# Iowa State Implementation Plan
for the Regional Haze Five-Year Review

Iowa Department of Natural Resources Environmental Services Division Air Quality Bureau 7900 Hickman Rd Suite 1 Windsor Heights, IA 50324

July 9 , 2013

## Table of Contents

i. Letter from Director

..................................................................................................................... 3

ii. E xecutive Summary

...................................................................................................................... 4

iii. I ntroduction

................................................................................................ ................................ . 5

iv

. Summary of the Initial Regional Haze SIP

..................................................................................... 7

v. F ederal Actions Affecting the Initial Regional Haze SIP

................................................................ . 8

1. Reg ional Haze Periodic Reports

.................................................................................................... 9

40 C FR 51.308(g)(1 ): Status of Measures in SIP

................................................................................... 9

BART and CAIR

................................................................................................ ................................ . 9

State Programs

............................................................................................................................... 10

Federal Programs

........................................................................................................................... 10

2. 40 CFR 51.308(g)(2): Emissions Reductions

................................................................................ 12

3. 4 0 CFR 51.308(g)(3): Visibility Conditions

................................................................................... 14

4. 40 CF R 51.308(g)(4): Emissions Tracking

.................................................................................... 15

5. 4 0 CFR 51.308(g)(5): Progress Assessment

................................................................................. 18

6. 40 CF R 51.308(g)(6): Assessment of Elements to Meet RPG

....................................................... 20

El ectricity Generation

......................................................................................................................... 20

New Regulations

................................................................................................ ................................ . 21

Conclusions

................................................................................................ ......................................... 22

7. 40 CFR 51.308(g)(7): Visibility Monitoring

.................................................................................. 23

8. 40 CF R 51.308(h): Determination of Plan Adequacy

................................................................... 24

9. S takeholder Input

...................................................................................................................... 25

F LM Consultation

................................................................................................ ................................ 25

Public Notice

................................................................................................ ....................................... 25

Appendix A. Source Apportionment Review

................................................................................... 26

Appendix B. MAC T Review

............................................................................................................. 36

Appendix C. Emissions Data Compilation

........................................................................................ 38

Appendix D. FLM and Public Comments

.......................................................................................... 47

Comments from the USDA Forest Service

.......................................................................................... 47

Comments from the National Park Service

........................................................................................ 49

C omments from EPA Region 7

............................................................................................................ 50

Comments from the Minnesota Pollution Control Agency (MPC A)

................................................... 50

Public Notice Documents

.................................................................................................................... 52

Appendix E. Legal Authority

........................................................................................................... 55

2

## ii. **Executive Summary**

Congress added the national goal of preventing any future and remedying any existing impairment of visibility at mandatory Class I Federal areas in the 1977 Clean Air Act Amendments . The Regional Haze
Rule (RHR) was promulgated in July 1999 (64 FR 35714, July 1, 1999) to furth er Congress’s national goal

, and established regulations to eliminate manmade visibility impairment in Class I areas by 2064

. Nationally there are 156 mandatory Class I Federal areas (Class I areas) but none are located in Iowa. This does not exempt Iowa from regional haze regulat ions as the pollutants which contribute to visibility impairment can be transported long distances.

Regional haze is a form of visibility impairment not directly attributable to a single source but occu rs as a result of emissions of air pollutants from numerous so urces located over a wide geographic area. The Regional Haze R ule and related regulations (40 CFR 51.308 and Appendix Y to Part 51) conta ined provisions that encouraged state, local, and tribal agencie s to work cooperatively within reg ional planning organizations (RPOs) to address visibility impairment. Five RPOs were created for this purpose. Iowa was part of the Central Regional Air Planning Association (CENRAP )

, originally comprised of nine
states in the c entral U.S

.

On March 25, 2008, the Iowa Dep artment of Natural Resources ( DNR ) submitted to the U.S.

Environ mental Protection Agency (EPA ) a state imple mentation plan (SIP) for the initial period of the Regional Haze Rule

. The DNR concluded emissions in Iowa may contribute to visibility impairment at the
Northern Midwest Class I areas

, which consist of two Class I areas in Minnesota ( Boundary W aters
Canoe Area Wilderness and Voyageurs National Park ) and two Class I areas in Michigan ( Seney
Wilderness Area and Isle Royale National Park )

. The initial regional haze SIP was developed considering the reasonable progress goals of the Northern Midwest Class I areas, consultation with stakeholders including Federal Land Managers and the sta tes of Minnesota and Michigan, Iowa’s role in visibilit y impairment , and applicable regulations.

Emissions of sulfur dioxide ( SO2 ) and nitrogen oxides ( NOx ) from larger point sources were generally identified as the types of sources contributing to the average worst visibility impairment in Class I areas
in the Midwest. Iowa’s participation in the Clean Air Interstate Rule (CAIR) , a cap and trade program
aff ecting larger fossil

- fuel fired power plants, was a significant component of the state’s long

- term strategy

. T he initial regional haze SIP also relied upon CAIR to satisfy Best Available Retrofit Technology (BART) requirements for electrical generating un it (EGU) SO2 and NOx emissions

. A review of other BART eligible sources and emissions concluded that no source specific BART emissions limits were needed.

Provisions of the Regional Haze Rule contained in 40 CFR 51.308(g) and (h) require that each stat e submit a progress report five years after the submittal of their initial regional haze SIP

. The progress reports must be in the form of a SIP revision and must include a determination regarding the adequacy of the existing regional haze SIP

. This docum en t h as been prepared to fulfill all applicable requi rements pertaining to the five year progress report of the initial regional haze SIP

. T he D NR concludes the current regional haze SIP is sufficient to address the reasonable progress goals of the Northern Midwest
Class I area s . The D NR is also providing to EPA a negative declaration that further revision of the existing implementation plan is not needed at this time. T his finding is based upon reductions in Iowa of anthropogenic NOx and SO2 emiss ions

, the magnitude of these reductions, and existing federal regulations

.

4

## iii. **Introduction**

On March 25, 2008, the Iowa Depart ment of Natural Resources ( DNR) submitted to the U.S. Environmental Protection Agency (EPA) a revision to Iowa’s s tate implementati on p lan (SIP) to address
the first implementation period of the regional haze program

. 1 The Regional Haze Rule was promulgated in July 1, 199 9 (64 FR 35714 ) and established the first regulations governing visibility impairment attributable to widespread and numerous sources

. P revious vis ibility regulations addressed nearby sources by regulating plume blight. T he Regional Haze Rule encompassed all types of sources significantly contributing to visibility impairment

.

T he Clean Air Act (CAA) provide s EP A with the authority to regulate visibility impairment . In the 1977

CAA Amendments Congress added the national goal of preventing any future and remedying an y exis ting impairment of visibility at mandatory Class I Federal areas. A map of the 156 mandator y Class I
Federal areas (Class I areas) is provided in Figure 1

- 1

. There are no Class I areas in Iowa, nor are there any Class I areas within 300 km of Iowa’s borders. However, the pollutants which contribute to regional haze can originate over diverse geographical regions and travel many hundreds of miles. While sources

nearer to Class I are as are initially expected to be more important contrib utors to visibi lity degradation
than similar sources located further away, the regional haze regulations (see 40 CFR 51.308) cover a time horizon of many decades, until at least 2064, at which point manmade visibility impacts are to be mitigated at Class I areas . Simply stated, the goals of the regional haze program are achieved when visibility conditions at Class I areas have return ed to natural conditions. The prospective longevity and

scope of the regional haze regulations cast a broad range of potential obligations across a n extended timeline. It is therefore possible for the requirements of the regional haze regulations to include states, such as Iowa, which are not near any Class I area s

.

Figure 1

- 1 . Map showing the location of the mandatory Class I Federal areas.

1 Available at: http://www.iowadnr.gov/InsideDNR/RegulatoryAir/RulesPlanning.aspx

5The Regional Haze Rule called for a cooperative approach involving state, federal, and tribal participants to address visibility impairment. Five regional planning organizations (RPOs) , shown in Figure 1

- 2

, were formed to assist in the development of work products needed to understand and address visibility impairment. When formed t he Central Regional Air Planning A ssociation (CENRAP) included Iowa and eight other states (Arkansas, Kansas, Louisiana, Minnesota, Missouri, Nebraska, Oklahoma, and Texas) in the central p ortion of the U.S.

Figure 1

- 2 . Geographical a reas of Regional Planning Organizations

.

Technical analyses and interstate consultation forums provided through CENRAP and other RPOs assisted the DNR in the development its initial regional haze SIP

. Within the initial regional haze SIP t he

DNR provided a long

- term strategy to fulfill the req uirement of 40 CFR 51.308(d)(3 ), addressed the Best Available Retrofit Technology (BART) regulations codified at 40 CFR 51.308(e), and satisfied the other applicable requirements found in 40 CFR 51.308.

The regional haze implementation process requires the submittal of a progress report five years following the submittal of the initial regional haze implementation plan . Progress reports are also due five years following all subsequent c omprehensive regional haze SIP revisions . This document
constitutes the DNR’s five

- year progress report on the initial regional haze SIP. It is in the for m of a SIP
revision and fulfills all applicable obligations required by 40 CFR 51.308(g) and 51.308(h ). The first comprehensive r evision to the regional haze SIP is due July 31, 2018.

6

## iv. **Summary of the Initial**  **Regional Haze SIP**

Two significant components of Iowa’s initial regional haze SIP included B est Available Retrofit Technology ( B ART ) requirements and the state’s long

- term strategy. A combination of federal equivalency determinations and local analyses were used to conclude that no BART

- eligible sources in
the state were subject to source specific BART limits

. On July 6, 2005, EPA published a final rule ( Regional Haze Regu lations and Guidelines for Best Available Retrofit Technology (BART) Determinations

, 70 FR 39104 ) w hich allowed electrical gene rating units (EGU s ) participating in the cap and trade provisions of the Clean Air Interstate Rule (CAIR) (70 FR 25162, May 12 , 2 005 ) to serve as a substitute for

BART for EGU NOx and SO2 emissions

. T he state utilized this option to satisfy most BART requirements
associated with EGUs and also included participation in CAIR as a component of the state’s long

- term strategy. D irect particulate matter emissions from EGUs were reviewed separately and found not to cause or contribute to visibly impairment at a Class I area

. BART requirements for non

- EGU sources were evaluated using a v ariety of analyses. The weight

- of

- evidence B ART analysi s concluded that no

non

- EGU BART eligible sources were subject to BART

.

The state developed a long

- term strategy to address Class I area s located outside the s tate which may
be affected by emissions from Iowa, as required by 40 CFR 51.308(d)(3 ). Development of the long

- term strategy and fulfillment of other regional haze obligations included consulting with downwind states containing Class I areas. The state participated in discussions involving Class I areas in the states of
Missouri and Ark ansas and was invited to discussions led by Oklahoma. Emissions in Iowa were
determined not to be contributing to visibility impairment in the Class I areas in Oklahoma or to any
Class I area in either Missouri or Arkansas.

T he DNR also participated in t he Northern Midwest Class I Are a Consultation Group, which was coordinated by the states of Minnesota and Michigan . Two Class I areas are located in Minnesota, the Boundary Waters Canoe Area Wilderness (BOWA) and Voyagers National Park (VOYA). Michigan a lso

contains two Class I areas

, Isle Royale National Park (ISLE) and Seney Wilderness Area (SENE). Collectively these four class I areas are referred to as the Northern Midwest Class I areas.

Photochemical modeling conducted by CENRAP

, using particulate matter source apportionment (PSAT) techniques

, indicated approximately 4

- 5% of the total modeled visibility impairment in both 2 002 and
2018 in each of the four Northern Midwest Class I areas was associat ed with emissions in Iowa. These
limit ed contributions were primarily attributable to SO2 and NOx emissions from elevated point sources.

A review of the source apportio nment results is provided in Appendix A for convenience

.

The DNR concluded emissions in Iowa may contribute to visibility impairment at the Northern Midwest
Class I areas

. Iowa’s long

- term strategy relied upon a combination of existing state and federal regulations to achieve a ‘fair s hare’ of emissions reductions necessary to meet the reasonable progress goal (RPG) established for each Northern Midwest Class I area

. On

- going emission control programs considered in the long

- term strategy included , for example, the state’s minor and major n ew source review (NSR) programs, and measures mitigating the imp acts of construction activities

. Federal programs considered in development of the long

- term strategy included the 2007 heavy

- duty highway
di esel rule, Tier 2 vehicle and gasoline sulf ur p rogram, cl ean air nonroad diesel rule, pertinent new source performance standards (NSPS), national emissions standards for ha zardous air pollutants (NESHAP) and associated maximum achievable control technology (MACT) standards, and CAIR

. These
lists a re not exhaustive but compromise the substantial components of the long

- term strategy

. A comprehensive discussion of the long

- term strategy can be found in the initial regional haze SIP

.

7

## v. **Federal Actions Affecting the Initial**  **Regional Haze SIP**

On December 23, 2008, roughly nine months after the DNR submitted the initial regional haze SIP, the U.S. Court of Appeals for the District of Columbia (DC Circuit Court of Appeals) issued a ruling remanding

CAIR . The remand left CAIR in place while directing EPA to development a replacement rule . The Court’s ruling was significant to Iowa’s regional haze S IP as CAIR was used to satisfy the BART requirements related to SO2 and NOx emissions from EGUs and was also relied upon as a component of the state’s long

- term s trategy.

During the interim period when CAIR remained in place

, while a replacement rule was being developed, EPA did not take action on the state’s regional haze SIP. On August 8, 2011 (76 FR 48208 ), the final rule “Federal Implementation Plans: Interstate Transport of Fine Particulate Matter and Ozone and Correction of SIP Approvals” was promulgated as the CAIR replace rule. This rule, commonly referred to
as the Cross Sta te Air Pollution Rule (CSAPR), also used a cap

- and

- trade approach to reduc e emissions of

NOx and SO2 from EGUs in the (mostly) eastern portions of the U.S.

On November 9, 2011

, EPA agreed to a schedule for taking action on 45 r egional h aze SIPS. The final Consent Decree required EPA to propose action on Iowa’s regional haze SIP by February 15, 2012, and take final action by June 15, 2012. O n June 7, 2012 (77 FR 33642) EPA published a final rule prov iding limited disapproval of Iowa’s (and many other state’s) regional haze SIP

. T he limited disapproval applied only to those p ortions of the regional haze SIP tied to (the remand of) CAIR; EPA disapproved the state’s

use of CAIR as a substitute for BART for NOx and SO2 emissions from EGUs, and the use of C AIR in the long

- term strategy.

In the same final rule (77 FR 3364, June 7, 2012) EP A promulgated a Federal Implementation Plan (FIP)
for Iowa which addressed the portions of the regional haze SIP disapproved for their reliance upon CAIR

. The FIP essentially substituted CS APR in lieu of CAIR in the long

- term strategy and to sa tisfy EGU B ART obligations r elated to NOx and SO2 emissions

. On June 26, 2012 (77 FR 38006), EPA finalized a limited approval of Iowa’s SIP for all other regional haze elements not addressed in the June 7, 2012 action . The
final rule approved the BART de terminations for non

- EGUs and EGU direct particulate matter emissions

, and components of the long

- term strategy not associated with CAIR

.

On August 21, 2012, a three judge panel of the DC Circuit Court of Appeals issued a 2

- 1 ruling which
vacated CSAPR an d remanded the rule to EPA, while leaving CAIR in place until supplanted . On October 5, 2012, EPA filed a petition with the U.S. Circuit Court of Appeals for the DC Circuit for a rehearing en banc of the court’s August 21, 2012

, CSAPR decision . Three add itional petitions for rehearing were also filed by other parties. On January 24, 2013, the D.C. Cir cuit Court of Appeals denied all petitions for rehearing en banc. Consequently the CSAPR vacature currently stands and CAIR continues to remain in
effect. Despite the litigation and the ongoing uncertainty associated with the appeal to the U.S. Supreme Court

, the DNR is still required to submit a five

- year progress report on the initial regional haze

SIP.

