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Summary of RH-LTS Requirements 51.308(d)(3)

Summary of RH-LTS Requirements 51.308(d)(3). Presentation to the WRAP Implementation Work Group Denver, CO August 30, 2007 Ray Mohr Colo. Dept. Public Health & Environment August 30, 2007. Long Term Strategy.

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Summary of RH-LTS Requirements 51.308(d)(3)

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  1. Summary of RH-LTS Requirements 51.308(d)(3) Presentation to the WRAP Implementation Work Group Denver, CO August 30, 2007 Ray Mohr Colo. Dept. Public Health & Environment August 30, 2007

  2. Long Term Strategy Those portions of the Visibility SIP which are the state’s long-term (first planning period) strategies for making reasonable progress toward the National Goal established in the Clean Air Act by Congress by remedying existing and preventing future impairment in Class I areas.

  3. Long Term Strategy Submittal Closes the Loop – Coordination of Phase I and RH SIPs • Review and update of Phase I Visibility SIP • Regional Haze SIP addresses 308 (d) (and (e)) requirements

  4. Phase I SIP Update and Revision • Included as Appendices to Colorado RH SIP • Addresses all Phase I requirements including RAVI and smoke management

  5. Regional Haze LTS Requirements • Addresses Rule requirements (consultation, meets RP show and how the Rule factors were addressed • Addresses the seven factors relating to 308 Rule requirements including smoke management, construction and BART • Reasonable Progress Goal portion of LTS is a state-only component (the 7th factor) and will be addressed in later submittals

  6. The 308 LTS Factors 1. Emission reductions from ongoing programs 2. Additional emission limitations and and compliance schedules 3. Source retirement and replacement schedules 4. Smoke management techniques 5. Measures to mitigate impacts from construction 6. Enforceability of emission limitations 7. Anticipated net effect of on visibility due to projected changes in emissions

  7. Smoke Management Plan addresses open burning, prescribed fire, permitting and wildfire 1. See State Regulation No. 9 for detailed program description 2. See Colorado Natural Events Action Plan for Wildfire Smoke 3. Public information and advisories

  8. Measures to mitigate impacts from Construction activities 1. Existing State Regulations Nos. 1 and 3 provide detailed program description 2. Emissions impact analysis indicates current control program is likely sufficient

  9. Regional Haze SIP - Chapter Overview • Chapter 1 Overview • Chapter 2 Plan Development and Consultation • Chapter 3 Monitoring Strategy • Chapter 4 Baseline and Natural Conditions and Uniform Progress for each Class I Area • Chapter 5 Sources of Impairment in Colorado • Chapter 6 Best Available Retrofit Technology • Chapter 7 Visibility Modeling and Apportionment • Chapter 8 Reasonable Progress Goals • Chapter 9 Long Term Strategy • Chapter 10 Commitment to Consultation, Progress Reports, Evaluations of Plan Adequacy and Future SIP Revisions • Chapter 11 Guidance, Resources and References:

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