SUMMARY OF COMMENTS AND STAFF RESPONSES FOR PROPOSED REVISION

TO THE OKLAHOMA REGIONAL HAZE STATE IMPLEMENTATION PLAN

COMMENTS RECEIVED PRIOR TO AND AT THE DECEMBER 16, 2009 PUBLIC HEARING

Written Comments

U. S. Environmental Protection Agency, Region 6 (EPA) in a letter dated December 15, 2009, signed by 

Carrie Paige for Guy Donaldson, Chief, Air Planning Section

1. COMMENT: Although on page 68, ODEQ states that Appendix V, Section 2.1(b) through (h), are 

included in Appendix 6-1, it does not appear that is the case. ODEQ should ensure, with the 

submittal of the final SIP, it demonstrates it has followed the requirements of Appendix V to 

Part 51.

RESPONSE: DEQ has added the required administrative materials.

2. COMMENT: On page 35, ODEQ states that for the purposes of calculating natural conditions, it 

considered all organic carbonaceous particulate, coarse matter, and fine soils as natural and all 

sulfureous, nitrate, and elemental carbon particulate as anthropogenic. This assumption ignores 

fine soil contribution from agricultural practices, such as wind-blown dust from tilled fields. 

Historically, this has been a significant source of fine soil. 

RESPONSE: It appears that EPA may misunderstand the purpose of this consideration. This 

consideration applied to “pseudo-natural” conditions, where the prefix “pseudo-” means false, 

deceptive, and sham. DEQ included these pseudo-natural conditions to highlight the three 

categories of particulate for which DEQ possesses enough evidence to attempt to regulate in 

this implementation plan revision. DEQ included this calculation to enlighten the reader 

regarding the efficacy of a strategy designed to reduce emissions contributing to these three 

categories of other particulate matter. 

DEQ concurs with EPA regarding the accounting of this contribution but finds this contribution 

relatively small and impossible to isolate at the Wichita Mountains. DEQ will address these 

sources in comprehensive periodic revisions to this implementation plan under 

40 CFR § 51.308(f). 

3. COMMENT: On page 32, ODEQ expands this discussion as it relates to fire, stating it assumed an 

overwhelming majority of organic aerosols originate from natural sources or fires. It is unclear 

whether this assumption ignores organic carbonaceous contributions from non-natural sources, 

such as agricultural fires and fires used to clear rangeland. Because of the economic component 

associated with these fires, it is unclear how they can be considered natural. Consequently, 

Region 6 feels these assumptions have not been adequately justified. 

RESPONSE: The final paragraph in Section III.A.3 has been deleted in its entirety. 

4. COMMENT: Also, these assumptions impact the requirement in 40 CFR 51.308(d)(3)(iv), which 

requires ODEQ identify all anthropogenic sources of visibility impairment considered by it in 

developing its LTS, including consideration of major and minor stationary sources, mobile 

sources, and area sources. 
RESPONSE: DEQ identifies all sources of emissions that degrade visibility in Section IV, which 

reinforces the assumptions concerned. DEQ considered all anthropogenic sources in developing 

the long-term strategy. DEQ will not control fires and various other sources as part of this 

implementation plan revision for various reasons, including their relatively small contribution to 

total visibility impairment and the administrative difficulty associated with such controls. 

5. COMMENT: On page 104, ODEQ states “Despite their prominence in the emissions inventory, 

agricultural burning and wildfires in Oklahoma do not contribute significantly to regional haze at 

the Wichita Mountains nor at any other Class I area.” However, Region 6 notes that according 

to Tables IV-1, IV-2, and IV-8, fire emissions account for approximately 33% of Oklahoma’s PM 

2.5 emissions inventory with agricultural burning itself accounting for approximately 23%. It 

would therefore appear that anthropogenic sources of biomass burning emissions are a 

significant contributor to the state’s PM 2.5 emission inventory. Especially when it is considered 

that much of these emissions usually occur within a few weeks in the spring or summer and are 

not evenly spread out over the year. 

RESPONSE: DEQ presumed that most particulate matter emitted from fires primarily takes the 

forms of organic and elemental carbonaceous particulate. Measurements of these components 

of visibility impairment at the Wichita Mountains do not indicate that these components of 

particulate matter predominate on many days without prescribed burning on the Wildlife 

Refuge or catastrophic fires in the vicinity. 

Table IV-1 does not disaggregate fire emissions from any emissions category. Table IV-2 lists all 

emissions from fire area sources, totaled according to category. The cited statistics come only 

from Table IV-8, which Environmental Protection Agency slightly misinterprets. Extensive 

burning in the Flint Hills region of Kansas and Oklahoma generally occurs during periods of 

southerly flow near the surface, and few Class I areas lie downwind of these fires. Agricultural 

grass fires alone account for 23% of direct PM2.5 emissions. The “all other” fire area sources 

classification in the table includes various other agricultural fires. 