8

## 1. **Regional Haze Periodic Reports** 

The general purpose of the five

- year review is to evaluate progress towards the reasonable progress goal s of each mandatory Class I Federal area (Class I area) which may be affected by emissions from
within the State . The progress reports are periodic in that they are due five years following the submission of the initial regional haze SIP and every five years following submission of a comprehensive regional haze SIP revision. The progress report must be in the form of an implementation plan revision
that complies with the procedural requirements of 40 CFR 51.10 2 and 51.103. The regulatory criteria for the progress reports ar e codified in 40 CFR 51.308(g) and (h). While Iowa does not contain a Class I area, this reduces but does not eliminate the applica ble requirements. The specific elements whic h
must be addressed in the five

- year progress report for a state without a Class I area are addressed throughout the remainder of this document.



### 40 CFR 51.308(g)(1): **Status of Measures in SIP**

40 CFR 51.308(g ) ( 1) requires that the five

- year periodic report contain: “ A description of the status of implementation of all measures included in the implementation plan for achieving reasonable progress goals for mandatory Class I Federal areas both within and outsid e the State. ”

L ong

- term strategies developed for the initial regional haze SIP s were to include all measures relied upon by a state to achieve the reasonable progress goals of Class I areas affected by their emissions.

Iowa ’s long

- term strategy was broad in scope to ensure it encompassed all ongoing state and federal

programs reducing the types of air pollutants that might be associate d with visibility impairment.

A dditional factors listed in 40 CFR 51.308(d )(3)(v) such as smoke management plans, source retirements and replacements

, emissions limits, and the net effect upon visibility from projected changes in emissions from anthropogenic emissions over the period addressed by the long

- term strategy , were also required components of the long

- term strategy

. Not all items included in Iowa’s long

- term strategy are expected to significantly influence visibility impairment in a Class I area but were included for completeness

. A review of all applicable measures either specifically 2 identified by the regional haze regulations or of greatest relevance to the reasonable progress goals of the Northern Midwest Class I areas is provided below

. 3

**BART and CAIR** Compliance with the BART requirement s for NOx and SO2 emissions from EGUs was sought through participation in CAIR. Participation in the CAIR cap and trade program was also a significant component of the state’s long

- term strategy an d was expected to yield EGU NOx emissions reductions and
moderate

, if not reduce

, SO2 emissions . Wh ile CAIR was remanded by the DC Circuit Court of Appeals,

as previously discussed the CAIR rule remains in effect and sources in Iowa continue to comply with the

state (see 567 Iowa Administrative Code Chapter 34) and federal requirements associated with C AIR.

No non

- EGU BART sources were found to be BART eligible and therefore no BART specific emissions limits were developed.

2 Such as the requirement that long

- term strategies must consider measures to mitigate emissions from

construc tion activities (51.308(d)(3)(v)(B)) and smoke management plans (51.308(d)(3)(v)(E)).

3 Not all measures reviewed are considered significant in terms of visibility impairment, but are once again included for completeness.

9**State Programs** No source specific or unit specific emissions limits or compliance schedules were developed for the regional haze S IP. The DNR continues to implement a major source Prevention of Significant Deterioration (P SD ) permitting program and a minor source review program

. The DNR’s rules on fugitive dust (567 IAC 23.3(2)“c”) , which apply to construction activities, continue to require that reasonable precautions shall be taken to prevent the discharge of visible emissions of airborne dust beyond the lot line of the property fro m which the emissions originate.

The DNR has developed a prescribed fire policy to address how the DNR conducts prescribed burning on state, federal, and private lands for which the agency has management authority

. The fire policy addresses smoke monitoring and minimizing the impacts from smoke and requires a smoke
management plan. However, Iowa currently burns less than approximately 30 ,000 acres per year on

average , which is considera bly less than most other states, and f ires in Iowa were not identified as contributing to visibili ty impairment in Class I areas

. Within the c ontext of the Regional Haze Rule changes in emissions resulting from smoke management plans for prescribed fires in Iowa are not significant and are expected to have no discernible impact on visibility impairment in Class I areas.

**Federal Programs 4** 
The em ission reductions associated with the federal programs that are described by the following paragraphs were included in the CENRAP future year emissions estimates. Descriptions contain qualitative assessments of emissions reductions associated with each pr ogram, and where possible, quantitative assessments

. A discussion of M aximum Achievable Control Technology (M ACT ) standards is provided in Appendix B

.

2007 Heavy

- Duty Highway Rule (40 CFR Part 86, Subpart P) In this regulation EPA set a particulate matter (PM) emissions standard for new heavy

- duty engines of 0.01 g/bhp

- hr, which took full effect for diesel engines in the 2007 model year. This rul e also included
standards for NOx and non

- methane hydrocarbons (NMHC) of 0.20 g/bhp

- hr and 0.14 g/bhp

- hr, respectively. These diesel engine NOx and NMHC standards were successfully phased in toge ther
between 2007 and 2010. The rule also required that sulfur in diesel fuel be reduced to facilitate the use of modern pollution

- control technology on these trucks and buses. The EPA required a 97 percent
reduction in the sulfur content of highway dies el fuel

-- from levels of 500 ppm (low sulfur diesel) to 15 ppm (ultra

- low sulfur diesel). These requirements were successfully implemented on the timeline in the regulation.

Tier 2 Vehicle and Gasoline Sulfur Program (40 CFR Part 80, Subpart H; 40 CFR Part 85; 40 CFR Part 86)
The EPA’s Tier 2 fleet averaging program for on road vehicles, modeled after the California LEV ( Low Emissions Vehicle) II standards, became effective in the 2005 model year. The Tier 2 program allows manufacturers to produce veh icles with emissions ranging from relatively dirty to very clean, but the mix
of vehicles a manufacturer sells each year must have average NOx emissions below a specified value. Mobile emissions continue to benefit from this program as motorists replace o lder, more polluting
vehicles with cleaner vehicles.

4 The majority of the text for thi s section courtesy of the South Carolina Department of Health and Environmental

Contro l, “ Regional Haze State Implementation Plan Periodic Report, ” December 28, 2012.

10Clean Air Nonroad Diesel Rule (40 CFR 89; 40 CFR 1039) The EPA adopte d standards for emissions of NOx , hydr ocarbons, and carbon monoxide from several groups of nonroad engines, including industrial spark

- ignition engines and recreational nonroad
vehicles. Industrial spark

- ignition engines power commercial and industrial applications and include forklifts, electric generators, airport baggage transport vehicles, and a variety of farm and construction applications. Nonroad recreational vehicles include snowmobiles, off

- highway motorcycles, and all

terrain vehicles. These rules were initially effective in 2004 and were fully phased in by 2012.

The nonroad diesel rule set standards that reduced emissi ons by more than 90 percent from nonroad diesel equipment and, beginning in 2007, the rule reduced fuel sulfur levels by 99 percent from previous
levels. The reduction in fuel sulfur levels applied to most nonroad diesel fuel in 2010 and applied to fuel

u sed in locomotives and marine vessels in 2012.

11

## 2. **40 CFR 51.308(g)(2): Emissions**  **Reductions**

40 CFR 51.308(g)(2) requires : “ A summary of the emissions reductions achieved throughout the State through implementation of the measures described in paragraph ( g)(1) of this section

. ”

T he requirements of 51.308(g)(2) are best m et quantitatively b y a review of changes in NOx and SO2

emissi ons from EGUs

. 5 The CAIR rule encompasses significant aspects of the state’s initial regional haze

SIP. 6 Emissions of SO2 and NOx from elevated point sources are responsible for most visibility impairment attributable to Iowa at the Northern Midwest Class I areas on the 20% worst impaired days (see Appendix A ); and b ased upon an emissions inventory review of the 2008 NEI (version 2), most point
source NOx and SO2 emissions in Iowa are associated with EGUs ( see Chapter 4 ).

Emiss ions data for EGUs affected by CAIR were obtained from EPA’s Clean Air Markets Division (CAMD) air markets program data website ( http://ampd.epa.gov/ampd/ ). Annu al EGU SO2 and NOx emissions

in Iowa for 2002, 2008, and 2011 are shown in Table 2

- 1 and compared with the 2018 projections from

t he Integrated Planning M odel (IPM) utilized in the initial regional haze SIP

. The units are in tons 7 per

year.

Table 2

- 1 . Actual annual SO2 and NOx emissions in tons per year for 2002, 2008, and 2011 from all EGU units reporting to CAMD

, and project ed 2018 EGU emissions from the initial regional haze SIP.

2002
Emissions 2008
Emissions 2011
Emissions 2018 Projections

SO2 127,847 109,293 95,946 151,354

NOx 78,956 49,023 38,574 65,629

The IPM projection s for 2018 include increase s in EGU SO2 emissions (23,507 tons) and de creases in EGU NOx emissions (

- 13,327 tons ) across the 2002 to 2018 planning period

. Interpreting these predictions in the context of CAIR it appears that IPM concluded more sources in Iowa would choose to purchase SO2 allowances rather than reduce emissions

, while modest NOx controls would be added

.

Between 2002 and 2008 EGU SO2 and NOx emissions reported to CAMD declined by 18,554 and 29,933 tons, respectively

. Table 2

- 1 shows that in 2011 SO2 and NOx emissions continued to decline and were below the 2002 levels by 31,901 and 40,382 tons , respectively, which represent decreases of 25% and

51%.

The 2011 ac tual S O2 and NOx EGU emissions were significantly below the projected 2018 values, by 55,408 and 27,055 respectively , which represent s SO2 and NOx emissions that are 37% and 41% below
the ir 2018 projections. Figure 2

- 1 shows that decreases in NOx and SO2 emissions between the 2002

5 Accurately calculating the emissions reductions from many of the state and federal meas ures mentioned in Chapter 1 requires data not routinely collected. Qualitatively, the continued implementation of those federal and state measures not affecting p oint sources are expected to reduce emissions, including NOx and SO2 emissions.

6 As discussed previously CAIR is relied upon to satisfy most BART requirements for BART

- eligible EGUs and is a significant component of the long

- term strategy.

7 All tonnag e values in this report use short tons.

12baseyear and 2011 have occurred while actual heat input has increased, ind icating the reductions reflect cleaner generation and not merely d ecreased demand.

Figure 2

- 1

. A ctual annual emissions of SO2 and NOx and heat input (in 1000 MMBtu) in 2002, 2008, and 2011 as reported to CAMD (includes all units reporting to CAMD) , and projected 2018 emissions

.

13

## 3. **40 CFR 51.308(g)(3): Visibility Conditions** 

The requirements of 40 CFR 51.308 (g)(3 ) relate to assessments of visibility condition s and apply only to
states that contain Class I a reas

.

14

## 4. **40 CFR 51.308(g)(4) :**  **Emissions Tracking** 

40 CFR 51.308 (g)(4) requires: “ An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and activities within the State. Emissions changes should be identified by type of source or activity. The analysis must be based on the most recent updated emissions inventory, with estimates projected forward as necessary and appropriate, to account for emissions changes during the ap plicable 5

- year period. ”

A statewide emissions inventory of pollutants that are reasonably anticipated to cause, or contribute to, visibility impairment in any Class I area was requ ired to be included in the initial regional haze SIP (40 CFR 51.308(d)(4)( v)). While not all emissions in Iowa contribute to visibility impairment at a Class I area, Iowa chose to comply with this requirement by including a complete statewide inventory containing emission rates for all anthropogenic and biogenic sources

. 8

Th e initial regional haze SIP used a baseline year of 2002 (see Chapter 7 of the initial regional haze SIP)

. The 2002 point source inventory was derived from the 2002 NEI and state

- specific updates. The remaining source categories were developed from a var iety of data sources and inventory development techniques. Emissions were classified into ten source categories: a mmonia , area, fugitive dust, o ffroad

,
o nroad , p oint EGU , point n on

- EGU , road dust, fires, and biogenic. A detailed description of these ten source categories can be found in Appendix C . The species considered were: volatile organic compounds (VOC), nitrogen oxides 9 (NOx), fine particulate matter ( PM2.5 )

, coarse particulate matter ( PM10 ) , ammonia (NH 3), and sulfur dioxide (SO2).

All species and source types summarized in the initial regional haze SIP are reviewed in this five

- year progress report . A compr ehensive emissions review is provided to be co nsistent with the initial regional
haze SIP

. The most recent comprehensive inventory is the 2008 National Emissions Inventory (NEI), version 2 ( version dated April 10, 2012) 10 , or simply the 2008 NEIv2 . T he 2008 inventory offers a recent
and nationally un iform platform for emissions comparisons and is the logical data s ource to meet the requirements of 40 CFR 51.308(g) (4)

. While technically pro viding a six, and not five year time horizon from the original SIP’s baselin e inventory, the 2008 NEI v2 does not require any forward projections to fulfill the obligations of 40 CFR 51.308(g) (4)

.

A summary of the 2002 inventory fro m the initial regional haze SIP is provided in Table 4

- 1

. 11 Table 4

- 2 provides a summary of 200 8 NEI v 2 inventory data. All units are tons per year. The bioge nic source category is not included in the subtotals to focus on anthropogenic emissions. Differences between the
2002 and 2008 inventories are summarized in Table 4

- 3

, with positive values representing emissions growth from 2002 to 2008. Note that the 2008 NEIv2 data have been categorized using methods to help ensure the comparison with the 2002 data is consistent . Additional details on the 2008 NEIv2 data categorization process are provided in Appendix C

.

8 In the Midwest point source emissions of NOx and SO2 are often more closely evaluated in the context of regional haze.

9 NOx is defined as the sum of NO2 and NO, this definition is used throughout this document.

10 All 2008 NEI emissions data included in this report are associated with version 2 of the 2008 NEI, version dated April 10, 2012. For simplicity, this version will be referred to as the 2008 NEIv2.

11 For reference the data is that reported in Table 7.1 of the initial regional haze SIP, available at http://www.iowadnr.gov/InsideDNR/RegulatoryAir/RulesPlanning.aspx

.

15Table 4

- 1

. Summary of Iowa e miss ions for the 2002 baseline year (tons)

. Category VOC NO x PM 2.5 PM 10 NH 3 SO 2
Ammonia 0 0 0 0 258,915 0

Area 106,712 6,782 11,540 12,182 6,560 3,184
Fugitive Dust a 0 0 38,666 193,331 0 0

Offroad 63,694 92,595 8,904 9,707 79 9,037

Onroad 87,392 120,621 1,747 2,373 3,064 3,200

Point EGU 1,075 81,761 4,527 9,424 0 135,833

Point Non

- EGU 41,184 35,812 7,651 17,495 3,317 51,836

Road Dust a 0 0 19,525 127,882 0 0

Fires b 1,670 200 5,493 5,817 48 203

Subtotal 301,727 337,771 98,053 378,211 271,983 203,293
Biogenic 408,291 25,732 0 0 0 0

a Fugitive d ust and road d ust emission rates reflect what rema ins after the application of transport factors.

b Represents the sum of the 2002 ‘Area Fire,’ Point Fire,’ and ‘Wildfire’ categories.

Table 4

- 2

. Summ a ry of Iowa e missions from the 2008 NEI v2 (tons)

. Category VOC NO x PM 2.5 PM 10 NH 3 SO 2
Ammonia 0 0 0 0 295,549 0

Area 68,399 5,163 6,967 7,288 892 2,155
Fugitive Dust a 0 0 70,238 365,960 0 0

Offroad 38,837 85,831 5,918 6,228 65 1,481

Onroad 41,293 90,630 3,666 4,234 1,515 1,229

Point EGU 686 51,347 6,007 8,586 31 117,692

Point Non

- EGU 21,480 35,933 5,357 8,372 3,387 43,166

Road Dust a 0 0 17,354 147,591 0 0

Fires 4,361 758 2,865 3,099 237 189

Subtotal 175,055 269,662 118,371 551,358 301,676 165,913
Biogenic 289,743 35,620 0 0 0 0

a Transport factors were not applied to the 2008 fugitive dust or road dust emissions

.

