2018 Regional Haze SIP Planning

Transcription

1 MARAMA SIP Training Course and Workshop February Gettysburg, PA 2018 Regional Haze SIP Planning Joseph Jakuta Ozone Transport Commission

2 Regional Haze Background CAA 169A &169B provide framework for visibility protection/improvement for 156 mandatory Class I Areas Regulations primarily found at 40 CFR 51 Goal: Return to natural visibility conditions (no anthropogenic impairment) by 2064 Pollutants of concern Primarily SO 2, NO X, and PM VOC and ammonia on a case by case basis Tracking metric is the deciview 2

3 Regional Haze SIP Schedule RH SIPs covering first 10-year plan were due from every state in 2007 Original deadline for second 10-year plan was 2018 EPA revised rule to extend deadline to 2021 MANE-VU states striving to meet 2018 deadline Costs higher if must redo analysis for

4 Regional Haze Update Rule updating regional haze regulations published January 5, 2017 Due to its nature as regulatory relief, went into effect immediately Uncertainties Congressional Review Act Texas initiated a request for reconsideration with DC Circuit which at this point has not been resolved Draft Guidance Unclear as to when it will be finalized

5 6 Elements of Haze SIPs 1. Baseline/Natural Conditions: Class I states (51.308(f)(1)) 2. Long Term Strategy: All states (51.308(f)(2)) 3. Reasonable Progress Goals: Class I states (51.308(f)(3)) 4. Progress Report Inclusion: All states (51.308(f)(5)) 5. Monitoring/Inventory: Class I states/all states (51.308(f))(4)&(6)) 6. FLM Consultation: All states (51.308(h)(2)) Note Best Available Retrofit Technology (BART) is not a part of this SIP

6 IMPROVE Data Analysis Class I states must calculate current visibility conditions With most recent 5-year period for which data are available (51.308(f)(1)(iii)) Show how close Class I is to natural conditions (51.308(f)(v)) 2017 Haze Rule Update Must rely on 20% most impaired days rather than 20% worst days, though final guidance is pending (51.308(f)(1)(i-ii)) Must recalculating baseline ( ) and natural conditions (2064) from last planning period No longer need to specifically evaluate whether improvements have been made to data collection and processing Winter Spring Summer Fall Sulfate Ext Nitrate Ext Organic Carbon Ext Elemental Carbon Ext Coarse Mas Ext Soil Ext Sea Salt Ext Rayleigh Ext

7 Inventory Development & Analysis Inventories serve 3 purposes in SIPs Provide statewide inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I Federal area (51.308(f)(6)(v)) Basis for developing Long Term Strategy and modeling Reasonable Progress Goals (f)(3) Basis for documenting emissions trends (51.308(g)(4)-(5)) Thousands Tons/Year Aircraft/GSE CMV/Rail NONROAD Small EGU NonEGU ERTAC EGU Onroad Nonpoint

8 Long Term Strategy (LTS) Development States must submit a LTS addressing impairment In Class I Areas in the state In Class I Areas that may be affected by emissions from the State (51.308(f)(2)) LTS must include: Enforceable emissions limitations, Compliance schedules, and Other measures that are necessary to make reasonable progress (51.308(f)(2)) All states must consider the 4-Factors (discussed later)

9 LTS Development (cntd.) States must consult with upwind states that are reasonably anticipated to contribute to visibility impairment in the mandatory Class I Federal area (51.308(f)(2)(ii)) States must also consider: Reductions due to ongoing air pollution control programs, including measures to address reasonably attributable visibility impairment Measures to mitigate the impacts of construction activities Source retirement /replacement schedules Smoke management techniques Anticipated effect on visibility due to projected changes in emissions (51.308(f))(2)(iv))

10 4-Factor Analysis 4-Factor Analysis must consider 1. Costs of compliance 2. Time necessary for compliance 3. Energy and non air quality environmental impacts 4. Remaining useful life of affected sources (51.308(f)(2)(i)) States should consider evaluating Major and minor stationary sources or groups of sources Mobile sources Area sources

11 Contribution Assessment Need to determine which sources and states are reasonably anticipated to contribute No specific requirements in the Regional Haze rule Draft guidance recommends quite expansive approaches

12 Updating Reasonable Progress Goals (RPGs) Class I States must adopt RPGs that Consider Long Term Strategies of Class I and Upwind States, modeled for future year Provide for improvement on most impaired days and no degradation for the least impaired days (51.308(f)(3)(i)) If above the Uniform Rate of Progress (URP) is justified (51.308(f)(3)(ii)(A)) Haze Index (deciviews) RPG/URP Example Uniform Rate of Progress RPG - 20% Worst Days Haze Index, 5-Year Rolling - 20% Worst Days Year

13 Consultation (cntd) Class I State and Contributing State Class I states must consult with upwind states before setting Reasonable Progress Goals Ask for additional controls Managed between Regional Planning Organizations (RPOs)

14 Consultation Every State and Federal Land Managers (FLMs) National Park, Forest, and Fish and Wildlife Services FLMs must be provided opportunity for in-person consultation during development of LTS (51.308(i)(2)) Not necessarily in-person, if FLMs agree CAA requirement (not just regulatory) Occurs at least 60 days prior to holding public hearing Includes: Assessment of impairment of visibility on Class I Federal areas (51.308(i)(2)(i)) Recommendations on RPGs and strategies (51.308(i)(2)(ii)) SIP must include a description of the consultation and provide procedures for continued consultation (51.308(i)(3-4))

15 Comments/Questions? 15