Despite the large proportion of directly emitted PM2.5 attributed to fires, DEQ does not believe 

that smoke from these fires contributes significantly to regional haze at the Wichita Mountains 

on the overwhelming majority of days. DEQ uses the Interagency Monitoring of Protected 

Visual Environments (IMPROVE) protocol to measure regional haze in accordance with 

40 CFR § 51.308(d)(4). This monitoring technique does not consider smoke plumes aloft as 

regional haze or any other form of visibility impairment in contrast to the definition of visibility 

impairment in 42 USC § 7491(g)(6). DEQ follows the EPA’s lead in not addressing atmospheric 

discoloration from smoke plumes aloft under as visibility impairment presently. Numerous 

pollutants emitted as gases not directly emitted as PM2.5 convert to particles in the atmosphere, 

also contributing to regional haze. Anthropogenic sources other than fires emit a considerable 

majority of these gases. 

Fires generally occur on days with atmospheric conditions that limit smoke spreading at the 

surface. Most smoke usually forms plumes aloft and generally travels above monitoring 

equipment. Easily identifiable smoke reached the Wichita Mountains in any considerable 

quantity on only a few monitored days. These events included known burning on the Wichita 

Mountains Wildlife Refuge and catastrophic fire. 
6. COMMENT: Region 6 understands that ODEQ is presently developing a smoke management 

plan. We view this as very important tool in the control of these emissions and urge ODEQ to 

work with us in the finalization of this important document. 

RESPONSE: DEQ will work with EPA as it develops the smoke management plan.

7. COMMENT: Section 51.308(d)(1)(iv) requires that ODEQ consult with those States which may 

reasonably be anticipated to cause or contribute to visibility impairment for the Wichita 

Mountains. According to Tables V-1-V-6, and as noted on page 66, Texas accounts for more 

sulfurous, nitrate, organic carbonaceous, elemental carbonaceous, and fine soil particulate 

sources of light extinction to the Wichita Mountains than do those source in Oklahoma, and is 

right behind Oklahoma in coarse particulate. Table V-8 also indicated the sulfurous sources 

from Louisiana and Indiana also account for more light extinction than do the sulfurous sources 

in Oklahoma. Appendix 10-1 contains several consultation letters between ODEQ and 

neighboring States regarding ODEQ’s consultation efforts. However, despite the obvious

contribution from Texas sources to the visibility degradation to the Wichita Mountains, it does 

not appear that ODEQ actually requested reductions from specific sources within Texas – only 

that it be consulted on BACT analyses for sources within 300 kilometers from the Wichita 

Mountains. We urge Oklahoma insure that Texas is aware its sources impacts and encourage 

reductions as necessary.

RESPONSE: DEQ’s consultations with Texas are accurately documented in this SIP revision and 

information provided during those consultations clearly indicate Texas sources contribute 

significantly to visibility impairment at the Wichita Mountains.

8. COMMENT: ODEQ should include in Section X and in Appendix 10-1 the details concerning its 

consultation with Louisiana, or discuss why it did not feel sources in Louisiana are not 

reasonably anticipated to cause or contribute to visibility impairment at Wichita Mountains, in 

fulfillment of Section 51.309(D)(1)(iv). 

RESPONSE: DEQ’s consultations with Louisiana are accurately documented in this SIP revision 

and information provided during those consultations clearly indicated the contributions from 

Louisiana sources to visibility impairment at the Wichita Mountains.

9. COMMENT: On page 69, ODEQ discusses how it identified which sources were BART-eligible, 

stating, “DEQ reviewed its emissions inventory and followed the steps listed in Subsection II.A 

of Appendix Y to 40 C.F.R. Part 51 to derive a list of BART-eligible sources.” However, no other 

information was located that describes the steps ODEQ took to make this determination. ODEQ 

should expand this discussion, making particular reference to information sources (e.g., permit 

databases, surveys, etc.) and how it ensured all BART-eligible sources were identified.

RESPONSE: Additional information has been added to the BART chapter.

10. On page 71, Table VI-3 lists BART-eligible sources that were granted waivers from BART via 

proposed permitted emission limits. The actual waivers in Appendix 6-3, all contain essentially 

the same language:
“The active Title V permit will now be modified to include requirements that the facility 

comply with the proposed changes/limits in the application within five years of the 

Regional Haze SIP approval by EPA. Also to be included, will be a requirement that the 

facility modify the operating permit to incorporate the proposed method of compliance 

with Appendix Y to Part 51, V. Enforceable Limits. The operating permit shall be 

modified no later than 6 months prior to the SIP approval.”