Table 4

- 3

. Change s in emissions from 2002 to 2008 (tons). Positive values indicate growth.
Category VOC NO x PM 2.5 PM 10 NH 3 SO 2
Ammonia 36,634

Area

- 38,313

- 1,619

- 4,573

- 4,894

- 5,668

- 1,029
Fugitive Dust a 31,572 172,629

Offroad

- 24,857

- 6,764

- 2,986

- 3,479

- 14

- 7,556

Onroad

- 46,099

- 29,991 1,919 1,861

- 1,549

- 1,971

Point EGU

- 389

- 30,414 1,480

- 838 31

- 18,141

Point Non

- EGU

- 19,704 121

- 2,294

- 9,123 70

- 8,670

Road Dust a

- 2,171 19,709

Fires 2,691 558

- 2,628

- 2,718 189

- 14

Subtotal

- 126,672

- 68,109 20,318 173,147 29,693

- 37,380
Biogenic

- 118,548 9,888

a Apparent increases in PM1 0 and PM2.5 emissions from the fugitive dust and road dust categories are

p redominantly, if not wholly, attributable to the 2008 emissions not being reduced by transport factor s

. 16Iowa’s e missions of anthropogenic SO2 and NOx , which may contribute to visibility impairment at the Northern Midwest Class I areas, decreased by 37,380 and 68,109 tons, respectively, from 2002 to 2008. Restated as a percentage the SO2 and NOx decreases between 2002 and 2008 represent reductions of
18.4 and 20.2%

, respectively

. The NOx emissions reductions are p redom i nantly associate d with offroad
and on road 12 sources ( potentially a result of ongoing federal programs) and point EGU sources

. Sulfur
dioxide emi ssions have declined from all applicable categories, with nearly half the total SO2 emissions
reductions attributed to point sou rce EGU emissions. Reductions from non

- EGU point sources and offroad sources account for most of the remaining SO2 reductions. A significant decrease in total anthropogenic VOC emissions of 126,672 tons (40%) is estimated to have occurred between the 200 2 and 2008 emissions inventories, associated with reductions from nearly all sectors.

Total anthropogenic PM2.5 and PM10 emissions show increases of 20,318 and 173,147 tons per year

, respectively

, between 2002 and 2008 . Th ese increase s are driven almost entirely by the fugitive dust
category , and to a lesser extent the road dust sector for PM10 emissions

. It is imperative to note that the 2002 fugitive dust and road dust emissions estimates provided in Table 4

- 1 represent the values that remain after the application of transport factors, while the 2008 data (see Table 4

- 2 ) have not been similarly adjusted. Transport factors are reductions applied to fugitive dust and road dust emissions to

a ccount for the removal of particles near their emission source by vegetation and surface features , a removal mechanism that p hotochemical grid models do not accurately capture

. The near

- source capture transport factors were based on county

- level vegetative cover and were applied to the 2002 raw fugitive dust and road dust inventories to prepare them for input to the air quality models used in development of the initial regional haze SIP

.

The transport factors used in the 2002 data inventory were applied within the emissions model ing system and are not readily available . While the transport factor discrepancy does not permit a precise comparison of the 2002 and 20 0 8 fugitive and road dust emissions

, a crude evaluation is possible assuming a simp le 50% reduction of the 2008 fugitive dust and road dust emissions as a surrogate for the application of county

- level transport factors. This simple reduction would bring the 2008 PM2.5 and

PM10 fugitive and road dust 13 emissions in line and generally below the 2002 values. Regardless of the
actual differences between the 2002 and 2008 fu gitive dust and road dust emissions, such emissions
from Iowa are not known to contribute significantly to visibility impairment at Class I areas, and s oil impacts at IMPROVE monitors are likely ma inly due to local dust sources

. 14

12 A meaningful comparison between the CENRAP 2002/2018 and the 2008 NEI on road emissions is complicated by the significantly different methods used to estimate onroad emissions. The 2002/2018 data are based upon use of the MOBILE6 model while the 2008 NEI are derived from EPA’s application of the new Motor Vehicle Emissions Simulator (MOVES) mobile source model . The extent to which the different methodologies influence the change in emissions is not readily quantifiable but could be significant. However, this discrepancy does not influence other

source sector emis sions and does not alter any substantive conclusions.

13 While the PM2.5 road dust emissions are lower in 2008 than 2002, despite the 2002 data being reduce d by the application of the transport factor s , it is not known if these changes represent real

- world modification or are simply the result of changes in the methods used to estimate emissions from this source category.

14 Environ International Corporation (ENVIRON), September 12, 2007. Technical Support Document for CENRAP Emissions and Air Quality Mode ling to Support Regional Haze State Implementation Plans. Prepared for the Central Regional Air Planning Association. (Appendix 7.1 of the initial regional haze SIP.)

17

## 5. **40 CFR 51.308(g)(5): P**  **rogress Assessment**

40 CFR 51.308(g)(5) requires: “ An assessment of any significant changes in anthropogenic emissions within or outside the State that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emission s and improving visibility

. ”

The 2018 emissions projections from the initial regional haze SIP are provided in Table 5

- 1

. 15 Table 5

- 2 provides the differences between the 2018 projectio ns and the 2008 NEI v2 summary ( Table 4

- 2 )

. Negative values in Table 5

- 2 indicate the 2008 NEIv2 emissions estimates are below the 2018 projections. Figure 5

- 1 provides a graphical representation of the anthropogenic emissions for 2002, 2008, and the projected 2018 inventory

.

Table 5

- 1

. Summary of Iowa emissions p rojected to 2018 (tons )

. Category VOC NO x PM 2.5 PM 10 NH 3 SO 2 Ammonia 0 0 0 0 302,012 0

Area 127,849 7,476 10,677 11,510 13,304 3,224 Fugitive dust a 0 0 40,608 203,044 0 0

Offroad 37,143 60,210 5,582 6,088 101 220

Onroad 36,404 33,975 708 708 4,225 400

Point EGU 1,802 65,629 9,578 11,232 713 151,354 b

Point Non

- EGU 56,714 40,964 10,151 21,737 5,763 42,862

Road dust a 0 0 17,712 114,889 0 0

Fires 1,672 200 5,495 5,819 49 204

TOTAL 261,584 208,454 100,511 375,027 326,167 198,264
Biogenic 408,291 25,732 0 0 0 0

a T he 2018 f ugitive dust and road d ust emissions were adjusted by the 2002 transport factors.

b R ef lects use of the “Modified” SO2 value from Table 7.2 of the initial regional haze SIP.

Table 5

- 2

. Difference s in emissions between the 2008 NEI v2 data and 2018 projections ( tons)

. a
Category VOC NO x PM 2.5 PM 10 NH 3 SO 2
Ammonia 0 0 0 0

- 6,463 0

Area

- 59,450

- 2,313

- 3,710

- 4,222

- 12,412

- 1,069
Fugitive Dust b 0 0 29,630 162,916 0 0

Offroad 1,694 25,621 336 140

- 36 1,261

Onroad 4,889 56,655 2,958 3,526

- 2,710 829

Point EGU

- 1,116

- 14,282

- 3,571

- 2,646

- 682

- 33,662

Point Non

- EGU

- 35,234

- 5,031

- 4,794

- 13,365

- 2,376 304

Road Dust b 0 0

- 358 32,702 0 0

Fires 2,689 558

- 2,630

- 2,720 188

- 15

TOTAL

- 86,529 61,208 17,860 176,331

- 24,491

- 32,351
Biogenic

- 118,548 9,888 0 0 0 0

a Negative values indicate the 2008 emissions are lower than 2018 projections.

b T he 2008 f ugitive dust and road dust emissions estimates were not reduced by a transport factor. Apparent increases in PM10 and PM2.5 emissions from these categories are predominantly , if not wholly

,
a ttributable to this inconsistency.

15 From Table 7.2 of the initial regional haze SIP.

18Figure 5

- 1 . Comparison of Iowa’s actual emissions for 2002 and 2008, and the 2018 projections

. (For
reference and convenience the data in this chart have been con solidated into a table in Appendix C

. )

Total anthropogenic SO2 emissions in 200 8 were below 2018 projections by 32,351 ton s. Between 2002 and 2018 total anthropoge nic NOx emission reductions of 129,317 tons were foreca st. According to the

2008 NEI v2, over half this reduction has already been achieved (68,109 tons, see Table 4

- 3 ). Whil e NH3 emissions increases were estimated to be about 14% between 2002 and 2008, the increase do es not exceed the 2018 forecast

. I t is not known if th e NH3 increase is a reasonable rep resentation o f actual

emissions increases between 2002 and 2008 or is computational in nature

— the result of using different versions of and inputs to the Carnegie Mellon University (CMU) NH 3 emissions model

. The 2008 estimate appears reasonable in compari son to the 2002 and 2018 data and further review of the

ammonia emissions estimates is currently not warranted

. At this time VOC emissions have not been widely targeted for reduction s in the context of regional haze SIPs

, however it may be of interest to note

t otal VOC emissions were significantly lower in 2008 than the 2018 projections

, by 86,529 tons

.

Total PM2.5 and PM10 emissions are noticeably higher in 2008 than either the 2002 or projected 2018

emission s. This apparent increase is not impeding progress in reducing pollutant emissions as it is mostly, if not completely, an artifact of t he transport factor discrepancy discussed above. 16 Many other
2008 PM2.5 and PM10 source category emissions estima tes are below the 2018 projections

.

In summary, emissions reductions in 2008 were generally ahead of schedule or g reater than the 2018 projections

. No changes in anthropogenic emissions within the state have occurred that have limited or impeded progress in reducing pollutant emissions an d improving visibility.

16 To summarize, the 2002 and 2018 PM2 .5 and PM10 fugitive dust and road dust emissions were reduced by a transport factor (which, for example, may be on the order of a 50% reduction) while the 2008 data were not similarly adjusted.

19

## 6. **40 CFR 51.308(g)(6) :**  **Assessment of Elements to Meet RPG** 

40 CFR 51.308(g)(6) requires : “ An assessment of whether the current implementation plan elements and strategies are sufficient to enable the State, or other States with mandatory Federal Class I areas affected by emissions from the State, to meet all established reasonable progress goals. ”

In the initial regional haze SIP the DNR concluded emissions in Iowa may contribute to visibility impairment at the Northern Midwest Class I areas, which consist of two Class I areas in Minnesota ( Boundary W aters Canoe Area Wilderness and Voyageurs National Park) and two Class I areas in Michigan (Seney Wilderness Area and Isle Royale National Park)

.

According to photochemical sou rce a pportionment modeling conducted for the initial regional haze SIP ( Appendix A ) Iowa’s visibility impacts in the Northern Midwest Class I a reas were primarily assoc iated with elevated point sour ce SO2 and NOx emissions. E levated point source emissions are split among

two c ategories in the inventory , EGUs and non

- EGUs. Based upon the 2002 and 2008 actual emissions data, about 70% of the elevated point source SO2 emi ssions are associated with EGUs, with the
remainder from non

- EGUs. For elevated point source NOx emissions, about 60

- 70% are associated with EGUs, with the remainder again associ ated with non

- EGUs

. It can be infer red that any s ignificant changes i n EGU emissions will inform whether the current implementation plan is sufficient to meet the reasonable progress goals of the Northern Midwest Class I areas.



### Electricity Generation Based upon the emissions data discussed previously it was shown Iowa’s 201 1 EGU SO2 and NOx emissions are substantially lower than projected 2018 EGU emissions, by 55,408 and 27,055 tons, respectively. A brief review of the recent 2012 Iowa specific CAMD data (not shown) indicates NOx and
SO2 emissions have continue d to decline

. D espite uncertainty that exists regarding the future of CAIR and any potential replacement rules , the declines are not entirely unexpected

.

CAIR will continue to be implemented i n Iowa until supplanted, but it s importance for influencing EGU
SO2 and NO x emission reductions appears diminished. A significant or prolonged upswing in SO2 and NOx emissions from the electrical generating sector is not anticipated before a comprehensive regional haze SIP revision is required (by July 31, 2018). This assumpti on is supported by projections of electricity generation from coal and natural gas provided in the 2012 Annual Energy Outlook (AEO) reference case developed by the U.S. Energy Information Agency. 17 Figure 6

- 1 shows that coal use for purposes of electricity generation is predicted to continue decreasing nationwide beyond 2011 through 2016 . The
decrease in coal use largely occurs as a result of an increa sing reliance upon natural gas u sage for electricity generation

. Decreases in NOx and SO2 emissions from EGUs are expected to accompany
these trends

. While the trends change slightly after 20 15, coal usage remains well below recent levels.
This information provides a national perspective that should represent likely patterns within the state of

Iowa.

17 http://www.eia.gov/forecasts/aeo/er/index.cfm

20Figure 6

- 1

. Nationwide projected net coal and natural gas electricity generation supply. Inclu des plants that only produce electricity for sale and combined heat and power plants whose primary business is to sell electricity and heat to the public.

Although NOx and SO2 emissions estimates for all non

- EGU source categories (including point non

- EGU, area, offroad, onroad, etc.) we re not readily available for 2011

, emissions increases between 2008 and

2011 from non

- EGU sources which could significantly offset reductions from the EGU sector a re not expected

. This assessment is based upon the magnitude of the EGU reductions, declining emissions
trends between 2002 and 2008 from other source sectors, and ongoing implementation of federal and state regulations.



### New **Regulations** Since the development of the state’s initial regional haze SIP EPA has promulgat ed standards which are anticipated to yield new emissions reductions

. Based upon the 2008 NEIv2

, total anthropogenic SO2
emissions have already declined ahead of the 2018 projections by 32,351 tons. Total anthropogenic NOx emissions in 2008 were 68,109 tons below the 2002 baseyear, achieving 53% of the 129,317 tons of NOx emissions projected to occur over the 16

- year timeframe between 2002 and 2018. The following new regulations have the pote ntial to further reduc e emissions associated with visibility impairment in
the Northern Midwest Class I areas. 18

Mercury and Air Toxics Standard (MATS) On December 16, 2011, the EPA signed a rule to reduce emissions of toxic air pollutants from power pla nts. Specifically, the mercury and air toxics standards for power plants will reduce emissions from new and existing coal and oil

- fired electric utili ty steam generating units

. The final rule establishes power plant emission standards for mercury, acid g ases , and non

- mercury meta llic toxic pollutants. EPA

18 Quantitatively evaluating the relationships between the new regulations, subsequent emissions reductions in Iowa, and any related visibility improvement within the Northern Midwest Class I areas is beyond the scope of the
five

- year review. Additionally, the DNR is currently not relying upon the new regulations as a source of emissions reductions necessary to meet regional haze obligations.

21estimates MATS will reduce acid gas emissions by 88% from power plants

, and is also exp ected to
reduce SO2 emissions.

Portland Cement Air Toxics Standards

On December 20, 2012 , EPA signed the final amendments to the air toxics rules for Portland cement manufacturing. The amended rule will maintain dramatic reductions of acid gases, particulate matter

, and total hydrocarbons from existing cement kilns across the country, while ensuri ng that emissions
from new kilns remain low. Existing kilns must comply with the standards by Sept. 9, 2015, and if needed, may request an additional year. Nationwide EPA anticipates the rule will reduce hydrochloric
acid emissions by 96 percent, particu late matter by 91 percent, and total hydrocarbons by 82 percent.

