. This result is consistent with satellite imagery and other information pointing to southern Mexico plus the southern Yucatan as being the major source areas for the smoke atBig Bend. The large amount of oil and gas production activity in the Bay of Campeche plus the urban and industrial activity in Mexico from the southern part of Mexico, which includes Mexico City and all but the northern tip of the Yucatan, arein the boundary conditions domain. The commission concludes that these facts are generally consistent with the international sulfate impact at Big Bend, which thePSAT analysis attributes mainly to the northern portion of Mexico, which is in the CENRAPmodeling domain.

The commission agrees that occasionally some United Statescontinental haze does migrate far enough south into the Gulf of Mexico that the GEOS-Chem model used to produce the boundary condition estimates could have included it in the regional haze transported from the boundary conditions domain into the CENRAP modeling domain. The commission disagrees with the suggestion that a significant amount of regional haze attributed to the boundary conditions comes from,theUnited States. When air masses penetrate that far south into the Gulf of Mexico, they areoften following strongcool or cold fronts moving rapidly enough thatthey do not accumulate large amounts of regional haze. Slow moving summertimehigh pressure areas that accumulate large amounts of regional haze are much more often associated with recirculation into the United States from the central and northern Gulf of Mexico, where the CENRAP PSAT modeling analysis would identify the correct source area and attribute the pollution to that area.
The commission agrees that there is significant uncertainty about emissions in the boundary conditions area and from Mexico, but the commission concludes that the representations in the CENRAP PSAT analysis appear generally reasonable. The commission notes that the analysis in the BRAVO study concluded in the late 1990s and analyzed early in this decadeindicates that approximately one-third of the sulfate atBig Bend comes from outsidethe United States, one-third from Texas, and one-third from areas of the United States upwind of Texas. The commission has revised its SIPrevision to include these important perspectives. If this attribution of more of the sulfate to the midwestern and southeastern United States turns out to be more accuratethan the CENRAP PSAT modeling, then the reductions from CAIR or its replacement program could be more effective in reducing regional haze atBig Bend and Guadalupe Mountains than the commission has projected using CENRAP PSAT modeling.



### The FS 

### commented that the uniform rate ofprogress shown in Chapter 10

### is not the EPA default rate and should be indicated as such.

The commission disagrees that the EPA default should be in the SIP narrative as it might add to reader confusion; however, the text in Chapter 10has been revised and refers the reader directly to the EPA default rate in Appendix 10-3: 

### Uniform Rate ofprogress Curves UsingDefault Natural CondiiionsEstimates. In addition, the appendices to Chapter 10are located directly after Chapter 10 in the SIP submission so that the relevant information that the FS requested is more convenient for review.



### The NPS 

### and FWS 

### requested the additional references cited 

### in the reasonable progress discussion, including the Alpine Geophysics, CENRAP, and EPA works, be included in the appendices.

These documents were written by parties outside the agency and are cited as references in support of Texas' work Except for the EPA documents, appropriate references have been added to the TCEQ's regional haze Web site in response to comments.



### One individual commented that it takes time to clean up present polluters. This individual proposed that Texas should not continueto grant exceptionstograndfathered emitters, and the TCEQ should not consider permitting additional uncontrolled sources.

The commission does not agree that grandfathered sources aregranted exceptions from permitting. There are no longer grandfathered facilities in Texas. TheTexas Clean Air Act requires that all sources previously grandfathered submit a permit, qualify for an applicable permit-by-rule, or shut down by 2004. During the permit review process, the emissionsfrom previously grandfathered sources arereviewed to ensure that the permit protects human health and the environment. The appropriate and feasible emission control requirements vary depending on the size and nature ofthe source are determined on a caseby-case basis. New and modified sources arerequired to meet currentBest Available Control Technology (BACT), including these previously grandfathered sources. Any source tha-tis modified must meet current technology requirements through additional permit review or by meeting the conditions of a permit-by-rule. Insignificant sources may be authorized under an applicable permit-by-rule, which may allow a lesser degree of control due to the small size of the source.

Four Factor Analysis 

### The FS 

### commented that given the uncertainty of the modeling and the implementation of CAIR, the SIP appeared to disregard Texas impacts to Class I areas in Arkansas and Missouri. PSAT results indicated that Texas sources were the largest contributor to visibility impacts at these wilderness areas, particularly at Caney Creek Wilderness in Arkansas. The

### FS requested that Texas analyze and fully disclose Texas impacts tothese Class I areas. The long term strategy and four factor analysis for reasonable progress should address these Class I areas at Caney Creek and Upper Buffalo.The commission agrees that the SIPrevision must show the full impact Texas has on each Class 

### I area it impacts as well asthe amount of reduction in that impact that modeling indicated the long-term strategy will produce by 2018. The commission has revised this SIP to show those full impacts and impact reductions for all Class 

### I areas affected by Texas' emissions. The commission agreesthat it 

### is necessary to identify specificareas of influence for each Class 

### I area impacted by Texas' emissions, includingArkansas and Missouri. Further, a four factor analysis is necessary for the set of sources in the respective areas of influence that impact each of the Class 

### I areas that Texas' emissions impact. Chapter 10 presents these areas of influence, the sources within these areas thatwere considered for additional control, and the results of the four factor analysis for each set of sources. (The fourfactor analysis considers the cost of reducing airpollution emissions, the time necessary for compliance, the energy and non-air quality environmental impacts of reducing emissions, and the remaining useful life of existing sources that contribute to visibility impairment.) Changeswere made to Chapter 10 Section 10.4 in response to this comment.


### One individual disagreed with TCEQ's approach ofnot adding more controls since

### 25 percent of regional haze emissions are due to international sources. The individual questioned if TCEQ had double counted emissions in Table 10-7 

### since boundary conditions and Mexico can have overlap. The individual questionedthe accuracy ofvisibility impairment from internatioilalsources.
The commission disagrees with these comments. The commission's decisions about the amount of control that is reasonable are independent of the impact of international transport. The boundary condition area andthe areas of Mexico that are inside the CENRAPemission inventory and modeling domain are distinct. The modeling procedures were set up to separatethe emission points into either the CENRAP modeling domain orthe domain for GEOS-Chem, which was used to model the boundary condition domain. The dividing line is the southern boundary of the CENRAP modeling domain, shown in Figure 8-2: 

### National Inter-Regional Planning Organizations Modeling Domain. The emission points in Mexico are in the CENRAPmodeling domain if they are north of the CENRAP domain boundary. The Mexican emissions south of the CENRAPdomain and the emissions from Central America are in the boundary conditions. The inventoried emissionsfrom Mexico are assigned to only one of these two areas. Chapter 

### 11discusses the uncertainty in assignment of regional haze atBig Bend to international transport, to Texas, and to the rest of the United States. The commission's decisions aboutthe amountof control that is reasonable in this Regional Haze SIPrevision is based on the four factor analysis, as the EPA's Regional Haze Rule specifies. (The four factor analysis considers the cost of reducing airpollution emissions, the time necessary for compliance, the energy and non-air quality environmental impacts of reducing emissions, and the remaining useful life of existing sources that contribute to visibility impairment.)



### One individual was concerned that what makes emissions reductions from programs like CAIR unlikely is that many sources want to purchase emission credits and do not want to add on air pollution controls to reduce regional haze. These actions undermine TCEQ's statement that existing program reductions are sufficient so nothing more needs to be done for the next five years.
Thecommission disagrees with these comments. The federal Regional Haze Rule requires that all reasonable reductions occur. Regarding CAIR orits eventual replacement, as a program that covers the entireEastern United States, reductions occurring in surrounding states will positively impact visibility in Class 

### I areas in Texas. TheTCEQhas used the four factor analysis, asrequired, forthe set of Texas sources impacting Class 

### I areas, to determine whether all reasonable reductims have been required. The four factor analysis considers the cost of reducing air pollution emissions, the time necessary for compliance, theenergy and non-air quality environmental impacts of reducing emissions, and the remaining useful life ofexisting sources that contribute to visibility impairment.



### TheNPS, FWS, and FS commented that in establishing the reasonable progress goals 

### (RPG), the TCEQ failed to establish a sufficientrelationship between the most attributable sources for visibility impacts and the affected Class I areas. The NPS and FWS found it difficult to ascertain what geographical sourceregion and which sources contained within that region TCEQ considered when establishing the total costs for visibility improvement at the two Class I area within Texas. The NPS and FWS commented that the TCEQ provided insufficient information
onthe four factor analysis to show that controls at specific sources on a cost per ton basis were unreasonable. The NPS and FWS requested that the TCEQ identify specific geographic regions, based upon area of influence studies, that encompass the most important visibility-affecting emission sources for Big Bend and the Guadalupe Mountains and focus its reasonable progress analyses for these two Class I 

### areas. The NPS and FWS asked that the TCEQ identify significant point sources in those areas of influence and conduct a thorough reasonable progress analysis with more specific four factor responses for that source region.

In response to these comments, the commission revised theRegional Haze plan with a summary of the area ofinfluence analysis for ten Class I areas, including eight outside the state. Impacts of emissionson those Class 

### Iareas are included. Texas has listed emissions from significantsources in a Class 1's area of influence. A list ofthese sources is included in an adopted version ofthe SIP.