Regarding this, ODEQ should address the following:

a) COMMENT: No information was provided that indicates what controls or practices 

would be necessary to comply with these new permit limits. ODEQ should ensure 

that if compliance is via relatively uncomplicated work practices or operational 

modifications that can be done in a relatively short period of time, the full five years 

is not granted. This is necessary in order to comply with 51.308(e)(1)(iv), which 

requires “each source subject to BART be required to install and operate BART as 

expeditiously as practicable, but in no event later than 5 years after approval of the 

implementation plan revision.”

RESPONSE: Additional information has been added on the BART waivers based on 

new emission limits. As previously indicated in the SIP, the Part 70 (Title V) permit 

for each of these facilities has or will be modified to include requirements necessary 

to qualify for the waiver from BART. The modified permit and/or accompanying 

evaluation memo as appropriate will specify the new permit limits, any controls or 

practices necessary to meet the limits, and timelines for implementation. For 

changes that entail a “major modification” of the Part 70 permit, the normal 

opportunity for EPA and public review of and comment on these permit changes will 

be provided. DEQ anticipates that each of these permits will be modified “...no later 

than 6 months prior to the SIP approval” as stated in the waivers.

b) COMMENT: ODEQ should provide all modeling and technical evaluations necessary 

to document the amount of reductions necessary for these facilities to fall under the 

BART threshold of 0.5 dv. 

RESPONSE: All modeling and technical evaluations documenting these reductions are in the 

applications and will be included DEQ’s evaluation memo for the Part 70 permit modification. 

This information has been provided to EPA and the FLMs, and is available for review online 

and/or in DEQ files. DEQ believes that including copies of all of these files in the SIP submittal is 

unnecessary, considering the documentation currently provided in the SIP and the status of 

these facilities.

11. On page 71, ODEQ makes the following statement regarding these facilities and BART 

enforcement:

“DEQ will issue enforceable Part 70 air quality permits requiring BART-eligible sources 

subject to BART to: (1) install BART and achieve the associated BART emission standards; 

or (2) “achieve greater reasonable progress toward natural visibility conditions” through 

an approvable alternative as provided for in 40 CFR § 51.308(e). Subject sources must 

achieve the BART emission standards referenced above or achieve the “greater 
reasonable progress” referenced above within seven (7) years from the date of 

submission of the Oklahoma Regional Haze SIP or within five (5) years of EPA’s approval 

of the SIP, whichever is longer.”

Regarding this, the following comments apply:

a. COMMENT: Any future alternative to BART, as contemplated under 40 CFR 51.308(e)(2), 

would require a SIP modification.

RESPONSE: The final BART Determinations and the SIP revisions spell out BART with, 

where applicable, corresponding Contingent SO2 BART Determinations and Greater 

Reasonable Progress Alternative Determinations. As a result, the referenced language 

has been modified. DEQ acknowledges that a SIP modification would be required for 

any BART changes or alternatives following EPA’s approval of this SIP Revision.

b. COMMENT: Region 6 suggests the language “achieve greater reasonable progress,” 

which is apparently offered as an alternative to the BART emission limits proposed in 

the SIP, be dropped to avoid confusion with the reasonable progress requirement of 

51.308. If a permit condition results in less SO2, NOx, or PM control than was provided 

for in the SIP, it would require a SIP modification.

RESPONSE: Although the specific language referenced by EPA’s comment has been 

modified in the updated SIP Revision, DEQ believes that it has correctly applied the 

“greater reasonable progress” phrase as it is used in 40 CFR § 51.308(e)(2). See also 

previous response.

c. COMMENT: A schedule of compliance with BART that provides for the operation of 

BART controls later than five years from EPA’s approval of the SIP would not be in 

compliance with 51.308(e)(1)(iv). Note similar language is on page 79.

RESPONSE: The specific language referenced by EPA’s comment has been modified in 

the updated SIP Revision, and the revised BART Determinations specify appropriate 

timelines.

d. COMMENT: The above comment concerning the review of the modeling not 

withstanding, ODEQ should understand that Region 6 will not be able to approve the 

Oklahoma regional haze SIP until we are assured there is an adequate enforcement 

mechanism in the SIP to ensure these sources are no longer subject to BART.

RESPONSE: DEQ is confident that the Part 70 permit modifications (in the context of the 

Part 70 Program), as referenced in the SIP, will constitute an adequate enforcement 

mechanism. In addition, Appendix 6-5 contains enforceable Regional Haze Agreements 

that cover certain BART-subject facilities. 

