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Update on Regional Haze. November 15, 2012 Michele Notarianni EPA Region 4. Overview of Regional Haze Provisions. Clean Air Act: Requires visibility protection for Federal Class I Areas (e.g., national parks and wilderness areas)
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Update on Regional Haze November 15, 2012 Michele Notarianni EPA Region 4
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)
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.
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.
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
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…..
*Tips for R4 Progress Report SIPs TIPs = 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.
*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.
*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.
*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.
*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).
*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.
*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.
*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/