# ENCLOSURE 6 :

TECHNICAL SUPPORT DOCUMENT REQUIRED BY SECTION 2.2

OF APPENDIX VTO40 CFR PART 51TECHNICAL SUPPORT DOCUMENT REQUIRED BY 40 CFRPART 51, APP . V, §2.2 (a) Identification ofall 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 ofthe 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 GHGpermitting are only for new

and modified sources. There are no "existing" sources affected at this time. Further, the entire State ofVermont is currently designated as attainment/unclassifiable for all ofthe 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 fromthe affected sources; estimates of changes in current actual emissions fromaffected sources or, where appropriate, quantification of changes in actual emissions fromaffected sources through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision. The proposed NSRrevisions regarding GHGpermitting 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 fromwhat 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 SIPrevision is proposed to meet the EPA's GHGTailoring Rule requirements. Vermont has not proposed any changes that would significantlyaffect the protection ofthe NAAQS, prevention ofsignificant 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 ofoffsite data (where used), modes of models used, assumptions, and other information relevant to the determination ofadequacy of the modeling analysis. Modeling in support ofthis 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 GHGemissions 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 technologicaljustifications required by any applicable EPA policies, or an explanation ofwhy suchjustifications are not necessary. Not applicable. There are no special economic or technologicaljustifications required.