12. COMMENT: ODEQ should discuss why the BART NOx limit for the AEP/PSO Southwestern power 

station unit 3 is 0.45 lbs/MMBtu, and not a lower value. It appears from an examination of 

EPA’s CAMD database, that the historical annual NOx emission rates from this facility for each 

year from 2000 – 2008 (except for 2008), are already lower than the proposed controlled BART 

rate, even considering the BART rate is a 30 day average.
RESPONSE: PSO is required to establish final emission limits for the BART source in the 

construction and operating permits. For the purposes of this evaluation AEP-PSO was unable to 

obtain lower guarantees from vendors for these specific boilers. DEQ would agree that average 

annual emissions should ultimately be lower than these conservative estimates.

13. COMMENT: ODEQ should discuss why the AEP/PSO Northeastern power station units 3 and 4, 

should not have a lower proposed BART SO2 limit than the presumptive limit of 0.15 

lbs/MMBtu. 

RESPONSE: After considering the comments including cost received, the portion of the Regional 

Haze SIP and/or attached BART determination(s) relevant to the above comment(s) has been 

modified or removed. Consequently, the above comment has been addressed and/or is no 

longer applicable. 

14. COMMENT: On page 76, ODEQ discusses additional information received for the OG&E Sooner 

and Muskogee coal fired EGUs. OG&E increased its cost effectiveness calculations for Dry FGDSDA to a range of $9,625 to $10,843 per ton of SO2 removed and to a range of $10,271 to 

$11,490 per ton of SO2 removed for Wet FGD. Region 6 has reviewed the information that was 

provided for public review. Based on cost estimates we have for other similar units, we feel 

these cost are significantly inflated. We question the assumptions in cost that have been made 

in general and the cost assumptions for annual operating costs, including administrative costs, 

which are significantly out of proportion with other cost analyses for similar control installations. 

Region 6 understands the data to support this cost estimate has been identified by the source as 

proprietary in nature. EPA Administrator Jackson’s priorities for regulatory decisions are they be 

transparent and meet the requirements of the law. Therefore, these principles of transparency 

and rule of law are ones Region 6 wants to ensure are met in this process. Therefore, we cannot 

base a decision regarding BART on data that is not available for public review. Because of the 

projected visibility benefits to multiple Class I areas that would result from the control of SO2 

emissions at these facilities, the lack of support for OG&E’s figures, and our feeling the true 

installed costs of these controls are much lower, Region 6 would likely not be able to approve 

the Oklahoma regional haze SIP without these controls. We note that the U.S. Fish and Wildlife 

have provided more detailed comments on the OG&E and PSO BART analyses. We share many 

of the concerns that they raised, but did not think it necessary to be as detailed in this comment 

letter.

RESPONSE: OG&E provided comments at the public hearing in response to this concern. OG&E 

has also supplemented its BART-related applications for Part 70 permit modifications with

additional data. The documents have been provided on the DEQ website and submitted directly 

to Region 6. ODEQ agrees that the original cost calculations were inflated. The final BART 

determinations are based on the more accurate revised estimates.

15. COMMENT: One of the items that is briefly mentioned is that for some BART-eligible sources, 

no BART reductions were assumed in the Regional Modeling. It would be helpful to have a table 

summarizing for each BART-eligible source, what emission rates were assumed in the RH 

modeling. 
RESPONSE: A preliminary draft table reflecting the emissions of BART-subject units used in the 

Regional Haze modeling has been assembled. Adding data to the table to reflect the emissions 

of BART eligible units used in the Regional Haze modeling would be an additional significant 

task. DEQ recognizes that the emissions resulting from the BART Determinations differ 

significantly from modeled emissions, and without additional analysis such a table would not be 

particularly relevant. Therefore, time restraints preclude including such a table in the BART 

chapter at this time. Further, emissions used in modeling reflect projected actual emissions 

rather than permitted potential emissions. Such comparisons, absent an understanding of 

facility operations, are of limited use.

16. COMMENT: An additional table indicating if the source was subject to BART, or was able to 

model out of BART and/or include the final emission rates that are being made federally 

enforceable (either through permitting, or other methods). 

RESPONSE: This information is available in our SIP.

17. COMMENT: While the zero-out modeling bounds the impact, it would helpful to have a 

summary of additional emission rate changes that have not been take into account in the RH 

modeling analysis.

RESPONSE: While such a table would be interesting, time restraints preclude developing an 

alternative inventory and necessary cross references for a true comparison. 

18. COMMENT: Within the body of the text in its reasonable progress section, beginning on page 

96, ODEQ should provide references for the data contained in all the tables and figures (e.g., 

Table IX-1 Figure IX-1) that direct the reader to where the data can be found. 