National Ambient Air Quality Standard s (NAAQS) On January 22, 2010, EPA strengthene d the health

- based NAAQS for NO2 , establishing a new 1

- hour standard at a level of 100 ppb. On January 2 0, 2012 EPA designated all areas of the country as
“unclassifi able/attainment” for the 2010 NO2 NAAQS.

On June 3, 2010, the EPA promulgated a new 1

- hour SO2 standard at a level of 75 ppb. Areas not meeting the standard are expected to be designated nonat tainment in the June 2013 timeframe. Within 18 months of a nonattainment designation states are required to submit a plan d emonstrating compliance (as expeditiously as practicable) with the standards

.

On December 14, 2012, EPA strengthened the PM2.5 NA AQS, reducing the level of the annual standard
from 15 μ g/m 3 to 12 μ g/m 3 . EPA is expected to finalize designations by December 14 , 2014 . Projections provided by EPA suggest 99% of counties with monitors will meet the revised standard by 202 0

. 19



### Conclusion **s**
S ubst antial EGU SO2 and NOx emission s reductions have occurred that were not anticipated in the initial regional haze SIP. Total anthropogenic NOx and SO2 emissions have also declined significantly since

2002. Offsetting future increases are not anticipated based upon existing regulations and current market forces. T hese factors demonstrate that the s tate’s current plan elements and strategies are
sufficient to meet our obligations related to the reasonable progress goals of the N orthern Midw est
Class I areas

.

19 Map provided at: http://www.epa.gov/air/particlepollution/actions.html

.

22

## 7. **40 C**  **FR 51.308(g)(7): Visibility Monitoring** 

40 C F R 51.308(g)(7) requires : “ A review of the State's visibility monitoring strategy and any modifications to the strategy as necessary. ”

The DNR currently operates two IMPROVE Protocol sampling sites, one at Viking Lake State Park in southwestern Iowa, and the other at the Lake Sugema Wildlife Management Area in southeastern Iowa. The monitors began operation in June 2002. Additional monitoring equipment located at these two locations provides supplemental information on fine particles and their precursors. Data from IMPROVE and IMPROVE protocol monitors is ana lyzed by a national laboratory (funded via an interagency agreement between EPA and th e National Park Service) and uploaded by the laboratory into two publicly available databases at http://vista.cira.colostate.edu/improve and http ://vista.cira.colostate.edu/views/

. The supplemental monitoring data is publicly available at http://www.epa.gov/airdata/ad_maps.html and at http:/ /www.epa.gov/ttn/airs/airsaqs

. The DNR intends to continue to operate the tw o IMPROVE protocol monitors as long as the interagency agreement is in place and funding is available.

23

## 8. **40 CFR 51.308(h):**  **Determination of Plan Adequacy**

40 CFR 51.308(h) requires: “...At the same time the State is required to submit any 5

- year progress report to EPA in accordance with paragraph (g) of this section, the State must also take one of the following actions based upon the information presented in the progress re port:

(1) If the State determines that the existing implementation plan requires no further substantive revision at this time in order to achieve established goals for visibility improvement and emissions reductions, the State must provide to the Administrator a negative declaration that further revision of the existing implementation plan is not needed at this time.

(2) If the State determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emissions from sources in another State(s) which participated in a regional planning process, the State must provide notification to the Administrator and to the other State(s) which participated in the regional planning process with the States. The State must also coll aborate with the other State(s) through the regional planning process for the purpose of developing additional strategies to address the plan's deficiencies.

(3) Where the State determines that the implementation plan is or may be inadequate to ensure

rea sonable progress due to emissions from sources in another country, the State shall provide notification, along with available information, to the Administrator.

(4) Where the State determines that the implementation plan is or may be inadequate to ensure reasonable progress due to emissions from sources within the State, the State shall revise its implementation plan to address the plan's deficiencies within one year. ”

Based upo n the evidence presented in this document and the options above the D NR has de termined that further revision of the existing implementation plan is not needed at this time. A neg ative
declaration to this effect

, as required by 40 CFR 51.308(h)

, is included in the transmittal letter for this SIP (see Chapter i )

.

24

## 9. **Stakeholder Input**

**FLM Consultation**  The Federal Land Managers (FLMs) were provided a copy of the draft SIP on April 4, 2013. The public hearing was held on June 1 1 , 2013, which is in accordance with the FLM coordination requirements of 51.308)( i)(2). Comments received from the FLMs are summarized and addressed in Appendix D

.

The DNR will continue to coordinate and c onsult with the FLMs during development of future plan provisions and progress reports, as well as during the implementation of programs having the potential
to contribute t o visibility impairment in Class I a reas. The DNR will continue to communicate with the FLMs individually, through interagency or other coordinated efforts, or b oth to meet the requirements
of 51.308(i)(4) , which requires procedures for consultation during : • Development and review of impl ementation plan revisions

, • Review of 5

- year progress reports

, • Development and implementation of other programs that may contribute to impairment of

visibility in Class I areas.

To enhance interstate consultation efforts, t he states of Minnesota and Mi chigan were each provided a

copy of th e draft SIP concurrent with the FLM review period. T he DNR has and continues to be available
for consultation concerning the Northern Midwest Class I areas. No requests for continued discussions
have been received s ince the DNR submitted its initial regional haze SIP.



### Public Notice

T he DNR provided public notice of the opportunity to comment on the SIP revision. Public comments
received on the draft SIP are summarized and addressed in Appendix D

. The DNR has the authority to adopt this SIP revision (see Appendix E ) and has adopted this revision in accordan ce with State laws and
rules.

A copy of this report i s available at the Iowa Department of Natural Resources

– Air Quality Bureau,
Records C enter, 7900 Hickman Rd, Ste 1, Windsor Heights, IA 5032 4 , and on our w ebsite at www.iowacleanair.gov

.

25

## Appendix A. **S ource Apportionment Review** 

This appendix provides a brief review of visibility degradation source apportionment results for the 20% worst visibility days from the 2002 basecase and 2018 Base

- E CAMx particulate matter source apportionment (PSAT) modeling conducted for the initial regional haze SIP

. 20 The source apportionment
results provide d estimate s of the contributions to visibility impairment at Class I areas by source region s ( e.g. s tates) and source categories

. The modeled concentrations from the PSAT results were converted to light extinction values (a measure of visibility impairment with units of inverse megameters, Mm - 1 ) using the new 21 IMPROVE equation

.

The intent of the CENRAP PSAT analysis was to obtain s eparate contributions due to on road mobil e,

non road mobile, area, natural (biogenic) , EGU point , and non

- EGU point source categories

. However

, separate source apportionment modeling of EGU and non

- EGU point sources was not possible for all

states due to technical considerations

. The six source categories that were s eparately tracked in the

PSAT modeling were:

• Elevated point sources ( i.e. larger industrial sources and power plants)

, • Low

- level point sources ( i.e. point source emissions emi tted into layer 1 of the model),

• Onr oad Mobile Sources,

• Nonr oad Mobile Sources,

• Area Sources, and
• Natural Sources (e.g. biogenic)

.

According to the PSAT results the combined effect of all Iowa emissions upon the total modeled visibility impairment at the four Northern Mid west Class I is approximately 4

– 5 % in both 2002 and 2018. This represents a contribution of ~2.0

– 4.5 Mm - 1 to the total modeled light extinction at the northern
Midwest Class I areas. T he se results are reviewed in Table A

- 1.

Table A

- 1. Iowa’s c ontribution s to modeled visibility impairment (using the new IMPROVE equation) for the 20% worst days at the Northern Midwest Class I areas

. 22

Site Iowa’s Percentage
Contribution Iowa’s Total Modeled

C ontribution (Mm - 1 ) Class I Area Total M odeled

I mpairment (Mm - 1 )

2002 2018 2002 2018 2002 2018

BOWA 3.7 % 3.9 % 2.39 2.08 64.87 53.44

VOYA 3.8 % 4.0 % 2.16 1.97 56.45 48.84

ISLE 4.5 % 4.9 % 3.23 3.02 71.4 0 61.26

SENE 4.2 % 4.8 % 4.54 3.95 107.92 82.00

20 The PSAT modeling was funded by CENRAP and conducted by ENVIRON. The PSAT results were consolidated within and evaluated using ENVIRON’s PSAT Tool (Microsoft Access based). Se e Appendix 7.1 of Iowa’s initial regional haze SIP for additional information

. 21 Note, Appendix 7.1 of the initial regional haze SIP (see page 5

- 14 of the appendix) states that the original IMPROVE equation was used to convert modeled concentrations to l ight extinction. However, an updated version of the PSAT Tool (version 1.2, dated August 27, 2007) was used for both the initial regional haze SIP and this progress report. The updated PSAT Tool used the new, and not the original, IMPROVE equation.

22 The data are from Tables 11.1 and 11.2 of the initial regional haze SIP.

26The above results focus solely upon contributio ns attributable to sources in Iowa

. T he charts below provide a graphical representation comparing how all source regions (e.g. states) contribute to the total
modeled visibility impairment at the Northern Midwest Class I areas

. 23 The results are also apportioned by pollutant and source categories

. There are four charts per Class I area , two plots each for the 2002
and 2018 results (Figures A

- 1 through A

- 16). The first chart provides results for the worst 20% visibility days in 2002 for Boundary Waters Canoe Area Wilderness (BOWA) in Minnesota. In this chart the visibility impairment is apportioned by state and source category. T he same visibility impairment data (worst 20% days in 2002 at BOWA) form the basis for the second plot but the results are apportioned by pollutant (and state)

. Source apportion ment results for the worst 20% visibility days in 2018 at BOWA are similarly plotted in the next two charts. The remaining charts pertain t o Voyageurs National Park (VOYA) in Minnesota, and Isle Royale National Park (ISLE) and Seney Wilderness Area (SENE ) in Michigan.

For simplicity only the raw modeled 200 2 and 2018 PSAT results are provided

. 24 While the total
modeled visibility degradation is provide d in the title of each chart, contributions from initial conditions (IC) , boundary conditions (BC) , anthropogenic secondary organic aerosol (SOAA) , and biogenic secondary organic aerosol (SOAB) are only shown when results are apportioned by poll utant

.

23 The 2018 data plotted below are the same as shown in Figures 11.1

– 11.4 of the initial regional haze SIP. Additional charts are included here for an expanded review, to include the 2 002 results and PSAT contributions by source categories.

24 The PSAT results that were scaled according to observed species ratios (referred to as the “Projected” results within the PSAT tool) are not utilized in this review.

27Figure A

- 1. CENRAP PSAT source region by source category contributions to the average 2002 extinction (Mm - 1 ) for the worst 20% visibility days at Boundary Waters ( BOWA), Minnesota.

Figure A

- 2. CENRAP PSAT source region by pollutant contributions to the average 2002 extinction (Mm - 1 ) for the worst 20% visibility days at Boundary Waters (BOWA), Minnesota. CENRAP PSAT Modeled W20% 2002 BEXT at Site BOWA1 [Total=64.87]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2002 BEXT at Site BOWA1 [Total=64.87]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

28Figure A

- 3. CENRAP PSAT source region by source category contributions to t he average 2018 extinction (Mm - 1 ) for the worst 20% visibility days at Boundary Waters (BOWA), Minnesota

.

Figure A

- 4. CENRAP PSAT source region by pollutant contributions to the average 2018 extinction (Mm - 1 ) for the worst 20% visibility days at Boundary Waters (BOWA), Minnesota. CENRAP PSAT Modeled W20% 2018 BEXT at Site BOWA1 [Total=53.44]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2018 BEXT at Site BOWA1 [Total=53.44]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

29Figure A

- 5. CENRAP P SAT source region by source category contributions to the average 2002 extinction (Mm - 1 ) for the worst 20% visibility days at Voyageurs (VOYA), Minnesota.

Figure A

- 6. CENRAP PSAT source region by pollutant contributions to the average 2002 exti nction (Mm - 1 ) for the worst 20% visibility days at Voyageurs (VOYA), Minnesota. CENRAP PSAT Modeled W20% 2002 BEXT at Site VOYA2 [Total=56.45]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2002 BEXT at Site VOYA2 [Total=56.45]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

30Figure A

- 7. CENRAP PSAT source region by source category contributions to t he average 2018 extinction (Mm - 1 ) for the worst 20% visibility days at Voyageurs (VOYA), Minnesota.

Fi gure A

- 8. CENRAP PSAT source region by pollutant contributions to the average 2018 extinction (Mm - 1 ) for the worst 20% visibility days at Voyageurs (VOYA), Minnesota. CENRAP PSAT Modeled W20% 2018 BEXT at Site VOYA2 [Total=48.84]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2018 BEXT at Site VOYA2 [Total=48.84]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

31Figure A

- 9. CENRAP PSAT source region by source category contributions to the average 2002 extinction ( Mm - 1 ) for the worst 20% visibility days at Isle Royale (ISLE), Michigan

.

Figure A

- 10. CENRAP PSAT source region by pollutant contributions to the average 2002 extinction ( Mm - 1 ) for the worst 20% visibility days at Isle Royale (ISLE), Michigan

. CENRAP PSAT Modeled W20% 2002 BEXT at Site ISLE1 [Total=71.4]

0 1 2 3 4 5 6 7 8 9 10

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2002 BEXT at Site ISLE1 [Total=71.4]

0 1 2 3 4 5 6 7 8 9 10

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

32Figure A

- 11. CENRAP PSAT source region by source category contributions to the average 2018 extinction ( Mm - 1 ) for the worst 20% visibility days at Isle Royale (ISLE), Michigan

.

Figure A

- 12. CENRAP PSAT source region by pollutant contributions to the average 2018 extinction ( Mm - 1 ) for the worst 20% visibility days at Isle Royale (ISLE), Michigan

. CENRAP PSAT Modeled W20% 2018 BEXT at Site ISLE1 [Total=61.26]

0 1 2 3 4 5 6 7 8 9 10

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2018 BEXT at Site ISLE1 [Total=61.26]

0 1 2 3 4 5 6 7 8 9 10

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

33Figure A

- 13. CENRAP PSAT source region by source category contributio ns to the average 2002 extinction ( Mm - 1 ) for the worst 20% visibility days at Seney (SENE), Michigan

.

Figure A

- 14. CENRAP PSAT source region by pollutant contributions to the average 2002 extinction ( Mm - 1 ) for the worst 20% visibility days at Seney (SENE), Michigan

. CENRAP PSAT Modeled W20% 2002 BEXT at Site SENE1 [Total=107.92]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2002 BEXT at Site SENE1 [Total=107.92]

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

34Figure A

- 15. CENRAP PSAT source region by source category contributions to the average 2018 extinction ( Mm - 1 ) for the worst 20% visibility days at Seney (SENE), Michigan

.

Figure A

- 16. CENRAP PSAT source region by pollutant contributions to the average 2018 extinction ( Mm - 1 ) for the worst 20% visibility days at Seney (SENE), Michigan

. CENRAP PSAT Modeled W20% 2018 BEXT at Site SENE1 [Total=82]

0 1 2 3 4 5 6 7 8 9 10 11 12

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois Indiana Ohio Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico

Source RegionExtinction (1/Mm) Elevated Point Low-Level Point Natural On-Road Mobile Non-Road Mobile Area

CENRAP PSAT Modeled W20% 2018 BEXT at Site SENE1 [Total=82]

0 1 2 3 4 5 6 7 8 9 10

East Texas

TX Gulf Coast West Texas Louisiana Oklahoma Arkansas Missouri Kansas

Nebraska Iowa Minnesota

North Dakota

South Dakota Wyoming Colorado

New Mexico Wisconsin Illinois

Indiana Ohio

Michigan Kentucky

Tennessee Mississippi Alabama Gulf of Mexico East West

Canada Mexico IC BC SOAA SOAB

Source RegionExtinction (1/Mm) SO4 NO3 POA EC SOIL CM SOAA SOAB

35

## Appendix B. **MACT Review** 

Numerous Maximum Achievable Control Technology (MACT) standards have been promulgated

pu rsuant to Section 112 of Title I of the Clean Air Act

. MACT standards are designed to reduce emissions
of air toxics, also known as hazardous air pollutants (HAPs)

, from stationary sources of air pollution. A significant percentage of the MACT standards yield VOC reductions since many HAPs a re also VOCs.
While VOC emissions were not specifically targeted for reduction in the initial regional haze SIP

, NOx emissions reductions were expected from the 2004 Reciprocating Internal Combustion Engines (RICE)
standards

. PM reductions were also possible from a subset of the applicable standards.

