Buddy Garcia, Chairman 

Larry R. Soward, Commissioner 

Bryan W. Shaw, Ph.D., Commissioner 

Mark R. Vickery, P.C., Executive Director 

RtiEi'k E.L~ - l;i'F,~ 

AIR PLAPY'IBIFiG SEC 

O9PIRR30 PM 1: I-1 

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

Protecting Texas by 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. 2006-022-1 16-EN 

Lawrence E. Starfield Acting Regional Administrator 

U.S. Environmental Protection Agency - 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 reasonable progress in reducing visibility impairment at Class I federal areas, 

including Big Bend and Guadalupe National Parks, resulting from anthropogenic air pollution. 

Enclosed are the proposed revisions to the SIP, adopted rules, public hearing certifications, a complete record 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 of Budget, Planning and Policy, Office of the Governor 

Mr. Mark R. Vickery, P.G., Executive Director, Texas Commission on 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 OF TRAVIS 6 

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

State Implementation Plan, adopted on February 25, 2009, pursuant to 40 Code of Federal Regulations (C.F.R.) 

6 51.104. I am the records administrator for the Air Quality Division of the Texas Commission on 

Environmental Quality (Commission). 

F Susana M. Hildebrand, P.E. 

Director, Air Quality Division 

Texas Commission on Environmental Quality 
Texas 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 I Areas 

Rule Project No. 2007-016-SIP-NR 

Volume 1 of 2 
INTRODUCTION 

The Texas Commission on Environmental Quality (commission) held a public hearing in Austin, on 

February 19, 2008, to receive testimony regarding proposed revisions to the state implementation 

plan (SIP) to meet the requirements of the Federal Clean Air Act (FCAA) 169A and 169B addressing 

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 is two volumes, 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 of this hearing record are maintained in the TCEQ central office at 121 00 Park 35 

Circle, Austin, Texas 78753. For further information, please contact Margaret Earnest at (512) 239- 

4581. 
EVALUATION OF

TESTIMONY
Texas Cornmission on Environmental Quality . INTEROFFICE MsMORANDUM 

To: . Commissioners Date: . November 16,2007 

Thm: LaDonna C-uela, Chief Clerk 

Glenn Shankle, Executive Director 

From: David C. Schanbacher, P.E., Chief Engineer 

Chief Engineer's Office 

Docket No.: 2007-1539;SIP 

Subject: ~e~ional Haze State Implementation Plan (SIP) Revisions 

' Regional Haze SIP Submission 

Project No. 2007-016-SIP-NR 

Reasons for the SIP revision:' 

The Federal Clean Air Act (FW) and the United States ~nv&nmenta~ ~rotection Agency (EPA) 

regulations require statcs to submit SIPS to make "reftsonable propssn in reducing visibilrty impairment at 

Class I Federal arkas resulting from auth~pogenic pollution. FCAA, 169A(a)(l), "declares as a national 

goal the prevention of any m, and the iemedying of any existing impairment of visibility in mandatory . Class I Federal areas which inhpairment results from man-made air pollution". Class I areas aie national 

parks over 6,000 acres and wilderness areas over 5,000 acres that Congress has recognized at significant 

sites. These SIPS must "contain ~h emission limits, schedules of compliance and other mcesasures 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 Staten on 

certain existing stationary sources. 

. The EPA Regional Haze Rule slmngly encourages @tes to work togetha in regional par&ershiPs to reduce 

b. There are five regional planning o~011s in the United States. Texas is a member of the Central 

Regional Air Planning &sociation (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 Regid Haie SlPs is December 17,2007. ClWRAP 

provides analysis, modeling results, and infonnatio@ exchange among states, but each state will submit its , . ' own regional haze SIP. 

. Under what aothckity are we proposing these changes? Texas Health and Safety Code (THSC), 

$3 82.002, Policy and Purpose; 53 82.0 11, General Pow& and Duties; 53 82.012, State Air Control 

Plan; FCAA, 5 1 10(a)(2)@)(i)CII), 169A and 169~ (42 U.S.C., §§7410(a)(2)(D)(i)(Q; 7491 and 

7492); 

Is this SIP revision required by federal rule or state statute? Which ones? Yes, two federal 

rules require this STP revision. The EPA adopted Regional Haze regulations in 40 Code of Federal 

Regulations (CFR) Part 51, Subpart P, on July 1,1999, and adopted amendments to Subpart P and a 

new Appendix Y (BART guidelines) to Part 51 rn July 6,2005. 

Are there any legal deadlines by which this SIP revision must be proposed, adopted, or 

effective? Yes. The Regional Haze SIP deadline is December 17,2007. Due to federal suits 

regarding the BART rule, the states delayed implementation for approximately five years. However, 

the Regional Haze SIP deadline remained unchanged. Many states will not meet the deadline. The 

commission is scheduled to consider the proposal of this SIP revision on December 5,2007, and 

adoption in July 2008. 
Commissioners 

Page 2 

1 1/16/2007 

Re: Docket No. 2007-1539-SP , , . . 

. What issue@) or problem(s) are we trying to solve? Make reasonable further progress in returning 

visibility at Class I areas to natural conditions and meeting federal requirements. Since air emissions 

do not recognize state boundaries, all states must work together to reduce emissions that impact each 

state and surrounding states. 

. Why is it important that we do this SIP revision? Not submitting a SIP could lead to federal . 

' sanctions (emission ofhets and hig&way funding sanctions) or a Federal Implementation PI& PIP) 

or both. . 

. other important bsckgomd or hirtohul information. The ~~~~;~ection 169A and B require ' 

the EFA to adopt regulations to reduce visibility impairment resulting '%om man-made air 

poIlution" in 156 Class I Federal areas. The regulations require each state SIP to contain control 

measures, including BART, to make reasonable props toward the national goal of natural 

visibility conditions by 2064 in dl Class I areas. Tbe two Class I areas m Texas ire Big Bend and 

Guadalupe Mountains National Parks. Each state bordering Texas has one or more Class I Federal 

mas designated for visibility protection. Where Texas' emissions impact visibility in Class I 

Federal mas in other states, the Texas SIP must include p1ans.b reduce Texas' visibility impacts in , 

those areas too. 

The EPA adopted Regional Haze regulations in 40 Code of Federal ReguIations (CFR) Part 51, 

subpart P, on July 1,1999, and adopted amendments to Subpart P and a new Appendix Y @ART 

guidelines) to Part 5 1 on July 6,2005. 

Scope of the SIP revision: 

The 1990 FCAA Amendments togeth& with EPAas Regional Haze Rule set the goal ofreducing 

'ban-made" impacts on visibility in Class I areas to zero (i.e., to 'haturd" conditions) by 2064 for 

the worst 20 percent visibiLity days and preventing any degradation for the best 20 percent visibility 

days. 

&NRAP and other Regional Air ~larnlin~ Orgmkmtions haw cooperated to calculate the base 

period (2000-2004) worst 20 percent and best 20 perceht visibility for each Class I area CENRAP is 

contracting projections of visibility impairment in 2018, the initial year for which each state's longterm strategy is to be evaluated. The state must reduce its visibm. 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 uied a ~hed estimate of natural conditions for Class I areas in Texas and other states as 

permitted by EPA guidance. These ~fin.4 esthwtes account for natural dust storms, which explain , 

' 

a sigd3cant number of impaired days at the Texas Class I areas. 

The Clean Air Interstate Rule (CAB) program is expected to reduce regional haze impact. . Following the legislature's statutory direction, fie TCEQ adopted CAZR requkemeuts applicable to 

electric generating units in Texas. Intershie trading of CAJR emission reduction credits makes t6e 

prediction of CAIR's visibility improvement benefits uncertain for each Class I area 

Additionally, the commission addpted the requirements of the BART program, which requires 

certain older sources with a visibility irnpakment impact 011 a Class I area to apply BART to the 
Commissioners 

Page 3 

11/16/2007 

' Re: Docket No. 2007-1539-SIP 

source to reduce its impact on a nearby Class I area. The SIP must contain a list of BART-eligible 

sources and the determination of BART for each source that is I-easonably anticipated to .contribute to 

visibility impairinent (BART-subject). , f 

Each state must evaluate and determine if additional emissions reductions are necessary. The statute and 

EPA rules and pidance set criteria for determining whether additional reductions are reasonable. These 

criteria ari based on the cost of contsol and other related faotm. 

cbanges'required by federal rule: The proposed SIP +$ion is intended to satis@ federal 

requirements. States are required to submit.Regional Haze SIPS under FCAA, $1694 Visibility 

Protection for Federal Class I Areas, and $ 1 69B, Visiiility; and 40 CFR Part 5 1, Subpart P. 

Changes required by state statute: N/A ' 

Staff recomm;ndations that are not =xpressly required by federal rule or &ate statuk None. 

Impact on the regulated community: . , 

Who will be affected? Some BART-eligible sources were required to submit modeling reports 

demonstrating impacts below threshold on Class I areas. No additional controls were added to this 

revision. 

Does it create a group of affected persons,who were not affected previously? How? NO. 

Will there be a fiscai impact? If so, estimate. No impact is estimated under the inik Regional 

Haze SIP. 

Impact on the public: 

Who wabe affected? Texas will benefit from increased visibility at Big Bend National Park and 

Guadalupe Mountains National Park. Visibility oould also potentially improve at Class I Areas 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 of participating in CZNRAP. . No new rules h~ve been added. 

Informational meetings: 

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

. With whom? Persons or companies curregtly interested in STP changes. 
Commissioners ' 

Page 4 

11/16/2007 

. . Re: Docket No. 2007-1'539-SIP 

. What were the gened sentiments? Some apprehension and uncertainty is expected with the 

implementatioll of a new federal and concern about the long schedule. 

B Were any changes made in response to stakeholder concerns? None are expected. The TCEQ is. 

following federal guidance. 

PoIicy issues: . 