RESPONSE: In Table IX-1 and Figure IX-1, the implementation plan revision earlier defines and 

discusses the observations, baseline visibility impairment, and natural visibility conditions. The 

reasonable progress goal for 2018 derives from Community Multi-scale Air Quality modeling 

from CENRAP as described in Chapter VIII of this implementation plan revision. DEQ staff 

extrapolated the remaining quantities from the reasonable progress goal for 2018. 

19. COMMENT: On page 99, ODEQ presents data in Table IX-3, that essentially shows the difference 

between its Reasonable Progress Goal (RPG) and the Uniform Rate of Progress (URP) is 

approximately equal to the visibility impact from sources outside of Oklahoma. Regarding this, 

ODEQ makes the statement: “The model-extracted data in Table IX-3 suggest that even 

complete elimination of all anthropogenic emissions in Oklahoma likely would fail to meet this 

uniform rate of progress.” This zero-out run of Oklahoma’s emissions assumes no additional 

changes in upwind states. This is not a realistic assumption and it does bias the conclusion that 

removal of all Oklahoma sources would still likely fail to meet the uniform rate of progress goals. 

Further reductions in upwind states in addition to local measures could yield a result meeting 

the uniform rate of progress goal.

RESPONSE: Table IX-3 shows the reasonable progress goal and the uniform rate of progress at 

the Wichita Mountains and the difference in visibility impairment between these rates in 2018. 

The visibility impairment attributable to sources outside Oklahoma, however, considerably 
exceeds the difference between these rates, whereas this difference likely slightly exceeds the 

visibility impairment attributable only to anthropogenic sources only within Oklahoma. 

DEQ did not engage in “zero-out modeling” to make this determination. The comparison 

between the contribution of all anthropogenic sources in Oklahoma to visibility impairment at 

the Wichita Mountains and the difference between the uniform rate of progress and the 

reasonable progress goal comes instead from particulate source apportionment modeling. The 

particulate source apportionment modeling assumes that upwind states will not require 

controls that they do consider unreasonable. 

In establishing the reasonable progress goal at the Wichita Mountains under 

40 CFR § 51.308(d)(1)(i)(B), DEQ considered the emission reduction measures needed to achieve 

the uniform rate of improvement in visibility before 2018. In this statement, DEQ considered 

only emissions sources under its territorial jurisdiction. Removal of all sources in Oklahoma 

likely would fail to meet the uniform rate of progress. 

For the reasons described in the implementation plan revision, DEQ does not consider the 

uniform rate of progress at the Wichita Mountains as an achievable goal. DEQ recognizes that 

reductions in emissions in Texas and in other upwind states and foreign countries might lead to 

reductions in visibility impairment beyond the reasonable progress goal. Reductions in 

emissions to attain the ambient air quality standard for ozone (O3) may contribute to these 

reductions; however, DEQ cannot anticipate the ancillary benefit of these emissions reductions 

on visibility impairment at the Wichita Mountains, especially without knowing specifically which 

emissions reductions those authorities will implement. 

20. COMMENT: Region 6 was unable to locate ODEQ’s response to the requirements contained in 

Sections 51.308(d)(1)(vi) and 51.308(d)(3)(v)(G).

RESPONSE: The first regulation, 40 CFR § 51.308(d)(1)(vi), forbids DEQ from adopting a 

reasonable progress goal at the Wichita Mountains that represents less visibility improvement 

than that which DEQ expects to result from implementation of other requirements of the 

federal Clean Air Act before 2018. CENRAP and DEQ worked together to predict the results of 

implementation of BART and of other requirements of the Clean Air Act and used these 

predictions to estimate an emissions inventory for 2018. Chapter VII lists several important 

measures under the federal Clean Air Act, and Chapter VIII discusses the process of estimating 

emissions inventory for 2018 and the modeling of regional haze under these emissions 

inventories. DEQ expects the implementation of various requirements of the federal Clean Air 

Act (and regulations promulgated thereunder) to result in the improvement in visibility that this 

modeling indicates. DEQ acknowledges that various interpretations of and regulations under 

the federal Clean Air Act may result in lower emissions than those which CENRAP and DEQ 

estimated for 2018. DEQ also recognizes that social and cultural trends, especially considering 

the continued rapid population growth in the sovereign state of Texas, may result in 

countervailing increases in emissions not anticipated in CENRAP modeling. DEQ nevertheless 

considers the CENRAP modeling to inform a “best guess” of the emissions in 2018 under all 

provisions of the federal Clean Air Act and set its reasonable progress goal accordingly. The 

requirements of 40 CFR 51.308(d)(3)(v)(G) are addressed in Chapter VIII. This regulation 

requires DEQ to consider the anticipated net effect on visibility due to projected changes in 

point, area, and mobile source emissions before 2018 in developing its long-term strategy. The 
long-term strategy ideally would diminish point, area, and mobile source emissions before 2018. 