Costs of controls for sourcesthat impact any ofthese ten Class I areaswere considered in the four factor analysis. A more detailed four factor analysis is summarized in Chapter 10. Thecommission's analysis indicates that additionalcontrols beyond those already existing
on the books arenot considered cost effectiveatthis time. This issue will be readdressed in future Regional Haze 

### SIPrevisions. ThefederalRegional Haze rule requires states to submit five-year progress reports that include an assessment ofwhether the current plan strategies aresufficient for the stateto meet the reasonable progress goals. If it is found that strategies are not sufficient, 

### 40 CFR 

## 5 51.308(h)(4) requires that a revision to the 

### SIP be submitted within one year, rather than waiting for the next 10-year comprehensive review. Changes were made in response to these comments.



### TheNPS, FWS, and FS commented that in large geographic states such 

### as Texas or Alaska, establishing these areas of influence are important for describingappropriate cost benefit arguments, since evaluations applied on a state-wide basis are often not relevant for any specific Class I area. The NPS, FWS, and FS asked that such areas be clearly identified by some geographic means, and to encompass sourcesthat have the most visibility impairing significance for a given Class I area. In the case of Texas, CENRAP has already generated area of influence information. The commenters suggested including geographic extent and significant source information.

The commission used the area of influence generated under CENRAP's direction to generate lists of major sources within the area of influence for ten Class 

### I areas, including eight areas in adjoining states. Cost ofcontrols for each ofthese Class 

### I areas is addressed and is now included in an update ofthe SIP. The commission made changes to Chapter 10 and Appendix 10-1in response to these comments.



### The NPS and FWS stated no narrative information was provided regarding cost benefit of controlling sources that may impair Class I areas outside Texas. The NPS and FWS asked that the TCEQ present information on how the controls were analyzed and provide tables specific to each Class I area. The NPS, FWS and FS asked that the TCEQ include analysis for all Class 1


### areas to which Texas contributes.This SIPrevision has been updated in Chapter 10and Appendix 10-1,Table 6-10 to present
a list of sources and potential controls for each Class 

### I area of influence, including eight outside Texas. Thecommission reviewed all the proposed controls on all sources provided by the CENRAP cost control study. Only the controls with costs per ton within the price range of strategies currently promulgated by the state were reviewed. These are $2,700 per ton (similar to levels for CAIR). These potential control strategies were further screened for potential effectiveness of the strategy by applying a cost over distance analysis for all units. Distance was defined asthe closest Class 

### I, regardless whether it was in- or out-ofstate. Additionally, the units without a proposed strategy in the CENRAP study were reviewed to determine if any source categories were represented that the TCEQbelieved a control strategy could be applied. For example, flue gas desulfurization for carbon black plants was added to the proposed list in this final step.


### The EPA,NPS, FWS, FS, and Sierra Club requested that the four factor analysis inAppendix 10-1, which is a required element inthe federal Regional Haze Rule Section 

### 51.308(d)(l)(i)(A), be included in the SIPnarrative. The EPA,NPS, FWS, and FS commented that in Section 10.2 ofthe proposed SIP stated that Appendix 10-1 provided an analysis ofthe four factors identified by statute as required for setting reasonable progress goals and concluded that based upon these factors the goals arereasonable. The NPS, FWS, and FS recommend information in that appendix should be summarized in the SIPnarrative and should clearly state the decision ofthe state on a Class I basis.

This SIPhas been revised with a more detailed four factor analysis 

### in Chapter 10. Costs for controls for sources that impact any of these ten Class 

### I areaswere considered in the four factor analysis. The control list originally in Appendix 10has been relocated to Chapter 10, not detached, to allow easier access by the public.



### The Sierra Clubrequested more evaluation of controls be located in the text of Chapter 10instead ofAppendix 10. The commenter does not have confidence 

### in the existing TCEQcontrol strategies to meet the long time framesto addressthe proposed SIPrevision.
In response to this comment, the commission has updated the SIPnarrative in Chapter 10 with more detail on the four factor analysis for controls. The list of specific list of controls, due to its length, remains in the appendix. In various parts of Texas, additional emission controls will be required due to the Dallas-Fort Worth and 

### Houston-Galveston-Brazoria SIPS,other early action plans, and various near nonattainment agreements. The commission expects these adopted control strategies as part of SIPSfor ozone nonattainment areas to also be pertinent for haze reduction as some of the precursor emissions areidentical. The recent EPA refinery consent decrees are also subject to sulfur dioxide reduction as part of the EPA negotiated agreements. Reductions in both nitrogen oxide and sulfur dioxide emissions areplanned. As a part of these ozone strategies and the Regional Haze SIP, periodic modeling and emissions inventories are required. The adequacy of Texas' control strategies and rules will be evaluated every five years as required by the federal Regional Haze Rule. TheRegional Haze rule requires states to submit five-year progress reports that include an assessment ofwhether the current plan strategies are sufficient for the state to meet the reasonable progress goals. If it is found that strategies arenot sufficient, 40 CFR 

## 5 51.308(h)(4) requires that a revision to the SIP be submitted within one year, rather than waiting for the next ten-year comprehensive review.Area of Influence (A011 

### TheNPS, FWS, FS, and one individual commented that the TCEQ has set a 20 

### percent cut offfor emission impacts, which is 

### an unacceptablyhigh 

### level ofimpact to allow. The commenters were concerned the data did not show Texas' visibility impacts on other states.

Thecommission did not use a 20 percent impact level in its analysis in this SIPrevision. However, in Appendix 10-1,the commission did include both Table 1: 

### Pollutant Impacts on Visibility at the ClassIAreas from Texas Emissions and Table 

### 3: Source Category Contributions to 5'04 

### andNO3

### at the Five Class I Areas Texas Affects the

### Most7which showed Texas7 impact on only the top five Class 

### I areasin terms of the percentage of impact that
came from Texas. This level was shown in the 

### SIP for sake of summarizingresults for the
areaswith the most impact from Texas. To prevent readers ofthe 

### SIP from getting the incorrect impression that Texas used a 20 percent cut off, the SIPrevision has been updated with a summary of impacts for ten Class 

### I areas, including eight outside the state. Impacts of emissions from Texas sources on those Class I areas areincluded. Significant sources within each Class 

### I area of influence (AOI) were identified, using an emissions over distance value (Qld) of

### 5to limit the list to those most likely to have a impact on a Class I area based on the magnitude of emissions and distance from the Class I area. The cost of potential controls on significantsources within an area of influence was analyzed. The commission revised Chapter 10

### in response to these comments.



### TheNPS, FWS, and FS requested that the TCEQ develop and adopt an area of influence approach to best define cost benefit information when concluding reasonable progress factors. Class

### I sites that shouldbe included are: Big Bend (NPS managed in Texas), Guadalupe Mountains (NPS managed in Texas),WichitaMountains (FWS managed in Oklahoma), Caney Creek (FS managed in Arkansas), Salt Creek (FWS managed in New Mexico), and White Mountains (FS managed in New Mexico). TheNPS and FWS suggested that the reasonable progress analyses are missing specific informationabout Texas' contributionsto visibility impairment at the Wichita Mountains in Oklahoma and other out-of-state Class I areas.
Thecommission revised Chapters 

### 4 and 10,and Appendices 

### 4-3 and 10-1in response to these comments asfollows. The area of influence analysis for ten Class I areaswere summarized. These areas include Big Bend, Breton Isle, Caney Creek, Carlsbad Caverns, Guadalupe Mountains, SaltCreek, Upper Buffalo, WhiteMountain, Wichita Mountains, andWheeler Peak. Thefirst two orders of magnitude (areas of influence) for each pollutant and each Class I area were identified. Then significant sourceswithin this circle
or area of influence were identified. The sourceswere screened using an emissionsover distance value (Qld) offive to limit the list to those sources most likelytohave a impact on visibility at a Class I area based on the magnitude of emissions and distance from the Class 

### I areas. Visibility impacts on those Class I areas areincluded.
Any source with identified potential add-on controls and its costs were included. These
were identified from the CENRAP-directed list, which was developed using EPA's program, AirControlNET. The visibility impact from these potential controls was evaluated and the 

### SIP is revised to reflect this analysis.



### The FS commented that if the averaged control costs in Chapter 10 

### are for the entire CENRAP region from Minnesotato Texas, this does not give an accurate description of costs sources would incur in Texas. The TCEQ should determine and use costs more representative ofthe southern tier of CENRAP states.

The commission7suse of theEPA's AirControlNET data to determine cost of controls for this SIP revision is consistent with other Texas SIPS. The commission typically relies on data supplied by EPA through resources such as AirControlNET. The commission takesinto consideration any known differences in cost. The commission added an estimated cost for the flue gas desulfurization proposed set of controls for Texas carbon black sources. These controls were not proposed in theAirControlNET data used by CENRAP. In regards to Texas specific controls, the commission did consider some source controls beyond the EPA's AirControlNET in the proposed SIPrevision. No changes were made to the SIP.



### TheNPS and FWS commented that the uncertainty of CAIR controls is clear in Texaswith regard topurchased emission credits and source unwillingness to make control commitments. TheNPS and FWS commented that this level of uncertainty can have a heavy influence on the ability ofthe state topredict or meet visibility goals into the future. The NPS and FWS commented that TCEQ should identify areas ofinfluence for each Class 

### 1 area and develop a Iist ofthe significant point sources within that area to form the primary basis tobetter evaluate the progress ofthose sources within the CAIR framework.