CENRAP estimated emissions reductions from the MACT standards for source categories with a post

2002 compliance data. MACT standards not achieving significant VOC emission reductions were excluded

. A list of the MACT standards considered in development of the 2018 inventory for the initial regional haze SIP is provided in Table B

- 1. This table also provides the associated CFR subpart containing the regulation s, the compliance date for existing sources, and the pollutants reduced in the 2018 inventory. Not all source categories listed in Table B

- 1 are found in Iowa, the list is based upon the data developed by E.H. Pechan and Associates. 25 It is likely that th e MACT sta ndards did not significantly impact any relationships between emission in Iowa and visibility impairment in a Class I area . Their

review is provided only as a courtesy and for future reference.

Table B

- 1. Post

- 2002 MACT standards considered in the 2018 emissions i nventory

MACT Standard

- Source Category CFR Subpart Promulgation (Federal Register) Compliance Date (existing sources) Pollutants
Affected Asphalt (Roofing Manufacturing & Asphalt Processing) LLLLL 4/29/2003 5/1/2006 VOC

Auto and Light Duty Trucks IIII 4/26/ 20 04 4/26/2007 VOC Coke Ovens: Pushing, Quenching and Battery Stacks CCCCC 4/14/ 20 03 4/14/2006 VOC

Fabric Printing, Coating &Dyeing OOOO 5/29/ 20 03 5/29/2006 VOC Friction Products Manufacturing QQQQQ 10/18/ 20 02 10/18/2005 VOC Integrated Iron and Steel FFFFF 5/20/ 20 03 5/20/2006 VOC, PM Large Appliances NNNN 7/23/ 20 02 7/23/2005 VOC Leather Finishing Operations TTTT 2/27/ 20 02 2/27/2005 VOC Lime Manufacturing AAAAA 1/ 5/ 20 04 1/5/2007 PM Manufacturing Nutritional Yeast CCCC 5/21/ 20 01 5/21/2004 VOC
Metal Can (Surface Coating) KKKK 11/13/ 20 03 11/13 /200 6 VOC
Metal Coil (Surface Coating) SSSS 6/10/2002 6/10/2005 VOC
Metal Furniture RRRR 5/23/ 20 03 5/23/2006 VOC Misc. Coating Manufacturing HHHHH 12/11/ 20 03 12/11/2006 VOC

Misc. Metal Parts and Products (Surface Coating) MMMM 1/ 2/ 20 04 1/2/2007 VOC

25 Development of Growth and Control Inputs for CENRAP 2018 Emissions, Draft Technical Support Document. E.H. Pechan and Associates, Inc. Durham, North Carolina. Carolina Environmental Program, University of North Carolina, Chapel, Hill, North Carolina. 2005, May.

36Misc. Organic Chemical
Production and Processes (MON) FFFF 11/10/ 20 03 11/10/2006 VOC

Paper and Other Web JJJJ 12/ 4/ 20 02 12/4/2005 VOC Pesticide Active Ingredient
Production MMM 6/23/ 19 99 12/ 23/2003 VOC

Petroleum Refineries UUU 4/11/ 20 02 4/11/2005 VOC
Plastic Parts PPPP 4/19/200 4 4/19/2007 VOC Plywood and Composite Wood
Products DDDD 7/30/ 20 04 10/1/ 2007 VOC

Polymers and Resins III OOO 1/20/2000 1/20/2003 VOC Reciprocating Internal Combustion Engines (RICE) ZZZZ 6/15/ 20 04 6/15/ 20 0 7 VOC, NOx

Rubber Tire Manufacturing XXXX 7/9/ 20 02 7/11/2005 VOC Secondary Aluminum Production RRR 3/23/ 20 00 3/24/2003 PM
Site Remediation GGGGG 10/ 8/ 20 03 10/8/2006 VOC Solvent Extraction for Vegetable
Oil Production GGGG 4/12/2001 4/12/2004 VOC

Stationary Combustion Turbines YYYY 3/ 5/ 20 04 3/5/2007 VOC Taconite Iron Ore Processing RRRRR 10/30/ 20 03 10/30/2006 PM Wet Formed Fiberglass Mat
Production HHHH 4/11/ 20 02 4/11/2005 VOC

Wood Building Products (Surface Coating) QQQQ 5/28/ 20 03 5/28/2006 VOC



### 2004 Industrial/Commercial/Institutional Boiler NESHAP

T he original regional haze SIP indicated that the future year 2018 emissions inventory included emissions reductions associated with the industrial, c ommercial, and institutional (ICI) boiler MACT

. 26 Upon further review it does not appear any such adjustments were actually incorporated. The vacature and remand of the ICI boiler MACT issued by the DC Circuit court of Appeals on July 30, 2007, would have called into question the accuracy of any previous attempt s to quantify the effects of the ICI boi ler MACT. On January 31, 2013, EPA published the final reconsideration amendments of the ICI boiler MACT. The compliance dates for the rule are January 31, 2016, for existing sources and January 31, 2013, or upon startup, whichever is later, for new sour ces. Additional review of the potential effects of the boiler MACT can better be assessed during the comprehensive regional haze SIP review due July 31,

2018.

26 The ICI boiler M ACT was published in the Federal Register September 13, 2004, affecting 40 CFR 63 subpart

DDDDD.

37

## Appendix C. **Emissions D ata**  **Compilation**

A meaningful comparison of the 2008 NEI version 2 (version dated April 10, 2012) 27 emission data with
the 2002 and 2018 data requires the underlying d ata be similarly categorized. A review of the sou rce categories used in the initial regional haze SIP is provided below. A detailed accounting of how the 2008

NEI v2 data was processed to ensure emission were consolidated using a classification system highly similar to 2002/2018 categories will follow

.



### Categories from the Initial R egional H aze SIP

H istorically emissions were classified according to five basic source categories: area, offroad, onroad, point, and biogenic sources. 28 This basic classification scheme was expanded in the 2002 and 2018 regional haze emissions inventories developed for CENRAP to include specialized source categories for

ro ad dust, fugitive dust, ammonia, three distinct fire categories , and the separation of the point sector into emissions from electrical genera ting units (EGUs) and non

- EGUs . For this five

- year progress report the three fire categories used in the 2002/2018 inventories have been summed in to a single fires category. Th is results in ten source categories : ammonia, area, fugitive dust, offroad, onroad, point EGU, point non

- EGU, road dust, fires, and biogenics. A simple summary of the se categories and the
typ es of so urces they included (in the 2002 and 20 18 regional haze inventories ) is provided in Table C

- 1

.

Table C

- 1

. Identification and description of the source categories used to classify the 2002 and 2018
emissions in the initial regional haze SIP.

Ammonia Essentially an area source category that pertained only to NH3 emissions

. Emissions sources considered include d agricultural livestock waste, agricultural fertilizer application, landfills , wildlife (deer), domesti c pets, and human perspiration an d respiration. This is not an exhaustive list but includes the most significant sources

. A gricultural livestock and fertilizer applications account ed for
over 95% of the 2002 A mmonia category emissions.

Area I nclude d a wide v ariety of emissions types and was intended to include all
emissions not otherwise re presented by one of the other nine categories . Common examples of area sources include gas stations, solvent utilization , and residential
wood combustion.

Fugitive Dust Include d only PM 10 and PM2. 5 fugitive emissions associated with mining, construction, crop production

, and dust kicked up by hooves at beef feedlots (drylots)

.

Offroad Generally included all non road mobile source activities, such as: airport; marine; rail (locomotive); resident ial ( e.g. lawn care); agricultural equipment ; construction
and mining equipment (no t associated with fugitive dust); and rec reational equipment

. This is not an exhaustive list.

Onroad I ncluded emissions resulting from rural and urban roadway traffic from cars, trucks, buses, motorcycles, etc.

Point EGU Emissions from large facilities producing electricity for sale. For example, this category commonly included facilities that have units subjec t to the Acid Rain

27 This inventory will be referred to simply as the 2008 NEIv2. It was the most recent comprehensive NEI dataset
available. All 2008 NEI data used in this doc ument is from this version.

28 The area source category is also referred to as the nonpoint source category and the offroad source category referred to as the as nonroad source category. For purposes of this document the respective terms are considered

to be interchangeable.

38Program or the Clean Air Interstate Rule (CAIR).

Point non

- EGU Emissions from large industrial activities not associated with electricity generation.

Road Dust I nclude d only PM10 and PM2.5 emissions from paved and unpaved roads.

Fires Included emissions from prescribed fires

, agricultural field burning, and wildfires

. (L arger prescribed fires we re categorized as ‘Point Fire’ in the 2002/2018

inventories

, with the ‘Area Fire’ category consisting of smaller prescribed fires and agricultural field b urning . Wildfire and ag ricultural burning are not common in

Iowa. ) Biogenic Included NOx and VOC emissions produced by the BEIS3 biogenic emissions model.



### 200 8 NEI D ata C ategories

The classification system used by EPA in the 2008 NEI has changed in some respects compared to the
allocation methods used in initial regional haze SIP

. 29 For example, certain emissions from aircraft, locomotives, and c ommercial marine vessels that were considered offroad emissions in the initial regional haze SIP are associated with point sources or nonpoint sources in the 2008 NEI

. 30

To help ensure the 2008 NEIv2 data were consolidated into categories comparable to t he 2002 inventory, the 2008 NEI v2 data were processed using the full detail SCC (source classification code) Data
Files provided by EPA for the Point

, OnRoad

, NonRoad (offroad ), and NonP oint (area) data categories

. The Iowa specific 2008 emissions were fi rst extracted from the SCC Data File s and the resultant data
reclassified where necessary to align the 2002 /2018 and 2008 source categories as closely as possible. For example, aircraft and rail emission s were extracted from the Point SCC Data File and reclassified as
offroad sources . Commercial marine emissions in the 2008 NonPoint SCC Data File were extracted and
reclass ified as offroad sources. T he fugitive dust category was defined by including emissions from agricultural activities, construct io n dust, and mining emissions from the NonPoint SCC Data File

. A lookup table is provided below which provides additional detail regarding how the 2008 NEIv2 data were cataloged for comparison to the ten source categories utilized in the initial regional haze SIP.

A minor complicating factor arises between the comparison of the 2002 /2018 and 2008 ammonia
categor y data . The 2002 /2018 and 2008 inventories both include emissions from livestock waste and
fe rtilizer applications, but only the 2002/2018 inve ntories include other source types such as waste disposal, miscellaneous, and biogenics. However, t hese exclusions are n ot expected to significantly compromise the leg itimacy of the comparison as livestock waste and fertilizer application sources

accounte d for over 95% of the total emissio ns in the 2002 ammonia category and similar conditions would be expected of 2008.

Changes and transitions in the methods, datasets, and models used to estimate emissions are expected to create additional, but unavoidable , discontinuities between the 2002/2018 and 2008 NEI data. For example, Chapter 4 and Chapter 5 discuss updates in the onroad and NH3 emissions methodologies, respectively. Such differences may moderate the comparability of some source categories but are not
known to affec t any substantive conclusions in this document . S ignificant inter

- annual discrepancies in
th e point source categories, which are important components of this five year review, are not expected.

29 EPA’s descriptions of the 2008 NEI source categories are included at the end of this appendix.

30 A ircraft engine emissions occurring during l anding and takeoff operations and the ground support equipment and auxiliary power u nits as s ociated with the aircraft are considered point sources associated with individual airports in the 2008 NEI. Emissions from locomotives th at occur at rail yards are also incl uded as point sources. Commercial marine vessel emissions are considered nonpoint sources.

39

### 2008 Emissions Classifications Lookup Table

The f irs t column in Table C

- 2 identifies the 2008 NIEv2 SCC Data File ( Point, NonPoint

, OnRoad

, or N onroad ) 31 from which the Iowa data were
extracted , with the following caveats :

• A n ‘AirRail ’ identifier was created to denote aircraft and locomotive emissions extracted from the Point SCC D ata F ile.

• The ‘B iogenics ’ ident ifier reflects emissions data obtained from t he “Biogenics

- Vegetation and S o ils ” E missions Inventory System (E IS ) Sector summary file. ( Biogenic em issions were not included in any SCC Data File

. )

• Th e ‘F ire ’ iden tifier represents prescribed fire emissions f rom the “Fires

- Prescribe d Fires” EIS Sector summa ry file in addition to

ag ricultural burn ing emissions contained in the NonPoint SCC Data F ile.

The second column in Table C

- 2 groups emissions from the SCC Data File s by EPA’s EIS Sectors

. 32

The 2008 NEIv2 emissions estimates are reported i n columns 3 through 8 of Table C

- 2

, in tons per year. The PM25

- PRI and PM10

- PRI data represent the sum of filterable and condensable (if any) emission.

The last column in Table C

- 2 identifies which category ( of the ten source ca tegories us ed i n the initial regional haze SIP ) was selected to cla ssify
those 2008 emissions

. Note, t he classification system used to process the 2008 NEI v2 data could not recrea te the categories used in the initial regional haze SIP perf ectly ( most n otable for the Ammonia category ) but other classification discrepancies are not known to be significant

. Additional information about the ten categories as they pertain to the 2008 NEIv2 data follows :

31 The four SCC Data Files were large (potentially many hundreds of megabytes) national scale datasets, obtained from EPA’s webs ite: http://www.epa.gov/ttnchie1/net/2008inventory. html

.

32 For the 2008 NEIv2 EPA developed convenient summaries ( e.g. pollutant emissions summed by state) using 60 different EIS Sector Summary files. Unfortunately, the EIS Sector summaries could not be distributed in a manner which would cleanly recre ate the ten categories used in the initial regional haze

SIP . For example, EPA’s “Industrial Processes

- Mining” EIS Sector summary consolidated emissions that under the 2002/2018 classifications would consist of both fugitive dust and point source ( non

- E GU ) emissions. While such discrepancies may not always be significant, such errors were avoided by instead processing the emissions data from the four SCC Data Files. Additional information regarding the data and processing steps follows.

Every emissions record in each of the four SCC Data Files contains a source classification code . For the 2008 NEIv2 EPA developed a crosswalk file ( ftp://ftp.epa .gov/EmisInventory/2008v2/doc/scc_eissector_xwalk_2008neiv2.xlsx ) that maps every source classification code to one of 60 EIS sectors. By first processing the SCC Data File s separately (and then reviewing the descriptions associated with source classification codes where uncertainty remained regarding the appropriate classification) it was possible to utilize the EIS Sectors classifications while still ensuring emissions cou ld be appropriately assigned into one of the ten categories used in the initial regional haze SIP

. For example, this process helped to ensure mining related emissions from the NonP oint SCC Data File could be appropriately identified as “Fugitive Dust” emi ssions and kept separate from mining emissions from the P oint SCC Data F ile which needed to be categorized as “Point non

- EGU” emissions. This exp lains why an EIS Sector, e.g. “Industrial Processes

- Mining

, ” may be listed more than once in Table C

- 2.

40• The Ammonia category i ncludes only NH3 emissions from agricultural livestock waste and agricultural fertilizer application s ( nonpoint emissions) . The 2002/2018 inventories included additional s ectors (examples provided in Table C

- 1 ) but these additional sources either could not be segregated from the 2 008 SCC Data F iles in an efficient manner or were not present (such as emissions associated with human respiration and perspiration) in the 2008 NEI v2 data . The se exclusion s do not compromise the comparison as they are expected
to contribute only a small percentage (approxi mately 5% or less) of the total ammonia emissions in this category.