As adopted hereunder, the long-term strategy of DEQ at least constrains point-source emissions. 

DEQ included this assessment in Chapter VIII, but iterations in modeling in conjunction with 

CENRAP allowed for the use of results from preliminary simulations of future emissions in 

formulating the long-term strategy in Chapter VII and reasonable progress goals in Chapter IX. 

21. COMMENT: Section 51.308(f) requires that ODEQ revise and submit its regional haze 

implementation plan revision to EPA by July 31, 2018 and every ten years thereafter. In 

response to this, ODEQ states on page 111, “DEQ awaits approval of this implementation plan 

before submitting any such revisions.” ODEQ should clarify that it will comply with this 

requirement.

RESPONSE: DEQ understands that next SIP revision is to be submitted to EPA by 31 July 2018 

and has the deleted the sentence.

22. COMMENT: Section 51.308(d)(4)(v) requires that ODEQ submit an emissions inventory that 

must include emissions for a baseline year, emissions for the most recent year for which data 

are available, and estimates of future projected emissions. The ODEQ has supplied an inventory 

for the baseline year, and for 2018. EPA understands that the ODEQ has emission inventory 

data available for 2005 and requests that it be included in the SIP. The preamble to the 1999 

Regional Haze Rule (64 FR 35745) clarifies EPA authority for requiring the emission inventory of 

the "most recent year for which data are available," under 51.308(d)(4)(v):

"Requirements Under Section 110(a)(2) of the CAA. Visibility SIP submittals must 

document certain program infrastructure capabilities consistent with the requirements 

of section 169B(e)(2) and section 110(a)(2) of the CAA. Section 169(B)(e)(2) requires 

States to revise their section 110 SIPs to ‘‘contain such emission limits, schedules of 

compliance, and other measures as may be necessary’’ to carry out regulations 

promulgated pursuant to this section. The EPA believes that this language authorizes 

EPA to ensure that States review their existing program infrastructures to ensure that 

the types of elements required by section 110(a)(2) for programs addressing the NAAQS 

are also sufficient for adoption and implementation of SIP measures for regional haze. 

The final rule does not include specific provisions addressing all elements of section 

110(a)(2). However, section 51.308(d)(4)(iv) of the final rule requires the State to 

maintain and update periodically a statewide inventory of emissions of pollutants that 

contribute to visibility impairment. Where a State is also revising its SIP to incorporate 

changes to address the PM2.5 NAAQS, many of these revisions may be sufficient to 

address both PM2.5 and regional haze. The EPA encourages States to consider the 

needs of both programs when updating the provisions required by section 110 of the 

CAA to minimize any administrative burdens."

EPA requests that the ODEQ contrast its 2005 emission inventory with that from its baseline 

year of 2002, and 2018, in order to serve as a check of the EI projection methodology.

RESPONSE: It is correct that 2005 emissions inventory is the most recent complete inventory. 

This inventory is available to the public via EPA’s website 

athttp://www.epa.gov/ttn/chief/eiinformation.html. A statement to that effect has been added 

to the Emission Inventory Chapter. DEQ is not aware that an analysis of this inventory is 
required, and there is insufficient time to accomplish this while meeting the deadline for 

submitting this SIP revision. 

23. COMMENT: In the modeling section, it would be helpful to note where the modeling files (RH 

and BART) can be accessed. Inclusion of a printout (or screenshots) of the list of documents 

available on the CENRAP and ODEQ websites and/or ftp sites that are being relied upon in the 

SIP would make a good attachment to the SIP narrative. 

RESPONSE: DEQ concurs that these additions could in some ways improve the content of this 

SIP; however, due in part to time restraints, DEQ has decided not to make the suggested 

changes. 

DEQ received numerous written and oral comments from the public concerning the 

implementation of BART and the BART determinations included in the draft Regional Haze SIP 

revision. After considering the comments received, applicable portions of the Regional Haze 

SIP and/or attached BART determination(s) relevant to those comment(s) has been modified 

or removed. Consequently, except where a specific response was needed, the following

comments have been addressed and/or are no longer applicable. The written submittals are 

included in Appendix 10-1.

OG&E – Mr. Kimber Shoops provided a written statement to duplicate his oral comments. In addition, 

OG&E provided many written comments which are included in a separate appendix.

Devon Energy submitted a letter December 16, 2009, signed by William F. Whitsitt, Executive Vice 

President of Public Affairs

Sierra Club, Oklahoma Chapter submitted a paper dated December 13, 2009, received by DEQ on 

December 16, 2009, signed by Bud Scott, Government Affairs Director

Chesapeake Energy Corporation submitted a paper dated December 16, 2009, received by DEQ on 

same day, which duplicates oral comments presented by Mr. Don Shandy.