As part ofthe Regional Haze SIPdevelopment process, the commission considered control options beyond CAIR and 

### BART, which arediscussed in the four factor analysis summarized in Chapter 

### 10. The commission's analysis indicates that additional controls beyond those already implemented arenot considered cost effective atthis time. The commission will address theneed for addition requirements aspart of the five-year review process, which startsin 2013. Due to the uncertainty of the impact of CAJR or its eventual replacement, whether over predicting or under predicting emissions, the commission's approach atthis time is to track CAIR orits replacement over the five-year and ten-year intervals, and determine if additional controls areneeded. Theprogress of impacted
sources will be evaluated in future SIPrevisions and review of annualemissions inventories, required by Federal Clean Air Act (FCAA) and the state.

A~~endix 10-1: Analvsis of Control Strategies 

### The FS stated it is also entirely possible that the control costs were over estimated.

Thecommission agrees there arevariations and uncertainties associated with the control cost estimates that could result in lower estimates as well as higher ones. However, given the increase in costs of controls being installed in current systems, the commission considers higher costs aremore likely. TheUnited States Department of Energy stated in October 2007 that "the latest benchmarking study by theEUCG, formerly known astheElectric 

### . Utility Cost Group, examines the technology and cost of 49 fluegas desulfurization systems currently under design or construction by 12 of the United States' largest utilities. The base cost of a flue gasdesulfurization system was $243 per kilowatt hour. The survey found that flue gas desulfurization retrofit projects areincreasing rapidly, even during the phased construction of similar units within a single utility. Overall cost increases were attributed to the rising costs of alloy steels and materials handling systems. Construction labor and concrete costs contributed least to these increases."



### The EPA requested the TCEQprovide a detailed cost accounting for the numbers in Appendix 10-1 

### on Table 4: Summary ofAdditiona1Point Source Controls Considered for Reasonableness, 

### which summarizes the estimated annualized costs for sulfur dioxide and NOx 

### controls on 24


### sources.
A detailed summary of the costs listed in Appendix 10-1 on Table 4 arein Table 6: 

### Proposed SO2 Controls Based on CENRAP Modeling; Table 8: 

### Proposed SO2Control for CarbonBlack Units;and Table 9: 

### Proposed NOXControlsBased on CENRAPModeling. Changes were made in Appendix 10-1 Section 1.5 in response to the comment.The 

### FS suggested that when looking at cost effectiveness of controls for sources, additional consideration should be given to those sources within the area of influence ofmore than one Class 

### I area.


### The commission revised Appendix 10-1 with a summary ofthe area of influence analysis for ten Class 

### I areas. The analysis forvisibility impairment was based on each Class 

### I area and costs of potential controls within that Class 

### I area impact. Once a sourcewas identified with a potential control, the cost of the control to the site remained the same, regardless of thenumber of areas of influence in which the source is located. A fourfactor analysis of
source categories including cost effectiveness is included in Appendix 10-1.

The 

### FS commented that without analysis of sources in northeastern Texas and Class 

### I areas affected by these sources, Appendix 

### 10-1 is of limited value. Texas should show the four factor analysis by which it determined no further controls on cement kilns for

### NO, was reasonable.



### In July 2006, a report entitled

### Assessment ofNitrogen OxideEmissionsReduction Strategies fir CementIr'lns

# -Ellis County: FinalReport was submitted totheTCEQby ERG

(www.tceu.state.tx.us). This study evaluated the applicability, availability and cost effectiveness of potential nitrogen oxide controltechnologies for the ten cement kilns iocated atthree Ellis County sites. The report focused on selective catalytic reduction (SCR), selective non-catalytic reduction (SNCR), and low temperature oxidation (LoTOx). Based
on theresults ofthe study, the TCEQ conducted modeling sensitivity analyses attwo levels of control to evaluatepotential ozone reduction benefits from possible cement kiln control strategies. A reduction in nitrogen oxide aspart of the ozone control strategies has haze control co-benefits. One modeling sensitivity run assumed a range of 35to 50 percent nitrogen oxide control on cement kilns depending upon kiln type; the second assumed a range of 80 to 85

### percent. After reviewing the report ofthe kiln study, the modeling sensitivity results, and all other availableinformation, the commission determined that the 35to 50 percent control range was the most appropriate control level to address ozone in theDallas Fort Worth area.

The commission developed a source cap that will require a reduction of approximately 9.69 tpd ofnitrogen oxide emissions from the cement kilns in Ellis County starting March 2009. The source cap approach does not require a specific technology, but provides flexibility for kiln operators to comply in the most effective, technically sound, and expeditious manner possible, while forcing sizeable nitrogen oxide emission reductions from all cement kilns in the area. In most cases, the commission anticipates that the limitations will be attainable with selective non-catalytic reduction and will not require costly and time consuming research and development of othertechnologies. Pilot testing of selective non-catalytic reduction on wet and drykilns in 2006 demonstrated that 30 to 40 percent reductions were achievable without hazardous by-product formation. In response to comments, two sections
were revised: 1)Chapter 10Section 10.4.2 and 2) 

### Appendix 10-1 Section 10-1.3. The references were also updated to include the cement kiln report.

The

### FS commented that the TCEQprovided no source-by-source determinations to identify sources that individually may have had a relatively high visibility impact on a particular Class 

### I area(s). By eliminating consideration of additional point source controls for those Class I areas such 

### as Breton, Wichita Mountains, and White Mountain that are .not predicted to meet the uniform rate ofprogress, Texas does notjustify how it contributed to its proportion of controls necessary tohelp these states work toward the uniform rate of progress.


### Impacts of emissions on those Class 

### I areas areincluded in the SIPnarrative, Section 10.3. Texas has updated this SIPand lists significant sources in each of ten Class 1's area of influence, including those mentioned in the comment. Potential additional controls wereevaluated for significant sourcesthat may have an impact on a Class

### I area based on their emissions and distance to the Class 

### I area. A four factor analysiswas done for each source category. As part of the consultation process, this information was sentto other stateswith
an impacted Class 

### I area (see Appendix 10-1and Appendix 4-3).

The commission performed category level reviews as allowed by the federal Regional Haze Rule. The non-air environmental impacts were considered on a source category basis. Most of these impacts, because they would be detrimental to any consideration of implementing a control, did not dissuade the original conclusion that the proposed control cost did notjustify the limited benefit. The commission asserts the application of additional controls is unreasonable because the insufficient improvement of visibility of 0.05 deciview is achieved (see Tables 10-4 and 10-5). Based on the impact and cost of over $300 million, the commission concluded that additional controls beyond those already on the books are not cost effective at this time (see Table 10-4).



### The NPS and 

### FWSstated that although the narrative portion of Appendix 10-1

### presented 

### an argument to conclude that additional controls are not reasonable, supporting information on how the controls were tested is neither provided nor described. Tables 6-10 

### ofthe Appendix 10-1 

### appearto 

### include information that is not relevant to the narrative description. The 

### NPS and 

### FWS requested the tables include information on sourceslikely to impair visibility at Class I 

### areas other that Guadalupe Mountains and Big Bend and present cost estimates that are in the range of those quoted in the narrative.
Appendix 10-1, Tables 

### 6 through 10arethe detailed proposed controls for nitrogen oxide and sulfur dioxide sourcesthat were discussed in Section 10-1.4 Proposed Controls. The summary of controls in Table4 is a consolidation of those listed in Tables 

### 6 through 10. The tables include the costs associated with those controls for all Class 

### I areas impacted, not just Big Bend and Guadalupe Mountains. The commission evaluated allpotential controls regardless of the Class 

### I impacted, as required under theEPA haze regulations. In response to comments, Chapter 10 Section 10.4.2 and Appendix 10-1 Section 10-1.5 has been revised to clarify that visibility impairment for all Class 

### I areas was assessed. Appendix 10-2: Estimatin~ Visibility Impacts from Additional Point Source Controls 

### The 

### FS suggested Appendix 10-2: 

### Estimating Visibilig,Impacts.fi-om Additional Point Source Controls 

### should estimate impacts to the other Class I 

### areas listed, both in and out of state.

The commission revised the SIPwith a summary of the area of influence analysis for ten Class 

### I areas, including eight out-of-state sites. Emissions and impacts from emissions on those Class 

### I areas is included. Texas has listed emissions from significant sources in a Class 1's area of influence. 

### In response to this comment, two tables were expanded to include all 10 Class 

### I areasthat Texas impacts: Table 2: 

### Projected VisibilityBenefit from CENRAP Control Set and Table 5: 

### Modeled Visibility Benefit from the 

### Texas Control Set In addition, several paragraphs were added to explain Texas impacts atthese 10 sites.



### The 

### FS is uncertain if the additional point source controls were the same as 

### those in the Base G modeling for the future year 201

### 8c conducted by CENRAP.

The additional controls considered by the commission were beyond those listed in the CENRAP Base G modeling. They were developed with the assistance of the EPA's PCbased AirControlNet program and took into consideration the controls that were on the books or that would be in place by 2018. No changes were made tothe SIPrevision in response to this comment.Chapter 11: Long-Term Strategy The FS commented that it would be very informative and helpful if Texas would show the PSAT results for the 20 percent best days as well as the 20 percent worst days.

The commission agrees with this comment and has added graphs showing the PSAT results for the 20 percent best days for each Class I area analyzed in Chapter 11.

An individual commented that the CAIR reductions projected for NOx are only 28.5 percent and for SO2are 61.1 percent. The commenter was concerned that Texas needs much greater reductions than these to increase visibility and reduce ozone precursors.
Based on the four factor analysis, the commission has adopted all reasonable controls for the period to2018. Sulfur dioxide reductions of more than 60 percent in the first of fivetenyear planning periods aresubstantial. The reason the NOx control percentage is not as high is that NOx point sources have already been controlled in the last six years for ozone reduction purposes. (Thefour factor analysis considers the cost of reducing air pollution emissions, thetime necessary for compliance, the energy and non-air quality environmental impacts of reducing emissions, and the remaining useful life of existing sources that contributetovisibility impairment.) No changes were made in response to this comment.

