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Update on Regional Haze

November 15, 2012

Michele NotarianniEPA Region 4

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Overview of Regional Haze Provisions

• Clean Air Act:

– Requires visibility protection for Federal Class I Areas (e.g., national parks and wilderness areas)

– Establishes national goal to prevent future and remedy existing visibility impairment from manmade air pollution in Class I areas

• EPA’s Regional Haze Rule:

– Mandates submission of a series of State Implementation Plans (SIPs) that will improve visibility in 156 Class I areas across the country

• The first regional haze SIPs were due December 17, 2007• Second SIP due July 31, 2018, and every ten years thereafter.• The first Progress Report SIPs are due five years after submittal of initial SIP.

– Key SIP components include, but are not limited to:

• Reasonable progress (RP) and RP Goals (RPGs)• Best Available Retrofit Technology (BART)• Long term Strategy (LTS)

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EPA’s Regional Haze Program

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EPA Action on Regional Haze SIPs • National Updates:

– EPA is in the process of acting on the 52 required SIPs (or instituting FIPs) due from all states, Washington D.C., and the Virgin Islands.

– As of September 2012, EPA has issued over 100 Federal Register actions on these SIPs.

– EPA’s Better-Than-BART (BTB) Rulemaking: BTB Proposal - 12/30/2011 and BTB Final - 06/07/2012.

• Regional Updates: – In R4, EPA has issued (or signed) 17 Federal Register actions (9

proposals, 8 finals) between June of 2011 and the present (i.e., 11/15/2012).

– All R4 states' regional haze SIPs acted on except portion of Florida’s regional haze SIP.

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Consent Decrees on Regional Haze SIPs• 124 consent decree deadlines in 5 consent decrees, and over 100

EPA regulatory actions to date.

• R4: All but two obligations have been met as of 11/15/2012.

• FL: Propose by 12/03/2012 and go final by 07/15/2013 on certain elements of Florida’s regional haze SIP.

• FL: 2012 SIP Revisions - EGU Control Analyses:

– 31 RP EGUs and 23 BART sources with BART-eligible (B-E) EGUs.– April 13, 2012 – draft SIP with shutdowns, exempters, and top-level controls for 13 RP

EGUs and 12 BART sources with B-E EGUs. – July 31, 2012 – draft SIP with control determinations for 18 RP EGUs and 11 BART

sources (total of 20 B-E EGUs).– September 17, 2012 – consolidated final SIP with finalized determinations for EGUs

covered in the April and July draft SIP revisions.

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Progress Report & Adequacy Check• Requirements:– Progress Report – 40 CFR 51.308(g); Adequacy Check – 40

CFR 51.308(h).– Due five years after submittal of initial regional haze SIP.

• National Activities:– Federal Register template for EPA’s future actions on

Progress SIPs. – EPA is internally discussing its expectations to aid Agency

internal reviews.– EPA has also reached out externally:

• Mid-September 2012 – calls with FLMs and RPOs• October 2012 - NACAA call general discussion

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Progress Report & Adequacy Check

• Regional Activities:

– SC and NC draft Progress SIPs and SC proposed SIP for public comment submitted to date.

– EPA is working with SC and NC to provide input on their SIPs.

– Preliminary lessons learned to date from this process…..

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*Tips for R4 Progress Report SIPsTIPs = Suggestions to strengthen technical support for

Region 4 states’ Progress SIP conclusions.

*Disclaimer: • The TIPs are intended to help the Region 4 states portray the

visibility improvement made to date.

• The TIPs are not all inclusive and are likely to change as we review more Progress SIPs.

• Characterizations of EPA’s regulations here are for summary purposes only. Please refer to 40 CFR 51.308(g) and 40 CFR 51.308(h) for the actual requirements.

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*Tips for R4 Progress Report SIPs

• 40 CFR 51.308(g):– General TIP: Be sure to include the conclusions of any

assessments required along with the supporting data.

• g1 – Status of Measures:

– TIP: Briefly explain if any measures in original SIP are not discussed in Progress SIP.

– TIP: For national/regional measures, helpful to highlight those measures which apply to your State’s sources/units which have visibility impacts on Class I areas.

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*Tips for R4 Progress Report SIPs (ctd)

• g2 – Emissions Reductions Summary of “g1” Measures:

– TIP: For national/regional measures, highlight those emissions reductions which apply to your State’s sources/units which have visibility impacts on Class I areas.

– TIP: Helpful to include early on in SIP why the focus of emissions reporting for RP is on SO2 reductions.

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*Tips for R4 Progress Report SIPs (ctd)

• g2 – Emissions Reductions Summary of “g1” Measures: (ctd.)

– TIP: Industrial/Commercial/Institutional (ICI) Boiler and Process Heater MACT standard - ideas to tailor to State vs VISTAS:

• Could include revised rule data for your state (or use data from 1st SIP showing percent reductions expected in your state from vacated rule).

• Could include a statement that given the expectation that the revised rule will result in greater emissions reductions of visibility-impairing pollutants, this provides further assurance that your State will achieve its RPGs.

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*Tips for R4 Progress Report SIPs (ctd)

• g3 – Visibility Data:– TIP: Helpful to include IMPROVE visibility monitoring data in a

table to aid with readability if data shown in a figure.

• g4 - Evaluation of Emissions Changes Over Five-Year Period:– TIP: At least two lookback years needed for this evaluation.– TIP: Could also include VISTAS 2009 emissions projections for

your state from 1st SIP to compare to updated emissions inventory.

– TIP: Could include most recent emissions data for significant sources of focus (e.g., 2010 data for EGUs).

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*Tips for R4 Progress Report SIPs (ctd)

• g5 – Significant Emissions Changes Assessment:

– TIP: Include explicit statement and explanation to indicate whether there are significant changes in emissions of concern that have limited or impeded progress in reducing pollutant emissions and improving visibility.

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*Tips for R4 Progress Report SIPs (ctd)

• g6 – Assessment of SIP Sufficient to Meet RPGs:– TIP: Include explicit statement with explanation for the

conclusions from the assessment of SIP sufficiency.

– TIP: Also address SIP sufficiency re: RPGs of out of state Class I areas impacted by your State’s sources.

• g7 – Monitoring Strategy Review:– TIP: Include explicit statement if review determines that

no modifications to the existing visibility monitoring strategy are necessary.

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*Tips for R4 Progress Report SIPs (ctd)

• 40 CFR 51.308(h) – Adequacy Determination of SIP:

– TIP: 308(h) determination is subject to public notice and comment.

– TIP: Explicitly address State’s determination in SIP or accompanying letter.

For More Information• EPA Visibility Home Website:

http://www.epa.gov/air/visibility/index.html– Basic Information – includes links to FLM websites– Regulatory Actions – chronological list of EPA actions – Regional Planning Organizations – incl. links to 5 RPO websites– Visibility in Parks and Wilderness Areas - Pollutants, photos, trends,

and real-time images; incl. links to IMPROVE website

• EPA Air Pollution Control Cost Manual:– http://www.epa.gov/ttncatc1/products.html#cccinfo

• Visibility Monitoring Networks: – IMPROVE: http://vista.cira.colostate.edu/improve/– VIEWS: http://vista.cira.colostate.edu/views/