Public Service Company of Oklahoma (PSO) submitted a letter dated December 16, 2009, received by 

DEQ on same day, signed by Howard L. Ground, Manager of Government Affairs.

24. COMMENT: Table VIII-2 projects an annual TPY increase of 32.86% in the state’s Ammonia 

emissions inventory from the 2002 year. As previously stated, AEP/PSO requests the ODEQ to 

consider the complementary role of Ammonia in visibility impairing particulate formation. 

AEP/PSO sees the need for the ODEQ to address Ammonia control (in the near term) as also to 

cap Ammonia emission for meaningful visibility reduction in the near term and into the future. 

RESPONSE: Public Service Company of Oklahoma correctly interprets a cell in the referenced 

table in the implementation plan revision. This statistic derives from projected inventories used 

in CENRAP modeling. DEQ will reevaluate ammonia emissions in preparation for any 

comprehensive periodic revision under 40 CFR 51.308(f). 
DEQ considered the complementary role of ammonia in forming visibility-impairing particulate 

in assessing the particulate observations and in developing an emissions inventory. Following 

the leadership of EPA, DEQ does not consider regulation or reduction of ammonia emissions as a 

strategy to reduce particulate matter concentrations in this implementation plan revision. DEQ 

nevertheless requires permitted point sources, excluding animals in agricultural production, to 

report ammonia emissions. 

DEQ currently does not regulate agricultural sources and consequently does not control most 

ammonia sources. 

Western Farmers’ Electric Cooperative – In a letter received by DEQ on December 16, 2009, signed by 

Gerald Butcher. 

25. COMMENT: The DEQ has determined the impact of out-of-state emissions (primarily from the 

State of Texas) on visibility in the WIMO are significant. Conversely, Texas recently submitted its 

Regional Haze SIP Revision to EPA and therein indicated emissions originating from Texas do not 

impact visibility in the WIMO. Therefore, there appears to be a significant disagreement 

between the findings from each State. How does the DEQ propose to resolve this issue?

RESPONSE: DEQ stands by its assessment that Texas emissions significantly impair visibility at 

the Wichita Mountains. EPA can evaluate both SIPs and will be ultimately responsible for 

determining which findings are supported by the technical demonstrations included in each SIP.

26. COMMENT: Did the DEQ advise Texas that additional emission reductions from Texas sources 

would not be needed to help Oklahoma meet the WIMO reasonable progress goals, and if so, on 

what basis was such determination made? 

RESPONSE: DEQ advised Texas of its finding during the consultation process that Oklahoma 

would be unable to meet the uniform rate of progress without additional reductions, including 

those from Texas sources. However, DEQ does not have the regulatory authority require 

emissions reductions in other states. Only Texas and EPA can require those reductions.

27. COMMENT: ... Based on the above and the fact that “... even the elimination of all 

anthropogenic sources within Oklahoma is not sufficient to comply with uniform rate of 

progress”, the DEQ concluded “any effective strategy for managing visibility impairment at the 

Wichita Mountains must address outside sources including regional and international 

transport.” However, the Revision is silent as to how such outside sources will be addressed.

RESPONSE: See response to previous comment.

Oral Comments Received at the December 16, 2009 Public Hearing

Joe Kordzi (EPA, Region 6)
COMMENT: I would like to urge the Air Quality Council and Environmental Quality Board to adopt 

the Oklahoma Regional Haze Plan. It is the opinion of EPA Region 6 that the measures contained 

within Oklahoma’s regional haze plan will do much to improve visibility at the Wichita Mountains, 

with co-benefits to DEQ’s other air quality programs. Furthermore, it is vitally important this plan be 

submitted to us for review as soon as possible. EPA Region 6 has submitted written comments of 

the plan that we request be entered into the record.

Paul Renfrow (OGE Energy Corp)

COMMENT: We disagree with and oppose the draft proposal for several reasons: First and most 

importantly, the proposal will result in the largest single rate increase for our customers in the 

company’s 108 year history. This cannot be minimized nor is it contrived. The proposal forces us to 

spend more than ONE Billion DOLLARS of customer’s money to add pollution control devices, 

commonly called scrubbers, to our coal plants. Those coal plants are each between 25-30 years old 

and somewhere in the last half of their planned useful lives. This proposal will actually PROLONG 

the life of the coal plants when it seems everyone in the country wants utilities to quit using coal. 

This proposal is completely contrary to the national efforts to reduce CO2 emissions. While the 

Regional Haze rule has the desirable intention of making our wilderness areas more beautiful over 

the next 50 years, this is, frankly, an inefficient, contradictory compliance exercise that ignores 

innovative or creative approaches. We strongly recommend that the OG&E alternative plan be 

adopted by the DEQ and included in their final State Implementation plan to be filed with the EPA. 