One individual commented that TCEQ took credit for SO2 reductions that the federal government required.

Section 51.308(d)(3)(v) ofthe federal Regional Haze Rule requires each stateto include all federal or state rules and legally enforceable requirements in its 2018 projections of the visibility improvements. The commission works with the federal EPA to improve the air
across Texas. In the case of Big Bend and Guadalupe Mountains, SO2is a primary component of haze in western Texas. Approximately one-third of sulfate pollutants come from the Ohio Valley and other states according tothe BRAVO study.

One individual commented that the TCEQ says CAIR "is expected to reduce regional haze impact." The individual commented that Texas' CAIR makes no improvements for particulate matter, ozone, or regional haze, andthe TCEQreduced NOx emissions due to the ozone nonattainment in Texas, especially Houston, and not because reductions were made forregional haze.

The commission agrees that the HGB region NOx reductions were adopted to reduce ozone pollution. The commission notes that these reductions also reduce Texas' contribution to regional haze due to air chemistry and the formation of ozone and particulate matter. The commission disagreesthat CAIR makes no improvements for particulate matter, ozone, or regional haze. The projected CAIR reductions in NOx and SOzemissions are substantial. Because NOx and SOzreact in the atmosphere to form nitrate and sulfate, which are components of particulate matter and regional haze, theNOx and SO2reductions will lower concentrations of PM2.~ and regional haze. The further NOx reductions will produce lower
ozone concentrations.

Several individuals were disappointed in this SIPrevision that will not result in reasonable progress toward meeting the national goal of achieving natural visibility,in our national parks by 2064. The inadequacy of Texas' Regional Haze SIPmeans that Guadalupe Mountains would not reach natural visibility until 2081, and Big Bend would not achievenatural visibility until 2155. Moreover, national parks and/or wilderness areas in nearby states will be affected by lack of adequate air pollution control on Texas sources.
The commission disagrees with these comments. The commission notes that the federal Regional Haze Rule requirement to project dates for meeting the goal of natural conditionsis unreasonable for Class I areas like Big Bend and Guadalupe Mountains National Parks that areheavily impacted by international transport of regional haze. This is particularly
sogiven EPA's acknowledgement in therule's preamble that international transport has not been sufficiently addressed by their rule. Because the anthropogenicportion of the international transport cannot be expected to approach zero, it is not realistic to project a date for zero anthropogenic haze impacts atsuch Class 

### I areas. Since there aresubstantial international transport impacts at Texas' two Class 

### .Iareas and there is not a reliable basis forprojecting decreases in these impacts, Texas and other states would have to over control to compensate for the international impacts if the affected Class 

### I areaswere to have reasonable progress goals as low as theuniform rate of progress. TheEPA's preamble to the federal Regional Haze Rule and EPA guidance clearly statethat states arenot expected to orrequired to impose such over control. No changeswere made in response to this comment.


### The FS and one individual commented that the second paragraph of Chapter 11

### refuted the argument that Texas made later that assumed 100

### percent ofcoarse mass was natural. Although the FS agreed that the majority of coarse mass likely is natural, some portion of it is likely anthropogenic. Therefore, Texas should consider treating some percentage determined in consultationwith the FLMs and EPA as anthropogenic. The TCEQ must determinehow much of the coarse mass and fine soil "comes primarily form natural dust storms and dust blowing form the ChihuahuanDesert" since much ofthis dust may be due to historical overgrazing or farming and therefore is human caused. Ecosystem restoration and reform of grazing and farming practicesmay be needed to reduce this human caused dust.

Thecommission agrees that there is some anthropogenic contribution to coarse mass and fine soil atboth Big Bend and Guadalupe Mountains National Parks. In response to recent discussions with theFLMs, Chapter5 and Appendix 5-2 now compare the impact of an 

### 80 percent and 

### 100 percent natural approximation for coarse mass and fine soil. The commission is not currently aware of an adequate, workable methodology for developing a well-founded estimate of the proportion of coarse mass and fine soil that is anthropogenic at the two Texas Class 

### I areas. Thecommission has chosen to use theapproximation that 

### 100 percent of the coarse mass and fine soil arenatural forthis first Regional Haze SIPrevision. 

### TheAssessment ofthePrincipal CausesofDust-Resultant Haze atIMPROW Sites in the Western UnitedStates: FinalReport, prepared for WRAP in 

### 2006 by the Desert Research Institute and Marc Pitchford of theNational Oceanic and Atmospheric Administration includes a map that showsthe areas of the Chihuahuan Desert in West Texas to be moderately-to-highly wind erodible shrub land and grassland areas. Themap does not show erodible areas from human activity. The areas of the Chihuahuan Desert in northern Mexico arenot categorized and areoutside United States control.

Thecommission plans to consult with theFLMs and work to develop more refined

, scientifically supportable estimates of the actual percentages of natural and anthropogenic portions of coarse mass and fine soil atBig Bend and Guadalupe Mountains for the fiveyear assessment and futurerevisions.



### The FS requested the SIP 

### address the reason the time of compliancewas not considered and points to the need for a source by source analysis. No calculations are provided to justify the conclusion. The conceptthat instituting controlsnear the 201

### 8 

### date would reduce the cost effectivenessin cost per ton is not convincing. The cost per ton is determined at a fixed rate at a fixed time, independent of any year except that used in the determination.

The commission has revised the SIPwith a summary of a four factor analysis. A four factor analysis of source categories has been added to Chapter 

### 10. Thecost of controls and improvements to visibility impairment aresummarized for each Class 

### 1 area. The

### statement referencing timing of controls impacting the cost per ton has been removed from the 

### SIPAppendix 10.1, 

### Time for Compliance.

The NPS and FWS were concerned the SIPrevision proposal indicated that attribution from Texas emissions not only contribute to visibility impairment at Class 

### I areas outside the Texas boundary, but these Texas emissions were clearly contributing at levels greater than the host state, like at Salt Creek, White Mountain, Wichita Mountains, and Caney Creek. The NPS and FWS requested that Texas demonstrate progress towards visibility goals in these out-of-state Class I
areas (as part of the Texas plan's reasonable progress discussion), and also show more detailed consulting and planning with these neighboring states. Oklahoma, New Mexico, and Arkansas received even larger percent of total attribution to visibility impairment at their Class I areas from Texas sourcesthan Texas' Class 

### I areas receive from international sources. Texas should provide additional documentation on efforts to not only discuss impacts, but ways that the states planned to work together to make progress in Class I areas where Texas is the majority contributor. Because the stateis not only a contributor, but the majority contributor, additional efforts should be shown to demonstrate multi-state controls. This should be further extended to demonstrate consistent control levels.



### The commission acknowledges thatemissions from Texas doproduce a significantminority ofthe visibility impairment at Salt Creek, White Mountain, Wichita Mountains, and Caney CreekWilderness areas. 

### In the 2002 

### base period year, the respective percentages of extinction contributed by Texas on the 20 

### percent worst days for these four areas are included in the following table:

Thehighest Texas contribution to extinction atone of these sites is 28.1 

### percent. The commission disagrees with the commentthat Texas contributes a majority of the 20 

### percent worst days extinction to any Class 

### I area in another state. Texas agreesthat the PSAT modeling results show that Texas contributes more than the host stateto extinction on the 20

### percent worst days atWhite Mountain, Wichita Mountains, and Caney Creek. 2002 

### Contributions to Extinction on the 20 

### Percent Worst Days

Thecommission agreeswith displaying the details of Texas' impact reductions at these Class 

### I areas and other Class 

### I areas impacted by Texas' emissions. Thetables showing Texas' pollutant-by-pollutant impacts on extinction for both the2002 

### base period and the 2018 

### planning year arenow included in the consultation section of Chapter 11. 

### These tables show the modeled impact of multi-state efforts to reduce visibility impairment atthese sites. Thecommission disagrees with the suggestion to place this information in Chapter 11 

### on reasonable progress chapter. The Regional Haze rule requires Texas to develop RPGs for Class 

### I areas in Texas.

Texas' Host State's

The EPA, NPS, FWS, 

### FS, and one individual commented that just because Texas has not received a formal invitation for consultation from Colorado, Louisiana or'NewMexico does not mean that these states accept Texas' long term strategy as adequate for producing Texas' share of emissionsreductions to help meet reasonable progress goals at each state's respective Class I area(s). New Mexico has not completed their reasonable progress goal analysis and is further behind in the process. This lack of consultation should be noted in the SIP, and Texas should display itspresent and projected impacts to those state's Class 

### I areas. The commenters would like better documentation in the SP to explain the pertinent issues discussed and agreements reached through consultation activities to address all Class 

### I areas where Texas' emissions are important contributors to visibility impairment. 

### Salt Creek 25.5% 28.3% 

### Wichita Mountains 28.1% 14.7% 

### White Mountain 22.5% 17.7% 

### Caney Creek 11.1% 10.1%

### As the commenters acknowledge, each state may not have completed its reasonable progress goals. Theconsultation process in the federal Regional Haze rule is not proscriptive precisely because of the differences in each state's SIP development and regulatory programs. The proposed SIPrevision indicated the state of consultations at the time itwas published. The commission concurs that the adopted SIP revision include documentation that it meets the requirements of §51.308(d)(3)(i) 

### - (iii). Thecommission has sent individual letters to Louisiana, Arkansas, Missouri, Oklahoma, Colorado, and New Mexico to askeach to confirm in writing that Texas' emissions reductions strategy is adequateto meet Texas' apportioned reductions in impact at the impacted Class 

### I areas. Thecommission also requested that recipients of the lettersconfirm they arenot expecting any additional emission reductions from Texas sources. Formal replies were requested of the adjoining stateswithin 30 days for inclusion in this SIP revision. The states that responded have documented letters in Appendix 4-3.