• The Area category includes all other emissions from the NonP oint SCC Data F ile not otherwise classified.

• The Fugitive Dust category includes ag ricultural crop and livestock dust, construction dust, and nonpoint mining dust

. Transport factors
have not been applied to these emissions.

• The O ffroad category i ncludes aircraft and locomotive emissions from the Point SCC Data F ile, commercial marine and locomotive
emissions from the NonP oint SCC Data File, and all emissions in the NonRoad SCC Data F ile.

• The Onroad category includes all emissions from the OnR oad SCC D ata F ile.

• The Point

- EGU category includes all emissions from the Point SCC Data F ile that are categorized with one of the following EIS Sectors:
Fuel Comb

- Electric Generation

- Biomass, Fuel Comb

- Electric Generation

- Coal, Fuel Comb

- Electric Generation

- Natural Gas, Fuel
Comb

- Electric Generation

- Oil, Fuel Com b

- Electric Generation

- Other.

• The Point non

- EGU cate gory includes all other industrial point source emissions.

• The Road D ust category includes paved and unpaved road dust from the NonPoint SCC Data F ile.

• The F ires category includes agric ultural field burning from the NonP oint SCC Data F ile, and prescribed f ire from the EIS Sector file: “Fires

Prescribed fires ” ( classified as an Event category under the 2008 nomenclature). As a reasonable assumption, n o wildfire emissions
were estimated in Iowa

.

• The B iogenics category includes emissions obtained from the EIS

- Sector File: “Biogenics

- Vegetation and soil”

Table C

- 2 . Lookup table defining how emissions from the 2008 NEIv2 SCC Data File s were categorized for comparison with the 2002/2018
emissions data from the initial regional haze SIP. Emissions data also provided (tons).

2008 NEI v2

SCC Data
File 2008 NEIv2 EIS Sector VOC NOX PM25

- PRI PM10

- PRI NH3 SO2 Categorization

NonPoint Agriculture

- Crops & Livestock Dust 66,996 334,982 Fugitive Dust

NonPoint Agriculture

- Fertilizer Application 89,461 Ammonia

NonPoint Agriculture

- Livestock Waste 206,087 Ammonia

Biogenics Biogenics

- Vegetation and soil 289,743 35,620 Biogenic

Point Bulk Gasoline Terminals 631 5 0 0

- - Point Non

- EGU

NonPoint Commercial Cooking 109

- 769 770

- Area

412008 NEI v2

SCC Data
File 2008 NEIv2 EIS Sector VOC NOX PM25

- PRI PM10

- PRI NH3 SO2 Categorization

NonPoint Dust

- Construction Dust 2,523 25,230 Fugitive Dust

NonPoint Dust

- Paved Road Dust 4,507 18,027 Road Dust

NonPoint Dust

- Unpaved Road Dust 12,847 129,564 Road Dust

NonPoint Fires

- Agricultural Field Burning 951 475 1,562 1,562 54 Fires

Fire Fires

- Prescribed Fires 3,410 283 1,303 1,538 237 134 Fires

Point Fuel Comb

- Comm/Institutional

- Biomass

- - - - - Point Non

- EGU

Point Fuel Comb

- Comm/Institutional

- Coal 27 817 56 85 30 4,126 Point Non

- EGU

Point Fuel Comb

- Comm/Institutional

- Natural Gas 24 200 19 21 6 2 Point Non

- EGU

Point Fuel Comb

- Comm/Institutional

- Oil 3 46 5 5 0 99 Point Non

- EGU

Point Fuel Comb

- Comm/Institutional

- Other 0 5 1 2 0 6 Point Non

- EGU

Point Fuel Comb

- Electric Generation

- Biomass

- - 1 1

- - Point EGU

Point Fuel Comb

- Electric Generation

- Coal 659 50,795 5,913 8,459 7 117,622 Point EGU

Point Fuel Comb

- Electric Generation

- Natural Gas 17 328 67 77 19 13 Point EGU

Point Fuel Comb

- Electric Generation

- Oil 8 205 12 18 5 15 Point EGU

Point Fuel Comb

- Electric Generation

- Other 2 20 14 31 0 41 Point EGU

Point Fuel Comb

- Industrial Boilers, ICEs

- Biomass 6 134 31 64

- 11 Point Non

- EGU

Point Fuel Comb

- Industrial Boilers, ICEs

- Coal 63 7,891 540 1,216 130 30,805 Point Non

- EGU

Point Fuel Comb

- Industrial Boilers, ICEs

- Natural Gas 622 15,984 319 323 52 19 Point Non

- EGU

Point Fuel Comb

- Industrial Boilers, ICEs

- Oil 26 509 19 21 4 121 Point Non

- EGU

Point Fuel Comb

- Industrial Boilers, ICEs

- Other 27 301 20 24 3 72 Point Non

- EGU

NonPoint Fuel Comb

- Residential

- Natural Gas 170 2,907 13 16 618 19 Area

NonPoint Fuel Comb

- Residential

- Oil 4 97 11 13 5 229 Area

NonPoint Fuel Comb

- Residential

- Other 167 1,273 50 80 28 1,750 Area

NonPoint Fuel Comb

- Residential

- Wood 4,643 416 3,933 3,936 229 102 Area

NonPoint Gas Stations 13,952 Area

422008 NEI v2

SCC Data
File 2008 NEIv2 EIS Sector VOC NOX PM25

- PRI PM10

- PRI NH3 SO2 Categorization

Point Gas Stations 33 4

- - - - - Point Non

- EGU

Point Industrial Processes

- Cement Manuf 250 5,293 399 633 37 5,156 Point Non

- EGU

Point Industrial Processes

- Chemical Manuf 2,117 1,370 190 213 1,129 483 Point Non

- EGU

Point Industrial Processes

- Ferrous Metals 535 695 509 654 8 490 Point Non

- EGU

NonPoint Industrial Processes

- Mining 718 5,748 Fugitive Dust

Point Industrial Processes

- Mining

- - 816 1,243

- - Point Non

- EGU

Point Industrial Processes

- NEC 10,208 2,264 1,567 2,623 613 1,754 Point Non

- EGU

Point Industrial Processes

- Non

- ferrous Metals 318 49 232 239 3 1 Point Non

- EGU

Point Industrial Processes

- Oil & Gas Production 62 0 0 0

- - Point Non

- EGU

Point Industrial Processes

- Petroleum Refineries 1 1 21 21

- - Point Non

- EGU

Point Industrial Processes

- Pulp & Paper 151 3 100 110 25

- Point Non

- EGU

NonPoint Industrial Processes

- Storage and Transfer 800 Area

Point Industrial Processes

- Storage and Transfer 1,500 26 330 559 1,311 5 Point Non

- EGU

NonPoint Miscellaneous Non

- Industrial NEC 2,597 10 1 1 2 Area

Point Miscellaneous Non

- Industrial NEC

- - 0 0

- - Point Non

- EGU

AirRail Mobile

- Aircraft 120 272 13 59 37 Offroad

NonPoint Mobile

- Commercial Marine Vessels 46 2,111 73 75 2 125 Offroad

AirRail Mobile

- Locomotives 138 2,140 58 60 1 18 Offroad

NonPoint Mobile

- Locomotives 1,211 24,167 748 814 11 248 Offroad

AirRail Mobile

- Non

- Road Equipment

- Diesel 34 10 28 1 1 1 Offroad

NonR oad Mobile

- Non

- Road Equipment

- Diesel 4,850 48,455 4,294 4,427 38 1,016 Offroad

AirRail Mobile

- Non

- Road Equipment

- Gasoline 34 2 6 0 0 0 Offroad

NonRoad Mobile

- Non

- Road Equipment

- Gasoline 31,753 5,904 705 767 14 29 Offroad

AirRail Mobile

- Non

- Road Equipment

- Other 35 2 9 2 2 2 Offroad

33 The se emissions are associate d with three Magellan Pipeline Co, LLC facilities ( located in Des Moines , Sioux City, and Iowa City), not consumer gas station s

. 34 Airport/ A ircraft ground support activities , extracted from the Point SCC Data File.

35 Aircraft auxiliary power u nits , extracted from the Point SCC Data File.

432008 NEI v2

SCC Data
File 2008 NEIv2 EIS Sector VOC NOX PM25

- PRI PM10

- PRI NH3 SO2 Categorization

NonRoad Mobile

- Non

- Road Equipment

- Other 706 2,738 24 24 5 Offroad

OnRoad Mobile

- On

- Road Diesel Heavy Duty Vehicles 2,822 41,364 2,216 2,382 87 962 Onroad

OnRoad Mobile

- On

- Road Diesel Light Duty Vehicles 116 661 57 61 4 23 Onroad

OnRoad Mobile

- On

- Road Gasoline Heavy Duty Vehicles 1,822 2,821 66 85 47 12 Onroad

OnRoad Mobile

- On

- Road Gasoline Light Duty Vehicles 36,533 45,784 1,327 1,706 1,377 233 Onroad

NonPoint Solvent

- Consumer & Commercial Solvent Use 39,286 Area

Point Solvent

- Degreasing 55

- 1 1

- - Point Non

- EGU

Point Solvent

- Dry Cleaning 36 82

- 15 15

- - Point Non

- EGU

Point Solvent

- Graphic Arts 154 2 0 0 0 0 Point Non

- EGU

NonPoint Solvent

- Industrial Surface Coating & Solvent Use 1,262 Area

Point Solvent

- Industrial Surface Coating & Solvent Use 4,539 50 108 130 1 1 Point Non

- EGU

NonPoint Solvent

- Non

- Industrial Surface Coating 4,534 Area

NonPoint Waste Disposal 875 460 2,189 2,473 11 54 Area

Point Waste Disposal 76 288 62 171 35 17 Point Non

- EGU

TOTAL 37 464,798 305,282 118,371 551,358 301,676 165,913

36 T hese point source emissions are associated with the facility “Industrial Laminates/Norplex, Inc.,” which is not a consumer dry cleaner.

37 Note, due to rounding the sum of the numbe rs in this table may not equal the totals shown.

44

### Consolidation of the 2002, 2008, and 2018 emissions d ata

Table C

- 3 provides a consolidated view of the 2002 base year, 2008 NEIv2 and projected 2018 emissions data. Note, the 2018 SO2 Point EGU emissions reflect the ‘M odified’ value listed in
Table 7.2 in the initial regional haze SIP. The ‘subtotal’ category represents the sum of all source categories except the biogenic (vegetat ion and so il emissions ) source category

.

Table C

- 3 . Consolidation of the 2002 base year inventory and the 2018 projected inventory from the initial regional haze SIP, and the 2008 NEI v2 emissions data

.

Category VOC NOx PM2.5 PM10 NH3 SO2

2002 2008 2018 2002 2008 2018 2002 2008 2018 2002 2008 2018 2002 2008 2018 2002 2008 2018

Ammonia 0 0 0 0 0 0 0 0 0 0 0 0 258,915 295,549 302,012 0 0 0

Area 106,712 68,399 127,849 6,782 5,163 7,476 11,540 6,967 10,677 12,182 7,288 11,510 6,560 892 13,304 3,184 2,155 3,224
Fugitive Dust 0 0 0 0 0 0 38,666 70,238 40,608 193,331 365,960 203,044 0 0 0 0 0 0
Offroad 63,694 38,837 37,143 92,595 85,831 60,210 8,904 5,918 5,582 9,707 6,228 6,088 79 65 101 9,037 1,481 220
Onroad 87,392 41,293 36,404 120,621 90,630 33,975 1,747 3,666 708 2,373 4,234 708 3,064 1,515 4,225 3,200 1,229 400

Point EGU 1,075 686 1,802 81,761 51,347 65,629 4,527 6,007 9,578 9,424 8,586 11,232 0 31 713 135,833 117,692 151,354

Point Non

- EGU 41,184 21,480 56,714 35,812 35,933 40,964 7,651 5,357 10,151 17,495 8,372 21,737 3,317 3,387 5,763 51,836 43,166 42,862
Road Dust 0 0 0 0 0 0 19,525 17,354 17,712 127,882 147,591 114,889 0 0 0 0 0 0

Fires 1,670 4,361 1,672 200 758 200 5,493 2,865 5,495 5,817 3,099 5,819 48 237 49 203 189 204
Subtotal 301,727 175,055 261,584 337,771 269,662 208,454 98,053 118,371 100,511 378,211 551,358 375,027 271,983 301,676 326,167 203,293 165,913 198,264 Biogenic 408,291 289,743 408,291 25,732 35,620 25,732

45

### EPA’ s D escriptions of the 2008 NEI Source C ategories

EPA’s descriptions of the Point

, NonPoint

, OnRoad , and NonRoad source categories used in the 2008 NEI are provided below ( from http://www.epa.gov/ttnchie1/net/2008inventory.html )

. As discussed above,

w h ere EPA’s 2008 NEI source category assignments differ from those used for the 2002/2018 inventories in the initial regional haze SIP

, the 2008 NEI data were re

- classified to maximi ze consistency

.

“ The NEI Point data category contains emissions estimates for sources that are individually inventoried and usually located at a fixed, stationary location, although portable sources such as some asphalt or rock crushing operations are a lso included. Point sources include large industrial facilities and electric power plants, but also increasingly include many smaller industrial and commercial facilities, such as dry cleaners and gas stations, which had traditionally been included in n on point sources. The choice of whether these smaller sources are estimated individually and included as poi nt sources or inventoried as a nonp oint source County or Tribal area aggregate is determined by the separate State, Local, or Tribal air agency. ” (No te, smaller source em issions are inventoried in the nonp oint source category in Iowa.)

“ The NEI NonPoint data category contains emissions estimates for sources which individually are too small in magnitude or too numerous to inventory as individual point sources, and which can often be estimated more accurately as a single aggregate source for a County or Tr ibal area. Examples are residential heating and consumer solvent use.

The NEI OnRoad and NonRoad data categories contain mobile sources which are estimated for the 2008 NEI v2 via the MOVES and NONROAD models, respectively. NONROAD was run within
the Na tional Mobile Inventory Model (NMIM). Note that emissions data for aircraft, locomotives, and commercial marine vessels are NOT included in the NonRoad data category starting with the 2008 NEI. Aircraft engine emissions occurring during Landing and Takeo ff operations and the Ground Support Equipment and Auxiliary Power Units associated with the aircraft are now included in the point data category at individual airports in the 2008 NEI. Emissions from locomotives that occur at rail yards are also included in the point data category.

In

- flight aircraft emissions, locomotive emissions outside of the rail yards, and commercial marine vessel emissions (both underway and port emissions) are included in the nonp oint data
category.

The Events data category includes wildfires, wild land fire use and prescribed burns. Wild land
fire use has been included in the "Fires

- Wildfires" sector. Emissions for these are presented as county totals on this website. ”

46

## Appendix D. **FLM and Public Comments** 

The Federal Land Manager s (FLMs) were provided a copy of the draft SIP on April 4, 2013, 69 da ys before the public hearing. Notices of the public comment period and public hearing were published in the Des Moines Register and posted on the State of Iowa’s Public Meeting Calendar on May 9, 2013. A

c op y of the printed p ublic notice is provided at the end of this appendix

. The public hearing was held June 11, 2013 . C omments received from the FLMs were available during the public hearing. No comments were received at the public hearing

. Federal Land Manager comments were received from the USDA Forest service, and jointly from the National Park Service and U

. S

. Fish and Wildlife Service.
Two additional comment letters were received before the public comment period closed on June 12,

2013. A summary of the comments and the Department’s responses is provided below

.



