Update on the STIP-II Project & Draft Model SIP

1. WRAP Meeting Portland, OR April 3, 2003 Update on theSTIP-II Project& Draft Model SIP Brian Finneran Oregon Department of Environmental Quality

2. STIP-2 Overview • What’s a STIP? = SIP + TIP • Objective: Create a model plan or “working template” for States & Tribes to use for preparing Regional Haze SIPs and TIPs for Section 309. • Started with the SIP/TIP Template prepared by WESTAR in 2000.

3. Project Summary • STIP-2 Project consists of 2 distinct parts: • a Model SIP – to help states meet the 12/31/03 deadline under 309. • a Model TIP – to help tribes that elect to adopt a 309 TIP. • Both Model SIP & Model TIP reviewed by the STIP-2 Working Group.

4. Project Participants • Model SIP author – Brian Finneran, Oregon DEQ. • Model TIP author – Rosanne Sanchez, New Mexico Environment Department. • STIP-2 Working Group – 18 members: 5 States, 3 tribal reps, 4 EPA, 2 NTEC, 2 WESTAR, & 2 WRAP. • TSD Project assistance – Tom Moore, WRAP

5. Project Timetable • One-year project – Started 10/02 • Model SIP: • Draft developed 10/2002 to 3/2003 • Draft submitted 3/11/03 • Now open for general comment/review • Model TIP: • Draft underway, est. completion 5/2003

6. Post Model SIP work • Model SIP follow up - address any outstanding issues, assist other states in preparing 309 SIPs. • Assist Rosanne in completing Model TIP. • Coordination with TSD Project.

7. “Guiding Principles”for Model SIP/TIP development • Needs to be both a “working template” and a “how to” guide for writing a 309 SIP/TIP. • Reference all technical work in the TSD, & where to incorporate it in SIP/TIP. • Reference & summarize all applicable WRAP Policies & Guidance developed for Sec. 309. • Explain how TSD and WRAP Policies will be used by states/tribes to meet Sec. 309 rule requirements. • Meet EPA criteria for SIP/TIP approvability.

8. Development of Model SIP • Nov 2003. STIP Working Group members identified. EPA role expanded to include Regions 6, 8, 9 and 10. • Held four STIP Working Group conference calls Dec 2002 – March 2003. • Jan 2003. EPA comments required expanding scope of Model SIP to make it more comprehensive, and address EPA concerns for SIP approvability.

9. Model SIP Table of Contents • Exec. Summary – describes Model SIP, Model TIP, & TSD project. • Background – Clean Air Act, GCVTC Recommendations, & WRAP overview. • 12 Chapters – for each 309 Rule Requirement. • Master List of Appendices from each chapter, list of RHR definitions, & EPA Completeness Criteria for SIPs.

10. Model SIP Chapters • Projection of Visibility Improvement • Clean Air Corridors • Stationary Sources • Mobile Sources • Fire Programs • Paved & Unpaved Road Dust • Pollution Prevention • Additional GCVTC Recommendations • Periodic Implementation Plan Revisions • State Planning/Interstate Coordination & Tribal Implementation • Geographic Enhancements • Reasonable Progress for Additional Class I Areas

11. Model SIP Chapters/Sections Each Chapter contains four sections: • Actual 309 Regulatory Language. • General description of rule requirement, and how state intends to meet the rule. • Recommended SIP Template language. • Summary of all applicable WRAP technical reports (TSD) and Policies/Documents.

12. Geographic Enhancements • Regulatory Language • 51.309(f)(4) Geographic Enhancement. In accordance with the provisions under paragraph (f)(1) of this section, the annex may include a geographic enhancement to the program provided for in paragraph (d)(4) of this section to address the requirement under § 51.302(c) related to Best Available Retrofit Technology for reasonably attributable impairment from the pollutants covered by the milestones or the backstop market trading program. • General Discussion of Rule Requirement • The requirements for geographic enhancement are discussed on page 35757 in the Preamble to the RHR. These requirements are related to Section 51.309(f)(1) which describe requirements for the Annex. The Annex allows states to submit a SIP, or tribes a TIP, which adopts an alternative measure to regional haze BART. Geographic enhancement is a voluntary approach that can be included in the Annex for addressing reasonably attributable (RA) BART for stationary sources, under the provisions of Section 51.302(c). RA BART is different from regional haze BART, • Template Language • Geographic Enhancement. • Procedure for addressing Reasonably Attributable BART under the Regional Haze Rule. Pursuant to 40 CFR 51.309(f)(4), the State of [name] shall rely upon the geographic enhancement provisions contained in the Annex for the purposes of addressing reasonably attributable impairment in any Class I area, and the need for Best Available Retrofit Technology, as specified in 40 CFR § 302(c). • 4. Applicable WRAP Reports and Documents • The WRAP Market Trading Forum has developed a Memorandum of Agreement (MOA) between federal land managers and states to address reasonably attributable BART. PLACEHOLDER – MOA still being developed, will provide further description when completed. Example of Model SIP Chapter

13. Section 3 Template Language • Legal ref: “Pursuant to 40 CFR 51.309(f)(4)” • “The State of [name] shall…” • Template section identifies & summarizes all control strategies, SIP commitments and implementation schedules. • Extensive use of appendices – detailed information goes into an appendix (22 references to SIP appendices) • “Master List of Appendices” in back of document, summarizes what information needs to be in each SIP appendix.

14. Review of Model SIP Draft • Draft submitted 3/11/2003. • “Placeholder” in Mobile Source chapter tied to outcome of “significance issue”. • Draft distributed to selected WRAP Forum and Committee members based on their area of expertise. • Focus of review on most important sections: Stationary Source chapter, Fire chapter, & Master List of Appendices. • EPA comments expected by mid-April.

15. Questions?