1 Brian Finneran, Oregon DEQ WRAP IWG Meeting, Portland August 2006 Suggested Changes to IWG Section 308 SIP Template

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Brian Finneran, Oregon DEQWRAP IWG Meeting, Portland

August 2006

Suggested Changes to IWG Section 308

SIP Template

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IWG 308 SIP TEMPLATEOutline of Most Recent Version

1. Introduction

2. Background and Regional Haze SIP Requirements – Historical and Statutory Overview Visibility Provisions in 1977 Clean Air Act (CAA 169A) EPA Visibility Protection Regulations Clean Air Act Amendments of 1990 Current <State> Long-Term Strategy Code of Federal Regulations 308/309 - 1999 Regional Haze Rule

3. <State> Regional Haze SIP Development Process Federal Land Manager Consultation

4. Visibility Monitoring and Impairment in Class I Areas – Overview of IMPROVE monitoring program in <state> Class I areas Visibility Impairment Characteristics in <State> Class I Areas

5. Visibility Impairment in <State> Class I Areas Natural Sources of Visibility Impairment Anthropogenic Sources of Visibility Impairment

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IWG 308 SIP TEMPLATEOutline

6. Establishing the plan baseline conditions – baseline and natural conditions, presumptive RPGs for 20% best/worst average days Baseline Conditions Natural Conditions Establishing Presumptive Reasonable Progress Goals

7. Emission Inventory – 2002 Baseline & 2018 Projections Regional Emission Inventories <State> Emission Inventories Local Emission Inventories Regional Modeling Preliminary Assessment of Presumptive RP at Class I Areas

8. Best Available Retrofit Technology (or a superior alternative) Description of <State> BART Rule and Schedule Visibility Improvement Resulting from BART in <State> + Other States

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IWG 308 SIP TEMPLATEOutline

9. Additional Measures (Long Term Strategy) Emission Reductions Due to Ongoing Air Pollution Programs Measures to Mitigate the Impacts of Construction Activities Emission Limitations and Schedules of Compliance Source Retirement and Replacement Schedules Agricultural and forestry smoke management Enforceability of emission limitations and control measures

10. Net Effects Resulting from Projected Emission Changes11. Projection of 2018 Visibility Conditions from 2002 Base Case &

Additional Strategies (BART & Others) Affirmative Demonstration of Presumptive Reasonable Progress

Goals12. State and Tribe Consultation13. <State> Share of Emission ReductionsAdditional SIP Requirements & Future Planning Period RequirementsList of Appendices and Technical Support Documentation (EDMS &

TSS)

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Oregon Suggested Format for 308 SIP TEMPLATE

1. Introduction

2. Oregon Regional Haze SIP Development Process

3. Introduction to Oregon Class I Areas

4. Regional Haze Monitoring

5. Visibility Sources and Conditions

6. Oregon Current Visibility Conditions

7. Oregon Visibility Impairment Analysis

8. Emission Inventory

9. Long-Term Strategy

10. Best Available Retrofit Technology (BART) Evaluation

11. Reasonable Progress Goal Demonstration

12. Misc. other SIP commitments

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Chapter Comparison of IWG SIP TEMPLATE to Oregon Version

1. Introduction – short section

2. Background and RH SIP Requirements

3. <State> RH SIP Development Process – FLM + state/tribe consultation

4. Visibility Monitoring and Impairment – IMPROVE monitoring – network description and 20% worst day monitoring data

1. Introduction – IWG #2 Background added here, and expanded

2. Oregon RH SIP Development Process - same as IWG #3, but added adv committee and public & stakeholder outreach

3. Introduction to Oregon Class I Areas – basic info on each Class I area (location, size etc)

4. Regional Haze Monitoring – no data here – just IMPROVE network description

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5. Visibility Impairment – short section, generic definition of natural/anthro sources

6. Estimates of Baseline/Natural conditions, RPGs for 20% best/worst days

Note: no in-depth analysis of Class I area haze conditions in IWG SIP Template

5. Visibility Sources and Conditions – same as IWG#5, but added defs of baseline, nat’l conditions, URP, and RPG

6. Oregon Current Visibility Conditions – review of all monitoring data showing current conditions

7. Oregon Visibility Impairment Analysis – Aerosol composition, species trends, monthly distribution, – similar to n draft CO SIP


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7. Emission Inventory – 2002 Baseline & 2018 Projections – local, state and regional EI, regional modeling results, and preliminary assessment of RP

8. BART (or a superior alternative) – results of BART analysis

9. Additional Measures (Long Term Strategy) – very short summary of LTS, no explanation of “additional measures” ??

8. Emission Inventory – similar to IWG#7 + more EI data and maps similar to draft CO SIP section

9. Long-Term Strategy – similar to IWG #9, more description of LTS, adds summary of interstate transport and anthro sources (follows RHR Sec.308 language)

10. Best Available Retrofit Technology (BART) Evaluation – similar to IWG #8


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10. Net Effects Resulting from Projected Emission Changes – short section on visibility benefits from emission changes in 2018 (??)