What policy issues are affected? Pollution transport &om Mexico and America is a major 

factor in visibility impairment at Texas' Class I areas. The goal of natural visibility will not be met 

unless international transport is addressedby the.federaI government 

. 'he~ry policies that are not currently bas& on rule being made into a rde? NO:. 

Whet are the consequences if this'SlP revision is not approved t~:~o forward? Not submitting a . SIP could lead to federal sanctions (emission offsets and highway funding sanctions) or a Federal . 

Implementation Plan (FP) or both. 

' Are there alternatives?. Fehd skctions. . ' 

. . 

Potentially controversial matters: . 

~atiial parks in momding. states of OkIahoma, Arkansas, Louisiana, and New Mexico. . may want more input on potentially petted new sources in proximity to their Class I mess. 

Presently, the rules dow these states and federal land msnagers (FLMs) to review new sources , 

within 100 kilometers. Oklahoma has requested the opportunity to examine and comment on new 

source app?ications greater than 100 kilometers fi~m Class I areas that may impact its p.arks. FLMs , , 

for the Forest Service, Fish and Wildlife Service, and the National Park Service have also requeskd .. 

the opportunity to examine new source applications greater than 100 kilomete &om their Class I , 

areas. 

. . There will likely be some concern from the public that this SIP does not make dcient 

progress towaid natural visibility. The national goal is to reach natural visibility by 2064. At the 

rate of irr@royement proposed in this SIP, natural visibility levels would not be reached until 2080 at 

the Guadalupe ~ountains'aud 2148 at Big Bend 

Key points in proposed SIP revision schedule: 

. Anticipated proposal date: December 5,2007 

Public hearing date.(if any): February 19,2008 

Public comment period: , December 21, 2007 through February 22,2008 (includes maudated 

60-day review by FLMs) . Anticipated adoption date: July 9,2008 

Agency contacts: 

keg Nudd, P.E., Technical Specialisf 239-1247, Air Quality Planning 

Margaret Earnest, SF Roject Manager, 239-45 8 1, Air Quality Planning 

John Minter, Staff Attorney, 23 9-0663 . 
' . Commissioners 

Page 5 . . 

11/16/2007 

Re: Docket No. 2007-1 539-SIP 

Attachments 

cc: Chief Clerk, 5 copies 

Executive Director's Office 

David C. Schanbacl~er, P.E. 

Susana Hildebrand, P.E. 

Ashley K. Wadick 

Daniel Womack 

Office of General 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.: 2007-1 539-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 1990 Federal 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 of visibility impairment in 201 8, the initial year for 

which each state's long-term strategy is to be evaluated. The state must 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 to promulgate 

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.makes comparable reductions 

in pollutants causing regional haze prior to 201 8. 

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 of the 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 other related 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 SIPS must "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. CENRAP provides 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; $382.01 1, General Powers and 

Duties; 8382.012, State Air Control Plan; FCAA, $1 lO(a)(2)(D)(i)(lI), 169A and 169B (42 U.S.C., 

$874 I O(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 

did not 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 of publishing a 

notice of finding of failure to submit a required SIP, in mid-December 2008 EPA Region 6 staff 

recommended that Texas submit its SIP revision incorporating CAIR or CAIR replacement. The notice was 

eventually published January 15,2009, in the Federal Register, 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. If EPA 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 Deterioration 
Commissioners 

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. Oklahoma has 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. 

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 TCEQ 

void all air permits and pending applications for the plant. The TCEQ voided these permits and applications 

on February 9,2009 (See Appendix 11 -4: ASARCO El Paso). The TCEQ will continue to consult with 

affected states and Federal Land Managers for the next Regional Haze SIP revision. 

Pollution transport from Mexico and Central America is a major factor in visibility impairment 'at Texas' 

Class I areas. The goal of natural 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 of improvement 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, Citizens League 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 1 1 ). 
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 21,2007 through 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, SIP Project 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 
RESPONSE TO 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 complete list is located at the beginning of the Regional Haze SIP. 

EPA United States Environmental Protection Agency 

FLM Federal Land Managers (includes NPS, FWS, and FS for this document) 

FS United States Forest Service 

FWS United States Fish and Wildlife Service 

NPS National Park Service, United States Department of the Interior 

Chapter 1: Background and Overview of the Federal Regional Haze Regulation 

The Forest Service (FS) and one individual requested rewording of the 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 

Environmental Quality (TCEQ) stated that Guadalupe Mountains contains the only 

congressionally designated wilderness in Texas; however, there are five congressionally 

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 commented that Big Bend and Guadalupe Mountains are identified in Chapter 1 : 

Background and Overview of the Federal Regional Haze Regulation, but out-of-state Class I 

areas are not. Including a summary of those other impacted Class I areas would provide balance 

to this chapter. The FS requested that the TCEQ include the out-of-state Class 1 areas that Texas 

impacts in Chapter 1. Additionally, the FS commented that Texas should quantitatively 

summarize its reasonable progress goals and associated rationale for 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: LongTerm Strategy to Reach Reasonable Progress Goals for analysis of Texas' impacts on all 

impacted Class I areas. The commission disagrees with the suggestion that the Texas 

Regional Haze SIP revision should list the reasonable progress goals established by each 

state with a Class I area that Texas impacts. Instead, Chapter 11 details both the total and 

Texas1 apportioned 2002 and projected 2018 extinction impacts on each Class I area 

impacted by Texas' emissions. 

One individual commented that Table 1-1 : Visibility-Impairing Pollutants lists evergreen trees as 

emitting volatile organic compounds (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 document that many areas with bare soil or 

little vegetation are due to human impacts. Example: overgrazing occurred in the area that 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 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: Assessment of Baseline and Current Conditions and Estimate 

ofNatura1 Conditions in Class IAreas show little difference in the final calculation whether 
natural dust sources are 80 or 100 percent. The commission made no changes in Chapter 

1 in response to this comment, but changes were made in Chapter 5 and Appendix 5-2: 

Estimate of Natural Visibility Conditions. (Also see responses on grazing under Chapter 8: 

Modeling Assessment.) 

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 follows the requirements of the Federal Clean Air Act and EPA in regard 

to visibility. Since there is no health based standard for visibility, there is not an exact 

number to reach. The commission's goal is to reduce haze-impairing pollutants in Texas 

and surrounding states to approximately natural conditions. Texas has calculated natural 

conditions to be about 11 deciviews at the state's two Class I areas. 

Chavter 2: General Planning Provisions 

The United States Environmental Protection Agency (EPA) commented that the TCEQ should 

ensure it followed the requirements of Part 5 1, 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 5 1, Appendix V. 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 SIP revision to the EPA for approval, it follows the administrative 

requirements of Appendix V, Section 2.0. This revision will be no exception. The 

commission's order, referral letter, public hearing record book, and SIP narrative will 

address those 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 commented that 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 satisfied with Texas' existing regulations for the 

next revision. 

The EPA specifically requested that TCEQ should address the 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 as part of the TCEQYs reasonable progress strategy? 

c) The TCEQ should demonstrate that it has included in its implementation plan all measures 

necessary to obtain its share of the emission reductions needed to meet the progress goal for those 

Class I areas for which it causes or contributes to visibility impairment. 

d) In Chapter 4, the TCEQ states that it attended Oklahoma's three consultation calls held in 

August and September 2007. The TCEQ should discuss the results of those 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 

Particulate Matter 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 that will improve visibility in the affected Class I areas. The commission 

also requested recipients of the letters to confirm they are not expecting any additional 

emission reductions from Texas sources. The letters and replies are in 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 are in 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 made changes to Chapter 4: State, Tribe, and Federal 

Land Manager Consultation and added a new appendix 4-3. 

Chapter 5: Estimate of Natural Conditions in Class I Areas 

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

Estimate of Natural Visibilig) Conditions on the calculation of the refined estimates of natural 

visibility for the two Texas Class I areas. 

Appendix 5-2 b: 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 are contained in 

the second part of Table 5-1: Regional Annual Mean -Natural Concentrations (RAM-NC) of 

Trijonis and the EPA. However, so others may more easily reproduce the 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 are bundled into a ZIP file 

named TXNC.zip and provided as Appendix 5-2c: Texas Natural Conditions SAS Program 

File and Data. The appendix was expanded to include more details as the 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 100 percent of the coarse mass and fine soil 

due to 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 difference in the final 

calculation whether natural dust sources are 80 or 100 percent. Additional supporting 

research from the Chihuahuan Desert (summarized and referenced in Appendix 5-2 Gill, 

T. et al. 2005; Kavouras, 1. G. et al. 2006 and 2007) suggests that, at least for the 

estimation of natural visibility values for Texas 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 data from 2000. 
The fourth quarter data of 2000 for Big Bend was not sufficiently complete. The fourth 

quarter had only 10 complete days. This information is reflected in the Regional Haze Rule 

data that can be obtained through the Visibility Information Exchange Web System 

(VIEWS), such as the summary data through 2004 (at 

vista.cira.colostate.edu/views/Web/IMPROVE/SummaryData.as~x~. The commission made 

additional explanations in the SIP revision for clarification. 

The NPS, FWS, and FS acknowledged Texas' right to develop its own estimates of natural 

conditions, as established in 40 Code of Federal Regulations (CFR) 51.308; however, the FLMs 

requested that the EPA default estimates of natural conditions given equal weight in all tables, 

plots, and predictions that involve or depend upon an estimate of natural conditions. 

The comparisons with the EPA default, or more specifically, the Natural Conditions I1 (NC 

IT) committee's estimates using the NewIRevised IMPROVE Algorithm, are available in 

Appendix 5-2. The commission made some changes in response to this comment, however 

the NC I1 estimates will 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 if the 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 components in 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 to this effect has been added to Table 5-1 in Appendix 5-2 to illustrate that 

the fractions shown for all but course mass and fine soil are essentially the same as used by 

the Natural 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. 