### The NPS and FWS agreed that Mexican emissionscontained within the boundaries of the CENRAP modeling domain are important contributorsto visibility impairment at Big Bend and Guadalupe Mountains. TheNPS and FWS requested that Texas acknowledge the work contained in the final Big Bend Regional Aerosol and Visibility Observational (BRAVO) study. This extensiveBRAVO study indicated sourcesin Mexico, Texas, and the eastern United Statesall play a role in sulfate conditions at Big Bend. TheNPS and FWS look forward to working with Texas to solicit EPA action with its sister agencies to address the Mexican portion of sulfate impairment at Big Bend. The NPS and FWS alsorequested that the SIP discussthe Texas contributionto sulfate found in the BRAVO field study in the long term strategy and reasonable progress sections.

Thecommission agreeswith this comment that the BRAVO results and their relationship to the CENRAPPSAT results warrant more discussion. The added discussion 

### is included in Chapter 

### 11.

The EPA is concerned about the potential ofthe American Smelting and RefiningCompany (ASARCO)El Paso to affect visibility in Texas and New Mexico Class 

### I areas. On February 13, 2008, the commission approved the renewal ofAir Quality PermitNo. 20345 for ASARCO Incorporated. The EPA statedthat with the Regional Haze SIP revision, the commission should
ensurethat ASARCO's impact assessmentwill be included in Texas' BART, reasonable progress goals, and long term strategy.

On February 13,2008, the TCEQ approved the renewal of Air Quality Permit Number 20345 for the American Smelting and Refining Company (ASARCO) El Paso copper smelter. On February 6,2009, the TCEQ received confirmation from ASARCO LLC that it intends to close the smelter and requests that TCEQvoid all air permits and pending applications for the plant. The TCEQvoided these permits and applications on February 9, 2009 (SeeAppendix 11-4: 

### ASARCOEl 

### Paso). TheTCEQwill continue to consult with affected states and Federal Land Managers on surrounding Class 

### I areas of concern.

### TheNPS and FWS commented on the uncertainty of CAIR implementation. The NPS and FWS requested that tlie co~nmission be more proactive in response tothe uncertainty associated with implementation of CAR. Although Texas identifies clear conflicts with emission inventories developed by CENRAP, with the Integrated Planning Model predictions of large electric generating unit growth results, and with the unwilling~iess ofparticipating CANsources to commit to particular emissio~l evels, it is concerning that Texas has elected to wait and see how the uncertainty unfolds as part ofthe required five-year review. The federal Regional Haze Rule mandates that each state develop a plan to make progress toward visibility impairment at Class 

### 1
areas. Although the commission concludes that the already planned controls between now and 

### 2018 are reasonable, it fails to address how multiple issues that prevent Texas from accurately determining future e~nissions to address Texas' substantial contribution to visibility improvement at Class

### I areas inside and outside of its territory. TheNPS and FWS requested that Texas develop areas of influence and associated major source lists within these zones as a precursor to a focused five-year review. The NPS and 

### FWS requested Texas establish in the SIP a process for ongoing discussions and consultations with neighboring states and FLMs on the progress of CAR.

The commission recognizes that the electric generating units arecontributors to visibility forthe Class 

### I areas and that these electric generating units arecovered by the provisions of CAIR aswell as other state requirements. There are uncertainties associated with prediction because of the cap and tradeprovisions of the program. Thepredicted levels used in the model were from the EPA's Integrated Planning Model, a tool widely used in regional planning. Thepredictions are based on assumptions applicable atthe time the model is constructed, including fuel prices, fuel availability, and regulatory policies. The commission acknowledgesthe uncertainty in the emissions projections. The commission is not aware of a better emissio~~s prediction tool for electric generating units and believes the predictions provide a valid planning tool. The difference in inventories between CENRAP's and the TCEQ's was in industrial and residential boilers, not in electrical generating units addressed by CAIR orits replacement.

In response to comments, Texas has developed a list of significant industrial sources, including the electric generating units, based on the area of influence analysis developed by 

### CENRAP for each Class

### I area, which progress can be evaluated duringthe 

### CAIR time frameorequivalent time. The list of sources can be found in Appendix 10-1,Tables

### 6 to 10, and the area of influence maps arein Appendix 4-3. The commission will continue to consult with FLMs and states through tlie 

### SIP consultation process on the implementation of CAIR.

The NPS, FWS, FS, and one individual commented that the TCEQ needed to elaborate on how theNew Source Review (NSR) and Preveiition of Significant Deterioration (PSD) permitting programs will be used by TCEQ as 

### part of its long term strategy for meeting reaso~iable progress goals. One individual commented that the Environmental Defense and the Sierra Club have requested that until these deficiencies in the PSD permitting program are resolved that 

### EPA should prohibit construction of new sources in Texas and/or impose sanctions. As pat? of these written comments, the individual attached a copy of the Environ~nental Defense and SierraClub petition that docutnents the inadequacy of the TCEQ's PSD permitting program. TheNPS and FWS requested Texas establish in the SIP a process for ongoing discussions and consultations with neighboring states and FLMs on the progress of PSD/NSR efforts.Thecommission has a SIP-approved, PSD permitting program. The commission is committed to working with the FLMs to attempt to develop mutually acceptable procedures that allow adequateopportunity for FLM review of permit applications. In the five-year and ten-year reviews for the Regional Haze SIP revision, the commission plans to consider the cumulative impact of PSD permitting actions on the projected visibility impairment at the Class 

### I areas that Texas' emissions affect. The commission will continue to consult with FLMs and states through the Regional Haze consultation process on the implementation of PSD/NSR permitting. Changeswere made in Chapter 

### 11,Section 11.6.3 in response to comments.



### TheFS commented that Texas has been providing notification to the FLMs only for major-source actions within I00 

### km of Class 

### I areas. In a letter dated August 21, 2007, the FS requested that Texas reconsider that policy and work with the FLMs to come up with a mutually acceptable policy of notification to theFLMs and surrounding states regarding NSR. Including resolution of this issue in the SIP would greatly strengthen the position that clean days are being maintained.

Thecommission has commented on EPA rulemaking aboutPSD review that nationally uniform guidance is needed for review of particulate matter impacts. Also, the Executive Director in a letter to his counterpart in the Oklahoma Department of Environmental Quality has committed "to working with theFLMs on mutually acceptable criteria for determining when a proposed PSD source should conduct a Class 

### I review" (see Appendix 4-3).

Fire 

# - TheNPS, FWS, and FS recommend that TCEQ reference fire and smoke plans in a way that does not require a SIP revision each time a fire or smoke plan is updated. The FS is concerned that linking the smoke management plans to the SIP will reduce the FS's ability to maintain flexibility in updating smoke management provisions and suggested these documents not be included in the SIP or its appendixes. The FS inquired if agricultural burning occurs in Texas and if it is regulated.
According to discussion with EPARegion 6, the EPA prefers inclusion of the smoke management plans in the appendix. The smoke management plans contained in the Regional Haze SIPrevision arefor reference purposes. The commission considers the FS's flexibilityto update the smoke management plans unhindered by inclusion in theTexas SIP. Agricultural burning does occur in Texas. Local and state ordinances regulate burning through fire permits. Texashas rules regulating outdoor burning in 

### 30 Texas Administrative Code (TAC) 

### 5111, Subchapter B: Outdoor Burning. These rules cover a wide variety of burning, including prescribed burning. The TexasForest Service tracks burning in Texas.



### TheNPS and FWS commented that it is appropriate for the TCEQ to declare smoke plans as a contributingprogram for visibility protection,but neither the state or CENRAP evaluated performance resulting from this or any specific smoke management component. Ifthe state wants to speakto not making a change to the smoke management plan, it should simply state that it is unreasonable to make modifications due to the low smoke apportionment or low priority of pollutant selection.

Thecommission agrees with this comment. The commission has revised the Chapter 11 discussion of smoke management plans to state that it is unreasonable to make modifications to the smoke management plans dueto the low smoke contribution from Texas to regional haze atthe Class 

### I areas that Texas' emissions impact.The NPS and FWS requested Texas indicate whether it intends to certify its Smoke Management System as provided for by the 

### 1998EPA Interim

### Air QualivPolicy on Wildland and Prescribed 

### Fire.

The commission does not intend to certieits smoke management system.

The NPS and FWS commented that the proposed SIP and the smoke management plans described in its Chapter 11 should identify appropriate nearby Class 

### I areas (both the two within Texas as well 

### as those located in neighboring states) as smoke sensitive areas. The commenters suggested that prescribed burners should be required to apply the appropriate smoke management techniques to minimize smoke impacts.



### Such an additional designation of Class 

### I areas as smoke sensitive areas is not required under the federalRegional Haze Rule oris a necessary part ofthis SIPrevision because of theminimal impact of smoke from fires on regional haze in Texas. State rules under 30 TAC 

### §Ill,Subchapter B: Outdoor Burning, already require all prescribed burning in Texas to apply appropriate smoke management techniques to minimize smoke impacts.