11. Projection of 2018 Visibility Conditions from 2002 Base Case & Additional Strategies (BART & Others) – very short, affirmative demonstration of RPGs

11. Reasonable Progress Goal Demonstration – major section – needs to show improvement from all RH haze strategies in comparison to the glide path, analysis if whether additional controls are needed, and affirmative demonstration of RPGs


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Oregon Version of 308 SIP TEMPLATE

1. IntroductionHistory and Background of RHR, purpose of SIP, definitions

Overview of Visibility and Regional Haze Oregon Class I Areas (list) Summary of Section 308 and 309 of the Regional Haze Rule Background on the Regional Haze Rule Phase I Visibility Rules – the Oregon Visibility Protection Plan The 1990 Clean Air Act Amendments Submittal of the 2003 Oregon 309 SIP Purpose of this Document Definitions and Acronyms contained in this plan

2. Oregon Regional Haze SIP Development ProcessGeneral description of the consultation process and public involvement

Federal Land Manager Consultation State and Tribal Consultation Advisory Committee Involvement Public and Stakeholder Outreach

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3. Introduction to Oregon Class I AreasGeneral introduction and description of each Class I area4. Regional Haze MonitoringDescription of monitoring strategy and summary of IMPROVE network

Overview of Oregon Regional Haze Monitoring Strategy IMPROVE site locations in Oregon

5. Visibility Sources and ConditionsSummary of basic elements of the SIP, review of key terminology.

Anthropogenic Sources of Visibility Impairment Baseline Conditions Natural Sources of Visibility Impairment Natural Conditions Uniform Rate of Progress Reasonable Progress Goal

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6. Oregon Current Visibility ConditionsSummary of monitoring data that shows current conditions7. Oregon Visibility Impairment AnalysisSummary of monitoring data that shows impairment – aerosol composition, species trends, presumptive GP, URP8. Emission Inventory Summary of all emissions data

Regional Emission Maps Oregon Emissions by Source Category Local (Nearby) Emissions for Each Class I Area by Source

Category Comparison to the URP for 2018 Back Trajectory Maps

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9. Long-Term Strategy Overview of the LTS Summary of Interstate Transport and Contribution Other State Class I Areas affected by Oregon emissions Oregon Class I Areas affected by Other States Estimated International Contribution to Oregon Class I Areas Estimated Non-Anthropogenic Sources and their contribution to

Oregon Class I Areas Summary of all Anthropogenic Sources of Visibility Impairment

considered in developing the LTS Emission Reductions Due to Ongoing Air Pollution Programs Measures to Mitigate the Impacts of Construction Activities Source Retirement and Replacement Schedules Agricultural and Forestry smoke management techniques Emission Limitations and Schedules of Compliance Net Effect on Visibility from the LTS Emission Reductions from point, area, and mobile sources Projection of 2018 Visibility Conditions from 2002 Base Case

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10. Best Available Retrofit Technology (BART) EvaluationSummary of BART process, modeling, and control evaluation results

Oregon BART-eligible sources Summary of BART Modeling Results Summary of BART Control Analysis Visibility Improvement Resulting from BART Evaluation in Oregon and

Other States11. Reasonable Progress Goal DemonstrationComparison of all haze strategies (chapters 9 & 10) to glide path, analysis if add’l controls are needed & affirmative RFG demonstration

Projected 2018 Visibility Conditions - Base Case vs. Control Case Scenarios

Review of Visibility Improvement from combination of BART modeling and regional modeling results.

Weight of Evidence Analysis Summary for each Class I area Comparison of RPG to the URP for each Class I area Assessment if Additional Controls Measures are needed Affirmative Demonstration of Reasonable Progress

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12. ConsultationSimilar to Chapter 2, but provides more info, such as consistency with other state SIPs and TIPs, details of consultation with FLMs

Other State Consultation Consistency with Neighboring State SIPs Oregon and Neighboring State Emission Reduction Obligations Tribal Consultation Federal Land Manager Consultation

13. Enforceability of Emission Limitations and Control Measures14. Commitment to Future SIP Revisions15. Commitment to Periodic Progress Reports16. Determination of Plan Adequacy17. Public Participation and Review Process 18. List of Appendices and Technical Support Documentation (EDMS & TSS)

Documents

1 Brian Finneran, Oregon DEQ WRAP IWG Meeting, Portland August 2006 Suggested Changes to IWG Section 308 SIP Template