The commission has included additional supporting evidence in additional appendices (and 

references therein) to Chapter 5. 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 100 percent 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 

Big Bend. The TCEQ acknowledges that the number of dust storms at Guadalupe Mountains and 

Big Bend do not correlate with each other in the SIP and appendixes. Because of these 

differences, the natural conditions for these two sites should be evaluated individually. The EPA 

requested that the TCEQ show how tinis information was 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 Guadalupe Mountains; 

therefore, two different numbers were recommended for natural conditions (see Chapter 5 

and Appendix 5-2). Regarding the difference in dust at 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/haze sipdust storms.pdf>). There is ample evidence, in addition to that cited in the dust storm 

paper, that these parks are in many ways quite different. However, this paper does support 

the assertion of the Appendix 5-2b: Estimating Natural Conditions Based on theRevised 

IMPROW Algorithm, 

(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 of natural conditions (see reference Trijonis 1990)' which 

are used 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 100 percent of the coarse mass and 

fine soil as stemming from natural sources is common to the calculation of natural 

conditions at both Texas Class I areas, the actual computations are carried 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 the previous 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 

for the 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 to the establishment and 

operation of the 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 case the IMPROVE 

program curtails operation of IMPROVE monitors or funding for Visibility Information 

Exchange Web System (VIEWS). 

The commission agrees that the proposed SIP revision did not mention that the financial 

contributions from the FWS and FS to funding the IMPROVE monitoring at Class I areas. 

The SIP is 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 if the current 

federal funding of any of these IMPROVE monitoring network sites or the VIEWS services 

is threatened. The commission 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 SIP in 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 are each unique in the current 

IMPROVE Class I site network, so there is no acceptable, reasonably representative 

alternative that could substitute for either site. 
In response to the question about the TCEQ's monitoring and monitoring plans at Big Bend 

and at Guadalupe 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 at the Big Bend 

IMPROVE site. Additionally, the TCEQ hosts the NPS ozone data from Big Bend on the 

TCEQ Web site. In fact, the NPS ozone data appear on the TCEQ Web site. 

The commission currently plans to continue this monitoring but ,is unable 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 

as the TCEQ is able to continue its monitoring at Big Bend, it will make all the data 

available to the FLMs, the EPA, and the public. 

Chapter 7: Emissions Inventorv 

The EPA requested an explanation of how the TCEQ resolved any significant differences 

between the actual locations of stationary sources in 2002 and the Integrated Planning Model 

(1PM)-generated 20 18 locations. 

As part of the review of the IPM Version 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 for predicting 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 at existing plants. 

In consideration of current air quality, the model also projects locations of new units based 

on a hierarchy of county attainment status, such that the units are located in pollutant 

attainment counties, particulate matter nonattainment counties, and eight-hour ozone 

nonattainment counties, in that order. The commission acknowledges the uncertainties that 

any projection 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 of Electric 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 significant differences between the 2002 magnitudes 

of stationary sources and the IPM-generated 201 8 magnitudes. 

Central Regional 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. 

CENRAP then used the projected EGU emissions in its photochemical modeling of visibility 

impacts in Class I areas. Inputs developed for IPM runs are based on assumptions 

applicable at the time the model 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 of SOl and NOs from EGUs - IPM 2.19 Versus IPM 3.0 in 

Appendix 7-2 shows that for the period 2002 to 2018, the IPM Version 2.19 predicted an 

approximately 35 percent 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 for regional haze is 

particularly long and model assumptions are thus quite uncertain. However, the 
commission still regards the TPM as a viable EGU emissions planning tool for Regional 

Haze SIP development and is not aware of a better tool. The commission has made no 

changes in this SIP revision. 

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 emissions from the combustion of these fuels are 

of most concern relative to visibility impacts. The appendix provides a comparison of total 

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 Versus IPM 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) during the 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 the Electric Reliability Council of Texas 

(ERCOT) show continued growth of coawlignite- and gas-fired capacity for the ERCOT 

region at least through 2013, the furthest projection year available from ERCOT. The 

commission acknowledges that the future growth of generating capacity for these 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 as are the 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 are in contrast to actual decreases in 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 of 2002, and 201 8, in order 

to check the accuracy of the EI projection methodology. 

A summary of the 2005 emissions inventory data was included in Appendix 7-1: Texas 

Emissions Invetztoq:l, Development: Base Year 2002 and Projected Year 2018, Section 7.5 of 

this SIP revision. Summary data from 2002,2005, and projected 2018 inventories are all 

included in the SIP revision. 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 sulhr dioxide were in and requested clarification on why Texas believes 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 

the TCEQ in 2002. The difference is attributed to industrial 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 of the 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 of the SOz 

emissions from these types of sources. 

The EPA, NPS, and FWS questioned that CENRAPYs modeled emissions estimate was not 

expected to significantly impact visibility estimates for 201 8 because of the relatively small 

contribution from these Texas sources on Class I areas. The EPA, NPS and FWS commented that 

data presented in the SIP narrative suggested that Texas sources' emissions constitute the 

majority of visibility impact at the Wichita Mountains Salt Creek, and Caney Creek; and 

indicated that Texas sources' emissions have a great impact at White Mountain. The EPA, NPS 

and FWS asked that the TCEQ explain the specific difference between the reported TCEQ sulfur 

dioxide inventory and the CENRAP modeled inventory as well as the rationale for why TCEQ 

considers Texas' contribution to visibility impairment in neighboring states' Class I areas to not 

be significant. 

The SIP statement that "the SO2 emissions modeled by the CENRAP are significantly 

higher than the 15,633 tpy reported by the TCEQ was intended to refer specifically to the 

area sources of industrial and residential coal combustion that were over-represented in the 

CENRAP modeling inventory, not all SO2 emissions. The commission 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 

are typically 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 SIP revision for clarity. 

The NPS and FWS referenced the SIP Table 7-3: CENRAP 's 2018 Emissions Inventor)? 

Summary for Texas showing that emission estimates of organics, primary particulates and 

ammonia are predicted to increase during the planning period (years 2002 to 201 8). The NPS and 

FWS suggested that the TCEQ include a summary within the SIP revision of why estimates 

predict increases in organics, primary particulates, ammonia, and area source sulfur dioxide, 

together with a discussion of how much these increases are expected to affect visibility 

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 factors were based on the 

most recently available (at the time of inventory projection) set of economic and 

demographic projections 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 are input into the model. These 

8 
anticipated increases in emissions are off-set in each category and region of the state by the 

appropriate on-the-books controls. The EGASS 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 10 microns 

(I'Mlo) are listed in both Table 7-1: CENRAP's 2002 Base Year Emissions Inventory 

Summaglfor Texas and Table 7-3. The emissions inventory predictions made for the 

CENRAP modeling indicate, for the area source category, sulfur dioxide emissions increase 

by approximately 2 percent. Statewide emissions of organics are predicted to increase by 6 

percent, the PMlo by 2 percent and the PM25 by approximately 7 percent. 

Ammonia is predicted to increase by 33 percent The largest portion of ammonia emissions 

are associated with the area source agricultural-based sources. The Carnegie Mellon 

University model was used to estimate these emissions. Ammonia is not a limiting pollutant 

for visibility for Texas' and neighboring Class 1 areas. 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 are not applicable to 

Texas and were not part of Texas' area source 2002 annual emissions inventory submission 

to EPA. Changes were not made in response to comments because the chapter summarizes 

the modeled values. 

The NPS, FWS, and FS agreed that Mexico emissions contained within the boundaries of the 

CENRAP modeling domain are important contributors to visibility impairment at Big Bend and 

Guadalupe. The NPS, FWS, and FS requested that Texas acknowledge the 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. The NPS, 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 of haze in Big Bend than previously suspected. 

The commission 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 outside the 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. 

The modeling for the SIP revision uses the latest available emissions estimates, including 

BRAVO study emissions estimates. The commission agrees that sulfur emissions are the 

most significant contributor to haze in the Big Bend Class I area. The commission disagrees 

that the importance of sulfur dioxide emissions in contributing to visibility impairment at 

Big Bend is a new finding. The NPS monitoring at Big Bend was showing this fact in the 

1990s. Coal fired power plants are the major source of sulfur dioxide emissions. In the 

2002 base period for the Regional Haze SIP revision, sulfate pollution contributed 55 
percent of the visibility impairment from pollution. Texas' sulfur dioxide emissions 

contributed 21 percent of this 55 percent of the visibility impairment from pollution at Big 

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 1999 for the 

Houston-Galveston-Brazoria (HGB) Ozone One-Hour Nonattainment Area SIP revision. The 

individual commented that numerous small to medium size point sources should be controlled to 

reduce regional haze, hazardous air pollutants, 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. Current effort is underway by the TCEQ and CENRAP to improve 

this estimate and any improved estimates will be included in the five year SIP review. No 

changes were made to the SIP. 

The EPA asked whether the mix of electrical generating capacity (gas versus coal plus 

renewables) as projected in 20 18 by the IPM appears reasonable when compared to that in 2002. 

As shown in Table 1 of Appendix 7-2, the IPM Version 2.19, used by CENRAP, projected 

an approximately 14 percent increase in coalllignite-fired generating capacity in Texas from 

2005 to 2018, and about a 32 percent increase in gas-fired capacity. The ERCOT 

projections, which are available 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 as wind power are not summarized in 

Appendix 7-2 (since sources such as wind power do not create visibility impairing 

pollutants), other data obtained from the EPA indicate that JPM projections of generating 

capacity from such renewable sources are much 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 of the 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 of the 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 IPM Version 3.0 

provides a significantly more accurate prediction of future EGU operating scenarios and 

emissions than IPM version 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 of IPM is necessarily better than the other. The commission is also not aware of a 
better EGU emissions planning tool than the IPM for regional haze SIP development. The 

commission made no changes in response to this comment. 