The NPS and FWS commented that the proposed SIP stated that wildfire emissions are assumed toremain the samelooking forward over the ten-year planning period. However, the 

### SIP should identify if prescribed burning emissions are proposed to decline, stay the same, or increase.



### The commission does not determine how much prescribed burning occurs. The commission's role is to regulate prescribed burning to minimize smoke impacts. The manager orowner of land determines whether to conduct prescribed burning. Concerning the estimate of change in impact, the general increase in use ofwell controlled prescribed burning to prevent catastrophic wildfire may increase low concentration impacts and reduce high impact events. Thecommission does not have sufficient information to produce
a more refined estimate than the no-change estimate used in the modeling to project conditions in 

### 2018.

One individual suggested that Chapter 1 1 should also list a smokemanagement plan for the national forests and grasslands in Texas (Davy Crockett, Sam Houston, Sabine, Angelina National Forests and Caddo and 

### LBJ National Grasslands). The individual commented that more prescribed burning was being conducted than in the past due to increased emphasis on improving woodpecker habitat.



### Thecommission agrees that there areadditional smoke management plans besides those listed asexamples in Chapter 11. 

### The plans referenced in the SIPincludeClass 

### I areasin Texas and a number of largerjurisdictions. Thecommission does not consider an exhaustive listing of specific plans necessary as part of the Regional Haze SIPrevision given the minimal impact fires areexpected to have on visibility.

One individual noted that the modeling indicated that primary organic carbon at Big Bend comes overwhelmingly from boundary conditions, which included the areas ofthe Yucatan and Central America with extensive agricultural burning and sometimes wildfire emissions each April and May. The individual wondered if TCEQ has correlated the actual burning and other sources with carbon concentrations and ifthe TCEQ knows where the problems exist. Since CENRAP modeling did not differentiate between boundaries, the commenter suggested that the TCEQ acknowledge that someofthe airpollution coming from boundary conditions may be due to Texas' and other states' emissions that are re-circulated.



### For a decade, the commission has been watching satellite images of smoke from the spring agricultural burning and wild fires in Southern Mexico and Central America as windstransport it to Texas. The satellite fire channel data clearly show the locations of the fires. This is the only major source the TCEQhas observed for smoke being transported into Texas from areas outside the United States and affecting Class 

### I areas in Texas and other states. Occasionally, smoke from marsh grass orcrop stubblefires along the Texas and Louisiana coastal areas moves directly to impact nearby areas. Sometimes the trajectory takes the smokea relatively short distance over the Gulf of Mexico. Marsh grass orcrop stubblefires arenot a significant source of smoke affecting Class 

### I areas in Texas. While transport of continental haze from the United States can occasionally reach the boundary conditions domain, under such circumstances the air masses areusually associated with rapidly moving cool orcold fronts and aremoving too quickly to accumulatemuch haze. Although re-circulation occurs, the commission notes it is a minor issue. No change was made in response to this comment.
Chapter 12: Plan Revisions 

### The FS requested that Chapter 12 should specificallymention that the SIP review and revision will involve consultationwith the FLMs.

The suggested change was made to the SIP. The commission looks forward to a continued and collaborative consultation process with the FLMs regarding haze reduction.

General Comments 

### Several individuals commented that although half of the air pollution sources at Big Bend and Guadalupe Mountains are from other states and countries, Texans want to clean up the part that comes from Texas. Many individualscommented that no new air pollution control strategies
were added to this SIPrevision and requested controlsbe added specificallyto reduce regional haze.

The commission notes that the Texas BART rule, adopted in January 2007, was a TCEQ rule specifically adopted for the Regional Haze SIPrevision (see 30 TAC $116, Subchapter 

### M orAppendix 9-2). The commission agrees that Chapter 11does cite rules and programs that have been in place that have reduced regional haze as well asother pollution impacts. The commission was reducing Texas' impact on visibility impairment long before issuance of the federal Regional Haze Rule. These long-standing rules and programs continue tobe effective. The commission notes that the national goal established by Congress and the EPA is to achieve natural visibility conditions in the Class 

### I areas by 2064, with a requirement for five ten-year planning periods that end in 2018,2028,2038,2048, and 2058. Further, EPA guidance recognizes that statesthat have adopted CAIR requirements may already have sufficient reduction requirements on the books for thefirst ten-year planning period, which is to 2018. Based on the four factor analysis for each Class 

### I area Texas impacts, Texas has adopted all reasonable controls for this first planning period. The four factor analysis considers the cost of reducing airpollution emissions, thetime necessary for compliance, the energy and non-air quality environmental impacts of reducing emissions, and the remaining useful life of existing sources that contribute to visibility impairment.



### One individualcommented that additional progresson cleaning up Texas' dirty air is possible if legislatorsfrom Texas use their clout in Congress to force Mexico to comply with its obligations to control emissions from coal-fired plants in Mexico.

Thecommission considers that the request (see Chapter 11) for federal efforts to reduce international transport is the appropriate action for the TCEQ.



### The EPA, NPS, FWS, 

### and FS requested the TCEQ combine the three sections of Texas, used for CENRAP modeling purposes, be added together to show the state's contribution as 

### a whole and

### providing a better comparison with other states. The commenters requested this be done throughout the document.

The commission has added tables showing Texas' total extinction contribution to each Class 

### I area where Texas impacts visibility in other states. Several chapters and tables have been amended. Chapter 7 discusses the emissionsinventory from Texas for each category. Only the figures break out the emissions by the three geographic areas in the tables in this section. Refer to Table 7-2: 

### Summary of2002 Annual Emissionsfor the Nine-State CElMlAPRegion and Table 7-5: 

### Nine-State CENRAP TotalEmissionsby Category for a state level comparison of the emissions. For a discussion on impacts, the reader is referred to Chapter 10. Impacts from emissionson the Class 

### Iareas are discussed in Chapter 10

### and
arediscussed from the state as a whole, not by geographical region.



### One individual commented that this Regional Haze SIPrevision should be withdrawn and revised to incorporatereductions in regional haze emissionsover the next five years. If this isnot done, the EPA should startthe sanctionsclock and in 18

### months EPA should apply highway sanctions and require 2:1 

### offsets for regional haze emissions until an acceptable SLPis approved.

The commission disagrees with these comments. The commission is submitting a Regional Haze SIPrevision that meets the requirements of 40 

### CFR 551.308.



### One individual commented that with the uncertainty that themodeling provides it seems prudent that Texas make reductionsnow so that there will not be delayed regional haze attainment. There is no doubtthat reductionsmust be made since on page 10-6,TCEQ impliesthat at least 

### 48 percent for Big Bend and 75to 80 percent for Guadalupe Mountains of thevisibility impairment
comesfrom Texas or other states, not foreign sources.
The commission disagrees with the commenter's interpretation of Table 10-7

### in Chapter 

### 10 and associated text and the commenter's solution. Haze reduction is a national issuewith a long-term goal of natural visibility conditions. At this time, the commission is working on the impact that Texas has on haze in Texas and otherknown states. TheEPA and other federal agencies areworking with other states and international governments to reduce haze causing pollutants. The commission acknowledges that the public can improve visibility in Class 

### I areas by an individual commitment to pollution reduction and appreciates groups that actively encourage the public to reduce the human contribution.



### The Sierra Club commented that the commissionwas missing an opportunity to demonstrate a commitment to air quality cleanup in one of the most culturally, historically, and naturally importantparts of our state. The failure to clearthe air in Big Bend and Guadalupe Mountains translates into continued regional haze problems for state-owned lands such asBig Bend Ranch State Park, Davis Mountains State Park, and other such areas, which increasingly are ofinterest for outdoorrecreation for Texas urban populations. The SierraClub saw no real commitmenton the part ofthe commissionto addressthe deficienciesin the proposal.

This SIPrevision addresses significant controls and programs that Texas and 

### EPA are undertaking that will reduce haze in Big Bend and Guadalupe Mountains as we1l.a~ neighboring state public lands. As 

### EPA anticipated when it developed the Regional Haze and BART rules, natural visibility conditions will take many years to achieve in any Class 

### I
area. The reduction of haze will require all states to reduce pollutants. Future revisions and possible additional controls areanticipated. 

### The FS appreciated that Texas documented coordination with the FLMs and abandoned one approachbased on FLM recommendations. The FS 

### looks forwardto continued consultation in the future.Thecommission appreciates the comment and looks forward to a continued and collaborative relationship with the FLMs in the future.

. 

### TheNPS and FWS appreciated the discussion of relative response factors and the two methods of applying relative response factorscreated by the CENRAP organization. The commenters welcomed the summary of these concepts in the main body of the SIP. It is very important to inform the non-technical reader how these complex models are applied 

### in a relative sense.

The commission appreciates the comment and looks forward to a continued and collaborative relationship with the

### NPS and 

### FWS in the future.



### The FS commented that while Big Bend and GuadalupeMountains, Class I areas within Texas,
are identified in Chapter 1, other Class I areas identified elsewhere in the SIP as being impacted by Texas sources were not identified in this chapter. The commenter suggested including a summary ofthose other impacted Class I areastoprovide balance to Chapter I. Chapter 1 is devoted to background information and an overview of regional haze and describes those Class

### I areaswithin Texas that areimpacted. The commission addressed Class 

### I areas located in other states within Chapters

### 4,10, and 11. The commission made
no changes to this SIPrevision.



### TheNPS and FWS commented that the Executive Summary says, "This SIPrevision contains a list of BART-eligible sources and the determination of BART for each sourcethat is reasonably anticipated to contribute to visibility impairment (BART-subject)." TheNPS and FWS find this statement misleading, since the narrative stated that there were no sources subject to BART in Texas, and therefore no BART determinations were provided.

