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Implementation Work 

Group: Documents 

- Select A Forum Destination - 

Reasonable Progress 4 Factor Evaluation Project

§308(d)(1) of the Regional Haze Rule requires 

States to set reasonable progress goals toward 

meeting a national goal of natural visibility 

conditions in Class I areas by the year 2064. The 

first reasonable progress goals will be established for 

the planning period 2008 to 2018. The Regional 

Haze Rule identifies four factors which should be 

considered in evaluating potential emission control 

measures to meet visibility goals. As listed in §308

(d)(1)(i) these four factors are as follows: 

1. Cost of compliance 

2. Time necessary for compliance 

3. Energy and non-air quality environmental 

impacts of compliance 

4. Remaining useful life of any existing source 

subject to such requirements 

The purpose of this project is to provide to those 

WRAP States who requested it, help in evaluating 

these four factors for additional control measures 

(beyond BART). States participating in this project 

include AK, AZ, CO, ID, ND, NM, SD, WA & WY 

(NV observing). These States first requested 

evaluation of a series of General Source Categories, 

while five (CO, ND, NM, SD & WY) also identified 

specific Stationary Sources located within their 

respective states for which they wanted a detailed 

control evaluation conducted. As contained in the 

Scope of Work for this project (12/10/08 DOC or 

PDF) the list of General Source Categories consisted 

of the following: 

i. Reciprocating Internal Combustion Engines 

and Turbines 

ii. Oil & Gas Exploration & Production Field 

Operations 

iii. Natural Gas Processing Plants 

iv. Coal or Oil Fired Industrial Boilers (six 

category bins by size, then by age) 

v. Wood Fired Industrial Boilers 

vi. Gas Fired Industrial Boilers 

vii. Cement Manufacturing Plants 

viii. Sulfuric Acid Manufacturing Plants 

ix. Pulp & Paper Plant Lime Kilns 

x. Petroleum Refinery Process Heaters 

Implementation 

Work Group 

z About 

z Members 

z Meetings & Calls 

z Documents

z Air Managers Committee

Tools 

z Forum Guidelines 

z Schedule Call/Meeting 

z Submit Document 

z Green Your Travel

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The Specific Sources requested for evaluation are 

contained in the “2008-12_4 Factor Point Source 

List (RV1)” spreadsheet XLS (12/08/08) 

Project Reports 

Draft Report for the General Source Categories PDF

(04/20/10, 4 MB)* 

* Chapter 6 Tables Corrected from Previous 

05/04/09 Version 

Draft Reports for Specific Individual Facility 

Reports 

z Colorado PDF (05/22/09, 1.8 MB) 

z New Mexico PDF (05/05/09, 1 MB) 

z North Dakota PDF (05/18/09, 1MB) 

z South Dakota PDF (05/19/09, 1MB) 

z Wyoming PDF (05/06/09, 1MB) 

Report Comments 

The WRAP States participating in the Reasonable 

Progress Four Factor Evaluation Project have 

solicited comments from stakeholders on the reports 

produced by the project contractor, and comments 

have been posted below as received. The States plan 

to respond to their own facility specific comments 

individually, and will consider all comments in the 

development of their Reasonable Progress proposals 

for their SIP’s. Response to these comments will be 

documented in the docket during the Public Review 

of the SIP’s. 

Colorado

z Black Hills Corporation: E-Mail PDF 

z Cemex Cement: E-Mail PDF 

z Colorado Utilities Coalition: E-Mail PDF, 

Letter PDF 

z Suncor: E-Mail PDF, Letter PDF 

New Mexico

z Navajo Refining: E-Mail PDF, Letter PDF 

North Dakota

z Basin Electric: Letter PDF 

z Dakota Gasification: Letter PDF 

z Hess Corporation: E-Mail PDF 

z Otter Tail Power: E-Mail PDF, Report PDF , 

Spreadsheet XLS 

South Dakota

z Black Hills Power & Light: E-Mail PDF 

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General

z WEST Associates: E-Mail PDF, Letter PDF 

Guidance for Setting Reasonable Progress Goals 

Under the Regional Haze Program 

Guidance for Setting Reasonable Progress Goals 

Under the Regional Haze Program (rev. 06/1/07) 

PDF (1.2 MB) 

The purpose of this document is to provide guidance 

to States in setting reasonable progress goals (RPGs) 

as part of their regional haze state implementation 

plans (SIPs) and in deciding those measures 

necessary to meet these goals. We emphasize that 

this document is merely guidance and that States or 

the Environmental Protection Agency (EPA) may 

elect to follow or deviate from this guidance, as 

appropriate. The ultimate determination of whether a 

given SIP submission by a State meets the statutory 

requirements of sections 169A and 169B of the 

Clean Air Act (CAA) and the regional haze 

regulations at 40 CFR 51.300 - 309 will be 

accomplished through notice and comment 

rulemaking in which the facts and circumstances of 

each State submission will be evaluated by EPA. 