The FS referred to a discussion in Appendix 7-1 regarding IPM 2.1 9 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 SIP referred 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 1 of Appendix 7-2, total sulfur 

dioxide emissions projected to 2018 for Texas EGUs by the IPM Version 3.0 were 

approximately the same as those projected by Version 2.19, even though the IPM 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 are a function not only of capacities for the fuel types but also of the 

assumptions upon which each IPM version is based, including the extent to which sources 

implement emission controls for projected units or purchase credits in response to the 

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 the projected decrease was primarily due to the fact that Version 

3.0 retired a large number of nitrogen oxide-emitting gas-fired generating units. In 

response to this comment, the commission made revisions to Appendix 7-2 to clarify the 

discussion of WM-projected emissions. 

The FS commented that it would be helpful for a more detailed discussion of the IPM results and 

the analysis of EGU impacts on visibility in the listed Class I areas. The FS said that a map 

showing the groupings of EGUs would add to the discussion. 

The commission notes that Section 7.3.2 of SIP Appendix 7-1, to which the commenter 

referred, contains only a brief summary of the IPM analysis. A detailed discussion 

comparing results from the analysis of the two IPM versions is provided in SIP Appendix 

7-2. This appendix presents a map of Texas EGUs emitting sulfur dioxide, the pollutant of 

primary concern for downwind visibility impacts, and presents tables showing the upwind 

Texas EGU groupings upon which the analysis is based. The commission considers that the 

map and the tables of EGU groupings provide sufficient information for the discussion 

provided in the appendix. No change was made to the SIP. 

One individual questioned why the TCEQ did not state how accurately the emissions inventory 

was for regional haze and questioned if this emissions inventory was any better than past 

inventories. The individual referenced several reports discussing the inaccuracy of the emissions 

inventory in past ozone SIPS and 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 of EPA refinery consent decrees. 

The commenter considered these reductions inadequate and insufficient for ozone attainment 

since the emissions inventories were deficient. 

The commission acknowledges the uncertainties of emissions inventory estimation 

techniques. Significant effort was made to provide the CENRAP modeling 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 and 
sulfur dioxide emissions were determined by the TCEQ to have the most significant impact 

on visibility impairment. For example, at Big Bend National Park annual average 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 SIP revision. The sulfur 

dioxide and nitrogen oxide inventories are not predisposed to the same level of uncertainty 

associated with parts of the volatile organic compounds inventory because emissions of 

these pollutants generally result from combustion sources that can be measured directly 

and often have continuous measuring or monitoring 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 SIP is 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 are also more pollutants to model. Haze does not 

have to meet a health based standard, but is measured in deciviews (dv) and meant to 

improve visibility. The Region Haze Rule requires using all existing rules and regulations, 

state and federal, to determine a uniform rate of progress to improve visibility. 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 

The NPS and FWS commented that both Figure 8-4: Observed and Base Case Modeled 

Concentrations at Big Bend and Figure 8-5: Observed and Base Case Modeled Concentrations at 

Guadalupe Mountains are intended to support the discussion of the model performance 

evaluation. The commenters asked that the commission explain 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 of the 2002F base case and 2002F typical case and found 

the differences in the statistics to be negligible. A minor correction was 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 are the 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 Big Bend? 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. 

The sentence 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 if the commission investigated the cumulative 

affect of sources along the Houston Ship Channel that can affect regional haze. 

The commission 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 CENRAP and the commission are presented in Appendix 8-1: Technical 

Support Document for CENRAP Emissions and Air Qualiqt Modeling to Support Regional 

Haze SIP, see Chapter 5: Additional Supporting AnaJysis. As shown in Figure 5-8: 30 

Source Regions used in the CENRAP 2002 and 2018 CAMx PSAT 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 the PSAT results. An example of the results for Caney Creek can be found 

in Figure 5-10: PSAT Source Region by Source Category Contributions lo the Average 2000- 

2004 Baseline and 2018 Projected Extinction for the Worst 20 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 contributions of.. . 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 to reduce Texas's agricultural emissions so that 

Class I areas outside of Texas will reach acceptable visibility levels as soon as possible. The 

individual advocated for quantification of agricultural impacts and destruction of natural 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 Under the Regional Haze 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) at both of Texas' Class I areas must 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 dry desert and dry lake bed areas with little or no human activity, almost all of which 

are situated in the Chihuahuan Desert. For instance, in the 2005 report Investigation of 

Dust Emission Hotspots in Chihuahuan Desert Playa Basins, Gill et al. state the conclusion 

that "Field campaigns revealed that . . . the vast 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 or three distinct grain size populations: very 

fine clays in the PM2.s range (including particles as small as 0.2 micron in clay playa 

sites) and fine sands (50- 200 pm), and in some sites silts (10- 50 pm particle size). 

This is consistent with current state-of-the-science knowledge of the desert wind 

erosion process. Sand grains saltate (bounce) across the land 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 5 for 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 100 percent of the 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 modeling may be inaccurate for the following reasons: 

the modeling area is larger than used for other nonattainrnent demonstrations; 

the poor quality of emissions inventory in Texas and other states; and 

the lack of credibility of the 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 done by the TCEQ, CENRAP, or EPA. For previous ozone attainment 

SIP revisions, the commission stated that 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 are continuing 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 discussion in 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 CENRAP typical 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 describing a significant over estimate of SOz emissions and model 

performance metrics that indicate a significant under estimate. One individual advocated for more 

control measures since the modeling under estimates many haze-forming pollutants. 

The commission 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 transporting them all the way to these West Texas Class I areas. The first report of 

this work has been added as Appendix 8-2: Big Bend Model Performance Ana!vsis. The 

commission has further model performance analysis work under way to support improved 

model performance in future Regional Haze SIP revisions. 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 201 8 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 should be made. 
The commission spoke with Minerals Management Senrice (MMS) personnel in spring 

2008 who stated that MMS has no issues holding offshore emissions constant for the 

following reasons: 

MMS currently has no data to justify growth in emissions and agrees that a 

projection to the future with no change is a reasonable one. 

Current closer-in leases are being exhausted and shutdown; new leases are for 

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 are likely 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 201 8 were heid 

constant. 

Global transport of air pollution from China would vary. 

Mexico and Central America emissions vary due to changes in 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 

federally endangered Red-cockaded Woodpecker. So within Texas, there may be more 

burning of vegetation. 

Emissions from wildfires between 2002 and 201 8 can vary greatly depending on 

droughts, winds, and other factors. 

GEOS-Chem was used to model boundary conditions for the CENRAP modeling domain, 

including those for China. 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 I visibility impairment. Depending upon resources and quality of 

future global emission inventory data, the commission may consider future case model runs 

of GEOS-Chem or other global models to use for future case boundary conditions. In 

addition, regional haze from China appears not to be a significant factor in the worst 20 

percent of days at Class I areas that Texas impacts, so the assumptions about this source of 

regional haze are likely to be insignificant in affecting future projections 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 or may 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 contributor to 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 asserted that biogenic 

VOC was not constant due to urban deforestation caused by sprawl. 

Predicting future biogenic inventories is projected to cost approximately $5 million 

and not necessarily more accurate than the base case inventory. Urban sprawl along with 

its vegetative changes is difficult to quantitatively estimate, so any predictions are also 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 current biogenics 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 of the approximately 250 potentially BART-eligible sources in the state. Tlle 

EPA commented that Texas sources significantly contribute to visibility degradation to a number 

of Class I areas in 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 submit an implementation plan containing emission limitations representing BART 

and schedules for compliance with BART for each BART-eligible source that may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal 

area." The individual considered that Texas having no sources subject to BART showed that the 

commission has 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 the emissions 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 control technology (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 or eliminate emissions of all air pollutants. 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 the Texas 

Legislature in 2001, required all previously grandfathered sources (i.e. constructed prior to 

August 30,1971) to obtain standard permits, permits by rule, or an individual permit. 

House Bill 2912 specified the performance required for upstream natural gas field 

compressors powered by internal combustion 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. The compliance 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 already been 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 or through 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 of the CAIR by participating in one or more of the EPA-administered CAIR 

trading programs for sulfur dioxideand nitrogen oxide need 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 SIP revisions that reduce emissions. These actions removed the 

large majority of the Texas sources from further BART 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 SIP revision 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 

are hundreds of kilometers from the nearest Class I area, so their contributions to visibility 

impairment at Class I areas are small. The emission reduction requirements under EPA's 

refinery consent decrees resulted in dramatic reductions 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 some cases. Because emissions from 

these facilities have already been controlled by Texas' permitting requirements, these 

sources were not subject to 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 accordance with the EPA guidance, the commission implemented 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 deciview impact on Class I areas as 

provided in the EPA's BART rule. Some sources that did not screen out of the initial 

modeling chose to shut down facilities or to apply controls which reduced their impact on 

Class I areas. Other sources already had extensive controls in place due to other emission 

control programs for ozone SIP revisions, and the refinery consent decrees. The BART 

process is fully explained in Chapter 9: Best Available RetroBt Technology of the SIP 

revision. All BART-eligible sources are listed. In addition, there is a list of sources that 

reduced their potential to emit through permit amendments, and/or by shutting down units 

in order to avoid being subject to BART controls. At this time, all BART-eligible sources 

have modeled emission impacts below the BART determination threshold due to 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 of how 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 that rule adoption stated: "The 

commission will not lower the 0.5 decivieaj threshold. The commission has received no 

evidence that a lower threshold is appropriate in Texas. By using only a single threshold, 

the TCEQ does not intend to imply that the threshold for causing visibility impairment is 

the same as for contributing to. Since TCEQ expects all Class I areas have more than one 

source impacting visibility, any source that 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. ... The commission 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 are hundreds 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 appropriate to 

use a threshold other than the 0.5 deciview threshold that EPA set. No changes were made 

in response to this comment. 

The EPA, 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-BART Emissions Reductions at Texas Sources in 

Chapter 9 and Appendix 9-12: BART-Eligible List are not the same. The NPS, FWS, and one 

individual asked the commission to clarify the differences between the two tables and provide 

more definite information regarding the ExxonMobil facility. 

The commission acknowledges that the BART-eligible tables may be difficult to understand 

due to the complexity of the BART process. 