### Comments from the USDA Forest Service

FS

- 1 ) Comment: I owa did not incorporate the vast majority of the Forest Service comments when the
initial Iow a regional haze SI P was finalized, and that many of their concerns were echoed by the National
Park Service and E nvironmental Protection Agency. In the technical support documents , t he Forest Service pointed out that e mission controls were shown to be effective on a cost p er ton basis

, but these comments were not incorporated as Iowa determined there would be minimal visibility impact.

If Iowa, as the third largest contributor state, does not require controls because of minimal visibility impact, the burden of all the emis sion reductions to achieve the national visibility goal will fall primarily to the states containing Class I areas. The Forest Service encouraged the state to revisit their comments on Iowa’s initial regional haze SIP Iowa SIP because they are as applicab le today as they were in 2007

DNR Response : In the initial regional haze SIP submittal t he Department appropriately responded to all

comments provided by the Forest Service and all other public and FLM comments

. As was discussed in
the initial haze SIP, considering costs only on a per ton basis ignores the visibility impairment
component

. To achieve the same level of visibility improvement, source s farther from a class I area
woul d generally require more reductions than nearby source s

. This can sig nificantly elevate the costs of visibility improvement to remote sources , especially if the ir contributions are low. The initial regional haze SIP established Iowa’s contribution to the northern class I areas as only 4

- 5% of the total modeled visibility i mpairment, a small percentage compared to the contributions from Minnesota. Significant
shifts in the relative state

- to

- state contributions to visibility impairment have not been identified

. Changes in the relative state

- to

- state contributions to visibili ty impairment are expected to be evaluated in the next comprehensive SIP review due July 31, 2018. No new information is provided which
demonstrates controls are available for sources in Iowa which would be cost effective in terms of visibility improvement. The Department believes the original response to comments and the existing
emissions reductions that have occurred since 2002 are sufficient to support existing conclusions and to meet the applicable obligations of the five year report.

F S

- 2 ) Comment: The Forest Service acknowledges that the 5

- year report shows total emissions of NOx
and SO 2 from all Iowa sources in 2008 declined from the base year (2002). They also note non

- EGU NOx

47point source emissions increased over the same period. In comparison to 2018 projections, the 2008
state emissions are lower for S O2 but over 60,000 tons higher for NOx.

T he Forest Service believe s more emission reductions in Iow a are appropriate and feasible, and that multiple commenters noted the technical information available in 2007 showed that further emission
reductions in NOx and SO 2 were cost effective for both EGUs and non

- EGU s. The Forest Service provided the following related questions and examples :

• The Forest Ser vice would like to know the current level of emission controls in place at the Holcim facility. The Forest Service b elieve s Holcim should have been subject to a best available retrofit technology (BART) determination.

• The Forest Service notes i ndustrial boilers were identified by the Northern Class I Area Workgroup as a class of sources with potential for cost effective controls. These sources are included in the point, non

- EGU category where NOx emissions increased in Iowa

.

• For EGUs, Minnesota asked Io wa to achieve an SO2 emission rate comparable to Minnesota’s of 0.25 pounds per million BTU. Based on Figure 2

- 1, 2011 S O2 emission rates in Iowa are 0.47 pounds per million BTU.

DNR Response : The Department does not agree that more emissions reductions in Iowa are appropriate at this time or that cost effectiveness should be assessed only in terms of dollars per tons in
the context of the Regional Haze Rule . The Forest Service does not identify specific controls or specific
sources where emissions redu ctions would be feasible, nor are any potential visibility improvements provided

.

• With respect to concerns over the Holcim Facility, a Portland cement manufacturing facility in Mason City, Iowa, m anufacturing o perations ceased at Holcim in 2009 and the p lant has not operated since.

• The increase in non

- EGU NOx emissions between 2002 and 2008 was 121 tons per year. The
DNR does not consider this value significant in t he context of regional haze. It is also un realistic to expect that all NOx emissions red uctions projected between 2002 and 2018 in the initial regional haze SIP would be achieved by 2008

. However, the 2008 non

- EGU NOx emissions were 5,031 tons below 2018 projections, and a s of 2008 more than half of the projected 2002 to 2018
total NOx emiss ions reductions had been attained

. Further emissions reductions from this sector are anticipated with the implementation of the Industrial

, Commercial

, Institutional (ICI) boiler MACT. Additional review of the potential effects of the ICI boiler MACT can be assessed during the comprehensive regional haze SIP review due July 31, 2018.

The Department concluded in the original regional haze SI P that additional review of the ICI
boiler emissions was not warranted

. This finding contin ues to be applicable, as does the original

response (reproduced for convenience here):

“ Commensurate with the regional haze rule requirements for establishing reasonable progress goals, the Department considered the costs of controls in tandem with their potential for visibilit y improvement. Evaluating controls on a dollar per ton basis alone does not sufficiently justify their installation. Examining the Four Factor analysis report, the EGU cost effectiveness, in terms of dollars per deciview, across the nine

- state region

48reach ed $2,994,000,000. This is 83% of the total estimated costs of $3,600,000,000 for CAIR. Coupling these values with both the latest MRPO and CENRAP contribution analyses that link all Iowa point sources to approximately a 1

- 2 Mm - 1 contribution in 2018, th e statements are justified. ”

• The state’s overall 2011 EGU SO2 lbs/MMBtu emission rate does not inform or quantify visibility impacts. N o information was provided which demonstrates Iowa’s overall EGU SO2 emission rate is significant in terms of visibilit y impairment. The lbs/MMBtu emission rate does not automatically correlate to visibility impairment, as there is no consideration of distance,
transport, chemistry, or any other relevant atmospheric factors.

The Department concludes the significant decreases in statewide total SO2 and NOx emissions are sufficient to meet the relevant obligations of the five

- year regional haze review.

FS

- 3) Comment: D ecreases in emission rates from the 2002 baseline by themselves are not sufficient to
determine i f a state plan is adequate. The level of decre ase must be enough to meet Reasonable Progress Goals (R PGs ) . The RPGs set by Minnesota for the BWCAW were above the uniform rate of progress line indicating the pace of emission reductions must increase in the future to achieve the national visibility goal.

Department Response : The Department’s conclusions that the significant and unanticipated decreases in Iowa’s emissions are sufficient to determine adequacy of a state plan are consistent with EPA’s April 12, 2013, guidance memo for the five year review s ( General Principles for the 5

- Year Regional Haze Progress Reports for the Initial Regional Haze State Implementation Plans ). As a small contributor to visibility impairment in the Northern Class I ar eas, Iowa’s ability to effect significant improvements are limited, and additional changes to Iowa’s implementation of regional haze requirements are not needed
at this time. The Regional Haze Rule incorporates an extensive timeframe (to at least 2064) an d Iowa intends to comply with those timeframes for comprehensive review of the regional haze state implementation pla n.



### Comments from the National Park Service

These c omments were provided by the National Park Service (NPS) in consultation with the U.S

. F ish & Wildlife Service (USFWS). The NPS/USFWS stated that overall Iowa has met the minimum requirements for the periodic progress report and concurred that Iowa is not required to discuss monitoring trends in the five year review because there are no Clas s I areas in Iowa. The two NPS/USFWS comments that require responses are addressed below.

NPS/USFWS

- 1) Comment: The NPS/USFWS believe it would be helpful to provide a table of specific
EGUs in the state that shows what controls were added under CAIR.

DNR Response : For the five

- year review the Department believes it is appropriate to evaluate EGU emissions comprehensively rather than adding facility

- specific components. The addition of controls is not necessarily the best indicator of emissions reduct ions as it does not consider other factors such as facility curtailment , fuel

- switching, or the degree of control technology utilization.

49NPS/USFWS

- 2) Comment: The NPS/USFWS note that it may be appropriate to mention that the CENRAP 2002/2018 and the 2008 NEI mobile source inventory data are not directly comparable because the methodologies used to calculate the on road emissions have changed.

DNR Response : The Department agrees that the use of MOBI L E6 in development of the CENRAP inventory and the use of the Motor Vehicle Emissions Simulator ( MOVES ) model by EPA in developing
the 2008 NEI are significant ly differen t . Chapter 5 of the report has been modified to note the discrepancies and discuss pot ential implications. Appendix C has also been modified to include additional discussion regarding changes in emissions methodologies

.



### Comments from EPA Region 7

EPA

- 1 ) Comment: The increase in ammonia emissions (NH3) shown in section 4 of the report is not
addressed in the narrative. EPA suggests it may be useful to include a brief narrative on the increase in ammonia emissions that occurred between 2002 and 2008, as the reason for the increase is not apparent to the reader. EPA also notes the 2008 NH3 emissions estimates did not exceed the 2018 projection.

DNR response: Modifications in the methods use d to estimate NH3 emissions likely contribute to the
differences between the 2002/2018 and 2008 estimates

. Chapter 5 has been updated to include a brief discussion regarding these changes. Appendix C has also been modified to include additional discussion regarding changes in emissions methodologies

.

EPA

- 2 ) Comment: The opening sent ence of the conclusions section in Chapter 6 appears contradictory
to the rest of the section and the rest of the conclusions.

DNR Response: The word “reductions” was inadvertently omitted from this sentence

. The sentence
has be en corrected and is now consistent with the existing conclusions

.

EPA

- 3 ) Comment : EPA suggests, but does not require, adding trend lines for each emissions category in Figure 5

- 1

.

DNR Response : Figure 5

- 1 provides a c omparison of Iowa’s actual emissions for 2002 and 2008, and the

2018 projections. The scale for the emissions data used in the f igure is adequate for readers to discern the pollutant trends for each source category. The Department does not believe a dding trendline s is necessary for communication of the meaning of the data

.



### Comments from **the Min**  **nesota Pollution Control Agency (MPC**  **A)**

MPCA Comment: The Minnesota Pollution Control Agency (MPCA) continues to be interested i n the progress made by sources in Iowa to reduce emissions that contribute to regional haze. The MPCA is pleased to note that SO2 and NOx emissions from EGUs in 2011 had decreased from 2008. MPCA also

50notes that 2011 levels are well below the projections for 2018. They also note that further reductions of SO2 will occur at EGUs that are either subject to a consent decree or will be retired.

M innesota also noted that in a letter dated September 19, 2007, they identified a target of reducing SO2

emissio ns from EGUs in contributing states to 0.25 lbs/MMBtu to address the improvement goal for the 20% worst visibility days. Minnesota encourages the state to continue to work towards meeting this target. Minnesota also notes their EGU’s have achieved a rate of approximately 0.17 lbs/MMBtu in 2012, and that they are now more concerned about the relative contribution from EGUs in other states.

DNR Response : The original regional haze modeling conducted by CENRAP indicated Minnesota’s
contributions to their c lass I area’s 20% worst impaired visibility days ranged from 26

- 30%, while Iowa’s contributions were five to six times lower (4

- 5%, see Table 11.1 of Iowa’s initial regional haze SIP). The Department did not see a compelling argument from Minnesota that d emonstrated how Iowa’s adoption of the 0.25 lbs/MMBtu request would benefit Minnesota’s Class I areas. Minnesota provides no causal linkage between visibility impairment and a statewide lb/MMBtu EGU emission rate, and provides no demonstration that SO2 l b/MMBtu emission rate reductions in Iowa will improve visibility in

the Minnesota Class I areas. I t is appropriate for Minnesota to seek and achieve greater in

- state reductions as their contributions and source proximities to Class I areas greatly exceed those of Iowa. The significant SO2 and NOx emission reductions (tons per year) that have occurred in Iowa since 2002
are sufficient for Iowa to meet the applicable regional haze obligations.

51

### Public Notice **Documents**

The following public notice was published in the May 9, 2013

, edition of the Des Moines Register. Proof of publication date can be found in the next page (“0509” in the DATE column)

.

5253The following information was posted to the State of Iowa’s Public Meeting Calendar.

54

## Appendix E. **Legal Authority** 

The DNR is the primary state agency responsible for protecting the environment, as indicated in the Iowa Code § 455A. The Environmental Protection Commission, established in the Iowa Code § 455A.6, is the governing commission for the environment al protection portion of the DNR. The DNR’s authority is provided under Iowa Code § 455B.133 and 455B.134 which are listed below. Additional information on
the Iowa Code is at http://www .legis.iowa.gov/IowaLaw/statutoryLaw.aspx

.



### 455B.133 Duties.

The commission shall:

1. Develop comprehensive plans and programs for the abatement, control, and prevention of air pollution in this state, recognizing varying requirements for different areas in the state. The plans may include emission limitations, schedules and timetables for compliance with the limitations, measures to prevent the significant deterioration of air quality and other measures as necessary to assure attainment
and maintenance o f ambient air quality standards.

2. Adopt, amend, or repeal rules pertaining to the evaluation, abatement, control, and prevention of air pollution. The rules may include those that are necessary to obtain approval of the state implementation plan under section 110 of the federal Clean Air Act as amended through January 1,

1991.

3. Adopt, amend, or repeal ambient air quality standards for the atmosphere of this state on the basis of providing air quality necessary to protect the public health and welfare and to reduce emissions contributing to acid rain pursuant to Tit. IV of the federal Clean Air Act Amendments of 1990.

4. Adopt, amend, or repeal emission limitations or standards relating to the maximum quantities of air contaminants that may be emitted from any air contaminant source. The standards or limitations adopted under this section shall not exceed the standards or limitations promulgated by the administrator of the United States environmental protection agency or the requirements of the federal Clean Air Act as amended through January 1, 1991. This does not prohibit the commission from adopting
a standard for a source or class of sources for which the United States environmental protection agency
has not promulgated a standard. This also does no t prohibit the commission from adopting an emission standard or limitation for infectious medical waste treatment or disposal facilities which exceeds the standards or limitations promulgated by the administrator of the United States environmental protecti on agency or the requirements of the federal Clean Air Act as amended through January 1, 1991. The commission shall not adopt an emission standard or limitation for infectious medical waste treatment or disposal facilities prior to January 1, 1995, which e xceeds the standards or limitations promulgated by the administrator of the United States environmental protection agency or the requirements of the federal Clean Air Act, as amended through January 1, 1991, for a hospital, or a group of hospitals, license d under chapter 135B which has been operating an infectious medical waste

treatment or disposal facility prior to January 1, 1991.

a. (1) The commission shall establish standards of performance unless in the judgment of the
commission it is not feasible t o adopt or enforce a standard of performance. If it is not feasible to adopt or enforce a standard of performance, the commission may adopt a design, equipment, material, work practice or operational standard, or combination of those standards in order to

55establish reasonably available control technology or the lowest achievable emission rate in nonattainment areas, or in order to establish best available control technology in areas subject to prevention of significant deterioration review, or in order to a dopt the emission limitations promulgated by the administrator of the United States environmental protection agency under section 111 or 112 of the federal Clean Air Act as amended through January 1, 1991.

(2) If a person establishes to the satisfaction of the commission that an alternative means of emission limitation will achieve a reduction in emissions of an air pollutant at least equivalent to the reduction in emissions of the air pollutant achieved under the design, equipment, material, work practic e or operational standard, the commission shall amend its rules to permit the use of the alternative by the source for purposes of compliance with this paragraph with respect to the pollutant.

(3) A design, equipment, material, work practice or operationa l standard promulgated under this paragraph shall be promulgated in terms of a standard of performance when it becomes feasible to promulgate and enforce the standard in those terms.