Under the Tribal Authority Rule, 40 CFR part 49, 

Tribes have the authority to seek “treatment as a 

State” for purposes of administering certain CAA 

programs, including the regional haze program. 

Whether Tribes seek this authority or not, EPA 

encourages Tribes to participate in the regional 

planning efforts to address visibility and to consult 

with neighboring States as they develop their 

regional haze SIPs. We hope that this guidance will 

provide Tribes with an understanding of the process 

for establishing RPGs that will assist them in the 

consultation process. 

Reasonable Progress Demonstration Case Study 

for Saguaro Wilderness Area (from the Arizona 

Regional Haze Stakeholder Meeting on 01/22/07) 

PDF (1.9 MB) or PPT (3.3 MB) 

AMC Letter to EPA on IMPROVE

Letter from AMC to EPA upper managers opposing 

proposed reduction of IMPROVE monitoring 

network at this time (08/22/06) PDF

Q&A Document from EPA Regarding Regional 

Haze Rule and BART Implementation (08/03/06) 

DOC or PDF

z BART Exemption Q&A (08/24/06) DOC 

EPA Checklist for Regional Haze SIPs (08/04/06) 

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DOC or PDF

EPA Releases Draft Guidance for Setting 

Reasonable Progress Goals (11/28/05) PDF or 

WPD

z WRAP Comments On Draft Guidance 

(02/10/06) PDF 

State/Tribal Timelines 

z Alaska (09/09/05) XLS 

z Arizona DOC 

z California Draft Planning Process Chart 

(06/19/06) XLS 

z California Draft Critical Path Table (06/23/06) 

DOC 

z Colorado XLS 

z Nevada (May 2006) XLS 

z North Dakota (06/29/06) DOC 

z Oregon DOC 

z Utah (06/30/06) DOC 

z Generic Process Chart (05/30/06) XLS 

State/Tribal Rules 

z Idaho Regional Haze Rule, proposed 

(08/02/06) PDF 

z North Dakota BART Rule, as approved by 

ND Air Pollution Advisory Council 

(07/17/06) DOC 

Class I Area Profiles 

z Draft Profile Template (July 2006) DOC 

z Colorado Profiles HTML 

State/Federal Protocol 

z Draft State/Federal Protocol (05/06/06) DOC 

z Utah Comments on the Draft WRAP State and 

Federal Protocol (07/19/06) DOC 

SIP/TIP Template 

z Draft 308 Regional Haze SIP Template 

(06/02/06) DOC 

BART Clearinghouse 

z WRAP BART Clearinghouse 

For several years through 2009 the WRAP 

maintained a BART Clearinghouse and 

updated that clearinghouse with BART 

information as States promulgated their 

individual BART Rules, made preliminary 

BART determinations, required BART 

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analyses from “Subject to BART” sources, 

and reviewed those analyses for making 

decisions on final BART control 

requirements. As this was a labor intensive 

effort to gather and summarize this BART 

information, and as WRAP funding is being 

reduced, the Implementation Workgroup 

determined that this effort was more 

demanding than could be sustained. Thus they 

gave direction to WRAP staff to “freeze” the 

BART Clearinghouse with the December 10, 

2009 update of the BART Summary 

Spreadsheet and Detailed Discussion 

Document. As an alternative, the WRAP is 

providing website links to the individual State 

Regional Haze pages and where available, to 

those States’ BART determination pages, such 

that interested parties can get BART 

information directly from the States. The 

“frozen” December 10th Clearinghouse 

Update and the new State BART links are 

accessed from the “SIP Status Summary – 

BART” link found in the blue banner in the 

upper left of the WRAP homepage, and reside 

at the following address: 

http://www.wrapair.org/forums/ssjf/bart.html. 