Kimber Shoop (OG & E)

COMMENT: OG&E believes that anyway you look at it, scrubbers are not cost effective. : That is 

why we developed our alternative proposal. OG&E strongly urges the State of Oklahoma to instead 

consider the alternative proposal submitted by OG&E on September 23, 2009 to achieve compliance 

with regional haze targets for these four units. OG&E’s alternative proposal will ultimately achieve 

the same visibility improvement as set forth in the Revised SIP, but in a cost effective manner 

through the use of more natural gas-fired and wind generation to meet the electric needs of our 

customers. 

Don Shandy (Chesapeake Energy Corporation)

COMMENT: Rather than requiring huge capital investment to the Oklahoma coal-fired units that are 

more than 30 years old, such units should either convert to natural gas firing systems or be replaced 

with new natural gas fired generation units. Oklahoma must begin to effectively address emissions 

from coal-fired electric generation plants in Texas. ... And these sources need to be evaluated with 

the same level of scrutiny that sources inside Oklahoma are being evaluated. While the Plan 

acknowledges impact from out-of-state sources and to some extent, attempts to address this matter 

via consultation with Texas, and if we attempt to address this in consultation with Texas and we 

have an agreement, according to the document, to allow Oklahoma the opportunity to comment on 

pending Texas air permits - permit application for sources within 300 kilometers of our border, we 

believe this approach is inadequate. This is particularly the case given DEQ is requiring again or 

mentioning excessive and expensive sulfur emission control on coal-fired electric generation units 

located inside the state of Oklahoma. Chesapeake’s comment is that in light of overwhelming 

evidence that Texas sources impact visibility at the Wichita Mountains, and given the potentially 

large financial impact on Oklahoma electric generation facilities and rate payers, DEQ should have 

requested additional reduction from Texas sources to meet the reasonable progress goal. While 

Chesapeake acknowledges that scrubber technology would result in significant reductions of sulfur 

emissions, which will accomplish – such will be accomplished only again after an extraordinary and 
unwarranted investment by rate payers in this state. ...And it would represent one of the largest 

capital investments in Oklahoma history. While we definitely agree that we’ve got to make 

movement to protect the Class I area, there has to be a very hard look at these numbers. 

Chesapeake believes that the expenditure of funds for this type of emission control equipment is 

imprudent. While it would undoubtedly be acceptable to DEQ, the culpable coal-fired generation 

sources should focus on the development and utilization of more environmentally friendly electric 

generation units and fuels. 

Bud Scott (Sierra Club)

COMMENT: I have submitted formal comments as well that should be entered into the record. One 

of our major issues with the draft SIP today first lies with the exclusion for most of the analysis of 

the Class I areas that are impacted outside of the state of Oklahoma, primarily Caney Creek and the 

Upper Buffalo Area. Those two we would request be given the same level of analysis as the Wichita 

Mountain Wilderness Refuge. The second of addressing out-of-state issues primarily with the state 

of Texas. Those have already been addressed by parties at Chesapeake and Oklahoma Gas and 

Electric. That’s one of our most important points is that we could be given alternative approaches 

which were very little addressed through the SIP for dealing with the out-of-state issues on 

transport, the out-of-state issues with direct emissions, and its impact on the Wichita Mountain 

Wilderness Area. Number two, we’ve identified in the alternative approaches for implementation of 

the BART and BACT that in the alternative approaches we look more towards fuel switching 

provisions which were not adequately addressed in the provided SIP. Most of the SIP addressed the 

direct implementation of BART and then somewhat in BACT. And we would just like to see more of 

that approached and given a little more detail. And then finally, we would really just like to see 

more cooperation on the interstate level. So ultimately the sierra Club while we do generally 

support the implementation of the Best Available Retrofit Technologies and Best Available Control 

Technologies at the same time we feel like the plan here in Oklahoma could be revised to address 

some of the alternatives available that will be best for the rate payers in Oklahoma, the citizens of 

Oklahoma, and for our natural resources. 

Darryl Smeete (Devon Energy) 

COMMENT: We’re here to support OG&E’s application for an alternative proposal to the Regional 

Haze Plan. In short what OG&E is saying is that it not only is more economical but we have less 

greenhouse gas emissions by converting some of the base load generating capacity go gas fueled 

rather than coal fueled. We think the proposal by OG&E is a win-win. First of all it reduces 

emissions. Second of all it puts people to work, drilling and completing wells. Once those wells are 

on stream and produces gas and that gas with subsequent productions tax. That tax goes to the 

State of Oklahoma and to the other states where it is produced.