(4) For the purpose of this paragraph, the phrase “not feasible to adopt or enforce a standard of performance” refers to a situation in which the commission determines that the application of measurement methodology to a particular class of sources is not practicable due to technological or economic limitations.

b. If the max imum standards for the emission of sulfur dioxide from solid fuels have to be reduced in an area to meet ambient air quality standards, a contract for coal produced in Iowa and burned by a facility
in that area that met the sulfur dioxide emission standards in effect at the time the contract went into effect shall be exempted from the decreased requirement until the expiration of the contract period or December 31, 1983, whichever first occurs, if there is any other reasonable means available to sat isfy the ambient air quality standards. To qualify under this subsection, the contract must be recorded with the county recorder of the county where the burning facility is located within thirty days after the signing of the contract.

c. The degree of emi ssion limitation required for control of an air contaminant under an emission standard shall not be affected by that part of the stack height of a source that exceeds good engineering practice, as defined in rules, or any other dispersion technique. This paragraph shall not apply to stack heights in existence before December 30, 1970, or dispersion techniques implemented before that date.

5. Classify air contaminant sources according to levels and types of emissions, and other characteristics
which relate to air pollution. The commission may require, by rule, the owner or operator of any air contaminant source to establish and maintain such records, make such reports, install, use and maintain such monitoring equipment or methods, sample such emissions in accordance with such methods at such locations and intervals, and using such procedures as the commission shall prescribe, and provide
such other information as the commission may reasonably require. Such classifications may be for application to the state as a whole, or to any designated area of the state, and shall be made with special reference to effects on health, economic and social factors, and physical effects on property.

6. a. Require, by rules, notice of the construction of any air contaminant s ource which may cause or contribute to air pollution, and the submission of plans and specifications to the department, or other information deemed necessary, for the installation of air contaminant sources and related control

56equipment. The rules shall al low the owner or operator of a major stationary source to elect to obtain a conditional permit in lieu of a construction permit. The rules relating to a conditional permit for an electric power generating facility subject to chapter 476A and other major st ationary sources shall allow
the submission of engineering descriptions, flow diagrams and schematics that quantitatively and qualitatively identify emission streams and alternative control equipment that will provide compliance
with emission standards. Su ch rules shall not specify any particular method to be used to reduce undesirable levels of emissions, nor type, design, or method of installation of any equipment to be used to reduce such levels of emissions, nor the type, design, or method of installati on or type of construction of any manufacturing processes or kinds of equipment, nor specify the kind or composition of fuels permitted to be sold, stored, or used unless authorized by subsection 4 of this section.

b. The commission may give technical adv ice pertaining to the construction or installation of the equipment or any other recommendation.

7. Commission rules establishing maximum permissible sulfate content shall not apply to an expansion of an industrial anaerobic lagoon facility which was cons tructed prior to February 22, 1979.

8. a. Adopt rules consistent with the federal Clean Air Act Amendments of 1990, Pub. L. No. 101

- 549, which require the owner or operator of an air contaminant source to obtain an operating permit prior to operation of the source. The rules shall specify the information required to be submitted with the application for a permit and the conditions under which a permit may be granted, modified, suspended, terminated, revoked, reissued, or denied. For sources subject to th e provisions of Tit. IV of the federal
Clean Air Act Amendments of 1990, permit conditions shall include emission allowances for sulfur
dioxide emissions. The commission may impose fees, including fees upon regulated pollutants emitted
from an air contamin ant source, in an amount sufficient to cover all reasonable costs, direct and indirect, required to develop and administer the permit program in conformance with the federal Clean Air Act Amendments of 1990, Pub. L. No. 101

- 549. Affected units regulated un der Tit. IV of the federal Clean Air Act Amendments of 1990, Pub. L. No. 101

- 549, shall pay operating permit fees in the same manner as other sources subject to operating permit requirements, except as provided in section 408 of
the federal Act. The fees c ollected pursuant to this subsection shall be deposited in the air contaminant source fund created pursuant to section 455B.133B, and shall be utilized solely to cover all reasonable costs required to develop and administer the programs required by Tit. V of the federal Clean Air Act Amendments of 1990, Pub. L. No. 101

- 549, including the permit program pursuant to section 502 of the
federal Act and the small business stationary source technical and environmental assistance program pursuant to section 507 of the federal Act.

b. Adopt rules allowing the department to issue a state operating permit to an owner or operator of an air contaminant source. The state operating permit granted under this paragraph may only be issued at the request of an air contaminan t source and will be used to limit its potential to emit to less than one hundred tons per year of a criteria pollutant as defined by the United States environmental protection agency or ten tons per year of a hazardous air pollutant or twenty

- five tons of any combination of hazardous air pollutants.

c. Adopt rules for the issuance of a single general permit, after notice and opportunity for a public hearing. The single general permit shall cover numerous sources to the extent that the sources are

represen tative of a class of facilities which can be identified and conditioned by a single permit.

579. Adopt rules allowing asphalt shingles to be burned in a fire set for the purpose of bona fide training of public or industrial employees in fire fighting methods only if a notice is provided to the director containing testing results indicating that the asphalt shingles do not contain asbestos. Each fire department shall be permitted to host two fires per year as allowed under this subsection.

10. Adopt ru les allowing a city to conduct a controlled burn of a demolished building subject to the requirements that are in effect for the proper removal of all asbestos

- containing materials prior to demolition and burning. The rules shall include provisions that a burn site have controlled access, that a burn site be supervised by representatives of the city at all times, and that the burning be conducted only when weather conditions are favorable with respect to surrounding property. For a burn site
located outside of a city, the rules shall include a provision that a city may undertake not more than one such controlled burn per day and that a burn site be limited to an area located at least six

- tenths of a mile from any inhabited building. For burn sites located wi thin a city, the rules shall include a provision that a city may undertake not more than one such controlled burn in every six

- tenths

- of

- a

- mile

- radius
circle in each calendar year. The rules shall prohibit a controlled burn of a demolished building in Cedar Rapids, Marion, Hiawatha, Council Bluffs, Carter Lake, Des Moines, West Des Moines, Clive, Windsor Heights, Urbandale, Pleasant Hill, Buffalo, Davenport, Mason City, or any other area where area

- specific state implementation plans require the control of particulate matter.

[C71, §136B.4; C73, 75, 77, 79, 81, §455B.12; 82 Acts, ch 1124, §1] C83, §455B.133 91 Acts, ch 242, §1; 91 Acts, ch 255, §8; 92 Acts, ch 1163, §87

– 89; 93 Acts, ch 137, §3; 94 Acts, ch 1040, §1; 95 Acts, ch 2, §1; 2002 Acts, ch 1162, §45; 2002 Acts, 2nd Ex, ch 1003, §241, 262; 2004 Acts, ch 1138, §1; 2010 Acts, ch 1061, §180

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### 455B.134 Director

— duties

— limitations.

The director shall:

1. Publish and administer the rules and standards established by the commission. The depart ment shall furnish a copy of such rules or standards to any person upon request.

2. Provide technical, scientific, and other services required by the commission or for the effective administration of this division II and chapter 459, subchapter II.

3. Gr ant, modify, suspend, terminate, revoke, reissue or deny permits for the construction or operation of new, modified, or existing air contaminant sources and for related control equipment, and conditional permits for electric power generating facilities sub ject to chapter 476A and other major stationary sources, subject to the rules adopted by the commission. The department shall furnish necessary application forms for such permits.

a. No air contaminant source shall be installed, altered so that it signif icantly affects emissions, or placed in use unless a construction or conditional permit has been issued for the source.

b. The condition of expected performance shall be reasonably detailed in the construction or conditional permit.

c. All applications f or permits other than conditional permits for electric generating facilities shall be subject to such notice and public participation as may be provided by rule by the commission. Upon denial or limitation of a permit other than a conditional permit for an electric generating facility, the applicant shall be notified of such denial and informed of the reason or reasons therefor, and such applicant shall be entitled to a hearing before the commission.

d. (1) All applications for conditional permits for elec tric power generating facilities shall be subject to such notice and opportunity for public participation as may be consistent with chapter 476A or any agreement pursuant thereto under chapter 28E. The applicant or intervenor may appeal to the commission from the denial of a conditional permit or any of its conditions. For the purposes of chapter 476A, the issuance or denial of a conditional permit by the director or by the commission upon appeal shall be a determination that the electric power generating facility does or does not meet the permit and licensing requirements of the commission. The issuance of a conditional permit shall not relieve the applicant of the responsibility to submit final and detailed construction plans and drawings and an applicati on for a construction permit for control equipment that will meet the emission limitations established in the conditional permit.

(2) In applications for conditional permits for electric power generating facilities, the applicant shall quantify the potential to emit greenhouse gas emissions due to the proposed project.

e. A regulated air contaminant source for which a construction permit or conditional permit has been issued shall not be operated unless an operating permit also has been issued for t he source. However, if the facility was in compliance with permit conditions prior to the requirement for an operating permit and has made timely application for an operating permit, the facility may continue operation until the operating permit is issued or denied. Operating permits shall contain the requisite conditions and compliance schedules to ensure conformance with state and federal requirements including emission

59allowances for sulfur dioxide emissions for sources subject to Tit. IV of the federal Clean Air Act
Amendments of 1990. If construction of a new air contaminant source is proposed, the department may

issue an operating permit concurrently with the construction permit, if possible and appropriate.

f. (1) Notwithstanding any other provision of division II of this chapter or chapter 459, subchapter II, the following siting requirements shall apply to anaerobic lagoons and earthen waste slurry storage basins:

(a ) Anaerobic lagoons, constructed or expanded on or after June 20, 1979, but prior to May 31, 1995, or earthen waste slurry storage basins, constructed or expanded on or after July 1, 1990, but prior to May 31, 1995, which are used in connection with animal feeding operations containing less than six hundred twenty

- five thousand pounds l ive animal weight capacity of animal species other than beef cattle or containing less than one million six hundred thousand pounds live animal weight capacity of beef cattle, shall be located at least one thousand two hundred fifty feet from a residence n ot owned by the owner of the feeding operation or from a public use area other than a public road. Anaerobic lagoons or earthen waste slurry storage basins, which are used in connection with animal feeding operations containing six hundred
twenty

- five thou sand pounds or more live animal weight capacity of animal species other than beef cattle or containing one million six hundred thousand pounds or more live animal weight capacity of beef cattle, shall be located at least one thousand eight hundred seventy

- five feet from a residence not owned by the owner of the feeding operation or from a public use area other than a public road. For the purpose of this paragraph the determination of live animal weight capacity shall be based on the average animal weight ca pacity during a production cycle and the maximum animal capacity of the animal feeding operation.

(b) Anaerobic lagoons which are used in connection with industrial treatment of wastewater where the average wastewater discharge flow is one hundred thousan d gallons per day or less shall be located at least one thousand two hundred fifty feet from a residence not owned by the owner of the lagoon or from a public use area other than a public road. Anaerobic lagoons
which are used in connection with industria l treatment of wastewater where the average wastewater discharge flow is greater than one hundred thousand gallons per day shall be located at least one thousand eight hundred seventy

- five feet from a residence not owned by the owner of the lagoon or from a public use area other than a public road. These separation distances apply to the construction of new facilities and the expansion of existing facilities.

(2) A person may build or expand an anaerobic lagoon or an earthen waste slurry storage basin
clos er to a residence not owned by the owner of the anaerobic lagoon or to a public use area than is otherwise permitted by subparagraph (1) of this paragraph, if the affected landowners enter into a written agreement with the anaerobic lagoon owner to waive the separation distances under such terms the parties negotiate. The written agreement becomes effective only upon recording in the office of the recorder of deeds of the county in which the residence is
located.

g. All applications for construction permi ts or prevention of significant deterioration permits shall quantify the potential to emit greenhouse gas emissions due to the proposed project.

4. Determine by field studies and sampling the quality of atmosphere and the degree of air pollution in
this s tate or any part thereof.

605. Conduct and encourage studies, investigations, and research relating to air pollution and its causes, effects, abatement, control, and prevention.

6. Provide technical assistance to political subdivisions of this state reques ting such aid for the furtherance of air pollution control.

7. Collect and disseminate information, and conduct educational and training programs, relating to air pollution and its abatement, prevention, and control.

8. Consider complaints of conditions reported to, or considered likely to, constitute air pollution, and investigate such complaints upon receipt of the written petition of any state agency, the governing body of a political subdivision, a local board of health, or twenty

- five affected reside nts of the state.

9. Issue orders consistent with rules to cause the abatement or control of air pollution, or to secure compliance with permit conditions. In making the orders, the director shall consider the facts and circumstances bearing upon the reas onableness of the emissions involved, including but not limited to, the character and degree of injury to, or interference with, the protection of health and the physical property of the public, the practicability of reducing or limiting the emissions from the air pollution source, and the suitability or unsuitability of the air pollution source to the area where it is located. An order may include advisory recommendations for the control of emissions from an air contaminant
source and the reduction of the emission of air contaminants.

10. Encourage voluntary cooperation by persons or affected groups in restoring and preserving a reasonable quality of air within the state.

11. Encourage political subdivisions to handle air pollution problems within their respective jurisdictions.

12. Review and evaluate air pollution control programs conducted by political subdivisions of the state with respect to whether the programs are consistent with the provisions of division II of this chapter and chapter 459, subch apter II, and rules adopted by the commission.

13. Hold public hearings, except when the evidence to be received is confidential pursuant to section 455B.137, necessary to accomplish the purposes of division II of this chapter and chapter 459, subchapter II. The director may issue subpoenas requiring the attendance of witnesses and the production of evidence pertinent to the hearings. A subpoena shall be issued and enforced in the same
manner as in civil actions.

14. Convene meetings not later than June 1 during the second calendar year following the adoption of new or revised federal ambient air quality standards by the United States environmental protection agency to review emission limitations or standards relating to the maximum quantities of air

conta minants that may be emitted from any air contaminant source as provided in section 455B.133, subsection 4. By November 1 of the same calendar year, the department shall submit a report to the governor and the general assembly regarding recommendations for law changes necessary for the
attainment of the new or revised federal standards.

[C71, §136B.4, 136B.5; C73, 75, 77, 79, §455B.12, 455B.13; C81, §455B.13; 82 Acts, ch 1124, §2, 3] C83, §455B.134

6186 Acts, ch 1245, §1899; 90 Acts, ch 1153, §2, 3; 91 Acts, ch 255, §11

- 13; 93 Acts, ch 137, §4; 95 Acts, ch 195, §14; 2007 Acts, ch 120, §2, 3; 2010 Acts, ch 1115, §1; 2011 Acts, ch 25, §49, 50 For regulations establishing separation distances between anaerobic lagoons or earthen manure storage structures

constr ucted or expanded on or after May 31, 1995, and various locations and objects, see chapter 459 For regulations governing the construction of earthen storage structures within agricultural drainage well areas, see chapter 460 Subsection 3, paragraph d, subp aragraph (2) amended Subsection 3, paragraph g amended

62

### 567 Iowa Administrative Code Chapters for Air Quality
Chapters 20

- 29, 31, and 33

- 34 of 567 Iowa Administrative Code contain the administrative rules that allow for the implementation of the relevant air quality laws contained in Iowa statute and the CAA, including Section 110.

• Chapter 20 provides general definitions and rules of practice.

• Provisions for compliance schedules are found in Chapter 21.

• Standards and procedures for the permitting of e mission sources, periodic monitoring, and requirements for nonattainment areas are found in Chapter 22.

• Air emission standards for contaminants are found in Chapter 23.

• Chapter 24 provides for the reporting of excess emissions and the equipment mainten ance and repair requirements.

• Testing and sampling requirements for new and existing sources are found in Chapter 25.

• Chapter 26 identifies air pollu tion emergency episodes and preplanne d abatement strategies

.

• Conditions that political subdivisions must meet in order to secure acceptance of a local air pollution control program are set forth in Chapter 27.

• Chapter 28 identifies the state’s adopted ambient air quality standards.

• Qualifications for observers o f visible emission are found in Chapter 29.

• Chapter 31 contains the conformity of general federal actions to the Iowa state implementation plan or federal implementation plan.

• Chapter 33 contains special regulations and construction permit requirements for major stationary sources and includes the requirements for PSD.

• Provisions for air quality emissions trading programs are found in Chapter 34.

63