BART Modeling 

z RMC BART CALPUFF Modeling Activities 

(07/15/06) DOC 

z RMC BART CALPUFF Modeling Center 

Consultation 

z WRAP RFP: "Analysis of Regional Haze 

State and Federal Implementation Plans for 

Tribal Implications/Issues" (09/15/06) PDF 

z FLM Recommendations on SIP Contents and 

Consultations (08/01/06) PDF 

z WRAP Comments on Draft EPA Guidance 

(08/07/06) DOC or PDF 

z Sample Contribution Matrix for Supporting 

the Consultation Process (06/15/06) PPT 

z Draft EPA Guidance on Consultation 

(06/20/06) DOC

Comments Due August 7 

Links to State Tribal Regional Haze Websites 

z Alaska 

z Arizona 

z Colorado 

z Idaho 

z Montana 

z Nevada 

z New Mexico 

z Oregon 

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z Utah 

z Wyoming 

Archived Documents

WRAP Technical Status Report PDF or DOC

(10/1/07) 

The September version of this report continues the 

series of periodic updates, as a tool to help planners 

and air managers stay up to date on the status of 

WRAP technical work to support regional haze 

planning efforts. Information in the report includes: 

z Section A - Access and content of existing 

data nodes; 

z Section B - Progress updates for key existing 

and planned work product deliverables from 

Forums and Workgroups, summarized from 

the project descriptions of the most current 

WRAP Workplan (PDF); 

z Section C - The 2007 Technical Analysis 

Plan; and 

z Section D - Highlights and brief descriptions 

of selected specific analyses and projects 

related to regional haze planning 

accomplished in the past few months. 

WRAP Technical Status Report PDF or DOC

(6/8/07) 

The June version of this report continues the series 

of periodic updates, as a tool to help planners and air 

managers stay up to date on the status of WRAP 

technical work to support regional haze planning 

efforts. Information in the report includes: 

z Section A - Access and content of existing 

data nodes; 

z Section B - Progress updates for key existing 

and planned work product deliverables from 

Forums and Workgroups, summarized from 

the project descriptions of the most current 

WRAP Workplan (PDF); 

z Section C - The 2007 Technical Analysis 

Plan; and 

z Section D - Highlights and brief descriptions 

of selected specific analyses and projects 

related to regional haze planning 

accomplished in the past few months. 

WRAP Technical Status Report PDF or DOC

(3/23/07) 

The March version of this report continues the series 

of periodic updates, as a tool to help planners and air 

managers stay up to date on the status of WRAP 

technical work to support regional haze planning 

efforts. Information in the report includes: 

z Section A - Access and content of existing 

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data nodes; 

z Section B - Progress updates for key existing 

and planned work product deliverables from 

Forums and Workgroups, summarized from 

the project descriptions of the most current 

WRAP Workplan (see: PDF or DOC); 

z Section C - The 2007 Technical Analysis 

Plan; and 

z Section D - Highlights and brief descriptions 

of selected specific analyses and projects 

related to regional haze planning 

accomplished in the past few months. 

WRAP Technical Status Report PDF or DOC

(7/14/06) - The July version of this report is the 

fourth in a series to provide periodic updates, as a 

tool to help planners and air managers stay up to 

date on the status of WRAP technical work to 

support regional haze planning efforts. It contains a 

summary of: 

z Section A - Access and content of existing 

data nodes; 

z Section B - Progress updates for key existing 

and planned work product deliverables from 

Forums and Workgroups, summarized from 

the project descriptions in the current WRAP 

Workplan Update for 2005-07 (a workplan 

update for 2006-08 is in preparation for the 

September 13-14 WRAP Board Meeting, and 

a prioritized budget has been discussed by the 

Planning Team in June, with review and 

approval planned for a July Planning Team 

call); 

z Section C - The Technical Support System 

website design and functions; and 

z Section D - Highlights and brief descriptions 

of selected specific analyses and projects 

related to regional haze planning 

accomplished in the past few months. 

Brief descriptions of projects and products are 

included in this report. Hot links to appropriate 

WRAP web pages, and references to work plans and 

the WRAP strategic plan are included for reference. 

Updates to this report are under the supervision of 

the Technical Oversight Committee. It is a living 

document, and any recommendations and 

suggestions on content and format are welcome. 

Please contact Tom Moore with your comments and 

suggestions. 

AMC Implementation Workgroup-Draft Work 

Plan PDF or DOC (01/12/04) 

Clearview Newsletter (Regional Haze/WRAP 

Activity Update):

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z February-March 2007 Clearview PDF or 

DOC 

z December 2006 Clearview PDF or DOC 

z July 2006 Clearview PDF or DOC 

z May-June 2006 Clearview PDF or DOC 

z April 2006 Clearview PDF or DOC 

z January 2006 Clearview PDF or DOC 

z December 2005 PDF or DOC 

z November 2005 PDF or DOC 

z September - October 2005 PDF or DOC 

z August 2005 PDF or DOC 

z July 2005 PDF or DOC 

 

Contact the Webmaster

©2009 Western Governors' Association 

Implementation Work Group: Documents Page 8 of 8

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