The table 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, or particulate 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 conservative because 

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 

SIP revision at the 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 of the SIP revision the TCEQ should address the 

following: 

a) The TCEQ should present additional detail on the methodology used to identie the initial list 

of potentially BART-eligible sources that received surveys. For instance, was a permit review 

part of this strategy? How did the TCEQ determine if particular sources were in one of the 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 of the 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 SIP revision provides additional information on the suwey 

methodology used by Texas. A copy of the suwey is included as Appendix 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 applicable codes and emissions thresholds, including fossil-fuel steam 

generating plants with potentially BART-eligible quantities of particulate, for additional 

information regarding build and reconstruct dates and potential to emit level for emissions. 

The information obtained in this suwey helped identify the sources that were BARTeligible. Sources requested exemptions based on the 2007 Texas BART Rule, modeling for 

visibility impacts, or other updated information at the site. The exemption process is also 

discussed in Chapter 9 Section 9.2 through 9.5 of the Regional Haze SIP revision. The 

BART-eligible sources were adequately captured in this process. The companies suweyed 

represented over 97 percent of the 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 after performing source-specific BART engineering determinations through 

either CALPUFF modeling (Table 9-3: BART-Eligible Sources Exempted Based on CALPUFF 

Modeling Results) or CAMx modeling (Table 9-4: BART-Eligib le Sources Exempted Using 

Single Source CAfi Modeling). The commenters suggested that it would be helpful to list the 

modeled visibility impact results for each of these 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 of the relative importance of 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 at each Class I area. 

One individual commented that the distances used for BART-eligible sources are too short (50 

kilometers or 3 1 miles and 100 kilometers 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 distances up to 400 kilometers or 250 miles, 

since it has been documented by studies that ozone can be transported into 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 for potential BART-eligibility 

to 50 or 100 kilometers. All sources regardless of distance, with the appropriate category of 

sources as defined by the BART rule, within the state were considered. Based on analysis of 

visibility impacts, the EPA allowed the use of the model plant analysis by which a state 

could choose to exempt sources that 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 to Exempt Individual Sources with Common Characteristics under Appendix Y to Part 

51-Guidelines for BART Determinations Under the Regional Haze Rule (page 39162). Texas 

concurred with this use for the lesser significant emitting sources for 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 or quantity of 

emissions, were included in regional haze modeling and consideration for additional 

potential controls, even if initially removed from BART consideration. The commission 
looked at a 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 50 to 100 kilometers away from Class I areas. This individual suggest the TCEQ use 

these areas of influence subdivided geographic areas and emphasize sources that have the highest 

possibility of providing reductions that will benefit visibility and thus reduce regional haze 

impairment. 

As part of the area of influence analysis, the TCEQ identified any source within an area of 

influence with potential a$d-on controls and its costs were included. The analysis included 

sources greater than 50 to 100 kilometers 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 

SIP revision is updated to reflect this analysis in Chapter 9. Control strategies were limited 

to costs similar to those of other air control programs such as EPA'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. 

The commission 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 reasonable progress 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-BART Emissions 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 10 at this time. Texas may examine these 

reductions again at the next revision, if needed. The commission made no changes in 

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 over prediction 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 CAIR program 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 or its eventual replacement (whether over 

predicting or under predicting emissions), the commission's approach at this 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 of the 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 10 of the SIP revision and Appendix 10-1: Analysis 

of Control Strategies RPG with a summary of Texas' 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 at the 24 sources (Table 

10-4: The TCEQ's Point Source Control Strategy Surnmaly), 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 assessment did not consider that the average cost of 

sulfur dioxide control was approximately $1,850 per ton. Considering that 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 of people'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 for various source categories beyond the Base G. These potential controls, 

associated costs, and benefits were considered in the four factor analysis which 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 for regional haze 

are not 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 

FS commented that the IPM projections could also be an under prediction, which would not add 

to the justification 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 IPM could also be under predicting. The paragraph has been revised. 

The EPA commented that an evaluation on emissions over distance analysis (Q/5d) can be 

conducted but emissions over distance analysis are sensitive to the meteorology that impacts the 

transport and may not yield a conservative analysis. For example, if the source modeled is not 

upwind (and the source does not transport direct'ly to the Class I area frequently), the analysis 

would not be conservative to evaluate another source that is upwind of the Class 1 area more 

frequently. The EPA requested an expanded discussion of this issue so the 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 10 and its appendices provide further information on the use of areas 
of 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: 

Contributions to Visibilig) in the Texas Class I Areas implies that the boundary conditions 

contribution to impairment is primarily from Central America. The CENRAP modeling 

assessment did not differentiate among five large-scale model 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 impairment based on the 

CENRAP tracking model. The TCEQ needs to acknowledge that a portion of boundary 

conditions may be a result of recirculation of Texas and other United States-generated emissions. 

The SIP revision 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 CENRAP modeling domain from the boundary, 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 1990s and back trajectory 

analysis for the 20 percent worst of days in 2002 at Big 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 and Pollutants Causing Regional Haze at Big Bend that the extinction contribution 

from Mexico and from the boundary conditions are roughly 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 at Big 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, are in the 

boundary conditions domain. The commission concludes that these facts are generally 

consistent with the international sulfate impact at Big Bend, which the PSAT analysis 

attributes mainly to the northern portion of Mexico, which is in the CENRAP modeling 

domain. 

The commission agrees that occasionally some United States continental 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,the United States. When air masses penetrate that far 

south into the Gulf of Mexico, they are often following strong cool or cold fronts moving 

rapidly enough that they do not accumulate large amounts of regional haze. Slow moving 

summertime high 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 decade 
indicates that approximately one-third of the sulfate at Big Bend comes from outside the 

United States, one-third from Texas, and one-third from areas of the United States upwind 

of Texas. The commission has revised its SIP revision 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 accurate than the CENRAP PSAT modeling, then the 

reductions from CAIR or its replacement program could be more effective in reducing 

regional haze at Big Bend and Guadalupe Mountains than the commission has projected 

using CENRAP PSAT modeling. 

The FS commented that the uniform rate of progress 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 10 has been revised and refers the 

reader directly to the EPA default rate in Appendix 10-3: Uniform Rate ofprogress Curves 

Using Default Natural Condiiions Estimates. In addition, the appendices to Chapter 10 are 

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 continue to grant exceptions to grandfathered emitters, and the 

TCEQ should not consider permitting additional uncontrolled sources. 

The commission does not agree that grandfathered sources are granted exceptions from 

permitting. There are no longer grandfathered facilities in Texas. The Texas 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 

emissions from previously grandfathered sources are reviewed 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 of the source are determined on a caseby-case basis. New and modified sources are required to meet current Best Available 

Control Technology (BACT), including these previously grandfathered sources. Any source 

tha-t is 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 to these 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 SIP revision must show the full impact Texas has on each 

Class I area it impacts as well as the 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 agrees that it is necessary to identify specific areas of influence 

for each Class I area impacted by Texas' emissions, including Arkansas 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 that were considered for 

additional control, and the results of the four factor analysis for each set of sources. (The 

four factor analysis considers the cost of reducing air pollution 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.) Changes were made to Chapter 10 Section 10.4 in response to this 

comment. 

One individual disagreed with TCEQ's approach of not 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 questioned the accuracy of visibility impairment from internatioilal sources. 

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 and the areas of Mexico that are inside the 

CENRAP emission inventory and modeling domain are distinct. The modeling procedures 

were set up to separate the emission points into either the CENRAP modeling domain or the 

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 CENRAP modeling domain if they are north of the CENRAP 

domain boundary. The Mexican emissions south of the CENRAP domain and the emissions 

from Central America are in the boundary conditions. The inventoried emissions from 

Mexico are assigned to only one of these two areas. Chapter 11 discusses the uncertainty in 

assignment of regional haze at Big Bend to international transport, to Texas, and to the rest 

of the United States. The commission's decisions about the amount of control that is 

reasonable in this Regional Haze SIP revision is based on the four factor analysis, as the 

EPA's Regional Haze Rule specifies. (The four factor analysis considers the cost of 

reducing air pollution 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. 

The commission disagrees with these comments. The federal Regional Haze Rule requires 

that all reasonable reductions occur. Regarding CAIR or its eventual replacement, as a 

program that covers the entire Eastern United States, reductions occurring in surrounding 

states will positively impact visibility in Class I areas in Texas. The TCEQ has used the 

four factor analysis, as required, for the 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, the 
energy and non-air quality environmental impacts of reducing emissions, and the 

remaining useful life of existing sources that contribute to visibility impairment. 

The NPS, FWS, and FS commented that in establishing the reasonable progress goals (RPG), the 

TCEQ failed to establish a sufficient relationship 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 source region 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 

on the 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 the Regional Haze plan with a 

summary of the area of influence analysis for ten Class I areas, including eight outside the 

state. Impacts of emissions on those Class I areas are included. Texas has listed emissions 

from significant sources in a Class 1's area of influence. A list of these sources is included in 

an adopted version of the SIP. 

Costs of controls for sources that impact any of these ten Class I areas were considered in 

the four factor analysis. A more detailed four factor analysis is summarized in Chapter 10. 

The commission's analysis indicates that additional controls beyond those already existing 

on the books are not considered cost effective at this time. This issue will be readdressed in 

future Regional Haze SIP revisions. The federal Regional Haze rule requires states to 

submit five-year progress reports that include an assessment of whether the current plan 

strategies are sufficient for the state to 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. 

The NPS, FWS, and FS commented that in large geographic states such as Texas or Alaska, 

establishing these areas of influence are important for describing appropriate 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 sources that 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 of controls for each of these Class I areas is addressed 

and is now included in an update of the SIP. The commission made changes to Chapter 10 

and Appendix 10-1 in 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 SIP revision has been updated in Chapter 10 and 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. The commission 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 as the 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 TCEQ believed 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 in Appendix 

10- 1, which is a required element in the federal Regional Haze Rule Section 5 1.308(d)(l)(i)(A), 

be included in the SIP narrative. The EPA, NPS, FWS, and FS commented that in Section 10.2 

of the proposed SIP stated that Appendix 10-1 provided an analysis of the four factors identified 

by statute as required for setting reasonable progress goals and concluded that based upon these 

factors the goals are reasonable. The NPS, FWS, and FS recommend information in that 

appendix should be summarized in the SIP narrative and should clearly state the decision of the 

state on a Class I basis. 

