Proposed Reasonable Progress Rule Workshop

1. Proposed Reasonable Progress Rule Workshop Second Public Workshop August 1, 2007 Tallahassee, Florida

2. Comments From 1st Workshop • Extend the permit application deadline (April 30, 2008, Dec 31, 2008) • Extended to September 30, 2008 • Change the compliance deadline date (Dec 31, 2017) • Extended to December 31, 2014 • Increase significant contribution threshold (1%) • Considered, developed new criteria • Allow consideration of visibility impact • Changed rule language to reflect visibility impact analysis not required

3. Comments From 1st Workshop (cont.) • Take out the “responsibility to comply” applicability statement • Retained – makes sense with new selection criteria • Produce area of influence document • Document no longer necessary with new selection criteria • “Reasonable progress” already made, no additional reductions needed • Reasonable progress only determined after four-factor analysis – state cannot bypass this requirement

4. Comments From 1st Workshop (cont.) • Provide justification for selection of various thresholds or cutpoints • Provided at this workshop • Change BART-equivalent determination submittal application deadline to coincide with the RP application • Extended deadline to June 30, 2008 – still does not coincide with application

5. Jun 14 Proposed Selection Criteria • Selection based on modified Georgia criteria with RTmax*Q/d: • VISTAS residence time data (within 5% for EGU’s and 10% non-EGU’s) • 2002 actual emissions (units > 250 tpy) • >= 0.5% unit contribution, considering only Florida units • Selection based on each Class I area potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

6. Considered Changes to Selection Based on Comments • Increase contribution threshold from 0.5% to 1% • Include units in all states to determine contribution • Take out EGU/non-EGU selection criterion based on RTMax • See handout for results

7. Considerations for Changing to a Q/d Selection Criteria • The inclusion of residence time (RTMax), while logical, is somewhat complicated, and when used with Q/d to develop a relative contribution surrogate at each Class I area, results in some seemingly illogical conclusions. • The use of Q/d alone as a surrogate for visibility impact is easy to understand and produces a similar selection of sources as does a Q/d*RTMax relative contribution criterion.

8. Proposed New Selection Criteria • All SO2 units having >= 250 tpy (2002 actual) and having an emissions Q (tons) to distance d (km) ratio of 50 or greater. • Selection based on each Class I area potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

9. Why Q/d >= 50? • Selection of sources close to those under the 1% Q/d*RTMax criteria. • Q/d of 50 is five times the exemption threshold used for BART. Provides that sources selected are important contributors to visibility impairment. • Recognize that visibility improvement at the Class I areas in or near Florida is projected to be near the uniform rate of progress, thus justifying selection of only the largest sources for four-factor review.

10. Sources Selected Under the Q/d Criteria

11. Sources Selected Under the Q/d Criteria

13. Comparison of Selection Criteria

14. Some Statistics • The 15 facilities included comprise ~⅔ of the total stationary point source SO2 emissions that occurred in 2002. • In rank order, these 15 facilities comprise the 1,2,3,4,5,6,7,8,9,15,18,19,26, and 30 largest facilities in the state as of 2002.