ENCLOSURE 6: 

TECHNICAL SUPPORT DOCUMENT REQUIRED BY SECTION 2 .2 

OF APPENDIX V TO 40 CFR PART 5 1 
TECHNICAL SUPPORT DOCUMENT REQUIRED BY 40 CFR PART 51, APP. V, §2.2 

(a) Identification of all regulated pollutants affected by the plan. 

The only regulated pollutant significantly affected by the plan is greenhouse gases 

(GHGs), including carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, 

perfluorocarbons, and sulfur hexafluoride . Regulatory amendments to other parts 

of the Vermont Air Pollution Control Regulations will not significantly impact 

other pollutants . 

(b) Identification of the locations of affected sources including the EPA 

attainment/nonattainment designation of the locations and the status of the 

attainment plan for the affected areas(s) . 

The proposed new source review (NSR) revisions regarding GHG permitting are 

only for new and modified sources . There are no "existing" sources affected at 

this time . Further, the entire State of Vermont is currently designated as 

attainment/unclassifiable for all of the National Ambient Air Quality Standards 

(NAAQS) and there is no NAAQS for GHG. Therefore, the State is not required 

to submit an attainment plan for affected sources and section 2.2 is not applicable 

to this rule. ' 

(c) Quantification of the changes in plan allowable emissions from the affected 

sources ; estimates of changes in current actual emissions from affected sources or, 

where appropriate, quantification of changes in actual emissions from affected 

sources through calculations of the differences between certain baseline levels and 

allowable emissions anticipated as a result of the revision . 

The proposed NSR revisions regarding GHG permitting are only for new or 

modified sources subject to regulation. Therefore, we cannot predict which, if 

any, sources will become affected and thus we cannot quantify the changes in 

plan emissions. However, we can expect emissions to be the same or reduced 

from what they otherwise would be for any source that becomes affected . 

(d) The State's demonstration that the national ambient air quality standards, 

prevention of significant deterioration increments, reasonable further progress 

demonstration, and visibility, as applicable, are protected if the plan is approved 

and implemented. For all requests to redesignate an area to attainment for a 

national primary ambient air quality standard, under section 107 of the Act, a 

revision must be submitted to provide for the maintenance of the national primary 

ambient air quality standards for at least 10 years as required by section 175A of 

the Act. 

This SIP revision is proposed to meet the EPA's GHG Tailoring Rule 

requirements. Vermont has not proposed any changes that would significantly 
affect the protection of the NAAQS, prevention of significant deterioration 

increments, reasonable further progress demonstration, or visibility . 

(e) Modeling information required to support the proposed revision, including input 

data, output data, models used, justification of model selections, ambient monitoring 

data used, meteorological data used, justification for use of offsite data (where 

used), modes of models used, assumptions, and other information relevant to the 

determination of adequacy of the modeling analysis. 

Modeling in support of this submittal is not applicable. 

(f) Evidence, where necessary, that emission limitations are based on continuous 

emission reduction technology. 

Not applicable. This submittal does not establish emission limitations but rather, 

applicability criteria for determining which sources of GHG emissions are subject 

to existing permitting requirements . 

(g) Evidence that the plan contains emission limitations, work practice standards 

and recordkeeping/reporting requirements, where necessary, to ensure emission 

levels . 

Not applicable - see above. 

(h) Compliance/enforcement strategies, including how compliance will be 

determined in practice. 

Not applicable. Vermont's procedures for determining compliance/enforcement 

are not changed by this submittal. 

(i) Special economic and technological justifications required by any applicable EPA 

policies, or an explanation of why such justifications are not necessary. 

Not applicable. There are no special economic or technological justifications 

required .