The BART process is fully explained in Chapter 

### 9 oftbe SIP. According to EPA Region 

### 6 training and flow charts, Texas understands the BART rule to be at least a three tiered process. Texas went through at least 

### 2 tiers of the process. The first step of BART is determining eligibility; all BART-eligible sources arelisted in Chapter 

### 9 and Appendix 

### 9-13. 

### In addition, there is a list of sources that reduced their potential to emit through permit amendments, orshut down units in order to avoid being subject to BART controls. At this time, all BART-eligible sources have modeled emissions impacts to be below the BART determination threshold in some extent dueto past emission reductions required by statelaw not anticipated when the federal BART rule was developed.



### The FS commented that within the Executive Summary, the TCEQ should quantitatively summarize its reasonable progress goals and associated rationale for each Class I 

### area addressed in the SIPrevision.

The commission added summaries of reasonable progress goals and associated rationale for each Class 

### I area in Chapter 

### 10. In response to this comment, no changeswere made in the Executive Summary. However, more information was added to Chapter 

### 10.

The Sierra Club expressed disappointment that several generations of Texans will not be ableto experience clear skies on a regular basis at these exceptional natural heritage parks. One individual commented that he hikes in Big Bend and Guadalupe Mountains and requested the commission take action to reduce haze forthose who come after us. One individual commented that Big Bend has the honor ofbeing a Biosphere Reserve under the United Nations Educational, Scientific and Cultural Organization (UNESCO) Man and Biospl~ere Program accentuatingthe need for the com~nission to do all it can to reduce haze at this special global site.This SIP revision addresses significant controls and programs that Texas and the EPA are undertaking that will reduce haze in Big Bend and Guadalupe Mountains as well as neighboring states' public lands. As the EPA anticipated when it developed the Regional Haze and BART rules, natural visibility conditions will take many years to accomplish in any Class 

### I area. This goal will ultimately be achieved through the efforts spelled out in this revision, as well as future revisions that may include additional controls and programs not yet created. The commission acknowledges that Big Bend National Park has been designated an international Biosphere Reserve. The commission made no changes in response to these comments.



### TheNPS and FWS commented that the Executive Summary stated that "TCEQ used a refined estimate of natural conditions for Class 

### I areas in Texas and other states 

### as permitted by EPA." However, there is no evidence in the SIPthat any other stateshave adopted Texas' alternative natural conditions calculation approach. The commenters requested that this SIPrevision specifically agree with the natural conditions adopted by Texas' neighboring states for said states' Class 

### I areas.
The commission has no substantive disagreement with the natural conditions estimates used by anyother state atthis time. Texas fully respects the right of all states to determine the natural conditions fortheir respective Class 

### Iareas. The phrase "and other states" has been removed from the referenced sentence in response to this comment.



### TheNPS and FWS pointed out that the Cooperative Institute for Research in the Atmosphere, or CIRA (www.cira.colostate.edu) 

### may have updated the baseline calculations found on the Visibility Information Exchange Web System (VIEWS) since the time ofTexas' SIPproposal.

On January2,2008, the latest data was downloaded from the 

### VIEWS Web site. The results have not changed for Big Bend or Guadalupe Mountains. The commission made no changes in response to this comment.



### One individual commented he was excluded from the consultation and stakeholder process since he submitted comments on BART and spoke with staff but was not contacted about regional haze.

The commission issued public announcements on the BART and SIP list sewer,published numerous announcements in newspapers across the state, and regularly updated the commission's regional haze Web site to reflect upcoming meetings and hearings open to the public. The commission does not automatically place an individual on its list sewerwithout their permission, but encourages the commenter to sign up with all the e-mail updates on 

### SIPhot topics; over 30 topics are now available through the new GovDelivery sewice as of Fall 2007 (www.tceq.state.tx.us).



### TheEPA commented that the TCEQ should ensurethat it has specifically addressed each requirement of Section 5 1.308. 

### The EPA requested the checklist EPA developed be used.

The commission has completed the EPA checklist that was provided to states giving references to specific chapters and appendices where each applicable requirements of Section 51.308 areaddressed in the SIP revision. The commission will submit the checklist to the EPA with the adopted SIP package.



### TheEPA requested that the TCEQ make sure all graphs and charts originally produced with color-coded lines and bars be reproduced in color, as black and white reproduction does not allow the identification of the individual items. This should be ensured in both printed and electronic versions of the SIP, including all appendices.The commission acknowledges that, where appropriate, graphs and charts produced in color should be reproduced in color. The print copies and files available electronically will be issued as originally produced.

The EPA was not ableto conduct athorough review because of time, resource constraints, and because the TCEQ did not submit a paper copy of the SIP. The Sierra Club found it difficult to justify any significant expenditure oftime or resources to do a thorough critique ofthe proposed Regional Haze SIPrevisions because the commissiondid not address the deficiencies in the proposal.

This SIPrevision had a longer comment period than most as the 60 days for the FLMs was added to the 30-day public comment period, which made the comment period 90 days. As with other SIP revisions, Texas has provided EPA the ability to access and print revisions from the agency website. Thecommission was not made aware of the EPA's need for paper versions prior to theclose of this commentperiod. Upon submission for review and approval,the EPA will receive paper copies of this SIPrevision. Thecommission understands the time and resource constraints of both groups as the commission and its staff have similar limitations, however, no change was made in response to this comment.

As required by Section 51.308(d)(4)(v),the EPA requested the commission include in the Regional Haze SIPrevision a commitmentto update the emissions inventory ofpollutants that are reasonably anticipatedto cause or contributeto visibility impairment in its Class I areas periodically.

The commission remains committed to updating its emissions inventory. This commitment
was included in Appendix 7-1, Section 7-5. "The Texas Commission on Environmental Quality (TCEQ), in compliance with the Clean Air Act Amendments and operating under the authority of the Texas Clean Air Act, Texas Healtb and Safety Code $382.014, and 30 TAC $101.10, conducts annual inventories of airemissions from point sources and periodic inventories of emissions from area, non-road mobile, and on-road mobile sources. The periodic inventory is updated statewide for all sectors every three years and submitted to EPA per tbe requirements of the Consolidated Emissions Reporting Rule, 40 CFR 51. The most recent, available inventory is for 2005 and is summarized in Table 7-4: Non-EGU Point Source Controls. Tbe inventory will next be updated for 2008."

The EPA Region 6 has submitted general commentson the Texas BART analysis with the intention of addressing the more significant issues that could be identified considering the review time available. The EPA was involved in review of much ofthe CAMx modeling done for screening out sources, but dueto time and resource constraints, the EPA has not been possibleto conduct a completelythorough review, particularly with regard to modeling. It is possible that additional concerns, not discovered during the review ofthis draft, will surface during the review ofthe final version ofthis SIP revision.

The commission notes that the comment period was three times longer than usual. In addition to the standard 30-day public comment period, the FLMs were given 60 more days
as required by the haze rule. Therefore, the comment period was 90 days. The commission understands time and resource contraints by government environmentalagencies. Tbe commission notes that EPA will have additional review after submittal.

The NPS and FWS noted that appendices were available upon request. Since significant portions ofthe rationale for the commission's proposed Regional Haze SIP revision are contained within the appendices, these should be posted for public examination along with the SIP narrative document.Thecommission considers the SIPrevision published for comment was complete and appropriatefor public review and comment. As stated by the commenters, appendices were available upon request if needed. The appendices are currently available on the agency Web site.



### The FS asked Texas to explain what is meant by the terms, Elevated Point and Low Level Point in the modeling inventory.

Pollutant emissions are treated in two basic ways within CAMx: low-level (gridded) emissions that arereleased into the lowest (surface) layer of the model; and elevated stackspecific (point) emissions with buoyant plume rise that can be emitted into any model layer. As shown in Table 8-2: 

### MM5 34 Vertical

### Layer Definitions of the SIP, the surface layer is 36 meters and lower. Theelevated layers are 

### 36 meters and above. No changes were made in response to this comment.



### The Sierra Club commented that it is disappointed that natural visibility was not a high priority issue to the commission. Many ofthe same sources ofpollution that affect the skies ofthe national parks in West Texas affect the air in cities elsewherein the state. Aggressive cleanup of these sources will certainly benefit both, and the failure to takeprotective actions to clean up air quality from these sources will harm both.

Thecommission is currently working to maintain health-effect standards as demonstrated by the state's current attainment for PMfine standards. Currentnitrogen oxide and sulfur reductions obtained by programs such SenateBill 7 benefit both the health-effect standards andvisibility across the state. Any additional controls implemented for purposes of visibility only arenot considered cost effective atthis time.



### The Sierra Club, City League for Environmental Action Now (CLEAN) Houston, and over 300 

### individuals commented that the SIPis inadequate and want the commission to add control strategies. The Sierra Club acknowledged that significant air pollution affecting parks are coming from sources outside of Texas; however, the commission can do more to control those sourcesin Texas that are contributing to the problem. CLEAN agreed with the SierraClub that the commission shouldreduce emissions from coal-fired power plants, which would make improvements in visibility within as little as five years; the commission should revise this SIP. One indjvidual commented that the SIP revision explained several important reasons why controls were delayed but requested the commission do some controls. Another individual suggested that the commission was not making reasonable progress because it delays action for fiveyears; five years is not reasonable.