This SIP has 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 areas were considered in the 

four factor analysis. The control list originally in Appendix 10 has been relocated to 

Chapter 10, not detached, to allow easier access by the public. 

The Sierra Club requested more evaluation of controls be located in the text of Chapter 10 instead 

of Appendix 10. The commenter does not have confidence in the existing TCEQ control 

strategies to meet the long time frames to address the proposed SIP revision. 

In response to this comment, the commission has updated the SIP narrative 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 SIPS for ozone 

nonattainment areas to also be pertinent for haze reduction as some of the precursor 

emissions are identical. 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 are planned. 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. The Regional Haze rule requires states to 

submit five-year progress reports that include an assessment of whether the current plan 

strategies are sufficient for the state to 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 ten-year comprehensive 

review. 
Area of Influence (A011 

The NPS, FWS, FS, and one individual commented that the TCEQ has set a 20 percent cut off for 

emission impacts, which is an unacceptably high level of impact to allow. The commenters were 

concerned the data did not show Texas' visibility impacts on other states. 

The commission did not use a 20 percent impact level in its analysis in this SIP revision. 

However, in Appendix 10-1, the commission did include both Table 1: Pollutant Impacts on 

Visibility at the Class I Areas from Texas Emissions and Table 3: Source Category 

Contributions to 5'04 and NO3 at the Five Class I Areas Texas Affects the Most7 which showed 

Texas7 impact on only the top five Class I areas in terms of the percentage of impact that 

came from Texas. This level was shown in the SIP for sake of summarizing results for the 

areas with the most impact from Texas. To prevent readers of the SIP from getting the 

incorrect impression that Texas used a 20 percent cut off, the SIP revision 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 are included. Significant sources 

within each Class I area of influence (AOI) were identified, using an emissions over distance 

value (Qld) of 5 to 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 significant sources within an area of influence was analyzed. The commission 

revised Chapter 10 in response to these comments. 

The NPS, 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 should be included are: Big Bend (NPS managed in Texas), Guadalupe 

Mountains (NPS managed in Texas), Wichita Mountains (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). The NPS and FWS suggested that the reasonable 

progress analyses are missing specific information about Texas' contributions to visibility 

impairment at the Wichita Mountains in Oklahoma and other out-of-state Class I areas. 

The commission revised Chapters 4 and 10, and Appendices 4-3 and 10-1 in response to 

these comments as follows. The area of influence analysis for ten Class I areas were 

summarized. These areas include Big Bend, Breton Isle, Caney Creek, Carlsbad Caverns, 

Guadalupe Mountains, Salt Creek, Upper Buffalo, White Mountain, Wichita Mountains, 

and Wheeler Peak. The first two orders of magnitude (areas of influence) for each 

pollutant and each Class I area were identified. Then significant sources within this circle 

or area of influence were identified. The sources were screened using an emissions over 

distance value (Qld) of five to limit the list to those sources most likely to have 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 are included. 

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 Minnesota to Texas, this does not give an accurate description of costs sources would 

incur in Texas. The TCEQ should determine and use costs more representative of the southern 

tier of CENRAP states. 

The commission7s use of the EPA'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 takes 
into 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 the AirControlNET 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 SIP revision. No changes were made to 

the SIP. 

The NPS and FWS commented that the uncertainty of CAIR controls is clear in Texas with 

regard to purchased emission credits and source unwillingness to make control commitments. 

The NPS and FWS commented that this level of uncertainty can have a heavy influence on the 

ability of the state to predict or meet visibility goals into the future. The NPS and FWS 

commented that TCEQ should identify areas of influence for each Class 1 area and develop a Iist 

of the significant point sources within that area to form the primary basis to better evaluate the 

progress of those sources within the CAIR framework. 

As part of the Regional Haze SIP development process, the commission considered control 

options beyond CAIR and BART, which are discussed in the four factor analysis 

summarized in Chapter 10. The commission's analysis indicates that additional controls 

beyond those already implemented are not considered cost effective at this time. The 

commission will address the need for addition requirements as part of the five-year review 

process, which starts in 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 at this time is to track CAIR or its replacement over the five-year and ten-year 

intervals, and determine if additional controls are needed. The progress of impacted 

sources will be evaluated in future SIP revisions and review of annual emissions 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. 

The commission agrees there are variations 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 are more likely. The United States Department of Energy stated in October 

2007 that "the latest benchmarking study by the EUCG, formerly known as the Electric . 

Utility Cost Group, examines the technology and cost of 49 flue gas desulfurization systems 

currently under design or construction by 12 of the United States' largest utilities. The base 

cost of a flue gas desulfurization system was $243 per kilowatt hour. The survey found that 

flue gas desulfurization retrofit projects are increasing 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 TCEQ provide a detailed cost accounting for the numbers in Appendix 

10-1 on Table 4: Summary ofAdditiona1 Point 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 are in Table 6: 

Proposed SO2 Controls Based on CENRAP Modeling; Table 8: Proposed SO2 Control for 

Carbon Black Units; and Table 9: Proposed NOX Controls Based on CENRAP Modeling. 

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 of more than one 

Class I area. 

The commission revised Appendix 10-1 with a summary of the area of influence analysis for 

ten Class I areas. The analysis for visibility impairment was based on each Class I area and 

costs of potential controls within that Class I area impact. Once a source was identified 

with a potential control, the cost of the control to the site remained the same, regardless of 

the number of areas of influence in which the source is located. A four factor 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 Oxide Emissions Reduction Strategies 

fir Cement Ir'lns - Ellis County: Final Report was submitted to the TCEQ by ERG 

(www.tceu.state.tx.us). This study evaluated the applicability, availability and cost 

effectiveness of potential nitrogen oxide control technologies for the ten cement kilns iocated 

at three Ellis County sites. The report focused on selective catalytic reduction (SCR), 

selective non-catalytic reduction (SNCR), and low temperature oxidation (LoTOx). Based 

on the results of the study, the TCEQ conducted modeling sensitivity analyses at two levels 

of control to evaluate potential ozone reduction benefits from possible cement kiln control 

strategies. A reduction in nitrogen oxide as part of the ozone control strategies has haze 

control co-benefits. One modeling sensitivity run assumed a range of 35 to 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 of the kiln study, the modeling 

sensitivity results, and all other available information, the commission determined that the 

35 to 50 percent control range was the most appropriate control level to address ozone in 

the Dallas Fort Worth area. 

The commission developed a source cap that will require a reduction of approximately 9.69 

tpd of nitrogen 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 other technologies. Pilot testing of selective non-catalytic 

reduction on wet and dry kilns 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 10 Section 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 TCEQ provided 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 of progress, Texas does not justify how it contributed to its proportion of controls 

necessary to help these states work toward the uniform rate of progress. 

Impacts of emissions on those Class I areas are included in the SIP narrative, Section 10.3. 

Texas has updated this SIP and lists significant sources in each of ten Class 1's area of 

influence, including those mentioned in the comment. Potential additional controls were 
evaluated for significant sources that may have an impact on a Class I area based on their 

emissions and distance to the Class I area. A four factor analysis was done for each source 

category. As part of the consultation process, this information was sent to other states with 

an impacted Class I area (see Appendix 10-1 and 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 not justify 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 FWS stated 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 6-1 0 of the Appendix 10- 1 

appear to include information that is not relevant to the narrative description. The NPS and FWS 

requested the tables include information on sources likely 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 10 are the detailed proposed controls for nitrogen oxide 

and sulfur dioxide sources that were discussed in Section 10-1.4 Proposed Controls. The 

summary of controls in Table 4 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 all potential controls 

regardless of the Class I impacted, as required under the EPA 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 SIP with 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 areas that Texas impacts: Table 2: Projected Visibility Benefit 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 at these 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 to the SIP revision 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 SO2 are 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 to 2018. Sulfur dioxide reductions of more than 60 percent in the first of five tenyear planning periods are substantial. 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. (The four factor analysis considers the cost of reducing air pollution 

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.) 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) of the federal Regional Haze Rule requires each state to 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, SO2 is a primary 

component of haze in western Texas. Approximately one-third of sulfate pollutants come 

from the Ohio Valley and other states according to the 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, and the TCEQ reduced NOx emissions due to the ozone nonattainment in Texas, especially Houston, and not because reductions were made for regional 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 disagrees that CAIR makes no improvements for particulate matter, ozone, or 

regional haze. The projected CAIR reductions in NOx and SOz emissions are substantial. 

Because NOx and SOz react in the atmosphere to form nitrate and sulfate, which are 

components of particulate matter and regional haze, the NOx and SO2 reductions will lower 

concentrations of PM2.~ and regional haze. The further NOx reductions will produce lower 

ozone concentrations. 

Several individuals were disappointed in this SIP revision 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 SIP means that Guadalupe Mountains would not 

reach natural visibility until 2081, and Big Bend would not achieve natural 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 conditions 
is unreasonable for Class I areas like Big Bend and Guadalupe Mountains National Parks 

that are heavily impacted by international transport of regional haze. This is particularly 

so given EPA's acknowledgement in the rule's preamble that international transport has 

not been sufficiently addressed by their rule. Because the anthropogenic portion of the 

international transport cannot be expected to approach zero, it is not realistic to project a 

date for zero anthropogenic haze impacts at such Class I areas. Since there are substantial 

international transport impacts at Texas' two Class .I areas and there is not a reliable basis 

for projecting decreases in these impacts, Texas and other states would have to over control 

to compensate for the international impacts if the affected Class I areas were to have 

reasonable progress goals as low as the uniform rate of progress. The EPA's preamble to 

the federal Regional Haze Rule and EPA guidance clearly state that states are not expected 

to or required to impose such over control. No changes were 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 of coarse 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 

consultation with the FLMs and EPA as anthropogenic. The TCEQ must determine how much of 

the coarse mass and fine soil "comes primarily form natural dust storms and dust blowing form 

the Chihuahuan Desert" since much of this dust may be due to historical overgrazing or farming 

and therefore is human caused. Ecosystem restoration and reform of grazing and farming 

practices may be needed to reduce this human caused dust. 

The commission agrees that there is some anthropogenic contribution to coarse mass and 

fine soil at both Big Bend and Guadalupe Mountains National Parks. In response to recent 

discussions with the FLMs, Chapter 5 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. The commission has chosen to use the approximation that 100 

percent of the coarse mass and fine soil are natural for this first Regional Haze SIP revision. 

The Assessment of the Principal Causes of Dust-Resultant Haze at IMPROW Sites in the 

Western United States: Final Report, prepared for WRAP in 2006 by the Desert Research 

Institute and Marc Pitchford of the National Oceanic and Atmospheric Administration 

includes a map that shows the areas of the Chihuahuan Desert in West Texas to be 

moderately-to-highly wind erodible shrub land and grassland areas. The map does not 

show erodible areas from human activity. The areas of the Chihuahuan Desert in northern 

Mexico are not categorized and are outside United States control. 

The commission plans to consult with the FLMs and work to develop more refined , 

scientifically supportable estimates of the actual percentages of natural and anthropogenic 

portions of coarse mass and fine soil at Big Bend and Guadalupe Mountains for the fiveyear assessment and future revisions. 

The FS requested the SIP address the reason the time of compliance was not considered and 

points to the need for a source by source analysis. No calculations are provided to justify the 

conclusion. The concept that instituting controls near the 201 8 date would reduce the cost 

effectiveness in 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 SIP with a summary of a four factor analysis. A four factor 

analysis of source categories has been added to Chapter 10. The cost of controls and 

improvements to visibility impairment are summarized for each Class 1 area. The 
statement referencing timing of controls impacting the cost per ton has been removed from 

the SIP Appendix 10.1, Time for Compliance. 

The NPS and FWS were concerned the SIP revision 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 sources than 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 state is 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 that emissions from Texas do produce a significant minority 

of the visibility impairment at Salt Creek, White Mountain, Wichita Mountains, and Caney 

Creek Wilderness 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: 

The highest Texas contribution to extinction at one of these sites is 28.1 percent. The 

commission disagrees with the comment that Texas contributes a majority of the 20 percent 

worst days extinction to any Class I area in another state. Texas agrees that the PSAT 

modeling results show that Texas contributes more than the host state to extinction on the 

20 percent worst days at White Mountain, Wichita Mountains, and Caney Creek. 

2002 Contributions to Extinction on the 20 Percent Worst Days 

The commission agrees with displaying the details of Texas' impact reductions at these 

Class I areas and other Class I areas impacted by Texas' emissions. The tables showing 

Texas' pollutant-by-pollutant impacts on extinction for both the 2002 base period and the 

2018 planning year are now included in the consultation section of Chapter 11. These tables 

show the modeled impact of multi-state efforts to reduce visibility impairment at these sites. 

The commission 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'New Mexico does not 

mean that these states accept Texas' long term strategy as adequate for producing Texas' share of 

emissions reductions 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 its present 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. The consultation 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 SIP revision indicated the state of consultations at the time it was 

published. The commission concurs that the adopted SIP revision include documentation 

that it meets the requirements of §51.308(d)(3)(i) - (iii). The commission has sent individual 

letters to Louisiana, Arkansas, Missouri, Oklahoma, Colorado, and New Mexico to ask each 

to confirm in writing that Texas' emissions reductions strategy is adequate to meet Texas' 

apportioned reductions in impact at the impacted Class I areas. The commission also 

requested that recipients of the letters confirm they are not expecting any additional 

emission reductions from Texas sources. Formal replies were requested of the adjoining 

states within 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 emissions contained within the boundaries of the 

CENRAP modeling domain are important contributors to visibility impairment at Big Bend and 

Guadalupe Mountains. The NPS and FWS requested that Texas acknowledge the work contained 

in the final Big Bend Regional Aerosol and Visibility Observational (BRAVO) study. This 

extensive BRAVO study indicated sources in Mexico, Texas, and the eastern United States all 

play a role in sulfate conditions at Big Bend. The NPS 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 also requested that the SIP discuss the Texas 

contribution to sulfate found in the BRAVO field study in the long term strategy and reasonable 

progress sections. 

The commission agrees with this comment that the BRAVO results and their relationship to 

the CENRAP PSAT results warrant more discussion. The added discussion is included in 

Chapter 11. 

The EPA is concerned about the potential of the American Smelting and Refining Company 

(ASARCO) El Paso to affect visibility in Texas and New Mexico Class I areas. On February 13, 

2008, the commission approved the renewal of Air Quality Permit No. 20345 for ASARCO 

Incorporated. The EPA stated that with the Regional Haze SIP revision, the commission should 

ensure that ASARCO's impact assessment will 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 TCEQ void all air permits and pending 

applications for the plant. The TCEQ voided these permits and applications on February 9, 

2009 (See Appendix 11-4: ASARCO El Paso). The TCEQ will continue to consult with 

affected states and Federal Land Managers on surrounding Class I areas of concern. 
The NPS and FWS commented on the uncertainty of CAIR implementation. The NPS and FWS 

requested that tlie co~nmission be more proactive in response to the 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 of participating CAN sources to 

commit to particular emissio~levels, it is concerning that Texas has elected to wait and see how 

the uncertainty unfolds as part of the 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 

201 8 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. The NPS 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 are contributors to visibility 

for the Class I areas and that these electric generating units are covered by the provisions of 

CAIR as well as other state requirements. There are uncertainties associated with 

prediction because of the cap and trade provisions of the program. The predicted levels 

used in the model were from the EPA's Integrated Planning Model, a tool widely used in 

regional planning. The predictions are based on assumptions applicable at the time the 

model is constructed, including fuel prices, fuel availability, and regulatory policies. The 

commission acknowledges the 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 or its 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 during the CAIR time 

frame or equivalent time. The list of sources can be found in Appendix 10-1, Tables 6 to 10, 

and the area of influence maps are in 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 

the New 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 Sierra Club 

petition that docutnents the inadequacy of the TCEQ's PSD permitting program. 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 PSD/NSR efforts. 
The commission 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 adequate opportunity 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. Changes were made in Chapter 11, Section 11.6.3 in response to 

comments. 

The FS 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 the FLMs and surrounding states regarding NSR. Including resolution of 

this issue in the SIP would greatly strengthen the position that clean days are being maintained. 

The commission has commented on EPA rulemaking about PSD 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 the FLMs on mutually acceptable criteria for 

determining when a proposed PSD source should conduct a Class I review" (see Appendix 

4-3). 

- Fire 

The NPS, 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 EPA Region 6, the EPA prefers inclusion of the smoke 

management plans in the appendix. The smoke management plans contained in the 

Regional Haze SIP revision are for reference purposes. The commission considers the FS's 

flexibility to update the smoke management plans unhindered by inclusion in the Texas SIP. 

Agricultural burning does occur in Texas. Local and state ordinances regulate burning 

through fire permits. Texas has 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 Texas Forest Service tracks 

burning in Texas. 

The NPS and FWS commented that it is appropriate for the TCEQ to declare smoke plans as a 

contributing program for visibility protection, but neither the state or CENRAP evaluated 

performance resulting from this or any specific smoke management component. If the state 

wants to speak to 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. 

The commission 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 due to the low smoke contribution from 

Texas to regional haze at the 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 1998 EPA Interim Air Qualiv Policy on Wildland and Prescribed 

Fire. 

The commission does not intend to certie its 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 federal Regional Haze Rule or is a necessary part of this SIP revision because of 

the minimal 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 

to remain the same looking 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 or owner of land determines whether to conduct prescribed burning. Concerning 

the estimate of change in impact, the general increase in use of well controlled prescribed 

burning to prevent catastrophic wildfire may increase low concentration impacts and 

reduce high impact events. The commission 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 smoke management 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. 

The commission agrees that there are additional smoke management plans besides those 

listed as examples in Chapter 11. The plans referenced in the SIP include Class I areas in 

Texas and a number of larger jurisdictions. The commission does not consider an 

exhaustive listing of specific plans necessary as part of the Regional Haze SIP revision given 

the minimal impact fires are expected 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 of the 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 if the TCEQ knows where the problems exist. Since CENRAP 

modeling did not differentiate between boundaries, the commenter suggested that the TCEQ 

acknowledge that some of the air pollution 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 winds 
transport it to Texas. The satellite fire channel data clearly show the locations of the fires. 

This is the only major source the TCEQ has 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 or crop stubble fires along the Texas and 

Louisiana coastal areas moves directly to impact nearby areas. Sometimes the trajectory 

takes the smoke a relatively short distance over the Gulf of Mexico. Marsh grass or crop 

stubble fires are not 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 are usually associated with 

rapidly moving cool or cold fronts and are moving too quickly to accumulate much 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 specifically mention that the SIP review and revision 

will involve consultation with 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 individuals commented that no new air pollution control strategies 

were added to this SIP revision and requested controls be added specifically to 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 SIP revision (see 30 TAC $116, Subchapter 

M or Appendix 9-2). The commission agrees that Chapter 11 does cite rules and programs 

that have been in place that have reduced regional haze as well as other 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 to be 

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 states that have adopted CAIR requirements may already 

have sufficient reduction requirements on the books for the first 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 air pollution 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 commented that additional progress on cleaning up Texas' dirty air is possible if 

legislators from Texas use their clout in Congress to force Mexico to comply with its obligations 

to control emissions from coal-fired plants in Mexico. 