Thecommission is not delaying improvements in visibility impairment. Current control strategies are anticipated to decrease sulfur dioxide emissions by over 225,000 tpy and nitrogen oxides emissions by over 670,000 tpy by 2018. Chapter 10has been updated with a
moredetailed discussion of the four factor analysis, including an updated cost-effectiveness analysis.

In addition to Senate Bill 7 that the Texas Legislature implemented in 1997, emissions from coal-fired power plants arebeing controlled by the provisions of CAIR, which is to be implemented by 2015, with the first phase by 2009. Emissions reported from electric utilities have been decreasing annually with a decrease of over 80,000 tpy of nitrogen oxides and 27,000 tpy of sulfur dioxide between 2002 and 2005.
Significantcost-effective control strategies are already being implemented in Texas to control ozone. These strategies have been included in Texas' ozone SIPmodeling. In addition to controlling ozone formation, the planned emissions reductions will also have aco-benefit of improvingvisibility impairment in Class I areasin Texas and nearby states by the reduction of sulfur dioxide and nitrogen oxides.

Because of the timing ofvarious rule adoptions, not all of the following rules listed arein CENRAP's 2018 model. Those strategies included in CENRAP modeling areidentified with an asterisk. Due to more recent adoption dates, other control strategies listed are not modeled by CENRAP but are expected to have emissions reductions by 2018. Control strategies thatwere effective after 2002 and prior to 2018 arelisted asfollows.

Point Source Controls 

## - Electric genera tin^ Utilities 

### Houston-Galveston-Brazoria *nitrogen oxide Mass Emission Cap and Trade (MECT) Dallas-Fort Worth "30 TAC $117 nitrogen oxide unit specific limits *30 TAC $101system-wide averaging caps Beaumont-Port Arthur *30 TAC $117 nitrogen oxide unit specific limits *30 TAC $101 system-wide averaging caps East and Central Texas Clean Air InterstateRule (CAIR) *30 TAC $117 nitrogen oxide unit specific limits *30 TAC $101system-wide averaging caps West Texas *30 TAC $101 SB7nitrogen oxide caps with trading

Point Source Controls

# - Non-Electric Generating Units Statewide *Site specific Refinery Consent Decree sulfurdioxide levels Houston-Galveston "nitrogen oxide Mass Emissions Cap and Trade (MECT) *Highly-Reactive VOC (HRVOC) Emission Capand Trade (HECT) Beaumont-Port Arthur "30 TAC $117 controls (process heaters, industrial boilers, engines) Dallas-Fort Worth *30 TAC $117 controls for select Kilns (including cement, lime, brick and ceramic) Furnaces (reheat, smelting, blast, reverb, glass, fiberglass, and mineral wool) Heaters and ovens Industrial Boilers Engines Increment of Progress (IOP) engine nitrogen oxide controls Increment of Progress (IOP) surfacecoating VOC controls East Texas "30 TAC $117 Cement Kiln nitrogen oxide limits *Agreed OrdersIConsent decree sites specific reductions atAlcoa and Eastman 30 TAC $117 engine nitrogen oxide controls in specified counties

Area Source Controls Statewide "30 TAC $117 nitrogen oxide emissions limits to water heaters, small boilers, and process heaters Dallas-Fort Worth IOP forEllis, Johnson, Kaufman, Parker, Rockwall counties VOC reductions from Stage 

### I vapor recovery

### VOC reductions from surface coating processesOn-Road Mobile Source Controls Statewide *sulfur dioxide reductions from low sulfur diesel fuel nitrogen oxide reductions from TrLED Nonattainment areas *Vehicle inspection and maintenance TERPnitrogen oxide reductions

Non-road Mobile Source Controls East Texas Counties (including nonattainment counties) TxLED nitrogen oxide reductions Houston-Galveston and Dallas-Fort Worth *nitrogen oxide reductions from California Large Spark Ignition Engine Standards TERPnitrogen oxide reductions

A proposed control strategy forregional hazewith a limiting cost for controls, equivalent to the CAIR program of $2,700 per ton, results in a negligible improvement projected in visibility with a cost over $300 million (Table 10-4). The commission's analysis concludes that additional controls for regional haze arenot reasonable atthis time. This will be reconsidered in future SIPrevisions.



### The Sierra Club and many individualsurged the commissionto withdraw its proposed Regional 

### Haze SIP and develop anew plan for addressing the regional haze problem to submit to the EPA. 

### The Sierra Club found the proposed Regional Haze SIPrevisions inadequate and insisted that the commission take responsibilityto address the visibility issues at Big Bend and Guadalupe Mountains. Many individualsurged the commissionto include specific air pollution control measures that go beyond existing rules so that Texas can move closer toward the national goal to clearthe air in Texas and national parks in neighboring states.

Thecommission does not plan to withdraw the proposed Regional Haze SIPrevision. Significant cost-effective control strategies arealready being implemented in Texasto control ozone. As part of these strategies, nitrogen oxides emissions will be reduced. State control measures required under SenateBill 7 reduce both sulfur dioxide and nitrogen oxides atelectric generating units. These control strategies will also reduce the emissions that contributeto visibility impairment in Class 

### I areas. These strategiesareanticipated to decrease these sulfur dioxide emissions by over 225,000 tons and nitrogen oxides emissions by over 670,000 tpy by 2018. The commission's analysis concludes that additional controls forregional haze arenot reasonable at this time. This will be reconsidered in future SIP revisions.



### The Sierra Club requested the commission develop a new plan to reach the 2064 

### goal; cast the net wider for the active involvementof a much more diversified set of interests for input and collaboration on plan development, including especially bringing into the process much greater representation of interests that have a strong commitment to the protection of areas such as Big Bend and Guadalupe Mountains,rather than an over-reliance on industries with a interest in avoiding new air pollution control strategies.

The commission made significant effort to contact interested parties during both the Texas BART Rule and Regional Haze SIPdevelopments. Public notices were sent to update interested parties and solicit input in the regional haze process. Regional haze notices were sent to six newspapers: Austin American-Statesman, El Paso Times, Fort Worth StarTelegram, Houston Chronicle, Midland Reporter-Telegram, and the Alpine Avalanche. Notices were also sent to twelve Councils of Government and Metropolitan Planning Organizations, and seven local programs throughout the state. Representatives from siradjacent state's environmental departments were also notified. A list sewer of over 200 participants was established for BART developments. After the BART rule was finalized, the SIPlist sewerwith over 500participants was used for regional haze outreach. Among the notices were announcements for two informational meetings on the BART Rule and one meeting on the Regional Haze SIP. 

### In addition, the Texas Regional Haze 

### SIPwas published in the Texas Register on December 21,2007.



### In addition to the health concernsin the areas ofDallas, Houston, San Antonio, and El Paso, one individual is concerned with the effects of air pollution on the investments in McDonald Observatorythat will be seriously impacted by continued inaction.
Although the Regional Haze SLP revision addresses haze impacts only atClass 

### I areasin Texas and neighboring states, the commission anticipates that reduction in haze-causing emissions and activities will also benefitvisibility in other parts of Texas, including the McDonald Observatory.


### The Sierra Club, CLEAN, and four individuals were concerned that the commission does not meet thegoal ofnatural visibilityby 2064. The Sierra Club was disappointed withthe inadequacy ofthe Regional Haze SIPrevisions being proposed by the commission at this time. One individual questioned if TCEQ is protecting and advocating for industry or the public.

The commission remains committed to clean airand reducing haze in public wilderness areas, national parks, and throughout Texas. Texas has significant cost-effectivecontrol strategies to reduce nitrogen oxides and sulfur dioxide to control ozone. In addition to controlling ozone formation, the planned emission reductions will also have a co-benefit of improving visibility impairment in Class 

### I areas in Texas and nearby states. The strategies in place are anticipated to decrease these sulfur dioxide emissions by over 225,000 tpy and nitrogen oxides emissions by over 670,000 tpy by 2018. The commission considers the strategies in place area cost-effective, reasonable approach to reducing visibility impairment. The commission's analysis concludes that additional controls for regional haze
arenot reasonable atthis time. This will be reconsidered in future SIPrevisions.

Corrections 

### TheEPA commented that Tables 8,9, and 10of Appendix 10-1

### were truncated. The FS commentedthat in Chapter 8, Figures 4 

### and 5;the captions indicate that these figures used the 2002 Base F emission inventory, however,the headings for the graph say that they used the 2002G typical emission inventory. The FS asked the commission to correct this error. The NPS, FWS, and EPA commented that the folder for Appendix 11-1: 

### Fire Management Plans was 

### empty on the CD. The FS indicated park name corrections for Badlands, Bandelier, and Great Sand Dunes to national parks. The 

### NPS and FWS noted that within Appendix 5-1 an ftp site was referenced for further information. The commenters noted that the ftp 

### link was password protected and not publicly available.

The commission thanks the EPA, 

### FS, NPS, and 

### FWSfor identifying these errors. The corrections to Appendix 10-1were made to the SIPrevision and posted on the TCEQ regional hazeWeb site in February 2008. The Chapter 8 figure caption has been corrected to indicate that model results arefrom the Typical 2002G or TypO2G inventory. The commission corrected the error in the CD's missing Appendix 11-1 and e-mailed the materials as soon as staffwas made aware of the omission. The park names were correct throughout the document. The ftp siteis not a stateWeb site and the reference is not critical for the appendix, so the link has been deleted dueto problematic access.