The commission 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 emissions inventory 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 

CElMlAP Region and Table 7-5: Nine-State CENRAP Total Emissions by Category for a 

state level comparison of the emissions. For a discussion on impacts, the reader is referred 

to Chapter 10. Impacts from emissions on the Class I areas are discussed in Chapter 10 and 

are discussed from the state as a whole, not by geographical region. 

One individual commented that this Regional Haze SIP revision should be withdrawn and revised 

to incorporate reductions in regional haze emissions over the next five years. If this is not done, 

the EPA should start the sanctions clock and in 18 months EPA should apply highway sanctions 

and require 2: 1 offsets for regional haze emissions until an acceptable SLP is approved. 

The commission disagrees with these comments. The commission is submitting a Regional 

Haze SIP revision that meets the requirements of 40 CFR 551.308. 

One individual commented that with the uncertainty that the modeling provides it seems prudent 

that Texas make reductions now so that there will not be delayed regional haze attainment. There 

is no doubt that reductions must be made since on page 10-6, TCEQ implies that at least 48 

percent for Big Bend and 75 to 80 percent for Guadalupe Mountains of the visibility impairment 

comes from 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 issue with 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 other known states. The EPA and other 

federal agencies are working 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 commission was missing an opportunity to demonstrate a 

commitment to air quality cleanup in one of the most culturally, historically, and naturally 

important parts of our state. The failure to clear the air in Big Bend and Guadalupe Mountains 

translates into continued regional haze problems for state-owned lands such as Big Bend Ranch 

State Park, Davis Mountains State Park, and other such areas, which increasingly are of interest 

for outdoor recreation for Texas urban populations. The Sierra Club saw no real commitment on 

the part of the commission to address the deficiencies in the proposal. 

This SIP revision 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 are anticipated. 

The FS appreciated that Texas documented coordination with the FLMs and abandoned one 

approach based on FLM recommendations. The FS looks forward to continued consultation in 

the future. 
The commission appreciates the comment and looks forward to a continued and 

collaborative relationship with the FLMs in the future. . 

The NPS and FWS appreciated the discussion of relative response factors and the two methods of 

applying relative response factors created 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 Guadalupe Mountains, 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 of those other impacted Class I areas to provide balance to Chapter I. 

Chapter 1 is devoted to background information and an overview of regional haze and 

describes those Class I areas within Texas that are impacted. The commission addressed 

Class I areas located in other states within Chapters 4,10, and 11. The commission made 

no changes to this SIP revision. 

The NPS and FWS commented that the Executive Summary says, "This SIP revision contains a 

list of BART-eligible sources and the determination of BART for each source that is reasonably 

anticipated to contribute to visibility impairment (BART-subject)." The NPS 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 of tbe 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 are listed in Chapter 9 and Appendix 

9-13. In addition, there is a list of sources that reduced their potential to emit through 

permit amendments, or shut 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 due to past emission reductions required by 

state law 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 SIP revision. 

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 changes were 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 able to 

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 for those who come after us. One individual commented 

that Big Bend has the honor of being a Biosphere Reserve under the United Nations Educational, 

Scientific and Cultural Organization (UNESCO) Man and Biospl~ere Program accentuating the 

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. 

The NPS 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 SIP that any other states have adopted Texas' alternative 

natural conditions calculation approach. The commenters requested that this SIP revision 

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 any other state at this time. Texas fully respects the right of all states to determine the 

natural conditions for their respective Class I areas. The phrase "and other states" has 

been removed from the referenced sentence in response to this comment. 

The NPS 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 of Texas' SIP proposal. 

On January 2,2008, 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 sewer without 

their permission, but encourages the commenter to sign up with all the e-mail updates on 

SIP hot topics; over 30 topics are now available through the new GovDelivery sewice as of 

Fall 2007 (www.tceq.state.tx.us). 

The EPA commented that the TCEQ should ensure that 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 are addressed in the SIP revision. The commission will submit the checklist 

to the EPA with the adopted SIP package. 

The EPA 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 able to conduct a thorough 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 of time or resources to do a thorough critique of the proposed 

Regional Haze SIP revisions because the commission did not address the deficiencies in the 

proposal. 

This SIP revision 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. The commission was not made aware of the EPA's need for paper 

versions prior to the close of this comment period. Upon submission for review and 

approval, the EPA will receive paper copies of this SIP revision. The commission 

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 SIP revision a commitment to update the emissions inventory of pollutants that are 

reasonably anticipated to cause or contribute to 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 air emissions 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 comments on 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 of the CAMx modeling done for 

screening out sources, but due to time and resource constraints, the EPA has not been possible to 

conduct a completely thorough review, particularly with regard to modeling. It is possible that 

additional concerns, not discovered during the review of this draft, will surface during the review 

of the final version of this 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 environmental agencies. 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 

of the 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. 
The commission considers the SIP revision published for comment was complete and 

appropriate for 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 are released 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. The elevated 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 of the same sources of pollution that affect the skies of the 

national parks in West Texas affect the air in cities elsewhere in the state. Aggressive cleanup of 

these sources will certainly benefit both, and the failure to take protective actions to clean up air 

quality from these sources will harm both. 

The commission is currently working to maintain health-effect standards as demonstrated 

by the state's current attainment for PM fine standards. Current nitrogen oxide and sulfur 

reductions obtained by programs such Senate Bill 7 benefit both the health-effect standards 

and visibility across the state. Any additional controls implemented for purposes of 

visibility only are not considered cost effective at this time. 

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

individuals commented that the SIP is 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 sources in 

Texas that are contributing to the problem. CLEAN agreed with the Sierra Club that the 

commission should reduce 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 

five years; five years is not reasonable. 

The commission 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 10 has been updated with a 

more detailed 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 are being 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. 

Significant cost-effective control strategies are already being implemented in Texas to 

control ozone. These strategies have been included in Texas' ozone SIP modeling. In 

addition to controlling ozone formation, the planned emissions reductions will also have a 
co-benefit of improving visibility impairment in Class I areas in Texas and nearby states 

by the reduction of sulfur dioxide and nitrogen oxides. 

Because of the timing of various rule adoptions, not all of the following rules listed are in 

CENRAP's 2018 model. Those strategies included in CENRAP modeling are identified 

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 that were effective after 2002 and prior to 2018 are listed as follows. 

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 $101 system-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 Interstate Rule (CAIR) 

*30 TAC $117 nitrogen oxide unit specific limits 

*30 TAC $101 system-wide averaging caps 

West Texas 

*30 TAC $101 SB7 nitrogen oxide caps with trading 

Point Source Controls - Non-Electric Generating Units 

Statewide 

*Site specific Refinery Consent Decree sulfur dioxide levels 

Houston-Galveston 

"nitrogen oxide Mass Emissions Cap and Trade (MECT) 

*Highly-Reactive VOC (HRVOC) Emission Cap and 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) surface coating VOC controls 

East Texas 

"30 TAC $117 Cement Kiln nitrogen oxide limits 

*Agreed OrdersIConsent decree sites specific reductions at Alcoa 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 for Ellis, Johnson, Kaufman, Parker, Rockwall counties 

VOC reductions from Stage I vapor recovery 
VOC reductions from surface coating processes 
On-Road Mobile Source Controls 

Statewide 

*sulfur dioxide reductions from low sulfur diesel fuel 

nitrogen oxide reductions from TrLED 

Nonattainment areas 

*Vehicle inspection and maintenance 

TERP nitrogen 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 

TERP nitrogen oxide reductions 

A proposed control strategy for regional haze with 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 are not reasonable at this time. This will be 

reconsidered in future SIP revisions. 

The Sierra Club and many individuals urged the commission to withdraw its proposed Regional 

Haze SIP and develop a new plan for addressing the regional haze problem to submit to the EPA. 

The Sierra Club found the proposed Regional Haze SIP revisions inadequate and insisted that the 

commission take responsibility to address the visibility issues at Big Bend and Guadalupe 

Mountains. Many individuals urged the commission to include specific air pollution control 

measures that go beyond existing rules so that Texas can move closer toward the national goal to 

clear the air in Texas and national parks in neighboring states. 

The commission does not plan to withdraw the proposed Regional Haze SIP revision. 

Significant cost-effective control strategies are already being implemented in Texas to 

control ozone. As part of these strategies, nitrogen oxides emissions will be reduced. State 

control measures required under Senate Bill 7 reduce both sulfur dioxide and nitrogen 

oxides at electric generating units. These control strategies will also reduce the emissions 

that contribute to visibility impairment in Class I areas. These strategies are anticipated 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 

for regional haze are not 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 involvement of 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 SIP developments. 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 sir 
adjacent 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 SIP list sewer with over 500 participants 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 SIP was published 

in the Texas Register on December 21,2007. 

In addition to the health concerns in the areas of Dallas, Houston, San Antonio, and El Paso, one 

individual is concerned with the effects of air pollution on the investments in McDonald 

Observatory that will be seriously impacted by continued inaction. 

Although the Regional Haze SLP revision addresses haze impacts only at Class I areas in 

Texas and neighboring states, the commission anticipates that reduction in haze-causing 

emissions and activities will also benefit visibility 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 of natural visibility by 2064. The Sierra Club was disappointed with the 

inadequacy of the Regional Haze SIP revisions 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 air and reducing haze in public wilderness 

areas, national parks, and throughout Texas. Texas has significant cost-effective control 

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 are a cost-effective, reasonable approach to reducing visibility 

impairment. The commission's analysis concludes that additional controls for regional haze 

are not reasonable at this time. This will be reconsidered in future SIP revisions. 

Corrections 

The EPA commented that Tables 8,9, and 10 of Appendix 10-1 were truncated. The FS 

commented that 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 FWS for identifying these errors. The 

corrections to Appendix 10-1 were made to the SIP revision and posted on the TCEQ 

regional haze Web site in February 2008. The Chapter 8 figure caption has been corrected 

to indicate that model results are from 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 staff was made aware of the omission. The park names were correct 

throughout the document. The ftp site is not a state Web site and the reference is not 

critical for the appendix, so the link has been deleted due to problematic access.